Tool Development Considerations

Stakeholder Engagement

Respondents indicated that numerous stakeholder groups should be included in stakeholder engagement and feedback opportunities for the creation of this tool. Groups that respondents want included are state and local governments, community solar developers and subscription managers, consumer advocates, community-based organizations, utilities, affordable housing agencies, tribal representatives, and IT companies. Numerous respondents also emphasized the importance of engaging directly with low-income households throughout the process, especially diverse stakeholders. Utilities were also indicated as a key stakeholder, as community solar developers and subscription managers often need access to historical utility billing information to determine subscription size for new subscribers and to coordinate billing and subscription credits.

Tool Project Requirements

Respondents indicated the need for robust consumer protection requirements for all projects and developers who connect to the tool. At a minimum, they felt that developers should sign a standard attestation, that is renewed annually, about the protections they will have in place and how they can/not use the personally identifiable information (PII) of the LIHEAP recipients for any purpose other than enrolling them in the program. Examples of consumer protection requirements that could be critical are: requiring a threshold of verified minimum bill savings (e.g., 20% or a dollar amount, with a preference for dollar amount since it is easier to understand for LI households); no sign up or deposit requirements; no exit, termination, or cancellation fees; no late, annual, or additional fees; no credit checks to qualify for participation; easy cancellation terms; and regular (e.g., annual) checks on existing programs/offerings to ensure that they meet standards. Additionally, consumer advocates emphasized that customers should not have to negotiate their own contract terms and a seamless hand-off between the tool and providers will improve the customer experience. Many commented that there should not be multiple developers or subscription managers reaching out to the same LI households. Respondents also preferred to only have projects connected to the tool that would be operational in the short term (e.g., within six months) to reduce the time when customer realize savings, and suggested projects should only connect to the tool after they had received their interconnection agreements, had secured legal control of their sites, and received their non-ministerial permits.

In addition, respondents indicated that consent language will be necessary in order for LIHEAP customers to have their data shared with developers or subscription managers who have available low-income community solar subscriptions. Currently, each state has individualized consent language and standardization would help with consistency of expectations nationally, if possible. If this could be combined with consent language for utility data release, the developer or subscription manager can right-size the subscription for the household based on historic energy usage data. Finally, subscription managers indicated that once customers are connected and signed up with a community solar subscription, that information can be sent back to the tool, so that particular subscription is allocated and removed from further consideration and availability on the tool.

Tool Implementation and Outreach

Many respondents indicated that transparency, education, trusted messengers, and robust outreach programs will be vital to the successful implementation of the tool. Many indicated the need for clear educational resources that explain how community solar programs and the tool work, how billing is set up, and how benefits like bill savings are administered. Additionally, on-call customer service during the decision process, via email, text, and phone, could be critical for success of the tool. Respondents indicated that these resources should be created for both community action agency staff – who are the on-the-ground organizations implementing the LIHEAP program and connecting folks to community solar through this tool – as well as LIHEAP household participants. Respondents emphasized the need for outreach materials to be in Spanish and other non-English languages. Some respondents recommended pursuing targeted community engagement, through local community representatives and community action agencies, to ensure the successful rollout of the tool in the pilot states.

Many stakeholders also emphasized the need to adequately fund state energy offices, state-level LIHEAP administrators, and community action agencies to ensure they have sufficient capacity to implement the tool successfully. In addition, one respondent indicated the need to ensure that customer education and support lasts for the lifetime of projects to ensure that LIHEAP customers receive support beyond the initial customer acquisition period, where they can continue to have a positive experience with the program over the long term.

Tool Access

Respondents emphasized the need to create a tool that is flexible and can be modified to meet the needs of different states in terms of policy and program requirements. Respondents varied in their responses about who should have access to the tool. Subscription managers and developers indicated their need to access the tool to identify potential subscribers. Many indicated that developers and subscription managers should have limited access to data from the tool, and they should only access data for LIHEAP households who actively opted in (or is required by their state to participate in) community solar and consented to having their data shared. Many respondents also indicated that the tool should support open-source application programming interfaces (APIs) for the most flexibility and access for developers and subscription managers. However, to protect personally identifiable information (PII), respondents suggest that the APIs only share pass/fail information initially to identify if a potential match exists, and then PII could be shared and customer marked as eligible and then matched.

