On October 7, 2024, NYSEIA submitted initial comments in the RAPID Act proceeding, a legislatively mandated proceeding "to review the cause and extent of any delays to interconnection of distributed energy resources...consider metrics related to the timely interconnection of distributed generation resources into the distribution system owned by an electric corporation, as well as revenue adjustments related to such metrics.”

NYSEIA's comments begin with an analysis of interconnection timelines over the last five years, which show that timelines have gotten longer for large and medium sized distributed energy resources (DER) and no meaningful improvements were made for small (residential) project timelines:

NYSEIA's comments continue with a number of statements and recommendations for the Commission's consideration:

Expediting Interconnection Requires a Holistic Approach: NYSEIA's comments advocate for the Commission to look holistically at the interconnection process and to identify opportunities for improvement even if they are not timelines that are currently governed by the Standardized Interconnection Requirements.

Unique Approaches Are Needed for Different Market Segments: as demonstrated above, timelines vary significantly by system size and therefore distinct metrics and incentives are needed to drive meaningful improvements in each of these unique market segments.

Accelerating Interconnection Requires Ambitious Goals, Carrots and Sticks: rather than simply creating penalties and incentives based upon the current timelines governed by the SIR, NYSEIA encourages the Commission to consider incentives and penalties that are broader and tied to achieving outcomes that the Commission, utilities and DER stakeholders agree are impactful from a CLCPA perspective, e.g., doubling annual DER deployment or halving of DER interconnection timelines. NYSEIA asserts that ambitious goals paired with meaningful incentives and penalties are more likely to deliver meaningful progress than simply enforcing current SIR requirements.

NYSEIA's comments included responses to each of the Commission's five questions, which state that: 1) NYSEIA supports evaluating interconnection data from the last five years; 2) NYSEIA believes the Commission should evaluate several post CESIR milestone timelines that are not currently governed by the SIR, including design and construction of distribution upgrades; 3) while most delays caused by DER developers are reasonable (e.g. moratoria, zoning issues), they should also be considered in the analysis; 4) the SIR inventory is one valuable data set that can be used to analyze utility performance (which should be supplemented by utility data disclosures and a DER developer survey); and 5) the SIR inventory and data from the utilities can similarly be analyzed to show delays not caused by the utility.

NYSEIA's comments also note that lack of cost certainty and rising interconnection costs paired with poor oversight are major interconnection issues that should be urgently addressed, in this proceeding or otherwise.