Public Act 104-0458 Implementation

About the Legislation

On October 30 2025, the Illinois General Assembly passed the Clean and Reliable Grid Affordability Act ("CRGA"). The bill was signed into law as Public Act 104-0458 by Governor J.B. Pritzker on January 8, 2026, and will take effect on June 1, 2026.

CRGA is a comprehensive energy bill aimed at enhancing energy reliability, affordability, and sustainability by facilitating the development of new battery storage projects, improving energy efficiency, and introducing new long-term energy planning.

The Illinois Power Agency (IPA) is charged with implementation of numerous elements of CRGA, and this page will be updated as implementation efforts progress and additional information becomes available. Stakeholders are encouraged to visit this page to stay apprised of key developments, timelines, and opportunities for engagement related to implementation of Public Act 104-0458.

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Implementation Activities Under Public Act 104-0458

Click to expand each section below for more information:

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Public Act 104-0458 directs the IPA to facilitate the procurement of energy storage resources through establishing an energy storage nameplate capacity target of 3,000 megawatts (MW) of cumulative capacity. The IPA’s initial energy storage procurement will target 1,038 MW and is set to take place no later than August 26, 2026.

In addition, the Act charges the IPA with evaluating and potentially implementing a new Illinois Storage for All program, which would provide incentives to encourage development of energy storage projects co-located with solar projects developed under the IPA’s already well-established Illinois Solar for All (ILSFA) program.

Final design of a future Storage for All program and future energy storage procurements will be governed by an Energy Storage Procurement Plan, a draft of which is due to be released by the Agency by June 1, 2027.

For more information, visit the IPA's Energy Storage web page.

For questions on energy storage, please email IPA Energy Storage Director, Audrey Steinbach, at Audrey.Steinbach@illinois.gov.

Public Act 104-0458 addresses Renewable Portfolio Standard (RPS) Budget constraints through a restructuring of the funding mechanism which will support continued, cost-effective expansion of renewable resources in Illinois.

Key changes to the RPS budget include an inflationary adjustment to the RPS charge starting June 1, 2026. In addition, the Act also shifts existing Zero Emissions Credits (ZECs) funding over to the RPS budget beginning June 1, 2027, increasing the annual RPS budget by approximately 38%. If so warranted, the Act also allows for Integrated Resource Planning to potentially provide relief of limitations associated with the RPS charge as a mechanism to support new renewable energy projects. For more information, visit the IPA's RPS Forecast and Budget webpage.

For questions on the RPS budget, please email the IPA's Head of Renewable Energy Procurement, Chandrika Mital at Chandrika.Mital@illinois.gov.

Public Act 104-0458 includes several provisions that directly affect the Illinois Shines program. These changes are intended to strengthen labor standards, improve consumer protections, and advance equity outcomes while supporting continued distributed solar development across Illinois. Key updates include the introduction of a project labor agreement requirement for community solar projects with a nameplate capacity greater than 3 MW. The Act also includes a change in REC contract structure for Small Distributed Generation and Public Schools Distributed Generation projects. In addition, the Act establishes a minimum equity standard for Equity Eligible Contractors participating in Illinois Shines and introduces new co-location and consumer protection requirements designed to safeguard customers and ensure program integrity. For more information, visit the Illinois Shines website.

For questions on Illinois Shines, please email IPA Illinois Shines Program Manager Andrea O’Shea at Andrea.Herrera@illinois.gov.

Public Act 104-0458 authorizes the IPA to allocate up to 25% of the ILSFA program budget to support the “Storage for All” program, enabling storage deployment paired with ILSFA projects. The Act also expands eligibility for the ILSFA’s non-profit and public facilities subprogram by allowing critical service providers located adjacent to income-eligible communities and environmental justice communities to qualify if they serve these communities.

In addition, the Act authorizes the IPA to propose an advance of capital mechanism for the Residential Solar (Small) sub-program and introduces the Minimum Equity Standard as an alternative to the ILSFA’s current trainee requirements.

For more information, visit the Illinois Solar for All website.

For questions on Illinois Solar for All, please email IPA Illinois Solar for All Senior Program Manager Jennifer Schmidt at Jennifer.M.Schmidt@illinois.gov.

Public Act 104-0458 includes new statutory language allowing a one-time post-award non-price contract renegotiation, prior to project’s commercial operations, for Indexed REC delivery contracts awarded by the IPA for large utility-scale solar, wind, and brownfield projects, entered into contract prior to January 1, 2025. Contract terms subject to renegotiation may include the project map, as defined under the applicable competitive solicitation, the real estate footprint, or any limitations thereof, the location of the generators, or a potential reduction in the quantity of renewable energy credits to be delivered. Contracts entered into prior to January 1, 2025 may be permitted such renegotiation under certain conditions as described in the Act. The IPA is currently working to develop the process for renegotiation requests and will issue specific guidance for the new renegotiation process.

