2026 Summer Indexed Wind, Solar, Brownfield, and Hydropower REC RFP (AIC, ComEd, and MEC)

1. The Project is not placed in service by the end of the fourth calendar year after the calendar year in which construction began due to delays in finalizing interconnection agreements or obtaining necessary governmental permits and approvals;
2. As a result of those delays, the federal Investment Tax Credit (ITC), Production Tax Credit (PTC), or Clean Electricity Investment Credit applicable to the Project is eliminated, materially reduced, or otherwise unavailable; and
3. The delays are not primarily attributable to the Seller (for example, they are not the result of the Seller's failure to timely pursue permits, interconnection requests, required information submissions, or required payments).

Any termination request must be submitted in writing to the Buyer and the IPA by January 31, 2031 and must include reasonable documentation demonstrating that the Project would have qualified for the applicable federal tax credit but for the qualifying delay. The request is subject to IPA approval. If approved, the Agreement will be terminated, the Seller's Performance Assurance will be returned.

06-16-2026

 

 

Under the terms of the Indexed REC Contract, Seller is entitled to extensions of the Initial REC Delivery Deadline upon demonstration of good cause by Seller to the Illinois Power Agency (IPA). Subsection 2.4(a)(ii) of the Indexed REC Contract provides that good cause includes delays outside of Seller’s control, including those related to obtaining necessary governmental approvals and permits provided such delays are not primarily attributable to Seller. Seller may receive multiple extensions under this provision.

Under subsection 2.4(c), after multiple extensions to the Initial REC Delivery Deadline have been granted and the cause(s) of delay(s) outside the Seller’s control will not be resolved by May 31, 2035, then Seller may request termination of the agreement and return of its Performance Assurance, subject to IPA’s approval.

Whether any particular governmental action, inaction, permitting delay, or other circumstance satisfies the requirements of the Agreement would depend on the specific facts and documentation presented at the time of any request and would be evaluated by the IPA in accordance with the applicable contractual provisions.

06-16-2026

 

Please use the Bid Form distributed with the Part 1 Notification on May 14, 2026 to submit your Bid(s) on the Bid Date on June 17. 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.

06-12-2026

 

Q: What is the “Financial Closing Date” with respect to choosing the Adjustment Reference Date for the one-time Strike Price Adjustment Mechanism?

 

For purposes of Section 2.7 of the Indexed REC Contract, the Financial Closing Date refers to the financial close associated with Project construction, which typically occurs in connection with the NTP Issuance Date and before COD. The Strike Price adjustment is not based on the actual Financial Closing Date or actual NTP Issuance Date. Rather, Seller is required to provide notice of an expected Financial Closing Date or expected NTP Issuance Date pursuant to Section 2.7(b), and the Adjustment Reference Date is established based on the expected date identified in that notice. Once Seller provides that notice, the Adjustment Reference Date is set based on the expected Financial Closing Date or NTP Issuance Date and is not later revised based on the actual Financial Closing Date or actual NTP Issuance Date.

Section 2.7 is intended to function like a rate-lock or index-lock mechanism. Seller provides notice of the expected Financial Closing Date or NTP Issuance Date, the Adjustment Reference Date is set as 15 days before that expected milestone, and the IPA then endeavors to issue the adjusted Strike Price five (5) Business Days before the expected Financial Closing Date/NTP Issuance Date. Both Buyer and Seller are then required to update the Product Order of the Indexed REC Contract with the adjusted Strike Price within three (3) Business Days of IPA’s notice. This sequencing is intended to benefit Seller as it enters financial close by allowing the adjusted Strike Price to be reflected in an updated, binding Product Order that Seller and its financing entities may rely on as part of the closing formalities.

Please also review FAQ-Indexed REC-124.

06-10-2026

 

Q: If the Seller elects in the Bid Form that the one-time Strike Price Adjustment Mechanism applies to the Project, when must the Seller inform the IPA and Buyer of its election to use either the Financial Closing Date or NTP Issuance Date to set the Adjustment Reference Date?

 

Electing the expected Financial Closing Date or NTP Issuance Date for purposes of setting the Adjustment Reference Date is not required during the RFP or at the point of contract execution.

Pursuant to Section 2.7(b) of the Indexed REC Contract, Seller will provide a written notice of an expected Financial Closing Date or NTP Issuance Date along with supporting documentation as soon as practicable for calculating the adjusted Strike Price. This notice shall be provided to Buyer and the IPA on or prior to the actual Financial Closing Date or NTP Issuance Date, as applicable. If the notice is not made by the actual Financial Closing Date or NTP Issuance Date, the IPA will designate an Adjustment Reference Date. Please note that once Seller provides this notice of an expected Financial Closing Date or NTP Issuance Date, the Adjustment Reference Date will be set and will not be amended further regardless of the actual Financial Closing Date or NTP Issuance Date.

06-03-2026

 

Q: Are there any exceptions to the Project Labor Agreement requirements under Section 6.3 of the Indexed REC Contract if the Project is located in an adjacent state?

 

No, the Project Labor Agreement requirements under Section 6.3 of the Indexed REC Contract apply to all Projects that begin construction on or after September 15, 2021 regardless of whether the Project is located in Illinois or an adjacent state. As a requirement of the Part 1 Proposal, the Officer of the Seller made certain acknowledgements and certifications regarding the Project Labor Agreement requirements in the P1 Project Labor Agreement Insert (#P1-6).

06-02-2026

 

Q: If the Officer of the Seller identified in our Part 1 Proposal is not available to make the representations required by the Part 2 Proposal, can we name a different individual to serve as an authorized signatory of the Seller?

 

As stated in paragraph IV.1.3 of the RFP Rules, “The Officer of the Seller whose contact information is provided in the Part 1 Proposal must make all representations required in the Part 1 Proposal and in the Part 2 Proposal for the Project, except as explicitly noted in these RFP Rules.”

In order to establish a new Officer of the Seller, please provide the name and contact information (title, address, mobile and business phone number, email address) of the new individual. This individual must be an officer, a director, or an individual otherwise empowered to undertake contracts and bind the Seller.

Additionally, you will be required to provide all applicable Part 1 Inserts duly completed and signed by the new Officer of the Seller.

05-28-2026

 

Q: Can you provide more detail on when Seller’s delivery obligations are suspended in the event of Government Action pursuant to Section 11.1 of the Indexed REC Contract? Can you provide a few examples of Government Actions that “fundamentally impact” the Project or REC deliveries?

