2025 Fall Indexed Wind, Solar, Brownfield, and Hydropower REC RFP (AIC, ComEd, and MEC)
Public Act 102-0662 (the “Climate and Equitable Jobs Act”) was signed into law and became effective on September 15, 2021. Public Act 103-0380, related to the procurement of RECs from certain hydropower projects, was signed into law and became effective on January 1, 2024. On October 20, 2023, the IPA filed its Long-Term Renewable Resources Procurement Plan (“2024 Long-Term Plan”) with the Illinois Commerce Commission (“ICC”) and the ICC issued a Final Order approving the 2024 Long-Term Plan with modifications on February 20, 2024. The IPA issued a final 2024 Long-Term Plan in accordance with this Commission Order on April 19, 2024. On August 21, 2025, the ICC granted the reopening of ICC Docket 23-0714 related to the 2024 Long-Term Plan. On October 16, 2025, the ICC issued an Order on Reopening in this docket modifying the 2024 Long-Term Plan.
A procurement for indexed renewable energy credits (“Indexed RECs”) from new utility-scale wind projects (projects over 5 MW), new utility-scale solar projects (projects over 5 MW), new brownfield site photovoltaic projects, and new hydropower projects at an existing dam or modernized or retooled hydropower projects at an existing dam was held on December 10, 2025.
The quantities to be procured were 2,963,078 RECs delivered annually from either new utility-scale wind or hydropower projects, 666,666 RECs delivered annually from new utility-scale solar projects, and 176,271 RECs delivered annually from new brownfield site photovoltaic projects.
Fall 2025 Indexed REC RFP Calendar (September 12, 2025)
Announcements – Fall 2025 Indexed REC RFP
Click here to view Indexed Wind, Solar, Brownfield, and Hydropower FAQs.
Fall 2025 Indexed Renewable Energy Credit RFP Results
- Indexed REC RFP Results (December 16, 2025)
- ICC Public Notice of Indexed Renewable Energy Credit Procurement Results (December 16, 2025)
FINAL Fall 2025 Indexed REC RFP Bidder Information Webcast
- Bidder Information Webcast Presentation (October 21, 2025)
- Bidder Information Webcast Recording (October 21, 2025)
FINAL Fall 2025 Indexed REC Contract Documents
- Final Indexed REC Contract (October 20, 2025)
- Form of Guaranty
- (AIC) Form of Guaranty (October 20, 2025)
- (ComEd) Form of Guaranty (October 20, 2025)
- (MEC) Form of Guaranty (October 20, 2025)
- Form of Letter of Credit
- Example of Delivery Year Requirement Calculation for Utility-Scale Solar and Brownfield Site Photovoltaic Project (November 25, 2025)
Redline Comparisons
- Redline (Final Indexed REC Contract vs Draft Indexed REC Contract) (October 20, 2025)
- Redline (Fall 2025 Final Indexed REC Contract vs Summer 2025 Final Indexed REC Contract) (October 20, 2025)
FINAL Fall 2025 Indexed REC RFP Documents
- Final Indexed REC RFP Rules (October 20, 2025)
- Appendix 2: Illustrative Part 1 Form (October 20, 2025)
- Part 1 Form: P1 Inserts Utility-Scale Wind Projects (October 20, 2025)
- Part 1 Form: P1 Inserts Utility-Scale Solar Projects (October 20, 2025)
- Part 1 Form: P1 Inserts Brownfield Site Photovoltaic Projects (October 20, 2025)
- Part 1 Form: P1 Inserts Hydropower Projects (October 20, 2025)
- Part 1 Processing (October 20, 2025)
- Appendix 3: Illustrative Part 2 Form (October 20, 2025)
- Appendix 4: Minimum Requirements for Letter of Intent or Memorandum of Understanding (October 20, 2025)
- Appendices 5-7: Standard Pre-Bid Letters of Credit – ELECTRONIC VERSIONS (October 20, 2025)
- Appendices 8-10: Standard Pre-Bid Letters of Credit – HARDCOPY VERSIONS (October 20, 2025)
- Appendix 11: Illustrative Bid Form (October 20, 2025)
- Appendix 12: Confidentiality Statement (October 20, 2025)
- Appendix 13: Sample Requests for Return of Cash (October 20, 2025)
- Appendix 14: Minimum Requirements for Letter of Intent or Evidence of Employment related to Equity Level commitment (October 20, 2025)
- Appendix 15: Evaluation Process (October 20, 2025)
- Appendix 16: Energy Transition Community Grant Areas and Hydropower Preference Communities (October 20, 2025)
Digital Signature Instructions
Comment Process on Draft Indexed REC Contract, Draft Preliminary Proposal Requirements
DRAFT Fall 2025 Indexed REC Contract
- Draft Indexed REC Contract (September 22, 2025)
- Redline Comparison
Draft Preliminary Proposal Requirements
Comment Process on Benchmark Categories of Inputs, Assumptions and Data Sources
Fall 2025 Indexed Wind, Solar, Brownfield, and Hydropower FAQs
FAQ-Indexed REC-121
Q: Under the Indexed REC RFP, is there a preference given to Projects interconnected with a specific regional transmission organization or utility? Are there separate targets for Projects that will be interconnected to PJM versus MISO?
Under the Indexed REC RFP, there is no preference in bid evaluation given to Projects interconnected with a specific regional transmission organization or utility, nor are there separate targets for Projects that will be interconnected to PJM versus MISO.
Additionally, there is no requirement for where a Project must be interconnected or deliver its energy. The Project must either be in Illinois or in a state adjacent to Illinois. However, please note that a Project that is located in a state adjacent to Illinois must meet the public interest criteria specified in Section 1-75(c)(1)(I) of the IPA Act by submitting data about the Project to the IPA and obtaining pre-approval from the IPA that the Project is eligible for Illinois RPS compliance.
01-14-2026FAQ-Indexed REC-120
Q: With reference to the information release related to the Fall 2025 Indexed REC RFP, is the average of the winning Bid prices ($/MWh) of $84.16/MWh a weighted average?
The average of the winning Bid prices of $84.16/MWh is weighted by the annual quantity of RECs awarded. Please see FAQ-Indexed REC-111 for additional information on the strike price for a winning Project that is used for this calculation.
12-19-2025FAQ-Indexed REC-119
Q: When would the seventh step of the evaluation, which reallocates any “shortfall quantity” regardless of Category, occur?
As explained in paragraph I.2.11 of the RFP Rules, “If after completing the sixth step, there is a remaining target for one or more Categories because an insufficient number of Projects were bid for that Category so that the Category is undersubscribed, and for one or more of the other Categories there is at least one Project in addition to the marginal Project that has not yet been selected so that the Category is oversubscribed, then the evaluation continues to a seventh step.”
To be clear, the determination of whether a Category is undersubscribed or oversubscribed takes place after Bids with strike prices (or Forecasted Strike Prices) that fail to meet or beat the benchmark associated with the Project Category are eliminated. Thus, an undersubscription is when there is a remaining target for a Category because an insufficient number of RECs were bid for a Category from Projects that meet or beat the benchmark for the Category and an oversubscription is when there is at least one Project that meets or beats the benchmark for the Category in addition to the marginal Project that has not yet been selected in a Category.
12-05-2025FAQ-Indexed REC-118
Q: Can the sum of the full quantities across all Projects presented by a Bidder exceed the Target associated with the respective Category?
It is acceptable for the sum of the full quantities across all Projects presented by a Bidder to exceed the Target associated with the respective Category. It is not acceptable for: (1) the full quantity of any single Project to exceed the Target associated with the respective Category; and (2) the sum of the minimum quantities across all Projects presented by a Bidder to exceed the Target associated with the respective Category.
12-05-2025FAQ-117
Q: If a Bidder submitted successful Part 1 Proposals for multiple Projects but did not submit a Part 2 Proposal for one or more of these Projects, will the Procurement Administrator issue a new Bid Form?
No. Bidders that submitted successful Part 1 Proposals for multiple Projects and did not submit a Part 2 Proposal for one or more of these Projects will not be issued a new Bid Form.
Please use the Bid Form distributed with the Part 1 Notification on November 14, 2025 to submit your Bid(s) on the Bid Date on December 10. You must leave the cells in the row(s) corresponding to the Bid for the Project(s) for which you did not submit a Part 2 Proposal blank.
12-04-2025FAQ-Indexed REC-116
Q: Can the Seller request the contract to be terminated due to legislation that has already been enacted under Section 11.3 of the Indexed REC Contract or does the “Government Action” have to take place on a later date than the execution of the Indexed REC Contract?
As stated in Section 11.3 of the Indexed REC Contract, “This Section 11.3 is intended to protect Seller from potential future changes to the availability of investment tax credits, production tax credits or other such clean electricity investment credits used to develop the Project. Relief under Section 11.3 is intended to address bona fide and material changes in such ITC or PTC eligibility arising from government actions occurring after contract execution. For example, the enactment of OBBBA on July 4, 2025 predates the Effective Date of this Agreement. Therefore, enactment of OBBBA does not constitute “Government Action” triggering Section 11.3 termination provisions. However, any forthcoming federal guidance after the Effective Date of this Agreement — such as clarifications that may render the ITC or PTC unavailable for the Project may be considered Government Action materially affecting ITC or PTC eligibility and impacting the opportunity for Sellers to access such credits consistent with Section 11.3 if Seller reasonably relied on such ITC or PTC qualification that would have been achieved but for the Government Action.”
12-04-2025FAQ-Indexed REC-115
Q: If the Army Corps of Engineers delays processing of solar permits such that the Project is delayed and therefore no longer qualifies for the Investment Tax Credit assumed in the awarded strike price, will a Seller request to terminate the contract pursuant to Section 11.3 be granted and will Seller’s Performance Assurance be returned?
Section 11.3 of the Indexed REC Contract is intended to protect Seller from potential future changes to the availability of investment tax credits, production tax credits or other such clean electricity investment credits used to develop the Project. Relief under Section 11.3 is intended to address bona fide and material changes in such ITC or PTC eligibility arising from government actions occurring after contract execution.
Delays in obtaining government permits and approvals would not constitute Government Action under Section 11.3 of the Indexed REC Contract.
12-04-2025FAQ-Indexed REC-114
Q: Does the adjustment to the strike price (or Forecasted Strike Price) for a Project that is a utility-scale solar project or a utility-scale wind project and for which at least 50% of the Project site is located within an Energy Transition Community Grant Area (“ETCGA”) happen before or after Bids that fail to meet or beat the benchmark are eliminated?
The adjustment to the strike price (or Forecasted Strike Price) for a Project with a Project site located at least 50% within an Energy Transition Community Grant Area is part of the fourth step of the Bid evaluation process described in paragraph I.2.11 of the RFP Rules. As such, this adjustment occurs after Bids with strike prices (or Forecasted Strike Prices) that fail to meet or beat the benchmark associated with the Project Category are eliminated (second step). All sequential steps of the Bid evaluation can be found in paragraph VI.2.9 of the RFP Rules.
12-02-2025FAQ-Indexed REC-113
Q: Is there an Excel template available to calculate the delivery year requirements as outlined in Exhibit F of the Indexed REC Contract?
An Example of Delivery Year Requirement Calculation has been posted to the to the Final Materials page of the Indexed Wind, Solar, Brownfield, and Hydropower section of the website, and is linked here.
11-26-2025FAQ-Indexed REC-112
Q: If a Project is selected for a quantity of RECs that is less than the full quantity in the sixth step of the evaluation is it possible for additional RECs from that Project to be awarded using shortfall quantity should the seventh step occur? In this case, will the total number of awarded RECs using both the Target associated with the Project Category and also the shortfall quantity from another Category be the RFP Awarded Annual Quantity in the Indexed REC Contracts?
That is correct if the evaluation continues to the seventh step. The condition for the occurrence of the seventh step is provided in paragraph 2 below. As stated in paragraph I.2.11 of the RFP Rules, “Seventh, the remaining target across undersubscribed Categories will be combined and called the “shortfall quantity”. In a similar fashion as the sixth step, Projects that have not yet been selected or were not selected at the full quantity from Categories that are oversubscribed will be selected in price order based on Final Strike Price regardless of Category. The following process will continue until all Projects are selected or the marginal Project is identified: the shortfall quantity will be added to the remaining Target associated with the lowest priced Project to select the full quantity, if possible, of that Project. If selecting the full quantity is not possible, the marginal Project is selected in a similar fashion as the sixth step except that the result may exceed the Target associated with the Category of the marginal Project plus the shortfall quantity by no more than 50%. If after completing this seventh step, the number of RECs selected for a Category does not exceed the number of RECs selected under the sixth step, then the result of the sixth step is the final selection for the Category so that shortfall quantities from undersubscribed Categories may be used in a future procurement event.”
Please note that the seventh step of the evaluation process only takes place when there is an undersubscription of one Category and an oversubscription of another Category. An undersubscription is when there is a remaining target for a Category because an insufficient number of RECs were bid for a Category from Projects that meet or beat the benchmark for the Category and an oversubscription is when there is at least one Project that meets or beats the benchmark for the Category in addition to the marginal Project that has not yet been selected in a Category.
If a Project is awarded RECs using the Target associated with its Category and also a shortfall quantity from another Category, the total number of awarded RECs will be the RFP Awarded Annual Quantity in the Product Order for each of the Indexed REC Contracts.
11-24-2025FAQ-Indexed REC-111
Q: Is the strike price for a winning Project that is used for the calculation of winning Bid prices in the public disclosure adjusted for any of the adjustments that were used in bid evaluation?
The average of the winning Bid prices from the public disclosure at the time of Commission approval is based on the strike price included in the Bid, except for the case where the Bid is an Opt-in Bid. A Bid is an “Opt-in Bid” if the Bidder elected to opt into the one-time Strike Price Adjustment Mechanism under the Indexed REC Contract in the Bid Form. If the Bid is an Opt-in Bid, the strike price used to calculate the average of the winning Bid prices has been adjusted by the Forecast Factor announced for that procurement event and applicable to the technology of the winning Project. For the avoidance of doubt, for purposes of calculating the average of the winning Bid prices in the public disclosure, the strike price as provided in the Bid without any further adjustments is used for Projects that either (1) committed to an Equity Level (%) for the Project above the Minimum Equity Standard; (2) are a utility-scale solar project or a utility-scale wind project and at least 50% of the Project site is located within an Energy Transition Community Grant Area; or (3) are a hydropower project and the Project site is located in or adjacent to a Hydropower Preference Community.
Please note that the public disclosure does not indicate if a Bid is an Opt-in Bid. For details about what information is publicly disclosed for winning Projects, please see FAQ-Indexed REC-53.
11-19-2025FAQ-Indexed REC-110
Q: Can the credit rating of a subsidiary of the entity named as the Guarantor be used for the purpose of meeting the minimum credit ratings in Table A of the Indexed REC Contract?
This is not possible. Under the Indexed REC Contract, the entity named as the Guarantor and that provides the Guaranty must have credit ratings directly assigned to it by Fitch, Moody’s, and/or S&P to qualify for a Collateral Threshold equal to $2,500,000.
11-19-2025FAQ-Indexed REC-108
Q: Are there any requirements for Interconnection Service to be Network Resource Interconnection Service or Energy Resource Interconnection Service?
There is no specific requirement for Interconnection Service for a Project to be Network Resource Interconnection Service or Energy Resource Interconnection Service under the Indexed REC RFP.
11-18-2025FAQ-Indexed REC-107
Q: Will the Procurement Administrator or Companies review a draft version of the Pre-Bid Letter of Credit prior to issuance?
Neither the Procurement Administrator nor the Companies review draft versions of Pre-Bid Letters of Credit. However, upon request the Procurement Administrator can confirm the amount of bid assurance collateral required to be posted with each company given the Project size.
