The Clean Energy Parties including NYSEIA submitted initial comments on the presentation by Navigant at the April 15, 2019 Value of Distributed Energy Resources (“VDER”) Rate Design Working Group meeting. As New York continues to require more of its electricity to be obtained from clean DERs, ensuring that future rate designs do not become a barrier to solar deployment is paramount, as is inclusion of state policy goals in evaluating bridge rates during the transition from Net Energy Metering. The CEP generally supports the analytical framework proposed for evaluating bridge rates and future rate design options.