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Rhode Island Remote Net Metering Cap in the October 8 Division Memo

The Rhode Island remote net metering cap is still a proposed number. On October 14, 2026, 175 MWAC sits in Rhode Island Energy's proposed tariff and in a Division memo dated October 8. It is not a final Commission vote. Docket 26-30-EL is open because the Public Utilities Commission suspended the tariff's effective date. A proposal that prints the new cap as if Rhode Island Energy can already enforce it is ahead of the docket.

Where 175 MWAC actually lives

Rhode Island Energy, which is Narragansett Electric, filed a tariff advice on August 14, 2026. The advice amends the Net Metering Provision, R.I.P.U.C. No. 2279. The proposed tariff in that filing is R.I.P.U.C. No. 2310. The company proposed an effective date of September 13, 2026. At its August 31, 2026 open meeting the PUC voted to suspend that effective date so it could investigate. The earlier writeup of the filing is the Docket 26-30-EL record. This post picks up after the October 8 memos.

Suspension means the proposed effective date did not arrive. It does not repeal the provision now on file, and it does not adopt the new one. A designer does not have a new cap to enforce on a sheet until the Commission acts on a tariff that is actually in front of it.

What the October 8 memo says

The Division memo is dated October 8, 2026. It is from Michael Brennan for the Division of Public Utilities and Carriers. The memo says the proposed tariff substantially implements the 2026 statutory amendments in Article 11 of 2026-H 7127 Substitute A, as amended. That is a description of the filing, not an approval order.

On the cap, the memo says the proposed tariff reduces the aggregate cap on specified ground-mounted remote net-metering systems from 275 MWAC to 175 MWAC. Aggregate means a program total for that class of systems. It is not a single-site maximum you sketch into one layout. The memo also says the proposed tariff extends the construction or operation deadline to December 31, 2032, preserves statutory exceptions to the cap, and sets up the optional fixed renewable net-metering credit in R.I. Gen. Laws section 39-26.4-3(f).

The Division recommends approval only after Rhode Island Energy files a revised compliance tariff. The memo flags corrections on how the fixed credit is administered, a statutory citation, and miscellaneous edits. A citation already marked for correction is not text to paste onto a customer page. Do not fill in a credit price. Do not fill in an escalation. Leave the credit as the optional mechanism that section names, and wait for the compliance tariff.

The memo says statutory exceptions are preserved. It does not give a designer a shortcut for labeling a site "outside the cap." That call belongs to the statute and to the tariff language the Commission accepts. This post will not invent the exception list.

The dates between the memo and the hearing

The procedural schedule is dated September 3, 2026. On October 14, part of it is behind you. The part that can still change the tariff is not.

  • Intervention deadline: September 16, 2026.
  • Division and intervenor memoranda: October 8, 2026.
  • Rhode Island Energy rebuttal: October 22, 2026, if needed.
  • Settlement or consensus deadline: November 10, 2026.
  • Evidentiary hearing: November 17, 2026, at 9:30 a.m., PUC hearing room A, 89 Jefferson Boulevard, Warwick.

The October 22 rebuttal is only if needed. Do not promise a customer that it will be filed. November 10 is a settlement deadline for parties, not a construction date. Between the memo and the November 17 hearing, the September 13 effective date stays suspended, and nobody has voted the new cap into force.

What to do with the Rhode Island remote net metering cap

Keep the old cap language and the proposed cap language off the drawing title block. The title block identifies the project, the site, the sheet, the revision, and the seal block when a sheet is sealed. It does not recite 275 MWAC or 175 MWAC as a design criterion.

General notes are the same trap. A note that the project "complies with the 175 MWAC cap" states a program fact the Commission has not adopted. A note that the project "is under the 275 MWAC cap" treats the filing's comparison figure as a total you are tracking. You do not have that aggregate total on a site plan. Leave both sentences off the sheet.

Do not resize a project to 175 MWAC as if the tariff were law. A ground-mounted remote system laid out for the study, the land, and the equipment the installer is buying should stay at that size while the docket is open. Cutting the AC nameplate to 175 treats an aggregate proposal as a per-project limit. A second layout means the portal, the permit set, and the proposal can disagree about which array is real.

If the project is not a specified ground-mounted remote net-metering system, the cap line does not belong on the sheet at all. The permit design set should describe the array, the point of interconnection, and the equipment. Program caps stay in the docket file.

What the proposal is allowed to print

A sales proposal can tell the truth without acting as the order. Name Docket 26-30-EL. Say the tariff advice was filed August 14, 2026, that the proposed sheets are R.I.P.U.C. No. 2310 against R.I.P.U.C. No. 2279, and that the PUC suspended the September 13, 2026 effective date on August 31. Say the October 8 Division memo describes a reduction of the aggregate cap from 275 MWAC to 175 MWAC and recommends approval only after a revised compliance tariff. Say the hearing is November 17, 2026.

Then stop. Do not write that the company will reject a project above a remaining balance you do not have. Do not write a credit price or an escalation. Do not convert December 31, 2032 into a promise that this customer has until that date. The date is in the proposed tariff. The proposed effective date was suspended. The customer can be told the date is in the filing.

Remote net metering credits and the Rhode Island Energy interconnection are related, and they are not the same submission. The application has to match the one-line. Changing the array on a proposal to chase 175 MWAC, while the portal still shows the studied size, looks like two projects. Hold the equipment list until an order gives you a reason to revise it.

After the hearing, revise from the order

November 17 can end in more than one way. The Commission can keep investigating. Parties can bring a settlement. The company can be told to file the compliance tariff the Division described. This post will not guess which one happens. When an order or a compliance tariff is posted, revise the proposal to match that document. Until then, the sheet set for a commercial or utility remote project describes the plant the installer intends to build.

Athol prepares those drawings, and the PE stamp when the sheet calls for one, for installers in Rhode Island. The installer owns the customer and the construction. A structural stamp does not turn a suspended tariff advice into a cap the company can enforce. Docket status belongs in the proposal narrative. Array facts belong on the drawing. Leave the size alone while the hearing is still on the calendar.

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