Category: Uncategorized

Program Guidebook Update – Request for Stakeholder Comment

A draft updated Adjustable Block Program Guidebook has been released for stakeholder feedback. The draft updated Program Guidebook and a redlined document showing changes from the May 31, 2019 version can be found here . As detailed in Section 9 of the current Program Guidebook, the Program Administrator is requesting comments on the changes in this draft version of the Program Guidebook. In lieu of hosting a webinar to discuss any changes made to this version of the Guidebook, the IPA and its Program Administrator are happy to provide answers to any questions or otherwise receive less formal input or feedback outside of the formal comment process, if necessary.

Stakeholders should email comments to admin@illinoisabp.com by Friday, August 21st. In general, responses will be made public and published on the ABP’s website (https://illinoisabp.com/). However, should a commenter seek to designate any portion of its response as confidential, that commenter should provide both public and redacted versions of their comments. The Program Administrator has provided a Word document version of the draft Program Guidebook in the case that stakeholders wish to edit the document directly and send an edited version of this document to the Program Administrator.

Key changes in this draft version of the Program Guidebook include, among others:

  • Updates to conform with the Revised Long-Term Renewable Resources Plan
  • Information on Designee Registration
  • Clarification on the Program’s disciplinary process
  • Removal of stale sections that are no longer relevant to the Program as it exists today

Updated COVID-19 Related Marketing Guidelines – August 5, 2020

On March 20, 2020, in light of the growing COVID-19 pandemic and its expected impacts in Illinois, the Illinois Power Agency adopted the following emergency amendment to its Adjustable Block Program and Illinois Solar for All Program Marketing Guidelines:

In-person marketing and solicitation: Given the public health emergency posed by the COVID-19 virus, in-person marketing or solicitation of photovoltaic system sales, installations, or financing; in-person marketing or solicitation of community solar subscriptions; or similar in-person solar marketing or solicitation activity are prohibited.

Clarifications to these requirements were offered on May 19, 2020, along with additional guidance and updates on June 4, 2020 and June 30, 2020.

This update once again confirms that the IPA’s prohibition of door-to-door sales and solicitation remains in place.  While Illinois is perhaps better situated than neighboring states, recent weeks have seen the Illinois statewide COVID-19 positivity rate (the percentage of positive tests across total tests given) creep upward from 2.6% to 4.0%.  This is a troubling trend, and Illinois has since been added to the New York/New Jersey/Connecticut joint quarantine list.  Additionally, as was the case in its prior updates, the Illinois Commerce Commission’s emergency order prohibiting door to door sales by Alternative Retail Electric Suppliers and Alternative Gas Suppliers likewise remains in place, and the state remains under a Gubernatorial Disaster Declaration.

For the foregoing reasons and those offered in its prior updates, the Agency believes this would be an inappropriate time to start permitting in-person interactions initiated without a customer, homeowner, or business owner’s express permission.  This prohibition will remain in effect until lifted by the IPA through a formal announcement, although the IPA will endeavor to continue providing updates.  Additionally, prior-issued guidance regarding best practices and permitted activities remains in effect.  Should you have questions about whether specific practices are permitted, please contact IPA Chief Legal Counsel Brian Granahan at Brian.Granahan@Illinois.gov.

Draft REC Contract Workshop #1

On July 31, the Illinois Power Agency, in conjunction with NERA Economic Consulting and the Adjustable Block Program Administrator, InClime, held the first of two online workshops to discuss the Draft REC contract that was posted on July 24th, alongside a request for stakeholder comments. The webinar can be viewed below, and the PowerPoint presentation shown in the webinar can be viewed by clicking here.

 

 

Final Requirements Posted – Job Training & Workforce Diversity Reporting Requirements

The Adjustable Block Program Administrator would like to thank all stakeholders that provided comments on the recent request for comments about the collection of job training and workforce diversity reporting requirements for the ABP Approved Vendor annual report.

Four stakeholders submitted comments in response to this request for feedback. The Illinois Power Agency has reviewed these stakeholder comments and finalized the requirements for job training and workforce diversity data .

The Program Administrator will provide more information about how to submit job training and workforce diversity data in the Approved Vendor portal in the coming weeks.

Stakeholder Comments – Job Training & Workforce Diversity Reporting Requirements

The Illinois Power Agency published a request for stakeholder feedback regarding Job Training & Workforce Diversity reporting requirements in June, 2020. The deadline for submitting comments was extended to July 2, 2020. The stakeholder comments regarding Job Training & Solar Workforce Diversity reporting requirements are posted below:

The Adjustable Block Program Administrator would like to thank all stakeholders that provided comments on the request for stakeholder feedback regarding Job Training & Workforce Diversity Reporting requirements.

Change to ABP Metering Requirements

The metering requirements for Adjustable Block Program projects have been updated as described in Section 6.12.2 of the IPA’s Revised Long-Term Plan. Previously, all systems registered in M-RETS were required to utilize an ANSI C.12 certified revenue grade meter regardless of system size. M-RETS has updated their operating rules to no longer require revenue grade meters and therefore the ABP metering requirements now reflect that change.

