A number of the Low-Income Community Solar (LICS) projects submitted during the PY4 submission window are co-located projects. The Project Selection Protocol and the Vendor Manual address how co-located projects should be handled in various scenarios. The particular instance of co-located projects that are individually sized such that each individual project could receive one point value, but the combined size of the two projects is over the threshold for a different point allocation, is not specifically addressed with in the Project Selection Protocol, but is discussed in the Approved Vendor Manual. This communication is intended to clarify how points will be allocated in this particular scenario.
As described in Table 2. Low-Income Community Solar in the ILSFA Project Selection Protocol Guidance Document, points are given based on the size point categories of:
< 100kW = 1.5 points
101-500kW = 1 point
501-1000kW = 0.5 points
This clarification applies to co-located projects that are sized such that they individually fall in one size point category, but when considered as co-located and added together the total size is in another size point category. For Project Selection, the size point category for proposed co-located projects is always the totaled size, whether on a single parcel or contiguous parcels. For example, two co-located projects that are each 275kW would each receive 0.5 points based on a combined size for the co-located systems of 550kW rather than 1 point each based on the individual 275 kW size.
This determination is based on the co-location guidelines described in the Approved Vendor Manual in Section 10.8 Co-location. This section makes a distinction between co-located projects located on either a single parcel or on contiguous parcels. On page 89 under Co-location of Low-Income Community Solar Projects, paragraph 3 states:
“3. Multiple projects up to 2 MW in aggregate on the same parcel with the same owner will be considered a single project for the purposes of REC pricing as well as size criteria in the case of a lottery.”
If the systems are on contiguous parcels, paragraph 5. applies:
“5. If there are multiple projects owned or developed by a single entity (or its affiliates) located on one parcel of land or on contiguous parcels of land, any size-based adders will be based on the total size of the projects owned or developed on the contiguous parcels by that single entity or its affiliates.”
Although the manual doesn’t explicitly state whether the multiple projects need to be selected projects or proposed projects for this to apply, paragraph 3 does state that the co-located projects’ total size needs to be considered in the case of a lottery (in this case project selection is a “lottery”). Therefore, use of the combined size of the co-located projects to determine the size point category is indicated before selection occurs.
Similarly, although paragraph 5 does not explicitly state how to allocate size points to co-located projects located on contiguous parcels of land, its reference to size-based adders being based on the “total size of the projects” also indicates the intent to view co-located projects based on the total combined size.
If an Approved Vendor wishes to drop one of the co-located projects they may do so before 12PM CDT on October 22, 2021 by notifying their Approved Vendor Manager in writing, and the remaining project will receive points based solely on the size of the remaining project.