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)
      

      Criteria	Number of projects affected	App ID(s)	Score Update	Reason for update	Explanation of error
      1a: Contaminated land	13	95055 95154 93293 93339 93346 94377 95107 93994 94002 95061 95113 95241 95244	-2 points	This project is not 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. Therefore, it cannot receive points for 1a, contaminated lands solely by virtue of being a brownfield.	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.
      1.a: Mechanically Disturbed land	3	94625 94800 95129	- 2 points	These projects do not meet the definition of mechanically disturbed land.	Upon review of all mechanically disturbed documentation, it was determined that these projects are not in transition from one cover type to another and therefore do not meet the definition of mechanically disturbed land.
      1.b: Brownfield	1	95165	-2 points for 1b +2 points for 1a	This project cannot produce the permits that are required to confirm brownfield status. However, it does meet the requirements for contaminated land, so 2 points can be awarded for criterion 1a.	Upon review of all brownfield documentation, it was determined that this project did not provide the necessary documentation outlined in the scoring guidelines.
      1.e: Conservation Opportunity Area (COA)	2	95118 95411	+2 points	The project was determined to not be sited in a COA area	The manual process of checking addresses was prone to error and some project addresses that are listed in the address field are not 100% accurate, especially in rural areas. For the audit, the Program Administrator double checked each project address/coordinates from the plot map to ensure the exact project location.
      1.e: COA	1	95164	+2 points	Though sited on a Conservation Opportunity Area, the project was in an R3 Area and should not have had points deducted.	This project was newly identified to be in an R3 Area, therefore, the COA subtractor is negated.
      1.e: COA	1	92997	-2 points	The project was determined to be sited in a COA and without meeting criteria that can prevent the subtraction of points.	The manual process of checking addresses was prone to error and some project addresses that are listed in the address field are not 100% accurate, especially in rural areas. For the audit, the Program Administrator double checked each project address/coordinates from the plot map to ensure the exact project location.
      1.e: COA	1	94002	-2 points	The project was determined to be sited in a COA and without meeting criteria necessary to offset the subtraction of points.	The COA deduction was originally negated because the project is located on a brownfield, but the Program Administrator did not confirm the commitment to a pollinator friendly habitat was included, so the COA subtractor remains applicable. Administrative error in the confirmation of multiple factors required in the application of criteria points.

      
      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
   

   Criteria	Number of projects affected	App ID(s)	Score Update	Reason for update	Explanation of error
   2.a	3	95164 95299 95360	+2 points	Located in R3 Area or an Environmental Justice Community	The manual process of checking addresses was prone to error and some project addresses that are listed in the address field are not 100% accurate, especially in rural areas. For the audit, the Program Administrator double checked each project address/coordinates from the plot map to ensure the exact project location.
   2.c	9	95191 95141 95246 95182 95252 95084 95303 95343 92996	- 2 points	Because there are CS reallocation projects found in Coles and McHenry County, Algonquin & Chemung township, the points should not have been added.	There was a gap in the original scoring process. The Program Administrator originally scored criteria 4.c based on CS projects that had been ICC approved before the date of application, and mistakenly did not include the CS reallocation projects.
   2.c	2	95192 95199	-2 points	Because there are ICC-approved CS projects located in Cook County, Bloom township, and St. Clair County, the points should not have been added.	The manual process of checking addresses was prone to error and some project addresses that are listed in the address field are not 100% accurate, especially in rural areas. For the audit, the Program Administrator double checked each project address/coordinates from the plot map to ensure the exact project location.
   2.c	9	95111 95447 95410 94726 95416 95069 90673 94773 92765	+2 points	There are no CS projects located in Macon, Fayette, Mercer, Perry, Lake, and DuPage County, and Kane County, Elgin & Aurora township, so the points should have been added.	The manual process of checking addresses was prone to error and some project addresses that are listed in the address field are not 100% accurate, especially in rural areas. For the audit, the Program Administrator double checked each project address/coordinates from the plot map to ensure the exact project location.

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.