On June 13, 2025, NYSEIA filed supplemental comments to the New York Public Service Commission under Case 21-E-0629 in the Matter of the Advancement of Distributed Solar. NYSEIA's comments bolster the solar industry petition for rehearing filed in May 2025, which seeks to restore the $271M that the NY Public Service Commission cut from NYSERDA's distributed solar program in April 2025 without advance warning or public notice.

NYSEIA's supplemental comments include an analysis of several events and publications since filing a petition for rehearing in May 2025. These new events and publications include: the recent passage of H.R.1. by the US House of Representatives, which threatens to phase out many clean energy tax credits within 60 days of enactment; the New York Independent System Operator's (NYISO) publication of Power Trends 2025, which highlights New York's dwindling reserve margins and the urgent need to add generating capacity to meet summer load growth; and NYSERDA's updated Cash Flow Analysis for the Clean Energy Fund in light of the Commission's April 2025 defunding of the NY-Sun program, which shows that the cut will not deliver material programmatic budget savings until 2028.

NYSEIA's comments make three major points:

1. The passage of H.R.1. on May 22, 2025 strengthens the claim in NYSEIA's May 19, 2025 petition for rehearing that federal threats to New York's distributed solar industry represent a "new circumstance" under Public Service Law 22, thereby warranting a different Commission determination regarding the NY-Sun budget.

2. NYSERDA's updated Clean Energy Fund Cash Flow, filed on June 9, 2025, shows that eliminating funding for the NY-Sun program will not deliver meaningful cost savings until 2028. However, it will cause layoffs in New York's solar industry immediately by eliminating new distributed solar development opportunities. It will also eliminate future utility bill savings by reducing distributed solar deployment at a time of record load growth. NYSEIA recommends that, as an alternative, the NY Public Service Commission achieve cost savings through interconnection reforms and rate design improvements.

3. NYISO's 2025 Power Trends report, published on June 2, 2025, forecasts that summer peak demand will increase by 2-4 gigawatts over the next decade. The report also notes that New York's capacity additions are not keeping pace with retirements, creating affordability and reliability concerns for New York's electricity system and customers. NYSEIA estimates that restoring the full NYSERDA NY-Sun program budget could support up to 1,459 MW of additional solar PV capacity, leveraging more than $2 billion in private capital, supporting more than 2,000 additional good jobs (the majority of which will pay Prevailing Wages), lowering electricity bills for participating and nonparticipating customers, and supporting New York’s grid reliability by increasing supply to meet load growth.

Finally, NYSEIA recommends a collaboration among NYISO, DPS Staff, NYSERDA and distributed energy resource (DER) stakeholders to consider and advance policies and programs to accelerate DER deployment in areas where they can most effectively address the projected electric load growth highlighted in NYISO’s June 2025 report.

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