The IPA filed its Long-Term Renewable Resources Procurement Plan (“2022 Long-Term Plan”) with the Illinois Commerce Commission (“ICC”) on March 21, 2022. Section 5.5.4 of the 2022 Long-Term Plan states:

“The Agency is not proposing any procurements of RECs from resources other than new wind and new photovoltaic projects; this includes both other renewable energy generating technologies as well as procurements for RECs not from specific projects or intended to result in new project development (e.g., RECs from existing projects energized prior to June 1, 2017).

As explained in Section 2.6.2.1, Section 1-75(c)(1)(C) of the IPA Act only established targets for RECs from new wind and furthermore that percentage-based RPS goals – be “met entirely by procurements of renewable energy credits from new wind and photovoltaic projects.” While the Agency appreciates that other renewable energy technologies are listed in the definition of renewable energy resources contained in Section 1-10 of the IPA Act, these provisions of Section 1-75(c)(1)(C)—taken in combination with the procurement priorities set forth in Section 1-75(c)(1)(F) of the Act— preclude consideration of a procurement from technologies other than wind and solar. RECs generated using technologies other than wind and solar can be used for other purposes, such as sales into voluntary REC markets outside the IPA’s purview, or by Alternative Retail Electric Suppliers for “green” or “renewable” retail electric supply offers.”

The ICC is expected to release its Final Order approving or modifying the 2022 Long-Term Plan on July 14, 2022.