Case Number: 12-0213

  • January 30, 2013

    Brief on Exceptions

    Date: January 24, 2013

    To: Chief Clerk’s Office

    From: Christopher Miller, Professor and Program Coordinator of Renewable Energy, Electronic Systems Technology, Industrial Technology, Heartland Community College.

    Heartland Community College respectfully submits its Brief on Exception to the Proposed Order issued by the Administrative Law Judge for docket number 12-0213. Specifically, in response to BRIEF ON EXCEPTIONS OF STAFF OF THE ILLINOIS COMMERCE COMMISSION by Kelly A Armstrong, ICC Staff dated January 18, 2013. The staff’s response to a “Qualified Person” involving graduates of an Associates Applied Science, AAS, degree, inquired about the lab / training within the degree program, here is a brief overview of our program. The AAS degree by its nature is heavily involved with hands-on lab and field work. Our technical courses are articulated with Illinois Community College Board as half lecture / half hands-on lab in structure. Professional Capstone projects are heavily used throughout the degree program preparing students on the installation and maintenance of the specific technical skill or trade they are preparing for. We fully understand and share the concerns mentioned about the quality of courses and programs. A consideration should be made that all training and certification bodies will have very different levels of “quality” involving the concerns outlined by the ICC staff.

    We support the views and rewrite by the ICC staff on the modification of a “Qualified Person”, section 468.20. It reflects the realities necessary to getting skilled people, from a wide and diverse group of Illinoisans, performing safe, reliable, installations of distributed energy systems. If the staff comments are implemented we feel the definition does not go far enough. We believe all persons, regardless of which track of education, apprenticeship, or training they pursue, should be required to satisfactorily completed at least one installation of a specified distributed generation technology under the direct supervision of a qualified person. This will lessen the risk defined by the ICC staff of the quality and content of a specific training or apprenticeship program.

    Advances in technology can and will change, as will the training, education and accreditation of the qualified people working on these systems. Great care should be used in crafting this final rule to allow people throughout all of Illinois the opportunity to become a “qualified person” in the specific distributed energy system they are trained in. From a Community College perspective we offer an accredited, affordable, and intensive technical hands-on training program in distributed energy systems. The rule should be crafted that a trained “qualified person” from whatever path they choose, college, apprenticeship, or select training can enter the workforce and be gainfully employed.

    All three listed certification organizations ETA, NABCEP and UL offer quality and competent certification for current technologies. But what about future distributed energy technologies and their future certification bodies, such as natural gas to electricity converters? While this docket has a serious impact mainly concerning photovoltaic distributed energy systems, it needs to be crafted to support future distributed energy systems.

    Heartland Community College supports Illinois Commerce Commission, ICC, adaptation of Administrative Law Judge's Proposed Second Notice Order, consistent with ICC Staff's recommendations and the recommendations described above.

    Respectfully submitted,

    Christopher Miller
  • December 21, 2012

    First Notice Comments 12-0123
    I am the Coordinator of Electrical Technology (ET) training at Kankakee Community College (KCC). KCC’s ET program includes Renewable Energy (RE) training with a course in Solar-PV. KCC is a NABCEP-approved Entry-Level Solar-PV training provider and has the only IREC/ISPQ-accredited Solar Training Program in Illinois. NABCEP is the gold standard for RE installer certification. IREC/ISPQ is the gold standard for RE instructor certification and RE training-program accreditation.
    I am a Registered Professional Engineer and a NABCEP-certified Solar-PV Installer. I’ve been a solar-PV professional since the early 1970’s. My professional projects include the first solar powered digital telephone exchange in the U.S., the first solar powered passenger railway station in the U.S., and the new Business Instructional Facility at the U of I.
    I am seriously concerned the draft DG Installer Certification Rules will ruin my business and destroy the nationally-recognized, Federally-supported, highly accredited DG training program I created at KCC.
    The bulk of the DOL electrical apprenticeship and conventional electrical licensing have no bearing on knowledge or skill about any specific DG technology. The DG rules should require a crew leader to hold a respected third-party certification that relates to the specific DG technology being installed, such as NABCEP and ETA-I certifications.
    Some Illinois Community College DG training programs are more robust than those available from DOL apprenticeships. KCC provides one example:
    KCC has the only IREC/ISPQ-Accredited Solar Training Program in Illinois. There are no JATC/DOL programs so accredited.
    I am the only IREC/ISPQ-Certified “Master Trainer” for solar-PV in Illinois. There are no JATC/DOL trainers in Illinois so certified.
    Electricians from the IBEW have taken my solar course at KCC and said they are not able to get the training they need at their JATC.
    IGEN and other Illinois Community Colleges are part of the Midwest Solar Training Network – a multi-million dollar effort of the USDOE to expand solar training capacity in Illinois. The draft DG Rule will harm USDOE’s strategy to use Community College training programs to move the National DG agenda forward.
    Specific Recommendations:
    Section 468.20 Definitions
    "Install" means to complete the final connection of the distributed generation facility’s AC output to the electric utility's distribution system. The meaning of "install" in this Part specifically does not include:
    Electrical wiring and connections internal to the assembly and construction of the distributed generation system performed by the manufacturer or by a qualified person trained and certified by NABCEP or ETA-I for the specific electrical generating technology being installed; or
    "Qualified person," in relationship to installing electrical wiring and connections internal to the assembly and construction of the distributed generation system, means the manufacturer or a person trained and certified by NABCEP or ETA-I for the specific generating technology being installed.
    Section 468.50 Required Application Information
    Applications for certification under this Part shall contain the following information:
    h) 2) A copy of a NABCEP or ETA-I Installer Certification for one or more specific DG generation technologies; or
    h) 3) Proof of the satisfactorily completion, prior to the effective date of this Part, of at least ten installations of DG facilities.
    Section 468.60 Certification Requirements
    d) The Applicant certifies that every installation of a distributed generation facility will be performed only by:
    4) a person enrolled in, or who has completed, a training program approved by NABCEP or ETA-I, or accredited by IREC/ISPQ
    Section 468.120 Fees
    a) 1) Application for certification $50.00
    Final Thoughts and Comments:
    “Install” should be limited to making the final connection of the DG facility to the utility distribution system.
    A clear distinction needs to be made between the on-site assembly/construction of a DG system vs. connecting that DG system to the distribution grid. Even apprenticed, licensed electricians should not assemble DG systems without technology-specific training and/or a technology-specific certification from NABCEP or ETA-I.
    “Qualified Person” should differentiate between persons who perform the assembly/construction of a DG system and those who connect that DG system to the utility’s grid.
    The DOL apprenticeship requirement should be dropped for the assembly/construction of a DG system.
    Section 16-128 of the Illinois Public Utilities Act was written to add oversight to the recently unregulated electric utilities, and many elements of Section 16-128 do not apply to private, RE installations. A homeowner with a net-metered solar-PV system is not a private utility company with employees handling ongoing operations and maintenance.

    Timothy J. Wilhelm
  • December 21, 2012

    468.70 as it appears in Fig. 13.
    7.0 Section 468.80 – Annual Recertification and Reporting
    This section of the docket appears in Fig. 14.
    Figure 14 Docket 12-0213 Annual Recertification and Reporting
    No challenges are made to Section 468.80 as it appears in Fig. 14. The balance of the annual recertification and reporting is given in Fig. 15.
    Figure 15 Docket 12-0213 Annual Recertification and Reporting (cont.)
    No challenges are made to Section 468.80 as it appears in Fig. 15. However, suppose a certificate holder secures or contributes labor resources to a project that exceeds the 2000-kW limit. Does that count and should be reported?
    8.0 Section 468.90 and 468-100 – Complaints and Oversight
    These two sections are in Fig. 16
    Figure 16 Docket 12-0213 Complaints and Oversight
    No challenges are made to Section 468.90 and 488-100 as they appear in Fig. 16.
    9.0 Section 468-110 – Complaints and Oversight
    Figure 17 Docket 12-0213 Maintenance of Records
    No challenges are made to Section 488-110 as it appears in Fig. 17.
    9.0 Section 468-110 – Complaints and Oversight
    Figure 18 Docket 12-0213 Fees
    No challenges are made to Section 488-120 as it appears in Fig. 18, with the provision it applies to businesses and does not apply to an Individual Installer Certification. However, given we are dealing with small businesses in a burgeoning industry, The fees must be reduced by nearly an order of magnitude - $3000 to $300, $500 to $50, $1500 to $150 and so on. Fees can always be evaluated and re-adjusted as required, but such large initial fees could help to kill small business attempts.
    9.0 Section 468-130 – Customers Seeking Net Metering
    Figure 19 describes the information the installation company must provide to customers seeking net metering.
    Figure 19 Docket 12-0213 Customers Seeking Net Metering
    No challenges are made to Section 488-130 as it appears in Fig. 19.
    10.0 Section 468-140 – Initial Compliance Date
    Figure 20 Docket 12-0213 Initial Compliance Date
    No challenges are made to Section 488-140 as it appears in Fig. 20.
    Additional comments would be to reiterate the document submitted by Professor Tim Wilhelm of Kankakee Community College related to the fact that the ICC chose the Apprenticeship training program as a requirement for individuals working in renewable energy installations based on the fact that it was a federally recognized program, although this training does not mandate specific Photovoltaic or other renewable energy installation training. The Community Colleges in Illinois are operating renewable energy programs based on funding and grants supplied by the US Dept of Energy, a Federal agency.
    In addition ETA International certifications are recognized by the US Dept of Labor on their Career One Stop website and both ETA International and NABCEP are recognized on the IREC website as certifications for individual renewable energy installers.
    Noted also should be comment from the December 10, 2012 Public Hearing regarding this docket that this legislation was not the result of poorly installed systems, accidents, injuries, fires or other disasters related to work in this field. Additionally, without changes to the current rulemaking document, small and entrepreneur start up and existing businesses will be put out of business thus restricting the development of work in this growing area.

