Behind the Bill: How New Hampshire Built a Safety-First Pathway for Plug-In Solar
By PlugInSolarUS Editorial · Published June 23, 2026 · 16 min read
Sen. David Watters and Sam Evans-Brown explain how New Hampshire used coalition-building, code-board flexibility, and consumer education to move plug-in solar forward.
Editor's Note: This article is part of PluginSolarUS.com's "Behind the Bill" series, which explores how different states are approaching plug-in solar legislation, consumer access, safety, and implementation. The article is based on an interview with New Hampshire Sen. David Watters and Sam Evans-Brown of Clean Energy New Hampshire, public legislative materials for SB 540, and additional background research. It reflects the status of New Hampshire's plug-in solar legislation and related standards as of the publication date. Product certification, electrical code requirements, utility practices, and implementation rules may continue to evolve. For a full overview of New Hampshire's plug-in solar status, see our New Hampshire state page.
New Hampshire is not known as an easy state for solar policy.
According to Sen. David Watters, solar adoption in New Hampshire has lagged far behind neighboring states. That challenge helped shape his interest in plug-in solar: if traditional rooftop solar and community solar have faced barriers, could a smaller, simpler consumer energy product help more residents participate?
For Watters, plug-in solar offered a practical way to extend solar access to people who may not be able to afford rooftop solar or participate in existing community solar programs.
"It seemed to me this might be a way to extend solar to folks who might not be able to afford rooftop or couldn't participate in our community solar programs."
That idea eventually became SB 540, New Hampshire's plug-in solar legislation. The bill creates a framework for small plug-in solar generation systems, while avoiding some of the most politically sensitive and technically unsettled issues around net metering, interconnection, building codes, utility liability, and consumer safety.
But the New Hampshire story is not simply about a bill. It is also about how the bill was built.
Watters credited Sam Evans-Brown and Clean Energy New Hampshire with playing an essential role in convening utilities, electricians, code officials, building inspectors, solar advocates, and other stakeholders. Evans-Brown described New Hampshire policymaking as deeply relationship-driven.
"Each piece of legislation that passes in every state house in the nation is like a weird cocktail of the people in that state."
In New Hampshire, those relationships may have been the difference between a bill that failed and a bill that moved forward.
Why Plug-In Solar Mattered in New Hampshire
New Hampshire's energy politics are complicated. Watters said renewable energy has faced significant resistance in the state. He described net metering as a particularly sensitive issue — a "third rail" in New Hampshire energy politics.
That shaped the bill's core strategy. Rather than treating plug-in solar like traditional net-metered rooftop solar, SB 540 was designed to keep small plug-in systems outside the net-metering framework.
That distinction matters. A full rooftop solar system often exports meaningful electricity to the grid and may require interconnection review, utility coordination, and net-metering rules. A small plug-in solar system is intended primarily to offset part of a customer's on-site electricity use. While some electricity may trickle out onto the grid, most customers wouldn't get paid anything for their contribution.
By keeping plug-in solar separate from net metering, Watters hoped to avoid triggering the same political and regulatory battles that have slowed other solar policies in New Hampshire. The goal was not to solve every distributed-energy issue at once. It was to create a practical, narrow pathway for one emerging category.
That narrow focus helped the bill avoid the broader net-metering debate while leaving billing and meter questions to be addressed through consumer education and implementation guidance.
Learning from Utah — but Adapting to New Hampshire
Watters said Utah's first-in-the-nation plug-in solar law served as a useful template. He had met the Utah lawmaker who worked on the bill and also reviewed approaches from other states, including Arkansas, New York, and Maine. But he emphasized that plug-in solar legislation cannot simply be copied and pasted.
"Utah was somewhat of a template for a lot of us, but everything is so state-specific."
Each state has its own utility structure, building code process, political culture, housing market, and stakeholder landscape. What works in Utah may not work in New Hampshire. What works in New Hampshire may not work in New York, Colorado, Maine, or Connecticut.
For New Hampshire, the key was to keep the bill narrow, practical, and flexible. Watters wanted to avoid creating unnecessary fights with landlords, municipal officials, utilities, or code authorities. He deliberately avoided provisions that might have triggered strong opposition from the rental industry or municipal associations.
That choice reflected a broader strategic philosophy: get the essential framework in place first, then build from there.
