Interconnection insurance requirements [RE-wrenches]

[Allan Sindelar]

Wrenches,
As I have indicated in recent posts, I'm involved in workshops to revise our
Public Regulatory Commission's interconnection standards. There are many
issues, but today's request is about requiring liability insurance. A
section of the "straw man" document that is serving as the basis for
discussion will require liability insurance for all interconnected systems.
The existing under-10kW regulation ("Rule 571" referenced below) recommends
but doesn't require it, and I want to make sure this remains.

Here is the new text, followed [in brackets] by my own draft comments on
this particular section. I need supporting information for my argument that
insurance shouldn't be required on small systems. I also need to know that
my comments about homeowner's policies are accurate. Any help from Wrenches
in other jurisdictions is much appreciated.

11.9     Insurance
All Generating facilities shall obtain liability insurance to cover risks,
liabilities, and consequences that may arise as a result of interconnection
with a utility system.  A utility may require qualifying Generating
facilities larger than 50 kW to obtain general liability insurance not to
exceed $1,000,000 before the qualifying Generating facility is
interconnected with the public utility.  In extraordinary cases and for good
cause shown the Commission may require a Generating facility to obtain a
greater amount of general liability insurance. [Note: Historically with
residential and small commercial systems, this is covered under general
liability provisions in homeowner's policies, and these have generally been
determined in other jurisdictions to be sufficient. It must not be required
on small residential systems, as the insurance industry has not caught up
with the rapid growth of residential PV; as such any specific rider could
add prohibitively to the cost of the system. Note also that existing Rule
571 states that "All customers are urged to obtain adequate liability
insurance to cover risks, liabilities, and consequences which may arise as a
result of interconnection with a utility system." This has served adequately
to date and should not be changed.]



Thanks as usual for any assistance.

Allan

Positive Energy


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