1) Introduction

The Clean Energy Parties (“CEP”) thank the New York State Energy Research and Development Authority (“NYSERDA”) and the New York State Department of Public Service (“DPS”) for its ongoing support of commercial and industrial (“C&I”) solar projects, including community distributed generation projects (“CDG”), also known as community solar, in New York State. Together C&I and CDG projects in New York have installed 2.7 gigawatts of clean electricity capacity, created thousands of good jobs and extended the benefits that solar can provide to more New Yorkers than ever before.

With NY-Sun incentive monies for this market segment upstate now fully allocated, and other resources in New York also on the cusp of being fully allocated, the solar industry is at a crossroads. As NYSERDA stated in their April 21, 2021, technical conference presentation, commercial solar and CDG must continue to play a key role in order for New York to meet its climate and economic objectives. Massive amounts of additional clean electricity are needed to meet the overall goals of the Climate Leadership and Community Protection Act (“CLCPA”).

a) To continue to support C&I and CDG solar in New York regulators should improve and build upon the VDER tariff.

Together, NYSERDA and DPS have created a strong policy foundation to support C&I and CDG solar. The Value of Distributed Energy Resources (“VDER”) tariff approved by the Public Service Commission (“PSC or Commission”) established a fair compensation structure for large- scale distributed solar projects. Furthermore, NYSERDA’s NY-Sun declining block incentive program, also approved by the PSC, encouraged solar developers to invest heavily in New York by providing a transparent and predictable incentive structure.

The declining block structure allowed developers to continue investing in projects even when the specific incentive level a project would receive was not known at the time they commenced the development process. The result of this ongoing public, private partnership has been a stable, growing market for C&I and community solar. The CEP appreciate that NYSERDA and DPS have convened two technical conferences to discuss the future of this market segment and that regulators are considering multiple options to sustain and grow this industry.

The CEP recommend modest adjustments to the VDER tariff to improve its accuracy, which will enable state regulators to reach the stated goals of the NY-Sun program for the C&I segment of the solar industry—phasing out direct incentives and creating a self-sustaining market. As we will explain in these comments, the CEP strongly recommend that as NY-Sun’s C&I/CDG funding comes to an end, the PSC responds by improving VDER’s compensation as well as increasing New York’s 6 gigawatt (“GW”) distributed solar goal.