CMC-8: With reference to the CMC Contract, we provided suggested language and a sample calculation for how Subsidies could be accounted for in our comments. Can you share why our suggested language and sample calculation was not included in the CMC Contract posted on November 15, 2021?

Regarding the example PTC calculation provided in comments on the draft contract, the Procurement Administrator’s understanding is that this sample calculation incorporated concepts found in pending federal legislation that has not yet been enacted.  An illustrative example predicated on proposed legislation would be inappropriate to memorialize in a legal instrument, especially as the underlying definitions would still apply should a subsidy take a different form.  Regarding the process for calculating that subsidy, provisions in the CMC Contract have been developed and finalized consistent with the Carbon Mitigation Credit Procurement Plan as approved by the Illinois Commerce Commission in ICC Docket No. 21-0718.