On November 10th, NYSEIA and the Coalition for Community Solar Access (CCSA) filed comments under Case 19-M-0463 and Case 15-E-0082 regarding CCSA’s Petition for Rehearing on the Public Service Commission’s order approving Community Distributed Generation (CDG) billing and crediting performance metrics.

On September 10th, the Commission issued an order establishing:

•  Negative revenue adjustments (NRAs) that would be imposed if a utility performs at or below 95% on either of the two approved performance metrics on an annual basis starting in 2026

• Approved two performance metrics

• Timely application of credits to CDG subscriber bills

• Timely processing of CDG Host Allocation Lists

• Established a statewide $10 monthly credit to be applied to CDG subscriber bills if credits are not applied within 75 days

• Authorized the utilities to increase the CDG Net Crediting fee from 1.0% to 1.5%, a 50% increase to the fee assessed to CDG Hosts imposed outside of a formal rate case and without the benefit of a utility proposal based on actual costs and recovery

The Petition seeks a rehearing regarding the New Crediting fee increase. The utilities were also directed to provide an estimate of its costs to implement the adopted performance metrics and associated NRAs in this filing, examined further in the comments.

NYSEIA and CCSA provide the following reasons the Commission should reconsider the Net Crediting Fee increase:

• Approving a rate increase prior to receiving data to justify it violates principles of ratemaking, is inconsistent with commission practice, and contrary to the intent of NRAs 

• Approval of a rate increase in this case is depriving other stakeholders of a fair opportunity to test and scrutinize whether additional expenditures are necessary

• The Commission previously expressly recognized a 1% CDG Net Crediting fee was appropriate given the simplicity of the Net Crediting model and expected moderation of costs relative to other consolidated billing arrangements

• Utility filings show discrepancies in methodology and magnitude of costs for implementing and administering performance metrics

• Most of the utility filings are not detailed enough, lacking information necessary to determine whether the proposed implementation costs are reasonable

○There was no standardized format or cost methodology

○Absence of data sources and additional materials

○Lack of explanation linking cost drivers to performance metric requirements

○Lack of information to demonstrate cost efficiency or scalability

Due to this, the parties recommend the Commission view utility filings as preliminary and insufficient for determining cost recovery, and any adjustment of the CDG Net Crediting fee should be verified through a full evidentiary review process, starting with the utilities being required to issue standardized additional information. NYSEIA and CCSA finally urge the Commission to grant the Petition’s request for rehearing and direct that any proposed increase to the CDG Net Crediting fee be supported by a formal discovery process.

Click “READ MORE” to view the full comments.