New York is at a crossroads. Our state has met the challenge of the Climate Crisis by passing landmark legislation designed to ensure that we do our part to avert the most catastrophic effects of GHG warming through both the Climate Leadership and Community Protection Act and the Accelerated Renewable Energy Growth and Community Benefit Act..

NYSEIA applauds the PSC for the work it is doing in an array of proceedings including in Case 20-E-0197, and appreciates the opportunity to provide these comments offering our perspective on the applicability of many of the issues being discussed herein to the state’s Electric Distribution Companies’ (EDCs) distribution systems.

While the focus of this proceeding to date has been on the bulk transmission system, NYSEIA submits that the historical separation of that system and utility distribution systems is no longer appropriate, as issues facing one system are increasingly affecting the other. In fact, the challenges of interconnecting renewable generation to the grid are affecting both utility-scale and DER projects. Fundamentally, NYSEIA believes that to meet the challenge of our time—and to ensure that we comply with the CLCPA—we need to examine the state’s electricity system more holistically.

A recent example of this new reality was one brought forth by Avangrid in the February Interconnection Policy Working Group (IPWG) in which it described a growing “Closed Substations” issue. The IPWG is a monthly collaborative meeting in which industry and the utilities discuss challenges around interconnecting DER projects which is co-chaired by DPS and NYSERDA Staff. In the February meeting, Avangrid made reference a listing of 20 substations currently referenced on the Distributed Generation website as “encumbered” by the capability of the transmission system.

Not only in New York but also in other early-mover states with increasing levels of DER penetration, issues such as Avangrid’s Closed Substations are arising, demonstrating that if we are to achieve the decarbonized electric generation future that is necessary, we will need to jettison our historical compartmentalization of the bulk and distribution systems.