While there have been many improvements to the interconnection process, the interconnection process continues to impose unnecessary costs and risk on DER projects, and more progress is needed to meet New York’s ambitious goals for climate and energy. Staff’s proposal does not provide sufficient evidence to demonstrate that the interconnection EAM is no longer necessary, or that removing it would not risk backsliding on progress that has already been made. ​ In light of these circumstances, we respectfully submit that there is no cause to declare victory at the present moment, and insufficient evidence to conclude that the EAMs should be eliminated. Rather than preemptively eliminating this potentially important tool, we recommend that the Commission continue to gather data on the efficacy and fairness of the EAM and interconnection processes generally, and direct Staff to work with all stakeholders on continued improvements to ensure the EAMs continue to result in improved, superior customer service for DER customers across the state.