Vermont Legislature SmartTranscripts:

[Dara Torre (Clerk)]: We're live.

[Rep. Kathleen James (Chair)]: All right, welcome everybody to House Energy and Digital Infrastructure. It's Friday, April 3, and we are here starting to kind of approach the finish line on the testimony we're taking on S202, which is a bill about portable solar or plug in solar devices. So I'm representative Kathleen James from Manchester.

[Rep. Michael "Mike" Southworth (Member)]: Scott Campbell from Saint John's Barry. Richard Bailey from Mobile two. Michael Caledonia two. Christopher Howland, Rutland four.

[Dara Torre (Clerk)]: Dara Torre, Washington two. Great. We've got a few

[Rep. Kathleen James (Chair)]: members who will probably show up in a minute. And, Brett Morrow, do you wanna introduce yourself?

[Rep. Christopher Morrow (Member)]: Chris Morrow, Windham Windsor Bennington.

[Rep. Kathleen James (Chair)]: Awesome. And we have some guests. Representative Brady here from Williston, and I've got five students from Colchester High School here today that are observing the process. Excellent. Well, just so you guys know, so we've been taking testimony on plug in solar, which are basically like it's called balcony solar, and they're smaller solar devices that you can just plug into a wall outlet. And right now, those devices are kind of commercially available. You could order one off YouTube. I mean, not YouTube. You could order one off Amazon and plug it right into your house to generate a little bit of solar power. And we're taking testimony on a bill that would make sure that Vermont has safety standards in place so that if you buy one of those, it's safe to use. And so that's gonna be what we're you're gonna hear us talking about today. There's a national group called Underwriters Laboratories that certifies all kinds of appliances to make sure they are safe. And so we are going to make sure UL certification applies to these devices. So you're going hear us get pretty wonky, I think, UL3700. So Bill, thanks again for being flexible and if you could just introduce yourself for the record.

[Bill Brooks (Brooks Engineering)]: Sure, thanks. I appreciate the opportunity, members of the committee and chair. Bill Brooks, Brooks Engineering is my company. Registered Professional Engineer both as an electrical engineer and as a mechanical engineer. I have a Masters of Science in Mechanical Engineering from North Carolina State University and I've been working in this field my entire careers for thirty eight years and one of the few engineers on the planet that have that many years in this field and have worked on pretty much every code and standard that relates to solar energy systems in The United States and internationally. So codes and standards is kind of my forte. And so that these issues as they come up are something that I generally pay attention to and have as much or more background than anyone in The United States on these subjects. And so there are plenty of questions about this particular area of plug ins, PV, TIPV if you will. And those issues are rather straightforward. And so that's one of the reasons we do have product safety standards. There are numerous product safety standards in the solar space and this new product safety standard is specific to address the issues related to this particular application of what we call photovoltaics, which is a fancy way of saying solar electric power. I've been on the National Electrical Code Code Making Panel four since 2009. I have chaired most of the committees related to photovoltaics over the years from issues as small as plug in systems, which are extremely small. And I also chaired the committee that oversaw the large scale photovoltaic electric supply station article of the National Electrical Code, covers the largest systems in the world, can cover 10 mile by 10 mile systems with millions of solar panels. And so obviously photovoltaics can scale from a small device on your watch to millions of solar panels providing major power for cities and communities.

[Rep. Kathleen James (Chair)]: Great. We have two members in particular, yep, reps Campbell and Southworth, who've been putting together a list of specific questions we have. About 3,700. I'd say most or all of them along the lines of does 3,700 already include this or do we need to be specific about it in the bill? So, Scott, do you want to Sure.

[Rep. R. Scott Campbell (Vice Chair)]: We have heard some concerns about safety issues, and obviously that's what we want to be absolutely sure that we're doing correctly in this bill. And we have also referenced the Virginia bill that just passed earlier in March as a good starting point. One of the things that we're curious about is there's a lot of reference to the new UL standard 3,700. And what does that include? We haven't actually seen the standard. We're hoping they get a look at it or ask somebody like you or somebody at UL whether it includes these things. So a reference to the UL seventeen forty one standard, Is that also include so are you familiar with 3700, I guess, the first question.

[Bill Brooks (Brooks Engineering)]: Yeah, sure. Great question. And let's start off at that level. I would classify IUL 3,700 as a type of standard that's an umbrella standard. That term that I use, which I pretty much coined as an umbrella standard. It covers basically a variety of standards that come under what you would have to cover to cover all the safety issues related to a plug in device. And so among those, so I don't know whether you've read the UL white paper that came out about two days before the 3,700 standard was published. But the UL white paper basically is is an excellent kind of rundown of all the things that the UL standard has to address in order to be a fully valid safety standard. And although since it predated the standard, it doesn't specifically have a lot of references to 3700 because it wasn't there yet. A good way to read that white paper is to say here's all the things that we're going to cover in 3700, and oh, here's 3700.

[Rep. Kathleen James (Chair)]: That's so helpful. Yeah. Yeah. But on you go.

