What's Good in the Draft
The draft regulations contain three provisions that are genuinely positive and align with regional best practice. First, the export credit rate is set at 85% of the retail tariff — meaning for every kWh you export to the APUA grid, you receive a bill credit worth 85% of what you'd pay to buy that kWh. At EC$0.4644/kWh retail, the export credit is EC$0.395/kWh. This is a reasonable rate; it's not the full 1:1 credit that Jamaica offers, but it's above the 75-80% range seen in some other Caribbean jurisdictions and reflects a fair balance between consumer interest and utility cost recovery.
Second, the draft establishes a 12-month rolling credit balance, meaning unused export credits don't expire at the end of each billing cycle but accumulate over a year. This is essential for seasonal generation patterns — Antigua's sunniest months are roughly March-June, and without rolling credits, solar owners would lose the value of summer surplus generation rather than banking it against winter bills. Third, the draft requires APUA to process complete net metering applications within 45 business days — a binding timeline that doesn't currently exist and would reduce the current 14-week average processing time if enforced.
What's Problematic: The 5kW Cap
The most significant problem with the draft regulations is the residential system size cap of 5kW. For the median Antiguan household this is adequate — a 5kW system covers approximately 100% of typical consumption. But for larger homes, households with electric vehicles, or properties with high air conditioning loads, 5kW is genuinely insufficient. A household consuming 700 kWh/month would need approximately 7-8kW to offset their full consumption. The 5kW cap forces them to either undersize their investment (foregoing savings and payback improvement from larger systems) or install 5kW and remain partly dependent on grid electricity.
The cap appears to be driven by APUA's concern about grid hosting capacity — the technical limit on how much distributed generation any given feeder line can safely accommodate without voltage problems. This is a legitimate engineering concern, but the right solution is a hosting capacity analysis that identifies which feeders can accommodate more than 5kW, not a blanket cap that penalizes all customers equally. St. Lucia's regulations use a 25kW cap for residential customers and Jamaica's uses 30kW — both without evidence of widespread grid stability problems. We recommend stakeholders submit comments requesting the cap be raised to at least 10kW with provisions for larger systems where feeder hosting capacity permits.
What's Unclear: Interconnection Standards
The most technically critical gap in the draft regulations is the section on interconnection standards, which states that systems must comply with "APUA's technical requirements for distributed generation as amended from time to time" — without actually specifying what those requirements are or where they can be found. This matters enormously for solar installers and equipment suppliers: a vague reference to APUA's internal standards creates a situation where APUA can effectively require anything it chooses of an applicant, with no fixed standard for installers to design to and no basis for an applicant to challenge an arbitrary rejection.
Best-practice frameworks (including the OECS model regulations that Antigua's draft is based on) require the interconnection standards to be appended to the regulations as a technical schedule — published, public, and legally binding on APUA as well as applicants. Without this, the regulations risk creating a system where the 45-day processing window is met procedurally but approvals are delayed indefinitely through requests for additional technical information under loosely defined standards. This is the mechanism by which APUA could, intentionally or not, undermine net metering in practice even after the regulations are enacted.