In 2025, REV represented members’ interests in four PUC proceedings covering changes to the single plant process, a proposed decommission fund, new rules governing storage permitting, an investigation into planned transmission upgrades, and the valuation of resilience investments.
Single Plant & Decommissioning Fund Investigation (25-1253-INV):
Single Plant: In the spring of 2025, REV successfully pushed for legislation requiring the Public Utility Commission (PUC) to recommend changes to the definition of “plant” in Vermont statute that would make it easier, more predictable, and more cost-effective to co-locate solar projects on the same or adjoining parcels.
In response to the opening order in the investigation, REV proposed language that would support more efficient land use by renewable generation projects by promoting denser, “solar smart growth” and reducing the need for redundant access roads and line extensions. REV’s proposal would have eliminated the single plant determination process for facilities that were neither net-metered nor enrolled in the Standard Offer Program and would have reduced the costs and uncertainty arising from the existing definition while protecting the state’s interest in promoting distributed generation and reducing costs to consumers.
The PUC’s draft recommendation made great strides toward achieving that goal. It focused on using objective characteristics to determine when co-location would be permitted and rightly rejected criteria proposed by the Public Service Department that related to preferred siting and grid constraints that would only apply to the second (or subsequent) facility built on a parcel.
REV filed a response highlighting that the proposal could be further improved by removing restrictive aggregate capacity limits to provide greater flexibility in locating Tier II resources.
REV supports the PUC’s final recommendation to the Vermont Legislature for changes to the definition of “plant” to make it more feasible to co-locate new renewables, which:
- Eliminates existing single plant restrictions, allowing for a more predictable, lower-cost and faster permitting process for new solar in almost all cases.
- Supports more efficient land use by renewable generation projects by promoting denser, “solar smart growth.”
- Reduces the need for redundant infrastructure like access roads and line extensions, which should also lower the cost of renewable power.
Decommissioning Fund: The PUC is also advocating for legislation that would authorize it to create and manage a decommissioning fund to replace the current process of obtaining financial assurances for projects larger than 500 kW. In initial comments, REV and GMP flagged the need for additional information about what the PUC is proposing before providing meaningful feedback. When provided with that information, REV members did not believe that this would be a beneficial change. REV is continuing to engage with the PUC, but will oppose this proposal in the Legislature as it is currently.
Proposed Energy Storage Rule (21-3883):
In 2021, Act 54 granted the PUC the power to create rules governing “the installation and operation of energy storage facilities of all sizes,” including a simplified process for siting storage facilities with capacities ranging from 100 kW to 1 MW or another larger threshold as determined by the PUC. The PUC’s proposed Rule 9.000 is now before the Legislative Committee on Administrative Rules, and is likely to go into effect in the first half of 2026.
In comments submitted in July of 2024, REV successfully recommended that sections 9.302 & 9.303 of the Rule, which waive certain Section 248 CPG criteria, apply to battery projects up to 5 MW in size, rather than 1 MW as the PUC initially proposed. In comments submitted in October, REV further recommended that the PUC set this threshold based on export capacity rather than nameplate capacity but it appears unlikely the PUC will make this change.
Resilience Investigation (25-0339-PET):
At the request of the Public Service Department, the PUC has initiated an investigation designed to develop “a common framework for defining, valuing, measuring, and planning for the resilience of Vermont’s electric grid.” In this case, REV has advocated that the framework support opportunities to invest in storage, microgrids, and other resilience strategies of interest to REV members. The Public Service Department will be issuing a draft report covering its findings and recommendations in early 2026.
As part of its “Valuation” working group, the PSD convened stakeholders for presentations by several utilities (VEC, GMP, VEC, WEC, MLP, and SED) about how they currently incorporate resilience into their planning processes. Dr. Benjamin Leibowicz of UT Austin also shared a presentation on “Decision-Making Paradigms for Electricity Resilience Projects.”
The utility presentations touched on several common points:
- Rates are rising and will continue to rise for the foreseeable future
- Storm recovery is becoming more expensive as a function of climate change
- Rural resilience investment can be difficult to justify on a straight cost-benefit basis
Several utilities did share examples about when hardening infrastructure saved money despite the upfront costs and stated that FEMA 406 hazard mitigation money could be helpful but that the process of getting those funds was not easy. Utility prioritization considerations included: public and utility worker safety, frequency and duration of outage, and number of customers impacted by outages. The municipal utilities especially emphasized the need to balance resilience investment against rate impacts.
The more highly resilience is valued, the higher the level investment in resilience — such as hardening infrastructure or adding storage – is justified.
Investigation into Transmission Upgrades in the 2024 LRTP (24-3351-INV):
The PUC has an ongoing investigation into the need for transmission upgrades identified in the 2024 Long Range Transmission Plan. Currently, GMP is leading an investigation into non-transmission alternatives that could alleviate the need for these investments. Early results indicate that transmission upgrades may be avoidable. Several utilities, as well as the Public Service Department, have raised the need for coordinated statewide planning/regulatory mechanisms to guide future renewable siting toward “optimal” areas on the grid. REV continues to monitor the progress in this case.