NASEO report probes the role of subscriber billing in community solar programs

Published on May 11, 2023 by Dave Kovaleski

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A new report from the National Association of State Energy Officials (NASEO) examines the role of subscriber billing in the community solar customer experience.

While the growth of community solar programs – where subscribers can purchase solar energy without panels on their roofs – long term success hinges on program design factors that affect the consumer experience. Costs are part of that, but so is the customer experience in terms of how they are billed.

The report – called Community Solar Consolidated Billing: Review of State Requirements, Policies, and Key Considerations – looks at the various aspects of the customer experience from a billing perspective, including how subscribers are communicated with, how they are enrolled into programs, the method in which they are credited for their solar production, how they are billed for their subscription, and how they are protected from adverse consequences. , It closely examines the various billing models, noting that many aspects of community solar programs are regulated and governed at the state level. Thus, the report explores state policies, programs, and regulations that address community solar billing arrangements.

Among the key takeaways, NASEO officials found that consolidated billing can serve an important educational and expense management function by helping subscribers understand the financial benefit they receive. A full accounting of the benefits in one consolidated bill can help subscribers better understand their net benefit (or loss) more readily than if they receive two separate bills.

It also contends that consumers and communities should be actively engaged in explorations of consolidated billing. Decisions made by states, subscription managers, and utilities about community solar billing processes can play a make-or-break role in how consumers participate and benefit from community solar programs. However, the truth is, many consolidated billing requirements stem from legislation or regulation, complex policymaking processes that are typically inaccessible to individual constituents. They add that community-based organizations, citizens utility boards, consumer advocacy organizations, and other consumer-representing groups should be included in decision-making processes on consolidated billing.

Further, the NASEO report states that 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 — can face great harm if there are delays, difficulties, or mishandling of crediting and billing processes. To smooth out the implementation hurdles, NASEO officials said 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. However, the report points out that it needs careful design. 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. It concludes that proactive engagement and collaboration with community solar providers and subscription managers may help states reach an acceptable billing arrangement when utility-consolidated billing is not an option.