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

[Bill Brooks (Brooks Engineering)]: So so you owe 17 41. You know, we throw around these numbers, and I apologize. You sound like when you say that number that you actually know what it means, and probably most of the other people in the room don't.

[Rep. R. Scott Campbell (Vice Chair)]: Well, I don't know what it means. I know that it had to do with with actually not plug in PV, but this PV business that's installed, you know, permanently, and then and then how it interacts with the grid. Right. That's all I know about it.

[Bill Brooks (Brooks Engineering)]: So it's the broad standard. Actually seventeen forty one is a very broad standard. It's been around since 1999. I'm on the technical committee for 1741 and was involved with writing it. And it covers a whole range of issues related to the electronics and the electrical equipment that coincides with making the solar panels run safely and operate, and it includes a whole section on what we call a utility interconnection. Okay so connecting certainly one of the biggest issues in my career since day one has been how do we get utilities to allow these products to connect to the utility grid. And so the utility grid heretofore you would have to have all kinds of very specialized electronics and switch gear and things like that because things that connected to the grid were measured in millions of watts, not tens of watts or hundreds or thousands of watts, millions of watts. And so all that infrastructure that you needed for interconnection was valid for very large systems, but when you got down to a residential size system, and certainly a small residential size system, they were prohibitively expensive. And so a lot of technology went into how do you make these products able to connect and parallel with the utility company in a safe way so that when the utility goes down, they automatically shut down. So it's something we call anti highlanding and we actually invented technologies in anti highlanding which are now fully accepted today as they work, nobody has concerns about them, they do what they do, nobody's gotten hurt from these problems. Oh, I'm sorry, was bored. I was hoping to keep the attention of those high school students, and I just failed miserably. I just

[Rep. R. Scott Campbell (Vice Chair)]: I'm so sorry. Friday bill. So Anyway oh,

[Bill Brooks (Brooks Engineering)]: well. I was hoping to get a few a few people on the team for solar energy, but I guess not. Hopefully, I'll make an impression. But no. So so that's what the the standard. That is what one of the things that UL seventeen forty one does, and it's an absolutely integral part of 33,700. There's just no way that you could plug anything into an outlet that was eventually connected to the utility company. It didn't have all these these safeties in it.

[Rep. R. Scott Campbell (Vice Chair)]: So we don't need to reference seventeen forty one and and and statute because that's part of the if don't need reference 3,700, we're good.

[Bill Brooks (Brooks Engineering)]: That's right. That's why I say it's an umbrella standard that covers all the issues that come up, of which there are numerous, and certainly utility interconnection is one of them.

[Dara Torre (Clerk)]: Okay. Sure,

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

[Rep. Michael "Mike" Southworth (Member)]: I know we have the white paper. I've read it a couple of times. Is there an actual UL 3,700 standard that has been written that we would be able to get from you?

[Bill Brooks (Brooks Engineering)]: Well, I mean, you can't get it from me because I have a copy of the standard, it's a copyrighted document that I'm not allowed to share. It is available online. You can actually reference it online. There's an online portal. I'm sure it sounds like you're going to be talking with UL. Who at UL are you going to be speaking with?

[Rep. Kathleen James (Chair)]: Megan. And then?

[Rep. Michael "Mike" Southworth (Member)]: Who is it that we talked to?

[Rep. Kathleen James (Chair)]: Megan Howstripe is a government affairs person and she brought

[Bill Brooks (Brooks Engineering)]: Okay.

[Rep. Kathleen James (Chair)]: And or is bringing someone more technical.

[Bill Brooks (Brooks Engineering)]: Okay, might be Pete Jackson or could be Steve Jones. Those are two people in their UL Solutions group. I'm sure they could share one with you. Again, there's sensitivity about sharing documents that are commercial documents. And so that's the only reason. Don't hesitate. If I could do it, I'd give it to you right now. The

[Rep. Michael "Mike" Southworth (Member)]: standard has actually been written in standard form and not just in a white paper, correct?

[Bill Brooks (Brooks Engineering)]: Absolutely, absolutely. It's called an outline of investigation, and many people have mis construed that to believe that it's an outline of investigation is not a standard. It is a standard. There are many, many outline investigations out there, and so it's the first it's the first version. It's basically UL is tasked by OSHA and and the federal government to write standards for the solar industry. So all standards in The United States that relate to solar are written by UL. Okay? So they have essentially a mandate to write these standards. And so if there's a need for a standard, they'll often they they they will internally work on a standard. They'll often bring in outside folks like myself and other folks to help maybe provide a little bit of input to that outline of investigation standard. And then they release the standard onto the market. And then products can be certified to that standard. That standard became available on 12/11/2025. That's when it was published. And then that standard goes through a life of its own which goes through revision processes. So that standard we just mentioned UL seventeen forty one of which this standard is part of that family. So the seventeen forty one family has 3,741, 4,741, it's got 9,741, it's got a whole family of standards, 3,700 which shares a seven is part of that family. But anyway, so so seventeen forty one, which was published as an outline of investigation in 1999, is now on its fifteenth revision, something like that, you know, over the years where where we've revised it. So 3,700 is available, products can be certified to that standard. To my knowledge, but again, my knowledge is not perfect. There are no products currently certified to that stand. There may be some in process UL because of their agreements with their clients is not at liberty to disclose who or what or whether they're working with customers and things like that. But the standard exists. And that is fundamentally important because these policy decisions that you guys are looking at are hinged on the reality of the standard existing.

