The Clean and Reliable Grid Affordability Act (Public Act 104-0458, or “CRGA”) was passed on October 31, 2025, and took effect on June 1, 2026. CRGA amended the IPA Act, among other Illinois laws, resulting in modifications to the Illinois Shines program and its requirements. CRGA introduced a Project Labor Agreement (PLA) requirement for community solar projects approved for a REC Delivery contract after June 1, 2026, where the aggregate capacity, including co-located projects, exceeds 3 MW.
To fulfill the requirement for applicable projects, Approved Vendors (AVs) must submit the PLA as attachment(s) (3.5MB size limit per document) through the secure Salesforce.com Project Labor Agreement Submission Form and are required to confirm the bullet points below are met. AVs should ensure they note the document name and provide the applicable PDF page number where evidence of meeting the requirement is found. PLA requirements are addressed in Section 4.R of the 2026-27 Illinois Shines Program Guidebook.
- The PLA being submitted is within the later of: (a) 60 days prior to the start of construction; (b) thirty (30) days of the execution of such Project Labor Agreement or amendment; or (c) thirty (30) days of ICC approval (the contract trade date).
- The PLA is a pre-hire collective bargaining agreement that covers all terms and conditions of employment on a specific construction project.
- The PLA includes the names, addresses, and occupations of the owner of the project and the individuals representing the labor organization employees participating in the project labor agreement consistent with the Project Labor Agreements Act.
- The PLA includes provisions establishing the minimum hourly wage for each class of labor organization employee.
- The PLA includes provisions establishing the benefits and other compensation for each class of labor organization employee.
- The PLA includes provisions establishing that no strike or disputes will be engaged in by the labor organization employees.
- The PLA includes provisions establishing that no lockout or disputes will be engaged in by the general contractor building the project.
- The PLA includes provisions for minorities and women, as defined under the Business Enterprise for Minorities, Women, and Persons with Disabilities Act, setting forth goals for apprenticeship hours to be performed by minorities and women and setting forth goals for total hours to be performed by underrepresented minorities and women.
The Program Administrator will review submitted documents and notify the AV of the results via email. If all provisions are not met, the AV will be required to resubmit using the submission form. An approved PLA will be required prior to Part II verification of applicable projects.
The current version of the Program Guidebook will remain effective until the new Program Year commences on June 1, 2027, or until an updated version is released. Compliance with all changes in the Program Guidebook is required. Stakeholders can find current and past versions of the Program Guidebook, and other documents, on the Program Documents page.
For questions, please contact the Program Administrator at [email protected].