Comments on the Illinois Power Agency (IPA) Long-Term Renewable Resources Procurement Plan

The intent of these comments is to provide information on industry best practices in regard to Section 7.6.3: Marketing Claims Related to the Ownership of RECs and Community Renewable Generation Subscriptions. Specifically, the decision to allow utilities to retire the associated Renewable Energy Certificates (RECs) for Renewable Portfolio Standard (RPS) compliance raises significant issues for how these programs can be responsibly marketed and what renewable energy claims subscribers can legally make.