S&B-1: Are there fundamental differences between the procurement events that will be conducted under the upcoming Forward Procurements and the procurement events that were conducted under the Initial Forward Procurements specifically with regards to brownfield site photovoltaic projects?

Yes. Unlike the Initial Forward Procurement, there is a quantity of 80,000 RECs set aside to be procured specifically from brownfield site photovoltaic projects. In previous events, there was no set aside quantity for brownfield site photovoltaic projects so that RECs from utility-scale solar projects and from brownfield site photovoltaic projects competed against each other.

Additionally, in response to the Illinois Commerce Commission’s Final Order issued on April 3, 2018 (Docket 17-0838), the eligibility requirements for brownfield sites in the IEPA’s Site Remediation Program will change from the requirements under the Initial Forward Procurement. Bidders that present a project regulated under this program will be required to show that the site currently features or featured actual blight or contamination prior to remediation. The IPA is developing these additional requirements and seeks stakeholder input.

On June 15, the Illinois Power Agency posted a Request for Comments to its website here:

Feedback regarding additional requirements for IEPA brownfield site eligibility is requested under Topic 5. Stakeholders are requested to send responses to this Request for Comments to by June 27, 2018.