Summary of 2026 Comments and responses

The public comment period on the draft 2026 solar and wind appraisal model opened on January 22, 2026 and ended on March 24, 2026. Numerous comments were received from interested individuals and entities. The following reflects a summary of the substantive comments received and responses. Similar comments and duplicative comments have been consolidated where appropriate.

Project Performance

Capacity Factors and Degradation

Comment: Capacity factors for operating wind assets should match project input data.

Response: In response to comments received during the 2025 public comment period, we re-evaluated our capacity factor assessment methodology for wind projects that were commercialized prior to 2015, using historical average annual production data for operating projects across each NYISO zone. For projects commercialized since 2015, we maintained our approach of using publicly available forecasts calibrated to each project’s commercialization year, as this approach is more appropriate than using historical data as a proxy for projected revenue expectations, and combining historical capacity inputs as the sole reference for forward-looking output may not always be appropriate.

Comment: The distinction between fixed-tilt and single-axis tracking solar projects, which was removed in the draft 2026 model, should be reinstated.

Response: Upon further investigation, we found it reasonable to include this distinction. The final 2026 tax model reflects capacity factors for both fixed-tilt and single-axis projects across each of the NEM, VDER, and Tier 1 asset classes.

Useful Life

Comment: Wind projects with Commercial Operations Date prior to 2015 should use a 20-year economic life, not the 25-year life assumed in the 2026 draft model. This argument is supported by Lawrence Berkeley Laboratory analysis.

Response: After reviewing and considering this comment, the Department has determined that anticipated early retirements of original equipment due to repowerings should not lead to a reduction in useful life for operating assets.

Project Costs

Operating Expenses

Comment: Operating expenses should be scaled up for NEM and VDER solar projects to account for reduced economies of scale relative to Tier 1 projects.

Response: After reviewing and considering this comment, the Department has determined that it is not appropriate to increase operating expenses as requested. The Department did not receive specific project-level data required to justify adding an incremental premium to the base operating expense forecast published by the National Laboratory of the Rockies for solar projects larger than 1 MW. Furthermore, updates to the final 2025 model to incorporate subscriber management costs for NEM and VDER solar projects have been maintained in the final 2026 tax model. Based on our investigation, we find it reasonable that these costs are primarily responsible for any incremental operating expenses associated with NEM and VDER solar assets relative to Tier 1.

Comment: Incremental host-community payments beyond those required under the Accelerated Renewable Energy Growth and Community Benefit Act should be considered for Tier 1 projects, as the Office of Renewable Energy Siting (ORES) requires some projects to negotiate Host-Community Agreements (HCAs) as a condition for siting approval.

Response The HCA guidance codified in 16 NYCRR Part 1100 General Procedures (regulations relating to the implementation of Article VIII of the Public Service Law) does not result in the agreements addressed therein constituting “host community benefit payments made pursuant to c. 58 of L.2020 part JJJ” (i.e. the Accelerated Renewable Energy Growth and Community Benefit Act). The inclusion of these particular HCAs as expenses within the model is therefore not mandated or otherwise addressed by RPTL 575-b.

Comment: The 2026 draft model does not capture rising insurance costs.

Response: Data available through June 30, 2025 does not reflect a trend specific to insurance costs beyond what is already reflected in the model.

Comment: Operating expenses should assume inverter replacement prior to end of 15-year asset life.

Response: Early inverter replacement has not been demonstrated to be common for assets with a 15-year life.             

Project Revenues

Market Price Forecasts

Comment: Year-over-year updates to energy, capacity, and ancillary service revenue forecasts should be minimized to reduce assessment volatility.

Response: The market prices used in the 2026 draft model are a blend of several reputable third party forecasts. The 2026 model uses production-weighted prices for valuation of energy output, meaning that changes year-on-year in both expected prices and technology-specific output are shaping revenue expectations. Separately, capacity prices reflect the effective UCAP and capacity accreditation-adjusted capacity price values, while ancillary service revenues included for hybrid assets factor in market saturation rates. Subsequent model years may consider a revised approach to reduce year-over-year volatility while ensuring sufficient input continuity.

Net Energy Metering (NEM) Rates

Comment: A model use case should be included for Remote NEM projects using 100% Commercial rates.

Response: There are both Residential and Commercial NEM rates for the major utilities in the 2026 model. Introducing new rate classes and rate class subcategories, including the distinction between Large Commercial and Small Commercial rate classes required to incorporate this requested change, would require complex analysis and updates to the methodology and model with a relatively small increase in precision of property values.

Comment: The assessed value of a NEM project is lower than the assessed value of a VDER project with otherwise equivalent inputs selected.

Response: NEM revenues are based on assumed retail rates and are generally higher on a per-unit basis than revenues from the statutorily taxable portion of VDER revenue.

Model Methodology

Discounted Cash Flow Modeling

Comment: The discount rate used for appraisal is too high and should also be specific to each municipality and Independent System Operator (ISO) zone.

Response: Discount rates reflect the expected cost of borrowing, the returns expected by equity capital providers, and tax rates. While these factors may vary from project to project, there are three reasons it would not be reasonable to introduce model-level variation in these factors across intra-state regions. First, verification of this variation would require project developers and municipalities to disclose their discount rate factors for benchmarking and audit purposes. Discount rates for private entities are commercially sensitive. Second, within a given state for which there is a corporate income tax rate, there is not typically sufficient variation in the factors that drive the discount rate to change valuation results to a material degree. Third, differentiation of WACC by ISO zone or municipality is not standard practice in any jurisdiction at the intra-state level.

 Hybrid Systems Modeling

Question: Noting that hybrid solar and storage projects have been added to the model, should standalone storage be included in the model as well?

                Response: Standalone storage is outside the scope of RPTL 575-b.

Comment: Hybrid systems should include PV:BESS ratios up to 100% (i.e. 1:1 ratio of solar capacity to BESS capacity).

                Response: There were an insufficient number of hybrid projects with BESS capacity greater than 70% of solar capacity to justify a model update for this year.