NYSEIA Summary of PSC Order Adopting NY-Sun Mid-Program Modifications
June 23, 2023
Today, the New York Public Service Commission issued an order adopting NY-Sun Mid-Program Modifications. The full order can be viewed here, and you can read NYSEIA’s brief (4-page) summary by scrolling to the bottom of this post and clicking "READ MORE".
Overall, the Commission’s Order is positive. It grants NYSERDA with authority to adjust NY-Sun incentive levels in response to IRA guidance and market conditions, authorizes modifications to the Prevailing Wage Adder eligibility to allow more projects to qualify; authorizes the creation of a Floating PV Adder; and removes system production adjustments from the upstate C&I incentive structure.
The Commission is not authorizing any changes to VDER at this time. In NYSEIA’s comments, we advocated to the Commission to revisit VDER compensation in order to increase accuracy (particularly for the Environmental, Demand Reduction and Locational System Relief Values, which we believe are artificially low) and create a long-term sustainable market. We did not expect the Commission to authorize changes to VDER in its Order today, and we will continue to advocate for these compensation improvements in all available venues.
The Commission did not direct the utilities to implement multiple Net Credit Rates for a single CDG project. However, the Commission did direct the utilities to convene technical conferences on the topic within the next sixty days and then to submit a filing to the Commission outlining if and how the utilities could implement multiple discount rates for consolidated billing customers within 120 days. NYSEIA is disappointed that the Commission did not adopt this NYSERDA/DPS recommendation, and we will continue advocating for multiple discount rates along with basic improvements to utility crediting for community solar.
Finally, the Order acknowledges that the Inflation Reduction Act could enable New York to exceed ten gigawatts of distributed solar capacity using the approved budget. The Order directs NYSERDA to file a report within 60 days outlining how much capacity (beyond 10 GW) NYSERDA believes the allocated funding could support, provided that the additional capacity is CDG and 40% of the capacity is allocated toward residential subscribers in Disadvantaged Communities.