A:

Respondent name:

Benjamin Hoyne

 

Respondent organization (if applicable):

Solar United Neighbors

 

Point of contact's address, phone number, and e-mail address:

1350 Connecticut Ave NW, Suite 412, Washington, DC 20036

bhoyne@solarunitedneighbors.org

 

What type of organization do you represent (government, non-profit, solar installer, financier, developer, energy efficiency provider, weatherization provider, etc.), or are you responding as a private citizen? 

Non-profit solar organization

 

Area or locality served or representing:

Entire Commonwealth of Virginia

 

What role would you or your organization play in any projects conducted through this program?

We would be open to supporting/consulting on projects as needed

 

B: What types of entities should be directly affiliated with the Virginia-based program to provide this funding opportunity to disadvantaged communities? What should the organization role(s) entail? 

 

Community partnerships and collaboration are at the core of SUN’s theory of change for equitable rooftop solar deployment. The energy justice framework is key to our procedural and recognition program approach for providing technical assistance to organizations working to provide LMI families with direct access to solar. SUN recognizes the importance of involving pre-existing and self-organized community-based organizations (CBO’s) in the program. These organizations have a deep understanding of the local community, its dynamics, and the specific needs of its members. Integrating CBO’s and their expertise can leverage networks and trust within the community to inform program design, outreach efforts, implementation, and evaluation processes. The CBO's involvement in the program design phase allows for the incorporation of community-driven perspectives and priorities. The CBO can contribute insights into the unique barriers faced by LMI families, recommend culturally appropriate messaging and outreach strategies, and identify potential solutions that align with the community's values and aspirations. This collaborative approach ensures that the program is responsive to the needs of the community it aims to serve.

 

C: 1. What eligibility criteria should be considered or required for evaluating residential single family home occupants as potential beneficiaries of the program? 

 

In designing the LMI pilots to be responsive to local energy markets and place-based, it's important to consider various paths and indices for the applicant review process. Many of our jurisdictional partners have used AMI, SNAP benefits, and WAP/LIHEAP enrollment as determinants for qualification. Other helpful tools include the DOE’s Low-income Energy Affordability Data (LEAD) tool as it specifically measures energy burden (https://www.energy.gov/scep/slsc/lead-tool ). To gain a more holistic applicant cohort we recommend using the Justice40 screening tool and the Environmental Justice Index (EJI) screening tool which account for cumulative health burdens ( https://www.atsdr.cdc.gov/placeandhealth/eji/index.html ). By incorporating these tools and indices into the applicant review process, LMI pilots can identify and prioritize communities that face energy burdens and environmental injustices. This approach helps ensure that the program reaches those most in need and contributes to addressing energy equity and environmental justice in a comprehensive manner.

 

2.         What contractor criteria should be required for local system installers of behind-the-meter solar, storage and/or enabling home upgrades?   

 

A competitive process should be set up to ensure maximal opportunity for a wide variety of vendors to provide services in support of program implementation. Installers eligible for the program should be vetted carefully by an independent third party. Virginia Energy should consider providing a minimum set of criteria that all vetting must adhere to and provide flexibility for a local list to include additional criteria. An active list should be created and maintained for each target geography of eligible installers. Installations should have a final inspection by a certified electrician before making final payment to the installer.

 

3. Should energy efficiency or weatherization standards be required prior to solar and/or storage installations? If so, how should energy efficiency be measured, modeled or documented?  

 

It is ideal to provide an energy audit and set a threshold for weatherization and energy efficiency before adding solar to reduce the costs of the solar system, provide for a more comfortable home, and ensure long term energy savings. However, weatherization or efficiency goals should not be a requirement that potentially bottlenecks low-income solar installations that would normally proceed and benefit participants on their own. This may apply in cases in which the GHG emissions performance of solar outweighs the performance of efficiency and weatherization upgrades(i.e in newer builds with higher efficiency to begin with), or if the resilience value of solar coupled with battery storage outweighs energy efficiency. Other instances may include when the supply of weatherization or efficiency providers is unable to meet demand while solar and storage providers are able to meet program demand immediately.  It’s important to note that efficiency improvements can be made after adopting solar to maximize performance of a system. Although this is not theoretical best practice, this frequently happens when a homeowner installs solar panels producing a percentage of their annual demand then making efficiency improvements afterwards to maximize a smaller system.  Furthermore the impact of solar installations in terms of cost savings, GHG emissions, energy production is very easy to track with reporting applications from the system itself. Efficiency and weatherization improvements should also be tracked at a more granular level.  SUN recommends leveraging funds from additional sources, if needed, to ensure appropriate resources to have weatherization completed in a timely manner and in a way that does not unnecessarily delay solar installations.  SUN also recommends having program funds, matching funds, and/or funds from other programs lined up to help with any health and safety upgrades needed relating to weatherization and solar.

