In a recent article we examined Governor Kathy Hochul’s proposal to expand the NY-Sun initiative with the aim of installing 10 gigawatts of distributed solar in New York by 2030—a considerable increase from the current target of 6 GW by 2030. Below are the answers to some common questions about this new 10 GW solar roadmap for NY.
New York’s 10 GW Solar Roadmap: Q&A
The following questions and answers are taken from a recent Q&A published by the New York Solar Energy Industries Association (NYSEIA). The full document, featuring further questions & answers and more in-depth information, is available to download here.
Q) How big is the initial Community Adder block?
A) The initial community adder block is for 2.27 GW with rates initially set at $0.07/W for Upstate New York and $0.10/W in Con Edison’s territory. This block is separate from any existing/proposed Inclusive Community Solar Adder.
Q) If a project has already secured MW Block incentive, is it eligible for the new Community Adder?
A) No, if a project has already received NY-Sun incentives it is not eligible for new block or Community Adder incentives. According to NYSERDA, the project would be eligible for the existing Inclusive Community Solar Adder (ICSA), but the ICSA is fully allocated. The following quote elaborates further on this:
“so absent recycling of ICSA funds from canceled projects, if Roadmap proposal is approved as is, projects that previously received a base incentive would have to move forward with just that incentive.”
The Roadmap does, however, propose additional Solar Energy Equity Framework (SEEF) funding which is earmarked for continuation of the ICSA and other programs. It is not clearly defined in the Roadmap if this potential “new” ICSA funding would be made available for those projects which have already received base incentives.
Q) Can the ICSA be added to the new Community Adder? Similarly, can the LMI Adder be stacked on top of newly announced incentives for approved projects?
A) This is uncertain because, as noted in the previous answer, there are no remaining ICSA incentives available as all have been allocated. However, new SEEF funding intended for the ICSA has been proposed. The amount of proposed funding is undefined at the moment. Additionally, the design of the next iteration of the ICSA remains unclear.
Q) Will there still be an adder for LMI projects in Con Edison territory? If so, what will that be? Additionally, will any of the 2.270 MW community adder be set aside exclusively for LMI, or is it all additive?
A) The Roadmap proposes 2,270 MW of new community adder at initial levels, while also proposing new SEEF funding for ICSA in a separate/additional line item. As noted, the existing ICSA has been fully allocated, but additional SEEF funding of $207 million has been requested, with the aim of 40% of the incremental NYSERDA-incentivized capacity of 1,375 MW to be included under the SEEF. Currently, details of new SEEF/ICSA funding are undecided.
Q) If a CDG project has a Con Edison status of “CESIR Payment Received - Pending Review”, will it be eligible for new incentives? Furthermore, is it correct that there is no interconnection payment milestone cutoff for incentives?
A) Yes, if a project has not received a commitment for any NY-Sun incentives to date, it will be eligible for new incentives—even if it is already in the utility interconnection queue.
Q) As there is no mention of a change to Upstate non-residential, what should be expected as an incentive for below 750 kW Upstate?
A) The following extract from the Roadmap elaborates on this:
“No changes to the existing Upstate Nonresidential MW Block structure. Once all Upstate Nonresidential incentives are committed, eligible projects may apply for the available Upstate C/I MW Block incentives. (For clarity, these projects would be subject to the NY-Sun nonresidential program rules, including incentive payment schedule, but would receive the Upstate C/I incentive rate and draw capacity from the Upstate C/I MW Block structure.)”
Q) Where will multifamily feature in the new incentives? Previously it fell under the nonresidential category, but it appears that this category has been removed?
A) Again, extracts from the Roadmap cover this subject:
“The Multifamily Affordable Housing Added Incentive, launched in 2018, provides additional NY-Sun incentives for projects under 200 kW sited on multifamily affordable housing properties that are either owned by a public housing authority (PHA) or are managed under a regulatory agreement with local, state, or federal housing agencies.”
“NYSERDA will continue offering the Affordable Solar Residential Incentive and the Multifamily Affordable Housing Incentive, as well as support for project predevelopment and technical assistance support.”
Q) Do the incentives outlined in the roadmap differentiate between solar-only assets and solar + storage assets?
A) No. The incentives outlined in the paper are specific to the solar portion of the project, regardless of whether they are standalone or paired with other technologies. There is no mention of new storage incentives, but there is reference to NY Green Bank solar + storage investments, and NYSERDA’s Affordable Solar and Storage Predevelopment Technical Assistance Program.
Q) Is standalone storage excluded from these incentives? If so, have there been discussions about standalone storage incentives?
A) Yes, standalone storage is excluded. A new storage roadmap will be filed in the summer, and will likely propose new incentives for storage projects. However, there may be replenishment of retail storage incentives for NYC before that. This is currently undecided and under discussion, with the possibility of an update sometime in Q1.
