NYSEIA submitted joint comments on September 3, 2019, with Alliance for Clean Energy New York, Coalition for Community Solar Access, Natural Resources Defense Council, Renewable Energy Long Island, Solar Energy Industries Association and Vote Solar (referred to as the “Clean Energy Parties,” or “CEP”) in response to the Notice Seeking Comments Regarding Consolidated Billing for Community Distributed Generation (“the Notice”). CEP expressed support for implementing Utility Consolidated Billing with Purchase of Receivables (“UCB- POR”) as an option for CDG providers if implemented properly with a reasonable fee structure and in a transparent, easy-to-understand customer interface.

The Joint Utilities (“JUs”), including National Grid, also submitted comments on Sept. 3, 2019, in response to the Notice, expressing reservations about UCB-POR because of what they said would be the time, effort and expense required to implement it. Instead, the JUs proposed a “Net Crediting Model” (“NCM”) as “a simpler and preferred alternative to consolidated billing.” National Grid subsequently filed the Petition to implement a Community Distributed Generation Platform (“CDG-P”) program. The CDG-P consists of two elements: (a) Platform 1 - Net Credit Allocation (“NCA”), which relies on the JU-proposed NCM, and (b) Platform 2 - Customer Acquisition and Turnover Management service.

Overall, NYSEIA is supportive of integrated billing approaches that can provide direct and equitable benefits to CDG customers, CDG providers, and that can help the state achieve its clean energy and equity goals by enabling more CDG development at lower cost. NYSEIA sees potential value in a net crediting approach as outlined in Platform 1; however, we strongly recommend that details on pricing, bill presentation, access to data, and non-discrimination protections should be addressed through a robust stakeholder process involving input from CDG providers prior to Platform 1 implementation. NYSEIA opposes Platform 2 as written and proposed, and recommends that the Commission thoroughly address the broad range of issues and ramifications it encompasses.