    Steve Fleeman
  • December 21, 2012

    The “Qualified person” definition must be replaced.
    “Qualified person” means a person who performs installations on behalf of the certificate holder and has satisfactorily completed at least three (3) installations of distributed generation technologies prior to the effective date of this part.
    A qualified person can also be an individual who performs installations on behalf of the certificate holder, has satisfactorily completed an apprenticeship as a journeyman electrician from a United States Department of Labor Registered Electrical Apprenticeship and Training Program, received a certificate of satisfactory completion, and has received a certification in the appropriate distributed generation technology as established by a recognized Individual Certification Body.
    Further, a qualified person can also be an individual who performs installations on behalf of the certificate holder, has satisfactorily completed (as evidenced by an earning Associate in Applied Science degree) from an ICCB-approved community college program in the appropriate distributed generation technology, and has received a certification in the appropriate distributed generation technology as established by a recognized Individual Certification Body.
    The last definitions are provided in Fig. 7.
    Figure 7 Additional Docket 12-0213 Definitions (continued)
    The “Self-installer” provision is unclear in that it restricts the installation to be accomplished without the assistance of any other person(s). Does this exclude consults? Since all distributed generation is included, trenching to run electrical lines, using a backhoe to create a hole for the pier of a wind turbine, a roof inspection prior to a photovoltaic system installation, or pouring concrete for a microhydro installation (water turbine mounting or forming a penstock) could be required. Is the self-installer required to do it all without assistance?
    3.0 Section 468.30 – Applicability
    Figure 8 includes this section of Docket 12-0213.
    Figure 8 Docket 12-0213 Applicability
    The certification is applied to a business that provides installations or to an individual installer who decides to form his own business. This needs to be clarified.
    4.0 Section 468.40 – Application Procedures
    Figure 9 shows the Application Procedures.
    Figure 9 Docket 12-0213 Application Procedures
    No challenges. Section 468.50 appears in Fig. 10.
    5.0 Section 468.50 – Required Application Information
    Figure 10 Docket 12-0213 Required Application Information
    This information in Section 468.50 refers to the (business) entity and will only apply to an individual who is trying to establish him or herself as a business. Comment: Section 468.50 must not refer to Individual Installer Certifications.
    Figure 11 continues the required application information.

    Figure 10 Docket 12-0213 Required Application Information
    The requirements shown in Fig. 10 are for companies. Part h) needs to be modified, which includes the addition of option 3.
    1) A copy of the DOL certification of satisfaction of a DOL registered electrician apprenticeship program, and a copy of the individual certification(s) in the appropriate distributed generation technologies from Individual Certification Body (or Bodies) for each Qualified Person and/or
    2) A copy of the Associate in Applied Science degree from the awarding ICCB-approved community college in the appropriate distributed generation technology (or technologies) and a copy of the individual certification(s) in the appropriate distributed generation technologies from Individual Certification Body (or Bodies) for each Qualified Person and/or
    3) Proof of the satisfactorily completed three (3) distributed generation technology (or technologies) of at least 1 kilowatt for each Qualified Person.
    The Certification Requirements are given in Fig. 11.
    Figure 11 Docket 12-0213 Certification Requirements
    Again, the certification requirements in Fig. 11 are for the installation company and must not be confused with Individual Installer Certifications.
    Figure 12 Docket 12-0213 Certification Requirements (continued)
    Add item 4).
    4) a person enrolled in an appropriate distributed-generation ICCB-recognized Associate in Applied Science degree program who is directly supervised by a qualified person.
    6.0 Section 468.70 – Certifications Conditioned Upon Compliance
    Figure 13 Docket 12-0213 Certification Requirements (continued)
    No challenges are made to Section

    Steve Fleeman
  • December 21, 2012

    Public Hearing Comments to
    Docket 12-0213
    Submitted by Teresa Maher, Electronics Technicians Association, International President and Stephen R. Fleeman, Electronics Technicians Association, International Chair on December 17, 2012
    1.0 Analysis of Docket 12-0213 Draft Rules for Distributed Generation
    The segment illustrated in Fig. 1 was captured from Docket 12-0213 as posted by the ICC. Other segments are also included as figures and added together comprise the entire docket.
    Figure 1 Header of Docket 12-0213
    Section 468.20 provides definitions
    2.0 Section 468.20 – Definitions
    The segment illustrated in Fig. 2 is Section 468.20 as posted by the ICC.
    Figure 2 Docket 12-0213 Definitions
    For reference, the appropriate references from Public Utilities Act [220 ILCS 5] have also been provided as referenced in Fig. 2. Note this section also includes the requirements electric vehicle charging station installers, for which the ICC has provided separate draft rules. Significant to the “distributed generation facility” definition is the reference to Section 1-10 of the Illinois Power Agency Act [20 ILCS 3855/1-10], which has been presented in Fig. 3.
    Figure 3 DG in the Illinois Power Agency Act [20 ILCS 3855/1-10]
    Significant to this reference is it defines distributed generation to include small wind, photovoltaics, biodiesel (electrical) generation, microhydro electrical generation, and solar thermal energy. (Assumption: Solar Thermal Energy results in electrical generation through technologies such as the Stirling engine and thermal piles.) It is also significant these systems are limited to be less than 2000 kW.
    Figure 4 includes additional Docket 12-0213 Definitions.
    Figure 4 Additional Docket 12-0213 Definitions
    Suggested additional definitions include:
    “Individual Installer Certification” includes the passing of a proctored examination that includes theory and a required demonstration of hands-on skills.
    “Individual Certification Body” is a nationally-recognized organization that offers written examinations. The Individual Certification Body also establishes the definition of hands-on skills to be demonstrated and an evaluation rubric for grading the demonstrated skills. The Individual Certification Body shall follow ANSI/ISO/IEC 17024 specified requirements which ensure that organizations operating certification systems for persons operate in a consistent, comparable, and reliable manner. ANSI/ISO/IEC 17024 includes rigorous requirements for examination development and maintenance and for quality management systems. The Individual Certification Body shall make available on its website the job task analysis competencies as well as recommended resources for the attainment of those competencies.
    These certification bodies could include the Electronics Technicians Association, International (ETA-I), the North American Board of Certified Energy Practitioners (NABCEP), and others such as the Underwriters Laboratory (UL) certification program.
    “Illinois Community College Board” is the state coordinating board for community colleges, and administers the Public Community College Act in a manner that maximizes the ability of the community colleges to serve their communities. As an integral part of the state's system of higher education, community colleges are committed to providing high-quality, accessible, cost-effective educational opportunities for the individuals and communities they serve. ICCB offices are located in Springfield, Chicago, and Herrin.
    Many (about 48) of the ICCB-approved community colleges are members of the Illinois Green Economy Network (IGEN). This is not a suggested requirement, but can serve as a guide.
    The Docket 12-0213 definitions are continued in Fig. 5.
    Figure 5 Additional Docket 12-0213 Definitions (continued)
    The wiring and connection of unity workers is not challenged. The inspection of wiring of internal connections of equipment performed by the manufacturer not being required is consistent with the National Electric Code and is not challenged.
    The “Tasks not associated” provide a role renewable energy integrators (system designers) to serve as consultants and project designers. Graduates of “installer” community college programs could also fit under this.
    Figure 6 Additional Docket 12-0213 Definitions (continued)
    The NEC definition is not challenged.

