IPA Files LTRRPP for ICC Approval

Posted December 19th, 2017 by SRECTrade.

On December 4th, the Illinois Power Agency (IPA) filed its Long-Term Renewable Resources Procurement Plan (LTRRPP or the Plan) for approval by the Illinois Commerce Commission (ICC). The Plan is part of the implementation of Public Act 99-0906 (the “Future Energy Jobs Act”), which took effect on June 1, 2017.

The initial ICC Filing, including the Filing Petition, Filed Plan and appendices, and the redline comparison of the draft Plan and the Filed Plan are available on the IPA’s website here.

In response to comments received on the draft Plan, the IPA made several changes to the Filed Plan, including changes to the following:

  1. REC Pricing Model – changes to the input data and structural assumptions in the CREST-based model used to create prices for the Adjustable Block Program (ABP)
  2. Collateral Requirements – reducing the required collateral percentage from 10% of contract value to 5% for the ABP
  3. Consumer Protection – includes adjustments to Approved Vendor requirements and the removal of duplicative or unnecessary requirements
  4. 10 – 25 kW System Size Adder – the addition of a new size category of 10 kW – 25 kW
  5. Initial Block Subscription Cap – reducing the minimum opening window for Block 1 from 60 days to 45 days; imposing a 200% capacity threshold; and proposing a lottery system for applications received after the budget is exceeded
  6. “Green Marketing” Challenges – adopting a proposal presented by several commenters to develop a “brand” for participation in the ABP and to develop content around that brand, explaining the value of participation
  7. Calculation of Load for MidAmerican – slight increase in MidAmerican’s RPS goals and budgets
  8. Single Approved Vendor Model – imposing a 100 kW minimum project size Single Approved Vendor category
  9. Allocation of Alternative Compliance Payment (“ACPs”) – proposing that the balance of payments made during the transition period be held in reserve for future years’ programs and procurements
  10. Voluntary Capacity Factors – allowing for Approved Vendors to submit a voluntary capacity factor based on PV Watts or an equivalent tool
  11. “Small Subscriber” Community Solar Participation
  12. Adjustable Block Program Group Organization – allocating the service territories of any rural electric cooperatives and municipal utilities within MISO to Group A, and any such territories within PJM to Group B, including moving MidAmerican to Group A
  13. Brownfield Site Procurement Volume
  14. Co-Location Restrictions for Developers

The IPA provided a summary of the above changes, and those proposals not accepted, in its Filing Petition.

In addition, the revised Block Group REC Price schedule is provided below (Table 6-2 of the Plan):

Block Group REC Prices ($/REC)

Objections were due on December 18, 2017 with responses to objections due on Thursday, January 11, 2018. Replies to responses will then be due on Thursday, January 25, 2018. The ICC is expected to issue its decision by April 3, 2018. The ICC docket for the plan is accessible here.

Visit our blog for previous and future posts about Illinois’ RPS and the Long Term Plan.

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