NYSEIA Comments Regarding Motion of the Commission to Implement Transmission Planning Pursuant to the Accelerated Renewable Energy Growth and Community Benefit Act

The Accelerated Renewable Energy Growth and Community Benefit Act (“AREGCBA”) was enacted in 2020 to hasten progress toward climate goals set forth in the Climate Leadership and Community Protection Act (“CLCPA”). Specifically, the AREGCBA directs the Public Service Commission (“Commission”) to develop and implement plans for future investments in the State’s electric grid that are necessary to ensure that it will support the CLCPA’s significant climate and clean energy goals.

In the Commission “Order on Transmission Planning Pursuant to the Accelerated Renewable Energy Growth and Community Benefit Act,” issued May 14, 2020, the Commission directed a Utility Transmission and Distribution Investment Working Group (“Working Group”) to complete a study and identify local transmission and distribution (“LT&D”) upgrades that may be “necessary or appropriate” for the timely achievement of the CLCPA targets after considering, among other items, existing constraints or bottlenecks, synergies with traditional capital expenditure projects, and potential new or emerging solutions. In response to this directive, the Working Group filed its Utility Transmission Investment Working Group Report (“Working Group Report”), which outlines the Working Group’s proposals and recommendations to guide future investments in LT&D projects and potential cost-allocation and cost-recovery methodologies for those projects.

NYSEIA appreciates the opportunity to submit comments pertaining to the results of the Working Group Report, detailed below, as the Commission considers the level of investment and implementation pathways required to enable New York to meet its CLCPA goals. Our specific concerns and recommendations are discussed in more detail in our comments below and are summarized here:

1. The Commission and utilities should act with urgency regarding project selection and implementation for Phase 1 and Phase 2 projects.

2. NYSEIA welcomes a continued and more expansive view of integrated system planning that includes stakeholder input and takes into account factors that span both the bulk and distribution electric systems.

3. The Commission should consider accelerated deployment of advanced technologies, many of which have been tested in New York and other areas of the United States.

4. The Commission should prioritize distribution investments in regions where there is a system need and collaborate with NYSERDA to ensure these investments complement the NY-Sun incentive program to optimize distributed generation (“DG”) development.

5. The Commission should consider the initiation of the Coordinated Electric Standardized Interconnection Review (“CESIR”) cost-sharing mechanism and capital project queue creation to enable the utilization of utility investments and promote continued distributed generation development as Phase 1 and Phase 2 projects are progressed.

6. The Commission should consider the initiation of the CESIR cost-sharing mechanism and capital queue to enable the utilization of utility investments and promote continued distributed generation development as Phase 1 and Phase 2 projects are progressed.