 

As stated in Section 11.1, “Government Action that changes in any respect the value of a Product (without rendering the Product out of compliance with the Applicable Program), will have no effect on the obligation of the Parties to purchase and sell such Product at the price and on the terms set forth in this Agreement.”

Section 11.1 is to address the situation when Government Action adversely affects the eligibility of the Project or Product to meet the requirements of the Applicable Program or renders such Project or Product out of compliance with the Applicable Program. There are no historical examples of which the Procurement Administrator is aware. Section 11.1 simply provides a process for the Parties to take should such Government Action occur.

05-22-2026

 

Q: Can you provide more detail on the “Available Funds” provision in Section 5.4 of the Indexed REC Contract?

 

Please refer to Section 3 of the IPA’s 2026 Long-Term Renewable Resources Procurement Plan (“2026 Long-Term Plan”) for information about the RPS budget and cost cap. The Agency’s most recent quarterly RPS Budget Update has been included as Appendix B to the 2026 Long-Term Plan. 

Please also refer to Section 5.4.1 of the 2026 Long-Term Plan for more information about the cost recovery provisions described in Section 5.4 of the Indexed REC Contract. 

05-22-2026

 

Q: The Inserts required with the Part 2 Proposal require that if the Seller and Bidder are different entities, a representative of the Bidder must make the representations in addition to the Officer of the Seller. If the Officer of the Seller is authorized to sign on behalf of both the Seller and Bidder can this individual sign in both places?

 

Yes. It is acceptable for the Officer of the Seller to make the representations required by the Part 2 Proposal on behalf of both the Seller and the Bidder if this individual is authorized to do so. The Officer of the Seller should sign in both places.

 

05-21-2026

 

Q: Please clarify the intent of the limitation of liability under Section 14.1 of the Indexed REC Contract.

 

The purpose of the limitation of liability is to provide certainty regarding the risk exposure faced by each Party to the transaction. This statement should not be treated as legal advice or an opinion on the specific limit, and each Party is responsible for evaluating its own risk and legal position in connection with the provision.

 

05-21-2026

 

Q: Can a Bidder substitute a Project that was submitted in the Part 1 Proposal with a different Project when submitting the Part 2 Proposal?

 

This is not allowed. As stated in paragraph VI.1.5 of the RFP Rules, “No late Part 1 Proposals will be accepted under any circumstances.” As the deadline to submit the Part 1 Proposal for a Project has passed, it is not possible to substitute a different Project at this time.

 

05-20-2026

 

Q: In the evaluation procedure for the Solar Category, how is the Strike Price reduced if at least 50% of the Project site is located within an ETCGA?

 

As described in paragraph VI.2.9 of the RFP Rules, for the Solar Category, if at least 50% of the Project site is located within an ETCGA, then the Strike Price for such Project is reduced (strictly for evaluation purposes and not for purposes of the Indexed REC Contract) by the product of: (i) ten percent (10%); and (ii) the lowest Strike Price in the Solar Category. This price reduction is rounded to the nearest cent.

A numerical example of this reduction is provided in Appendix 15 to the RFP Rules available on the Final Materials page of the procurement website.

05-18-2026

 

Q: Can the Surety issuer be domiciled in a state other than Illinois?

 

No. The Surety must be domiciled in the state of Illinois.

 

05-15-2026

 

Q: The Form of Surety Bond requires the Surety to represent that it has total assets of at least $10,000,000,000. Does this threshold apply to the Surety issuer, or can it be applied to the Surety’s parent?

The $10 billion threshold applies at the level of the Surety issuer, not a parent or other level. The Surety issuer itself is required to represent it has total assets of at least $10,000,000,000. 

05-15-2026

 

Q: When is the supplier fee due to the IPA?

Payment of the Supplier Fees to the IPA by the Bidder or Seller will be due within seven (7) business days after Commission approval of the Bids, as stated in paragraph I.3.12 of the RFP Rules. The ICC is expected to render its decision on the results of the Summer 2026 Indexed REC procurement on Wednesday, June 24, 2026.

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.

05-08-2026

 

Q: Can multiple Bids be submitted for the same Project that vary by full/minimum quantity and strike price?

No. As stated in paragraph V.6.4 of the RFP Rules, only one Bid may be submitted for a Project.

05-07-2026

 

Q: Can the Delivery Term begin earlier or later than the expected Date of First Operation provided within the Part 1 Proposal?

The expected Date of First Operation provided within the Part 1 Proposal is not binding. Under the Indexed REC Contract, the Delivery Term may begin prior to the expected Date of First Operation within the Part 1 Proposal. As stated in the agreement, the Delivery Term starts “on the date that the first REC is issued by PJM-EIS GATS or M-RETS for the Project subsequent to 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); provided that if such first REC issued for the Project is associated with a Vintage that is earlier than July 2026, then the Delivery Term shall start on the date that the first REC is issued for the Project associated with a Vintage of July 2026, and (ii) ending on the last day of the third month after the conclusion of the Acceptable Vintage Period.”

It is also acceptable for the Delivery Term to begin after the expected Date of First Operation provided in the Part 1 Proposal. However, please note that each Project selected through this RFP with a Bid approved by the Commission must deliver at least one REC to each Company by December 31, 2030. Notwithstanding the foregoing, such deadline may be extended to May 31, 2033 if Seller meets an increased collateral requirement; and may be further extended as described in the Indexed REC Contract.

05-06-2026

 

Q: Can you provide more information about how the Procurement Administrator evaluates whether the Project site in the Proposal is located at least 50% within an ETCGA and how and when the Illinois Power Agency will evaluate whether the Project built is at least 50% located within the ETCGA?

 

First, we note that an Energy Transition Community Grant Area (ETCGA) 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.  Second, it is entirely optional and a decision by the Bidder and Seller of the Project at its sole discretion to elect for the Project to be identified as a Project that is located in an ETCGA, in which case the bid price of such ETCGA-located Project shall be reduced for purposes of bid evaluation as explained below. Third, it is an Event of Default under the Indexed REC Contract if the Project is proposed to be in an ETCGA in the RFP, but when the Project becomes operational, Seller fails to demonstrate, and the IPA is unable to verify, that at least 50% of the Project is located within the ETCGA identified in the RFP by the Bidder. As such, each bidder is required to make its own determination whether the Project will be able to comply with the below requirements before electing to identify its Project to be located in an ETCGA so as to benefit from a bid price reduction for purposes of bid evaluation.