The Act further provides flexibility for the IPA to use multiple third-party forward price curves in procurement planning and expands bid-information disclosure opportunities.

For more information, visit the IPA’s Downstream Negotiation for Indexed REC Contracts webpage.

For questions on Indexed REC Procurements, please email the IPA's Head of Renewable Energy Procurement, Chandrika Mital at Chandrika.Mital@illinois.gov.

Public Act 104-0458 directs the IPA to develop a long-term clean energy procurement framework as a component of its Electricity Procurement Plans (EPP), starting with the 2027 EPP. This new framework will be informed by the ongoing Resource Adequacy Mitigation Plan and Integrated Resource Planning (IRP) process.

For information on stakeholder feedback, supporting content, and workshops related to this work, visit the IPA Stakeholder Engagement page.

For questions on the Long-Term Clean Energy Procurement Framework, please email Planning and Procurement Chief James Rouland at James.Rouland@illinois.gov

Public Act 104-0458 directs the IPA to design and administer a new Geothermal Homes and Businesses Incentive Program through its 2028 Long-Term Renewable Resources Procurement Plan.

The Program is intended to support the deployment of geothermal heating and cooling systems at homes and businesses across Illinois by providing financial incentives through the procurement of geothermal renewable energy credits (RECs). The Act authorizes the IPA to allocate up to $10 million per delivery year for procurement of geothermal RECs. The Geothermal Homes and Businesses program is subject to the IPA’s Equity Accountability System. Prevailing wage and project labor agreement requirements may apply to geothermal projects supported through the program.

For questions on the geothermal program, please email Planning and Procurement Chief, Jim Rouland, at James.Rouland@illinois.gov.

Public Act 104-0458 creates a statewide Integrated Resource Plan (IRP) in Illinois to tackle resource adequacy and grid reliability issues and to support long-term electric system planning.

Under the Act, agencies coordinated by the Illinois Commerce Commission (ICC) staff, including the IPA, IFA, and IEPA are required to develop and propose an IRP. The first IRP is to be filed with the ICC by November 15, 2026.

The IRP framework provides Illinois with a centralized mechanism and a roadmap to evaluate and plan for future electricity supply and demand, cost-effective resource portfolios, and reliability challenges considering evolving load growth and supply constraints. The process also grants the ICC authority to amend other programs and procurements to effectuate any recommendations or conclusions resulting from the IRP process. For more information, visit the ICC’s IRP web page.

Pursuant to Public Act 104-0458, the IPA has a new responsibility to support the collection of information from prospective consulting firms in support of integrated resource planning efforts to be undertaken by municipal electric utilities and rural electric cooperatives in Illinois. The IPA’s role, as defined through CRGA, is purely supportive and administrative in nature.

Specifically, the IPA will:

Develop and issue Request for Information (RFI) for experts who can assist municipal utilities and rural electric cooperatives with integrated resource planning.
Qualify experts capable of supporting those planning processes.
Maintain and publish a list of qualified experts.
Provide a public repository of completed municipal and cooperative integrated resource plans to promote transparency and accessibility.

The IPA does not direct, control, or conduct the planning processes for municipal utilities or rural electric cooperatives. Additionally, the IPA does not fund those planning efforts.

For more information, please visit the IPA’s IRP Support for Munis and Co-ops web page. This page will serve as a central location for updates, RFQ postings, and related materials. Information regarding the RFI, qualified experts, and submitted plans will be posted to this page as it becomes available. Stakeholders are encouraged to return to this page periodically for updates regarding this implementation under CRGA.

Public Act 104-0458 directs IPA and ICC to jointly conduct a study to evaluate the RTO framework and how such a framework – either maintaining the status quo, or changing the construct – best aligns with Illinois goals and to maximize benefits to State residents and businesses. As a component of the study, the IPA and ICC shall analyze the feasibility and practicality in changing the RTO construct if a change is proposed.

Broadly, the study will be conducted over a twenty-year horizon and examine the costs and benefits to ratepayers, considering topics such as resource adequacy benefits, resilience, affordability, equity, and environmental impacts. The agencies must publish the final study no later than December 1, 2026.

For questions on the study, please email Planning and Procurement Chief, Jim Rouland, at James.Rouland@illinois.gov.

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