The U.S. community solar market is experiencing – and expecting – significant growth. While the forecast appears strong, the success of programs and projects hinges on program design factors that affect the consumer experience. Net costs or savings (i.e., credits minus subscriptions and other fees) are an important – but not the only – factor in this experience. How subscribers are communicated with, enrolled into programs, credited for their solar production, billed for their subscription, and protected from adverse consequences also come into play. These dynamics are especially important for lower-income subscribers, who may rely on shared solar programs to reduce their energy burden but who face the greatest harms if community solar programs and billing processes are mishandled or mistimed.
NASEO’s new report, “Community Solar Consolidated Billing: Review of State Requirements, Policies, and Key Considerations,” explores the role of subscriber billing as a key facet of the community solar customer experience. It includes an overview of billing models, with a focus on the emerging area of consolidated billing. Because many aspects of community solar programs are governed or regulated at the state level, it reviews state policies, programs, and regulations that address community solar billing arrangements.
Key takeaways from the analysis include:
- Consolidated billing can serve an important educational and expense management function by helping community solar subscribers understand the size and timing of the financial benefit they receive. By providing a full accounting of the benefits (i.e., generation credits) and costs (i.e., subscription and program fees) in one bill, consolidated billing can help subscribers better understand their net benefit (or loss) more readily than if they were to receive two separate bills. This consolidation can also help subscribers manage household expenses by increasing predictability and transparency in the billing process.
- Utility-consolidated billing can make it easier for customers in low-income bill assistance programs to access community solar benefits and cost savings. Utility-consolidated billing in particular can help ensure that bill assistance payments to the utility lower the full cost of the customer’s electricity usage, including community solar generation and program participation costs, rather than just the net costs of electricity usage minus the generation credit.
- Consumers and communities should be actively engaged in explorations of consolidated billing. Decisions made by states, project developers and subscription managers, and utilities about community solar billing processes can play a make-or-break role in whether and how consumers participate and benefit from community solar programs. Yet, many consolidated billing requirements stem from legislation or regulation, complex policymaking processes that are typically inaccessible to individual constituents. Community-based organizations, citizens utility boards, consumer advocacy organizations, and other consumer-representing groups are often effective at elevating underrepresented and community voices in these forums and should be included in decision-making processes on consolidated billing. Additionally, in their role as policymaking (as opposed to regulatory, judicial, or lawmaking) bodies, State Energy Offices may be well-positioned to convene and bring together these and other stakeholders to inform and support participation in formal lawmaking and rulemaking processes.
- Utilities should be consulted and actively engaged in explorations of utility-consolidated billing. Changing and updating utility billing systems is a complex and costly endeavor. Experiences in New York and the District of Columbia suggest that community solar subscribers – particularly lower-income participants – as well as the community solar market in general can face great harm if there are delays, difficulties, or mishandling of crediting and billing processes. To smooth implementation hurdles, utilities should be engaged early and often in the development of policies, programs, and rules requiring consolidated billing.
- In states where utility-consolidated billing is not required, provider-consolidated billing offers a promising alternative, but needs careful design. Provider-consolidated billing can help ease many of the challenges commonly associated with dual billing, without requiring utility investment or involvement. Even so, states should closely examine community solar providers’ billing methods to ensure alignment with equity, access, and low-income participation goals. Provider requirements around auto-pay, the use of credit cards, and penalties for partial payment or late payment may pose undue risks or burdens on lower-income, lower-credit participants. Proactive engagement and collaboration with community solar providers and subscription managers may help states reach an acceptable provider-consolidated billing arrangement when utility-consolidated billing is not an option.
To learn more about NASEO’s programs in community solar, please contact Sandy Fazeli (sfazeli@naseo.org) or Grace Lowe (glowe@naseo.org).