CPC Lenders will require a 20% minimum household savings net of costs incurred by the LIDAC household over the period of performance for all projects funded under this Program, such that the estimated monthly cost of electricity (both community solar subscription + other utility bill costs) after subscription is at least 20% less than customer’s monthly cost of electricity beforehand, on average per year. To advance this goal, CPC Lenders will review pro forma revenue assumptions in its underwriting that reflect at least a 20% discount on average annually to households benefiting from each project and will review developer’s calculations and subscription agreement or other documentation. CPC Lenders will adhere to IRS guidance on proper calculations of the “bill credit discount rate” in underwriting (26 CFR Part 1). For more information, please refer to IPC’s program guidance and 20% household savings methodology on IPC’s Solar for All Resources webpage. (Updated May 21, 2025)

Yes, a community solar project supported by Solar for All financing products must provide a minimum of 20% household savings to all LIDAC households. Projects are not required to exceed this 20% minimum savings threshold for the LIDAC households served. The savings must be calculated net of costs incurred by the LIDAC household over the performance period. This means that the estimated total monthly cost of electricity (including both community solar subscription and other utility bill costs) should be, on average per year, at least 20% less than the customer’s monthly cost of electricity prior to subscription. For more information, please refer to IPC’s program guidance and 20% household savings methodology on IPC’s Solar for All Resources webpage. (Updated May 21, 2025)

Yes, we can provide financing for third-party-owned solar projects that meet our eligibility and screening criteria. (Updated February 27th, 2025)

To qualify as an eligible upgrade, roof replacement must be necessary to deploy or maximize the benefits (such as financial savings or resiliency) of a multifamily residential rooftop or residential-serving community solar project.  

Roof replacement will only be funded through the program in the absence of other funding sources and after exploring alternative strategies for financing this enabling upgrade. It will be supported only for rooftop multifamily residential-serving solar projects and rooftop community solar projects on those buildings where the funded project is located. Roof replacement would not be an eligible enabling upgrade for ground-mounted multifamily residential-serving solar projects and community solar projects. 

IPC will review eligibility for roof replacement as an enabling upgrade on a case-by-case basis. (Updated February 27th, 2025)

There may be opportunities to leverage IPC’s technical assistance or financing products while receiving support from other Solar for All awardees, but outputs and outcomes may not be double counted. Solar for All-supported projects may also leverage other federal or local sources of funding, including solar investment tax credits, SRECs, LIHEAP, USDA, and similar funding, as well as private sources of capital, but we will avoid issuing financial assistance to projects that could be financed through other sources of funding. (Updated February 27th, 2025)

Yes, IPC welcomes co-investment as a strategy to increase the capacity of local lenders to underwrite LIDAC-serving multifamily and community solar projects, including lenders that utilize CCIA funding. IPC highly encourages solar developers to leverage other private sources of capital for projects, as well as federal and state sources of funding; Solar for All aims to complement and extend the private market. To that end, IPC aims to ensure that financial assistance from SFA will only go to projects unable to be fully financed through other sources of funding. (Updated February 27th, 2025)

IPC’s program does not target Tribal land, but we may be able to provide technical assistance to Tribal developers seeking financial assistance under other Solar for All programs.  

There are other Solar For All awardees who are targeting Tribal communities, including the Washington State Department of Commerce, Bonneville Environmental Foundation (Idaho, Montana, and Wyoming), Tanana Chiefs Conference (Alaska), North Carolina Department of Environmental Quality, Minnesota Department of Commerce, Center for Rural Affairs (Nebraska), Executive Offices of the State of Arizona, Nevada Clean Energy Fund, Midwest Tribal Energy Resources Association (Minnesota, Wisconsin, and Michigan), Oweesta Corporation (Nationwide), Three Affiliated Tribes (The Mandan, Hidatsa and Arikara Nation) (North Dakota, South Dakota, Montana, Wyoming, and Wisconsin), and GRID Alternative (Western Indigenous Network Solar for All) (Arizona, Colorado, Nevada, New Mexico, and Utah). Please refer to EPA’s list of Solar for All awardees to learn more about programs that serve projects on Tribal land. (Updated February 27th, 2025)

The Build America, Buy America Act (PL 117-58) or “BABA” requirements apply to public “infrastructure” projects which are funded by federal financial assistance and mandates use of iron, steel, manufactured products, and construction materials used in the projects are produced in the United States.  

