Comment
Q 1: It appears that all community solar incentives are up front. For clarification in Con Ed territory - will there be any equivalent of the .12 cent/Community Credit that is credited to the kWh production - for example, as modeled in the VDER - Value Stack Calculator? Without a Communty credit on the rate compensation side, it would seem to put a lot of pressure on smaller projects that are required to have a minimum of 10 subscribers. For example, with many residents in Con Ed territory are paying .30/kWh recently, if a solar project was offsetting a subscribers bill with only .10kWh (plus or minus) in the value stack, they would have to produce two to three times as much solar to offset the dollar value of an equivalent bill. A project under 100KW wouldn't be able to meaningfully offset a subscriber's bill under those constraints - and the marketing of most community solar programs that profess to reduce subscriber costs by 10% would become very questionable. A small percentage of buildings in NYC can support more than 100KW of solar. This is where the .12 cent adder was particularly helpful. It also allowed high density building residents to get a fair value of solar compared to their wealthier single family resident neighbors who enjoy net metering on non-demand accounts. I didn't catch how this economic justice issue is addressed under the new incentives laid out in the roadmap and would appreciate a specific explanation. Q2: I am concerned by the delayed monthly Value-Stack crediting from utilities. Small building that have taken out a solar loan - CPACE, NYCEEC, Fannie Mae, etc that is tied to value of solar production - to adopt solar under your program will not be able to make make monthly loan payments if Con Ed doesn't distribute value stack credits accurately and consistently. This would in turn harm their credit. It also erodes fragile trust between the end customer and all parties related to solar - utility and PSC included. All program design must consider execution of the program to ensure the results are as designed. How is the PSC addressing this ongoing issue under the new roadmap? Would they consider creating a credit safety net for solar project loans? Would the PSC allocate funds for auditing community solar accounts on behalf of subscribers who are otherwise bearing this cost and administrative headache?