 

4. What is the best way for customers (occupants) to receive 20 percent energy savings while making the best use of public funding?  

 

The best way for customers to receive savings is monthly on their energy bill. Customers already pay the bill monthly and will be familiar with the cost, so they will see the savings. Meaningful energy bill savings are important to have an impact. Weatherization and solar savings should be at least 50% of the average monthly energy usage to ensure meaningful savings. With energy bill fees, total bill savings should be around 40% if the average savings are 50% providing a buffer to ensure 20 percent energy savings. 

 

5. What is the best way for financing arrangements, solar ownership models and/or financial incentives to leverage private capital?  

Customer- friendly third-party ownership models with adequate consumer-protection should be considered to take advantage of financial incentives that would normally not be available to the homeowner due to tax or other financial status.

 

 

D: How should program incentives and/or credit enhancements be designed to enable shared solar projects and/or multi-family shared solar projects to provide utility bill savings to subscribers?

 

If program design includes a minimum bill, then you should ensure a low minimum bill. Program participants should experience instant saving from day one and have clear and predictable bill credits.  Transferability of the credits to future residents/subscribers should have clear guidelines and be simple to understand.

 

 

4. 5. 1. How should the Program ensure utilization of Renewable Energy Certificates (RECs) to increase economic feasibility for the Program and increase savings to the household?

 

RECs should either accrue to the system host or in a third-party ownership model be monetized to ultimately reduce costs for the system host. For homeowner owned systems, the program should investigate the development of a program that can cover out-year REC value risk to enable market providers to offer above market upfront SREC payment options for use in reducing installation costs.

 

2. What workforce development elements should be considered to ensure disadvantaged communities benefit from this public investment opportunity?   

 

Develop targeted training programs that specifically address the needs and barriers individuals in disadvantaged communities face. Programs should provide comprehensive training on solar technology, installation, maintenance, and related skills. Collaborate with community colleges, vocational schools, and training centers to offer accessible and affordable training options. Implement effective outreach strategies to reach individuals in disadvantaged communities and encourage their participation in solar workforce development programs. Engage community-based organizations, local leaders, and community networks to spread awareness about the opportunities and benefits of solar employment. Offer comprehensive support services to help individuals develop the necessary skills and overcome barriers to employment. This may include assistance with resume writing, interview preparation, job placement, and ongoing mentorship. Access to financial resources can cause a significant barrier for individuals in disadvantaged communities. Providing financial assistance, such as scholarships, grants, or low-interest loans, to help cover training costs, certification exams, tools, and equipment needed for solar jobs.

 

3. How should marketing and outreach activities be designed to reach disadvantaged communities?  

 

Marketing and outreach should be designed to fit various digital applications. Use the available Census ROAM data to understand device access rates in the targeted communities. This data can provide insights into the prevalence of mobile, fixed-line, PC, and broadband access. Tailor the marketing content and channels to fit the devices most commonly used in the community. For example, prioritize mobile-friendly websites and optimize content for mobile devices. Align with local language CLAS (Culturally and Linguistically Appropriate Services) standards to ensure the marketing materials are culturally sensitive and resonate with the target audience. Identify and center trusted local voices to inform the content and channels for disseminating the pilot opportunity. Collaborate with community leaders, influencers, and organizations that have established credibility and trust within the target communities. Engage them in marketing to ensure the message is authentic and resonates with the intended audience. Adopt a multichannel approach to reach a wider audience. Utilize print media, direct mailing, and placements in BIPOC print mediums to maximize visibility. Advertise in local newspapers, magazines, community newsletters, and other print publications widely read by the target audience. Develop targeted campaigns that appeal to youth, leveraging social media platforms, online communities, and influencers popular amongst young people.

 

 

 

 

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.

