Ohio Department Of Development Updates QEP PILOT Construction Reporting Process

The Ohio Department of Development ("ODOD") has made some changes to documents provided by renewable energy projects that have received certification as a Qualified Energy Project ("QEP") in the Payment in Lieu of Taxes ("PILOT") program under R.C. 5727.75:

• Recently, ODOD established new informational requirements that a QEP must meet if the project provides an alternative document to prove that an employee is domiciled in Ohio, rather than one of the three types of acceptable documents ODOD has listed in its rules.
• In April 2025, ODOD also revised its Construction Completion Report form, which must be submitted to ODOD within 90 days after a QEP is placed in service.

Ohio-domicile verification documents: A QEP must maintain a ratio of Ohio-domiciled full-time equivalent ("FTE") employees employed in the construction or installation of a solar project to the total number of FTE employees of not less than 70%. Other renewable energy projects, such as wind