Updated COVID-19 Related Marketing Guidelines – August 5, 2020

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On March 20, 2020, in light of the growing COVID-19 pandemic and its expected impacts in Illinois, the Illinois Power Agency adopted the following emergency amendment to its Adjustable Block Program and Illinois Solar for All Program Marketing Guidelines:

In-person marketing and solicitation: Given the public health emergency posed by the COVID-19 virus, in-person marketing or solicitation of photovoltaic system sales, installations, or financing; in-person marketing or solicitation of community solar subscriptions; or similar in-person solar marketing or solicitation activity are prohibited.

Clarifications to these requirements were offered on May 19, 2020, along with additional guidance and updates on June 4, 2020 and June 30, 2020.

This update once again confirms that the IPA’s prohibition of door-to-door sales and solicitation remains in place.  While Illinois is perhaps better situated than neighboring states, recent weeks have seen the Illinois statewide COVID-19 positivity rate (the percentage of positive tests across total tests given) creep upward from 2.6% to 4.0%.  This is a troubling trend, and Illinois has since been added to the New York/New Jersey/Connecticut joint quarantine list.  Additionally, as was the case in its prior updates, the Illinois Commerce Commission’s emergency order prohibiting door to door sales by Alternative Retail Electric Suppliers and Alternative Gas Suppliers likewise remains in place, and the state remains under a Gubernatorial Disaster Declaration.

For the foregoing reasons and those offered in its prior updates, the Agency believes this would be an inappropriate time to start permitting in-person interactions initiated without a customer, homeowner, or business owner’s express permission.  This prohibition will remain in effect until lifted by the IPA through a formal announcement, although the IPA will endeavor to continue providing updates.  Additionally, prior-issued guidance regarding best practices and permitted activities remains in effect.  Should you have questions about whether specific practices are permitted, please contact IPA Chief Legal Counsel Brian Granahan at [email protected].