If you are using Pre-Bid Letters of Credit to post bid assurance collateral, please have the Issuing Bank submit the final, executed version to each Company using the instructions provided by email on November 10, 2025. Bid assurance collateral must be received by 12 PM (noon) CPT on December 1, 2025 (the Part 2 Date) along with all other information and documents required by the Part 2 Proposal except for a Bidder’s Bids.
If a Bidder submits a Pre-Bid Letter of Credit for a Company, the Bidder will receive notice of whether such Pre-Bid Letter of Credit is acceptable to the Company as specified in the Part 2 Proposal Processing Procedures. Please see the Part 2 Processing document posted to the Final Materials page of the Indexed REC section of the procurement website for information on the timing of such notices.
11-18-2025FAQ-Indexed REC-106
Q: Is form for the Post-Bid Letter of Credit the same for all three companies?
If a Bid for a Project is selected and approved by the Illinois Commerce Commission, Performance Assurance Collateral must be posted separately with each company, AIC, ComEd, and MEC, in the form of cash of a Post-Bid Letter of Credit. There are two options to the standard form of the Post-Bid Letter of Credit. These options are not company-specific, like the three forms for the Pre-Bid Letter of Credit, and either option may be used for the Post-Bid Letter of Credit for each of the three companies. The Post-Bid Letter of Credit (Options 1 and 2), along with a list of acceptable modifications for each option, is posted to the Final Materials page of the Indexed REC section of the procurement website.
11-18-2025FAQ-Indexed REC-105
Q: Is a curtailment made by MISO considered a Force Majeure event?
If the Project is interconnected with the Midcontinent Independent System Operator, Inc (“MISO”), a curtailment of the Project made by MISO would be a Force Majeure event provided that such curtailment was not initiated by the Project or Seller.
As stated in Section 10.1 of the Indexed REC Contract, “Force Majeure may include curtailments of the Project made by the regional transmission organization or independent system operator responsible for the operation of the transmission system to which the Project is interconnected, any transmission provider providing transmission services for the Project, the utility interconnecting with the Project and providing interconnection services to the Project, or a Governmental Authority, provided that such curtailment was not initiated by the Project or Seller. Upon such Force Majeure event, the Shortfall Amount in a Delivery Year may be excused by the amount of such curtailment. Seller shall provide written notice to Buyer within thirty (30) days of the commencement of any curtailment that meets the foregoing requirements and, in the event that Seller fails to so notify Buyer, Seller shall not be relieved of its Delivery obligations as a result of such curtailment. Upon the occurrence and proper notice of a curtailment meeting the foregoing requirements, Seller shall estimate the amount of Deliveries prevented by such curtailment based on the most recent twelve (12) months of Actual Production data from the Project and utilizing actual meteorological conditions during the period of curtailment and shall provide such estimate to Buyer along with all supporting documentation, including any supporting information from the entity that curtailed the Project’s generation”.
11-17-2025FAQ-Indexed REC-104
Q: If we add battery storage to our Project, how would this be included in the Bid?
First, the Procurement Administrator cannot advise bidders on their bid submissions. The Strike Price that you indicate in your Bid will be used to calculate the payments under the Indexed REC Contract and there is no separate payment adjustment related to additional battery storage under the Indexed REC Contract.
Second, with respect to a Project co-located with an energy storage facility, the RECs Delivered shall be associated with energy generated exclusively from the Project as measured by the Project’s Revenue Quality Meter and not from any other electric source. Similarly, the MWh hourly generation that must be provided under Section 6.1 of the Indexed REC Contract for which the REC Monthly Price Hourly Component is calculated must be from the Project as measured by the Project’s Revenue Quality Meter and not from any other electric source. As such, increasing the Actual Production and REC quantity (as these terms are defined in the Indexed REC Contract) by using a battery is prohibited.
11-17-2025FAQ-Indexed REC-103
Q: We understand that a Project with a Bid that is selected and approved by the Commission will sign three contracts, one with each of AIC, ComEd and MEC. What is the name of the Company that signs the Indexed REC Contract on behalf of each Buyer?
As described on page 4 of the Indexed REC Contract, the “Buyer” or “Party B” which enters each contract is Ameren Illinois Company d/b/a Ameren Illinois, Commonwealth Edison Company, and MidAmerican Energy Company, respectively.
11-13-2025FAQ-Indexed REC-102
Q: Can Bidders provide an Opt-in Bid and an Opt-out Bid for the same project?
Bidders cannot provide both an “Opt-in” (opting into the Strike Price Adjustment Mechanism) Bid and an “Opt-out” Bid for a single project. As stated in paragraph V.5.5 of the RFP Rules, only one Bid may be submitted for a Project.
A “Bid” for a Project includes three (3) elements: a strike price ($/MWh), an annual quantity of RECs that the Project will deliver annually under the terms of the Indexed REC Contract (“full quantity”), and an annual minimum quantity of RECs that the Seller is willing to accept as a partial award (“minimum quantity”).In the Bid Form, the Bidder must also confirm, for each Project for which a Bid is submitted, whether or not the Bidder is electing to opt into the one-time Strike Price Adjustment Mechanism under the Indexed REC Contract.
Please refer to Section I.2 of the RFP Rules for information on Bids and how Opt-in and Opt-out Bids are evaluated.
11-13-2025FAQ-Indexed REC-101
Q: Will a Bidder’s Bid Assurance collateral be returned in full if they choose not to submit a Bid on the Bid date?
If a Bidder posts bid assurance collateral by the Part 2 Date and does not submit a Bid on the Bid Date, the full amount of the bid assurance collateral will be returned within the timeframes provided in the Indexed REC RFP as if the Bid for the Project was not selected. All bid assurance collateral remains in place until the Commission has rendered a decision on the results of the procurement event. The Commission renders its decision on the results of the procurement event on Tuesday, December 16, 2025.
A Company may draw upon the letter of credit or a cash deposit if: (i) the Bidder or a Seller has disclosed information relating to the Proposal for a Project publicly or to any other party (excluding disclosures required by a federal, state, or local agency, or by a court of competent jurisdiction) before the Illinois Commerce Commission has rendered its decision on the results of the procurement event; or (ii) the Bidder or a Seller has made a material omission or misrepresentation in the Part 1 Proposal or the Part 2 Proposal for a Project submitted in connection with the procurement event; or (iii) a Seller has failed to execute the applicable supplier contract for a Project within three (3) business days of being notified that the Illinois Commerce Commission has approved the Bid on that Project or has failed to meet the creditworthiness requirements of the applicable supplier contract within fifteen (15) business days of such Illinois Commerce Commission decision; or (iv) the Bidder or a Seller has failed to pay to the Illinois Power Agency the applicable Supplier Fee for a Project within twelve (12) business days of being notified that the Illinois Commerce Commission has approved the Bid on that Project.
Please see FAQ-Indexed REC-96 for additional information on timing of the return of bid assurance collateral.
11-13-2025FAQ-Indexed REC-100
Q: Can we submit a proposal for a Project after the P1 Date?
As stated in paragraph VI.1.5 of the RFP Rules, “A Bidder must submit the Part 1 Proposal for a Project to the Procurement Administrator by 12 PM (noon) on the Part 1 Date. All times in this RFP are Central Prevailing Times unless specifically noted. No late Part 1 Proposals will be accepted under any circumstances.”
11-13-2025FAQ-Indexed REC-99
Q: If a Seller is successful in this Indexed REC RFP, but ultimately due to significant inflation and interest rate increases prior to construction, the Project is no longer economic at the strike price, are there any remedies available to the Seller who is committed to developing the project? Can the Seller submit a new bid in a subsequent Indexed REC RFP for the Project and if so, what would be the process?
Section 4.1(d) of the Indexed REC Contract outlines the termination of the contract if the Seller determines that it will not be able to construct the Project in a timely manner prior to the REC Delivery deadline. In such a case Seller shall provide a written notice of that determination to Buyer. Buyer shall be entitled to payment by Seller in the amount of the Collateral Requirement or Increased Collateral Requirement, as applicable. Buyer shall terminate this Agreement within twenty (20) Business Days of the later of: (i) Buyer’s receipt of written notice from Seller; or (ii) Buyer’s receipt of payment in the amount of the Collateral Requirement or Increased Collateral Requirement, as applicable. In this situation, there is no prohibition for the bidder to submit a bid for the same Project in a subsequent Indexed REC RFP provided that the contract is fully terminated prior to the submission of the Part 1 Proposal for the Project.
11-10-2025FAQ-Indexed REC-98
Q: Can we use a surety bond or rely on an unrated Guarantor to meet the Collateral Requirement under the Indexed REC Contract?
FAQ-Indexed REC-97
Q: Our company is not rated and does not intend to rely on the financial standing of a Guarantor under the Indexed REC Contract. Can we participate in the Indexed REC RFP?
It is not a condition of participation in the RFP that the Bidder or the Seller is a rated entity or that the Seller rely on the financial standing of a Guarantor that is a rated entity. If the Seller is not rated by one of the major rating agencies and if the Seller does not intend on relying on the financial standing of a Guarantor during the supply period, please confirm this fact by checking “no” to the applicable questions in Section 8 of the online Part 1 Form.
Please also refer to FAQ-Indexed REC-34 for information about the Collateral Requirement for Sellers not eligible for unsecured credit.
10-31-2025FAQ-Indexed REC-96
Q: When is the bid assurance collateral returned if we submit a Bid and the Project is selected and in the case the Project is not selected?
All bid assurance collateral remains in place until the Commission has rendered a decision on the results of the procurement event. If the Bid for a Project is selected by the evaluation procedure and approved by the Commission, bid assurance collateral remains in place until full execution of the Indexed REC Contract and posting of any required Performance Assurance, and until payment of the Supplier Fee is received. The Commission is expected to render its decision on the results of the procurement event on Tuesday, December 16, 2025.
If the Bid for a Project is not selected by the evaluation procedure, the bid assurance collateral for that Project will be returned as stated in Paragraph VI.2.19 of the RFP Rules, “A Pre-Bid Letter of Credit will expire on the date stated as part of its terms, twenty-one (21) business days after the anticipated date of the Commission decision on the procurement event and cash provided as bid assurance collateral will be returned in the same general timeframe”. The return of cash tendered as bid assurance to a Company is not initiated until the Company receives an executed request in a form acceptable to the Company and, for AIC, until an account in AIC’s vendor portal used for the return of cash is set-up, for MEC, until a Vendor Request Form is received that MEC finds to be duly completed. Please note that for a Bidder who is not yet set up on AIC’s portal used for the return of cash, account set up may take six (6) business days after the ICC’s decision on the procurement results.
Please note that Cash posted as bid assurance collateral under the RFP may be used towards meeting the performance assurance requirement under the contract. In this case, the Bidder needs only to make a second wire for the difference between the performance assurance requirement and the bid assurance collateral already posted, if the difference is positive. A Bidder must indicate whether it elects for cash to be retained by the applicable Company in the Contract Insert, also labelled INSERT #P2-5, as further described in Paragraph V.4.2.
Please see paragraph V.2.2. of the Indexed REC RFP Rules for the conditions under which a draw on cash posted as bid assurance collateral may be made.
10-31-2025FAQ-Indexed REC-95
Q: When does Performance Assurance need to be posted under the Indexed REC Contract? When will the Performance Assurance be returned?
A Seller with a Project with an approved Bid must meet the creditworthiness requirements under the Indexed REC Contract within fifteen (15) business days of the Illinois Commerce Commission decision on the results of the procurement event. The Performance Assurance must be posted no later than January 8, 2025. It is Seller’s responsibility to ensure Seller’s Performance Assurance is maintained pursuant to Article 7 of the Indexed REC Contract. Pursuant to Section 7.1(c) of the Indexed REC Contract, at the conclusion of the Delivery Term of the Indexed REC Contract upon completion of the final delivery obligations and payment obligations under the Indexed REC Contract, Seller may request for the return of Seller’s Performance Assurance.
10-31-2025FAQ-Indexed REC-94
Q: Can you provide instructions for submission of bid assurance collateral?
The Bid Assurance Collateral Instructions for each Company will be distributed to Bidders shortly after the Part 1 Date, which is November 5, 2025. The instructions will include both information on how to submit cash as bid assurance collateral to the Companies as well as how to transmit the Pre-Bid Letter of Credit to the Companies, including the physical address for each of the companies.
10-31-2025FAQ-Indexed REC-93
Q: Does opting in to the Strike Price Adjustment Mechanism impact bid evaluation?
Yes, if the Bidder elects within the Bid Form to opt into the one-time Strike Price Adjustment Mechanism under the Indexed REC Contract, the Strike Price will be adjusted during the Bid evaluation. As detailed in Section I.2.11 of the RFP Rules, the first step of the bid evaluation proceeds as follows: “the strike price for an Opt-in Bid is multiplied by a “Forecast Factor” specific to the Category of project. The Forecast Factor is the expected percent change in the strike price of an Opt-in Bid if the strike price adjustment described in Exhibit G to the Indexed REC Contract were to be made 30 months from the Commission Bid Approval Date. The Forecast Factor for a Category is calculated as the weighted average of forecasts for each Index in Exhibit G to the Indexed REC Contract using weightings from the Strike Price Adjustment Mechanism formula for that Category. The Forecast Factor by Category will be provided to Bidders on the date the Part 2 Window opens, which is fifteen business days prior to the Bid Date.”
10-31-2025FAQ-Indexed REC-92
Q: Is the Supplier Fee non-refundable?
The Supplier Fee is non-refundable.
10-31-2025FAQ-Indexed REC-91
Q: Will the Bidder have an opportunity to update the Degradation Rate after the submission of the online Part 2 form?
A Bidder will have the opportunity to update the Degradation Rate for purposes of the Product Order of the Indexed REC Contract after the submission of the online Part 2 Form. Any update must be provided no later than 12 PM (noon) on the day after the Procurement Administrator notifies a Bidder that the Bidder has Bids that the Procurement Administrator identifies as winning Bids. Please see paragraph VI.2.14 of the RFP Rules, which states “The Procurement Administrator will contact the Representatives of each Bidder with Bids identified by the Procurement Administrator as winning Bids to the Commission to ensure that the contact information of such Representatives remains correct and up-to-date as early as practicable. If the Procurement Administrator notifies a Bidder that the Bidder has Bids that the Procurement Administrator identifies as winning Bids, and if the Bidder did not fully complete the Contract Inserts, the Bidder will be required to provide all information required by the applicable Contract Inserts promptly after such notification occurs and no later than 12 PM (noon) on the day after such notification is received by the Bidder. The Bidder may also update the Degradation Rate for purposes of the Product Order of the Indexed REC Contract, if needed, by this time. The Companies prepare the Indexed REC Contract documents.”
10-31-2025FAQ-Indexed REC-90
Q: Who makes up the “project workforce” for the purpose of the MES?
The 2024 Long-Term Plan, as approved by the Illinois Commerce Commission, adopts the following definition of “project workforce”:
Employees, contractors and their employees, and subcontractors and their employees, whose job duties are directly required by or substantially related to the development, construction, and operation of a project that is participating in or intended to participate in the IPA-administered programs and procurements under Section 1-75(c) of the IPA Act. This shall include both project installation workforce and workforce in administrative, sales, marketing, and technical roles where those workers’ duties are performed in Illinois. For purposes of this definition, ‘directly required by or substantially related to’ shall be construed to be any direct employee of the Approved Vendor, Designee, or Indexed REC contract holder, or any contractor and its employees whose contract exceeds 5% of the REC Contract value. Employees of contractors below that threshold may be counted toward the MES on a voluntary basis, but then all contractors below the 5% of REC contract value threshold must be included. (2024 Long-Term Plan at 356-357).
The MES applies to the project workforce, so if the MES is 14%, EEPs must make up 14% of the project workforce. Therefore, compliance with the MES is based on number of workers or employees, not the work hours performed by those employees.
