By Michael Kuser

ALBANY, N.Y. — The New York State Public Service Commission on Wednesday expanded the eligibility of distributed energy resources to be compensated under the state’s “value stack” tariffs, particularly standalone storage systems with 5 MW or less of capacity.

The commission’s Sept. 12 order (Case 15-E-0751; 15-E-0082) mentions that “energy storage systems charged by using regenerative braking technologies, such as those used by New York subway systems, be eligible for the Value for Distributed Energy Resources (VDER) tariff for any hourly injections to the grid.”

The order also authorizes interzonal crediting, allowing DERs receiving value stack compensation to apply credits to the bills of customers in the same utility territory but different NYISO load zones.

“It’s good policy to continue to expand the value stack to new types of projects and to larger sizes of existing projects,” Commissioner Gregg C. Sayre said.

Ted Kelly, assistant counsel for the Department of Public Service, testified that combined heat and power (CHP) systems would not be eligible for value stack compensation now, but that staff would analyze CHP to establish “under what conditions CHP would be eligible and that greenhouse gases would not be worse than under system power and that it does not cause local impacts in sensitive areas such as environmental justice areas.”

The PSC in February ordered the state’s utilities to open participation in their value stack programs to DER projects up to 5 MW, more than doubling the previous 2-MW limit. (See NYPSC Expands VDER Project Size to 5 MW.)

The commission’s original VDER order of March 2017 (Case 15-E-0751) directed that compensation for eligible DER transition from net energy metering (NEM) to the value stack, a methodology that bases compensation on the benefits provided by the resources.

The new order expands the eligibility for value stack crediting to any clean generation technology that qualifies as a Tier 1 resource under the Clean Energy Standard (CES). The new rules also make resources that would qualify for Tier 1 but for their start date before the Jan. 1, 2015, eligible for compensation under the value stack.

The new eligibility rules also cover tidal energy generators, biomass generators and food waste digesters that meet CES requirements.

“There is no reason to exclude any renewable DERs from value stack compensation, as the value stack represents a determination of the actual value created by those generators,” the commission said.

Commissioner Diane Burman voted against the measure.

“Some of this has direct impact on other pending proceedings, including some declaratory ruling requests,” Burman said, adding that careful analysis and wording is needed to prevent unnecessary requests for clarification of commission orders.

In a related matter on its consent agenda (Case 18-E-0130), the commission accepted the environmental review of policy options to implement New York’s Energy Storage Roadmap, supporting the state’s energy storage target of 1,500 MW by 2025.

PSC Rules on CDG Compensation

The PSC backed NRG Community Solar in its dispute with Central Hudson Gas & Electric and Orange & Rockland Utilities over compensation for NRG’s community distributed generation (CDG) projects.

The commission’s declaratory ruling (18-E-0485) said the NRG Energy subsidiary had identified a conflict between the PSC’s VDER transition order and the utilities’ Phase One NEM tariffs.

NRG said the utility tariffs would pay its projects through monetary crediting (dollar-value credits based on the $/kWh rate applicable to the project) although they were designed assuming they would receive more lucrative volumetric crediting (kilowatt-hour credits that reduce the bill based on the $/kWh rate applicable to that subscriber).

“CDG projects receiving compensation under Phase One NEM … should receive volumetric crediting, regardless of the project’s service class, meter type, or billing methodology,” the commission said. “As this declaratory ruling is explaining and clarifying the effect of prior orders, rather than establishing a new rule or modifying existing rules, it applies to all utilities with VDER tariffs.”

The ruling does not affect the compensation of CDG projects receiving value stack compensation.

“There is in fact an inconsistency between the orders and tariffs cited here,” PSC Chair John Rhodes said. “That fact is objectively true. I find this recommendation carefully and clearly addresses that inconsistency.”

Burman voted against the ruling. “What if the issue is we didn’t intend it, but that’s what happened and we didn’t do the right analysis?” she said. “If we’re saying there’s an inconsistency between the VDER order and the tariff, maybe we need to look more closely at some of the challenges that are being raised with the VDER order.”

PSC Expands Con Edison EV Smart Charging

The PSC approved Consolidated Edison’s request to expand its electric vehicle charging program, SmartCharge NY, to allow the utility to offer incentives to customers who charge medium and heavy-duty EVs during off-peak hours.

The commission’s order (Case 16-E-0060) said “it is critical to begin testing the efficacy of off-peak charging programs for the full gamut of EVs at a time when EV penetration is comparatively low.”

“This strikes me as a useful, budget-prudent and limited expansion of an existing and innovative program, tailored to some market realities,” Rhodes said.

Burman voted against the expansion, saying “this order does not clearly define or give clear guidance on the specifics of the implementation plan.” She said the commission was shirking the “hard work” of defining potential logistical issues.

The order noted that the transportation sector is the largest contributor of GHG emissions in the state, and that diesel-powered medium and heavy-duty trucks account for a disparate share of total automobile pollution.

Expanding the SmartCharge NY program should cut carbon emissions and help meet the state’s goal of reducing GHGs by 40% by 2030, the commission said.

New York’s Zero-Emissions Vehicle (ZEV) plan calls for creating statewide EV infrastructure to support 30,000 to 40,000 EV sales by the end of 2018 and 10,000 charging stations by 2021. The commission reported 26,470 EVs are now registered in New York.

On its consent agenda, the commission also approved Con Ed’s shared solar program for low-income customers, with modifications, and with a budget not to exceed $9 million (Case 16-E-0622).