Illinois Shines Releases New Disclosure Forms for Program Year 2023-2024

May 5, 2023

The Illinois Shines program announces the release of new Distributed Generation and Community Solar Disclosure Forms, which will be available in the Illinois Shines Program portal and required for use by participating AVs and Designees beginning June 1, 2023, the commencement of the 2023-2024 Program year. This announcement contains important information about:

Changes to the standard Disclosure Form including length, organization, and portal functionality
The end of the temporary leniency period related to the timing of Disclosure Form signatures, effective May 31, 2023
The availability of a Community Solar Disclosure Form API, and information on a forthcoming DG API
Discontinuation of the SharePoint workaround process for the CSV upload of Disclosure Forms
Materials and support available to stakeholders to support transition to the improved Disclosure Forms and processes

The Program Administrator acknowledges and apologizes for challenges that participating entities have experienced with Disclosure Forms in the new Program portal since the Program’s transition in July 2022, including gaps in expected and planned DF functionality, bugs, the unavailability of an API tool, and other difficulties. These challenges formed the basis of an extended leniency period that that Agency instituted to accept Disclosure Forms signed after execution of installation and subscription contracts, as ordinarily required.

BACKGROUND

A key consumer protection requirement in both the Illinois Shines and Illinois Solar for All programs is the standard Disclosure Form. Since the beginning of these Programs, it has been a requirement that each customer receive and sign a standard Disclosure Form before signing their installation (for distributed generation) or subscription (for community solar) contract. The Disclosure Form provides clear, consistent information to the customer about the Program, the specific offer, and consumer rights. The standardized format allows customers to use the Disclosure Form to compare multiple offers in an apples-to-apples manner. The 2022 Long-Term Plan explained (p. 316) that the Agency would update and streamline the Disclosure Forms, and initial samples were included.

In December 2022, the Agency and Program Administrators facilitated a stakeholder feedback process including the issuance of proposals, and the invitation for public comment in writing and at the Consumer Protection Working Group; a follow up proposal specific to a feature of new Distributed Generation Disclosure Forms occurred in March. The Agency carefully reviewed and considered the feedback before finalizing the new Disclosure Forms and published a Rationale Document explaining the major changes.

The new forms (referred to as Version 2) will replace current versions (Version 1) and offer the following notable updates:

For Illinois Shines, there are 4 Disclosure Form types:
- Distributed Generation: Purchase, Lease, and Power Purchase Agreement
  - Dynamic elements allow the disclosure of information, as applicable, about collateral requirements and the Smart Inverter/DG Rebate
- Community Solar
  - Dynamic elements allow the disclosure of information, as applicable, about community solar offers bundled with Alternative Retail Electric Supply (ARES) offers and about offers where the Community Solar Provider takes over management of customer’s utility account
- All Disclosure Forms can be generated in English or Spanish.
The new Disclosure Forms are approximately 50% shorter than the current Disclosure Forms, and introduce improved organization and presentation of information, including use of graphics, tables, color, and other formatting improvements.
The portal has been updated for improved usability including helper text, data validations, and color-coded progress
The Program brochures, which are pre-pended to Disclosure Forms for both Distributed Generation and Community Solar offers, have been updated; an updated Guide to Going Solar flyer that is pre-pended for DG offers that include a passthrough of the REC incentive has also been updated.

LENIENCY PERIOD, SHAREPOINT WORKAROUND, AND COMMUNITY SOLAR AND DISTRIBUTED GENERATION API TOOLS

The transition to a new Program Administrator in July 2022 necessitated the development of a new Program portal. Due to challenges in portal functionality, the Agency announced on August 26, 2022 that it would grant leniency to the normal Program requirement that Disclosure Forms must be signed before the installation/subscription contract. The Program has continued to operate with the leniency period in place but indicated that it would provide 2 weeks’ notice before the requirement became effective again. The leniency period will officially end on May 31, 2023; all customer contracts signed on or after June 1, 2023 are therefore subject to the Program requirement that a signed Disclosure Form is required prior to the execution of the contract.

In addition to the leniency period, and in recognition that the Program portal did not include an application processing interface (API) to support the upload of Disclosure Forms, the Program Administrator has been providing a SharePoint “workaround” where AVs have been provided blank Disclosure Forms with pre-associated Disclosure Form ID numbers and logging the details of the form into a CSV upload template. With the forthcoming introduction of a Community Solar Disclosure Form API tool, which began beta testing in April 2023, and the Community Solar Disclosure Form CSV upload functionality now available in the portal, the SharePoint workaround will no longer be available after May 31, 2023. All AVs using the workaround are asked to begin using the Community Solar Disclosure Form CSV portal upload functionality as soon as practicable, and no later than June 1, 2023. AVs will be required to upload any outstanding Disclosure Forms generated through the CS DF workaround process into SharePoint no later than July 1, 2023. A Distributed Generation API is not yet developed, but the Program Administrator will update AVs and Designees on development plans and progress, including the potential of a Working Group to solicit stakeholder input and feedback.

DISCLOSURE FORMS THAT ARE IN PROGRESS OR PENDING SIGNATURE ON MAY 31, 2023

The following table outlines the possible scenarios of disclosure forms that are in process, or waiting to be signed, as of the June 1, 2023 cut over date to Version 2 Disclosure Forms. Please reference the following directions on actions for AVs to take prior to June 1, as well as options available after June 1, 2023. Further usability enhancements will be made following the new program year launch and will be communicated through release announcements.

