Comments Regarding LIPA CBC Proposal

November 30, 2021

NYSEIA rejects LIPA’s underlying premise used to support the imposition of fixed charges on solar customers. LIPA’s proposal is based on correcting a perceived “cost shift” from solar customers to non-adopters. The study published by the Department of Public Service which underpinned the CBC proposal did not consider many of the benefits of solar. This improper valuation of solar resulted in the perception of a “cost shift,” but this does not exist and an independent study outlining all of the values of residential solar would reflect that. Additionally, solar customers account for approximately 4% of the total electric customers in LIPA territory; therefore, any potential “cost shift'' is not significant.