Many respondents indicated that there should be an accessible tool so LIHEAP recipients can access data about available subscriptions and have choice in their subscription selection. LIHEAP recipients could select projects based on projected bill savings, project location, customer reviews, pricing, or other factors. If now or in the future, low-income households have access to the tool, respondents indicated the need for robust accessibility and tool support, so they can view the project owner’s name, project details, and bill credit information (and have it standardized across all projects). To ensure accessibility, respondents suggested that the tool should work on desktop, tablet, and mobile devices, include language access, and that online tool support can be provided through multiple channels, such as phone, email, or text options.

Tool Ownership and Management

Ultimate ownership of this tool is distinct from long-term tool management and both should be addressed. Respondents did not express a unified perspective on long-term management and operation of the tool nor on a long-term business model for the tool. Most subscription managers, developers, power providers, utilities or utility representatives who responded to the RFI indicated an interest in supporting the creation and/or long-term operation of the tool. Some indicated that having utility management, experienced IT companies, or subscription managers in charge of the tool could lower costs. The majority of other stakeholders, such as consumer advocates and government entities, indicated that a nonprofit or government entity should maintain long-term management and/or operation of the tool. Some respondents indicated that transferring ownership to a utility or community solar provider could lead to unfair advantage. There was no consensus on who should ultimately own and/or operate the tool, as well as no consensus on a long-term business model for the tool.

Community solar project developers were generally willing to pay for low-income subscribers to access their projects; they would prefer to avoid monthly payments and were more interested in paying for successful subscriptions than connections to households that indicated interest.

Policy Constraints

Over a third of respondents indicated that consolidated billing is necessary to ensure the successful rollout of this program. Consolidated billing is when community solar credits are consolidated into the utility’s electricity bill, rather than a community solar subscriber paying their electric bill and receiving a separate accounting of community solar credits. Some respondents indicated that local utilities may be seen as a trusted billing source for LIHEAP customers since they have a pre-existing relationship, whereas external developers or entities with a separate bill might be met with more skepticism. Respondents indicated that two bills can be confusing for households, and can make the bill savings seem unclear. LIHEAP customers can also be on budget or balance billing, with a fixed bill each month and participation in community solar could remove them from this levelized payment system. A few respondents also noted there are a few successful alternatives to consolidated billing that are worth exploring (e.g., NYSERDA buys and disperses credits onto bills).

Consolidated billing can also tie in with utility data sharing, as respondents noted that utilities providing past data can help inform what quantitative cost savings will be delivered to LIHEAP customers based on historical energy usage. Additionally, respondents emphasized that consolidated billing and utility collaboration simplify the customer experience by combining community solar credits and charges on the participants normal utility bill and reducing the amount of monthly paperwork. Overall, according to respondents, consolidated billing (or a similar alternative) is important for ease of customer use, for payment effectiveness, and for utility participation.

Respondents indicated that state differences in LIHEAP administration and community solar policies may impact the tool development and that state regulators can coordinate qualification between LIHEAP participants and the state’s low-income community solar programs. Respondents also indicated that states have different LIHEAP program start and end dates, as well as additional state-specific program processes and requirements, and this may impact the development of the tool. Respondents also emphasized that states also have varying capacity constraints due to staffing, administrative, IT capacity and IT infrastructure age, which may impact their ability to support the tool, interact with the tool, and oversee project vetting and verification.

In addition, respondents indicated that multifamily affordable housing residents should have access to the benefits of this tool, because signing up a whole building is easier than individual residents. Respondents indicated that they want policymakers to ensure that access to community solar will not negatively impact other benefits received by LIHEAP households. To ensure that multifamily affordable housing residents can have access, states can coordinate with the U.S. Department of Housing and Urban Developemnt (HUD) to ensure that utility allowances are not impacted by community solar benefits.

Many respondents submitted comments recommending that the tool coordinate with Inflation Reduction Act implementation so that community solar projects that connect with income-qualified customers through the tool can be used as a proxy verification for the Low-Income Bonus Credit under the extended Solar Investment Tax Credit.

