On October 19th, 2026, NYSEIA submitted comments on NYSERDA and DPS’s Draft 2026 Clean Energy Standard Biennial Review. The Biennial Review presents an assessment of New York’s progress deploying clean energy resources, and makes clear the State is not on a trajectory to achieve its statutory clean energy goals with the current projected rates of deployment and electric load growth– with the one exception being distributed solar.

NYSEIA urges the Commission to prioritize distributed solar to close the State’s forecast energy supply gap, and to place a greater emphasis on non-emitting resources that can be deployed quickly, provide direct benefits to customers, and strengthen reliability. We urge the Commission to take near-term action to lower solar and energy storage project costs by streamlining and modernizing interconnection, update VDER, adopt DPS’s recommendation to establish enhanced performance requirements for dispatchable DERs where they provide greatest transmission and distribution system deferral value to ratepayers, and advance broader regulatory reforms that align utility profit incentives with the public interest.

More clean energy deployment is needed to achieve New York’s energy goals and close the forecasted demand gap– making a strong cast for a 20 GW distributed solar goal, as the resource has met its statutory goal early and can deploy quickly and affordably.

Distributed energy storage is correctly identified as a critical component of New York’s reliable, affordable clean energy strategy. This should be reflected in state planning documents and policies and utility practices that determine whether storage projects can actually be deployed. In Con Edison, energy storage deployment barriers must be addressed by the Commission. The Commission should grant NY-BEST’s petition on this expeditiously. The Commission should also increase residential BESS attachment rates and utilization through NYSERDA incentives and Bring Your Own Battery (BYOB) programs.

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