By John A. Nichols, Guest Contributor
There is a bill moving through the Delaware General Assembly that its sponsors describe as a step toward billing simplicity and transparency for community solar subscribers. Read carefully, the bill does the opposite. It would authorize a billing model called net crediting, under which the subscription fee a subscriber pays to a private solar company is permanently hidden from the subscriber’s monthly Delmarva Power bill. The subscriber sees only a net savings figure. The fee that produced it disappears.
The bill’s synopsis calls this “a simpler, more transparent experience.” That claim does not survive contact with the bill’s own text. What is transparent about a bill that shows subscribers their savings but conceals the fee deducted to produce it? Transparency means being able to see what you are charged. This bill ensures you cannot.
The Grid Is Not a Battery
Before examining the billing model, a common misunderstanding deserves correction. Some subscribers enroll in community solar believing that the grid functions like a battery — that electricity generated by a solar array during the day is stored and available for withdrawal at any hour. It is not. The electric grid moves power in real time. A solar array generates electricity only while the sun is shining, typically six to eight hours a day. That electricity flows into the grid and is consumed immediately by whoever is drawing power at that moment.
The credit that appears on a subscriber’s Delmarva bill is a financial mechanism, not a record of electrons reserved for that subscriber. It is calculated under 26 Del. C. §1014(f)(1) as the subscriber’s allocated share of the array’s output, valued at the full volumetric delivery and supply charges on their rate schedule. The subscriber is credited for kilowatt-hours of generation attributed to their subscription. They are not credited because those kilowatt-hours powered their home. In the evening, overnight, and on cloudy days, their home runs on Delmarva’s conventional grid power, as it always has. This matters because it defines what subscribers are actually purchasing: a financial credit derived from solar generation, not solar-powered electricity.
Who Keeps the Money
That credit is substantial. Under 26 Del. C. §1014(f)(1), it equals all volumetric delivery and supply charges on the subscriber’s rate schedule — the full per-kilowatt-hour retail rate, excluding only fixed charges (the flat monthly Customer Service Charge of $13.50 that every Delmarva customer pays regardless of how much electricity they use) and taxes. But subscribers do not keep it. They pay most of it back to the Subscription Coordinator — the private company that signed them up and manages their account.
The split is documented. Delaware’s first operating community solar array, a 4.7-megawatt project in Georgetown, Sussex County developed by Nautilus Solar Energy and TurningPoint Energy, advertises a 10 percent savings rate for general subscribers. (WHYY, June 16, 2025.) Ten cents of every dollar of credit value generated on the subscriber’s behalf stays with the subscriber. The remaining 90 cents flows to the Subscription Coordinator and developer through the subscription fee — every month, over contracts that typically run twenty years or more.
The private contract governing how the Coordinator splits that 90 cents with the array developer is not filed with the Public Service Commission and is not disclosed to subscribers. The subscriber who funds that revenue stream has no legal right to know how it is divided or what the Coordinator earns.
Net Crediting Hides the Mechanics by Design
This is precisely the information that net crediting conceals. Under the proposed consolidated billing bill, Delmarva would calculate the gross credit, deduct the subscription fee internally, apply only the net savings to the subscriber’s bill, and remit the subscription fee to the Coordinator within 60 business days. The subscriber’s bill shows one new line: a net credit. The gross credit that Delmarva calculated does not appear. The subscription fee that Delmarva deducted does not appear. The per-kilowatt-hour rate the Coordinator is charging does not appear.
From a subscriber’s consolidated bill under this model, it is impossible to determine the gross credit generated on their behalf, the fee deducted, the per-kilowatt-hour rate the Coordinator is charging, whether that rate matches the enrollment contract, or whether it has changed since enrollment. A subscriber who cannot answer those questions from their monthly bill is a subscriber who cannot protect themselves. The monthly bill is the only document a subscriber reliably receives and reviews every month. If the fee is not on it, it effectively does not exist in the subscriber’s awareness, regardless of what the enrollment contract says.
