Colorado Joins Michigan, Maryland, and California in Clarifying Treatment of EV Home Backup Power Systems
By Zach Woogen, Executive Director
The Vehicle-Grid Integration Council (VGIC) applauds the Colorado Public Utilities Commission (PUC) for approving a settlement clarifying how electric vehicle (EV) charging systems with home backup power features are treated under the state's utility distribution system interconnection rules. The settlement, reached by VGIC Leadership Circle Member Ford Motor Company, Xcel Energy, and Black Hills Colorado Electric – and unopposed by Commission staff – was approved and became the decision of the Commission on Thursday, October 22, 2026.
In December 2025, Ford issued a petition asking the PUC to confirm that the automaker’s F-150 Lightning Home Backup Power (HBP) feature, and its Home Power Management (HPM) feature when disabled, are not subject to Colorado's interconnection rules. The rules include "electric vehicle chargers with vehicle to grid, vehicle to home, vehicle to building" in the definition of an interconnection resource, but are silent on:
(a) systems that only discharge when the home is islanded from the grid, and
(b) systems that are capable of but not enabled to discharge in any configuration.
VGIC filed comments in February supporting Ford's request, as did VGIC General Member Tesla, which offers a similar Powershare Home Backup feature.
The approved settlement includes the following provisions:
EV charging systems enabled for bidirectional operation (i.e., vehicle discharge) while in parallel with the grid are subject to the state’s interconnection rules. This includes the F-150 Lightning with HPM enabled, which can discharge to the home or the grid while the grid is operating. This is consistent with VGIC’s 2022 V2X Bidirectional Charging Systems: Best Practices for Service Connection or Interconnection and with the current treatment of systems in California, Maryland, New York, Massachusetts, Connecticut, Michigan, New Mexico, Washington, Oregon, and other states that have previously or are actively interconnecting bidirectional charging systems configured to discharge while in parallel to the grid.
EV charging systems in load-only mode are not interconnection resources. EVs with grid-parallel features disabled, such that they can only charge, are not subject to the state’s utility interconnection rules and do not need to go through any interconnection application or notice process. This includes F-150 Lightnings with HBP and HPM disabled via software. This is critical, as we noted when Maryland adopted its comprehensive slate of interconnection rules for bidirectional charging systems. Otherwise, the mere capability to discharge could pull all owners of the 20 light-duty vehicle models that currently offer grid-parallel bidirectional charging features, the two light-duty vehicle models that currently offer only home backup power, and nearly every electric school bus sold in the U.S. since 2021, into a potentially lengthy, costly, and complex utility approval process regardless of whether they ever plan to use that feature.
Utilities can leverage a simplified notification process for backup-only systems. For EVs with Ford's HBP feature, or EVs and generators from other manufacturers with similar home backup power features, Xcel Energy and Black Hills can leverage a customer notification process. Importantly, the notification process is not an interconnection application and is not subject to utility approval. The utility only reviews it for completeness and accuracy. The notice would collect only the following information:
Customer name
Service address
Attestations that the customer has an EV with backup power features or a backup generator, has a permit from the local Authority Having Jurisdiction, and understands they may only use backup power when the home is not receiving power from the grid.
There is no penalty for failing to submit a notice. If a utility finds that a customer has not submitted one, the customer gets at least 60 days to complete it electronically. Customers who installed their system before October 22, 2026, are not required to submit a notice.
The Settlement Leverages the Technical Basis of Existing Home Backup Generators and Batteries
Ford's HBP system uses a disconnect device that operates in a "break-before-make" fashion, meaning the home is fully electrically disconnected from the grid before the vehicle ever discharges power. Testing by the Electric Power Research Institute (EPRI) confirmed that the device waits roughly 90 seconds after detecting an outage before allowing the vehicle to power the home, and that the system cannot backfeed the grid. Functionally, this looks a lot more like a standby generator than a rooftop solar system, and the settlement treats it that way.
Xcel Energy’s original proposal would have required these customers to apply through its interconnection portal, submitting a one-line diagram, system size, installation date, proof of permitting and inspection, and photos of the installation. The final notice is a significantly improved approach. Utilities want visibility into where backup systems are installed, and the notification process gives them that without requiring customers to move through an approval process that was never designed for this technology, but instead designed for power plants and, later, adapted to rooftop solar systems. The final adopted approach is also consistent with the Colorado General Assembly's direction that utility processes for customer-sited energy storage be "simple, streamlined, and affordable."
Colorado Joins Maryland, Michigan, and California in Providing the Necessary Clarification
Colorado's approach closely tracks Maryland's V2G interconnection rules, adopted in 2025, which specify that customers with backup-only systems may need to notify the utility, but that only systems configured to discharge while operating in parallel to the grid need to move through the adopted interconnection process. It is also consistent with the long-standing norm for integrated backup generators in California. For example, Pacific Gas & Electric stated in its 2024 VGI Strategy Report that “…we have established an option to bypass interconnection for solutions that are configured to not allow operation parallel to the grid as in the example of solutions that only support islanded backup.” California’s Health and Safety Code does require customers to notify their electric utility of the existence of a backup power system. In March 2025, the Michigan Public Service Commission issued a Declaratory Ruling finding that Ford's HBP system “will not operate in parallel with the electric utility’s distribution system” and “cannot export active power to the distribution system,” and therefore “does not require written authorization” under Michigan's interconnection rules. For automakers and charging manufacturers trying to bring bidirectional products to market in many states at once, this growing alignment is critical.
Where to Next? Connecticut, Texas, Nevada, New York, New Jersey, New Mexico, Maine…
VGIC is proud to continue supporting this and related leading-edge policy and regulatory work across the U.S. and, through strategic collaboration, Canada. We anticipate regulatory direction on a utility proposal consistent with this approach in Connecticut and are an active party to related proceedings in Texas and Nevada. We’ve also raised the issue in New York, New Jersey, and New Mexico, and VGIC General Member EquinoxDG has raised it alongside partners in Maine. While clarity on the applicability of interconnection rules is not always necessary, it can provide manufacturers with a degree of certainty that supports product strategy, development, and launch.
VGIC commends Ford, Xcel Energy, Black Hills, and the Colorado PUC for resolving this proceeding through settlement in roughly ten months. With this decision, Colorado takes yet another step toward unlocking more value from EVs, whether that means backup power systems that keep the lights on during an outage or utility-interconnected bidirectional charging systems that save or earn customers money during blue-sky conditions.
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