Plug-and-Play or Plug-and-Pray?

My wife has a saying that she pulls out at the most opportune of occasions: “Hope in one hand, shit in the other. See which gets fuller faster.” It’s an adage that state legislatures across the country might consider as proposals related to plug-in solar, also known as balcony solar, end up in their lap. The model legislation being pushed in more than twenty states depends too heavily on hope. Hope that certified equipment will be used. Hope that consumers will find (and follow) the right guidance. Hope that an electrician will be involved when needed. And hope that pushing the envelope doesn’t get someone killed.

Hope is not a safety strategy. If we want to help put clean energy in the hands of more Americans, we need to create pathways that are clear, credible, and easy to follow. Otherwise, we risk something more concerning than a handful of shit: the safety of our neighbors.

The mismatch between the argument and reality

The underlying problem is this: many advocates are supporting plug-in solar legislation based on the success of this technology in Europe, while the model legislation seeks to legalize something that is three times as impactful on a house’s electrical system and eliminates the only process that would provide meaningful safety guardrails. In essence, the legislation promotes bringing a proven technology from elsewhere, dramatically changing its use from what has been deemed as safe, and using constituents as test cases for that expanded use.

The challenge springs from legislation in Utah that was passed in 2025 and opened the door to plug-in solar in the United States. Utah House Bill 340, which serves as the model for legislation being considered in states across the country, defines a new class of “portable solar generation devices” with a capacity of up to 1,200 watts and excludes these devices from the utility processes used to evaluate small rooftop solar energy systems. The legislation requires the devices to be “certified by Underwriters Laboratories or an equivalent nationally recognized testing laboratory” and “meet the standards of the most recent version of the National Electrical Code.” When presented to the Utah legislature, the bill sponsor noted that the requirements of UL and the NEC would need to be addressed before plug-in solar could be used in Utah.  

Once the bill passed, manufacturers and consumers did not wait for the necessary standards to be addressed. Multiple companies are selling plug‑in solar appliances, often marketed as “plug‑and‑play” with guidance that these devices can be installed without an electrician and already meet UL and NEC requirements. The reality is that those who are buying and installing plug-in solar appliances without consulting an electrician are installing a device that is not UL listed and violates the NEC, the standard used to define safe electrical design and installation. The unregulated use of plug-in solar leaves electrical safety in the hands of customers and manufacturers – many of whom communicate either blatant disregard for or ignorance of common safety requirements. This creates a public safety risk and consumer protection problem, not because the technology is inherently unsafe, but because there’s no clear, enforceable pathway for safe use.

This puts legislators in a tough spot. They’re being encouraged to pass a bill that exacerbates the public safety concern by allowing systems that need more attention than those used in Germany and removing any measure of meaningful oversight that would help.

There are two legislative solutions that can correct this: actually following Germany’s example to achieve permissionless applications and/or coupling the American appetite for bigger systems with effective safety protocols.

Solution 1: Actually use Germany’s example

If states want to move towards “permissionless” implementation, where individuals are able to buy these devices off the shelf and plug them in without oversight by an electrician, we need to simmer down on the whole 1,200 watt threshold. After taking into account the difference in operating voltage between German and American households and the 800-watt limit imposed in Germany, the equivalent size in the U.S. is on the order of 400 watts.

Should legislatures be determining that threshold? Hell. To. The. No. Anyone who’s been involved in writing, amending, and passing legislation knows that the process is an inexact one that is often littered with clerical errors, negotiated language, and late-night voting as the end-of-session deadline approaches. The legislature trusts administrative bodies in each state to adopt and enforce electrical codes. The legislature should recognize that these bodies are best served to work out the technical details related to plug-in solar.

We’re already seeing the pitfalls of legislating these technical thresholds. In the absence of U.S. consensus, plug-in solar legislation proposes a 420-watt threshold in Maine and a 391-watt threshold in Colorado. Those differences aren’t about fundamentally different safety conditions; they’re a symptom of lawmakers being asked to make engineering decisions. The result is inconsistent guidelines that manufacturers will need to navigate on a state-by-state basis. While every state has the opportunity to be unique, standardization across states will result in products that are less expensive and will promote clearer guidance for constituents buying these systems.

