Re: Case 19-E-0735 - Joint Petition for Approval of an Expanded Solar For All Program For Providing Community Solar to Low-Income Customers

Dear Secretary Phillips,

Please find below the joint comments of the Alliance for Clean Energy New York (ACE NY), the New York Solar Energy Industries Association (NYSEIA), and the Solar Energy Industries Association (SEIA) (referred to herein as the Clean Energy Parties, “CEP”) in response to the NYSERDA-National Grid joint proposal (“the E-SFA petition”) for approval of an Expanded Solar For All (E-SFA) program for providing Community Solar to low-income customers, filed on April 23, 2021.

1. Utility Participation in Competitive Market Sector

CEP appreciates NYSERDA’s and National Grid’s efforts with regard to designing and advancing the ESFA program and proposal, and striving to expand Community Solar access to low-income customers, which have to date have been an underserved segment of this important and growing market. At the same time, the E-SFA program as proposed would allow for the entry of a utility monopoly business possessing intrinsic advantages and privileges into what is a competitive market sector, which raises concerns amongst CEP’s member firms relating to the lack of a level playing field for private sector participation and competition, as well as constrictions on the overall addressable market for Community Solar customer acquisition and management. CEP therefore cautions the Public Service Commission to take a measured approach in rolling out this program to ensure: (i) continuing healthy private sector participation and innovation in this market segment, (ii) that any possible market disruption is minimized, and (iii) to ensure that the program supplements, rather than cannibalizes, market-based solutions, providing a greater benefit and access to all New Yorkers.

2. Program Size

Building on the above comments, it is crucial that the E-SFA program, if approved and implemented, is limited in its scope and supplements private market activity rather than crowding it out. CEP’s member companies do not want to be precluded from offering Community Solar to New York residents, either because utilities in New York have signed up all of the low-income customers, or because utility-run programs have used up all the available program capacity in the State.

Pertinent to this point, CEP strongly recommends that the amount of Community Solar project capacity available for this program should be capped at a reasonable percentage of the total available community solar capacity in National Grid’s footprint. The E-SFA petition estimates that approximately 600 MW-DC of capacity will be expected to participate in the program, which would amount to almost 30 percent of National Grid’s Community Solar project pipeline at a mature stage of development as of June 2021. Acquiring and managing customer subscriptions for community solar projects is core to the business models of many CEP’s member companies. These companies will have limited or no participation in the proposed E- SFA program, unless they make changes to their business models, because National Grid will be performing those functions.

CEP member companies are concerned that at this scale, the program could significantly restrict private sector participation with regard to customer acquisition and management, and that there will not be a healthy private customer acquisition and management market for the state to fall back on should the E-SFA not succeed. CEP recommends that the Commission caps total participating E-SFA capacity to a maximum of 200 MW-DC, which would imply a mature pipeline share of approximately 10 percent for the E-SFA, and still provide enough capacity for more than 40,000 low-income households in National Grid territory to benefit from the program.

3. Focus on Supporting New Distributed Generation and More LMI Customers

As proposed, the E-SFA program only targets projects that are at an advanced stage of development, specifically those projects that have obtained a Market Transition Credit or a Community Credit. Most such projects are mostly or fully subscribed at this stage. While pivoting mature projects to serving low-income customers would increase low-income participation in Community Solar, it would not represent a net gain in customer enrollment. If targeted at both late-stage as well as early-stage projects, the E-SFA program would likely stimulate the development of additional Community Solar projects towards meeting New York’s legislatively mandated goal of generating 70 percent of its electricity generation through renewable resources by 2030. Specifically, CEP recommends that the 200 MW initial block be split evenly between mature and early-stage projects.

Respectfully submitted,

Shyam Mehta

Executive Director

New York Solar Energy Industries Association (NYSEIA)

Anne Reynolds

Executive Director

Alliance for Clean Energy New York (ACE NY)

David Gahl

Senior Director of State Affairs, East

Solar Energy Industries Association (SEIA)