“Infrastructure” is interpreted broadly. The following types of Solar for All projects are infrastructure for the purposes of BABA applicability:   

• The public infrastructure portion of any property (e.g., retail in a mixed-use multi-family property) where the principal purpose of the Financial Assistance is to directly benefit such portion of the property;  

• Privately-owned commercial buildings when they meet the “public function” test;  

• Residential-serving community solar projects which EPA deems “structures, facilities, and equipment that generate, transport, and distribute energy” per 2 CFR 184.4(c).   

The following types of Solar for All projects are not infrastructure for the purposes of BABA applicability:   

• Single family homes;   

• Privately-owned, non-mixed-use, multi-family housing properties;   

• Privately-owned residential portions of mixed-use properties;  

• Any privately-owned, behind-the-meter energy generation and storage project that does not otherwise meet the definition of infrastructure.   

Absent other factors, the inclusion of the following types of funding, support, guarantee, or sponsorship in the funding stack of any Solar for All project does not trigger BABA, either individually or in combination:   

• Low-Income Housing Tax Credit (LIHTC);  
• Fannie Mae and Freddie Mac Backed Multifamily Mortgages;  
• Federal Housing Administration Insured Multifamily Mortgages;   
• HUD Section 8 Funding;   
• Other Federal, State, Tribal, or Local Housing Assistance Funding Sources: in general, subsidies issued by federal, state, Tribal, or local housing assistance funding sources that do not confer equity or ownership stakes for the governmental funding source do not trigger BABA applicability.   

The ultimate determination on BABA applicability for a particular project is always fact-specific. BABA applicability is assessed at the time of provision of financing based on the terms, limitations, and requirements of the financing product. Applicability does not change retroactively based on a change of use (e.g., if a ground floor apartment is re-zoned for a restaurant). Recipients may not temporarily modify or mischaracterize usage to intentionally avoid BABA compliance.  

Please see the EPA’s GGRF BABA FAQ for additional details. 

Davis Bacon Act (40 U.S.C. 3141-3144.), the Copeland “Anti-Kickback” Act, and the Contract Work Hours and Safety Standards Act, together the Davis Bacon and Related Acts (DBRA) apply to federally assisted construction projects.  

Note, however, that under Solar for All, DBRA requirements do not apply to any form of financing that meets any of the following criteria:  

1. Financing which exclusively funds pre-construction (e.g. permitting or design work) or post-construction activities (e.g. subsidies for subscriptions to already constructed solar assets).  
2. Financing which serves end-users who are individual homeowners or tenants of single-family homes or multifamily buildings when these individual end-users ultimately select the contractor(s) and execute the contract(s) for the construction work, as opposed to IPC or subrecipient or a contractor hired by IPC or subrecipient.  
3. Financing which serves end-users who meet the definition of Federally Recognized Tribal Entities, as defined under the SFA  assistance agreement, when these Federally Recognized Tribal Entities ultimately select the contractor(s) and execute the contract(s) for the construction work, as opposed to IPC, subrecipient, or a contractor hired by IPC or subrecipient.  
4. Financing which serves any end-user when such financing is less than $250,000 for a project and the end-user ultimately selects the contractor(s) and executes the contract(s) for the construction work, as opposed to IPC, subrecipient, or a contractor hired by IPC or subrecipient.  

Please review EPA mandated contract provisions which will apply to financial assistance with DBRA requirements. 

More information about BABA and DBRA compliance, including the Purpose, Time, and Place (PTP) test is provided in IPC’s Program Guidance materials. (Updated February 27th, 2025)

There may be solar industry-wide challenges in meeting BABA requirements. We anticipate opportunities to partner with other organizations, including trade associations, to help financial assistance awardees navigate these challenges collectively. IPC is exploring these opportunities.  

BABA waivers are available on agency-wide, program-wide, product-specific, and project-specific basis. The EPA has already issued several program-wide waivers, including a temporary BABA waiver based on non-availability for domestically assembled solar modules for infrastructure projects using SFA financing products awarded by IPC, as of January 10, 2025. The waiver applies to expenditures on solar panels made on or after January 10, 2025, until December 31, 2025, so long as those panels are installed by June 30, 2026. The EPA’s full waiver can be found here.  

