PUC recommends simpler 'single plant' test to limit aggregation of colocated renewables

The Public Utility Commission recommended a narrower, easier‑to‑apply statutory definition of "plant" to the House Committee on Energy and Digital Infrastructure on Jan. 9, saying the change would simplify eligibility determinations for net metering, the standard offer program and renewable energy compliance.

"This definition principally functions for 3 different types of renewable energy programs," said Steph Hoffman, general counsel for the Public Utility Commission. Hoffman told the committee the proposed test treats installations on the same or contiguous parcels that use the same generation technology as a single plant, and otherwise as separate plants.

The distinction matters because two incentive programs have capacity caps the PUC uses to limit ratepayer exposure: the standard offer program is capped at 2.2 megawatts and the net‑metering program at 500 kilowatts, Hoffman said. Under the PUC proposal, colocated arrays that share a single point of interconnection or other infrastructure could still be treated as separate plants if they have separate interconnections and are outside those incentive programs.

The PUC built exceptions into the proposal to avoid unintended consequences for small residential systems and multi‑owner residential developments. Hoffman said the draft seeks to "not prohibit neighbors from developing solar" and to allow separate billing meters in duplexes or similar multi‑unit housing to participate individually in residential net metering.

During committee questions, members pressed whether shared transformers, distribution‑line upgrades or other shared equipment would automatically aggregate projects. Hoffman said the existing statutory test requires an often onerous historical inquiry into continuity of construction, ownership and shared equipment; the PUC's recommendation uses the simpler contiguity + same‑technology test to reduce that burden.

The PUC submitted its recommended definition and supporting report to the committee as part of the record and the staff said the proposal followed multiple workshops and written comment rounds with developers, utilities and agencies. Representative Kathleen James and legislative staff noted sponsor Brett Campbell had filed legislation to move the PUC's single‑plant language forward.

Committee members can expect the PUC report and the proposed statutory language to appear in the bill text; if enacted, the change would alter how projects are grouped for program eligibility and could affect whether colocated arrays can be treated as separate projects for incentive caps.