NY-BEST Comments on DPS Staff Straw Proposal for Conducting Headroom Assessments

Strategic Insights -

The New York Battery and Energy Storage Technology Consortium (NY-BEST) has submitted comments to the New York State Public Service Commission on the Department of Public Service Staff's Straw Proposal for Conducting Headroom Assessments. The proposal aims to ensure that the state's transmission planning meets the requirements of the Accelerated Renewable Energy Growth and Community Benefit Act (AREGCB Act) and the Climate Leadership and Community Protection Act (CLCPA). NY-BEST advocates for a more comprehensive approach to headroom assessments, highlighting the importance of probabilistic analysis, energy storage deployment, and maximizing the utilization of renewable energy.

Key Takeaways:

  • NY-BEST recommends that the adopted methodology incorporate probabilistic analysis to account for the uncertainty of future energy generation and load growth.
  • The consortium urges the Commission to value optionality in transmission planning, recognizing that energy storage can provide flexible solutions for future renewable energy deployment.
  • NY-BEST suggests that the headroom methodology should holistically consider energy storage deployment, including the role of energy storage in time-shifting energy and maximizing energy deliverability.
  • The consortium emphasizes the need to maximize the utilization of renewable energy generation now and in the future, as renewable overgeneration poses significant challenges to transmission planning.
  • NY-BEST recommends incorporating hybrid projects and energy storage resources into the analysis to ensure a more robust and cost-effective transmission plan.

Statistics:

  • The transmission planning proceeding in Case 20-E-0197 involves the assessment of headroom in the state's transmission and distribution systems.
  • NY-BEST has submitted comments on the DPS Staff Straw Proposal, advocating for a more comprehensive approach to headroom assessments.
  • The consortium suggests that probabilistic analysis can discount the value of long-term investments that have limited optionality value if the projected future does not materialize.
  • NY-BEST estimates that building in optionality would increase headroom across a wide range of likely future outcomes for generation siting.

Sources:

  • New York State Public Service Commission. (2021). 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. Retrieved from http://documents.dps.ny.gov/public/Common/ViewDoc.aspx?DocRefId={F8CA2C7D-F6A9-480D-8329-AA0312C5F3E4}.
  • New York Battery and Energy Storage Technology Consortium (NY-BEST). (2021). NY-BEST Comments DPS Staff Straw Proposal on Conducting Headroom Assessments. Attachment 3 NY-BEST Comments.