For a Project that is not yet operational, the Long-Term Procurement Plan states:
“In the case of a new adjacent-state facility that is not yet operational (and thus also not registered in GATS or M-RETS), an owner may submit a request for determination of eligibility based upon the planned design of the facility. Such a submittal must also include documentation from the applicable RTO (or utility for distributed resources) that the facility has entered the interconnection queue and is actively pursuing an interconnection agreement. If the Agency determines that the planned facility does meet the public interest criteria, then it will grant a pre-approval of the eligibility. It will be the responsibility of the facility owner to notify the IPA and the tracking system once the facility is operational to request being coded as eligible for the Illinois RPS in the applicable tracking system. The Agency will review final system information to verify consistency with the information submitted for the pre-approval.”
Thus, for a Project that is not yet operational, there are two steps: a first step for pre-approval before the project is operational, and then a review by the IPA in a second step once the Project is operational AND registered in a tracking system to confirm eligibility. In the second step, the IPA will verify consistency of the information submitted for pre-approval with the information provided through the tracking system upon registration of the system.
If a Project is operational and registered in a tracking system, and if such a Project is presented in a Proposal to the Brownfield and Utility-Scale Solar RFP (“RFP”), then the Project should provide with the Part 1 Proposal confirmation of its eligibility status for the Illinois RPS from the second step. If the Project is not yet registered in GATS or M-RETS, the Project is between the first step and the second step. If such a Project is presented in a Proposal to the RFP, the Bidder should explain that pre-approval was obtained, that the Project is not registered in a tracking system, and thus that final eligibility for the Illinois RPS has not yet been determined. While such a Project may participate in the RFP, please note that any risk associated with the IPA not being able to confirm the Project’s eligibility for the Illinois RPS is entirely borne by the Bidder.