On March 11, 2025, the Alliance for Clean Energy New York (ACE NY) and NYSEIA submitted joint comments on the Department of Taxation and Finance (DTF) 2025 Solar and Wind Appraisal Model. Our comments outline key concerns of solar and wind developers and provide concrete recommended modifications to increase the accuracy of the draft model.

The comments address the importance of a stable and predictable tax model for solar and wind projects, but point out major discrepancies in this years model. Increased valuation and appraisal values of solar projects are driven by a projected increase of solar and wind project revenues, which make them dramatically higher than previous years. The model also includes lower operating expenses and insurance costs which also contributes to higher appraised value and tax burden. Some of the suggestions in our comments include: reusing 2024 energy curves, disclosure on how the expense numbers are calculated, usage of RPTL § 575-a reports, and disclosure regarding the composition of O&M expenses.

We recommended the DTF to adopt a multi-pronged approach similar to Illinois’ solar program for adjusting their wind & solar appraisal model, which employs two strategies: annual surveys of market participants, and a summary of year-to-year changes in models.

Click "READ MORE" for our full comments and find coordinating attachments below.