Cross-State Gap Analysis #2

Across five states, fewer than 2,300 LMI households participate in any DER program — and the $590 million that would have scaled it is frozen

DER integration with LMI electrification barely exists. Massachusetts has a single 100-household pilot that the DPU banned from replication for five years. Vermont has the most developed community solar infrastructure at ~1,900 enrolled. Pennsylvania lacks enabling legislation for community solar entirely. The EPA Solar for All grants — the only funding mechanism at scale — were terminated in August 2025.

LMI households in DER programs by state
What each state offers
Vermont: ACRE community solar — GMP (~1,200), VEC (~505), Stowe (~180 target), VPPSA (in dev.). Bill credits: $0.04/kWh (GMP) to $45/mo (VEC). EAP customers can stack ACRE + Shared Solar + EAP for ~40% total discount.
Wisconsin: Energize Wisconsin — 550 subscriptions through Couleecap + Vernon Electric Co-op. ~25% reserved for LI (~138 HH). Participants: $56/yr bill credit. Auto-enrolled from WHEAP participation.
Massachusetts: CVEO pilot — 100 LMI homes on Cape Cod/Martha's Vineyard. Solar PV + battery + HP + weatherization. LI: 100% free. DPU banned replication for 5 years.
Michigan: Three co-op pilots — Cherryland (50 LMI HH), L'Anse (25 LMI HH), Consumers/CACS Lansing (50 LMI HH). Bill credits ~$0.10/kWh. IOUs excluded — no enabling legislation.
Pennsylvania: Zero. No community solar enabling legislation. HB 504 passed House (114-89, May 2025), stalled in Senate. PA is 1 of 26 states without community solar law.
Solar for All grants — all frozen as of August 7, 2025
Massachusetts
$156M
Paused. AG challenging.
Michigan
$156M
Paused. AG pursuing.
Pennsylvania
$156M
Not operational.
Vermont
$62M
Paused. DPS dispute filed.
Wisconsin
$62M
Gov. Evers letter to EPA.
$592M
Total frozen Solar for All funding across 5 states — the only scaled pathway to LMI DER access, now terminated
The one integrated model that exists
Massachusetts CVEO: Solar + Storage + Heat Pump + Weatherization for 100 LMI homes
The Cape & Vineyard Electrification Offering is the only program in the five-state corpus that packages rooftop solar, battery storage, cold-climate heat pumps, induction stoves, and weatherization as a single coordinated intervention. LI households receive everything at no cost. Participants retain ownership and are auto-enrolled in demand response.
The DPU prohibited replication of this model by other utilities for 5 years pending pilot evaluation.
~2,300
Total LMI households in any DER program across all 5 states combined. VT: ~1,900. WI: ~138. MI: ~125. MA: 100. PA: 0. Against millions of eligible LI households.
$592M
Total Solar for All funding frozen by EPA termination. Vermont's Act 142 report had identified ACRE expansion via Solar for All as the primary pathway to scaling LMI community solar. No substitute exists.
0
States in the corpus that coordinate DER deployment (solar, storage, DR) with LMI heat pump installation as an integrated program — other than the 100-household CVEO pilot banned from replication.
The DER-LMI integration gap is not a failure of program design — it's a failure of program existence. Community solar reaches fewer than 2,300 LMI households across five states. No state coordinates solar, storage, and heat pump deployment as a single LMI package at scale. The one model that does this (CVEO) serves 100 homes and cannot be replicated. The funding that would have changed this ($592M in Solar for All) has been terminated.
This gap matters for electrification because DERs — particularly solar + storage — can reduce the net cost of heat pump operation, making electrification more affordable. Without DER integration, every LMI heat pump customer faces the full retail rate for heating. With solar + storage, the effective rate drops. The states that solve DER-LMI integration first will be the ones that make electrification pencil for LMI households.
Sources: VT ACRE programs (~1,900 enrolled) — Act 142 Final Report, VT PUC, Dec 1, 2025, pp. 31-34. WI Energize Wisconsin (550 subscriptions, ~138 LI) — NASEO, "Community Solar for All," Oct 2024, pp. 31-33; DOE case study, Sep 5, 2024. MA CVEO (100 HH, replication banned) — DPU Order approving CVEO, 2023; Clean Energy Group, "Solar+Storage+Electrification," Mar 2025. MI co-op pilots (~125 LMI HH) — CESA, "Michigan Solar Communities"; EGLE MI Solar Communities page. PA no enabling legislation — PA General Assembly, HB 504, 2025-2026 Session. Solar for All frozen — EPA announcement Apr 22, 2024; EPA termination letters Aug 7, 2025; state AG responses. Note: MI and WI household counts sourced to CESA and NASEO reports rather than primary state regulatory filings.