The bill’s synopsis describes this arrangement as delivering a “simpler, more transparent experience” because the subscriber receives one bill rather than two. One bill is simpler. It is not more transparent. Transparency is a property of information, not of paper count. A single bill that conceals 90 percent of the financial transaction is less transparent than two bills that show it completely.
Delmarva Would Collect Fees It Cannot Verify
Under current law, Delmarva’s role in community solar is administrative: it applies credits to subscriber bills and has no financial relationship with the Subscription Coordinator. The Coordinator invoices subscribers separately. Delmarva is not a party to that transaction.
The proposed bill fundamentally changes that relationship. Delmarva would collect the subscription fee from subscribers, deduct one percent as an administrative charge — paid not by the Coordinator as a cost of doing business, but by subscribers — and remit the balance to the Coordinator. Delmarva would become the enforcement arm of a private, unregulated commercial transaction.
When Delmarva collects a charge on a customer’s bill, customers reasonably assume that charge has been reviewed and authorized by the Delaware Public Service Commission. That assumption would no longer be correct for the subscription fee. The PSC has not reviewed the Coordinator’s fee structure. It has not determined the fee is just and reasonable. The subscription fee would carry the implicit authority of a regulated charge while receiving none of the oversight that regulated charges require.
Delmarva would collect whatever the Coordinator instructed it to collect. If the fee rate changed, if an incorrect kilowatt-hour allocation was applied, if a subscriber was overcharged relative to the enrollment contract, Delmarva would collect it anyway. It has no obligation under the bill to verify that the amount matches the contract. Under net crediting, the subscriber — who could detect the discrepancy from an itemized bill — has no itemized bill to consult.
The bill does prohibit Subscription Coordinators from imposing unauthorized charges through consolidated billing. A prohibition the subscriber cannot monitor enforces itself against no one. It is a statement of aspiration directed at a party with every financial incentive to test its limits.
Twenty Years Without a Receipt
Community solar enrollment contracts in Delaware run for twenty years or more. Subscription Coordinators are sold. Developers are acquired. Fee structures are renegotiated. The subscriber who enrolled in 2027 may be dealing with an entirely different commercial entity by 2035, operating under assignment provisions in a contract the subscriber signed eight years earlier and has not reviewed since.
Under net crediting, if the Coordinator’s fee rate rises by a fraction of a cent per kilowatt-hour, the subscriber cannot detect it from the consolidated bill. If the gross credit falls and the net savings shrink, the subscriber cannot determine from the bill whether the credit calculation changed, the fee rate changed, or both. The bill shows only the result. The mechanics that produced it are hidden by design — and will remain hidden for the life of a contract that may outlast the company that wrote it.
What the Bill Should Require Instead
Three lines on a bill: the gross credit, the subscription fee, and the net savings. Delmarva already calculates all three under the net crediting model. The statute requires the gross credit calculation under 26 Del. C. §1014(f)(1). The subscription fee is the contractual basis of every subscriber’s twenty-year obligation. The net savings is what the subscriber keeps. Displaying all three is a formatting decision, not a technical challenge. The only party for whom that display creates a problem is the Subscription Coordinator, whose financial position improves when subscribers cannot see the fee.
A program that extracts fees from ratepayers through the state’s regulated utility infrastructure, under contracts lasting twenty years, without disclosing those fees on any bill the subscriber receives, is not a ratepayer program. It is a ratepayer extraction. The General Assembly should call it what it is — and require itemized billing before authorizing the mechanism that makes it invisible.
John Nichols is a long-standing advocate for affordable and reliable electricity in Delaware.
Sources: 26 Del. C. §1014(f)(1); Delmarva Power Tariff P.S.C. Del. No. 8 — Electric; Liberty Consulting Group, Technical Consultant Final Report, Delmarva 2025 SOS Auctions, Feb. 19, 2025 (Delaware PSC); WHYY News, “Wilmington residents encouraged to sign up for community solar initiative,” June 16, 2025; Sen. Hansen, Consolidated Billing Bill, 153rd General Assembly (draft March 18, 2026); 26 Del. C. §1014(f)(1)(e) (15% LMI subscriber requirement).
