Position Summary

1. It is becoming increasingly challenging to connect DER to the grid, which will only increase at an increasing rate, evidenced by many things, including "closed" substations in various regions.

2. The DER industry is concerned that we are going to effectively run out of hosting capacity far sooner than any meaningful upgrades can be made via CLCPA processes, putting thousands of jobs and hundreds of companies at risk.

3. Baseline metrics are essential to understanding basic state of affairs and making informed decisions. Presently no NYS regional/global benchmarks are available.

4. Presently there is no ability to assess the rate of change or trending over time. Using rates and trending we can create a timeline and estimates for when we expect major issues to arise, and can respond accordingly.

5. We therefore request a joint industry & utility effort to produce a "State of DER Dashboard" as soon as possible. Industry requests data collection start of Q4, 1 October 2021, published on 1 November 2021.

6. The dashboard will provide critical data to inform all stakeholders of key areas of concern, trends, rates of change, and indications whether current or planned efforts are having any objective positive benefits.

7. This information is essential for influencing how and where to focus our collective efforts as interconnection challenges become more and more frequent.