Vendor FAQs
General
When a program block reaches capacity, all qualifying subsequent project applications will be put on waiting list for the applicable project category. In order for project applications to be approved off of the waitlist or to be considered upon the opening of new blocks when capacity becomes available, the projects must be compliant with all Program requirements. This includes requirements surrounding the distribution of the Illinois Shines brochure and the execution of the Disclosure Form prior to the installation contract. Project applications that do not conform with Program requirements risk the ability to receive REC contract awards. New blocks of capacity are released at the start of each Program year on June 1st.
(Updated February 2023)
The system sizes utilized for the Program are all AC system sizes based on the nameplate size of the system’s inverter.
(Updated February 2023)
Each unique utility customer may have one project of up to 5,000 kW (5MW) AC in the Illinois Shines Program. Two or more utility customers that are affiliated and physically adjacent could each have a project of up to 5,000 kW AC.
The total capacity of systems enrolled in the Illinois Shines Program at a customer’s location will be considered a single system. (For example, three 100 kW systems at a single location will be considered a 300 kW system.) See the Program Guidebook for more information on co-location and associated REC pricing.
(Updated February 2023)
Under the 2019 and 2021 REC contracts, distributed generation projects are given 12 months to be developed and energized. Community solar projects are given 18 months to be developed, energized, and demonstrate that they have sufficient subscribers.
Under the 2022 REC contract, distributed generation projects are given 18 months to be developed and energized. Community solar projects are given 24 months to be developed, energized, and demonstrate that they have sufficient subscribers. Extensions may be granted under certain circumstances, as described in more detail in Section 7.11 of the Long-Term Plan.
(Updated February 2023)
Except where otherwise provided (such as with certain project-specific information being made publicly available through publishing lottery results), Approved Vendor submittals including quarterly reports, annual reports, Approved Vendor applications, and project applications will not be publicly posted or made publicly available as a matter of course – provide that nothing included herein shall a) prohibit the IPA from reporting information taken from Approved Vendor submittals to appropriate authorities should the IPA have reasonable suspicion of any fraudulent or otherwise illegal behavior, b) prevent the IPA from making aggregated information taken from across Approved Vendor submittals publicly available, or c) prevent the IPA from sharing information received with the Illinois Commerce Commission or public utilities to support the Program’s operation.
Additionally, the IPA and the Program Administrator will provide confidential treatment to any commercially sensitive information submitted by Approved Vendors in connection with participation in Illinois Shines. Under Section 1-120 of the IPA Act (20 ILCS 3855), the Illinois Power Agency has a statutory obligation to “provide adequate protection for confidential and proprietary information furnished, delivered, or filed” by any third party. As Section 7(1)(g) of the Illinois Freedom of Information Act (“FOIA”) (5 ILCS 140/7) exempts from disclosure “[t]rade secrets and commercial or financial information obtained from a person or business where the trade secrets or commercial or financial information are furnished under a claim that they are proprietary, privileged or confidential, and that disclosure of the trade secrets or commercial or financial information would cause competitive harm to the person or business,” the IPA believes that its responsibility under Section 1-120 necessitates the assertion of this FOIA exemption when applicable in response to a FOIA request, and to otherwise protect the confidentiality of commercially sensitive information in response to any discovery request or other request made in connection with formal investigation or litigation. While the IPA will presume that submittals including quarterly reports, annual reports, Approved Vendor applications, and project applications are commercially sensitive (to the extent not reflecting public information, or otherwise obviously not commercially sensitive) and thus should be actively protected from disclosure, Approved Vendors should designate any particularly sensitive information as “confidential or proprietary” to maximize the likelihood that such information would be protected from disclosure by a reviewing body (such as a reviewing court or the state’s Public Access Counselor) in response to an appeal of the Agency’s determination that such information should not be disclosed in response to a FOIA request.
(Updated February 2023)
As of February 2023, retail rate net metering – described in more detail below – is still being offered to residential and small commercial customers of Ameren Illinois (“Ameren”), Commonwealth Edison (“ComEd”), and MidAmerican Energy Company (“MEC”) that install a distributed generation system. It is anticipated that the replacement of retail rate net metering with a distributed generation rebate will be triggered under current Illinois law in the Ameren territory in late 2022 or early 2023, and likely later in the ComEd and MidAmerican territories. The mechanism which will trigger the switch from retail rate net metering to a distributed generation rebate, and the process for calculation of that rebate value, is described further below. Customers of rural electric cooperatives and municipal electric utilities should check with those entities to determine whether net metering is offered in the service area.
Background
Under current Illinois law, net metering is available to any retail customer that “owns or operates solar, wind, or other eligible renewable energy generating facility with a rated capacity of not more than 2,000 kilowatts that is located on the customer’s premises and is intended primarily to offset the customer’s own electrical requirements.” 220 ILCS 5/16-107.5. Small customers, such as homeowners and small business owners, may receive a one-for-one kWh credit for the net electricity supplied to their utility at the retail rate – that is, for both distribution and supply charges. This is known as “retail rate net metering.” Non-residential customers, as well as owners and developers of community renewable generation projects, have the option to apply for a rebate equal to $250 per kilowatt of the nameplate capacity of the solar project; these customers are not eligible to receive retail rate net metering and instead only receive net metering credits for the energy supplied from their system to the utility. The net metering landscape in a utility’s territory will change and retail rate net metering will no longer be available to new net metering customers once the installed net metering capacity in that utility’s territory reaches 5% of the total peak demand supplied by that utility provider in the previous year. Instead, those customers who install a distributed generation system after that point in time would be eligible for net metering of energy supplied to the utility and to apply for the distributed generation rebate, the value for which is to be set by the Illinois Commerce Commission (“Commission”) (the State agency charged with approving utility rates) through “an investigation into an annual process and formula for calculating the value of rebates.” 220 ILCS 5/16/107.6(e). The investigations are conducted separately by utility.
Ameren Illinois
In April 2020, upon notification from Ameren that it had reached a 3% net metering penetration, the Commission opened an investigation into the value of successor rebates for distributed generation systems in the Ameren service territory, which remains open and is ongoing. Additional information related to that proceeding may be found at: https://www.icc.illinois.gov/docket/P2020-0738.
Ameren Illinois notified the Illinois Commerce Commission that it reached the 5% net metering threshold on October 2, 2020. The Commission, which has exclusive jurisdiction over the matter of utility net metering, opened an investigation into Ameren’s net metering tariff (Rider NM) to determine whether Ameren had indeed met the 5% threshold as defined under Illinois law. The Commission found that Ameren’s Rider NM incorrectly calculated the threshold and that the volume of installed net metering capacity in the Ameren service territory has not yet met the 5% threshold. The effect of that ruling was to restore the availability of retail rate net metering for otherwise-eligible new Ameren Illinois net metering customers. Pursuant to the Commission’s order, Ameren filed updated tariff language reflecting changes to how Ameren calculates the 5% net metering threshold on December 23, 2020, with an effective date of seven business days later. Furthermore, the Commission ordered that Ameren compensate any customers who became net metering customers between October 2, 2020, and the effective date of the revisions to Rider NM for the delivery netting credits those customers should have received during that time. Ameren estimates that it will reach the 5% net metering penetration under the Commission’s interpretation of the Public Utilities Act in late 2022 or early 2023.
Commonwealth Edison
In March 2021, upon notification from ComEd that it had reached a 3% net metering penetration, the Commission opened an investigation into ComEd’s net metering tariff (Rider POGNM) and its community solar tariff (Rider POGCS) to determine whether the tariffs correctly implement section 16-107.5(j) of the Public Utilities Act, which outlines the calculation of the 5% net metering threshold. In response to an inquiry from the Commission, ComEd confirmed that under the Commission’s interpretation of the Public Utilities Act as applied in the investigation into Ameren’s net metering tariff, the net metering penetration in its service territory as of March 1, 2021, was only 1.48%. The Commission’s investigation of ComEd’s tariffs is ongoing; related documents may be found at: https://www.icc.illinois.gov/docket/P2021-0196/documents.
(Updated February 2023)
Yes, any work performed on a project subject to the requirements of the Illinois Prevailing Wage Act must be paid at a minimum the posted rate for the classification of the work performed. If the worker receives a salary, the yearly amount must be divided by 2,080 hours to calculate the hourly rate. This rate must be at least the relevant prevailing wage for the classification of the work performed. (Example $72,000.00 per year/2,080 hours = $34.62 per hour.)
(Updated September 2023)
All Disclosure Forms submitted to the Program require a customer email address. If the customer does not have an email address, the Program offers a waiver that the customer can sign confirming that they do not have an e-mail address. The Approved Vendor must submit this waiver along with the customer’s Disclosure Form. Additionally, if the customer does not have an email address, the Approved Vendor/Designee must secure the customer’s wet signature on a hard copy of the Disclosure Form.
Approved Vendors
The Program Administrator has published a set of Approved Vendor requirements. Please refer to the webpage link for all Approved Vendor requirements and additional resources.
(Updated February 2023)
In PJM-GATS an Approved Vendor can have a generator account (if they have a generator to register) or an aggregator/broker account (does not require a generator). Click here to view the various account types offered by PJM-GATS and the fees associated with those account types.
In M-RETS an Approved Vendor can have a General Subscription, a Project Subscription, a Small Generator Project Subscription, or a Micro Gen Project Subscription (only eligible for one 100 kW batch of generators). Click here to view the various account types offered by M-RETS and the fees associated with those account types.
When applying to become a new Approved Vendor, you will be asked to provide proof of an account in either PJM-GATS or M-RETS. This can be provided in the form of a screenshot taken upon logging into the chosen system, showing that your company name is registered.
(Updated February 2023)
No. The Distributed Generation Installer certification is required by all firms performing actual distributed generation installations, and as such an Approved Vendor may also be a Distributed Generation Installer. However, any entity that meets the Approved Vendor requirements can become an Approved Vendor and doesn’t necessarily need to be involved in the installation process at all, in which case they would not need to be certified as a Distributed Generation Installer. Approved Vendors can choose to work with Installer Designees for the installation work.
(Updated February 2023)
Yes, there are two requirements for distributed generation installation in Illinois. The first is a company level requirement that Distributed Generation Installers be certified by the Illinois Commerce Commission (ICC). Details of this requirement can be found at the ICC’s Distributed Installers page. A list of Certified Distributed Generation Installers can be found here. Any questions about this requirement should be directed to the ICC which oversees this program. Additionally, installation of a photovoltaic system, if it will seek a REC contract under the Illinois Shines Program, must be done by a Qualified Person as defined under 83 Ill. Adm. Code § 468.20, which covers the qualifications required of the individuals who are actually installing the system.
(Updated February 2023)
The sale of an Approved Vendor is permissible. Both the previous and new owner of the Approved Vendor should notify the Program Administrator in the event of a sale of an entity operating as an Approved Vendor. The new owner and/or company will be required to enter its information into the registration record for that Approved Vendor entity with subsequent approval by the Program Administrator.
(Updated February 2023)
Yes. A project that has been waitlisted or otherwise not yet selected for a REC contract may change its Approved Vendor. To be clear, this switch of Approved Vendor could be for an individual project that is a subset of a larger batch (although minimum batch size requirements would still apply).
While it is not necessary to seek Program Administrator approval in advance of commencing this transaction, the Approved Vendor transferring the project and the Approved Vendor receiving the project (“Transferee”) must provide the Program Administrator with a binding document wherein both agree that the Transferee shall have rights to the RECs produced by the project and the authorization to represent the project for an Illinois Shines application. The documentation also must show that the project host and the project owner, if different, consent to the change of Approved Vendor.
Please note that if a project was submitted co-located with another project, it will continue to be deemed co-located after any change of Approved Vendor. As a result, any co-located pricing or array layout requirements will still apply after a potential change of Approved Vendor. The transferred project, if community solar, could, if applicable, be newly considered co-located after being received by the Transferee. The co-located pricing provision will only be applicable if the Illinois Commerce Commission’s approval of the second project is within one year or less of the Commission’s approval of the first project. If the first project has not yet received Commission approval at the time of the second project’s approval, then the co-located pricing provision will apply.
Please see the ‘Change of Approved Vendors’ section of the Program Guidebook for a complete description of this process as well as clarifications for co-locations.
(Updated February 2023)
Another Approved Vendor could obtain the rights to your project’s Illinois Shines Program REC contract, but only with the consent of your original Approved Vendor. Please see Section 9.2 of the 2019 REC Contract and Section 13.1 of the 2021 and 2022 REC Contracts.
(Updated February 2023)
No. A utility bill includes both fixed and volumetric ($/kWh) charges. Electricity from solar can offset and reduce volumetric charges, but not fixed charges (e.g., the “customer charge” and “meter charge”). Thus, even if electricity from solar were to offset 100% of the volumetric charges of a given utility bill, fixed charges would still be levied by the utility. Therefore, it is incorrect and is a misrepresentation to claim that solar can eliminate, or reduce to zero, a customer’s utility bill. Claims through an Approved Vendor’s (or its agent’s) marketing materials that participation in the Illinois Shines Program will eliminate a customer’s utility bill are not permitted and will be flagged by the Program Administrator. Please reference the Consumer Protection Handbook for details on Program marketing requirements and representation.
(Updated February 2023)
In a case where one Approved Vendor submits a Part I application for a project, and then (before the first application is reviewed and approved by the Program Administrator and its batch submitted to the ICC for approval) a second Approved Vendor submits a new Part I application for a project at the same location, the Program Administrator will proceed as follows to resolve the potential conflict:
The Program Administrator will first investigate (including potentially contacting the site host) whether there is an intent that the multiple project applications are for separate, co-located projects (and if so, whether the co-location would be allowed under Program terms and conditions).
- If co-location is intended and feasible, then the Program Administrator will allow for co-location.
- If co-location is not both intended and feasible (i.e., if the two applications appear to represent the same project), the Agency will review the documents submitted with the Part I applications to determine which Approved Vendor is premising its control of RECs on an earlier-executed site control agreement (or, if both Approved Vendors rely on the same site control agreement, then which Approved Vendor has an earlier-executed REC control agreement); this Approved Vendor will be presumed to be the proper representative of the project.
- An Approved Vendor with a later-executed site control or REC control agreement (as applicable) will be given an opportunity to furnish documentation showing that the earlier-executed instrument was properly terminated prior to that Approved Vendor’s Part I Illinois Shines application. If acceptable documentation is provided (subject to confirmation with the other Approved Vendor), then the application from the Approved Vendor with the later-executed agreement would proceed (subject to any other review and approvals of the application).
(Updated February 2023)
A change in an Approved Vendor’s banking information represents a change to the REC contract. As such, in order for the contracting utility to process the change, the Approved Vendor must provide a letter to ComEd at WB&[email protected] or to Ameren at [email protected] and [email protected], requesting the change in banking information. The letter must be on company letterhead, contain the new banking information as well as a contact from the Approved Vendor’s Treasury group that the utility can contact directly to confirm this change request, and be signed by an authorized signatory of the company. If the contracting utility is MidAmerican, the Approved Vendor must contact the utility’s accounts payable department at [email protected] to request a banking change form.
To provide for processing time, a request to update banking information (including a completed banking change form to MidAmerican) must be provided to the contracting utility at least 15 calendar days in advance of an invoicing window (e.g., no later than February 14, 2021 in time for the opening of the invoicing window on March 1, 2021). The updated banking information may be entered into the “Enter Contract Notices Contact Information” section of the Approved Vendor’s dashboard in the Program portal at any time prior to generation of an invoice.
(Updated February 2023)
Minimum Equity Standard
General
Section 1-75(c-10) of the Illinois Power Agency Act (“IPA Act”) requires that the Illinois Power Agency (“IPA” or “Agency”) establish an Equity Accountability System, which includes 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 percentage of an Approved Vendor or Designee’s workforce to be Equity Eligible Persons. The purpose of the MES is to ensure increasing access to employment in the Illinois clean energy sector for those who historically have been excluded from such opportunities.
The Equity Accountability System will take effect in the first delivery year after the approval of the IPA’s 2022 Long-Term Renewable Resources Procurement Plan, which is the 2023-2024 delivery year beginning June 1, 2023. The 2023-2024 delivery year minimum equity standard is 10%. By June 1, 2023, existing Approved Vendors and Designees must file an annual Minimum Equity Standard Compliance Plan. Approved Vendors and Designees must submit a year-end report within 45 days of the end of the 2023-2024 program year (i.e., by July 15, 2024) that includes data on its performance compared to the Compliance Plan.
Individual plans will not be posted publicly. The Agency will release aggregated data from end of year MES reports tracking achievement of the MES across the market, but will not identify any individual entities. Compliance plans and MES reports will not be made public as a matter of course, however they may be subject to the Illinois Freedom of Information Act (FOIA). The Agency will provide confidential treatment to MES Compliance Plans in accordance with the provisions of Section 2.F of the Program Guidebook.
The Compliance Plan Assessment is described in Section 10.1.1.5 of the August 2022 version of the Program Guidebook. The Agency will utilize a graduated rating system to evaluate Compliance Plans. A rating of 1 (Needs Development), indicates that the entity must review, correct, and/or include missing compliance items in order for the plan to be approved. This rating indicates that the Agency identified inconsistencies in the plan, putting the applicant at risk of non-compliance, and that the plan will not be accepted without updates or inclusion of requirements that need resolution or are missing.
As stated in the 2022 Long-Term Renewable Resources Procurement Plan, Compliance Plans that receive a rating of 1 will be rejected and the AV or Designee will be sent a recommended corrective action plan. If the Agency discovers an area of the Compliance Plan that needs to be amended or requires correction, the Agency will notify the applicant in writing of the required correction(s). The applicant will then have thirty days from the date of the notification to submit amendments to the Compliance Plan. Applicants may request deadline extensions that will be granted by the Agency on a case-by-case basis. After resubmittal of a corrected Compliance Plan, the Agency will notify the applicant in writing of the final re-evaluation status. The Agency will have a maximum of twenty-one days to notify the program participant of final acceptance of the Compliance Plan. The Agency will accept multiple revisions of a proposed Compliance Plan.
