Vermont Legislature SmartTranscripts:

[Rep. Kathleen James (Chair)]: You're live. Alright. Welcome back, everybody. It's Tuesday, March 17, and we are continuing our testimony on S202 and act relating to portable solar energy generation devices. I'm representative Kathleen James from Manchester.

[Rep. R. Scott Campbell (Vice Chair)]: Scott Campbell from St. Johnsbury. Bailey, Lamoille two. Chris Morrow, Windham, Windsor Bennington. Christopher Howland, Rutland four. Dara Torre, Washington two.

[Rep. Bram Kleppner (Member)]: Bram Kleppner, Chittenden Thirteen, Burlington.

[Rep. Kathleen James (Chair)]: Laura Sibilia, Windham two. Great. And in the room.

[Julie Walsh (Committee staff/assistant)]: Bennington, Julie Walsh from Deep Creek.

[Rep. Kathleen James (Chair)]: Super. Hi, Wesley.

[Wesley Schrock (BrightSaver, nonprofit witness)]: Hello. Good afternoon.

[Rep. Kathleen James (Chair)]: Yeah. Thanks for joining us.

[Wesley Schrock (BrightSaver, nonprofit witness)]: My pleasure. Happy to be here.

[Rep. Kathleen James (Chair)]: Yeah. So I just wanted to give you a little bit of an orientation. So we are just starting our testimony on S202. And I think I would let you guys know that we, at the beginning of the session, had identical bills introduced, a House bill on our committee, H. Five ninety eight, and then s two zero two on the senate side. And we have dropped h five ninety eight, and we're taking up s two zero two. That's the bill that's on the move. So that's the relevant language, and We're really just getting started. All we've done so far is walk through the language of S202 with our journey so that we understand what's in the bill legally and what's not and where it fits in the statute. And now we're going to start learning all about this technology. So appreciate you joining us. I know we have some written testimony that you've submitted and if you can just walk us through it and if it's okay with you, we usually ask questions as we go. Is that alright?

[Wesley Schrock (BrightSaver, nonprofit witness)]: Yeah, that's totally fine. However, however you prefer. I do, I do have a, have a slide deck. It's about, nine slides. So I'll walk through that. I was instructed to give sort of an overview of our or an introduction to plug in balcony solar, so I'll do that. And I'm happy to take questions along the way or once I'm done with the So I'll share my screen if that's okay.

[Rep. Kathleen James (Chair)]: Great. And if you could also just identify yourself for the record.

[Wesley Schrock (BrightSaver, nonprofit witness)]: Yes. Sure. My name is Wesley Schrock. I am representing a BriteSaver. We are a nonprofit based in California. Let me start the and so we we basically what we do, we do a couple of things. We do pilot programming. So we install we're not a manufacturer of systems, but we install and service systems to see what works, what doesn't work, what the obstacles are, and also to gather savings data. So that's one thing. Then what else, the other thing that we work on is on the educational piece. So on the policy piece. So let me share my screen now. Okay. Can everyone see that?

[Rep. Kathleen James (Chair)]: We can.

[Wesley Schrock (BrightSaver, nonprofit witness)]: Alright. So what are we talking about? What is Plugany or Balkan or portable, solar? So these are small, modular photovoltaic units, typically 1,200 watts and below, although some states are setting a nineteen twenty threshold and they plug into a standard outlet and exterior outlet. Right now, systems, 800 watt systems cost as low without a battery cost as low as well, actually even with the battery cost as low as 5 or $600 in Europe. In The US prices right now are a little higher. If we take Utah as an example, Utah being the only state that has passed plug in solar enabling legislation. There you can buy an 800 watt system that's too big for a watt glass panels and a micro inverter for about $1,000. If you add a battery, it's about 2,000. And as the picture on the right there shows you can place them sort of anywhere you have a flat surface. So you can place them on the ground in your backyard, you can place them on a patio, flat roof of a garage, hang them over a balcony. And so because of this, and because they're easy to install, ideally plug and play, go to the store, you buy it, you bring it home, you plug it in permissionless thing. They are accessible to a pretty large percentage of the population unlike say, for example, rooftop solar. So that is the idea is that this sort of democratizes solar allows people who wouldn't otherwise be able to do so to access solar, including renters, including people living in multi unit buildings or high rise buildings. So what they do, these systems, is they feed power directly into the home through the outlet. So the power goes into the outlet, it will feed anything else plugged into the outlet then to the panel. And from there, go to wherever the load is being drawn on the panel. And if there is no load in the house, if the battery is full, if it has a battery, the additional power electricity would go back to the grid. And so what they do, so why would people do this is will they offset grid use and reduce electricity bills, potentially up to 25% per month. That of course depends on the size of the PV system and the electricity use in the home. We ran running some numbers for Vermont, a 400 watt system could save about a $120 a month, whereas a 1,200 watt system about not not a month, per year. One one twenty to three sixty per year, 400 watts one twenty, 1,200 watts three sixty, depending on the system size and whether or not there's a battery. We think that batteries will be key to these systems. We found in our pilot programs that we're running in California, that with a battery, households are able to utilize pretty much 100% of the generation capacity without they were not utilization rates were not nearly as good. And the last point on this slide is that these work with traditional grid connected homes. These are not this is not an off grid product. That's already an established market for camping, RVs, what have you. This is for grid connected homes. Okay, this is just some more photos to get a sense.

