[EDITOR’S NOTE: A previous version of this story erroneously included the New York Power Authority as part of the group of utilities.]

New York’s local transmission and distribution system owners on Thursday recommended that state regulators approve a coordinated grid planning process (CGPP) and revised benefit-cost analysis (BCA) method as proposed by them in December (20-E-0197).

The New York Public Service Commission in September established a category of public policy transmission investments and directed investor-owned utilities to revise their proposed benefit-cost analyses. (See New York Adopts Groundbreaking Tx Investment Rules.)

“The CGPP will facilitate technical collaboration between planning authorities and vetting of the existing system studies to ensure consistency between all studies, eliminating confusion and potential conflicting information,” Bart Franey, National Grid supervisor of regulatory strategy, said to more than 220 participants at a technical conference held by the PSC.

“Once established, the CGPP will align system representation planning tool assumptions and other key constraints to drive consistency between all CLCPA-based studies [and] will be used to inform the market policymakers on the cost and viability of future interconnections,” Franey said, referring to the Climate Leadership and Community Protection Act, which requires that 70% of New York’s electricity generation come from renewable resources by 2030 and that generation be 100% carbon-free by 2040.

The utilities group include the state’s IOUs, as well as the Long Island Power Authority. Staff from the Department of Public Service (DPS), the New York State Research and Development Authority (NYSERDA) and NYISO helped shape the proposals, on which interested parties can submit comments until March 21.

The revised BCA approach would use capacity expansion analyses. Costs would be evaluated on a dollars-per-megawatt basis for transmission and non-wire alternatives (NWAs). Benefits would be evaluated as the incremental amount of energy delivered to load as a result of reduced curtailments and the capacity of additional renewable generation that can be interconnected.

Projects would be ranked on the basis of metrics and criteria to be developed in collaboration with DPS staff, the utilities said.

New Technologies and More

The utilities considered several new and emerging technologies in their potential projects, including power flow control devices, dynamic line ratings and energy storage, the commission said, noting several “areas of concern” characterized by the presence of existing renewable generation that is already experiencing curtailments and a strong level of developer interest that exceeds the capability of the local transmission system.

FERC in December ordered transmission owners to stop the use of static line ratings in evaluating near-term transmission service, which it said will improve accuracy and transparency, and increase utilization of the grid. (See FERC Orders End to Static Tx Line Ratings.)

“Modifying the rating of a given transmission line throughout some given period rather than solely having seasonal based ratings, as is the conventional practice, can be taken into consideration in operations and planning, so that’s a very recent order,” said Zach Smith, NYISO vice president of system and resource planning. “From NYISO’s perspective we’re looking at it and considering what we do on compliance for that.”

PSC orders in this proceeding have specifically pointed to DLR as a technology that may help the state get more CLCPA benefit at low cost, said Elizabeth Grisaru, deputy director of the DPS’ Office of Electric, Gas and Water. “The commission has specifically pointed to [DLR] as one of the technologies our utilities should be considering when developing and proposing” their projects.

The crux of the grid analysis is to identify the placement of generation that can optimally use existing transmission on both the bulk and non-bulk systems, and those siting assumptions and land-use assumptions are going to be critical, Franey said.

NYISO analysis found tightening margins across the New York grid through time, with a margin of only 200 MW in New York City (Zone J) and only 700 MW in western New York (Zone A) by 2030. | NYISO

 

Transmission providers are hoping for long-sought-after changes on FERC’s Advance Notice of Proposed Rulemaking, a wide-ranging inquiry into the commission’s rules on transmission planning, cost allocation and generator interconnection. (See Transmission Industry Hoping for Landmark Order(s) out of FERC ANOPR.)

The ANOPR proceeding will likely have impacts not only on the comprehensive system planning process, but on the way that that interacts with various policies, such as the interconnection process and how the system is planned as a whole relative to generation coming forward, Smith said.

“Depending on what comes out of that FERC proceeding, presumably an order at some point, it could be a great opportunity for the NYISO, our stakeholders, for all of us to be working together on what’s the most efficient planning process,” Smith said.

Advisory Council Makeup

The utilities also proposed creating a new advisory council to manage the planning cycles.

The scope of work would be developed in the first stages of the CGPP by the council, said Martin Paszek, section manager for transmission planning at Consolidated Edison.

“I would try to keep the council as one group and maybe with subgroups … but not have two separate groups that are losing the coordination we’re trying to achieve,” said Bill Acker, executive director of New York Battery and Energy Storage Technology Consortium (NY-BEST).

A planning group with a distribution subgroup would work well, agreed Zack Dufresne, executive director of the New York Solar Energy Industries Association (NYSEIA).

The proposed process is two-pronged, with the first being NYISO’s local transmission owner planning process, wherein utilities’ specific content and technical information regarding transmission investments would be reviewed and discussed openly, Franey said.

“The second prong to our stakeholder engagement plan really adopts a couple of models that exist in New York today such as the New York State Reliability Council or the Climate Action Council, [which] are very useful at leveraging stakeholder input on a more tactical basis,” Franey said.

The council would invite information that utilities aren’t experts in, such as generation development and land use, so it would consist of representatives not only from utilities and the state, but also from community organizations and renewable energy trade associations, he said.

“We envision that these industry organizations or groups would nominate a rep and an alternate to set up a lot of the critical input that would then translate into assumptions for modeling purposes,” Franey said.

In thinking about stakeholder engagement, the DPS considered its own Interconnection Policy Working Group and Interconnection Technical Working Group structures, which “are pretty good models,” Grisaru said.

One important group that wasn’t in the proposal is consumers, who “absolutely” need to have a voice in the process, said Couch White attorney Kevin Lang, representing New York City.

“I believe there are a lot of people that are participating this morning who are not active in the NYISO process, and if what we’re talking about is distribution and local transmission, which is under PSC purview, I question whether or not a NYISO process that looks at the bulk system is the right venue  to be talking about distribution and local transmission issues and whether or not the audience is even the correct audience for those discussions,” Lang said.

Lang had an ally in Erin Hogan of the state’s Utility Intervention Unit.

“Allowing developers to select sites very remotely and then have the expectation that consumers will be recouping costs and the investments that might need to expand the headroom does not seem to be wise, leaving consumers too far out of the loop,” Hogan said.

She suggested informing county executives of the planning discussions so they can share the information and make communities knowledgeable about the decisions being made and how people might be able to participate.

“I want to be clear today that this is the starting point for this effort,” said Tammy Mitchell, director of the DPS Office of Electric, Gas and Water. “Much more work and stakeholder input will be needed to fill out the details of the process and align [utilities] and New York ISO activities to support holistic views of CLCPA needs, so there will be many other opportunities to ask questions and provide input in the planning process.”