How Illinois Agencies Can Lead in Transforming the Midwest Power Markets

IRP and Procurements and REAP
How Illinois Agencies Can Lead in Transforming the Midwest Power Markets

Illinois energy regulators face a huge task: By the end of the year, the Illinois Commerce Commission, the Illinois Power Agency (IPA), and the Illinois EPA are charged with performing a comprehensive analysis of how to mitigate the state's looming resource adequacy shortfall, and conduct state-wide integrated-resource planning and state-wide transmission planning for the first time.

... In a state with a restructured energy market that straddles two RTOs.
... While meeting Illinois' carbon-free energy standard.
... During a period of massive load growth.
Tall order? Yep. Achievable? Absolutely.

But success in these efforts will take a coordinated and thoughtful approach.

Passage of the Clean and Reliable Grid Affordability Grid Act
Illinois has been a national leader in setting clean energy policy. In 2021, the state passed the Climate and Equitable Jobs Act (CEJA) – an ambitious piece of legislation that set the state on the path toward 100% clean energy by 2050 and set state policy to ensure that the Illinois workforce and economy would see the lion's share of the resulting economic benefits. Last year, Illinois followed up with additional tools for the state to achieve these goals, packaged in the Clean and Reliable Grid Affordability Act (CRGA).

Together, CEJA and CRGA represent some of the most ambitious state climate, energy, and jobs programs in the entire U.S.
Notably, CRGA establishes a 3GW-minimum energy storage requirement for Illinois, directs the Illinois Commerce Commission to develop a state-wide integrated resource plan, and boosts the State's Renewable Energy Access Plan to support these efforts. When added to CEJA's Renewable Energy Credit (REC) procurement requirements, the Illinois agencies, and their stakeholders, are looking at some pretty significant work in 2025.

Here's the rundown:
Indexed-REC Procurements:

The first indexed-REC procurement under the 2026-2028 Long-Term Renewable Resource Procurement Plan is underway. The event targets 2,500,000 REs from Wind, 1,300,000 RECs from utility-scale PV & 90,000 RECs from brownfield PV. This is a familiar process to the IPA, renewable energy developers, and Illinois' utilities; it represents the 8th such procurement of RECs from utility-scale projects since the passage of CEJA. This procurement will run concurrently with the state's first energy storage procurement process, described below.

Energy Storage Procurements
An initial energy storage procurement with a target of 1038 MW of stand-alone storage is scheduled for summer, 2026 (CRGA imposes a deadline of August 26). The IPA is currently working through a stakeholder feedback process to finalize the indexed storage contract and bid guidelines.

Resource Adequacy Mitigation & Integrated Resource Plan Development
CEJA required the ICC, IPA, and IL EPA to conduct a study on resource adequacy by December 15, 2025 and to subsequently develop a plan to mitigate any anticipated resource adequacy shortfalls. Because this type of analysis has significant overlap with integrated resource planning required by CRGA, the agencies will be merging these two processes. With workshops currently underway to develop the technical aspects of the agencies' modeling efforts, this process has commenced even before the effective date of CRGA (June 1, 2026). The deadline for ICC's IRP submission is November 15, 2026.

Renewable Energy Access Plan Update
By December 31, 2026, the ICC must update the Renewable Energy Access Plan (REAP) must be updated to include the inputs and assumptions developed under the IRP, provide an evaluation of advanced transmission technologies, and recommend specific transmission projects that achieve the clean energy public policy objectives of the state. The ICC paused the preexisting REAP process after CRGA was passed and is re-starting its REAP process with a kickoff workshop on March 31.

With great opportunity comes... great opportunity.

CRGA presents a huge opportunity for Illinois to show the Midwest how to get it done. If successful, Illinois' IRP, REAP, and procurement processes will:
• Ensure compliance with Illinois' clean energy policy objectives as articulated by CEJA.
• Set a precedent for best-in-class modeling of anticipated load expansions and available resources, especially storage.
• Maximize the use of existing resources through identified advanced transmission technologies while supporting least-regrets transmission investments.

But the devil is in the details, and in order to efficiently and cost-effectively achieve these goals, [EP1.1]the regulatory process must effectively engage stakeholders to make sure Illinois is able to meet the requirements of CEJA and CRGA in the face of rising energy demand and an increasingly complex energy market.

With all of these moving parts, now is the time for us to collectively roll up our sleeves and get to work to ensure that we're able to meet our energy needs without compromising what Illinois set out to do in 2021. With proper implementation through CRGA, CEJA's clean energy mandate is achievable – and will pave the way for other states to follow suit.