[Julie Walsh (Committee staff/assistant)]: I'm sorry.

[Rep. R. Scott Campbell (Vice Chair)]: Wesley, back to that comment. You said these are for grid connected homes, not for, say, RVs or non grid connected homes.

[Rep. Bram Kleppner (Member)]: Can you

[Rep. R. Scott Campbell (Vice Chair)]: expand on that a little bit?

[Wesley Schrock (BrightSaver, nonprofit witness)]: Yes. So basically, right. So the idea with these systems is that the electricity that they generate is substituting what you'd otherwise be using or drawing from the grid. So I have a diagram later that I'll explain sort of the components of the system, but the microinverters themselves are grid interactive or grid tied. So these meaning that they only operate when the household is connected to the grid, Like only when they're sensing, only when the microinverter is sensing that the grid is on will the system operate. And so these are not they're not grid forming devices. They are grid interactive. They work in conjunction in parallel with the grid. Okay.

[Rep. R. Scott Campbell (Vice Chair)]: Is that how all these systems are? I'm sorry. Interrupting again. Is that is that all these systems are or is that or is that a subset of of these types of these plug and play types of systems?

[Wesley Schrock (BrightSaver, nonprofit witness)]: Yeah. So so what we are yes. So when I when when I'm talking about plug and play or balcony or portable, I am talking specifically about the S like the grid, the grid interactive, the grid tied systems. So within solar, within the solar universe, you have sort of the off grid systems. You have your generator or your solar generators, and then you have the balcony or plug and play. And so that's the type of system that we are talking about and I believe the legislation is also talking about.

[Rep. R. Scott Campbell (Vice Chair)]: Okay, great. Thank you. Thanks for that clarification. Okay.

[Wesley Schrock (BrightSaver, nonprofit witness)]: So I'll I'll keep moving then. So this is this is to give you an idea. So, you know, as I mentioned before, you can put them in their back in your backyard. You've got some large 400 watt glass panels in the photos on the left. And then you have a, I think that's a 180 watt flexi panel that you could zip tie to a balcony or use suction cups to a balcony, it's very lightweight. So these are sort of the types of products are already on the market. And there'll be of course, more iterations and more variations as the market matures. This is just an example, a photo from Germany. This is sort of if you Google balcony solar Germany, you'll see this where you've got these high rises and solar panels on every balcony all the way down. This is the graphic that I was referring to. So these systems are quite simple. There aren't a lot of components. So you've got the solar panels, which at this point are pretty much a commodity. And then you have the key piece really is the microinverter that I was referring to. And that has, you plug the solar panels into the microinverter and the microinverter you plug into your home. And you can integrate that micro inverter with a battery. In some, systems, it's it's it's quite slick. The micro inverter and the battery are just one box. They're not separate. They're not separate components. And so it's that micro inverter that converts the DC from the solar panels into the AC that is used by the home grid and but, yeah, by the by the by the home. And as I said, these are you know, the homes are connected to the grid and electricity is flowing back and forth between the home and the grid just like with rooftop solar. Now keep in mind that, know, again, with a battery, that export will be very minimal to the grid. Okay, this is sort of some data on what has happened in Germany and what we are hoping to recreate in The US. So on the left hand side, can see the cost of the systems. So it fell quite dramatically from €2 a watt to, you know, fifth half a euro a watt more recently. And then you see the adoption. They went from, you know, less than a 100,000 systems to more than 1,000,000 registered systems in 2025. So Germany does have a notification system. So that's how when when I say registered balcony solar units. So basically, when someone buys these systems, are supposed at post installation, post setup, they're supposed to notify the German I think it's their public their equivalent of the Public Utilities Commission that the system has been installed. There are estimates, though, that there are up to 4,000,000 of these in use, although only a million officially registered.

[Rep. R. Scott Campbell (Vice Chair)]: Wesley?

[Wesley Schrock (BrightSaver, nonprofit witness)]: Yes, please.

[Rep. R. Scott Campbell (Vice Chair)]: So we heard that the bill before us does not have any registration or notification requirement to the utility. In fact, we heard that the utilities don't want to hear about it. They view it as an appliance and they don't want to have to track that. So I guess, if you could, what can you say about why in Germany they've decided that they do want to know about it? Do know anything about that?

