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Comments on NY-Sun Inclusive Community Solar Adder: Rule Changes, Round 2 Program Design

October 13, 2022

We appreciate New York State Energy Research and Development Authority’s (NYSERDA’s) continued commitment to the development of distributed solar in New York State through the NY-Sun program. We also encourage NYSERDA to launch the expansion of the ICSA as authorized in the recent Order Expanding NY-Sun Program without further delay to properly incentivize projects serving Low-and-Moderate Income (LMI) subscribers and related disadvantaged communities, a core tenet of the CLCPA.

In the absence of an immediate successor block to the now fully allocated Upstate Community Adder, and in light of the reduction of ConEdison base incentives from NYSERDA’s proposed levels in the 10 GW Roadmap (to account for higher initial ICSA, Community Adder, and MAHI rates), there is currently significant uncertainty in New York’s Community Distributed Generation (CDG) market. Historically, when there has been a lapse in incentives the solar market reacts by pausing project development. Neglecting to fulfill the 10 GW NY-Sun expansion and establish ICSA rates and successor blocks at this critical juncture could not only imperil the State’s ability achieve its CLCPA targets, but could jeopardize New York developers’ ability to secure the recently announced federal Inflation Reduction Act (IRA) funds.

With a limited capacity of “low-income bonus” tax credits being made available, NYSERDA should launch the new State program and block rates as soon as possible to allow New York community solar developers serving LMI customers and disadvantaged communities to move forward with development activities in advance of securing limited federal funds, while reserving the authority to modify incentive rates and program rules if appropriate when federal guidance is released early next year.

The Inclusive Community Solar Adder is critical to the solar industry’s ability to target benefits to LMI families and disadvantaged communities in New York State. We encourage NYSERDA to digest and integrate stakeholder feedback and launch Round 2 of the ICSA as efficiently as possible. While we appreciate that the Inflation Reduction Act has piqued the State’s interest in identifying potential savings in the NY-Sun program that could be utilized to fund additional distributed solar projects to further amplify savings, NYSERDA will have ample opportunity to make further adjustments to the NY-Sun program as part of the Mid-Point Review and once the guidance around IRA provisions is finalized.

For the time being, and to avoid further market uncertainty through excessive re-evaluation of program design which may also result in administrative inefficiencies as expressed by PSC in their Order Expanding NY-Sun Program, NYSEIA and CCSA urge NYSERDA to proceed as planned by releasing the ICSA along with the next Upstate Community Adder block without delay.

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