Illinois Commerce Commission Approves Long-Term Renewable Resources Procurement Plan

Husch Blackwell LLP

The state of Illinois continued its push to achieve 100 percent renewable energy by 2050 when, on July 14, 2022, the Illinois Commerce Commission (ICC) approved the Illinois Power Agency’s (IPA) 2022 Long-Term Renewable Resources Procurement Plan (LTRRPP) and finalized rules and programs established under the Climate and Equitable Job Act (CEJA), which passed in September 2021. The LTRRPP is a guidebook for CEJA’s implementation, and its approval authorizes over $1.1 billion to procure new renewable generation in Illinois over the next two years by helping to fund renewable energy projects across Illinois.

The LTRRPP is required under CEJA and is designed help Illinois achieve 100 percent clean electricity by 2050. The ICC must ensure that Illinois utilities Ameren Illinois Company (Ameren), Commonwealth Edison Company (ComEd), and MidAmerican Energy Company (MidAmerican) procure renewable energy credits (RECs) to meet renewable portfolio standard (RPS) compliance requirements. With the passage of CEJA, the RPS expanded Illinois’ goal to 40 percent renewable energy by 2030, 50 percent by 2040, and 100 percent by 2050.

Importantly, the 2022 LTRRPP approves six procurement blocks under the Adjustable Block Program (ABP) instead of three, as in prior years. The original three blocks included small distributed generation, large distributed generation, and community solar. With the approval of the LTRRPP, three additional blocks have been added that will incorporate incentives for solar panels at public schools, community-driven community solar facilities, and Equitable Eligible Contractors, which benefits disadvantaged businesses in the renewable energy sector.

A chief objective of CEJA is to expand the low-income program, Illinois Solar for All (ILSFA). ILFSA’s goal is to achieve at least 25 percent of program incentives to be utilized in environmental justice communities. As a result of the ICC’s approval of the LTRPP, ILSFA is broadened by enabling low-income and environmental justice communities to access and benefit from the program. For example, the LTRRPP expands access to solar energy for residential customers and specifically for low-income residents by creating new customer classes for renters, and a pilot program will provide roof repairs to low-income residents so that they can install rooftop solar facilities. Contractors seeking RECs must also meet minimum criteria for equity and inclusion in their workforces to receive beneficial price adjustments during the competitive bidding process for various programs.

In May, the IPA announced that it would transition to a new program administrator, Energy Solutions (formerly Inclime), which will use the LTRRP to create a detailed proposal for how renewable energy project developers and customers can participate in the various incentive programs. The IPA has 60 days to submit a compliance file based on the LTRRPP. When the ABP and ILSFA incentives reopen in the fall, it is expected that various parties will begin applying to take advantage of the new opportunities available in Illinois.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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