    Steve Fleeman
  • December 21, 2012

    SoCore Energy’s Comments on Rulemaking Docket 12-0213 Concerning the Illinois Distributed Generation Installer Certification Rules.

    SoCore is a commercial-sector solar energy developer based in downtown Chicago. We are very concerned that the proposed DG Installer Certification Rules (“the Rules”) will negatively impact the solar industry in Illinois by imposing unnecessarily narrow and costly certification requirements on DG installers. The ICC’s definition of “qualified person” is unnecessarily narrow, will preclude otherwise qualified installers from being able to work in Illinois, and will increase the costs of solar installations. The qualifications options are unnecessarily narrow. As written, the Rules will have the unintended consequence off eliminating existing solar installers from the Illinois workforce, erecting undue barriers to new, would-be workforce entrants, reducing competition in the Illinois solar market and ultimately, raising costs for consumers without further enhancing safety or reliability concerns.
    According to the information on the Illinois Department of Employment Security’s website, DOL registered electrical apprenticeship programs are offered by six International Brotherhood of Electrical Workers (IBEW) union locals in Illinois as well as the Illinois Chapter of the Associated Builders and Contractors (ABC). These are 4-5 year programs with limited and selective enrollment and limited geographic availability. They offer a broad spectrum of training and experience in electrical work. They also offer optional renewable energy/distributed generation training, but it is not part of the mandatory curriculum. If DOL registered electrical apprenticeship programs become the only avenue for obtaining certification, this Rule will create first a shake out, and then a bottleneck in the Illinois solar workforce. The majority of solar installers currently doing business in the State of Illinois have not gone through an eligible DOL registered training program, nor have they completed twenty installations of distributed generation technologies. They will become immediately ineligible to do their jobs for which they have been properly trained. Those who choose to enroll will first have to meet enrollment requirements (the IBEW programs require a participant to be a resident of the IBEW Zone in which the program is offered, for instance), and receive four to five years of electrical training (even if he or she is already a licensed electrician) before becoming eligible to resume installing solar. This is an untenable, anti-competitive outcome and certainly not what the legislature intended.
    A solar project is made up of a variety of labor classifications including electrical and sometimes carpentry, steel, masonry, labor, iron, etc. Existing licensing programs are already in place for these classes of labor in Illinois through the state or local governments. Local authorities having jurisdiction (AHJs) already apply training, experience and testing requirements to their licensing protocol, and these existing licensing programs have thus far ensured the safety and reliability of the electric grid in Illinois when applied to DG systems. To our knowledge, there has been no evidence put forth in this docket to the contrary. Nor has there been any evidence put forth that supports the position of applying an additional layer of mandatory training and certification for DG installers specifically, as opposed to electricians that conduct other types of electrical tasks (installing the electrical wiring and connections necessary to interconnect a new building, for example). Therefore, our recommended approach is to allow the local government AHJs that are currently and ably responsible for licensing electricians and performing safety inspections to continue to perform these functions for our industry, just as they will continue to perform these functions for electricians engaged in other electrical tasks.

    However, if the Commission determines that the existing licensing regime does not satisfy the new statutory requirements, we recommend allowing for other routes to certification as alternatives to successful completion of a DOL registered electrical apprenticeship and training program. The North American Board of Certified Energy Practitioners (NABCEP) certification program, the Underwriters Laboratories (UL) PV System Installer Certification program, and the Electronics Technicians Association (ETA) Renewable Energy Photovoltaic and Small Wind Installer Certifications are nationally recognized as the pre-eminent certification credentials for DG installers.

    Joshua Nathan c/o SoCore Energy, LLC
  • December 21, 2012

    First Notice Comments:

    I and my business have been involved in the Renewable Energy and Energy Conservation field for over 20 years. I have worked on these system projects in hundreds of locations both in Illinois, nationally and even internationally. My work has been for a wide variety of clients: projects have included various local governments, Illinois government, Federal government, private companies (both large and small), museums and private residences.

    I have researched green energy renewable systems and integrated them to build what is one of the Greenest Buildings ever built in the 110 countries that LEED has a presence in. We have had over 150 media articles (print, radio, pod casts and television) from 9 different countries on this project. Since the project is in Illinois, it has been a great plus for the perception of our State. Using both photovoltaic and a wind turbine renewable energy on this project helped make it one the greenest modern building ever built. The renewable energy aspect of it has been the highlight of many of the media articles.

    I oppose the proposed RULE as is currently written. I believe it would hinder a still small but growing field making it much more difficult for Illinois to reach its Renewable Portfolio Standard (RPS) of 25% by 2025. Please see (20 ILCS 3855/1-75(c)(1)) as an example.

    When I attended the public comment session last Monday it was stated by ICC personnel (when asked by a speaker) that there is no record of an improperly connected renewable energy system causing loss of life or property damage. This would tell me that all the existing grid connect systems in Illinois are safe any no way present any safety hazards.

    These existing systems were installed by licensed electrical contractors (electricians), licensed by the various local municipalities or county governments which have jurisdiction for electrical work in their area. All these projects were properly performed with a local permit as all electrical work should be. In addition the local power provider (for example in Northeast Illinois it is ComEd) has to approve any grid connect system and already has guidelines, procedures and safety requirements in place to put in one of their grid connect meters. The most stringent requirement is the required use of a UL (or other OSHA approved testing Laboratory) grid connect devise to meet UL 1741 or equivalent standard. This devise makes grid connect systems safe no matter what the energy source is be it photovoltaic, wind, micro hydro, biogas or solar thermal electric.

    I believe limiting the number of currently licensed electricians to install grid connect systems would hurt the growth of renewable energy in Illinois by decreasing its availability and increasing its price. This would thereby hurt small and medium sized companies providing employment in Illinois, reduce our air quality and not be conductive to our balance of trade. In addition, as stated in the public hearing and not rebuffed by the ICC personal under the current guidelines, there are less than 100 electricians in Illinois who meet these guidelines - which is a very small percentage.

    Suggested modifications of the current Docket:

    (1) Leave the existing local jurisdiction current licensing procedures in place for smaller systems but adopt the current proposed docket guidelines for large systems with a nameplate capacity of 1 megawatt of greater. For a system of this size (1 megawatt or greater) the proposed license fees would not hinder a large project since it would be a small percentage of the total cost.

    (2) Require all renewable energy systems to have a wiring installation line drawing from the manufacturer for the system being installed.

    (3) Require all installers to take and pass an installation course approved by the renewable energy manufacturer whether it theirs or a third party approved by the manufacturer.

    In conclusion I have no opinion with the licensing requirement for electric vehicle charging stations.

    Thank You:

    Jacek Helenowski
    President
    Square 1 Precision Lighting, Inc.
    EES, Inc.

    Jacek Helenowski
  • December 21, 2012

    First Notice Comments.

    My name is Benjamin Harroun. I have been in the renewable energy business for the past five years in many aspects. I am a NABCEP(North American Board of Certified Energy Practitioners)certified Solar PV Installer. I am an ETA(Electronics Technicians Association) certified Photovoltaic Installer. I also hold numerous certifications in individual Solar Electric, Small Wind, and Solar Thermal. Over the past 5 years, all of this experience, knowledge, and training was garnered through 5 years of regular training with the most reputable educational facilities in the Midwest: The Midwest Renewable Energy Association and Solar Energy International. Both of these programs are used by the IBEW to help train their journeymen on an 'optional' basis. By trade, I am not an electrician. I have never made the final interconnection of a system as the current laws relegate that job to a licensed electrician in the state of IL. However, I have been responsible for over 18 installations here in Illinois and a couple in Indiana. Many that have been moving this market forward with our countless battles with local zoning, the piles of paperwork required for interconnection, and the seemingly endless amount of time required for this job have too much invested to accept the rules for Installer certification as they are written.

    I have 2 primary complaints with the rules as they stand.

    The first is with the installer registration cost. This amount is beyond exorbitant, and will limit the market to only the largest companies, none that are currently operating in the state of IL. I believe a fair number would be around $100 to $150 per year as a reoccurring fee such as contractor registration. This is an amount most small businesses can afford.

