Publish Date: June 19, 2025
Written by: Po-Yu Yuen
Estimated Reading Time: 7 Minutes
On May 15, the New York Public Service Commission (PSC) issued its final order on the Clean Energy Standard (CES) Biennial Review. While NYSERDA and DPS Staff had considered a wide array of proposals, the PSC ultimately adopted a targeted set of changes, balancing the need to strengthen renewable energy progress (read: support projects reaching commercial operation) with ratepayer cost constraints.
For renewable energy developers participating in New York’s Tier 1 large-scale renewable (LSR) procurements, the outcome offers a mix of new opportunity, higher expectations, and important market signals just ahead of the upcoming RESRFP25-1 procurement round.
More Volume, More Time, and a Clear Signal of Long-Term Demand
The PSC approved NYSERDA’s proposal to increase the annual Tier 1 procurement target from 4.5 TWh/year to 5.6 TWh/year and extended NYSERDA’s procurement authority through 2029. This paves the way for five more annual solicitations, starting with the upcoming RESRFP25-1.
While the PSC declined to expand the annual procurement target further, even as offshore wind development faces material uncertainty, it signaled a willingness to revisit procurement levels in the next review cycle.
Takeaway: New York is offering rare demand visibility in today’s volatile U.S. clean energy market. That provides confidence for ongoing development and may justify infrastructure investments – like workforce expansion – that relieve project delivery bottlenecks.
Maturity Requirements Tighten: Early-Stage Projects Face Higher Barriers
Although the PSC declined to alter the 70% price weighting in bid scoring, it did raise the minimum project maturity threshold. Bids must now demonstrate that they’ve entered Phase 2 of the NYISO interconnection process, including making all required payments. NYSERDA can impose stricter requirements in future solicitations and must coordinate with DPS to ensure a competitive pool of qualifying bids.
Takeaway: The bar for participation is rising. Developers will need to be more deliberate about timing their development activities and bids to ensure qualification, with enough progress to meet minimum thresholds and settle key project details. The goal: bid when the project is both eligible and competitive, securing revenue certainty while avoiding the risk of leaving project development investment stranded without a viable offtake.
No Onshore Wind Carveout: But NY Can’t ‘Solar Its Way’ to 70% CES Target
The PSC rejected proposals for an onshore wind carveout or bonus, citing ratepayer cost concerns. Still, it acknowledged that resource diversity is essential, and New York can’t meet its climate targets with solar alone.
NYSERDA retains the ability to shape award portfolios, including through technology caps and diversity metrics. It may now also treat solar and solar-plus-storage as distinct technologies, allowing more tailored portfolio composition.
Takeaway: While onshore wind won’t receive special treatment, NYSERDA has the policy tools – and clear encouragement – to maintain a balanced, diversified mix of awards.
Contract Flexibility: A Critical Adjustment for an Uncertain Market
The PSC gave NYSERDA greater flexibility in contract terms:
- Contract tenors may now extend up to 25 years (previously capped at 20 years); and
- Mandatory termination clauses for delayed CODs have been removed, replaced by more flexible tools like milestone security and contract tenor reductions.
These changes acknowledge the real-world complexity of project development, especially as developers face federal policy uncertainty and supply chain risk.
Takeaway: Flexible contracts are essential for enabling success in a high-risk environment with extended development timeline. The PSC’s approved changes give both NYSERDA and developers more room to adapt (before pulling the plug) without shifting that risk and uncertainty onto ratepayers.
Index REC Risks Remain, for Now
While stakeholders have previously flagged Index REC basis and shape risk as a source of price premiums, the PSC opted not to act… yet. Instead, NYSERDA and DPS will consider potential changes in the next Biennial Review or a separate proceeding.
Takeaway: The existing Index REC structure remains unchanged for RESRFP25-1. Bidders must still account for price volatility and market exposure as they craft their strategies.
The Bottom Line
The PSC’s final order offers a clear, if measured, set of signals:
- New York is committed to steady LSR procurement.
- Projects must be mature, competitive, and resilient.
- And while structural reforms are still under review, bidders must sharpen their strategies to manage market and contract risk within the existing framework.
How New York Renewable Energy Market Outlook (NY REMO) Can Help
Sustainable Energy Advantage’s NY REMO Tier 1 Early Look Briefing, to be released in late June, will give subscribers a head start on RESRFP25-1, before NYSERDA releases its RFI or RFP in Q3. You’ll get:
- A preview of expected eligible bid cohort, including total volume and breakdown by technology, location, and size
- Supply curve analysis shaped by the latest policy and market developments
- Insights into expected award outcomes, considering competition and procurement appetite
NY REMO delivers the market intelligence you need to bid with confidence.
Boost Your Prospects Now:
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