If in the Part 1 Proposal, the Bidder elects to identify that its Project is in an ETCGA and confirms 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) associated with the ETCGA(s) applicable to the Project. In the Part 1 Proposal, the Bidder must provide evidence that at least 50% of the Project site is located within the applicable ETCGA(s). Such evidence, in the Part 1 Proposal, 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 ETCGA(s) associated with the plant(s) and/or mine(s) named in the Part 1 Proposal.

For purposes of evaluating the Part 1 Proposal, the Procurement Administrator will confirm that at least 50% of the boundary line on the Project site map is within the 30-mile radius of the coordinates associated with the names of the plant(s) and/or mine(s) named in the Part 1 Proposal. If confirmed, the name(s) of the plant(s) and/or mine(s) identified in the Proposal will be an input to the Product Order in the Indexed REC Contract should the Bid for the Project be selected and approved by the Commission.

Under the Indexed REC Contract, if the Seller has committed for the Project to be located within one or more ETCGA(s) in the Proposal, the Seller must provide to each Buyer and the IPA information and documents sufficient to verify that at least 50% of the Project is located within the ETCGA(s) as identified in the Product Order within thirty (30) days of the Date of First Operation. In the event that the Seller fails to demonstrate, and the IPA is unable to verify, that at least 50% of the Project is located within the ETCGA(s) in connection with the IPA’s review of information submitted of such Project, then an Event of Default shall be deemed to have occurred and the Indexed REC Contract shall be terminated. More information regarding payments and damages in this case is available in Section 2.5(c) of the Indexed REC Contract.

For purposes of the IPA verifying that at least 50% of the Project that is ultimately built is located within the ETCGA(s), the IPA would accept a map that clearly displays the distance between the plant(s) and/or mine(s) identified in the Product Order and the Project that is built. The Project boundary in this case may be based on (1) the acres associated with the final parcels of land on which the equipment for the Project is sited; and/or (2) the subset of acres beneath the equipment for the Project. Methods (1) and (2) may be used together when developing the Project boundary. The IPA will confirm that at least 50% of the acres associated with this Project boundary is within the 30-mile radius of the coordinates associated with the names of the plant(s) and/or mine(s) in the Product Order.  For avoidance of doubt, securing additional parcels of land on which the equipment does not reside so as to increase the acres within the ETCGA would not be acceptable.

05-01-2026

 

Q: Is the P2 Certifications Insert required to be submitted with the Part 1 Proposal?

 

The P2 Certifications Insert is a requirement of the Part 2 Proposal and is not required to be submitted with the Part 1 Proposal. Part 2 Proposals are received and processed during the Part 2 Window from May 15, 2026 to June 3, 2026; however, the representations required by the online Part 2 Form may be submitted during the Part 1 Window for early processing. Early processing allows the Officer of the Seller, at the Officer’s option, to make all representations and certifications required in the Part 1 and Part 2 Proposals at one time.

 

04-29-2026

 

Q: If the Bidder is a Joint Venture Partner, is it a requirement for a Signatory for the Bidder to sign each Insert required in the Part 1 Proposal and Part 2 Proposal for the Project?

 

Each required Insert must be signed by a Signatory for each Joint Venture Partner. The Officer of the Seller may serve as a Signatory for one of the Joint Venture Partners. If the Bidder is a Joint Venture Partner and the Officer of the Seller does not serve as the Signatory for the Bidder, then each Insert must also be made by a Signatory for the Bidder.

It is acceptable for the signatures by each Signatory for each Joint Venture Partner to be completed on separate Inserts with one signature on each Insert or on a single Insert with additional signatures placed below or to the side of the signature line.

04-29-2026

 

Q: Is disclosure required if an entity above the Seller is the product of a Joint Venture or only in the case where a Seller is the Product of a Joint Venture?

 

Disclosure is only required if a Seller is the product of a Joint Venture or similar agreement and is not required if other entities above the Seller are the product of a Joint Venture.

Please note that if there are other entities not already named in the Part 1 Proposal that are currently involved in the development of the Project, these entities must be disclosed in the Project Team Insert (#P1-2). This is a new requirement for the Summer 2026 Indexed REC RFP. Please see paragraph IV.1.6 for additional information on the Project Team.

04-29-2026

 

Q: Which individuals are allowed to make the certification required in the Bid Form?

 

The certification in the Bid Form must be completed and signed by an individual authorized to submit Bid(s). This individual must be the Officer of the Seller, a Representative named in the Proposal, or the individual named in the ‘Bidder Information’ section on the General Information tab of the Bid Form.

 

04-28-2026

 

Q: Does the question “Has the Bidder already designated additional Representatives in a previously submitted Part 1 Proposal for another Project?” refer to a another Project in the Summer 2026 Indexed REC RFP or to a Project submitted under a prior procurement event?

 

This question refers to whether the Bidder has already designated additional Representatives in a previously submitted Part 1 Proposal for another Project in this Summer 2026 Indexed REC RFP only. If the Bidder is presenting Proposals for multiple Projects in the Summer 2026 Indexed REC RFP, the Bidder must identify the same Representatives for all such Proposals. Such Bidder is only required to submit the information regarding the Representatives once, with the first Project for which a Proposal is submitted.

 

04-28-2026

 

Q: Under Basic Information, the fifth item includes the checkbox stating: “This Representative is or can be authorized to submit the Bid(s) on the Bid Date and to make the certification required on the Bid Form.” How should this be answered if the individual submitting the bid is authorized to submit the Bid(s) on the Bid Date, but is not the individual who would make or sign the certifications required on the Bid Form (i.e., the submitter is not the signatory to the Inserts)?

 

If the individual is not and will not be authorized to make the certification required on the Bid Form, the answer to this question should be “No”. This individual may still submit the Bid Form on the Bid Date, and this individual’s contact information may be listed on the Bid Form, which will be used by the Procurement Administrator to confirm receipt of the Bids. Please note, however, that it is expected that at least one (1) of the Representatives listed in the Part 1 Proposal is or can be authorized to make the certification required on the Bid Form.

 

04-28-2026

 

Q: Is it possible to change the election of whether or not to commit to an Equity Level (%) greater than the Minimum Equity Standard (MES) of 14% after the deadline for the Part 1 Proposal?

 

In the Part 1 Proposal, a Seller that chooses to commit to an Equity Level (%) greater than the Minimum Equity Standard (MES) of 14%, must provide the required materials in the third item of Section 3 of the Part 1 Proposal. There is no process to change this election after the deadline for the Part 1 Proposal.

 

04-27-2026

 

Q: Is there an option to commit to an equity level (%) that is less than the Minimum Equity Standard (“MES”) of 14%?

