Posts Tagged ‘Illinois SRECs’

Illinois Power Agency Releases Draft Long-Term Renewable Resources Procurement Plan

Posted October 5th, 2017 by SRECTrade.

On September 29, 2017, the Illinois Power Agency (IPA) released its Draft Long-Term Renewable Resources Procurement Plan (the Draft Plan). The Draft Plan has been released for comment pursuant to Section 16- 111.5(b) of the Public Utilities Act and Sections 1-56 (b) and 1-75(c) of the Illinois Power Agency Act as recently modified by Public Act 99-0906, which went into effect on June 1, 2017.

The Draft Plan sets out the procurements and programs that the IPA has proposed in order to meet the Renewable Portfolio Standard (RPS) requirements contained in Section 1-75(c)(1) of the Illinois Power Agency Act, including the Adjustable Block Program and the Illinois Solar for All Program. This post provides a summary of the statutory process and a brief overview of the Adjustable Block Program (ABP) as presented in the Draft Plan, but does not contain detail on other elements of the plan, including competitive procurements, the Illinois Solar for All Program, or the Community Renewable Generation Program. For more details on these elements of the plan, please refer to the Draft Plan here.

Statutory Process

The IPA is accepting public comments on the Draft Plan for 45 days. Comments must be submitted to Mario Bohorquez, Planning and Procurement Bureau Chief, at by November 13, 2017.

In addition to accepting public comments on the Draft Plan until November 13, 2017, the IPA will host three public hearings to accept in-person public comments. The dates and locations of these meetings are as follows:

  • Thursday, October 26, 2017, 3:00 pm – 4:30 pm CT: Illinois Commerce Commission Springfield Office, 527 East Capital Ave, Springfield, Illinois. Hearing Room C.
  • Tuesday, October 31, 2017, 10:00 am – 12:00 pm CT: Illinois Commerce Commission Chicago Office, 160 North LaSalle Street, Chicago, Illinois. Room N808.
  • Friday, November 3, 2017, 3:00 pm – 4:30 pm CT: MidAmerican Moline Customer Office, 716 17th Street, Moline, Illinois.

The IPA has 21 days following the end of the 45-day comment period to revise the Draft Plan and to file the Plan with the Illinois Commerce Commission (ICC). Based on the timeline presented by the IPA, April 3, 2018 is the deadline for the ICC to enter its order confirming or modifying the Plan. Please refer to the IPA Cover Letter and Hearing Notice for a full overview of the statutory deadlines and timeline.

Adjustable Block Program Overview

The Adjustable Block Program (ABP) features capacity-based blocks set at pre-determined prices for 15-year REC contracts. Key elements of the ABP model include the following, which are detailed in turn:

  1. Project Eligibility
  2. Program Administration & Application
  3. Block Structure & Transition between Blocks
  4. REC Target & Allocation
  5. Pricing
  6. Contract Payment Terms
  7. Performance Assurance & Delivery Requirements

Project Eligibility

There are two types of “new” projects that are eligible for the ABP. “New” is defined in the Draft Plan as “energized on or after June 1, 2017”.

The two project types are:

  1. Photovoltaic distributed renewable energy generation devices (i.e., DG solar); and
  2. Photovoltaic community renewable generation projects (i.e., community solar)

DG solar must be Illinois-sited and interconnected, behind-the-meter, and less than or equal to 2,000 kW AC. Refer to Section of the Draft Plan for full project eligibility requirements.

Section 6.12.1 of the Draft Plan sets forth additional technical system requirements, including system documentation and metering requirements.

Program Administration & Application

The IPA will conduct an RFP for a Program Administrator to run the day-to-day operations of the Adjustable Block Program. The Program Administrator responsibilities will include program and contract management, application review and approval, providing program information for the public, and more.

Participation in the ABP “will take place through, and conditional upon, an Approved Vendor process” proposed by the IPA. Approved Vendors will be required to meet certain criteria and agree to certain terms set forth in the Draft Plan. The use of Approved Vendors will ensure program efficiency and protect Illinois consumers from “bad actors”.

