On July 20th, the Joint Utilities (JU) and the City of New York filed comments in response to the Staff Whitepaper Regarding Marginal Cost of Service (MCOS) studies submitted on March 27th, 2023 in Case 19-E-0283. The Clean Energy Parties (CEP), a coalition of clean energy trade associations active in New York, submitted reply comments in response to selected items contained in the comments of the JU, including:

• Probabilistic Load Forecasts

• Counterfactual Load Forecast

• Reliability vs. Growth Investments

• 10 Year Time Horizon

• Presentation of Costs & DRV and LSRV Calculation Methods

• Request for a Technical Conference Focused on LSRV Calculations and Administration

The CEP recommended a technical session to further investigate the competing proposals and also to discuss ways to improve LSRV administration so that DERs can respond to the price signals and provide tangible deferrals in distribution upgrade requirements.

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