Illinois Shines Project Inspections to Resume March 2024

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Inspections are critical to ensure Program requirements are met and that the system equipment described in the project’s technical documentation of the Part II application, including site plans, drawings, and photos match what is installed on-site. The inspection process is designed to verify that installations meet the Program requirements outlined in the Program Guidebook and are installed as submitted to the Program. This announcement provides an overview of the inspection types, Minor and Material Deficiencies, and the results of the inspections process.

All projects are subject to local jurisdiction permitting and inspection processes; as such, local code compliance is not included in this inspection process. Any potential fraud detected through inspections will be immediately communicated to the Illinois Power Agency (IPA).

Per the requirements outlined in the Program Guidebook, all inspections will start no earlier than 90 days after Part II application verification. Inspections will be randomly selected and completed using one of the following inspection types:

  • On-site inspections will be conducted at the installation site and will compose the majority of project inspections. The goal of an on-site inspection is for the inspector to perform an in-person review of the equipment and functionality of the verified project submission.
  • Virtual inspections will be utilized for remote project locations or cases where on-site inspection is not feasible and will follow the same procedure as the on-site inspection to the extent possible. For virtual inspections, video conferencing will be used in which a representative of the Approved Vendor (AV) is guided through the inspection process on-site by the inspector, who will be remote.
  • Desktop inspections will be utilized periodically as another layer of quality control to review Small Distributed Generation (DG) projects with established AVs. Projects for which all the technical information submitted can be verified remotely will be eligible for desktop inspections. If a project is selected for desktop inspection, the inspector will provide the AV with a list of photos required. The AV will be responsible for providing the photos at that time, unless already provided as part of the Part II application submission. If during a desktop inspection, concerns about onsite conditions are identified, the inspector will schedule an on-site inspection.

Inspection scheduling will start March 18, 2024. Customers and AVs will be notified two weeks before each project’s proposed inspection date. The inspection team will schedule on-site inspections, directly with the customer copying the project AV on all communications. When scheduling virtual inspections, the team will coordinate with the customer and AV as both also need to be present during the inspection. Desktop inspections do not require a fixed date and time.

The data collected during inspections will be evaluated to identify potential deficiencies. A deficiency is an instance of project information that deviates materially from what was reported to the Program Administrator within the Part II project application. Deficiencies will be categorized as either Minor or Material depending on how far the onsite system deviates from the submitted application, which has potential impacts on the project’s energy generation. The table below delineates between Minor and Material deficiencies:

Deficiency Categories
CategoryRangeDeficiency Range and Type DetailsDeficiency Type
Module make and modelNot Exact MatchThe substitution of module make and model or number of modules will not have a significant impact on production if the overall DC size is maintained.Minor
Module WattageNot Exact MatchMinor
Module countNot Exact MatchMinor
Project DC sizeNot Exact MatchDC size of the system should match the application for accurate REC estimates.Material
Inverter ModelNot Exact MatchThe substitution of inverter make and model or number of inverters will not have a significant impact on production, as long as the overall AC size is maintained.Minor
Inverter CapacityNot Exact MatchMinor
Inverter count Not Exact MatchMinor
Project AC sizeNot Exact MatchSystem AC size must match the application for accurate REC estimates. Material
Array TiltMatch or within ±10°A variation within ±10°will have a limited impact on production estimates.Minor
Outside ±10°More than 10° bias toward 39° tilt will significantly increase production estimates.Material
Array AzimuthMatch or within ±10°Variations of ±10°will have limited impact on production estimates. Minor
Outside ±10°More than 10° bias toward 180° (South) significantly increases production estimates. Material
Mount and Tracking TypeNot Exact MatchThis information is used in the application process to generate REC estimates, as part of the application process. Tracking systems will have a significant impact on production.Material

The Inspection Team will communicate the inspection results, including a Deficiency Notice if required, within 15 business days after the inspection. Inspection reports will be sent to the following:

  • Inspection results with no material deficiencies identified:
    • The report is sent to the project owner or host, AV, and their associated Program Administrator Sector Strategist.
  • Inspection Results with one or more material deficiencies identified:
    • The report including Deficiency Notice is sent to the project owner or host, AV, and their Sector Strategist.
  • Immediate safety concern identified:  
    • In the rare event that an immediate safety concern with the installed project is identified, the inspector will consult with a senior member of the Inspection Team.
    • The senior team member will contact the IPA. If the IPA agrees with the recommendation, the senior team member will notify the inspector to proceed with the applicable next steps to ensure safety concerns are communicated to relevant parties.
  • Inspection results with ancillary installation issues
    • The report template includes an addendum section for documenting any ancillary issues found relating to workmanship and installation quality. The inspector may provide installation best practice recommendations for each workmanship issue found in the report addendum. Copies of the report are sent to the AV, the installer, and Sector Strategist.

If one or more material deficiencies are identified, the Inspection Team will issue a Deficiency Notice with the inspection report. The AV will have five business days upon receipt of the Deficiency Notice to respond to the communication. If a Material Deficiency is identified, a member of the Inspection Team will create a new production estimate using PVWatts®. The new estimated production will be for the length of the REC contract associated with the project, using a degradation factor of 0.5% per year.

  • If the new production estimate generated using PVWatts is lower than 5% or more compared to the REC obligation associated with the project in the Part II verified application, the AV can make physical changes to the project to align it with the technical information originally submitted with the Part II application. If this option is not viable, the AV can request a REC delivery obligation reduction (Program Guidebook, Section 7.C, page 89, August 3, 2023).
  • If the new production estimate exceeds the REC delivery obligation, no further action is required by the AV.

The new production estimate will be communicated as part of the Deficiency Notice with the project owner or host, installer, AV, and their Sector Strategist. Proof of the action plan’s completion shall include, at minimum:  

  • A brief explanation of how the issue was corrected
  • Before and after photos of the correction, if applicable
  • Confirmation of any resulting changes to system specifications

The Inspection Team will assess such proof for acceptability case-by-case, depending on the deficiency. The AV will be notified by email (including cc: to the system owner or host) once the Inspection Team accepts the completion of the action plan. Should the action plan or completion of the action plan not be accepted by the Inspection Team, the team will work with the AV to modify the plan and/or its implementation, such that it becomes acceptable.  

If the Inspection Team is unable to verify the resolution of the deficiencies via the photographs and/or documentation provided by the AV, they will work with the customer and AV to schedule a re-inspection of the project. This may be on-site or virtual.  

Instances that may require disciplinary action will result in a handoff from the Inspection Team to the Program Administrator’s Consumer Protection team, those instances include, but are not limited to the following:  

  • AV is unresponsive to Deficiency Notice communication after three attempts.
  • AV fails to complete deficiency resolution plan within agreed upon timeframe. 
  • Three or more independent projects of the same type (Small DG, Large DG, Community Solar) by the same installer reveal material deficiencies upon inspection within one Program Year (June 1 – May 31).
  • Five or more independent projects by the same AV reveal material deficiencies (regardless of project type) within one Program Year.

Please note that an Illinois Shines inspection with no material deficiencies identified does not mean the photovoltaic system complies with local authorities’ permitting, building, and/or electrical codes. The Illinois Shines inspection process only inspects that a project was built as specified in the Program application and meets Program requirements. Ultimately, it is the installer’s responsibility to ensure that the system was installed properly, safely, and in accordance with local requirements/codes.

The Illinois Shines program and the IPA are not responsible for any post-inspection operational issues with a system caused by occurrences not related to the inspection. An Illinois Shines inspection does not ensure that future issues will not arise with the photovoltaic system.

For assistance or questions relating to project inspections, contact the Inspection Team at [email protected].

Thank you!    
Illinois Shines Program    
[email protected]