Two public comment periods are open on how Plug-In Solar is treated in the United States, and anyone may take part in both.
The first closes in a few days. Until November 20, 2026, the National Fire Protection Association (NFPA) is accepting comments on six proposed amendments that would give plug-in photovoltaic systems a definition and a set of rules in the National Electrical Code for the first time. A comment is a short email. The six links and the instructions are directly below.
The second closes on January 8, 2027. The Public Utilities Commission of Nevada has opened the first investigation by any state commission into how plug-in photovoltaic appliances connect to the grid, Docket No. 26-10020, and has asked the public what the investigation should address. GismoPower filed its comments on November 10. This page summarizes them and explains how to file your own.
Comment on the six National Electrical Code amendments by November 20
The National Electrical Code (NFPA 70) has no definition for a plug-in photovoltaic system. Inspectors have no category to cite on a permit, and utilities have no Code-defined product type to assess. GismoPower wrote and filed six Tentative Interim Amendments (TIAs), Nos. 1951 through 1956, to the 2020, 2023 and 2026 editions of the Code. NFPA has posted them for public comment with a closing date of November 20, 2026. They are proposals: pending, and not adopted.
The six amendments, each with its direct link:
- TIA 1951 (Article 100 and new Part IV, 705.100). A definition of a Plug-in Photovoltaic (PIPV) System, and a new Part IV of Article 705 for cord-and-plug-connected power production sources. https://docinfofiles.nfpa.org/files/AboutTheCodes/70/NFPA_70_Proposed_TIA_1951.pdf
- TIA 1952 (705.12(C)). The connection method: a source of up to 60 A at 240 V or 20 A at 120 V may connect at a marked receptacle outlet, subject to the 120 percent busbar limit and listing to an applicable standard. https://docinfofiles.nfpa.org/files/AboutTheCodes/70/NFPA_70_Proposed_TIA_1952.pdf
- TIA 1953 (705.20(H)). The plug as disconnecting means, where it is accessible without tools, within sight of the inverter, and the outlet is marked. https://docinfofiles.nfpa.org/files/AboutTheCodes/70/NFPA_70_Proposed_TIA_1953.pdf
- TIA 1954 (705.10). Labeling: permanent labels at the dedicated receptacle, at the panelboard, and on the appliance. https://docinfofiles.nfpa.org/files/AboutTheCodes/70/NFPA_70_Proposed_TIA_1954.pdf
- TIA 1955 (705.12(D)). The aggregate calculation when several sources share a panelboard: the 120 percent busbar limit, breaker position, a warning label, and circuit directory entries. https://docinfofiles.nfpa.org/files/AboutTheCodes/70/NFPA_70_Proposed_TIA_1955.pdf
- TIA 1956 (705.102). Utility notification: a non-export system needs no utility interconnection agreement as a condition of Code compliance; an export-capable system notifies the serving utility within 30 days of connection. https://docinfofiles.nfpa.org/files/AboutTheCodes/70/NFPA_70_Proposed_TIA_1956.pdf
Two of the six bear directly on interconnection practice:
- TIA 1955: how plug-in sources count in the aggregate busbar calculation.
- TIA 1956: no interconnection agreement as a condition of Code compliance where a listed inverter or power control system prevents export, and notice to the utility within 30 days for export-capable systems. Tariffs and interconnection rules stay with the state commission.
The other four cover the definition (1951), connection method (1952), disconnecting means (1953) and labeling (1954).
How to email a comment
NFPA asks every commenter for three things: the TIA number, the word SUPPORT or OPPOSE, and the comment itself.
- Open an amendment from the list above and click "SUBMIT A COMMENT" in the document. The link opens an email to NFPA. You can also write directly to TIAs_Errata_FIs@nfpa.org.
- Use the subject line "Comment on Proposed TIA 195(1-6) on NFPA 70," with the number of the amendment you are commenting on.
- Address the comment to the Secretary, Standards Council. Identify the TIA number and state whether you SUPPORT or OPPOSE it.
- Add your comment in your own words. Two or three sentences are enough: who you are (electrician, inspector, engineer, installer, utility employee, researcher, homeowner) and why a Code provision for plug-in PV matters in your work or at your home.
