Shared solar (aka community solar) solar has the attention of states, regulatory commissions, and utilities across the country. Best practices and success stories are emerging, but the market still remains relatively small. What's more, as the model gains traction, this relatively new sector of the solar industry is meeting new growing pains. In her presentation at Intersolar North America 2016, Erica McConnell shares what's happening across several states to scale the model to reach more consumers and new markets, including low-income customers.

1. Shared Solar: National Overview
Erica S. McConnell
Attorney, Shute, Mihaly & Weinberger LLP
July 12, 2016
Scaling Shared Solar: What’s Working, What’s Not & What’s Next
Intersolar North America

2. • Independent, non-partisan, national non-profit organization founded in 1982
• Non-industry voice and non-lobbying
• Our focus: Expand access to reliable, affordable clean energy for all consumers
• Workforce Program: Ensure a qualified, job-ready clean energy workforce
• Solar Career Map
• National Coordinator, Grid Engineering for Accelerated Renewable Energy
Deployment (w/ EPRI, SEPA, US DOE)
• Credentialing Program: Develop national education/training standards,
best practices, and credentials
• National Administrator, Solar Instructor Training Network (US DOE)
• ANSI-Accredited National Standards Developer
• Regulatory Program: State regulatory engagement on distributed energy
resource policies
• Model rules, national best practices, policy innovations
www.irecusa.org | @IRECUSA
© 2016 IREC
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3. IREC Regulatory Activity 2007-2015
IREC Current Regulatory Engagement
IREC’s National Regulatory Engagement
© 2016 IREC
DC
IREC is represented by the law firm Shute, Mihaly & Weinberger LLP 3

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Defining Shared Renewables:
Guiding Principles
© 2016 IREC
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5. Terms and Nomenclature
• Nested within NEM
program
• Based on
participant’s retail
rate
Virtual Net
Metering (VNM)
Investment-Based
Models
• Participants receive
cash return, rather than
bill credits
• Investment-based, e.g.,
through an LLC
Green Tariff
Programs
• Often relies on
distant REC
purchases
• No rate hedging,
usually premium
These can all be “community solar”
© 2016 IREC
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6. Based on IREC research as of September 2015, www.irecusa.org
National Shared Renewables Landscape
DC
+ many voluntary
utility programs
on the horizon
© 2016 IREC
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7. Key Program Attributes
 Program size
 Administration and ownership
 System/facility
 Size, location and siting requirements
 Number of participants
 Participation
 Term and eligibility requirements
 Portability and transferability of subscriptions
 Allocating the benefits of participation
 Bill credit valuation
 REC ownership and valuation
 Unsubscribed energy
 Portability and transferability of subscriptions
© 2016 IREC
Plus simplicity,
comprehensibility,
and attractiveness
for customers
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8. Facility Ownership & Administration
• Direct ownership—customer(s) own
• Third-party ownership/administration
• Utility ownership and/or administration
– Mostly seen in voluntary utility offerings
(vs. state-wide programs)
– Some competitive programs allow for utility
ownership—but not in practice to date (MN, CO)
• Policy Considerations
Financing options available for facility
Benefits to customers of competitive offerings
Fair competition—utility ownership through affiliate
© 2016 IREC
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9. Bill Credit Valuation
• Embedded-cost-based approach—based on existing
retail rates
– Generation, transmission, and distribution
– Can get complicated with TOU rates and non-kWh
components, e.g., demand charges
• Value-based approach—value of solar rate
– Costs = lost revenue, admin. costs, incentives
– Benefits = avoided generation costs, avoided line
losses, capacity benefits, avoided T&D costs, avoided
environmental compliance costs, other benefits, etc.
IREC Model Rules provide language for both approaches
© 2016 IREC
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10. State Program
Year
Launched
Program Capacity
Limit
System
Capacity Limit
Bill Credit—
kWh or $
Bill Credit—Value
CA GTSR/ECR 2015 600 MW 20 MW $
Compilation of statute-mandated
costs and credits
CO CSG 2011
2011-13 = 6 MW per
year
2014-16 = 6.5-30 MW
per year
2 MW $
Total Aggregate Retail Rate = base
energy, demand charges and other
riders; excludes T&D, customer
charge, DSM, RESA
DE CS 2011
5% of a utility’s
aggregated customer
monthly peak demand
2 MW $ (?)
Same feeder = full retail rate
Different feeders = supply service
charge
MA VNM 2009
15% of system peak
load (7% private, 8%
public)
2 MW
(10 MW for
gov’t)
$
All but Class III = full retail rate;
Class III = energy, transmission,
transition (but recent legislation
will change this)
MN CSG 2014 None 1 MW $
Full retail rate plus REC adder
depending on size (but VOS & other
changes under consideration)
NY CDG 2015
(NY NEM caps
currently lifted)
2 MW
kWh unless
demand-
metered, then $
Full retail rate (but “LMP + D” and
other changes being discussed)
© 2016 IREC
State Programs at a Glance
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11. Emerging Issues
• Consumer protection, including mandatory
disclosures & other transparency measures
• Low- to moderate-income (LMI) customer
access and participation
– Along with consumer protection, relevant beyond
shared solar
• Facility siting to maximize grid benefits
– Intersection with interconnection and grid
modernization efforts
– Also valuation proceedings
© 2016 IREC
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12. State Program
Year
Launched
LMI
Component?
Siting Requirements
CA GTSR/ECR 2015 Yes
Same municipality or county, or within ten miles
of the customer’s address
CO CSG 2011 Yes Same or adjacent county
DE CS 2011 No
Same utility service territory; bill credit varies by
location
MA VNM 2009 No Same utility service territory
MN CSG 2014 No Same or adjacent county; co-location limitations
NY CDG 2015 Yes
Phase 1 = "Opportunity Zones" and 20% low-
income projects
Phase 2 (May 1, 2016) = unrestricted
Emerging Issues at a Glance
© 2016 IREC
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13. IREC Resources
Both available at www.irecusa.org/regulatory-reform/shared-renewables
© 2016 IREC
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14. Additional Resources
© 2016 IREC
• IREC Consumer Protection Trio
www.irecusa.org/consumer-protection
• IREC Shared Renewable Energy Program Catalog
(update coming very soon)
www.irecusa.org/regulatory-reform/shared-renewables
• US DOE/White House Community Solar Partnership
http://energy.gov/eere/solarpoweringamerica/national-community-solar-
partnership
• US DOE Solar Market Pathways
www.solarmarketpathways.org
• National Renewable Energy Laboratory
www.nrel.gov
• Shared Solar: Current Landscape, Market Potential, and the Impact of
Federal Securities Regulation
www.nrel.gov/docs/fy15osti/63892.pdf
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15. Thank you
Erica S. McConnell
Attorney, Shute, Mihaly & Weinberger LLP
mcconnell@smwlaw.com
Sara Baldwin Auck
IREC Regulatory Program Director
sarab@irecusa.org