New York state energy agencies on Tuesday released a three-part study that urges faster permitting, planning and approval processes to build the transmission necessary to accommodate the nearly 40 GW of new renewable energy plugging into the grid over the next two decades.

The Initial NY Power Grid Study Report recommends that transmission planners increase their reliance on NYISO’s stakeholder processes, particularly for developing public policy projects. It says the most urgent needs are to link Long Island’s expected 3 GW of offshore wind energy with the mainland and to beef up the infrastructure needed to import 6 GW of OSW into New York City.

The state’s Department of Public Service and the New York State Energy Research and Development Authority (NYSERDA) prepared the study, supported by The Brattle Group and Pterra Consulting, among others.

“‘Initial’ means it’s the 2021 installment, and ‘full’ means it is complete at about 750 pages of work,” Public Service Commission Chair John Rhodes, said in announcing release of the report at a meeting of the state’s Climate Action Council.

The PSC ordered the report last May, as directed by the Accelerated Renewable Energy Growth and Community Benefit Act (Case No. 20-E-0197). (See NYPSC Launches Grid Study.)

The study comprises three components, examining transmission needs for OSW and bulk system needs for land-based renewables out to 2040, as well as needs on the sub-bulk level.

“We think it’s very well done. We know it’s informative, has many interesting findings and is a major milestone in terms of creating the information foundation for us to craft the right kind of transmission future for the state,” Rhodes said.

Procuring 9 GW of OSW by 2035 is vital to meeting the goals established by the Climate Leadership and Community Protection Act, which mandates that 70% of electric power in New York come from renewable resources by 2030 and that electricity generation be 100% carbon-free by 2040.

Local transmission and distribution (Phase 1) projects already under development appear sufficient to integrate land-based renewables, although some might be accelerated, the report said.  Other more preliminary (Phase 2) projects might be pushed forward in order to attract investment in solar and wind development Upstate.

“In particular, [New York’s] Zero Emissions Study results suggest that additional bulk transmission from Upstate into the New York City area (from Zone H to Zones I, J and K) will likely become cost effective as the state approaches 2040 and congestion costs increase,” the report said.

OSW Scenarios

In calling for the start of development of a tie-line between Long Island and Zone I or J, the study said that “all studies indicate that additional tie-line capacity would be needed by 2035–2040 as renewable requirements grow and emissions limits tighten. Advancing such a project would provide additional value earlier if constraints into New York City force more than 3,000 MW of OSW into Long Island and mitigate curtailments associated with real-world operating conditions not captured in the studies’ simulations.”

The report also urged a multidisciplinary planning and coordination effort for routing up to 6 GW of OSW generation into New York City and interconnecting it with the city’s substations.

“However, overcoming cable routing limitations in New York Harbor, space constraints in substations in Manhattan, and permitting complexities in both the Harbor and along the Long Island coastline (including approaches to New York City through the Long Island Sound) will require careful planning of OSW transmission cable routes and points of interconnection,” the study said. “Creating the option for a meshed offshore network by linking the offshore substations of several individual OSW plants near each other is valuable because a meshed configuration can achieve a more reliable and resilient delivery of OSW generation.”

The study concluded that a decision to implement a meshed system can — and possibly should — be delayed pending federal approval of new wind energy areas, as long as New York officials ensure that any projects with radial connections are built with an option to integrate into a meshed system later.

In its comments related to the study, NYISO said transmission congestion and curtailment patterns drive bulk transmission expansion, which the study contends will be necessary to integrate all the new renewable energy resources being developed under state clean energy policies.

To inject OSW energy, smaller megawatt amounts at more points of interconnection could potentially require less transmission expansion, NYISO said.

However, “based on the cable routing study conducted by the DPS’s technical consultant, there appear to be limited available cable routings through New York Harbor. If each project has independent radial connections, opportunities for necessary cabling to achieve the full offshore wind goal of 9,000 MW will be limited,” The ISO said.

“The study makes clear that to overcome interconnection challenges and achieve this [9 GW] goal, New York needs carefully planned offshore wind cable routes and points of interconnection that will ensure reliable, resilient delivery of offshore wind energy to power New York homes and businesses,” Janice Fuller, Anbaric’s Mid-Atlantic president, told RTO Insider. “Governor Cuomo has called on the market for creative proposals to meet this critical challenge.”

Local T&D Cost Allocation

The report found that Phase 1 local transmission projects would unbottle delivery of an estimated 6.6 GW of renewable generation, while proposed Phase 1 distribution projects could tap another 2 GW. The study estimates that the more preliminary Phase 2 project proposals for local transmission could provide 12.7 GW of renewable integration benefits, based on the headroom calculations, while Phase 2 distribution proposals could support an estimated 2.8-4.3 GW.

Both utility and NYISO transmission planning processes should be improved to recognize the unique advantages that advanced technologies such as dynamic line ratings can provide, the study said. For example, commercial-scale applications for dynamic line ratings “have demonstrated a 20-30% increase of average annual transmission capacity above static ratings (e.g., with a 10% increase during 90% of the year, 25% during 75% of the year, and 50% during 15% of the year), while maintaining or enhancing system reliability.”