 

There is no option to commit to an equity level (%) that is less than the Minimum Equity Standard (“MES”) of 14%. Unless the Project has a Date of First Operation prior to December 15, 2022, the Seller will be required to acknowledge that an MES of 14% applies to the Project Workforce for each delivery year in which Construction Activities are performed through the Date of First Operation. The required certification is made in the P1 Minimum Equity Standard Insert (#P1-4) in the Part 1 Proposal. The Product Order in the Indexed REC Contract will indicate that the Minimum Equity Standard requirements apply to the Project.

 

04-27-2026

 

Q: Our System Impact Study from PJM contains information considered confidential. Can we provide a draft version of a document that shows that our Project is further in the interconnection process with PJM than the System Impact Study instead?

 

Please note that, as stated in Section VI.3 of the RFP Rules, “Any information provided by a Bidder or Seller in its Part 1 Proposal is provided on a confidential basis to the Procurement Administrator and may be provided on a confidential basis to the Procurement Monitor, to the IPA, or to ICC Staff.” Each representative of the Procurement Administrator, Procurement Monitor, and the Companies that has access to any portion of the Proposals is required to sign a Confidentiality Statement in the form of Appendix 12 to the RFP Rules prior to evaluation of any portion of the Proposals. The list of all signatories is available to a Bidder or Seller upon request. Additional information related to confidentiality of Proposal materials is provided in Paragraphs VI.3.3 – VI.3.5 of the RFP Rules.

Additionally, please note that you may submit a System Impact Study with certain financial terms redacted as long as the Procurement Administrator is able to verify that the document is relevant to the Project, and that any operational characteristics listed in the study, such as Project size and location, are consistent with other information provided in the Part 1 Proposal.

If the completed System Impact Study is not available, then the Bidder may provide a document that shows that the Project is further in the interconnection process such as an interconnection agreement. However, draft documents are not acceptable.

04-24-2026

 

Q: Can you please confirm whether a Partner for a Joint Venture Project can present a Proposal as a different Bidder for a separate Project that belongs to the same Category? For example, in the following scenario, can Company A and Company B submit Proposals for Projects that belong to the same category as different Bidders? (i) Company A, who is in a Joint Venture with Company B, intends to bid Project A and (ii) Company B intends to also bid its own non- Joint Venture project, Project B

 

A “Joint Venture” is an agreement between two or more parties to own a Project jointly through a Seller organized for this purpose. Such parties (called “Joint Venture Partners” or “Partners”) otherwise maintain their distinct identities and business plans. If a Seller is the product of a Joint Venture or similar agreement, the Part 1 Proposal must disclose this fact. Since Partners maintain their distinct identities and business plans, it is possible that a Partner for a Joint Venture Project is also involved in the development of another Project that could be presenting a Proposal under this RFP. To take this into account, the confidentiality certifications of the Part 2 Proposal for a Joint Venture Project are customized to the Joint Venture arrangement.

Please refer to paragraph IV.1.7 of the RFP Rules for additional rules governing a Joint Venture arrangement. Paragraph IV.1.7 states, “If: (i) a Partner for a Joint Venture Project (“Project 1”) is a member of the Project Team for another Project (“Project 2”); and (ii) Project 1 and Project 2 are presented by different Bidders, such Partner must advise the Procurement Administrator of this fact as soon as practicable and no later than the Part 1 Date. More generally, if an entity is a Partner in a Joint Venture with potentially multiple Projects (Projects 1a, 1b, 1c, etc., as applicable, the “Project 1s”) and such entity is also a member of the Project Team for Projects presented by another Bidder (Project 2a, 2b, 2c, etc., as applicable, the “Project 2s”), then such Partner must advise the Procurement Administrator of this fact as soon as practicable and no later than the Part 1 Date. […] In such a case, Project 1 and Project 2 must belong to different Categories. More generally, the Category or Categories of the Project 1s cannot overlap with the Category or Categories of the Project 2s. For example, Project 1s could be all Solar Projects and Project 2s could be all Wind Projects (but it could not be the case that Project 1a and Project 2b are both Solar Projects).”

In your example, given that Projects A and B belong to the same Category, it would not be acceptable for a Proposal for Project A and a Proposal for Project B to be submitted by two different Bidders given that both Proposals involve Company B. It would be acceptable for Company B (or another entity that can take the lead in preparing the Proposals for both Projects) to present the Proposals for both Project A and Project B.

04-24-2026

 

Q: Can you provide an example calculation of the REC monthly price and invoice amount?

 

An example of the Indexed REC monthly price and invoice amount calculation can be found here.

 

04-23-2026

 

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.”
04-22-2026

 

Q: Will the Procurement Administrator review a draft 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. The amount required for each of the three Companies can be found in paragraph V.2.1 of the RFP Rules posted to the Final Materials page of the procurement website.

The Letter of Credit for a Company may only include 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. The final lists of acceptable modifications are expected to be posted to the Final Materials page on Monday, April 27, 2026.

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. Bid assurance collateral must be received by 12 PM (noon) CPT on Wednesday, June 3, 2026 (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.

04-22-2026

 

Q: If construction has not begun as of the submission of the Part 1 Proposal, are we required to provide evidence that the Project Labor Agreement(s) and any amendments thereto for the Project have been filed with the IPA?

 

Only Projects for which construction has begun at the time of the Part 1 Proposal submission are required to provide evidence that the Project Labor Agreement(s) and any amendments thereto for the Project have been filed with the IPA. If construction activities for a Project has not begun as of submission of the Part 1 Proposal, the Bidder must provide the Project Labor Agreement Insert (#P1-6) by email or by upload to Section 3 of the online Part 1 Form.

Please note that Project Labor Agreement requirements are not applicable to New Hydropower Projects.

04-22-2026

 

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-73.

04-20-2026

 

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 Summer 2026 Indexed REC procurement on Wednesday, June 24, 2026.

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.

04-20-2026

 

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.

04-16-2026

 

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-91 for additional information on the strike price for a winning Project that is used for this calculation.

 

04-16-2026

 

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 Seller elects in the Bid Form that the one-time Strike Price Adjustment Mechanism under the Indexed REC Contract apples to the Project. 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-43.

04-16-2026

 

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.

04-16-2026

 

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.
04-16-2026

 

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 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.

 

04-16-2026

 

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”.

04-16-2026

 

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.

04-16-2026

 

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 Wednesday, June 24, 2026.

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 seven (7) business days of being notified that the Illinois Commerce Commission has approved the Bid on that Project.

Please see FAQ-Indexed REC-82 for additional information on timing of the return of bid assurance collateral.

