On September 23, 2024, NYSEIA submitted comments in response to NYSERDA and DPS' Draft Clean Energy Standard Biennial Review.

While the Clean Energy Standard (CES) is principally focused on Large-Scale Renewables, the CES filing was the first major public disclosure by New York's energy agencies that we are not on track to achieve New York's renewable electricity mandates with a business-as-usual approach. The NYSERDA/DPS filing outlines a partial plan and a series of recommendations to help New York close its reenwable energy electricity gap.

NYSEIA's comments include the following high-level points:

• New York must be unwavering in its commitment to the mandates of the CLCPA

• A new 70X30 strategy that bolsters deployment of LSR, energy efficiency and distributed solar is needed

• Scaling up distributed solar deployment to 20 gigawatts by 2035 can help New York close its renewable electricity supply gap while delivering immense benefits to New Yorkers

• Policy interventions are needed in order to scale up distributed solar deployment

Proposed Policy Interventions

• Interconnection Reform

  • The Public Service Commission must regulate utility distribution upgrade costs

  • The Commission should support flexible interconnection at scale

  • The Commission should direct New York utilities to make proactive investments in the distribution system to increase DER hosting capacity

  • The Commission should incentivize utilities to cost-effectively achieve CLCPA mandates

• Community Solar Siting Reform

  • New York should streamline zoning approvals for community solar

  • New York should develop freshwater regulations for distributed solar that balance ecological conservation with climate mitigation

• DER Compensation and Incentives

  • The Commission should continue to improve DER compensation, protect net energy metering, and promote energy storage

  • The Commission should authorize continued investment in the NY-Sun program, including targeted incentives for beneficial siting and LMI benefit projects

  • Additional funding sources should be leveraged to mitigate ratepayer impacts

• Other Recommendations to Accelerate Distributed Solar Deployment

  • Strengthen New York’s community solar programs by ensuring New York’s utilities issue timely and accurate credits to community solar customers, and by encouraging continuous improvement to community solar customer experience and operational efficiency.

  • Incremental improvements to interconnection, such as allowing for the use of letters of credit and surety bonds in lieu of cash deposits for expensive distribution upgrades and additional reforms proposed through the Interconnection Policy and Technical Working Groups.

  • Lower the cost of residential interconnection by allowing for the use of meter collar devices (aka meter socket adapters).

  • Automate residential solar + storage permitting through platforms such as Symbium and SolarAPP+.

Next, NYSEIA's comments opined on specific recommendations that were included in NYSERDA/DPS filing. NYSEIA voiced support for accelerating LSR procurements and was fairly deferential to NYSERDA/DPS Staff's recommendations. NYSEIA also voiced opposition to utility-owned generation, and then concluded:

Through the CLCPA, New York has established some of the most ambitious clean energy mandates in the nation. The Draft CES Biennial Review highlights that New York is not currently on track to achieve 70X30 with a business-as-usual approach, and has a significant renewable electricity supply gap to fill. NYSEIA asserts that New York likely also has a DAC benefit gap to fill, and distributed solar can be deployed quickly and equitably, helping close both these gaps. With six years until the 70% renewable electricity mandate, it would be premature for New York to move the goalposts, and doing so would send the wrong signal to clean energy developers, investors and agency leaders. NYSEIA urges the Commission to work with legislators and agency leaders to develop and advance an aggressive new strategy to achieve 70X30. Scaling up distributed solar deployment must be a central pillar in New York’s new and improved CLCPA compliance strategy.