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State Energy Strategies Project: Lessons Learned for State Agencies

From 2017 to 2020, Connecticut, Minnesota, New Mexico, Oregon, Rhode Island, and the District of Columbia worked with CESA to develop and implement innovative strategies for expanding access to solar for low-to-moderate income (LMI) households and communities. The United States Department of Energy (DOE) Solar Energy Technologies Office provided a financial award to fund this work.

An original objective of this State Energy Strategies project was to expand market penetration of solar PV among LMI residents and communities, and this objective was certainly met. Over 30,000 LMI households have received or will receive the benefits of LMI solar. In addition, the work of the project team yielded a deeper understanding of the unique challenges of LMI solar and of ways to meet those challenges.

The differences in implementation across the participating states point to the many diverse routes available for implementing LMI solar. The experiences of those states provide useful guidelines for other states and indicate the need to continue growing the knowledge base around LMI solar policy.

This webpage has been published to share some of the lessons learned. We also provide links to case studies, reports, webinars, and other products developed over the life of the project. We believe that the insights and links included here can be of use to states across the country and to many other stakeholders interested in LMI solar.

General Lessons Learned Research Connecticut District of Columbia Minnesota New Mexico Oregon Rhode Island Acknowledgements

General Lessons Learned

GENERAL LESSONS LEARNED

LMI Solar Is Complicated

Even when there is strong commitment on the part of a state agency to advance LMI solar, progress can be slow. The project team understood upfront that it is difficult to implement LMI solar, especially in ways that provide meaningful economic benefits for LMI households. However, the obstacles turned out to be even more numerous and difficult to overcome than expected. Each obstacle requires a well-planned strategy and concerted effort.

For example, the project team initially assumed that shared solar projects with subscribers (often called “community solar” by the solar industry) would be a relatively easy way to bring solar to large numbers of LMI households. However, there were more obstacles than expected to include LMI subscribers in community solar projects and there were serious consumer protection issues that needed to be addressed. To take an example of another obstacle, because of previous predatory practices in LMI communities (mostly having to do with competitive electricity suppliers rather than with solar), there was considerable community distrust that needed to be overcome. Regulatory changes in one of the states also posed problems. The multiple obstacles meant that the states needed to proceed carefully and deliberately when developing their plans. The planning phase of the project therefore took longer than expected, but it set up a foundation for long-term success.

Different Submarkets Need Different Strategies

The LMI market is diverse, and a single program will not reach or impact all segments of that market in the same way. A solar program is unlikely to be able to serve both LMI homeowners and renters equally, or benefit community institutions and individual households to the same degree. State solar programs will generally be most successful if they explicitly target specific market segment(s) and are tailored to the needs of that audience.

Community Engagement is Essential

The project team learned that it was especially valuable to engage and work upfront with representatives of community-based organizations (CBOs) that understand the needs of LMI households in their state. This helped ensure that the strategies developed by the participating states would be well received. For case studies of states’ work with CBOs and general recommendations, see a report produced for this project: Community Outreach and Solar Equity: A Guide for States on Collaborating with Community-Based Organizations. Because of the importance of this topic, CESA is embarking, with DOE support, on a new initiative that will work with state energy agencies and CBOs so that they are better able to share the knowledge and information that is needed for solar to be developed efficiently, equitably, and cost-effectively in LMI communities. Read more about this initiative on the Solar with Justice webpage.

Successful Programs Often Require Cooperation among Multiple State Agencies and Programs

Several states found success through coordinating working groups which included multiple state agencies. For example, the District of Columbia’s Department of Energy and Environment (DOEE) engaged partners in an LMI solar working group which included the District Department of Consumer and Regulatory Affairs (DCRA), District of Columbia Housing Authority (DCHA), and the Office of People’s Counsel, among others. Working groups allowed for greater information sharing and effort coordination.

Good Data Is Key

Lawrence Berkeley National Lab and the National Renewable Energy Laboratory provided valuable information to the states on income trends among residential PV adopters and community solar pricing models. In addition, most of the states collected data that significantly influenced the design and implementation of their strategies. See, for example, the discussions by Connecticut, DC, and Minnesota.

Different States Need Different Strategies

States vary in several ways: their LMI populations live in different mixes of housing; the electricity system in structured in different ways; electricity prices vary; the solar industry is in a different state of development; and solar policy varies. All these and other factors require a state to develop and implement an individualized strategy.