    The second complaint is on the issue of the description of a 'Qualified Person'. With the limiting rules as they are written, my company, like the other 90% of the state's operating installers, will be out of business. In 5 years of advertising, working with hundreds of homeowners and businesses, and offering free educational experiences, we have had a total of 18 installations from all of that effort. I believe that there should be a tiered effort that allows for beginners in the industry to work with qualified installers to gain the experience needed to become a 'qualified person' and that the 'qualified person' should be someone with 5 or more installations, not the 20 as listed. Our market in Illinois has not been conducive to having a large amount of installations unless you have been installing systems for more than 10 years. I personally know many of the best and most experienced installers in the state, and can count them on 1 hand. I can also list only 1 IBEW installer that truly knows the same amount of technical knowledge necessary to complete a code compliant, fully functional solar PV and Wind system. His name is Harry Ohde and he trains the small classes of IBEW Journeymen that are interested in Solar PV and they pretty much exclude all Small Wind in their classes.

    In summary, I suggest that the court amend the rules as written to accept a qualified person as someone with either a trusted third party certification such as NABCEP or ETA, has 5 Distributed Generation installations under their belt, or is an IBEW Journeyman or master electrician that has COMPLETED a training course in Solar PV and/or Small Wind Installation. I also push for the fees to be $100 per year for installer certification registration.

    Thank you for your time.

    Sincerely,

    Benjamin Harroun
    Cofounder of Angel Wind Energy Inc. EST. 2008.
    Board of Directors: Illinois Solar Energy Association
    NABCEP Certified Solar PV Installer
    ETA Certified Solar PV Installer

    Benjamin Harroun
  • December 21, 2012

    RE: Docket 12-0213, Title 83, Chapter I, Subchapter c, Part 468 – “Distributed Generation Installer Certification”

    PLEASE ATTACH TO PREVIOUS COMMENTS FOR MATTHEW VESTER
    SUBMITTAL CONFIRMATION #5951
    COMMENTS:

    What strikes us as the most important change that needs to be made is the exclusivity of the “qualified person” definition, along with how a “qualified person” is able to facilitate a DG installation. In the language that currently exists, there is a very narrow pathway to become a “qualified person”.

    According to the current language, one has to be established in the industry currently (20 documented DG installations to date) or has to be a journeyman electrician who has gone through an exclusive Department of Labor approved training program. While it is clear that those are both good and appropriate requirements, they provide an extremely narrow definition of what makes a person qualified and the pathway to becoming certified by the ICC as a “Certified DG Installer” very limited.

    Throughout the process of drafting this document, there have been numerous qualifications, certifications and licenses that have been presented, many of which carry merit when been judged as “qualified” or “unqualified”. To name a few, North American Board of Certified Energy Practitioners (NABCEP), electrical contractors who have been licensed by AHJ’s and/or municipalities throughout IL, Electronics Technicians Association Int’l (ETA Int’l) are recognized and credentialed bodies who have been identifying such “qualified persons” that the ICC is seeking for quite some time.

    It is definitely of concern and benefit to the state of Illinois that DG systems being installed are installed by parties who are qualified, and who demonstrate excellence in their fields of practice. What does not make sense is putting into practice a “one-size-fits-all” approach to DG installations. “Distributed Generation” includes, but is not limited to the following sub-industries: Fuel Cells, Wind Turbines, Solar Photovoltaic Panels, Hydro Turbines, Combined Heat and Power, Hydrogen Energy Systems. These fields have the potential to be vastly different from one another. And no single qualification can be expected to accurately judge the merits of a “qualified person” who is responsible for system installation.

    Additionally, it is hard to imagine that any interested party in this conversation would state categorically that they know what the DG industry in IL (or the country) will look like in the years to come. Because this is an emerging and growing industry for the state, it is in the state’s interest to allow as much market flexibility as possible, while guaranteeing safe and appropriate installations. That includes taking a hard look at what qualifications a person should have to install these systems. By opening the definition of “qualified persons” to include a larger number of industry-recognized entities, the ICC and the State of Illinois will better position itself to oversee and encourage the deployment of its’ DG systems.

    In addition to selecting from a larger pool of currently identified certifications, licenses and experiences, we also recommend that the ICC allows for further expansion of the definition of “qualified persons”, left to ICC discretion after the final document is approved. This will allow the ICC to adapt to changes that the DG industry will certainly see in months and years to come. Once a rule like “DG Installer Certification” is passed into practice, it will immediately be outdated by the changing technologies and practices. By leaving discretion to the ICC on what constitutes a “qualified person”, it will allow it to run more efficiently and safely in the future.

    Aside from the definition of “qualified persons”, we believe that revisions need to be made to the actual practice on installation by the qualified person and their ability to facilitate a successful DG installation. (Section 468.60 “Certification Requirements”, d) As the language currently exists, the only people who can participate in DG installations are “qualified persons”, an electrical contractor under direct supervision or a DOL registered electrician apprentice under direct supervision. We agree that those are people who should be able to perform DG installations under the circumstances dictated in the document. However, we believe that an addition should be made to include:

    •“Employees or subcontractors of the Certified DG Installation Entity who is not a qualified person, provided he/she is directly supervised by a qualified person.”

    This addition to the list of who can perform DG installations will ensure that the entity that the ICC has certified will be able to complete the installation to the standards of the ICC as well as maintain their own quality and continue to develop their professional workforce, leading to installations of increased safety and performance.

    Thank you for your consideration

    Garrison Riegel
  • December 21, 2012

    The DG Certification ruling (Docket 12-0213) is a completely unnecessary layer of certification that will 1) impose unnecessary barriers on the growth of Illinois' solar and small wind industry; 2) place burdensome financial requirements on small businesses; and 3) displace highly trained individuals from employment.

    There is simply no reason to implement a bad policy such as this that will be harmful to small and renewable-related businesses in Illinois. There are no current safety issues with these systems, therefore making the measure an unnecessary cost that will filter down to the consumer. It will be harder and harder for smaller, local companies to offer solar PV installation services, leaving this potential business to potentially go to companies outside of the state.

    If you care about small business growth in Illinois, you will not support this measure. Other states do not require this certification and leave it up to national entities such as the North American Board of Certified Energy Practitioners (NABCEP), this level of certification is sufficient. Please do not support this measure.

    Paul Szczesny
  • December 21, 2012

    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.



    I agree with this, and plead that you hold off with your legisltaion, or administrative decree. I am a customer and work in a small buisiness.

    I think the citizens of Illinois know very little about what you are doing here, and they need time to be informed and decide what is in their best interests. You represent the citizens of this state, and not just your agency.

    We all know the price is high as it is, and should not be burdened with more fees.

    Regards,
    Lu Bozinovich

    Lu Bozinovich
  • December 21, 2012

    PART 1: MULTIPLE DOCUMENTS COMMENTS SUBMITTED!
    We have composed this note, along with the attached comments, addressing the current draft of the ICC’s Distributed Generation Installer Certification.
    My colleague, Garrison Riegel, and I have collaborated on these comments as technical industry professionals who are currently employed as distributed generation (DG) professionals in the state of Illinois. We are co-workers at Solar Service Inc. located in Niles, IL and have each been responsible for well over the # of installs (20) that the ICC’s draft language is currently requires one to have to be considered a “qualified person” as a DG Installer. We have successfully designed an implemented over 500 renewable energy systems in Illinois and nationally. We are both recognized by the North American Board of Certified Energy Practioners (NABCEP), the Nation’s leading renewable energy certifying body, as Certified PV Installers. We are members of the “Green Economy” in Illinois and have played an important part in the growth and deployment of DG and renewable energy throughout the state. It is from this experience and perspective that we approach the Distributed Generation Installer Certification document that the ICC has drafted.
    The documents that we have attached to this note highlight some major changes that we feel are necessary to the current draft of the document in order to achieve a safe and successful DG industry in Illinois. We believe that, with the suggested changes outlined, the ICC can ensure that DG installations will be done professionally and safely while encouraging and sustaining the growth of the industry, in both infrastructure and economically.
    As established professionals employed and working in the DG industry in Illinois, it is not an overstatement to say that the drafted document will be harmful to the current industry. Not only will the document limit the industries ability to grow, adapt, and thrive, but it will also have the negative impact of stalling out and, possibly, eliminating much of the current progress being made in the DG industry in Illinois.
    Solar Service Inc. has been in the business of implementing renewable energy systems since 1977 and DG systems since 2001. It is safe to say that, if the currently drafted document was in place in the year 2000, our business would not have experienced the growth, longevity and respect in the marketplace that we currently have today. Our years as a continuous presence in the Illinois DG industry are a very rare quality that our company is fortunate to have. However, many businesses currently operating in the DG industry in Illinois do not benefit from the same history and likely do not meet the extremely narrow criteria as it is laid out in the current docket. With no ability to determine the experience or quality of these businesses, other than a very large number of completed installations or a very specific type of training, these companies will no longer be allowed to carry out work that they are well qualified to do. The results of something like this cannot be overstated: companies currently operating in the industry will be forced to close their doors. These companies may also choose to relocate to a state with more inclusive legislation (all of our bordering states), or restructure their companies to meet this new criteria, but this would certainly result in layoffs of current, highly experienced employees who do not meet the new requirements. We can also ensure the ICC that higher prices for DG installations will be a result due to the much higher labor costs that come along with employing electrical contractors who have completed a Dept. of Labor approved apprenticeship program.
    The costs of implementing the current language into law are huge. Businesses currently operating successfully, safely and profitably in the Illinois DG industry will close, leave, shrink or undergo costly restructuring at best. The companies who are on the ground and paving the way for further development and implementation of DG technologies will be lost. We believe that a quick assessment of DG installations in Illinois to date would show that a large number of completed projects would have never taken place had the document been written into law years ago. Illinois will lose not only these DG systems moving forward, but also the companies who actively promote and develop the market for them. We believe that it is easy enough to deduce that large DG businesses that operate on a national scale will continue to stay out of Illinois, choosing to do business elsewhere, where the regulations are easier to navigate and the costs of doing business are lower.
    You will find the changes that we find necessary for a viable, safe and successful DG industry in Illinois on the following pages.

