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.
· 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.firstname.lastname@example.org.
Illinois Department of Commerce and Economic Opportunity
Office of Regulatory Flexibility
500 East Monroe Street, 5th Floor
Springfield, IL 62701