[Wesley Schrock (BrightSaver, nonprofit witness)]: Yeah. So, well, let me let me speak to rather than Germany, let's talk about, Virginia, for example. So Virginia, their bill has passed both chambers. It's going to the governor here in April, by all accounts, she is very likely to sign it. And Virginia does require a utility notification system. And so the bill actually specifies what is to be in that notification, fields that are to be there and whether it's they're supposed to be a digital version, online version, and a physical copy. And so, you know, why did the, you know, why did the utilities want to manage that system even though, yes, there is a cost like somebody has to do it. Right? So there is a cost of of running and maintaining the system, but they wanted to do so for a number of reasons. One is just for is just for planning to understand what the like, how many are out there, what it might possibly mean for the grid, infrastructure improvements. Also for, you know, so for you could say for line line worker safety. So just just understanding, okay, which households have these, which don't. And then also for, meters. I know that the Vermont bill currently, requires the the customer to have a smart meter, in order to use or to buy a plug in solar bill. And so basically with a with a registration system, then the utility can check, okay, what kind of meter does this person have or does household have? Do we need to go in and and swap it out? Because if it's an old analog meter that only runs one direction, then it might be problematic. So those are sort of the the main reasons why, utilities, not just in Virginia, but in other states are are requesting. And I'll say one final thing is also so that if they sort of you know, some some utilities are monitoring and how like, if they see any sort of export to the grid, they that that gets flagged, in their system. And so if they know, okay. This system this this household has has a a plug in PV, can export up to 1,200 watts. That's great. You know, we don't need to send a truck out there to find out what's going on. So those are some of the those are some of the reasons why utilities want them. But in Vermont, yeah, the utilities made the decision that the cost of running the system is not worth the benefits that I just explained.

[Rep. R. Scott Campbell (Vice Chair)]: Well, do these other utilities in Dublin, Virginia and Germany, you hear our examples, still have a fair number of analog meters out in the field.

[Wesley Schrock (BrightSaver, nonprofit witness)]: So my yeah. My my understanding is that like that, I cannot speak to the to the situation of meters in Germany. But I but I like in The US in talking to understanding is that in talking to states like Delaware, Massachusetts, that specifically in the Northeast, there are a lot of old analog meters out there. That's not so much the case in California. We have, like, time abuse billing out here. We all have smart meters. So I think it varies dramatically state to state. And so One thing to consider is if you've got a lot of analog meters in Vermont and the the expectation is that, you know, not everyone's going to pair a plug in solar system with a a with a battery. What are the you know, what does that mean for meter functionality and billing if some if there's some export back to the grid?

[Rep. R. Scott Campbell (Vice Chair)]: Well, I think there's a pretty good penetration of advanced metering in in in Vermont. Just something that the Inexico you took on these, the last ones, it has some analog to this, as I understand it. Yeah, more to learn about this. Thank you.

[Wesley Schrock (BrightSaver, nonprofit witness)]: Yeah, sure. So, okay. So, what are we talking about? Yeah. So basically, let's let's talk about so what the the Utah bill. So the Utah was the first. It was a Republican by the name of Raymond Ward, that introduced HB three forty last year. It was passed unanimously signed into law. And that bill and then all the others that are being introduced this this year, 2026 in The US, do a couple of a couple of fundamental things. They all sort of do a few basic things and then and then each one gets a little different. But so they all sort of define what is plug in solar. So you're creating the category, setting a threshold. 1,200 is what most states are using. As I mentioned before, some are using nineteen twenty. So you establish, you define plug in solar.

[Rep. Richard Bailey (Member)]: So can I ask you a question about that? Yes.

[Wesley Schrock (BrightSaver, nonprofit witness)]: Yeah.

[Rep. Richard Bailey (Member)]: We got a letter from some guy who runs Craftstrum,

[Rep. R. Scott Campbell (Vice Chair)]: which

[Rep. Richard Bailey (Member)]: I guess company that makes these things. And his recommendation was that we align the system capacity to existing national electric codes, which should be 1,800 watts for a 15 amp circuit and 2,400 watts for a 20 amp circuit. You said the 1,200 watt limitation was based on old German grid standards and in aligning with American NEC standards. Do you have any comment on that?

