On January 29, 2024 New York Solar Energy Industries Association and the Coalition for Community Solar Access jointly submitted comments to the PSC in support of expanding New York's net crediting program to volumetric CDG projects and customers.

NYSEIA and CCSA's comments note that the volumetric CDG projects and customers were early adopters of community solar, and should enjoy the benefits of net crediting just like new community solar customers.

NYSEIA and CCSA advocate for rapid implementation of net crediting for volumetric CDG projects and customers (within 6 months of an Order).

NYSEIA and CCSA also encourage the PSC to consider directing New York's utilities to:

• eliminate volumetric crediting caps that are no longer relevant, result in banked credits and delayed customer savings; and

• enable net crediting for remote crediting, which would be a materially similar software update and would allow more small businesses and nonprofits to participate in distributed generation.