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Comments in Support of CCSA Request for Rehearing on Expanded Solar for All

May 23, 2022

The New York Solar Energy Industries Association (NYSEIA) respectfully submits these comments in support of the rehearing request regarding the Expanded Solar For All (E-SFA) Program, submitted by the Coalition for Community Solar Access (CCSA) in Case 19-E-0735- Petition of the New York State Energy Research and Development Authority Requesting Additional NY-Sun Program Funding, filed on February 22, 2022.

The rehearing petition filed by CCSA is narrow in scope and relates to a specific determination of the Public Service Commission in its January 20, 2022 Order that prohibits eligible customers from simultaneously participating in the E-SFA Program and a community distributed generation (CDG) project. NYSEIA supports CCSA’s request to allow for simultaneous enrollment.

Enabling simultaneous participation in both E-SFA and CDG increases energy equity, customer choice, and the potential savings directed to eligible low-income customers and disadvantaged communities (DAC). This type of “dual participation” brings greater harmony to the market in National Grid service territory and maximizes customer benefits; National Grid customers enrolled in rate assistance programs should not be barred from receiving potentially increased benefits from CDG due to their auto-enrollment in the E-SFA program. Simultaneous enrollment will also prevent undermining confidence in the recently expanded NY-Sun program.

Should the Public Service Commission approve this rehearing request, we urge for a clear implementation schedule and clarity for customers and CDG providers about how the two offerings will be implemented.

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