Research

RESEARCH

At the beginning of this project, the six participating states all recognized the importance of addressing the need for better access to the benefits of solar among LMI communities. However, they also faced unique challenges within their operating context, from limited budgets and staff resources to unfavorable regulatory environments. Funding from this grant award, along with research support from teams at Lawrence Berkley National Laboratory, National Renewable Energy Laboratory and CESA, helped address some of these gaps in knowledge as well as inform LMI solar strategies among the states.

Research produced for all participating states, as well as other LMI stakeholders, includes:

Connecticut

CONNECTICUT

Photo Credit: CT Green Bank

The Connecticut Green Bank spearheaded Connecticut’s efforts under the SES grant. Connecticut’s approach to improving access to LMI solar included three main initiatives. Each initiative provided its own challenges and lessons learned:

(1) Green and Healthy Homes Initiative

This initiative focused on creating a link between a building’s quality, health and safety, energy efficiency deployment, improved energy home profile, and improved health of occupants. A better home environment can address several health issues, including asthma and falls that result in medical expenses. It can also provide savings from energy efficiency and solar. The initiative required considerable cross agency participation involving multiple state agencies and utilities. Some lessons learned are:

Relationships are critical to achieving success. Many different people have been involved, including commissioners from the participating agencies and their staffs. During the three years that the Connecticut Green Bank worked on this project, the governor changed, which led to commissioner and staff changes. That required starting over by reeducating and getting folks on board again. This is an issue to be prepared for when dealing with senior people at the political appointee level.
Hard data is important. The initiative sought to use medical dollars to cover in-home interventions that improve health and safety. The project made a significant investment in collecting data that would show the potential payback and payout. Having hard numbers helped get approval to move forward. Although the data collection and analysis were time-consuming, they were worth it.
Regular communication is important. Even though Connecticut is a relatively small state and does not have as much bureaucracy as larger states with more complex governing structures, it was important to communicate regularly with the many agencies working on the project, as well as with other stakeholders interested in it. The project unfolded slowly over several years. To make sure folks stay involved and committed to the project, it is important to communicate regularly with stakeholders even if nothing dramatic is going on.

(2) Solar for All

This was focused on the implementation of a model of solar for single-family owner-occupied homes that included elevated incentives for LMI households, affordable solar leases, strong consumer protections, support for solar companies entering the LMI market, targeted outreach via community outreach campaigns. Lessons learned include:

Combining solar with energy efficiency is desirable. Many of the participating households had the potential to save significant money from efficiency, which could increase overall savings when combined with a solar installation. Posigen, the Green Bank’s solar company partner, coupled solar with in-depth efficiency and made this a required component of the program in 2019. Participants received a combined solar plus efficiency offer.
Community partnerships are important. The Green Bank partnered with nonprofits and municipalities to run community campaigns. Solar for All built on an existing initiative, Sustainable CT, which is a sustainability certification for municipalities. Municipalities could receive credits towards certification by participating in Solar for All. The partnerships with communities developed relationships that could help address problems on the ground.

(3) Support implementation of shared clean energy facilities legislation

Shared solar can be a critical policy for making the benefits of solar available to all LMI residents in the state, including renters. Connecticut is developing a program that will require a significant share of the subscribers to be LMI households or LMI service organizations. Because the program has not yet been implemented, there is little in the way of lessons learned.

Products and Webinars Produced by the Connecticut Green Bank:

District of Columbia

DISTRICT OF COLUMBIA

Photo Credit: DC Solar United Neighbors

The strategy of the District Department of Energy and Environment (DOEE) focused on several approaches, including developing the Oxon Run brownfield community solar pilot project; collaborating on education for solar in affordable housing; a mapping project identifying the best community solar sites; developing educational materials on solar for low-income District residents; and a survey of low-income District residents. DOEE’s work under these approaches mostly fell under the District’s Solar for All program. Lessons learned from this work include:

Everything was more complicated than initially hoped. This was the biggest lesson learned. It was difficult for residents to navigate the PV acquisition process even with favorable incentives. DOEE therefore had to create no-cost or minimal-cost installations for residents and develop consumer protection solutions, standardized application processes, and secure information gathering. They also had to overcome distrust in the community.
Community partnerships were important. DOEE was able to gain access to customers by implementing outreach and engagement strategies involving community partnerships. DOEE partnered with other agencies working in the same community to reduce administrative burdens and increase education. They also created partnerships with local community councils so that joint branding and program identity would help bridge some of the trust issues that resulted from third-party competitors. As community partnerships increased, it became easier to get residents to sign up.
Developing direct relationships with property owners and lenders can pay off. It was difficult to obtain access to sites and real estate for PV installations, even when there were financial incentives. It was helpful for DOEE to deal directly with building owners to create the right incentives to compete with the many competing demands on building owners’ time and attention. Here, too, partnerships with community organizations were beneficial, including the local housing associations and the local real estate industry.

