Illinois Shines Program Administrator

(877) 783-1820 • admin@illinoisshines.com

www.illinoishines.com

May 10, 2024

Heather Lenovich
PSG LMTD, INC
125 Half Mile Rd., Ste. 200
Red Bank, NJ 07701
heatherl@pservices.group

02 Boo Inc. (dba 02 Energy)

1333 Route 9 Unit 1
Toms River, NJ 08755
info@02.energy

Dear Heather Lenovich and 02 Boo Inc.,

This letter serves as a formal warning (“Warning”) to PSG LMTD, Inc. (“PSG LMTD”) and
02 Boo, Inc. (“02”). PSG LMTD, a registered Designee with the Program, and/or 02, an
unregistered entity, have violated Program requirements regarding responsiveness to the
Program Administrator, Approved Vendor/Designee registration, requirements surrounding
required certification for distributed generation system installations, business registration in
Illinois, and misrepresentation of affiliation. The letter summarizes these violations and details
what PSG LMTD and 02 must include in a response to this Warning letter.

I. Background and Facts

A. Notice of Potential Violation Regarding Nonresponsiveness

On January 22, 2024, the Program Administrator received an anonymous complaint regarding
PSG LMTD. The Program Administrator investigated the complaint and communicated a set of
questions to PSG LMTD in an email dated January 30, 2024. The Program Administrator
originally gave a deadline of February 1, 2024, to acknowledge receipt of these questions, and a
deadline of February 6, 2024, to respond. PSG LMTD did not acknowledge receipt or submit any
response to this communication. The Program Administrator then sent a second email, notifying
PSG LMTD of its failure to respond and setting a second deadline of February 14, 2024. PSG
LMTD did not submit any response by the second deadline.

On January 31, 2024, the Program Administrator received an additional complaint from
customer, , regarding PSG LMTD being nonresponsive regarding her system’s
installation and failed inspection. On February 1, 2024, the Program Administrator contacted
PSG LMTD about the complaint and set a deadline of February 5, 2024, to acknowledge receipt
of the email and submit a response by the February 8, 2024, deadline. PSG LMTD did not
acknowledge receipt or submit any response to the communication. The Program Administrator

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 Illinois Shines Program Administrator
(877) 783-1820 • admin@illinoisshines.com
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then sent a second email, notifying PSG LMTD of its failure to respond and setting a second
deadline of February 20, 2024. PSG LMTD did not acknowledge receipt or respond.

Because of the above nonresponsiveness, on February 26, 2024, the Program Administrator
issued PSG LMTD a Notice of Potential Violation (“NOPV”). The Program Administrator noted
that if it “confirms the above violation, the Program Administrator may restrict PSG LMTD’s
portal access and pursue additional steps outlined in the Consumer Protection Program Violation
Response Matrix, located in Section X.D of the Consumer Protection Handbook.” The Program
Administrator further explained that PSG LMTD must acknowledge receipt of the NOPV by
February 28, 2024, and provide a substantive response by March 4, 2024, and failure to do either
“may result in a warning, suspension, and/or a requirement to take corrective action or enter a
compliance plan.”

PSG LMTD did not acknowledge receipt of the NOPV, nor did it provide a substantiative
response by the deadline. On March 7, 2024, the Program Administrator sent a second email
notifying PSG LMTD of its failure to respond and set a second deadline of March 14, 2024.
Subsequently, the Approved Vendor, Carbon Solutions Group, LLC (“Carbon Solutions”)
notified the Program Administrator of PSG LMTD being assumed by a company called
02Energy. Carbon Solutions received information for a contact and reached out to notify PSG
LMTD (02) of the NOPV. Neither PSG LMTD nor 02 ever responded to the February 26 NOPV
or to subsequent communications regarding the same.