[Wesley Schrock (BrightSaver, nonprofit witness)]: So yeah. So the let me explain. So the so Germany uses 800 watts. That's basically what Germany has has determined. So their their their systems are all 800 Watts and blue is all plug and play. Like you just go to IKEA, you bring it home, you plug it into any outlet. It doesn't matter if it's a dedicated circuit or a branch circuit on their system. 800 Watts is totally safe. Now, so where does the 1,200 come from? So yes. So what what would be safe? Let's see. Let's do the what would be safe on a like a 15 amp? So let's see. 15 amp. One. So we have 120 volts. Yes, it's 1,800. But technically you need to my understanding is that you need to ratchet that down 80%. So if you multiply so if you took like 80% of 1,800, you'd be at fourteen forty. However, not exactly sure why, perhaps an error in math, Utah went even more conservative and didn't use fourteen forty, they used 1,200. So basically in Raymond Ward's discussions with the utilities, that was sort of like in the code bodies, that was sort of the number that they came out at. But technically on a Most of our circuits are 15 amps, 120. If you took 80% of that, you would actually have fourteen forty. And that nineteen twenty number that I'm referring to, that's if you have a 20 amp. So if you took 20 amps times 120 and then did 80%, that's where you get nineteen twenty. 20 times one twenty is 24. 2,400 times point eight. I'm just doing it on my phone here. Nineteen twenty. Does that make sense?

[Rep. Richard Bailey (Member)]: Yeah. What's the 80%? That's just a a safety standard that

[Wesley Schrock (BrightSaver, nonprofit witness)]: you That's yeah. My understanding is the NEC yes. That's that's like I'm I'm not an NEC expert. But, yes, my understanding is that that's yeah. That that's like the safety buffer

[Rep. R. Scott Campbell (Vice Chair)]: Right.

[Wesley Schrock (BrightSaver, nonprofit witness)]: That the NEC requires.

[Rep. Richard Bailey (Member)]: Okay. Thank you.

[Rep. Bram Kleppner (Member)]: So

[Wesley Schrock (BrightSaver, nonprofit witness)]: yeah. So you've got, as I mentioned, some some states pushing for 1920. So you create the category and then you exempt it. The idea is to exempt these systems from interconnection agreements and net metering. So the idea being to sort of reduce the friction to not subject these systems to the same sometimes lengthy, sometimes complicated, sometimes expensive interconnection agreement that is required for rooftop solar. And then all of the bills include some sort of nod to safety pointing towards, okay, the systems have to be UL certified or an equivalent NRTL nationally recognized testing laboratory, they need some sort of, they need a safety certification. And then also the bills have no fiscal impact. So all this legislation is doing is enabling the market, no subsidy, no incentive required. Those are sort of the basic tenants, but then each state is doing things a little bit differently. So Utah was last year, so far this year, 31 states, I don't have them all. 31 states, this year, have introduced. And so, you know, you're seeing states on the East Coast, the West Coast, the middle of the country, blue states, red states, purple states. Like, this is cutting across all of those divisions. And we think at least two more will still introduce yet in 2026. So I mentioned Virginia through both chambers. They're they're going to be or more than likely going to be the second state after Utah to do it. Colorado is through the house. Massachusetts is through the house. Hawaii is through the senate. Vermont is through the senate. And then in all the other states, they're still working their way through committee or in a handful, they're already the bills are to be The bills have already died. But in all those cases, the sponsor and the coalitions are already gearing up or looking towards 2027 to reintroduce. So I talked about I'll say one more thing about Virginia. We talked about some of the how each state is doing things. They all have that core tenet of defining what it is, setting a threshold, exempting from interconnection net metering, requiring UL certification or equivalent certification. And then some states like Virginia, for example, they're doing the utility notification. They are also, so they in Virginia, they're defining portable solar as a good so that they can regulate the sellers of plug in solar according to the Virginia Consumer Protection Act. They also included some like tenants rights or solar rights. I think they did so in very measured way. For example, a renter must request permission from the landlord before they do any installation that requires changes to the building's wiring. And they do allow for landlords to set, you know, reasonable restrictions on the use of these. So I think they think they did a decent job of striking a balance between enabling Is

[Rep. Kathleen James (Chair)]: that all the Virginia bill?

[Wesley Schrock (BrightSaver, nonprofit witness)]: Go ahead. Say again.

[Rep. Kathleen James (Chair)]: Did you was that all the Virginia bill you were just

[Wesley Schrock (BrightSaver, nonprofit witness)]: talking Yeah. So I was talking about the what the Virginia bill does. So I was I was trying to to illustrate how each each state, is doing some slightly different things. And so I was using Virginia, as an example because they're the furthest along to talk about some of the things that they did.

[Rep. Kathleen James (Chair)]: Yeah. Was just curious because I think we're gonna wanna take a look at that because sounds like they included notification, which we had included utility notification, which we had included in the House bill and has gone from the Senate bill and it feels important to me. And then you mentioned consumer protections, might be of interest. And I think we probably have some interest in renter landlord stuff. So maybe we need to get a get a look at that Virginia bill.

[Wesley Schrock (BrightSaver, nonprofit witness)]: Yeah. You can you can find it online, and I'm happy to share a a link to it as well. And I also have a nice, like, two page write up of what of what the bill does. Know, you can you can look through the the text, but I also have a nice summary that I'm happy to share as well.

