Indexed Renewables FAQs Fall 2026

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FAQ-Indexed Rec-7

Q: Does a project have to be located in Illinois to participate?

A brownfield site photovoltaic project must be located in the state of Illinois. A utility-scale wind project, a utility-scale solar project, or a hydropower project is not required to be located in the state of Illinois; however, if the Project is not located in Illinois, additional requirements described in this paragraph must be met. A Project that is located in a state adjacent to Illinois may qualify to participate in the Indexed REC RFP if it meets the public interest criteria specified in Section 1-75(c)(1)(I) of the IPA Act by submitting data about the Project to the IPA and obtaining pre-approval from the IPA that the Project is eligible for Illinois RPS compliance. States adjacent to Illinois are Wisconsin, Iowa, Missouri, Kentucky, Indiana, and Michigan. Instructions for obtaining approval through the public interest criteria are available from the Procurement Administrator. If a Project: (i) is located in a state adjacent to Illinois but does not meet the public interest criteria specified in Section 1- 75(c)(1)(I) of the IPA Act; or: (ii) is located in a state other than Illinois and the states adjacent to Illinois; such a Project may be eligible for Illinois RPS compliance if the energy from the Project is transmitted to Illinois over a High Voltage Direct Current transmission line that meets the criteria specified in Section 1-75(c)(1)(I) of the IPA Act. A Bidder that seeks to qualify such a Project must email the Procurement Administrator for additional information.

09-23-2026

Part 1 Proposal Rules

FAQ-Indexed Rec-6

Q: How can a Project located in a state adjacent to Illinois become pre-approved to be eligible for Illinois RPS compliance?

In order for a Project located in a state adjacent to Illinois (Wisconsin, Iowa, Missouri, Kentucky, Indiana, and Michigan) to be pre-approved to be eligible for Illinois RPS compliance, the bidder must submit an evaluation spreadsheet to the Illinois Power Agency by email to ipa.contactus@illinois.gov. The evaluation spreadsheet is available on the IPA’s website, under the header “Adjacent State Facility Eligibility” here, and is dated February 27, 2026. Please complete the fields in yellow. Once the required fields in yellow have been inputted, the spreadsheet generates a preliminary score subject to review by the IPA. The minimum score needed to qualify is 60.

09-23-2026

Part 1 Proposal Rules

FAQ-Indexed Rec-5

Q: Are we able to choose our counterparty to the Indexed REC Contract, either ComEd, AIC or MEC? If yes, do we post Bid Assurance Collateral with only the Company we choose?

This is not possible. If the Bid for a Project is selected by the evaluation procedure and approved by the Commission, the Procurement Administrator allocates the quantity of RECs selected by the evaluation procedure to the Companies in pre-specified proportions. The Seller will be the counterparty to each Company for delivery of RECs from the Project.

Bid Assurance Collateral must be posted separately with each Company in the form of cash or a Pre-Bid Letter of Credit and the amount required is based on the Project size. The RFP Process and Rules for the Fall 2026 Indexed REC RFP will be posted to the Final Materials page of the procurement website with more information regarding Bid Assurance Collateral required for each Company on September 23, 2026. The Standard Pre-Bid Letters of Credit for each Company are already posted to the Final Materials page: https://www.ipa-energyrfp.com/indexed-renewables/final-materials/

09-22-2026

Pre-Bid Collateral

FAQ-Indexed REC-4

Q: When will the list of the qualifying plants and mines associated with the Energy Transition Community Grant Areas for the Fall 2026 Indexed REC RFP be posted?

The list of the qualifying plants and mines associated with the Energy Transition Community Grant Areas for the Fall 2026 Indexed REC RFP will be posted to the Final Materials page of the procurement website on September 23, 2026 as Appendix 18 to the RFP Rules.

09-22-2026

Part 1 Proposal

FAQ-Indexed REC-3

Q: Can the Procurement Administrator provide a sample of a confidentiality agreement and a confidentiality process that Bidders and Sellers can use, at their option, to ensure that the confidentiality of the Proposal is properly maintained in accordance with the Indexed REC RFP by the Contributors identified in the Proposal?

The Officer of the Seller and the Representatives of the Bidder are responsible for ensuring that, for the period starting with the opening of the Part 1 Window through the Commission decision on the results of the procurement event, all Contributors communicate Confidential Information relating to the Proposals only with each other and not to any other party.  In the Part 2 Proposal, the Officer of the Seller and a representative of the Bidder are required to acknowledge this obligation and to certify that all necessary measures to meet this obligation have been undertaken.

Attached is a sample of a confidentiality agreement and a confidentiality process that Bidders and Sellers can use, at their option, to ensure that the confidentiality of the Proposal is properly maintained in accordance with the Indexed REC RFP. It is not a requirement of the Proposal to provide evidence of use of this sample or process. This document is provided for the convenience of Bidders and Sellers.

09-22-2026

Part 1 Proposal

FAQ-Indexed REC-2

Q: I’ve received an email from the Illinois Commerce Commission asking me to submit a Supplier Diversity report for my company. Why am I being asked this and what does it entail?

Section 5-117 of the Public Utilities Act, as amended by Public Act 99-0906, requires certain non-utility entities to submit an annual Supplier Diversity report to the Illinois Commerce Commission (ICC) by June 1 of each year. Renewable energy developers and Approved Vendors (AVs) in IPA programs must submit these reports if they have received a contract with delivery obligations of over 10,000 RECs in a given year.

Eligibility is based on the average annual RECs expected from each contract over its lifetime. For utility-scale and Indexed REC participants, this is the “Annual Quantity” as outlined in each Product Order. For Illinois Shines and Illinois Solar for All AVs, this refers to the Expected Maximum REC Quantity in the Schedule A. Eligibility is not based on RECs expected per individual project, as REC contracts may include multiple, smaller projects. Importantly, each REC contract from each entity is examined separately: eligibility is not based on the sum of an entity’s entire contract portfolio, their contract portfolio across each IPA program, or any other combination.

• Example: Entity A holds one Illinois Shines REC contract for a total of 150,000 RECs to be delivered over 15 years. The average annual RECs delivered is 10,000. Entity A is required to submit a Supplier Diversity report to the ICC.
• Example: Entity B holds five Illinois Solar for All REC contracts. Each contract is for a total of 30,000 RECs to be delivered over 15 years. The average annual RECs delivered from each individual contract would be 2,000. Entity B is not required to submit a Supplier Diversity report to the ICC.

While eligibility for Supplier Diversity reporting is based on participation in IPA programs, the reporting process itself is overseen by the ICC. For more information along with report submission instructions, please visit the ICC’s Supplier Diversity page: Supplier Diversity Reports for Non-Utilities.

08-19-2026

Contract

FAQ-Indexed REC-1

Q: Does the Indexed REC Contract include payment for capacity or any other product related to the Project in addition to the renewable energy credits?

The Indexed REC RFP is for the procurement of Renewable Energy Credits only from a Project that is qualified and selected under the RFP. The Indexed REC Contract does not include delivery or payment for energy, capacity, or any other product related to the Project. Each Bidder is responsible for the sale of other products related to the Project including energy and capacity.

08-17-2026

Contract