Self-direct Frequently Asked Questions
- Annual REC Retirement Quantity
- The application asks for the Annual REC Retirement Quantity. What is this term designed to capture?
- Can the IPA treat the Annual REC Retirement Quantity as confidential if requested by the applicant?
- Can the Annual REC Retirement Quantity be adjusted year-to-year without having to submit a new application or update the application?
- Renewable Contract Documentation
Annual REC Retirement Quantity
The application asks for the Annual REC Retirement Quantity. What is this term designed to capture?
This is the quantity of RECs that will be used to determine if the applicant is eligible for participation. It must be at least 40% of the customer’s annual load. Please provide a quantity that can be verified against the contract provided.
Can the IPA treat the Annual REC Retirement Quantity as confidential if requested by the applicant?
Generally, the Annual REC Retirement Quantity would not be considered confidential. An applicant may request confidential treatment of the Annual REC Retirement Quantity, however for that treatment to be considered, the applicant must provide an explanation of why the Annual REC Retirement Quantity should be treated as commercially sensitive information.
If the Agency were to grant confidential treatment, the Agency notes that it plans to publish aggregate information about program size and if there is limited participation (e.g., one or two participants in a given service territory), the Agency would reserve the right to publish that program size as a range. For example, if there is one participant in a utility service territory and their Annual REC Retirement Quantity is 40,000 RECs, the Agency could publish that the annual program size in that utility service territory is between 30 and 60,000 RECs. A similar principle would apply if there are only two participants, because publishing a fixed number would allow one participant to determine the Annual REC Retirement Quantity of the other.
Can the Annual REC Retirement Quantity be adjusted year-to-year without having to submit a new application or update the application?
Yes, the Annual REC Retirement Quantity may be updated each year but may not go below the initially established 40% threshold. However, please note that bill crediting is based on the customer’s entire load and thus will not be directly impacted by the Annual REC Retirement Quantity.
Renewable Contract Documentation
Applicants are required to upload a copy of their renewable energy contracts. Will the IPA accept excerpts of contracts if those excerpts clearly show relevant supporting information?
Full copies of contracts must be submitted so that the IPA may verify that there are not any terms inconsistent with the provisions of the Self-direct Program. An applicant may redact confidential or commercially sensitive information.
If an applicant is accepted for the upcoming program year but for some reason decides to leave the program in a future year, would that customer need to provide notice by a certain date?
As required by Section 1-75(c)(1)(R)(5)(vi) of the Illinois Power Agency Act (and as certified in 1.i of the Self-direct Application Form) applicants must certify that they intend to maintain their REC delivery contract for the duration of the length of the contract. However, the Agency recognizes that there could be circumstances that lead to a customer having to withdraw from the program. As program size and bill crediting is determined on an annual basis for the energy delivery year starting each June 1, the Agency would request a notice of withdrawal be received no later than March 15 to provide time for proper notice to the utility so that bill credits for that delivery year are not applied.
The Agency also notes that Section 1-75(c)(1)(R)(6) of the Illinois Power Agency Act addresses the situation wherein a participating customer fails to procure and retire sufficient RECs during a delivery year, by allowing the Agency to petition the Illinois Commission to have the applicable utility recover wrongfully issued bill credits and interest.
Using the upcoming 2023/2024 program year as an example, does “the previous year” mean the program year that just ended (i.e. June 2023-May 2024), the previous program year (June 2022-May 2023) or the previous calendar year (Jan 2023-Dec 2023)?
Section 6.9 of the IPA’s Long Term Renewable Resource Plan, item 3 notes that participating Self-Direct customers will need to provide, “The actual energy usage at the facilities participating in the program during the previous year, based on the accounts of participating customers.” The previous year refers to the delivery year ending May 31, 2024.