On May 1st, 2026, NYSEIA submitted comments in response to the Petition filed by the Coalition for Safe and Reliable Energy seeking a hearing and potential suspension or modification of the Renewable Energy Program pursuant to Public Service Law § 66‑p(4).

The Petition’s main claims to consider suspending or modifying the Renewable Energy Program is that New York’s grid is facing near-term challenges: load increases, parts of the generation fleet are aging, reliability margins are tightening. NYSEIA strongly disagrees with CSRE’s unsubstantiated assertion that suspension or modification of the Renewable Energy Program is necessary to address the challenges. Instead, this would actually introduce market uncertainty, reduce energy infrastructure investment, and increase costs for customers without actually solving the near-term reliability issues the petition highlights.

Furthermore, the Petition advances three claims, New York’s renewable energy programs impede the provision of safe and adequate electric service, impair existing system obligations, and contribute to rising customer arrears and service disconnections. However, the Petitioners bear the burden of demonstrating renewable energy programs impede the provision of safe and adequate service.

NYSEIA recommends the Commission rather address barriers to clean cost-effective capacity additions with an emphasis on enabling resources that can be deployed quickly, reduce peak demand, and lower utility bills, distributed solar and storage. Distributed solar and storage are key to addressing the grid’s near-term challenges.

The petition treats reliability and renewable deployment as competing priorities, which is a false choice that does not reflect how DERs actually perform on the system and ignores the fact that there is no credible lower cost alternative to deploying clean energy to meet load growth. Volatility in fossil fuel prices has been the primary driver of sharp increases in wholesale electricity costs which flow directly to consumers. Distributed solar reduces customer bills and promotes affordability, as found by independent research by Synapse Energy Economics.

Accelerating distributed solar and storage deployment, improving interconnection processes, and aligning distribution system planning with areas of load growth would all directly address the issues raised in the Petition. NYSEIA has a petition and comments before the Commission that identify specific and near-term actions to accelerate distributed solar and energy storage while reducing costs to ratepayers through its cost-transparency petition. Additionally, the Commission could increase clean energy supply by advancing the DPS Staff Proposal in the Value of Distributed Energy Resources (VDER) proceeding that was filed in December 2025.

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