Under this RFP, sites for which the last available documentation for the brownfield site is older than 15 years would not fulfill the requirements for “brownfield site photovoltaic projects” under the Brownfield and Utility-Scale Solar RFP.
A goal of the Brownfield and Utility-Scale Solar RFP is to support the development of brownfield sites within Illinois to help return blighted or contaminated land to productive use. As defined in the Public Act 99-0906 (“the Act”), brownfield site photovoltaic project means only photovoltaic projects that are: (1) interconnected to an electric utility, a municipal utility, a public utility, or an electric cooperative as defined by the Act; and (2) located at a site that is regulated by one of the entities and four programs listed in the Act. To comply with this statutory language, the IPA proposed in draft guidelines that any documentation issued by or filed with the relevant authority must be dated no earlier than 15 years prior to the Bid Date, understanding that this requirement may exclude sites that have been fully remediated for a longer period while allowing participation from some sites that may no longer currently be regulated by one of the entities under the Act’s four delineated programs. An invitation to comment on the “Draft Brownfield Site PV Guidelines”, including this timing requirement, was issued on September 17, 2018 and an announcement was sent to website registrants. As the comments received did not provide a clear direction or alternative to these draft guidelines, this 15-year requirement was maintained for the RFP Rules.
While the parameters used in this RFP could potentially change for any future brownfield site procurements, under the current Brownfield and Utility-Scale Solar RFP, Projects without documentation within the last 15 years cannot meet the qualification standards for brownfield site photovoltaic projects. However, please be aware that any such Project, if it is greater than 2 MW in size, may meet the requirements for a utility-scale solar project under this RFP.