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Supplemental Comments: Petition Regarding Permissions for Customer Participation in Multiple CDG Projects

September 14, 2020

These supplemental comments, which address a more narrow issue raised in the noticing of the petition in the New York State Register, CCSA, SEIA, and NYSEIA also urge the Commission to: (1) clarify that eligibility under the CDG membership requirements be determined by 25 kW subscription size; and (2) affirm the current treatment, under the 60/40 membership rule, of customers who are billed on a volumetric basis to ensure a diversity of community participation in CDG projects.

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