Brownfield FAQs

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General

FAQ-BSP-38
Q: Where can I find results for previously awarded projects under the Brownfield RFP?

The Procurement Administrator has conducted two procurement events to procure RECs from Brownfield projects: the Fall 2018 Brownfield and Utility-Scale Solar RFP and the Summer 2019 Brownfield RFP. No RECs were procured from brownfield projects under the Fall 2018 Brownfield and Utility-Scale Solar RFP. The average winning price of Brownfield Projects under the Summer 2019 Brownfield RFP was $58.10/REC.

Additional information on the 2018 Brownfield and Utility-Scale Solar RFP and the 2019 Brownfield RFP is posted in the Previous RFPs page on the procurement website. For example, to access the results of the 2018 Brownfield and Utility-Scale Solar RFP or the 2019 Brownfield RFP, first click on the “2018 Brownfield and Utility-Scale Solar Procurement and 2019 Brownfield Procurement (AIC, ComEd, and MEC)” link, and download the results posted at the top of the page under the header “Fall 2018 Brownfield and Utility-Scale RFP Results” or “Summer 2019 Brownfield RFP Results”.

07-20-2020

FAQ-BSP-37
Q: Must the entire site where the project is located be regulated by one of the brownfield Programs?

The project must be located in Illinois and must be entirely located within a site that is regulated by one of the following “Programs”: (1) the United States Environmental Protection Agency under the federal Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as amended (“CERCLA”); (2) the United States Environmental Protection Agency (“U.S. EPA”) under the Corrective Action Program of the federal Resource Conservation and Recovery Act, as amended (“RCRA”); (3) the Illinois Environmental Protection Agency (“IEPA”) under the Illinois Solid Waste Program; or (4)  the Illinois Environmental Protection Agency under the Illinois Site Remediation Program (“SRP”).

12-11-2019

FAQ-BSP-36
Q: To meet its statutory target, will the IPA need to conduct another brownfield procurement?

The brownfield procurement that was conducted in 2019 had target of 80,000 RECs delivered annually, in excess of the statutory target for 2020-2021. While the exact quantity procured was not released, the IPA noted in its Revised Long-Term Plan that this procurement resulted in the IPA exceeding its statutory target of 40,000 RECs delivered annually by 2020-2021.

In its Revised Long-Term Plan, the IPA also notes that unless additional funding becomes available, its available funds will not be sufficient to support another brownfield procurement.  However, should additional funding become available, the IPA proposed that the first priority would be to meet the 2025-2026 targets under the Adjustable Block Program and the IPA proposed that the second priority would be to hold an additional brownfield procurement with a target quantity of 50,000 RECs delivered annually.

Please see the IPA’s draft Revised Long-Term Renewable Resources Procurement Plan released on August 15, 2019 available here: https://www2.illinois.gov/sites/ipa/Pages/Renewable_Resources.aspx

11-05-2019

FAQ-BSP-35
Q: What exactly is meant by “brownfield”? Must a Project be utility scale to qualify as brownfield? Can a project on a greenfield site qualify?

The Act requires brownfield site photovoltaic projects to be located at a site that is regulated by the United States Environmental Protection Agency under either the federal Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as amended, or the Corrective Action program of the federal Resource Conservation and Recovery Act, as amended; or by the Illinois Environmental Protection Agency under either the Illinois Site Remediation Program, or the Illinois Solid Waste Program.

A project on a greenfield site does not qualify.  A brownfield project does not have to be utility-scale, i.e., the project may be less than 2 MW (AC rating) in size.

10-30-2019

FAQ-BSP-34
Q: Can a Community Renewable Generation Project qualify under the Brownfield RFP? Is a project required to be utility-scale?

Section 1-75(c) of Public Act 099-0906 mandates that the IPA to procure at least 2,000,000 RECs from new photovoltaic projects of which “at least 2% from brownfield site photovoltaic projects that are not community renewable generation projects”. Thus, the requirement that the RECs procured from brownfield projects not be from community renewable generation projects is mandated by law.  A brownfield project does not have to be utility-scale, i.e., the project may be less than 2 MW (AC rating) in size.

