Each year, NYSEIA sets ambitious policy goals which help to shape our advocacy work in the coming year.
For 2019, we are focused on New York's solar energy target, prevailing wage legislation, distributed generation compensation, bolstering community solar, administrative streamlining, and rate design.
Prevailing Wage Legislation
NYSEIA has concerns about the impact of prevailing wage legislation, which directly threatens solar jobs, economic investment, and the ability of New York to meet emissions-reduction goals.
NYSEIA is currently compiling research on the impact of prevailing wage requirements on project costs. Preliminary information indicates project costs could rise by as much as 25 percent of total installed costs.
Without a commensurate increase in state support (such as through the NY-Sun Megawatt Block Program), huge numbers of solar projects will no longer be economical. Prevailing Wage mandates are also likely to dramatically expand administrative burdens to prove compliance.
NYSEIA member companies—which maintain a mix of union and open shops and pay highly competitive wages and salaries as it is—already face a competitive labor market and lower incentive levels.
NYSEIA urges major changes to the language in last session’s Senate Bills S2975A and S7971A. At a minimum, prevailing wage standards must not be applied to smaller projects of nameplate capacity less than a certain size.
Solar Energy Goal
NYSEIA urges New York State to adopt a new, robust solar goal that dramatically expands solar access and creates a stable, predictable market for solar employment and investment. The goal should be enforceable and include interim targets to ensure progress.
Addition of intermediate targets to the existing Clean Energy Standard (CES) in line with prior RPS program requirements.
A solar-specific sub-tier/carve-out as part of the existing CES.
Household targets for adoption of solar (such as the Million Solar Strong campaign, which calls for powering 1 million NY homes with solar by 2023).
6 GW of distributed solar by 2025, as proposed in Governor Cuomo’s State of the State address.
Distributed Generation Compensation
The solar compensation framework set by the Public Service Commission continues to be overly complex, uncertain and thus unfinanceable over the long term, and economically unviable in much of the state, with community solar still being out of reach for nearly all downstate residents (New York City, Long Island, Westchester). The Public Service Commission has put forth proposals in the Value of Distributed Energy Resources (VDER) proceeding to improve compensation levels, but it is too early to know whether they will be sufficient to create a robust market.
Bolstering Community Solar
The community solar (Community Distributed Generation) program continues to fall far short of its potential.
Despite providing an alternative to rooftop solar, nearly all NYC residents cannot subscribe to community solar offerings because of regulatory hurdles. These hurdles must be addressed, such as through cross-utility crediting.
Non-residential customers—such as businesses, municipalities, hospitals, and schools—could lower project costs by serving as anchor customers but are discouraged from participating under the current framework.
Consolidated and automated billing is key to improving the customer experience and minimizing consumer complaints.
Utilities must also onboard CDG customers and apply bill credits within 30 days.
NYSEIA advocates for the design and implementation of electric rates that properly value and enable a high penetration of distributed generation, while recognizing the interests of utility shareholders and non-generating customers.
Rates should include accurate price signals for peak, shoulder, and off-peak energy usage.
Rates should be understandable, enabling customers to take responsive actions to reduce their usage, shift their load profile, or install on-site generation.
Net energy metering customers should be allowed to remain on their current rate form, with the option to move into new rate forms.
NYSEIA supports efforts to streamline administrative processes to reduce costs and accelerate solar growth.
NYSEIA continues to lead and coordinate interconnection reform efforts through its participation in the Interconnection Policy and Technical Working Groups (IPWG and ITWG) to streamline processes and reduce interconnection-related costs.
NYSEIA advances property tax policy allowing solar providers to more easily navigate local taxation while also giving tax jurisdictions fair treatment.
Siting solar is very challenging in much of the state. NYSEIA supports efforts to streamline local zoning and codes to address local concerns while creating clear and cost-effective pathways for solar adoption.
NYSEIA supports efforts to reform the NYS and local building codes to ensure that new homes and businesses are built solar-ready.