The undersigned parties (together, “Petitioners”) hereby submit these brief comments on the Joint Petition Regarding Community Credit Compensation that Petitioners filed on March 10, 2021 in this docket (“Petition”). These comments are submitted in response to the notice published in the NYS Register on April 21, 2021, I.D. No. PSC-16-21-00006-P, and are intended to provide an update on community distributed generation (“CDG”) market activity and regulatory proceedings in the three months since the Petition was filed.

In particular, and as detailed herein, Petitioners emphasize that: (i) there is an impending cliff in the Con Edison CDG market based on the limited remaining Community Credit capacity and as a result prompt Public Service Commission (“Commission”) action is required on the Petition; (ii) the soundest option for maintaining near- and mid-term certainty in this market is to replace the Community Credit capacity previously allocated to fossil-fired fuel cells at the full $0.12/kWh as requested in the Petition; and (iii) the Commission may consider a modified or tiered approach to incremental Community Credit capacity, beyond that requested in the Petition, that reduces the value of the Community Credit depending on system size.

PETITIONERS

City of New York

New York City Housing Authority

New York City Economic Development Corporation

New York Solar Energy Industries Association

Solar One

Sustainable Westchester, Inc.

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