In the last two years, the availability of the Community Credit has coincided with a growing community solar industry in Con Edison’s service territory. Despite the COVID-19 pandemic and related economic shutdowns, approximately 89 MW of solar capacity entered the pipeline of projects proposed for interconnection in Con Edison’s service territory in 2020, compared to only 22 MW in 2019 and 3 MW in 2018. In fact, community solar, the dominant technology for CDG, was the single largest source of incremental solar capacity in Con Edison’s service territory in 2020; in comparison, behind-the-meter solar development only grew by two percent year-over- year while community solar increased by 405 percent year-over-year.

That notwithstanding, the MTC and Community Credit frameworks also inadvertently resulted in a recent influx of natural gas-fired fuel cells in Con Edison’s service territory (“Fuel Cell Loophole”). As explained herein, the Commission took steps to close the unintended Fuel Cell Loophole because fuel cells do not align with the State’s decarbonization goals and because the Community Credit and MTC were designed around solar technology. However, before the loophole was closed, a small number of fuel cells reserved over half of the Community Credit capacity that otherwise would have been available to renewable CDG projects in the Con Edison service territory. Petitioners expect that renewable CDG development in the Con Edison service territory will stagnate once the remaining Community Credit Capacity is exhausted, hampering solar’s contribution to the economic recovery from the COVID-19 crisis in the Downstate region. Prompt action is therefore needed to support the continued development of renewable generation in the Con Edison service territory, and to ensure that the economic benefits of New York’s bold investments in renewable energy reach the State’s most diverse and populous region.

Given those needs, Petitioners respectfully request that the Commission (1) expand the availability of Con Edison’s Community Credit by at least 180 MW for renewable CDG projects; and (2) work with stakeholders to identify policy actions that ensure renewable development in the region can be sustained after Con Edison’s additional Community Credit capacity is filled.