The Program Administrator will notify the applicant in writing of the score for their Compliance Plan within fourteen days of submission, though the initial review of the first MES Compliance plans may exceed this timeline. If corrections or amendments to the Compliance Plans are required, the applicant will have thirty days to submit amendments. Applicants may request extensions to that window that will be granted by the Agency on a case-by-case basis. After resubmittal of a corrected Compliance Plan, the Program Administrator will notify the applicant in writing of the final re-evaluation status. The Program Administrator will notify the program participant of final acceptance of the Compliance Plan within 21 days. The Agency will accept multiple revisions of a proposed Compliance Plan. The Agency and Program Administrator will strive to meet the timelines listed above, but extensions may be necessary during periods of high volumes of Compliance Plan submissions.
An AV or Designee that fails to submit a Compliance Plan by June 1, 2023, will receive communication from the Program Administrator explaining how to cure this violation. Entities that fail to cure or entirely fail to submit a Compliance Plan will be subject to disciplinary action, which may include suspension from the program.
Each Approved Vendor, Designee, or Competitive Procurement Supplier must submit a year-end report within 45 days after the end of the delivery year in which they have had active participation through activities developing a project or projects. If the deadline falls on a weekend or holiday, the year-end report will be due on the following business day. Therefore, MES compliance reports for the 2023-2024 program year will be due on would be due on or by July 15, 2024.
The MES Compliance Plan Template, which is available to submit as a Microsoft Form, is available here.
MES requirements are separate from the scoring for project selection for Traditional Community Scoring.
Please contact the Program Administrator at [email protected] and phone: (877) 783-1820.
There is no required verbiage that entities must use on job postings. However, entities are encouraged to utilize the Energy Workforce Equity Portal to foster involvement with EEPs
The threshold to qualify for the waiver is a score of 20 points or above.
Identifying EEPs
Equity investment eligible communities are geographic areas throughout Illinois which would most benefit from equitable investments by the State designed to combat discrimination. The eligible communities are: (1) R3 Areas as established pursuant to Section 10-40 of the Cannabis Regulation Tax Act, where residents have historically been excluded from economic opportunities, including opportunities in the energy sector; and (2) Environmental justice communities, as defined by the Illinois Power Agency pursuant to the Illinois Power Agency Act, where residents have historically been subject to disproportionate burdens of pollution, including pollution from the energy sector.
A map of EIECs can be found here.
The Illinois Solar for All Program Administrator, Elevate Energy, is currently updating the map of Environmental Justice communities used in Solar for All, which is one of the bases for the Equity Investment Eligible Community map. The updated EJ communities map will incorporate data from the 2020 census and updated EJSCREEN data. For more details on the methodology used to create the EJ communities map, please see Section 8.12 of the 2022 Long-Term Plan. The Agency will seek stakeholder feedback on the frequency of updates to the EIEC map in the summer of 2023 through the development of the next Long-Term Plan, which will be published for public comment on August 15, 2023. The Agency encourages all interested parties to provide input on potential schedules for updating the EIEC map.
No, the equity-eligible communities’ boundaries do not precisely align with zip code boundaries, as they are based upon other data. Employers are highly encouraged to ask employees to certify through the Energy Workforce Equity Portal to make the process simpler.
An entity reporting on the makeup of its project workforce must be able to demonstrate that an EEP qualified based upon residency resided in the qualifying location prior the completion of the project. This can be demonstrated by the date displayed on the supporting documents (such as a driver’s license or other identification, utility bill, lease agreement, etc.) or through registration by the EEP on the Energy Workforce Equity Portal. The Agency highly recommends that employers request their employees that qualify on residency to register through the Energy Workforce Equity Portal. The Agency will require an individual who qualifies as an EEP based upon residency to recertify within the portal every three years.
Persons residing in an equity investment eligible community qualify as Equity Eligible Persons. The equity investment eligible community map can be used to help assist in determining whether a person qualifies based upon residency. https://energyequity.illinois.gov/resources/equity- investment-eligible-communitymap.html
Approved Vendors and Designees that are majority owned by an Equity Eligible Person may qualify as an Equity Eligible Contractor. For more information on qualification as an EEC, please visit: https://illinoisshines.com/become-an-equity-eligible-contractor-eec-approved-vendor-or-designee/
In reviewing EEC applications, the Program Administrator will request documentation verifying the relevant individual’s previous incarceration. Clarifications are on the Program website’s Become an Equity Eligible Contractor page. Specifically, “Formerly Incarcerated” means any individual who (i) was sentenced to a term of imprisonment, not including juvenile detention, after the disposition of one or more misdemeanor or felony charges; and (ii) has completed their sentence. Determinations will be made on a case-by-case basis. For EEP-individuals who qualify based upon their status as a formerly incarcerated person, the Agency strongly encourages employers to ask all of their employees to register with the Energy Workforce Equity Portal if they have concerns about asking individual employees for sensitive information regarding formerly incarcerated status.
There is no time limit on how long ago the incarceration occurred. At this time, the IPA is requesting an attestation from the individual that they indeed were incarcerated following conviction. An attestation for can be found at: https://illinoisshines.com/become-an-equity-eligible-contractor-eec-approved-vendor-or-designee/
There is no requirement that the person who is an enrollee or graduate of the foster care system was a part of the system within the State of Illinois. For the purpose of eligibility to be an EEP, a “graduate or enrollee” of the foster care system refers to an individual who is currently or was formerly a youth in care of the IL Department of Children and Family Services, or the equivalent agency in another state.
No. Only individuals who are enrolled or have graduated from the foster care system qualify as EEPs and use that status to qualify their business as an EEC.
EEPs are highly encouraged to seek certification through the Energy Workforce Equity Portal. Illinois law requires that the Program verify the status of every EEP, so submitting entities (AVs, Designees, or utility-scale developers) will need to provide those verifications with their MES year-end report, even if the EEPs did not seek certification through the Portal.
EEPs are able to certify through the Energy Workforce Equity Portal without having to reveal sensitive information to employers. If an EEP does not have access to the internet or is otherwise unable to register themselves in the Portal, they can contact the Program Administrator or their employer for assistance.
Employers should encourage employees to register on the Energy Workforce Equity Portal, which allows employees to certify as equity eligible without disclosing sensitive information directly to their employer. Confirmation of EEP designation through participation in foster care or former incarceration may be demonstrated through completion of the attestation, either through the Portal or directly with the employer.
The Agency strongly encourages employers to utilize the Energy Workforce Equity Portal to confirm whether their employees qualify as EEPs. The IPA is unable to advise AVs and Designees as to the best method of identifying such individuals within their workforce.
Although all employees in the project workforce, including employees of subcontractors, count toward the MES, the IPA does not require that an AV take any specific step to identify EEPs, nor does it advise AVs regarding the best approach for their business.
Populating the database will require individuals voluntarily adding their personal or professional information. There is no comprehensive listing of all Equity Eligible Persons in the state, so the Agency is working with the Illinois Department of Commerce and Economic Opportunity (DCEO), other state agencies, and community organizations to conduct outreach to educate individuals and communities about the Portal and assist EEPs in certifying their status as an EEP. The Agency is working to make sure as many people as possible have access to this database
In order to reach as many potentially qualified EEPs as possible, the IPA and the Program Administrator are providing outreach to specific programs. The IPA is working with DCEO to obtain additional training program information and will provide that information when it is available. Please note only the Solar Training Pipeline and the Multicultural Jobs Programs created and funded by FEJA qualify individuals as an EEP due to the requirements of CEJA (P.A. 102-0662). Please see the Program website’s Equity Eligible Contractor page for further details.
Identifying the Project Workforce
EEPs can be hired at any time during the Program Year.
If there is any reason to believe that an entity is utilizing suspicious hiring practices, such as hiring EEPs for a limited amount of time solely in order to meet the MES, hiring an EEP but not assigning them any hours, or otherwise observed to be attempting to subvert Program requirements, those cases will be promptly reviewed by the Agency and the Program Administrator.
(Updated October 2023)
Section 1-10 of the IPA Act does not provide a definition for “project workforce,” however, the IPA has developed a definition that reflects the context and language in the IPA Act Sections 1-75(c-10), (c-15), (c-20), and (c-25) as well as previously IPA-published guidance regarding required workforce reporting. For the purposes of the MES, “project workforce” includes: employees, contractors and their employees, and subcontractors and their employees, whose job duties are directly required by or substantially related to the development, construction, and operation of a project that is participating in or intended to participate in the IPA-administered programs and procurements under Section 1-75(c) of the IPA Act. This shall include both project installation workforce and workforce in administrative, sales, marketing, and technical roles where those workers’ duties are performed in Illinois.
Employees that do not live in Illinois and do not work in Illinois are not considered part of the project workforce. Only workers whose duties are performed in Illinois are included in the IPA’s “project workforce” definition. Employees who perform duties in Illinois that are related to developing projects or educating consumers about program options should be included in the project workforce.
The 10% equity commitment is based on the total number of employees. For example, if an AV has 100 employees working in Illinois on projects participating in Illinois Shines, that AV must have at least 10 Equity Eligible Persons employed to meet the 10% MES. This includes both project installation workforce and workforce in administrative, sales, marketing and technical roles where those workers’ duties are performed in Illinois.
If an AV or Designee’s project workforce for a given Program Year is less than 10 people, they should aim to employ one Equity Eligible Person and provide a Compliance Plan that outlines how they will strive to recruit an EEP in the event that they hire during that year. They may also apply for a waiver. Please reach out to the Program Administrator if there are questions with compliance and support/guidance can be provided.
The MES requirements are not limited to construction. Per Section 10.1.1. of the Long-Term Renewable Resources Procurement Plan, project workforce includes “employees, contractors and their employees, and subcontractors and their employees, whose job duties are … in administrative, sales, marketing, and technical roles where those workers’ duties are performed in Illinois.”
If an AV has projects participating in the Program (see clarification below), any employees performing duties in Illinois substantially related to those projects must count toward meeting the MES for that Program Year, even if construction will not occur that year,. The MES applies to any work conducted in a given delivery year on projects that are participating in IPA programs.
Yes, temporary and/or part-time employees or subcontractors performing work on the project and getting paid for that work count towards the MES. The MES applies to number of individuals, not number of hours worked.
Pre-construction work, including siting and permitting, is included in the definition of project workforce and therefore counts toward the MES.
The Agency understands the primary policy objective of Section 1-75(c-10) of the IPA Act as advancing equity across Illinois by providing access to the Illinois clean energy economy for businesses and workers from Illinois communities that have been historically excluded.
Therefore, the relevant location is where the work is being performed, for both installation workers and those doing support and business services, as that is the location of the economic opportunity. Only workers whose duties are performed in Illinois are included in the IPA’s “project workforce” definition. Employees who perform duties in Illinois that are related to developing projects or educating consumers about program options should be included in the project workforce.
While the IPA understands that project labor crews and locations vary, applicants do not need to include office workers who live and work outside of Illinois in their project workforce. Such an outcome would not serve the purpose the MES, which is intended to increase access to clean energy jobs for Illinois workers.
The definition of “project workforce” does not include functions performed outside of Illinois. For example, there are many national companies that participate in IPA programs and procurements and the Agency does not believe it would be consistent with the goals of the MES to allow persons working in another state to count toward complying with a standard designed to measure the equity of the Illinois clean energy sector.
Employees That Do and Do Not Count Toward the MES
| Example of Worker | Should they be counted toward the project workforce for the MES? |
|---|---|
| Designees/Nested Designees | No, Approved Vendors do not need to include the workforce of their Designees in their MES but shall report which Designees they worked with in the delivery year to allow the Agency to correlate activities and compliance |
| Temporary or Part-Time Workers | Yes |
| Subcontractors | Yes |
| Pre-Construction Work | Yes |
| Admin Work | Yes |
| One-Time Subcontractors (surveyors, consultants, etc.) | Yes |
| Employees who do not perform work duties in Illinois (including any of the above) | No |
Please see the Long-Term Plan on pg. 330: Approved Vendors in the Adjustable Block Program do not need to report on data regarding their Designees but shall report which Designees they worked with in the delivery year to allow the Agency to correlate activities and compliance. This is not meant to relieve Approved Vendors of responsibility to comply with the Equity Accountability Standard, but rather to ensure that efforts are not double-counted.
If the contractor/subcontractor is itself a Designee, then the AV does not need to include those workers in their project workforce because that Designee will be submitting its own data on their project workforce. All the AV needs to do is indicate which Designees it is working with, for our own tracking purposes to make sure that Designee reports data for that project. Likewise, “nested” Designees should report on their own workforce.
If the AV’s subcontractors are not Designees, then they are included in the AV’s project workforce and the AV must report all of the demographic data associated with those workers.
To further clarify, if either an AV or Designee uses contractors or subcontractors that are not themselves a registered Designee, and therefore do not need to submit their own Compliance Plan, those workers should be included in the employing AV/Designee’s project workforce for that Compliance Plan.
Entities Subject to MES Requirements
Yes, all Approved Vendors and Designees, with the exception of those who are EEC-certified, are required to comply with the Minimum Equity Standards.
The Equity Accountability System applies to Designees. The IPA‘s 2022 Long-Term Plan provides that Approved Vendors do not need to include the workforce of their Designees in their MES but shall report which Designees they worked with in the delivery year to allow the Agency to correlate activities and compliance. This is not meant to relieve Approved Vendors of responsibility to comply with the Equity Accountability Standard, but rather to ensure that efforts are not double-counted.
If the contractor/subcontractor is itself a Designee, then the AV does not need to include those workers in the AV’s project workforce because that Designee will be submitting its own data on their project workforce. The AV simply needs to indicate which Designees it is working with to make sure that Designee reports data for that project.
If the AV’s subcontractors are not Designees, then the employees of those subcontractors are included in the AV’s project workforce and count toward the MES. If an AV or Designee uses contractors or subcontractors that are not also Designees, the AV or Designee must include the workers of those contractors or subcontractors in calculating its MES and reporting, since those contractors or subcontractors will not report on the MES independently.
Nested Designees, as registered Designees within the Program, will need to comply with the Minimum Equity Standard and submit a Compliance Plan and subsequently report on their achievement of the MES.
The MES Compliance Plan is a plan for the year ahead. The Agency understands that circumstances may require adjustments to that plan, but it should show the intention for the year.
To meet the MES, AVs do not necessarily have to work with Equity Eligible Contractors; the requirement is that their workforce must meet the MES for a given Program Year, and that can be achieved without Equity Eligible Contractors. However, the project workforce is defined to include all non-Designee contractors, subcontractors, and the employees of subcontractors. A non-Designee general contractor is included in the MES calculations, and all subcontracted workers are included in the project workforce. The AV does not need to hire the entirety of the workforce, but must ensure compliance with the MES.
Approved Vendors who are Equity Eligible Contractors (EECs) are, by virtue of their participation in the Program as an EEC, in full compliance with the Equity Accountability System and thus do not need to submit a Compliance Plan. However, EECs will need to report on the demographic and geographic data of their employees, just as other AVs do.
Approved Vendors are only required to include their direct employees and employees of non-Designee subcontractors in the project workforce identified in their Compliance Plan and year-end MES Report. Designees must submit their own Compliance Plan and MES Report encompassing the Designee’s project workforce. IPA will include a field in the Compliance Plan form where AVs and Designees may indicate whether they are working with another AV or Designee on any of the projects in the relevant program year.
Scope of Participation in Program or Procurement
An AV is not responsible for submitting a Designee’s MES Compliance Plan, but a non-compliant Designee could affect the progress of a project in a number of ways.
If a project has yet to be Part II verified, it could result in the project not moving forward until the Designee has come into compliance with MES requirements, or the AV has ceased working with the Designee that is out of compliance.
If a Designee is out of compliance after the project has been Part II verified and construction has been completed, and the Designee is not involved in ongoing management of the system, the project will still be able to participate in the Program. If the Designee is still involved with the project after Part II verification (for example, a Designee responsible for subscriber management of a community solar project), the project is at risk until the Designee is in compliance or the AV ceases working with that Designee.
If a Designee continues to demonstrate non-compliance, the AV may be required to present a Designee Management Plan to the Program Administrator and IPA, as outlined in Section X.B.1 of the Consumer Protections Handbook. Continued non-compliance could result in disciplinary action and affect project status.
(Updated October 2023)
There are two determinations necessary for calculating whether an entity has met the MES: the size of the relevant project workforce (the denominator), and the number of Equity Eligible Persons employed in that workforce (the numerator). The project workforce is defined by the Agency as: employees, contractors and their employees, and subcontractors and their employees, whose job duties are directly required by or substantially related to the development, construction, and operation of a project that is participating in or intended to participate in the IPAadministered programs and procurements under Section 1-75(c) of the IPA Act. This shall include both project installation workforce and workforce in administrative, sales, marketing, and technical roles where those workers’ duties are performed in Illinois.”
Once the number of individuals within the project workforce has been established, an entity can calculate the portion of its workforce which must be comprised of equity eligible persons or contractors in order to meet the Minimum Equity Standard. For the 2023-2024 program year, the required percentage is 10% of the overall project workforce; that percentage will increase over time to 30% by 2030, with an already-planned increase to 12% in 2024-25. An AV or Designee may not meet the MES solely through contracting with an EEC that makes up at least 10% of the overall project workforce. Instead, the AV or Designee must include the employees of that EEC in the denominator (described above) of the calculation. The Agency will count Equity Eligible Persons employed by an EEC-certified contractor or subcontractor, including the Equity Eligible Person majority owner, 1.5 times in calculating compliance with the MES. In this way, an AV or Designee will more easily meet the MES if they contract with an EEC, but that alone will not be enough. Additionally, the IPA has determined that an Approved Vendor that subcontracts with an EEC on a project and yet is unable to meet the MES will receive additional points towards a request to seek an MES waiver for the project.
