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Comments Requested In Annual Residential Renewable Energy Solutions Program Review – Year 5

Dockets: 25-08-02

From Notice:

[ *** ] To facilitate the Authority’s evaluation of the RRES Program, the Authority requests that docket participants and interested stakeholders file written comments on or before 4:00 p.m. on Tuesday, September 16, addressing the following:

  1. 2026 Rate Setting [ *** ] The Authority invites stakeholders to provide legal argument and comments regarding options to achieve both statutory objectives for projects in 2026, given the upcoming changes to federal investment tax credit (ITC) eligibility. In particular, the Authority seeks comments on the following: A. Whether the Authority may, within its statutory authority, implement a positive renewable energy certificate (REC) rate for the netting tariff in addition to the required nonbypasssable charge, if the netting tariff with the required nonbypassable charge alone would not provide a reasonable rate of return on average costs of installation. B. Whether the statute governing rate setting allows for any alternative options to set residential tariff compensation rates. C. Any recommended safeguards to balance participant costs and benefits with costs and benefits to non-participating ratepayers.

    2. 2026 Rate Setting – System Ownership

Beginning in 2026, homeowner-owned residential solar projects will no longer be eligible for the ITC, while the commercial ITC will continue to be available for third-party owned systems placed in service by the end of 2027. Accordingly, the Authority seeks comments on the necessity and feasibility of distinguishing RRES compensation rates based on system ownership to generate a reasonable rate of return for both homeowner owned and third-party owned projects.

3. Program Manual Updates

Order No. 1 of the October 16, 2024 Decision in Docket No. 24-08-02 (Year 4 Decision) directed the EDCs to file annually, by August 1, the Program Manual and other resources for residential utility customers and/or renewable energy contractors to explain the technical, administrative, and procedural requirements of the RRES Program. Accordingly, the Authority requests written comments on the proposed Program Manual and other RRES Program documents, as filed in Motion No. 6.

4. Application Fees

Order No. 2 of the Year 4 Decision directed the EDCs to file, by August 1, a proposed application fee to cover the estimated administrative costs associated with processing applications. Year 4 Decision, p. 28. On August 1, Eversource filed its proposed application fee in Motion No. 2,3 and UI filed its proposed application fee in Motion No. 5. Consequently, the Authority requests written comments on the EDCs’ proposed application fees.

5. Metering diagrams

Order No. 7 of the Year 4 Decision directed the EDCs to review and update their meter wiring diagrams and guidelines no less frequently than August 1 annually and to submit the revised documents in the appropriate Annual Review docket. Year 4 Decision, p. 30. Accordingly, the Authority requests written comments on the proposed meter wiring diagrams, as filed in Motion No. 4.

6. Contractor filing requirements

In response to the Authority’s June 24, 2025 Notice of Request for Written Comments regarding contractor filing requirements, the Office of Education, Outreach, and Enforcement (EOE) filed comments regarding Topic #2, Contractor Filing Requirements. Specifically, EOE suggested that: (1) that solar contractors should be required to provide customers with financial and production documentation as part of the initial sales process, not only after the customer signs a contract; (2) approaches for calculating financial costs and savings and production should be standardized across installers and provided to customers in a pre-contract disclosure document. EOE also provided suggestions for how to standardize such calculations. 

In addition, on November 20, 2024, the Connecticut Solar and Storage Association (ConnSSA) filed Motion No. 54 in Docket No. 23-08-02RE01 requesting that the Authority direct the EDCs to add six new fields to the RRES PowerClerk application.

Accordingly, the Authority requests comments on EOE’s suggested financial calculation methods and proposal for a pre-contract disclosure document, as well as ConnSSA’s recommendation to add fields to the PowerClerk application.

7. Skipped Production Meter Installation

In Written Comments filed on July 15, 2025, the EDCs stated that 5,738 systems in Eversource territory went online without a production meter, of which 52% now have the production meter installed. In UI territory, 5,670 systems went online without a production meter, of which 23% do not yet have a production meter installed. Tech Mt’g Tr., July 23, 2025, 20:19-23. The EDCs note that “customers are still trued-up for all incentives once the meter is installed and RECs reported, but further incentives will not be paid to these customers and the renewable generation produced by their PV systems will not be reported until production meter installation steps are completed.” EDC Comments, July 15, 2025, p. 5. The EDCs also noted that it is the solar installer’s responsibility to ensure that a production meter is ultimately installed. See Tr., 37:3 – 39:5. 

The Authority invites comments on what further steps should be taken to address RRES projects with outstanding production meter installations, including any potential penalties for solar developers with a high number of outstanding production meter installations.

8.  Annual Program Reviews

The Authority seeks stakeholder comments on whether and how the annual review process should be streamlined for the remainder of the RRES Program term. In particular, stakeholders may suggest docket process changes, compliance orders that could be simplified or eliminated, or other ways to simplify the annual review while ensuring the Program can continue to achieve its objectives. [ *** ]

Notice (09/02/2025)
25-08-02 (10/30/2024)  
(Annual Residential Renewable Energy Solutions Program Review – Year 5)