Approved Vendors will submit projects bundled into batches of at least 100 kW and up to 2 MW. Once an Approved Vendor has successfully submitted five batches, the minimum size of a batch for that Approved Vendor will increase to 250 kW. However, the IPA sets forth special exemptions for minority-owned and female-owned businesses. For each project, there will be a non-refundable application fee of $10 per kW, not to exceed $5,000.

Once approved, each batch will result in one contract with one utility. That is, a batch of systems will be contracted with one utility on a portfolio basis. However, the price for the RECs for each system within a batch will be based on the price available within the applicable block on the date of the submittal (see sections below for more on blocks, categories, and pricing). In addition to the non-refundable application fee, there are collateral requirements. See below for information regarding contracting credit requirements.

Project Development Timeline and Extensions

It is not required that projects be energized or interconnected at the time of application. However, all projects will be subject to the following timelines and extensions (based on the contract execution date):

  • DG projects: one year to be developed and energized
  • Community solar projects: 18 months to be developed and energized and to demonstrate that they have sufficient subscribers

The IPA sets forth certain permissible extensions under Section 6.15.2.

Block Structure & Transition between Blocks

Each block will be for a specified quantity of nameplate capacity with a specific REC price. When a block reaches its subscription capacity, projects will be eligible for the next block and its block price.

For each Block 1 as summarized in the table below, all projects submitted within 60 days of the program opening date will be included in that Block 1, regardless of subscription to the block.

For subsequent blocks, each block will be held open for 14 days after the block is fully subscribed. The IPA will announce when a block has been filled and when the closing date will be.

REC Target & Allocation

The initial REC target for the ABP is to have 1,000,000 RECs delivered annually by the end of the 2020-2021 delivery year (i.e., May 31, 2021). Based on a blended 17% capacity factor, this amounts to roughly 666 MW of new photovoltaic generation. However, the IPA notes in its Draft Plan that this goal is not a cap and that, subject to demand and budget constraints, there is potential for additional capacity.

The blocks will be divided into two groups by service territory/geographic category and then further allocated by project category as follows:

Block Groups
  • Group A: for projects located in the service territories of Ameren Illinois, Mt. Carmel Public Utility, and rural electric cooperatives.
  • Group B: for projects located in the service territories of ComEd, MidAmerican, and municipal utilities.
Project Category Allocations

Section 1-75(c)(1)(K) of the Act requires a 25% each allocation for four categories:

  1. DG PV systems less than or equal to 10 kW (“Small systems”);
  2. DG PV systems greater than 10 kW and up to 2,000 kW (“Large systems”);
  3. PV community solar; and
  4. remainder to be allocated by the IPA.

Since it is too soon for the IPA to appropriately allocate the “remainder” category in any other manner, the IPA will distribute the 25% remainder amount evenly, for an allocation of 33.3% in each category 1-3. The IPA will revisit, review and reallocate the 25% remainder amount as needed in the Plan Update.

Accordingly, the 666 MW allocation is summarized by the IPA as follows:

Illustrative Block Opening Volumes (MW)

Capacity Factors

The IPA set a 16.4177% capacity factor for fixed-mount systems and a 19.3149% capacity factor for tracking systems. Accordingly, the estimated REC production would be as follows:

  • Fixed-Mount Systems: 21 RECs over 15 years per 1 kW AC
  • Tracking Systems: 25 RECs over 15 years per 1 kW AC


The IPA adapted its REC Pricing Model from the CREST model developed by the National Renewable Energy Laboratory (NREL). The IPA modified the CREST model’s “input assumptions and post processing of the results.” IPA cautions in its Draft Plan that the prices summarized in the table below “should be viewed as preliminary in nature and not necessarily the prices that will be offered once programs launch, and parties should not take actions in reliance on the availability of these preliminary proposed incentive levels.” Parties can review, explore and comment on the data used, assumptions made, and the REC Pricing Model itself through the public comment process.

