a clean energy leader without specific measures to ensure that low-income households participate and benefit.

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2 Serving 100,000 low-income New York households with solar by 2023 is an important step toward an equitable energy system. This plan outlines the path toward enough solar to save low-income communities millions of dollars on electric bills, improve energy and housing affordability, prove economic models to sustainably serve this population, and make headway on building an equitable energy economy. As with the goal above, this mandate must be made real and accountable through the Public Service Commission. As New York plots a course toward an energy future that is cleaner and more efficient with some of the country s most ambitious clean energy goals, policies must be inclusive of all residents. New York will not make meaningful progress toward becoming a clean energy leader without specific measures to ensure that low-income households participate and benefit. This Roadmap outlines four key policy and market categories that New York must consider: Accessibility and affordability Community engagement and energy democracy Flexibility and sustainability Compatibility and integration These measures build on the New York policy roadmap to one million solar customers, will help ensure that 100,000 of those are low-income households benefitting directly from solar by 2023, and lay the foundation for an even more equitable clean energy future. Enable fair compensation: Enact fair, simple, and predictable compensation for customers solar power, including values that account for the disparate environmental impacts from electricity generation on low-income communities and communities of color. Simplify compensation mechanisms to make it easier for customers to understand. Ensure the value of customers solar power translates to meaningful savings. Include explicit values to reflect avoided impacts of fossil fuel based generation on environmental justice communities.

3 Unlock Sufficient Funding: Direct Clean Energy Fund and other resources toward incentives and other support that facilitates robust participation in and savings from energy efficiency and solar for low-income households. Current plans for the NY-Sun Programs include approximately $1.2 billion for solar programming between 2014 and Of that, approximately one percent is budgeted for solar for low-tomoderate income households. 1 Under the ten-year, $5 billion Clean Energy Fund, while approximately 23 percent of funds that are committed will go to clean energy programs for low- and moderate-income households, only seven percent of overall funding has been allocated for energy efficiency, renewable energy, and other clean energy programming for low-to-moderate income households. 2 More resources are needed. Forty percent of overall funding from Regional Greenhouse Gas Initiative revenue, Clean Energy Fund proceeds, and other climate-related funding streams (including any future market-based mechanisms) must be spent on benefits for low-income communities. These communities have contributed funds for those initiatives for years, but have not benefited proportionally. A large percentage of energy program funding earmarked for low income households is spent on bill payment assistance, which, while often essential to prevent utility shut-offs, does not support a long-term solution to low income energy burdens. New York transfers only 10% of federal LIHEAP dollars to weatherization rather than the full 15% automatically allowed, and far below the 25% that can be authorized. Transferring additional LIHEAP dollars to weatherization to address building infrastructure needs (efficiency and potentially solar) would better serve the long term needs of the low-income population than annual bill payments to utilities and fuel vendors. Innovative Financing: Provide or facilitate affordable financing for equitable efficiency and solar access. will benefit low-income New Yorkers. 3 The The NY Green Bank has invested over $400 New York Green Bank must follow the million in clean energy projects across New example of its peer, the Connecticut Green York; however, few if any of those Bank, to equitably deploy clean energy investments are for clean energy projects that solutions to low-income households. 1 NY-Sun Annual Performance Report Through December 31, (March 2018), at 2017 NY-Sun Performance Report 2 NYSERDA Annual Investment Plan & Performance Report through June 30, (Nov. 2017), at Annual Investment Plan and Performance Report through June 30, See also correspondence from NYSERDA, April 27, NYSERDA Ann. Investment Plan & Perf. Report through June 30, 2017 at 4.

4 The NY Green Bank must: Implement a loan loss reserve and other credit enhancement mechanisms. Offer no-cost or very low-cost financing solutions. Develop toolkits on proven financing and ownership models for community solar projects. 4 Provide upfront incentives for community solar projects serving low-income households and that provide those households with meaningful cost savings (including projects for affordable multifamily buildings). 5 Encourage comprehensive programs that incorporate community solar, energy efficiency and weatherization upgrades, and workforce development for LMI participants. 6 Explore how to leverage or layer dollars from other programs alongside state energy incentives (e.g., solar incentives, weatherization funding, housing finance). Ease of access and payment: Customer identification and acquisition is a key barrier to ensuring greater solar participation among low-income households, especially when participation might mean the customer has an additional bill to pay. NYSERDA, the PSC, and utilities should facilitate consumer-friendly low-income customer payment methods, where such payments are required, e.g. consolidated billing and on-bill payment. New York agencies must provide support for identification and participation of eligible customers. Inclusion of Multifamily Buildings: A significant percentage of New York s low-income households live in multifamily buildings (1.7 million low income housing units) and equitable access to clean energy opportunities must include this sector. Multifamily building access to solar (preferably in conjunction with efficiency which lowers operation and maintenance costs), can lower utility bills for owners and tenants, which helps maintain housing affordability. Community solar, whether located on- or off-site, may be especially useful for this sector. Solar for multifamily buildings can help offset common area expenses and/or tenant bills. 4 CEAC LMI Report at CEAC LMI Report at CEAC LMI Report at 50.

5 Community Engagement: Maximize participation and opportunities for local resident input by partnering with communities through trusted, local community-based organizations, including WAP sub-grantees, CDCs and others. Support coordinated energy literacy and outreach campaigns to assist lowincome customers and affordable housing providers to find programs and incentives within their communities. Increase programming for customer education, acquisition, and management. Every program related to clean energy deployment should include a robust process for working with these organizations to gather community input. Energy Democracy through Community Ownership: A solar powered future in which communities have decision-making power and opportunities to build community wealth. As community solar moves forward for community-owned and low-income communities, there should community-operated projects. be increased focus on supporting community-owned and communityoperated projects where desired. Increased technical assistance to support communities who wish to own and operate their own solar projects. The New York Green Bank must develop solutions to provide affordable financing to support More resources in the Clean Energy Fund must be allocated to support proof-of-concept pilots for community-owned or operated demonstration projects across the state. Expand the NYSERDA Solar for All program to provide deeper incentivizes for community-owned projects.

6 Use funds to support the necessary risk inherent in supporting new business models and project innovations. Support market participants as they develop innovative new offerings that can expand access to affordable clean energy solutions. Equitable, long-term investment in funding for low-income solar benefits, looking to peer states like California and Connecticut for examples. Program adjustments in a timely manner to maximize program participation and the impact of funding. Mechanisms to support on-the-job training for disadvantaged workers within communities where solar projects are being developed, building on experience and networks of community organizations, apprenticeship and preapprenticeship programs, and training and credentialing programs. Ensure funding and support for workforce development is targeted to current and forecasted solar workforce needs. For example, current solar workforce needs are in sales and related jobs. Workforce resources should be targeted to underserved communities to provide technical and soft skills for potential new solar sales workers. Provide access to business opportunities for disadvantaged business enterprises. Establish advisory councils for NYSERDA low-income programs and for inter-agency coordination of lowincome programs and policies (e.g., NYDPS, DHCR, OTDA, NYSERDA); advisory councils should include representatives of impacted parties, including mission-aligned service providers and community-based organizations. With assistance from impacted parties, establish protocols to ensure maximum coordination of services and benefits for low-income households.

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