A number of the Illinois Solar for All: Community Solar projects submitted during the 2021-2022 program year’s submission window are co-located projects. The Project Selection Protocol and the Approved Vendor Manual address how co-located projects should be handled in various scenarios, such as how individually sized co-located projects could each receive one point value.
However, the combined size of the two Community Solar projects that were submitted for this program year’s submission window is over the threshold for a different point allocation. This situation is not specifically addressed within the Project Selection Protocol, but it is discussed in the Approved Vendor Manual. To address this particular situation, the Illinois Solar for All Program Administrator provides clarification on how points will be allocated.
Size Point Allocation Clarification for Co-Located Projects
As described in the 2021-2022 Project Selection Protocol, points are given based on the size point categories:
- < 100 kW = 1.5 points
- 101-500 kW = 1 point
- 501-1000 kW = 0.5 points
This clarification applies to co-located projects that are sized such that they individually fall in one size point category. However, when considered as co-located and added together, the total size is in another size point category. According to the Project Selection Protocol, the size point category for proposed co-located projects is always the totaled size, whether on a single parcel or contiguous parcels. For example, two co-located projects that are each 275 kW would each receive 0.5 points based on a combined size for the co-located systems of 550 kW rather than 1 point each based on the individual 275 kW size.
This determination is based on the co-location guidelines described in Section 10.8 of the Approved Vendor Manual, which discusses co-location and distinctly distinguishes between co-located projects located on either a single parcel or on contiguous parcels: “Multiple projects up to 2 MW in aggregate on the same parcel with the same owner will be considered a single project for the purposes of REC pricing as well as size criteria in the case of a lottery.”
If the systems are on contiguous parcels, the following applies: “If there are multiple projects owned or developed by a single entity (or its affiliates) located on one parcel of land or on contiguous parcels of land, any size-based adders will be based on the total size of the projects owned or developed on the contiguous parcels by that single entity or its affiliates.”
Although the Approved Vendor Manual doesn’t explicitly state whether the multiple projects need to be selected projects or proposed projects for this to apply, the co-located projects’ total size needs to be considered in the case of a lottery (in this case, project selection is considered a “lottery”). Therefore, the use of the combined size of the co-located projects to determine the size point category is indicated before selection occurs.
Similarly, although it is not explicitly stated how to allocate size points to co-located projects located on contiguous parcels of land, the Approved Vendor Manual does reference size-based adders being based on the “total size of the projects,” which also indicates the intent to view co-located projects based on the total combined size.
If an Approved Vendor wishes to drop one of the co-located projects, they may do so by notifying the Program Administrator in writing by 12 p.m. CT on October 22, 2021. The remaining project will receive points based solely on the size of the remaining project.