The New York Solar Energy Industries Association (NYSEIA), the Solar Energy Industries Association (SEIA), and the Coalition for Community Solar Access (CCSA), referenced herein as “the Solar Parties”, provided feedback on the Department of Public Service (DPS) Staff Proposal on a Statewide Solar for All Program in these comments. The Solar Parties support the intent of the Statewide Solar for All (S-SFA) Proposal, which seeks to catalyze additional distributed solar and storage project development and to leverage solar and energy storage projects to provide direct bill savings to low- and moderate-income (LMI) New Yorkers. We fully agree with DPS Staff and NYSERDA that community solar is a critical tool to meet the State’s decarbonization and equity objectives under the Climate Leadership and Community Protection Act, and we support Staff’s Proposal that the S-SFA program be additive to the existing programs supporting opt-in community solar. 

However, the Solar Parties are concerned that the program structure as proposed will not adequately permit both models to operate in harmony while achieving their stated goals, and recommend modifications to build a successful S-SFA without impeding existing community solar programs. With a few key changes, S-SFA can be instrumental to expanding the distributed energy opportunity in New York State in a manner that supports a diversity of business models and ensures that a growing number of LMI customers will directly benefit. An S-SFA program designed to achieve “additionality” will support New York to go beyond its existing 10 GW distributed solar goal, demonstrating its unmatched leadership and commitment to addressing climate and equity.

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