    Sincerely,

    Matt Vester
    4635 N. Damen Ave. #1R
    Chicago, IL 60625
    773-818-2948
    mattv@solarserviceinc.com

    Matthew Vester
  • December 21, 2012

    I would like to comment on Section 16-128(A) regarding installer compliance.

    A certification or compliance requirement for installing alternative energy components to the electric grid is unnecessary. The Illinois Distributed Generation Interconnection Standard already provides guidelines for grid connection and utilities and local permitting units must certify that correct procedures were followed. Adding an additional layer of government regulation will have little, if any, positive effect on public safety, but instead will create substantial barriers to adopting renewable sources of energy in Illinois.

    In addition, recent advancements in inverter technology are making grid interconnection progressively safer and easier. Adding an additional regulatory requirement in this environment would be ill advised and counterproductive.

    Please do not adopt this amendment. Thank you.

    Adrian Gross
  • December 21, 2012

    Ladies and Gentlemen,
    I have taken part in several DG installations and I have no doubt that this will become more and more the new normal for power generation and distribution. As an individual with considerable experience with electric motors 200HP or more in size, I clearly understand the need for some sort of training. Electricity can kill. This certification program being pushed by Commonwealth Edison and the IBEW however has little to do with safety and everything to do with keeping guys like me out of work. This is not the time to be making it more difficult to earn a living.

    As it is there are already steps in place:
    1) Electrical licensing through local municipalities
    2) Municipal Inspection
    3) Utility company interconnection approval of equipment
    4) UL certification

    The proposed rule does not make it any safer. It only makes the whole process more costly. I don’t think we need any additional requirements. Further, Commonwealth Edison would do well to think more about how they will manage multiple distributed sources of power and not how they are installed. That is the real challenge of the future for ComEd because moving forward, one way or another, cost effective or cost prohibitive, these installations will occur and with increasing frequency.
    Thanks for reading,
    Max

    Max
  • December 21, 2012

    I, PJ Burns, have worked with General Contractors and Electricians in the area of alternative energy. I have been more of an interested observer in the past few years, because lack of funding has reduced my employment opportunities in the industry, though I have recently become involved again as with State support and funding we were on the cusp of actually making headway, and then ComEd and the IBEW somehow managed to craft and push through a rather restrictive, unnecessary DG Installer Certification Bill which was then forced on the ICC to oversee.

    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
    The Application fee for certification is $3,000 with an annual recertification report of $500. Penalty for noncompliance is $6,000.

    This Illinois Certification program was crafted and designed by ComEd and IBEW - two groups pretty much dedicated to eliminating the competition of alternative energy. Both ComEd and IBEW have stated that these RULES will apply ONLY to grid-tied Alternative Energy installations and NOT to off-grid applications at all; further proof of an agenda that has nothing to do with any kind of safety, other than the safety of their customer bases, and making sure that only Union electricians qualify.

    The fact is that installers do not need to be electricians at all to perform the necessary work in DG installation; it is more important that they be properly trained in all aspects of safe installation. The requirements for Certification should be changed so they include other avenues allowing for experienced non-union electricians and contractors to become certified without the prohibitive restrictions as now written by and in favor of Union electricians. Additionally, it must be noted that most DOL apprentices and journeymen (as well as many other experienced electricians) don’t have the training necessary to perform a DG installation from start to finish. Therefore, all applicants should be required to have third party certifications like NABCEP, North American Board of Certified Energy Practitioners. I think this type of requirement could and should replace the requirements the IBEW is pushing if it is still felt that special Certification is actually required.

    The fee structure of this Certification Program as currently crafted ($3,000 Certification Test Fees, $500.00 annual renewal) is cost prohibitive for many small businesses, and completely out of line with other testing and licensing fees. The ICC has agreed to reduce the fee structure to match that for the proposed electric vehicle charging stations, which would be acceptable.

    Finally there really is no need for additional ICC intervention or Certification for Installers because they already have to comply with the following before an installation is approved: 1) electrical licensing through local municipalities, 2) Municipal Inspection, and 3) a utility company interconnection approval of equipment and UL certification before installation is permitted to be in place. This rule is not adding any additional protection to the grid that is not already in place. It only succeeds in adding additional cost to the installation. It would be my recommendation that no state requirements be added to the current installation process.

    PJ Burns
  • December 21, 2012

    Illinois needs to encourage small both businesses and renewable energy.

    This regulation will put a damper on both renewable energy in Illinois and small business. Small businesses already are required to have the proper licenses, such as electrical, for installation of solar. In addition, the work must pass local building department requirements and inspections. This new regulation is not needed.

    Recently we had a small business, eco sun inc., install 3K of solar PV. on our home. Our installer did an excellent job, and I hope we are leading the way for more solar installations. This regulation will place cost barriers without improving the quality of the industry.

    People are starting to be interested in solar energy, but the first question is about cost. Illinois should not add the additional and unnecessary costs of this proposed regulation. Illinois should help support both small businesses and more renewable energy for our state's future.

    Respectfully,
    Janet K. Smith

    Janet K. Smith
  • December 21, 2012

    I, Ron Cowgill, am a General Contractor and a Licensed Electrician (locally licensed since 1989 through Downers Grove, IL plus by various local municipalities I’ve work in regularly through the 20+ years I’ve been in business), who has been trained in the SEI Program for DC installation, and the MREA program for wind site assessment. I personally have installed six (6) solar arrays, and eight (8) turbine installations to date plus serviced turbines and arrays installed by others through my businesses WinSol Power Company and D/R Services Unlimited, both in Glenview, IL.

    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
    The Application fee for certification is $3,000 with an annual recertification report of $500. Penalty for noncompliance is $6,000.

    This Illinois Certification program was crafted and designed by ComEd and IBEW - two groups pretty much dedicated to eliminating the competition of alternative energy. Both ComEd and IBEW have stated that these RULES will apply ONLY to grid-tied Alternative Energy installations and NOT to off-grid applications at all; further proof of an agenda that has nothing to do with any kind of safety, other than the safety of their customer bases, and making sure that only Union electricians qualify.

    The fact is that installers do not need to be electricians at all to perform the necessary work in DG installation; it is more important that they be properly trained in all aspects of safe installation. The requirements for Certification should be changed so they include other avenues allowing for experienced non-union electricians and contractors to become certified without the prohibitive restrictions as now written by and in favor of Union electricians. Additionally, it must be noted that most DOL apprentices and journeymen (as well as many other experienced electricians) don’t have the training necessary to perform a DG installation from start to finish. Therefore, all applicants should be required to have third party certifications like NABCEP, North American Board of Certified Energy Practitioners.

    The fee structure of this Certification Program as currently crafted ($3,000 Certification Test Fees, $500.00 annual renewal) is cost prohibitive for many small businesses, and completely out of line with other testing and licensing fees. The ICC has agreed to reduce the fee structure to match that for the proposed electric vehicle charging stations, which would be acceptable.

    Finally, I don’t actually see the need for additional ICC intervention or Certification for Installers because we already have to comply with the following before an installation is approved: 1) electrical licensing through local municipalities, 2) Municipal Inspection, and 3) a utility company interconnection approval of equipment and UL certification before installation is permitted to be in place. This rule is not adding any additional protection to the grid that is not already in place. It only succeeds in adding additional cost to the installation. It would be my recommendation that no state requirements be added to the current installation process.