10-31-2025FAQ-Indexed REC-89
Q: What is required at the time of bid for Bidders that do not wish to commit to an Equity Level (%) greater than the Minimum Equity Standard of 14%?
As provided in paragraph IV.3.1. of the RFP Rules, an Officer of the Seller must acknowledge that if the Date of First Operation for a Project is on or after December 15, 2022, a Minimum Equity Standard of 14% applies to the Project Workforce for each delivery year in which Construction Activities are performed through the Date of First Operation for a utility-scale wind, utility-scale solar, brownfield site photovoltaic, or New Hydropower Project; or through the Hydropower Refurbishment Completion Date if the Project is a Modernized or Retooled Hydropower Project; and that there are reporting requirements described in Section 6.4 of the Indexed REC Contract.
No additional documentation or information is required at the time of Bid submission.
10-31-2025FAQ-Indexed REC-88
Q: Does the Minimum Equity Standards apply to Projects located in adjacent states? Can you please provide clarification on how adjacent state Projects can meet these requirements?
A Minimum Equity Standard of 14% will apply under the Indexed REC Contract to a Project selected through this RFP if the Date of First Operation (or the Hydropower Refurbishment Completion Date if the Project is a hydropower project that is newly Modernized or Retooled) is on or after December 15, 2022, regardless of whether the project is located in Illinois or an Adjacent State.
An “Equity Eligible Persons” means persons who would most benefit from equitable investments by the State designed to combat discrimination, specifically: (a) persons who graduate from or are current or former participants in the Clean Jobs Workforce Network Program, the Clean Energy Contractor Incubator Program, the Illinois Climate Works Pre-apprenticeship Program, Returning Residents Clean Jobs Training Program, or the Clean Energy Primes Contractor Accelerator Program, and the solar training pipeline and multi-cultural jobs program created in paragraphs (a)(1) and (a)(3) of Section 16-108.12 of the Public Utilities Act; (b) persons who are graduates of or currently enrolled in the foster care system; (c) persons who were formerly incarcerated; (d) persons whose primary residence is in an Equity Investment Eligible Community as defined in Section 1-10 of the IPA Act as further clarified in the IPA’s long term renewable resources procurement plan as approved by the Illinois Commerce Commission in ICC Docket No. 23-0714.
As defined in the Indexed REC Contract, “Project Workforce” means employees, contractors and their employees, and subcontractors and their employees whose job duties are directly required by or substantially related to the development, construction, and operation of the Project that is participating in the IPA-administered programs and procurements under Section 1-75(c) of the IPA Act. This shall include both project installation workforce and workforce in administrative, sales, marketing, and technical roles where those workers’ duties are directly related to the Project. For workforce in administrative, sales, marketing and technical roles, this shall apply only if those workers are located in Illinois. For purposes of this definition, “directly required by or substantially related to” shall be construed to be any direct employee of Seller, or any contractor and its employees whose contract exceeds 5% of the REC Contract Value. Employees of contractors below that threshold may be counted toward the MES on a voluntary basis, but then all employees of all contractors below the 5% of REC Contract Value threshold must be included.
Persons working in administrative, sales, marketing and technical roles, shall be included in the Project Workforce only if their duties are related to the Project and performed in Illinois. The project installation workforce shall be included in the Project Workforce and must meet the MES regardless of location.
Please note, CEJA provides that the Agency may utilize its discretion in rare circumstances to grant a waiver of the MES (20 ILCS 3855/1-75(c-10)(4)(E)). In describing the criteria for granting such a waiver, the statute provides that the Agency may do so “where the applicant provides evidence of significant efforts toward meeting the minimum equity commitment, including: use of the Energy Workforce Equity Database; efforts to hire or contract with entities that hire eligible persons; and efforts to establish contracting relationships with eligible contractors.” (20 ILCS 3855/1-75(c-10)(4)(E) (emphasis added)). The IPA posted waiver request forms to the Minimum Equity Standard webpage here: https://ipa.illinois.gov/diversity-equity-and-inclusion/minimum-equity-standard.html. As described in the waiver request form, requestors must receive at least 20 points to qualify for a waiver.
10-31-2025FAQ-Indexed REC-87
Q: Can the Companies draw upon the pre-bid collateral if the Bid for a Project is selected by the evaluation procedure, and then approved by the Commission, but the Seller does not execute the Indexed REC Contracts with the Companies?
As part of the Part 2 Proposal, the Seller must certify that the Bid constitutes a binding and irrevocable offer to supply the annual quantity of RECs from the Project selected in the evaluation and the Seller agrees that, if the Project is selected in the RFP and the Seller’s Bid on that Project is approved by the Commission, the Seller will execute the Indexed REC Contracts with all Companies as instructed by the Procurement Administrator. If the Bid for a Project is selected by the evaluation procedure and approved by the Commission, and the Seller fails to execute the Indexed REC Contract, a Company may draw upon the letter of credit or a Company may draw upon a cash deposit. If bid assurance collateral was submitted for multiple Projects and a draw is required on the bid assurance collateral for one of the Projects, the amount of the draw would not exceed the amount that would have been required as bid assurance collateral for that Project alone.
In addition, please refer to FAQ-Indexed REC-86.
10-31-2025FAQ-Indexed REC-86
Q: What conditions may the bid assurance collateral be drawn upon?
The Company may draw upon the letter of credit or a Company may draw upon a cash deposit if: (i) the Bidder or a Seller has disclosed information relating to the Proposal for a Project publicly or to any other party (excluding disclosures required by a federal, state, or local agency, or by a court of competent jurisdiction) before the Illinois Commerce Commission has rendered its decision on the results of the procurement event; or (ii) the Bidder or a Seller has made a material omission or misrepresentation in the Part 1 Proposal or the Part 2 Proposal for a Project submitted in connection with the procurement event; or (iii) a Seller has failed to execute the applicable supplier contract for a Project within three (3) business days of being notified that the Illinois Commerce Commission has approved the Bid on that Project or has failed to meet the creditworthiness requirements of the applicable supplier contract within fifteen (15) business days of such Illinois Commerce Commission decision; or (iv) the Bidder or a Seller has failed to pay to the Illinois Power Agency the applicable Supplier Fee for a Project within twelve (12) business days of being notified that the Illinois Commerce Commission has approved the Bid on that Project.
10-31-2025FAQ-Indexed REC-85
Q: What is the penalty if the Seller fails to deliver RECs by the initial REC Delivery Deadline?
As specified in Section 9.2(g) of the Indexed REC Contract, Seller’s failure to Deliver at least one (1) REC from the Project by May 31, 2030 or extended deadline pursuant to Section 2.4 or Section 10.1 shall constitute an Event of Default. Upon the occurrence of such Event of Default, Buyer shall terminate this Agreement twenty (20) Business Days after written notice by Buyer to Seller unless Seller demonstrates, within such twenty (20) Business Day period and to the satisfaction of Buyer in its reasonable discretion, that Seller has posted Seller’s Performance Assurance to satisfy the Increased Collateral Requirement required for an extension pursuant to Section 2.4 or Seller has made such Delivery by the deadline or the extended deadline, as applicable. For such Events of Default, Buyer shall be entitled to payment by Seller (i) in the amount of the Collateral Requirement if there has been no extension; or (ii) in the amount of the Increased Collateral Requirement if an extension is granted and Seller fails to Deliver at least one (1) REC from the Project by the extended deadline pursuant to Section 2.4.
Under the Indexed REC Contract, Collateral Requirement means, (a) with respect to a Utility-Scale Wind Project or a Hydropower Project, an amount equal to four dollars ($4) times the Annual Quantity and which shall be reduced for the last Delivery Year, if applicable, to reflect an amount equal to the product of the Delivery Year Requirement for the last Delivery Year and four dollars ($4); provided that if the Collateral Requirement is calculated to be less than $20,000, then the Collateral Requirement shall be $20,000; and means, (b) with respect to a Utility-Scale Solar Project or a Brownfield Site Photovoltaic Project, an amount equal to ten dollars ($10) times the Annual Quantity and which shall be reduced for the last Delivery Year, if applicable, to reflect an amount equal to the product of the Delivery Year Requirement for the last Delivery Year and ten dollars ($10); provided that if the Collateral Requirement is calculated to be less than $20,000, then the Collateral Requirement shall be $20,000.
The Increased Collateral Requirement means, (a) with respect to a Utility-Scale Wind Project or a Hydropower Project, an amount equal to eight dollars ($8) times the Annual Quantity; provided that if the Increased Collateral Requirement is calculated to be less than $40,000, then the Increased Collateral Requirement shall be $40,000; and means, (b) with respect to a Utility-Scale Solar Project or a Brownfield Site Photovoltaic Project, an amount equal to twenty dollars ($20) times the Annual Quantity; provided that if the Increased Collateral Requirement is calculated to be less than $40,000, then the Increased Collateral Requirement shall be $40,000. The Increased Collateral Requirement shall revert to the Collateral Requirement upon Delivery of one (1) REC from the Project by Seller by the extended Initial REC Delivery Deadline.
10-30-2025FAQ-Indexed REC-84
Q: When can the Seller request the one-time reduction of the REC Delivery Obligation, as described in Section 2.6 of the Indexed REC Contract?
The Seller may request a one-time adjustment to the REC Delivery Obligation, as described in Section 2.6 of the Indexed REC Contract, if such request is made before the start of the Project’s construction. This adjustment can be requested if there is a reduction of at least 5% to the anticipated nameplate capacity or generation output. Approval of such request may be granted by the IPA on a case-by-case basis upon a demonstration of good cause by Seller to the satisfaction of the IPA in its sole discretion. Any adjustment will only reduce the Seller’s REC delivery obligation and cannot increase the Annual Quantity or Maximum Contract Quantity.
10-30-2025FAQ-Indexed REC-83
Q: If a brownfield site photovoltaic project is co-located with another facility on a greenfield site, can we submit a Proposal for a partial capacity of the project under the utility-scale solar category and a second Proposal for a partial capacity of the same Project under the brownfield site photovoltaic category in the same solicitation?
Yes, a Bidder with a brownfield site photovoltaic project co-located with another facility on a greenfield site may submit separate Proposals, one for partial capacity of the Project under the utility-scale solar category and another one for partial capacity of the same Project under the brownfield site photovoltaic category. Under the RFP, these partial capacities would be considered separate Projects. Please note that, the Bidder must (i) disclose this fact during the Part 1 Proposal, (ii) the separate projects must be separately metered with a dedicated, single revenue quality meter and need to have separate PJM EIS GATS or M-RETS accounts, and (iii) the Brownfield project must be entirely contained within the brownfield site.
10-30-2025FAQ-Indexed REC-82
Q: Does the Indexed REC Contract allow for RECs to be delivered from Projects other than the Project selected under the RFP?
No, all RECs delivered to the Buyer must be from the Project selected under the RFP. As stated in Section 4.1(a) of the Indexed REC Contract, “All RECs Delivered to Buyer from Seller under this Agreement shall be associated with electric energy generated by the Project.”
10-30-2025FAQ-Indexed REC-81
Q: If the Delivery Year Requirement is already met for a Delivery Year, does the Seller or Buyer still get payment from any RECs in excess of the Delivery Year Requirement?
Pursuant to Section 4.1(i) of the Indexed REC Contract, if the Delivery Year Requirement is already met, then any RECs generated by the Project in excess of the Delivery Year Requirement for any Delivery Year are deemed Excess RECs. Such Excess RECs are not eligible for payment by Buyer except as provided in Section 2.3(f)(ii).
10-30-2025FAQ-Indexed REC-80
Q: Can the Project sell RECs to third parties after the Indexed REC Contract expires?
At the conclusion of the Delivery Term of the Indexed REC Contract and upon completion of the final delivery obligations and payment obligations under the Indexed REC Contract, the Seller may sell all the RECs from the Project to a third-party at Seller’s sole discretion.
10-30-2025FAQ-Indexed REC-79
Q: Can you provide any guidance on how to select the Index Hub?
The Index Hub, namely either MISO-IL Hub or PJM-NIHUB, which will be used for purposes of calculating the Index Price, is selected by the bidder in the bid form. A bidder may select either MISO-IL Hub or PJM-NIHUB, no matter the location of the Project. The Procurement Administrator cannot provide any guidance on how to select the Index Hub.
10-30-2025FAQ-Indexed REC-78
Q: Is there a ceiling or floor price on the REC Monthly Price?
No, there is no limit on the maximum or minimum value of the REC Monthly Price.
10-30-2025FAQ-Indexed REC-77
Q: Could you explain how the contract settles if RECs delivered are more than or less than the annual quantity?
Seller shall Deliver RECs to Buyer to satisfy the Delivery Year Requirement in each Delivery Year (June – May). Delivery Year Requirement is defined in Section 1.32 of the Indexed REC Contract. RECs generated by the Project in excess of the Delivery Year Requirement for any Delivery Year are deemed Excess RECs; the amount of RECs that Seller fails to Deliver to satisfy the Delivery Year Requirement for a Delivery Year is deemed the Shortfall Amount. It is an event of default if (i) Seller fails to meet the Delivery Year Requirement for five (5) or more years, and (ii) the Shortfall Amounts (as the term is defined in the Indexed REC Contract) cumulatively equals or exceeds 3.5 times the Annual Quantity.
Excess RECs:
- If the Delivery Year Requirement is already met, then any RECs generated by the Project in excess of the Delivery Year Requirement for any Delivery Year are deemed Excess RECs. Such Excess RECs shall remain the exclusive property of Seller, to be utilized in Seller’s sole discretion. For avoidance of doubt, such Excess RECs are not eligible for payment by Buyer except as provided in Section 2.3(f)(ii). In the event that the Delivery Year Requirement for a Delivery Year has been met and Excess RECs are Delivered to Buyer such Excess RECs shall be disposed pursuant to Section 2.3(f).
- Excess RECs may be used for purposes of reducing Shortfall Amounts. Please review Section 4.1(k) of the Indexed REC Contract for more information.
Shortfall Amounts:
- In the event that Seller fails to Deliver the Delivery Year Requirement for a Delivery Year, the amount of RECs that Seller fails to Deliver to satisfy the Delivery Year Requirement for a Delivery Year shall be deemed the “Shortfall Amount”. Please review Section 4.1(f) of the Indexed REC Contract for more information.
- Regarding flexibilities related to Shortfall Amounts, please see FAQ-Indexed-REC-76.
FAQ-Indexed REC-76
Q: What are the flexibilities related to delivery under the Indexed REC Contract?
There are several flexibilities related to delivery under the Indexed REC Contract; however, including, but not limited to:
- The Annual Quantity in the Indexed REC Contract related to a utility-scale solar project or a brownfield site photovoltaic project is subject to a degradation factor that is calculated using the Degradation Rate designated by the Bidder within the Part 2 Proposal. The Delivery Year Requirement calculation is set forth in Section 1.31 and 1.32 of the Indexed REC Contract.
- Seller must deliver a quantity of RECs that meets the Delivery Year Requirement in each deliver year, the failure to meet any Delivery Year Requirement through the first two (2) full Delivery Years (i.e., first two (2) full June through May periods as well as any prior stub period) shall not constitute a Shortfall Amount.
- As described in Section 9.2 it is an event of default under the Indexed REC Contract if: (i) Seller fails to meet the Delivery Year Requirement for five (5) or more years, and (ii) the Shortfall Amounts (as the term is defined in the Indexed REC Contract) cumulatively equals or exceeds 3.5 times the annual quantity.
