Vermont Legislature SmartTranscripts:

[Speaker 0]: We're live.

[Rep. Kathleen James (Chair)]: We we are live. And now we are live. We're live. Alright. Welcome everybody to House Energy and Digital Infrastructure. It's Thursday, March 19, and we are continuing to explore s two zero two and act relating to portable energy solar devices. So we'll go around the room and introduce ourselves, and then we'll turn it over to you to introduce yourself for the record. My name is rep Kathleen James, and I am from the Bennington 4 District.

[Rep. R. Scott Campbell (Vice Chair)]: I do apologize. Not that an opportunity. I'm Scott Campbell from Saint John's branch.

[Ken Boyce, Vice President of Engineering, UL Solutions]: Richard Bailey, Lamoille 2. Michael Caledonia two.

[Rep. Christopher Howland (Member)]: Christopher Howland, Rutland Park. Dara Torre, Washington two. Bram Kleppner, Kleppner, Tidman Chittenden thirteen, Burlington.

[Speaker 0]: Laura

[Rep. Laura Sibilia (Ranking Member)]: Sibilia, Sibilia, Windham Windham two. Two.

[Rep. Dara Torre (Clerk)]: Great. Great. And And joining joining us in the room? Gabriel Gabriel Molina, Molina, Dow Dara Brown Torre, Lamarty. Washington Super.

[Rep. Kathleen James (Chair)]: For the record, we have invited the International Brotherhood of Electrical Workers, Local three hundred, to join us today, so over to you.

[Speaker 0]: Thank you very much. It's not always best to sound like an attorney. It's always best to be yourself.

[Rep. R. Scott Campbell (Vice Chair)]: Correct. Speaking of an attorney.

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

[Speaker 0]: thank you for inviting me. Again, my name's with the IBEW, the International Brotherhood of Electrical Workers, Jeffrey Willmatt. I've been the business manager of the IBEW since 2008. We represent approximately just over a thousand union members, of which 700 are either work for the utility, the electrical utilities, or are inside wiremen. So we represent the utility workers and employees or members of the inside Wireman trade. So we represent about 200 licensed electricians and apprentices in and around Vermont. So that's partly who we represent other than municipalities, highway departments, police departments, Benningeris, so on and so forth. But I was invited here today to talk about S202. This is a brief summary of some of my talking points regarding what you either already know or don't know, but a couple of my goals today are to give you my perspective based on who I work with. Again, we work with the utilities, represent the utility workers and the inside wires in and around the lawn. Was approached on this matter by the utilities saying, Hey, have you seen this bill? I said, No, I have not. Would you testify on behalf of this bill? I'm like, Yeah, it's always the utilities coming in, trying to accommodate their needs, and then they typically ask me or I get involved when it comes to the safety aspect, but I'm not just involved with the safety aspect. I've been working in this trade for twenty eight years. Am a licensed master electrician in Vermont. I have gone through the apprenticeship amongst other pathways. I come from a wealth of knowledge, I think. I worked with the utilities for the past twenty years, all of them, except for a couple. But we used to represent the Mahmoud Yankee. So I've seen the transition from what was going on twenty eight years ago when I started to where it is today. And just as an example, as a licensed electrician, this is what you're supposed to know. And this gets bigger every year. And the addition of this item is not really covered in here. Part of what my goal is to kind of show you, visually show you the requirements of a licensed electrician and what utility workers are required to know to manage those safely. And I see you have the UL Solutions white paper, which is what I utilize to create some of my talking points. We dive into this. This is Bill two zero two. It talks about 50 solar devices, which is a plug and play photovoltaic device that has been created to give residents the ability to possibly offset the cost of their electrical bill and possibly make them feel like they're contributing to the health and welfare of our land. The concerns that arise with devices like this are numerous because even though it's supposed to work properly, it doesn't always work properly even if it's UL approved. The highest bar set in our industry is UL standards. If it doesn't have a UL stamp on it, an electrician or any trades person or any utility will look at it and say, I'm not touching this device. If it's got a UL approved stamp on it and I don't like the device, it's still UL approved and I'm going to install it. I'm not fond of these devices because they're counterintuitive to how my brain was wired with regards to the power goes off and people used to plug in their generators and back feed into their houses and back feed onto the grid. And that's kind of what this does. So I'm still wired, if you will, to say this doesn't sound right. But it can be right if complies with UL listings. And I give kind of examples of the concerns that we have. Did talk to Dennis Blair, who's the electrical inspector for the state of Vermont. I did talk to most of the utilities with regards to their concerns. So there are ways to make these devices safe as long as they're approved by UL listings. So I have two requests. One, that we meet the needs of the utility companies that provide us with the safe, reliable electricity that we get in need every day. And I know they're coming here in droves to present their cases. I've seen their modifications to the bill. As long as they're comfortable with reducing their liability, Liability meaning they're not going to get The electrical workers are safe. The products are UL listed. Meaning I plug it in, it's not going to back feed onto the grid, it's not going to back feed into the house. The employees will be safeguarded, hopefully. And the cost that the utility would possibly have to absorb through net metering. I know there's an article in here that secures their net metering process so that they're not being charged for that. Right. That's a significant item for them. Their liability with regards to the functionability of the equipment, again, if it's UL listed, you can't argue with it. The other item has to do with There are other items that they've talked about that aren't in there that I know they're gonna present to you folks for your consideration. So as long as those items are met, they're okay with it. They just don't want to be liable for things that they have no control over if it's a resident owned device. The And concept of a resident owned device. You have your overcurrent, the fire hazards that are part of these mechanisms. Primary concerns relate to overcurrent protection of the household circuit. So typically, your power comes into your electrical panel and goes out to your appliances. Now you have an appliance being sending electricity back to your panel door. That's not what these items were created for. That's where I'm wired the way I am in accordance with this. And again, if you will, appliances or these devices are approved by UL solutions, which I don't believe any are at this point, they may have elements that could make them eligible for you all listening, but there are none to my knowledge. Even the way they're currently manufactured doesn't meet the standard set on this bug. Like the plug and play port adapters, how they plug into your house are not necessarily safe. The wiring My biggest concern when I hear about this is new construction can be easily modified to accommodate this and the white paper. We have a lot of old housing infrastructure here. How do we accommodate those facilities with these new applications? Is it kind of like, hey, here's the new device. How do we make this square peg fit into this round hole with the old stuff that we have out there? Again, this only gets bigger and we do a pretty good job with UL Listings to try to accommodate all these new products that come out, but we can't capture it all and we can't do it all. The first thing us guys tend to get busted on, we get a set of instructions and we throw them away and we try to make it work. This has a set of instructions that currently don't follow these rules. I'm on board with those to the extent that they comply with UL listings and they comply with this. And as long as the utilities are comfortable with what their requests are and that they're being met. There's always concern with touch safety and shock. Again, that has to do with how these things are developed and they currently don't line up with the manufacturing needs to accommodate the rules that we have set. There's only current production within the system. Have old residential housing. I mean, we live in a state where you don't need to be a licensed electrician to wire a house. That alone is frustrating to me and scary to me. Now we're asking a simple individual, simple, who doesn't know anything about this stuff, who has an older model house to take care of it and do it properly. And they don't understand the lick of what's going on. That frustrates me and has frustrated me ever. I don't understand it. I just live with it. But again, if it's UL listed, hey, I got no complaint. But if something breaks inside your house, that's your fault. And that's not how I wanna view things. New housing units, new residential facilities where you could easily accommodate these requests by the UL Solutions. Easily accommodate. I go to my house and simply plug in something and make it work. I'm an electrician. I can do it. It's easy. Someone like yourself is gonna take you about six months to get an electrician to go and do it. Right. It's hard and it's frustrating.

[Rep. Kathleen James (Chair)]: I think Brett Campbell has a question.

[Rep. R. Scott Campbell (Vice Chair)]: I have a

[Rep. Christopher Howland (Member)]: couple questions. Yes, sir. I don't wanna interrupt your flutter, but

[Rep. R. Scott Campbell (Vice Chair)]: you mentioned a few minutes ago about generators and backfeeding backfeeding to the grid. And that certainly hit me as, boy, that must be a hazard, which when the power is out and and people fire up gas generators, how do how do they avoid being a danger to blind workers?

[Speaker 0]: By using like solar commercial or residential solar devices that are either roof mounted or ground mounted have these safety mechanisms in place. They're already certified. A generator can be UL listed if it's hooked up properly with a transfer switch, done correctly by an electrician. So there are safety mechanisms already involved that are inherently made into the system. It's the one off where a resident just wants to do what they wanna do, how they wanna do it, that ends up being the problem.

