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Updated June 2026 | P.A. 104-0458 (CRGA) Analysis

Illinois Renewable Portfolio Standard - Geothermal Renewable Energy Credits

The Clean and Reliable Grid Affordability Act (CRGA), signed into law January 8, 2026 as Public Act 104-0458, establishes a dedicated geothermal credit program inside the Illinois Power Agency. Qualifying ground-source heat pump systems are now eligible for 15-year GREC delivery contracts with RPS-obligated utilities. Flett Exchange is applying for Approved Vendor status to manage enrollment and delivery on behalf of Illinois owners.

About the Program

The Geothermal Homes and Businesses Program

Under CRGA, the Illinois Power Agency must include a dedicated geothermal block in its Long-Term Renewable Resources Procurement Plan, with committed volumes and contract prices through at least 2035. For the first program year 2028, $10 million per delivery year is allocated across three project categories: Residential, Commercial, and Public & Environmental Justice sites. At least 50% of each annual block is reserved for residential systems.

Contracts run 15 years and are executed with RPS-obligated utilities. Residential projects receive no less than 40 percent of total contract value at the point of energization, with the balance paid annually on actual GREC delivery. All enrollments flow through an IPA-certified Approved Vendor.

"Payment structures shall include provisions that provide portions of the renewable energy credit delivery contract value upon energization, including no less than 40% of the contract value for residential projects … the delivery contract length shall be 15 years." 20 ILCS 3855/1-75 · P.A. 104-0458 (CRGA) Geothermal Homes and Businesses Program

Program status: IPA rulemaking pending. The Illinois Power Agency commission responsible for certifying and administering the Geothermal Homes and Businesses Program is not yet fully established. Block pricing, Approved Vendor certification requirements, and application windows remain subject to pending IPA rulemaking, with the first compliance delivery year beginning in 2028. Every figure in this sheet is drawn solely from enacted law: P.A. 104-0458; 20 ILCS 3855/1-75.

GREC Calculation

How Credits Are Calculated

The IPA will select a calculation formula supported by a recognized geothermal industry trade organization. Credits represent the thermal energy advantage of the ground-source heat pump over a conventional baseline system.

Annual GREC Formula
GREC annual = Load Served GSHP − Replaced Load Baseline
Space Heating

All heating load served by the GSHP loop.

Space Cooling

All cooling load served by the GSHP loop.

Water Heating

Desuperheater or dedicated hot-water loop.

Eligibility

What Qualifies an Illinois System

Requirement Description
Equipment Meets current Energy Star specifications and is AHRI-certified.
Displacement Replaces or displaces a less efficient heating, cooling, or water-heating system.
No grid export Does not feed electricity back to the grid at the heat-pump level.
Install date Operational on or after June 1, 2026.
Location Installed and operating within Illinois.
Enrollment Registered through an IPA Approved Vendor.

CRGA does not permit self-registration. All project enrollments must be submitted by an IPA-certified Approved Vendor. Flett Exchange is pursuing AV certification and will begin accepting projects the moment the IPA opens applications.

Block Categories

Annual Allocation Segments

Category Statutory Allocation Key Feature for Owners
Residential Minimum 50% of each annual block 40% of total contract value paid at energization
Commercial Remaining volume after statutory set-asides Annual payments based on actual GREC delivery
Public / EJ Schools, municipal, low-income, and EIEC sites Enhanced pricing may be available under statute
Residential Earnings

What a Home System Could Earn

Annual GREC yield scales with system size and verified thermal output. A typical single-family ground-source heat pump produces on the order of 50 GRECs per year; larger or multi-zone systems produce proportionally more. The illustration below applies the statutory 15-year contract term and the 40% energization payment for residential projects across a range of per-GREC contract prices, since final block pricing is set by pending IPA rulemaking.

System Size 15-Yr GRECs Lifetime Value @ $35 Lifetime Value @ $50 Upfront @ 40% ($50)
30 / yr small home 450 $15,750 $22,500 $9,000
50 / yr typical home 750 $26,250 $37,500 $15,000
75 / yr large home 1,125 $39,375 $56,250 $22,500
100 / yr multi-zone 1,500 $52,500 $75,000 $30,000

Illustrative only. Per-GREC contract prices ($35 and $50 shown) are placeholders pending IPA block pricing and are not offers. Actual yield depends on AHRI-certified performance, displaced-equipment baseline, and verified building load. Flett Exchange provides a free, project-specific estimate before any commitment.

Working with Flett Exchange

Five Steps to Your GREC Contract

1
Request a GREC estimate

Send us your project location and system specs. We produce a free, non-binding GREC yield estimate.

2
Documentation package

We compile everything the IPA requires: AHRI certificate, displaced-equipment records, building load data, and commissioning report.

3
IPA application

Flett Exchange files as Approved Vendor, monitoring block pricing, category reservation, and waitlist position for each delivery year.

4
Contract execution

We execute the 15-year delivery contract. Residential projects receive the 40% payment at energization.

5
Annual settlement

Annual production reporting, GREC retirement, and settlement across the full 15-year term.

Program at a Glance

Key Terms in One View

Term Value
Governing law P.A. 104-0458 (CRGA)
Contract term 15 years
Annual IPA budget Up to $10M through 2035
Residential block share 50% min. (statutory)
Eligible vintage On/after June 1, 2026
Upfront (residential) 40%+ at energization
First compliance year 2028
Enrollment path Approved Vendor only

Statutory sources: All program details are cited exclusively from enacted law: P.A. 104-0458, Illinois Clean and Reliable Grid Affordability Act (CRGA), signed January 8, 2026; 20 ILCS 3855/1-75, Geothermal Homes and Businesses Program. The IPA commission has not been fully established as of this document's date. All parameters - block pricing, AV certification requirements, application windows, payment schedules, and fee structure - remain subject to pending IPA rulemaking. First compliance delivery year: 2028. For informational purposes only; not a binding offer. Flett Exchange LLC · Hoboken, NJ · June 2026.

Start With a Free GREC Estimate

There is no cost and no obligation to find out what your geothermal system could earn. Send us your project details and Flett Exchange will return a non-binding GREC yield projection.

  • Since 2007, Flett Exchange has been the leading PJM REC aggregator and broker trusted by system owners across multiple state RPS programs.
  • We handle estimation, IPA filing, contract execution, and the full 15-year compliance and settlement cycle.
  • Our guidance is statute-grounded - every figure here is drawn solely from enacted law.
Contact Us

Questions? Call 201-209-0234 or cflett@flettexchange.com.