A. Respondent Characteristics 1. Respondent name John Morrill 2. Respondent organization (if applicable) Fairfax County government, Office of Environmental and Energy Coordination 3. Point of contact\'s address, phone number, and e-mail address 12000 Government Center Parkway, # 533, Fairfax VA 22035, 703-324-1792, john.morrill@fairfaxcounty.gov 4. What type of organization do you represent (government, non-profit, solar installer, financier, developer, energy efficiency provider, weatherization provider, etc.), or are you responding as a private citizen? Local government 5. Area or locality served or representing Fairfax County 6. What role would you or your organization play in any projects conducted through this program? Fairfax County, primarily through an emerging Fairfax County Green Bank (to be a 501c3 organization), is interested in providing low- and moderate-income solar and shared solar financing program(s) in Virginia. B. Program Affiliate Roles: 1. What types of entities should be directly affiliated with the Virginia-based program to provide this funding opportunity to disadvantaged communities? What should the organization role(s) entail? Partnerships between any program sponsor or lending entity (whether for-profit or non-profit or governmental) and community-based organizations (CBO) are essential to success in delivering program and funding opportunities to disadvantaged communities. Fairfax County government and the Fairfax Green Bank formation team have been in consultation with the extensive network of CBOs in Fairfax and elsewhere in northern Virginia. Continued development of these partnerships is deemed essential to the success of the green bank effort. C. Behind-the-Meter Solar Program Design and Questions: 1. What eligibility criteria should be considered or required for evaluating residential single family home occupants as potential beneficiaries of the program? Median household incomes vary substantially across various regions of Virginia. To gain a broad constituency of equitable participation, multiple criteria should be considered for eligibility; these include thresholds that take into account local area median income (AMI) levels, not just statewide figures. In that spirit, eligibility such as the Justice40 screening tool (which Fairfax County already uses extensively in its community energy planning), WAP/LIHEAP enrollment, SNAP benefits, and the One Fairfax vulnerability index can identify individual households and communities as beneficiaries. 2. What contractor criteria should be required for local system installers of behind-the-meter solar, storage and/or enabling home upgrades? Contractors should be selected through a competitive process that includes verification of credentials and certifications appropriate to the industry. Virginia Energy should consider providing a minimum set of criteria that all vetting must adhere to and provide flexibility for a local list to include additional criteria. 3. Should energy efficiency or weatherization standards be required prior to solar and/or storage installations? If so, how should energy efficiency be measured, modeled or documented? Although energy efficiency upgrades or attainment of certain minimum energy performance levels are desirable for all households as a matter of public interest, it is not desirable to require such upgrades or standards for potential beneficiaries of the LMI solar installations. Experience elsewhere has shown that addition of rooftop solar often leads to subsequent interest in greater energy efficiency thanks to the feedback gained from reduced utility bills and the desire to ‘get to zero’. D. Shared Solar, Community Solar or Multi-family Shared Solar: 1. How should program incentives and/or credit enhancements be designed to enable shared solar projects and/or multi-family shared solar projects to provide utility bill savings to subscribers? Shared solar projects should be structured in a manner that ensures, through incentives or credit enhancements that lower the cost of implementation, direct and immediate utility bill savings to subscribers, especially in cases where the rate structures impose minimum monthly bills on subscribers. E. Overall Program Design: 1. How should the Program ensure utilization of Renewable Energy Certificates (RECs) to increase economic feasibility for the Program and increase savings to the household? One concept Fairfax County is studying for its green bank is direct purchase (by the green bank) of multi-year REC values as an incentive to lower the cost of LMI solar installations. The SRECs would be owned and retired by Fairfax County to meet its own carbon reduction goals for county operations, while providing immediate value to subscriber via reduced project cost and lower utility bills. 2. What workforce development elements should be considered to ensure disadvantaged communities benefit from this public investment opportunity? The shortage of skilled tradespeople across the United States and in Virginia in particular is a fundamental hurdle to a widespread clean energy future. All potential routes of workforce development should be explored and pursued statewide, including collaboration with community colleges, training centers, and career resources for refugees, veterans, dislocated workers, and individuals re-entering the workforce. Partnerships with community-based organizations and state programs in these areas should be nurtured and leveraged to the greatest extent possible. 3. How should marketing and outreach activities be designed to reach disadvantaged communities? Local governments are particularly close to the communities they serve, and the safety net programs local government agencies operate provide a very strong channel for outreach activities aimed to benefit disadvantaged communities. Fairfax County is eager to deploy state clean energy resources to its citizens, and the county’s One Fairfax vision provides a framework for outreach focusing on delivering programs to LMI, disadvantaged, and vulnerable households in our community.