[Rep. Kathleen James (Chair)]: Yeah. That'd be great. I'm curious about some of the stuff they're including.

[Wesley Schrock (BrightSaver, nonprofit witness)]: Happy happy to do that. So let's see. So we're talking about where this is happening. So I also wanna touch on, so we're talking about yeah. So there's a there's a push, nationally to to do, enabling legislation. Also, there are developments happening on the safety front. So in December, the first so keep in mind that the Utah bill was released or wasn't released, was signed into law before this this this safety system the safety standard came out. But in December, so UL released UL 3,700, which is the first safety standard for plug in balcony solar in The US. And then in January, they announced a a testing and certification program for manufacturers who wanna get their system certified to UL 37. And I believe you have maybe on, I think on Thursday, a representative from UL coming to talk about that. So basically what the main takeaway is that a UL 3,700 listed device installed according to the manufacturer's guidelines, which come directly from UL, you can be sure that it is safe and that it complies with current NEC guidelines. The other thing I wanna talk about is sort of this market enablement piece. So the, when Utah passed that naming legislation, you had a couple of manufacturers immediately begin selling there. Others, some of the major players in Europe and in Asia are sort of sitting on the sidelines to wait and see what happens in The US with legislation. And in our conversations with manufacturers, if we can get five, six, seven states to pass this legislation, that is a signal that The US is becoming a real market. Have the interconnection red tape being cut. You have QL working diligently on developing a standard. And so that's a signal. Okay. The US is now a legitimate market. And so you'll have other manufacturers expand. You'll have existing manufacturers expand their offerings, other manufacturers enter the market. And that competition will help drive down prices for consumers. The last slide that I have is around grid impact. So there's a gentleman by the name of Bill Brooks who serves on UL technical committees. He's been on NEC code making panels including for article seven zero five of the NEC, which is

[Rep. Richard Bailey (Member)]: all

[Wesley Schrock (BrightSaver, nonprofit witness)]: about solar. So he's sort of a a noted solar export expert. And so we had him, ourselves and permit power commissioned a report to sort of get at, okay, what would be what's going to what is going to be the impact on the grid if we have mass adoption of these systems? And so he ran did some modeling where even if we had 1.2 kilowatt systems, so the biggest systems possible adopted by 40% of households without batteries. So he looked at a regional level. Even if you had that level of penetration or of adoption, the residential sector would still at no point during the day, at no point during the year be a net exporter. So the point of that is that the best way to think about what these devices do are sort of energy conservation measures. And so because again, you're reducing electricity bill, you're using less grid energy, less grid power. And so from the utilities perspective, really what these are, you know, it's it's there. The households are using household using less. And so it's it's it's basically like an energy conservation measure is is the point I wanna make there. It would not it would not require, you know, significance, if any, investment in in utility infrastructure to accommodate these devices even at a pretty significant scale. Okay. It is I'm gonna stop my share. And are there any questions? If not, I can I can talk? There's one more, I think, key piece in the Virginia bill that I could talk about that is currently not in the Yeah.

[Rep. Kathleen James (Chair)]: That sounds great.

[Wesley Schrock (BrightSaver, nonprofit witness)]: Montville. So I

[Rep. Bram Kleppner (Member)]: have a question.

[Wesley Schrock (BrightSaver, nonprofit witness)]: Yeah. Please.

[Rep. Bram Kleppner (Member)]: The units being sold in Utah currently require any changes to a structured wiring?

[Wesley Schrock (BrightSaver, nonprofit witness)]: Yeah. So that's let's let's dive in. Let's let's dive into that. So no. So the the the EcoFlow so I mentioned a company called EcoFlow. So they're selling a system there. AP Systems is selling a system. And those systems have standard NEMA, you know, the NEMA five fifteen plug that all of our appliances do that you just plug into a wall. So those systems don't require any changes homes wiring. The manufacturers do recommend using a dedicated, only using them on a dedicated circuit to prevent breaker masking. So let's talk about

[Rep. Bram Kleppner (Member)]: What is breaker masking?

[Wesley Schrock (BrightSaver, nonprofit witness)]: Yes. So, okay. So breaker masking can occur basically it's if a section of the wire of the wiring gets too hot without the breaker on your breaker panel recognizing it. So the breaker panel doesn't flip. So typically what would happen is you've got too much current running through the wire, the breaker flips and circuit is dead. Like if you try to run your toaster and your microwave and all at the same time, the breaker trips. So the wires can't heat up because the breaker tripped. But what can happen with these plug in devices on a branch circuit, so if you have the panel, let's see on the right hand side, you plug plug in in solar system in the middle and then at the other end, you've got a space heater. So the electricity that's flowing between the space heater and the plug in solar device, that section of the wire, that additional current that the plug in solar units is providing is not detectable by by the by the breaker. And so that section of the wire could, in theory, get overheated. And in the absolute worst case scenario, cause a house fire. More likely, you're just gonna degrade the wire. But theoretically, you could create a fire. And so, but if you're on a dedicated circuit, then you don't have to worry about the breaker masking. And there are technologies, there are things you can do to make branch circuits, to set up a branch circuit such that you will not get breaker masking. There are overcurrent protection solutions for that, which you all 3,700 contemplates and explains very well.

