On April 29, NYSEIA submitted comments in response to NYPA's filing regarding the REACH program, a legislatively mandated program for NYPA to provide solar bill credits to LMI customers. NYSEIA's comments voice conceptual support for REACH while making the following key points:

• REACH must be designed in the context of NYPA’s yet-to-be-established renewable energy development plan.

  
  

• REACH must complement New York’s successful opt-in community solar program.

  
  

• To achieve additionality, REACH projects must not be eligible for NY-Sun incentives.

  
  

• The State should consider having REACH projects participate directly in Statewide Solar for All.