BSP-34: 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.