Request for Public Comment: New DG Disclosure Forms – Project Performance (“Efficiency”) Disclosures

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The Illinois Power Agency seeks public comment on a potential modification to a portion of the new Distributed Generation (DG) Disclosure Forms. The new Distributed Generation (“DG”) Disclosure Forms that were put out for public comment in December 2022 (for implementation starting June 1, 2023) included a new section, titled “Project Efficiency.” The intent of the section was to provide information to customers on if their project was designed or sited in a sub-optimal way. For example, if a solar project is shaded or is sited on a northern facing roof, it is important that the customer understand the limitations of the project design and/or siting. The IPA proposed this new disclosure because it is aware that there have been projects that have been submitted in both the Illinois Shines and Illinois Solar for All programs that have relatively low performance because of siting/design issues.
In the public comments, questions were raised about exactly what number would be disclosed, and how that number would be calculated. Based on that feedback, the Agency is considering modifying this portion of the disclosure form to be framed as “Project Performance” – that is, eliminating the use of the term “efficiency” – and using the Total Solar Resource Fraction (“TSRF”) as the actual number that is disclosed. This Request for Public Comment includes a full description of the proposed, new modification, including a mock up of how the new “Project Performance” section of the Disclosure Form would appear using the TSRF approach. Comments in response to this request are due: March 10, 2023.
Comments should be submitted to  with the subject line “[Responding Entity Name] – Response to New DG Disclosure Forms – Project Performance (“Efficiency”) Disclosure.” Comments will be posted online.