[Rep. R. Scott Campbell (Vice Chair)]: Yeah. So a a generator

[Speaker 0]: Especially done, it works. Unprofessionally done, it doesn't work. Yeah.

[Rep. R. Scott Campbell (Vice Chair)]: So these generators have a device in them like like these portable solar, I guess inverters for rooftop solar, that detect whether there's power coming from the grid, and if there's not, they shut off.

[Speaker 0]: But they also go to a separate module, if you will, that goes to the panel. These devices, these porch, what are they called, patio solar or whatever? Portable solar, yeah. They go directly back to the panel. So there's this concept of, and again, it's so detailed in that white paper, I really appreciate it, that they overload the wiring going to the panel. So there's no fail safe system there other than if your house is 50 years old and you have this really antiquated wiring system, it may not be able to manage it like you do now. Even the older model GFCIs, which are supposed to be plugged into, may not be able to manage the system like the newer GFCIs or the ArcBall system, current protection devices. So it doesn't matter how safe that is. If they're plugging it in inappropriately. Yeah.

[Rep. R. Scott Campbell (Vice Chair)]: Well, that leads me to another question, is how how you feel about not you think being plugged into what is not a dedicated circuit. In other words, a new a brand circuit where there's other ones.

[Speaker 0]: You have greater liability if you plug it into something that's not dedicated. Because you as an electrician, you don't even say, put an outlet over there. Mhmm. They'll think, well, that's just put an outlet over there. It could take me two days to put an outlet over there because I don't know where your house has been wired or what's on that circuit. So you could have six items on that circuit or no items on that circuit. To have a dedicated circuit, I think it's very I think it can be easily accomplished if done by a professional. And then you are absolutely sure there's nothing on it that would overload that circuit. Like, your smoke sensors in new housing is supposed to be on a dedicated circuit. Mhmm. Your older houses don't have that. So now they're modifying older houses to accommodate the new requirements. It's not exact. You know, the stars are not aligned there, but it works for now. Moving forward, given the, I think, the interest in these devices, people want them. I want the new iPhone. Hey. I want the new iPhone. I don't want the new iPhone. People want new gadgets to make them feel like they're accomplishing something. This allows them that benefit. It may give them a sense that they're reducing their energy costs, but at what cost?

[Rep. R. Scott Campbell (Vice Chair)]: So do you do you have a, I guess, a a percentage preference for a dedicated circuit? Would you say, you're a 100% in favor of a dedicated circuit? Or

[Speaker 0]: If it's a dedicated circuit, I would have no argument.

[Rep. Bram Kleppner (Member)]: Yeah.

[Speaker 0]: And that would satisfy my needs because, again, UL List Solutions is requesting that. There are other modifications to just the plug in part.

[Rep. Bram Kleppner (Member)]: Yeah.

[Speaker 0]: The male adapter and the female adapter. They're not weather tight. It's just the vacuum cord plug that doesn't fit into a GFI on the outside of the house appropriately. They're not weather tight. There are other faults in that process, in that system. So if you have a generator that is created, built appropriately, there's typically a weather tight push lock kind of concept for that device. Whereas it's seasonal, it can handle whatever mother nature wants to give it. Whereas these things do not allow for that safety sensitivity. If it's a dedicated circuit, it means there's only one thing on it. It cannot get overloaded. As long as that inverter is in there, in the device, and you all approve, it should work accordingly to protect the people that are on the possible receiving end.

[Rep. R. Scott Campbell (Vice Chair)]: Check. Yeah. Thanks.

[Rep. Kathleen James (Chair)]: Yeah. Brooks Sibilia?

[Rep. Laura Sibilia (Ranking Member)]: So I apologize. I had to step out yesterday and kind of missed some of the testimony on this, but are you aware of any opposition to

[Rep. Christopher Howland (Member)]: the dedicated circuit? Do

[Speaker 0]: mind wearing them? Should I?

[Rep. Laura Sibilia (Ranking Member)]: I don't that's I will also ask my committee, but you you, if you're talking with folks.

[Rep. Bram Kleppner (Member)]: Yes. As

[Speaker 0]: an electrician, a dedicated go ahead.

[Rep. R. Scott Campbell (Vice Chair)]: Go ahead. Do my you mean opposition to a coronary dedicated Is that what you is that

[Rep. Laura Sibilia (Ranking Member)]: what talking who's likely to oppose excuse me. Who's likely to oppose that? And and are you aware of, any of the stakeholders that do oppose that?

[Speaker 0]: I am not aware of anybody opposed to it in my rational opinion. The dedicated circuit makes things easier to accommodate the needs of the individual trying to get one of these devices.

[Rep. Laura Sibilia (Ranking Member)]: Did you testify in the Senate?

[Rep. Kathleen James (Chair)]: I didn't. No. You didn't, did you? No. I think Senator Watson texted us after they passed the bill out and said you should hear from IBEW, so we put you on the list.

[Speaker 0]: Yeah. So They ran out

[Rep. Kathleen James (Chair)]: of time or I don't know what

[Speaker 0]: Again, it's similar to your again, new fire alarm smoke detectors in in houses are required to be on a dedicated circuit so they don't get tripped by other devices so that they're constantly on. That's why they're on a dedicated circuit. Dedicated circuit is exactly what it is. It's for that device and that device only.

[Rep. Laura Sibilia (Ranking Member)]: I

[Rep. Bram Kleppner (Member)]: would say I do have concerns about dedicated circuits in terms of the time and expense and hassle it adds to a consumer who wants to add solar to their balcony. As you said, it would take us six months to get someone in here. So I'll say this,

[Speaker 0]: and I've say this forever. Safety goes out the window when money comes into play.

[Rep. Bram Kleppner (Member)]: And I would say To put in

[Speaker 0]: a device, put in a dedicated circuit, depending on the house, depending on the residence, depending on the structure, is worth the price.

[Rep. Bram Kleppner (Member)]: Absolutely. I And time. I couldn't agree that we do not wanna kill anybody, either the electrical workers outside or inside the house or the family who lives in the house or the kids who are gonna play with the floods and whatever else not. And we don't wanna burn down any houses. And it feels like, personally, I'd like to apply some creativity and try to keep finding a solution that does not require the homeowner to spend six months and get an electrician and have their house rewired, but also keeps everyone safe.

[Rep. Kathleen James (Chair)]: I have a comment on that, but a question. You were asking yesterday about the and I I think we should see if Ellen can come and walk us through the Virginia and Utah bills. I know they're not her bills, but I assume she can translate the language for us. But Virginia had a a below a certain you were asking about this yesterday. Below a certain size, plug and play was okay.

[Rep. Bram Kleppner (Member)]: Yeah. Virginia law sort of allows for 391 watts and below to simply plug in. And I believe that's based on Rutland and I were talking about the fact that German standard is 800 watts for some of plug and play, and they're on two twenty. So you sort of take half of that and then discount it a little bit for what your actual, voltages at the outlet, and you arrive around three ninety one. Southern Virginia has done, and with a lower wattage limit like that, does that reduce I'm sensing it doesn't eliminate your concerns. But No. Because, again,

[Speaker 0]: I don't know what's on that circuit. Yeah. Nor do you. So it's it's your responsibility. It's their responsibility. It's your solution's responsibility to keep people safe. You folks create the rules. They create the guidance. They create the rules to keep residents safe from them you know, safe from themselves, safe from others. And we are supposed to implement these rules, those guidances, and what you're asking for. To just say I agree with it, you could view it as a safe bet, but I'm not comfortable with it. UL Solutions has the best solution. I would wholeheartedly support that. I have folks in my position elsewhere who would probably say, no, don't even allow it. But here, I am working with the utilities and you folks to understand that this is the next best thing that people want. So how do we make UL Solutions and this and UL align with what they're asking for? That's kind of where I fall is. These three parts can align and I would be overwhelmingly supportive.

