The Program Administrator is updating the Illinois Solar for All (ILSFA) 2023-2024 program year schedule in response to the enactment of Public Act 103-0188, which adds prevailing wage requirements to Illinois Solar for All: Community Solar and Illinois Solar for All: Non-Profit and Public Facilities projects.

Project Submission Windows

• The Non-Profit and Public Facilities sub-program project submission window is now July 31 to August 14, 2023. This change allows the Program Administrator to prepare for the updated requirements regarding prevailing wage. The Program Administrator will also provide an updated version of the Approved Vendor Manual before July 31, 2023, to describe changes in procedures relevant to the new prevailing wage requirements.
• The Illinois Solar for All: Residential Solar sub-program submission window is not changing and is open from June 26 to July 31, 2023. Also, the Residential Solar sub-program is not impacted by Public Act 103-0188.
• The Community Solar sub-program submission window is not changing and will be from October 23 to November 3, 2023.

Prevailing Wage Requirements

Prevailing wage is a minimum compensation level set by the Illinois Department of Labor (IDOL) by county for construction activities on public works. Section 1-56(b-15) of the Illinois Power Agency Act (20 ILCS 3855/), added by the Illinois Solar for All – Prevailing Wage law (Public Act 103-0188), now requires that individuals engaged in the construction, maintenance, and repair of applicable projects submitted to the Illinois Solar for All Program (“ILSFA”) are paid at least the relevant prevailing wage rate. Additionally, Public Act 103-0188 clarifies that Non-Profit and Public Facilities and Community Solar projects submitted after the effective date of the law and undertaken pursuant to one or more ILSFA sub-programs are now expressly classified as “public works” subject to the Prevailing Wage Act (820 ILCS 130/), which includes notice requirements and related provisions. The Prevailing Wage Act defines ‘construction’ activities to include all work on public works involving laborers, workers, or mechanics, including any maintenance, repair, assembly, or disassembly work performed on equipment that is a public work.

All projects submitted to the ILSFA Program after July 3, 2023, that receive a renewable energy credit (“REC”) contract are considered public works and are subject to the requirements of the Prevailing Wage Act, with the exception of:

• Residential Distributed Generation projects
• Distributed Generation projects that serve houses of worship and do not exceed 100 kW AC

Such projects and projects submitted prior to July 3, 2023 (the effective date of Public Act 103-0188) that receive REC incentives are not subject to prevailing wage requirements of ILSFA. However, these projects may still be subject to prevailing wage requirements based on other funding sources or legal requirements.

ILSFA REC incentive levels for the 2023-2024 Program Year will remain as published for this program year. Updates to the ILSFA REC prices will be considered as part of the update of the Illinois Power Agency’s Long-Term Renewable Resources Procurement Plan for implementation with the 2024-2025 Program Year.