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Joint Comments on NYSERDA's Proposed Inclusive Community Solar Adder (ICSA)

April 10, 2023

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.

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