Community Distributed Generation (CDG) is an important tool for New York to achieve its ambitious clean energy and equity goals. In addition to favorable interconnection, siting, and solar compensation policies, timely and accurate utility billing, crediting, and customer service are foundation to a successful community solar program. Despite years of visibility into the pipeline of CDG project development, New York’s Investor-Owned Utilities (IOUs) did not make the necessary technology investments or staffing decisions to provide an acceptable level of service to CDG customers and developers, resulting in significant CDG billing errors and delays, particularly over the last two years. These utility billing and crediting issues have negatively impacted New York’s community solar market. While CDG developers are experiencing significant financial impacts due to crediting delays and errors, the impact of greatest concern is the customer experience; community solar customers, including low-income households, are not receiving their promised utility bill savings, eroding trust in New York’s community solar program.

The New York Solar Energy Industries Association (NYSEIA) / Coalition for Community Solar Access (CCSA) Negative Revenue Adjustment (NRA) Working Group was initiated to provide industry support and input on the development of performance metrics and associated Negative Revenue Adjustments (NRA) intended to incentivize the utilities to reduce billing and crediting issues for the CDG program. The NRA Working Group is firmly in support of the Public Service Commission’s Order to initiate a stakeholder conference to establish CDG billing performance metrics and directing stakeholders to propose NRAs tied to such metrics. This Working Group believes that well-designed metrics are important to achieve consensus and clarity around the utilities’ performance serving CDG customers, and the NRA is the appropriate mechanism to encourage improved performance.

The NRA Working Group is proposing performance metrics and NRAs designed to improve customer experience while ensuring that New York remains the nation’s leading CDG market. Proposed metrics and NRAs seek to ensure that the IOUs reliably provide:

• Timely allocation of credits to customer bills on a monthly basis;

• Accurate allocation and application of credits to customer bills;

• Appropriate customer service and accurate information to CDG customers;

• Timely processing of CDG Host reports;

• Accurate processing of CDG Host reports;

• Accurate reflection of the time period when credits are generated;

• Accurate reflection of the time period when credits are applied to a customer bill;

• Accurate reflection of banked credits as a discrete line item; and

• Regular and detailed reporting on CDG credit allocation.

Finally, we recommend that CDG customers negatively affected by utility billing and crediting issues (and particularly customers who do not receive a monthly credit when they are owed that credit) be compensated via a Remedial Credit mechanism. This proposed $50 Remedial Credit would be additional to their CDG Credit and is designed to compensate the customer – in real time – for instances of utility underperformance that may cause the customer to leave their CDG project.

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