How can legislatures leverage their public safety boards to solve this challenge? The answer likely varies by state, but requiring the board to issue an order within a certain timeframe – say within 9-12 months of bill enactment – provides a clear timeline for action. Boards should be directed by the legislature to issue an order that defines the maximum size that can be plugged into a standard outdoor outlet without the need for an electrician’s supervision or modification of existing house wiring. This creates specificity about the information needed to make plug-in solar “permissionless” in the manner similar to Germany. Additional language can be added to ensure that the board engage with other states to harmonize its approach.

While some may be concerned that these boards may default to being overly conservative, it is important to recognize that the failure to provide clear guidance won’t stop these devices from being used; it will result in no clear guidance for how to use these devices safely. Overregulation will create a nearly impossible enforcement challenge for building code officials, thus there is incentive for these boards to get it right.

By the time the specific public safety board has passed its guidance, UL should have an equipment certification protocol that can provide a pathway to a fully compliant installation. Until then, every system that is installed without the use of an electrician will be out of compliance with the state electrical code.

This solution is the only reasonable one for getting plug-in solar in the hands of most renters, as anything above this threshold will require an electrician and a landlord willing to let their tenant have work done on their electrical system. I’m not sure your experience with landlords, but I have some guesses on the most likely response to that request.

Solution 2: Satisfying the American appetite

The average annual electricity use for a German household is around 3,100 kilowatt-hours. The average household in the U.S. uses nearly 3.5 times that amount! A “permissionless” solution in the U.S., such as the one offered above, is likely to result in a maximum size of around 400 watts, which is half the capacity allowed in Germany. This means permissionless plug-in solar in the U.S. will be a drop in the bucket compared to the experiences of the average user in Germany. It’s fair to say that the American consumer is going to want a pathway to install larger plug-in systems if they are available and affordable.

The only way to do that safely is with an electrician. Standard wall outlets aren’t configured to have a generator of any size plugged into them, and failure to verify the capacity of the outlet that the device is being plugged into puts people at risk.

Most plug-in solar bills being considered by state legislatures mirror the Utah threshold of 1,200 watts, which puts us back to the unsavory scenario of shitting in peoples’ hands. There are legitimate reasons why we want to ask permission from people when we’re plugging an electrical appliance into a wall outlet, starting with someone saying “no” if I am unwittingly asking, “May I burn my house or apartment building down?” Hoping that people will receive clear guidance from manufacturers and will hire an electrician doesn’t cut it.

If we truly care about public safety, we want to make sure that we’re not just giving lip service to this risk. If you need any proof that putting requirements in a legislative bill isn’t a sufficient enough guardrail, we should go count how many of these systems have been installed in Utah without an electrician in the year since HB 340 passed. It’s not zero, and you can readily find instances online where companies are selling into that market based on claims that are inconsistent with the legislation.

There are three mechanisms I can think of to address this:

1. Require the homeowner to pull a permit;
2. Regulate the sale of these devices to ensure that there are clear consumer protections; or
3. Get rid of the utility interconnection exemption from the Utah bill.

Let’s go through these one-by-one.

First, pulling a permit is unlikely to happen. These devices are already being promoted as permissionless and people rarely pull permits for small jobs. Furthermore, if someone pulls a permit, they would likely run into red tape and tell everyone they knew to avoid their experience. This approach won’t provide adequate safeguards.

Second, regulating product sales is a significant endeavor. Who’s going to set the rules? Who’s going to enforce them? Ho do we avoid good actors being undercut by online sales from manufacturers who don’t comply? This seems like a “break glass in case of emergency” approach that will be expensive and difficult to implement. Let’s pass.

