Stakeholder Feedback
Project-Specific Feedback
Public Schools
The Illinois Power Agency sought public comment on multiple requirements for projects submitted to the Public Schools category of the Illinois Shines program. Background on the topics, a list of requirements for the Public Schools category, and relevant questions for feedback were detailed in the linked Stakeholder Feedback Request – Public Schools Category issued on February 22, 2023. Please see the below reference table for the Stakeholder Feedback Request, which were due on March 3, 2023, and the comments received.
Equity Eligible Contractors
A feature of the Equity Accountability System, as established by the Climate and Equitable Jobs Act, is the ability of Equity Eligible Contractors (EECs) to request an advance of a portion of REC Contract value prior to the associated project’s energization. This capital advancement pre-energization is intended to serve EEC-certified businesses exhibiting true need and to support a more diverse Approved Vendor pool.
The IPA has developed the rubric linked below as criteria for evaluating requests for an advance of capital for projects receiving a REC contract in the EEC Category for the 2022-23 and 2023-24 Program Years. Please provide comments via email attachment to [email protected] with the subject “[Responder’s Name] – Stakeholder Feedback on Advance of Capital Authorization Rubric” by November 14, 2023.
Note: The Agency has filed the 2024 Long-Term Renewable Resources Procurement Plan with the Illinois Commerce Commission and thus is not seeking any input on the advance of capital process contemplated within that Plan. Stakeholders seeking to provide input on Plan content may do so through the intervening in the open docket (Docket 23-0714). Please limit all comments in response to this request for feedback to the criteria listed below as applied to the 2022-23 and 2023-24 Program Years.
Final Advance of Capital Rationale — published December 12, 2023
Final Advance of Capital Evaluation Criteria — published December 12, 2023
The Illinois Power Agency seeks stakeholder feedback on potential strategies to strengthen the criteria for qualifying as an Equity Eligible Contractor and for receiving incentives under the Equity Eligible Contractor block of capacity within the Illinois Shines Program. This feedback will inform new requirements as part of the IPA’s upcoming Long-Term Renewable Resources Procurement Plan. More information on the Equity Eligible Contactor category can be found in section 7.4.6 of the Agency’s Final 2022 Long-Term Renewable Resources Procurement Plan.
Please provide comments via email attachment to [email protected] with the subject “[Responder’s Name] – Stakeholder Feedback on EEC Criteria” by May 5, 2023.
Stakeholders may comment on as many or as few of the items outlined within the request for feedback as they would like. Stakeholders should not feel limited by the questions offered in the request for feedback and may provide comments on these proposals beyond the scope of these specific questions as it relates to the criteria for certifying Equity Eligible Contractors. Responses will be published on both the IPA and Illinois Shines websites. Should a commenter seek to designate any portion of its response as confidential and proprietary, that commenter should provide both public and redacted versions of its comments. Independent of that designation, if the Agency or the Program Administrator determines that a response contains confidential information that should not be disclosed, the IPA reserves the right to provide its own redactions.
The Agency is greatly interested in hearing directly from Equity Eligible Persons, Equity Eligible Contractors, or those looking to qualify as such, but generally seeks input from a wide array of stakeholders.
Consumer Protection
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
#1 – Updated and Streamlined Disclosure Forms
A Just Harvest Response to Proposal 1 Disclosure Forms
Central Road Energy Response to Proposal 1 Disclosure Forms
Clearway Response to Proposal 1 Disclosure Forms
Constellation Response to Proposal 1 Disclosure Forms
CUB Response to Proposal 1 Disclosure Forms
Doshi Response to Proposal 1 Disclosure Forms
Joint Solar Parties Response to Proposal 1 Disclosure Forms
MC Squared Response to Proposal 1 Disclosure Forms
December 30, 2022
Proposals #2-13
#2 – Requirements for Designee Management Plans
#3 – Clarification about Approved Vendor Responsibility for Designees that Market “TBD” Community Solar Offers
#4 – Restrictions on Marketing ARES Products in Conjunction with ILSFA Offers
#5 – Exception to Allow ILSFA Approved Vendors to Use the ILSFA Logo with Approval of the Program Administrator
#6 – Community Solar Billing Issues – Notification and Payment Plan
#7 – Adjusted Disclosure Form Execution Process for Community Solar for Large Commercial and Industrial Customers
#8 – Clarification on Restrictions for Offering Distributed Generation Projects that Cannot Take Advantage of Net Metering Crediting under the Public Utilities Act
#9 – Program Violation Response Matrix
#10 – Requirement to Provide a Copy of Executed Disclosure Form and Contracts to Customer
#11 – Community Solar Contract Requirements – Insurance and Maintenance
#12 – Community Solar Contract Requirements – Assignments
#13 – Replace References to “Adjustable Block Program” and to Separate ABP and Illinois Shines Websites
A Just Harvest Response to Proposal 2-13
Carbon Solutions Group Response to Proposals 2-13
Clearway Response to Proposals 2-13
COFI Response to Proposals 2-13
El Valor Response to Proposals 2-13
ILSFA Working Group Response to Proposals 2-13
Joint Solar Parties Response to Proposals 2-13
December 30, 2022
Minimum Equity Standard Waiver Process
In February 2023 the Illinois Power Agency sought public comment on the waiver for Minimum Equity Standard requirements for entities that have received a REC contract award under the Adjustable Block/Illinois Shines Program or through the IPA’s utility-scale REC procurements for a given Program/delivery year. Following the review and consideration of public comments on the waiver, the Agency finalized the waiver and process for the 2023-2024 Program year/Delivery year beginning June 1, 2023. The proposal, public responses, final waiver, and waiver rationale document are included in the following table. More information on the waiver for Minimum Equity Standard requirements can be found in Section 10.1.3.1 of the Agency’s Long-Term Renewable Resources Procurement Plan.