Block Group REC Prices ($/REC)

For systems in the Large DG PV and Community Solar categories, the IPA set a base price for each category at the >500 kW – 2,000 kW level with adders to differentiate the price for RECs from different sized systems, as summarized above. The IPA proposes these adders in lieu of sub-dividing project categories by project size or type. Adders are discussed in further detail in Section 6.5 (Tables 6-3 and 6-4) of the Draft Plan.

As shown in the table above, REC prices will step down by 4% in each block after Block 1. However, the IPA will monitor performance during the blocks and may modify the price step-down based upon the speed at which each block is filled.

Contract Payment Terms

For systems that are accepted into the ABP with an executed contract for 15 years of REC deliveries, payment will be made as follows:

  • Full Prepayment for DG systems of no more than 10 kW, paid “at the time that the facility producing the [RECs] is interconnected … and energized.”
  • 5-Year Payment Term for systems larger than 10 kW and community solar projects, with 20% paid at the time of interconnection and energization and the remaining portion “paid ratably over the subsequent 4-year period.”

The standard for “energized” as it applies to contract payment is the “completion of the interconnection approval by the local utility and the registration of the system in GATS or M-RETS so that generation data can be tracked and RECs created.”

Performance Assurance & Delivery Requirements

The Draft Plan sets forth certain credit and delivery requirements to manage performance over the life of the contracts. The Approved Vendor will be required to post collateral equivalent to 10% of the total contract value when each Batch’s contract is approved.

The collateral amount will be maintained for the life of the batch contract, but can be reduced in the later years of the contract when the collateral amount exceeds the remaining value of the contract. This requirement will be maintained at the portfolio level, not the individual system level, to manage the risk of systems that under-perform or have other issues, balanced against projects that over-perform. Under certain conditions, failure to deliver RECs will result in the utility drawing on the collateral to be compensated for undelivered RECs.

Next Steps

SRECTrade intends to participate in the continued statutory process set forth above, and plans to participate in the ABP as an Approved Vendor in a capacity similar to its role in the SPV and DG procurements.

The IPA issued an Errata on the Draft Plan on 10/06/17, which is available here. The Block Group REC Prices ($/REC) table in this post has been updated to reflect these corrected prices.

SRECTrade at the Environmental Markets Association – Chicago Round Table: Illinois RPS Update

Posted July 7th, 2017 by SRECTrade.

On June 21, 2017, members of the SRECTrade team attended the Environmental Markets Association (EMA) round table event in Chicago.   The event featured presentations and discussions on a variety of environmental issues and new developments in Illinois environmental markets.   SRECTrade’s Manager of Business Development and Operations, Tom MacKenty was invited to speak about the new IL RPS and upcoming Adjustable Block Program.

Tom’s full presentation can be viewed HERE

While there are many details about the RPS and Adjustable Block Program forthcoming, SRECTrade has been actively monitoring the progress and posting information as it has become available.  A recent SRECTrade blog post with an outline of the program can be found HERE.

We will continue to provide updates as the rule making proceeds. As always, please feel free to reach out to us if you have specific questions.

SRECTrade Attends IPA’s 2017 RPS Workshops

Posted May 30th, 2017 by SRECTrade.

On May 17th and 18th, SRECTrade attended the Illinois Power Agency’s Renewable Resources Workshops. These workshops centered around the state’s new RPS and its components, including the Adjustable Block Program, Community Solar incentives, and the Illinois Solar For All Programs.

Overview of the New Illinois RPS and the Long-Term Renewable Resources Plan

The new RPS moves to a single compliance regime rather than having separate mechanisms for customers serviced by the alternative retail electricity suppliers (ARES). Under the old RPS, this retail choice lead to budget and target uncertainties. The goal of the new RPS will still be 25% renewables by 2025, but this target will now apply to all retail sales. The Future Energy Jobs Act, Public Act 099-0906, was signed into law on December 6, 2016 and can be read here.

The new law will take effect on June 1, 2017. Please see below for a draft timeline for the implementation of the RPS programs, as provided by the IPA in its Overview presentation:


Under the new RPS, Illinois is moving away from structured procurements for non-utility scale solar. Projects up to and including 2 MW in size will instead be eligible for participation in the new RPS’ Adjustable Block Program, or ABP, which will provide for 15-year REC contracts.