The power grid study also recommends allocating the costs of these projects state-wide on a load ratio share basis, as recommended by the state’s investor-owned utilities, which in November jointly filed a report on transmission and distribution investment. Representatives from each company joined a technical conference to outline their policy recommendations and propose projects to state officials. (See Meshed OSW Tx Grid May Work Best, NY Officials Hear.)

The IOUs include Avangrid subsidiaries New York State Electric and Gas and Rochester Gas and Electric; Central Hudson Electric and Gas; Con Edison and its subsidiary Orange and Rockland; and National Grid subsidiary Niagara Mohawk Power. Collectively the utilities propose to spend $7 billion on transmission and distribution upgrades by 2025 and an additional $10 billion over the following five years.

The IOUs’ comments on the new grid study reiterated points from their earlier report and incorporated learnings from the technical conference Nov. 23, noting “the fundamental need” for local transmission and distribution investment to support the integration of clean energy resources. “In other words, the zero emissions grid presentation recognized that there is a clear interdependence between the local and bulk transmission system upgrades; without resolving the congestion and curtailments on the LT&D system, the value to customers of new bulk transmission investments and renewable generation will be limited,” they said.

Con Edison identified three immediately actionable projects around New York City, estimated at $860 million. The utility on Dec. 30 filed a petition with the PSC seeking approval to recover project costs through its rate plan capital budget, and also for up to $4 billion for the second phase of six projects to create points of interconnection, including two new “NYC Clean Energy Hubs,” several new feeders and the rebuilding of two area stations.

Multiple Intervenors, a coalition of large industrial, commercial and institutional energy customers, submitted comments on the new grid study emphasizing that “customer funds are not unlimited, particularly in the aftermath of the economic recession caused by the COVID-19 pandemic.” The group urged the commission “to ensure that customers — and especially energy-intensive/trade-exposed businesses that are price-sensitive — are not burdened with excessive or unnecessary costs.”

New York City said the PSC should deny Con Edison’s requests for pre-approval as the report does “not provide sufficient information to provide a rational basis for such a decision,” and should also consider mechanisms for cost containment to help control the costs of the additional infrastructure that will be needed.”

The New York Power Authority (NYPA) said that a cost allocation approach in which NYSERDA would use System Benefits Charge funds to pay for transmission improvements supporting state policy goals would be “extremely difficult to exercise with NYPA” because its customers do not pay the charge, nor does NYSERDA have legal authority to charge NYPA’s municipal customers.

NYPA supports a proposal for the PSC to authorize a retail charge that would be distributed as appropriate among utilities pursuant to a commission-approved adjustment mechanism, which “means cost recovery would be set within retail rates and would not require a proceeding at FERC or any additional approval.”

NYISO Views

The state will likely need new transmission system facilities if more renewable resources are assumed to locate in Western New York, Northern New York and the Southern Tier as development trends suggest, the ISO said.

The grid operator said that NYSERDA awards of renewable energy credits to date support the conclusion that renewable investments will concentrate in certain geographic areas, and that its 2019 Congestion Assessment and Resource Integration Study (CARIS), released last July, provides insights into the potential value of additional transmission capability across the state.

“In the 70×30 Scenario simulations, approximately 11% of the annual total potential renewable energy production would be curtailed across the New York system,” NYISO said.

The power grid study said that more work will be necessary to quantify existing headroom in various transmission-constrained areas on the local and bulk transmission systems and “to identify high-priority, high-value locations that should be targeted with transmission upgrades. These studies should be based on both a power-flow model that better measures headroom capacity and a production simulation model — ideally aligned with the NYISO’s economic planning process assumptions and modeling tools — that can estimate annual curtailments and the extent to which proposed upgrades can reduce these curtailments.”

Based on its interconnection queue, over 90% of the land-based renewable capacity proposed outside New York City and Long Island is in NYISO Zones A through E, leaving less than 10% in Zones F and G, NYISO said.

The ISO referred to its own climate change impact and resilience study and to a decarbonization pathways study by NYSERDA, saying that both 2020 reports support the need for firm capacity to meet multi-day periods of low wind and solar output, a need most pronounced during winter periods of high demand for electrified heating and transportation.

Regarding bulk system storage resources, NYISO said a model should reflect their operational charging and discharging cycles as well as the probability of their availability.

NYISO also supports the use of its public policy process to solicit competitive solutions, a process it says should now take approximately 18 months following the PSC’s identification of such a transmission need.

The ISO’s Market Monitoring Unit, Potomac Economics, questioned NYISO’s benefit/cost analysis methodology for local transmission planning, saying that if “it relies on biased assumptions, there is a risk that viable alternative solutions that are more cost-effective or do not rely on ratepayer guarantees will be crowded out.”

In particular, the Monitor said that the CARIS 70×30 case was never designed to be an accurate forecast of the power system in 2030 and hence does not provide a reasonable basis for evaluating the benefits of individual transmission proposals.

“First, we recommend developing economic criteria for future resource inclusion in the forecast model and using multiple realistic scenarios when assessing projected curtailment. Second, we recommend changes to the LBMP, capacity value, cost of capital and period of analysis assumptions that will more accurately quantify projects’ benefits and risks,” the Monitor said.