On February 27, 2024, NYSEIA and ACE NY submitted joint comments to the New York State Department of Taxation and Finance regarding their proposed 2024 appraisal model for solar and wind facilities. NYSEIA and ACE NY recommend that DTF:

• Support market stability and legislative intent by reducing year-to-year changes between appraisal models and resultant appraisal values;

• Correct capacity factors to be more accurate for both wind and solar, and collect DC and AC nameplate capacity to calculate project-specific capacity factor for PV;

• Adjust operating expense assumptions to include subscriber management costs for community solar and host community agreement benefits for large-scale renewables;

• Allow users to adjust the analysis period to support accurate modeling for projects that will not be operational for a few years;

• Reduce the assumed revenue for VDER projects from 95% of gross VDER value to 90% to account for typical subscriber discounts, utility administrative fees and cases of customer nonpayment;

• Reduce the economic life for wind projects from 25 to 20 years;

• Increase the assumed weighted average cost of capital from 9.35%-10.38% to 13.19%; and

• Modify the model to dispay all values in nominal dollars (rather than inflation adjusted) to reduce user confusion.

  
  

Finally, NYSEIA and ACE NY requested that, in future years, DTF publish a change log and documentation for any proposed modifications to provide transparency and simplify the public comment process.

According to DTF's auto-reply email, DTF aims to publish a final version of the wind and solar appraisal model by April 1, 2024.

Click "READ MORE" to view NYSEIA and ACE NY's full comments.