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Parties File Initial Comments On PUC’s Draft Net Metering Rules
On October 1, 2025 the transcript of the September 30, 2025 public hearing made available.
Parties filed initial comments in the Maine Public Utilities Commission (PUC) net metering or net energy billing (NEB) rulemaking.
OPA: (i) “agrees with the proposed rule’s approach of requiring the utility to cease providing credits to a subscribing customer under the NEB arrangement that is providing fewer credits,” noting that “It may be helpful to clarify that it should be the smaller share in terms of overall number of kilowatt-hour credits per month, not the percentage share of the resource’s output”; (ii) “recommends the Commission assume a capacity factor of 16% as a reasonable average for all NEB facilities over the life of the program”; (iii) recommends “the adjusted Project Charge be different for the different utility service territories,” given that “transmission and distribution rates increase at different rates and at different times across utilities”; (iv) “agrees that an annual change in the Project Charge is generally appropriate,” but “recommends that the Commission retain discretion to adjust the Project Charge at more or less frequent intervals or at different times throughout the year depending on changes in transmission and distribution rates”; (v) recommends “the proposed rule’s prohibition on project sponsor’s retaining the value of expired credits should apply to… all credits that expire after the effective date of Chapter 430”; (vi) “urges the Commission to consider further amending the proposed rule to ensure that solar subscribers are aware of the important consumer protections that are included within Chapter 430 and to solve existing weaknesses with the standard disclosure that Project Sponsors currently provide”; (vii) “urges the Commission to require the utilities to provide the customer manger of the project and their phone number on the customer’s bill”; and (viii) recommends that, as a part of utilities’ required annual report, they “be required to provide a breakdown of expired credits by project sponsor.”
ReVision raises concerns “that the Notice and the proposed amendments to Chapter 313 do not address Sections 2, 3, 5, and 6 of LD 1777, which describe the sunset of the net energy billing (NEB) program for distributed generation (DG) resources ‘interconnected or planned to be interconnected to the distribution grid on the utility side of a customer’s utility meter’” and that “the language in these sections – ‘a distributed generation resource that is interconnected or planned to be interconnected to the distribution grid on the utility side of a customer’s utility meter” (hereinafter as ‘front-of-the-meter’, or ‘FTM’) – is a technical impossibility,” and so “the “FTM” distinction made in Sections 2, 3, 5, and 6 of LD 1777 requires Commission interpretation, both to avoid unnecessary confusion for market participants and to align Chapter 313 with the intent of the Legislature.”
Syncarpha Capital and Altus Power: (i) “propose that rather than terminating credits for the ‘NEB arrangement with a lesser value of the shared interest’… the final rule reflect that if a customer is party to more than one NEB agreement under 35-A MRS S 3209-A, the customer should keep the NEB agreement under which they first received project credits”; (ii) “agree that a thirty (30) day payment period is reasonable,” but recommend that project sponsors “have an opportunity to cure before issuance of credits are impacted”; (iii) “urge the Commission to adopt more specific language defining the obligation of Project Sponsors to ‘right size’ subscriptions, as the current language… could be read to suggest that Project Sponsors are required to change subscription size monthly based on seasonal variation in production and or normal variations in usage such as higher heat pump usage in the winter”; (iv) “request that the final rule clarify the obligation of utilities to provide customer information to Project Sponsors in a timely, useable manner”; and (v) “agree with the proposed rules regarding the treatment of expiring credits, which are consistent with our current practice,” but object that “OPA’s proposed change that requires offering cash refunds to customers who cancel their accounts is neither required by the new law nor reasonable.”
2025-00264
(Public Utilities Commission Amendments To Net Energy Billing Rule Chapter 313)