Technical Tool Considerations

Data Security Requirements

Respondents, especially consumer advocates and subscription managers, indicated that personally identifiable information (PII) must be encrypted using accepted standards (e.g., ISO 27001), and that application programming interfaces (APIs) should be used to securely connect interested households who have consented to participating in the program. Most stakeholders indicated that the tool should include customer name, home address, phone number, email address, utility account information, and the customer’s consent approval (for the state and/or utility with a Y/N for each). This information could then be sent to the subscription manager or developer to complete customer enrollment.

Consumer advocate respondents indicated that the tool needs to include appropriate mitigation for data breaches if it will contain personally identifiable information (PII). Some respondents also indicated that to protect customer privacy, the tool should not allow for proactive outreach through the tool to LIHEAP eligible households, but only to households who have consented to this outreach. While developers could reach out to households independently, consumer advocates emphasized that the tool should only release data with customer consent. Many indicated that the tool will need dedicated engineers to maintain the database, personally identifiable information (PII), and APIs connections over time, as well as provide support to the LIHEAP administrators and community solar subscription managers and project developers as needed.

Information Technology Systems

Respondents indicated that the tool should be highly customizable and secure, so that it can be adjusted for the needs and policies of each state, no matter how advanced the state’s programs and software is. Many indicated that the tool should have clearly defined requirements, security controls, verification and validation that is checked over time. Some respondents indicated that a single sign-on (SSO), potentially through utility account credentials, could simplify the customer experience.

Required Features

Most respondents agreed that LIHEAP customers should sign an authorization to allow for the release of their data for the tool. This information could then be communicated securely to the community solar developers or subscription managers to verify the secure release of customer information.

The majority of respondents indicated a preference for the tool being operated in an opt-in fashion, with some, especially consumer advocates, advocating for opt-out support. In this way, the tool should be developed so that it can support either opt-in or opt-out community solar programs, reflecting each state’s program design requirements. Respondents indicated that the tool should allow for some customizability so it can adjust to the policy and program needs of each state. Respondents also indicated that the tool should track, over time, aggregate numbers of subscribers successfully enrolled, as well as aggregate customers waiting to connect to projects in each service territory. This would help support planning for new project capacity as well.

Subscription Considerations

Project and Developer Vetting Process

Respondents indicated that the standardization of project terms could help LIHEAP administrators, community action agencies, and LIHEAP households to compare different community solar subscription offerings (e.g., have all projects provide a monthly savings amount).

Respondents indicated that the vetting process should ensure that projects on the tool will deliver the promised savings and also be built within a reasonable timeframe for customers to receive benefits. There were varying recommendations for processes to vet and verify projects, as well as developers. Some respondents recommended whichever body oversees community solar in the state to be the one to vet and verify projects, which can be state agencies. There was also a question about which community solar projects or developers would be prioritized if there is more than one in a specific location – suggestions included prioritizing developers with facilities or projects located in environmental justice communities or only those that have experience with LI households and communities.

Community solar developers indicated that adding customers to waiting lists is essential. This is especially important to do ahead of project development. Developers emphasized the benefit for project financing if they can connect to customers in earlier stages of project development (earlier than the recommended 6-month timeframe). One respondent suggested providing subscriptions on an aggregate capacity basis rather than for specific projects to account for variable timelines for project creation. This would mean assigning a household to a developer's portfolio rather than a specific project initially. One respondent indicated the desire for community solar providers to demonstrate partnerships with community-based organizations to have access to the tool as a way of ensuring that projects will provide benefits and authentic engagement to and with the communities they serve.

Prioritization of Households

Most respondents assume that there will initially be more LIHEAP recipients opting in to low-income community solar subscriptions than will be available at any given time, so prioritization of households may be necessary. Several respondents suggested to not use first-come, first-served as the basis for assigning low-income community-solar benefits, but rather use a standard and transparent list of metrics to prioritize households.

Many different examples of potential metrics on how to prioritize households were given. Perhaps the most straightforward are those that include information that LIHEAP administrators collect to determine LIHEAP eligibility and prioritization. Households in arrears were identified as a potential first priority, to reduce arrears. It was also suggested that LIHEAP recipients that regularly received total bill payoffs could be prioritized over those with partial bill payment or occasional total bill payoff. Other possibilities were suggested including energy burden over a specific value (6% and 20% were both mentioned), households on fixed income, and households in disadvantaged communities (DACs).

