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Coalition Seeks Rehearing On Billing/Crediting Performance Metrics For Community Distributed Generation

Dockets: 19-M-0463

In the New York proceeding to consider whether to allow community distributed generation and other distributed energy resources products and services seek to refine what performance metrics should apply the utility consolidated bill:

  • By January 1, 2026, the utilities must implement the metrics for billing credit timeliness and utility response time to host allocation lists.
  • Also beginning January 1, 2026, the utilities must file quarterly report updates.
  • Beginning March 31, 2027, the utilities are directed to file annual reports for each calendar year ending December 31st.  

As previously reported previously, on November 10, 2025 the Coalition for Community Solar Access (CCSA) and the New York Solar Energy Industries Association (NYSEIA) filed  comments re petition for rehearing related to the billing and crediting performance metrics regarding the order approving community distributed generation billing and crediting performance metrics issued by the NY PSC on July 17, 2025.

“The Petition requests the limited rehearing and reconsideration, in part, of the New York Public Service Commission’s (“Commission”) Order Approving Community Distributed Generation Billing and Crediting Performance Metrics, issued July 17, 2025 (the “Order”).  The Order established negative revenue adjustments (“NRAs”) that would be imposed if a utility performs at or below 95% on either of the two approved performance metrics on an annual basis starting in 2026. The two approved NRA performance metrics focus on: (1) the timely application of credits to community distributed generation (“CDG”) subscriber bills; and (2) the timely processing of CDG Host Allocation Lists. The Order also established a statewide $10 monthly credit to be applied to CDG subscriber bills if credits are not applied within 75 days of the host billing period end date; an expansion of a credit that is already in effect in Con Edison, New York State Electric & Gas (“NYSEG”), and Rochester Gas & Electric (“RG&E”) service territories. Finally, the Order also authorized the utilities to increase the CDG Net Crediting fee from 1.0% to 1.5%. This 50% increase to CDG Net Crediting fee assessed to CDG Hosts was imposed outside of a formal rate case and without the benefit of a utility proposal “based on actual costs and recovery.” 

“The Petition seeks a narrow rehearing of the 50% increase to the CDG Net Crediting fee on grounds that it is inconsistent with the New York Public Service Law (“PSL”) and contrary to the factual record before the Commission. The Petition recommends the Commission maintain the 1.0% CDG Net Crediting fee until the appropriateness of the fee and the obligated party responsible for funding the implementation costs associated with the adopted timeliness metrics can be duly considered and evaluated in a separate proceeding.” 

“As part of the Order, the Commission also directed each electric utility to provide an estimate of its costs to implement the two adopted performance metrics and associated NRAs. Each utility filed its cost estimate in this case on September 15, 2025.4 As discussed below, the information provided in these utility cost estimate filings is insufficient to determine whether the increase to the CDG Net Crediting fee is warranted. Further, the lack of granularity in the utilities’ filings reinforces the Petition’s request that the Commission closely evaluate these cost estimates to determine their reasonableness.”

Highlights from comments on the CCA’s petition for rehearing include:

The Joint Utilities urge the NYPSC to reject the CCSA’s petition for rehearing “as it rests on the concept that the NYPSC had no record basis for increasing the net crediting fee.” 

CCSA-NYSEIA commented that the NYPSC should reverse its premature 50% increase to the CDG net crediting fee based on data from the September 2025 utility cost filings.

Order Approving Community Distributed Generation Billing And Crediting Performance Metrics  (07/17/2025)
19-M-0463
(In the Matter of Consolidated Billing for Distributed Energy Resources.)

See also: Case 15-E-0082 – Proceeding on Motion of the Commission as to the Policies, Requirements and Conditions For Implementing a Community Net Metering Program.