"I'm an incrementalist. Just a pragmatist."
The Basic Structure of SB 540
SB 540 creates a framework for plug-in solar generation systems in New Hampshire. The bill generally allows each metered customer to use one plug-in solar generation system, capped at a maximum inverter output of 1,200 watts AC, if the system meets applicable safety and certification requirements.
The legislation exempts compliant plug-in solar systems from several utility requirements that would otherwise create significant barriers, including utility approval, interconnection review, interconnection agreements, additional utility-specified equipment, and related fees.
The bill also directs the New Hampshire Department of Energy to provide consumer information, including information on meter compatibility, potential billing impacts, applicable safety standards, and other relevant guidance. It gives the Building Code Review Board a central role in addressing how plug-in solar systems interact with buildings and electrical systems.
In plain English, New Hampshire's approach says: small plug-in solar systems should not be treated like full-scale solar generators, but they still need clear safety, consumer education, and building-code guardrails.
Why 1,200 Watts?
One important design question was system size. Watters said the team considered several approaches: limiting the number of devices, setting a wattage cap, or allowing different categories. The bill ultimately landed on one plug-in solar system per metered customer, with a maximum inverter output of 1,200 watts AC.
That number helped address utility concerns. Evans-Brown said utilities in New Hampshire often describe the average residential base load as roughly 1.2 kilowatts. That made a 1,200-watt cap easier for utilities to understand and accept. From the utility perspective, a system of that size is more like an efficiency measure that offsets behind-the-meter consumption than a generator that requires major distribution-system upgrades.
Utilities still wanted visibility into what was happening on their systems. The compromise was a notification or registration concept, focused on information rather than prior approval. New Hampshire did not want utilities to have veto power over compliant plug-in solar systems, but it did recognize that utilities may want to know how many systems are being used and where.
The Surprise-Billing Issue
Plug-in solar savings depend on more than sunlight and panel size. They also depend on how much electricity a customer is using at the same time the system is generating power, how the customer's utility meter works, and how the utility treats excess generation.
Watters said New Hampshire wanted to address the fact that Eversource NH customers will be charged for power they send back to the grid, due to quirks in Eversource's billing and metering systems. The solution was not to require every customer to install a new meter — that could increase costs and make plug-in solar less accessible. Instead, the bill requires consumer-facing information through the Department of Energy, including warnings about meter compatibility and billing impacts.
This is a major implementation lesson for other states: plug-in solar is not only a product question. It is also a billing, meter, consumer-information, and expectation-management question. A customer who expects easy savings could become frustrated if their meter configuration causes unexpected charges. That kind of bad early experience could damage public confidence in the entire category. New Hampshire's approach tries to reduce that risk through education.
Why the Building Code Review Board Mattered
One distinctive feature of New Hampshire's approach is the role of the Building Code Review Board. Watters said UL and other standards are still evolving. Rather than hard-coding detailed technical rules into statute, New Hampshire chose to rely on the Building Code Review Board to incorporate recognized safety standards as they become available.
That flexibility was important because plug-in solar is still a developing category. Standards, products, circuit requirements, safety plugs, dedicated-circuit rules, and installation practices may change over the next few years. If lawmakers write too much technical detail into law, the statute may quickly become outdated. If they write too little, safety officials may be uncomfortable. The Building Code Review Board gave New Hampshire a middle path.
Evans-Brown said this approach also reflected stakeholder trust. Clean Energy New Hampshire had long-standing relationships with members of the Building Code Review Board, including people who understood both solar and code enforcement. That allowed the bill to move forward without forcing lawmakers to decide technical questions better handled by safety and code experts.
A Coalition Built Before the Hearing
Evans-Brown emphasized that the bill's success came from engagement before conflict hardened. Clean Energy New Hampshire began reaching out to stakeholders before the first public hearing. The organization spoke with utilities, electricians, code officials, building inspectors, and other participants to understand concerns early.
After the hearing, the group moved quickly into working sessions, including broader stakeholder meetings and smaller subgroups focused on specific issues. Evans-Brown said there were effectively two major concern groups: utilities on one side, and electricians and code inspectors on the other. Their concerns were different, so the process allowed them to work through issues separately and then bring the language back together.
The process was line-by-line, iterative, and relationship-heavy. In a small state like New Hampshire, that mattered.
