The Climate and Equitable Jobs Act (CEJA) was enacted in September of 2021 and is the second major piece of legislation in Illinois impacting community solar in a meaningful way. The first bill, the Future Energy Jobs Act (FEJA) established two major programs: the Adjustable Block Program (ABP), also known as Illinois Shines, and Illinois Solar For All (ILSFA) which is a separate low-income solar program. CEJA updates and expands those programs.
CEJA creates a framework through which Illinois:
By the end of 2022, Illinois had 181 megawatts (MW) of installed capacity across 93 projects. The third-party Program Administrator, Energy Solutions, oversees both the ABP and ILSFA. The ABP is a state-administered program for new solar photovoltaic systems which provides payments in exchange for 20 years of Renewable Energy Credits (RECs) for what Illinois refers to as Traditional Community Solar (TCS). The TCS category makes up at least 30% of the ABP’s overall capacity but has exceeded the minimum in previous program years.
The ABP has no low-to moderate-income (LMI) carveouts. ILSFA is the program that focuses on increasing renewable energy generation benefits for LMI households and communities. However, the incentives in the Inflation Reduction Act (IRA) will likely ensure LMI participation in non-ILSFA projects in Illinois is at least at parity with federal guidelines.
Each year, Illinois opens the development of new renewable energy resources in “blocks” of Megawatts. The current block has 250 MWs available for development. The block is further divided into 2 groups based on the major utility’s (Ameren Illinois & ComEd) coverage areas.
The ILSFA program is an incentive program that supports community solar development to benefit low-income households and communities in Illinois through the purchase of RECs. With the passage of CEJA, the ILSFA program has an increased annual budget of $70 million to support its programs:
When the Traditional Community Solar Block reopened, a total of 262 applications were received totaling nearly 700MW, nearly 3 times the available capacity for the program year. Click here to see the program capacity available and application processing statuses.
For the 2022 block which opened November 1, 2022, some updates were made to clear the waitlist and facilitate the transition from a lottery project selection system that existed prior to CEJA’s updates to the ABP, to a first come, first serve basis with minimum scoring criteria to be placed on the new waitlist. Those updates allowed that projects that were originally eligible for the lottery system must meet a small subscriber requirement and placed a cap on capacity awards for developers. In the following program years, projects should meet the criteria below.
Minimum Equity Standard & Equity Eligible Contractors
In the update to the ABP, Illinois underscored the importance of ensuring the transition to renewable energy prioritizes people and communities that have been excluded form economic opportunities in the energy sector and subjected to disproportionate levels of pollution and subsequent negative public health outcomes. In pursuit of a more equitable system, the Minimum Equity Standard (MES) requires participants in the ABP to ensure economic opportunities are more fairly distributed to all Illinoisans.
Starting in Energy Year (EY) 2023-2024 beginning June 1st, 2023, each Approved Vendor and designee must include a minimum of 10% Equity Eligible Persons (EEP) in their workforce, rising to a 30% minimum by 2030.
A new category called Equity Eligible Contractors (EEC) has been incorporated into the ABP program both with an exclusive block of capacity as well as a certification for the contractors themselves. Project selection scoring criteria heavily favors the use of EECs for the project development process.
Prior to reopening the Traditional Community Solar Block for applications on Nov 1, 2022, IPA released the Final Project Selection Guidelines to outline the criteria projects would have to meet in order to secure a spot on the waitlist for capacity in program year 2023 in the event that more applications were received than was available for program year 2022, a reasonable expectation given the previous popularity of this program. A minimum score of 5 points is needed to obtain a capacity reservation on the waitlist.
The same requirements are in place for Program Year 2023-2024. Click here for the Program Year 2023-2024 Guidebook.
Waitlist Scoring Criteria:
Refer to the Final Project Selection Guidelines for a full explanation of the scoring criteria.
Community solar subscribers will get credit on their electric bills at the price to compare rate for each kWh their subscription produces. This portion of the customers’ bill pays for electricity generation, as opposed to distribution, and usually accounts for about half of the electricity rate paid by residential customers in Illinois.
Project value comes from three sources:
REC Proces for TCS 2023-2024
|Group A||Group B|
|0 - 25 kW||$71.10||$82.37|
|25 - 100 kW||$76.16||$93.61|
|100 - 200 kW||$78.33||$95.12|
|200 - 500 kW||$73.02||$84.10|
|500 - 2000 kW||$63.72||$71.80|
|2000 - 5000 kW||$49.33||$53.31|
Rate Classes & Adders
Projects selected after February 18, 2020, or Program Year 2021 and later have the Small Subscriber Adder incorporated into the REC price. Refer to the program guidebook for the Small Subscriber Adder if your project was selected prior to this change.
Small Commercial Rate Classes:
Consolidated Billing Option
CEJA creates an option for Utility Consolidated Billing (UCB) by allowing owners/operators of a CS project to enter into a net crediting agreement with the utility. The utility can charge a net crediting fee to the CS operator at a maximum of 2% of the bill credit value.
ComEd has outlined their consolidated billing option, called Community Supply Subscription Billing (CSSB), in their Community Solar Handbook Chapters 4 and 5. CSSB would apply to all subscribers of a project and any subscriber using a Retail Electric Supplier (RES) and using a single bill option (SBO) cannot participate in consolidated billing for community solar.
As of April 2023, Ameren has yet to publish guidance for their consolidated billing option.
The Illinois market is split between two major investor-owned utilities: Ameren Illinois and ComEd. The IPA is in the process of details surrounding the dual use potential of agricultural land for CS projects, which would make more parcels available in each utility’s respective service area.
Since the establishment of the MES, the use of EECs for future project development will likely be sought for many projects. Additional points for that category include various degrees of involvement for EECs, meaning if a project cannot achieve a maximum score by being an EEC Approved Vendor, points can still be attained in that category.
The ABP’s small subscriber requirement notable includes both residential and commercial subscribers as eligible small subscribers. However, with the expanded Investment Tax Credit (ITC), it is likely that residential subscribers – especially LMI subscribers – will be highly sought after to achieve the maximum possible ITC bonus. This ensures that the LMI market will be competitive outside of the ISLFA program.
|Group||Category||Block 1, Block 2, Block 3||Block 4||Block 5||Block 6|
|Group A (Ameren Illinois, MidAmerican, Mt. Carmel Public Utility)||Traditional Community Solar||Approved Projects submitted before February 13, 2019 - Assigned by lottery||Not accepting applications||Opened November 1, 2022 - First come, first serve||Opened June 1, 2023 - First come, first serve|
|Group B (ComEd)||Traditional Community Solar||Approved projects submitted before February 13, 2019 - Assigned by lottery||Not accepting applications||Opened November 1, 2022 - First come, first serve||Opened June 1, 2023 - First come, first serve|
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