Disclosure Forms (DFs) – When New DFs are Needed, Signatory Requirement Exceptions, and Portal Inputs

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  • When New DFs are Needed – The standard DF has been a central consumer protection requirement since Program inception The baseline requirement is that if information provided to the customer in their DF substantively changes, a new DF must be provided to and signed by the customer to ensure the customer has up-to-date and accurate information about their project. The Program Guidebook explicitly provides limited exceptions to this requirement for changes in AC size below a certain threshold. This week, a chart was published to the Program website to address several additional circumstances and whether specific changes in information contained in a Disclosure Form trigger the requirement to have the customer sign a new Disclosure Form. One entry in the chart concerns the Program requirement that when the DC size decreases by the greater of 5% or 1kW AC, a new Disclosure Form is required. The Program Administrator acknowledges some market confusion previously on this DC size decrease threshold requiring a new Disclosure Form. Accordingly, please note that the Program Administrator will require a new DF for Part I and Part II applications submitted on, or after, September 1, 2023 that meet this criteria. For Part I and Part II applications submitted prior to September 1, 2023, the Program Administrator will require entities to provide proof that the customer was aware of, and signed off on, the project size decrease. Such proof may come in the form of a new DF, a scope change document, and/or an installation contract that permits such size changes without additional customer approval.
  • DF Signatory Requirement Exceptions – As stated in Section V of the Consumer Protection Handbook, “[t]he signatory on the Disclosure Form must be the holder of the relevant utility account, or, if the account holder is a company or organization, an individual authorized to sign on behalf of the accountholder.” There are limited exceptions where the signatory on the Disclosure Form may vary from this requirement. These limited exceptions, along with clarifications on who should sign Disclosure Forms when the customer is a company or other organization, are outlined in a new document published to the Program website.
  • Portal Inputs – Average Retail Rate and Price to Compare – A new Portal Inputs document published to the Program website provides input rates utilized for Program portal calculations. The document will be updated quarterly.
    • For Distributed Generation, these include the Current Average Retail Rate (for ComEd/Ameren/MidAmerican) used to calculate the Savings Estimates for DG Disclosure Forms, and for rural electric co-ops or municipal utilities, an average statewide retail rate is used and updated annually.
    • For Community Solar, a Price to Compare is provided for the utilities.