"In a state like New Hampshire, I think you just have to remember that all these people are people. You're best off treating them like people and talking to them."
The Role of Clean Energy New Hampshire
Clean Energy New Hampshire was well positioned to convene the process because its membership includes a broad mix of stakeholders: individuals, municipalities, businesses, utilities, solar companies, and energy professionals. Evans-Brown said all four of the state's utilities participate in the organization in some form, along with both union and non-union electrical voices. That gave the organization a platform to bring people together rather than treating every disagreement as a public fight.
He also highlighted the importance of staff and institutional knowledge. Clean Energy New Hampshire had people who had been attending Building Code Review Board meetings for years. Those relationships made it easier to understand how code officials think and what kind of language would be acceptable.
For advocates in other states, that may be one of the biggest lessons: technical credibility and trusted relationships can matter as much as the bill text itself.
Mike Hagan as a Bridge-Builder
Evans-Brown singled out Mike Hagan, the building inspector for the city of Keene, as especially important. Hagan was able to speak the language of code inspectors, electricians, and solar advocates. Evans-Brown described him as a bridge between the safety community and the clean-energy community.
That kind of bridge is critical in plug-in solar because the category sits at the intersection of consumer energy, home wiring, utility rules, product standards, building codes, and electrical safety. A solar advocate may focus on access and affordability. An electrician may focus on circuit safety. A building inspector may focus on code enforceability. A utility may focus on grid operations and billing. A successful bill has to make sense to all of them. In New Hampshire, Hagan helped translate between those worlds.
Taking Safety Concerns Seriously
Evans-Brown was clear that safety concerns should not be dismissed. Even when some worries sounded exaggerated, he said advocates still need to take electricians, code officials, and safety professionals seriously — otherwise, they will not build the trust needed to pass legislation or protect consumers.
The category's promise depends on consumer simplicity. But simplicity cannot mean ignoring wiring, circuit configuration, anti-islanding, breaker behavior, plug safety, product certification, and local code requirements.
Evans-Brown warned that one bad incident could damage the entire category. A staff member at Clean Energy New Hampshire described the risk bluntly: plug-in solar cannot become the "lawn darts" of the clean-energy transition. That means advocates need to promote access and safety together — not as opposing goals.
Electricians: Threat or Opportunity?
In some states, electricians and electrical unions have raised concerns about plug-in solar. From one perspective, the product sounds like it could reduce electrician work: if consumers can simply plug in solar panels, who needs installation labor?
But Evans-Brown argued that the reality may be different. Depending on UL 3700, the National Electrical Code, and final installation practices, many consumers may need safer outlets, dedicated circuits, circuit reconfiguration, or other electrical work. Renters and multifamily residents may especially need professional support. That means plug-in solar could create work for electricians rather than eliminate it.
New Hampshire also faces an electrician shortage, which makes the fear of lost work less compelling. Watters said the state will need more electricians for years to come.
The lesson for other states: do not assume electricians will automatically oppose plug-in solar, but do engage them early. Show how the category can create safe, professional work rather than bypass safety expertise.
Utilities Saw It Differently Than Rooftop Solar
Utilities had concerns, but Evans-Brown said they did not necessarily view plug-in solar as a major threat. Because the systems are small and mostly offset consumption behind the meter, some utilities saw them more like energy-efficiency measures than generation resources requiring major grid upgrades.
He even noted that one utility leader suggested plug-in solar could potentially fit within NHSaves, the state's energy-efficiency program. That framing is important. If plug-in solar is viewed only as a generator exporting to the grid, utilities may treat it like rooftop solar and push for interconnection controls. If it is viewed as a small behind-the-meter load-reduction product, it may be easier to integrate. New Hampshire's 1,200-watt cap helped support that framing.
Smart Meters and Grid Modernization
The conversation also touched on a deeper problem: many utilities do not have modern data systems or smart-meter infrastructure. Evans-Brown said utilities often want to know what is on their system, but the larger issue is that grid data is often poor. Watters also noted that utilities in New England have resisted next-generation meters.
That matters because plug-in solar is part of a bigger distributed-energy future. A modern grid will need better visibility, better customer billing tools, better sensors, and better software. Plug-in solar is small, but it reveals bigger questions: how will utilities manage a future where more customers have solar, batteries, electric vehicles, flexible loads, and distributed energy resources? New Hampshire's bill does not solve those issues. But it points toward them.