Lastly, utility interconnection processes aren’t necessarily designed as a proxy for code compliance, but they serve as one. When customers install a rooftop solar project, the utility commonly reviews the equipment to verify that it is certified to operate in parallel with the grid, checks to determine that the installation won’t have adverse impacts on neighboring customers, and then requires an electrician or local code enforcement official to attest that the system has been installed in accordance with relevant building codes. While, this process commonly may take up to a couple of weeks due to the time the utility takes to evaluate the adverse impacts on the grid, the review of the certification and the attestation takes very little time. In many states, this could be done on the same or next day.

Current model legislation is based on the premise that utility interconnection review is the barrier to widespread use of these devices. The reality is this: utility interconnection review is a barrier to widespread safe use of these devices if states approve pathways for larger plug-in systems. Instead of exempting these systems from the interconnection process, legislation should provide guidance to the state utility regulator to issue an order that streamlines the utility review process for these applications. This requires no additional work of the regulator than passing an interconnection exemption does; in both instances, states with existing interconnection rules or tariffs will need to amend them. By defining the content of the utility commission order, the legislature can provide clear guidance on their expectations of the regulator.

What should be included in that order? The model legislation already hints at a few outcomes, such as no fee related to connecting the device and no additional utility requirements for controls and equipment. Current legislation also indicates that the utility must provide default approval; this is where more attention is needed.

First, it is in both the utility and the customer’s interest for the utility to review the device listing. The utility does this for other systems to ensure the inverters will play nice with the grid. That their review will also help ensure that customers aren’t buying unlisted equipment is a consumer protection bonus.

Additionally, it is worthwhile for the utility commission to include in their order that the Certificate of Completion commonly used to attest that a system being interconnected to the grid can be satisfactorily signed by an electrician. Rooftop solar projects commonly require building permits, thus utilities commonly require attestation by a code enforcement official. With the intent to move plug-in solar to a streamlined approach that encourages regulatory participation by the customer, attestation from an electrician without the need for a permit goes a long way.

Finally, the interconnection exemption in current model legislation has an unintended consequence: if the utility is required to provide default approval, then ratepayers will be in the hook for the cost of grid upgrades should the use of plug-in solar devices push equipment above its design capacity. This isn’t theoretical; there are several states where even small rooftop systems are not approved by the utility due to concerns about the need for significant grid upgrades due to high levels of solar adoption on a circuit. Whether those determinations are fair or not depends upon the level of conservatism used by the utility, but a reality here is this: in those states, these issues will be brought up in the interconnection rulemaking triggered by an interconnection exemption. By providing clarity on the contents of the order issued by the utility regulator in the legislation, the legislature has the opportunity to weigh in now in a way that it won’t once the proceeding is in progress.

Recommendations

Legislatures don’t have to, and shouldn’t, go it alone. States already have expert bodies that exist to answer the technical questions; lawmakers should charge these bodies with developing a practical and timely framework that reflects how people actually use these products and that channels that usage into safe, compliant behavior.

The path for sustainable and safe plug-in solar legislation includes:

• Building on Germany’s experience by directing the appropriate state public safety board (e.g., electrical board, Fire Marshal’s Office, building code body) to define the permissible size for a plug‑in solar device (in AC watts) that can be safely plugged into any standard outdoor 120V receptacle when the device is listed for that use.
• Directing the state utility regulator to issue an order creating a streamlined registration/interconnection process for plug‑in systems above that threshold that eliminates fees, provides same‑day or next‑day acknowledgments, and reviews limited to product listing verification, attestation by an electrician, and a check for any known grid issues that would be exacerbated by the device.
• Require these agencies to deliver rules within a fixed timeline that acknowledges both the current unregulated use of these devices and the development of equipment standards for plug-in solar devices.

Plug‑in solar can be a safe, renter‑friendly on‑ramp to clean energy. But safety doesn’t happen by hoping for it. It happens when statutes set clear goals, expert bodies define practical thresholds, and customers have a simple, credible way to comply. That’s how we move from plug‑and‑pray to plug‑and‑play.