Long-Term Renewable Resources Procurement Plan August 6, 2018
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The law then provided parties with 45 days to provide comment on the draft plan. Comments were
made publicly available through being posted on the IPA’s and ICC’s websites, and such comments
were required to be “specific, supported by data or other detailed analyses, and, if objecting to all or
a portion of the procurement plan, accompanied by specific alternative wording or proposals.”
During the comment period, the Agency held public hearings for receiving public comment on the
Plan in the service territory of each affected utility. The Agency’s hearings occurred on October 26th
of 2017 in Springfield (Ameren Illinois), October 31st in Chicago (ComEd), and November 3rd in
Moline (MidAmerican).
With a draft Plan release date of September 29, 2017, comments were due on the draft Plan by
November 13, 2017. 49 comments were received from: 3Degrees, Ameren Illinois, APX, Carbon
Solutions Group, Center for Resource Solutions, City of Springfield, Clean Energy Design Group,
Coalition for Community Solar Access, ComEd, Direct Energy, Downstate Caucus, Elevate Energy,
Environmental Defense Fund/Citizens Utility Board, Environmental Law and Policy Center, Exelon
Generation, ForeFront Power, GRID Alternatives, GRID Alternatives/Elevate Energy, IGS Solar/SGC
Power, Illinois Attorney General, Illinois Commerce Commission Staff, Illinois Municipal Electric
Agency, Illinois National Association for the Advancement of Colored People, Illinois People's Action,
Illinois Solar Energy Association, Illinois Solar for All Working Group, Innovative Power Systems,
Interstate Renewable Energy Council, Joint Solar Parties, Kimberly Wasserman/Veronica Kyle/Keith
Harley, Landlease Energy Development, Little Village Environmental Justice Organization, Marseilles
Land & Water, Metropolitan Mayors Caucus, Natural Resources Defense Council, Northern Illinois
Hydropower, Renewables Suppliers, Sierra Club, SolAmerica Energy, Solar Energy Industries
Association, SRECTrade, Sunvest Solar, Syncarpha Capital, Tick Tock Energy, Trajectory Energy
Partners, Village of Oak Park, Vote Solar, Will County, and Wind on the Wires.
After the conclusion of the comment period, “the Agency may revise the long-term renewable
resources procurement plan based on the comments received” and, within 21 days after the
conclusion of that period, “shall file the plan with the Commission for review and approval.”
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This
left the Agency with a filing deadline of December 4, 2017, on which date the Agency filed its Plan for
approval reflecting revisions made by the Agency in response to, and in consideration of, the
comments received.
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The Illinois Commerce Commission’s Plan approval proceeding took the form of a contested,
docketed proceeding governed by the Commission’s Rules of Practice (Title 83, Part 200 of the Illinois
Administrative Code). Similar to the requirements applicable to the IPA’s annual procurement plans,
within 14 days after the filing of the Plan, “any person objecting to the plan” was required to “file an
objection with the Commission.”
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With a December 4, 2017 filing date, “objections” were due by
December 18, 2017. Objections were filed by the Joint Solar Parties, Environmental Defense Fund,
ICC Staff, Renewables Suppliers, Wind on the Wires, Bosch Building Grid Technologies, Coalition for
Community Solar Access, Carbon Solutions Group, Natural Resources Defense Council, Ameren
Illinois Company, Commonwealth Edison Company, Elevate Energy and GRID Alternatives, Inc.
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Id.
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For additional discussion of the Agency’s review of comments received, and the resulting positions modified and explanation of why
certain positions were not modified, please refer to the Petition accompanying the initial filing of the Plan for Commission approval in
Docket No. 17-0838. A redline copy showing changes in the filed Plan against the Draft Plan published on September 29, 2017 can also be
found on the Agency’s website (www.illinois.gov/ipa
).
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220 ILCS 5/16-111.5(b)(5)(ii)(C).