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Solar + Storage Parties Comments on DPS Staff Proposal for Queue Prioritization (Case 24-E-0621)

December 10, 2025

On December 10th, 2025, NYSEIA along with the Coalition for Community Solar Access, New York Battery Energy Storage Technology Consortium, and the Solar Energy Industries Association (collectively referred to as the “Solar +Storage Parties) submitted comments on the Department of Public Service’s (DPS) staff proposal in Case 24-E-0621.


The Staff Proposal introduced new proposed rules to manage the timely interconnection of distributed energy resources (DER) in direct response to the enactment of H.R.1 by the Federal Government– which placed cascading “commence construction” and “placed-in-service” deadlines and the rapid phase-out of the federal Investment Tax Credit. Staff updated their proposal in November 2025 with stakeholder input, including additional certainty for interconnection applicants and interconnecting utilities on scheduling the work necessary to bring projects into service


The Solar + Storage Parties’ core objectives in these comments are to

  1. Clarify certain ITC qualification requirements; 

  2. Provide Staff and the Commission with information about potential unintended consequences of the Staff proposal; and

  3. Offer suggestions for how DPS and the Commission can improve upon the Proposal to enable more ITC-eligible DER to be deployed in New York while strengthening the New York State Standardized Interconnection Requirements (SIR) to benefit all future projects


The Solar + Storage Parties received DER industry feedback on the Staff Proposals which generally:

  • Oppose the Staff Proposal’s creation of priority groups and additional interim deadlines, which impose new risks and uncertainty on DER development in New York

  • oppose the exclusion of Standalone BESS and the many other ITC-eligible projects that the Staff Page 5 Proposal excludes

  • Strongly support the proposed enhancements to timeline transparency and certainty, and recommend they be expanded to all SIR projects

  • Highlight the need for the Commission to authorize tools and practices to condense timelines and expedite interconnection;

  • Express concern regarding the significant administrative burden that creating and maintaining a master distribution upgrade work plan would impose on New York utilities; and

  • Recommend that the Commission take an extra month or two to get this proposal right rather than rushing a December Order. 


Click “READ MORE” to view the full comments. 

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