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Ford Seeks Declaratory Order From Texas PUC Concerning Ford Home Backup Power System
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Ford Motor Company sought a declaratory order from the Texas PUC, "affirming Ford’s interpretation of the
Commission’s rule at 16 Texas Administrative Code § 25.211 that installation by a retail customer
of a Ford Home Backup Power system does not require an application for interconnection and
parallel operation of on-site distributed generation, nor does such installation of a Ford Home
Backup Power system require the customer to execute an interconnection agreement with the local
utility, because the Ford Home Backup Power system cannot operate in parallel with the utility
distribution system."
Ford stated, "This proceeding arises from Ford’s and its customers’ experiences with some distribution
utilities that have sought from the customer an application for interconnection and parallel
operation of a Ford Home Backup Power system even though the Ford Home Backup Power
system cannot operate in parallel with the utility distribution system."
Ford said, "A live controversy exists because at least one utility that owns and operates distribution
facilities in Texas requires customers to submit an application for interconnection before the
customer can install a Ford Home Backup Power system in that utility’s service area."
16 Tex. Admin Code § 25.211 provides that, "to interconnect distributed generation to a utility
system, a customer must first submit to the utility an application for interconnection and parallel
operation with the utility system and execute an interconnection agreement on the forms prescribed
by the commission."
The Ford Home Backup Power system uses the battery in a Ford F-150 Lightning pickup truck to provide power to the Ford F-150 Lightning owner’s residence during a
grid outage.
Ford, "seeks clarification of what it
believes the rule at 16 Tex. Admin Code § 25.211 provides -- that a home backup power source
that does not and cannot operate in parallel with the utility system is not 'on-site distributed
generation' as defined by the rule and needs no 'interconnection' as defined by the rule, because
of the lack of parallel operation."
Ford stated, "The Ford Home Backup Power system employs a 'break before make' control system that
prohibits the flow of electricity from the battery of a Ford F-150 Lightning to the customer’s home
unless the system has confirmed that the customer’s home is isolated from the utility distribution
system. A 'break before make' switch ensures that one set of contacts (in this case, contacts
between the customer’s home and the distribution grid) are open (i.e., electricity is not flowing
across those contacts) before the second set of contacts (in this case, contacts between the Ford
F-150 Lightning and the customer’s home) are closed to allow flow of electricity (from the
Lightning to the home). Consequently, it is not possible for the Ford Home Backup Power system
to function as 'distributed generation while the customer is connected to the company’s utility
system.' Thus, the Ford Home Backup Power system cannot function in 'parallel operation' as
defined by the rule."
"Consequently, parallel operation
cannot occur (i.e., the Ford Home Backup Power system cannot be in operation 'while the
customer is connected to the company’s utility system,' 16 Tex. Admin Code § 25.211(c)(11))
and therefore 'interconnection' cannot occur, since 'interconnection' is a physical connection to
the utility system 'so that parallel operation can occur.' Id. § 25.211(c)(6)," Ford said
Docket 59176
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December 29, 2025
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Reporting by Paul Ring • ring@energychoicematters.com
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