On behalf of the Alliance for Clean Energy New York (ACE NY) and the New York Solar Energy Industries Association (NYSEIA), we are writing to request that the Department of Taxation and Finance (DTF) extend the deadline for comments on DTF’s draft solar and wind appraisal models and preliminary discount rates. While we appreciate that DTF is continuing to consider input, our member companies need additional time—at least 10 more business days—to adequately review and comment on the second model (Model #2) which DTF posted on Friday, September 17.

We welcome DTF’s continuing efforts to develop a model for valuing wind and solar projects. We also recognize the complexity of valuing these projects. The release of Model #2—and DTF’s request for comments on this model—is clearly an example of the agency’s continuing efforts.

In comparison to the first model, Model #2, which DTF describes as "a potential alternative to the previously published preliminary model," features different assumptions regarding revenue and expense factors that our members companies are in the process of examining and running simulations. We believe that DTF will find the feedback from the project developers useful and it should not publish the final model before carefully reviewing this feedback.

Complicating the review of both models is DTF’s statement that “the final appraisal model may incorporate assumptions from both,” according to your website. It’s impracticable for project developers to comment on potential hybrid model scenarios in which various valuations could ultimately undercut one another. Much of the feedback that project developers provide on the individual models may not apply to a hybrid model.

To assist our member companies in their review and simulation, we request that any hidden or locked components of Model #2 (and Model #1) be unlocked. This will enable our member companies to examine the valuations more carefully and to run audits and simulations. Some of our members have conveyed that there are several tabs in Model #2 that are not visible. Four of these tabs contain information directly related to the calculation of revenues, a critical element of the model. Being able to review the information and mechanics of the contents of the inaccessible portions of the model is essential for commenters proposing potential corrections.

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