- Section 9.2(k) outlines the process for a Seller to request a waiver excusing Shortfall Amounts or a portion of such Shortfall Amounts from the IPA. Approval of waivers to Shortfall Amounts may be granted by the IPA on a case-by-case basis upon a demonstration of good cause by Seller to the satisfaction of the IPA at its sole discretion. Good cause may include long-term changes in weather patterns, serial defects in the Project’s components, and other events outside of the control of Seller that impact the Project’s ability to meet its Delivery Year Requirement. The approval of any such requests shall be at the IPA’s sole discretion.
- There is flexibility on Project size changes after contract award subject to the term of the Indexed REC Contract.
- There is an option for Seller to indicate a percent of the project’s output it elects to commit to the Buyer under the applicable Indexed REC contract so as to allow for a third party off-taker to procure a portion of the project’s output that is not committed to the Buyer under the applicable the Indexed REC contract. Please review Section 2.3(b) of the Indexed REC Contract for information regarding the Project Committed Percentage and the Standing Order.
- A process for Seller to make manual transfer of RECs to the Buyer(s) for the purpose of reducing Shortfall Amounts incurred in one or more Delivery Years, which may include RECs that were generated in excess of prior Delivery Year Requirements and RECs that were not previously committed to the Buyer(s). Please review Section 4.1(k) of the Indexed REC Contract for information regarding the manual transfer of RECs for purposes of reducing Shortfall Amounts.
FAQ-Indexed REC-75
Q: What detail is required in the Project site map provided with the Part 1 Proposal for a utility-scale wind or utility-scale solar project?
The map must include a boundary line around the entire Project site and not just the parcels of land that have been secured at this time or the location of the panels. There is no requirement to provide the location of the panels or other equipment on the map. Please be aware that, as stated in Section IV.4.4. of the RFP Rules, “If the Project is selected by the evaluation in this RFP and approved by the Commission, the map of the Project site provided by the Bidder in its Proposal will become part of the Indexed REC Contract. With each REC delivery, the Seller will be required to represent that at least 50% of the Project is located within the physical location, identified by the boundary line, provided in the Proposal. The boundary line may contain additional land than the parcels of land that have been secured at the time of the Proposal.”
10-30-2025FAQ-Indexed REC-74
Q: What are the requirements to demonstrate adequate project maturity?
Please note, in the Part 1 Proposal, the Officer of the Seller is required to make a representation that the Project has reached the appropriate development milestones to fully expect that the Project will deliver its first REC to each Company by a date consistent with terms of the Indexed REC Contract. In the Part 1 Proposal, an RFP Bidder will also be required to provide documentation to demonstrate adequate project maturity. The RFP Bidder must provide, if available for the Project, one of the following:
- the Queue/OASIS ID from PJM and a copy of the completed System Impact Study from PJM for the Project; or
- the Project Number from MISO and a copy of the Preliminary System Impact Study under Definitive Planning Phase 1 (“DPP 1”) under the DPP-2020-Cycle 1 or a later study cycle; or
- the Project Number from MISO and a copy of the fully executed interconnection agreement for the Project; or
- a fully executed interconnection agreement with a utility for the Project.
If none of the information bulleted above is available for the Project, or if the Bidder cannot provide a document that shows that the Project is further in the interconnection process, then the Bidder must: (i) if available, provide the Queue/OASIS ID from PJM, the Project Number from MISO, or the applicable ID/Number associated with the Project under the interconnection process with a utility; (ii) describe the stage of development of the Project applicable to the point of interconnection (including providing the name of the regional transmission organization or utility with which the Project plans to interconnect; e.g., PJM, Ameren, etc.) and to the size of the Project; and (iii) demonstrate control for a portion of the Project site as described in Paragraph IV.7.3.
According to Paragraph IV.7.3 of the RFP Rules, a “A Bidder that demonstrates site control to meet the requirements of Section IV.7, must do so for a portion of the Project site that covers an area of at least 40 acres times the Project size for a utility-scale wind project, an area of at least 4 acres times the Project size for a utility-scale solar project, or an area of at least 3 acres times the Project size for a brownfield site photovoltaic project. For example, if the Project size for a utility-scale wind project is 10 MW, then the Bidder must demonstrate control for 400 acres included in the Project site.”
10-30-2025FAQ-Indexed REC-73
Q: What Degradation Rate will be used in the Indexed REC Contract for a utility-scale solar or brownfield site photovoltaic project? How does the Degradation Rate impact the Delivery Year Degradation Factor?
The Annual Quantity in the Indexed REC Contract related to a utility-scale solar project or a brownfield site photovoltaic project is subject to a degradation factor that is calculated using the Degradation Rate designated by the Bidder within the Part 2 Proposal. Please note that the Delivery Year Degradation Factor is different from the Degradation Rate as these terms are defined in the Indexed REC Contract.
For utility-scale solar and brownfield site photovoltaic Projects, the Bidder must provide a Degradation Rate up to 1% for the Project, rounded to two decimals, within the Part 2 Proposal.
The Delivery Year Degradation Factor for a utility-scale solar or brownfield site photovoltaic project, means 1 for Delivery Year 0 and Delivery Year 1, and means the result obtained from subtracting the Degradation Rate from the prior year’s Delivery Year Degradation Factor for all subsequent Delivery Years; where Delivery Year 1 is first full Delivery Year within the Acceptable Vintage Period.
Exhibit F-1 of the Indexed REC Contract provides an illustrative example of the Delivery Year Requirement calculation for a utility-scale solar or brownfield site photovoltaic Project using a Degradation Rate of 0.5%.
There is no degradation factor that is applicable to utility scale wind projects and hydropower projects.
10-30-2025FAQ-Indexed REC-72
Q: During the Term of the Indexed REC Contract can a Seller replace cash posted as performance assurance with a letter of credit?
Yes, this is possible. Cash posted as performance assurance may be replaced with a letter of credit under the Indexed REC Contract. The request for cash to be returned may be made to each company following the posting of an acceptable Letter of Credit to each of the companies. It is Seller’s responsibility to ensure Seller’s Performance Assurance is maintained pursuant to Article 7 of the Indexed REC Contract.
10-30-2025FAQ-Indexed REC-71
Q: Is it a requirement for my Project to interconnect with a specific regional transmission organization or utility?
Under the Indexed REC RFP Rules there is no requirement for where a Project must be interconnected or deliver its energy. The Project must either be in Illinois or in a state adjacent to Illinois. However, please note that a Project that is located in a state adjacent to Illinois must meet the public interest criteria specified in Section 1-75(c)(1)(I) of the IPA Act by submitting data about the Project to the IPA and obtaining pre-approval from the IPA that the Project is eligible for Illinois RPS compliance.
10-30-2025FAQ-Indexed REC-70
Q: Can a Bidder confirm the correct amount of bid assurance collateral required to post to each company for a Project to be able to submit Bids on its Projects(s) with the Procurement Administrator?
Yes, the Bidder may request to confirm the amount of Bid Assurance Collateral required to be posted with each Company by email to the Procurement Administrator.
10-30-2025FAQ-Indexed REC-69
Q: Is it a requirement to utilize both Equity Eligible Contractors and Equity Eligible Persons to meet the Minimum Equity Standard of 14%? Or could this requirement be met using EECs or EEPs?
There is no requirement to utilize Equity Eligible Contractors (EECs) to meet the Minimum Equity Standard. As defined in the Indexed REC Contract, “Minimum Equity Standard” means specific requirements provided in Section 1-75(c-10) of the IPA Act, for which a minimum percentage of the Project Workforce must consist of Equity Eligible Persons or Equity Eligible Contractors”.
10-30-2025FAQ-Indexed REC-68
Q: Can a Bidder submit a Part 1 Proposal for a Project and ultimately not move forward with submitting a Part 2 Proposal? Are we required to notify the Procurement Administrator if we decide not to submit a Part 2 Proposal for a Project?
A Bidder may submit a Part 1 Proposal for a Project, and later decide to not submit a Part 2 Proposal for that Project. The Bid Participation Fee of $500 will not be refunded.
If a Bidder submits Proposals for multiple Projects, but ultimately decides not to present a Part 2 Proposal for all of the Projects that qualified through a successful Part 1 Proposal, such Bidder should notify the Procurement Administrator by email at Illinois-RFP@nera.com, with the list of Projects for which the Bidder will not be submitting a Part 2 Proposal as early as practicable and no later than the Part 2 Date. The Procurement Administrator will refer to this list of Projects submitted by the Bidder in conjunction with the Part 2 Proposals submitted in order to determine if the Bidder has provided sufficient bid assurance collateral to all Companies.
For the Bidder to be able to submit Bids on its Project(s), the Bidder must have submitted bid assurance collateral to all Companies in an amount that is sufficient given the Project size for each of the Bidder’s Projects. If the Bidder fails to provide bid assurance collateral to one or more of the Companies or if the Bidder provides bid assurance collateral to all Companies but the amount of the bid assurance collateral for one or more of the Companies is insufficient given the Project size across all of the Bidder’s Projects, the Part 2 Proposals for all of the Bidder’s Projects will be considered deficient.
10-30-2025FAQ-Indexed REC-67
Q: What is the required amount of bid assurance collateral? Is there a cap on the amount required to each utility?
The amount of bid assurance collateral required for a Project is determined separately for each Company as detailed below. As described in Paragraphs V.2.3 and V.2.5, a Bidder that submits Proposals for multiple Projects may post bid assurance collateral by effecting a single wire transfer to each Company or a single Pre-Bid Letter of Credit to each Company for all Projects. In this case, to determine the amount of bid assurance collateral across all Projects, for each Company the amount of bid assurance collateral for each Project should be calculated as described below and then the amounts, each already rounded up to the nearest $100, should be summed across all Projects.
- The amount of bid assurance collateral required for AIC is $1,600/MW for a Wind Project and Hydropower Project and $5,500/MW for a Solar Project and Brownfield Project.
- The amount of bid assurance collateral required for ComEd is $4,000/MW for a Wind Project and Hydropower Project and $13,000/MW for a Solar Project and Brownfield Project.
- The amount of bid assurance collateral required for MEC is $400/MW for a Wind Project and Hydropower Project and $1,000/MW for a Solar Project and Brownfield Project.
For the Bidder to be able to submit Bids on its Project(s), the Bidder must have submitted bid assurance collateral to all Companies in an amount that is sufficient given the Project size for each of the Bidder’s Projects. There is no cap on the amount of bid assurance collateral tendered to each utility.
10-30-2025FAQ-Indexed REC-66
Q: Is the Index Hub selected in the bid form used for purposes of bid evaluation?
A Bidder must select an “Index Hub”, either MISO-IL Hub or PJM-NIHUB, for each Project for which a Bid is submitted in the bid form. The Index Hub is not used in the evaluation of bids. The Index Hub is used for purposes of payment under the Indexed REC Contract.
10-30-2025FAQ-Indexed REC-65
Q: Is a Bidder required to select the Index Hub, either PJM-NIHUB or MISO-IL, based on whether the project is or will be interconnected with PJM or MISO?
No. According Section V.5.6 of the RFP Rules, a Bidder shall choose an “Indexed Hub”, either of PJM-NIHUB or MISO-IL, and this selection is independent and regardless of whether the project is or will be interconnected with MISO or PJM.
10-30-2025FAQ-Indexed REC-64
Q: Where can I find more information about the requirement for a utility-scale solar and brownfield solar photovoltaic project to be installed by Qualified Persons?
Under the Part 1 Proposal, the Seller must certify that the project has been installed or will be installed by a “qualified person[s] in compliance with the requirements of Section 16-128A of the Public Utilities Act and any rules or regulations adopted thereunder.” (Citing 20 ILCS 3855/1-75(c)(7)).
As stated in Section 2.5.2.4 of the IPA’s 2024 Long-Term Renewable Resources Procurement Plan, “The Illinois Commerce Commission has adopted administrative rules for the certification of utility-scale [solar] and distributed generation installers under Section 16-128A of the PUA. The Commission has specifically defined the terms “qualified person” and “install” for both categories of projects. Any entity seeking to develop new photovoltaic projects in Illinois should be aware of the Commission’s Part 461 rules (governing installers of utility-scale photovoltaics), Part 468 rules (governing distributed generation installers) and the certification process more generally.” The Illinois Commerce Commission has regulatory authority over solar installers in Illinois; questions related to the interpretation of the Commission’s administrative rules are best directed to the Commission.
For utility-scale solar projects, the definitions of “install” and “qualified person” for project installations, and details for utility-scale solar installer certification under Section 16-128A of the PUA (220 ILCS 5/16-128A) and 83 Ill. Adm. Code 461 (“Part 461”) are accessible here.
For distributed generation facilities, the definitions of “install” and “qualified person” for project installations, and details for distributed generation facilities installer certification under Section 16-128A of the PUA and 83 Ill. Adm. Code 468 (“Part 468”) are accessible here.
10-30-2025FAQ-Indexed REC-63
Q: What is the Minimum Equity Standard? How does it relate to the Equity Accountability System?
The Minimum Equity Standard is a minimum percentage of an applicant’s project workforce that must be comprised of Equity Eligible Persons. Please see additional FAQs below for definitions of “Project Workforce” and “Equity Eligible Person.”
The Equity Accountability System is the umbrella suite of policy levers and standards included in the Illinois Power Agency Act that advance “priority access to the clean energy economy for businesses and workers from communities that have been excluded from economic opportunities in the energy sector, have been subject to disproportionate levels of pollution, and have disproportionately experienced negative public health outcomes” (20 ILCS 3855/1-75(c-10)). The Equity Accountability System includes the Minimum Equity Standard (“MES”), the reserved category in the Adjustable Block Program for Equity Eligible Contractors (“EECs”), and the requirements developed by the Agency to ensure “that competitive procurement processes, including utility-scale solar, utility-scale wind, and brownfield site photovoltaic projects, advance the equity goals” of the Climate and Equitable Jobs Act (20 ILCS 3855/1-75(c-10(3))).
The IPA, through its 2024 Long-Term Renewable Resources Procurement Plan (“Long-Term Plan” or “Plan”), developed requirements for utility-scale projects bid into competitive procurements for indexed REC contracts that require those projects to meet the Minimum Equity Standard and provide additional prioritization for projects that employ a higher percentage of Equity Eligible Persons (“EEPs”) than that required by the MES. Thus, the MES (and the associated Compliance Plan) and the equity prioritization mechanism constitute the pieces of the Equity Accountability System applicable to bidders in competitive procurements, and those steps constitute full compliance with the Equity Accountability System.
The IPA created a Minimum Equity Standard (MES) webpage to provide the most up to date MES related documents, educational resources, and training materials related to MES Compliance Plans and waiver requests. Please visit the IPA Minimum Equity Standard webpage here: https://ipa.illinois.gov/diversity-equity-and-inclusion/minimum-equity-standard.html
In particular, the IPA posted an MES Compliance and Waiver Request Training Presentation applicable to utility-scale solar and wind projects under the header “MES Educational Resources”.
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Q: Who qualifies as an Equity Eligible Person?
The Climate and Equitable Jobs Act (“CEJA”) defines an equity eligible person as:
- Persons who graduate from or are current or former participants in the Clean Jobs Workforce Network Program, the Clean Energy Contractor Incubator Program, the Illinois Climate Works Pre-apprenticeship Program, the Returning Residents Clean Jobs Training Program, or the Clean Energy Primes Contractor Accelerator Program, and the solar training pipeline and multi-cultural jobs program created in paragraphs (a)(1) and (a)(3) of Section 16-108.21 of the Public Utilities Act;
- Persons who are graduates of or currently enrolled in the foster care system;
- Persons who were formerly incarcerated; [or]
- Persons whose primary residence is in an equity investment eligible community. (20 ILCS 3855/1-10).
A person may fall into multiple categories or only one; a person does not need to have participated in a CEJA- or FEJA-funded training program in order to be an EEP if they qualify under one of the other categories.
