Inclusive Utility Investments

Inclusive Utility Investments (Including Pay-As-You-Save®)

Inclusive utility investments provide support for cost-effective energy-saving measures through financing attached to the meter, not the resident.

IMPACT AREAAffordability, climate mitigation
TOPICEnergy transition, utility bills, energy efficiency, financing
REGIONState, utility
AFFORDABILITY PATHWAY
OVERSIGHTUtility commission
POLICY MECHANISMLegislation, regulation

Challenge

Investments in residential clean energy technologies, in particular energy efficiency measures, can reduce energy consumption, bills, and greenhouse gas emissions, but often require high upfront investment costs. These upfront costs may place clean energy upgrades out of reach of low- and moderate-income households. Many existing financing approaches for such investments are inaccessible—due to credit score or other requirements—or pose a risk to consumers by placing a lien on a house (risking foreclosure in case of nonpayment) or a personal loan that could contribute to poor credit in the case of an inability to pay. Moreover, protections are needed to ensure that any investments achieve projected energy and bill savings, rather than driving up costs for households.

Policy Solution

Inclusive utility investments—the most common approach being the Pay-As-You-Save® (PAYS) model developed by the Energy Efficiency Institute, Inc.—finance clean energy upgrades through an on-bill tariff that is attached to the energy meter, rather than a lien on the house or a loan to an individual. Any approved upgrades must have an independent party verify that estimated cost savings will exceed the on-bill tariff.1

Model Policy Features

Below, we describe some of the core elements of the PAYS® model, which is the most commonly adopted form of inclusive utility investments. PAYS® programs require meeting all of the specified Essential Elements and Minimum Program Requirements.23

Potential Policy Drawbacks and Pitfalls

  • Studies of existing programs show that average energy efficiency savings are somewhat lower than estimated, and some houses may even show an increase in energy usage after clean energy investments are made—although in many cases these demand increases are related to other behavioral changes (e.g. addition of inhabitants at a given location).4
  • Strong consumer protection guardrails are required to ensure real savings after implementation, such as active oversight of project quality,56 and requiring that the annual investment payback amount is no more than 80% of annual savings;7 however, the more stringent these requirements, the fewer measures will qualify—requiring customers to instead pay a larger share of the investment up front for measures that they wish to implement that are somewhat less cost-effective.
  • Customers who are already on discounted low-income utility rates may take much longer to pay back any implemented measure, resulting in fewer measures being financeable using this model.
  • Estimated savings are based on projected energy prices, which can be volatile and affect realized savings.
  • In many cases, lack of loan repayment can lead to utility disconnections; consumer protections can be enhanced by prohibiting disconnections for nonpayment of the on-bill financing portion of the bill.8

Complementary Policies

Policies that may support inclusive utility investment effectiveness or provide customer protections include: 

  • LMI home electrification programs, pre-weatherization, disconnection protections, arrearage management plans


Additional Information: As of 2024, 12 states had inclusive utility investment programs or pilots.9

1. Midwest Energy How$mart® Program

Details:

  • Provides on-bill payment to Midwest Energy electricity and/or gas customers for energy efficiency upgrade measures such as insulation, heating, and cooling, following the PAYS model.
  • Accessible to renters if both landlord and tenant agree.
  • Recipients must be in good standing on utility payments.10
  • 90% of estimated savings can be included in the cost recovery tariff. 
  • Average payback period is 15 years, longer than many other programs.
  • 73% of households had a copay to pay some of the upfront costs of the project.
  • Payments are reduced or eliminated if the implemented measures do not work properly.
  • An evaluation of installed measures reduced annual electricity by 15% and gas by 26% on average, but were somewhat lower than expected: total savings were 83% of what were estimated before implementation.
  • Cost savings are higher in summer and winter, when bills tend to be highest, helping smooth out utility bill payments.11

Challenges:

  • Does not apply to houses that do not attach to the foundation (e.g. certain mobile homes).12
  • While the majority of households saw energy savings, only half of households saw cost savings that covered their annual tariffed bill payments—likely due to a mix of changing gas and electricity prices (lower prices yield less savings), changes in occupant behavior, and relatively high level of estimated savings (90%) that can be included in the cost recovery tariff.13

2. Duke Energy Improve and Save Program14

Details:  

  • The program is available to Duke Energy electricity customers, including both renters and homeowners if both landlord and tenant agree.
  • Recipients receive a third-party energy audit to estimate the savings associated with energy efficiency upgrades, such as HVAC, duct sealing, insulation, and heat pump water heaters.
  • Customers may pay a portion of the investment up front, some of which may be offset through additional incentives.
  • The remainder of the clean energy investment is paid for through an on-bill tariff, which remains at the site of the meter rather than following the account holder.
  • Repayment period is set at 10 years.

    Challenges:

    • Does not apply to gas customers.

    1. Energy Efficiency Institute, Inc. (2021). PAYS essential elements and minimum program requirements. ↩︎
    2. Energy Efficiency Institute, Inc. (2021). PAYS essential elements and minimum program requirements. ↩︎
    3. Clean Energy Works. (2023). Introduction to inclusive utility investments. ↩︎
    4. Deason, J., Murphy, S., & Leventis, G. (2024). Participant outcomes in residential Pay As you Save® programs. Lawrence Berkeley National Laboratory. ↩︎
    5.  Clean Energy Works. (2023). Introduction to inclusive utility investments. ↩︎
    6. National Consumer Law Center. (2023). Tariff-based On-Bill Financing: Assessing the Risks for Low-Income Consumers . ↩︎
    7. Energy Efficiency Institute. (2021). PAYS essential elements and minimum program requirements. ↩︎
    8. National Consumer Law Center. (2023). Tariff-based On-Bill Financing: Assessing the Risks for Low-Income Consumers . ↩︎
    9. US Environmental Protection Agency. Inclusive Utility Investment. Accessed: September 30, 2025. ↩︎
    10. Midwest Energy. How$mart® Q&A Sheet. Accessed: September 29, 2025. ↩︎
    11. Deason, J., Murphy, S., & Leventis, G. (2024). Participant outcomes in residential Pay As you Save® programs. Lawrence Berkeley National Laboratory. ↩︎
    12. Midwest Energy. How$mart® Q&A Sheet. Accessed: September 29, 2025. ↩︎
    13. Deason, J., Murphy, S., & Leventis, G. (2024). Participant outcomes in residential Pay As you Save® programs. Lawrence Berkeley National Laboratory. ↩︎
    14. Duke Energy. Improve and Save. Accessed: September 30, 2025. ↩︎