Entities that do not think they’ll be able to achieve the 10% MES goal should submit a waiver request outlining the size of their current and future workforce and plans for recruiting. Program participants are not required to replace qualified current employees who are not EEPs in order to meet the MES. If an employee leaves or the entity finds themselves in a position to hire more employees, they should have a plan in place to do so in an equitable manner.
Yes, the company will still count the EEP majority owner in the project workforce
Compliance with the MES is viewed across the totality of an entity’s Illinois project workforce, both in terms of planning and reporting. The Program Administrator and the Agency will consider any waiver granted in determining whether an entity has met the MES requirements.
To achieve the MES for the 2023-2024 delivery year, at least 10% of the project workforce for each entity participating in an IPA Indexed REC procurement or the Illinois Shines program must be equity eligible persons or equity eligible contractors. The Agency stated its intention to increase the MES to 12% for the 2024-2025 delivery year in its 2022 Long-Term Plan.
In its draft 2024 Long-Term Renewable Energy Resources Procurement Plan, which will be submitted to the Illinois Commerce Commission for approval in the fall of 2023, the Agency will propose future increases of the MES over subsequent delivery years to eventually reach the 30% statutory requirement by 2030. The proposed schedule of annual increases shall be revisited and updated on an annual basis. Revisions shall be developed with stakeholder input, including from equity eligible persons, equity eligible contractors, clean energy industry representatives, and community-based organizations that work with such persons and contractors.
Program participants must submit an annual report on how it achieved the MES for the activities in the last program year year within 45 days following the end of the program year. For projects where work spans several program years, participants should report on the work conducted in the previous year. For example, the employees that performed administrative work on a project submitted for Part I in the June 1, 2023-May 31, 2024 program year, assuming those employees did their work in Illinois, would be included in the project workforce for that program year. If the project installation for this same project did not occur until the a subsequent program year, , then the installation workforce would be included toward meeting the MES of that program year in which the project was installed.
The Compliance Plan requirement and Minimum Equity Standard will apply to work that has happened in that delivery year. As a reminder, the project workforce can include office workers if they are performing their duties in Illinois. If your project participated in the Program (e.g., you submitted a Part I application), if you have staff whose duties on the project are performed in Illinois, even if construction is not beginning that year, the Minimum Equity Standard would apply to this workforce. The Minimum Equity Standard applies to work conducted in a given delivery year on projects that are participating in IPA programs.
If an Approved Vendor or Designee (or utility-scale supplier) has no activity during a program year, that may be indicated on the year-end report and compliance obligations will not apply.
The 10% equity commitment is based on the total number of employees. For example, if an AV has 100 employees working on projects participating in Illinois Shines, that AV must have at least 10 Equity Eligible Persons employed to meet the 10% MES (Minimum Equity Standards). This includes both project installation workforce and workforce in administrative, sales, marketing and technical roles where those workers’ duties are performed in Illinois.
Minimum Equity Standard
General
Section 1-75(c-10) of the Illinois Power Agency Act (“IPA Act”) requires that the Illinois Power Agency (“IPA” or “Agency”) establish an Equity Accountability System, which includes 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 the Illinois Shines program. The MES requires a certain percentage of an Approved Vendor or Designee’s workforce to be Equity Eligible Persons. The purpose of the MES is to ensure increasing access to employment in the Illinois clean energy sector for those who historically have been excluded from such opportunities.
The Equity Accountability System took effect in the 2023-2024 Delivery Year/Program Year that began on June 1, 2023. By June 1, 2023, existing Approved Vendors and Designees had to file an annual Minimum Equity Standard (“MES”) Compliance Plan that details how they plan to comply with the MES for the upcoming Delivery Year/Program Year.
If an entity applies to be an Approved Vendor or Designee during a Delivery Year/Program Year, the Agency will require an Minimum Equity Standard (“MES”) Compliance Plan at the time of the initial application. Halfway through the Delivery Year/Program Year, each Approved Vendor and Designee must respond to a written inquiry from the Agency or Program Administrator, by submitting a Mid-Year Report confirming that their MES Compliance Plan is progressing in accordance with MES requirements. Approved Vendors and Designees must submit a Year-End report within 45 days of the end of the Delivery Year/Program Year (i.e., by July 15) that includes data on its performance compared to the Compliance Plan.
Templates for the Minimum Equity Standard (“MES”) Compliance Plan, MES Mid-Year Report, and MES Year-End Report are available at: https://illinoisshines.com/equity-accountability-system/. MES reports are submitted via Microsoft form, but the templates will be available to review prior to the deadline.
| MES Year-End Report for Previous Delivery Year/Program Year (PY) | MES Compliance Plan for Upcoming Delivery Year/Program Year (PY) |
Forms Open for Submission | May of the current PY | April leading up to new PY |
Submission Deadline | 45 days after the end of the PY (i.e., by July 15) | Opening of PY (i.e., on or around June 1) |
Intent | The MES Year-End Report is intended for each organization to document how it implemented and achieved compliance with the MES over the applicable PY. This report reflects back on the PY on which it is reporting. | The MES Compliance Plan is intended for organizations to show how they plan to achieve the MES over the upcoming PY. In this Compliance Plan, each organization will explain its plans to conduct outreach and hire Equity Eligible Persons (“EEPs”) to reach the % EEPs requirement under the MES for the upcoming/current PY. |
Data Required |
Please see sample Year-End Report form for more details |
|
Who Needs to Submit | All Approved Vendors, Designees, and Nested Designees who participated in the Illinois Shines program during the relevant PY. Entities certified as Equity Eligible Contractors (”EECs”) are exempt from the MES requirement, but must fill out the demographic and geographic data in the report. | All Approved Vendors, Designees, and Nested Designees who intend to participate in the Illinois Shines program during the relevant PY. Entities certified as Equity Eligible Contractors (“EECs”) do not need to provide a Compliance Plan |
Individual plans will not be posted publicly. Minimum Equity Standard (“MES”) Compliance Plans, Mid-Year Reports, Year-End Reports, and any other reporting of data will not be made public as a matter of course, however they may be subject to the Illinois Freedom of Information Act (“FOIA”). The Agency will release aggregated data from end of year MES reports tracking achievement of the MES across the market but will not identify any individual entities. The Agency will provide confidential treatment to MES reports in accordance with the provisions of Section 2.F of the Program Guidebook.
The review process for the Minimum Equity Standard (“MES”) Compliance Plan is described in Section 7.B of the April 2024 version of the Program Guidebook and Section 10.1.5.1 of the 2024 Long-Term Plan.
Compliance Plans must include the following items:
i. Company and contact information.
ii. Attestation affirming intent to comply with requirements related to the Minimum Equity Standards.
iii. Disclosure of any categories that apply to the business, including:
- Minority-owned Business Enterprise (“MBE”)
- Woman-owned Business Enterprise (“WBE”)
- Disabled-owned Business Enterprise
- Veteran-owned Business
- Small Business
iv. A narrative description of how the company will ensure that at least 10% of its project workforce are Equity Eligible Persons.
v. Disclosure if the entity works with subcontractors that are not registered as Designees (for accurate calculation of project workforce).
vi. Projected total project workforce subject to the MES requirements.
vii. Estimated number of Equity Eligible Persons (“EEPs”) currently in project workforce.
viii. Projected number of EEPs entity seeks to hire to meet MES compliance.
ix. Plans for the use of Equity Eligible Contractors (“EECs”), if applicable.
x. Any known or projected use of non-EEC Designees (for tracking Plans related to the same projects).
xi. Communication plan for local outreach to increase the utilization of EEPs and EECs.
xii. Status of any corrective actions or adjustments from prior Compliance Plans.
Compliance Plan Evaluation, Rating and Correction Processes:
- Submitted Compliance Plans will be reviewed to confirm that all required information has been provided.
- Completed Compliance Plans are reviewed and either approved or denied.
- If a Compliance Plan is denied, the Approved Vendor or Designee will have an opportunity to revise and re-submit their Compliance Plans.
The review process for the Minimum Equity Standard (“MES”) Year-End Report is described in Section 7.B of the April 2024 version of the Program Guidebook. Within 45 days after the end of the Delivery Year/Program Year, each Approved Vendor or Designee must submit a Year-End Report. If the entity has not performed an activity during the relevant year that constitutes as Program participation, that may be indicated on the Year-End Report and compliance obligations will not apply. The Year-End Report will confirm or update information from the original Compliance Plan including data on actual performance. The Year-End Report should reflect any major differences from the Compliance Plan such as changes in project workforce, or innovative ways to provide employment opportunities to Equity Eligible Persons (“EEPs”) and residents of environmental justice communities.
Data and information required to be submitted via the MES Year-End Report includes:
- Approved Vendor and Designee information
- Project workforce total
- Project workforce demographic and geographic information
- EEP workforce totals, including proof of EEP eligibility and any supporting documentation for any EEPs not registered in the IPA’s Energy Workforce Equity Portal (e.g., for individuals that qualify based on residency in an Equity Investment Eligible Community [“EIEC”], submission of proof of primary residence will be required)
- Description of outreach efforts employed by the Approved Vendor or Designee to recruit EEPs
- Job training program graduate hiring data, Illinois-based workforce diversity data
- Other diversity and workforce data previously collected during the Annual Report
Year-End Report Evaluation, Rating and Correction Processes:
- Submitted Year-End Reports will be reviewed to confirm that all required information has been provided.
- Year-End Reports are reviewed to see if the submitter met the MES requirements
- If a Year-End Report is denied, the Approved Vendor or Designee will have an opportunity to revise and re-submit their Year-End Report or submit an MES Waiver
The Program Administrator will notify the applicant in writing of the score for their Compliance Plan within 14 of submission. If corrections or amendments to the Compliance Plans are required, the applicant will have 30 days to submit amendments. Applicants may request extensions to that window that will be granted by the Agency on a case-by-case basis. After resubmittal of a corrected Compliance Plan, the Program Administrator will notify the applicant in writing of the final re-evaluation status. The Program Administrator will notify the program participant of final acceptance of the Compliance Plan within 21 days. The Agency will accept multiple revisions of a proposed Compliance Plan. The Agency and Program Administrator will strive to meet the timelines listed above, but extensions may be necessary during periods of high volumes of Compliance Plan submissions.
An Approved Vendor or Designee that fails to submit a Minimum Equity Standard (“MES”) Compliance Plan by the first day of the Delivery Year/Program Year or the MES Year-End Report 45 days after the end of the Delivery Year/Program Year will receive communication from the Program Administrator explaining how to cure this violation. Entities that fail to cure or entirely fail to submit a Compliance Plan or Year-End Report will be subject to disciplinary action, which may include suspension from the Program.
Failure to submit a Mid-Year Report will not result in disciplinary action, but the Mid-Year Report does provide an opportunity to show progress toward meeting the Minimum Equity Standard (“MES”). If an organization is struggling to meet MES requirements, the Program Administrator will reach out to share additional resources and guidance. Failure to submit a Mid-Year Report may negatively affect an organization’s request for a waiver.
Yes, the Program Administrator has published a list of EEC certified Approved Vendors and EEC certified Designees. This information can also be found on the Energy Equity Portal.
Minimum Equity Standard (“MES”) requirements are separate from Traditional Community Solar and Community-Driven Community Solar scoring. However, failure to comply with the MES may lead to disciplinary action, including suspension from the Program.
Equity Accountability System resources, including past webinars, can be found at: https://illinoisshines.com/equity-accountability-system/.
There is no required verbiage that entities must use on job postings. However, entities are encouraged to utilize the IPA’s Energy Workforce Equity Portal to connect with perspective Equity Eligible Persons employees.
The threshold to qualify for a waiver from compliance with the Minimum Equity Standard is a score of 20 points or above. Information on the waiver contents and how to submit a waiver can be found at https://illinoisshines.com/equity-accountability-system/.
Identifying EEPs
Equity Investment Eligible Communities (“EIEC”) are geographic areas throughout Illinois which would most benefit from equitable investments by the State designed to combat discrimination. The eligible communities are: (1) R3 Areas as established pursuant to Section 10-40 of the Cannabis Regulation Tax Act, where residents have historically been excluded from economic opportunities, including opportunities in the energy sector; and (2) Environmental justice communities, as defined by the Illinois Power Agency (“IPA”) pursuant to the Illinois Power Agency Act, where residents have historically been subject to disproportionate burdens of pollution, including pollution from the energy sector.
As announced on September 28, 2023, the IPA updated the EIEC map to reflect the new Solar for All Environmental Justice Community map.
As of April 29, 2024, the IPA’s Equity Investment Eligible Community map has been refreshed to include the updated R3 Areas. These R3 Area designations were determined through a process conducted by the Illinois Criminal Justice Information Authority (“ICJIA”) regarding the R3 maps. For this process, ICJIA utilized the new 2020 census and geography information, unemployment indicators, child poverty indicators, and reflected a five-year time span.
Equity Eligible Investment Communities are comprised of R3 Areas as established pursuant to Section 10-40 of the Cannabis Regulation and Tax Act, where residents have historically been excluded from economic opportunities, including opportunities in the energy sector; and Environmental justice communities, as defined by the IPA pursuant to the IPA Act, where residents have historically been subject to disproportionate burdens of pollution, including pollution from the energy sector.
For Program Year 2024-25, the EIEC map, will include both the updated R3 Areas identified through new analysis and previously identified R3 Areas. On June 3, 2024 the IPA refreshed the EIEC map for Program Year 2024-25. This updated map reflects the removal of previously eligible 2022 Environmental Justice Community (EJC) areas used in Program Year 2023-24. This update increases the total number of R3 Areas in central and southern Illinois.
Equity Eligible Persons’ (“EEPs”) status based on residency may be affected by the changes. As stated in Section 10.1.1. of the 2024 Long-Term Plan, the IPA will incorporate the R3 map updates while continuing to consider areas from the previous R3 map as EIECs for the 2024-25 Program Year. The R3 map is expected to be updated every four years. For individuals whose EEP status is affected by the EIEC map update, their status will change at the next recertification – i.e., two years after they first certify for workforce EEPs and at the next registration renewal for EEPs that are majority-owners of Equity Eligible Contractors (“EECs”). For EECs that may lose the status of EEC due to a majority-owner EEP no longer qualifying as an EEP, any projects already under contract through the EEC Category will not be affected by that loss of status. Similarly, any projects that have received points in project selection due to contracting with an EEC Designee will not be penalized for a downstream change in the EEC status of that Designee due to a map update.
The IPA plans for previously eligible areas no longer identified as R3 Areas to be removed from the EIEC map on June 1, 2025.
Lastly, as part of the EIEC map refresh, the IPA has updated the EIEC map instructions to improve the user experience. Furthermore, the EIEC map shapefiles are now available to the public. These enhancements reflect the IPA’s ongoing commitment to transparency and accessibility around Diversity, Equity, and Inclusion (“DEI”) initiatives. For questions, please contact [email protected].
No, the Equity Investment Eligible Communities’ (“EIEC”) boundaries do not precisely align with zip code boundaries, as they are based upon other data. Employers are highly encouraged to ask employees to certify through the Energy Workforce Equity Portal to make the process simpler.
An entity reporting on the makeup of its project workforce must be able to demonstrate that an Equity Eligible Person (“EEP”) qualified based upon residency resided in the qualifying location when the employee was hired. This can be demonstrated by the date displayed on the supporting documents (such as a driver’s license or other identification, utility bill, lease agreement, etc.) or through registration by the EEP on the Energy Workforce Equity Portal. The Agency highly recommends that employers request their employees that qualify on residency to register through the Energy Workforce Equity Portal. The Agency will require an individual who qualifies as an EEP based upon residency to recertify within the portal every two years.
“Formerly Incarcerated” means any individual who (i) was sentenced to a term of imprisonment, not including juvenile detention, after the disposition of one or more misdemeanor or felony charges; and (ii) has completed their sentence. Determinations will be made on a case-by-case basis. For Equity Eligible Person (“EEP”)-individuals who qualify based upon their status as a formerly incarcerated person, the Agency strongly encourages employers to ask all of their employees to register with the Energy Workforce Equity Portal if they have concerns about asking individual employees for sensitive information regarding formerly incarcerated status.
There is no time limit on how long ago the incarceration occurred. At this time, the IPA is requesting an attestation from the individual that they indeed were incarcerated following conviction. An attestation for can be found at: https://illinoisshines.com/wp-content/uploads/2024/04/EEP-Attestation-Form-vFeb2024.pdf
There is no requirement that the person who is an enrollee or graduate of the foster care system was a part of the system within the State of Illinois. For the purpose of eligibility to be an EEP, a “graduate or enrollee” of the foster care system refers to an individual who is currently or was formerly a youth in care of the Illinois Department of Children and Family Services, or the equivalent agency in another state. Individuals who act as foster parents do not qualify under this criterion.
Equity Eligible Persons (“EEPs”) are highly encouraged to seek certification through the Energy Workforce Equity Portal. Illinois law requires that the Program verify the status of every EEP, so submitting entities/employers (Approved Vendors, Designees, or utility-scale developers) will need to provide those verifications with their Minimum Equity Standard Year–End Report, if EEPs do not seek certification through the Equity Portal. EEPs are able to certify through the Energy Workforce Equity Portal without having to reveal sensitive information to employers. If an EEP does not have access to the internet or is otherwise unable to register themselves in the Equity Portal, they can contact the Program Administrator or their employer for assistance.