Q) What will happen to Con Edison CDG projects currently in the pipeline that have received interconnection approval, along with community credit in the Value Stack, but don’t yet have MW Block incentive capacity? Is NYSERDA cancelling the current MW Block that these projects have based their development on?
A) It is expected that the current Con Edison nonresidential block ($0.20) will remain open until filled, or after the PSC has approved the Roadmap. If and when the Roadmap is approved, a new C&I block will open at $1.30 for projects under 1 MW, and $0.75 for projects at/over 1 MW. At this point, pending another authorizing Order, non-residential projects that apply for the current non-residential block subsequent to Roadmap filing, or that have already applied to the current non-residential block not been awarded a Community Credit, will be eligible to opt in to the new C&I block. These projects would be subject to NY-Sun nonresidential program rules, including the incentive payment schedule, but would receive the Con Edison C&I incentive rate and, similarly, draw capacity from the Con Edison C&I MW Block structure. For those projects which have been awarded a CC, but are still in process with AHJ approvals to secure MWB, the current nonresidential MWB will be open up until the date that the new blocks are opened. This date would arrive sometime in Q2—assuming the PSC approves the proposal.
Q) If a CDG was being developed in NGRID Upstate, would it be eligible for the base incentive, plus the CC incentive, and then compensated for the appropriate VDER rate?
A) Yes, this is correct, assuming that no NY-Sun incentives have been received to date.
Q) Will projects that have already secured MW Block incentives be eligible for the 3.1 cent E-Value?
A) Yes, VDER projects may receive both MW Block incentives and the E-Value. The E-Value is part of the VDER Value Stack, which is separate from Phase One NEM compensation. VDER is required for eligible CDG, RC, and large on-site, and opt-in for eligible residential and small commercial. Otherwise, projects are compensated through Phase One NEM—effective as of January 1, 2022—with no E-Value.
Q) Is there any chance of the E-Value being revisited before final approval of the plan?
A) Maybe not as part of this Roadmap, but NYSEIA will likely make the case for revisiting E-Value either in this case or, perhaps more likely, another.
Q) How will the Community Adder be awarded? Will it be a case of just going back and issuing new compensation letters for projects that missed the cut, or is it only for those projects which have yet to pay their 25% interconnection deposits?
A) Under the Roadmap’s proposals, any project that did not receive a NY-Sun incentive, regardless of interconnection status, would be eligible for the new base incentive and Community Adder.
Q) For the NY-Sun block incentive, is it advisable to apply now for those incentives in order to join a queue, or will there be a different method for prioritizing applications?
A) No, the NY-Sun application portal for Upstate Commercial and the Community Adder will soon be closed. You should not apply for the proposed new incentives right now. Developers should move ahead with interconnection and AHJ approvals in order to get into shape to meet NY-Sun eligibility criteria when the new incentives arrive. This is projected to be mid/late Q2, pending PSC approval. At this point there will likely be an unavoidable rush to get in line. However, there is a small chance that initial demand for the new incentives is higher than the initially proposed capacity level of 800 MW. If this is the case, applications could be ordered based on the date of the 75% interconnection payment.
Q) What is regarded as a single project for the purposes of the 1 MW PW cutoff?
A) This is not specified in the Roadmap, but it would likely default to interconnection application for project capacity in AC, and then convert to DC based on uprate factor.
Q) What will happen after the initial blocks are filled?
A) This has not been decided. NYSERDA expects that these incentives will support development through 2022. If blocks run out early, they may opt to open a new block at reduced incentives, or bolster the existing block at the same levels, or do something else entirely.
Q) What is the status of Con Edison residential incentives?
A) Currently, there is ~46 MW remaining in Block 9 at $0.20. This will remain available until it is expended. Additionally, there are proposals to shift current nonresidential blocks into new residential blocks:
Nonresidential Block 9, with ~52 MW remaining at $0.20, would shift to a new residential block of ~70 MW at $0.15.
Nonresidential Block 10, of 70 MW at $0.15, would shift to a new residential block of 70 MW at $0.15.
There is also a proposal to add 150 MW at $0.15, bringing the totals to:
Residential Block 9: ~46 MW at $0.20.
New Proposed Block 10: 290 MW at $0.15.
Once again, the NYSEIA document which this information is taken from can be downloaded, or read in full, at this link.
If you want to go solar in New York then reach out to YSG today. YSG has been operating in the NY solar industry for over a decade, working on everything from rooftop residential projects to large-scale solar farms. Whatever your energy needs, we can identify the ideal project to save you money on your utility bill. Call the office at 212.389.9215 or send us an email to learn how much you could save with solar.
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