W&S-228: Will the IPA consider repowered facilities as “new” projects for purposes of the upcoming procurement event under the Wind and Solar RFP?

No.  Section 1-75(c)(1)(G) of the IPA Act (20 ILCS 3855) provides statutory authority only for the IPA to conduct “initial forward procurements” of RECs from “new utility-scale wind projects” and “new utility-scale solar projects and brownfield site photovoltaic projects.”  Section 1-75(c)(1)(C)(iii) defines new wind and solar “projects” as “renewable generating facilities,” while Section 1-10 of the IPA Act defines a “facility” as “an electric generating unit or a co-generating unit that produces electricity along with related equipment necessary to connect the facility to an electric transmission or distribution system.”

As many repowered facilities would feature a substantial portion of what by law constitutes the “facility” as something other than “new,” they would be disqualified from participation in the initial forward procurements.  However, as any repowered facilities (even those with entirely new components) would be competing for selection on the basis of price with facilities representing entirely incremental generation first “energized” after the effective date of Public Act 99-0906, the IPA does not consider repowered projects with “new” components to be “new” projects that qualify for the initial forward procurement.  Providing an incentive for existing generation to simply repower more efficiently would be inconsistent with statutory authority encouraging the development of “new” projects to “to diversify Illinois electricity supply, avoid and reduce pollution, reduce peak demand, and enhance public health and well-being of Illinois residents” (20 ILCS 3855/1-75(1-5)(6)), as the incremental benefits offered to Illinois residents by a repowered project would be significantly less than those offered by an entirely new facility.

To the extent that parties believe that such projects should be considered “new” for future RFPs, parties may offer those comments as part of their comments on the draft of the IPA’s long-term renewable resources procurement plan scheduled to be released in September 2017.