Stakeholder Feedback

The Agency and Program Administrators are requesting stakeholder feedback on detailed proposals for three new consumer protection initiatives: an escrow process, a stranded customer REC adder, and a Restitution Program. A framework for each of these initiatives was approved as part of the 2024 Long-Term Plan, and the Agency is now seeking feedback on more comprehensive proposals for each initiative.   

• Escrow Process Stakeholder Feedback Request: The escrow process will be used when necessary to ensure that customers who have been promised a portion of the REC incentive payment do in fact receive that promised payment.   

• Stranded Customer REC Adder Stakeholder Feedback Request: The stranded customer REC adder creates an economic incentive for Approved Vendors to take on customers who have been stranded by the original solar company.  

• Restitution Program Stakeholder Feedback Request: The Restitution Program will provide compensation to customers harmed through their participation in Illinois Shines and Illinois Solar for All.   
  
  

The Agency and Program Administrators request feedback on all aspects of the proposals, and commenters should not feel limited by the specific questions posed.   

Please provide comments via email attachment to [email protected]  with the subject “[Responder’s Name] – Stakeholder Feedback on CP Initiatives” by October 7, 2024.  

The Agency and Program Administrators are requesting stakeholder feedback on a proposal to update Distributed Generation Disclosure Forms for both Illinois Shines and Illinois Solar for All (“ILSFA”). The Programs are proposing to update Distributed Generation Disclosure Forms to reflect the change for residential and small commercial customers from “full retail rate” net metering to “supply only” net metering in the ComEd, Ameren, and MidAmerican service territories. This change will be in effect for new net metering customers starting in 2025.

The proposed updates would change the approach for calculating the value of electricity from solar projects. The Agency and Program Administrators believe that the change in net metering for residential and small commercial customers may lead to an increased deployment of batteries as part of solar projects. Therefore, the proposal also includes new disclosure fields for information about batteries, including size and information about the utility storage rebate. The linked document describes separate proposals for Illinois Shines and ILSFA and breaks down each proposal into three sections: changes to the user inputs into the Portal; changes to the Portal calculations related to the value of electricity, and utility rebate payments; and changes to the Disclosure Form PDF presented to the customer.

The Agency and Program Administrators request feedback on all aspects of the proposal, including the overall approach and the proposed values for the simplifying assumptions. The Agency intends for the new Disclosure Forms to be available starting January 1, 2025.

Please provide comments via email attachment to [email protected] with the subject “[Responder’s Name] – Stakeholder Feedback on DF Updates” by September 6, 2024.

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 [email protected] with the subject line “[Responding Entity Name] – Response to New DG Disclosure Forms – Project Performance (“Efficiency”) Disclosure.” Comments will be posted online.

The Illinois Power Agency published a packet of thirteen Consumer Protection Proposals for Public Comment on December 2, 2022. Each proposal includes background information, a description, redline edits to the relevant Program documents, questions for feedback, and referenced exhibits, are linked here. (Proposal Packet, Exhibit 1, Exhibit 2, and Exhibit 3). Please see the below reference table for each proposal and its associated deadline for comments. Comments should be submitted to [email protected] with the subject line “[Responding Entity Name] – Response to Consumer Protection Proposals.”

#1 – Updated and Streamlined Disclosure Forms

Proposals #2-13