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ALJ Issues Proposed Order Approving 2024 Long-Term Renewable Resources Procurement Plan With Modifications
The administrative law judge (ALJ) issued proposed order (PO) approving the 2024 long-term renewable resources procurement plan with modifications Of note, the PO:
(1) declines to approve post-award contract changes to indexed REC contracts, sharing “both the concerns of ComEd that post-award contract changes could undermine the competitive process and the concerns of the IPA that Illinois’ RPS goals could be hampered by projects becoming uneconomic,” but said that no limitations should be placed on workshop discussions, “In other words, it may be appropriate that there be no post-award changes or if there are post award changes, they may be negotiated or based on a formula and might result in higher or lower REC prices”;
(2) declines to adopt Clean Grid Alliance’s non-photovoltaic (non-PV) community renewable generation proposal as impractical, but directs IPA to “again request information regarding the level of interest in non-PV community renewable generation for the next iteration of the LTRRPP,” including “looking at whether projects such as this are economically viable”;
(3) “adopts the IPA’s position to maintain the establishment of a DG subcategory for the EEC category and to extend the amount of time that the capacity would be held open for behind-the-meter projects from nine months to eleven months”;
(4) adopts ComEd’s proposed modifications to the REC pricing model to correct for failure “to recognize the core principle that a fixed price paid today has greater value than the same fixed price paid in the future”;
(5) notes that IPA agrees with parties’ “various arguments regarding the revenue streams available to community solar projects and whether they are accurately reflected in the REC Pricing model“ and will make appropriate corrections, and “agrees with the IPA that it should consider whether an update” to “the assumed 80/20% split between developers and subscribers” would “be appropriate for the next Long-Term Plan”; and
(6) encourages IPA to continue discussion with stakeholders of an economic incentive for AVs that assist stranded customers in the form of a ‘REC adder’ – that is, an increased price in the REC Contract for RECs generated by projects that were stranded and then ‘unstranded’.”
Order (01/16/2024)
ICC Docket No. 23-0714 (10/20/2023)
