NRG Berrians East Development LLC Comments on Utility Transmission and Distribution Investment Working Group Report

The New York State Public Service Commission has received comments from NRG Berrians East Development LLC regarding the Utility Transmission and Distribution Investment Working Group Report and the Petition of Consolidated Edison Company of New York, Inc. for Approval to Recover Costs of Certain Transmission Reliability and Clean Energy Projects. NRG Berrians East Development LLC supports the State's initiative to reduce greenhouse gas emissions and believes its Astoria Replacement Project would resolve the Astoria East/Corona 138kV constraint and relieve a Near-Term Reliability Need on the New York City 345kV bulk power transmission system.

Key Takeaways:

• NRG Berrians East Development LLC provides comments to assist the New York Public Service Commission in assessing certain electric reliability needs in New York City and considering the benefits of a market-based solution.
• The company supports the State's initiative to reduce greenhouse gas emissions and understands the Commission's concern in ensuring reliable grid operations that support the State's climate mandates.
• The Astoria Replacement Project, a 437 MW state-of-the-art peaking project under development, would resolve the Astoria East/Corona 138kV constraint and relieve a Near-Term Reliability Need.
• The project would provide a potential market-based solution to address reliability needs in New York City.
• NRG Berrians East Development LLC is committed to lowering the carbon intensity of electricity production and increasing the deployment of clean generation technologies.
• The company has approximately 23,000 MW of generation resources throughout the U.S. and is one of the nation's largest competitive retail energy suppliers.
• NRG Berrians East Development LLC has more than 2,000 MW of existing natural-gas and oil-fired generation in New York and is developing both new natural gas and energy storage projects within the State.
• The company has hundreds of employees in the State of New York and is committed to creating value through reliable and efficient conventional generation.
• NRG Berrians East Development LLC has announced its commitment to reducing greenhouse gas emissions by 50% by 2025 and achieving net-zero emissions by 2050.

Statistics:

• NRG Energy, Inc. has approximately 23,000 MW of generation resources throughout the U.S.
• NRG Berrians East Development LLC has more than 2,000 MW of existing natural-gas and oil-fired generation in New York.
• The Astoria Replacement Project has approximately 437 MW of capacity.
• NRG Energy, Inc. has over 1,000 employees in the State of New York.
• The company has developed both new natural gas and energy storage projects within the State.
• The New York State Department of Environmental Conservation's NOx Peaker Rule has driven the retirement of local peaking units.

Sources:

• Case 20-E-0197, Proceeding on Motion of the Commission to Implement Transmission Planning Pursuant to the Accelerated Renewable Energy Growth and Community Benefit Act, Utility Transmission and Distribution Investment Working Group Report (November 2, 2020).
• Case 19-E-0065, Proceeding on Motion of the Commission as to the Rates, Charges, Rules, and Regulations of Consolidated Edison Company of New York, Inc. for Electric Service, Petition of Consolidated Edison Company of New York, Inc. for Approval to Recover Costs of Certain Transmission Reliability and Clean Energy Projects (December 30, 2020).
• NRG Accelerates Emissions-Reduction Goals to Align With 1.5@C Trajectory | NRG Energy (source of NRG's emissions reduction goals and commitment to achieve net-zero emissions).
• NYISO 2020 RNA Report Reliability Needs Assessment (November 2020) at pg. 1 (source of Reliability Needs Assessment and Near-Term Reliability Needs).
• Q3 STAR (source of Short-Term Assessment of Reliability and identification of reliability shortfalls).