- Sign with your name, your affiliation if you have one, and your city and state.
- Send it by November 20, 2026.
To comment on all six, we suggest one email per amendment, so that each comment is filed with the right TIA number. A comment can be as short as this:
Subject: Comment on Proposed TIA 1951 on NFPA 70
To the Secretary, Standards Council:
I SUPPORT proposed TIA Log No. 1951 to NFPA 70.
[Your reasons, in your own words.]
[Name, affiliation, city and state]
For the reasoning behind the six amendments, see our op-ed in pv magazine USA of October 28, 2026, "Our National Electrical Code has no definition for plug-in solar; six amendments would give it one" (LINK).
Comment in Nevada's Plug-In Solar investigation by January 8, 2027
On October 16, 2026 the Public Utilities Commission of Nevada (PUCN) opened Docket No. 26-10020 "to examine the interconnection of plug-in photovoltaic appliances." It is the first proceeding of its kind before any state commission. Procedural Order No. 1, issued November 6, invites interested persons to file written comments by Friday, January 8, 2027, at 12:00 p.m., on two questions:
- What issues need to be addressed in this investigation regarding the interconnection of plug-in PV appliances in Nevada?
- What additional resources or avenues of inquiry should the Commission consider as part of this investigation?
What GismoPower filed
GismoPower filed its comments on November 10, 2026: 199 pages, made up of 14 pages of comments and references and six attachments (Direct LINK). In answer to the first question, the comments identify nine issues:
- Whether a utility may decline an interconnection application by treating a mobile, cord-and-plug appliance as a fixed structure. The Commission reserved this question in August 2026 and assigned it to this investigation.
- What documentation is enough when the local authority issues no permit and performs no inspection for the appliance.
- Whether a land-use matter such as a zoning setback can be a condition of electrical interconnection, and who decides when two departments of the same county disagree.
- Which safety standards are "applicable" under NRS 704.774(2) to each function of a 240-volt plug-in appliance, and whether an interim certification pathway is available.
- How a Nevada rule should allow for standards now in motion at NFPA, IEEE (the P1547 revision, in public review until December 27, 2026) and UL (UL 3700 Issue 2).
- Whether review can be scaled to risk, with an expedited pathway for qualifying appliances on a dedicated circuit.
- How to treat relocation: repositioning at an approved connection point is different from a new connection point, address or utility territory.
- Safeguards for applicants when a utility declines to process an application: written reasons that cite a statute, regulation or tariff provision; pending status in place of cancellation; time limits; and a record of any inquiry the utility makes to a local authority.
- Separate criteria for 120-volt devices of up to 1,200 watts and for 240-volt appliances.
In answer to the second question, the comments place the research on the MEGA in the record:
- PNNL-39895, "Toward Streamlined Permitting and Interconnection of 240 V Plug-In Photovoltaic Appliances," Pacific Northwest National Laboratory with Lawrence Berkeley National Laboratory, November 2026: https://www.osti.gov/biblio/17427382. It proposes three review pathways: notification-only, expedited and full review. It states that it does not certify any MEGA configuration.
- The DOE SBIR Phase II Final Report, award DE-SC0022708: https://www.osti.gov/biblio/3011045
- Grid impact study by North Carolina State University, 2023: https://tinyurl.com/NCSU-ImpactAnalysis
- Grid impact study by SLAC National Accelerator Laboratory, 2025: https://tinyurl.com/SLAC-GISMO
- "Barriers to Balcony Solar and Plug-In Distributed Energy Resources in the United States," a peer-reviewed article in Energies, 2025, by authors at Lawrence Berkeley National Laboratory, GismoPower and Impulse Labs: https://www.mdpi.com/1996-1073/18/8/2132
- The email exchange of September 21, October 5 and October 14, 2026 in which NV Energy stated why it will not process the application behind this investigation.