An “equity investment eligible community” is defined by CEJA as:
- R3 Areas as established pursuant to Section 10-40 of the Cannabis Regulation and Tax Act, where residents have historically been excluded from economic opportunities, including opportunities in the energy sector; and
- Environmental justice communities, as defined by the Illinois Power Agency pursuant to the Illinois Power Agency Act, where residents have historically been subject to disproportionate burdens of pollution, including pollution from the energy sector. (20 ILCS 3855/1-10).
A map of R3 Areas can be found here, a map of environmental justice communities can be found here, and the Equity Investment Eligible Community Map that combines EJ and R3 areas can be found here.
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Q: Are suppliers required to submit Compliance Plans related to the MES under the Indexed REC Contract?
CEJA requires that applicants comply with the MES through a Compliance Plan submitted at the start of the delivery year. Section 1-75(c-10)(1)(A) directs that:
At the start of each delivery year, the Agency shall require a compliance plan from each entity participating in a procurement program of subsection (c) of this Section [1-75] that demonstrates how they will achieve compliance with the minimum equity standard percentage for work completed in that delivery year. (20 ILCS 3855/1-75(c-10)(1)(A)).
Competitive procurements are required by Section 1-75, and therefore applicants to those procurements must submit a Compliance Plan under the law.
The Compliance Plan is meant to ensure that applicants are making a concerted effort to hire EEPs and contribute to the equity goals of CEJA. The law requires participants to complete a Compliance Plan, which contains the elements outlined above, and directs the Agency to ensure that competitive procurements advance the equity goals of CEJA. As laid out by the statute, CEJA envisions the EAS as a method to create “priority access to the clean energy economy for businesses and workers from communities that have been excluded from economic opportunities in the energy sector, have been subject to disproportionate levels of pollution, and have disproportionately experienced negative public health outcomes.” (20 ILCS 3855/1-75(c)(10)). Accounting for generations of such exclusion and disproportionate harms requires buy-in from all stakeholders and coordination between the public sector and private sector actors. The IPA hopes that all participants in competitive procurements take this policy seriously and contribute sincere efforts to creating a more equitable clean energy economy in Illinois.
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Q: Is a Compliance Plan required at the time of bid?
No. As provided in the Indexed REC RFP Rules, only if a Bidder optionally elects to commit to an Equity Level (%) greater than the Minimum Equity Standard of 14% is a plan required at the time of bid. In this case one of the requirements includes:
[The] Bidder must provide a narrative plan to meet the Equity Level (%) provided in the Part 1 Proposal. The narrative plan must include the following items:
- a narrative description of how the Seller will ensure that at least the Equity Level (%) will be met;
- a statement of intent to comply with all necessary requirements set forth in Public Act 102-0662 relating to the Minimum Equity Standard and agreement to comply with certain obligations, including hiring a diverse project workforce and working with Equity Eligible Contractors, where applicable;
- the total projected number of workers related to Construction Activities up to the point of the Date of First Operation, or up to the Hydropower Refurbishment Completion Date if the Project is a Modernized or Retooled Hydropower Project;
- plans for the use of Equity Eligible Contractors, if applicable;
- Seller classification (i.e., Minority-owned business enterprise, Woman-owned business enterprise, Disabled-owned business, Veteran-owned business, Small business, etc.), if applicable;
- the qualifying Equity Eligible Person category/categories the Seller seeks to hire, if known; and
- a communication plan for local outreach to increase the utilization of Equity Eligible Persons and Equity Eligible Contractors.
Many of these elements may be repeated in the eventual Compliance Plan submitted after a contract has been awarded to a selected bid. Given that the strike price for a project that submits an Equity Level (%) greater than the Minimum Equity Standard of 14% will be reduced for purposes of bid ranking, additional assurances should be provided that the Bidder will meet this commitment.
10-30-2025FAQ-Indexed REC-59
Q: What is the Energy Workforce Equity Portal? What role does it play in a Seller’s Compliance Plan and outreach efforts?
CEJA directs the IPA to develop an Energy Workforce Database in consultation with the Department of Commerce and Economic Development that consists of a searchable database of vendors, suppliers, and contractors that are minority and women-owned business enterprise certified or are certified as EECs. The IPA’s Energy Workforce Equity Portal is designed to help connect clean energy companies with Equity Eligible Persons looking to work in the clean energy sector in Illinois. Developers of clean energy projects, such as developers of utility-scale wind, utility-scale solar, and brownfield site solar projects, can use this portal to advertise clean energy jobs and to search for Equity Eligible Persons seeking employment, as Equity Eligible Persons register on the portal. Developers can also use the portal to apply to qualify as an Equity Eligible Contractor. Please visit the IPA Energy Workforce Equity Portal here.
Phase I of the portal was launched on January 31, 2023 and includes:
- Information on qualifications and requirements for job seekers to become Equity Eligible Persons.
- A form for applying to be certified as Equity Eligible Person.
- A listing of Equity Eligible Persons who have volunteered to identify themselves to potential clean energy companies.
- Information on job postings from clean energy companies for which they are recruiting Equity Eligible Persons.
- Information on workforce training programs administered by DCEO.
- Equity Investment Eligible (EIE) Community Map that can be utilized by anyone to determine if they or someone else reside in an identified equity investment eligible community.
- Information on Equity Eligible Contractors participating in the IPA’s Adjustable Block Program.
- FAQs outlining commonly asked questions and answers on the portal.
- A user guide to help clean energy companies and Equity Eligible Persons navigate the portal easily.
Phase II of the Portal, launched in Summer 2023, includes enhancements to help facilitate more inclusive participation in the clean energy workforce. Additional information can be found on the Portal’s Resources page.
The IPA hosted a training for participants to get acquainted with the portal and its various functionalities. This includes advertising jobs and searching for Equity Eligible Persons seeking employment, as they register on the portal. The training is available here.
The Energy Workforce Equity Database should serve as a tool for applicants to find EEPs, but may not include the entire universe of available EEPs seeking clean energy work, since it will only list EEPs that voluntarily add their information to the database. The Database is still in development and applicants should not assume they will be able to rely solely on the Database to find EEPs to meet the Minimum Equity Standard.
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Q: What is the status of FEJA- and CEJA-funded workforce training programs?
The Department of Commerce and Economic Development (“DCEO”) has awarded funding for FEJA-funded workforce training programs, the management of which passed to DCEO under CEJA. CEJA also created several new workforce training programs to be managed by DCEO.
Please monitor the DCEO CEJA website for updates from the Department on its job training programs.
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Q: What are the additional avenues for fulfilling the MES?
The IPA encourages applicants to utilize all possible means for identifying, recruiting, and hiring EEPs, especially those that qualify by virtue of their status as formerly incarcerated, a graduate of the foster care system, or a resident of an equity investment eligible community. The Long-Term Plan outlined several strategies that may be useful:
- Working with State-approved job training and workforce development programs to recruit EEPs and provide evidence of outreach
- Maintaining applications of individuals not selected for an opening for contact regarding future project openings
- Participating in job fairs and related local community events to recruit a diverse workforce
- Utilizing the Energy Workforce Equity Database
- Outreach on various platforms of targeted social media, engagement in direct outreach to relevant associations or organizations to notify them of the project opportunity. (2024 Long-Term Plan at page 362-363).
The IPA cannot provide advice to bidders regarding the specifics of a recruitment strategy or point an entity toward specific organizations or events where it might recruit EEPs.
10-30-2025FAQ-Indexed REC-56
Q: What reports are required to comply with MES?
Under Section 6.4 of the Indexed REC Contract, to demonstrate compliance with the MES the following reports must be submitted to the IPA , if applicable pursuant to Section 6.4(a) of the Indexed REC Contract;
- MES Compliance Plan. The first MES Compliance Plan shall be submitted to the IPA within thirty (30) days of the Commission Bid Approval Date regardless of whether Construction Activities have been performed or will be performed in that delivery year. Notwithstanding the foregoing, if the Date of First Operation of the Project as recorded by PJM-EIS GATS or M-RETS (or the Hydropower Refurbishment Completion Date if the Project is a hydropower project that is newly Modernized or Retooled) occurred prior to the date that is thirty (30) days of the Commission Bid Approval Date, then the MES Compliance Plan shall not be required. Subsequently, by June 1 of each delivery year, Seller shall submit to the IPA an MES Compliance Plan demonstrating how Seller will achieve compliance with the Minimum Equity Standard in such delivery year. The MES Compliance Plan shall include: (a) a narrative description of how Seller will meet the Minimum Equity Standard and a statement of intent to comply with equity accountability standards for the applicable delivery year and to hire a diverse project workforce including Equity Eligible Persons and Equity Eligible Contractors; (b) projected number of workers and the demographic breakdown by race, gender, and participation in job training or workforce development programs, or other means of compliance with the standard for Equity Eligible Persons; (c) plans for the use of Equity Eligible Contractors, if applicable; (d) Seller classification (i.e., Minority-owned, Woman-owned, Disabled-owned, Veteran-owned, Small Business, etc.), if applicable; (e) communication plan for local outreach to increase the utilization of Equity Eligible Persons and Equity Eligible Contractors; and (f) status of any corrective actions or adjustments from the prior delivery year’s MES Compliance Plan.
- Mid-Year MES Confirmation. No later than December 1 of each delivery year, Seller shall provide to the IPA a statement confirming that Seller is on track to meet the Minimum Equity Standard and that there exist no impediments for Seller to meet the Minimum Equity Standard for such delivery year. If Seller is unable to provide such confirmation, Seller shall explain why it is unable to meet the Minimum Equity Standard for such delivery year. The Mid-Year MES Confirmation shall be submitted to IPA via email at the email address provided in Exhibit B or submitted in accordance with procedures established by the IPA. If the Date of First Operation of the Project as recorded by PJM-EIS GATS or M-RETS (or the Hydropower Refurbishment Completion Date if the Project is a hydropower project that is newly Modernized or Retooled) occurred prior to the date that is thirty (30) days of the Commission Bid Approval Date, then the Mid-Year MES Confirmation shall not be required.
- MES Report. After the conclusion of a delivery year regardless of whether Construction Activities have been performed, and no later than July 15 immediately succeeding such delivery year, Seller shall submit to the IPA an MES Report. If the Date of First Operation of the Project as recorded by PJM-EIS GATS or MRETS (or the Hydropower Refurbishment Completion Date if the Project is a hydropower project that is newly Modernized or Retooled) occurred prior to the date that is thirty (30) days of the Commission Bid Approval Date, then the MES Report shall be submitted as soon as practicable on or around the date that is thirty (30) days after the Commission Bid Approval Date. The MES Report shall include data on actual performance compared to the information previously submitted as well as any major differences from the previously submitted MES Compliance Plan for such delivery year. These differences could include information such as new and innovative ways to provide employment opportunities to low-income participants and residents within the Environmental Justice Communities.
FAQ-Indexed REC-55
Q: Can we submit a single MES Compliance Plan for all Projects if we have multiple projects selected and approved under an Indexed REC RFP?
The Seller must submit the reports required by Section 6.4 Minimum Equity Standard of the Indexed REC Contract to the IPA separately for each such Project.
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Q: What are the consequences under the Indexed REC Contract for failure to meet the percentage requirement of the Minimum Equity Standard?
A Minimum Equity Standard of 14% will apply under the Indexed REC Contract to a Project selected through this RFP if the Date of First Operation (or the Hydropower Refurbishment Completion Date if the Project is a hydropower project that is newly Modernized or Retooled) is on or after December 15, 2022.
The remedies related to a failure to meet the percentage requirement of the Minimum Equity Standard (i.e., 14%) is described in Section 10.1.5.4 of the IPA’s 2024 long-term renewable resources procurement plan (the “Long-Term Plan”) as approved by the Illinois Commerce Commission in ICC Docket No. 22-0714, which is pasted below for your convenience. Further, please also note that Section 1-75(c-30) of the IPA Act provides the following: “……If the Agency concludes the entity has not met or maintained its minimum equity standards required under the applicable subparagraphs under subsection (c-10), the Agency shall deny the entity’s ability to participate in procurement programs in subsection (c), including by withholding approved vendor or designee status.”
As set forth in Section 6.4(d) of the Indexed REC Contract, “no other remedies are contemplated under the Indexed REC Contract for Seller’s failure to comply with the Minimum Equity Standard requirements”. As such, failure to meet the percentage requirement of the Minimum Equity Standard is not an event of default leading to contract termination or forfeiture of the performance assurance under the Indexed REC Contract.
As noted above, and for your convenience, Section 10.1.5.4 of the 2024 Long-Term Plan provides that:
“If the Agency determines that an Approved Vendor, Designee, or Competitive Procurement Supplier has failed to comply with any of the requirements set forth by the Agency, or any contract, the entity will be notified and may face disciplinary action. The Agency will impose consequences for violations by program participants, including but not limited to:
- Notice of Potential Violation
- Suspension of the entity’s ability to submit project applications to IPA programs or to participate in competitive procurements during the remainder of the delivery year.
- Repeated violations could potentially result in the Approved Vendor or Designee becoming suspended from the IPA’s programs for an entire delivery year or more. Competitive Procurement Suppliers could likewise be barred from participation in future competitive procurement events.
- Provision of Mid-year Progress information
If the entity does not submit a Compliance Plan or if the Compliance Plan fails to meet the required Minimum Equity Standards after the chance to resubmit, it will receive a Notice of Potential Violation (NOPV). If the entity doesn’t submit an edited Compliance Plan or the revised Compliance Plan still does not pass after receiving an NOPV, it will be issued an official warning letter from the Agency. If the entity does not submit an edited Compliance Plan or the revised Compliance Plan still does not pass after receiving a warning letter, it will be issued suspension letter. Suspensions of an Approved Vendor or Designee in the Adjustable Block Program will be noted on the program website’s lists of Approved Vendors and Designees as well listed on the disciplinary actions report and in the Energy Workforce Equity Database”
Please see Section 6.4 of the Indexed REC Contract as well as the FAQs page for additional information on the MES including requirements, compliance plans, and waiver requests.
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Q: What information will be publicly disclosed for winning applications?
Please see paragraph VI.2.16. of the RFP Rules. At the time of Commission approval of a procurement event, the names and contact information of winning Bidders, the average of the winning Bid prices, and the business address and nameplate capacity of the Project are made public. Additionally, as approved under the 2024 Long-Term Plan, the Annual Quantity of RECs for Projects selected and approved by the Commission will also be released as long as the confidentiality of individual winning Bid prices is maintained. The Public Utilities Act states that participants in the procurement process will maintain the confidentiality of all other supplier and bidding information.
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Q: Where can I find the results from previous Indexed REC Procurements?
The results from previous procurement events can be found on the procurement website. If you click on the “Previous RFPs” link on the left-hand side of the home page, you can find a list of previous procurements. Within each procurement’s archived page you can locate the procurement results.
10-30-2025FAQ-Indexed REC-51
Q: Can we provide an alternative form of bid assurance collateral, such as a surety bond?
Bid assurance collateral, which is due with the Part 2 Proposal, must be submitted in the form of cash or a letter of credit. Surety bonds are not an accepted form of bid assurance collateral.
Whether providing bid assurance collateral in the form cash or a letter of credit for a Company, the Bidder must follow all instructions provided by the Procurement Administrator for transmission of bid assurance collateral to each Company. Such instructions are provided after submission by the Bidder of a Part 1 Proposal and by the date of the Part 1 Notification. Such instructions specify that the Bidder must provide cash by wire transfer and that the original executed Pre-Bid Letters of Credit must be in the form of Appendices 5, 6 and 7 to the RFP Rules if submitting the letter of credit via electronic means or in the form of Appendices 8, 9 and 10 to the RFP Rules if submitting the letter of credit via overnight delivery service. The letter of credit may include only modifications to the Standard Pre-Bid Letter of Credit acceptable to that Company, applicable specifically to either the Electronic Version or Hardcopy Version, and posted to the procurement website.