Registering on the Energy Workforce Equity Portal allows employees to certify as Equity Eligible Persons (“EEPs”) without disclosing sensitive information directly to their employer. Employees who do not want to register on the Equity Portal can be registered via EEP Attestation. Employers are responsible for ensuring that EEP Attestations and supporting documentation are properly submitted.
The Equity Portal contains information voluntarily provided by individuals and gives permission for that information to be shared with prospective employers. There is no comprehensive listing of all Equity Eligible Persons (“EEPs”) in the state, so the Agency is working with the Illinois Department of Commerce and Economic Opportunity (“DCEO”), other state agencies, and community organizations to conduct outreach to educate individuals and communities about the Equity Portal and assist EEPs in certifying their status as an EEP. The Agency is working to make sure as many people as possible have access to this database.
In order to reach as many potentially qualified Equity Eligible Persons (“EEPs”) as possible, the IPA and the Program Administrator are providing outreach to EEP-qualifying training programs. The IPA is working with Department of Commerce and Economic Opportunity (“DCEO”) to obtain additional training program information and will provide that information when it is available. Please note only the Solar Training Pipeline and the Multicultural Jobs Programs created and funded by Future Energy Jobs Act (“FEJA”) qualify individuals as an EEP due to the requirements of Climate and equitable Jobs Act (“CEJA”) (P.A. 102-0662). A list of CEJA and FEJA workforce training programs that qualify individuals to become EEPs can be found on the Employers page of the Energy Workforce Equity Portal.
Identifying the Project Workforce
For the purposes of the Minimum Equity Standards, the IPA defined “project workforce” as the following:
“Employees, contractors and their employees, and subcontractors and their employees, whose job duties are directly required by or substantially related to the development, construction, and operation of a project that is participating in or intended to participate in the IPA-administered programs and procurements under Section 1-75(c) of the IPA Act. This shall include both project installation workforce and workforce in administrative, sales, marketing, and technical roles where those workers’ duties are performed in Illinois.”
The Agency received feedback from Program participants regarding challenges with the current approach. According to feedback, the breadth of occupations included in the project workforce makes it difficult to fully define which persons and subcontractors are part of the workforce for a given project, particularly if some of those positions include significant work performed out of state or are services requiring a relatively small portion of project hours (e.g., a surveyor assessing a site for two hours). Therefore, the ICC approved this change Final Order at 155, ICC Docket No. 23-0714:
For purposes of this definition, ‘directly required by or substantially related to’ shall be construed to be any direct employee of the Approved Vendor, Designee, or Indexed REC contract holder, or any contractor and its employees whose contract exceeds 5% of the REC Contract value. Employees of contractors below that threshold may be counted toward the MES on a voluntary basis, but then all contractors below the 5% of REC contract value threshold must be included.
To further clarify, an entity’s project workforce for a given Program Year will include individuals employed, either directly or through contractors or subcontractors, during that Program Year who work on projects either already participating in Illinois Shines or that are intended to participate in Illinois Shines. The scope is any work performed in service of a project during that Program Year, across types of projects and types of work.
(Updated July 12, 2024)
The 5% REC Contract value threshold for project workforce is project-specific. For example, if a subcontractor worked on 8 projects, the percentage of REC Contract value would need to be determined for each of those projects.
(Updated July 12, 2024)
The 5% contract exception applies uniformly to all subcontractors, regardless of whether they are hired through a staffing agency. This means that either all subcontractors with less than 5% of the REC Contract value are counted towards the project workforce, or none are.
(Updated July 12, 2024)
When determining its project workforce, companies may either count all subcontractors with less than 5% of the REC Contract value, or none at all. It is not permitted to choose to count some contractors under the threshold towards the project workforce and not others.
(Updated July 12, 2024)
Equity Eligible Persons (“EEPs”) can be hired at any time during the Delivery Year/Program Year for compliance with the Minimum Equity Standard (“MES”).
If there is any reason to believe that an entity is utilizing suspicious hiring practices, such as hiring EEPs for a limited amount of time solely in order to meet the MES, hiring an EEP but not assigning them hours, or otherwise attempting to subvert Program requirements, those cases will be promptly reviewed by the Agency and the Program Administrator.
For the purposes of the Minimum Equity Standard (“MES”), “project workforce” includes: employees, contractors and their employees, and subcontractors and their employees, whose job duties are directly required by or substantially related to the development, construction, and operation of a project that is participating in or intended to participate in the IPA-administered programs and procurements under Section 1-75(c) of the IPA Act. This shall include both project installation workforce and workforce in administrative, sales, marketing, and technical roles where those workers’ duties are performed in Illinois. For purposes of this definition, ‘directly required by or substantially related to’ shall be construed to be any direct employee of the Approved Vendor, Designee, or any contractor and its employees whose contract exceeds 5% of the REC Contract value. Employees of contractors below that threshold may be counted on a voluntary basis, but if the Approved Vendor or Designee includes at least one such contractor whose contract is less than 5% of the REC Contract value, then all contractors below the threshold must be included.
Employees That Do and Do Not Count Toward the MES
Type of Worker | Should they be counted toward the project workforce for the MES? |
Designees/Nested Designees | No, Approved Vendors do not need to include the workforce of their Designees in their MES but shall report which Designees they worked with in the Delivery Year/Program Year to allow the Agency to correlate activities and compliance |
Temporary or Part-Time Workers | Yes |
Subcontractors | Yes |
Pre-Construction Work | Yes |
Admin Work | Yes |
One-Time Subcontractors (surveyors, consultants, etc.) | Yes |
Employees who do not perform work duties in Illinois (including any of the above) | No |
The Agency understands the primary policy objective of Section 1-75(c-10) of the IPA Act as advancing equity across Illinois by providing access to the Illinois clean energy economy for businesses and workers from Illinois communities that historically have been excluded.
Therefore, the relevant location is where the work is performed as that is the location of the economic opportunity. Only workers whose duties are performed in Illinois are included in the IPA’s “project workforce” definition for Minimum Equity Standard (“MES”) compliance in Illinois Shines. Employees who perform duties in Illinois that are related to developing projects or educating consumers about Program options should be included in the project workforce.
While the IPA understands that project labor crews and locations vary, applicants do not need to include office workers who work outside of Illinois in their project workforce. Non-construction employees doing work outside of Illinois are not included in the project workforce for the MES, regardless of where they live. Such an outcome would not serve the purpose the MES, which is intended to increase access to clean energy jobs for Illinois workers.
Individuals who perform work in Illinois do count towards the project workforce, regardless of where they live. Only workers whose duties are performed in Illinois are included in the IPA’s “project workforce” definition for Illinois Shines.
If an Approved Vendor or Designee’s project workforce for a given Delivery Year/Program Year is less than 10 people, they should aim to employ one Equity Eligible Person (“EEP”) and provide a Compliance Plan that outlines how they will strive to recruit an EEP in the event that they hire during that year. If the company has not hired anyone during the Delivery Year/Program Year, they will be able to submit an attestation stating so on the Minimum Equity Standard Year-End Report. Please reach out to the Program Administrator if there are questions with compliance and support/guidance can be provided.
The Minimum Equity Standard (“MES”) is not limited to construction. Per Chapter 10 of the Long-Term Renewable Resources Procurement Plan, project workforce includes “employees, contractors and their employees, and subcontractors and their employees, whose job duties are … in administrative, sales, marketing, and technical roles where those workers’ duties are performed in Illinois.”
If an Approved Vendor has projects participating in the Program, any employees performing duties in Illinois substantially related to those projects must count toward meeting the MES for that Delivery Year/Program Year, even if construction will not occur that year. The MES applies to any work conducted in a given Delivery Year/Program Year on projects that are participating in IPA programs.
Yes, temporary and/or part-time employees or subcontractors performing work on the project count toward the Minimum Equity Standard.
The Minimum Equity Standard (“MES”) is based upon the number of individuals, not number of hours worked. Part-time employees, one-time contractors, or other employees with limited number of hours count towards the MES as long as they fit within the definition of “project workforce”, as referenced elsewhere in these FAQs.
Employees of contractors below 5% REC Contract value may be counted on a voluntary basis, but if the Approved Vendor or Designee includes at least one such contractor whose contract is less than 5% of the REC Contract value, then all contractors below the threshold must be included.
Pre-construction work completed in Illinois, including siting and permitting, is included in the definition of project workforce and therefore counts toward the Minimum Equity Standard and should be reported on.
Approved Vendors participating in Illinois Shines do not need to report on employee level data regarding their Designees, but must report which Designees they worked with in the Delivery Year/Program Year to allow the Agency to correlate activities and compliance. This is not meant to relieve Approved Vendors of responsibility to comply with the Equity Accountability System, but rather to ensure that efforts are not double counted.
If the contractor/subcontractor is itself a Designee, then the Approved Vendor does not need to include those workers in their project workforce because that Designee will be submitting its own data on their project workforce. All the Approved Vendor needs to do is indicate which Designees it is working with, for our own tracking purposes to make sure that Designee reports data for that project. Likewise, “nested” Designees should report on their own workforce.
If subcontractors are not also Designees, then they are included in the submitter’s project workforce, and the submitter must report all of the demographic data associated with those workers.
To further clarify, if either an Approved Vendor or Designee uses contractors or subcontractors that are not themselves a registered Designee, and therefore do not need to submit their own Minimum Equity Standard Compliance Plan and Year-End Report, those workers should be included in the employing Approved Vendor/Designee’s project workforce for that Compliance Plan or Year-End Report.
Entities Subject to Minimum Equity Standard (“MES”) Requirements
All Approved Vendors and Designees, with the exception of those who are Equity Eligible Contractor (“EEC”)-certified, are required to comply with the Minimum Equity Standard (“MES”). Approved Vendors do not need to include the workforce of their Designees in their MES reports, but must indicate which Designees they worked with in the Delivery Year/Program Year to allow the Agency to correlate activities and compliance. This is not meant to relieve Approved Vendors of responsibility to comply with the Equity Accountability System, but rather to ensure that efforts are not double-counted.
If the reporting company works with subcontractors that are not Designees, then the employees of those subcontractors are included in the Approved Vendor’s project workforce and count toward the MES, since those contractors or subcontractors will not report on the MES independently.
Nested Designees, as registered Designees within the Program, will need to comply with the Minimum Equity Standard (“MES”) and submit a Compliance Plan, Mid-Year Report, and Year-End Report related to their compliance with the MES.
Because the Minimum Equity Standard (“MES”) Compliance Plan is a plan for the year ahead, the Agency understands that circumstances may require adjustments to that plan. Still, MES Compliance Plans should show the intention for compliance with the MES in the upcoming year. The submitting company will confirm which Designees it did end up working with in the MES Year-End Report.
To meet the Minimum Equity Standard (“MES”), Approved Vendors do not necessarily have to work directly with Equity Eligible Contractors (“EECs”); the requirement is that an Approved Vendor’s workforce must meet the MES for a given Delivery Year/Program Year, and that can be achieved without EECs. However, the project workforce is defined to include all non-Designee contractors, subcontractors, and the employees of subcontractors. A non-Designee general contractor is included in the MES calculations, and all subcontracted workers are included in the project workforce for an Approved Vendor. The Approved Vendor does not need to hire the entirety of the workforce directly, but must ensure that the entirety of their project workforce (which includes non-Designee contractors) is in compliance with the MES.
Approved Vendors and Designees who are Equity Eligible Contractors (“EECs”) are, by virtue of their participation in the Program as an EEC, in full compliance with the Equity Accountability System and thus do not need to submit a Compliance Plan. However, EECs will need to report on the demographic and geographic data of their employees via the Minimum Equity Standard Year-End Report, just as other entities do.
Utilization of the capacity in the Equity Eligible Contractor (“EEC”) category is limited to Approved Vendors who qualify as an EEC. EEC Approved Vendors may choose to work with Designees or subcontractors or completely on their own, and those Designees or subcontractors may or may not be also EEC certified.
However, Approved Vendors that do not qualify as an EEC but partner with a Designee or subcontractor that does qualify as an EEC are ineligible to participate in the EEC category. These Approved Vendors must submit their projects to another Program category.
Utilization of EEC certified Designees could have an impact on Community Solar project scoring. Please see more information in the Program Guidebook, as certain scores in this category are dependent on utilization of EECs for project development work.
Approved Vendors are only required to include their direct employees and employees of non-Designee subcontractors in the project workforce identified in their Minimum Equity Standard (“MES”) Compliance Plan and MES Year–End Report. Designees must submit their own MES Compliance Plan and MES Year-End Report encompassing the Designee’s project workforce. A field is present in the MES Compliance Plan form where Approved Vendors and Designees may indicate whether they are working with another Approved Vendor or Designee on any of the projects in the relevant Delivery Year/Program Year.
Scope of Participation in Program or Procurement
An Approved Vendor is not responsible for submitting a Designee’s Minimum Equity Standard (“MES”) Compliance Plan or MES Year-End Report, but a non-compliant Designee could affect the progress of a project in a number of ways.
If a project has yet to be Part II verified, it could result in the project not moving forward until the Designee has come into compliance with MES requirements, or the Approved Vendor has ceased working with the Designee that is out of compliance.
If a Designee is out of compliance after the project has been Part II verified and construction has been completed, and the Designee is not involved in ongoing management of the system, the project will still be able to participate in the Program. If the Designee is still involved with the project after Part II verification (for example, a Designee responsible for subscriber management of a Community Solar project), the project is at risk of not moving forward until the Designee is in compliance or the Approved Vendor ceases working with that Designee.
If a Designee continues to demonstrate non-compliance, the Approved Vendor may be required to present a Designee Management Plan to the Program Administrator and IPA, as outlined in the Consumer Protections Handbook. Continued non-compliance could result in disciplinary action and affect project status.
There are two determinations necessary for calculating whether an entity has met the Minimum Equity Standard (“MES”): the size of the relevant project workforce (the denominator), and the number of Equity Eligible Persons (“EEPs”) employed in that workforce (the numerator). The project workforce is defined as: employees, contractors and their employees, and subcontractors and their employees, whose job duties are directly required by or substantially related to the development, construction, and operation of a project that is participating in or intended to participate in the IPA-administered programs and procurements under Section 1-75(c) of the IPA Act. This shall include both project installation workforce and workforce in administrative, sales, marketing, and technical roles where those workers’ duties are performed in Illinois. For purposes of this definition, ‘directly required by or substantially related to’ shall be construed to be any direct employee of the Approved Vendor, Designee, or any contractor and its employees whose contract exceeds 5% of the REC Contract value. Employees of contractors below that threshold may be counted on a voluntary basis, but if the Approved Vendor or Designee includes at least one such contractor whose contract is less than 5% of the REC Contract value, then all contractors below the threshold must be included.
Please see the example below for a company that has 100 employees, 15 of which are EEPs.
15 𝐸𝐸𝑃𝑠 ÷ 100 𝐸𝑚𝑝𝑙𝑜𝑦𝑒𝑒𝑠 = 15%
Once the number of individuals within the project workforce has been established, an entity can calculate the portion of its workforce which must be comprised of equity eligible persons or contractors in order to meet the MES. The required percentage to meet the MES is outlined in the current version of the Long-Term Plan. An Approved Vendor or Designee may not meet the MES solely through contracting with an EEC that makes up the required percentage of the overall project workforce. Instead, the Approved Vendor or Designee must include the employees of that EEC in the denominator (described above) of the calculation.
The Agency will count EEPs employed by an EEC-certified contractor or subcontractor, including the EEP majority owner, 1.5 times in calculating compliance with the MES. In this way, an Approved Vendor or Designee will more easily meet the MES if they contract with an EEC, but that alone will not be enough. Additionally, the IPA has determined that an Approved Vendor that subcontracts with an EEC on a project and yet is unable to meet the MES will receive additional points towards a request to seek an MES waiver for the project.
Yes, the company will still count the Equity Eligible Person (“EEP”) majority owner at 1.5x in the project workforce, but not the non-EEP employees working on the project, who will be counted in the denominator.
Equity Eligible Contractor (“EEC”) Designees do not need to demonstrate compliance with the Minimum Equity Standard (“MES”). The Agency will count Equity Eligible Persons (“EEPs”) employed by an EEC-certified subcontractor, including the EEP majority owner, 1.5 times in calculating the Approved Vendor’s compliance with the MES for the projects on which the EEC Designee works. Additionally, an entity that subcontracts with an EEC on a project and yet is unable to meet the MES will receive additional points towards the waiver request for the project.
If an Approved Vendor or Designee’s project workforce for a given Delivery Year/Program Year is small enough that reaching the Minimum Equity Standard (“MES”) would be <1 person, they should aim to employ one Equity Eligible Person (“EEP”) and provide a Compliance Plan that outlines how they will strive to recruit an EEP in the event that they hire during that year. If the company has not hired anyone during the Delivery Year/Program Year, they will be able to submit an attestation stating so on the MES Year-End Report. Please reach out to the Program Administrator if there are questions with compliance and support/guidance can be provided.
Compliance with the Minimum Equity Standard (“MES”) is viewed across the totality of an entity’s Illinois project workforce, both in terms of planning and reporting. The Program Administrator and the Agency will consider any waiver granted in determining the relevant project workforce size and whether an entity has met the MES requirements.
The scheduled plan for the Minimum Equity Standard (“MES”) can be found in the current, approved Long-Term Plan. Program participants must submit the MES Year-End Report on how it achieved the MES for the activities in the last Delivery Year/Program Year within 45 days following the end of the Delivery Year/Program Year.
