W&S-34: Will the IPA consider repowered facilities as “new” projects for purposes of the upcoming procurement event under the Wind and Solar RFP?

No.  The statutory support for the initial forward procurements envisions that procurements of RECs occur only from “new” projects.  The definitions of “new” wind and photovoltaic projects found in Section 1-75(c) of the IPA Act refers to new “renewable energy generating facilities,” with “facility” defined in the IPA Act 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 a substantial portion of what constitutes the “facility” would not be “new,” and as repowered facilities would be competing for selection on the basis of price with facilities featuring entirely “new” components, the IPA does not consider repowered projects to be “new” projects that qualify for the initial forward procurement.  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.