On March 6th, NYSEIA submitted comments on  the January 2026 Reliability Needs Report from Consolidated Edison (ConEd) in Case 25-E-0764. 

ConEd’s report identifies where and when future reliability needs are expected to arise in its territory, and outlines a gradual increase in reliability needs from now into mid 2040, as well as hours during which the system is stressed which increase in longevity over time. These findings underscore the need to evaluate a broad set of tools as planning moves forward. It predicts steady growth in demand over the coming decade due to economic activity, electrification, and the retirement of certain older power plants. It finds that solutions need to be added quickly, and tailored to changing system conditions. 

NYSEIA appreciates the expeditious release of the report, and the opportunity to provide commentary on the opportunity to leverage non-emitting resources to meet New York City’s electricity needs while protecting customers from avoidable costs. As the proceeding shifts from identifying needs to considering solutions, there is an opportunity to make better use of distributed solar and storage in NYC. 

Solar paired with storage particularly meet the growing need for energy in predictable afternoon and evening hours. The systems reduce demand on the bulk system at times and locations where the system is the most constrained. Furthermore, distributed solar and storage can be deployed on shorter timelines and in shorter increments than larger infrastructural upgrades. 

NYSEIA recommends three strategies to accelerate distributed solar and storage:

1. Address interconnection barriers for energy storage, restoring fair and transparent access to the electric system

2. Ensure the Value of Distributed Energy Resources (VDER) tariff accurately reflects ConEd’s true marginal cost of service

3. Partner with NYC to create a viable permitting pathway for safe residential and medium-sized battery energy storage systems

Click “READ MORE” to view the full comments.