[Rep. R. Scott Campbell (Vice Chair)]: So how long is the process for certifying a product or a device?

[Bill Brooks (Brooks Engineering)]: Anywhere from a month to six months.

[Rep. R. Scott Campbell (Vice Chair)]: There are some products that are currently in the process now.

[Bill Brooks (Brooks Engineering)]: I We I've been led to believe through obscure references that there may be products available, but it's like one of the things where we can't confirm or deny. I see. Alright.

[Rep. R. Scott Campbell (Vice Chair)]: Well, some other specifics that we, wanted to be sure were referenced, and they were mentioned in the white paper. We we did get the white paper, and I think probably all of us read it. Is there a requirement for a dedicated circuit? Is there a requirement for a specialized plug? Is there a requirement for a bidirectional GSCI? Do you know, are those actually specifically referenced or required by 3700?

[Bill Brooks (Brooks Engineering)]: Well, so there's three very different questions.

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

[Bill Brooks (Brooks Engineering)]: I'm interested in the term dedicated circuit, which in the National Electrical Code is called an individual branch circuit, is not a requirement of the standard nor is it a requirement to be safe. So I heard that statement and I'm curious where it comes from because there there is a technology, and and and the real the real technology that makes this PIPV technology practical is called power control systems. Okay. Power control systems, which is also part of the family of seventeen forty one standards, it's 3,141, is part of 3,700 under the umbrella of 3,700. And what power control systems do is and and I actually invented the term, and it went into the 2020 National Electrical Code. So it is part of the code, code in the state of Vermont. And what it does is it provides monitoring and control of sources and loads to maintain current within the capability of the wiring systems that we're talking about. And so there is a lot of technology that goes into that. It's an amazing, it's become an amazing technology. I mean, invented it as a means of addressing concerns of mixing sources, which a solar system is a source, loads together because that's a complex thing. And we can't just rely on the simple methodologies of circuit breakers that we have today to address that issue. Power control systems are really the key to preventing damage to circuits on a branch circuit or other circuits and switch gear or handle boards in a house or a building. So understanding a little bit about power control systems is critical to this entire conversation. And without that, people would come up with the idea, well, you'd have to have a dedicated circuit or things like that, which if you didn't have power control systems might be a logical answer. And then we had this issue of bidirectionality of GFCIs. So we've been talking about GFCIs for a very long time as they relate to trying to push power into a circuit and how that might affect the circuit. Years And ago we found issues with certain types of GFCIs where they could get damaged under certain conditions with the products that were around twenty five years ago. What has not been done recently is a detailed study of existing products and existing products that are in people's homes and the existing devices that would be used in PIPV systems to see how compatible those things are. So we have devices that are in your house that are circuit breakers that have GFCI capability. We have receptacles that are GFCI devices, and those are part of the testing of 3,700. So if somebody comes up with a product, they're going to have to prove that they can be installed and plugged into any device that's on the market today without damaging it. Typically these devices haven't been tested for bidirectionality, but they could be tested as part of 3,700. Also, it's likely that the device itself will have its own GFCI bidirectional capability for additional protection. And so it's not unlike, are you familiar with RVs and various power cords that are used for construction that have GFCIs built into them. And so you can build a GFCI into a pluggable device and things like that. So these are all issues that have to be dealt with. So it's not that they're going to be pooh poohed or pushed to the side. They're front and center. They're well known issues. We've been talking about those issues for literally twenty five years, and so they're not surprises. They're not like, oh, here's a new thing. They're well understood and well known, and there was another issue. You had three issues. What was the third issue? I missed it.

[Rep. R. Scott Campbell (Vice Chair)]: Let's see. A specialized plug in in terms of

[Rep. Michael "Mike" Southworth (Member)]: Touching plug.

[Bill Brooks (Brooks Engineering)]: Yes. So current the current version of 3,700 does require a specialized plug. Okay? But that is not necessarily a requirement of having a safe PIPV system. It is a requirement of the current 3,700. But it's extremely likely and if because I will be involved I will certainly be working toward doing the testing and requirements related to allowing a standard three prong NEMA 15 amp plug to be used safely because it's all about touch safety. Okay and just as an example and this may become part of the standard may not. Every pluggable UPS, uninterruptible power supply that is used for computers, every single one on the market today goes through a goes is tested to a standard. And that standard when when you if you were to inadvertently disconnect a UPS from the wall from your wall outlet in your office, That plug can remain energized for up to one second. So there is fundamentally actually no difference whatsoever between a pluggable UPS, of which there are millions in The United States, and everybody's not concerned about the safety of those devices. And we don't hear about people getting shocked from plugs from UPSs. It just doesn't happen. And so that standard has been successful. But those devices do remain energized in the exact same way that a device like this could remain energized. Whether it's one second, whatever the rules are, again, that has not been determined yet in the standard right now. To be exceedingly, I would say safety conscious. The first version of 3,700 said, well we're not going to cross that bridge yet. We're going to require a specialized plug and that specialized plug would require that the unit be shut down before you would remove it and would be specialized so you couldn't interchange it and that's certainly a great way to start and and that that kind of sets the stage for the kind of issues that you have to address moving forward so that people don't get shocked.