Who Will Benefit First?
Although plug-in solar is often framed as a solution for renters, Watters and Evans-Brown were realistic about early adoption. They expect homeowners may benefit first.
Homeowners are more likely to control their property, have a deck, yard, porch, garage, shed, camp, or suitable outdoor space, and have the ability to make small electrical changes. Some may treat plug-in solar as a "starter solar" product before considering rooftop solar or storage. Watters also mentioned hunting camps, summer camps, and off-grid or semi-off-grid use cases, where people already use portable panels, batteries, or small generators.
Renters remain an important long-term target, but Evans-Brown warned that if final safety standards require dedicated circuits or do not create a practical lower-power pathway, many renters may be left out. That is why he believes national advocates should pay close attention to the UL 3700 process.
The UL 3700 Question
UL 3700 is one of the most important next steps for plug-in solar nationally. Evans-Brown said New Hampshire explored whether there could be a lower-power pathway, around 400 watts, that would allow simpler plug-in use. But the Building Code Review Board was not comfortable creating that pathway without UL or another nationally recognized safety body confirming that it was safe.
"They were like, listen, if that is safe, the UL will figure that out."
That means the UL process will shape how accessible plug-in solar becomes. If UL 3700 treats all systems the same — requiring the same controls, dedicated circuits, or installation conditions regardless of size — then renters may face major practical barriers. If the standard creates appropriate distinctions for lower-power systems, broader access may become easier.
Evans-Brown urged national organizations to participate in that process. For state lawmakers, this is a reminder that legislation can open the door, but standards determine how wide the door becomes.
Do Not Overpromise
Evans-Brown was enthusiastic about plug-in solar, but he also warned against overpromising. He said plug-in solar may have less impact in the United States than it has had in Germany because the two countries have different electrical systems, market structures, housing conditions, and policy environments.
That does not mean plug-in solar is unimportant. It means expectations need to be realistic. Consumers should not think they can plug multiple systems into random outlets and automatically save money safely. Circuit configuration matters. Metering matters. Product certification matters. Usage patterns matter. Battery integration matters. Plug-in solar can be useful, but only if consumers understand how to use it safely and effectively.
Battery Integration May Be the Real Unlock
Evans-Brown said the biggest future unlock may be battery integration. Without batteries, plug-in solar savings depend on using electricity at the same time the system is producing it. If the sun is shining but the household load is low, excess production may not create much value — and in some cases could create billing complications.
With batteries, customers can store solar generation and use it later, better matching production to household demand. Evans-Brown put it simply: without storage, customers may need to be "toasting your toast furiously when the sun is out" to maximize savings.
Watters also sees batteries as the next policy frontier. But he noted that battery storage raises its own code and fire-safety challenges, including installation location, fire separation, cold-weather performance, and cost. That means New Hampshire's plug-in solar bill may be step one. A future battery bill could be step two.
Plug-In Solar and the Politics of Visibility
Watters sees plug-in solar's value not only in direct electricity savings, but also in visibility. When people see a neighbor using a plug-in solar system on a deck, backyard, or camp, it can normalize solar in a way that policy speeches cannot. He compared it to electric vehicles: seeing a neighbor with an EV, or passing a charging station, changes how people think about the technology.
"Once your neighbor puts one of these out in their backyard or on their deck or something, that has as much impact as anything I or Sam can say."
In a state where renewable energy can be politically difficult, that visibility matters. Plug-in solar can make solar feel tangible, local, and personally controlled. Watters called it a "power to the people" idea.
Distributed Energy and the Future Grid
The interview also touched on data centers, rising energy demand, and grid capacity. Evans-Brown said he is bullish on distributed energy resources more broadly because they can help open up capacity on the bulk transmission system. Plug-in solar alone may not be the category that transforms the grid, but it is part of a broader shift toward distributed generation, storage, demand response, and customer-side energy resources.
That broader distributed-energy future will require more than small solar panels. It will require batteries, smart meters, modern utility software, flexible loads, and better coordination between consumers and the grid. But plug-in solar can be an entry point — helping consumers understand that energy is not only something delivered from far away by a utility, but also something produced, managed, and partly controlled at home.
