Guidance on Group A Distributed Generation Capacity and Waitlists

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The Group A Small Distributed Generation and Large Distributed Generation categories have run out of available capacity for the 2023-24 Program Year. The Group A Large DG category closed on July 14, 2023 at 4:41 p.m., followed by Small DG on October 3, 2023 at 11:59 p.m. Therefore, any Part I applications batched and submitted to the Program after these blocks closed are being waitlisted, which will cause a delay in the availability of Illinois Shines incentive payments. These projects will be first in line when new capacity becomes available for the 2024-25 Program Year on June 1, 2024.

The Agency understands that the depletion of Group A capacity is causing stress and confusion in the Illinois solar market. The IPA is actively working on solutions to Group A oversubscription challenges as proposed in Section of the draft 2024 Long-Term Renewable Resources Procurement Plan filed for ICC approval on September 20, 2023, which includes a revised, suggested approach to the reallocation of uncontracted capacity across project categories, at the conclusion of a given Program Year and in support of rollover capacity for the following Program Year. 

The Agency encourages Approved Vendors to continue to submit applications for Distributed Generation projects in Group A to Illinois Shines even though there is no Program capacity currently available for that category. Customers may still purchase, install, and finance solar projects in southern and central Illinois during the current Program Year. Customers should be advised that delays in Illinois Shines incentives do not affect other economic benefits associated to their projects including net metering, rebates offered by the utilities, or any federal tax incentives. The Program Administrator is aware that with several Illinois Shines blocks closing and new projects being waitlisted, Approved Vendors and Designees are concerned about how to accurately disclose the expected REC incentive value (and possibly pass-through payment) to customers on the Disclosure Form.

To address this issue, the below language will be substituted for the highlighted text shown below in the screenshot:

This payment amount may change if project specifications change, OR if the Program is full for the current year and the solar project is waitlisted for the following Program Year (which begins June 1). The value of Program incentives may change in the next Program Year. Please check the “Additional Information from Project Seller” section, below, for details on any expected changes in incentive rates.

In addition, the Program Administrator is providing “stock” language that Approved Vendors / Designees may use in the “Additional Information” section at the end of the Disclosure Form. Approved Vendors / Designees may modify this language as appropriate and/or necessary to be accurate for the specific project and as circumstances change.

For solar projects where the relevant Program block has closed:

The Illinois Shines category for this project is full for the current Program Year. This solar project will be waitlisted and is expected to receive an Illinois Shines incentive in the next Program Year, which begins June 1, 2024. Incentive rates may change for the next Program Year. If the amount of the incentive payment that you receive will change, the Project Seller or Approved Vendor is required to notify you.

For solar projects sold near the end of the Program Year:

This solar project may not be approved by Illinois Shines prior to the end of the Program Year. If the project receives an Illinois Shines incentive in the next Program Year, which begins June 1, 2024, it may receive a different incentive rate. If the amount of the incentive payment that you receive will change, the Project Seller or Approved Vendor is required to notify you.

If the amount of the Illinois Shines REC incentive payment, or the amount of the pass-through payment, changes solely because of a change in REC price from when the Disclosure Form was generated and when the Part I application was submitted, a new Disclosure Form is not required, but the Approved Vendor or Designee must notify the customer if there is a change in the amount of the direct lump-sum pass-through payment. If there are other changes in the information presented in the original Disclosure Form, consult this chart to determine if the customer must sign a new Disclosure Form.

Additionally, the Program Administrator has implemented resources to educate and help the customers navigate the Illinois Shines program. The “Deep Dive into Your Disclosure Form” is a resource designed for customers to understand their Disclosure Forms. The Project Look Up Tool was recently added to the Program website, and allows customers who have a Distributed Generation solar project participating in Illinois Shines to view the status of their application. Knowing the project’s application status can provide insight to customers on how close an Approved Vendor is to receiving the incentive payment for the project. These tools along with the Distributed Generation brochure attached to the Disclosure Form and the Guide to Going Solar are available to support customers in their understanding of the Program.

The Program Administrator invites Approved Vendors and Designees to continue participating in the Consumer Protection Working Group that meets on the first Friday of each month and discusses market trends, best practices, consumer education, updates to Program requirements, and documents, and other consumer protection issues for both Illinois Shines and Illinois Solar for All.

The Agency seeks to provide helpful information that Approved Vendors and Designees can share with their customers. Approved Vendors and Designees should feel free to utilize these communications if needed:  

  • Block Capacity Exhaustion – The exhaustion of block capacity does not mean that Illinois Shines or the state have run out of Program funds. It just means that space in this Program Year has been used up. Waitlisted projects will be reviewed and approved in the next Program Year, which starts June 1. The amount of the REC incentive payment may be different in the next Program Year due to changes in REC prices.
  • Continued Project Development – As shared above, customers, Approved Vendors and Designees may continue to develop solar projects. These projects may be added to the Program’s waitlists after submission to the Program and will be first in line when new capacity becomes available. 
  • Net Metering – While waiting for capacity and incentive availability, customers can still take advantage of net metering credits. 
  • REC Prices and Disclosure Forms – Since the inception of the Illinois Shines and Illinois Solar for All programs, the Illinois Power Agency has required that standard Disclosure Forms be provided to customers for their signature, with those customer-executed forms then submitted to the appropriate Program Administrator. The customer must sign their completed Disclosure Form prior to signing an installation contract or subscription agreement. Because REC prices for the 2024-25 Program Year have not yet been published, and are likely to change from current Program Year 2023-2024 prices, Approved Vendors and Designees can use the “Additional Information” text fields at the bottom of the customer Disclosure Forms to note that the Illinois Shines incentive payment is only an estimate using the language provided above. Dynamic Disclosure Form “Deep Dive” tools are available at the Program website to help educate consumers on what to expect and look for on their project and subscription offers.