On November 18, 2024, NYSEIA submitted comments in response to NYSERDA's draft residential and retail energy storage incentive implementation plan under Case 18-E-0130. NYSEIA's comments:

• Recommend increasing the size of the first retail energy storage incentive block in Con Edison territority based on the robust pipeline of projects in the interconnection queue (while ensuring capacity is available for Upstate projects).

• Urge Long Island to fully implement the Public Service Commission's Energy Storage Roadmap Order despite LIPA's alternative regulatory framework. This is particularly important considering LIPA's apparent intent to ignore the Commission directive to provide capacity-based incentives for retail energy storage on Long Island.

• For residential energy storage, ensure that Dynamic Load Management program participation is not a requirement for accessing NYSERDA capacity-based incentives, especially in utility service territories where they have not yet modified their DLM programs to account for behind-the-meter energy storage's unique characteristics.

• Encourage New York State to urge New York City to lift its de facto ban against residential energy storage. NYC's Fire Code includes infeasible and bespoke requirements for residential energy storage that serve as a functional ban against energy storage. NYC's ban against residential energy storage undermines public safety by denying NYC households access to resilient backup power in the event of a blackout. NYS could urge the City to allow for the installation of safe, resilient backup power.

• Advocate for creating a carveout for medium-sized energy storage systems. While retail storage and BTM residential energy storage have demonstrable potential to scale, medium-sized BESS have important applications, such as resilience and demand-charge management at community centers, small-commercial and multifamily buildings. This segment should be supported.