REC Contracts
The Illinois Power Agency has issued a request for comments on the draft of the 2024 draft REC Contracts (which are posted on the Program Documents page) for Illinois Shines. The draft REC Contracts have changes to conform with the ICC’s Final Order on the IPA’s 2024 Long-Term Renewable Resources Procurement Plan dated February 20, 2024.
Responses are due by April 5, 2024 and should be sent to [email protected].
Program Guidebook
The Agency has released a draft of the 2024-25 Program Year Illinois Shines Program Guidebook for stakeholder feedback.
This draft Guidebook will undergo stakeholder feedback, the Agency will review comments submitted and then release a final version of the Guidebook for the 2024-25 Program Year, which commences on June 3, 2024. Changes in this draft version of the Program Guidebook include updates to conform with the ICC’s Final Order on the IPA’s 2024 Long-Term Renewable Resources Plan dated February 20, 2024 , and changes derived from stand-alone feedback process that have already occurred, such as Advance of Capital Evaluation Criteria and 2024 AV Application update, as well as changes to the Public School category derived from the passing of Public Act 103-0580.
The Agency will release the final Program Guidebook for the 2024-25 Program Year on April 19, 2024, 45 days in advance of the start of the Program Year, to allow Program participants time to review, understand, and prepare to be in compliance with all changes in the Program Guidebook when the 2024-25 Program Year commences on June 3, 2024.
PLEASE NOTE – Changes to the Program requirements via edits to the Program Guidebook as published on April 19, 2024 will not take effect until June 3, 2024. Beginning June 3, 2024, all Program participants are expected to be in compliance with new Program requirements in the finalized 2024 Long-Term Plan and the updated Program Guidebook or may face disciplinary action.
Next Steps in Program Guidebook Comment & Update Process
- Comments on draft Program Guidebook due March 27, 2024
- Draft Program Guidebook
- Redline comparison between current 2023-24 Program Guidebook and draft 2024-25 Program Guidebook
- Comments should be emailed to [email protected] with subject line “2024-25 Program Guidebook Feedback”
- Agency to review comments and make final edits
- Agency to release final Program Guidebook for the 2024-25 Program Year on April 19, 2024
- Updated Program Guidebook takes effect June 3, 2024
High Level Changes to Draft Guidebook
- Program Capacity Increase – from 666 MW to 800 MW starting June 3, 2024
- Removed the capacity delineations of Group A and Group B for Distributed Generation categories
- Approved increase in application fees to $20/kW, not to exceed $15,000/project (increase from $10/kW; $5,000/project)
- Program will close and not accept new Part I applications from May 27, 2024 to June 2, 2024, in order to prepare for next Program Year
- Updated prioritization approach for redistributing uncontracted capacity
- Created Distributed Generation and Community Solar sub-categories for the Public Schools category
- New information regarding the Equity Eligible Contractor (EEC) requirements
- 200% DC/AC ratio limit for systems that include a battery/storage component
- Clarification on Community Solar residential and small commercial customers with multiple subscriptions requirement
- Removal of the 5% of REC contract value collateral requirement for Public Schools in the Tier 1 and 2 categories, or located in environmental justice communities
- Creation of new EEC Subcontractor category
- New information on the advance of capital process
- Development of an Escrow process and Solar Restitution program to provide economic assistance to harmed customers
Stakeholders can find the draft Program Guidebook at the Program Documents page of the website. Responses will be made public and published on the Program’s website https://illinoisshines.com/. However, should a commenter seek to designate any portion of its response as confidential, that commenter should provide both public and redacted versions of their comments. Stakeholders should email comments to [email protected] by March 27, 2024.
The Agency has released a draft Program Guidebook for the Illinois Shines program for stakeholder feedback. This draft Guidebook will undergo stakeholder feedback, the Agency will review comments submitted, and then release a final version of the Guidebook for the 2023-24 Program year, which commences on June 1, 2023. All changes in this draft version of the Program Guidebook are to be considered proposals upon which stakeholders can provide feedback (aside from those changes derived from stand-alone feedback processes that have already occurred, such as the December 2022 consumer protections feedback process, MES waiver feedback process, and the Public Schools feedback process).
