On April 20th, 2026, NYSEIA, the Coalition for Community Solar Access (CCSA), and Solar Energy Industries Association (SEIA), submitted comments in support of National Grid’s Flexible Interconnection (Flex IX) Scaling Pilot Proposal. 

In January, 2026, National Grid filed a petition seeking to offer Flex IX service options to distributed generation and/or energy storage projects interconnecting under the NY-SIR at limited locations as an expansion of their Active Resource Integration (ARI) pilot. 

Rising interconnection costs and dwindling cost effective hosting capacity are critical barriers to sustained cost-effective deployment of large DERs. The Solar Parties urge the Commission to swiftly authorize the proposal’s implementation, offer suggestions for consideration that seek to strengthen the proposal and increase its impact and scalability. 

The Parties support the Proposal’s alignment with the SIR and optionality for developers, the approach to qualifying upgrades under cost sharing, and the 5% target limit to annual curtailment and the pro rata curtailment framework. 

The Parties offer the following recommendations to strengthen the Flex IX Scaling Pilot:

• Expand the scope of the pilot to at least 100 MWac

• Expand the scope to actively manage energy storage import constraints

• Expand the Pilot to manage both charging and discharging behavior for 1-5 MWac BESS

• Make a Pilot Participation Agreement template available to the public, extending through the full length of the project and clearly describing the program and Flex IX risks

• Address the risk of excessive curtailment 

• Provide full data transparency to DER developers

• Establish a fixed and predictable annual fee structure

Click “READ MORE” to view our full comments.