10-30-2019

FAQ-BSP-33
Q: Is there another Brownfield RFP planned? How do I register to receive information about any future Brownfield RFP?

Please join our mailing list to receive updates and announcements regarding RFPs announced by the Procurement Administrator by completing the Contact Us form here: https://www.ipa-energyrfp.com/contact-us/register/.

The Summer 2019 Brownfield RFP has concluded. The procurement website currently contains dedicated pages for the remainder of events to be held in 2019: Fall Block Energy and Capacity RFP, Utility-Scale Wind RFP, Low-Income Community Solar Pilot Program, and Community Renewable Generation Program.

The Illinois Power Agency (“IPA”) released its update to the Initial Long-Term Renewable Resources Procurement Plan on August 15, 2019. This plan is in draft form for public comment and includes an overview of the procurements and programs administered by the Illinois Power Agency. The plan is available on the Renewable Resources page of the IPA website (https://www2.illinois.gov/sites/ipa/Pages/Renewable_Resources.aspx).

08-21-2019

FAQ-BSP-32
Q: Please provide me a detailed summary of those projects that submitted a proposal as a brownfield site photovoltaic site under the Brownfield and Utility-Scale Solar RFP and precisely why those projects were not successful.

The results of the Brownfield and Utility-Scale Solar RFP were released on December 4, 2018.  No successful bids were received from brownfield site photovoltaic projects, and thus no projects were selected under the Brownfield and Utility-Scale Solar RFP.

For competitive procurements, such as the Brownfield and Utility-Scale Solar RFP, Section 16.111.5(h) of the Public Utilities Act provides as follows:

“The names of the successful bidders and the load weighted average of the winning bid prices for each contract type and for each contract term shall be made available to the public at the time of Commission approval of a procurement event. The Commission, the procurement monitor, the procurement administrator, the Illinois Power Agency, and all participants in the procurement process shall maintain the confidentiality of all other supplier and bidding information in a manner consistent with all applicable laws, rules, regulations, and tariffs. Confidential information, including the confidential reports submitted by the procurement administrator and procurement monitor pursuant to subsection (f) of this Section, shall not be made publicly available and shall not be discoverable by any party in any proceeding, absent a compelling demonstration of need, nor shall those reports be admissible in any proceeding other than one for law enforcement purposes.”

This section allows only the names of successful bidders and the weighted average of the winning bid prices to be made publicly available.  Further, provided that there are at least three successful suppliers, prior Commission Orders allow the quantities awarded also to be made publicly available.  Information, including “a detailed summary of the projects that submitted” a proposal, is considered confidential and cannot be provided.

In terms of why those projects were not successful, the following explanation for how this outcome could arise was provided at the time. Section 1-75(c)(1)(D) of the IPA Act requires that proposed REC prices cannot exceed benchmarks based on market prices or other publicly available data for the region.  Benchmarks are established by the Procurement Administrator, in consultation with the IPA, the Procurement Monitor, and the Staff of the Illinois Commerce Commission, and are subject to the review and approval of the Commission.  Benchmark prices are specific to each category of product being procured, and to protect the integrity of the IPA’s competitive procurement processes, all aspects of the benchmark development process (including the resulting benchmark prices) are treated as confidential.

Consequently, each bid submitted must first meet or beat the benchmark price applicable to that category before proceeding to evaluation.  Bids not exceeding the benchmark price for that category are then ranked in order of price per REC, starting with the lowest price, until the annual REC delivery target for that category is met or until all bids that meet or beat the benchmark price have been ranked.  These bids are selected and identified by the Procurement Administrator to the Commission as winning bids.

Revised 7/25/2019 first posted 2/19/2019

07-25-2019

FAQ-BSP-31
Q: I am looking at the May 2, 2018 information release where the product is solar RECs from utility-scale projects or brownfield site photovoltaic projects. The average winning price is $5.01/REC. Such a low price would make it challenging to pursue a high-risk project such as one on a brownfield site. Am I interpreting the price information correctly?

