This document outlines proposed updates to the Illinois Solar for All (ILSFA) Approved Vendor Manual. The Program Administrator is publishing this draft of the updated Approved Vendor Manual to provide several clarifications and ensure ILSFA guidelines remain consistent with the 2022 Long-Term Renewable Resources Procurement Plan (the 2022 Plan).

The Illinois Power Agency (the Agency) and the ILSFA Program Administrator are seeking feedback on the proposed changes to the Approved Vendor Manual. Specific questions on which feedback is sought are found below. Commenters need not respond to each question and should not feel limited by these questions in providing feedback. A list of substantive updates to the Approved Vendor Manual is provided in Section 19.1. Comments are welcome from both stakeholders in ILSFA as well as from other interested parties.

In general, responses will be made public and published on the ILSFA website (IllinoisSFA.com). However, should a commenter seek to designate any portion of its response as confidential, that commenter should provide both public and redacted versions. Independent of that designation, if the Agency or the Program Administrator determines that a response contains confidential information that should not be disclosed, it reserves the right to provide its own redactions.

The Program Administrator and the Agency will also be seeking stakeholder comment at a later date to inform the implementation of the Pilot Program on Home Repairs and Upgrades and the Program Delivery Pilot found respectively in Sections 8.5.3.3 and 8.5.3.4 of the Plan.

Responses are due by no later than Friday, October 7, 2022, at 12:00 PM CDT and should be sent to comments@IllinoisSFA.com.

The Agency and the Program Administrator are seeking the following feedback:

• Energy Sovereignty
  • Community Solar:

    • Section 2.3 Illinois Solar for All: Section 8.2.2 of the 2022 Plan allows Community Solar Sub-program projects that promote energy sovereignty and are structured as cooperatives to charge a “nominal fee” as an up-front cost to a participant to join the cooperative.

      The Agency and Program Administrator are interested in stakeholder input on methodologies to establish a cap for that nominal fee that is consistent with financing models being used or under consideration for use on ILSFA energy sovereignty projects. 

    • Section 4.3 Community Solar Project Eligibility has a list of requirements for how projects within the Community Solar sub-program can qualify as energy sovereignty projects for the purpose of the Project Selection Protocol under either an ownership model or cooperative model.

      Are the contract types and specifications sufficient to capture the breadth of ownership models? Are there additional requirements that should be added to require a certain percentage of ownership shares beyond a majority (>50%) ownership threshold?
      
      What additional consumer protections or customer contract requirements are needed to define how Energy Sovereignty Ownership subscriptions are sold?

      How should ownership turnover be measured in terms of maintaining subscription levels for Community Solar projects?

      The Program Administrator and Agency are interested in feedback on allowing for-profit anchor tenant owners in Energy Sovereignty Community Solar projects.  For-profit anchor tenants could represent either corporate or small- and/or locally-owned businesses.

  • For Non-Profit and Public Facility or Residential Energy Sovereignty projects, what additional consumer protections or customer contract requirements are needed to ensure that buyout structures before year seven meet the intent of the law to “ensure that local people have control of the project and reap benefits from the project over and above energy bill savings?”
• Income Verification and Eligibility

  • In Section 6 Project and Participant Verification, the Program Administrator provides a list of categories that are or are not considered as income. This list was initially formed as part of the program’s development phase with the input of stakeholders and is meant to align with LIHEAP guidelines (which is the most frequently used 3rd party income verification method).

    Given the updates to the 80% AMI income limits, and other Program changes since initial program development, are there other changes that should be made to this list?

• Tangible Benefits

  • In Section 2.2 Illinois Solar for All: Community Solar Sub-program and in Section 5 Tangible Benefits and Value to Participants, language was added to clarify the process of identifying tangible benefits for residents of master-metered residential buildings.  Benefits must be available and communicated to all tenants of master-metered residential buildings, regardless of income level, and cannot represent necessary repairs or renovations.  This creates a challenge of ensuring residents are seeing benefits while not creating an overly burdensome system of ongoing tracking and verification.

    The Program Administrator is interested in feedback on this process and if additional information would be helpful to streamline the process for both Approved Vendors and building owners to collect and submit information initially and on an ongoing basis.

• Project Submission Process

  The 2022 Plan included a number of changes to the project submission process to increase participation, lower soft costs, and simplify customer acquisition procedures including:

  • Extending the time period during which the Program Administrator-provided income verification is valid from 6 to 12 months (Section 2.1).
  • Eliminating the requirement to present and sign the disclosure form seven days prior to consummation of the contract along with extending the cancellation period to simplify the participant engagement process.
  • Removing the minimum batch requirement (Section 8.1) and improving the project submission experience.
  • Redesigning the disclosure forms for ILSFA to shorten and simplify the documents.
  • Expanding Method D of Income Verification for Community Solar subscribers, allowing use of income affidavits to document eligibility for residents of Income-Eligible Census Tracts, where at least half the households are below 80% AMI (Section 6).
  • Adding Approved Vendor Photo Guide to Approved Vendor Manual (Section 14).
  • Removing prioritization of FEJA Workforce Development trainees for ILSFA job training requirements (Section 15).
  • Removing required proof of satisfying non-ministerial permit requirements (Section 8.4).

The Program Administrator and Agency believe the Program should maintain robust protections against gaming, substandard work, and a negative customer experience, but are open to feedback on further process improvements.

The Illinois Solar for All Program Administrator will be presenting proposed changes to the Approved Vendor Manual on Tuesday, September 27, at 2:00 PM CDT. This is an opportunity for stakeholders to ask questions and share feedback. The proposed Approved Vendor Manual document has been posted on the website.

Please register for the session.