Upon opening of community solar categories for the 2022-23 program year on November 1, 2022, the Illinois Shines program saw a large number of applications submitted to the Equity Eligible Contractor (“EEC”) Category, specifically Group A, creating a substantial oversubscription for this Group/category combination without a project selection process in place.
In December 2022, the Illinois Power Agency petitioned to reopen the 2022 Long-Term Renewable Resources Procurement Plan approval proceeding before the Illinois Commerce Commission (Commission) seeking to modify the Plan to address this unanticipated oversubscription of the EEC category. The Commission granted the Agency’s request and reopened the proceeding to evaluate the Agency’s proposed modifications. On May 4, 2023, the Commission issued an Order on Reopening which modifies the EEC Category for both the 2022-23 and 2023-24 program years. Those changes are summarized below for the benefit of Program participants.
These changes have already been incorporated into a modified version of the Long-Term Renewable Resources Procurement Plan, which is linked below and available on the Program website.
These changes will be incorporated into the Program Guidebook as soon as practicable.
Material Changes to the EEC Category per the ICC’s Order
- EEC Block Size – For the 2022-23 Program year, the Group A EEC capacity has been expanded in size to accommodate all EEC applications batched and submitted on November 1. The amount of capacity for the EEC category in the 2023-24 program year will remain at the size that has been published in the Program Guidebook. At the end of the 2022-23 program year, additional uncontracted capacity from other categories will be reallocated according to the process set forth in the Program Guidebook, with uncontracted capacity first applied to the EEC waitlist from 2022-2023.
- EEC Subcategories – Beginning in the 2023-2024 program year, capacity for the EEC category will be divided into subcategories between Community Solar and Distributed Generation projects. The Community Solar EEC sub-category will receive 75% of the capacity by Group, while 25% of the capacity by Group will be reserved for DG projects. After the block has been open for nine months (i.e., March 1, 2024) any unused capacity in the DG sub-category will be available to all project types in the EEC category.
- By way of example, if the annual block of capacity for EEC Group A 10MW, for the first nine months the block is open, 7.5MW will be reserved for EEC Group A CS and 2.5MW will be reserved for EEC Group A DG. After the category has been open for nine months, the reserve of capacity for the sub-categories will end, and all remaining capacity in the block will be available to both CS and DG projects.
- Developer Cap – Beginning in the 2023-2024 delivery year, a 20% developer cap may be applied to the EEC category. This 20% developer cap will be applied across the category if capacity for an EEC sub-category in either Group A or B is oversubscribed on Day One of the program year. If none of the EEC sub-categories are oversubscribed on Day One, the developer cap will not be applied. If triggered on Day One, the 20% developer cap will be applied across the total capacity for the annual block, inclusive of capacity for all sub-categories, such that an EEC-certified Approved Vendor (and its affiliated EEC-AVs) may not be awarded REC contracts in excess of 20% of the capacity for the EEC Category for the 2023-2024 Program year.
- By way of example, if the annual block size is 100MW, and the developer cap is applied due to a sub-category’s oversubscription on Day One, all EEC-AVs will be limited to development of no more than 20MW of projects across any sub-category of the EEC block.
- Order on Reopening (Entered May 4, 2023)
- Modified Long-Term Plan (Published May 9, 2023) – This is now the operating version of the Long-Term Plan
- Redline Comparison between May 9, 2023 version and August 23, 2022 version
The Program Guidebook will be updated shortly in order to reflect these changes to the EEC category.
Per the ICC’s Order, the IPA will continue to diligently oversee the EEC category in the Illinois Shines program in order to remove barriers to participation.
Please reach out to the Program Administrator at [email protected] with any further questions on these changes.