Policy Action Alert- DG Certification ruling written comments due Monday Dec 17th

14 Dec 2012 12:16 PM | Lesley McCain (Administrator)

              POLICY ACTION ALERT

Public written comments on the DG Certification ruling (Docket 12-0213) are due on Monday December 17th 2012. 

Please provide your written comments directly to the Illinois Commerce Commission.  It is imperative that you detail how this ruling will impact your business.

 In our interpretation, there are 3 basic issues with the statute: the definition of “install”, the definition of “qualified person” and the certifications that will be recognized and the fee structure.

Please note, the process on how to provide comments is outlined below.

 1.      “Install” means to complete the on-premise electrical wiring and connections necessary to  interconnect 

          distributed generation facility with the electric utility’s distribution system            .

           However the subsequent language of what it does not include creates confusion and ambuguity.

           The  meaning of  “install” in this part specifically does not include:

•·      Electrical wiring and connections to interconnect the distributed generation facility performed by utility workers on the electric utility's distribution system;

•·      Electrical wiring and connections internal to the distribution facility performed by the manufacturer; or

•·      Tasks not associated with the electrical interconnection of the distributed generation facility, including those relating to planning and project management performed by individuals such as an inspector, management planner, consultant, project designer, contractor or supervisor for the project.
 

2.      The current DG Installer Certification requirements specify that only “Qualified Persons” may connect a

         solar PV array to the grid.  A “Qualified Person” is currently narrowly defined as:

 

  • An apprentice or journeyman electrician who has completed a United States Department of Labor Registered Electrical Apprenticeship and Training Program and received a certification of satisfactory completion; OR
  • Or a person who has satisfactorily completed at least twenty installations of DG technologies

 

3.      Currently, the Application fee for certification is $3,000 with an annual re-certification report of $500.  

         Penalty for noncompliance is $6,000.

 

The ISEA believes these rules will:

•·      Impose unnecessary barriers on the growth of Illinois' solar and small wind industry;

•·      Place burdensome financial requirements on small businesses; and

•·      Displace highly trained individuals from employment.

 

. Process:

·         Go to  www.icc.illinois.gov

·         Select Consumers tab

·         Click Comment on a Case

·         Select a case from list drop down menu box, enter P 12 0213, SELECT

·         In the comment section be sure to include “First Notice Comments”

 

 

AN ADDITIONAL NOTE REGARDING THESE DRAFT RULES:

The Illinois DCEO is required to run a small business impact study to determine how the DG certification ruling will affect solar businesses in Illinois.  As such, please also email a copy of your comments to Katy Khayyat at her email address below and copy Lesley.mccain@illinoissolar.org.

 

Katy Khayyat

Illinois Department of Commerce and Economic Opportunity

Office of Regulatory Flexibility

500 East Monroe Street, 5th Floor

Springfield, IL 62701

Email:  Katy.Khayyat@Illinois.gov

 

 

 

 

Webinar Q&A

Q: There is a 2% limit on rate increases. Are you sure this is not a problem? The rate increase is in reference to the total procurement, so we do not anticipate it being an issue.


Q: I am a homeowner. Your invitation stated you may have some new information concerning Gov. Rauner's budget. That's what I'm particularly interested in. The proposed budget for 2015/2016, at this time has eliminated rebates and grants. ISEA’s position is that we will continue to advocate for the continuation of this program. There is also a legislative bill that has proposed an extension to this program through 2020 which we support and will continue to track.


Q: Can you provide an REC typical value for an average sized home with this proposed declining block program? I have a hard time explaining the value of RECs. Since Illinois has not had a REC price in the past, it’s difficult to estimate what the initial market value may be. The supplemental procurement will go a long way in establishing Illinois REC market prices. In the meantime, the Illinois Power Agency (IPA) will continue to research other markets to make the best decisions for the Illinois market. The goal, of course, is to install solar, and the purpose of the REC is to incentivize solar purchases and ensure pricing makes economic sense. As a reminder, there’s still a bit of the process left before we see what price RECs will have in Illinois. Once the legislation has been passed, and the REC price is published, we’ll update as needed.


Q: What recs are available for people who installed solar systems in 2014? If the system was energized prior to January 21, 2015, you qualify for the regular procurement event in September 2015.


Q: Does Exelon nuclear energy qualify as renewable energy with the 35% by 2030? It does not. Renewable energy is defined within the statute and includes wind, solar, and biofuels. More information can be found at http://www.ilga.gov/legislation/fulltext.asp?DocName=&SessionId=88&GA=99&DocTypeId=HB&DocNum=2607&GAID=13&LegID=88134&SpecSess=&Session=

It is important to note that the Clean Jobs Bill, not to be confused with other energy bills, is the only bill that focuses on renewable energy while producing 32000 jobs per year.


Q: Will clean energy that has already been produced from existing systems be considered for auction? No. The RECs will only be from the contract date of the accepted bid moving forward.


Q: If I plan to install more solar panels in 2015, are IL rebates still available, or is it dependent on Governor Rauner's budget proposal? The program for the 2014/2015 fiscal year is closed. So any future rebate availability will depend on the budget proposal. However, consider the procurement events of 2015/2016 as potential funding sources.  This scenario strongly highlights why we need to pass the Clean Jobs Bill (HB2607/SB1485) as it will provide a way to raise the status of renewable energy to equal that of all other forms of energy. Thus, any perceived dependence on rebates and grants will be removed.


Q: Evidently the 2014/20­15 rebates were frozen. Is that still the case? At this time, rebate decision letters have gone out, clarifying which will be paid and informing the owners that no further extensions will be granted.


Q: When will the specific process of solar customers contracting to be paid for future SRECs in place of the Illinois DCEO Rebate program be rolled out?­ The first supplemental procurement will be June 18, 2015. Aggregators are already available. We have a list of preferred companies here http://www.illinoissolar.org/SRECTrade-FAQ


Q: Once the REC schedule is defined, can you post some investment payback time scenarios on the ISEA blog, including the declining block ­ to let people know what is a realistic investment outlook?

We will try, however, we don’t anticipate seeing any information on this until early to mid 2016.



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