Over the last decade, New York’s distributed solar market has grown significantly. To date, the solar industry has installed approximately 5.5 gigawatts-DC of distributed solar generating capacity in New York, and is on track to surpass 6 gigawatts (GW) this year, achieving the first goal in the Climate Leadership and Community Protection Act (CLCPA) one year ahead of schedule. The passage of the federal Inflation Reduction Act (IRA) in 2022, which strengthened federal support for clean energy, has allowed New York to make rapid progress toward New York’s expanded 10 GW by 2030 goal ahead of schedule and under budget. New York State Energy Research and Development Authority’s (NYSERDA) NY-Sun program has been and continues to be, foundational to New York’s distributed solar market. NYSERDA’s flexible, adaptive approach has resulted in a robust, cost-effective Megawatt Block program that is now supporting nearly one gigawatt of distributed solar per year, primarily community solar and increasingly community solar for low-income subscribers.

While New York is ahead of schedule toward its goal of deploying 10 GW of distributed solar by 2030, the state is behind schedule on the more ambitious goals of generating 70% of the state’s electricity from renewable sources by 2030 and ensuring that 40% of clean energy benefits accrue to low- to moderate-income households and residents of disadvantaged communities (DAC). Expanding the NY-Sun program beyond 10 GW will help New York close the gap on its 2030 and 2040 renewable electricity goals. NYSERDA’s proposal to reinvest surplus funds in NY-Sun is an important incremental step forward, and will provide the distributed solar industry another year of runway to develop projects that support progress toward the CLCPA. In addition to this near-term proposal, the New York Solar Energy Industries Association (NYSEIA), Coalition for Community Solar Access (CCSA), and Solar Energy Industries Association (SEIA), (collectively the “Solar Parties”), encourage the Commission to begin considering a longer-term plan to sustain distributed solar deployment in New York. The Solar Parties strongly support NYSERDA’s proposal, and offer the following comments and recommendations for the Commission’s consideration.