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.