Results of Traditional Community Solar Score Audit

This audit is now complete and the results are presented here. The Program Administrator has published updated scores, as applicable, and an allowance for additional appeals is available for any impacted AVs whose project scores have been revised due to a scoring error and adjustment as a result of the audit.

Following the finalization of scores post-appeal determination, the Agency will utilize a random selection process to break ties between projects that received the same scores and where those scores would impact project selection or waitlist placement. Currently, the Agency intends to hold the random selection reordering event in late May 2023, pending the Agency’s ability to review submitted appeals from AVs with updated scores resulting from the audit.

The audit process comprised the following areas:

• Evaluation of the Program Administrator’s Standard Operating Procedure (SOP) for scoring
• Audit of all project scores following the SOP evaluation and update

1. TCS Scoring Standard Operating Procedure (SOP) Audit & Findings
   The audit concluded that the original SOP did not sufficiently document all information from the TCS Final Scoring Guidelines and the TCS Clarifications #1 and #2 documents into the scoring process. Critical gaps were identified:

1. 1. In TCS Clarifications #2, Question 11 states, “As it relates to the points offered for the top 2 queue position in the clarification document, the IPA states ‘interconnection agreements must be both executed and valid meaning not expired. Can you confirm that this requirement applies to scoring criterion item 4.a (Project has a valid interconnection agreement at the time of application (Add 1 point) as well)? Yes, a valid and executed interconnection agreement is required for both scoring items 1.a and 1.b under ‘Interconnection Status’.”
      1. This clarification was not incorporated into the original scoring process. The error resulted in 8 projects incorrectly earning points for Scoring Criteria 4.b, a top two-queue position, even though they did not have a valid interconnection agreement. This error was identified before the audit began, and all affected AVs were notified of the score corrections.
   2. Final TCS Scoring Guidelines footnote 10 states, “Multiple projects in a given county or township that does not presently feature a community solar project either under contract or part of developers’ March 2022 reopening portfolios may receive points in this category for the current program year. Project application reports will be used to verify this information”.
      1. The March 2022 reallocation portfolio was not included in the original scoring process for Siting Criterion 2.c. After reviewing the March 2022 reallocation portfolio, CS reallocation projects were found in Coles and McHenry County, Algonquin & Chemung township. Nine TCS projects located in these counties have lost 2 points for 2.c.
   3. Final TCS Scoring Guidelines footnote 16 states, “Pursuant to Article 3 of the Interconnection Contract (see 83 Ill. Adm. Code Part 467, Appx. C), the interconnection agreement will be considered “valid” if it is fully executed by both parties and the effective of the contract date (i.e., the date noted in the first paragraph of the agreement, pursuant to 3.1 of the contract) falls before the date of the application.”
      1. All projects were originally scored consistently for criterion 4.c based on the assumption that the date of the last signature was the contract effective date. The utilization of this date was incorrect per the Final Guidelines and was discovered during the audit. As such, all projects were reviewed and the interconnection recency points were adjusted based on the correct effective date of the interconnection agreements. This resulted in a date change for 51projects
   4. Final TCS Scoring Guidelines footnote 3 states (emphasis added), “The Agency recognizes that there may be overlap between projects defined by the U.S. Environmental Protection Agency (“EPA”) as a brownfield that also meet the definition of contaminated lands. The Agency believes that allowing a contaminated project that qualifies as a brownfield site under Section 1-10 of the IPA Act to receive points in both categories fits within the spirit of this scoring criteria. Therefore, if a project is sited on a location that independently qualifies as both contaminated lands defined by the U.S. EPA and as a brownfield under Section 1-10 of the IPA Act, the project may receive points under both (a) and (b) of the Built Environment scoring. …”.
      1. In the scores for TCS projects released on March 10, 2023, this footnote was applied incorrectly. Projects that documented brownfield status via a singular cause or determinant were incorrectly given points for contaminated land for that same determinant. Footnote 3 clearly states that in order for a project to receive points for both brownfield (1.b) and contaminated land (1.a), the site must “independently qualify” for each distinction (meaning projects may not “double dip” with a single determinant for both scoring criteria, as any brownfield site would necessarily, by definition of a brownfield, be contaminated). As this was originally applied incorrectly and discovered via the Audit, all projects that were awarded points for both scoring criterion 1.a and criterion 1.b for the same determinant were corrected.

2. Audit of All Scores
   The Program Administrator reviewed all projects using the audited TCS Scoring SOP. For each TCS project, the following steps were taken:

1. 1. Re-reviewed all scoring documents that were received in the portal and any updates to Project Details.
   2. Re-reviewed documents that were received in AV SharePoint Folders during the Need Info Cure period.
   3. Re-reviewed the individual TCS Scores workbooks that were created and shared with AVs via SharePoint.
   4. Re-reviewed all Salesforce cases associated with the Project and the AV.