B. Notice of Potential Violation Regarding Business Registration and Related Issues

On March 21, 2024, the Program Administrator issued a second NOPV to both PSG LMTD and
O2. The NOPV recounted that on January 22, 2024, the Program Administrator received an
anonymous complaint from a customer of PSG LMTD. The customer alleged that PSG LMTD is
incorporated in Delaware but is not registered to do business in Illinois. The customer alleged
that PSG LMTD was operating under the d/b/a PSG Energy, and that this d/b/a, along with its
website and domain name, pservices.group, resulted in him developing the false belief that PSG
LMTD Inc./PSG Energy was affiliated with or a division of PSG Energy Group, a registered
Approved Vendor in the Program.

The Program Administrator investigated this complaint and found that PSG LMTD is registered
to do business in Delaware. However, a search of the Illinois Secretary of State’s database of
registered business showed that no entity named “PSG LMTD, Inc.” or “PSG Energy” is
registered to do business in Illinois.

Additionally, the Program Administrator found that PSG LMTD registered as a marketing, sales,
Disclosure Form, and installer Designee of Carbon Solutions SREC, LLC on December 10,
2022. However, PSG LMTD Inc. does not appear to have registered its d/b/a, PSG Energy, as a
Designee of Carbon Solutions or any other Approved Vendor or Designee. A search of the

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 Illinois Shines Program Administrator
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Illinois Commerce Commission’s (“ICC”) online database showed that no entity named PSG
LMTD has been certified by the ICC as a distributed generation installer.

The Program Administrator found that PSG LMTD’s website stated that it has been acquired by
02 Energy. 02’s website indicates that “02 Energy” is a d/b/a “02 Boo Inc.” 02’s website further
indicates that it is headquartered in New Jersey. The Program Administrator found that “02.Boo
Inc.” is registered in Delaware as a domestic corporation. The Program Administrator further
found that “02 Boo Inc.” is registered to do business in New Jersey as a foreign corporation. A
search of the Illinois Secretary of State’s database showed no registration for an entity named
“02 Boo Inc.” or “02.Boo Inc.,” nor did it reveal “02 Energy” as a registered d/b/a for any entity.
Additionally, no entity is registered as a Designee or Approved Vendor under the name “02 Boo
Inc.” or “02 Energy.”

Currently, navigating to PSG’s website, pservices.group, redirects to a separate webpage,

02.energy/psg-closure/, which states that:

We are no longer operating as PSG Energy! Based on decisions made by the

leadership and investors of PSG LMTD Inc, the company is no longer in operation
as PSG Energy. Much of our infrastructure is being acquired by a nationwide
company named 02 Energy.2

The NOPV noted that it was unclear if PSG LMTD Inc. ceased operations under the name PSG
Energy.

The Program Administrator issued a March 25, 2024, deadline to acknowledge receipt and
March 28, 2024, deadline to respond to the NOPV. After neither PSG LMTD nor 02
acknowledged receipt or responded, on April 3, 2024, the Program Administrator provided a new
response deadline of April 10, 2024. Neither entity responded to that second deadline.

II. Basis for Warning

Illinois Shines is a state-administered incentive program supported by funds collected from

Illinois residents and businesses. For Approved Vendors and their Designees, the financial
benefits of Renewable Energy Credit (“REC”) delivery contracts, funded by ratepayer dollars,
carry with them the responsibility to fully comply with all Program requirements. Approved
Vendors and Designees must provide clear and honest information to customers interested in
installing solar, should be responsive to customer questions and concerns, and strive to ensure
that customers have a positive experience. Disregard for Program requirements undermines the
public’s trust in the Program and jeopardizes both the success of the Illinois Shines program and
the development of a robust Illinois solar market. Program entities that continually provide
negative experiences for customers and partner businesses through Program violations risk
forfeiting the privilege of being supported by state administered incentive funding.

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 Illinois Shines Program Administrator
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Additionally, as part of registering as Designee, PSG LMTD signed an attestation on December

10, 2022, stating that it would “comply with all ABP1 requirements applicable to our work as a
Designee,” and that it would “abide by the Program's Marketing Guidelines, Program
Guidebook, and associated materials[.]” PSG LMTD and 02 violated Program requirements as
detailed below.