Each of the Electronic Versions and Hardcopy Versions of the Pre-Bid Letters of Credit have been posted in separate zip files along with the corresponding lists of modifications acceptable to each Company. A Bidder may provide comments on or propose modifications to each Pre-Bid Letter of Credit drawn for the benefit of a Company with the Part 1 Proposal. Any one of a Bidder’s comments or proposed modifications to a Pre-Bid Letter of Credit may result in an addition to the list of modifications to the Pre-Bid Letter of Credit approved by the Company for use by all Bidders on an optional basis. The Bidder provides comments and proposes modifications exclusively by submitting a redline of a Pre-Bid Letter of Credit in Microsoft Word format. This document is provided by email or by upload to the application website.
10-30-2025FAQ-Indexed REC-50
Q: Can the Bidder submit multiple Bids for a project?
Please see paragraph V.5.5. of the RFP Rules which states, “Only one Bid may be submitted for a Project.”
10-30-2025FAQ-Indexed REC-49
Q: What is the relationship between the annual quantity indicated in our bid and the annual quantity in the Indexed REC Contract? Also, how is the Maximum Contract Quantity under the Indexed REC Contract determined?
First, if you bid and win in the RFP, the RECs from your winning Project will be allocated by the Procurement Administrator to the Companies in pre-specified proportions (27.09% to AIC, 72.67% to ComEd, and 0.24% to MEC). As such, it is contemplated that you will sign three contracts, one with each of AIC, ComEd and MEC.
Second, the annual quantity that you bid and win in the RFP will be the “RFP Awarded Annual Quantity” in each of the Indexed REC Contracts. The Annual Quantity in a contract will reflect the portion of the RFP Awarded Annual Quantity allocated to such contract. The Maximum Contract Quantity will be equal to the Annual Quantity indicated in such contract multiplied by 20.
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Q: What does it mean if the Committed Project Percentage for a Project is 100%?
Project Committed Percentage means the percentage of the Project’s Actual Production to be used for purposes of the Standing Order with each Company. A Project Committed Percentage of 100% would mean that 100% of the RECs produced from the Project will be used for purposes of the Standing Order. Please see Section 2.3 of the Indexed REC Contract for more information including a numerical example in footnote 7.
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Q: What is the process to submit comments on the Indexed REC Contract?
The Procurement Administrator held a comment process on the Draft Indexed REC Contract and Preliminary Proposal Requirements. Comments were due on October 6, 2025. The Final Indexed REC Contract was posted to the Final Material pages of the Indexed REC Section of the procurement website on October 20, 2025. Each Seller must accept the terms of the Indexed REC Contract as a condition of participation.
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Q: Is there a requirement for the Seller to own the Project?
A Seller that cannot certify that it owns the Project and that it will own the Project at the time of execution of the Indexed REC Contracts must disclose this fact. A Seller that does not own the Project but has full title to the RECs produced by the Project will be required to provide documentation that shows this to be the case.
10-30-2025FAQ-Indexed REC-45
Q: What are the fees required to participate in the Indexed REC RFP?
A Bidder that has not already paid a Bid Participation Fee pursuant to participation in a 2025 procurement event held on behalf the IPA and that submits a Part 1 Proposal in this RFP, is required to pay a non-refundable Bid Participation Fee of $500. A Bidder that submits Proposals for multiple Projects (regardless of Category) is only required to pay a single Bid Participation Fee.
Projects with winning Bids approved by the Commission will be assessed a Supplier Fee per REC that reflects the cost of conducting the procurement event less the total of the Bid Participation Fees. The exact amount of the Supplier Fee per REC will be announced no later than two (2) business days before the Bid Date. Payment of the Supplier Fees to the IPA by the Bidder or Seller will be due within twelve (12) business days after Commission approval of the Bids. An estimate of the Supplier Fee per REC is provided in the webcast.
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Q: What is the timeline for executing the Indexed REC Contract?
Please refer to paragraph VI.2.17 for details on the timeline for executing the Indexed REC Contract:
If a Seller has a Project with approved Bids, each Company prepares and sends a partially executed electronic copy of the Indexed REC Contract and related documents to the Seller. Each Company expects to provide such documents to Seller on the same day as the Commission approval, but no later than by 12 PM (noon) on the first business day after the Commission decision. The effective date of the Indexed REC Contract shall be the date of the Commission approval of the results of the procurement event. It is expected that the signatory named in the Contract Insert for each Company’s Indexed REC Contract will sign a copy of the partially executed Indexed REC Contract and related documents. If this individual is not available to sign the Indexed REC Contract and related documents, the Seller will advise each Company of this fact, will name another individual to sign the Indexed REC Contract and related documents, and will confirm that this individual is an officer, a director, or an individual otherwise authorized to undertake contracts (including the applicable supplier contract documents) and bind the Seller.
By 12 PM (noon) CPT (1 PM Eastern Prevailing Time) on the third business day after the Commission decision, the Seller executes the signature pages of the partially executed Indexed REC Contracts and related documents and sends such fully executed signature pages to each Company electronically. Creditworthiness requirements under the applicable Indexed REC Contract must be met within fifteen (15) business days after the Commission decision in accordance with the terms of the Indexed REC Contract. Upon execution of the Indexed REC Contracts and related documents in counterparts by both parties, such Indexed REC Contracts and related documents are fully executed.
The Procurement Administrator will provide instructions to each Bidder qualified pursuant to a successful Part 1 Proposal for executing and completing the Indexed REC Contract should the Bidder have winning Bids that are approved by the Commission. The Procurement Administrator will outline such instructions as part of the webcast to be held at or prior to the opening of the Part 1 Window.
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Q: Is there any flexibility in allowing comments on the Pre-Bid and Post-Bid Letters of Credit after Part 1 date?
Comments on or proposed modifications to a Pre-Bid or Post-Bid Letter of Credit are due with the Part 1 Proposal. The respective Company will review a Bidder’s comments or proposed modifications and a response with the evaluation is provided directly to the Bidder. Additionally, any comment or proposed modification that is approved by a Company will be added to the list of modifications approved by the Company for use by all Bidders on an optional basis. Therefore, comments must be submitted with the Part 1 Proposal to give adequate time for review prior to the opening of the Part 2 window when Bidders may start submitting Bid Assurance Collateral in the form of a Pre-Bid Letter of Credit.
10-30-2025FAQ-Indexed REC-42
Q: What are ETCGA requirements for the Part 1 proposal?
The Bidder must confirm whether at least 50% of the Project site is located within an Energy Transition Community Grant Area (“ETCGA”) in the Part 1 Proposal. An Energy Transition Community Grant Area is an area that is both within a 30-mile radius of the coordinates associated with a plant or mine in Table A in Appendix 16 to the RFP Rules and within Illinois. The Project may be located in more than one ETCGA. If the Bidder confirms that at least 50% of the Project site is located within an ETCGA, the Bidder must provide the name of the plant(s) and/or mine(s) from Table A associated with the ETCGA(s) applicable to the Project. The Bidder must provide evidence that at least 50% of the Project site is located within the applicable ETCGA(s). Such evidence may be a map that clearly displays the distance between the plant(s) and/or mine(s) and the Project site and includes the names of the plant(s) and/or mine(s). The Officer of the Seller must also certify that at least 50% of the Project site will be located within the boundary of the Energy Transition Community Grant Area(s) associated with the plant(s) and/or mine(s) named in the Part 1 Proposal. Please note that only utility-scale wind and utility-scale solar projects located in Illinois are eligible for the ETCGA bid evaluation price reduction.
10-30-2025FAQ-Indexed REC-41
Q: What is the procurement quantity for utility-scale solar projects in the Fall 2025 Indexed REC RFP?
On August 21, 2025, the Illinois Commerce Commission (“ICC”) granted the reopening of ICC Docket 23-0714 related to the Illinois Power Agency’s Long-Term Renewable Resources Procurement Plan (“2024 Long-Term Plan”). On October 16, 2025, the ICC issued an Order on Reopening in this docket approving a procurement target of 666,666 RECs delivered annually from new utility-scale solar projects in the Fall 2025 Indexed REC RFP. For more information on the background for the 2024 Long-Term Plan reopening, please see the ICC website: https://www.icc.illinois.gov/docket/P2023-0714/documents.
10-30-2025FAQ-Indexed REC-40
Q: Is the supplier fee paid by cash or a letter of credit?
Generally, two electronic methods of payment, ACH or E-Pay, will be accepted by the IPA for the payment of the required supplier fees. The Procurement Administrator will distribute detailed instructions for payment of the supplier fees to Bidders that have Bids approved by the ICC. The ICC is expected to render its decision on the results of the Fall 2025 Indexed REC procurement on Tuesday, December 16, 2025.
The invoice for the supplier fee will be sent to Bidders that have Bids approved by the ICC directly from the Illinois Power Agency after the ICC decision is released.
10-30-2025FAQ-Indexed REC-39
Q: What is the definition of a strike price? How is the strike price used for payment under the Indexed REC Contract?
As defined in the IPA Act, “Strike price” means a contract price for energy and renewable energy credits from a project. The strike price ($/MWh) in the Bid and the Index Price ($/MWh) that corresponds to the Index Hub selected in the bid form will be used for purposes of calculating the REC Monthly Price, defined in the Indexed REC Contract (e.g. if MISO-IL Hub is selected in the bid form as the Index Hub for the Project, then the Index Price for purposes of calculating the REC Monthly Price will be the hourly Real-Time LMP for the MISO-IL Hub).
The REC Monthly Price applicable to the Project with respect to a Vintage month shall be calculated as follows. The REC Monthly Price Hourly Component is the product of (a) the result obtained by subtracting the Strike Price from the Index Price of such hour and (b) the MWh actual generation of the Project for such hour. The REC Monthly Price for a Vintage month shall be calculated by dividing (a) the sum of all REC Monthly Price Hourly Components in such Vintage month by (b) the MWh actual generation of the Project for such Vintage month, and rounding to the nearest cent. The REC Monthly Price may be either positive or negative. Payment is made from Seller to Buyer if the REC Monthly Price is positive and payment is made from Buyer to Seller if the REC Monthly Price is negative.
Please review the Indexed REC Contract posted to the Final Materials page of the procurement website for additional information.
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Q: When is the deadline to execute the Indexed REC Contract? What if the Seller does not execute the Indexed REC Contract by this date?
Sellers must execute the signature pages of the partially executed Indexed REC Contracts and related documents and send such fully executed signature pages to each Company electronically by 12 PM (noon) CPT (1 PM Eastern Prevailing Time) on the third business day after the Commission decision. The Commission is expected to render a decision on the procurement results on December 16, 2025.
Please be aware that a Company may draw upon the letter of credit or a Company may draw upon a cash deposit if a Seller has failed to execute the applicable supplier contract for a Project within three (3) business days of being notified that the Illinois Commerce Commission has approved the Bid on that Project or has failed to meet the creditworthiness requirements of the applicable supplier contract within fifteen (15) business days of such Illinois Commerce Commission decision.
10-30-2025FAQ-Indexed REC-37
Q: How are benchmark prices formulated?
The Illinois Power Agency Act (“IPA Act”) requires that benchmarks are kept confidential. Benchmarks are established by the Procurement Administrator, in consultation with the IPA, the Procurement Monitor, and the ICC Staff. The benchmark is subject to review and approval by the Commission.
Section 1-75(c)(1)(D) of the Act states that, “Renewable energy credits shall be cost effective. For purposes of this subsection (c), “cost effective” means that the costs of procuring renewable energy resources do not cause the limit stated in subparagraph (E) of this paragraph (1) to be exceeded and, for renewable energy credits procured through a competitive procurement event, do not exceed benchmarks based on market prices for like products in the region. For purposes of this subsection (c), “like products” means contracts for renewable energy credits from the same or substantially similar technology, same or substantially similar vintage (new or existing), the same or substantially similar quantity, and the same or SB2408 Enrolled LRB102 11366 BMS 16699 b Public Act 102-0662 substantially similar contract length and structure. Benchmarks shall reflect development, financing, or related costs resulting from requirements imposed through other provisions of State law, including, but not limited to, requirements in subparagraphs (P) and (Q) of this paragraph (1) and the Renewable Energy Facilities Agricultural Impact Mitigation Act. Confidential benchmarks shall be developed by the procurement administrator, in consultation with the Commission staff, Agency staff, and the procurement monitor and shall be subject to Commission review and approval. If price benchmarks for like products in the region are not available, the procurement administrator shall establish price benchmarks based on publicly available data on regional technology costs and expected current and future regional energy prices. The benchmarks in this Section shall not be used to curtail or otherwise reduce contractual obligations entered into by or through the Agency prior to June 1, 2017 (the effective date of Public Act 99-906).”
Additional information regarding the benchmark development process is provided in an Invitation to Comment posted to the Draft Documents page on the procurement website. Stakeholder comments on the benchmark categories of inputs, assumptions, and data sources were due on Wednesday, October 22, 2025.
10-30-2025FAQ-Indexed REC-36
Q: Is the Date of First Operation provided in the Part 1 Proposal a binding date?
There is no REC delivery obligation associated with the expected Date of First Operation provided in a Bidder’s Part 1 Proposal as this date is not binding. The actual Date of First Operation may be different from the expected date provided in the Proposal.
However, please note, each Project selected through this RFP with a Bid approved by the Commission must deliver at least one REC to each Company by May 31, 2030. Notwithstanding the foregoing, such deadline may be extended to May 31, 2032 if Seller meets an increased collateral requirement; and may be further extended as described in the Indexed REC Contract.
10-30-2025FAQ-Indexed REC-35
Q: Can office staff related to the Project may be included in the Project Workforce for purposes of the Minimum Equity Standard (MES) requirements?
Yes, office staff related to the Project may be included in the Project Workforce for purposes of the Minimum Equity Standard (MES) requirements, provided they are located in Illinois.
As the MES of 14% is a contractual obligation, please rely on definition of “Project Workforce” in Section 1.95 of the Indexed REC Contract for purposes of determining the percentage of EEPs in the Project Workforce:
“‘Project Workforce’ means employees, contractors and their employees, and subcontractors and their employees whose job duties are directly required by or substantially related to the development, construction, and operation of the Project that is participating in the IPA-administered programs and procurements under Section 1-75(c) of the IPA Act. This shall include both project installation workforce and workforce in administrative, sales, marketing, and technical roles where those workers’ duties are directly related to the Project. For workforce in administrative, sales, marketing and technical roles, this shall apply only if those workers are located in Illinois. For purposes of this definition, “directly required by or substantially related to” shall be construed to be any direct employee of Seller, or any contractor and its employees whose contract exceeds 5% of the REC Contract Value. Employees of contractors below that threshold may be counted toward the MES on a voluntary basis, but then all employees of all contractors below the 5% of REC Contract Value threshold must be included.”
10-30-2025FAQ-Indexed REC-34
Q: Can you give more details on the initial Performance Assurance to be posted under the Indexed REC Contract if Seller is not eligible for unsecured credit?
If you bid and win in the RFP, the RECs from your winning Project will be allocated by the Procurement Administrator to the Companies in pre-specified proportions (27.09% to AIC, 72.67% to ComEd, and 0.24% to MEC). As such, it is contemplated that you will sign three contracts, one with each of AIC, ComEd, and MEC. Each Indexed REC Contract is administered separately and independently by each of Companies, as such the Performance Assurance is determined for each of AIC, ComEd, and MEC independently.
The amount of the Performance Assurance is defined in Section 7.1 of the Indexed REC Contract. “The amount of such Seller’s Performance Assurance shall be equal to the positive difference, if any, between: (a) the Collateral Requirement (or Increased Collateral Requirement, if applicable); and (b) the Collateral Threshold, as estimated by Buyer (“Performance Assurance Amount”).”