[Rep. R. Scott Campbell (Vice Chair)]: Okay. I have one follow-up and then I know they're right. And then my follow-up is back to your power control systems. Sounds like that deals with any overcurrent problem that we heard various presentations about. Is that accurate?

[Bill Brooks (Brooks Engineering)]: Yes. Power control systems absolutely deal with overcurrent.

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

[Bill Brooks (Brooks Engineering)]: the entire reason for it.

[Rep. R. Scott Campbell (Vice Chair)]: Right. Even though we heard presentations in the middle of graphics and all that about how a solar panel can sort of bypass the circuit breaker and and and put more more amperage into a wire than it's it's it's rated to carry, We shouldn't worry about that. It's covered by UL 3,700.

[Bill Brooks (Brooks Engineering)]: That is correct. It's kind of, I guess, fun to hear when people use the term circuit breaker masking. You might hear that term. I invented that term. It's it's kind of fun to hear people use terms that I've invented. And because the the rules related to how we interconnect permanently wired systems into houses have to deal with the same exact issue. Okay, so we have to make sure and those are generally going on what we would call a dedicated circuit. And so but at the same time, we can interject so here's here's a comparison. What's completely allowed today in the National Electrical Code and your electrical code is that we can interject a photovoltaic system into a what's called a feeder. A feeder in a house is coming off a circuit breaker in your main panel going to a sub panel. So that's called a feeder. And so we can actually interject power into that circuit and then we have to worry about breaker masking for the feeder breaker that's protecting that conductor. And so the code says, and I I wrote this in the code. It was my design. For the connection that is downstream away from this from the electrical panel toward the subpanel, you have to reestablish overcurrent protection for the downstream conductors because you have two sources now, right? You have the main source coming in from the feeder breaker, and then you have the solar coming in from here into that. And they can the streams combine, and they go to this subpanel. So you have to then re protect the wire with an overcurrent device at the load side of that connection point, and that protects everything downstream. Okay? So that's in the code for feeders. And so that's the same and also another way to do that is not necessarily an overcurrent device, but power control system. So the power control system monitors the current coming from the feeder breaker, the current coming from the solar. And if the current coming from the feeder breaker and the solar adds up to more than the rating of the conductor, it just backs the solar off. Okay? So the the the passive feeder breaker still is allowed to do its job. So these are the things that are done on a feeder level and can easily be done on a branch circuit level as well.

[Rep. R. Scott Campbell (Vice Chair)]: Okay. I know Madam Chair had a question also and then, for the software as well.

[Rep. Kathleen James (Chair)]: No, I'm gonna turn it over to Rick Southworth.

[Rep. Michael "Mike" Southworth (Member)]: So I just kind of want to bring this down to a little bit easier level to understand for me, for us.

[Rep. Kathleen James (Chair)]: What? I'm very disappointed.

[Rep. Michael "Mike" Southworth (Member)]: You're saying the power control system is built into the PIPV, correct?

[Bill Brooks (Brooks Engineering)]: Yes. I believe that as products come onto the market, they're all gonna have some type of power control system capability in them.

[Rep. Michael "Mike" Southworth (Member)]: And that is a requirement under UL 3,700?

[Bill Brooks (Brooks Engineering)]: It's it's it's a requirement under the National Electrical Code. So when when UL writes a standard, they write standards that are commensurate with and compatible with the National Electrical Code. So with the code that we have today, the only way to truly comply with the code in anything other than a dedicated circuit. So we heard that that term earlier. We could use a dedicated circuit and comply with the code. But how many people have a 15 amp dedicated circuit in their house? The answer is not very many. So In order to connect to what we call a general purpose branch circuit, which can include multiple receptacles and lighting and things like that, we have to have power control.

[Rep. Michael "Mike" Southworth (Member)]: Okay. Along with that, if this power control system is built into the PIPV, it is plugged into a branch circuit, theoretically it is supposed to and I'm just this is where I get caught up. Is it going to sense the amount of load before it allows the power to go in from the panel into the branch circuit?

[Bill Brooks (Brooks Engineering)]: Yes.