    Ronald E. Cowgill
  • December 21, 2012

    Distributed Generation Rulemaking – Docket No. 12-0213
    First Notice Comments
    Date: December 13, 2012
    To: Chief Clerk’s Office
    From: Christopher Miller, Professor and Program Coordinator of Renewable Energy, Electronic Systems Technology, Industrial Technology, Heartland Community College.

    Heartland Community College wishes to add input to docket number 12-0213. Our degree is recognized by the Illinois Community College Board and is a member of the Illinois Green Economy network. The College is a certified training center for ETA’s Alternative Energy Photovoltaics Installer, Renewable Energy Small Wind Installer as well as a provider for NABCEP Entry Level Certification. The college strongly supports our graduates in obtaining jobs in the emerging distributed generation field. We want the State of Illinois and our communities to know that an installation in Distributed Generation is of quality and value. Our graduates have gained the skills and knowledge to apply what they have learned as prospective employees, integrators, independent installers and entrepreneurs. An area of concern the college has is that the rules being considered in this proceeding may place unnecessary or unreasonable entry barriers that impair the ability to place candidates into the job market. Constraints that unduly limit the abilities of our degree program and our graduates entering this field should not be included in these rules.
    Graduates of our program should have the right to completely install any distributed generation equipment that falls within the scope this rule making docket. We believe that multiple paths of certification and training will benefit our community and the State of Illinois.
    We are firmly in agreement with the need for quality of installation and the use of best electrical practices. We want to ensure that our community and graduates have the ability to get jobs and ensure the safety of new energy distribution systems for the future.
    Language we would like to specifically see is:
    “qualified person” means a person who performs installations on behalf of the certificate holder and who has either satisfactorily completed at least five installations of distributed generation technologies prior to effective date of this Part, or has completed an apprenticeship as a journeyman electrician form a DOL registered electrical apprenticeship and training program and received a certification of satisfactory completion, or has completed an Associate in Applied Science degree from an Illinois Community College Board approved community college program in the appropriate distributed generation technology, or pass an Individual Installer Certification from an Individual Certification Body that is nationally recognized as that distributed generation technology certification body.

    Thank you for allowing us the opportunity to provide input to the draft rule Docket No. 12-0213.
    Christopher Miller

    Christopher Miller
  • December 21, 2012

    I am writing this letter as a Central Illinois concerned renewable energy business owner in regards to the proposed policy of requiring that interconnection be completed by a journeyman electrician and fees be assessed in the amount of $3,000 initially and $500 to be a state licensed /certified installer.

    First, I do not have a problem requiring that interconnections to our power grid be done by a qualified individual. I feel what must be determined and defined is “qualified”. Licensed electrical journeymen certainly fit this qualification. Additionally, others that have taken industry training and testing to gain an industry certification should also be considered qualified. Namely, those that have obtained the NABCEP certification and/or completed certificate programs administered by accredited colleges and learning institutions.

    Taking this a step further, if an individual can produce documentation verifying that they are “qualified” why should a fee and more bureaucracy be added to this process? There is no reason for the state to assess a fee to deem an individual “qualified” when that individual has already qualified him or herself. Rather, policy could be adopted that would require that an entity applying for a building permit/submission of an interconnection agreement would have to include their installer’s name and credential(s) proving their qualification to complete the interconnection (as previously stated above) to the entity holding jurisdiction for approval. Those local jurisdictions should have a specific list of what they can and cannot accept and either issue or deny the request accordingly.

    In closing, I am 100% in support of making sure that qualified individuals be the only ones who can make connections to our grid. I am 100% against establishing another level of bureaucracy and fees that will only increase the costs associated with solar projects. I feel the fees are nothing more than another money making opportunity for the state that will only make it harder for small businesses, like mine, to survive. There is a very simple solution listed above that can suit everyone’s needs and concerns. Any choice other than this will, in my opinion, be for political and monetary reasons that are not beneficial to the citizens in the state of Illinois.

    Thank you for reading my thoughts. If you have any questions or would like me to answer questions/make comments in person, I am more than happy to help. I hope the right decision will be made for the citizens, businesses and environment of Illinois!

    Sincerely,
    Michelle Marley-Knox, Founder/President of WindSolarUSA, Inc.

    Michelle Marley-Knox
  • December 21, 2012

    First Notice Comments

    As an Illinois licensed Architect involved in the specification of renewable energy equipment, specifically wind and solar site generated electricity, I oppose the proposed Rule as currently constructed, both as to the amount of the fee and the training requirements, and believe that it will adversely affect small businesses by placing upon them an onerous and unnecessary burden.

    I hold these beliefs for the following reasons:

    1) As an attendee of the December 10th public meeting, the Staff noted that no life safety concerns were creating a need for additional regulation. Furthermore, under questioning from the public, the Staff noted that they have no data or complaints from citizens regarding improper or hazardous installations of distributed generation equipment. If no life safety issues are involved than the proposed regulation is not necessary.

    2) Every local community has established its own requirements for the certification and licensure of electricians. All grid connections are inspected by the local electrical inspector and/or the local electrical supplier prior to their activation and must be installed by an approved/licensed electrician who has met the community's training and experience requirements. This method is time tested and has proven an effective method for safeguarding the public from improperly installed equipment. For many small businesses that have successfully and safely serviced their communities for years, the training requirements of the proposed Rule would be an unnecessary burden as the existing regulatory framework has proven satisfactory over time. Furthermore, as electricians are licensed/certified in each community, small businesses must spend a significant portion of their limited resources, each year, to pay the fees associated with maintaining their licenses, thus making the additional one time and yearly fee of the proposed Rule an additional burden on businesses that are already trying to survive during these difficult economic times.

    3) Public comments at the December 10th meeting, which were not rebutted by Staff, placed the number of potential electricians who could, as of today, qualify as a Certified Distributed Generation Installer at less than 100 in the entire state of Illinois. Given that this pool of candidates is far too small to service the needs of the burgeoning renewable energy business within the State this factor alone should dictate a reformulation of the proposed Rule.

    4) In conjunction with item #3 above, the Illinois Renewable Portfolio Standard (RPS) states that by 2025 25% of the electrical energy generated in the State should come from renewable energy sources. Given the complete lack of electricians who could qualify under the proposed Rule, it will be difficult if not impossible for the State to meet the requirements of this Standard.

    5) In my business, I have found that most of my clients are interested in installing some type of Distributed Generation system. For the majority of my clients the inclusion of a DG system is very price sensitive. Given that the payback time on most DG systems can run many years, any increase in the cost of the system will extend the payback period and thus greatly increase the chance that the DG system will ultimately be cut from the project. The proposed Rule will serve only to significantly increase the cost of DG systems and will result in a dramatic decline in the installation of DG systems. Thus, the State will receive less revenue from sales taxes on equipment and also have increased unemployment in a market that should be expanding rather than contracting. Given the need for more employment within the State and the need for the increased use of locally developed renewable energy and less dependence on outside sources of energy, I believe that it would be in the best interest of the State to support and encourage rather than increase regulation of the renewable energy market.

    The proposed Rule would be better constructed if the one-time fee were eliminated and a yearly fee of $50-$100 imposed as this would be more in-line with what electricians currently pay to maintain licenses. Secondly, the proposed Rule should exempt from the training requirements all projects below 100Kw (100,000 watts), as this would be in-line with federal guidelines for 'small wind' turbines and do not represent significant connections to the grid. Lastly, in lieu of the proposed training requirement, the Rule could require manufacturers to supply electrical line diagrams for review and approval by the local building department and utility provider so that all life and grid safety concerns can be addressed prior to the installation of any DG equipment.

    Tim Green
    President
    Tartan Associates

    Tim Green
  • December 21, 2012

    First Notice Comments: D G Certification Ruling Dec. 17, 2012

    1. INSTALL
    Needs better definition +/or clarification.
    What about 'Inspections' prior to completion?
    What about 'Acceptance of Install' by Utility to be connected to?

    2. QUALIFIED PERSON
    Needs better definition other than an apprentice or journeyman completion of a course.
    What about other nationally recognized certifications such as "master Electrician' or other certified installers?

    3. FEES
    I think the $3000 application fee and $500 annual recertification fees are too high.

    Respectfully Submitted; James Tysiak

    James Tysiak
  • December 21, 2012

    12-14-2012 Testimony to ICC on DG installation certification program

    Testimony by:
    John Ailey and Dorian Breuer
    Ailey Solar Electric
    2416 S Ridgeway
    Chicago, IL 60623

    Dear ICC commissioners,

    Overall perspective:
    a) Illinois needs a lot more PV installed. The RPS demands it. The planet needs it. There is a lot of potential in this state, lots of places to put it, decent solar exposure, good electrical infrastructure.

    b) We need a lot more people doing this work and they need to be doing it at a price people can afford. If this work is only being done by large companies at high prices we will never get the quantity of installations done that we need.

    c) The regulatory situation is creating obstacles on both the state and local levels. This regulation puts another huge obstacle to new people getting into this business.

    d) Creating a regulatory environment where more people can get into the business of PV installation will be good for consumers, good for the state's goal of more renewable energy supply, and good for jobs.

