NYSEIA, in partnership with the Solar Energy Industries Association, the Coalition for Community Solar Access and the Alliance for Clean Energy New York (collectively the "Clean Energy Parties") submitted comments in response to NYSERDA's NY-Sun Mid-Point Review. Our comments voiced support for several recommendations that were included in the NYSERDA/DPS filing, but also included some additional recommendations to strengthen the solar market over the long term. Key points included:

• The rapid achievement of the Mid-Point Review trigger demonstrates the immense potential for distributed solar, provided that the State continues to provide support through NY-Sun and key interconnection and siting issues are addressed

• While the industry made rapid progress over the last few years, rapidly escalating interconnection costs paired with inflation and supply chain issues threaten continued progress

• NY-Sun incentives are an important bulwark against rising costs, and incentives are needed on an ongoing basis

• VDER Value Stack improvements are critical to accurately compensate clean DERs for the value they provide to the grid, ratepayers and the environment. We recommend reconvening the VDER Working Group

• We agree with NYSERDA's recommendation that the utilities enable multiple discount rates for net crediting customers, which is particularly important for efforts to provide community solar bill savings to low-income households

• Utility failure to properly administer billing & crediting for New York's community solar program remains an ongoing issue, and threatens to undermine New York's position as a leading community solar market; robust action is needed to increase utility accountability and performance

• High interconnection costs are a frequent cause of project cancellation, and NYS analysis of interconnection costs needs to consider cancelled projects as well as those that move forward in order to set appropriate compensation and incentive levels

Click "READ MORE" to view our full comments.