For all scores in which the awarded points do not match the audited points, the following steps were taken:

1. 1. The details of the project and the point change were noted in the Tracking Errors table of the audit workbook.
   2. The error was reviewed and double checked by every person on the TCS Scoring Team.
   3. A determination of the reasoning behind the error was made.

Below is a summary of scores that were corrected for each criterion. More details for each correction are in the published TCS Scores file, Errors tab.

1. 1. Built Environment (BE)
      

      Part I Large DG	New Applications Submitted		Actual Applications Batched and Paid	New Applications Reviewed		End of Week Queue*	Reviewing Apps Submitted Week of
      	Projected	Actual		Projected	Actual
      Week Of						104
      3/13/2023	N/A	2	2	N/A	3	103	11/22/2022
      3/20/2023	N/A	0	1	N/A	6	98	12/19/2022
      3/27/2023	N/A	9	9	15	6	101	12/19/2022
      4/3/2023	3	2	2	30	11	92	2/6/2023
      4/10/2023	3	0	0	25	20	85	2/6/2023
      4/17/2023	3	0	0	0	28	56	2/13/2023
      4/24/2023	3	N/A	N/A	12	N/A	47	2/27/2023
      5/1/2023	3	N/A	N/A	2	N/A	48	3/6/2023

      
      During the audit, a lack of consistency in documentation for criteria 1.c, Agrivoltaics, and 1.d, Pollinator friendly habitat, was identified. The Program Administrator requested additional documentation from affected projects, however no scores were changed in this process.

1. Siting
   

   Part II Large DG	New Applications Submitted		New Applications Reviewed		End of Week Queue*	Reviewing Apps Submitted Week of
   	Projected	Actual	Projected	Actual
   Week Of					55
   3/13/2023	N/A	8	N/A	3	60	12/19/2022
   3/20/2023	N/A	4	N/A	10	54	12/26/2022
   3/27/2023	N/A	3	14	0	57	1/16/2023
   4/3/2023	5	1	15	17	40	1/16/2023
   4/10/2023	5	4	4	20	25	1/16/2023
   4/17/2023	10	3	3	1	27	1/30/2023
   4/24/2023	10	N/A	3	N/A	34	2/6/2023
   5/1/2023	10	N/A	19	N/A	25	2/13/2023
   5/8/2023	10	N/A	7	N/A	28	3/6/2023

2. Equity Eligible Contractor
   A lack of consistency in documentation for criteria 3.d, Equity Eligible Contractor, was identified. The Program Administrator requested additional clarification from the affected AV and the issue was resolved without any changes to scores.
3. Interconnection Status
   In addition to the eight projects affected by the interconnection queue error outlined in the SOP Audit section above, there was a scoring process change affecting criterion 4.c, Recency of project having obtained a valid interconnection agreement. In the Final TCS Scoring Guidelines, footnote 16 states, “Pursuant to Article 3 of the Interconnection Contract (see 83 Ill. Adm. Code Part 467, Appx. C), the interconnection agreement will be considered “valid” if it is fully executed by both parties and the effective of the contract date (i.e., the date noted in the first paragraph of the agreement, pursuant to 3.1 of the contract) falls before the date of the application.” All projects were originally scored based on the assumption that the date of the last signature was the contract effective date. This assumption was incorrect and resulted in a date change for 51 projects. The details of this change can be found in the published TCS Scores file, Interconnection Date tab.

Conclusion

The Program Administrator  has completed the audit of the scores released on March 10, 2023 and have posted updated TCS project scores. Individual entities whose project scores have been directly affected will be contacted, and are provided two weeks to appeal any changes to scores. The Agency will review and intends to answer all appeals by May 26, 2023. Because other projects’ potential for award may be affected by the updated scores of select projects, all participating entities are encouraged to familiarize themselves with the updated project scores list.

Following the conclusion of the appeal period, and the finalization of scores, the Agency and Program Administrator will announce a Random Selection Event, to be held in late May, 2023, which will be used to break ties between projects that received the same scores and where those scores would impact project selection, or waitlist placement.

Schedule of Next Steps

• Appeals due May 17, 2023
• IPA determination on submitted appeals to be finalized by May 26, 2023
• Random selection event on May 30, 2023 (Agency will endeavor to hold the random selection event sooner in the case that no appeals are submitted)
• Projects will be sent to the ICC for approval for REC contracts after random selection event is complete and project selection for the 2022-23 Program year concludes

The Program Administrator greatly appreciates the patience and understanding of all Approved Vendors throughout this process in the first year of Traditional Community Solar scoring.