Key components of the ABP are:

  • Blocks have set sizes and prices that adjust between blocks, which the IPA may review
  • Eligible systems are those energized after June 1, 2017 (emphasis on new projects)
  • Transparent, upfront schedule of REC prices
  • 15 year REC contracts
    • Paid upfront and in full for systems 10 kW and below
    • 20% of contract price paid at interconnection/energization and the remaining portion paid over subsequent 4 year period for systems 10 kW-2 MW (DG or community)
  • The utility will be the counterparty to the executed contracts

The goal of the ABP is to ensure that solar projects are developed in diverse locations and that they are not overly concentrated. The IPA has yet to determine the number, size, categories, and prices of blocks as well as the application, contracting and delivery process. These issues will be resolved during the implementation process.

Community Solar

Community Solar will operate as a subset of the ABP with similar features and the same goal. Under community solar, an electric generating facility credits the value of electricity generated to the subscribers of the facility. A subscriber has a subscription of no less than 200 watts to a community renewable generation project and may total no more than 40% of the nameplate capacity of an individual project. At a high level, the provision for Community Solar Projects will mirror those for larger DG systems, but may differ in project development and application requirements.

Illinois Solar for All Programs

The goal of the Illinois Solar for All Programs is to bring solar PV to low-income communities in Illinois. The programs are distinct but will share aspects with the Adjustable Block Program for DG and Community Solar. The four programs are as followed:

  1. Low-Income Distributed Generation Incentive (22.5%)
  2. Low-Income Community Solar Project Initiative (37.5%)
  3. Incentives for Non-Profits and Public Facilities (15%)
  4. Low-Income Community Solar Pilot Projects (25%)

SRECTrade will continue to participate in the implementation proceedings for the new RPS. In addition, SRECTrade will server as an aggregator in the Fall 2017 DG Procurement. You can see the results from the Spring Utility DG Procurement here.

ICC Issues Final Order on IPA’s 2017 Procurement Plan

Posted December 15th, 2016 by SRECTrade.

On December 13, the Illinois Commerce Commission (ICC) issued its Final Order on the Illinois Power Agency’s (IPA) 2017 Procurement Plan. The 2017 Procurement Plan, which will include two DG procurement events, will govern the final series of procurements held under Illinois’ existing RPS provisions, before the state transitions to its new RPS.

The Plan calls for two DG procurement events, with an allocated $40 million budget for the procurement of an estimated 20 MW of DG resources. The DG procurements under the Plan will be unique from previous DG procurements in that the IPA will allow for speculative bids for systems under 25kW for the first time. This change, made in light of the success of the IL SPV Procurement Plan and in response to public support, is combined with a reduced $4/REC letter of credit for both identified and speculative systems.

The DG procurements will be for 5-year REC contracts for systems under 25kw (“small”) and systems 25kW – 2MW (“large”), with a 50:50 procurement split between small and large systems. Any such new and existing systems interconnected with Ameren, ComEd, MidAmerican (Illinois service territory only), Mount Carmel, Illinois municipal utilities or rural co-ops are eligible to participate in the procurement, including “speculative” (unidentified) projects. There is a 1 MW “bid minimum”, and RECs will need to be offered at a single, blended REC price per bid. Interested participants are encouraged to bid through aggregators in order to meet the 1 MW “bid minimum”.

Speculative systems will have nine months to identify systems, and all systems will have between nine months and one year from identification to commence delivery, depending on the system type.

The timing of the DG procurement event rounds will be contingent upon the IPA’s determination regarding an April 2017 contingency procurement under the SPV Plan and other factors. The final version of the 2017 Procurement Plan and future updates on the Plan will be posted on the IPA’s website here.

Illinois Passes New RPS, Comprehensive Energy Package

Posted December 2nd, 2016 by SRECTrade.