In order to track interested households, developers and subscription managers suggested creating a waitlist (by state and utility territory at a minimum) to provide an indication of interest in community solar participation across the country; this list could help prioritize the future location of new community solar project development targeted at low-income households. Additionally, they suggested that it will be important to keep the LIHEAP administrators informed about how many people are waiting and upcoming projects in their area, so they can clearly communicate availability to households.

Bill Savings Accountability

Respondents indicated concern with a required 20% savings, as savings amounts may vary by region or state. Some respondents mentioned that if a minimum of 20% savings is established as a mandate, the burden of these cost savings might be passed onto non-low-income customers. Respondents indicated that there will need to be additional conversations to determine what the best savings strategy is to ensure that participating households receive sufficient benefits. Respondents indicated that if a specific savings threshold is required, it should be clear how it is defined (e.g., 10% savings per month/year, or $X/month savings in summer months), and that if savings are guaranteed, that should be included in a contract or signed offering with the customer. Many respondents emphasized the importance of having access to historical utility data to calculate bill savings.

By lowering customer acquisition costs, some developers and subscription managers indicated that this should be able to lead to increased savings for customers. Respondents did not provide detailed strategies of how the tool can ensure bill savings are achieved for households as a result of customer acquisition savings.

Developer Support

Some respondents indicated that because developers and subscription managers will benefit from lower customer acquisition costs from the tool, they should contribute to the implementation costs, including ongoing costs for updating information for customer service and complaints resolution, as needed. Developer respondents generally indicated a willingness to contribute financially to the tool support and management, with a preference for paying for successful subscription connections. Developers communicated that the effectiveness of the tool, as well as concrete results and customer retention, would justify them paying in to use the service. A few respondents indicated an interest in paying for an allocated LMI capacity through a fee as opposed to a pay-per-subscriber model. Some developers also indicated a desire to get a refund for certain fees paid if customers defect or do not get replaced readily.

Subscription Turnover

Some respondents indicated that customer turnover should be managed by developers or subscription managers after being connected through the tool. Many respondents – including developers, trade organizations, and state agencies – indicated that it's important to streamline and limit the need for re-qualification of income eligibility. This means that once households are verified, they should be enrolled in the community solar program for multiple years (e.g., 3 years or 5 years) or even indefinitely. Respondents also indicated that it is important to ensure that customers can stay connected to community solar benefits if they move within the same service territory for the project. This means their subscription can get transferred, or they get a referral for another project.

Additional Barriers and Considerations

Respondents indicated that there is a great need for additional consumer education on community solar and that the DOE can do more to help define community solar and its benefits. Some also indicated that the National Community Solar Partnership’s technical assistance program can provide additional support on community solar development and education, especially for local and state officials. Respondents also indicated the importance of marketing technical assistance to environmental justice stakeholders and relevant community-based organizations.

Many respondents indicated that it would be important to build the tool so that it could be expanded to include additional income-qualified programs in the future beyond LIHEAP. This could include additional government programs such as the Supplemental Nutrition Assistance Program (SNAP), Medicaid, Lifeline, the Weatherization Assistance Program (WAP), Temporary Assistance for Needy Families (TANF), and other energy bill or water assistance programs.

Rural communities have additional challenges of fewer government resources, and solar prospect limitations in mountainous or forested areas. Respondents indicated that with the passing of the IRA, the tool could help provide educational materials for those interested in learning more about incentives and community solar, such as for communities served by rural electric cooperatives. Respondents indicated that this tool could be tangentially used for community solar marketing and as an educational opportunity targeted towards low-income customers. For instance, a respondent suggested enabling a ‘inform your neighbor’ capability on the tool for users to alert their neighbors about what community solar is.

Some respondents also indicated that by including LIHEAP recipients, income-qualified households who do not have access to the LIHEAP program will be excluded from this tool. Households that experience barriers to accessing LIHEAP will also experience barriers from accessing community solar through this tool. Expanding to additional income-qualified programs in the future could help to address this challenge.