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

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

[Bill Brooks (Brooks Engineering)]: So one one way to do this, and again, I'm I'm an innovator. I don't have any patents because I've I I litigate patent cases, and I know how hard it is to hold a patent. But I I help companies that work on patentable things. And and one thing you could do is you could actually develop an outlet or a receptacle, we call it in the code, or a receptacle. We can develop a receptacle that has all the power control system sensing devices inside it, maybe even an overcurrent device inside of it. Okay? And we could pull out a GFCI that maybe didn't have the proper ratings or whatever. We could pull that out and we could install this device. And it could sense all the load going downstream of it away from the panel so that the current on the branch circuit going down to it, where we have these two streams that I just talked about, two streams of power coming together, can never provide enough current to overcurrent the downstream conductor. So that's an example. Now, course, that would require removing a receptacle. And that may not be necessary in all cases. So you may come up with a technology that actually is able to do this remotely through the device. Again, we're going to see some really cool innovation out of this whole thing. And one of the reasons that we developed this power control systems idea was just to see where human innovation would go in this area. And it's it's really been mind blowing to see how technology and manufacturers have come together with the safety standard to develop some really, really amazing products that nobody ever thought of before. So, yeah, that's that's one example of how you could do that.

[Rep. Michael "Mike" Southworth (Member)]: So with without a power control system, there is still a chance of an overcurrent occurring. Correct?

[Bill Brooks (Brooks Engineering)]: Well, if you exceed the ratings of the conductors, is possible. So one of the things that we're looking to put it, so I've written a what's called a public input or a proposal for the 2029 National Electrical Code, which would allow for small systems of around three fifty to 400 watts to be plugged into one branch circuit on one general purpose branch circuit on per house, only one. And we can show that that about in that three fifty to 400 watt range, is physically impossible to overcurrent the downstream conductors, which is what we're worried about. And the reason for that, I don't want go into all the details but it has to do with all the the methodologies we use to connect to feeders and things like that. The main breaker has to be de rated for how much current it's allowed to run through it to 80% of its rating. So a 15 amp breaker can handle 12 amps continuous. So we can interject another three amps into that same conductor for downstream conductors, and the conductor itself is rated for 15 amps. And it is physically impossible to overcurrent that conductor at three amps. Okay, anything higher than that, and again, this is gonna get deliberated in the NEC process, and I'll be representing that. Anything that goes higher than that, we go to PCS. So so that's something that's gonna be kind of a a foundational thing. You can plug one of these things in. You can't plug more than one of these things in. Anything more than that's gonna be PCS.

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

[Rep. Michael "Mike" Southworth (Member)]: be 1,200 watt panels?

[Bill Brooks (Brooks Engineering)]: It could go up to 1,200 watts, which is actually pretty large. I don't know whether you know how big a solar panel is, but a 400 watt solar panel is approximately a little over three feet by five feet. Okay. So that's a pretty big panel. And so you'd have to have three of those to make 1,200 watts. And that's I believe is that the that's the threshold that's in the Vermont bill?

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

[Bill Brooks (Brooks Engineering)]: Okay. And so but if you had a 1,200 watt system, unless it was on a dedicated circuit, as pointed out earlier, you would have to have PCS to make this work. There's just no other way to do it. Great. Thank you.

[Rep. R. Scott Campbell (Vice Chair)]: Okay. You mentioned that National Electric Code, and so what I heard from what you said was UL standards, did I need to reference the National Electric Code because UL standards must comply with NEC.

[Bill Brooks (Brooks Engineering)]: That's correct, that's correct. It's kind of a general rule because these products are interfacing with the electrical code in one shape or another. It would be foolhardy for them to develop a standard that was in conflict with the NEC, and so they're usually pretty conservative if you will in their interpretations of the code and what they would allow to go through a product safety standard.

[Rep. R. Scott Campbell (Vice Chair)]: Sure. And how about IAAA fifteen forty seven? There was another standard that was mentioned along the way. Is that also covered 5,700?

[Bill Brooks (Brooks Engineering)]: Yes. IAAA fifteen forty seven, but I should change their name to IAAA. That sounds better to me. IAAEE fifteen forty seven is basically the IAAEE standard that UL seventeen forty one uses as the interconnection requirements. And so I helped develop the rules that went into IEEE fifteen forty seven, which are all the specific interconnection limits and frequency and voltage limits anti aliasing all that's in fifteen forty seven and then document fifteen forty seven point one is a a test standard and then UL seventeen forty one adopts fifteen forty seven point one and associated grid support stuff. So we have Supplement A and Supplement B that go along with that are part of seventeen forty one that are addressing the specific issues in IEEE fifteen forty seven.

[Rep. R. Scott Campbell (Vice Chair)]: Okay. So I think what it sounds like is that what we need to cover in terms of safety for our residents if they're going buy these things is that they comply with UL 3,700 if they're larger than what is it three ninety one watts. Otherwise they don't need to comply. That true? No,