[Rep. Bram Kleppner (Member)]: Got it. Thank you.

[Wesley Schrock (BrightSaver, nonprofit witness)]: Okay. Did I raise my hand? Whose hand is up? Sorry about that. Okay. So I want to talk then, so this leads into a discussion Sorry,

[Julie Walsh (Committee staff/assistant)]: one sec.

[Rep. Kathleen James (Chair)]: Rutland, do you have a question?

[Rep. Christopher Howland (Member)]: All right, so you got 120, two forty volt service from the utility and it's 110 when you get down to the NEC size and you can get as low as 108 volts in the home. That's where your ampacity is, You're dividing by 120 rather than 108 when you're calculating your hands. But if you've got this plugged in to leg A and your power's on leg B, how does the power get from leg A to leg B? And that's a leading question because I know the answer.

[Wesley Schrock (BrightSaver, nonprofit witness)]: So, yeah, like, you're talking about, like, the phase issue? Correct. Right. Right. So yes. So, like right. So yes. So the systems that we've piloted will only power what is on the same phase as what you've got the system plugged into or if you've got anything that's like on both phases, like an EV charger or, you know, whatever is drawing from both phases. But yes, it won't go to the other phase.

[Rep. Christopher Howland (Member)]: It won't go back to if you plug it in leg a, it won't go to leg b.

[Wesley Schrock (BrightSaver, nonprofit witness)]: Yes. That is that is yes. That is a a known issue with, like, our system and and with with, like, our our US, like, electoral system having these these phases. And so, yes, it won't get it won't get over to the other leg. It'll only it'll only power what's on yeah. It's what's on the same phase and leg or anything as I as I said before is like two forty is drawing people.

[Rep. Christopher Howland (Member)]: Well, if it's there's excess power, it's gotta go back through the through the meter, back to the transformer, come over to leg b at the transformer where where that's is connected to the transformer, the windings of the transformer. So and and your your conventional meters, your mechanical meters do run backward unless you put in a specific meter that's called a detented meter.

[Rep. R. Scott Campbell (Vice Chair)]: So you you you've I guess

[Rep. Christopher Howland (Member)]: you covered that. Is there a capacitor involved in these things to get the voltage to support the voltage from the DC to AC inverter.

[Wesley Schrock (BrightSaver, nonprofit witness)]: That would happen at the at the microinverter. That's what the microinverter does.

[Rep. Christopher Howland (Member)]: And microinverter has a capacitor in

[Wesley Schrock (BrightSaver, nonprofit witness)]: it. Yeah. Yeah. Yep. So it's the microinverter that's converting the DC to to the AC. But, yes, I mean, to to to your point, yeah. If if right. If if there isn't if there isn't sufficient load in the home, to absorb all of the generation capacity of the panels, then these systems will export some back to the grid.

[Rep. Christopher Howland (Member)]: And do the manufacturers put any switch in the cord? Here, I kind of like to I don't plug my lights in at home to turn them on. I use a switch. Do they do they put a a switch in the cord so you can plug it in and and make and break through a switch rather than through the, outlet? Because, we'll talk about the battery energized. How does the bat how does it de energize if it's connected to a battery that the inverter would get this charging voltage through the inverter? But once it's operating and you disconnect it, you've got your energy in the battery Will the solar panel continue to generate because it has the charging current, if you will, from the battery?

[Wesley Schrock (BrightSaver, nonprofit witness)]: Yeah. So right. So a couple couple of things. So, yeah, to my knowledge, none of the systems currently have the switch that you're talking about. All of the systems have software, have apps, and so you basically control the settings via your phone. In terms of what happens yeah. What happens when there is a power outage or you unplug it and the battery is charged? So the panels will not continue to charge that battery. So in terms of what sort of resilience, well, it depends on the system a bit. What sort of resilience do these systems offer? If the battery has an outlet, then you can the power goes out, you can plug a device, your phone, a medical device, whatever into the battery and use up all that, all the electricity in the battery. There are some newer systems, Enphase, for example, where they they basically it's almost like a like a Tesla Powerwall or like a rooftop solar. They have like these little mini transfer switches that isolate sort of the battery and the panel from the rest of the home. And so if there's a power outage, the, the solar panels will continue to charge that battery. Am I answering your question?

