RESRFP25-1 Is Coming: Planning Bids in the Wake of New Federal Tax Credit Changes

Publish Date: July 9, 2025

Written by: Po-Yu Yuen, Director

Estimated Reading Time: 5 Minutes

Congress has just passed the One Big Beautiful Bill Act (OBBBA), bringing major changes to clean energy tax credits for solar and wind projects. For developers preparing to bid in NYSERDA’s upcoming RESRFP25-1 solicitation (expected in Q3), these changes could trigger critical shifts in project economics, competitive strategy, and risk exposure.

It makes one thing clear: this year’s bidding decisions will require deeper analysis, more careful planning, and sharper strategy than ever before.

Why the Tax Credit Changes Matter for RESRFP25-1

The OBBBA accelerates the phase-out schedule of the Inflation Reduction Act’s clean energy tax credits. Under the new rules: Projects that begin construction more than 12 months after the bill’s enactment (i.e., after July 4, 2026) must be placed in service by the end of 2027 to secure full-value credits.

For developers considering RESRFP25-1, this creates a critical question: Can your project realistically ‘begin construction’ in time to lock in the full value?

This timeline pressure is likely to constrain the bid pool, favoring more advanced projects confident in meeting the tax credit eligibility deadline while forcing others to weigh risky, bullish assumptions.

Beyond the Timeline: Other Uncertainties

Even with the bill passed, key details are unsettled.

Most notably, the White House has issued an Executive Order directing the Treasury Department to revise its ‘begin construction’ guidance to narrow safe harbor provisions, aimed at preventing a rush of projects attempting to lock in eligibility without real progress. Depending on the final RESRFP25-1 schedule and when Treasury issues its revised guidance, developers considering RESRFP25-1 participation face significant uncertainty around:

• How to ensure tax credit eligibility?
• Willingness to make early capital investments to secure safe harbor?
• The size of risk premiums they may need to price in to account for potential ineligibility

Additionally, developers will need to navigate expanded Foreign Entity of Concern (FEOC) restrictions that add complexity to project structuring and tax credit eligibility. Enhanced reporting requirements and compliance burdens further increase planning uncertainty.

These factors will force developers to decide how conservative or aggressive to be in their assumptions. Some may choose to sit out RESRFP25-1 rather than price in large uncertainty premiums. Others may proceed, but with a wider spread in bid pricing to account for these risks.

Strategic Implications for Bidding

If NYSERDA moves forward with its planned Q3 2025 release for RESRFP25-1, developers will have limited time to revisit strategy in light of this new uncertainty.

Smart bidding will depend on:

• Thoughtful pipeline screening: Which projects can realistically meet maturity and timing thresholds?
• Scenario-based analysis: Building realistic risk bands for schedule and credit qualification; evaluating competitive landscape and your project’s positioning in the face of bid pool uncertainty and pricing spread.
• Leveraging contract flexibility: Utilizing up to 25-year contract terms (if available) to spread costs and mitigate financing risks under uncertain federal incentives.

How NY REMO Helps You Navigate This Complexity

This is exactly the kind of environment NY REMO is built for.

Our NY REMO Early Look Briefing, to be released in the coming days, has been updated to provide early consideration of the impact of the newly passed federal tax bill and its implications for the RESRFP25-1 competitive landscape.

It will:

• Preview the expected eligible bid cohort, including volume and breakdown by technology, location, and size;
• Analyze how the supply curve and bid pool may potentially change when accounting for tax credit phase-out and risk; and
• Assess realistic award pricing outcomes that reflect this new risk landscape.

This is not a generic market forecast. It is tailored for Tier 1 New York developers who need to decide if, how, and at what price to bid this cycle.

Following release of NYSERDA”s RFP, our Detailed Look Briefing will help refine pricing and strategy based on the final solicitation design, evaluation criteria, and the latest market signals.

Bottom Line

The federal tax credit changes reshape the competitive landscape for RESRFP25-1.

Success will go to developers who deeply understand the new incentives, rigorously test their schedule and pricing risk, and position the right projects to bid at the right price.

NY REMO is here to help you do exactly that.

Contact us to schedule a NY REMO demo or Subscribe to this NY REMO blog series to stay ahead of New York’s Tier 1 Market.