04-16-2026

 

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.
04-16-2026

 

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-27 for information about the Collateral Requirement for Sellers not eligible for unsecured credit.

04-16-2026

 

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. For Bidders with Bids approved by the Commission, bid assurance collateral remains in place for a Company until all of the following have occurred: (i) full execution of the Indexed REC Contract; (ii) posting of Seller’s Performance Assurance under the Indexed REC Contract; and (iii) receipt of payment of the Supplier Fees by the IPA. The Commission is expected to render its decision on the results of the procurement event on Wednesday, June 24, 2026.

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.2.22 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”. Return of cash tendered as bid assurance to a Company is not initiated until the Company receives fully executed request for return of cash in a form acceptable to the Company. AIC requires additionally that an account in AIC’s vendor portal be set up for the entity to which cash is returned. MEC requires additionally receipt of a completed Vendor Request Form that MEC finds acceptable. 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 indicates whether it elects for cash to be retained by the applicable Company in the Contract Insert, also labelled INSERT #P2-4, as further described in Paragraph V.3.2.

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.

04-16-2026

 

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 July 16, 2026. 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.

04-16-2026

 

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 Thursday, April 30, 2026. 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.

04-16-2026

 

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.2.13 of the RFP Rules, “If the one-time Strike Price Adjustment Mechanism under the Indexed REC Contract applies to the Project, then the Strike Price in the Bid is adjusted using a parameter called the “Forecast Factor”, which is announced on the date the Part 2 Window opens. The Forecast Factor is the expected percent change in the Strike Price under the Strike Price Adjustment Mechanism described in Exhibit G to the Indexed REC Contract if such an adjustment is made thirty (30) months after the day on which the Commission approves the Bid for the Project.”
04-16-2026

 

Q: Is the Supplier Fee non-refundable?

The Supplier Fee is non-refundable.

04-16-2026

 

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. Please see paragraph VI.2.17 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 identified 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 business day after such notification is received by the Bidder. The Bidder may also update the Degradation Rate and Index Hub for purposes of the Product Order of the Indexed REC Contract, if needed, by this time”
04-16-2026

 

Q: Who makes up the “project workforce” for the purpose of the MES?

 

The 2026 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. (2026 Long-Term Plan at 404-405).

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.

04-16-2026

 

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 project, utility-scale solar project, brownfield site photovoltaic project, 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.

04-16-2026

 

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. 25-0945.

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.

04-16-2026

 

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 seven (7) business days of being notified that the Illinois Commerce Commission has approved the Bid on that Project.

04-16-2026

 

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 December 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.

04-16-2026

 

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.
04-16-2026

 

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.

 

04-16-2026

 

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.”

04-16-2026

 

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).

 

04-16-2026

 

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.

 

04-16-2026

 

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.

 

04-16-2026

 

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 1.33 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-64.

04-16-2026

 

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 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 1.32 and 1.33 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 terms 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.

04-16-2026

 

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.7.4. of the RFP Rules, “If the Project is selected by the evaluation procedure 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 land other than the parcels of land that have been secured at the time of the Proposal.”
04-16-2026

 

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.6.3.

According to Paragraph IV.6.3 of the RFP Rules, a “A Bidder that demonstrates site control to meet the requirements of Section IV.6, 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.”

04-16-2026

 

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. A Seller may substitute one form of acceptable Performance Assurance for another acceptable form during the term of the Indexed REC Contract. It is Seller’s responsibility to ensure Seller’s Performance Assurance is maintained pursuant to Article 7 of the Indexed REC Contract.

 

04-16-2026

 

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.

 

04-16-2026

 

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.

 

04-16-2026

 

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”.

04-16-2026

 

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 a Bid on a Project, the Bidder must have submitted bid assurance collateral to all Companies in an amount that is sufficient given the Project size. In the case where a Bidder submits Proposals for multiple Projects and elects to effect a wire transfer to each Company or to submit a Pre-Bid Letter of Credit to each Company that covers two (2) or more of the Bidder’s Projects, then if the Bidder fails to provide bid assurance collateral to one or more of the Companies, or if the amount of the bid assurance collateral for one or more of the Companies is insufficient for all such Projects, then the Part 2 Proposals for all such Projects will be considered deficient.

04-16-2026

 

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.

There is no cap on the amount of bid assurance collateral tendered to each utility.

For the Bidder to be able to submit a Bid on a Project, the Bidder must have submitted bid assurance collateral to all Companies in an amount that is sufficient given the Project size. In the case where a Bidder submits Proposals for multiple Projects and elects to effect a wire transfer to each Company or to submit a Pre-Bid Letter of Credit to each Company that covers two (2) or more of the Bidder’s Projects, then if the Bidder fails to provide bid assurance collateral to one or more of the Companies, or if the amount of the bid assurance collateral for one or more of the Companies is insufficient for all such Projects, then the Part 2 Proposals for all such Projects will be considered deficient

04-16-2026

 

Q: Is the Index Hub selected in the online Part 2 Form used for purposes of bid evaluation?

 

The Seller must elect in the online Part 2 Form either the MISO-IL Hub or PJM-NIHUB as the hub for the Index Price for the Project. The Seller may elect either the MISO-IL Hub or PJM-NIHUB as the hub for the Index Price for the Project, regardless of whether the Project is or will be interconnected to MISO or PJM. 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.
04-16-2026

 

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 2026 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.

04-16-2026

 

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 FAQ-Indexed REC-28 and FAQ-Indexed REC-52 for definitions of “Project Workforce” and “Equity Eligible Person”, respectively.

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 2026 Long-Term Renewable Resources Procurement Plan (“Long-Term Plan” or “Plan”), requires utility-scale projects bidding into competitive procurements for Indexed REC contracts to meet the MES and provides 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 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”.

04-16-2026

 

Q: Who qualifies as an Equity Eligible Person?

 

The Climate and Equitable Jobs Act (“CEJA”) defines an equity eligible person as:

1. 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;
2. Persons who are graduates of or currently enrolled in the foster care system;
3. Persons who were formerly incarcerated; [or]
4. 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:

1. 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
2. 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.

04-16-2026

 

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.

04-16-2026

 

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.

04-16-2026

 

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 Portal 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.

04-16-2026

 

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.

04-16-2026

 

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
• Continuing utilization the Energy Workforce Equity Portal
• Outreach on various platforms of targeted social media, engagement in direct outreach to relevant associations or organizations to notify them of the project opportunity. (2026 Long-Term Plan at page 410).

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.