The Agency will release the updated Guidebook for the 2023-24 Program year on April 17, 2023, 45 days in advance of the start of the Program year, to allow Program participants to review, understand, and prepare to be in compliance with all changes in the Program Guidebook when the 2023-24 Program year commences on June 1, 2023.
PLEASE NOTE – Changes to program requirements via edits to the Program Guidebook as published on April 17, 2023 will not take effect until June 1, 2023. After June 1, 2023, all Program participants are expected to be in compliance with new program requirements finalized in this Guidebook update process or may face disciplinary action.
Comments on draft Program Guidebook due April 3, 2023. Comments should be emailed to [email protected]
April 3, 2023
The Program Administrator proposes to update the current AV application to improve clarity and relevance, incorporate questions on demographic information the Agency is required to collect from AVs, and reflect the application’s use for verifying Equity Eligible Contractors.
- The Program Administrator is also proposing to update Section 2 of the Program Guidebook with the following edits related to AV applications:
- A new requirement that AVs must promptly submit a renewal application if there is a transfer of ownership of 50% or more of the entity, or if there is a new basis for the AV to answer “yes” to one of the questions in the Company and Affiliate History section (formerly referred to as the Legal and Regulatory section);
- Language reflecting the existing process and requirements for an AV to change its registration status to “inactive” or “withdrawn”;
- Clarification that an AV may not simply fail to renew its application and failure to renew may lead to disciplinary action, which may also apply to an entity’s participation in Illinois Shines as a Designee (if applicable);
- Revision of Section 2.D – Evaluation Criteria for Approved Vendors; and
- Clarification about how conditional application approvals are handled.
- The Program Administrator seeks feedback on the proposed updated AV application and the proposed edits to Section 2 of the Program Guidebook.
Stakeholder feedback is due January 11, 2024 and should be submitted to [email protected].
View the proposed, redlined AV Application and Program Guidebook Section 2 updates
2024 AV Application Updates
- The Program Administrator is also proposing to update Section 2 of the Program Guidebook with the following edits related to AV applications:
- A new requirement that AVs must promptly submit a renewal application if there is a transfer of ownership of 50% or more of the entity, or if there is a new basis for the AV to answer “yes” to one of the questions in the Company and Affiliate History section (formerly referred to as the Legal and Regulatory section);
- Language reflecting the existing process and requirements for an AV to change its registration status to “inactive” or “withdrawn”;
- Clarification that an AV may not simply fail to renew its application and failure to renew may lead to disciplinary action, which may also apply to an entity’s participation in Illinois Shines as a Designee (if applicable);
- Revision of Section 2.D – Evaluation Criteria for Approved Vendors; and
- Clarification about how conditional application approvals are handled.
- The Program Administrator seeks feedback on the proposed updated AV application and the proposed edits to Section 2 of the Program Guidebook.
2024 Long-Term Plan Development
On August 15, 2023, the Illinois Power Agency (IPA) released the Draft 2024 Long-Term Renewable Resources Procurement Plan for public review and comment. The IPA welcomes public comments on the draft 2024 Long-Term Plan. Written comments are due on Friday, September 29 and should be submitted to [email protected]. Previously, on September 15, the Agency held virtual public hearings for the draft 2024 Long-Term Plan.
PLEASE NOTE – Chapter 7 of the Long-Term Plan covers the Illinois Shines program, but Chapter 9 – Consumer Protection and Chapter 10 – Diversity, Equity, and Inclusion both have requirements and proposals within that impact Illinois Shines participants. In order to understand the full scope of changes to the Illinois Shines program, all three chapters should be reviewed in full.
Find the 2024 Long-Term Plan’s Cover Letter and Appendices to the draft Plan on the Agency’s website: https://ipa.illinois.gov/energy-procurement/plans-under-development.html.
September 29, 2023
Minimum Contract Requirements
Equity Accountability System Assessment
The Illinois Power Agency (“IPA” or “Agency”) invites public comment on their proposed plan to assess the Equity Accountability System (“EAS”) and its impact on promoting equity and increasing participation of historically marginalized communities in Illinois’ clean energy economy. As part of this endeavor, the Agency is seeking stakeholder feedback to gather insights and recommendations.
Stakeholders are encouraged to provide feedback on the assessment questions, scope of data collection, proposed methodologies, and additional considerations outlined here. Stakeholders may comment on as many or as few of the items outlined within the document as they would like. Stakeholders should not feel limited by the questions offered within the feedback request and may provide comments on these proposals beyond the scope of these specific questions as it relates to the EAS Assessment.
Please provide comments via email attachment to [email protected] with the subject “[Responder’s Name] – Stakeholder Feedback on EAS Assessment” by April 10, 2024.
In general, responses will be made public and published on the IPA’s website. Should a commenter seek to designate any portion of its response as confidential and proprietary, that commenter should provide both public and redacted versions of its comments. Independent of that designation, if the Agency determines that a response contains confidential information that should not be disclosed, the IPA reserves the right to provide its own redactions.
April 10, 2024
