On January 15th, 2026, NYSEIA submitted comments on the Joint Utilities’ Proactive Planning Framework Methodology Document. 

In September the Public Service Commission (PSC) issued an order adopting a modified Proactive Planning framework, stating “Existing and new DERs, such as solar and energy storage, have the ability to serve load locally and cost effectively, which may reduce the impact of new loads on the system, mitigating the need for certain grid upgrades. The Commission therefore directs each utility to incorporate both existing and forecasted quantities of DER into the load forecasts utilized in the Modified Proactive Planning Framework.”. The Joint Utilities (JU) presented their Proactive Planning Framework Methodology Document in December. 

In the comments, NYSEIA expressed support for New York’s efforts to proactively plan for and build the grid we need tomorrow, and that proactive planning and strategic investments can lower costs and ease the process of incorporating larger and more dynamic electric loads. NYSEIA’s comments highlight opportunities to more fully consider and integrate Distributed Energy Resources (DER) in the Proactive Planning Proceeding and in the Framework Methodology with the following points:

• The JU intended to primarily consider traditional distribution investments that may be needed for electrification and load growth, but seems to consider DER as solely a load modifier. DER’s are meaningful resources, and load reduction is just one of the use cases/values of DER. NYSEIA encourages the Utilities to consider cases where scaling up DER deployment could serve load growth more cost effectively than traditional transmission and distribution system expansions 

• The JU methodology doesn’t consider proactive investments that create DER hosting capacity

• DER forecasting assumptions must be clarified, and additional focus on the need for distributed generation in the Framework is needed since it is currently focused on forecasting building and transportation electrification

• The potential of DER to meet evolving grid needs must be accounted for. The Commission, Staff, and JU should increase DER stakeholder engagement to ensure the resources are given robust consideration in the process.

• The Department of Public Service should convene a technical conference focused on the opportunity to integrate DER forecasting and integration in the Proactive Planning process

Click “READ MORE” below for our full comments.