On July 15th, 2025, NYSEIA submitted comments on the Grid Flexibility Study in the Grid of the Future Proceeding. NYSEIA’s comments include some guiding principles, but focus on tactical recommendations to unlock grid flexibility quickly.

The Study under the proceeding found that New York can unlock 8.5 GW of grid flexibility potential by 2040, and flexible resources could provide nearly $3 billion in annual savings to ratepayers. The study also importantly shows that the flexible resources identified would be cost-effective in comparison to fossil fuel generators. NYSEIA believes this should motivate the Commission and other stakeholders to execute strategies to accelerate flexible resource deployment.

The specific focus areas in NYSEIA’s comments include:

1. Creating adequate price signals for all parties (customers, DER providers, and utilities:

The energy market includes various price signals that drive the behavior of market participants. Understanding and accommodating each parties’ motivation is critical for designing and scaling-up successful programs with minimal friction, and encouraging stakeholders to row in the same direction. NYSEIA urges the Commission to develop meaningful price signals to ensure New York’s utilities are compensated for scaling-up their grid flexibility programs, engaging customers to maximize their savings, and implementing the following recommendations for DER providers.

2. Animating a robust market for behind-the-meter energy storage with performance-based compensation:

Programmatic and policy interventions can expand New York’s BTM BESS potential to 1.1 GW and $57 million in annual benefits to consumers. NYSEIA supports the pursuit of all strategies to achieve this in the Study, including expanding participation by increasing the value to customers, improving BTM BESS utilization through improved forecast/dispatch strategies, permitting reform, allowing customers to monetize the various value streams batteries can provide, and reducing program costs through scaling-up the program. NYSEIA also provides specific recommendations of guidelines on net metering eligibility, settlement/measurement points, event participation, enrollment, event duration, caps on events, and consistency of performance payments.

3. Accelerating front-of-the-meter distributed energy resource deployment and lowering costs through flexible interconnection:

NYSEIA encourages the Commission to support utility-driven efforts to expand existing Flex IX pilot programs. NYSEIA also recommends the Commission initiate a proceeding to develop a statewide flexible interconnection framework.

4. Improving VDER compensation for front-of-the-meter DER:

NYSEIA encourages the Commission to consider revisiting the Environmental Value to phase-out upfront incentives but encourage the continuation of distributed solar deployment unabated.

5. Aggressive pursuit of opportunities to lower the cost of DERs:

NYSEIA urges the Commission and New York’s utilities to quickly establish and adapt discrete programs to accelerate flexible resource deployment, activation, and integration. This will allow New York to quickly launch and scale programs that save ratepayers money while allowing the state to unlock the value of flexible resources.

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