    Specific problems with this proposed regulation:
    a) The $3000 fee is way too high. It imposes a huge barrier to new companies just starting up. If you need any fee it should be under $100. It costs me $70 to renew my Chicago Supervising Electrician license every year. It should not cost more than that just to get permission to do electrical work in just one subset of this field.

    b) The training requirement is overly restrictive. I know from personal experience that the best training programs are not necessarily those recognized by the Department of Labor.

    c) We do not agree that you should require all installations to be done by a NABCEP certified installer. To get a NABCEP certification one of the requirements is to have done five installations. You are creating a barrier to new people getting into this field with this requirement. Is a NABCEP installer going to be willing to train a competitor?

    d)A training requirement that we think would be more reasonable is something more like preliminary requirements to get NABCEP certification. Thus

    d-1) 40 hours of training with any course that NABCEP recognizes.
    d-2) OSHA safety training
    d-3) Perhaps a written test similar to the NABCEP entry level test

    e) Installers passing this level of qualifications would get a provisional certification to do residential installations up to maybe 20kW. The provisional license could last for a couple of years, maybe no more than 5. Then the installer would need to advance to NABCEP certification which would allow him/her to oversee installations of any size.

    Please note that any photovoltaic installation in Illinois must be inspected and approved by the local “Authority Having Jurisdiction”, i.e. the local electrical inspector. It is the responsibility of the AHJ to verify that the installation is done safely and correctly.

    Dorian Breuer and John Ailey
  • December 21, 2012

    The DG Certification ruling (Docket 12-0213) is a completely unnecessary layer of certification that will 1) impose unnecessary barriers on the growth of Illinois' solar and small wind industry; 2) place burdensome financial requirements on small businesses; and 3) displace highly trained individuals from employment.

    There is simply no reason to implement a bad policy such as this that will be harmful to small and renewable-related businesses in Illinois. There are no current safety issues with these systems, therefore making the measure an unnecessary cost that will filter down to the consumer. It will be harder and harder for smaller, local companies to offer solar PV installation services, leaving this potential business to potentially go to companies outside of the state.

    If you care about small business growth in Illinois, you will not support this measure. Other states do not require this certification and leave it up to national entities such as the North American Board of Certified Energy Practitioners (NABCEP), this level of certification is sufficient. Please do not support this measure.

    Joshua Marder
  • December 21, 2012

    I am writing to tell you I am against this ruling for the following reasons.

    1. For nearly a decade, I have been working diligently in Illinois to install Solar systems. When I began, my union electrician acquaintances mocked the efforts saying there would never be a need for solar energy and I was making a huge mistake. After being laughed at for a few years, I started generating interest and began installing solar systems. During the days when union workers felt there was no need for alternative energy, my fellow small business owners and myself continued to implement what we believed would be responsible to our environment. Suddenly when the market crashed and government threw money to alternate energy programs, union workers received training that we paid for on our own both through private classes and through on the job experience. Should this pass, something we pioneered, will be taken away from us and we will go out of business. I personally have worked to educate villages and townships in Northern Illinois and helped them write their ordinances regarding solar and wind installations - all necessary because there was no knowledge at what concerns should be considered with this technology. I find it completely unfair that you would consider placing this industry in a situation that would not allow the consumer the right to pick whom and how they want to spend their money. It is clear that those who mocked me and laughed at me have finally realized that there is a need for this type of work and wish to push the small businesses who can barely afford to make a living on this in Illinois completely out of business so that they can have employment.

    2. Your definitions are very vague. I have installed systems that were tied to the grid and have received MANY compliments from Com Ed on my work - them realizing my work is of high quality, I have had the training to back me up and the installations I have done, have NEVER required any work to be re-done, yet I have NOT installed 20 or more systems. This regulation is completely unfair and once again, I will have to shut my business down because I don't meet these vague requirements.

    3. My experience with solar & wind installations in Illinois is that compared to our neighboring states, it is very costly as our rebates are completely limited making consumers flip for most of the bill. The high cost is NOT the costs I impose for my labor and asking consumers to be required to pay union labor rates will stop any growth of renewable / alternative energy in Illinois. Currently, we are far behind in this progress; why would you want to see that we become stalemate on this at all?

    4. The implications financially for this mandate will not only impact the consumers, but your Application Fee of $3000 with an annual renewal fee of $500 will not be attainable for most of us who own small businesses. We are barely making a profit in Illinois. What exactly does this enormous fee for application cover? Asking unions to pay this amount and small businesses to pay the SAME amount is another way of putting us out of business because if we can't pay the $3000 fee, how can we pay a penalty twice the amount?

    Should you choose to pass this legislation, then many of us will not only forced to be out of business and unemployed, but may have to move from Illinois altogether and most importantly this does NOT give consumers in Illinois a fair choice.

    Kind Regards,
    Brian Brown
    Owner of Eco Sun, Inc.

    Brian Brown
  • December 21, 2012

    Hello,

    I am the solar integrator for a small family run business here in Illinois (Keenan Roofing and Solar) and I had attended the public hearing last Monday here in Chicago. I would like to thank you for this opportunity to briefly comment on three vital points.
    Number One: The Illinois solar industry, in general, is healthy and does not require further legislation/requirements/certifications beyond which already exists. NABCEP already offers a voluntary, yet stringent, certification that is recognized nationally and has met the demands of the solar industry, Illinois municipalities, and the consumer. The path to becoming a NABCEP Certified Installer is difficult. The path towards the ICC's proposed twenty (20) installation requirement is diffucult without basis and will cripple the bright future of Illinois solar.
    Number Two: The Fees proposed are both excessive and without justification. Such fees would force the small company I work for, and other small Illinois businesses, to abandon solar. Fifty dollars is acceptable and in line with other fees (i.e., charging stations).
    Number Three: The current Illinois solar industry and its professionals have provided safe, clean, renewable energy to its customers without the need for DOL requirements and without the demands organized labor/IBEW (full disclosure: although I am a currently a union member, the IBEW's sense of entitlement is offensive).
    Please listen to the voices from within our industry when deciding whether or not to regulate it further. Personally, they have inspired me to become the professional I am today and I have great faith that, with their guidance, support, and relentless pursuit of safety, Illinois will have a resplendent future.

    Thank you.

    Erik Brandenburger
  • December 21, 2012

    I had a Solar PV system installed back in 2008. My installer was a small business owner with proper electrician credentials. This new act you are proposing will hinder the growth of Solar PV systems and affect good, hard working folks.
    In summary, The I believe 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.

    Please reconsider.

    Brian Christopher
  • December 21, 2012

    This appears to be putting a terrible burden on the average small installers. This will lead to higher costs for consumers who may already see this as too expensive. We are trying to become energy independent so we want to encourage more competition among installation companies. There are already standards in place by NABCEP. There appears no upside for the consumer.
    Edward Washak
  • December 21, 2012

    Gentlemen:

    First Notice Comments: It has recently come to my attention that the Illinois Commerce Commission is considering new requirements and regulations for the installation of renewable energy electrical generation systems. From what I understand, these proposed changes would require that the installer/electrician retain a special license and special training in order for these devices to be installed and interface with the grid. I understand that it is necessary to protect the public and the grid system, but I am concerned that this may put the costs of installing these products out of reach for many homeowners and small businesses.

    As an advocate and specifier of “green” and renewable energy products in the architectural and interior design projects that I do, I often have a difficult time convincing my clients to consider the use renewable energy systems. The main problem is that the initial costs of the products and their installation is not always conducive to an acceptable return on investment for the end user. At this time, any additional added costs to these systems will dramatically reduce the chances of a homeowner or small business even considering installing any solar or wind generation system.

    I acknowledge that there could be a serious problem if a renewable energy system is not installed properly, but I feel that any experienced, licensed electrician can successfully install a residential or smaller electrical power generation system. This is especially true when you consider the built-in safeguards supplied and required by reputable manufacturers and power generation/distribution companies. I have had no issues with the installation of any of systems that I have specified and had installed by a licensed electrician. I do believe that only a licensed electrician or licensed electrical contractor should install these systems. I will admit that specialized training and expertise would, and should be required for larger megawatt systems; I do not feel that a smaller system’s installation needs this level of skill or regulation. I also believe that in no way should these systems be installed by a homeowner or other untrained individual or contractor. Avoiding this issue can easily be accomplished through specific requirements and oversight during the permitting process for the project.