[Bill Brooks (Brooks Engineering)]: no, that's not correct. So just a fine point on that. The three ninety one number which I put together as a commensurate number to the 800 watt German number, which is what they use in Germany, it's just translating that number to US voltages and currents. That is that threshold that I was talking about under which you do not have to have power control systems. Right. That's all. Everything else about the standard is critical. Utility connection critical, Touch safety critical. Bi directionality of GFCI critical. So these are all things that have to be tested and proved in the 3700 standard. Size can be like, okay, you can have a system. For instance, here's here's an example of how it might go. And again, this is all just kind of dreaming about the future, which I like to do. You have a you have a 360 watt panel or something like that, something under three ninety one. And it's it's got PCS built into it, but it it doesn't have any PCS hardware to interact with to so you plug that in and it works. Okay. Fine. But what it's doing is it's sending out a pulse, and we do things called power line carrier. And so it sends out a pulse and says, is anybody else out there? And if nobody responds and nobody else is out there, he says, oh, okay. I can run because nobody else exists. I'm the only one here. And then then they go, you know, this is really cool. I'm gonna go buy another one. So they go in and they plug it in to their house, and it does the same thing. It goes, is anybody out there? And it goes, yep. I'm over here. And they go, well, wait a minute. I can't run with you unless I have a concert master called the power control system that says that it's okay for both of us to run. Okay, so now that goes, well, wait a minute, where's my concertmaster? And so then they install concertmaster and they go, oh, okay, now I know where I am at. I know that I'm not going to overcurrent anything. And so now I can operate. And so then I can plug in another one and another one up to 1,200 watts. And so

[Rep. R. Scott Campbell (Vice Chair)]: Is that concert is that concert master integral to each of these panels that passes the, UL 3,700?

[Bill Brooks (Brooks Engineering)]: If If it was a product that was designed to be installed in more than one, yeah, that's where I believe this is my interpretation of the future. The initial products that are going come on the market, I believe will all have power control systems and all require power control system to function whatsoever. So unless they have a concertmaster, they're not going to run. And so the question is, would there be because of the things we're deliberating about in the NEC and will eventually deliberate on in 3700, would there be a time where we could actually plug a device directly in and it not have to look for a concertmaster? And so I don't believe that that's currently possible in the 3700 unless well, there's another thing about 3700 that we need to talk about. And that is with all UL standards, when when you buy a product, it has installation instructions. And those installation instructions are required to be followed by the consumer or the installer, whoever's using the device. And if you violate those installation instructions, then all bets are off on the safety and operation of the product because that's not how it's certified. And so there there's these are stipulations and so it could say what kind of outlet you can plug it into, whether it would have to be a dedicated outlet or not, and you know the type and size of the outlet all that kind of thing. And it's similar to I use the analogy of a hair dryer, a blow dryer in your bathroom. So any outlet in your bathroom for a house that was built after 1968, something like that has to have a GFCI outlet in it within six feet of a sink. Okay, so your house is going to have a GFCI outlet. So if you go out and buy one of the original blow dryers, it's going to tell you in the instructions, you must plug this into a GFCI outlet. Can't use it any other way. That way, this idea of how to murder somebody where you plug in your hair dryer and throw it in the tub can't happen because the GFC aisle is gonna trip. So it foils the the murderer with the the the, you know, the hair dryer. So yeah. Well, so it turns out we have houses that were built before 1965, and you have plenty of them in Vermont, right? So most hair dryers, in fact, all hair dryers that are on the market today have a GFCI device built directly into it, right? It's got the little plug and it's got a little red button and a little yellow button on it. And that's the GFCI. So foiled again. You know, I'm in an old house and I I still can't murder this person with the hairdryer. So and so that's so the safety standard is acknowledging the existing wiring of the house and building a product that's safe for inner inner interacting with that house. And that's the same same thing, essentially that we're dealing with here with these plug in devices.

[Rep. R. Scott Campbell (Vice Chair)]: Okay. I have one last question about UL standards. The does the 3,700 have any reference or any requirements about mounting these things so that they don't blow around in the wind?

[Bill Brooks (Brooks Engineering)]: Yes, yes. So again, back to the installation instructions. So a lot of people thrown around the term balcony solar. I don't like the term personally because, you know, balconies are not as common in The United States as they are in Europe with a lot of high rise, living, but we certainly have it. Absolutely. And so if you were, for instance, wanting to set this out on your lanai, I like that term better than balcony. It's Hawaiian. Yeah. If you're gonna put this out on your balcony, then if it were if it were a fully portable unit, you say, you can you can set it out there and bring it back in, set it out there, bring it back in, do whatever you want. If you wanna put it in permanently, well then here's all the rules if the product is allowed to be mounted permanently, here's all the rules that you'd have to follow in order to mount it permanently. And so we have we have mounting structure standards, it's UL 2,703, which is also called up by three thousand seven hundred. It says if you're going to use mounting hardware to mount this device, then you have to follow these test standards and these structural concerns have to be addressed, and they have to be in the installation instructions that tell people how to do that correctly. If you're not going to, you can say, tell people, you cannot permanently mount this device. It could be something that you just, it's on wheels and you wheel it outside during the day and you bring it in at night or whatever, Or you know it's designed to be put in your backyard and there's a device that fastens it to the ground or maybe a screw anchor that holds it in and keeps it steady. Whatever is intended to hold that device in place would have to be in the installation instructions and the customer would have to follow them. If somebody buys one and just hangs it off the side of their balcony, it'd be not unlike somebody putting a 20 or 50 pound flower pot on the corner of their balcony railing, and whoopsie, it falls off and kills somebody 10 stories down. You don't you know, that's that's irresponsible for the person to put the flower pot there in the first place. It's against regulations. Nobody's allowed to do that, and somebody did it. So can people break rules?

