NYSEIA and LISSA appreciate LIPA’s proposal, in their proposed tariff revisions under consideration for the May 2020 Board meeting, to allow for developers to secure the Value of Distributed Energy Resources Tariff’s Community Credit value at 25% interconnection payment or signature of an interconnection agreement if no payment for interconnection costs are needed. We encourage the Board to establish the same policy for securing the Value of Distributed Energy Resources Tariff’s Environmental Value (“E Value”) and Distribution Relief Value/Locational System Relief Value (“DRV”/”LSRV” value). Such a revision to the tariff would be consistent with policy in the rest of New York and would account for uncertainty about future DRV/LSRV and E values.