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Excerpts from Ford Petition:

“Ford Motor Company (“Ford”) respectfully petitions the Public Utility Commission of Texas (the “Commission”) to issue a declaratory order affirming Ford’s interpretation of the Commission’s rule at 16 Texas Administrative Code § 25.211 that installation by a retail customer of a Ford Home Backup Power system does not require an application for interconnection and parallel operation of on-site distributed generation, nor does such installation of a Ford Home Backup Power system require the customer to execute an interconnection agreement with the local utility, because the Ford Home Backup Power system cannot operate in parallel with the utility distribution system.”

“This proceeding arises from Ford’ s and its customers’ experiences with some distribution utilities that have sought from the customer an application for interconnection and parallel operation of a Ford Home Backup Power system even though the Ford Home Backup Power system cannot operate in parallel with the utility distribution system. Issuance of a declaratory order in response to Ford’ s request will provide clarity and ensure that customers can install Ford Home Backup Power systems quickly and efficiently, to promote greater reliability for the customer. A live controversy exists because at least one utility that owns and operates distribution facilities in Texas requires customers to submit an application for interconnection before the customer can install a Ford Home Backup Power system in that utility’ s service area. Issuance of a Commission decision as requested in this Petition for Declaratory Order will wholly resolve and settle the controversy, to the benefit of customers anywhere in Texas who wish to promote reliable electric service for their homes and families.”

“Under the Commission’ s rule governing “Interconnection of On-Site Distributed Generation,” 16 Tex. Admin Code § 25.211, “to interconnect distributed generation to a utility system, a customer must first submit to the utility an application for interconnection and parallel operation with the utility system and execute an interconnection agreement on the forms prescribed by the commission.” The Ford Home Backup Power system uses the battery in a Ford F-150 Lightning pickup truck to provide power to the Ford F-150 Lightning owner’ s residence during a grid outage. Because the Ford Home Backup Power system could, like a conventional gas-powered home backup generator, generically be considered distributed generation, a question has arisen regarding whether the requirement to apply for interconnection and parallel operation applies to customers proposing to install a Ford Home Backup Power system in their home. At least one ” utility has said the answer to that question is “yes.”

“Ford believes the right answer is “no.” Thus, Ford seeks clarification, in the form of a declaratory order, from the Commission that an application for interconnection and parallel operation cannot be required, nor can an executed interconnection agreement be required, because the Ford Home Backup Power system cannot operate in parallel with the utility system.” 

“Ford is not seeking an exemption. Rather, Ford simply seeks clarification of what it believes the rule at 16 Tex. Admin Code § 25.211 provides-that a home backup power source that does not and cannot operate in parallel with the utility system is not “on-site distributed generation” as defined by the rule and needs no “interconnection” as defined by the rule, because of the lack of parallel operation.”

“Ford respectfully requests that the Commission enter an order declaring that a customer proposing to install a Ford Home Backup Power system need not make application, and a utility cannot require such an application, for interconnection and parallel operation under 16 Tex. Admin. Code § 25.211, nor may a utility require the customer to execute an interconnection agreement, because the Ford Home Backup Power system cannot operate in parallel with a utility system.”

Petition for Declaratory Order (12/29/2025)
59176
(Ford Motor Company Petition For Declaratory Order Re: Home Backup Power System)