National Grid USA has sought FERC approval of a transaction under which National Grid Green Homes Inc. (Green Homes), a wholly-owned direct subsidiary of National Grid, will acquire from Sunrun Inc. rights to participate in Sunrun’s 'grid services' activities, including wholesale energy and capacity sales, for the rooftop solar facilities owned by Sunrun.

This includes potentially providing grid services from a small portion of the rooftop solar distributed generation facilities in the "Equity Portfolio" described below, a subset of Sunrun-owned rooftop solar generation facilities in which National Grid holds certain non-voting securities

Green Homes currently holds non-controlling equity interests in a portfolio of approximately 216 MW of Sunrun’s residential solar facilities located throughout the United States (Equity Portfolio). However, the additional control rights over the energy sales activities of those facilities National Grid is seeking through Green Homes in the Proposed Transaction for grid service appears to be beyond those limited rights the Commission permits for non-voting equity investors. Therefore, National Grid is seeking Commission approval to acquire these additional control rights out of an abundance of caution

The Equity Portfolio consists of over 28,000 residential solar systems, the voting equity interests in which are wholly and indirectly owned by Sunrun Neptune Investor 2016, LLC. All of the facilities in the Equity Portfolio are less than 30 kW at each residential home, with the vast majority less than 10 kW. The subsidiary companies in the Equity Portfolio sell electric energy generated on the homeowner’s property directly to the homeowner under long-term agreements that may include power purchase agreements or leasing agreements

The aggregate size of the facilities in the Equity Portfolio located in RTO regions is as follows:

• ISO-NE: 23.2 MW

• PJM: 47.6 MW

• CAISO: 52.4 MW

• NYISO: 13.7 MW

In the Proposed Transaction, National Grid will acquire rights to participate in Sunrun’s grid services activities for the Sunrun portfolio of rooftop solar generation facilities, including potential wholesale energy and capacity sales from the portion of the rooftop solar distributed generation assets in the Equity Portfolio in which National Grid indirectly holds certain non-voting securities.

Only a small portion of the generation facilities in the Equity Portfolio will likely be able and used to provide grid services, but because the exact portion of those facilities providing grid services cannot be identified with specificity ahead of time, the application makes the conservative simplifying assumption that all of the generation in the Equity Portfolio could be used to provide grid services.