On October 6th, 2025, NYSEIA and the Coalition for Community Solar Access submitted comments on the 2025 Draft New York State Energy Plan. 

Overview

The New York Solar Energy Industries Association (NYSEIA) and the Coalition for Community Solar Access (CCSA) strongly support New York’s clean energy and climate goals but find that the Draft State Energy Plan (the Plan) fails to recognize the proven and growing role of distributed energy resources (DER) such as rooftop and community solar in achieving an affordable, reliable, and equitable energy system.

The Plan's analytic foundation, the Pathways Analysis, undervalues distributed resources by relying on outdated assumptions regarding utility transmission and distribution costs, resulting in little or no distributed solar deployment after 2030. These flaws misrepresent DER as a marginal solution rather than a cornerstone of New York’s future energy resource mix.

Key Concerns

• Outdated and inaccurate modeling: The Pathways Analysis uses 2018 utility cost data and an arbitrary 10 GW cap on distributed solar, ignoring today’s much higher transmission/distribution costs and rapid DER growth.

• Misplaced resource emphasis: The Plan favors utility-scale generation while discounting rooftop and community solar + storage —resources that reduce grid costs, enhance reliability, and directly lower consumer bills.

• Federal headwinds: Recent federal actions eliminating clean energy tax credits make state-level support for distributed energy more vital than ever.

• Workforce risk: The Plan implies a significant reduction in distributed solar jobs (6,114 job losses between 2030 and 2040), threatening New York’s most successful clean energy sector.

  
  

Recommendations

1. Correct modeling errors and assumptions

   • Update cost assumptions for transmission and distribution infrastructure.

   • Remove arbitrary DER caps and differentiate between utility- and distribution-scale storage.

   • Reflect realistic capacity factors and cost trajectories for community and residential solar.

2. Expand New York’s distributed solar target

   • Increase the goal from 10 GW by 2030 to 20 GW by 2035 (as proposed in the Accelerate Solar for Affordable Power Act), consistent with legislative proposals and achievable deployment rates.

3. Maintain and modernize NY-Sun

   • Avoid a premature program phaseout; provide a multi-year runway or successor initiative that supports diverse project types while prioritizing benefits for low- and moderate-income New Yorkers.

4. Cut red tape and accelerate deployment

   • Advance interconnection reforms (e.g., flexible interconnection, self-performance, cost-certainty).

   • Enact statewide community solar siting reforms and automated residential permitting to lower soft costs.

5. Protect New York’s clean energy workforce

   • Ensure policy continuity to prevent layoffs and preserve a 15,000-strong distributed solar workforce.

   • Oppose expanded utility ownership of generation that would distort fair market competition and eliminate private investment.

     
     

Conclusion

Distributed solar and storage are essential to meeting New York’s affordability, reliability, and climate goals. NYSEIA and CCSA urge the Energy Planning Board to:

• Correct analytical flaws in the Pathways Analysis / Draft Plan,

• Voice support for expanding New York's distributed solar target to 20 GW by 2035, and

• Advance a bold deregulatory and pro-deployment agenda for distributed solar + storage.

By doubling down on distributed energy resources, New York can lower costs, strengthen the grid, and sustain one of its most successful clean energy industries.

The full comments can be accessed by clicking "READ MORE" below.