For projects where work spans several Delivery Years/Program Years, participants should report on the work conducted in each year, regardless of if the project was completed during that time. For example, the employees that performed administrative work on a project Part I submitted in the 2023-24 Delivery Year/Program Year, assuming those employees did their work in Illinois, would be included in the project workforce for the 2023-24 Delivery Year/Program Year. If the project installation for this same project did not occur until the subsequent Delivery Year/Program Year, then the installation workforce would be included toward meeting the MES of that Delivery Year/Program Year in which the project was installed.
The MES, displayed through the Compliance Plan and Year-End Report, will apply to work that has happened in that Delivery Year/Program Year. As a reminder, the project workforce can include office workers if they are performing their duties in Illinois. If the company had a project participated in the Program (e.g., a Part I application was submitted), has staff whose duties on the project are performed in Illinois, even if construction is not beginning that year, the MES would apply to this workforce. The MES applies to work conducted in a given Delivery Year/Program Year on projects that are participating in IPA programs.
If an Approved Vendor or Designee has no activity during a Delivery Year/Program Year, that may be indicated on the Minimum Equity Standard (“MES”) Year-End Report and compliance obligations will not apply.
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.
Energy Workforce Equity Portal
The Energy Workforce Equity Portal is a publicly accessible database of clean energy vendors and subcontractors, including Equity Eligible Contractors.
(Updated January 2023)
This portal is intended to provide useful information to those looking to work in the renewable energy sector in Illinois, individuals who are looking to certify as Equity Eligible Persons, companies already participating in IPA programs and procurements that need to comply with the minimum equity standard, companies looking to qualify as Equity Eligible Contractors, and anyone interested in learning more about what the IPA and DCEO are doing to ensure an equitable energy transition and clean energy economy.
(Updated January 2024)
The Climate and Equitable Jobs Act is the colloquial name for Public Act 102-0662, a piece of legislation passed by the Illinois General Assembly and signed by Governor J.B. Pritzker on September 15, 2021. The Climate and Equitable Jobs Act, or “CEJA”, expanded and updated the existing programs run by the IPA that issue incentives for distributed solar generation projects. Those programs are Illinois Shines and Illinois Solar for All. CEJA added new provisions to those programs and to the IPA’s competitive procurements for utility-scale renewable energy that seek to ensure that the Illinois clean energy economy is inclusive and accessible to communities that have been historically excluded from economic opportunities and that have suffered disproportionate levels of environmental pollution and hazards.
(Updated January 2023)
The Illinois Power Agency, or “IPA”, is an independent state agency established in 2007 by the Illinois Power Agency Act. The mission of the Agency is the planning and procurement of reliable, efficient, and cost-effective electricity for residents and businesses in an ethical and objective manner, insulated from improper influence. The IPA also administers incentive programs and procurements to promote renewable and zero-carbon energy generation, while building an equitable clean energy future for all Illinoisans.
(Updated January 2023)
CEJA created five main workforce training programs: the Clean Jobs Workforce Network Program, the Clean Energy Contractor Incubator Program, the Illinois Climate Works Preapprenticeship Program, Returning Residents Clean Jobs Training Program, or the Clean Energy Primes Contractor Accelerator Program.[1] These programs are run by the Department of Commerce and Economic Opportunity. Please see the workforce trainings program page of this website for more information.
[1] See Sections 5-20, 5-40, 5-45, 5-50, and 5-55 of the Energy Transition Act.
(Updated January 2023)
The Illinois Shines and Illinois Solar for All programs are the non-competitive programs that provide incentives for installing solar distributed generation projects and community solar projects. The overall purpose of these programs is to encourage the installation of solar energy projects, to reduce the cost of adopting solar for Illinois residents, and to ensure that low- and moderate-income residents have access to the benefits of solar energy, such as decreased utility bills.
These incentive programs provide payments based on the size of the project and the number of “Renewable Energy Credits” the project will generate. A Renewable Energy Credit (“REC”) is a tradable credit that represents the environmental attributes of the energy produced from a renewable energy resource. One REC represents the environmental benefit (e.g., the reduction in emissions) associated with 1 MWh of energy generated by a renewable energy source.
Approved Vendors (solar developers and contractors participating in the IPA’s solar incentive programs) receive incentives through Illinois Shines or Illinois Solar for All in exchange for the RECs produced by the project, which then count toward meeting the level of renewable energy generation required under Illinois law. The incentive payments in turn reduce the cost of the project for the resident/consumer that purchases it.
(Updated January 2023)
An Equity Eligible Person (“EEP”) is a person that “would most benefit from equitable investments by the State designed to combat discrimination,” and CEJA provided four specific characteristics that would qualify a person as an EEP:
- Graduates or current or former participants in the Clean Jobs Workforce Network Program, Clean Energy Contractor Incubator Program, Illinois Climate Works Preapprenticeship Program, Returning Residents Clean Jobs Training Program, or the Clean Energy Primes Contractor Accelerator Program, and the solar training pipeline and multicultural jobs program created by Future Energy Jobs Act
- Persons who are graduates of or currently enrolled in the foster care system
- Persons who were formerly incarcerated
- Persons whose primary residence is in an equity eligible investment community
CEJA requires companies participating in the Illinois Shines program and in the competitive procurements for utility-scale renewable projects to employ a workforce that includes a minimum percentage of Equity Eligible Persons. Thus, CEJA requires participating companies to hire workers that are members of communities that have historically been excluded from economic opportunities, and in this way accomplishes the legislative objective of ensuring an equitable and inclusive clean energy economy.
(Updated January 2023)
Equity Investment Eligible Community is defined by statute as is either an Environmental Justice Community as defined by Illinois Solar for All, or an R3 Program Community (Restore, Reinvest and Renew Program, designated by the Illinois Cannabis Regulation and Tax). For maps and address lookup tools for these two types of areas see the Environmental Justice Communities map on Illinois Solar for All website and R3 Program Community map respectively.
(Updated January 2023)
Please reach out to the Program Administrator of the Illinois Shines program, Energy Solutions, for any questions regarding eligibility for certification as an EEP or EEC. See the “Contact Us” page of this website for more information.
(Updated January 2023)
The Minimum Equity Standard (“MES”) is the minimum portion of the workforce of an entity seeking to participate in Illinois Shines or a competitive procurement that must consist of EEPs. For the delivery year of 2023-2024, the MES is 10%. For more information, please see the current Program Guidebook.
(Updated January 2023)
Approved Vendors, Designees, and other entities seeking to hire EEPs should work with local partners such as workforce training programs, community colleges, and community-based organizations that work with returning residents and residents of equity investment eligible communities in order to identify potential EEPs.
(Updated January 2023)
Please visit CEJA-funded workforce training programs page within the Illinois Department of Commerce and Economic Opportunity for more information about upcoming funding opportunities for establishing a CEJA-funded training program.
(Updated January 2023)
The “For Job Seekers” section of this website includes a list of currently operating workforce training programs that would qualify a person as an EEP. Please contact those workforce training programs for more information on enrollment windows.
(Updated January 2023)
Equity Eligible Contractors (EECs)
An Equity Eligible Contractor (“EEC”) is a business that is majority-owned by eligible persons, a nonprofit or cooperative that is majority governed by eligible persons, or is a natural person that is an eligible person offering personal services as an independent contractor. EECs may be EEC Approved Vendors, EEC Designees, or EEC Subcontractors. More information on the distinctions between these three types of EECs can be found on the Become an EEC webpage.
(Updated June 2024)
Equity Eligible Contractors (“EECs”) are eligible for several benefits within the Illinois Shines program. For example, EEC certified Approved Vendors are eligible to submit projects to the Equity Eligible Contractor block within Illinois Shines, which also enables them to request an advance of incentive capital to support project development costs upon Part I application submission. Please see the EEC Contractor page of the Program website for more information on how to become EEC certified and the benefits of participating in IPA programs.
(Updated June 2024)
Yes, the Program Administrator maintains a list of EEC certified Approved Vendors, EEC certified Designees, and EEC certified Subcontractors.
(Updated June 2024)
The IPA can assure applicants that all personally identifiable information and other sensitive, confidential information shared with the Agency for the purpose of meeting the Minimum Equity Standard will be appropriately and securely handled. For more information on confidentiality of information in the Program please see Section 2.F of the Program Guidebook.
(Updated June 2024)
Utilization of the capacity in the Equity Eligible Contractor (“EEC”) category is limited to Approved Vendors who qualify as an EEC. EEC Approved Vendors may choose to work with Designees and Subcontractors or on their own, and those Designees or Subcontractors may or may not be also EEC certified. However, Approved Vendors that do not qualify as an EEC but partner with a Designee or Subcontractor that does qualify as an EEC are ineligible to participate in the EEC category. These Approved Vendors must submit their projects to another Program category. Utilization of EEC certified Designees or Subcontractors can have an effect on Traditional Community Solar scoring. Please see more information in Appendix E of the Program Guidebook.
(Updated June 2024)
For EECs that lose their status due to their majority-owner EEP no longer qualifying as an EEP due to a change in the Equity Investment Eligible Community (“EIEC”) map, their contracted projects in the EEC category will not be affected by that loss of status. Similarly, any projects that have received points in project selection due to contracting with an EEC Designee will not be penalized for a downstream change in the EEC status of that designee due to a map update.
For EECs that lose their status due to their majority-owner EEP no longer qualifying as an EEP due to another reason, their contracted projects in the EEC category must either be assigned to a qualified EEC Approved Vendor, they must be majority-owned by a new EEP, or they will be in violation of the terms of the REC Contract.
(Updated June 2024)
If an EEC Approved Vendor ceases to have qualifying ownership, that Approved Vendor will no longer be an EEC and will have to either assign their REC Contracts to another EEC or will be in violation of the terms of the REC Contract.
Bankruptcy is an event of default under the REC Contract. The REC Contract allows for an Approved Vendor to collaterally assign the REC Contract or pledge the accounts, revenues or proceeds in connection with a financing agreement. If the EEC Approved Vendor ceases to have qualifying ownership through any involuntary change in control, that Approved Vendor will no longer be an EEC and will have to either assign the REC Contract to another EEC Approved Vendor or will be in violation of the terms of the REC Contract.
(Updated June 2024)
An EEP is allowed to serve as the majority-owner of one EEC Designee and one EEC Approved Vendor, which may be separate legal entities. EEPs that serve as the majority-owner of an EEC Approved Vendor may not serve as the majority-owner EEP for more than one EEC Approved Vendor, except for the case of Single-Project Approved Vendors (“SPAVs”). An EEC SPAV may indicate their parent EEC Approved Vendor as the majority-owner of their SPAVs, instead of the majority-owner EEP. Note that affiliated EEC SPAVs will share the same developer cap in the EEC and Traditional Community Solar (“TCS”) categories as their affiliated parent EEC Approved Vendor.
(Updated June 2024)
Equity Eligible Contractors (EECs) are considered in full compliance with the Minimum Equity Standard and need not submit an MES Compliance Plan nor a Mid-Year Report. However, EEC AVs and Designees must annually submit an MES Year-End Report providing workforce demographic data required to be submitted to the Program each year. EEC Subcontractors are exempt from submitting MES Compliance Plans, Mid-Year Reports, and Year-End Reports but must provide their AVs and/or Designees with their project workforce demographics data for the relevant Program Year.
Designee Registration
No, because community solar installers do not have direct interaction with end-use customers they are not required to register as a Designee with the Program.
(Updated February 2023)
Every third-party entity that has direct interaction with end-use customers needs to register as a Designee. This includes:
- DG Installers
- Marketing firms
- Lead generators
- Sales organizations
(Updated February 2023)
If your company operates as a Designee but is also an Approved Vendor, you must also register as a Designee and identify those Approved Vendors or Designees with which you work.
(Updated February 2023)
New Designees must register with the Program prior to working with any Approved Vendor. Designees can register and be connected with their Approved Vendors through the Program portal.
(Updated February 2023)
Illinois Solar for All has a process for registering third-party entities that have direct interaction with end-use customers as ILSFA Aggregator Designees and subcontractors. More information about registering with Illinois Solar for All can be found here. ILSFA Aggregator Designees and subcontractors are not required to register as Designees of Approved Vendors.
(Updated February 2023)
A nested Designee is a Designee’s Designee (Approved Vendor > Designee > Nested Designee). All nested Designees that have direct interaction with end-use customers are required to register as Designees with the Program.
(Updated February 2023)
No, use of the Illinois Shines Designee logo is not required. The Consumer Protection Handbook, published on July 14, 2022, states that “an Approved Vendor or Designees may state the fact that it is (or working with) an Approved Vendor under the IPA’s Adjustable Block Program/Illinois Shines and may use a uniquely assigned Illinois Shines Approved Vendor logo or Illinois Shines Designee logo.”
Both the Illinois Shines Approved Vendor logo and the Illinois Shines Designee logo may be used only by an Approved Vendor or (with the Approved Vendor’s authorization) its Designees. Designees shall only use an Illinois Shines Approved Vendor logo with the express approval of the Approved Vendor. Neither the Illinois Shines Approved Vendor logo or the Illinois Shines Designee logo may be modified. Approved Vendors and Designees shall not use other forms of the Illinois Shines logo. This restriction does not apply to dissemination of materials created by the IPA and its Program Administrator. If an AV or Designee is interested in utilizing the AV or Designee logo, they can reach out to the Program Administrator.
(Updated February 2023)
The Agency has received inquiries as to whether Distributed Generation (“DG”) installation companies must be registered as a Designee. As defined in the Illinois Shines Program Guidebook, “Designee” refers to third-party (i.e., non-Approved Vendor) entities that have direct interaction with end-use customers on behalf of the Approved Vendor or another Designee. The Agency has concluded that DG installers must be registered as Designees. For purposes of registration requirements, installers of DG projects are presumed to interact with the end-use customer by working on the customer’s property, and the purpose of Designee registration requirement is to increase Program transparency.
(Updated May 2024)
RECs
This topic is addressed in section 7.5 of the current Long-Term Plan. When a project is approved for the Illinois Shines Program, a 15-year or 20-year REC obligation will be calculated for that project, depending on the project category. Approved Vendors will have the option to use either a PVWatts calculated capacity factor automatically computed by the Program portal or an alternative capacity factor based on an estimated production analysis conducted using an equivalent tool. Information on approved capacity factor calculations for use under the program can be found in Section 4(J) of the current Program Guidebook.
(Updated February 2023)
The final REC prices can be found in the Program Guidebook.
(Updated February 2023)
The payment terms vary based on the REC Delivery Contract. The below information pertains to 2022 contracts.
For Small DG, an upfront payment for the full value of the REC contract will be made to the Approved Vendor at the time the project is fully energized. The contract term is 15 years.
For Large DG and Community Driven Community Solar, 15% of the contract value is paid upfront to the Approved Vendor at Energization. The remaining portion is paid quarterly over the subsequent 6-year period. The contract term is 15 years.
For Traditional Community Solar and Public Schools, RECs are paid as they are delivered. The contract term is 20 years.
For Equity Eligible Contractors, an advance of capital may be requested via the Part I application.
For full details on the payment schedule for all block categories, please reference the Program Guidebook.
(Updated February 2023)
Project Eligibility
All applications will have to be submitted to the Program by an Approved Vendor. Larger (non-residential) systems of at least 100 kW can apply as a Single Project Approved Vendor.
For small systems that have already been built (and energized after June 1, 2017), if your installer does not become an Approved Vendor, or work with an Approved Vendor, you will need to choose an Approved Vendor from the Approved Vendor list to apply on your behalf. Each Approved Vendor may offer you different terms and you should review multiple offers and choose carefully.
Systems will have to comply with all Program terms and conditions, which may require retroactive adjustments to the system or agreements with the installer. Systems in the Adjustable Block Program must have been installed by an individual who is a “Qualified Person” as defined in Section 16-128A of the Illinois Public Utilities Act and Title 83, Part 468 of the Illinois Administrative Code.
(Updated February 2023)
Under the Illinois Power Agency Act, the definition of “public schools” for this Program comes from the Illinois School Code, which includes any public school, common school, alternative public school, or free school operated by the authority of the Illinois School Code, including Illinois public schools from pre-school through grade 12, and vocational schools over which the State Board of Education has authority.
(Updated February 2023)
Disclosure Forms
For both Distributed Generation (DG) and Community Solar, the customer must receive, review, and sign the Disclosure Form before signing an installation contract or subscription agreement. Failure to secure customer signature on a Disclosure Form before securing customer signature on an installation contract or subscription agreement could result in rejection of the Disclosure Form or disciplinary action against the Approved Vendor and/or Designee. The Disclosure Form includes important information about the customer’s proposed solar photovoltaic (PV) system or community solar subscription. For DG, the Disclosure From must be generated for the customer after the customer’s PV system is designed. For Community Solar, the Disclosure Form must be generated after the customer’s community solar subscription is sized.
(Updated February 2023)
There are three options for Disclosure Form generation:
- Directly through the Portal: The Approved Vendor/ Disclosure Form Designee enters all the information for the Disclosure Form in the Portal and generates the form there.
- Via CSV Upload: The Approved Vendor/Disclosure Form Designee enters all information for one or multiple Disclosure Forms into a CSV document available in the ABP Portal. After the information is entered into the CSV, the Approved Vendor/Disclosure Form Designee can upload the CSV, and generate multiple Disclosure Forms at once.
- Via API: With the Program Administrator’s approval, Approved Vendors or Disclosure Form Designees (with Approved Vendor approval) may generate Disclosure Forms outside of the Program Portal via API. This option is not currently available in the program Portal but will be a feature released in the future. Please stay tune to Program Announcements for portal development updates related to the API.
(Updated February 2023)
There are three options available for securing customer signatures:
- Wet signature: The Approved Vendor/Designee can print a hard copy for the customer to review and sign with a wet signature. After the customer has signed the Disclosure Form, the Approved Vendor/Designee can upload a scan of the signed Disclosure Form to the Portal.
