On March 22, 2023, NYSEIA presented a proposal to the Joint Utilities (JU) and staff from the Department of Public Service and NYSERDA at the Interconnection Policy Working Group (IPWG) recommending the use of letters of credit in lieu of cash deposits for expensive distribution upgrades. NYSEIA proposes the attached SIR modifications, which would require New York’s utilities to accept Surety Bonds and Letters of Credit as an alternative to cash deposits for distribution upgrades with a total cost estimate above $500,000 based upon the Coordinated Electric System Interconnection Review (CESIR) results.

The proposal considers and addresses a variety of potential scenarios for projects with shared and non-shared distribution upgrades. While the proposal presented to the IPWG last year only included Letters of Credit, further discussion with DER developers confirmed that in many cases, Surety Bonds are both lower cost and more accessible for midsize and small developers. The additional option will increase the impact of this proposal and better address the problem statement that NYSEIA outlined in IPWG in March 2023.