04-16-2026

 

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;

1. First 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. Starting with the second MES Compliance Plan, each MES Compliance Plan shall be combined with the MES Report as described in Section 6.4(c)(ii) due on July 15 each year.
2. MES Compliance Plan and MES Report. By July 15 of each delivery year, Seller shall submit to the IPA a combined report for MES Compliance Plan and the MES Report in accordance with the IPA’s long-term renewable resources procurement plan as approved by the ICC in ICC Docket No. 25-0945. The submission shall include a backward-looking MES Report (for entities to demonstrate how they achieved MES compliance in the previous delivery year), as well as a forward-looking MES Compliance Plan (for entities to demonstrate how they will achieve MES compliance in the new delivery year). The MES Report portion 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. The MES Compliance Plan portion 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.
3. 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 in accordance with procedures established by the IPA.

04-16-2026

 

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.

04-16-2026

 

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 10.1.6 of the IPA’s 2026 long-term renewable resources procurement plan (the “Long-Term Plan”), 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 10.1.6 of the 2026 Long-Term Plan provides that:

“If the IPA determines that an Approved Vendor, Designee, or Competitive Procurement Supplier has failed to comply with the applicable MES requirements, the entity will be notified and may face disciplinary action.

The Agency may impose consequences for violations by program participants, including, but not limited to the following:

1. Notice of Potential Violation;
2. Provision and implementation of a Corrective Action Plan;
3. Suspension of the entity’s ability to submit project applications to IPA programs or to participate in competitive procurements until compliance is achieved; and
4. For repeated violations – suspension of the entity’s ability to participate in IPA programs for an entire Program/delivery year or more or to participate in future competitive procurement events.

If an Approved Vendor or Designee in Illinois Shines fails to comply with any of the MES requirements, the entity will receive a Notice of Potential Violation (“NOPV”). If, after receiving the NOPV, the entity still does not meet the Agency’s requirements, the Agency will issue an official warning letter to the entity. If the entity does not come into compliance after receiving a warning letter, it will be issued a suspension letter.

If the Agency initially determines that a Competitive Procurement Supplier has failed to comply with the requisite MES, the Agency will notify the entity in writing. Following communication of this initial determination, the IPA may request any additional reports, information, and documentation that are reasonably necessary to determine compliance. If the requested materials are not received by the Agency within 21 days, the Agency may render a finding of noncompliance. Requests for an extension for more time to provide such additional information must be made prior any deadlines and will be considered on a case-by-case basis.

Suspensions of an Approved Vendor or Designee in Illinois Shines 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 Portal. Suspensions of Competitive Procurement Suppliers will be noted on the Procurement Administrator’s website, as well as the Energy Workforce Equity Portal.”

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.

04-16-2026

 

Q: What information will be publicly disclosed for winning applications?

Please see paragraph VI.2.19. 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 2026 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.

04-16-2026

 

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.
04-16-2026

 

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 were provided to Bidders that submitted a Part 1 Proposal on Monday, May 4, 2026. 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 to a physical address. 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.

04-16-2026

 

Q: Can the Bidder submit multiple Bids for a project?

 

Please see paragraph V.6.4 of the RFP Rules which states, “Only one Bid may be submitted for a Project.”

 

04-16-2026

 

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 (26.44% to AIC, 73.34% to ComEd, and 0.22% to MEC). As such, 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.

04-16-2026

 

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.

 

04-16-2026

 

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 March 23, 2026. The Final Indexed REC Contract was posted to the Final Material pages of the Indexed REC Section of the procurement website on April 6, 2026. Each Seller must accept the terms of the Indexed REC Contract as a condition of participation.

 

04-16-2026

 

Q: Is there a requirement for the Seller to own the Project?

 

 

04-16-2026

 

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 2026 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 Technology) 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 seven (7) business days after Commission approval of the Bids. An estimate of the Supplier Fee per REC is provided in the webcast.

04-16-2026

 

Q: What is the timeline for executing the Indexed REC Contract?

 

Please refer to paragraph VI.2.20 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.

04-16-2026

 

Q: Is there any flexibility in allowing comments on the Pre-Bid and Post-Bid Letters of Credit after the Credit Instrument Comments due date?

 

Comments on or proposed modifications to a Pre-Bid or Post-Bid Letter of Credit were due on April 9, 2026. 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. Only comments that were submitted on or before April 9 will be reviewed.

 

04-16-2026

 

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.

 

04-16-2026

 

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.

04-16-2026

 

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 Friday, April 10, 2026.

04-16-2026

 

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 December 31, 2030. Notwithstanding the foregoing, such deadline may be extended to May 31, 2033 if Seller meets an increased collateral requirement; and may be further extended as described in the Indexed REC Contract.

04-16-2026

 

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 1.96 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.”

04-16-2026

 

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 (26.44% to AIC, 73.34% to ComEd, and 0.22% to MEC). As such, 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.

04-16-2026

 

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 Summer 2026 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.

04-16-2026

 

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.

04-16-2026

 

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.6.2 of the RFP Rules to demonstrate adequate project maturity is not available, the Bidder must provide the required information in Paragraph IV.6.3 including demonstrating site control for a portion of the Project site.

04-16-2026

 

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 (1) the Project in the procurement event represents an additional portion of RECs from the renewable energy facility; (2) the Project in the procurement event will have a revenue quality meter separate from the meter associated with the RECs selected and approved in a prior procurement event; and (3) the Project in the procurement event will have its own account within PJM EIS GATS or M-RETS for purposes of tracking only the additional portion of RECs associated with the Project.

04-16-2026

 

Q: Does a Project located in an adjacent state to Illinois that received pre-approval by the IPA to be eligible for Illinois RPS compliance in a prior RFP have to reapply again for purposes of qualifying under the Summer 2026 Indexed REC RFP?

 

Yes. 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 27, 2026 and available on the IPA’s website, under the header “Adjacent State Facility Eligibility” here, must be used for the Summer 2026 Indexed REC RFP. This spreadsheet was updated based on the approved 2026 Long-Term Plan. Evidence of pre-approval based on a spreadsheet related to a prior plan is not acceptable.
04-16-2026

 

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.

1. 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/

2. 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.

04-16-2026

 

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.

 

04-16-2026

 

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 April 6, 2026 to the Final Materials page of the Indexed REC section of the procurement website

 

04-16-2026

 

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.

 

04-16-2026

 

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.
04-16-2026

 

Q: Where can I find information about the IPA’s Adjacent State Requirement scoring methodology?