    I hope that you will take my thoughts and concerns into consideration in your evaluation and possible implementation of any new laws or regulations. It is important that this State of Illinois remain steadfast in its commitment to the use of renewable energy and “green” products for both economic and the environmental reasons and will not do anything unnecessary to hinder this laudable goal.

    Respectfully,

    David Jungel, IIDA, CRF
    President
    DESIGN WORKS, INC.
    1500 University Lane
    Lisle, Illinois 60532
    630-369-6700

    David Jungel
  • December 21, 2012

    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.


    This industry is just barely getting started locally.
    Please allow the time it needs to grow.

    Robert Speros
  • December 14, 2012

    Your proposed rules appear to completely eliminate a homeowner installing their own PV systems. I have installed the electrical for a 10kW Bergey wind turbine, an 8 kW set of 44 Evergreen PV panels with Xantrex inverters and just finished another 8 kW with Enphase microinverters. Are your regulations going to prevent me from adding more panels if I should so need and desire, or helping my son or daughter install their systemsif they so desire. If so, why? I note I also wired our house when it was built in 83, using low voltage switching which is still a forthcoming electricity saving concept. The main wiring of the panels is now simple with the new microinverters, with the only possible complis=cation being a new meter box. I have no license and am a retired faculty member at UIUC. I note I had the new meter base installed by a licensed electrician and one also installed the main disconnect box when the house was built.
    Phillip H. Geil
  • December 14, 2012

    As a small businessman, I am simply opposed to these rules for the following reasons:
    1. The small scale solar and wind industries are just trying to come up, and are nascent industries with a lot of employment potential, if nurtured properly. Unfortunately, these rules will Impose unnecessary barriers on the growth of Illinois' solar and small wind industry
    2. They will also place highly burdensome burdensome financial requirements on small businesses; and
    3. Displace highly trained individuals from employment. People have spent hours, and thousands of dollars getting such certifications as NABCEP, which are very specialized training for solar field, for instance.

    So, unless the ICC simply wants to kill the industry of small scale solar, and wind installers, thereby jeopardizing the thousands employed in this industry, this ruling should not be enforced, and should be withdrawn. Allow us to survive, and we will show you the great employment potential in this industry, and you will also notice how our industry contributes to mitigation of global warming, in addition.

    Gan Visva
  • December 14, 2012

    I am the Founder & CEO of Intelligent Generation, a renewable energy software company that makes solar energy economically compelling for Illinois and 20 other states. Our software networks distributed solar and energy storage to form market blocs of virtual power, which cuts the payback time for solar by half or more. We are on track to install solar in at least 200 homes and 15 commercial buildings in Illinois in 2013.

    I am deeply troubled by the wording of the proposed rule, particularly as it relates to customer-sited solar energy which equates to a "distributed generation facility" under the proposed Rule. If adopted as currently phrased, the rule would destroy the huge potential market for distributed solar in Illinois before it even gets started. My specific objections include:

    1) Installation of residential solar with net metering is not rocket science. The requirement of a "certified distributed generation installer" to implement or oversee implementation is not only unnecessary, it would add to project costs and result in project delays. To my knowledge, there is no documented case of installed rooftop solar in Illinois today where net metering problems have resulted even with the lack of a "certified distributed generation installer." Licensed electrical installers have done just fine.

    2) Customer-sited solar is almost entirely an internal affair. Panels send DC to the inverter and the inverter feeds the load. To the extent the panels provide more power than the building needs, the excess goes out to the grid (and the meter goes backwards). Generally, this is a rare occurrence. Thus, the interconnection with the grid is automatic and does not require additional special skills.

    3) Permitting and the interconnection agreement will prevent installation of solar capacity that is more than the distribution circuit (e.g., transformers and substation) can handle. There is no need for a "certified distributed generation installer" to prevent this. A licensed electrical contractor is sufficient.

    4) The fact that every customer-sited solar installation on the customer's side of the meter must obtain a docket number and certificate from the ICC is onerous and unnecessary. A copy of the interconnection agreement itself should be sufficient for the ICC's records.

    5) The proposed rule goes far beyond what states with robust solar markets like New Jersey and California require. The only requirement for an installer in New Jersey is that he or she be an "electrical contractor." N.J.S.A. 45:5A-2(d). California, which has by far the largest solar market in the U.S., allows the following types of licensed contractors to install photovoltaic solar: a) general engineering contractors, b) general building contractors, c) electrical contractors and d) solar contractors. http://www.cslb.ca.gov/Resources/GuidesAndPamphlets/DescriptionOfClassifications.pdf Rather than create our own unnecessary and overly restrictive rule and certification category, we should adopt what states with successful solar markets have done.

    Companies like mine will always seek the path of least resistance to success. It pains me to think that our state is on the verge of shooting itself in the foot once again just at a time that we are poised to become a leader in smart grid and renewable energy.

    Thank you for your consideration.

    Sincerely,

    Jay Marhoefer
    Founder & CEO
    Intelligent Generation LLC

    Jay Marhoefer
  • December 14, 2012

    First Notice Comments

    I believe these rules will:
    Impose unnecessary barriers on the growth of Illinois' solar and small wind industry;
    Place excessive financial requirements on small businesses; and
    Increase unemployment.

    Nathaniel Kirby
  • December 14, 2012

    This is clearly a move by the large Corps to kick small business right in the seat of there pants.. Is this rule written by Com Ed ? So you folks can just endorse it ? In my opinion this is just another squeeze of the "The Little Guy" by an in in-favor of the Mega Corp..
    William Lorch
  • December 14, 2012

    The application fee of $3000 seems unreasonable to me. Is the goal here to limit the development of clean energy and just favor our continued trend of setting the planet's resource on fire (coal, natural gas...) ? If that's the goal, well done ICC!

    I can understand the desire to ensure qualified individuals are doing the work and that's fine, but let's not try to balance the state's (or your department's) budget here. I'm a state employee too and yeah, I worry about not having a retirement, but this is no way to go about funding it.

    The reporting requirements on the property owner also seem a bit onerous to me. If Illinois can't get this right, then nearby states that can will have a competitive advantage in attracting this business...and it's only going to grow as energy prices increase.

    Galen Arnold
  • December 14, 2012

    First Notice Comments

    There are many highly qualified NABCEP certified individuals who in many ways are more qualified than those described under "Qualified person" who will be left out if this ruling is enacted.

    Further, the $3,000 entry fee discriminates against small businesses at a time we need more small businesses.

    The ruling would bar highly trained individuals from this emerging business as well as discourage small business owners.

    The only winners would be unions...not a good thing in these economic times where Illinois has just been downgraded AGAIN today.

    Mark Wilkerson
  • December 14, 2012

    First Notice Comments Re. DG Certification rulling
    I strongly object to your forced definition of "Installer" buy following this rule and not including other electrical wiring or electrical wiring and connections internal to the distribution system or other tasks not associated with electrical connections but relating to the system.
    The DG Installer certification requirement that calls for only a qualified persons can connect solar PV to the grid is too narrowly defined and not inclusive enough.
    Your application fee of $3000 and a yearly fee of $500 or your penalty is way out of reasonable price.
    What you're doing here will close a lot of existing businesses of PV installers and will choke any development of the solar industry in the State of Illinois not to mention that you'll displace highly trained people from employment.You need to re-think these.

    dan litvin
  • December 14, 2012

    I would like to comment on the order being considered in Section 16-128(A)regarding the compliance of installers.

    I do not believe there needs to be a certification or compliance requirement from the state for installing alternative energy components to the electric grid. The Illinois Distributed Generation Interconnection Standard currently gives the guidelines for connecting to the grid and each utility and local permitting unit of government certifies the correct procedures were followed. Adding an additional layer of government regulation and over-site will only deter and create barriers to an increase of renewable sources of energy being shared by everyone connected to the grid.

    In addition to the current regulatory safeguards already in place, the new electronics in the marketplace have built in safeguards that prevent most equipment from being installed incorrectly. Technology can adapt and change much faster that any regulatory barriers.

    Please reconsider adopting this amendment.

    Thank You,
    William Marcomb



    Section 16-128(A)(a) requires the Commission to ensure that the installers of
    distributed generation facilities are in compliance with Subsection 16-128(a) of the Act.
    Section 16-128(a) of the Act addresses the knowledge, skill, training, experience and
    competence levels required of employees that perform work on “the electric system” on
    behalf of electric utilities and alternative retail electric suppliers.

    William Marcomb
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