The comments ask the Commission to convene a workshop with NV Energy, Staff and the Bureau of Consumer Protection, where GismoPower offers to demonstrate the appliance and answer data requests. They suggest inviting the PNNL authors, Clark County's building and planning departments, the Nevada State Contractors Board, UL Solutions, NFPA, the IEEE P1547 working group and Solar United Neighbors. They also suggest asking NV Energy how many applications it has declined or cancelled for lack of local permit documentation.
One limit applies. Procedural Order No. 1 states that this docket "is not the appropriate proceeding to reconsider the complaint in Docket No. 26-05022," the homeowner's complaint described below. GismoPower's comments do not ask for that. Review of the complaint is before the District Court, and GismoPower is not a party there.
Why your comment matters
The Commission has asked an open question: what does this investigation need to address? The comments it receives will inform the scope. This is the first such proceeding in the country, so its record is likely to be read beyond Nevada.
The order invites "interested persons" and sets no residency requirement. If you are an NV Energy customer, an electrician, an inspector or building official, a utility engineer, a solar installer, an owner of a vehicle that can export power, a researcher, or an advocate working on plug-in solar in another state, you have something the Commission can use. You do not need to agree with GismoPower.
A useful comment can do any of these:
- Answer the Commission's two questions directly.
- Say which of the nine issues matters most to you, or name one that is missing.
- Describe your own experience: a permit desk with no category for a plug-in device, an interconnection application that stalled, or a jurisdiction that handles these appliances well.
- Point the Commission to a source it should read: a study, a standard, or another state's law.
How to file a comment with the PUCN
- Write your comment, put "Docket No. 26-10020" at the top, and save it as a PDF.
- Open the PUCN's Electronic Filing System (search for "Electronic Filing System PUCN," or start at puc.nv.gov). If you are new, choose "Not Registered?" and sign up with your email address.
- Log in, select "Open Docket Filing," enter 26-10020 and select "Find Docket."
- Choose "Other Filings in an Open Docket," upload your PDF, sign electronically and submit.
- File before 12:00 p.m. on Friday, January 8, 2027.
To receive further notices in the docket, the Notice of Investigation requires a written request to be placed on the service list.
How Nevada got here
In December 2024, NV Energy approved a single-rack MEGA at a Las Vegas home for net metering. It was the first plug-in solar appliance the utility had ever interconnected. In June 2025 the homeowner applied to add a second MEGA to the same inverter at the same location. That application has not been approved seventeen months later, and the reasons given have shifted five times: a missing solar permit, a missing licensed contractor, a county code case that the utility's own inquiry set in motion, a zoning setback, and finally a reading of NRS 704.774 under which the utility waits for "full approval by Clark County" of something the county's Building Official has said it does not permit at all.
Along the way, four things were settled that matter well beyond one driveway:
- Clark County's Building Official confirmed in writing on September 21, 2026 that a MEGA on wheels, unanchored and cord-and-plug connected, requires no building permit and no inspections, and that the 240 V outlet it plugs into was permitted, inspected and approved.
- The PUCN ruled on September 17, 2026 that the utility's two stated deficiencies are cured by a Clark County building permit or exemption plus a Nevada State Contractors Board owner-builder exemption. Both are in the utility's hands.
- On October 16, 2026 the Commission issued its written order in Docket 26-09004, directing its Secretary to open an investigatory docket on plug-in PV appliance interconnection and finding that its authority over how a utility processes such an application "is express" under NRS 704.773(9). GismoPower petitioned for it. That docket is now open as Docket No. 26-10020.
- Clark County's own records, obtained under the public records law, show that the code enforcement case against the homeowner was opened on August 26, 2025 at the request of a county official after an NV Energy engineer sent the county photographs of the unit: "Please open a case for unpermitted solar on the carport."
What is not settled: NV Energy wrote on October 5 and again on October 14 that it cannot proceed, first until the county's setback question is resolved or waived, then because the unit "has not been granted full approval by Clark County." Both emails attribute their facts to a telephone conversation with a code enforcement supervisor. Neither mentions the Building Official's letter.