- E-signature through the ABP Portal: The Approved Vendor/Designee can send the Disclosure Form for e-signature through the Program Portal. The customer will receive an email from the Program Administrator requesting their e-signature on the Disclosure Form, and the customer can follow the link in that email to e-sign the Disclosure Form. The Portal will automatically record the date, time, and IP address of that e-signature.
- E-signature through a commercially available, third-party platform: The Approved Vendor/Designee can download the Disclosure Form and send it to the customer for e-signature through a commercially available, third-party e-signature platform. After the customer electronically signs the Disclosure Form, the Approved Vendor/Designee uploads the e-signed document to the Portal. This upload must also include the tracking page generated by the e-signature platform. We suggest that program participants reach out to the Program Administrator if any question exists about whether a signature platform falls within the definition of a commercially available, third-party platform to prevent the rejection of Disclosure Forms at verification check points. In-house developed e-signature platforms will not be accepted.
(Updated February 2023)
It is never permissible to edit the static text on Disclosure Forms, whether before or after customer signature. If an Approved Vendor/Disclosure Form Designee needs to update the information entered in a Disclosure Form field after the customer signs the Disclosure Form, please use the following options:
- Generate a new Disclosure Form for the customer: In this instance the Approved Vendor/ Disclosure Form Designee would start at the beginning of the process, and the new Disclosure Form would have a different Disclosure Form ID than the previous Disclosure Form. With this option, all information on the Disclosure Form would need to be reentered. If the new Disclosure Form needs to be linked to an existing application, please email the Program Administrator at [email protected] with the new Form ID to request it be linked to the existing application. This option is available at any point during the application process.
The following two options are not currently available in the Program Portal but will be a feature released in the future. Please stay tuned to Program Announcements for portal development updates.
- Duplicate an existing Disclosure Form: Approved Vendors/ Disclosure Form Designees can submit requests to the Program Administrator to duplicate an existing Disclosure Form. This will create a new Disclosure Form (with a new Disclosure Form ID), that is in the “In Progress” stage. This new Disclosure Form will be populated with all the information from the first Disclosure Form, and the Approved Vendor/ Disclosure Form Designee can update the field(s) as needed. This option is available at any point during the application process.
- Return the existing, signed Disclosure Form to the “In Progress” status within the Program Portal: Within the Disclosure Form section of the Portal, click on the system name, scroll to the bottom, and click the “Edit Disclosure Form” button. This will allow you to revisit any sections of the Disclosure Form, update the field(s) that need to be updated, and then resend the Disclosure Form to the customer for e-signature. This generates a new version of the existing Disclosure Form, and the new version will maintain the same Disclosure Form ID. This option is only available until the application associated with that Disclosure Form is Part I submitted. The Program Portal will maintain a record of any previous e-signatures and uploads of the Disclosure Form. Approved Vendors/ Disclosure Form Designees cannot currently view this information but can email the Program Administrator to request the full history of a Disclosure Form.
(Updated February 2023)
This Customer Disclosure Form E-mail Address Waiver, which must be completed and signed by both the Approved Vendor or Designee, as well as the prospective customer, can be submitted to the Program Administrator where the residential customer considering participation in Illinois Shines does not have an e-mail address.
The Illinois Power Agency’s Long-Term Renewable Resources Procurement Plan provides that the Program’s Disclosure Form requirements “are fundamental to subscribers receiving standardized information,” serving as “the backbone of the Agency’s efforts to deliver uniform content about the rights and obligations under a ratepayer-funded program to everyday citizens.” (Emphasis added.) The Consumer Protection Handbook requires that customers receive a completed Disclosure Form prior to contract execution, so that the customer has “clear information” about the offer.
Therefore, providing a customer with a Disclosure Form that has incomplete or erroneous information is a violation of program requirements and may lead to disciplinary action. In addition, noncompliant Disclosure Forms may be rejected by the Program Administrator.
(Updated February 2023)
The Agency has observed that select Disclosure Forms have included references to attachments. To ensure Disclosure Form content meets the Program’s intent of uniform, standardized content, the Agency provides the following clarification of Program requirements.
Each Disclosure Form field must be completed such that it provides the information required by the field prompt or description. A Disclosure Form field may not simply refer the customer to an attachment or other document. An attachment may be used to provide additional information beyond what is required in the Disclosure Form. For example, the community solar Disclosure Form requires, for offers with a variable rate, an explanation of the method or formula for calculating payments throughout the term of the subscription. An Approved Vendor or Designee must complete that field with information from which an average customer could fairly be expected to calculate their monthly subscription fee. An Approved Vendor or Designee could then also provide a full rate schedule in an attachment.
(Updated February 2023)
The Consumer Protection Handbook requires that customers receive a completed Disclosure Form prior to contract execution, so that the customer has “clear information” about the offer. One Disclosure Form requirement for community solar and distributed generation leases and PPAs is disclosure of whether there are any fees or penalties for early termination of the contract.
Any requirement (triggered by early termination) that a customer make additional payments that they would not otherwise be required to make at that time counts as an early termination fee or penalty. For example, a requirement that a customer pay part or all of the future payments under the remaining duration of the contract counts as an early termination fee or penalty and must be disclosed as such.
(Updated August 2023)
A Designee can complete Disclosure Forms only if it is registered in the Program portal as a Disclosure Form Designee. To complete this registration, the Approved Vendor that the Designee is tied to must approve the Designee in that role. Designee registration is currently taking place via a form submitted to the Program Administrator via email. The form is available for download here.
If a Designee is unable to complete Disclosure Forms, please contact the Program Administrator at [email protected].
(Updated February 2023)
The baseline Program requirement is that if information provided to a customer in their Disclosure Form substantively changes, a new Disclosure Form must be provided to, and signed by, the customer, to ensure the customer has up-to-date and accurate information about their project. The Program Guidebook explicitly provides limited exceptions to this requirement for changes in AC size below a certain threshold, and a chart at the Program website addresses several additional circumstances and whether specific changes in the information in a Disclosure Form trigger the requirement to have the customer sign a new Form.
There are limited exceptions where the signatory on the Disclosure Form may vary from this requirement. These limited exceptions, along with clarifications on who should sign Disclosure Forms when the customer is a company or other organization, are outlined in a chart at the Program website.
Net Metering
Changes in Net Metering in Illinois: AV and Designees
Net metering is changing for ComEd, Ameren, and MidAmerican residential and small commercial utility customers. Under Illinois law, full retail rate net metering will no longer be available for new distributed generation customers registering for net metering on and after January 1, 202 5. After that date, customers installing a distributed generation system will receive only energy supply credits for the excess energy generated by their system and sent back to the grid.
(Updated July 2024)
In order for a residential or small commercial project to be guaranteed full retail rate net metering in the ComEd and Ameren service territories, the Certificate of Completion (and Witness Testing if in Ameren territory) must be submitted by 5 PM on December 31, 2024. (Note: this date was updated to December 31, from December 13, on October 4, 2024, and the correction to the text was made November 1, 2024).
The submissions must be complete and accurate – there is no cure period for errors. If the Certificate of Completion or Witness Test Request is submitted after 5 p.m. CPT on December 31, but prior to the end of December 2024, the utility may still complete their review and the project may be eligible for full retail rate net metering, but there is no guarantee that the review will be completed in time to obtain full retail rate net metering for the project.
In order for a project to receive full retail rate net metering in the MidAmerican service territory, customers must submit their net metering application to the utility before January 1, 2025.
Full retail rate net metering is not available for any solar project that takes the utility distributed generation rebate (also called the smart inverter rebate). These rebates are only available from ComEd and Ameren.
(Updated November 1, 2024)
ComEd and Ameren customers receiving Permission to Operate from their utility after the relevant cutoff date will be eligible for the supply-only crediting.
MidAmerican customers that submit a net metering application before January 1, 2025 will be eligible for full retail rate net metering, but those who submit an application after that date will be eligible for supply-only net metering.
More details on these changes from each utility can be found here:
- ComEd:
- General Net Metering Information: https://www.comed.com/smart-energy/my-green-power-connection/developers-contractors/net-metering
- Changes to Net Metering: https://azure-na-assets.contentstack.com/v3/assets/blt3ebb3fed6084be2a/blt81f54d30b184ae59/66630a42613ade000a0858cd/ComEd_2025-Changes-To-NetMetering.pdf
- Ameren:
- General Net Metering Information: https://www.ameren.com/illinois/residential/supply-choice/renewables/net-metering
- MidAmerican:
- General Net Metering Information: https://www.midamericanenergy.com/customer-interconnection#IllinoisApp
(Updated July 2024)
The Agency understands that ComEd and Ameren will be able to complete reviews of COCs and WTR submissions on or before December 31, 2024, but neither ComEd or Ameren will be able to provide an extension or a cure period beyond that point for any COC/WTR submitted on or before December 31, 2024 that is determined to be incomplete, inaccurate or to contain material defects. If the utility requires a new/modified COC/WTR be submitted, it must be received on or before December 31 to ensure it can be reviewed for completion in 2024.
MidAmerican requires that the customer submit a completed net metering application prior to January 1, 2025, rather than a COC or WTR.
(Updated October 4, 2024)
The Agency understands that ComEd and Ameren will require distributed generation systems to be built and operational prior to January 1, 2025 to be eligible for full retail rate net metering credits. A deadline of December 13, 2024 cutoff provides 10 business days for the utilities to review Certificates of Completion/Witness Test Requests for completion prior to the end of the 2024 calendar year.
(Updated October 4, 2024)
Under Illinois law, eligible systems registered for full retail net metering before January 1, 2025 will continue to receive net metering services under the current methodology for the lifetime of the system, regardless of whether those customers change electricity providers or whether the customer receiving the benefit from that system changes. Systems receiving full retail rate net metering prior to December 31, 2024 shall maintain eligibility for full retail rate net metering for the life of the facility, unless the system is modified in the following circumstances:
- For ComEd, such that a new interconnection application is required
- For Ameren, such that the nameplate capacity increases by more than 100%
(Updated July 2024)
No, the current interconnection application review processes will not change for ComEd, MidAmerican, or Ameren.
(Updated July 2024)
No, the net metering services stay with the system itself. Therefore, customers that acquire projects eligible for the legacy full retail rate net metering will receive those rates.
(Updated July 2024)
The Climate and Energy Jobs Act (CEJA) which was signed into law September of 2021 provides that, starting January 1, 2025, new residential and small commercial net metering customers in the ComEd, Ameren, and MidAmerican territories will receive supply-only net metering, rather than full retail rate net metering. ComEd and Ameren customers are eligible for a “Distributed Generation” or “Smart Inverter” rebate from the utility (which is separate from incentives provided through the Illinois Shines program). If a residential or small commercial customer in the ComEd or Ameren territory elects to receive the rebate in 2024, they will no longer be eligible for full retail rate net metering, and will instead receive supply-only net metering. In 2025 and later, all net metering customers in ComEd and Ameren territories (regardless of whether they take the rebate) will receive supply-only net metering.
(Updated July 2024)
- ComEd:
- General Net Metering Information: https://www.comed.com/smart-energy/my-green-power-connection/developers-contractors/net-metering
- Changes to Net Metering: https://azure-na-assets.contentstack.com/v3/assets/blt3ebb3fed6084be2a/blt81f54d30b184ae59/66630a42613ade000a0858cd/ComEd_2025-Changes-To-NetMetering.pdf
- Ameren:
- General Net Metering Information: https://www.ameren.com/illinois/residential/supply-choice/renewables/net-metering
- MidAmerican:
- General Net Metering Information: https://www.midamericanenergy.com/customer-interconnection#IllinoisApp
(Updated July 2024)
Changes in Net Metering in Illinois: Consumers
Net metering credits you for your electricity that your solar project sends to the utility electric grid. If your solar project generates more electricity than you use, the excess electricity flows to the grid and you will receive a credit on your bill for that electricity.
Rural electric cooperatives and municipal electric utilities may limit access to net metering or may offer a different approach for crediting customers for electricity that is sent to the grid.
(Updated July 2024
Net metering policies and rates for ComEd, Ameren, and MidAmerican distributed generation (on-site) residential and small commercial solar customers are changing. Full retail rate net metering will no longer be available to residential and small commercial customers net metering customers interconnecting new renewable energy systems after December 31, 2024.
Your utility will “net out” the electricity that your project sends to the grid against the electricity that you pull from the grid. For example, if your solar project sends 400 kWh of extra electricity to the grid, and you use 500 kWh of electricity from the grid, your net usage would be 100 kWh. You will then only pay supply and transmission charges for that net usage.
With supply-only net metering, electric delivery charges are no longer included in net metering. This means that customers will pay delivery charges for the entire amount of electricity that they pull from the grid, regardless of how much electricity they send back to the grid. With the above example, you would pay supply and transmission charges for 100 kWh, but you would pay delivery charges for the full 500 kWh pulled from the grid. Your electric bill will also include non-volumetric (not based on kWh used) customer charges and fees.
Customers that have systems installed that are already receiving full retail rate net metering will continue to receive full retail rate net metering for the life of their system, or unless the solar project is modified so extensively that it requires a new interconnection agreement (in ComEd territory) or doubles the nameplate capacity of the project (in Ameren territory).
(Updated July 2024)
Under Illinois law, customers beginning net metering service on or after January 1, 2025 will receive net metering just for supply charges, rather than the full retail rate net metering. The Agency understands that as a result, ComEd will require customers submit a certificate of completion by December 31, 2024 to be assured full retail rate net metering, and that Ameren will require customers to submit the Witness Test Request by December 31, 2024 to be assured full retail rate net metering. If the submissions are incomplete or have errors, or if they are submitted after 5 PM on December 31, 2024 but before January 1, 2025, the utilities may or may not be able to review and approve net metering before the January 1 deadline. (Note: this date was updated to December 31, from December 13, on October 4, 2024). MidAmerican requires that a completed net metering application be submitted prior to January 1, 2025 for the solar project to receive full retail rate net metering.
(Updated October 4, 2024)
Residential and small commercial customers interconnected to Ameren or ComEd prior to January 1, 2025 who did not request a Distributed Generation Rebate from the utility will continue to have full retail net metering for the life of the system unless material modifications are made. Residential and small commercial customers in MidAmerican territory who submit a net metering application prior to January 1, 2025, will receive full retail rate net metering. If you are unable to determine if you are receiving full retail rate net metering, you may want to check with your utility.
(Updated July 2024)
If the system has been receiving full retail rate net metering prior to January 1, 2025, it will continue to receive full retail rate net metering even if ownership of the project changes.
(Updated July 2024)
If your system is enrolled in the legacy full retail rate net metering, meaning it was interconnected prior to January 1, 2025 and you did not request a DG (also called “Smart Inverter”) rebate with the utility, the net metering rate will change if the system is modified under the following circumstances:
- For ComEd, changes to the system that require a new interconnection application
- For Ameren, an increase to the system’s nameplate capacity of more than 100%
(Updated July 2024)
Customers enrolled in net metering on or after January 1, 2025, will only receive supply credits, meaning that customers whose systems send excess energy to the grid will be compensated at a lower rate per kilowatt-hour than those already enrolled in net metering.
If your system was fully interconnected and receiving full retail rate net metering prior to December 31, 2024, and did not receive a Distributed Generation or Smart Inverter rebate from the utility , the amount of savings will not be affected unless material changes are made to the system.
Customers whose project is approved for net metering after December 31, 2024 will be enrolled to the new net metering rates and will only receive supply credits.
(Updated July 2024)
ComEd:
- General Net Metering Information: https://www.comed.com/smart-energy/my-green-power-connection/developers-contractors/net-metering
- Changes to Net Metering: https://azure-na-assets.contentstack.com/v3/assets/blt3ebb3fed6084be2a/blt81f54d30b184ae59/66630a42613ade000a0858cd/ComEd_2025-Changes-To-NetMetering.pdf
Ameren:
- General Net Metering Information: https://www.ameren.com/illinois/residential/supply-choice/renewables/net-metering
MidAmerican:
- General Net Metering Information: https://www.midamericanenergy.com/customer-interconnection#IllinoisApp
(Updated July 2024)
Net Metering Unavailability Customer Acknowledgment Form
This form is required when a customer’s project is located in the service territory of a municipal electric utility or rural electric co-operative, and when the solar project will not receive net metering credits comparable to what the customer would receive if the project was located in the service territory of ComEd, Ameren, or MidAmerican.
(Updated July 2024)
The standard Disclosure Forms include an estimate of the monetary value of electricity generated by the solar project. Up to and through late 2024, the Disclosure Forms assume that the customer will receive full retail rate net metering, and electricity generated by the system is valued at the retail rate (for ComEd, Ameren, and MidAmerican, the portal uses current utility retail rate; for municipal electric utilities and rural electric co-operatives, the portal uses a state-wide average retail rate). If a customer does not receive comparable net metering credits from their utility or co-operative, it is important that the customer understands this and how it may affect the overall financial benefits of the solar project.
Note that beginning in December 2024 or January 2025, the portal will be updated to estimate the value of electricity from solar projects that receive supply-only net metering. The Net Metering Unavailability Customer Acknowledgment Form is required when the customer is not going to receive credits comparable to what they would receive if they were located in ComEd, Ameren, or MidAmerican service territories—this standard for when the Form is required will be the same after ComEd, Ameren, and MidAmerican change to supply-only net metering for residential and small commercial customers.
(Updated July 2024
Community Solar
A list of community solar projects that have opted to be listed publicly are is posted here. Please keep in mind that projects that are in development and have not yet applied to and been approved by the Program will not appear on the list. Also keep in mind that some of the projects here may already be fully subscribed. This list will be updated as projects opt to be added. This list will be updated quarterly and as projects opt to be added.