[Rep. Christopher Howland (Member)]: You think so.

[Wesley Schrock (BrightSaver, nonprofit witness)]: Okay.

[Rep. Christopher Howland (Member)]: And the one thing I see in your pictures, and we had quite a windstorm last night Mhmm. Here. And we didn't get advice to bring in our lawn furniture yet, but do you anchor do you do you anchor these things for the wind loads on the the balconies and or the lawns? Yes.

[Wesley Schrock (BrightSaver, nonprofit witness)]: Yes. Exactly. So so the UL so let's talk about the the, I think, the the balcony situation. So the UL the UL guidance weighs in on that on sort of, like, the the requirements around the balcony mounts. But yes, like like, absolutely, the systems need to be mounted and installed in a way that can withstand, you know, wind storms, snow, you know, whatever the conditions in the place where they are installed. And so basically, yeah, like, not just sort of the you so what's interesting about this UL standard is that, yeah, it weighs in on not just like the the the manufacturer of the plug in system itself, but UL is weighing in on how it needs to be installed. That installation includes, like, do any changes need to be made to the home's wiring, and how is it mounted?

[Rep. Christopher Howland (Member)]: Thank

[Wesley Schrock (BrightSaver, nonprofit witness)]: you. So that that leads to the question around, you know, this, like, self install versus professional installation. So and what Virginia did about this. So UL 3,700 requires professional installation. It does not allow for self install. There are a couple of things that UL 3,700 does. It it it requires professional. It requires a proprietary plug and a proprietary receptacle. And it requires a bidirectional GFCI. It requires for to establish over current protection. It requires either that the system is installed on a dedicated circuit or as I was talking about before on a branch circuit. And it requires like one of three different things to be done to that branch circuit so that you don't get breaker masking. And the idea, as you all will, I assume, tell you on Thursday, the idea behind the professional installation and the unique or the proprietary plug and receptacle is that it prevents so the electrician comes to your home, they get everything set up on outlet you know, with the GFCI and overcurrent protection. And then because it's a proprietary plug, you can't unplug it and then just go plug it in somewhere else. And you can't string a bunch of them together. But the implications of that are, okay, maybe from a safety perspective, that makes it very, very, very safe. But it adds quite a bit of friction. It means that I have to like what makes what what would result in mass adoption of these is you go to the store, you bring it home, you plug it in. Right? But now I I go to I have to order it and I have to get an electrician. An electrician has to come out to my house. I have to pay him to he or she to do that. And, you know, it adds a lot of friction and cost to the process or to getting to do getting for plug in solar. So what Virginia did is they basically did a carve out or exemption. So for systems three ninety one watts and below, the the UL requirements that basically, like, any UL requirement that requires changes to the wiring's premise is doesn't apply. And so it it basically the idea is to preserve plug and play self install for three ninety one and below. Now we do expect that the UL 3,700 will evolve. Right? So this is UL 3,700 right now is an outline of investigation. It was published by UL. It will eventually become a standard after input from it'll become a consensus standard after input from stakeholders, manufacturers, whomever else. In our expectation, you can see what UL says on Thursday. Our expectation is that it will be more conducive or more that they will allow more self install as the technology improves, as the technology is proven. But this first iteration is quite conservative.

[Rep. Kathleen James (Chair)]: I have a question about that, and I know I can ask, know, we'll ask you all this, but if we peg our legislation to UL 3,700, then will our legislation simply stay nimble as UL 3,700 gets updated? Or do we have to keep going back and then peg it to UL 700.1? UL 3,700.2.

[Wesley Schrock (BrightSaver, nonprofit witness)]: Yeah. Exactly. So yeah. So generally, like, once it's been assigned u l 3,700, it will stay that even as it evolves from an 11 investigation to to a full standard. However, you know, there are other bodies that create standards that might be just as good. I what what's, I e e e? What does that stand for? But the so it it you know, it could be that, there is a risk in pegging to a very specific number, and the risk is what is exactly what you explained. Like, will that limit us and will that mean we have to go back and change and change it? So what what some states have have done is made the language flexible enough so that they're, you know, they're referencing like, okay. UL 37 is what we have today. But so the system needs to be certified UO 3,700 or a successor standard or an equivalent standard or sort of using like a to a standard such as UO 3,700 or equivalent or successor, making a language such that you don't have to do exactly what you just described.

[Rep. Kathleen James (Chair)]: K.

[Wesley Schrock (BrightSaver, nonprofit witness)]: Yeah. So I think that was the yeah. That that that pretty much, wraps up sort of, you know, the differences between, the Virginia bill and and your in the in the current Vermont bill, the main one being this 391 watt exemption to preserve self install or to allow for immediate self install, not waiting on UL to get there. And then, of course, the utility notification and the solar and and and and and addressing solar rights or tenants' rights.

