Background
- December 2025 Large Group SAG Meeting: Questions were raised about how Illinois evaluators are interpreting the Net-to-Gross (NTG) for Disadvantaged Areas Policy (from Section 7.4 of the Illinois Energy Efficiency Policy Manual).
- Utility EE Plan Presentations in Early 2026: Several stakeholders requested further discussion / understanding of how the policy is being applied.
- Interpretation by Illinois Evaluators: Guidehouse (current evaluator for ComEd, Nicor Gas, Peoples Gas & North Shore Gas) and E Source (current evaluator for Ameren Illinois) are interpreting the policy application differently. The two evaluators differ on whether the location of a Trade Ally should be considered when applying the policy.
- ICC Staff Request: ICC Staff requested the SAG discuss this policy issue, with an opportunity for stakeholder input.
- June 8, 2026 Large Group SAG Meeting: A SAG meeting was held to discuss the policy interpretation issue. A request for SAG feedback was circulated following the June 8 Large Group SAG meeting, asking interested SAG participants to answer the following question: Should the location of a Trade Ally in a utility’s service territory be considered when applying the NTG for Disadvantaged Areas policy?
- SAG Feedback Received: The comment deadline was Friday, June 26, 2026. The following written comments are posted on the June 8 meeting page and the Policy page:
Request for Comments on Potential Compromise for NTG Ratio for Disadvantaged Areas Policy Interpretation Issue
Following review of the comments received in June 2026, the SAG Facilitator requested a second round of comments from interested SAG participants on a potential compromise resolution of this policy issue.
- Question: In written comments submitted in June 2026, ICC Staff suggested a potential policy compromise, which is described in the comment template (linked below). Does your company or organization support this policy clarification as a compromise to address situations where customer end-use data is unavailable? If not, what concerns or alternative suggestions would you like the Large Group SAG to consider?
- Feedback was requested using a comment template: Request for Comments on Potential Compromise for NTG Ratio for Disadvantaged Areas Policy Interpretation Issue.
- SAG Feedback Received: The comment deadline was Wednesday, August 19, 2026. The following written comments were submitted:
Issue Status
Consensus was not reached in 2026 on this policy issue. If needed, a follow-up discussion with interested parties will be scheduled.