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
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.
