Summary: Low-Income Community Solar Subscription Tool Request for Information

On July 27, 2022, the U.S. Department of Energy (DOE) Solar Energy Technologies Office (SETO) released a Request for Information (RFI) to obtain feedback on the structure and development of the Low-Income Energy Connector. DOE will develop and pilot this digital tool to make community solar more accessible to households participating in government-run, low-income support programs. The tool is initially intended for Low-Income Home Energy Assistance Program (LIHEAP) recipients.

The RFI, developed in partnership with the U.S. Department of Health and Human Services, sought input from a wide variety of stakeholders. We received 45 responses from organizations including solar developers, subscription managers, IT companies, trade associations, utilities, state and local governments, consultants, nonprofits, consumer advocates, community-focused organizations, and others.

Summary of Stakeholder Feedback

Tool Development Considerations

TopicKey Recommendations
Stakeholder Engagement
  • State and local governments, tribal authorities, community solar developers and subscription managers, consumer advocates, utilities, community-based organizations, affordable housing agencies, and IT companies all have key perspectives needed for the success of the tool.
  • Respondents indicated that community engagement should be considered, including low-income household members and LIHEAP participants.
Requirements
  • Robust consumer protections are critical to ensure data privacy and protections for participating LIHEAP households.
  • Respondents indicated that the tool can include standard consent language that states can use to confirm the release of LIHEAP customer data to streamline connection with community solar projects.
Implementation and Outreach
  • Outreach and educational materials that are transparent and build trust for LIHEAP staff, community action agencies, and participants will be critical for project success.
  • Real-time customer service to support access to community solar programs can support a high-quality customer experience.
  • Respondents emphasized that adequate funding to state energy offices and/or LIHEAP administrators will support implementation.
Access
  • Limiting developers and subscription managers access to LIHEAP household data increases security, and customer consent should be included before any data is shared.
  • Respondents indicated that the tool should be flexible to meet the needs of all state LIHEAP and community solar programs.
  • LIHEAP recipients could access the tool to have more choice and transparency about community solar subscription options.
Ownership and Management
  • Non-developers and subscription managers prefer a nonprofit or government entity to maintain long-term ownership and/or operation.
Policy Constraints
  • Consolidated billing is important for the tool’s success.
  • Respondents indicated that DOE, HUD, and others should ensure other low-income benefits such as utility allowances are not impacted by access to community solar.
  • States have varying policy requirements, and the tool can be adaptable to meet each state’s needs.
  • Respondents suggested that it would be beneficial if the tool could be a proxy verification to developers for the Low-Income Bonus Credit under the extended Solar Investment Tax Credit (ITC).

Technical Tool Considerations

TopicKey Recommendations
Data Security Requirements
  • Advocates indicated that personally Identifiable Information (PII) should be minimized and encrypted using accepted standards to ensure household data privacy and security.
  • Numerous stakeholders suggested the tool should obtain participant consent before providing data to subscription managers or developers.
  • Dedicated engineers can support long-term tool security and updates.
Information Technology Systems
  • The tool can be developed to be customizable for each state.
  • Subscription managers indicated that the tool should be able to integrate with all community solar subscription management platforms.
Required Features
  • Respondents indicated preferences for both opt-in and opt-out models for low-income community solar programs, indicating that the tool should be able to operate and support both types of models.
  • Solar developers emphasized the desire for on-going tracking of both current community solar participants and waitlisted participants (anonymized) based on location.

Subscription Considerations

TopicKey Recommendations
Project and Developer Vetting Process
  • Respondents emphasized that a vetting process can ensure developers and projects meet the consumer protection criteria, such as minimum required energy savings.
  • State offices managing community solar programs could perform the vetting process to make sure projects are suitable.
  • To ensure households are connected in a timely fashion, some suggested that projects could be added to the platform when they will be operational within six months.
Prioritization of Households
  • Prioritization can help ensure that households with the greatest need are connected to projects with priority.
Bill Savings Accountability
  • Respondents indicated that required bill savings should be clearly defined and indicated in the community solar contract that LIHEAP customers will sign to ensure they receive savings from the project.
  • Bill savings amount may need to vary depending on market conditions.
Developer Support
  • Developers indicated that they were willing to financially support the tool implementation and maintenance, and preferred to do so based on the number of customers acquired through the tool rather than an annual or monthly fee.
Subscription Turnover
  • Respondents emphasized that limiting the need for income re-verification would lower administrative burdens for program managers and participants and ensure benefits are gained over a longer period.
  • Respondents also indicated that it would be important to ensure participants are connected to the tool for subscription transfer if they relocate.

Additional Barriers and Considerations

TopicKey Recommendations
Additional Considerations
  • Some also emphasized the need for continuing education for local and state officials on the tool and community solar programs.
  • Respondents supported a potential for future expansion to additional government income-qualified programs such as SNAP, WAP, etc.
  • A few respondents also indicated that technical assistance to relevant community-based organizations and stakeholders could help with successful implementation of the program.
  • A few respondents also indicated that rural communities may experience additional barriers to participation.

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