On October 19th, NYSEIA and SEIA submitted comments on NYSERDA’s Petition for Clarification and Modification of the Statewide Solar for All (S-SFA) program.

NYSEIA and SEIA support NYSERDA’s proposed clarifications in the Petition, including:

1. Request that the S-SFA rules be modified to remove the requirement for a minimum of 12- months’ notice for a non-operational project to disenroll from S-SFA

2. Clarification confirming that projects may enroll in S-SFA at the time of the project’s initial 25% interconnection deposit payment or when a Standard Interconnection Contract has been executed or at any time thereafter until a project’s operational date

3. Clarification confirming that a project’s Compensation Level is determined by the date of the project’s initial 25% interconnection deposit payment or the date when a Standard Interconnection Contract has been executed

4. Requests that information about projects enrolling in or disenrolling from S-SFA be added into the utility Community Distributed Generation/Remote Crediting Switching Reports that each utility submits to NYSERDA

The first would provide more flexibility to storage and solar developers and owners. We further recommend the Commission establish a defined reasonable timeframe for utilities to process requests to transition S-SFA projects to another crediting method.

NYSEIA and SEIA support the second proposal as it would be beneficial for the Commission to clarify these pieces, as it would provide clarity to program participants and new market entrants. The third recommendation reduces market confusion, aligning it with our current understanding of program rules. The final proposal would ensure NYSERDA receives accurate information for the purpose of administering NY-Sun. 

Click “READ MORE” to view our full comments.