[Rep. R. Scott Campbell (Vice Chair)]: Well, yeah. I mean, so that so that's guess the question is, are there, are there, requirements about M3700 about how you deploy these? Can you just prop it up against the side of the house with no, with no, no mounting at all? Is that is that allowed? Is it in in It

[Bill Brooks (Brooks Engineering)]: would depend on what kind of product it was. So there are plenty of portable solar panels that you just actually unfold. I've got one. It unfolds like an accordion, and it weighs five pounds, and you can lay it on the ground. You take it camping with you, whatever. It doesn't require permanent installation. And then when you're you're done with it for the day, you fold it up and you bring it back in. So there's nothing wrong with having a product like that. And if that's how it's intended to be used, that's fine. But if you were to take it to the step of saying telling people that, you know, so so the installation instructions are going to confine the methodologies in which it can be used. Okay? Yeah. And so if somebody goes beyond that, then that's their liability. Not it's not a pro it's not on the product manufacturer's head that somebody did something crazy. It's like, you you remember hearing the stories about people picking up a a push mower and trimming their hedges with it? And and somehow they got hurt. How could that happen? You know, it's like so they had to put in the in the installation instructions. No lie. If you look in the installation instructions for a lawn mower, a push mower, it will tell you not to pick that thing up and use it as a hedge lever because somebody needed to hear that. And so so yeah. So that's the kind of things from a product liability you have to put in to say, hey. Listen. We haven't designed our system to mount to a balcony, And we don't want the liability of somebody mounting this to a balcony and hurting somebody. Okay. Well, that's that is a decision by the manufacturer to omit that particular installation technique for liability purposes.

[Rep. Kathleen James (Chair)]: Great. You. Oh, yeah. Real softwares? No. Please.

[Rep. Michael "Mike" Southworth (Member)]: Go ahead. I just have one question. I don't know the answer, so I'm asking you. In our bill, it says systems complies with UL solutions or an equivalent certification by an equivalent nationally recognized testing laboratory. My question is, will they have to create their own standard at that point or will they utilize UL 3,700?

[Bill Brooks (Brooks Engineering)]: Yeah, I kind of see that language is kind of redundant and somewhat unnecessary. But like I said, UL has been tasked by the federal government to write standards in this particular area. So it doesn't mean that a Met Labs, which also is a nationally recognized testing laboratory or Intertek couldn't write their own standard. The challenge would be what makes their standard better, different, whatever than the UL standard. And so generally, way it's worked for my entire career is that UL writes the standard and people certify to that standard. So though it's an out, so it's an outline investigation, it's published. Intertek or CSA or Metlabs, which are all allowed to test to UL standards, would certify a product, but they're going to choose to use the 3,700 standard. There is a certain amount of liability involved with writing your own standard and that's why UL is very, I would say safety conscious in their initial offering of a standard so that it doesn't it's obvious that it addresses the safety issues and then what they do is they put it out to the stakeholders in the community and we have an ANSI process, American National Standards Institute process that brings together various parties distributed evenly over a variety of stakeholders and we take that standard, and we work on it, and we revise it with vote on any changes we would make to that standard over time. And as I said, we get additions over time. And so that's the way standards live. So they normally start out conservative, if you will, and very tight in their safety requirements. And then as we understand more about it, it's not that we're loosening safety. We're just allowing more options to be safe within that confine. And so I have not found that CSA, Intertek, or Met Labs have ever decided to go off on their own and make their own standard. It just doesn't work that way. They don't do it. And they rely on the UL standards. There's a lot of effort and work that goes into it. That's another reason they don't do it because it takes a lot of resources in order to write a standard. Then once we get into this larger community standard and then turn it into an ANSI standard, they're then both standards, now it has been reviewed by a much broader group of folks and usually has some more options for application.

[Rep. R. Scott Campbell (Vice Chair)]: I think the reason why that or equivalent language is included is because we don't like to reference one particular company in statute.

[Rep. Michael "Mike" Southworth (Member)]: That's right

[Bill Brooks (Brooks Engineering)]: and in this particular case it's it's fine by the way I have no problem with Because the federal government has tasked UL with this, it is a territory issue. But to that statement, federal mandate or whatever, TUL, does not prevent other people. So I think there's nothing wrong with the language. And really, where it came from, I believe, was the Utah legislation, which predated 37 by quite a lot. And so there was a concern that if UL doesn't come forward with a standard, then Intertek could write their own standard. And they are OSHA approved nationally recognized testing laboratory, and they could fit the bill too. But now that we have 3,700, it's a bit of a moot point.

[Rep. Michael "Mike" Southworth (Member)]: I was just trying to see if we would be having to look for another version of UL 30 Thank you.