Nonresponsiveness to the Program Administrator

Section 3.B of the 2023 Program Guidebook states that:

[t]he failure of an Approved Vendor or Designee to meet deadlines, respond to the

Program Administrator during the investigation of a complaint or consumer
protection issue. . . could affect that entity’s status in the Program, including
potential disciplinary action and suspension.

Additionally, Section X.C of the 2023 Consumer Protection Handbook states that:

If an Approved Vendor or Designee is not responsive to the Program Administrator

during the investigation of a complaint or potential Program violation, or responds
unsatisfactorily, the Program Administrator may limit the Approved Vendor or
Designee’s access to portal functions, including the ability to generate Disclosure
Forms or submit Part I application.

PSG LMTD and 02 were nonresponsive to the Program Administrator’s inquiries regarding the
above inquiries. They were further nonresponsive after the Program Administration issued the
above-referenced NOPVs. This conduct violated the requirements in both the Program
Guidebook and Consumer Protection Handbook that registered entities (PSG LMTD) meet
deadlines and respond to the Program Administrator’s inquiries.

Approve Vendor/Designee Registration

To participate in the Illinois Shines program, entities must register as either an Approved Vendor
or Designee. Section 2.A of the October 2022 Program Guidebook, effective at the time of PSG
LMTD’s registration as a Designee, requires that all Approved Vendors register (and annually
renew) to participate in the Program. Section 2.G requires that all Designees register (through
their Approved Vendors) and renew annually. Section 2.G additionally states that “[i]f a
Designee does business under multiple names, the Designee must register separate Designee
accounts for each name under which it conducts business.”

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“ABP” refers to the “Adjustable Block Program,” which is the legislative name for the Illinois Shines program.

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 Illinois Shines Program Administrator
(877) 783-1820 • admin@illinoisshines.com
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These requirements were retained in the 2023 version of the Guidebook.

PSG LMTD registered as a Designee of Carbon Solutions SREC, LLC, a registered

Approved Vendor, under its name PSG LMTD Inc. However, PSG LMTD is also
participating in the Program under its d/b/a, PSG Energy, without registering as a Designee
of any entity under its d/b/a. This conduct violates the above requirements of Section 2 and
Section 2.G of the Program Guidebook.

Similarly, 02 is not a registered Approved Vendor or Designee, yet it is participating in the

Program, after its acquisition of PSG LMTD Inc./PSG Energy. 02 is operating under its
d/b/a 02 Energy, which it has likewise not registered with the Program. This conduct
violates Sections 2 and 2.G of the Program Guidebook.

Performing Distributed Generation Installations Without ICC Certification

Section 4.D.1 of the 2022 Program Guidebook, active at the time of PSG LMTD’s
registration as a Designee, states that, to be eligible for participation in the Illinois Shines
Program, “[a] system must be installed by an entity certified as a Distributed Generation
Installer in good standing with the Illinois Commerce Commission.” This requirement was
retained in the 2023 version of the Guidebook.

PSG LMTD is registered as an installer Designee of Carbon Solutions. This implies that
PSG LMTD either has or intends to perform installations that it has or will enroll in the
Program. PSG LMTD is not certified by the ICC as a DG Installer. Thus, all installations
of systems by PSG LMTD intended to be enrolled in the Program violated the requirement
of Section 4.D.1 of the Guidebook.

Failure to Comply with State Law

Section I.F of the 2022 Consumer Protection Handbook, active at the time that PSG LMTD
registered as a Designee in the Program, states that “Approved Vendors and Designees must
comply with all existing local, state, and federal laws, regulations, and guidance[.]” This
requirement was retained in the 2023 version of the Consumer Protection Handbook.

The Illinois Business Corporation Act of 1983 states, at 805 ILCS 5/13.05, that “a foreign
corporation organized for profit, before it transacts business in this State, shall procure authority
so to do from the Secretary of State.”

