On December 1st, 2025, NYSEIA submitted comments in support of Nexamp’s complaint against National Grid regarding utility cost overruns. 

On August 7th, 2025, Nexamp filed a verified complaint against National Grid regarding cost overruns for distribution upgrades to interconnect completed community solar projects in the service territory. The complaint asserts National Grid failed to comply with timelines under the New York Standardized Interconnection Requirements (SIR), did not provide cost estimates in good faith, failed to communicate cost increases prior to incurring the increased costs, and did not adequate justify the costs included in final reconciliation invoices. 

For large distributed energy resources (1-5 MW), interconnection costs have increased significantly. A growing number of DER developers are receiving reconciliation statements from New York utilities whereby they are being charged retroactively for utility cost overruns that materially exceed the utility’s cost estimate and the 15% allowable contingency. Nexamp’s complaint is a clear example of this, and is tied to NYSEIA’s interconnection-related work in improving interconnection cost-certainty. This retroactive imposition of cost overruns is untenable, undermines the SIR, and limits New York’s ability to leverage private capital to build clean energy in the State. 

In the comments, NYSEIA urges the Commission to:

1. Grant Nexamp’s requested relief: Nexamp’s complaint provides clear information that National Grid is not appropriately managing costs for distribution upgrades and violating the SIR. Further, NYSEIA disagrees with National Grid’s rationale, and urges the Commission to deny the utility’s requests of Nexamp to set aside the amount of money in overruns in an escrow while the conflict is mediated.

2. Establish guardrails to protect DER developers and ratepayers from utility cost overruns: NYSEIA references its petition in Case 24-E-0621 that seeks to provide greater transparency and cost certainty for DER interconnection in New York State. The petition recommends the Commission:

   1. Direct New York’s utilities to increase the level of detail in cost estimates for distribution upgrades

      Modify the SIR to turn the 15% allowable contingency that can be included in the utility’s CESIR cost estimates into a hard cap

   2. Direct New York’s Investor-Owned Utilities (IOUs) to publish itemized actual costs for common distribution upgrades on an annual basis

   3. Direct IOUs to provide interconnection customers with detailed, itemized, clear statements of final costs for all distribution upgrades

Click “READ MORE” to view the full comments.