Disclosure Form Status	Suggested Actions BEFORE June 1, 2023	Available Actions AFTER June 1, 2023
1. Disclosure Form in progress in portal (not yet generated for signature)	Complete form and download for wet signature or send for e-signature	Any in-progress form data will automatically populate in the Version 2 form format in the portal, even if data entry began prior to June 1. User will need to correct data validations and complete new fields present in Version 2 forms. Version 2 forms can be executed through wet signature or e-signature
2. Disclosure Form generated but not yet signed	Download form to wet sign OR send out for e-signature prior to June 1	If an e-signature request is sent to the customer prior to June 1, the customer can execute the e-signature after the cutover date, and the e-signed form will appear in the Portal as normal E-signature requests cannot be made for Version 1 forms after June 1 The form will be able to be downloaded for wet signature and uploaded after June 1 The ability to “View Summary” of Version 1 Disclosure Forms will not be available on June 1 (this is the view that shows all questions and answers for the DF); users will be able to view PDFs of completed Version 1 Disclosure Forms* The Administrator “Resume” feature, which is used by the Program Administrator to revise completed and submitted Disclosure Forms, will not be available in the portal on June 1; without this functionality, AVs will need to submit a new Disclosure Form in cases of errors requiring correction.*
3. Disclosure Form generated and sent for e-signature, but not yet signed	No action	If an e-signature request is sent to the customer prior to June 1, the customer can execute the e-signature after the cutover date, and the e-signed form will appear in the Portal as normal Generated PDF forms and uploaded forms will be visible and downloadable The ability to “View Summary” of Version 1 Disclosure Forms will not be available on June 1 (this is the view that shows all questions and answers for the DF); users will be able to view PDFs of completed Version 1 Disclosure Forms* The Administrator “Resume” feature which is used by the Program Administrator to revise completed and submitted Disclosure Forms will not be available in the portal on June 1; without this functionality, AVs will need to submit a new Disclosure Form in cases of errors requiring correction.*
4. Disclosure Form generated and wet signed	No action	Generated PDF forms and uploaded forms will be visible and downloadable The ability to “View Summary” of Version 1 Disclosure Forms will not be available on June 1 (this is the view that shows all questions and answers for the DF); users will be able to view PDFs of completed Version 1 Disclosure Forms* The Administrator “Resume” feature which is used by the Program Administrator to revise completed and submitted Disclosure Forms will not be available in the portal on June 1; without this functionality, AVs will need to submit a new Disclosure Form in cases of errors requiring correction.*
5. Disclosure Form generated with completed e-signature	No action	Generated PDF forms and uploaded forms will be visible and downloadable The ability to “View Summary” of Version 1 Disclosure Forms will not be available on June 1 (this is the view that shows all questions and answers for the DF); users will be able to view PDFs of completed Version 1 Disclosure Forms* The Administrator “Resume” feature which is used by the Program Administrator to revise completed and submitted Disclosure Forms will not be available in the portal on June 1; without this functionality, AVs will need to submit a new Disclosure Form in cases of errors requiring correction.*
6. CSV Template	Forms started before June 1 by CSV but not generated/submitted will fall under scenario 1. Forms generated and downloaded for wet signature or sent for e-signature before June 1, 2023, by CSV will fall under Scenarios 2-4.	Use Version 2 CSV template for Disclosure Form creation that will be released June 1, 2023 to enable CSV uploads for new DFs
7. CS Disclosure Forms submitted and signed in SharePoint work around	Upload CSV template to SharePoint by July 1, 2023 Recommended: New forms to be created by CSV upload or in the portal	Utilize the Version 2 CSV template, or API for CS forms Program Administrator will support backend data uploads for work around process until the end of June
8. Accessing Version 1 completed Disclosure Forms	Work with Program Administrator to complete revision and re-submission for any forms previously submitted. This may apply for disclosure forms that are progressing through app processing	The ability to “View Summary” of Version 1 Disclosure Forms will not be available on June 1 (this is the view that shows all questions and answers for the DF); users will be able to view PDFs of completed Version 1 Disclosure Forms* The Administrator “Resume” feature which is used by the Program Administrator to revise completed and submitted Disclosure Forms will not be available in the portal on June 1; without this functionality, AVs will need to submit a new Disclosure Form in cases of errors requiring correction.* Users will be guided to start a new Version 2 Disclosure Form for any changes to previously submitted and signed forms

*The Program Administrator will provide further information on the availability of these functionalities in future announcements.

SUPPORT AND RESOURCES

The Program Administrator and Agency are providing the following resources in support of stakeholder understanding and familiarity with the new Disclosure Forms:

Updated content at the Program website, including Disclosure Form samples, background information, and a consumer-facing resource that allows readers to select specific Disclosure Forms applicable to their project, and learn more about the information presented on the form
A stakeholder informational webinar to be held Thursday, May 18, 2023, to cover the new Disclosure Forms, the CSV upload tool, the Application Programming Interface (API), and “in flight” scenarios related to Disclosure Forms started prior to June 1, 2023. Register link: https://energy-solution.zoom.us/j/91519233251
Availability of a Portal Help Guide including screen shots and step-by-step guidance
Dedicated DF Office Hours hosted by the Program Administrator to support stakeholders. Please see the weekly Program Updates for details
Publication of Frequently Asked Questions at the Program website