The EPA may waive BABA requirements on a project-level where it finds that: (1) applying the domestic content procurement preference would be inconsistent with the public interest; (2) types of iron, steel, manufactured products, or construction materials are not produced in the United States in sufficient and reasonably available quantities or of satisfactory quality; or (3) the inclusion of iron, steel, manufactured products, or construction materials produced in the United States will increase the cost of the overall project by more than 25 percent. Waiver requests may take many months to process after submission to the EPA. (Updated February 27th, 2025)

Under Section 314 of the Clean Air Act, DBRA applies to federally assisted construction projects. The Solar for All terms and conditions state, “Davis-Bacon and Related Act requirements apply to forms of Financial Assistance that directly fund and are directly linked to specific construction projects that were not completed prior to the execution of the final binding documentation governing the use of the Financial Assistance.”  

Under the Solar for All terms and conditions, BABA applies to Federal funds obligated for infrastructure projects. BABA applies to infrastructure projects that were not completed before the date award funds were obligated, which for our Solar for All award was August 8, 2024. 

EPA has indicated that BABA will apply to an interconnection loan where the underlying project to be financed meets the definition of infrastructure (e.g., residential-serving community solar). DBRA will apply in this scenario as well.  

For permanent debt, BABA will apply if an infrastructure project was not complete prior to August 8, 2024. Post-construction financing for a project that was complete prior to this date and that meets the definition of infrastructure (for example, providing a “take-out” facility for a residential-serving community solar project) will trigger BABA requirements. DBRA will also apply to such a project if it was not complete before executing the permanent debt documentation. (Updated February 27th, 2025)

Developers are able to apply for BABA waivers. Developers should review previous EPA approved waivers on the EPA website. Waivers must be approved by EPA before they can be used by EPA financial assistance recipients. Waivers approved by other federal agencies do not satisfy BABA requirements for EPA-funded projects, unless it is a joint waiver with the EPA in which the EPA has signed the waiver. Waiver requests may take many months to process after submission to the EPA. (Updated May 21, 2025)

No, program guidelines provide two map or search tools to search LIDAC eligibility;, the Climate and Economic Justice Screening Tool and the EJScreen mapping tool may be used. For additional information about the other ways the program defines LIDAC, please refer to the definition of Low-Income and Disadvantaged Communities in Appendix 1 of the Program Guidance.  (Updated May 21, 2025) 

While single-family solutions are authorized under Solar for All, IPC’s award is directed solely at residential-serving community solar and multi-family solar solutions. (Updated May 21, 2025)

Solar for All grant funds must be used for financial assistance and technical assistance to enable low-income and disadvantaged communities to deploy and benefit from rooftop residential solar and residential-serving community solar. Infrastructure to store solar-generated power for the purposes of maximizing residential rooftop and residential-serving community solar deployment that is deployed in conjunction with an eligible project is allowed, but neither stand-alone energy storage nor other energy upgrades or technologies are allowed. (Updated May 21, 2025)

CPC Lenders will adhere to IRS guidance on proper calculations of the “bill credit discount rate” in underwriting (26 CFR Part 1). Using a subscribing household’s historical utility bills as our benchmark, our approach will be to start with the financial benefit provided to the subscribing household. We will then subtract all payments made by the household to the project owner and any related third parties as a condition of receiving the financial benefit. Finally, we will divide the difference by the financial benefit distributed to the subscribing household to ensure 20% minimum household savings. Financial benefits considered will include utility bill credits, reductions in the subscribers’ electricity rates, and other benefits accrued by subscribers, including non-utility benefits. 

Where it is impracticable to obtain individual households’ electric bills, we will use electricity price data pulled from publicly available state or utility-level retail electricity sources (e.g., derived from Energy Information Administration Form 861) taking into consideration household size, bill credits rate, and non-bypassable bill costs. Any estimates relied upon will be annualized.  

For more information, please refer to IPC’s program guidance and 20% household savings methodology on IPC’s Solar for All Resources page. (Updated May 21, 2025) 

The minimum requirement to complete the Intake Form and have a project evaluated is site control. (Updated May 21, 2025)