As stated on page 87 of the Long-Term Renewable Resources Procurement Plan, “The Initial Forward Procurements, conducted in August 2017, March 2018, and April 2018, did not procure any RECs from new brownfield site photovoltaic projects, and the Agency has not otherwise procured any RECs that would satisfy the brownfield site photovoltaic project requirement.” The average winning price of $5.01/REC that you reference was for RECs from utility-scale solar projects only. Under the Initial Forward Procurements, there was no carve-out for brownfield site photovoltaic projects. All RECs from utility-scale solar projects and from brownfield site photovoltaic projects were evaluated together.

This was not the case for the Brownfield and Utility-Scale Solar RFP. Under this procurement event, utility-scale solar projects and from brownfield site photovoltaic projects were evaluated separately. Ultimately, no successful bids were received from brownfield site photovoltaic projects and thus no such projects were selected.

The IPA received feedback on any barriers that may have limited successful participation in the Brownfield Procurement. A document listing specific questions that the Agency posed is available on their website here. The comments received are posted on the Illinois Power Agency’s (“IPA”) website here.

Revised 7/25/2019 first posted 2/19/2019

07-25-2019

FAQ-BSP-30
Q: Has the IPA published the responses to its request for comment on the Brownfield Site Photovoltaic Procurement? Has the IPA responded to these comments?

The comments are posted on the Illinois Power Agency’s (“IPA”) website here. Information was redacted in accordance with the IPA’s Questions and Request for Comments posted on February 5, 2019.  The IPA has not provided responses at this time.

07-25-2019

FAQ-BSP-29
Q: Will there be another event to procure RECs from brownfield site photovoltaic projects?

A procurement for 80,000 RECs delivered annually from new brownfield site photovoltaic projects was held in Fall 2018 under the Brownfield and Utility-Scale Solar RFP. No successful bids were received from brownfield site photovoltaic projects, and thus no projects were selected under this RFP. Information regarding this previous RFP is available on the procurement website here.

On March 28, 2019, the IPA filed a petition requesting that the Illinois Commerce Commission (“Commission”) clarify that the IPA had the authority to run a second procurement event to procure RECs from new brownfield site photovoltaic projects. The Commission issued its Order on April 26, 2019 confirming that the IPA had the authority to run a procurement event for 80,000 RECs delivered annually from new brownfield site photovoltaic projects. This procurement event will be held in Summer 2019.

Information pertaining to the Summer 2019 Brownfield procurement event is posted to the dedicated Brownfield page of the procurement website. The schedule for this procurement event is posted to the Calendar page.

Revised 7/25/2019 first posted 3/19/2019

07-25-2019

FAQ-BSP-21
Q: When will the results from the Summer 2019 Brownfield RFP be announced publicly?

The results from the Summer 2019 Brownfield RFP are expected to be made public at the time of Commission approval on Thursday, August 1, 2019.

At the time of Commission approval of a procurement event, the names of successful bidders and the average of the winning Bid prices are made public.  The quantity of RECs procured may also be disclosed if there are at least three successful bidders.

07-02-2019

FAQ-BSP-18
Q: Does a Brownfield Project have to be a certain size?

There is no minimum or maximum size requirement for brownfield site photovoltaic projects.

06-24-2019

FAQ-BSP-16
Q: Is there a list of the suppliers that are participating in this procurement event?

For a procurement event held by a Procurement Administrator on behalf of the Illinois Power Agency, the Commission makes public only the names of the successful bidders and the average of the winning bid prices.  As required by Section 16-111.5(h) of the Public Utilities Act, “all participants in the procurement process shall maintain the confidentiality of all other supplier and bidding information.” Participants include the Procurement Administrator, the Procurement Monitor, the Commission, and the Illinois Power Agency. As further provided for in that section, any such confidential information “shall not be made publicly available and shall not be discoverable by any party in any proceeding, absent a compelling demonstration of need.”