For an entity that is not eligible for unsecured credit under the Indexed REC Contract, Collateral Requirement means, (a) with respect to a Utility-Scale Wind Project or a Hydropower Project, an amount equal to four dollars ($4) times the Annual Quantity and which shall be reduced for the last Delivery Year, if applicable, to reflect an amount equal to the product of the Delivery Year Requirement for the last Delivery Year and four dollars ($4); provided that if the Collateral Requirement is calculated to be less than $20,000, then the Collateral Requirement shall be $20,000; and means, (b) with respect to a Utility-Scale Solar Project or a Brownfield Site Photovoltaic Project, an amount equal to ten dollars ($10) times the Annual Quantity and which shall be reduced for the last Delivery Year, if applicable, to reflect an amount equal to the product of the Delivery Year Requirement for the last Delivery Year and ten dollars ($10); provided that if the Collateral Requirement is calculated to be less than $20,000, then the Collateral Requirement shall be $20,000.
A Seller with a Project with an approved Bid must meet the creditworthiness requirements under the Indexed REC Contract within fifteen (15) business days of the Illinois Commerce Commission decision on the results of the procurement event.
10-30-2025FAQ-Indexed REC-33
Q: If we are using Pre-Bid Letters of Credit from more than one bank, should we submit their comments and proposed modifications separately?
A Bidder may only submit a single document with all of its comments and proposed modifications for each of the Pre-Bid Letter of Credit – Electronic Version, the Pre-Bid Letter of Credit – Hardcopy Version, and each Post-Bid Letter of Credit option. Please consolidate all comments and proposed modifications within a single submission for each applicable form and Company.
Also, please be aware that any comments or proposed modifications to the Pre-Bid Letters of Credit for the Fall 2025 Indexed REC RFP must be submitted for review in redline using the standard form posted on October 20, 2025. The Standard Forms of the Pre-Bid Letters of Credit contain changes to the standard forms from the prior procurement event.
Currently posted to the procurement website are preliminary lists of acceptable modifications to the Standard Pre-Bid and Post-Bid Letters of Credit. These lists include all of the modifications that are already acceptable to a Company for use in this Fall 2025 Indexed REC RFP and include modifications proposed and approved from the prior procurement event. A Bidder does not need to resubmit any of the modifications on this list for approval again.
10-29-2025FAQ-Indexed REC-32
Q: Is the Bid due by the Part 2 Date?
The Bid for the Project, which includes the strike price ($/MWh), is submitted between 10 AM and 12 PM (noon) on the Bid Date on Wednesday, December 10, 2025. Bidders must use the Bid Form provided by the Procurement Administrator for purposes of submitting Bids. The Bid Form is provided to Bidders with Projects that qualify pursuant to a successful Part 1 Proposal on the Part 1 Notification date on Friday, November 14, 2025.
The Part 2 Proposal, which includes submission of the online Part 2 Form and posting Bid Assurance Collateral, is due prior to the Bid Date, by 12 PM (noon) on the Part 2 Date on Monday, December 1, 2025.
10-28-2025FAQ-Indexed REC-31
Q: Do Projects need to have entered into a Project Labor Agreement with a General Contractor by the Part 2 Date?
The answer to your question depends on if construction for the Project has begun as of the submission of the Part 1 Proposal, but not prior to September 15, 2021. If construction has not yet begun as of the submission of the Part 1 Proposal, an executed PLA is not required. Instead, the Officer of the Seller must make certain representations applicable to the Project in the P1 Project Labor Agreement Insert (#P1-13). These representations can also be found in paragraph IV.7.4 of the RFP Rules.
If construction has begun as of the submission of the Part 1 Proposal, but not prior to September 15, 2021, the Bidder must provide evidence that the Project Labor Agreement(s) and any amendments thereto for the Project have been filed with the Director of the IPA by email to IPA.PLA@Illinois.gov. Evidence that the IPA has determined that such Project Labor Agreement(s) and any amendments meet the requirements under the IPA Act and the Project Labor Agreements Act is due by the Part 2 Date. If the IPA has already determined that such Project Labor Agreement(s) and any amendments meet the requirements, evidence of this determination may be provided with the Part 1 Proposal.
The requirements related to the Project Labor Agreement do not apply to a Project if construction began prior to September 15, 2021, the date that Public Act 102-0662 became effective. Additionally, all hydropower projects are exempt from Project Labor Agreement requirements.
10-28-2025FAQ-Indexed REC-30
Q: Is the Minimum Equity Standard (“MES”) of 14% subject to increase under the Term of the Indexed REC Contract?
A Minimum Equity Standard (“MES”) of 14% will apply under the Indexed REC Contract to a Project selected through this RFP if the Date of First Operation is on or after December 15, 2022, or for a Modernized or Retooled Hydropower Project, if the Hydropower Refurbishment Completion Date, as defined in the Indexed REC Contract, is on or after December 15, 2022. At least 14% of the Project Workforce in each applicable delivery year shall be Equity Eligible Persons or Equity Eligible Contractors, as these terms are defined in the Indexed REC Contract. The MES applies for each delivery year in which Construction Activities are carried out through the Date of First Operation, or if the Project is a Modernized or Retooled Hydropower Project, through the Hydropower Refurbishment Completion Date.
For Contracts executed under this Fall 2025 Indexed REC RFP, the minimum percentage indicated in the Product Order for the Minimum Equity Standard shall not change during the Term of the Indexed REC Contract.
Please review paragraph IV.3.1 of the RFP Rules and Section 6.4 of the Indexed REC Contract for additional information.
10-28-2025FAQ-Indexed REC-29
Q: In order to meet the requirements to commit to an Equity Level (%) greater than the MES of 14% are we required to provide the information outlined in Appendix A in Appendix 14 to the RFP Rules for each Equity Eligible Person listed?
In order to qualify for the bid evaluation price reduction described in Paragraph 1.2.11 of the RFP Rules for the Fall 2025 Indexed REC RFP, a Bidder must provide each of the requirements listed in Paragraph IV.3.2 of the RFP Rules. This includes providing letter(s) of intent or evidence of current employment related to 50% times the Equity Level (%) provided in the Part 1 Proposal times the total projected number of workers in the Project Workforce during delivery years for which Construction Activities will be performed up to the point of the Date of First Operation, or up to the Hydropower Refurbishment Completion Date if the Project is a Modernized or Retooled Hydropower Project, provided in the narrative plan.
Any letter of intent or evidence of current employment must meet the minimum requirements provided in Appendix 14 to the RFP Rules. This includes the requirement that the information outlined in Appendix A must be provided for each Equity Eligible Person listed (#9).
Given that the strike price for a project that submits an Equity Level (%) greater than the Minimum Equity Standard of 14% will be reduced for purposes of bid ranking, additional assurances should be provided that the Bidder will meet this commitment.
10-28-2025FAQ-Indexed REC-28
Q: Can a Project’s energy be stored in a battery prior to entering through the Revenue Quality Meter?
No. The arrangement proposed in your example is prohibited under the Indexed REC Contract. In order for the REC Monthly Price Hourly Component to be calculated under the Indexed REC Contract, the Project must allow for its MWh production (as opposed to energy exported from the storage facility) to be measured for each hour.
10-28-2025FAQ-Indexed REC-27
Q: Can a Project in MISO’s or PJM’s interconnection process related to surplus capacity at a shared Point of Interconnection (POI) participate in the Indexed REC RFP?
A Project in MISO’s or PJM’s interconnection process related to surplus capacity at a shared Point of Interconnection (POI) may qualify to participate in the Indexed REC RFP. Such a project must meet the requirements of the Indexed REC RFP Rules and comply with the Indexed REC Contract.
Please note, the Officer of the Seller must certify that the Project has or will have a single revenue quality meter that satisfies the requirements of the applicable regional transmission organization, transmission provider, or distribution company and that measures or will measure its generation output. Also, if one of the documents listed in Paragraph IV.7.2 of the RFP Rules to demonstrate adequate project maturity is not available, the Bidder must provide the required information in Paragraph IV.7.3 including demonstrating site control for a portion of the Project site.
10-28-2025FAQ-Indexed REC-26
Q: Can a Bidder offer partial capacity of a project in this RFP and then offer partial capacity of the same project in a future RFP?
Yes, that is possible. If in a subsequent procurement event the Bidder proposes the same Project and submits a bid for the remainder (or another portion) of the RECs, and the Project is selected and approved by the Commission, the Seller will sign a separate Indexed REC Contract that was posted for purposes of that subsequent event for those RECs. Thus, the two Indexed REC Contracts for the Project may have different terms.
In order to bid a remainder (or another portion) of the RECs from the Project, the Bidder is required to confirm that the Project will have a separate revenue quality meter (separate from the revenue quality meter associated with the portion of RECs for which the Project is already under contract) and will have its own account within PJM EIS GATS or M-RETS for purposes of tracking the RECs. Please also note that the MWh hourly generation that must be provided under Section 6.1 of the Indexed REC Contract, for which the REC Monthly Price Hourly Component is calculated for the RECs, must be from the Project as measured by the Project’s separate revenue quality meter and not from any other electric source.
10-27-2025FAQ-Indexed REC-25
Q: What is the definition of Construction Activities related to the Minimum Equity Standard requirements under the Indexed REC RFP?
We assume that you are asking for the definition of “Construction Activities” related to the Minimum Equity Standard requirements under the Indexed REC RFP. If the definition below does not answer your question, please contact the Procurement Administrator and specify the Part 1 Proposal requirement related to your question.
As defined in the Indexed REC Contract, “Construction Activities” means activities related to the Project that includes not only construction, but also any maintenance, repair, assembly, or disassembly work performed on equipment whether owned, leased, or rented and all construction work performed by Seller, including its contractors and subcontractors, relating to construction, maintenance, repair, assembly, or disassembly work in relation to the Project; and in the case of a Hydropower Project that is newly Modernized or Retooled, Construction Activities shall also include activities set forth in Section 1.75.
10-27-2025FAQ-Indexed REC-24
Q: Where do I upload site control documentation to the online Part 1 Form?
In the Part 1 Proposal, an RFP Bidder will be required to provide documentation to demonstrate adequate project maturity. The RFP Bidder must provide, if available for the Project, one of the following:
- the Queue/OASIS ID from PJM and a copy of the completed System Impact Study from PJM for the Project; or
- the Project Number from MISO and a copy of the Preliminary System Impact Study under Definitive Planning Phase 1 (“DPP 1”) under the DPP-2020-Cycle 1 or a later study cycle; or
- the Project Number from MISO and a copy of the fully executed interconnection agreement for the Project; or
- a fully executed interconnection agreement with a utility for the Project.
If none of the information bulleted above is available for the Project, or if the Bidder cannot provide a document that shows that the Project is further in the interconnection process, then the Bidder must: (i) if available, provide the Queue/OASIS ID from PJM, the Project Number from MISO, or the applicable ID/Number associated with the Project under the interconnection process with a utility; (ii) describe the stage of development of the Project applicable to the point of interconnection (including providing the name of the regional transmission organization or utility with which the Project plans to interconnect; e.g., PJM, Ameren, etc.) and to the size of the Project; and (iii) demonstrate control for a portion of the Project site as described in Paragraph IV.7.3 of the RFP Rules.
Upload fields for site control documentation can be found in Section 7 (Additional Project Information) of the online Part 1 Form. Please note that, because site control is only required for Utility-Scale Wind, Utility-Scale Solar, and Brownfield Site Photovoltaic Projects, the questions and upload fields for site control will not show up on the online Part 1 Form until the Bidder specifies the Category of the Project in the First Item of Section 2 (Project Information). If the answer to the question related to interconnection documentation in the first item of Section 7 is no, then the upload specifically for site control will appear under the second item of Section 7.
10-27-2025FAQ-Indexed REC-23
Q: Is a narrative plan to meet the Minimum Equity Standard of 14% required in the Part 1 Proposal?
A narrative plan to meet the Minimum Equity Standard of 14% is not required unless the Seller opts to commit to an Equity Level (%) greater than the MES of 14% in order to qualify for the bid evaluation price reduction described in Paragraph 1.2.11 of the RFP Rules. This is an optional commitment available to the Seller if the Project has not yet started Construction Activities. Please refer to Paragraph IV.3.2 of the RFP Rules for information on the specific requirements of the MES narrative plan if you plan to opt into the Equity Level Commitment. The RFP Rules is available on the on the Final Materials page of the Procurement website. There is no “Guidebook” for the Indexed REC RFP.
10-27-2025FAQ-Indexed REC-22
Q: Is the online Part 1 Form a single page? Is there no additional information required after hitting submit?
The online Part 1 Form is a single webpage. Once the Bidder presses “Submit” at the bottom of the online form for a Project, the Bidder will be temporarily locked out of the account for the Project as the Procurement Administrator evaluates the information submitted. Additional information or documentation may be required by the Procurement Administrator after the evaluation is complete. Bidders will be notified of the additional information or documentation required by the Procurement Administrator in a notice sent via email if that is the case. Please refer to the Part 1 Processing document located under Appendix 2: Illustrative Part 1 Form on the Final Materials page of the Procurement website for information on the timeline and process.
10-27-2025FAQ-Indexed REC-21
Q: What counts as an Acceptable Digital Signature?
As stated in Article IV of the RFP Rules, “A digital signature together with an additional document or information that verifies the identity of the signatory is an “Acceptable Digital Signature”. Additional documentation or information may include: (i) a certificate of completion if the signatory uses DocuSign; (ii) a Final Audit Report if the signatory uses Adobe Sign; (iii) evidence that the digital signature has been certified by the signatory using a document signing certificate; or (iv) other documentation or information produced by a commercially available software that can be used by the Procurement Administrator to verify the identity of the signatory. Digital signatures without a document or information verifying the identity of the signatory are not acceptable; signature images and other electronic signatures are not acceptable.”
10-27-2025FAQ-Indexed REC-20
Q: How long are the certifications made as a part of the Part 1 Proposal valid and in full force?
As stated in Section III.1.5. of the Indexed REC RFP Rules, “All information provided and certifications made in the Part 1 Proposal must remain valid and in full force until fourteen (14) business days after the anticipated date of the Commission decision on the procurement event. Regardless of the reason, if any information provided in the Part 1 Proposal changes or any previous certification fails to remain valid, it is the sole responsibility of the Bidder and Seller to notify the Procurement Administrator. Failing to do so may result in disqualification of the Project and of the Proposal. The Procurement Administrator reserves the right to change the assessment of qualifications based on any revised information provided by the Bidder or Seller.”
10-27-2025FAQ-Indexed REC-19
Q: Is the Seller required to pay the Increased Collateral Requirement in order to extend the Initial REC Delivery Deadline pursuant to Section 2.4 of the Indexed REC Contract if the Seller or the Seller’s Guarantor is investment grade?
Pursuant to Section 2.4 of the Indexed REC Contract the Seller may extend the REC Delivery Deadline from May 31, 2030 to May 31, 2032 if the Seller posts the Increased Collateral Requirement. The Increased Collateral Requirement would be required to extend this deadline pursuant to Section 2.4 regardless of the Seller’s or Guarantor’s credit ratings.
10-27-2025FAQ-Indexed REC-18
Q: Is there a competitive procurement event planned for energy storage?
The purpose of this website is to provide information to suppliers participating in the Illinois Power Agency (“IPA”)’s competitive procurement events. There are currently no competitive procurement events planned for energy storage projects in 2025.
