Committee weighs SB 228 to expand community solar access for low‑ and moderate‑income residents; utilities warn of billing complexity

Senate Energy and Natural Resources took public testimony on SB 228, a package of changes to New Hampshire net‑metering and community solar rules intended to expand access for low‑ and moderate‑income customers and public entities.

Sponsor Senator David Waters (District 4) said the bill updates statutory size thresholds and eligibility to attract more investment to community solar. Key changes discussed included raising the definition of small customer generators from the existing threshold to permit systems up to 500 kilowatts, increasing community/low‑income community solar project caps up to 3 megawatts, and allowing group net‑metering members to sign agreements with multiple group hosts.

Supporters — including Lindsey Burgoyne of Revision Energy, Malcolm Bliss of Kearsarge Energy, Jack Ruderman (New Hampshire Housing), and others — said bigger project caps and flexible subscription rules will improve economics and enable more low‑income residents to participate. New Hampshire Housing described plans tied to the federal Solar for All grant (the hearing record cites a $43.5 million federal award to the state, of which New Hampshire Housing expects a $23 million subaward) to develop community arrays that serve low‑income housing, and said larger project caps improve economies of scale.

The Department of Energy indicated neutrality but raised administrative concerns tied to program design, recordkeeping and accounting. DOE counsel Matt Young said changes that would let customer generators become group members could complicate energy accounting and risk “double dipping” unless safeguards and rules are clarified; he also noted ongoing work on new net‑metering rules (referred to as the department’s “900 rules”) that overlap with the bill.

Utilities flagged billing and staffing implications. Griffin Roberge (Eversource) testified that current billing systems are not set up to automatically track simultaneous on‑site exports and multiple off‑site subscriptions; utilities would need manual processes or system upgrades and that would increase administrative costs borne by ratepayers. Revision Energy and other developers urged tailored statutory language and technical rule changes to prevent unintended exclusions (for example, language in the current draft that changes “households” to “homeowners” might exclude renters from low‑income programs).

Why it matters: supporters say modest statutory changes will expand access for low‑ and moderate‑income customers, improve project economics and let Solar for All federal funds go further. Opponents worry about administrative complexity and utility billing impacts unless the statutory changes are paired with clear rules and systems upgrades.

What to watch: bill language about whether low‑income eligibility refers to homeowners versus households, whether special‑purpose districts and public housing authorities remain eligible as municipal hosts, and whether the Department of Energy’s pending net‑metering rules (the “900 rules”) address the same issues. No committee vote was reported at the hearing; sponsors and DOE said they would continue to work on fix‑it amendments.