On April 24th, 2026, NYSEIA, NY-BEST, SEIA, and CCSA (referred to as the SSP) submitted comments in response to DPS Staff questions regarding Utility Owned Renewable Generation (UOG).

The SSP foundational concerns regarding UOG is that it will cost more for ratepayers, undermine competitive markets, and cause financial harm to market participants who are investing significant amounts of private capital in New York’s electric sector. The SSP notes that cost overruns are already negatively impacting distributed energy resource development. 

The build transfer, develop transfer, and milestone-based transfer proposals would allow regular utilities to directly compete with other owner operators to finance and purchase projects. If private companies are replaced by a regulated utility, project risk is transferred from investors to captive ratepayers. 

The SSP’s preferred approach is to limit ownership of renewables and energy storage to IPPs and utilities’ unregulated affiliates, who bear project risks on the same terms as other market participants. 

The SSP respectfully disagrees with the notion that Utilities have unique advantages that would enable the development of renewable and storage projects more effectively than private developers. While they have valuable system knowledge, this does not justify UOG– rather it is a rationale for surfacing more granular data to clean energy developers so they can identify optimal locations to deliver projects cost-effectively. 

The most significant challenges currently facing renewable and energy storage projects relate to permitting and interconnection– UOG does not solve these challenges, as they are subject to the same siting and approval process as private developers, and rising interconnection costs are largely driven by outdated utility practices. In addition to this, UOG would create market asymmetry, due to their control of the SIR queue and study process for DERs, and undermining of EAMs.

Read our full comments below.