What Still Needs to Happen in New Hampshire
New Hampshire has created a policy pathway, but several things still need to happen before plug-in solar becomes widely practical.
First, UL 3700 and other applicable standards need to mature. Consumers, code officials, utilities, manufacturers, and retailers need clarity on what qualifies as a safe system. Second, the Building Code Review Board needs to incorporate appropriate standards into the state's code framework. Third, the Department of Energy needs to create clear, accurate consumer information — Watters emphasized that the state website must get this right, because consumers need one trusted place to understand safety, billing, meter compatibility, and practical use.
Fourth, prices need to fall. Evans-Brown said current systems may still be too expensive for many households, but he expects competition to increase and prices to drop as more states act and manufacturers see a national market. Fifth, local solar installers, electricians, and community organizations need to decide whether they will offer plug-in solar as a product or service. Finally, battery integration needs to become safer, cheaper, and easier if plug-in solar is going to deliver stronger savings and resilience.
Lessons for Other States
Asked what other states should learn from New Hampshire, Watters gave a simple answer: "You need a Sam Evans-Brown."
By that, he meant that states need trusted conveners — people and organizations that can bring together utilities, electricians, code officials, building inspectors, solar advocates, businesses, and lawmakers. Legislators can introduce bills, but stakeholder trust often determines whether the bill survives.
Watters also advised states to think small and stay practical. Do not try to solve every issue at once. Focus on the core barrier, make the bill fit the state's political culture, and leave room for technology and standards to evolve.
Evans-Brown's lesson was similar: build relationships before the fight, take safety concerns seriously, and work through language collaboratively. That may be New Hampshire's biggest contribution to the national plug-in solar movement — showing that even in a politically difficult environment, a careful, relationship-driven, safety-first process can move the category forward.
A Message to Consumers
Evans-Brown's message to consumers was direct: do your homework. Understand where the system can be plugged in. Understand how to use it safely. Understand how to get the most value. Do not assume every product advertised online is safe or compliant. He also suggested that some consumers may want to wait as the market develops, standards become clearer, and prices come down.
Watters offered a more optimistic version of the same advice: plug in, turn on, and save some money — but make sure you know what you are doing and rely on trusted information. That combination captures New Hampshire's overall approach. Plug-in solar should be accessible. It should empower consumers. It should help people participate in clean energy. But it must be safe, informed, and realistic.
New Hampshire's Place in the National Movement
New Hampshire's SB 540 is important because it shows a different model for plug-in solar legislation. Utah showed how to remove a utility-contract barrier. Colorado created one of the most ambitious state frameworks. Connecticut embedded plug-in solar inside a broader renewable-energy package. New Hampshire focused on stakeholder trust, code-board flexibility, consumer education, and avoiding the net-metering fight.
The state did not try to solve every problem. It did not force a landlord-access battle. It did not create a broad battery framework. It did not hard-code every technical requirement into statute. Instead, New Hampshire created a careful pathway and handed key implementation questions to the institutions best positioned to address them.
That may make the law less flashy than some other state approaches. But it may also make it durable. For a new category like plug-in solar, durability matters. The market is early. Standards are evolving. Prices may fall. Products may change. Batteries may become central. Renters may need additional protections. Electricians may become key partners. Utilities may eventually treat these systems like efficiency resources.
New Hampshire's approach leaves room for that future. It is a first step — deliberately incremental, safety-conscious, and coalition-built. And in a state where solar policy has often been difficult, that first step may be exactly what was needed.
Source Notes: Primary sources for this article include an interview with Sen. David Watters and Sam Evans-Brown regarding New Hampshire SB 540; public legislative materials and bill summaries for New Hampshire SB 540 ("relative to plug-in solar generation systems"); public information on UL 3700, National Electrical Code considerations, Building Code Review Board processes, and plug-in photovoltaic safety; and background research on emerging U.S. plug-in solar legislation. Direct quotes have been lightly edited for clarity and readability without changing their intended meaning.
Disclaimer: PluginSolarUS.com provides general educational information only. This article is not legal, electrical, engineering, product-safety, installation, or financial advice. Before purchasing or installing any plug-in solar product, consumers should confirm current requirements with applicable state law, local building and electrical authorities, their utility, their landlord or HOA where applicable, and a qualified electrician if needed. Laws, standards, utility rules, product certifications, and installation requirements may change over time.