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Comments on the Proposed Stepdown in Community Credit Level

January 21, 2020

In its Nov. 1 Petition, NYSERDA requests that the New York Public Service Commission (the “Commission”) issue an Order (1) reallocating CDG capacity from canceled projects in the MTC tranches to a new, subsequent Community Credit tranche; and (2) authorizing NYSERDA to use uncommitted NY-Sun funds to support a Community Adder incentive in utility territories where the Community Credit is no longer available. The Coalition for Community Solar Access (CCSA), New York Solar Energy Industries Association (NYSEIA), and Solar Energy Industries Association (SEIA), referred to herein as the Clean Energy Parties (“the CEP”), are supportive of the spirit of both requests given that as of January 6, 2020, the Community Credit has been exhausted in both NYSEG and National Grid service territories, and given the need to ensure robust—and uninterrupted—development of CDG projects to enable consumer access to solar and meet state clean energy goals. Overall, the CEP finds the request for temporary relief in the Nov. 1 Petition reasonable and warranted and is grateful for ongoing collaboration between NYSERDA and the solar industry as the state works to deploy 6 gigawatts (GW) of distributed generation by 2025, as required by the Climate Leadership and Community Protection Act (“CLCPA”). However, the industry is extremely concerned about the immediate step-down being proposed from the current Community Credit level ($0.0225/kWh) to $0.18/Watt DC—a roughly 45% decrease in value—and urges a more moderate decline in line with market realities.

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