The three earlier proceedings, in brief
The complaint, Docket 26-05022. The homeowner, representing himself, complained to the Commission in October 2025. On August 12, 2026 the Commission dismissed the complaint without a hearing. Footnote 1 of that order left open whether a utility may deny interconnection to a mobile, portable solar unit by classifying it as a fixed structure. On reconsideration the Commission reaffirmed the dismissal, spelled out the two cures, and preserved a renewed complaint if the utility denies on mobility grounds. The docket closed on October 7, 2026.
The rulemaking petition, Docket 26-09004. GismoPower petitioned the Commission to adopt regulations on plug-in PV appliance interconnection or, in the alternative, to open an investigatory docket. The October 16, 2026 order declined the proposed text for reasons of timing and drafting and granted the alternative. It framed the question as "how a utility should treat an appliance that the local authority has determined it does not permit or inspect," and found that this "is a question about the utility's tariff and NAC 704.8823, not about county authority." The docket closed on November 9, 2026.
The court case, No. A-26-959617-P. On October 15, 2026 the homeowner petitioned the Eighth Judicial District Court in Las Vegas for judicial review of the dismissal, naming the Commission and NV Energy. He asks the court to set the dismissal aside and to order the utility to restore his application to pending status with its original 2025 date while the case is decided. The case is assigned to Department XIII and is pending.
Clark County
The county's Building Official confirmed that the MEGA needs no building permit and no inspections while it is portable, on wheels, unanchored and cord-and-plug connected. The county's planning department treats it as a carport standing in the front setback, which under Title 30 requires a waiver of development standards. The homeowner decided not to apply for the waiver: it is a discretionary grant, and applying would have meant accepting the classification of a wheeled, cord-and-plug appliance as a "structure." Each MEGA has been registered as a trailer, with license plates. A second notice of violation, dated October 16, 2026, is limited to the setback.
One thing we will not do is relocate the unit. There is no compliant location outside the setback on this lot, and a product whose purpose is to put solar on a driveway has to be able to stand on a driveway. The setback question is a legitimate land-use conversation with the county. It is not a reason for a utility to refuse an interconnection that its own regulator has told it how to process.
Where things stand
As of November 12, 2026:
- NEC amendments, TIAs 1951 through 1956. Open for public comment at NFPA until November 20, 2026.
- PUCN Docket 26-10020, the investigation. GismoPower's comments were filed November 10. Public comments are due January 8, 2027 at 12:00 p.m.
- IEEE P1547 revision, including Annex K. In initial ballot and public review until December 27, 2026.
- Expansion application NVE-177532. Shown as "Cancelled" in NV Energy's portal since November 2025. The cures were submitted on September 21 and 22, 2026. NV Energy's position, stated October 14, is that it cannot proceed until Clark County grants "full approval."
- The court case. The petition for judicial review is pending in Department XIII of the Eighth Judicial District Court. A renewed complaint to the Commission, the path its September 17 order preserved, is prepared.
- Federal research. PNNL-39895 was published in November 2026 and is in the record of Docket 26-10020.
- UL 3700 certification. Issue 2 of the Outline of Investigation was published October 1, 2026. The CSA Group certification project is under contract, with testing in 2027.
How to read the dockets yourself
Everything described above is on the public record.
- Go to the PUCN Document Search portal at https://puc-onbase.nv.gov/
- In the "Search Type" field, choose "PUC - Public Search - Dockets."
- In the "Docket Number" field, enter one of the three docket numbers:
- 26-10020 for the open investigation: the Notice of Investigation, Procedural Order No. 1, and GismoPower's comments with Attachments A through F.
- 26-09004 for GismoPower's petition, the public comments, the General Counsel's briefing memo and the October 16, 2026 order (closed November 9, 2026).
- 26-05022 for the homeowner's complaint against NV Energy (closed October 7, 2026).
- Leave the date range boxes blank and click "Search."
- The result lists every filing in date order. Each opens as a PDF.
Direct LINK to GismoPower's comments in Docket 26-10020, to Procedural Order No. 1, to the PUCN order of October 16, 2026 and to the PUCN briefing memo.
The court case can be followed on the Eighth Judicial District Court's public portal (Clark County Courts, Case Search) under Case No. A-26-959617-P or you can use the Direct DOWNLOAD LINK