Similarly, even though the financial incentives for solar development were lucrative, it was difficult for developers to put together the capital for projects. Even with government grants, it was difficult to find lenders to invest locally. It has been important to develop relationships with lenders.

Products and Webinars Produced by DOEE:

Minnesota

MINNESOTA

Photo Credit: Minnesota Department of Commerce

The Minnesota Department of Commerce’s final LMI solar strategy included three approaches: expanding access to community solar gardens for income-eligible households; developing a model income-eligible solar incentive program; and identifying ‘no loss’ opportunities to leverage resources for income-eligible households. Lessons learned from this work included:

Be prepared for both success and failure. States ultimately want to have wide-scale development of PV projects benefitting LMI households and communities. To get to that point requires starting with pilot projects that can be tested and replicated. Pilots, by their very nature, will not necessarily all succeed. There will be a wide range of successes, and some failures. Similarly, the Department of Commerce’s action plan saw successes, where the ideas have been implemented, as well as some ideas that have been delayed or are still under discussion
Relationships with communities require ongoing nurturing. Outreach to communities is not a one-and-done conversation. It takes considerable time to develop relationships in communities, and those relationships then need to be maintained over time. Cultural differences need to be understood and respected. State agencies should expect to hear many strongly held different opinions about how best to serve the LMI community. For example, utility-scale solar may be cheapest to implement and yield the greatest equity benefits for LMI households, but distributed generation can be the most empowering for individual households and community organizations as well as provide long-term energy security. As other examples, there can be differences of opinion on how much to emphasize doing energy efficiency first before solar and on solar workforce development as an LMI priority.
Good data can influence strategy. The Department of Commerce gathered data from a variety of sources– the Low-Income Energy Affordability Data (LEAD) tool, Weatherization Assistance Program (WAP) data, Low-Income Home Energy Assistance Program (LIHEAP) data, anecdotal conversations—to determine how to proceed. For example, learning that there was only 6 percent uptake of a solar program in low-income areas built the case for having a carve-out. In terms of the decision to seek to incorporate solar into the WAP program, having good data from Colorado that showed that WAP+solar has a significantly larger impact built the case for acceptance.
Early and consistent engagement with stakeholders is critical for success. When seeking to modify or build on an existing program (e.g., Solar*Rewards and WAP), it is important to understand the current program requirements and how participating stakeholders view the program before adding any new measures or carve-outs. Then, it is important to get stakeholder buy-in into, or at least understanding of the reason for, the new provisions. It is especially important to get support of the solar installer community for complicated programs. In the case of the Solar*Rewards LMI Carve out, many developers were fearful that a excessively large share of Solar*Rewards dollars would be allocated to LMI projects; their concerns quieted with transparent, consistent stakeholder outreach/discussion. In the case of adding solar to WAP, some solar providers were initially against providing solar installation; engagement, training, and time led to a change in heart.
Financing is a big deal. Lack of financing was addressed as a critical barrier at some point in each pilot project and initiative. Successful projects utilized creative and flexible solutions, such as partnering with utilities to provide a monetized upfront incentive (Solar*Rewards), utilizing a crowdfunding mechanism that functioned as an investment tool for solar arrays (Red Lake), leveraging state agencies and nonprofits as “back up subscribers” to stabilize solar gardens where individual shares change hands (CEF).
Everything will take longer than anticipated. Much of this work is either in the pilot phase or is a new addition (disruption) to longstanding processes that have been run a certain way for many years. This requires time to train staff on new processes and technology and foster buy-in. Pilots are great, but the documentation and administrative burden are considerable and must be considered. All projects have many moving parts, many in arenas that are still developing processes and infrastructure resulting in high potential for delays in things like incorporating into existing programs (WAP), permitting, land acquisition (Lincoln Park), subscriber acquisition (CEF), and addressing stakeholder concerns.

