For purposes of the initial forward procurement, there is no carve-out for brownfield site photovoltaic projects. The first procurement event Target of 200,000 RECs is thus for brownfield site photovoltaic projects and utility-scale solar projects combined, each of which is eligible to participate in this procurement process under Section 1-75(c)(1)(G)(ii) of the IPA Act. Both types of projects are evaluated together on the basis of price alone.
You are correct that there is a 2% requirement for brownfield site photovoltaic projects in the Illinois RPS (20 ILCS 3855/1-75(c)(1)(C)). Depending on the results of the initial forward procurements, the IPA will adjust future targets through procurements proposed in its long-term renewable resources procurement plan, currently under development, to meet that 2% brownfield site photovoltaic requirement. Thus, if brownfield site photovoltaic projects are selected through the initial forward procurements in a manner that exceeds the 2% requirement, then the future targets for brownfield site photovoltaic projects will be set lower than they otherwise would have been (and vice versa with future targets representing more than the 2% overall requirement if less than this percentage is procured through the initial forward procurements) for future procurements proposed in the IPA’s long-term renewable resources procurement plan.