NYSEIA partnered with the Coalition for Community Solar Access (CCSA) to draft and submit comments to NYSERDA regarding the Proposed Round 2 Program Design for the NY-Sun Inclusive Community Solar Adder. Key points included:

• We strongly support the relaunch of this program as soon as possible

• We encourage NYSERDA to consider allowing projects that receive the Low-Income Benefit Bonus Investment Tax Credits to also utilize the ICSA if greater than the federally required 50% of project capacity will serve low-income or ICSA eligible customers

• We encourage NYSERDA to allow the ICSA to be stacked with location-based Bonus ITCs as well as NYSERDA's Multifamily Affordable Housing Incentive

• We recommend that the full value of the ICSA be paid to projects in a single installment upon project completion rather than over the course of 3 years to increase its value

• We support NYSERDA's proposed subscriber eligibility requirements, and recommend several additional ways for subscribers to demonstrate eligibility to be considered as the program is rolled out

• We encourage NYSERDA to consider reducing the number of years that contractors would be required

• to maintain the original subscriber composition to increase interest and participation in the program

Click "Read More" to view our full comments.