 

Please refer to Section 4.3 of the 2026 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:

1. Minimizing sulfur dioxide (SO2), nitrogen oxides (NOx), particulate matter (PM), and other pollution that adversely affects public health in this State
2. Increasing fuel and resource diversity in this State
3. Enhancing the reliability and resiliency of the electricity distribution system in this State
4. Meeting goals to limit carbon dioxide emissions under federal or state law
5. Contributing to a cleaner and healthier environment for the citizens of this State

The 2026 Long-Term Plan includes specific details about the methodology for evaluating each criterion.

04-16-2026

 

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 27, 2026.

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 Thursday, April 30, 2026.

04-16-2026

 

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 27, 2026. 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.

 

04-16-2026

 

Q: Can a Bidder with multiple Projects submit a single Letter of Credit to meet the Bid Assurance Collateral requirement or is Bid Assurance Collateral required to be posted separately for each Project?

 

Please refer to paragraph V.2.5 of the RFP Rules:

“A Bidder presenting Proposals for multiple Projects and that elects to provide bid assurance collateral in the form of a letter of credit for a Company may present a single Pre-Bid Letter of Credit to that Company for all Projects presented by the Bidder provided that: (i) the Bidder and all Sellers are properly identified in the Pre-Bid Letter of Credit; and (ii) the entity or entities named in Paragraph 2 of the letter of credit consist of the Bidder, and/or one or more of the Sellers, and/or another entity identified in the Part 1 Proposal and associated with the Projects. Notwithstanding the provision of this paragraph, a Bidder consisting of a group of Sellers may, at its option, provide more than one letter of credit (for example, providing a separate letter of credit for each Project) instead of providing a single letter of credit for all Projects presented by the Bidder.”

04-14-2026

 

Q: If a portion of a Project’s output is committed to another PPA set to expire during the delivery term of the Indexed REC Contract, can that Project’s annual quantity under the Indexed REC Contract be adjusted upwards when the other PPA expires?

The Indexed REC Contract does not allow for a ramp up of the quantity of RECs to be delivered at a point during the delivery term.

There is an option for the Seller to indicate a percent of the project’s output to commit to the Buyer under the 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.

04-14-2026

 

Q: Has the constraint on the aggregate of the minimum quantities in the Bids across Projects presented by a Bidder exceeding the Target for the Category been removed?

 

Yes. The aggregate minimum quantities from various Projects in a Category presented by the Bidder may exceed the Target for that Category. The constraints on Bids related to quantities across Projects have been removed starting with this Summer 2026 Indexed REC RFP.

The minimum quantity of each Project presented by a Bidder may not exceed the Target for the Category associated with that Project. The full quantity may exceed the Target of the Category associated with the Project. However, if the Bidder selects a full quantity that exceeds the Target, the Bidder will be required to acknowledge that the Project could only be selected at a quantity above the Target if: (i) the evaluation proceeds to the Reallocation Stage; and (ii) the Category associated with the Project is Oversubscribed.

04-13-2026

 

Q: When will the schedule and targets be available for the Fall 2026 Indexed REC RFP?

 

The schedule for the Fall 2026 Indexed REC RFP with deadlines for all procurement activities is expected to be posted in late-July or early-August 2026. Additional information on deadlines is not available at this time.

Please see Table 5-5 in Section 5.6 of the 2026 IPA Long-Term Plan, which lists the proposed procurement targets for upcoming competitive procurement events. Please note that these targets are not final and may be adjusted as described in Section 5.6. The Fall 2026 Indexed REC RFP targets will not be finalized until after the conclusion of the Summer 2026 Indexed REC RFP.

04-13-2026

 

Q: Can you provide any guidance on how to select the Index Hub?

 

The Strike Price in the Bid and the Index Price that corresponds to the Index Hub elected by the Bidder will be used for purposes of calculating the REC Monthly Price for a Vintage month, as defined in the Indexed REC Contract. The Index Price is the hourly real-time energy price either for the MISO-IL Hub (from MISO’s Real-Time Energy Market and Operating Reserve Market for the Illinois Hub) or for the PJM-NIHUB (from PJM’s Real-Time Energy Market for the Northern Illinois Hub). The same Index Hub must be used in the Index REC Contract with all three Companies.

The Procurement Administrator cannot provide any guidance on how to select the Index Hub. The bidder provides either MISO-IL Hub or PJM-NIHUB as the Index Hub for their Project in the online Part 2 Form. The Seller may elect either the MISO-IL Hub or PJM-NIHUB as the hub for the Index Price for the Project, regardless of whether the Project is or will be interconnected to MISO or PJM.

04-08-2026

 

Q: Are the Seller and the Bidder required to be the same entity?

 

No, the Seller and the Bidder named in the Part 1 Proposal may be different entities. This is a change from prior Indexed REC RFPs, where the Seller and the Bidder were required to be the same entity when a Proposal was submitted for a single Project.

The “Seller” is an entity that bids to deliver RECs from a Project under the terms of the Indexed REC Contract and that will be the signatory to the Indexed REC Contract if the Bid for the Project is selected through this RFP and the Bid is approved by the Commission.

The “Bidder” is the entity submitting the Proposal. The Bidder may present a Proposal for one (1) or multiple Projects with the same or different Sellers. If an entity has a role in the development of multiple Projects, this entity must serve as the Bidder and present the Proposals for all such Projects. If several entities each have a role in the development of the same multiple Projects, one (1) of these entities must be selected to present the Proposals for all such Projects and serve as the Bidder.

04-08-2026

 

Q: What are the confidentiality certifications required with the Part 2 Proposal?

 

The Officer of the Seller and the Representatives of the Bidder are responsible for ensuring that the confidentiality of the Proposal is properly maintained. The Bidder or the Seller may communicate with a financial institution for purposes of arranging the posting of bid assurance collateral and may communicate with contractors, subcontractors, or other parties for purposes of meeting labor-related requirements. Other than such communications, the Officer of the Seller and the Representatives of the Bidder are responsible for ensuring that, for the period starting with the opening of the Part 1 Window through to the Commission decision on the results of the procurement event, all Contributors communicate Confidential Information relating to the Proposal only with each other and not to any other party. See FAQ-Indexed REC-5 for more information on Contributors.

The certifications related to confidentiality are provided in the P2 Confidentiality Certifications Insert (#P2-7) posted to the Final Materials page of the RFP website and also listed in paragraph V.5.2 of the RFP Rules.

Additional rules may apply to a Joint Venture Project or other Projects in specific circumstances. Please advise the Procurement Administrator as soon as possible if the Seller for your Project is the product of a Joint Venture or similar agreement.

04-08-2026

 

Q: If the Bidder is presenting Proposals for multiple Projects, do we provide an aggregate list of Contributors across the Proposals for our Projects?