[Rep. Kathleen James (Chair)]: I just wanted to say that I think we're on the same page because I am this is we're ahead of the market here, right? With this bill, like

[Speaker 0]: We're way ahead of

[Rep. Kathleen James (Chair)]: the market. And so I'm in making sure that any early adopters can use these safely if they want to and they can afford it. So, I'm actually less interested right now. I am far more interested in safety right now than in parsing out what choice a consumer might make about with their month. You know what I mean? If if somebody can wants one of these for whatever reason, if they can afford it, if they're not worried about the payback time, if it's gonna bring their energy bills down and they don't care that it's gonna take them ten years to pay back or whatever. So I'm not really interested in, and and I don't think it's our job actually to think too hard about what somebody can afford and whether they wanna buy one of these. I'm interested in making sure that as this market evolves, we've got safety considerations in place so that folks who wanna do it now can. And then over time, I think we're probably looking so we'll be ready. And then over time, I think we're probably looking at the future. I mean, ten years from now, I'd love to see these be cheap and safe and you can go pick one up at Home Depot and we are so not there yet. But one one technical question I did have, I don't know if you're the person to ask this or not. And we've we've talked about liability. We've talked about having the AG come in and weigh on this bill to talk about, like, consumer protection. Mhmm. So that people understand when they're buying these. This is how it works. This is what it may or may not deliver to you in terms of benefits. I'm curious about if we're requiring it to be compliant with UL 3,700, who's that on? In the because this must be this must be common for a wide range of appliances and things. So they have to have that UL stamp of approval. Is that on the manufacturer? They're not allowed to sell them into Vermont? Because I know you can do that. We do things like that all the time. Or is that on the consumer to know that they're not supposed to buy one that isn't? Or is it on the installer? Because that would be the ultimate not fair. Like, who Who's responsible for that compliance?

[Speaker 0]: It's the age old question of, again, it goes back to the generator. There are safeguards with how a professional constructs something. As long as the professional constructs it appropriately and the device meets UL listings, they're safe. It should be safe. But if a resident goes and buys one of these devices that's not UL approved, that doesn't meet the UL requirements, I don't know the answer to your question other than it's the resident's fault, not the professional that installed it. Right. Because they didn't. So again, it goes back to we're here to prevent things like that from happening, but at the end of the day, we can't prevent all of it from happening. Right. So safety, so my request, again, when money comes into place, safety goes out the window, that's my attempt and others' attempts to say, as long as we cover our own butts, we are safe. If a homeowner does what they want to do with their castle, that's their problem and their fault, and that's unfortunate.

[Rep. Kathleen James (Chair)]: Yeah. Bram, or and then

[Speaker 0]: So I think the the UL 3,700

[Rep. Bram Kleppner (Member)]: standard calls for a dedicated circuit and a unique receptacle and plug. Isn't that accurate? And it doesn't address the whole affordability question, but one thing I wonder is if the cost and hassle of installing that could stay with the property owner since it would be a permanent improvement rather than the renter.

[Rep. Kathleen James (Chair)]: Wouldn't she just pick pack it up and take it to Kimberly?

[Rep. Bram Kleppner (Member)]: Well, you take your panel that the wiring, the circuit, and the unique receptacle would stay so that apartment would forever be configured for the next tenant who wants to add a solar panel. You know, the the the the renter pays for the panel, the thing they buy, but the landlord pays for the circuit or the receptacle that stays with the house. That might slice the apple in a way that gets us safety and affordability.

[Speaker 0]: I would imagine the renter would have to approve somebody plugging in portable solar to their

[Rep. Bram Kleppner (Member)]: building. Right? The the Virginia law requires renters to notify their landlords if they are plugging in, but does not require permission from landlords who own more than four rental units. So if you're if have three or four apartments in your own house, then you can forbid them. But if you own five or more, then you can't prove it. You can't actually plug in the system. Like Sounds like an interesting problem. It is an interesting problem.

[Rep. Kathleen James (Chair)]: Yeah. Rick Southworth?

[Rep. Michael "Mike" Southworth (Member)]: So in your professional

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

[Rep. Michael "Mike" Southworth (Member)]: could you explain to us if it's not installed on a dedicated circuit, what it will actually do to the wiring? And is there more of a chance for overcurrent in that situation? And if there's overcurrent from time to time, does that degrade the wiring to a point where there's an issue that shows

[Rep. Bram Kleppner (Member)]: up over time, not immediately?

[Rep. Michael "Mike" Southworth (Member)]: Does it actually

[Speaker 0]: do? What it does is you're so if you have appliances plugged into a circuit, so your wire runs through the wall, you got appliances plugged in, you have current running through that wire, it heats up the wire. Now you're adding a solar array and you're sending current back through the system, so you're adding more heat to that wire, which degrades the wire over time. The newer the wire, the better. The older the wire, the more degraded it is already. It does overheat and it would eventually either trip the device, trip the panel or just burn up. We over time have created devices put in the panel or in the GFCIs or our fault receptors to monitor that amperage, that current, but they don't always work and it may not work in this scenario. They may still not trip the circuit, still overheat depending on where they're located in the wall or in in the in the stream of the the current, it may not trip the circuit. So, again, it it will degrade the wire if it reaches a certain point. It degrades it no matter what. The longer you use it, the older the wire. I'm getting older. I'm not as surprised as I used But to I still function. But yeah, again, UL Solutions does a really good job with explaining how if I have five amps coming this way and five amps coming this way, it's five amps more than I used to have. The wire's gonna degrade faster. Devices may not work. Old houses that we currently live in may not have the appropriate devices currently there, and they may not put in new devices. By adding a device, an appliance, like a portable solar that's not properly manufactured with the requirements that they're asking for. If you have shock hazard going from the device that's not UL listed, like with the device, the caps. It could trip the circuit, it could trip, it could hurt the electrician that may be working on the device that doesn't realize that something's coming in the house. So I don't know if I answered your question, but, yeah, it degrades that system twofold at least.

[Rep. Michael "Mike" Southworth (Member)]: So it won't necessarily trip the breaker in the panel if it's not an arc fault. Correct?

[Speaker 0]: It depends on if it's an arc fault on the on the end or in the panel. On the panel. Some places put an arc fault breaker in the panel that covers the whole circuit. Some places put arc fault devices in a single location that doesn't protect the downstream.

[Rep. Michael "Mike" Southworth (Member)]: It's like a in the panel and, you know, they trip every time power goes on and off.

[Speaker 0]: So Right. Some panels, some breakers will trip if you plug in a vacuum, because it senses something and it pops. It's like, okay, something's either wrong with the breaker. You could have faulty breakers. I've seen faulty breakers before. So it doesn't mean the equipment may be bad, but it may mean the the breaker's bad. So but if you have the equipment that is appropriately if you have the and some wire is not sized appropriately. It's not big enough to accommodate the needs. All of your traditional house is wired at 15 amps. Many houses are wired at 20 amps. We could possibly accommodate for some of that overload or added amperage current, but most houses aren't. My mother's house is not built the same as my house, which is 15 years old.

[Rep. R. Scott Campbell (Vice Chair)]: Can I follow-up on Mike's question? I'm thinking about a situation where you have, I don't know, a toaster or a hot lead. Something something draws a lot on a circuit, and then you add one these plug in panels to the same circuit. What happens physically with the electrons that are feeding that hot plate or something or whatever that's drawing a lot of current at a moment, and then the PV panel is also feeding electrons back into the same circuit. What physically happens there? Current goes from the from the from the grid, from the panel to the load.

[Speaker 0]: And then it's

[Rep. R. Scott Campbell (Vice Chair)]: also from the PV panel. How do those things interact?

[Speaker 0]: Kind of like what we had just talked about. You could view it as energy, like it's heat. So electricity current running to the outlet where your hot plate is plugged in will will heat up Yeah. Because you have current being pulled through it. Yeah. And then if you add another appliance, it gets even warmer because you're adding more current to it. If you add what you're asking for, it even you're adding more

[Rep. R. Scott Campbell (Vice Chair)]: heat It's to going the other way.

[Speaker 0]: It's going the other way. It it runs in a circle. So I mean, it it it it handles it to the point, but it heats it up. So but the other thing

[Rep. R. Scott Campbell (Vice Chair)]: is Does it go because I'm sorry. I I'm just trying nobody here is, like, using repellent. But does does the does the current go from the from the PV panel and then feed the hot plate, or does it yes? Or does it go does it does it go somewhere else? Does it is there any

[Speaker 0]: It comes through the circuit. Yeah. So it has to go to the panel. It's a circular It goes to the panel and comes out the breaker back to the hot plate. It's not going directly to the hot plate, so to speak. Okay. That's the other thing is sometimes your hot plate cools down, and then it heats up. So your Yeah. Your wires are going from cooler to hotter. Same with your PV panel. If it's if it's getting more sunshine, it's sending more heat. If it's got less sunshine, it's sending less heat. So your wiring's fluctuating with the heat that's going through it based on how much sun or based on how much your hot plate is operating

[Rep. R. Scott Campbell (Vice Chair)]: or whatever other device. What I'm taking away from this is also what you're saying is the current coming from the PV panel is going back to the panel before it goes out in out to any level. I would think so. I don't know. Depends on where it is.