Products and Webinars Produced by MNDoC:

New Mexico

NEW MEXICO

PV on a Pole installation. Photo Credit: New Mexico Energy, Minerals and Natural Resources Department

The New Mexico Energy, Minerals and Natural Resources Department (EMNRD) focused on the PV on a Pole™ concept, as the core of its LMI solar strategy. PV on a Pole was designed as a lightweight, easy to install, pole-mounted PV alternative for LMI manufactured housing residents who could not afford the structural modifications needed for a roof-mounted array. Unfortunately, the project faced many obstacles, including the imposition of high tariffs on steel, aluminum, and PV panels, which inhibited its scaling. However, EMNRD still gleaned several lessons from these difficulties:

Be realistic about the state’s political context. Community solar has not seen much success in New Mexico. In late 2015 when EMNRD looked at pushing for community solar, it seemed unlikely that a community solar bill would be passed by the legislature for New Mexico in the near term. Discussions about community solar bills for New Mexico continue regarding viable bills for the 2021 legislative session. All of this was due to a confluence of factors: A governorship that did not support community solar, utility opposition, and a lack of strong public sentiment. With these barriers in mind, EMNRD decided to pursue an alternative low-cost solar option rather than continue to push for community solar.
LMI solar solutions should be tailored to the community. New Mexico has a large population of low-income residents who live in manufactured housing. These residents face dual barriers to accessing solar for their homes – they cannot afford the multi-thousand-dollar upgrades required to site solar for residential use, and because they do not have a tax liability, they cannot take advantage of tax credits or incentives that might mitigate the costs of those upgrades. Added to this is that most manufactured housing cannot support the weight of solar panels on the roof, which means that manufactured housing residents would need to have access to enough land for ground-mounted panels. EMNRD designed the PV on a Pole concept to work around these barriers and address the localized needs of the LMI manufactured housing population.
Robust support is crucial to get a project off the ground. The PV on a Pole project was innovative and is still a possible solution. However, the project was underfunded, and under-supported. In order to promote this idea, a much more robust effort would be needed. Support was needed both at the local level with a manufacturer and a supportive solar installer, as well as from within EMNRD. PV on a Pole only had two dedicated staff members, and so it was difficult to put in the administrative, fundraising, and outreach efforts that the project needed.
Bring in partners early. Related to the lesson above, it was difficult to find partners with the capacity and finances to support PV on a Poletm. Vetting partners early with a robust screening of actual support for leadership support, funding support and personnel availability may have improved the outcomes of this project. Additionally, gathering help at the start of the project would have streamlined partnership efforts and potentially led to better successes later.
Consider eventualities when setting goals. EMNRD was ambitious with setting milestones for PV on a Pole’s success, but as with most pilots the project ran into obstacles that made achieving those goals difficult. For example, high tariffs on steel sharply increased the cost of manufacturing the kits, limiting the potential to scale. Setting more achievable goals and then expanding these through follow-on opportunities would have been more realistic for the type of pilot project EMNRD was pursuing.

Products and Webinars Produced by EMNRD:

Oregon

OREGON

Representatives from community organizations across Oregon participated in working group meetings to provide Energy Trust of Oregon feedback about how to make solar affordable and accessible for customers with lower incomes, customers from rural areas and communities of color. Photo credit: Energy Trust of Oregon

Energy Trust of Oregon’s LMI solar strategy included three approaches: building the capacity of non-profit and housing agencies to develop solar projects; supporting the development of effective and replicable funding models for LMI solar projects; and helping Oregon’s community solar program overcome barriers to LMI participation. Energy Trust found that making transformational progress in LMI solar is doable, but that frontline communities needed to be engaged in multiple ways:

State agencies need to lay a lot of groundwork to engage, excite, and empower frontline communities. That involves finding intersections with their work, financially valuing their time, and getting out of the office. Investments need to be made further upstream than state clean energy organizations are accustomed to. Energy Trust found that energy education is important for potential solar customers -- understanding their electric bill. For community solar, where the transaction is virtual, building trust and understanding of digital transactions and digital privacy are important
It is important to acknowledge how race and racism are present in this work. Many people in the renewable energy and energy efficiency field are upper-middle class white people most familiar with designing programs for other upper middle-class white people. Community engagement will help, but an important longer-term solution will be to make the clean energy industry more diverse and inclusive.
It takes additional funding to reach the LMI market. Energy Trust found that more funding is needed at all stages of project development and planning than they usually put on the table for their other programs. They provided funding for capacity-building for community-based organizations; early-stage project and program planning; and the upfront cost of solar installations
It can take creative solutions to ensure that LMI families reap financial savings from solar installations. For example, to avoid the situation where the federal Department of Housing and Urban Development (HUD) utility allowance formula causes residents’ rent to go up when utility costs go down, Energy Trust worked with a multifamily affordable housing project to set up a periodic granting program to tenants under which tenants can apply for the funds on a sporadic basis. Another project involved a community action program (CAP) agency that owns a manufactured home park; they put solar on the roof of the community building and pass the savings directly to tenants as cash payments.
Progress should not be measured primarily by kilowatts installed, at least in the short run. It takes time to build relationships, deeply understand customers, and do capacity-building. Opportunities to build long-lasting benefits and the potential for LMI solar solutions to scale will be limited in the future if the focus is primarily on the kilowatts installed at the end of the first year or two.