The IPA develops procurement plans and conducts competitive procurement processes in accordance with the requirements of Section 1-75 of the Illinois Power Agency Act and Section 16-111.5 of the Public Utilities Act. The IPA filed their Long-Term Renewable Resources Procurement Plan (“2026 Long-Term Plan”) on October 20, 2025 with the Illinois Commerce Commission. Chapter 5 of the 2026 Long-Term Plan covers the IPA’s competitive procurement activities relevant to Ameren Illinois Company (“Ameren Illinois”), Commonwealth Edison Company (“ComEd”), and MidAmerican Energy Company (“MidAmerican”) for 2026 and 2027. A competitive procurement related to energy storage is not contemplated under the 2026 Long-Term Plan. Please see Chapter 5.6. of the 2026 Long-Term Plan for the schedule of competitive procurement events for 2026 and 2027. More information regarding the IPA’s 2026 Long-Term Plan is available here: https://ipa.illinois.gov/renewable-resources/long-term-plan.html
FAQ-Indexed REC-17
Q: How is the Project site determined for a utility-scale wind or utility-scale solar project?
For the purposes of the Indexed REC RFP, the Project site is based on the Project site map a Bidder provides for the Project in the Part 1 Proposal.
The map must include a boundary line around the entire Project site and not just the parcels of land that have been secured at this time or the location of specific equipment. Please be aware that, as stated in Section IV.4.4. of the RFP Rules, “If the Project is selected by the evaluation in this RFP and approved by the Commission, the map of the Project site provided by the Bidder in its Proposal will become part of the Indexed REC Contract. With each REC delivery, the Seller will be required to represent that at least 50% of the Project is located within the physical location, identified by the boundary line, provided in the Proposal. The boundary line may contain additional land than the parcels of land that have been secured at the time of the Proposal.”
FAQ-Indexed REC-16
Q: Does a Project located in an adjacent state to Illinois that has already received pre-approval by the IPA to be eligible for Illinois RPS compliance have to reapply for pre-approval with the IPA again for purposes of qualifying under the Fall 2025 Indexed REC RFP?
A Project that is located in a state adjacent to Illinois may qualify to participate in the Indexed REC RFP if it meets the public interest criteria specified in Section 1-75(c)(1)(I) of the IPA Act by submitting data about the Project to the IPA and obtaining pre-approval from the IPA that the Project is eligible for Illinois RPS compliance. The evaluation spreadsheet dated February 23, 2024 and available on the IPA’s website, under the header “Adjacent State Facility Eligibility” here, must be used for the Fall 2025 Indexed REC RFP.
If a Project was pre-approved by the IPA ahead of a prior procurement event based on the evaluation spreadsheet dated February 23, 2024, then this approval remains valid for purposes the Fall 2025 Indexed REC RFP. The Bidder must provide evidence of this determination with the Part 1 Proposal.
10-23-2025FAQ-Indexed REC-15
Q: Is Bid Assurance Collateral and Performance Assurance Collateral posted separately with each Company? Are the amounts dependent on the credit ratings of the Seller or Seller’s Guarantor, if applicable?
Please note there are two types of collateral: (1) Bid Assurance Collateral, which is due by the Part 2 Date to support your Bid(s) and (2) Performance Assurance Collateral required under the terms of the Indexed REC Contract if a Bid for a Project is selected and approved by the Illinois Commerce Commission. Please see the response below to your question as it relates to (1) Bid Assurance Collateral and (2) Performance Assurance Collateral.
- Bid Assurance (Pre-Bid) Collateral
All Bidders are required to submit Bid Assurance Collateral regardless of whether the Seller or Seller’s Guarantor is rated. Bid Assurance Collateral must be posted separately with each Company in the form of cash or a Pre-Bid Letter of Credit and the amount required is based on the Project size. Please refer to paragraph V.2.1 of the RFP Rules for the specific calculations of Bid Assurance Collateral required for each Company. Please note that if you are using a Pre-Bid Letter of Credit, there are separate standard forms for Bid Assurance Collateral (Pre-Bid) and Performance Assurance Collateral (Post-Bid). The Standard Pre-Bid Letters of Credit are posted as appendices to the RFP Rules on the Final Materials page: https://www.ipa-energyrfp.com/indexed-renewables/final-materials/
- Performance Assurance (Post-Bid) Collateral
If a Bid for a Project is selected and approved by the Illinois Commerce Commission, the RECs from the Project will be allocated by the Procurement Administrator to the Companies in pre-specified proportions (27.09% to AIC, 72.67% to ComEd, and 0.24% to MEC). Therefore, you will sign three contracts, one with each of AIC, ComEd and MEC.
Each Indexed REC Contract is administered separately and independently by each of Companies (each is the Buyer under each such Indexed REC Contract). The Collateral Threshold amount determined in accordance with Table A in Section 7.1 of the Indexed REC Contract, and the Performance Assurance Amount, applies to each of AIC, ComEd, and MEC independently. The Collateral Threshold amount is dependent on the credit ratings available for the Seller or the Seller’s Guarantor, if applicable. If the Seller is relying on a Guarantor and Seller’s Guarantor has provided a Guaranty, the Collateral Threshold shall be the lesser of the Collateral Threshold as determined by (i) the table in Section 7.1 or (ii) the amount of such Guaranty. If the Seller or Seller’s Guarantor is a party to one or more additional Indexed REC Contracts with a Buyer, then the Seller or Seller’s Guarantor will be granted a single Collateral Threshold to be applied in aggregate to all such Indexed REC Contracts entered into with such Buyer.
The amount of a Seller’s Performance Assurance is equal to the positive difference, if any, between: (a) the Collateral Requirement (or Increased Collateral Requirement, if applicable); and (b) the Collateral Threshold, rounded up to the nearest $10,000, as estimated by Buyer (“Performance Assurance Amount”). Performance Assurance may be posted in the form of cash or a Post-Bid Letter of Credit. There are two options for the Post-Bid Letter of Credit posted with the final contract documents to the Final Materials page: https://www.ipa-energyrfp.com/indexed-renewables/final-materials/
For example, for a utility-scale solar project, if the Annual Quantity allocated to the Indexed REC Contract with ComEd is 300,000 RECs, and the Seller’s Guarantor is investment grade and has provided a Guaranty in an amount equal to the Collateral Threshold of $2,500,000, then the required Performance Assurance Amount to be posted with ComEd is $500,000 ($10 x 300,000 – $2,500,000). A similar calculation would be performed to calculate the required Performance Assurance Amount to be posted separately with each of AIC and MEC. This example assumes that the Seller is party to only one Indexed REC Contract with each utility and the Seller is not posting the Increased Collateral Requirement.
10-23-2025FAQ-Indexed REC-14
Q: Does the Indexed REC Contract include payment for capacity or any other product related to the Project in addition to the renewable energy credits?
The Indexed REC RFP is for the procurement of Renewable Energy Credits only from a Project that is qualified and selected under the RFP. The Indexed REC Contract does not include delivery or payment for energy, capacity, or any other product related to the Project. Each Bidder is responsible for the sale of other products related to the Project including energy and capacity.
10-23-2025FAQ-Indexed REC-13
Q: If we paid the Bid Participation Fee for the Summer 2025 Indexed REC RFP do we need to pay again for the Fall 2025 Indexed REC RFP?
A Bidder that paid a Bid Participation Fee pursuant to its participation in a prior 2025 procurement event, such as the Summer 2025 Indexed REC RFP, is not required to pay the Bid Participation Fee for the Fall 2025 Indexed REC RFP.
10-23-2025FAQ-Indexed REC-12
Q: Where can I find materials from the bidder information webcast?
The Procurement Administrator posted the presentation materials and the audio recording from the bidder information webcast held on October 22, 2025 to the Final Materials page of the Indexed REC section of the procurement website.
10-23-2025FAQ-Indexed REC-11
Q: Is the KMZ file for Figure A in Appendix 16: Energy Transition Community Grant Areas and Hydropower Preference Communities available?
Figure A in Appendix 16 is only available as a picture in pdf format. The picture is provided for reference purposes only. The actual coordinates for each mine and plant are available in Table A of Appendix 16, which is posted to the Final Materials page in the Indexed REC RFP section of the procurement website.
10-21-2025FAQ-Indexed REC-10
Q: Can multiple, non-contiguous, parcels of land be used for a Project site for a single Project?
This is acceptable as long as the Project has or will have a single revenue quality meter and its own account with PJM EIS GATS or M-RETS.
10-21-2025FAQ-Indexed REC-9
Q: Can we combine the output from multiple systems and submit a single Proposal and Bid under the Indexed REC RFP?
No, under the Indexed REC RFP, the output from multiple systems, each system with its own meter and account with PJM EIS GATS or M-RETS, cannot be combined and submitted as a single Proposal and Bid. Under the Indexed REC RFP, each “Project” for which a Proposal and Bid is submitted must have or will have a single revenue quality meter and must have its own account with PJM EIS GATS or M-RETS. If the Project is a solar project, for purposes of the Indexed REC RFP, it must qualify as either a “utility-scale solar project” or a “brownfield site photovoltaic project”. A utility-scale solar project means an electric generating facility that generates electricity using photovoltaic cells and that has a nameplate capacity greater than 5,000 kW (AC rating). There is no minimum size requirement for a brownfield site photovoltaic project. The definition of a brownfield site photovoltaic project is provided in paragraph I.2.1 of the RFP Rules:
https://nera-content-media.s3.us-east-1.amazonaws.com/ipa/Indexed_REC_RFP_Process_and_Rules_Fall_2025_20_OCT_2025_ebcd56cea5.pdf
FAQ-Indexed REC-8
Q: Can a roof-mounted solar canopy over a parking area qualify under the Indexed REC RFP?
There is no rule that a Project cannot be a roof-mounted solar canopy. Such a Project must have or will have a single revenue quality meter and must have its own account with PJM EIS GATS or M-RETS. If the Project is a solar project, for purposes of the Indexed REC RFP, it must qualify as either a “utility-scale solar project” or a “brownfield site photovoltaic project”. A utility-scale solar project means an electric generating facility that generates electricity using photovoltaic cells and that has a nameplate capacity greater than 5,000 kW (AC rating). There is no minimum size requirement for a brownfield site photovoltaic project. The definition of a brownfield site photovoltaic project is provided in paragraph I.2.1 of the RFP Rules:
https://nera-content-media.s3.us-east-1.amazonaws.com/ipa/Indexed_REC_RFP_Process_and_Rules_Fall_2025_20_OCT_2025_ebcd56cea5.pdf
FAQ-Indexed REC-7
Q: Are solar projects 5 MW (AC rating) or less eligible to participate in the Indexed REC RFP?
Under the Indexed REC RFP, a utility-scale solar project means an electric generating facility that generates electricity using photovoltaic cells and that has a nameplate capacity greater than 5,000 kW (AC rating). Projects 5 MW or less are not eligible to participate in the Indexed REC RFP unless they qualify as a brownfield site photovoltaic project.
10-15-2025FAQ-Indexed REC-6
Q: Where can I find information about the IPA’s Adjacent State Requirement scoring methodology?
Please refer to Section 4.3 of the 2024 Long-Term Renewable Resources Procurement Plan for details about the Adjacent State Requirement scoring methodology. As a reminder, the Procurement Administrator does not evaluate Adjacent State Eligibility requests; this is done by the IPA. Please submit your Adjacent State Eligibility spreadsheets and any specific questions related to the facility score to the IPA by email to ipa.contactus@illinois.gov.
Section 1-75(c)(1)(I) of the IPA Act permits qualifying renewable energy credits may be sourced from facilities in adjacent states—but only if these facilities can meet public interest criteria spelled out in the law. The public interest criteria that the Agency considers include:
- Minimizing sulfur dioxide (SO2), nitrogen oxides (NOx), particulate matter (PM), and other pollution that adversely affects public health in this State
- Increasing fuel and resource diversity in this State
- Enhancing the reliability and resiliency of the electricity distribution system in this State
- Meeting goals to limit carbon dioxide emissions under federal or state law
- Contributing to a cleaner and healthier environment for the citizens of this State
The 2024 Long-Term Plan includes specific details about the methodology for evaluating each criterion.
10-14-2025FAQ-Indexed REC-5
Q: For a Project located in a state adjacent to Illinois, when should we submit the evaluation spreadsheet to the IPA for pre-approval?
Please submit the evaluation spreadsheet to the IPA by email to ipa.contactus@illinois.gov as soon as practicable. The IPA may take up to two (2) business days to review and issue their determination back to the submitter. The evaluation spreadsheet is available on the IPA’s website, under the header “Adjacent State Facility Eligibility” here, and is dated February 23, 2024.
If the Project is located in a state adjacent to Illinois and has been pre-approved by the Illinois Power Agency (“IPA”) to be eligible for Illinois RPS compliance based on public interest criteria, the Bidder must provide evidence of this determination with the Part 1 Proposal by upload to the online form or by email to Illinois-RFP@nera.com. The Part 1 Proposal, including this evidence and all other required supporting documentation, is due by 12PM (noon) CPT on Wednesday, November 5, 2025.
10-13-2025FAQ-Indexed REC-4
Q: How can a Project located in a state adjacent to Illinois become pre-approved to be eligible for Illinois RPS compliance?
In order for a Project located in a state adjacent to Illinois (Wisconsin, Iowa, Missouri, Kentucky, Indiana, and Michigan) to be pre-approved to be eligible for Illinois RPS compliance, the bidder must submit an evaluation spreadsheet to the Illinois Power Agency by email to ipa.contactus@illinois.gov. The evaluation spreadsheet is available on the IPA’s website, under the header “Adjacent State Facility Eligibility” here, and is dated February 23, 2024. Please complete the fields in yellow. Once the required fields in yellow have been inputted, the spreadsheet generates a preliminary score subject to review by the IPA. The minimum score needed to qualify is 60.
10-08-2025FAQ-Indexed REC-3
Q: Is there a calendar with deadlines for the Fall 2025 Indexed REC RFP?
On September 12, 2025, the Procurement Administrator scheduled the Fall 2025 Indexed REC RFP to procure RECs from new utility-scale wind projects, new utility-scale solar projects, new brownfield site photovoltaic projects, and new hydropower projects at an existing dam or modernized or retooled hydropower projects. The calendar with deadlines for the Fall 2025 Indexed REC RFP is available on the calendar page of the procurement website here: https://www.ipa-energyrfp.com/calendar/.
In order to submit a Bid for a Project in the Fall 2025 Indexed REC RFP, a Bidder must submit a Proposal, which consists of two (2) parts. The first part of the Proposal, the Part 1 Proposal, is the Bidder’s response to the qualification standards under the RFP Rules. Part 1 Proposals are due by 12 PM (noon) CPT on Wednesday, November 5, 2025.
10-06-2025FAQ-Indexed REC-2
Q: Can you please confirm the appropriate process and contact for submitting comments on the Draft Indexed REC Contract and Preliminary Proposal Requirements due Monday, October 6, 2025?
Comments on the Preliminary Proposal Requirements and the Draft Indexed REC Contract for the Fall 2025 Indexed REC RFP are welcome from any interested party. To facilitate the reviewer’s understanding and consideration of the comments, stakeholders are strongly encouraged to provide comments in the form of redlines against the posted documents along with explanatory notes either in a separate document or highlighted in tracked changes.
The timeline and process for interested parties to provide comments are as follows:
- Please submit an attachment with your comments on the Draft Indexed REC Contract and the Preliminary Proposal Requirements by email to the Procurement Administrator at: Illinois-RFP@nera.com
- Please provide telephone and e-mail contact information in the event that the Procurement Administrator seeks clarification regarding your comments.
- If providing feedback on the Draft Indexed REC Contract, please submit your comments with track changes in Microsoft Word. We strongly encourage you to provide explanatory notes either in a separate document or highlighted in tracked changes.
- If providing feedback on the Preliminary Proposal Requirements, please include a reference to the paragraph number of section name, from the left-hand column of the respective table, that is applicable to the requirement for which you are providing comment(s).
The deadline to provide comments is October 6, 2025. More information about the comment process and specific questions and topics on which feedback is sought can be found in the Invitation to Comment posted here.
10-02-2025