[Speaker 0]: Eventually, it goes into the panel and possibly back onto the grid. Some of these devices, to this gentleman's point, they say if it's below 400 watts, that's typically what a house may use. My house uses much more than 400 watts, but the hope is that you can scale it down so much that it doesn't go back onto the grid, And then at that point, what what's the use of it anyways? But

[Rep. R. Scott Campbell (Vice Chair)]: And so does it go back? I'm I'm I'm picturing a wire. Sorry. Belabor this, but you're the only one we're gonna have in here who might be able to answer this. Because I I picture a wire that goes to a few loads and then maybe ends at an outdoor outlet. So there's one that's the circuit. So there's one wire. I don't know what's called it. It's all three wires. It's got Yeah. Hot, neutral, and ground, and it goes out to the to the it goes by by a load and then out to the out to the PV panel. Mhmm. Does the does the the the current from the PV panel go back on the neutral back to the back to the to the service panel? Is that how it works? Or or

[Speaker 0]: You know, I'm I'm not an expert on that. I just know that your electrons are going in a circle. It could be feeding back to the panel and coming back on, or it could be feeding your device specifically.

[Rep. Kathleen James (Chair)]: R. Howland, I sense

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

[Rep. Kathleen James (Chair)]: I see your mind quarreling.

[Rep. Christopher Howland (Member)]: Alright. I got three or four questions. We're gonna start with the current.

[Speaker 0]: So

[Rep. Christopher Howland (Member)]: the current's gonna oscillate between power and the Loop current. Alright. So what call alternating current. Alternating current. Yeah. Alright. The sinusoidal current. Yeah. So what the question raised here, you are now adding, and this just came up with this conversation today, I hadn't thought about this before, but you're now adding additional neutral current. So the breaker in the panel is only connected to the power side. So it's only going measure power current. The danger here now is the same size 12 gauge wire that is your neutral is now going to have the additional amperage of your hot plate load plus the neutral current from your EV generator. We'll take up with that with fire safety people and Okay. Okay. So let me say one more caveat. My electrical engineering education is a course for nonelectrical engineers. I'm a structural engineer who went to work for an electric utility. Alright? And then got my thirty years of exposure. What what I had concerns about is this. I think they call it a 15 dash five, National Electric Manufacturers. Plug. That's your plug. And that's the male plug that comes off this PV generator. So as you're making and breaking, you're disconnecting. And there may be a capacitor back in the inverter that establishes the voltage or whatever. The manufacturer says that it remains hot for a they use a couple of seconds. Right. Two seconds. Two seconds is, I think, a 120 cycles is a long time electrically. And and so my thought on this process is to plug it in and then make and break with a switch, a breaker, And your exposure, there's a field gym at the high school, for school, had breakers that were rated to be used to switches, but your breaker in your main panel is not supposed to be an everyday light switch. And so those are the my concern is that when that's being disconnected, whether it's an adult or a child, is that that plug remains hot for some period of time as a potential. Secondly is that you talked about what's called NEMA four for weather tight enclosure, but the so that might be the enclosure around the outlet, but the person initially installing this, it may be on a wet carpet on the deck or a a water exposure. Correct. And the the idea that these things are portable is not really such because, as we spoke earlier, they have to be

[Rep. Bram Kleppner (Member)]: secured from blown away in a windstorm.

[Rep. Christopher Howland (Member)]: So they're not really they're not something like putting out your heat outside furniture Yeah. On a on a good day. Don't go people don't put them out on sunny days and take them in on rainy days. So those are some of my concerns and particularly the log that remains on top. You you address this with the with the twist log type. The weather resistance. And

[Speaker 0]: they're they're $30, $40.

[Rep. Laura Sibilia (Ranking Member)]: Right.

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

[Rep. Christopher Howland (Member)]: if I answered the the the.

[Rep. Kathleen James (Chair)]: Rictor?

[Rep. Dara Torre (Clerk)]: I just wonder. I don't know anything about Shannon, electric myself. But Victoria. I should. I have heard about You know something. These fan panels, these smart panels. Do they would that make an appliance like this super?

[Speaker 0]: They're experimenting with smart panels. Mean, that's not even I don't even know much about smart panels. I know somebody who may have a smart panel, but I think the smart panels have more to do with an app so that you can manipulate your power usage. Opposed to So I think some utilities are trying to get around some of these requirements with smart panels, but even the inspectors will tell you, no, that's not how you should interpret the language with regards to how a smart panel is supposed to be utilized. They allow you to manage your output of your appliances from afar. Like, hey, I wanna turn up the heat. Hey, I wanna turn off my whatever. That's currently what they're doing. They're not manipulating or safeguarding anything downstream that I know of.

[Rep. Laura Sibilia (Ranking Member)]: Sibilia? Just quick question here back to the dedicated circuit. I have no concept of what installing something like that might cost.

[Speaker 0]: Would, again, depending, if I use my house as an example, a couple $100.

[Rep. Kathleen James (Chair)]: I have a question. I don't know what your schedule is today, UL is coming on with us at ten. We'd love to have you stay if you want to, but you

[Speaker 0]: Yeah. Saw they were on the list.

[Rep. Dara Torre (Clerk)]: Yeah. Go ahead.

[Rep. Kathleen James (Chair)]: You're invited. You're included. I I wanna get a I I mentioned earlier how important I think safety is, and I just wanna reiterate that. But and I also wanna get some perspective on what level of risk and danger we're, like, actually talking about here. I mean, I feel like I've got a I'm not belittling this at all, but I feel like I've got a toaster I should throw away. Like, what what are these what are we actually talking about here? Like, what are the odds that this is gonna back feed and shock somebody if if we're requiring it to meet UL 3,700 safety standards? How how is this any different or more dangerous than generators that anybody can go out and buy at Home Depot or anything else. I wanna make sure we're also keeping the conversation in accurate perspective.

[Speaker 0]: I'll go back to, again, in my trade, something that's UL approved. People are very comfortable with installing the device. If it's not UL approved, I'm gonna have Michael install it rather than me because I don't approve of it. Right. And therefore, it's not my liability.

[Rep. Kathleen James (Chair)]: Right. But that would be a violation of state law.

[Speaker 0]: That's not my problem. That's dead.

[Rep. Michael "Mike" Southworth (Member)]: You ever seen my wiring skins?

[Rep. Kathleen James (Chair)]: Well, do you know what I mean? Well,

[Speaker 0]: that's the comfort level of somebody in my position as a trades person as well with the level of dedication and oversight that UL puts on their products as opposed to something that's not UL approved where it's really up to the resident or the purchaser to accept all liability.

[Rep. Kathleen James (Chair)]: And I think that's what I'm getting at. As long as we create a state law that we feel comfortable would make these safe to use, then they're infinite rabbit holes. We could I I many bills. On any bill, really, we could fall into about what if somebody chooses not to follow the law.

[Speaker 0]: Something we struggle with all the time.

[Rep. Kathleen James (Chair)]: Yeah, I'm sure.

[Speaker 0]: Again, this accommodates UL solutions. We try to keep these in alignment. Yep. So whatever I'm being taught or whatever your future electricians or even plumbers are being taught falls in line with UL solutions. Right. Because we try to keep those in alignment because that's our comfort level. Okay. Brett Kleppner.

[Rep. Bram Kleppner (Member)]: For what it's worth, the AI bot did a quick search in I love AI. According to it, there are no reported injuries or fires from portable PV in Germany. Again, I cited the source first. But

[Rep. Laura Sibilia (Ranking Member)]: Yep. To

[Rep. Bram Kleppner (Member)]: your question of, like, what's the level of risk?

[Rep. Laura Sibilia (Ranking Member)]: Yeah.

[Rep. Bram Kleppner (Member)]: It's one tiny data point.

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

[Ken Boyce, Vice President of Engineering, UL Solutions]: That's So

[Rep. Michael "Mike" Southworth (Member)]: I would just counter that with their electrical system is totally different than ours. Their wiring is totally different than ours, so I don't think we can compare that to what we're trying to do here. I just wanna be cautious about that.

[Rep. Bram Kleppner (Member)]: Yeah. Very very well taken.

[Speaker 0]: Yeah. If and it even makes to your point, it spells that out in The US language. It says European standards are different than our If you look at the pictures of the breakers in there, the European breakers, they're not American standard breakers. Everything in there has to do with what they do, how they do it, and sometimes they're even better than we are. Hate to say it, but they do things a little bit different. Even our code, our code is a couple years behind. So we're constantly catching up with these new pieces of equipment that everybody wants and we don't even have it written in here to accommodate it yet. So again, that's a pretty high standard for people in this industry to follow and they're comfortable with that standard.

