With the close of the current Program Year on May 27, 2024, the IPA and Program Administrator are providing additional guidance to supplement the Minimum Equity Standards (MES) information shared on February 27, 2024. This announcement includes the release of the Equity Eligible Person (EEP) Attestation form, an updated MES Year-End Report template, release of the MES Compliance Plan form for Program Year 2024-25, and additional guidance for union entities seeking a waiver from the MES. Please review both announcements as you prepare to submit your Minimum Equity Standard (MES) Year-End Report for the 2023-24 Program Year and prepare for MES compliance for the 2024-25 Program Year.
The Illinois Power Agency Act (IPA Act) required the Illinois Power Agency to establish an Equity Accountability System, including a Minimum Equity Standard (MES) for the project workforce of entities applying for Renewable Energy Credit (REC) contracts under the IPA’s Indexed REC procurements and Illinois Shines program. The MES requires a certain minimum percentage of an Approved Vendor or Designee’s project workforce to be Equity Eligible Persons, with this required percentage increasing to 30% by 2030. Beginning in the current Program Year, all Approved Vendors and Designees participating in the Illinois Shines program, with the exception of Equity Eligible Contractors (EECs), must meet a required minimum percentage of 10% EEPs in their project workforce. For more information on the Minimum Equity Standard, please visit www.illinoisshines.com/equity-accountability-system, which provides informational resources including the Guide to the Equity Accountability System & Illinois Shines.
Key Dates
- April 11, 2024 – MES Compliance Plan for next Program Year (2024-25) opens for submissions
- May 1, 2024 – MES Year-End Report opens for submissions
- May 27, 2024 – Conclusion of the 2023-24 Program Year
- June 3, 2024 – Deadline for submission of MES Compliance Plan for 2024-25 Program Year
- July 15, 2024 – Deadline for submission of MES Year-End Report for Program Year 2023-24
EEP Attestation
The IPA and Program Administrator are pleased to announce the release of the Equity Eligible Person (EEP) Attestation form. This form provides participating entities an alternative to certifying EEPs who do not want to register in IPA’s Energy Workforce Equity Portal. As noted in the March 6, 2024 MES Year-End Report webinar and previous communications, participating Approved Vendors and Designees will be required to certify all EEPs in their project workforce when submitting their Year-End Report. This can be done in one of two ways:
- The Approved Vendor/Designee can encourage all EEPs in their project workforce to register in IPA’s Energy Workforce Equity Portal prior to the MES Year-End Report deadline: https://energyequity.illinois.gov
- This option allows the Approved Vendor/Designee to simply provide to the Program Administrator a list of the names of the registered EEPs in its MES Year-End Report.
- The EEPs can provide documentation of their registration with the Energy Workforce Equity Portal to their employer in order to demonstrate that they qualify as an EEP, rather than having to provide the personal information underlying that qualification directly to the employer.
- The Approved Vendor/Designee can collect signed EEP attestations and provide documentation for their EEPs to the Program Administrator in their secure SharePoint folder*. The EEP attestation can be downloaded here: https://illinoisshines.com/wp-content/uploads/2024/04/EEP-Attestation-Form-vFeb2024.pdf
- This option requires that the Approved Vendor/Designee collect required supplemental documentation for EEPs who qualify based on graduation from a participating workforce training program, or whose primary residence is located in an Equity Investment Eligible Community. Acceptable documentation includes:
- For EEPs who qualify based on graduation or current participation in a qualifying workforce training program, please provide either an acceptance letter from the training provider or a certificate of completion, where available, from the training provider.
- For EEPs who qualify based on primary residence, please provide one of the following: the individual’s driver’s license, state ID, pay stub, utility bill, lease, mortgage agreement, or other similar documentation for the Program Administrator to verify the individual’s address.
- The Approved Vendor/Designee then lists the EEPs in its project workforce in the Year-End Report and uploads the EEPs’ attestations and required supplemental documentation to their secure SharePoint folder.
