MES Guidance Updates (April 2024)

With the close of the current ABP 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
• 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. 

Failure to meet MES may result in:

1. Notice of Potential Violation from the IPA.
2. Suspension of entities ability to submit projects to IPA for the rest of the Program year.
3. Having to re-submit Mid-Year Progress information.
4. Repeated failure may result in suspension.

What is the MES

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 previously, 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: 

1. 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.  
2. 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
   • 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.   
• 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. 

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.

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.

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 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. Completed waivers should be sent to [e-mail].  

• Additional resources on the MES and the Equity Accountability System can be found here. 
• For any questions related to the MES Year-End Report, please reach out to [e-mail].