[Rep. Kathleen James (Chair)]: Well, we have, let's see, we have UL next. We're hearing from GMP tomorrow. I don't know if she can do this, but I've already written to our attorney to see if she can help help us translate the Utah and Virginia bills in particular. And then I can't remember who else we're hearing from. Oh, I missed the c yesterday. Fire safety.

[Speaker 0]: Can I make one more comment regarding the infrastructure, the electrical grid? Every time somebody plugs in a device to reduce the cost of their electricity, reduces forgive me, but it reduces the income of the utility. But all these wires and transformers and substations and folks who manage these systems that we need and are constantly being upgraded because of all these new systems that are coming on board, that still has to be paid for. Every bit of energy that is now at no cost or low cost that the utilities are able to pull in there's revenue sources that they lose. And I'm not advocating that they need more money. I'm just saying our electrical grid infrastructure needs to be maintained to manage all of these things. And the money that they don't get from a plug in solar gets pushed back out to the customers anyways. Somebody is absorbing what you're saving. Somebody is absorbing what you're saving because they're not getting the revenue. And what everybody wants is low cost energy. Reduces load, right?

[Rep. Kathleen James (Chair)]: I mean, are also reducing the load. When we reduce Agree. Load by making you know, by reducing use and making things more efficient, we all save money as well. So I I'm not quite following you on that one. How

[Rep. Bram Kleppner (Member)]: It's Yeah. 50. Right? We we avoid having to upgrade the transmission systems because we've got more local load. So we save costs there, but the utility loses, then it gets

[Speaker 0]: You don't avoid upgrading anything. I understand what you're saying, but I would disagree. So my point is everybody wants low cost energy. How do we create low cost energy for everybody as opposed to just allowing this to go into the market without being unchecked?

[Rep. Laura Sibilia (Ranking Member)]: Okay. Okay.

[Speaker 0]: Carbon neutral, safe, reliable energy. Thank

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

[Rep. Kathleen James (Chair)]: Alright. We are oh, yeah. Alright, Bailey.

[Rep. Richard Bailey (Member)]: So before any of these even come on, you as the worker, you're looking and I know you're not installing, but you wanna make sure that the panel has a UL sticker on it and the the plug is just, whatever it takes to plug it into the wall, the and the inverter part have a UL.

[Speaker 0]: I mean, the panels are used to get well. Square d or Murray or whatever. You can buy those at Home Depot or whatever.

[Rep. Christopher Morrow (Member)]: I mean, that's No. But I'm talking about the new the panel. It's the new ones are hanging on the balcony. No. No. No. Solar panel. Those have never none of

[Rep. Richard Bailey (Member)]: these have gone through a UL testing that we don't.

[Speaker 0]: I mean, UL just came out with a white paper, to my knowledge, none of them have been approved.

[Rep. Kathleen James (Chair)]: Here we are. UL. That was a perfect segue.

[Ken Boyce, Vice President of Engineering, UL Solutions]: There you go.

[Rep. Kathleen James (Chair)]: I don't think that we should take a break. Is everybody okay with just moving on? That's Sibilia. Yes. Fill this with hot water for me as as long as you're Yeah. Sure. There's here. Just hot water to the top. Thanks. Alright. Great. Thank you so much for being here, and hope hope feel free to stay.

[Rep. Laura Sibilia (Ranking Member)]: Have fun day. We have We're already waiting.

[Speaker 0]: Oh, great. So Call all these gentlemen

[Rep. Christopher Howland (Member)]: You've been down for some time.

[Rep. Laura Sibilia (Ranking Member)]: Thank you.

[Speaker 0]: Thank you.

[Rep. R. Scott Campbell (Vice Chair)]: And but it's and that we all separate.

[Rep. Bram Kleppner (Member)]: Yeah. Yeah.

[Speaker 0]: We're working on that.

[Rep. Bram Kleppner (Member)]: Apologies are just like that. They're just. But it's kinda There

[Speaker 0]: was a reason for this to be

[Rep. Kathleen James (Chair)]: Oh, great.

[Speaker 0]: A fair reason, but now we're reviewing

[Rep. Kathleen James (Chair)]: Hi. Can you guys hear us? Yes.

[Ken Boyce, Vice President of Engineering, UL Solutions]: Can. Can you hear us?

[Rep. Kathleen James (Chair)]: Yes. We can. We're live on YouTube. Just there's your heads up. Our livestream is up and running. So thanks so much for joining us. You've not met everybody, so we'll quickly go around the room and introduce ourselves. I'm representative Kathleen James from Manchester.

[Rep. R. Scott Campbell (Vice Chair)]: Scott Campbell from Saint Johnsbury. Richard Bailey from Lamoille too.

[Rep. Christopher Howland (Member)]: Michael Southworth, Caledonia too. Christopher Howland, Rutland for.

[Rep. Dara Torre (Clerk)]: Dara Torre, Washington too.

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

[Rep. Kathleen James (Chair)]: And we have representative Sibilia will be back in a minute and representative Morrow is joining us on Zoom as well with you today. And then we have some folks in the room. If you could introduce yourselves, please.

[Rep. Dara Torre (Clerk)]: Gabrielle Lamoille, Downtown Glenmark.

[Speaker 0]: Jeffrey Willbat, International Brotherhood of Electrical Workers.

[Rep. Kathleen James (Chair)]: Serena Knight, VNRC. Great. Alrighty. So thank you for joining us. And we are interested in your testimony and also interested in your white paper. We did have a request from a committee member to do a high level walkthrough of the white paper. So if you're not prepared to do that today, that is totally fine and we can get you back in. Okay.

[Ken Boyce, Vice President of Engineering, UL Solutions]: First, let me say it's a pleasure to meet all of you. Thank you so much for the chance to provide testimony. I do have a prepared statement and then I'd be glad to walk through the high level concepts in the white paper and answer any questions.

[Rep. Kathleen James (Chair)]: Great. We just need to get you to give us your name and title for the record, both of you, please.

[Ken Boyce, Vice President of Engineering, UL Solutions]: Great. I'm Kim Boyce, vice president of engineering at UL Solutions.

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

[Megan Housewright, Government Affairs, UL Solutions]: And my name is Megan Housewright. I am with government affairs of UL Solutions based in Washington DC.

[Rep. Kathleen James (Chair)]: Alrighty. Take it away.

[Ken Boyce, Vice President of Engineering, UL Solutions]: Great. Thank you so much. Chair, vice chair, and members of the committee, my name is Ken Boyce. I'm vice president engineering for the industrial Testing, Inspection and Certification Division at UL Solutions. I am an electrical engineer by training, and I've been with UL for over forty years. Many of you may know UL Solutions by our former name, Underwriters Laboratories. Underwriters Laboratories was founded in 1894, created to test electrical products after fire concerns at the World Fair in Chicago highlighted serious safety risks. Today, UL Solutions is a leading global independent organization focused on safety, security, and sustainability. Through testing, inspection, certification, and verification, we help manufacturers, regulators, consumers, and others build trust in products that meet established safety and performance standards. Thank you for the opportunity to speak with you today about plug in photovoltaic systems, often referred to as PIPV. UL Solutions appreciates the growing interest in PIPV technology as a way to expand access to solar energy, particularly for renters and households that are unable to install rooftop solar. We share that goal. However, our mission, working for a safer world, requires us to look carefully at how new technologies interact with existing systems and the people who will use them to ensure they will do so safely. UL Solutions work on PIPV was prompted by the passage of Utah Bill HB three forty. The Utah law allows PIPV systems to be exempted from interconnection standards if the systems conform to standards in the National Electrical Code or NEC, also known as NFPA 70, and are certified by Underwriters Laboratories. At that time though, there was no standard to which these systems could be certified nor specific National Electrical Code requirements that apply to PIPV. To address this gap, our engineers conducted a detailed technical review of PIPV systems and identified several unintended but serious safety hazards. These hazards span both the PIPV products themselves and also how the PIPV products can introduce hazards to the residential wiring systems. First, overcurrent risk. In a typical US home, branch circuits are protected by circuit breakers located at the main electrical panel. A plug in PV system injects current downstream of that panel. When that injected current combines with utility supplied power, it can exceed the safe capacity of the branch circuit conductors without being detected by the circuit breaker. That creates a real risk of overheating electrical fires and electric shock. Second, ground fault circuit interrupter, or GFCI, compatibility is a concern. GFCIs are required in bathrooms, kitchens, outdoors, and other areas where people are more vulnerable to electric shock. These protective devices are designed for one directional current flow. Plug in PV systems introduce bidirectional current, which can damage or impair GFCIs, potentially affecting their response or preventing them from tripping at all during a ground fall. These products could continue to provide power but not be able to protect the public any longer. Third, touch safety. While existing inverter standards like UL seventeen forty one focus on grid interactive performance, they were not written to address the unique human exposure risks associated with consumer accessible plug in PV systems. Without additional safeguards, both the AC and DC sides of a PIPV system could expose users directly to electric shock hazards. In response to these findings, UL Solutions developed UL 3,700, a comprehensive set of technical requirements specifically designed to address PIPV safety concerns. UL 3,700 covers system design, performance, installation instructions, mounting durability, and critically, how these systems interact with existing residential wiring. UL 3,700 allows for different pathways to mitigate these hazards. Among other protections, UL 3,700 requires practical methods to ensure that PIPV systems can only connect to circuits designed to handle the injected current safely. Verify compatibility with bidirectional GFCIs, maintaining the high level of shock protection Americans have come to expect. Rigorous touch safety requirements across all system components. Mechanical and environmental testing to ensure mounting hardware does not fail and injure someone below. These protections are not arbitrary. They are an extension of the same safety principles that have driven dramatic declines in residential electrical injuries and fatality over decades. For example, expanded GFCI requirements since the 1970s have reduced consumer product electrocutions by more than 90%. New technologies must respect and not bypass these proven protections. We are often asked why plug in solar systems used in Europe cannot simply be adopted in The United States. The simple answer is that our electrical systems, building stock, and safety requirements are fundamentally different than those in Europe. US codes are intentionally more conservative, particularly to protect children, the elderly, and other vulnerable populations. Even at lower wattages, plug in PV systems present the same fundamental potential hazards if they circumvent established protective devices. For these reasons, UL Solutions strongly supports legislation that allows PIPV to move forward only with appropriate safety certification, including certification to UL 3,700. This approach protects consumers, provides clarity to manufacturers, and enables innovation without compromising the electrical safety framework that has served this country well. Thank you for the opportunity to share our perspective. I'll look forward to questions and be glad to walk you through the white paper.

