On May 10, 2024, the Coalition for Community Solar Access (CCSA) and New York Solar Energy Industries Association (NYSEIA) submitted comments in response to the Commission’s Order inviting Reply Comments to the DPS Staff Proposal (Staff Proposal) to establish Performance Metrics and Negative Revenue Adjustments (NRAs) for Community Distributed Generation (CDG) Billing & Crediting. CCSA and NYSEIA’s comments strongly support the Staff Proposal, along with every intervenor in the proceeding, with the exception of the Joint Utilities (JU) who are the subject of the proposed performance metrics and NRAs. Therefore, these reply comments focus specifically on the JU comments. CCSA and NYSEIA’s reply comments address multiple substantive errors, logical flaws, and misunderstandings of the Commission Order in the JU comments:

• The JU comments do not represent an attempt to implement the Commission’s Order in good faith

• The JU claim that the Staff Proposal’s metrics are “unduly burdensome” and “unreasonable” misunderstand the Commission Order

• The JU Alternative Proposal does not adequately address numerous CDG billing & crediting issues that are adequately addressed in the Staff Proposal

• CCSA and NYSEIA reject the JU assertion that “the proposed metrics and targets are wholly inconsistent with the basic principles for the design and implementation of performance mechanisms” 

• The Commission need not be hamstrung by historical precedent for baselining and establishing performance targets for Customer Service Performance Indicators (CSPI)

  • CDG Performance Metrics are fundamentally different from CSPIs because of the immense financial impact to developers, customers, and subscriber organizations and the reputational impact on New York’s community solar programs

  • CCSA and NYSEIA reiterate support for the metrics and penalty values in Staff’s Proposal

• The JU make several specific claims, some of which are valid; others are invalid

  • Upstate vs. Downstate NRAs are perfectly aligned based on utility revenues and should not be modified

  • Any Commission Order in this proceeding should supersede the CDG metrics in existing rate plans

  • Some of the JU proposed remedy and exclusion periods are reasonable; others are not

NYSEIA and CCSA's comments conclude by encouraging the Commission to quickly adopt the DPS staff proposal to ensure that solar customers receive timely and accurate solar credits from their utilities.