Following a whirlwind revival and numerous amendments, both chambers of the Illinois General Assembly voted late on Thursday to pass a comprehensive energy bill to address the state’s RPS, energy efficiency programs, net metering, nuclear plants, and more. SB 2814, the Future Energy Jobs Bill, is a product of nearly two years of negotiations between utilities, renewable energy stakeholders, environmental advocates, ratepayer advocates, and others. The 440-plus page bill underwent nearly 30 rounds of changes before passing 63-38 in the House and 32-18 in the Senate on the final day of the General Assembly’s veto session.

The energy package includes a sizable bail-out for Exelon’s struggling nuclear power plants–providing $235 million a year to Exelon for 13 years to keep the plants up and running. In return, the adjustment will allow Exelon’s utility subsidiary, Commonwealth Edison (ComEd) to spend roughly $400 million a year on energy efficiency programs. Costs to consumers will be capped at 1.3% over 2015 rates for business classes, and at 25 cents per month for ComEd’s residential customers.

In addition to the nuclear bail-out and energy efficiency programs, the Future Energy Jobs Bill will reform the state’s RPS policy. While Illinois’ RPS target will remain at 25% by 2025, the bill provides for new community solar, low-income, and brownfield solar targets. Distributed generation (DG) will be incentivized through an adjustable block incentive program, which will allow DG facilities to receive upfront REC payments in a 15-year contract with the Illinois Power Agency.

Thanks to the advocacy of the solar industry, ComEd’s proposed demand charge was eliminated from the final version of the bill, and retail net metering rates will be preserved with grandfathering up to a 5% statutory cap. Once the cap is hit, net metering rates will be replaced through a commission process to establish fair DG compensation based on locational grid value.

Governor Bruce Rauner (R) has already announced his support of the heavily negotiated bill. After Gov. Rauner signs the bill, it will take effect on June 1, 2017.

The Future of SRECs in Illinois – What Happens after the IL SPV Program?

Posted March 9th, 2016 by SRECTrade.

With the third and final round of the Illinois Supplemental Photovoltaic (SPV) Procurement Program under way, stakeholders are pondering what lies ahead for Solar Renewable Energy Credits (SRECs) in the State of Illinois. The bid for the Spring 2016 SPV Procurement Program (Round 3) will take place on March 31, 2016. The Illinois Commerce Commission (ICC) will issue its final decision on the results of the Procurement on or before April 6, 2016, when we will learn whether the Illinois Power Agency (IPA) spent the entire $15 million allocated for the final round. SRECTrade will publish another blog post with the results of the third round shortly after the ICC releases its decision.

For the Illinois SPV Procurement Program, the State appropriated $30 million of the Renewable Energy Resources Fund (RERF) to procure SRECs from solar photovoltaic (PV) systems energized on or after January 21, 2015. The $30 million budget was divided between the three procurement program rounds, with $5 million allocated for the first round, $10 million allocated for the second round, and $15 million allocated for the third round. The funds appropriated for each of the first two rounds were fully expended by the IPA.

What will happen next for Illinois remains indefinite. If the IPA awards $15 million worth of contracts in the final round, it is uncertain whether there will be a need for a fourth contingency event to take place in Spring 2017. Once the SPV Procurement Program comes to a close, the future of Illinois SRECs will once again destabilize. Although there is potential that solar PV facility owners could participate in other statewide Procurements, there is no long-term certainty for in-state SREC sales, as was made available by the SPV Program. Even more uncertain is whether the Illinois General Assembly will take up any energy bills this year to institute long-term solutions, either before or after the budget for FY2016 is adopted.

SRECTrade encourages PV facility owners in the ComEd utility service territory to apply for the Pennsylvania SREC market. Solar PV facility owners and installers may submit an online application to sell their SRECs in Pennsylvania by creating an SRECTrade account on our home page, and submitting an application for a new facility.

Please feel free to visit our Illinois and Pennsylvania Markets pages for more information on the SREC markets in these states.

If you have any questions about the SPV Program, you can view our introduction webinar and slides online here. You can also email us at, or call us at (415) 763-7732 ext 1. SRECTrade is also happy to address inquiries pertaining to our online application and the Pennsylvania SREC Market for Illinois facility owners and installers.