Products and Webinars Produced by ETO:

Rhode Island

RHODE ISLAND

Rhode Island's Community Solar Marketplace Website, an initiative of CESA's SES project. Photo Credit: Rhode Island Office of Energy Resources.

The LMI solar strategy of the Rhode Island Office of Energy Resources (OER) included six main approaches: an online survey of Rhode Island residents concerning solar; a “train-the-trainer” convening of community leaders on solar education; an education campaign on community solar; an online marketplace to match community solar projects with customers; ongoing meetings with community solar developers and subscription management companies; and exploring the development of a Solarize community solar program. Not all approaches met with equal success. OER has lessons learned from its work on the Community Solar Marketplace website and engaging with stakeholders on expanding one of the two state community solar programs:

There is a long timeline necessary for procurement, vendor selection, and IT involvement. It took a year and a half to get to the web building phase of this effort. The eighteen-month process included drafting a request for proposals for the design of the website, reviewing applications, scoring, selecting and contracting a vendor, drafting website content, designing the website, beta-testing the website and going-live. There were also unexpected expenses in the development of the website. These costs included purchase of a domain name, hosting and maintenance fees, and IT support and project management.
There can be consumer protection concerns related to LMI households’ participation in community solar projects. OER’s conversations with the state’s investor-owned utility, National Grid, surfaced concerns about whether LMI customers would benefit from participation in shared community solar projects. OER needed to work with National Grid, community solar developers, and subscription management companies to address this issue. As a result, new language in National Grid rules clearly shows that LMI customers will receive the value of their community solar credits before their income-eligible discount, ensuring they will save money by participating. National Grid customers on the income-eligible rate can participate in community solar projects even if they are enrolled in the arrearage management plan. This is important information to relay to LMI customers who are considering participating in community solar.
Surveys can yield a better understanding of barriers to LMI participation in community solar. OER conducted a survey specific to National Grid’s income-eligible rate customers. Although it took several months, it was desirable because it gave insights into the reasons why it can be difficult to get LMI households to participate. The results also indicated that LMI customers feel strongly about environmental impacts and climate change, not only about saving money. This was an important realization, since solar (and environmentalism) is often associated with higher-income households and wealthier neighborhoods.
Meaningful community engagement and outreach can lead to improved program design and impactful policy changes. OER held three stakeholder meetings to educate customers and LMI community groups about community solar in Rhode Island, and gain input about their perspectives on a newly created LMI carveout in a proposed expansion of one of the state’s two community solar programs. The carveout, if approved by regulators, would be 20% per project for any new capacity awarded in the Community Remote Net Metering program. Feedback from these meetings directly informed the eligibility criteria for the carveout.

Products and Webinars Produced by OER:

Acknowledgements

ACKNOWLEDGEMENTS

This report was produced under U.S. Department of Energy (DOE) Solar Energy Technologies Office Award Number DE-EE-0007667. Under this project, CESA worked with five states—Connecticut, Minnesota, New Mexico, Oregon, and Rhode Island—and the District of Columbia to develop and implement low and moderate-income solar strategies. The U.S. Department of Energy Solar Energy Technologies Office supports early-stage research and development to improve the reliability and performance of solar technologies.

Abbe Ramanan of CESA served as overall report coordinator and editor. Warren Leon of CESA and Nicole Hernandez Hammer, formerly of CESA, helped with identification of lessons learned and editing. Each of the participating states developed its own list of lessons learned. Point people for those states were: Emily Basham and Madeline Priest from the Connecticut Green Bank, Daniel White and Jennifer Kulp from the D.C. Department of Energy and the Environment, Kellye Rose and Jack Kulempke from the Minnesota Department of Commerce, Lizzie Rubado from Energy Trust of Oregon, and Shauna Beland and Yasmin Yacoby from the Rhode Island Office of Energy Resources. Samantha Donalds of CESA designed and formatted the webpage.