06-24-2019

FAQ-BSP-15
Q: Who pays the supplier fees and what costs do these fees reflect?

Projects with winning Bids approved by the Commission will be assessed a Supplier Fee per REC that reflects the cost of administering 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.

06-24-2019

FAQ-BSP-13
Q: The Brownfield and Utility-Scale Solar RFP conducted in Fall 2018 did not have any successful brownfield site photovoltaic projects. Can you confirm that the average winning price provided in the results posting for the Brownfield and Utility-Scale Solar RFP is only applicable to Utility-Scale Solar Projects? Can you also confirm that the average winning prices provided in the results postings for the procurement events held under the 2017-2018 Initial Forward procurements were only applicable to Utility-Scale Solar Projects?

That is correct. No RECs were procured from brownfield site photovoltaic projects in the Fall 2018 Brownfield and Utility-Scale Solar RFP or in any of the procurement events held under the 2017-2018 Initial Forward procurements. Thus, the average winning prices provided in the results postings are applicable to Utility-Scale Solar Projects only. Please note that the winning price posted for the Wind and Solar RFP also includes winning RECs from Utility-Scale Wind Projects in the average.

06-19-2019

FAQ-BSP-9
Q: Where can I find the bidder information webcast for the Brownfield RFP?

The Procurement Administrator has posted the presentation slides and audio recording from the bidder information webcast held on June 13, 2019, to the Final Materials page of the Brownfield section of the procurement website.

06-14-2019

FAQ-BSP-6
Q: As a Bidder with a brownfield project that qualified in a previous procurement event under the Wind and Solar RFP, the New Solar RFP, or the Brownfield and Utility-Scale Solar RFP, can we use the same login credentials that we used previously?

As a Bidder with a brownfield project that qualified under a previous procurement event under the Wind and Solar RFP, the New Solar RFP, or the Brownfield and Utility-Scale Solar RFP, you will receive access to the Part 1 Form opening on Thursday, June 13, 2019 for the Brownfield Site Photovoltaic RFP.  You can use the same login credentials that you have used previously. If you are unsure whether you still have your login credentials, or if you are presenting additional projects, please contact the Procurement Administrator.

06-12-2019

FAQ-BSP-3
Q: Are there any changes in this Brownfield RFP compared to the procurement event held in Fall 2018?

The Procurement Administrator issued the draft Brownfield REC Contract on May 23, 2019. A redline of this draft to the final REC contract under the Fall 2018 Brownfield and Utility-Scale Solar RFP was also posted at that time. In addition to several clarifications, the changes were to make the contract only applicable to new photovoltaic projects that are built on brownfield sites, to incorporate additional force majeure events to Article 6, and to remove fax as a delivery method for notices and other correspondence. Please review the documents posted for complete details.

Preliminary Proposal documents will be posted by June 3 and the final RFP documents will be posted by June 13, 2019. The Procurement Administrator will hold a webcast on June 13 and will discuss any changes from the prior procurement events. The documents will be posted to the dedicated Brownfield Site Photovoltaic Procurement page of the procurement website.

If you have not done so already, please RSVP for the webcast.

05-24-2019

FAQ-BSP-2
Q: When does the Part 1 Window open?

The online Part 1 Form will become available no later than the morning of June 13, 2019, which is the opening of the Part 1 Window. The schedule for the Brownfield Site Photovoltaic Procurement, including the dates applicable to the Part 1 Window is posted to the Calendar page of the procurement website.

05-24-2019

FAQ-BSP-1
Q: Is the date of July 26, 2019 the date for submission of Bids as well as the date to meet other requirements of the Proposal?

July 26 is the date strictly for the submission of Bids.  To be eligible to submit Bids, a supplier must have met the qualification standards through the submission of a successful Part 1 Proposal (due June 20, 2019) and must have met all other requirements of the Part 2 Proposal (due July 12, 2019).

Proposals are submitted online.  To request login credentials for the submission of proposals, please register here:  https://www.ipa-energyrfp.com/contact-us/qualification-registration/

05-24-2019