Systems registered in M-RETS now follow the same ABP metering requirements as applies to systems registered in GATS, which are as follows:

  • Systems over 25 kW must utilize a new meter that meets ANSI C.12 standards.
  • Systems over 10 kW and less than 25 kW in size must utilize a meter that meets ANSI C.12 standards. Meters that are refurbished (and certified by the meter supplier) are allowed.
  • Systems of 10 kW in size and below must utilize either a meter that is accurate to +/‐ 5% (including refurbished and certified meters), or an inverter that is specified by the manufacturer to be accurate to +/‐5%. The inverter must be UL‐certified and must include either a digital or web‐based output display.

Please contact the Program Administrator at admin@illinoisabp.com or (877) 783-1820 with any questions.

Approved Vendor Annual Report Training Material

Section 6.17 of the Revised Long-Term Plan describes an Annual Report requirement for each Approved Vendor:

On an annual basis, each Approved Vendor is required to submit an Annual Report of the contracts and systems in its portfolio. The Annual Report serves as the basis for verifying that RECs from projects are being delivered to the applicable utility, and, absent corrective actions taken by the Approved Vendor, will be used to determine what actions should be taken by the utilities to enforce the contractual requirements that RECs are delivered, including, but not limited to, drawing on collateral. Additionally, the Annual Report will be used by the Agency to consider the ongoing eligibility of an Approved Vendor to continue participation in the program.

The Program Administrator has created training material to assist Approved Vendors in completing the Annual Report. The training material can be accessed here.

Please reach out to the Program Administrator at (877) 783-1820 or admin@illinoisabp.com with any questions regarding the annual reporting process.

Approved Vendor Annual Report – Due July 15

Section 6.17 of the Revised Long-Term Plan describes an annual report requirement for each Approved Vendor:

On an annual basis, each Approved Vendor is required submit an Annual Report of the contracts and systems in its portfolio. The Annual Report serves as the basis for verifying that RECs from projects are being delivered to the applicable utility, and, absent corrective actions taken by the Approved Vendor, will be used to determine what actions should be taken by the utilities to enforce the contractual requirements that RECs are delivered, including, but not limited to, drawing on collateral. Additionally, the Annual Report will be used by the Agency to consider the ongoing eligibility of an Approved Vendor to continue participation in the program.

Submission of the annual report takes place via the ABP portal and is now live.

Approved Vendors are required to submit the annual report no later than July 15, 2020 for all ABP activity from January 30, 2019 (Program start date) through May 31, 2020.

Please note that failure to submit an annual report may be considered an Event of Default under the REC contract and could affect an Approved Vendor’s ongoing status in the Program.  Approved Vendors will have the chance to cure deficiencies by October 13, 2020 under Section 10(c) of the REC contract; failure to cure any deficiencies prior to the October 13th deadline may also be considered an Event of Default.

Please note that per Section 6(d) of the REC contract, collateral drawdowns take place only after a project has been Energized for at least three full energy years.

The annual report includes the following items for all projects:

  • RECs delivered by each of the systems in the portfolio
  • Status of all systems that have been approved, but not yet energized, including any extensions requested and granted (Note that extension requests cannot be made through this annual report. They must be made pursuant to guidance issued by the IPA on May 5, 2020.)
  • Energized systems that have not delivered RECs in the year
  • Balance of collateral held by each utility
  • A summary of requests for REC obligations reductions due to force majeure events
  • A summary of requests for REC obligations, suspensions, reductions, or eliminations due to force majeure events
  • Information on consumer complaints received
  • Other information related to ongoing program participation, including use of graduates of job training programs and other information related to increasing the diversity of the solar workforce

The last item above is currently the topic of a stakeholder comment process; as a result, job training information likely will be collected separately from the rest of the annual report data after the stakeholder comment process concludes.

The annual report also includes the following items for community solar projects only:

  • Percentage of each system subscribed on a capacity basis
  • The number and type of subscribers (e.g., residential, small commercial, large commercial/industrial), including capacity allocated to each type
  • Subscriber turn-over rates

Rather than require the Approved Vendor to compile much of the information for the Annual Report independently, many of the items Approved Vendors are required to report on will be provided by the Program Administrator. For these items, the Approved Vendor will only need to either confirm the accuracy of the data or note any discrepancies in the data set provided.

Please reach out to the Program Administrator at (877) 783-1820 or admin@illinoisabp.com with any questions regarding the annual reporting process.

Response to Comments: ABP Batching Process

The Agency would like to thank all stakeholders that provided comments on the recent request for comments about the Adjustable Block Program’s application batching process. Four stakeholders provided comments and the comments did not offer a consensus opinion. Below is the IPA’s proposed approach after reviewing this feedback.