[Rep. Kathleen James (Chair)]: Jen, I have a couple of questions as a non technician. It goes to a couple questions I asked earlier today. So obviously you guys are very familiar with, you know, appliances and products bearing your sticker. And I am curious if you know, this is a really broad question and this may be a question for somebody else, but if certain states require UL certification or UL compliance with whatever the product is, is that on the manufacturer not to sell it into that state? Or is it just simply state law and it's kind of on the consumer? Like who's that on?

[Ken Boyce, Vice President of Engineering, UL Solutions]: Yeah, that's an interesting question. I mean, obviously all of you would know more about the nuances of enforcement of state laws more so than I would. We do know that there are several levels of enforcement for electrical safety requirements. And so if there are requirements in the National Electrical Code, for example, which is what we call the model code, it's published by National Fire Protection Association, but it's not enforceable until a local jurisdiction adopts it and says this is required with or without amendment. And so that jurisdictions vary widely across The United States. It could be a city, it could be a county, it could be a township, it could be a state. But once that jurisdiction adopts the code and says, these are the requirements for electrical products, then that is enforced by electrical inspectors and other authorities having jurisdiction to conduct that enforcement. And I think there's probably a very important relationship between a state law and what would be adopted into the code. But I think manufacturers obviously would have an interest in complying with the legal requirements for the markets that they're selling products in. Consumers may not be aware of the need to comply with those, or it may vary at least. So it's maybe a little bit more uncertain how consumers may act on practical enforcement of those concepts. And then there's a role, would think for these local jurisdictional authorities that may help reinforce compliance with the applicable state law.

[Rep. Kathleen James (Chair)]: Thanks. That is helpful. And then I had another question, which I also posed earlier. And we're obviously as a committee very focused on making sure that these devices are safe, you know, can be used safely. But at the same time, I'm also trying to make sure that we're keeping a perspective on the level of hazard. So, you know, I kind of asked earlier, what how are these devices any more or less hazardous in the real world or statistically than, like, a generator I go pick up at Walmart and plug in or, you know, and and I'm not saying this to be snarky. I'm know, or like an ancient toaster I might have that catches on fire because I haven't thrown it out. I wanna make sure that we're keeping a sense, that we really have a sense of actual risk here.

[Rep. Christopher Howland (Member)]: Yeah,

[Ken Boyce, Vice President of Engineering, UL Solutions]: fair enough. I mean, I think that's a very important topic here. And obviously, again, we're just trying to keep people safe. I mean, that's really our mission and what we're constantly focused on. So we think about this exact topic all the time and we want practical solutions that work in the real world, right? Very much to the to the spirit of your question. I think there's a couple important issues here to think about. One is the existing electrical infrastructure that we're all very familiar with, you know, in our households, in our workplaces, with those receptacles where we plug products in, that has worked really, really well and very safely. But it was all designed for you to plug an appliance in to that receptacle and draw power from the power structure, which basically is primarily provided by the electric utility, right? So it's all about drawing current from that circuit into the appliance to do something meaningful. You plug in your toaster, you want to toast a bagel, now you can toast your bagel because you have a source of electrical supply. The fundamental difference with PIPV products is that now that plug is being used to inject power into that receptacle, which it was never designed for, and the electrical circuit was never designed for. It is different, and I'll talk a little bit about this, when you think about, let's say a generator or a rooftop solar system, Those are also power sources that can feed into the power infrastructure in the building, but it's done through a very well established set of rules done with what's called hardwiring with conductors and conduit and other electrical products that generally are installed by qualified persons. And so it's done under very controlled circumstances. PIPV is very different, which is part of the appeal is that it could be easier than having to do that work. But it also is very different in the sense that now you have this uncontrolled connection from the PIPV product into the power system, which it was never designed for, and it could be done in ways that could cause these hazards. And so I think that those differences are really important and quite unique to these PIPV systems. They are not unsolvable engineering problems. As we've outlined in the white paper, we wanted people to understand these are the potential hazards that could occur. They can be mitigated. There are ways to mitigate those potential hazards. And we tried to capture that in UL 3,700 as a way to say, here are product level requirements that can support safe introduction of products to the marketplace with those identifiable hazards having been practically mitigated. You asked about kind of percentages, and we don't have that data unfortunately, but hopefully that helps you understand the very unique aspect of PIPV products and why there are some special measures that are needed to make sure that they can be used safely.

[Rep. Kathleen James (Chair)]: Okay, and then one final question, and we'll turn to the white paper because I know folks wanna get into that. Did you, I assume testified in Virginia or were involved in the development of the Virginia law?

[Ken Boyce, Vice President of Engineering, UL Solutions]: Maybe you can help with that.

[Megan Housewright, Government Affairs, UL Solutions]: Yeah, I can speak to that. We have provided them with information, but we're not directly involved in, say, lobbying on the law or anything, just providing information.

[Rep. Kathleen James (Chair)]: Okay. Did you testify? I I was just Okay. See, we're more thorough in Vermont. We do things better

[Rep. Laura Sibilia (Ranking Member)]: in Vermont.

[Rep. Kathleen James (Chair)]: I was just curious. I I just wondered if you I I were interested in how that bill turned out because they seem to have added some things that we're interested in. So I was just wondering if you had feedback on that. I think we're gonna try to we're gonna get our attorney to kind of walk us through the Virginia and Utah laws next week, if you're interested.

[Megan Housewright, Government Affairs, UL Solutions]: Yeah. Ken, why don't I go I can take a review of those and provide our thoughts to you on those in the interim before you meet with your attorney.

[Rep. Kathleen James (Chair)]: That'd be great. I think Utah, we may have I'm not sure if we've already left Utah on the dust. I think our bill was based on Utah, but it sounds like Virginia then got out ahead of us on some of the revisions so that we might, we're going to take a look at. So Virginia maybe especially. Okay.

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

[Ken Boyce, Vice President of Engineering, UL Solutions]: Okay, so did you want to walk quickly through white paper or are there other questions we want to explore right now?

[Rep. Kathleen James (Chair)]: Through white paper.

[Ken Boyce, Vice President of Engineering, UL Solutions]: Okay, fantastic. So it sounds like people have access to white paper and are familiar with the content in some form. Is that true?

[Rep. Kathleen James (Chair)]: I'd say we have access to it. Okay. Great.

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

[Ken Boyce, Vice President of Engineering, UL Solutions]: go ahead.

[Rep. R. Scott Campbell (Vice Chair)]: Oh, I was just saying, at least I haven't read it all. It's pretty devastating.

[Rep. Kathleen James (Chair)]: Yeah, but we do have it.

