On November 25, 2024, NYSEIA submitted comments regarding New York's draft scope of work for the NY State Energy Plan. In general, NYSEIA believes the draft scope of work is strong and includes the most critical components. NYSEIA's comments encourage NYSERDA, the Public Service Commission and other members of the Energy Planning Board to consider the expanded role that distributed energy resources can play in New York's overall clean energy mix. NYSEIA's comments encourage action to advance distributed solar + storage, including:

• Siting reform to cut through red tape and expedite permitting for community solar + storage

• Interconnection reform to eliminate unnecessary and bloated utility costs for distribution upgrades

• Rate design improvements to ensure distributed energy resources are fully compensated for the value they provide to the system; and

• Targeted incentives for projects that minimize land use impacts and/or directly benefit low-income New Yorkers

NYSEIA looks forward to providing detailed commentary an input regarding the State's Energy Plan when it is drafted and released for public comment.