To: John B. Rhodes, President and CEO, NYSERDA, Valerie S. Milonovich, Senior Counsel, NYSERDA, Janet Joseph, Vice President for Technology & Strategic Planning, NYSERDA, Richard Kauffman, NYS Chairman of Energy and Finance, Peter Keane, D...

Extend New York On-Site Wind Incentives

We oppose the discontinuation of the NYSERDA On-Site Wind Turbine Incentive Program and strongly urge you to continue this or a similar program for five years to maintain momentum in the small wind industry, and allow New Yorkers, particularly farmers and rural homeowners, to continue to realize its benefits.

NYSERDA's On-Site Wind Turbine Incentive Program (PON 2439) provides financial assistance to residents, farmers, and businesses that want to invest in on-site wind turbines that are smaller than 2 megawatts. Most of those who benefit are farmers who use the electricity generated by the turbines to power farm operations, and thereby reduce their electric bills. The program has been in place since January, 2012 and is currently set to expire at the end of 2015. Over the last four years, this program has supported the installation of 124 small wind energy projects, at a total program cost ranging between $800,000 and $2.7M per year. By continuing the program for an additional five years, New York will be invigorating a home-grown New York renewable energy industry and allowing family farmers and rural small businesses to become a part of New York's energy future.

Through the installation of small wind turbines, family farmers and other small businesses are able engage in the energy market, diversify the State's renewable energy portfolio, bring energy resiliency to the grid and community, and reduce carbon emissions. All of these results mirror the State's objectives of its Reforming the Energy Vision (REV) proceeding. While the various REV initiatives continue to be designed and implemented, it is imperative to continue NYSERDA support for on-site wind turbines and keep this industry thriving in the Empire State.

We urge you to continue offering an incentive program tailored for on-site wind, and we thank you for your consideration.

Why is this important?

New York is in the midst of a landmark Reforming the Energy Vision (REV) process, including reorientation of NYSERDA's programs. The small wind industry has been actively participating in the REV proceeding and has been impressed by its breadth and ambition. We expect that certain of the REV initiatives – such as community net metering, community choice aggregation, valuing distributed generation in new utility tariffs, and demonstration projects could provide new exciting opportunities for the small wind industry in New York.

However, we need to maintain momentum until these REV initiatives are in place, and not disrupt business opportunities in New York to the point where there is no small wind industry to take advantage of the new REV framework. For this reason, we strongly urge you to support continuation of on-site wind incentives, in some form, in the near-term, to avoid a cliff in the small wind industry.

A cliff for small wind will disrupt our trajectory towards grid parity, which is the goal for distributed wind, like other distributed generation technologies.

DWEA had previously suggested a program modeled after NY-Sun in meetings with NYSERDA and DPS. Like solar, a system of declining incentives based on the amount of megawatts deployed would provide a long-term signal to the industry and a strong incentive to continue to reduce costs. Further, achieving scale will itself reduce costs as customer acquisition, design and construction, and permitting costs come down due to economies of scale.

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