Renewable Portfolio Standard Planning and Development Process

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Renewable Portfolio Standard Planning and Development Process Anthony Star Director, Illinois Power Agency Institute for Regulatory Policy Studies New Legislation on Future Energy Jobs, Lead & Water Pollutants, and Federal Policies April 27, 2017

Overview How the Renewable Portfolio Standard is changing Schedule and timing Procurement and Program overview Some issues for consideration How to participate

How RPS Approach Will Change Old Model Each year the IPA had to assess eligible retail customer load forecasts, available budgets, and RPS goals Other than a large procurement in 2010, this forced the IPA towards a short-term procurement perspective that was not well suited to developing new renewable resources Model for distributed generation was restrictive (e.g., 1 MW minimum bid size) Challenges for the use of the Renewable Energy Resources Fund New Model More budget and load certainty RPS moves towards a single stream as separate ARES compliance phases out Ability to do long-term planning and procurement Addition of specific program tailored to solar

Procurement vs. Program Traditionally IPA ran competitive procurements for energy and used this model for renewable resources Sealed-bid Request for Proposals Evaluated on the basis of price Pay as bid Distributed Generation and Community Solar will shift from a competitive procurement model to a administrative program model (Adjustable Block) Prices determined by methodology developed by IPA Blocks of Renewable Energy Credits available according to a schedule Programs will be ongoing rather than episodic Competitive procurements will continue to be the model for utility-scale renewables A variety of competitive procurements to meet utility RPS annual goals

April Energy Procurement Spring DG Procurement July Deadline To Release Draft ZEC Plan (7/15) May Workshops Release Request For Information August Draft Plan Released Initial Forward Procurement (Wind And Solar) IPA Releases Draft 2018 Power Procurement Plan Energy/Capacity Procurement Deadline To File ZEC Plan For ICC Approval June P.A 99-0906 Take Effect (6/1) Release Draft Initial Forward Procurement Contracts Request For Information Responses Due September Public Comments Due Deadline To Release Draft Plan (9/29) IPA Filed 2018 Power Procurement Plan For ICC Approval Fall DG Procurement Begins Deadline For ICC To Approve ZEC Plan Renewable Resources Timeline (Draft, dates subject to change) October IPA Files Plan For ICC Approval IPA Issues Program Administrator RFQ Fall DG Procurement, Cont. November Deadline To Hold Wind Initial Forward Procurement (11/8) Deadline For Comments On Draft Plan (11/13) December Deadline To File Plan For ICC Approval (12/4) IPA Issues Program Administrator RFP ICC Approves 2018 Power Procurement Plan January, 2018 February ICC Approves Plan Program Administrator RFP Responses Due March Program Administrator(s) Selected April Deadline For ICC Plan Approval (4/3) Energy Procurement May June Through December Programs Launch (Schedule TBD) Color Coding Statutory Deadline Plan Development Schedule Process Development Schedule Other Renewables Schedule Power Procurement Schedule

Initial Forward Procurement Held prior to, and separate from, the development/approval of the Long-Term Renewable Resources Procurement Plan Competitive procurement 1 million annual RECs each from new utility scale wind, and utility scale solar and brownfield solar 15 year contracts Earliest delivery start June, 2019, must start delivery by June, 2021 One procurement event for wind within 160 days of effective date of Act Multiple procurement events for solar over the year Goal is to hold procurement in August for both wind and solar Additional solar procurements to be scheduled at a later date Solar targets expected to increase for each procurement

Long-Term Renewable Resources Plan Plan will include: Analysis of utility load forecasts, budgets, and annual RPS goals Proposed approaches for the Adjustable Block and Illinois Solar for All programs Proposed schedule and approach for other procurements to meet annual RPS goals Plans for evaluation and ongoing adjustments

Adjustable Block Programs Three programs Distributed Generation below 10 kw, upfront payment Distributed Generation between 10 kw and 2 MW, 20% payment when energized, remainder over four years Community Solar, 20% payment when energized, remainder over four years Contracts to purchase 15 years of RECs Long-term Plan will include proposed approach for the determination of prices, block size/schedule, application process/criteria, etc. Contracts will have clawback provisions to ensure REC delivery Detailed program rules to be developed in conjunction with Program Administrator subject to the provisions in approved Plan

Illinois Solar for All Programs Funded primarily by the Renewable Energy Resources Fund Four specific programs Low-income Distributed Generation Incentive Low-income Community Solar Project Initiative Initiatives for Non-profits and Public Facilities Low-Income Community Solar Pilot Projects Long-term Plan will specify methodology for determining incentives Pilot projects competitively bid, other programs presumably will be based on the Adjustable Block approach Up to 5% of funding to community-based groups for grassroots education Agency will define Environmental Justice Communities and approaches to verifying low-income eligibility

Some Issues of Note Timing Of Program Launches Not likely to all start at the same time Managing Initial Blocks Want to avoid an unsustainable bubble Application Process How a developer reserves RECs, and how that process connects to project development timelines and interconnection requests/queue What Is The Community Solar Market Mix of commercial and residential customers Need For Consumer Protections Lessons learned from the bad actors in the alternative gas and electric sectors

Potential Delays Complexity of developing Long-Term Renewable Resources Plan could push release later than August and would thus delay ICC approval of Plan in 2018 Other IPA mandates could constrain available resources for development and implementation of new programs Lack of a State budget and resulting Agency appropriation could delay funding for Illinois Solar for All, the hiring of Procurement Administrator(s) and thus the start of new programs

Opportunities for Participation May Attend Workshops Initial Forward Procurements. May 10 (Chicago) Plan Overview/Adjustable Block Programs. May 17 (Chicago) Community Solar/Illinois Solar for All. May 18 (Chicago) Programs for Rural Communities. May 24 (Springfield) May/June Respond to workshop follow-up questions August/September Comment on the draft Long-term Renewable Resources Plan Fall/Winter Participate in Illinois Commerce Commission Docket to approve the Long-term Renewable Resources Plan