Additionally, the Act states, at 805 ILCS 5/4.15 that:

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 Illinois Shines Program Administrator
(877) 783-1820 • admin@illinoisshines.com
www.illinoishines.com

A domestic corporation or a foreign corporation admitted to transact business or

attempting to gain admission to transact business may elect to adopt an assumed
corporate name[.]. . . Before transacting any business in this State under an assumed
corporate name or names, the corporation shall, for each assumed corporate name,
pursuant to resolution by its board of directors, execute and file in duplicate in
accordance with Section 1.10 of this Act, an application [with the Secretary of
State].

Here, both PSG LMTD and 02 are foreign corporations conducting business in the State of
Illinois under assumed names: PSG Energy and 02 Energy, respectively. Neither entity has
procured authority to transact business in the State of Illinois nor have they filed an application
to transact business under their assumed names. Neither entity refuted these alleged Program
violations outlined in the above-referenced NOPVs. As such, the Program Administrator finds
this conduct does not appear compliant with the above provisions of the Illinois Business
Corporation Act and thus violates the requirements of Section 1.F of the Consumer Protection
Handbook.

Misrepresentation of Affiliations

Section I.A of the 2022 Consumer Protection Handbook, active at the time PSG LMTD first
registered with the Program, states:

Approved Vendors and Designees shall conduct business affairs with the goal of
openness and transparency and shall not seek to take advantage of or otherwise
exploit a customer’s lack of knowledge.

Approved Vendors and Designees shall not make any claim that is false, deceptive,
or misleading, whether by affirmative statement, implication, or omission.

Additionally, Section I.D.1 of the 2022 Consumer Protection Handbook states that “Approved
Vendors and Designees, including individual agents and salespersons, shall accurately portray
their identities and affiliations. Approved Vendors and Designees shall not make false claims or
create false impressions regarding their identity and/or affiliations.”

These requirements were retained in the 2023 version of the Consumer Protection Handbook.

The Program Administrator concludes that PSG LMTD has been operating under an unregistered
d/b/a, which it had not registered with the Program. This d/b/a, “PSG Energy” strongly
resembles the name of a registered Approved Vendor, PSG Energy Group. PSG LMTD Inc./PSG
Energy may have intended to, and—as shown by the anonymous complaint discussed above—
did in fact, cause a false impression that it either was PSG Energy Group or was affiliated with
PSG Energy Group. As PSG LMTD did not respond to or refute this allegation, the Program

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 Illinois Shines Program Administrator
(877) 783-1820 • admin@illinoisshines.com
www.illinoishines.com

Administrator concludes that PSG LMTD violated the above requirements of Section I.A and
Section I.D.1 of the Consumer Protection Handbook.

Accordingly, today, the Program Administrator restricted PSG LMTD’s portal access.

III. Response Required

As reflected in the Consumer Protection Program Violation Response Matrix, included in the
2023 Consumer Protection Handbook, a material violation of consumer protection Program
requirements may result in an entity being required to take corrective action or follow a
compliance plan. Depending on the severity of a violation, a pattern of Program violations, or
failure to satisfactorily respond to violations, an entity may also be subject to a formal warning,
suspension, and/or permanent revocation of its Approved Vendor/Designee status;
nonresponsiveness may result in restrictions on portal access.

The Program Administrator directs PSG LMTD and 02 to acknowledge receipt of this
Warning letter by May 14, 2024. Further, PSG LMTD must provide a substantive response
to the underlying issues identified above by May 17, 2024. The Program Administrator may
lift PSG LMTD’s portal access restriction upon receipt of PSG LMTD’s response to this
Warning letter.

Any further violations of Program instructions and requirements by PSG LMTD and/or 02,
including a failure to timely acknowledge receipt of this letter or timely respond to future
Program Administrator deadlines, may subject PSG LMTD and/or 02 to requirements and/or
disciplinary action beyond this Warning letter, up to and including suspension from the
Program.

Sincerely,

Matt Pryor
Consumer Protection Team Lead
Illinois Shines Compliance Administrator
complaints@illinoisshines.com

Cc: Rachel Granneman, Consumer Protection Counsel, Illinois Power Agency

Audrey Steinbach, Senior Program Manager, Illinois Power Agency
Karen Craig, Consumer Protection Specialist, Illinois Power Agency
Carbon Solutions SREC, LLC