Equity Accountability System

The Climate and Equitable Jobs Act (Public Act 102-0662 or “CEJA”) amended the Illinois Power Agency Act to expand the “priority access to the clean energy economy for businesses and workers from communities that have been excluded from economic opportunities in the energy sector, have been subject to disproportionate levels of pollution, and have disproportionately experienced negative public health outcomes.”
 
CEJA directed the Illinois Power Agency (“IPA” or “Agency”) and Illinois Department of Commerce and Economic Opportunity (“DCEO”) to help historically underserved communities participate in and benefit from the growing clean energy economy. One of the tools to reach that goal is to have the IPA and DCEO create a public-facing portal that helps develop a diverse pipeline of skilled and trained clean energy workforce. The portal may be used by employers to connect to job seekers, register as a clean energy company, and post jobs, and by job seekers to connect to employers, explore jobs, and apply to become Equity Eligible Persons. On January 31, 2023, the Illinois Power Agency announced the launch of the Energy Workforce Equity Portal at energyequity.illinois.gov. This site includes an Equity Investment Eligible Community Map to help identify if communities and individuals reside in an identified equity investment eligible community.
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The IPA has created a webpage dedicated to Diversity, Equity, and Inclusion (DEI). The page represents the Agency’s commitment to DEI, which plays a central role in its mission to create an equitable clean energy future in Illinois. The page includes information on DEI targets and mandates for Illinois Shines, IPA outreach resources, and links to equity webinars. To learn more, visit IPA’s page on Diversity, Equity, and Inclusion. In addition, a dedicated page on the Minimum Equity Standard (MES), including final documents and educational resources on MES, can be found at IPA’s page on the Minimum Equity Standard.

To advance that objective, the Act directed the Agency to establish an Equity Accountability System (EAS), which includes the following:

The Act further establishes several required monitoring, reporting, and facilitation requirements to support the assessment of the Equity Accountability System. Section 1-75(c-10)(4) of the IPA Act directs the Agency to include the following in each revision to the Long-Term Renewable Resources Procurement Plan:

The Act also empowers the Agency to assess and attempt to ameliorate existing racial discrimination or disparities in rates of participation in the clean energy economy:

For Program Year 2022-2023, the Agency and Program Administrator presented three webinars on the Equity Accountability System and Illinois Shines to date. Recordings of the webinars, presentation slides, and Q&A from each webinar, can be found here. All AVs and Designees have been strongly encouraged to attend the webinar series or to view the recordings to ensure comprehension and compliance with forthcoming Program requirements, and to complete attestation and attendance forms included in the materials, to indicate their viewing and provide information about how they will incorporate EAS plans into their organization.

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Webinar Resources

Minimum Equity Standard for Program Year 2023-2024

Beginning in Program Year 2023-24, each participating Approved Vendor and Designee must meet a required minimum percentage of their project workforce that includes Equity Eligible Persons, with this required percentage increasing to 30% by 2030. Definitions of equity eligible persons, the minimum workforce percentages, and key steps and dates for compliance, are provided at this page and in its linked resources. The MES requirement for the 2023-24 Program year is 10% EEPs for an entity’s workforce and the MES for the 2024-25 Program year is 12% EEPs for an entity’s workforce. Future Program years’ percentages will be determined by the IPA through the update to the Long-Term Renewable Resources Procurement Plan. Resources in support of MES Compliance for Program year 2023-2024 include:


February 2023 Stakeholder Feedback – Waiver for Minimum Equity Standard

In February 2023 the Illinois Power Agency sought public comment on the waiver for Minimum Equity Standard requirements for entities that have received a REC contract award under the Adjustable Block/Illinois Shines Program or through the IPA’s utility-scale REC procurements for a given Program/delivery year. Following the review and consideration of public comments on the waiver, the Agency finalized the waiver and process for the 2023-2024 Program year/Delivery year beginning June 1, 2023. The proposal, public responses, final waiver, and waiver rationale document are included in the following table. More information on the waiver for Minimum Equity Standard requirements can be found in Section 10.1.3.1 of the Agency’s Long-Term Renewable Resources Procurement Plan.

Final Minimum Equity Standard Waiver Request– published March 10, 2023 (and updated March 22, 2023)
Minimum Equity Standard Waiver Rationale – published March 17, 2023

Equity Eligible Contractors

October 2023 Stakeholder Feedback Request – Proposed Advance of Capital Request

A feature of the Equity Accountability System, as established by the Climate and Equitable Jobs Act, is the ability of Equity Eligible Contractors (EECs) to request an advance of a portion of REC Contract value prior to the associated project’s energization. This capital advancement pre-energization is intended to serve EEC-certified businesses exhibiting true need and to support a more diverse Approved Vendor pool.

The IPA has developed the rubric linked below as criteria for evaluating requests for an advance of capital for projects receiving a REC contract in the EEC Category for the 2022-23 and 2023-24 Program Years. Please provide comments via email attachment to [email protected] with the subject “[Responder’s Name] – Stakeholder Feedback on Advance of Capital Authorization Rubric” by November 14, 2023.

Note: The Agency has filed the 2024 Long-Term Renewable Resources Procurement Plan with the Illinois Commerce Commission and thus is not seeking any input on the advance of capital process contemplated within that Plan. Stakeholders seeking to provide input on Plan content may do so through the intervening in the open docket (Docket 23-0714). Please limit all comments in response to this request for feedback to the criteria listed below as applied to the 2022-23 and 2023-24 Program Years. 

Final Advance of Capital Rationale — published December 12, 2023
Final Advance of Capital Evaluation Criteria — published December 12, 2023

April 2023 Stakeholder Feedback – Adjusting EEC Criteria

The Illinois Power Agency seeks stakeholder feedback on potential strategies to strengthen the criteria for qualifying as an Equity Eligible Contractor and for receiving incentives under the Equity Eligible Contractor block of capacity within the Illinois Shines Program. This feedback will inform new requirements as part of the IPA’s upcoming Long-Term Renewable Resources Procurement Plan. More information on the Equity Eligible Contactor category can be found in section 7.4.6 of the Agency’s Final 2022 Long-Term Renewable Resources Procurement Plan.

Please provide comments via email attachment to [email protected] with the subject “[Responder’s Name] – Stakeholder Feedback on EEC Criteria” by May 5, 2023.

Stakeholders may comment on as many or as few of the items outlined within the request for feedback as they would like. Stakeholders should not feel limited by the questions offered in the request for feedback and may provide comments on these proposals beyond the scope of these specific questions as it relates to the criteria for certifying Equity Eligible Contractors. Responses will be published on both the IPA and Illinois Shines websites. Should a commenter seek to designate any portion of its response as confidential and proprietary, that commenter should provide both public and redacted versions of its comments. Independent of that designation, if the Agency or the Program Administrator determines that a response contains confidential information that should not be disclosed, the IPA reserves the right to provide its own redactions.

The Agency is greatly interested in hearing directly from Equity Eligible Persons, Equity Eligible Contractors, or those looking to qualify as such, but generally seeks input from a wide array of stakeholders.

Equity Eligible Contractors Utilizing Advance of Capital
2022 15-Year REC Delivery Contract15 yearsSmall DGUp to 50% upfront payment (pending approval) at pre- Energization and the remainder one month after Energization
Large DG
Up to 50% upfront payment (pending approval) pre- Energization, 15% payment at Energization, and the remainder ratably over 6 years
2022 20-Year REC Delivery Contract20 yearsTraditional Community SolarUp to 50% upfront payment pre-Energization (pending approval) and pay-as-delivered resumes once Seller delivers at least 50% of Maximum REC Quantity
DG or CS