[Rep. Kathleen James (Chair)]: Bill, thanks so much for joining us. I just, we'll let you go, but I just wanted to try to briefly I just wanna make sure I was listening and taking notes. And I am just gonna and it can be a brief answer. I'm just gonna go back over a list of things we had from all the testimony we've taken. There was a list of things that different people told us, oh, you gotta put this in the bill. And what I heard today was that all these things are covered in one way or the other by 3,700. So I just want to recap what I think I heard is that a requirement for a dedicated circuit, a requirement for a specialized plug to satisfy touch safety, a requirement for bidirectional GFCI, and a specific mention of UL seventeen forty one, a specific mention of IEEE fifteen forty seven, a reference to the NEC and mounting requirements are all covered by requiring compliance to UL 3,700.

[Bill Brooks (Brooks Engineering)]: That's correct. The issues that are behind all those concerns are covered in And 3,007 that's why you do not want to have those details in a legislative bill. And just as an example of that laundry list that you just mentioned, if you were to put in your bill that it required a dedicated circuit, then that would fundamentally hamstring the technology in a way that was inappropriate because we have power control systems. And so because of power control systems, requiring a dedicated circuit is completely unnecessary. So that's why it's important not to have those kind of languages in bills because you rely on the safety standard. And in this case, sometimes when Utah wrote their bill, there wasn't the standard for them to look at. But now we have one. It's in writing. And so it's not a question of whether or not the standard might address these issues. And we have to worry about them because they don't know what they're doing. It's in there. And so that's that's something that, know, one of the benefits of not being the first on the block is being able to take advantage of what's already been done.

[Rep. Kathleen James (Chair)]: That is so helpful. I think we have two more quick questions.

[Rep. Michael "Mike" Southworth (Member)]: Bill, you mentioned the 80% low factor on a breaker being rated for 15 amps continuous current. And then you mentioned the power supply, backup power supply for the computer. You say it can remain in touch potential for a minute or did you say sixty seconds?

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

[Bill Brooks (Brooks Engineering)]: One second.

[Rep. Michael "Mike" Southworth (Member)]: One second. 60 cycles.

[Bill Brooks (Brooks Engineering)]: That's correct. Okay. And so if if you can pull it out of the wall and touch it to your tongue in less than a second, you might get shocks.

[Rep. Michael "Mike" Southworth (Member)]: Okay. Alright. So continuous current and a time current curve, where's that continuous current? Is it out at a second, or is it out longer than that for

[Rep. R. Scott Campbell (Vice Chair)]: 15 ampere The

[Bill Brooks (Brooks Engineering)]: term being continuous in the National Electrical Code is three hours. Great. Thank you.

[Dara Torre (Clerk)]: Okay. And I just wanted to also echo what I think I heard, which is that the fact that we have old housing stock in Vermont and some electrical wiring might not be modern. That doesn't require anything in our legislation beyond the UL 37.

[Bill Brooks (Brooks Engineering)]: That's that's correct and so for instance and and that's where the National Electrical Code comes in because every house has been built according to whatever code was available at the time and so when we look at applying the code to something that goes back in history, like any directly connected, permanently wired photovoltaic system, we have do the same thing, right. So we have to address all those issues. It doesn't matter how old the house is. Okay. And so a house that predates GFCI's for instance, actually is a simpler case for us. Because we can have our own GFCI on our device and we don't have to worry about interfacing with somebody's GFCI. The most complicated is going to be older GFCIs and making sure that anything we do is compatible with those older GFCIs. Or there may be a requirement that says, well, these specific older GFCIs, they would have to be removed. You'd have to replace them. The good news about GFCIs is they don't last all that long. And so it's a pretty common thing for GFCIs to fail and need to be replaced. And when they fail, if you're familiar with this, if you ever had one fail on you, and I've had many over the years, they don't work. Just don't work. The button and it just doesn't work, and it's like, darn it, I gotta go get another GFCI.

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

[Dara Torre (Clerk)]: And the other reason to not have the items spelled out separately is that the standard evolves over time. You That's reference it once in the statute and let it evolve the way it's going to and not have some big pieces.

[Bill Brooks (Brooks Engineering)]: Exactly. And it's going to become more and more robust over time. Again, start out is a pretty confined set of requirements that says here's you got to do this. And then it goes, well, we've done all this testing. We've done all this research. We now know that you can go to here. And then now we can go to here. And then now we can, know, so so now you have a product that says, hey, you can plug as many of these things into your house as you want. It's fine. But when you hit 1,200 watts, they don't work anymore. You know, so it's like, have on at it, you know, whatever the situation is. So I mean, can could somebody take a power strip and plug a whole bunch of of plugging devices into it? The answer is absolutely. And will they? I'm sure they will. And so but there's all kinds of things that we can do to our house that attempt to kill us. So that's why we have instructions, and that's why we have rules, and we have regulations, and things like that. And at the end of the day, we cannot prevent somebody from a Darwin Award. Those get handed out on routine basis.

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

[Rep. Kathleen James (Chair)]: was really, really helpful. Yeah. We did need that.

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

[Rep. Kathleen James (Chair)]: you, Bill. I

[Rep. R. Scott Campbell (Vice Chair)]: really appreciate it. Thank you. You have

[Bill Brooks (Brooks Engineering)]: a wonderful day.

[Rep. Kathleen James (Chair)]: Alright. Thank you. Alright. And we are