 

Yes. If the Bidder is presenting Proposals for multiple Projects, the Bidder must identify the same Contributors for all such Proposals. It is not a breach of the confidentiality provisions for a Contributor primarily concerned with the Proposal for a Project presented by a Bidder to communicate Confidential Information relating to the Proposal for such Project to another Contributor who is primarily concerned with the Proposal for another Project presented by the same Bidder. Such Bidder is only required to submit the information regarding the Contributors once.

See FAQ-Indexed REC-5 for more information on Contributors.

04-08-2026

 

Q: Can you give an example of an individual that is a “Contributor” for purposes of completing the Contributor Insert (#P1-3)?

 

It is expected that a Contributor is a representative of an entity in the Project Team, or an adviser to the Project Team. See FAQ-Indexed REC-4 for more information on the Project Team. A “Contributor” is an individual expected to make specific and material contributions to preparing and submitting the Proposal(s) presented by the Bidder. A Contributor is privy to Confidential Information relating to the Proposal by virtue of the Contributor’s involvement in the preparation or submission of the Proposal. “Confidential Information relating to the Proposal” includes but is not limited to: the fact that a Proposal is presented for the Project in this procurement event; the specific contents of the Proposal for the Project including the elements of the Bid for the Project; estimation of the value of RECs for the Project’s Technology; and the estimation of the risks associated with providing RECs under the terms of the Indexed REC Contract.

The Contributors include individuals already named in the Part 1 Proposal, including the Officer of the Seller and the Representatives (and all Signatories for a Joint Venture) by default. Also, individuals employed by the Seller or by the Bidder or by a Partner of a Joint Venture Project and concerned with the Project are Contributors by default. These individuals do not need to be but may be named again in the Contributor Insert (#P1-3). If there are no other Contributors other than those already named in the Part 1 Proposal then the Bidder will indicate this fact in the seventh item of Section 1 and the Contributor Insert (#P1-3) is not required.

04-08-2026

 

Q: Can you give an example of an entity that would be included on the “Project Team” for purposes of completing the Project Team Insert (#P1-2)?

 

The “Project Team” is a list of entities currently involved in the development of the Project. The Bidder must provide the activities related to the development of the Project for which the entity has a role such as permitting, procurement, construction, project sponsorship, financing, or providing advice. The Project Team is not expected to include entities whose anticipated role in the development of the Project would begin after the Commission decision on the procurement event or whose role was already completed as of the opening of the Part 1 Window.

Entities already named in the Part 1 Proposal, namely the Bidder, the Seller (and all Partners for a Joint Venture), are already included on the Project Team by default. These entities already named in the Part 1 Proposal do not need to be named again in the Project Team Insert (#P1-2). If there are no other entities involved in the development of the Project other than those already named in the Part 1 Proposal then the Bidder will indicate this fact in the sixth item of Section 1 and the Project Team Insert (#P1-2) is not required.

04-08-2026

 

Q: Can the Procurement Administrator provide a sample of a confidentiality agreement and a confidentiality process that Bidders and Sellers can use, at their option, to ensure that the confidentiality of the Proposal is properly maintained in accordance with the Indexed REC RFP by the Contributors identified in the Proposal?

 

The Officer of the Seller and the Representatives of the Bidder are responsible for ensuring that, for the period starting with the opening of the Part 1 Window through the Commission decision on the results of the procurement event, all Contributors communicate Confidential Information relating to the Proposals only with each other and not to any other party.  In the Part 2 Proposal, the Officer of the Seller and a representative of the Bidder are required to acknowledge this obligation and to certify that all necessary measures to meet this obligation have been undertaken.

Attached is a sample of a confidentiality agreement and a confidentiality process that Bidders and Sellers can use, at their option, to ensure that the confidentiality of the Proposal is properly maintained in accordance with the Indexed REC RFP. It is not a requirement of the Proposal to provide evidence of use of this sample or process. This document is provided for the convenience of Bidders and Sellers.

04-06-2026

 

Q: Does bid assurance collateral in the form of cash need to be a wire transfer, or would ACH be acceptable?

 

Bid assurance collateral, which is due with the Part 2 Proposal, must be submitted in the form of cash or a letter of credit.

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.

04-03-2026

 

Q: Can a repowered wind facility qualify to participate in the Indexed REC RFP?

 

A repowered facility is not eligible to participate in the Indexed REC RFP.  As part of the Part 1 Proposal, the Officer of the Seller will be required to certify that the Project is not a repowered facility and that the Date of First Operation of the Project, as this term is defined in the Indexed REC Contract, did not occur on or before June 1, 2017.

Please refer to Section 5.5.5 of the Illinois Power Agency (“IPA”)’s filed 2026 Long-Term Renewable Resources Procurement Plan, which provides rationale for the exclusion of repowered wind projects from the IPA’s competitive procurement events:

“P.A. 103-1066 added “repowered wind projects” to the list of project types that qualify to produce RECs to meet Illinois RPS goals. Under Section 1-75(c)(1)(C)(iii) of the IPA Act, a “repowered wind project” refers to “utility-scale wind projects featuring the removal, replacement, or expansion of turbines at an existing project site.” That definition may be further refined through Long-Term Plan development.

As support for projects that have already been financed and constructed would not be the most impactful use of RPS funds, Section 1-75(c)(1)(C)(iii) clarifies that REC contract awards made to repowered wind projects “shall only cover the incremental increase in facility electricity production resultant from repowering.” As with brownfield site photovoltaic projects, Section 1-75(c)(1)(C)(i) clarifies that the Agency “shall consider and may propose other approaches in addition to competitive procurements to procure renewable energy credits from repowered wind projects.”

At this time, the IPA is unaware of any existing RPS-compliant utility-scale wind projects planning to repower, but suspects that dedicated support for repowering may become an issue across the next planning cycle. Nevertheless, the draft 2026 Plan solicited stakeholder feedback as to 1) whether the IPA should allow for repowered wind project participation, 2) if so, whether repowered wind projects should compete on the basis of price against new utility-scale wind projects, and 3) whether alternative procurement approaches for repowered wind projects other than the Agency’s Indexed REC procurement process should be considered. In the draft Plan, the Agency noted that if commenters demonstrated serious interest in RPS support for repowering wind projects through comments on this 2026 Plan, the Agency would reconsider its approach in this filed Plan; however, the Agency did not receive public comments related to repowered wind. Consequently, the IPA is not proposing procurement events or procurement event eligibility for repowered wind projects as part of this Plan.”

04-03-2026