- * Please note – the Program Administrator will be creating these SharePoint folders in the coming weeks. Please look out for an email from SharePoint with access to your secure folder.
- * Please note – the Program Administrator will be creating these SharePoint folders in the coming weeks. Please look out for an email from SharePoint with access to your secure folder.
- This option requires that the Approved Vendor/Designee collect required supplemental documentation for EEPs who qualify based on graduation from a participating workforce training program, or whose primary residence is located in an Equity Investment Eligible Community. Acceptable documentation includes:
| Method For Certifying EEPs | EEP Documentation Needed | Where to Submit | Deadline |
| Using Equity Portal | List of all EEPs | MES Year-End Report Form and/or SharePoint Folder | Must be submitted to Program Administrator prior to/on MES Year-End Report deadline. Please note – EEPs must be approved in Equity Portal prior to deadline. |
| Send documentation for Program Administrator to review and confirm EEP status | – List of all EEPs – EEP attestation for all EEPs – Supporting documentation for all EEPs (if applicable) | SharePoint Folder | Must be submitted to Program Administrator prior to/on MES Year-End Report deadline. |
Updated MES Year-End Report Template
The Agency has made some minor changes to the questions in the MES Year-End Report Template. An updated version can be viewed here: https://illinoisshines.com/wp-content/uploads/2024/04/MES-Year-End-Report-Draft-Template-Program-Year-2023-24-11April2024.pdf. The changes/additions to the form include:
- An updated definition of ‘project workforce’, as described in the ICC final order
- Questions asking organizations to attest that they did not hire any new employees during the Program Year
MES Year-End Reports will go live for submission via Microsoft form on May 1, 2024. The report is due by July 15, 2024.
MES Compliance Plan for Program Year 2024-25
The MES Compliance Plan for the next Program Year has opened for submissions. Please submit your MES Compliance Plan for the 2024-25 Program Year by June 3, 2024 using this link: https://forms.office.com/r/qvDmuW5Z74. The MES Compliance Plan template can be viewed here. As a reminder, the MES Compliance Plan is a forward-looking document that is intended for participating organizations to show how they plan to achieve the MES over the upcoming Program Year. In this Compliance Plan, you will explain your organization’s plans to conduct outreach and hire EEPs to reach the 10% EEPs requirement under the MES for the 2024-25 Program Year.
How does the MES Year-End Report differ from the initial MES Compliance Plan?
With the preparation and submission deadlines for the current Program Year’s MES Year-End Report and the following Program Year’s MES Compliance Plan overlapping, the following chart clarifies the differences between the documents including a breakdown of each submission’s requirements:
| MES Year-End Report for PY 2023-24 | MES Compliance Plan for PY 2024-25 | |
| Form Opens for Submissions | May 1, 2024 | April 11, 2024 |
| Submission Deadline | July 15, 2024 | June 3, 2024 |
| Intent | The MES Year-End Report is intended for your organization to document how it implemented and achieved compliance with the MES over the applicable Program Year. For this report, the applicable Program Year is 2023-24, and the MES requirement is 10% EEPs. | The MES Compliance Plan is intended for organizations to show how they plan to achieve the MES over the upcoming Program Year. In this Compliance Plan, you will explain your organization’s plans to conduct outreach and hire EEPs to reach the 10% EEPs requirement under the MES for the 2024-25 Program Year. |
Data Required | – Actual project workforce total – Actual project workforce demographic information – Actual EEP total – Description of outreach efforts employed to recruit EEPs – Job training program graduate hiring data, Illinois-based workforce diversity data – Number of full-time, part-time, temporary, and contract employees in workforce – Please see sample Year-End Report form for more detail | – Estimated project workforce total – Estimated project workforce demographic information – Estimated number of EEPs currently in your project workforce – Number of EEPs your organization seeks to hire over the Program Year to achieve compliance – Communication/outreach plan that will be used to increase the utilization of EEPs |
| Who Needs to Submit | All Approved Vendors, Designees, and Nested Designees who participated* in the Illinois Shines program during the 2023-24 Program Year. Entities certified as EECs are exempt from this requirement. | All Approved Vendors, Designees, and Nested Designees who intend to participate* in the Illinois Shines program during the 2024-25 Program Year. Entities certified as EECs are exempt from this requirement. |
*For the purposes of the MES, “participation” in the Program includes:
- Submitting projects to Illinois Shines.
