Why community solar will not raise the rent in public housing
A household in public housing, a Housing Choice Voucher unit, or a Section 8, Section 202 or Section 811 building can sign up for community solar, a shared solar project that credits a subscriber electric bill, without it raising the rent or shrinking the utility allowance, the fixed amount the Department of Housing and Urban Development, known as HUD, sets to cover a low income household electricity costs. Two signed HUD policy documents answer the question a tenant asks first, will community solar raise my rent.
HUD uses a 2 step test. Step 1 asks whether a solar credit is tied to how much electricity a household used. A flat credit that does not change the price per kilowatt hour does not require raising the utility allowance. Step 2 asks whether the credit counts as income for rent. HUD treats a credit that is subtracted from the bill total as a discount, not a cash payment, so it does not count toward the income used to set a family rent.
The 2022 memo did not cover every household right away
HUD applied this test first on August 4, 2022, in a memorandum covering only the Housing Choice Voucher Program and Public Housing, where a tenant pays an electric bill directly. A resident sharing one electric meter with an entire building waited a year longer, since HUD did not extend the test to its Multifamily Housing programs until Notice H 2023-09, signed August 3, 2023, covering 7 named program categories including Section 202 and Section 811 buildings.
In a shared meter building, the property owner receives the whole solar credit, so the notice lists 11 ways an owner can pass along that value without it counting as tenant income, among them free internet, a facility upgrade, or added support staff. A one time gift card is excludable as a temporary gift, HUD states, but a recurring gift card or cash payment generally counts as income.
How many buildings could actually use this
The Department of Energy says the guidance could potentially benefit approximately 4.5 million families in affordable housing, and affects 8.7 gigawatts of rooftop solar potential across roughly 200,000 HUD supported buildings. Nearly 50% of HUD assisted facilities suit rooftop solar, the agency says, against a national average of 26%.
HUD says nearly 50% of its assisted facilities are suitable for rooftop solar, compared with a national average of 26%. Both figures come from the Department of Energy program page.
Show the numbers
| HUD assisted facilities | 50 |
| National average | 26 |
No source found in HUD own guidance states how many households have actually signed up. The Department of Energy figures describe potential reach, not enrollment.
The funding HUD announced alongside its update
HUD announced its 2023 notice in a release naming 837.5 million dollars in Inflation Reduction Act grant and loan subsidy funding and 4 billion dollars in loan commitment authority for its separate Green and Resilient Retrofit Program, plus 42.5 million dollars for an energy and water usage data initiative. None of the 3 figures is a cost or a savings figure for the solar credit guidance itself.
These 3 figures describe HUD own broader Green and Resilient Retrofit Program funding, announced in the same release as the August 2023 notice on solar credits, not a cost or a savings figure for the solar guidance itself.
Show the numbers
| Inflation Reduction Act grant and loan subsidy funding | 837.5 |
| Loan commitment authority for the Green and Resilient Retrofit Program | 4,000 |
| Funding for the energy and water usage data initiative | 42.5 |
This updated guidance is reinforcing that all communities deserve to participate in America's growing clean energy economy.
Marcia Fudge, HUD Secretary. Source 4.
For a household deciding whether to sign up, a solar credit that lowers a bill will not count as new income or raise the rent, whether that household pays its own bill or shares a meter with the whole building.