By Damien Hall and Carly Sellers
Expanding the benefits of clean, renewable solar energy to underrepresented low-income, BIPOC or frontline communities is a priority for state-level regulators. While some states have struggled to deliver, Oregon’s community solar program provides a unique platform to bring solar to frontline communities by successfully leveraging public-private partnerships and providing flexible project structure and financing alternatives.
The Oregon Community Solar Program (ORCSP) kicked off in early 2020. Similar to other states that propped up community solar programs, the ORCSP implemented legislation which included a mandate to “determine a methodology by which 10% of the total generating capacity of the [CSP] projects will be made available for use by low-income residential customers,” according to Oregon Senate Bill 1547 (2016). Through an extended rulemaking process, the public utility commission has translated this mandate into standards that require diversification of the subscriber pool for each project as follows:
- 10% of the subscribers for each project must be low income (defined as a household earning less than 80% of the area median income)
- No single subscriber may account for more than 40% of a project and may not subscribe to more than 2 MWac of capacity across all participating utilities during the pertinent ORCSP tranche.
- 40% of project capacity is reserved for residential/small commercial customers while up to 50% can be allocated to large commercial customers.
- Participants must subscribe to a community solar project in their utility territory. Portland General Electric (PGE), Pacific Power (PAC) and Idaho Power (IDP) are participating utilities.
These standards target outcomes that manifest the policy objectives of the state to spread the benefits of solar to new constituencies that would otherwise not have access. These standards also add complexity to the solar facility development process.
Creativity and collaboration are paramount for organizations like Oregon Shines, who represent registered project managers within the program to assist in subscribing to their projects. Partnerships with public agencies have proven to be a viable path to meeting the economic needs of the project and the community benefit objectives of the ORCSP.
One such partnership has been founded in Portland Community College (PCC), whose Sustainability Department has forward-thinking approaches to meeting internal climate goals. A leader of participation in the ORCSP, PCC has chosen to offset a large portion of its PGE electricity consumption with community solar.
An aspect of the ORCSP is the ability given to subscribers to maintain ownership of the Renewable Energy Certificates (RECs) generated by their subscription which allows agencies, such as PCC, an alternative to simply buying RECs. Through community solar, participants are gaining an opportunity to support local solar projects while also saving an average of 5% on their subscribed electricity annually.
Partnerships, such as the one between Oregon Shines and PCC, set the precedent for all consumers of electricity, large commercial or residential, to look at their energy consumption and ask themselves what options they have to mitigate the environmental impact of their consumption while also maximizing economic benefits.
Community solar offers a harmonious match between the two. The balance between access and affordability is exactly what makes the program an attractive opportunity for low-income qualified consumers of electricity.
Community Energy Project (CEP), the designated low-income facilitator for the ORCSP, has been working to fulfill the low-income requirements of the program through outreach and education to communities who may not otherwise have the chance to participate in the green revolution. Going solar has traditionally meant the installation and maintenance of solar panels on site, which excludes a vast majority of the population who may not have the financial means or a roof of their own to support solar panels.
The program offers a multitude of opportunities for public-private partnerships that can advance this aspect of the program, and it will be exciting to see what partnerships are cultivated to bring solar and savings to those who have historically been barred from reaping the many benefits that solar has to offer.
ORCSP allows flexibility in contracting for low-income subscriber participation. Project managers may contract directly with rate paying low-income households, or contract with affordable housing providers, including public housing authorities. This flexibility lets low-income families take their bill credit with them when relocating, but also gives the project managers the efficiency to contract for entire buildings to meet the 10% threshold for community solar projects.
When contracting with affordable housing providers, the ORSCP standard requires that 75% of the financial benefit go directly to the low-income household, ensuring that either contracting method satisfies the community benefit objectives of the program.
There are many opportunities and possibilities on the horizon in Oregon that have been ushered in by the ORSCP. Programs such as this need public-private partnerships to help them take root, grow and thrive and that process is just beginning with the ORCSP. With strategic, well-established partnerships in place between the many organizations that have been working to make this program a success, community solar will continue to offer benefits and rewards to communities throughout Oregon for years to come.
Damien Hall is a partner at Ball Janik LLP. Hall is active in renewable energy development throughout the Pacific Northwest. He has participated in local and state-level rulemaking for utility-scale photovoltaic solar energy generation projects in both Oregon and Washington. He may be reached at firstname.lastname@example.org.
Carly Sellers is a program manager at Oregon Shines. She manages and develops programs that are designed to connect Oregonians with sustainable energy options while also providing resources and education on the importance of clean energy for a sustainable future. She can be reached email@example.com.