Enforcement of Two Withhold Limit from ICC Meetings

Per the Program Guidebook, the Program allows for Approved Vendors to only withhold projects from ICC submission twice before they must be withdrawn. This policy will be strictly enforced in conjunction with the start of the 2025-26 Program Year that commences June 2, 2025, beginning with the memo submitted for the June 18, 2025 ICC meeting date. Any projects with more than two withholds at the time this memo is submitted will be put forward for ICC approval.

Please see Section C. ICC Batching and Submission Process of the 2025-26 Program Guidebook Rationale Document, published April 18, 2025, for further explanation of this policy.

When a batch is approved by the ICC, the Approved Vendor will then be required to sign the contract (or Product Order) as approved by the Commission within seven business days of receiving it. Within 30 business days of the ICC approving the contract (or Product Order), collateral constituting 5% of the value of a system’s REC Contract must be posted with the utility counterparty in the form of cash or a letter of credit from an underwriter with credit acceptable to the utility. Failure to execute a Product Order or post collateral on time may result in withdrawal of the batch and any associated projects. As a result, the Approved Vendor may face disciplinary measures impacting their status as an Approved Vendor in the Program moving forward. Please see Section 5.A of the Program Guidebook for more information.

Thank you!
Illinois Shines Program
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