The DG industry in New York is facing severe disruption and challenges brought by the COVID-19 pandemic. Installation of new projects is currently stopped, and it will likely take years for the industry to rebuild, even after construction work begins again. Customer demand will be reduced because of COVID-19 and the economic recession. For these reasons, we believe that now is not the time to implement sweeping changes to rate design for DG customers. As we’ve shown in previous comments, the rate design changes proposed in the Staff Whitepaper will decrease customer incentives to invest in new DG, presenting additional challenges to rebuilding the industry in New York. It will be difficult for New York to meet its ambitious clean energy goals in the face of recovery from COVID-19, which will only be made more difficult by implementing sweeping changes to rate design that harm the economics of new projects.

Accordingly, the CEP recommend that DPS delay consideration of any new changes to DG rate design until the end of calendar year 2022, including any decision to replace Phase One NEM and the implementation of a new customer benefit charge for DG customers.