(Updated February 2023)
Under state law and the Long-Term Renewable Resources Procurement Plan, subscriptions to community solar projects must be portable (i.e., the subscriber may retain the subscription while changing locations within the same utility service territory) and transferable (i.e., a subscriber may assign or sell the subscription to another person within the same utility service territory). The Illinois Shines Program requires that the community solar provider may not charge a fee for transferring your subscription to someone else. These rights of transferability and portability may still be subject to other restrictions, including the community solar provider’s right to check a new subscriber’s credit score, and the utility’s right to ensure that a subscription is appropriately sized relative to the subscriber’s usage.
(Updated February 2023)
The Program Administrator has published a set of marketing materials, standard disclosures, Approved Vendor/Designee registration, and requirements for consumer protections during customer interactions community solar projects which can be found in the Consumer Protection Handbook.
(Updated February 2023)
For Community Solar projects under the 2019 REC Delivery Contract and the 2021 and 2022 15-Year REC Delivery Contracts, based on any changes to that project’s total percentage subscribed, to the Standing Order percentage shall be updated in the relevant registry after both Part II verification and Program Administrator review of each of a project’s four Community Solar Quarterly Reports. This process is as follows:
If the project is registered in GATS:
- The Program Administrator sends email to the contracting utility and Approved Vendor with a link to the revised Schedule B, highlighting any change in the Standing Order percentage.
- If there is a change to the Standing Order percentage, the Program Administrator sends an email to the contracting utility and the Approved Vendor, requesting removal of the irrevocable flag on the Community Solar project’s Standing Order. The email will include at a minimum, the project’s Illinois Shines application ID, registry Unit ID, and new Standing Order percentage.
- The utility replies to all documenting its consent. The utility then removes the irrevocable flag and replies to all confirming that the irrevocable flag was removed.
- The Approved Vendor cancels the existing Standing Order and initiates a new irrevocable Standing Order with the new specified percentage.
- The Approved Vendor replies to all confirming the new Standing Order has been initiated.
- The utility confirms the new Standing Order is accurate.
If the project is registered in M-RETS:
- The Program Administrator sends email to the contracting utility and Approved Vendor with a link to the revised Schedule B, highlighting any change in the Standing Order percentage.
- If there is a change to the Standing Order percentage, the Program Administrator sends email to the M-RETS admin, copying the utility and Approved Vendor, requesting a change to the Community Solar project’s Standing Order percentage. The email will include at a minimum, the project’s Illinois Shines application ID, registry Unit ID, current Standing Order percentage, and new Standing Order percentage.
- The utility and Approved Vendor reply to all confirming their consent to updating the Standing Order percentage.
- M-RETS updates the Standing Order with the new percentage and replies to all confirming that the change is complete.
- Both the utility and Approved Vendor confirm that the Standing Order accurately reflects the new percentage in the registry.
The process of registering with GATS or M-RETS should be completed in no less than 30 calendar days from the Program Administrator’s initial email to the registry. Failure to update the Standing Order in a timely fashion may have an impact upon obligations under the REC Contract.
(Updated February 2023)
Under Section 1-75(c)(1)(G)(iv)(3)(iii) of the IPA Act, Approved Vendors that are awarded a 2021 20-Year REC Delivery Contract for a community solar project that was previously waitlisted have the right under the contract to substitute the contracted community solar project(s) with other waitlisted community solar projects without penalty in the event that the project receives a non-binding estimate of costs to construct the interconnection facilities and any required distribution upgrades associated with that project of greater than 30 cents per watt AC of that project’s nameplate capacity. The 2021 REC Delivery Contract does not provide for substitution of a project for other circumstances outside of the control of the applicant; therefore, once a project has received a REC Contract, it may only be substituted due to interconnection costs in excess of 30 cents/W AC.
In accordance with Section 7.2 of the REC Delivery Contract, an Approved Vendor wishing to make a substitution may make a written request to the Buyer and IPA within 30 days of receipt of the cost estimate to substitute a project or projects from the waitlist of equal or lesser nameplate capacity. The request must be accompanied by the cost estimate from the interconnecting utility which demonstrates the costs exceeds 30 cents/W AC. The written request and accompanying documentation should be submitted to the IPA via email to [email protected]. As soon as practicable after this request, the Program Administrator will provide to Buyer and Seller a revised Schedule A, Schedule C and Schedule D.
The Agency understands that other circumstances beyond the control of the Approved Vendor may adversely impact the viability of a project such that the AV wishes to substitute the project. Therefore, after the submission of an Approved Vendor’s portfolio of community solar projects to the Program Administrator on March 14, 2021, but prior to the Program Administrator submitting a batch that contains such a project to the Commission for approval of a 2021 REC Delivery Contract for a project submitted under Section 1-75(c)(1)(G)(iv)(3) of the IPA Act, an Approved Vendor may request to substitute a submitted project with other waitlisted project(s) up to the submitted project’s nameplate capacity. Substitution will be granted without penalty in all cases where the project receives a cost estimate for interconnection facilities and any required distribution upgrades of greater than 30 cents/W AC of that project’s nameplate capacity. The Agency will allow substitution of projects due to other circumstances outside of the control of the applicant firm upon demonstration that project substitution is warranted, including but not limited to unforeseeable development hurdles, permitting issues, and/or restrictions resulting from the COVID-19 global health pandemic. Approved Vendors that wish to substitute a waitlisted project for a submitted project prior to the batch containing that project having been submitted to the Commission for approval of a REC Delivery Contract should send a written request to the Program Administrator and include a copy of any supporting documentation. As soon as practicable after a review of the circumstances supporting the request, the Program Administrator will notify the Approved Vendor of its determination. If granted, the Program Administrator will notify the Approved Vendor that the substitution has been completed and will submit the project to the Commission for approval. If denied, the Approved Vendor may appeal that decision to the IPA, and the original project application will continue to be held pending determination of that appeal.
Approved Vendors wishing to hold a traditional community solar project from submission to the Commission in order to determine whether a substitution of the project is necessary must make that request in writing to the Program Administrator once the relevant project(s) are Part I verified. The Program Administrator will hold each such project for 60 days or until a substitution has been completed and will consider requests for additional time on a case-by-case basis. The Program Administrator will work with Approved Vendors to submit projects/batches to the Commission for approval after the expiration of the 60-day window or subsequent extension.
Please note that substitution is limited to community solar projects awarded contracts upon reopening pursuant to Section 1-75(c)(1)(G)(3) of the IPA Act. Whether substitution will be permitted under future blocks of Traditional Community Solar will be determined through the Agency’s Long-Term Renewable Resources Procurement Plan or requirements published thereafter.
(Updated February 2023)
As the historical waitlist for this project category has been addressed via the 2021 waitlist allocation process, the Traditional Community Solar project category will take new applications and those applications will be scored per scoring requirements discussed in Section 1.F of the Program Guidebook. Projects must receive a minimum score of 5 points to receive a spot on the waitlist. Should first day project applications not exceed category capacity, then all applicant projects otherwise qualifying shall be deemed acceptable and may qualify for a REC Delivery Contract. Should category capacity fill later in the program year, then from that point forward, only projects meeting this scoring threshold of 5 points may be considered for an eligible for a spot on the waitlist for the Traditional Community Solar category. Demonstration of continuous site control will be required to maintain a waitlist position throughout the program year and into the next program year; the degree to which this is monitored by the Program Administrator, and the manner of that monitoring, will be determined at a later date.
(Updated February 2023)Project Applications
A system applying for the Illinois Shines Program can only be self-installed if the individual installing the system is a Qualified Person which is defined under 83 Ill. Adm. Code § 468.20 as: “Qualified person” means a person who performs installations on behalf of the certificate holder and who has either satisfactorily completed at least five installations of a specific distributed generation technology or has completed at least one of the following programs requiring lab or field work and received a certification of satisfactory completion: an apprenticeship as a journeyman electrician from a DOL registered electrical apprenticeship and training program; a North American Board of Certified Energy Practitioners (NABCEP) distributed generation technology certification program; an Underwriters Laboratories (UL) distributed generation technology certification program; an Electronics Technicians Association (ETA) distributed generation technology certification program; or an Associate in Applied Science degree from an Illinois Community College Board approved community college program in solar generation technology. Project applications must still be submitted via an Approved Vendor.
Please see the Program Guidebook for the full requirements to install a Distributed Generation system.
(Updated February 2023
In response to the Program’s shift in September 2022 from a declining block price structure to an annual block structure, and in an effort to eliminate gaming opportunities, projects submitted to the Program will not be permitted to receive a REC price higher than the price available at the time of its initial submission to the Program (i.e., an application cannot be withdrawn and resubmitted in order to receive a higher REC price).
For projects selected off of a waitlist, Approved Vendors have 10 business days to decide whether to accept the block allocation. The Approved Vendor will be able to exercise this option without any further penalty, process, or the posting of collateral. If a project selected from the waitlist declines its selection by this option, then the next ordinally ranked project(s) on the waitlist will be selected along with the same terms (10 business days to accept or decline). Projects declining a block allocation will be removed from the Illinois Shines Program. The Approved Vendor may decline a block allocation by communicating its decision in writing to the Program Administrator. The application fee is non-refundable. In the case where a project has been continuously waitlisted, it will receive the REC price associated with the block of capacity to which the project is assigned.
(Updated February 2023)
Initially, systems over 25 kW were required to obtain all non-ministerial permits prior to submitting a project application. With the ICC’s approval of the Revised Long-Term Plan, other than a land-use permit for systems above 250kW AV, non-ministerial permits are no longer required.
(Updated February 2023)
While proposed projects may be submitted to both Illinois Shines and Illinois Solar for All (ILSFA) (when eligible) for approval and funding, contracts will be awarded from only one program or the other. Because the potential exists that a single proposed project could be found eligible or approved by both programs concurrently, a milestone must be identified that indicates acceptance of contracting from one program and ineligibility from the other. Therefore, once a batch containing a Part I Verified Illinois Shines application has been submitted to the Illinois Commerce Commission for approval, the underlying projects in that batch will no longer be eligible for ILSFA. Any Illinois Shines application that wishes to remain eligible for ILSFA must be withdrawn prior to Illinois Commerce Commission submission.
(Updated February 2023)
Pursuant to Section 4.F of the October 2022 version of the Program Guidebook, all solar projects at a customer’s location that are owned by that customer or affiliates of that customer must be submitted under a single Illinois Shines application regardless of the number of utility accounts associated with the projects. An Illinois Shines application represents all of the systems on a customer’s parcel, regardless of the location of the utility meter(s). The location of the modules and arrays, not the location of the utility meter(s) determines the location of a project.
In cases in which two or more projects on one parcel are separately owned and serve to offset the load of separate entities, they may be submitted as separate applications. The Approved Vendor must provide documentation that those customers are not affiliated* entities and that each project has a separate utility meter.
If an Approved Vendor submits an application for a project owned by a customer and a co-located project owned by the same customer already is under an Illinois Shines REC contract, the new application will be subject to the expansion rules and pricing in the current edition of the Program Guidebook.
The intent of these requirements is to prevent gaming, such as a situation in which an Approved Vendor or customer intentionally divides up a project in order to receive higher REC pricing that might be available to a smaller system. The IPA appreciates that there may be special circumstances that apply to specific projects, particularly in rural areas and those served by rural electric cooperatives, and those situations could warrant different consideration. Therefore, the Agency will consider requests for exemptions to this requirement on a case-by-case basis. A request should be submitted via a letter (not just an email) on the Approved Vendor’s company letterhead and emailed to the Program Administrator at [email protected] who will then forward it to the Agency for consideration.
*From Section 7.4.3 of the Long-Term Renewable Resources Procurement Plan: “’Affiliate’ means, with respect to any entity, any other entity that, directly, or indirectly through one or more intermediaries, controls, is controlled by, or is under common control with each other or a third entity. ‘Control’ means the possession, directly or indirectly, of the power to direct the management and policies of an entity, whether through the ownership of voting securities, by contract, or otherwise. Affiliates may not have shared sales or revenue-sharing arrangements, or common debt and equity financing arrangements.”
(Updated February 2023)
No, the Illinois Shines Guidebook requires that DG systems entered into the Illinois Shines program must include the entire output of the system. If there are multiple installations with separate interconnections, you can opt to not register the separately interconnected capacity. Any capacity of a system which is not part of Illinois Shines must be separately metered with a separate inverter.
A system can be built to be smaller than proposed in Part I if the variance is less than or equal to the greater of 5kW or 25%, but it would keep the lower REC price commensurate with the proposed larger system and the quantity of RECs used for purposes of payment shall be the lesser of the REC quantities calculated based on: (1) the Proposed Nameplate Capacity and Capacity Factor and (2) the Actual Nameplate Capacity and Capacity Factor. For additional details please see Section 2.5 of the REC Contract.
(Updated February 2023)
Projects may, but are not required to, remain in the interconnection queue (i.e., maintain a valid interconnection agreement with the applicable utility) to maintain their place on the waitlist. This includes projects that are forced from the utility interconnection queue due to the utility’s queue management process, including, but not limited to, being forced to pay a potentially nonrefundable deposit to remain in the queue, or incurring other costs to remain on the waitlist. Any project that has exited the interconnection queue must provide proof that it has reapplied for interconnection as a condition of its selection off of the waitlist. Any project that declines a utility interconnection restudy, declines to pay a potentially nonrefundable deposit to remain in the queue, or otherwise takes an action that pre-emptively removes itself from the utility interconnection queue rather than wait for involuntary removal will be deemed to have been removed from the queue involuntarily. Such projects will remain eligible for selection off of the waitlist.
(Updated February 2023)
Site control must be evidenced through a binding contract for system purchase, lease, Power Purchase Agreement (PPA), option, or other form. Non-binding documents such as a Letter of Intent do not meet this requirement. It’s acceptable for the binding contract to be contingent on the underlying project securing a REC Contract in the Illinois Shines program, however securing such a REC Contract must satisfy that contingency, rendering the contract otherwise binding. In cases where the system owner and host are the same entity, site control can be demonstrated by a statement from the system owner and host that this is the case.
Site control must be signed by both parties, the customer, and by the Approved Vendor or installer. In projects where the Approved Vendor is the customer, such as in Community Solar, site control must be signed between the Approved Vendor and the host/landlord of the installation property. If the Approved Vendor is the same entity as the host/landlord of the installation address, only one signature from the entity is needed.
(Updated June 2024)
All Distributed Generation systems over 25 kW AC in size must submit an executed interconnection agreement in the Part I application. Community solar systems are not required to submit an interconnection agreement in the Part I application unless selected as a point criterion, but are requirement to provide a Certificate of Completion in the Part II application.
(Updated February 2023)
Please see the Program Guidebook for the specific application requirements for the Part I and Part II applications. Part I is the initial application and Part II is for projects in an ICC approved batch when they are completed and energized.
(Updated February 2023)
Initially, a shading study was required for all projects. With the ICC’s approval of the Revised Long-Term Plan, a shading study is no longer required for project applications as covered in this announcement.
(Updated February 2023)
An application fee equal to $20/kW, not to exceed $15,000, will be required for each project. This application fee will be paid to the Program Administrator at the time the batch is submitted and is nonrefundable. The application fee payment will be part of the batch submission process and the fee will be automatically calculated by the application Portal. Fees may be paid by wire, check, credit card, or ACH direct deposit initiated by the applicant using a unique tracking code generated by the application portal in the wire or direct deposit notes section to allow matching of deposits to batch submissions by the Administrator. Credit card payments will be subject to an additional fee of 2.9% of the total payment to account for credit card processing fees. An application will not be considered submitted until the application fee for the project is initiated. If an application fee for a project is not paid within 10 business days of batch submittal, the Program Administrator may consider the application fee unpaid, thus the application not submitted.
(Updated June 2024)
Applications for each Group/Category are typically opened at the start of the Program Year on June 1. Please find the current status of each Group/Category on the Program’s Block Capacity Dashboard page. The Program is currently open for applications from Approved Vendors for all categories with available capacity with the exception of Community Driven Community Solar (CDCS). CDCS accepts applications over a 90-day period at the beginning of each Program year. For categories where program capacity is filled, projects are now being added to waitlists for the applicable project category. Please reference Section 1C of the Program Guidebook for waitlist procedures.
(Updated February 2023)
In order to provide reliable and accurate information on REC production, the meter must be capable of recording the cumulative or incremental kWh that the system produces. When an Approved Vendor learns that one of its Part II verified systems has had a production meter failure, it must notify both the Program Administrator and that system’s contracting utility as soon it becomes aware of the failure. When alerting the Program Administrator, the Approved Vendor should provide an estimate of when the meter failed, when it became aware of the failure, its expected plan and timeline for fixing or replacing the meter, and any proposed temporary alternatives for reporting production if there is a significant time before the meter can be fixed or replaced.
(Updated August 2023)
System Engineering
No. The project approval is location-specific.
(Updated February 2023)
Variations in the system layout between Part I and Part II are not allowed except in the cases outlined in the current Program Guidebook. Switching between tracking system types and non-tracked systems is allowed; however, the lower of the Part I capacity factor or Part II capacity factor must be used. Switching tracker types by itself is not sufficient to qualify for an exception. At least one additional criterion from the list in the Guidebook must be met to qualify for an exception.
(Updated February 2023)
All systems regardless of size must use a meter or inverter that is UL-certified with digital or web-based output display.
Systems up to 10kW in size can use either a production meter that is accurate to +/-5% (including refurbished and certified meters) or an inverter specified by the manufacturer to be accurate to +/‐5%. Inverters with integrated ANSI C.12 compliant production meters are allowed with a specification sheet showing this standard has been met.
