S&B-87: I noticed that no RECs were procured from brownfield site photovoltaic projects in the latest procurement event. What was the basis for this decision and how could such an outcome arise?

Each bid in the Brownfield and Utility-Scale Solar RFP consists of a) a proposed quantity of RECs to be delivered annually from the project (based on the project’s nameplate capacity) as well as b) a price to be paid to the Seller for each REC delivered.  Given that the two project types are subject to separate statutory definitions and separate procurement targets under the law, brownfield site photovoltaic projects and utility scale photovoltaic projects were evaluated independently from each other.

For competitive procurement events (such as the brownfield site and utility-scale photovoltaic procurement) 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.