[Rep. Kathleen James (Chair)]: Yeah.

[Julie Walsh (Committee staff/assistant)]: So, how is a an apartment dweller gonna find a dedicated circuit in their in their unit? You said you're saying these should be on a dedicated?

[Wesley Schrock (BrightSaver, nonprofit witness)]: Well, so so that's so mhmm. So they, they either need a couple of things. Yes. So the idea so they either need to be on a, a dedicated circuit or a branch circuit with proper overcurrent protection. So basically, so the idea behind three ninety one, that that three ninety one threshold is that that is small enough that it doesn't really matter where you're plugging it in. You can plug it into a dedicated circuit. You can plug it into a branch circuit like it will be safe. You're not going to have breaker masking or breaker masking that matters. Now if you're going above that, then yes, then you need to take the precautions like, okay, I need to plug this into a dedicated circuit or I need a branch circuit with overcurrent protection. So how does anyone know that? Whether you are a renter or a homeowner, I certainly prior to beginning working with BrightSphere, I didn't know what a dedicated circuit was. So if you're looking at like, if a 1,200, if you're buying a 1,200 watt system and the manufacturer's guidelines are install this on a dedicated circuit, then yeah. I mean, there are, you know, there are ways, you know, obviously, you can call electrician or you can, you know, you yourself can play and can try to figure it out. But yeah.

[Rep. Kathleen James (Chair)]: Curious about how widely available the units are in The United States right now. Like, who's selling them? Where can I go buy one?

[Wesley Schrock (BrightSaver, nonprofit witness)]: Yep. Yeah. So, I mentioned a couple of sellers. So EcoFlow, will only ship their system to Utah. AP Systems is actually selling a microinverter nationally. And then Craftstorm was mentioned. They're a firm in Texas that will ship nationally. The thing about their systems is they their systems are a little different in that they don't back feed. They're zero export systems. And then but that's your export. But to do that, it requires going into the breaker panel and installing some some sensors, having electrician install some sensors on the breaker panel. So those those are the the main the main three. If you go on Amazon, I think there's a there's a company on there called like plugged in solar or something that's selling their product from Amazon. I'm sure you could get that shipped to your house. But, yeah, some of the some of the major players like Anchor are not yet selling selling in The US. Enphase Enphase is not yet. Enphase is doing, you know, they do plenty of rooftop solar products here in The US, but they haven't begun selling their balcony products in The US yet.

[Rep. Kathleen James (Chair)]: So right now it's mostly if you want one, you go online and find these find these manufacturers and you have it shipped

[Rep. R. Scott Campbell (Vice Chair)]: to you.

[Wesley Schrock (BrightSaver, nonprofit witness)]: Yes. Exactly. So yes. Right now it's like it's all shipped. You can't go to any like Home Depot. No. None of those none of the big retailers are selling them. And I don't think, I think we're a ways off. I don't think they would even consider it until legislation was passed and the safety issues were fully resolved.

[Rep. Kathleen James (Chair)]: Right.

[Wesley Schrock (BrightSaver, nonprofit witness)]: I think a little ways from the the big box people carrying it.

[Rep. Kathleen James (Chair)]: Super. Yeah.

[Julie Walsh (Committee staff/assistant)]: I was trying to find the letter from was it the village of Innisburg that sent a letter on plug in solar that you had sent for us for some

[Rep. Kathleen James (Chair)]: I don't know. I'll track it down. Okay.

[Julie Walsh (Committee staff/assistant)]: Because I I can't seem

[Rep. Kathleen James (Chair)]: to find it. Okay. Sorry about that.

[Julie Walsh (Committee staff/assistant)]: That's alright. I just maybe about. They had some questions about it.

[Rep. Kathleen James (Chair)]: K.

[Julie Walsh (Committee staff/assistant)]: And wanted to see if it was something he could answer on.

[Rep. Kathleen James (Chair)]: Okay. Shoot. Sorry about that. I don't know.

[Julie Walsh (Committee staff/assistant)]: But maybe I didn't see anything.

[Rep. Kathleen James (Chair)]: Alright. Any more questions for Wesley? Alright. Wesley, thank you so much for joining us and after the written testimony. I always really appreciate that.

[Wesley Schrock (BrightSaver, nonprofit witness)]: My pleasure. Thanks. Thanks for your time this afternoon.

[Rep. Kathleen James (Chair)]: Yep. We'll get it all posted on our website. I'm not seeing a whole lot posted up there right now, so we gotta get our website up to date.

[Rep. R. Scott Campbell (Vice Chair)]: Okay.

[Rep. Kathleen James (Chair)]: Alright. Thanks.

[Wesley Schrock (BrightSaver, nonprofit witness)]: You

[Rep. Kathleen James (Chair)]: so