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December 21, 2021

NYSERDA Submits Its 10 GW Distributed Solar Roadmap to Expand the NY-Sun Program

On December 17, 2021, the New York State Energy Research and Development Authority (NYSERDA) submitted to the New York State Public Service Commission (PSC) its Distributed Solar Roadmap (Roadmap) for the deployment of 10 GW of distributed solar by 2030 in the new PSC Docket 21-E-0629. The existing 6 GW target is nearly achieved, which prompted NYSERDA to declare the NY-Sun program a success and request additional funding.

NYSERDA’s new Roadmap proposes to expand the NY-Sun program in order to generate approximately $4.4 billion in private investments and spur the development of an additional 4 GW of solar, bringing the state’s total distributed solar capacity to over 10 GW by 2030. The framework is also expected to generate an additional 6,000 jobs in the state’s solar industry. Overall, the Roadmap proposes enough new, clean, renewable energy to annually power 700,000 additional homes in New York State. As was the case with the previous targets, NYSERDA selected an administratively set incentive rather than an auction-based procurement approach due to the fact that, unlike large-scale projects such as offshore wind, an auction-based procurement may not always align with distributed solar development processes and timetables and may present unique challenges to developers. Interestingly, NYSERDA also determined that expanding the existing NY-Sun Megawatt (MW) Block program was preferable to transitioning to a variable environmental value under the Value of Distributed Energy Resources (VDER) value stack, given the existing programmatic infrastructure and the MW Block program’s proven track record.

New initial incentives fall into four categories: Upstate Capital and Infrastructure (C&I), Small C&I, Large C&I, and Residential Projects. As its name suggest, the Upstate C&I block is for development throughout Upstate New York, whereas the other three blocks fall within Consolidated Edison’s territory in Downstate New York. The incentives for each category through the end of 2022 are below.

Upstate C&I 

  • The initial block will be set at 800 MW, with a $0.17/W base incentive and a $0.07 community adder for community distributed generation (CDG). 
  • An additional 2.1 GW block of incentives to follow.

Small C&I (projects less than 1 MW in capacity)

  • The initial block will be set at 30 MW, with a $1.30/W base incentive and a $0.10/W community adder. 
  • An additional 120 MW block of incentives to follow.

Large C&I (projects greater than 1 MW in capacity)

  • The initial block will be set at 30 MW, with a $0.75/W base incentive and a $0.10/W community adder. 
  • An additional 120 MW block of incentives to follow.

Residential Projects

  • The initial block will be set at 150 MW, with a $0.15/W base incentive. 

The Roadmap also adds a new requirement that workers associated with the construction of NY- Sun–supported projects that are greater than 1 MW be paid the applicable prevailing wage as long as the initial application for utility interconnection has been made after December 17, 2021, when the Roadmap was filed. Projects that fit within that definition, but that have submitted their initial utility interconnection application prior to the filing of the Roadmap, are proposed to be exempt from the new prevailing wage requirement.

The Roadmap is open for public comments, and the PSC is set to make a decision on this sometime in 2022. Barclay Damon’s Regulatory Practice Area attorneys will be monitoring these and other regulatory updates that affect the renewable energy industry.

If you have any questions regarding the content of this alert, please contact Brenda Colella, Regulatory Practice Group Leader and Regulatory Practice Area co-chair, at; Ekin Senlet, Regulatory Practice Area co-chair at; David Solimeno, associate, at;  Angela Sicker, associate, at; or another member of the firm’s Regulatory Practice Area.

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