PRIOR BATCHING PROCESS

Under the original Long-Term Renewable Resources Procurement Plan (approved by the Illinois Commerce Commission in 2018 in Docket No. 17-0838), all batches that an Approved Vendor submits to the Program Administrator were required to be at least 100kW (with a 50 kW first batch exception for women- and minority-owned firms, and upon application for small businesses) and no greater than 2 MW in size. At least 75% of the capacity of each batch must be Part I verified for the batch to be eligible to be submitted to the ICC for the Commission’s review and approval.

The Program Administrator submits batches to the ICC at least eight business days prior to a scheduled ICC meeting (ICC meeting schedule is here).  The ICC votes to approve batches at that meeting, with each approved batch constituting a new REC delivery contract or a new Product Order to an existing REC contract once executed by each party.

NEW BATCHING PROCESS

Many aspects of the new batching process remain the same as the prior batching process:

  • Batches of photovoltaic project applications are still submitted by Approved Vendors to the Program Administrator for its review and verification;
  • Application fees are still due from those Approved Vendors upon submittal of a batch of project applications;
  • After Program Administrator review and verification of projects, batches are still sent by the Program Administrator to the ICC for its approval on the same 8-business day timetable;
  • Each ICC-approved batch constitutes a Product Order attached to the REC delivery contract.

However, under Section 6.14.1 of the IPA’s Long-Term Renewable Resources Procurement Plan (approved by the Illinois Commerce Commission in 2020 in Docket No. 19-0838), project applications may now be processed on a rolling basis under circumstances as described below.[1]

  • If an Approved Vendor does not wish to actively manage the batching of its applications, then batches of Part I verified applications that are at least 100 kW in batch size will be automatically submitted by the Program Administrator to the ICC for approval.
  • On a rolling basis, the Program Administrator may also submit additional verified project applications from that Approved Vendor to the ICC for approval, whether as an add-on to an existing batch or as an independent batch (with all verified applications being batched together into standalone batches of no more than 2MW of capacity). Those applications processed on a rolling basis may constitute a batch of less than 100 kW in size.
  • If an Approved Vendor does wish to actively manage the batching of its applications, then it may elect to “rebatch” its verified project applications—including keeping individual verified applications from being submitted by the Program Administrator to the ICC on a rolling basis after verification.
  • Batches actively managed and shaped at the Approved Vendor’s direction must be at least 100 kW in size to be submitted to the ICC for approval.
  • For this election, four business days prior to the Program Administrator’s date of submission to the ICC (with that four-business-days-prior referred to herein as the “Eligibility Deadline”), the Program Administrator will provide Approved Vendors with a list of all applications that have been Part I verified prior to the Eligibility Deadline.
  • Approved Vendors may take one or both of the following elections on a new page in the Approved Vendor portal. Any of these elections that the Approved Vendor chooses to make must be completed no later than 12:00 PM Central Prevailing Time two business days prior to the Program Administrator’s submission date (the “Election Deadline”).:
  • Completely “rebatch” these Part I verified applications into batches of at least 100kW and no more than 2MW, with the content of that batch or those batches determined at the Approved Vendor’s discretion.
  • Hold back any individual verified applications from submission to the ICC.
    1. Approved Vendors may make the election to hold back a Part I verified application from submission to the ICC no more than twice for any given project application.
    2. After the second election, that application may no longer be held back and will be placed into a batch and submitted to the ICC for approval on a rolling basis.
  • After the Election Deadline has passed, should an Approved Vendor take one or more of the above elections and still have batches containing less than 100 kW of Part I verified projects the Program Administrator will use its discretion to make batching decisions for those projects on behalf of the Approved Vendor prior to the Program Administrator submitting batches to the ICC.

Example:

The ICC is scheduled to meet on Wednesday, July 29, 2020. The Program Administrator must submit batches to the ICC for consideration no later than Friday, July 17, 2020. Approved Vendors will be notified of their eligible Part I verified applications on Monday, July 13, 2020. Approved Vendors may completely rebatch these applications into batches of at least 100kW and/or elect to hold back any of these applications no later than Wednesday, July 15, 2020 at 12:00 PM Central Prevailing Time. Any Part I verified applications that are not a) in a batch of at least 100kW or b) held back from submission to the ICC may either be placed into a new or existing batch or held back from submission to the ICC at the discretion of the Program Administrator.

IMPLEMENTATION TIMELINE

This new batching functionality is tentatively expected to be implemented in mid-August. The Program Administrator will make a subsequent announcement once this functionality is live. No action presently is required by any Approved Vendor regarding this proposed batching process. The current interim batching process will remain in effect until such time as the Program Administrator has announced that the new batching process is implemented.

[1] Note that for a new Approved Vendor who has not yet had a batch approved by the ICC, batches submitted to the Program Administrator must be at least 100 kW in size (with at least 75% of the capacity verified for the batch to be submitted to the ICC for approval) until the ICC has approved one of the Approved Vendor’s batches. Once a batch has been approved by the ICC a new Approved Vendor may follow the process of project applications submitted on a rolling basis as described herein.