Limitations on Reasons Cited in Good Cause Extension Requests

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Each project that is Part I verified in the Illinois Shines program is required to be Energized (Part II verified) within a certain timeframe from the date that the project has been approved for a REC Contract by the Illinois Commerce Commission (“Trade Date”).  The following table provides the timeframe for projects to be Energized according to the application’s REC Delivery Contract:

REC Contract TypeDistributed GenerationCommunity Solar
2019 REC Delivery Contract12 months from Trade Date18 months from Trade Date
2021 REC Delivery Contract12 months from Trade Date18 months from Trade Date
2022 REC Delivery Contract18 months from Trade Date24 months from Trade Date
2024 REC Delivery Contract18 months from Trade Date24 months from Trade Date

The Energization Date can be found in the project’s most recent Schedule A, Scheduled Energization Date. If a project is not expected to be Energized by its Scheduled Energization Date, an extension request may be made to the IPA. The Illinois Shines REC Delivery contracts contain several provisions for requesting extensions of system Energization deadlines. Under Section 5(b)(v) of the 2019 REC Contract and Section 2.4(b)(iii) of the 2021, 2022, and 2024 REC Contracts, Approved Vendors can request what is known as a good cause extension of the original Scheduled Energization Date. The Agency understands that the COVID-19 pandemic had significant impacts on the global supply chain and the ability for Approved Vendors to visit the site of their projects. Since then, the Agency allowed Approved Vendors to cite the COVID-19 pandemic as a reason for a good cause extension request. As of July 1, 2024 the Illinois Power Agency will no longer accept good cause extension requests that cite the COVID-19 pandemic as reason for the request. Examples of acceptable reasons to request an extension under the good cause provision include, but are not limited to:

  • Energization delays associated with processing of permit requests or addressing regulatory requirements
  • Delays in receiving interconnection approval
  • Delays in receiving the interconnecting utility’s estimate of costs to construct the interconnection facilities, and to complete required distribution upgrades, necessary for the interconnection of a project
  • Limited workforce availability
  • Supply chain shortage or shipping delays for vital products, provided such reasons are not primarily caused by the Approved Vendor’s actions

The Agency encourages Approved Vendors to limit the use of the extension process except when absolutely necessary. Approved Vendors are encouraged to review all projects with upcoming Scheduled Energization Dates with proper due diligence to evaluate if the project will in fact be moving forward, thus requiring an extension request. It is administratively burdensome for the Agency to process hundreds of extension requests and the Agency wants to ensure that any extensions granted are truly warranted.  

The Program Administrator’s sector strategist team will be reaching out to AVs to remind them of this change and answer any questions.