[Ken Boyce, Vice President of Engineering, UL Solutions]: Okay, great. Yeah, and I think some of these topics are a little complex technically, so we realize it can be challenging to process the important aspects of this if you don't have a technical background in electrical safety. But I can talk a little bit about some of the things that I've highlighted in my testimony, but you will certainly see called out very specifically in the white paper. So the intention here was to really share the results of the research and technical analysis work that our team of technical experts undertook to really understand PIPV systems and how they may interact with the wiring systems that are embedded in the buildings where they will be used, to really understand those aspects and then to understand the performance of the PIPV products themselves. And so we did walk through a comparison starting off just to highlight some of those differences between plug in photovoltaic products and other PV installations like rooftop installations, which are quite different. Understandably, you know, some of the market appeal for PIPV products is to promote ease of use for consumers who may not have access to installing a rooftop system. And that's a worthwhile consideration, right, to allow people to make choices about how they will generate and use energy. And if you can't put in a rooftop solar system, then you don't have a choice unless you have some other mechanism like community solar that could provide access to clean energy. So it's important though to note that for rooftop solar, again, requirement there's that that's installed by qualified personnel. There's a very structured set of rules about how the power that's generated by that rooftop solar system would be wired into the wiring system upstream of the breakers and to coordinate that protection throughout the building's wiring system in a way that's very different than the PIPV products that are on the market today. And so that was one important consideration we thought it was worth addressing. I think as we see the evolution of these products, we really do wanna highlight the critical role of what's called overcurrent protection, and that can be accomplished by circuit breakers or fuses. You know, commonly it's done by circuit breakers in most residences today, that are in a panel board, a central panel board, very close to the connection to the electric utility in a building. And those overcurrent protective devices like circuit breakers play a really important role in protecting all of the wiring and the devices that will be used inside that house on that electrical circuit. So they are able to sense when when wires are being overloaded and and trip to prevent those wires from being, overheated so much they could cause a fire hazard or that the insulation on those wires can be degraded because it's overheating, and now you can have a subsequent electric shock hazard. So those overcurrent protective devices play a really critical role. Again, they've been very, very effective. The challenge, and we spent some time in the white paper trying to illustrate this, the challenge with PIPV products is they are plugged into that electrical system and generate power downstream of the circuit breaker. So the circuit breakers are essentially blind to the current that's being injected by those PIPV systems into the wiring system. They can't protect from overloads associated with that current because they can't see it. They're upstream, electrically upstream of the PIPV product. And so this does run a risk. Certainly is possible that you don't have a circuit loaded up to its rating, say 15 amps. You may have a lower electrical load. And so in that case, a PIPV product on that circuit at that moment in time may not overload that circuit. But the circuits are designed so, and we plug things into different receptacles and turn them on and unplug them and plug them into a different receptacle all the time. And so the concept is that circuit has a rating the overcurrent protection is set to protect up to that rated current, and then it will sense an overload, but the PIPV product would blind the circuit breaker to the overload condition. And so that means there's some real concerns about overheating those wires, overheating the devices like receptacles and the electrical connections that can overheat and cause significant fire and electric shock hazards. So we spent some time trying to explain what that looks like. Another key topic that I mentioned is touch safety. And touch safety is the idea, again, when you think of your toaster or any appliance, when you're plugging it into the receptacle, you're making a connection with the electrical circuit inside that receptacle, and now that's done safely, and now the toaster can take electricity from the power circuit and toaster bagel. The difference with PIP And when you unplug that, you can touch the blades and it's disconnected from the electrical circuit, so there's no hazard in touching the blades. The difference with PIPV products is when light strikes for the voltaic panel, it generates electricity, and that will put a voltage on those plug blades that you can touch at any time, and that would be an electrical shock hazard. You can get electrocuted by that. So there are requirements that electric utilities have to stop power export under certain conditions. Really those developed to optimize the electric utility operation. It's not about minimizing a shock hazard to a consumer who may touch those plug blades. And so unless you have additional safety measures, there is an electrocution hazard for people touching those plug blades. We talk about and so we're nearing the end. I certainly want to hear any questions that people may have. We talk about the that compatibility with ground fault circuit interrupters or GFCIs. These are critical protective devices that have been required for many years in the electrical code, and they provide an additional level of protection from electrocution hazards. Again, they've only been designed for unidirectional current flow traditionally. We have requirements for bidirectional ground fault circuit interrupters, But if you backfeed them, if you have current flowing the opposite direction than what those GFCIs were designed for, you can also blind the GFCIs. And so they will continue to provide power through that receptacle, but now the consumer has lost the benefit of the ground fault protection, and they would be oblivious to that. There's no way you would know because those GFCIs now have been misused. And so that's another important consideration that would be highly relevant in terms of connection to legacy power systems. And then, you know, in summary, think we had kind of highlighted these are really important topics. They are able to be mitigated through effective safety engineering mechanisms. And we tried to outline what some of those could be. We, you know, continue always to see innovation and we're open to other innovative ways that would effectively mitigate these hazards that we've spelled out and allowing those to be certified under UL 3,700. But it's really important that we keep people safe if we're going to allow them to use these PIPV systems. So that in summary is a quick overview of the white paper, and I'm glad to answer any questions people may

[Rep. Kathleen James (Chair)]: have. Brett Campbell.

[Rep. R. Scott Campbell (Vice Chair)]: Is UL 3,700 sort of finalized?

[Ken Boyce, Vice President of Engineering, UL Solutions]: It is, yeah. So we published it in January, December We announced it in January just because of the holidays, but it is finalized. Now we can change those requirements, again, if we see, you know, new innovative ways to accomplish different methodologies for affecting the same levels of protection and safety. We can update them at any time, but it is finalized.

[Rep. R. Scott Campbell (Vice Chair)]: Do you have, I don't see that we have a copy of that. Do you have a, I don't know if a copy is really useful to the non technical person, but I guess I'm wondering if you have a summary of the requirements.

[Rep. Bram Kleppner (Member)]: Yeah,

[Ken Boyce, Vice President of Engineering, UL Solutions]: Megan, I think we probably can provide a copy, right? I mean, that certainly is something we'll take as an action item. Just very quickly, know, to kind of walk through the construct of UL 3,700. So there, as with many of our safety requirements, there are some well established pillars of requirements. The first is construction. How do the products have to be built in order to minimize these safety features? And that includes some of the things like access to hazardous voltage parts, how the mounting means would have to be resistant to corrosion and degradation, things like that, right? So we wanna see it built a certain way that would mitigate those known hazards. We talk about flammability of plastic materials to minimize the risk of a fire hazard. Those are construction requirements. And then there's another pillar that's focused on performance. And so that's our testing regime, all the tests we would do to evaluate this. We will disconnect the PIPV product and measure the voltage that's available on the plug blades and make sure that that's in a safe level before anyone could be electrocuted, for example. We'll do a series of normal operation tests where we're trying to see as the product works the way it's intended to, is it working safely, are internal parts overheating, is there some concern about long term degradation that may emerge over the lifetime of the product and degrade some of these safety features. So we have a normal testing regime, we have an abnormal testing regime, which is things like, you know, will impact it and make sure that plastic enclosure doesn't crack and allow access to live parts. We have an environmental regime for products, especially that are used outdoors, where we'll think about exposure to water and ultraviolet light and making sure that those things don't degrade the performance of the product. And then obviously taking those concepts that I have walked through in the white paper and making sure we have testing data as appropriate to back up, that there's not a safety concern with the product. Then the last pillar is really associated with markings and instructions. We require certain markings to be on the product to inform the consumer about potential hazards and what they would need to do to avoid those hazards from manifesting themselves. There are obviously instructions about how to install the product, how to use it safely, what has to be done over the lifetime of the product to be safe in its use. And so those are the that's a quick overview of the construct of UL 3,700. Obviously, there are a lot of detailed technical requirements embedded in each of those sections to address the particular safety hazards. But yeah, we definitely can share a copy, and we'll get that over to you.

[Rep. R. Scott Campbell (Vice Chair)]: Oh, great. Thanks, Richard. One other one other question on this. Does it include how does it treat the suggestion or requirement for a dedicated circuit?

