Illinois Is Buying 3,000 Megawatts of Storage. Here's What the Rules Actually Require.

Illinois has committed to buying three gigawatts of battery storage, and the first auction has already happened. If you own ground in central Illinois, that procurement is the reason your phone is ringing — and the rules it runs on explain which sites developers actually want.

Here is what the law requires, what the first round actually bought, and why most parcels do not qualify.

What the statute actually says

The operative language sits at 20 ILCS 3855/1-75(d-20)(3)(B), added by Public Act 104-0458, effective June 1, 2026. It directs the Illinois Power Agency to conduct procurements resulting in utilities contracting for:

"3,000 megawatts of cumulative energy storage capacity for projects committed to reaching commercial operation on or before December 31, 2030, or an alternative date proposed by the Agency, subject to extension for a delay due to interconnection of the energy storage system, a delay in obtaining permits necessary to build or operate the energy storage system, or other circumstances at the discretion of the Agency."

20 ILCS 3855/1-75(d-20)(3)(B)

Two points of precision, because both get reported loosely.

First, the deadline is softer than the headlines suggest. The statute requires contracting for projects committed to commercial operation by the end of 2030, and it expressly permits an alternative date and extensions for interconnection delay, permitting delay, or other circumstances at the Agency's discretion. Illinois has not promised three gigawatts operating in 2030.

Second, on naming: this law is widely called the Clean and Reliable Grid Affordability Act. That phrase does not appear anywhere in Public Act 104-0458, and no act by that name is codified. The short titles the Act actually enacted are the Municipal and Cooperative Electric Utility Transparent Planning Act and the Utility Data Access Act. The popular name is fine in conversation; the citation is to the Public Act and the ILCS section.

What the first procurement actually bought

The Illinois Commerce Commission approved the results of the first stand-alone storage procurement on September 1, 2026. The RFP targeted 1,038 megawatts. It awarded 600.

The average winning strike price was $110.52 per megawatt-hour.

Downstate was oversubscribed. Northern Illinois was not.

This is the finding that should shape how a central Illinois landowner reads the market.

Ameren's target was 450 MW. Ameren-area projects took 520 MW — more than the target. The Commission explains that the RFP rules permit procuring above target so long as the marginal project does not push the total more than 50% past it.

ComEd's target was 588 MW. ComEd-area projects took 80 MW, a shortfall of more than 500 megawatts. And there is no contingency RFP to make it up.

So in the Ameren footprint — which is McLean, Logan, DeWitt and the rest of central Illinois — developer competition is already strong enough to oversubscribe the state's own target. That is a seller's market for genuinely qualified sites, and simultaneously a warning: the good interconnection points are going.

Two more procurements are required, not optional

The statute provides that additional procurements "shall be conducted in calendar years 2027 and 2028." The Commission's notice says the same. You will see this reported as 2027 "and potentially 2028" — that phrasing appears on the Agency's own website and is contradicted by the statute it administers.

Beyond 2028, further procurements depend on whether the Integrated Resource Planning process concluding in 2027 identifies need above three gigawatts. The eligibility rules and procurement design for 2027 and 2028 have not been set yet. Anyone quoting you a 2027 target number is speculating.

Why most sites do not qualify

The Summer 2026 RFP rules were demanding. A project had to be:

• At least 20 MW AC. Smaller projects were ineligible, full stop.
• Four hours of continuous discharge at contract capacity.
• Interconnected to the transmission system operated by MISO or PJM. A resource "physically interconnected with a distribution system is not eligible." It also had to sit inside MISO Local Resource Zone 4 or the PJM ComEd zone — a project in MISO Zone 3 did not qualify even in Illinois.
• Round-trip efficiency of at least 70%, and at least 85% in the first delivery year. Both numbers apply; the 85% is not a one-time test.
• New — energized on or after June 1, 2026 — with commercial operation by December 31, 2029, extendable a year in exchange for more collateral.
• Backed by a developer that has previously built at least 100 MW AC in aggregate, in facilities of at least 20 MW each.

Read that list against a typical farm parcel and the picture clarifies. A site served off a 12 kV distribution feeder cannot play. The threshold question is not acreage; it is whether the site can reach transmission-level interconnection at a price someone will pay. We wrote separately about why the grid rather than your acreage sets project size.

These were the Summer 2026 rules only. The 2027 and 2028 criteria are undetermined, and a smaller or distribution-connected project may qualify under a future round or a different revenue model.

The contract is a two-way hedge, not a subsidy

Winning bidders receive Indexed Storage Credits over a twenty-year term. The credit settles daily against an index built from the top four and bottom four priced hours each day, plus a capacity component.

The part that surprises people: if the index price exceeds the strike price, the supplier pays the utility. The Commission's own worked example shows a 100 MW project at an $80 strike owing $3,000 for a single day. Anyone describing this to a landowner as a guaranteed government revenue stream has the economics backwards, and that misunderstanding tends to show up as unrealistic rent promises.

Two other terms worth knowing: there is no published price cap — benchmarks are confidential, and bids above them are eliminated — and network upgrade and transmission service costs stay with the project. The utility does not absorb them.

Counties lost most of their discretion, and the deadline to conform has passed

The same Public Act added 55 ILCS 5/5-12024, a county siting section for standalone storage above 1,000 kW. It works as a ceiling on local control, not a floor. County standards:

"may not include requirements for energy storage systems that are more restrictive than specified in this Section or requirements that are not specified in this Section."

55 ILCS 5/5-12024(b)

The statutory setbacks, measured from the nearest edge of the nearest battery enclosure, are 150 feet from the outside wall of an occupied community building or nonparticipating residence, 50 feet to the property line of such a building or property, and 50 feet from a public road right-of-way. Perimeter fencing must be at least 7 feet and no more than 25 feet. Those setbacks are waivable by written consent of each affected nonparticipating owner — which is worth understanding before you sign anything, because consenting converts your land to participating property and gives up the protection.

The section also caps siting fees at the lesser of $5,000 per megawatt or $50,000, limits county sound rules to the Pollution Control Board's standards, bars a county from restricting storage at all unless it has adopted formal zoning, and requires a decision within 30 days after the public hearing closes.

Now the timing. Subsection (e) required a county with a conflicting zoning ordinance to amend it within 120 days after the effective date. The Act took effect June 1, 2026, which put that deadline at September 29, 2026. It has passed.

A county whose storage ordinance still imposes setbacks beyond the statutory figures, or conditions the statute does not authorize, is out of compliance — and a developer facing those requirements has a straightforward preemption argument. Landowners and neighbors should understand the same thing from the other direction: the protections your county ordinance seemed to give you may not be enforceable.

One distinction that gets blurred constantly: this section governs counties. It is part of the Counties Code and by its terms reaches areas outside municipal zoning jurisdiction. A home-rule municipality adopting its own storage rules is exercising different authority — which is why a town's setbacks can lawfully exceed the county ceiling. We covered one example in Normal's battery storage ordinance.

What to take from this

The state is buying, downstate is where the buying is happening, and two more mandatory rounds are coming in 2027 and 2028 on rules nobody has written yet. If a developer approaches you, the questions worth asking early are what interconnection position they hold, whether the site can reach transmission voltage, and what happens to your ground if the answer turns out to be no.

We represent landowners — not developers — in these negotiations. See our wind, solar and battery lease practice and our land use and zoning work.