NYISO on Jan. 21 presented stakeholders with its preliminary proposal for complying with FERC Order 1920, giving a first glimpse into how the ISO may conduct a long-term transmission planning process.

The ISO would repurpose elements of its current Economic Planning and Public Policy planning processes while retaining reliability studies like the Short-Term Assessment of Reliability and Reliability Needs Assessment as separate processes. The System & Resource Outlook would serve as the “core assessment and analysis element” of the new process.

“It’s a tough balance,” Yachi Lin, director of system planning for NYISO, told the Transmission Planning Advisory Subcommittee. “FERC does give us options on how to comply with Order 1920. We either have a multi-value [process], [with] everything going into one batch, or we decide how to repurpose our current processes, or we develop a new one.”

Lin said adding a fourth process specifically for Order 1920 would be overwhelming.

“That’s why we landed here,” Lin said. “Let’s repurpose, leverage, our existing success and experience in economic and public policy planning processes.”

NYISO would also adapt its current solution solicitation, evaluation and selection process into the new long-term process. This would incorporate the seven categories of benefits that FERC specified in the order.

Order 1920 also requires a 20-year horizon for transmission planning with cost allocation for projects that ensures that only customers who receive benefits pay for the projects. The order mandates that new grid enhancing technologies and previously passed-over projects be considered.

With Order 1920-A, FERC gave state governments more of a say in the new long-term processes, granting “relevant state agencies” the opportunity to propose alternative cost-allocation methods for long-term regional transmission facilities. (See FERC Order 1920-A Wins Approval with Accommodations to States.)

Several stakeholders asked about why NYISO had only included the Department of Public Service and Long Island Power Authority as “relevant state entities.”

“We looked at this issue in connection with a meeting around cost allocation options,” said Liz Grisaru, senior adviser for policy at the DPS. “And it appears to us anyway that a ‘relevant state entity’ is either a state permitting authority or a state entity with the authority to set rates.”

One stakeholder pointed out that New York Power Authority sets rates for its communities “all the time,” and it was not clear why it was excluded from being a relevant state entity for the purposes of Order 1920. Another stakeholder chimed in that which state entities qualified should be better clarified before “we get too far down the road.”

Challenges

The commission required that transmission providers conduct their long-term planning processes every three years. The new process requires NYISO to incorporate more factors, develop more scenarios and include more evaluation metrics than those in the Outlook and Public Policy Transmission Process combined, Lin said.

If the Public Policy and Outlook processes were simply combined without expanding the scope mandated by Order 1920, it would take about four years of NYISO-only work, she said. “We’ve got to think of ways, creative ways, to try to squeeze the time into three years,” she said.

In addition, the New York Public Service Commission will still play a role in the new process. She noted that the involvement of the PSC would add processing time, particularly with the notice and timing rules of the State Administrative Procedure Act.

Lin said that some time could be saved by soliciting data from stakeholders and relevant state entities that might affect long-term transmission needs. In effect, this would replace the biennial Public Policy Transmission Need solicitation.

Chris Casey of the Natural Resources Defense Council said that he was worried about the separation of the reliability processes and the new planning process. He said that in the past, the reliability planning assumptions had typically been conservative.

“I guess what I’m worried about is having a separate reliability process identifying a longer-term reliability need and potentially acting on it through that process without understanding if we should be expanding what the solution might be,” Casey said.

Lin replied that the objectives of the reliability planning process and the new long-term process were different. Reliability planning is about making sure that there’s enough energy and capacity. She said that short-term reliability solutions should be used as inputs into the long-term situation.

“There are opportunities to make sure that we link them up together,” Lin said. “I do not envision that we will be in a vacuum, only addressing long-term reliability needs without understanding [short-term] reliability.”

Lin asked stakeholders and state entities for feedback on the preliminary proposal. NYISO is aiming to submit its compliance filing on regional planning requirements by June 12 and another filing on interregional requirements by Aug. 12.