[Ken Boyce, Vice President of Engineering, UL Solutions]: Yeah, so that's one of the options that is available. So just to be clear, it's a great question. A dedicated circuit means electrically nothing else is connected to that circuit, right? So if you think about your household, again, you know, you'll have a number of receptacles in your kitchen. You know, you may plug your toaster in one, you may plug a stand mixer in another. Those are probably all the same electrical electrical circuit. And that's fine because of the way that overcurrent protection and the wiring has been addressed to allow that type of usage. One of the concerns about PIPV, as I've indicated, is you may be back feeding GFCIs, for example, with bidirectional current flow. If you have a dedicated circuit where there is nothing on that circuit but your PIPV product, you can still generate power, you'll mitigate the overcurrent protection issues if you have the right construct that UL 3,700 requires. And so you've eliminated some of those potential hazards I've outlined, because nothing else is on that surface, right? And so that's one way, there are other methodologies, but that's one way to allow the products to be installed in such a way that you won't have some of the safety concerns manifesting themselves.

[Rep. R. Scott Campbell (Vice Chair)]: Okay, thanks a lot. I've seen a lot of questions.

[Rep. Kathleen James (Chair)]: Rick Southworth?

[Rep. Michael "Mike" Southworth (Member)]: Similar to the way portable standby generators are hardwired into a panel, is it possible to mitigate concerns with the plug in panels by having that receptacle wired in similar to that, or does that not work?

[Ken Boyce, Vice President of Engineering, UL Solutions]: That's a good question, and certainly that concept would be a valid one, right? So whether it's a generator or rooftop solar system or a PIPV product, if it were wired in at the panel board using those existing rules about interconnect circuits that are very, very clear in the National Electrical Code, that would mitigate some of those concerns. Because now you're doing it in such a way that you've integrated the power source into the wiring system in a safe and established manner. So that certainly would work. That's very much different than the way we've seen the products on the market today being marketed, right, where anybody can buy it, and you can take the plug and plug it into any receptacle that will accept that plug blade, which is, you know, throughout our house, right, or apartment or condo. So that would be another way to say, yeah, let's use a more conventional interconnection of the source with the wiring system using established rules, that would also do it. So again, there are a number of ways that can be leveraged to effectively mitigate these hazards. So it's a good question that, you know, using those more traditional approaches would certainly be valid.

[Rep. Michael "Mike" Southworth (Member)]: And one last question. Have any approvals been issued yet for these through UL or have any been submitted for testing for approval?

[Ken Boyce, Vice President of Engineering, UL Solutions]: Yeah, great question. So we are actively working with manufacturers of these systems. You know, we can't talk about which companies, obviously. I know you didn't ask that, but we can't talk about that just in terms of confidentiality. But there are active interactions and engagement with manufacturers of PIPV products. As of today, that has not resulted in any certifications to UL 3,700, but we think that will change in the near future.

[Rep. Michael "Mike" Southworth (Member)]: Thank you.

[Ken Boyce, Vice President of Engineering, UL Solutions]: Thank you.

[Rep. Kathleen James (Chair)]: Now Christopher Howland?

[Rep. Christopher Howland (Member)]: Yeah. Mister Boyce, I was involved with photovoltaic generation way back from 2000. The initial electronic inverters were UL certified, and then for a short period of time, a certification was lifted or removed. How do those get tracked? Mean, we never knew whether the inverter that was on the system was pre certification removal and or false.

[Ken Boyce, Vice President of Engineering, UL Solutions]: Okay, yeah. So maybe I'll start more generally just to outline what the certification process looks like, and then we'll try to drive down more specifically. So if a company is seeking certification to be able to put the UL mark on their product, they would approach us and say, we would like to have authorization to use the UL mark. And then our engineering and laboratory teams will take samples of that product, assess it against the requirements that are applicable, in this case, UL 3,700, as we're talking about today. And then once the product has been shown to comply with all of those applicable requirements through the establishment of very clear evidence, test data, verification of construction features, etcetera, etcetera, then we would authorize them to begin production using the UL mark. At that point, our engineering and laboratory interaction with them has been completed, but we do what's called a surveillance program where we will go into the factory where the products are being manufactured and conduct periodic assessments at each factory where the product's being made to verify that the ongoing production has the same attributes from a safety standpoint as the products that we evaluated in our laboratories. And so the manufacturer is authorized under the terms of engagement to continue to produce with the UL mark as we do this surveillance program. They can choose to stop that at any time. And so that's really their decision. So I'm not familiar with the specific scenario that you discussed about inverters in the, you know, circuit 2,000, but it is, you know, there is a discretionary aspect where the manufacturer may say, okay, well, I'm not gonna produce this product anymore, or I won't produce it with the UL mark. Once it's established, there's obviously a pretty significant incentive to keep that going, but ultimately it falls to the manufacturer to make that decision about how they'd like to introduce their product to the market. We have been testing inverters for a very long time. We've seen a lot of changes in inverter requirements. And so sometimes, just one more little wrinkle on this, there are times where we look at what's being done from a technological innovation standpoint, and there are times where we say we're going to introduce new requirements that are more stringent. And that sometimes means the products that had been evaluated to legacy requirements have to be reevaluated in order to continue to bear the UL mark. We call that an industry file review. So when that happens and there is a new set of requirements that are more stringent, we'll set what's called a future effective date. So that may be 01/01/2028. And we say, if you want to continue to use the UL mark after 01/01/2028, you have to show that you comply with these new or revised requirements before then. And there are some cases where manufacturers decide not to do that. So again, I'm not familiar with the specific scenario you were talking about in the 2,000 era, but there has been a lot of those types of technological developments on the inverter front. These are very sophisticated power electronics devices. They've actually evolved quite a bit in positive ways to help support the grid in very constructive ways so that now buildings are not just loads on a grid, they can actually collaborate with the grid in really important ways. And as we've seen more and more renewable energy resources being deployed, there have been a lot of new features that have been added to inverters. So they're very important and sophisticated devices. So there's a lot of technological development on the inverter front. So hopefully that helps you understand kind of where we are on them.

[Rep. Christopher Howland (Member)]: Thank you.

[Rep. Dara Torre (Clerk)]: Ruttory? I have a question about the systems that are being paired with batteries so that you could use, have access to power during an outage. Does the battery piece of that require a different UL certification?

[Ken Boyce, Vice President of Engineering, UL Solutions]: Yeah, so batteries that are integrated into, let's say, a residence or a commercial building, those are generally referred to as energy storage systems. So they also have very sophisticated power electronics devices that help them integrate with the grid would make sure that the conductors aren't overheated. That is all addressed very carefully. What we see with a lot of deployments across The United States, it's commonly referred to as a solar plus storage. And so what we see in a lot of cases is you'll have rooftop solar that will be brought down, the electrical supply will be brought down to the panel board, and there's an energy storage system that's also hooked in right there. And so again, it's all coordinated with the wiring system that's in the building using those well established National Electrical Code interconnection rules. And so most I've never seen a solar plus storage installation for PIPV. We may see that in the future because the benefit of batteries is, you know, they can store the energy. Solar is diurnal, right, which means it generates electricity when the sun's up. It doesn't generate any electricity really at all when the sun's down, unless you have some artificial lighting coming to bear on it. But the benefit of energy storage systems is that you can use the batteries, store the energy, and then use it when you want to, you know, when energy prices are more expensive, maybe in the afternoon, and there's a lot of demand on the grid, depending upon how that works in jurisdiction. When the power is out, you know, when it's convenient for you to use that energy that you generated with solar panels, you know, clean energy and use that and not buy electricity from the grid, that's being generated in a variety of different ways. So there's a lot of reasons that energy consumers like to be empowered by the choices that are enabled by energy storage systems, and solar plus storage is a very powerful combination to accomplish that. But again, it's most common with rooftop solar combined with an energy storage system and put in a residence using those national electrical code rules at the panel board. Does that help? Yeah. Okay, great.

[Rep. Christopher Howland (Member)]: Thanks.

[Rep. Kathleen James (Chair)]: Do we have any more questions? All right.

[Ken Boyce, Vice President of Engineering, UL Solutions]: I appreciate you kind of working through. I'm sorry, I'm a little bit of a nerd. It does get very technical, but I appreciate you trying to work through what does this mean for the decisions that you'll be making. Again, we wanna certainly continue to support you in making the best possible decision for Vermont.

[Rep. Bram Kleppner (Member)]: A nerd is exactly what we want in your position. That's what keeps us safe.

[Ken Boyce, Vice President of Engineering, UL Solutions]: Thank you.

[Rep. Kathleen James (Chair)]: Thank you so much for joining us, and we appreciate your time. And I think we can probably go offline.

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

[Ken Boyce, Vice President of Engineering, UL Solutions]: Alright. Thank you very much.

[Megan Housewright, Government Affairs, UL Solutions]: Long on on follow-up, and appreciate the opportunity. Thank you.

[Ken Boyce, Vice President of Engineering, UL Solutions]: So much. Bye now.