A number of for profit, non profit and public sector organizations have filed objections to the Illinois Power Agency (IPA) Long-Term Renewable Resource Procurement Plan, which was filed with the Illinois Commerce Commission on December 4. The plan is derived from the Future Energy Jobs Act (FEJA), enacted in December 2016. The FEJA programs include community solar and the low and moderate income Illinois Solar For All.
Fifteen objections, filed by December 20, were specific in nature as the petitioners were generally supportive of the plan as a whole. A summary of objection items are as follows:
- The use of spot renewable energy credits (RECs), especially in 2018 and 2019, is at the risk of not having RECs available for long term projects further out from 2020 on to the end of the program in 2026.
- The ability to meet the 25% renewable portfolio standard (RPS) goals by 2030 is at risk with the exhaustion of REC funding.
- RECs should not be front loaded in incentive payouts.
- Annual REC delivery requirements should be eliminated in favor of total production requirements.
- Consumer protection proposals should be modified to fit within the existing statutory framework.
- The Illinois Solar For All (ISFA) Program had no public stakeholder involvement.
- The incentive levels under ISFA should be set to ensure no cost to low-income households.
- The REC values under ISFA should be passed onto participants.
- Single (1-4 unit) and multi-family (more than 5 units) residences should have their own program.
- ISFA community solar REC funding levels are not sufficient.
- Better modeling of costs and assumptions of low-income solar projects are needed.
- IPA should allow ISFA program administrators to use subcontractors to maximize benefit of community participation.
- There should be a residential carveout for community solar.
- The ISFA community solar pilot projects should not be evaluated solely on price.
- There should be allowance for direct current (DC) as well as alternating current (AC) connected PV systems.
- Alternative compliance payments from alternative retail electric suppliers (ARES) should be used right away instead of being held in reserve.
- Competitive procurement of RECs should be used instead of forward (posted) procurement.
- Projects located in municipal utility and rural electric cooperative territories should not be permitted to participate in adjustable block funding, community renewable generation (essentially community solar) or the ISFA.
- Additional criteria is needed for contracts assigned from original approved vendors (AV).
- No marketer or generator should sell power to an end user without being an ARES or a utility.
- Collateral minimums for projects provided by AVs should be increased from 5% to 10% of total value.
- Clarification is needed for coordination of project and subscription data on projects, as well as coordination of IPA and utility contracts.
- Adjacent state (installations located in Wisconsin, Indiana, Kentucky, Missouri and Iowa) requirements need to be modified.
A hearing schedule will be set by the ICC for January and February, 2018. A draft order is expected by early March, 2018. The Commission must issue an order to approve the IPA Plan or amend it by April 3, 2018.