Systems over 10 kW and less than 25 kW in size must utilize a production meter that meets ANSI C.12 standards. Meters that are refurbished (and certified by the meter supplier) are allowed.
Systems over 25 kW must utilize a new production meter that meets ANSI C.12 standards.
Note: System sizes are AC nameplate capacity. Therefore, a system with a 10kW inverter, for example, is considered a 10kW system regardless of DC nameplate capacity of the system.
(Updated February 2023)
REC Contract
The Revised Long-Term Renewable Resources Procurement Plan approved by the Illinois Commerce Commission on February 18, 2020 included changes eliminating the collateral withholding provisions in both the 2021 and 2022 REC contracts. This FAQ clarifies the process under the 2019 REC contract.
In order to have collateral withheld from the first REC payment under the 2019 REC contract rather than having to post collateral in the form of cash or a letter of credit, a Designated System must:
- Be interconnected and generating electricity as of the date of ICC approval (Trade Date);
- Have an irrevocable standing order with no end date initiated with the contracting utility in PJM-GATS or M-RETS within 30 business days of the Trade Date;
- Be Part II Verified by the Program Administrator, as evidenced by the issuance of Schedule B to Exhibit A, within 30 business days of the Trade Date;
- The Approved Vendor must submit Part II of a Designated System’s project application at least four weeks prior to the collateral due date to allow the Program Administrator sufficient time to review the submission and issue Schedule B to Exhibit A.
- Have a request made via email by the Approved Vendor to the contracting utility requesting that the utility withhold collateral from the Approved Vendor’s first REC payment. To ensure that the contracting utility has sufficient time to process the request and recalculate the collateral amount due, this request must be made as soon as possible after the Approved Vendor’s receipt of the Schedule B and no later than 25 business days after the Trade Date. The email requesting withholding of collateral must include the application ID, batch ID, contract ID, Trade Date, interconnection date, and Approved Vendor name.
Email requests for collateral withholding should be directed to the following contacts for a project’s contracting utility, which may be different from the interconnecting utility:
- ComEd: WB&[email protected]
- Ameren: [email protected]and [email protected]
- MidAmerican: [email protected]
If an Approved Vendor under the 2019 REC Delivery Contract elects for the 5% collateral under the REC Contract to be withheld from the first REC payment for a system, this balance will be released at the end of the contractual period for the last system in that batch. Please contact the program administrator for further details. For all other REC Delivery Contracts upfront collateral is required and cannot be withheld from the first REC payment.
(Updated February 2023)
As PJM-GATS and M-RETS create only whole RECs, the delivery obligation for each year must be rounded down to a whole REC. As a result, the sum of the annual delivery obligations almost always is less than the total 15 or 20 year delivery obligation. Having lower annual delivery obligations also conveys to Sellers the benefit of reducing the potential for REC under-delivery and commensurate collateral drawdowns.
Annual evaluations of delivery performance as described in Section 6(d) of the Cover Sheet to the REC contract are based on annual delivery obligations, i.e. each delivery year’s Delivery Year Expected REC Quantity. The 15-year delivery obligation, i.e. the Designated System Contract Maximum REC Quantity, is used in calculating payment but is not used in evaluating annual REC deliveries. Thus, a project can deliver fewer RECs by the end of the delivery term than the 15-year delivery obligation indicates and still be fully compliant with its delivery obligations under the REC contract.
(Updated February 2023)
With respect to declining to execute a contract after receiving a contract award, the Program Guidebook notes the following:
When the Program Administrator submits contract information to the Commission for approval, that submittal will include the Program Administrator’s recommendation for approval of the batch, with a summary of factors relevant to Plan compliance and pertinent to the Commission’s standard of review for batch approval. Once a batch is approved by the Commission, the applicable utility will execute the contract. The Approved Vendor will then be required to sign the contract within seven business days of receiving it. Approved Vendors that do not execute an ABP contract after project selection, submission to the Commission for approval, the Commission’s approval, or the utility’s contract execution may face disciplinary measures impacting their status as an Approved Vendor in the Program moving forward; any such discipline will be based on the Program Administrator and IPA’s review of the circumstances under which the contract was declined.
Discipline may include a possible suspension or termination of the Approved Vendor’s status under the Adjustable Block Program. Suspension or termination will not impact an Approved Vendor’s rights or obligations under already-executed contracts or product orders, but rather it will impact its ability to submit new project applications. Generally, the Program Administrator and the IPA will review all of the circumstances informing why a contract award was declined before the issuance of any discipline. Approved Vendors should provide a detailed, comprehensive explanation for why they declined to execute any contract or product order. If circumstances genuinely outside of an Approved Vendor’s control necessitated non-execution, then discipline may have limited deterrent effect and may not be warranted, and thus the Approved Vendor’s explanation may want to emphasize and explain any such circumstances. Neither the IPA nor Program Administrator is able to provide a disciplinary determination in advance of non-execution to “pre-approve” such an action, nor can they provide a timeframe for the issuance of such determination after non-execution.
(Updated February 2023)
Although the REC Contract indicates in several places that fees and collateral are payable by the Seller, the IPA is not aware of language in the Final REC Contract prohibiting a Seller from appointing a different entity to make cash payments on its behalf. The IPA does note that the Letter of Credit forms in Exhibit E of the REC Contract indicate that the “Account Party” under the Letter of Credit must be the same as the Seller under the REC Contract.
Regarding receipt of REC payment funds, the REC Contract indicates in several places that payment is to be made to Seller or received by Seller. The IPA notes that the Cover Sheet gives the Seller the power to indicate its account details for receiving a wire transfer or ACH payment.
(Updated February 2023)
Assignments are governed by the REC contract. As explained in the REC contract, assignments may be subject to fees, and may in certain circumstances require the Buyer’s consent to be effectuated.
An entire REC contract or any product orders/batches under a contract may be assigned in their entirety. It is not possible to assign individual projects within a product order.
Following are the steps for assignment. The Assignor is the Approved Vendor that already holds the product order(s) and wishes to initiate assignment, while the Assignee is the Approved Vendor that will receive the assignment. The Buyer is the contracting utility.
- Assignor contacts Buyer and Program Administrator to provide informal notice of intent to assign, including the identity of Assignee.
- Assignee applies to be an Approved Vendor (if not already) on the Program website. (In the case that the Assignee is a foreclosing financing party, the requirement that the Assignee is an Approved Vendor shall be waived for up to 180 days following the transfer.)
- Program Administrator reviews and approves Approved Vendor application (if the Assignee is not already an Approved Vendor).
- Assignee and Assignor execute the appropriate form of Acknowledgement. The Acknowledgement without Consent form is used if the Assignee already is a valid Approved Vendor with an existing fully executed REC contract. The Acknowledgement and Consent form is used in all other situations. Thus, one of the two versions of the form is required in all cases.
- Program Administrator and Buyer collaborate to confirm that Assignor has met all prerequisites for assignment:
- Full collateral has been posted for the subject product order(s).
- Thirty business days have passed since ICC approval of the subject product order(s).
- Buyer has received any applicable assignment fees.
- A fee of $1,500 is required for the first assignment of a contract or product order. If Assignee and Assignor are affiliates, this fee is waived. Any subsequent assignments of prior-assigned product orders, even between affiliates, carry a fee of $5,000. All assignment fees are payable directly to Buyer.
- Assignee, Assignor, and Buyer must work out together how collateral will be maintained.
- Assignee and Assignor have met any other requests by Buyer for additional information for Buyer to use in determining whether to grant consent (not applicable if consent is not required).
- Program Administrator generates shell REC contract (if needed), Exhibit A, Schedule A(s), and Schedule B(s) (if appropriate) for Assignee. Generates Schedule A(s) for Assignor. All documents are provided directly to Buyer.
- Buyer signs Acknowledgement, REC contract (if needed), and Exhibit A. Sends all items to Assignee. Sends Acknowledgement to Assignor.
- If any irrevocable standing orders have been established from Assignor’s registry account for projects in the batches being assigned, Assignor must transfer those projects to Assignee’s GATS or M-RETS account. Assignor and Assignee must ensure that the irrevocable standing orders remain in place during the transfer or are re-established post-transfer.
- Assignee and Assignor effect the legal assignment. Assignee countersigns REC agreement and Exhibit A. Assignee and Assignor provide copies of fully executed documents to Buyer along with proof that any projects with irrevocable standing orders have been transferred to Assignee’s registry account and that those irrevocable standing orders have been maintained or re-established post-transfer.
- Upon confirming that all requirements have been completed, Buyer notifies Program Administrator that the assignment is complete.
- Program Administrator updates the Illinois Shines database, moving subject product order(s) from Assignor’s REC contract to Assignee’s REC contract.
Note that an Approved Vendor may, without consent, collaterally assign or pledge the revenue stream of a REC contract or product order(s), or collaterally assign the REC contract itself, in conjunction with financing or other financial arrangements. The Approved Vendor must provide notice to the Program Administrator and Buyer of such a collateral assignment or pledge, including the identity and contact information of the financing party obtaining collateral rights. Also note that collateral assignment of the contract, and any associated time period for a financing party to conduct the collateral assignment of the contract, should operate in the same manner for EEC AVs as it would for non-EEC AVs.
(Updated February 2023)
In order to allow the Program Administrator sufficient time to verify the application, Approved Vendors should submit distributed generation Part II applications no later than four weeks prior to the opening of an invoicing window. For community solar projects, because of the more complex verification process that includes validating subscriber data, Approved Vendors should submit Part II applications no later than six weeks prior to the opening of an invoicing window.
(Updated February 2023)
The REC Contract governs the requirements surrounding the review of quantities of REC deliveries, including the application of any RECs included in the Delivery Year Surplus Amount to any Delivery Year Shortfall Amount. Surplus RECs will be applied to any shortfall, and any shortfall that remains after the application of the surplus will result in the drawdown of an Approved Vendor’s posted Performance Assurance.
In the case of a shortfall of RECs after the application of Surplus RECs resulting in a subsequent Drawdown Payment, the RECs Delivered will be adjusted to reflect that the RECs Delivered in each of the three Delivery Years of a Delivery Year REC Performance equals the Expected REC Quantity for those Delivery Years for the purposes of reviewing the quantities of subsequent REC Deliveries. In this way, an Approved Vendor is not penalized for the same shortfall of RECs Delivered in subsequent 3-year rolling averages.
Additionally, a 3-year rolling average that results in the shortfall of a number of RECs that is not a whole number will be rounded down to the nearest whole REC, since it is not possible to create or deliver a fraction of a REC. If a 3-year rolling average results in an over-delivery of RECs, any fractional RECs will be carried forward until such time as the fractions add up to a whole REC.
In the example below, for a project with a delivery obligation of 100 RECs annually, 20 RECs are delivered in the first year, 110 in the second year, and 120 in the third year, resulting in a 3-year rolling average of 83.33 RECs ((20+110+120)/3) at the end of year 3. This number gets rounded down to 83 whole RECs, resulting in a shortfall of 17 RECs (delivery obligation of 100 RECs minus 83 RECs delivered). After a drawdown to cover the 17 RECs that were not delivered, 100 RECs will be deemed to have been delivered in year 1, 100 RECs will be deemed to have been delivered in year 2, and 100 RECs will be deemed to have been delivered in year 3, exactly meeting the delivery obligations for each of the component years of the 3-year rolling average. Subsequently, if 100 RECs are delivered in year 4, this results in a 3-year rolling average of 100 RECs ((100 from year 2 + 100 from year 3 + 100 from year 4)/3).
(Updated February 2023)
If an Approved Vendor learns that one of its Part II verified systems has been offline (no longer electrically connected to the distribution system or no longer delivering power to either an on-site load or to the distribution grid) for one month or longer, it must notify both the Program Administrator and that system’s contracting utility. If appropriate given the specific circumstances for which the system is offline, the Approved Vendor may consider making a force majeure claim under the REC contractor or request a reduction in REC delivery obligation under the REC contract.
If the system remains offline for more than three months, the Approved Vendor must notify the contacting utility, Program Administrator, and IPA. The contracting utility and IPA will then evaluate if the system is in material non-conformance with the requirements of the Program under the REC contract, and if any repercussions may be applicable, including pausing payment on any unpaid amounts under the Program. Please direct any questions to the Program Administrator at [email protected].
(Updated February 2023)
- Date request is being made
- Vendor ID
- System ID
- Detailed reason for the proposed REC reduction
- The proposed quantity of RECs to be reduced (ex. 500 RECs were promised, only 300 RECs will be delivered)
- Requested new Contract Nameplate Capacity
- For systems permanently going offline, the new Contract Nameplate Capacity should be calculated to correspond to actual number of RECs delivered to date.
- For systems continuing operation at a reduced capacity, the Approved Vendor must provide a new Contract Nameplate Capacity.
- Value of the payment adjustment that is required, calculated by the multiplicative product of the Contract price and the REC Reduction Quantity
Some projects located in one utility’s service territory may be contracted to another utility, as the interconnecting utility and the contracting utility may or may not be the same entity. The interconnecting utility is the utility that issues the interconnection agreement and to whose infrastructure the project system is connected. The contracting utility (also known as the Buyer) is the utility that signs the REC Contract and purchases the RECs delivered by the system. There are only three contracting utilities: ComEd, Ameren, and MidAmerican. A project system may be interconnected to Ameren but contracted with ComEd for REC delivery, or vice versa. The Program Administrator determines which utility will serve as the Buyer for each contract. While a batch may contain projects in multiple utility service territories, the Program Administrator will strive to assign contracts to the utility where the bulk of the projects are located but may not always be able to do so because consideration is made to allow each utility to meet its pro-rata share of the Renewable Portfolio Standards (“RPS”) REC targets and available RPS funding. The REC price for each system will be based on the applicable Group for that system’s physical location, and not based on service area of the contracting utility.
(Updated July 2024)
Annual Reports
On an annual basis, each Approved Vendor with an active REC Contract is required to submit an Annual Report covering the contracts and systems in its portfolio, which serves as the basis for verifying that RECs are being delivered as required.
Approved Vendors should monitor the inbox of their organization’s primary email address as provided to the Program for the official invitation to submit their Annual Report.
(Updated June 2024)
Non-submission of the Annual Report is an Event of Default of the REC delivery contract. This will jeopardize an Approved Vendor’s standing in the Program, meaning without submission of an Annual Report the ability to participate in the Program is revoked.
(Updated June 2024)
The Annual Report includes the following information:
- RECs delivered by each of the systems in the portfolio (as reported by GATS/MRETS)
- Status of systems that have been approved but not yet energized
- Energized systems that have not delivered RECs
- Subscriber information for Community Solar (CS) projects
- Balance of collateral held by each utility
The above items are provided to Approved Vendors for review and confirmation of accuracy. Approved Vendors are expected to raise any concerns with the data (e.g. inaccuracies) during the Annual Report process.
The following items must be provided by the Approved Vendor during the annual reporting process:
- Summary of requests for REC obligation suspension, reduction or elimination
- Information on consumer complaints received
- Verification of prevailing wage requirements
- Verification of CS scoring requirements
(Updated June 2024)
The portions of the Annual Report that are provided to the Approved Vendor for review will be added to each Approved Vendor’s SharePoint folder. The remaining items can be answered through the Annual Report form that will be sent at the beginning of a Program Year. The Annual Report Form is built using Microsoft Forms and is structured like a survey. There are questions referencing the reports that are provided through SharePoint and areas for the Approved Vendor to provide information about other topics, including such topics as consumer complaints, prevailing wage, and requests for REC reduction. Supporting documents may be emailed to the Program administrator separately or uploaded to the Approved Vendor SharePoint folder where the reports are located. Tip: Use file names that correspond to the Annual Report topic and Approved Vendor name for additional documents. E.g. “PW_Requirements_Verification_AVName.docx”
(Updated June 2024)
SharePoint folders are created for each Approved Vendor by the Program Administrator. Approved Vendors receive an invitation to access their SharePoint folder from Microsoft SharePoint. Email [email protected] if you have not received an invitation to SharePoint or if you need to make access changes. The Program Administrator can only grant access change requests that come from the same email domain as the Approved Vendor’s primary email address.
(Updated June 2024)
The following are key dates relating to Annual Reports:
- July 1 – Annual Report Response Period begins
- July 15 – Annual Report Response Period ends
- July 16 – Annual Report Cure Period begins
- October 1 – Last day for Program Administrator to inform Approved Vendors of discrepancies on Annual Reports
- October 14 – Annual Reports are finalized
- November 15 – Program Administrator Drawdown calculations complete
(Updated June 2024)
Please visit the Program Help Guides and Application Tips page for additional resources on Annual Reports.
(Updated June 2024)
- Collateral Report
-
a. Rather than reporting balances for comparison, Approved Vendors will be presented with utility-provided collateral balances to review and approve.
- Confirmation that prevailing wage requirements are being met for any maintenance to projects subject to prevailing wage requirements.
- Confirmation that community solar scoring commitments at being met.
- Demographic questions related to workforce have been removed and are now included in the Minimum Equity Standard (“MES”) Year-End Report.
The purpose of the REC Performance Evaluation process is to ensure that the Approved Vendor is meeting its obligations under the REC Delivery Contract. This provides leverage (via potential Drawdowns of collateral resulting from the REC Performance Evaluation) to make sure RECs are delivered in appropriate quantities over the contract term. One of the core items in the annual report is reviewing REC quantities. The Program Administrator takes all the registry data and sums it up by delivery year. The totals by year are what make it into Drawdown calculations. The Annual Report is the opportunity for Approved Vendors to ensure the systems that are required to undergo an evaluation are included in the report, have correct REC delivery quantities reflected, and to provide corrections and/or supplemental information to support the accuracy of the evaluation. This includes the “curing period” where Approved Vendors may be contacted to clarify or provide additional project information.
(Updated June 2024)
