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Clean Energy Party Comments on the 10-Gigawatt Distributed Solar Roadmap

March 7, 2022

Clean Energy Parties recommended that the New York Public Service Commission:

  • Support the overall framework: Approve the overall budget and allocation of funds/capacity between Upstate and Consolidated Edison and authorize NYSERDA to finalize details of the blocks/incentive levels as part of its Operating Plan after taking stakeholder feedback into consideration.

  • Accelerate oversight of program progress: Conduct the NY-Sun Program Review after an initial 1 GWdc of capacity has been allocated, not at Mid-Program as proposed in the Roadmap.

  • Plan for the future starting now: Reconvene the Value Stack working group to consider proposals for Value of Distributed Energy Resources tariff improvements and determine a long-term NY-Sun successor program for distributed solar.

  • Solve hosting capacity constraints: Expand and improve Cost Sharing 2.0 and the Distributed System Implementation Planning process such that distribution planning is more forward looking, and the upgrade costs necessary to achieve the Climate Leadership and Community Protection Act goals are not borne solely by distributed energy resource developers.

  • Ensure broad and equitable participation: Expand eligibility for NY-Sun to allow some projects to fully take advantage of the new funding, avoid project attrition, and help make faster progress toward New York’s CLCPA goals.

  • Periodically recalibrate on prevailing wage: NYSERDA and DPS should regularly review their cost assumptions and be prepared to adjust the size of the PW pool of funding and per project incentive level based on changing conditions.

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