Full Comments provided via email to PublicComments@energy.virginia.gov that include the final comments as follows:

The most important piece to any LMI Solar Program is flexibility to allow a program to tailor to the specific household, the specific community, within the specific utility business model and involving the household and its support community in the implementation and follow up on any program. A one-size-fits-all approach will not work across Virginia’s vast and varied landscape. The tried and true approach of ensuring a minimum energy savings of 20% is laudable, but families need cost savings. The 20% energy savings goals should equate to a significant cost savings for the household. Such cost savings should focus on reducing energy burden and stabilizing it near 3% of the household’s annual income. There are three elements to be achieved through a Solar for All program – energy savings, costs savings and bill stabilization (and not in that particular order). Households’ utility costs must be sustainably affordable for its family members to thrive. It also should include the opportunity for households to understand the impact energy usage has on their daily lives and their household budgets. More awareness, with actionable tips, can help a family live a life with less stress as their energy bills will be manageable while living in a safer, comfortable environment.

There are a number of Solar for All program models across the country and we believe each has its own benefits to their particular communities but are not perfect models. Again, we reiterate our insistence that a Virginia Solar for All program be flexible to allow different models for different communities, depending on the varying factors, including but not limited to, utility service business model, supportive resources available within the community for marketing, outreach and continuing education, workforce availability, geographic accessibility and project siting, housing stock, energy burden statistics, area household economic statistics, and community adaptability.

There are several good program models but lessoned learned from the following models may be helpful to the development of Virginia’s program(s):

Oregon - https://www.oregoncsp.org/wp-content/uploads/2021/03/PIM-v20210112.pdf Community solar program where customers subscribe to a solar project and receive a credit on their bill for their portion of the solar energy produced by the project (similar to the “shared solar” program in Dominion Energy Virginia’s territory currently under development)

Connecticut - https://www.ctgreenbank.com/strategy-impact/societal-impact/successful-legacy-programs/solar-for-all/ Public-private partnership that coupled energy efficiency with solar system leases

New Mexico - https://www.nm-prc.org/utilities/community-solar Solar subscription program with strong consumer protection provisions, including language accessibility

Massachusetts - https://www.mass.gov/info-details/solar-massachusetts-renewable-target-smart-program Solar subscription program by one utility – improvement on original design to ease bill credits (requires involvement and cooperation of utilities)

Michigan, Cherryland Electric Cooperative - https://cherrylandelectric.coop/renewable-energy-programs/ Solar panel subscription based on per panel leasing for cooperative members. Utility builds and owns solar project, setting aside a set number of “panels” for the subscriptions. Cooperative members can lease (monthly or one time upfront fee) up to ten panels of the project and receive a credit for the kWh produced by the panel per month. Grants to assist LMI residents to purchase upfront leases of panels could help cooperative and/or municipal customers access direct benefit of solar energy.