Solar for All

On April 22, 2024, the Tennessee Department of Environment and Conservation’s Office of Energy Programs (TDEC OEP), which serves as the State Energy Office for Tennessee, was notified that the U.S. Environmental Protection Agency (EPA) intends to award the State $156,120,000 to develop solar programs that enable the deployment of residential solar and community serving solar to benefit low-income households and disadvantaged communities.

TDEC OEP has not received funding for the Program, and the State’s Solar for All Program is not currently accepting applications. EPA anticipates executing contractual aspects of the award no later than September 30, 2024. Following such execution and EPA’s distribution of additional Solar for All Program Guidance, including special terms and conditions, TDEC OEP will begin a one-year planning period to extend through the third quarter of calendar year 2025.

During the planning period, the State will focus on refining Program plans, developing the State’s Program Guidelines (including those related to residential and community serving solar projects to be funded or financed with Solar for All funding), designing technical assistance and workforce development offerings, and procuring / contracting with Program partners (e.g., Local Project Implementation Teams) and a third-party implementer. Prior to the start of the planning year, TDEC OEP will continue engaging stakeholders to address aspects that will inform the planning year.

TDEC OEP is considering options for the installation of solar photovoltaics (PV), including residential-serving community solar systems, that would allow low-income households to benefit from solar PV without being the owner of the system or having the solar PV installed on their property.

TDEC OEP intends to identify Local Project Implementation Teams that will provide locally-tailored implementation of solar projects across Tennessee’s communities. Communities not represented by a Local Project Implementation Team will be covered by the Statewide Program. Per the application summary, TDEC OEP anticipates awarding subgrants under the following categories: (1) Local Project Implementation Teams; (2) A Statewide Program Administrator; (3) Public high schools to support introduction to solar trades and science, technology, engineering and mathematics (STEM) programs; (4) Public community or technical colleges for workforce development training programs, including employer apprenticeship support and wraparound services; (5) Subgrants to local nonprofits and community organizations for workforce development training programs, including employer apprenticeship support and wraparound services. Categories (1) and (2) include both (a) financial assistance for rooftop and community-serving solar, appropriate storage, and/or enabling upgrades and (b) program administrative activities for delivering financial assistance and/or project deployment technical assistance.

Local Project Implementation Teams have not been selected. Given the short amount of time to develop the application after responsibility was transferred from the Tennessee Housing Development Agency (THDA) to TDEC and the volume of information that needed to be gathered, TDEC engaged local governments and local power companies that had previously reached out to TDEC, THDA, TVA, and/or various nonprofit advocacy groups to express interest in the Solar for All opportunity. The list of local entities that engaged with TDEC following our outreach include the City of Chattanooga, Electric Power Board of Chattanooga, the City of Clarksville, CDE Lightband, the City of Knoxville, Knoxville Utilities Board, the City of Memphis, Memphis Light-Gas-Water, Metro Nashville, Nashville Electric Service, and Middle Tennessee Electric.

“Residential rooftop solar” is defined in EPA’s Solar for All Notice of Funding Opportunity (NOFO) as behind-the-meter solar photovoltaic (PV) power-producing facilities, including rooftop, pole-mounted, and ground-mounted PV systems, that support individual households in existing and new single-family homes, manufactured homes, and multi-family buildings. “Residential-serving community solar” is defined in EPA’s Solar for All NOFO as a solar PV power-producing facility or solar energy purchasing program from a power-producing facility, with up to 5 MW nameplate capacity, that delivers at least 50% of the power generated from the system to multiple residential customers within the same utility territory as the facility. There are a variety of community solar ownership models that can be considered, including community-owned solar, third-party-owned community solar, and utility-owned community solar. Eligible community solar projects could therefore be either in front of the meter or behind-the-meter, depending on the project.

TDEC OEP has not made a determination as to how we will ensure that 20% household savings can be delivered to low-income households, regardless of whether they rent, own, or pay an electricity bill for their place of residence. Solutions will likely need to be tailored to each local electric utility serving the participating low-income households.

It is our understanding that EPA and the Clean Energy States Alliance are also currently working on guidance related to the topic of “20% household savings” and how to implement such programmatically. Please note that per the Notice of Funding Opportunity, “household savings” is defined as delivering a benefit of at least 20% of average household’s electricity bill, including households that do not have individual electricity bills. The average is for the “utility territory” and should be delivered as a financial or non-financial benefit with an equivalent financial value that meaningfully improves the lives of households directly. Some examples of non-financial benefits can be found here: MF_Memo_re_Community_Solar_Credits_in_MM_Buildings.pdf (hud.gov)