Compass is uniquely positioned to provide turn-key compliance, monitoring, and audit preparation due to our extensive experience with Domestic Content compliance, monitoring, and audit support from Ontario, Canada, which stipulated similar compliance requirements across supply chains.

Similar to the IRA requirements, the Ontario rules had both labour tracking and equipment manufacturer audit requirements. We completed Domestic Content auditing on over 200 MW of solar projects and as a result, developed a repeatable process that we can leverage to help assess compliance with the IRA requirements. We conducted over 50 manufacturing site audits throughout the solar supply chain in Ontario and are intimately familiar with the different major components and subcomponents that are used within each.

Task 1 – Pre-Construction Compliance Planning

Critical step prior to drafting the EPC Agreement. Contractual obligations will be identified, and specific language will be furnished for the EPC Agreements and to be passed down through subsequent supply chain agreements. Template documents and minimum standards will be set.

Task 2 – Domestic Cost Percentage Determination

Data requisition of Direct Costs from specified supply chain vendors (Manufactured Product and U.S. Manufactured Product Component vendors). Compliance approach and target Domestic Cost Percentage will be determined in conjunction with the procurement plan to ensure the adjusted percentage minimum requirement is exceeded.

NOTE: Compass Energy Consulting can act as a third party to the manufacturers so that cost information remains confidential.

Task 3 – Annual Prevailing Wage Determination

Reoccurring task to determine the applicable prevailing wage(s) for the construction, alteration, or repair work expected on-site for that calendar year.

Task 4 – Monthly Compliance Reporting

Adherence to labor provisions and Domestic Content requirements progress. Identify any shortcomings in compliance with applicable next steps to realign compliance.

 

Task 5 – Manufacturing Supply Chain In-Person & Desktop Audits

In-person auditing of selected equipment manufacturers to ensure capability of satisfying contractual requirements and maintaining robust data management systems to substantiate compliance. Desktop auditing to ensure records provided are complete and accurate by reconciling production, shipping, and invoice records with purchase orders. These reports will form part the evidence of compliance in the event of an audit.

Task 6 – On-Site Project Audit

Ensure labor hour tracking compliance, retention of qualified apprenticeship evidence, and major equipment deliveries are tracked and recorded for traceability to U.S. production records.

Task 7 – Labor Provisions & Domestic Content Audit Binder

Compiling and organizing all prevailing wage, apprenticeship, and Domestic Content records required to sufficiently evidence that the contractual requirements have been met and/or exceeded for the 30% base credit and 10% Domestic Content bonus credit.

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Audit-proof your portfolio. Reach out to Compass Energy Consulting today to learn more about how we can support your compliance plan, implementation, and record keeping.