The Program Administrator has published a Subcontractor Attestation and Registration Form on the Registering as an Approved Vendor webpage.
This form must be filled out by entities working with Illinois Solar for All (ILSFA) Approved Vendors, Aggregators, and/or Designees in a role that requires direct interaction with end-use customers (such as marketing, installation, lead generation, and sales). Subcontractors registration is subject to verification and approval by the applicable Approved Vendor(s). Approved Vendors should ensure that their current subcontractor complete this registration within 45 days of this announcement, (Thursday, September 10, 2020), and that new subcontractors comply with this requirement on an ongoing basis.
Subcontractors should submit a signed Registration form via email to vendors@IllinoisSFA.com. Approved Vendors who have questions about which of their subcontractors must register should reach out to their Approved Vendor manager for clarifications of this requirement.
The requirements for ILSFA subcontractor registration has been included below (excerpted from Section 3.1 of the Approved Vendor Manual, which also contains additional information about types of Approved Vendors).
Subcontractors and Contracting with Customers
The definition of an Approved Vendor as provided by the Revised Plan allows for flexibility regarding how various entities may be involved in a given solar development. The use of subcontractors offers an alternative to the Aggregator and Designee roles [as described in Section 3.1 of the Approved Vendor Manual]. It is common in the solar industry for multiple business entities to have roles in the project development process at different stages. For example, some solar developers use independent sales organizations to acquire and contract with customers. They may also use subcontractors to perform the installation. If that solar developer maintains the REC contract, they are required to be the Approved Vendor and accept responsibility for meeting all program requirements.
Similarly, some solar companies acquire customers and may even facilitate installation with their employees or with subcontractors. But instead of managing long-term REC contracts, they transfer ownership to investor organizations. In these instances, the solar developer could act as a Designee, with the investor organization acting as an Aggregator. It is also feasible that the investor organization is the Approved Vendor and all other entities are subcontractors. In all instances, the Approved Vendor or Aggregator maintains the REC contract and holds accountability for meeting all program requirements.
The flexibility in this model means that those entities directly interacting and ultimately contracting with customers may or may not be Approved Vendors. Therefore, in order to increase transparency for the program, subcontractors will be required to register with the Program Administrator. The types of subcontracts subject to this provision include those that have direct interaction with end-use customers. This includes installers, marketing firms, lead generators, and sales organizations. The Agency reserves the right to add additional categories as needed. Potential customers will then be able to verify that a company that reaches out to them is actually a program participant registered with the Program (and likewise be able to review if they are listed on the complaint or disciplinary databases).
Registration shall encompass the subcontractor’s provision of contact information, acknowledgment of the business relationship with the Approved Vendor, and identification of the categories of the consumer-facing services provided. Additionally, a subcontractor is responsible for acknowledging that they will comply with all Program requirements applicable to installers or marketing agents, as applicable. Failure by a subcontractor to comply with applicable requirements could subject them to suspension or termination from registration. If the subcontractor ignores a suspension (or termination) decision made by the Program Administrator and continues its market activity nonetheless, any Approved Vendor that works with that subcontractor during that period will be subject to discipline. Likewise, Approved Vendors found to be working with entities engaged in the proscribed activities that fail to register will be subject to discipline.
The ultimate accountability for any given batch or project resides with the Approved Vendor or the Aggregator. But the Program Administrator will monitor all entities and has the right to exclude any entity from performing work on ILSFA projects.