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New York PSC Denies Opt-Out Municipal Aggregation Community Solar, In Adopting Statewide Solar For All Program
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In an order adopting a Statewide Solar for All program (S-SFA), the New York PSC denied again a proposal to allow municipal aggregations (also known as community choice aggregations or CCAs) to provide community distributed generation (CDG) on an opt-out basis
The PSC previously placed a "pause" on CCA-offered opt-out CDG
Under S-SFA, the investor owned utilities (IOUs) will
aggregate bill credits generated by participating community
distributed generation (CDG) projects and distribute them among customers who meet both of the following criteria: (1) reside in disadvantaged communities and (2) are
enrolled in the utility’s low-income energy affordability
program (EAP)
Certain municipal aggregation administrators and aligned parties had requested, as the PSC considered a proposed S-SFA, that the PSC authorize opt-out CDG by CCAs
The PSC declined to do so in adopting an S-SFA program
The PSC said, "Pertaining to [CCA parties'] request that the Commission
approve the CCA opt-out CDG 'at scale solution,' the Commission
finds the objective of the Statewide Solar for All and 'Opt-Out
CDG' proposals equivalent, as both policies seek to promote
enrollment of low-income customers into a program to receive
solar credits. The Commission considers National Grid’s E-SFA [Expanded Solar for All
Proposal]
model an 'at scale solution' fully operational right now and,
for that reason, is authorizing the scalable solution to be
administered at each major electric IOU. Moreover, under an S-SFA program, the value of participation in the program could
accrue to low-income customers across the State, instead of only
to low-income customers in municipalities that have a CCA
program, as would be the case under an opt-out CDG program[.]"
The PSC also dismissed concerns, raised by certain retail suppliers, about monopoly utilities running the S-SFA program
The PSC said, "In response to comments that the S-SFA program will be
run by utilities, or that the program is handing over control to
the utilities, the Commission reminds market participants, and
the public in general, that CDG in New York State has always
been, and will continue to be, a market-based program with very
active third-party project development. Currently, there is no
existing utility control of the CDG program and the adoption of
S-SFA will not change that."
"Fundamentally, any program,
including opt-in CDG, opt-out CDG, S-SFA, and onsite net energy
metering (NEM), that involves utility bill credits also involve
administrative and implementation activities by the utilities," the PSC continued
"It is disingenuous to assert that S-SFA reflects a qualitative
change in utility control or involvement compared to traditional
opt-in CDG, EAP assistance [a utility’s low-income energy affordability
program], or onsite NEM," the PSC said
The PSC did order that utilities will be required to train their
call center representatives to, "help low-income customers sign up for opt-in CDG by directing
them to tools established for the purpose of making CDG
subscriptions with savings more accessible to households
participating in government-run low-income support programs."
Specifically, the PSC ordered the Joint Utilities to
develop a shared "dual participation" [customer participation in both S-SFA and opt-in CDG] resource plan that includes training material for utilities to
"proactively encourage dual participation[.]"
Such dual participation plan shall include a utility-sided S-SFA EAP webpage with links to
New York State's Energy Advisor webpage [a clearinghouse for state info on low-income assistance], DOE’s Low-Income Clean Energy Connector tool,
and NYSERDA’s Find a Community Solar Project tool.
Tariffs to implement S-SFA shall be filed to be effective December 1, 2024, while utilities were ordered to begin Statewide Solar for
All credit distribution to eligible customers on December 1,
2025
Cases 21-E-0629, 19-E-0735, 14-M-0224
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May 16, 2024
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Copyright 2024 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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