The solar workforce is changing because of IRA apprenticeship and prevailing wage requirements that went into effect in January. Contractors that haven’t yet made a long-term recruitment plan have a few options available to help them do so.
To collect the full 30% ITC for projects 1 MWAC and larger, contractors with four or more workers on a jobsite must employ apprentices for a certain percentage of labor-hours and pay prevailing wages to all workers. For projects starting in 2023, registered apprentices must make up 12.5% of the on-site labor during the construction phase. That number increases to 15% for projects that start construction in 2024 and after.
Since this is a new initiative for the clean energy industry, the Dept. of Labor (DOL) is working with a few partners to coach and acclimate contractors to the country’s well-established apprenticeship system.
The Interstate Renewable Energy Council (IREC) was contracted by the DOL to lead the Apprenticeships in Clean Energy (ACE) Network, a national coalition of industry, education and workforce development leaders working to create, expand and diversify Registered Apprenticeship opportunities in the clean energy industry.
“The intermediaries can help understand what that process of registering a program is, what the requirements are, navigate that process, and also navigate where additional funding may be available to support programs,” said Richard Lawrence, program director at IREC.
IREC is specifically tasked with recruiting more veterans into the clean energy industry. Veterans in Registered Apprenticeship programs can access a monthly housing allowance benefit through the GI Bill, making apprenticeships appealing for this population. IREC is also working to bring other diverse workers into the industry who may not have access to green employment without an apprenticeship program.
“Being an ‘earn-while-you-learn’ model, as they say, is a great way to attract diverse candidates. You remove a lot of the barriers that are associated with similar pathways, like getting a college degree, where you’re having to often pay for those courses up-front,” Lawrence said.
While it was unclear whether the DOL would create an entirely new “solar installer” Registered Apprenticeship at the start of the IRA rollout, the DOL has now issued a memo clarifying that the solar industry should instead use existing apprenticeship and prevailing wage occupations that already fit the job roles on a solar construction site. Those can include construction craft laborers, electricians, pile drivers and wiremen.
“That makes it easier to fit into the prevailing wage scale side of things,” Lawrence said. “Because if you start recognizing new occupations in the apprenticeship system, it may meet the apprenticeship’s piece of it, but [you may find out] that occupation hasn’t been approved for prevailing wage.”
Using these established roles instead of a solar-specific apprenticeship can also help workers with job security and skill transferability — foundational tenets of apprenticeship programs for North America’s Building Trades Unions (NABTU).
“We want to make sure that they are able to, in a hypothetical world, go from working on a nuclear power plant one day to an offshore wind facility the next to a solar farm on the third,” said Trevor Falk, special assistant to the president for energy policy at NABTU.
Companies have a few options to bring on apprentices, including creating an internal program and registering it with the DOL, hiring a workforce firm to establish the program or access the firm’s external program, or forming a partnership with a union or other workforce development body.
Setting up an internal Registered Apprenticeship program is the most difficult route.
“It does require, obviously, effort to manage the apprenticeship program that is registered with the Dept. of Labor. There’s some oversight and certainly compliance activities there. That step of registering your training programs there and following those standards does take some additional effort,” Lawrence said.
Some states offer funding or tax credits to support Registered Apprenticeship programs, which IREC and other DOL partners can help companies identify. But successfully running these programs and complying with regulations to ensure investors get the return they’re expecting takes a lot of cooperation with various groups, said Nicholas Morgan, president of employment and training services provider Adaptive Construction Solutions (ACS).
“The most successful apprenticeship programs in the country got there through collaboration. It’s not something you do by yourself, either. Even if you have a team, you’ve got to work with the workforce system; you’ve got to work with nonprofits, community-based organizations [and] training providers,” Morgan said.
Like IREC, ACS is also working with the DOL on this effort — the company won an $8 million grant from the agency in 2022 to expand apprenticeships in energy, especially for veterans and other underserved populations. Morgan himself is a veteran who was wounded in the Iraq War and is now dedicated to bringing veterans into apprenticeship programs.
Companies can hire ACS to start and manage internal RA programs, or they can sign up to hire ACS’s own apprentices. Morgan said ACS walks stakeholders through the process from start to finish, showing them the reports they’ll get to ensure they’re hitting their apprenticeship percentages and milestones along the way.
“We’re seeing now where contracts aren’t being signed with the project owner until they see an apprenticeship and a compliance plan,” Morgan said. “That then makes everyone comfortable, especially equity tax investors who are transferring these tax credits.”
If an internal program is too much work or money, contractors can join existing group programs like those offered by college programs or trade associations. For example, the Florida Solar Energy Industries Association is a co-sponsor of a state-approved Florida Solar Energy Apprenticeship program.
But perhaps the simplest option to ensure compliance is to sign up with a union.
“We call that the ‘easy button,’ because they’ve got the systems very well in place. You’re going to be sure that your compliance is on track because they know how to do it,” Lawrence said.
NABTU is the umbrella organization for many unions applicable to the solar industry. The association has found solar developers working with quick project timelines have turned to unions to recruit the apprentices needed to meet IRA requirements.
“Going into a program that’s already established and has shown for eight, nine, 10 decades that it’s done right would be the right way to go, in our opinion,” said Falk at NABTU. “Starting something from scratch, getting DOL approval — it’s quite a few hoops to jump through.”
NABTU and its associated building trades unions have around 1,600 training centers across the country training registered apprentices. Contractors looking to tap into those resources should search for their local Building Trades Union Council to start a conversation.
Unions will likely require contractors to switch most of their laborers over to union workers, according to Lawrence, but establishing Project Labor Agreements that require union labor only for specific projects is also an option for IRA compliance.
“There’s always trepidation toward folks changing, wanting to meet these incentives. But with proper education and engagement, we’ll show folks that [union workers are] the highest-skilled, highest-trained workforce in this country, and we’re happy to get the job done for them,” Falk said.