Catalyst Power Petition Submission to NYS Public Service Commission in Response to NYSERDA Mid-Program Modifications

Catalyst Power recently submitted detailed comments and recommendations on the proposed modifications to the NY-Sun program by NYSERDA, focusing on enhancing support for distributed solar capacity beyond the 10 GW goal and specifically targeting the Commercial and Industrial (C&I) sector. Here are the key points and recommendations made by Catalyst Power:

1. Support for Incremental Solar Capacity: Catalyst Power supports using the remaining $346 million in surplus funds to expand solar capacity beyond the initial 10 GW target set by the NY-Sun program. This funding is vital for supporting additional distributed solar projects, which are crucial for meeting New York State's ambitious climate goals under the Climate Leadership and Community Protection Act.
   
   
2. Focus on the Commercial and Industrial Sector: Catalyst Power advocates for targeted incentives and program adjustments that reflect the unique benefits and challenges of the C&I sector. They propose increasing the incentive structure and providing programmatic flexibility to facilitate the expansion of solar installations on commercial and industrial properties.
   
   
3. Proposed Program Modifications:
   • Introduce a "rooftop adder" for C&I solar installations, similar to the existing brownfield adder, to account for the unique barriers and higher costs associated with these projects.
   • Increase the on-site solar capacity limit from 750 kW to 1,500 kW for the Upstate Non-Residential program to better support C&I solar projects and enhance incentive levels to accelerate deployment.
   • Adjust the Non-Residential MW Block program's incentive level to $0.50/W, reflecting the lower projected median levelized cost of commercial solar compared to utility-scale solar.
     
     
4. Refinement of Pricing Structures: Catalyst Power recommends refining the locational marginal price (LMP) aspect of the current Value of Distributed Energy Resources (VDER) pricing structure from zonal to nodal pricing. This change would allow for more accurate prioritization of solar projects that alleviate grid constraints and enhance system functionality.
   
   
5. Benefits of C&I Solar:
   • Infrastructure and Cost Reduction - C&I solar reduces the need for extensive grid infrastructure upgrades and lowers transmission and distribution costs, making energy more affordable for consumers.
   • Land Use and Community Acceptance - Compared to larger solar farms, C&I solar typically uses less land and faces fewer community objections. It utilizes already-developed sites, reducing environmental and visual impacts.
   • Job Creation and Economic Benefits - The deployment of C&I solar creates local jobs and contributes to workforce development within New York.
     
     
6. Challenges and Market Conditions: The memo acknowledges the increased costs and economic challenges affecting C&I solar, such as inflation, supply chain issues, and financial market volatility. It calls for adaptive policy support to overcome these barriers and facilitate the continued growth of solar energy deployment.

Catalyst Power urges the Commission to ensure the robust development of the C&I solar market. This will help New York State achieve its clean energy objectives while supporting economic growth and grid resilience.