- Performing construction on any project intended on being submitted to Illinois Shines.
- Conducting any sales or marketing activity for projects that have been or will be submitted to the Program.
- Managing subscriptions for a Community Solar project that holds a REC contract (including projects approved prior to the passage of the Climate and Equitable Jobs Act [CEJA]).
- Maintaining a project on a waitlist.
- Otherwise conducting business on a project seeking or that holds a REC contract.
MES Waiver
If, despite significant efforts, your organization determines that prior to June 1, 2024 it will not achieve the 10% MES goal for Program Year 2023-24, your organization is encouraged to request a waiver. In order to qualify for a waiver, your organization must demonstrate the outreach activities and efforts it conducted to connect with and attempt to recruit EEPs, and to detail why those efforts were not successful, ultimately resulting in noncompliance with the MES.
Waiver requests are evaluated against a scoring system, with each waiver item scored, and a minimum score of 20 points needed to grant a waiver. The template for the waiver request can be found here: https://illinoisshines.com/wp-content/uploads/2024/02/MES-Waiver-Request-and-Scoring-22-March-2023.pdf. Completed waivers should be sent to [email protected].
Additional Guidance for Union Entities Seeking an MES Waiver
On February 8, 2023, the IPA released a Request for Stakeholder Feedback regarding the process to request a waiver for the MES The Agency received and reviewed comments from eight parties, slightly adjusted the scoring rubric and points available for each category, and developed a separate rubric for entities which use organized labor in their workforce. The IPA released the final MES waiver request forms and associated scoring rubric on March 10, 2023.
Since then, the IPA received MES waiver requests from entities with organized labor workforces that did not include an acceptable letter from unions detailing efforts to recruit EEPs. This document provides guidance regarding what does and does not constitute an acceptable letter from the union.
The Agency addressed the difference in hiring practices for unionized and non-unionized entities in the MES waiver request by requiring a letter from a local branch of the relevant union documenting the due diligence activities it conducted to recruit EEPs. The existing rubric stated that the letter should affirm that no union EEPs were available in the area and should describe efforts the local chapter undertook to recruit EEPs. Based on MES Waiver requests received thus far, the IPA sees a need to clarify further what it expects such “efforts to recruit EEPs” would include to receive the full points for this letter in the Waiver request rubric.
A union letter that only reiterates existing union hiring practices with no mention of specific efforts to increase outreach to EEPs will not receive points for this criterion. A statement that the union could not find any EEPs to recruit, without specific description of outreach to EEPs or organizations that serve EEPs, will not receive points for this criterion. Acceptable efforts to recruit EEPs are listed in the waiver and may include but are not limited to:
- Register in the Energy Workforce Equity Portal and post available positions or opportunities
- Establish relationships with qualifying workforce training programs in the area to promote opportunities among EEPs
- Efforts to contact community colleges, community-based organizations, and other entities that may serve EEPs to extend outreach
- Documentation of the use of state-sponsored employment platforms (Illinois WorkNet or Illinois Job Link), employment websites, alumni listservs, social media, union hall listservs, etc.
Additional Resources
- Additional resources on the MES and the Equity Accountability System can be found here: https://illinoisshines.com/equity-accountability-system/
- For any questions related to the MES Year-End Report, please reach out to [email protected].
Thank you!
Illinois Shines Program
[email protected]
