LOWVILLE – The faster, streamlined large-scale renewable energy siting process approved with the state budget earlier this year moved forward on Thursday when an advising document made its way into the public record.
The “white paper,” written corroboratively by the state Department of Public Service staff and the New York State Energy Research and Development Authority, known as NYSERDA, was given to the state Public Service Commission earlier in the month. It makes recommendations that are intended to ensure that the state can reach its goal of meeting 70% of its energy needs with renewable sources by 2030.
The public and other interested parties in the siting of renewable energy now have until Aug. 18 to make comments on the Public Service Department’s electronic record board.
The recommended changes are primarily to aspects of the Clean Energy Standard put in place in 2016, when the goal was 50% renewable energy by 2030.
“The investment and procurement commitments for 70 by 30 are needed now in order (to) drive the availability of the quality and quantity of renewable resources required,” the white paper said, noting that policy and procurement targets will need additional adjustments throughout the next 10 years.
The most fundamental changes proposed in the paper are to the definition of “renewable energy systems.”
In order to align with the the siting process legislation passed last year, known as the Climate Leadership and Community Protection Act, which replaces the Article 10 project siting process for large-scale renewable projects, the recommended definition does not include biomass or biogas.
It also limits fuel cell project eligibility to those that do not use fossil fuels as their energy source.
In both cases, NYSERDA will continue to honor existing contracts until 2029, but no new projects in those categories will be accepted.
The white paper does not recommend following the Climate Leadership Act’s definition of hydropower which included all hydroelectric resources, but rather said the 2016 definition of eligible hydroelectric projects should include upgrades to existing facilities that do not have dams and new low impact run-of-river projects.
In 2030, NYSERDA and the DPS staff anticipate 151,678 gigawatt hours of energy will be needed by the state, including anticipated increases in the use of electric heat pumps in building and an uptick of electric vehicles.
The total number also takes into account a 40,865 GW hour reduction in energy requirements due to energy efficiencies in lighting, HVAC systems and appliances replacing less efficient items by 100% by 2025.
Seventy percent of the 151,678 GW total is 106,174 GW hours of power to come from renewable sources to meet the intended goal.
As of 2018, the paper noted operating renewable projects were generating 39,013 GW hours. Projects under construction or already contracted as well as solar projects through the NY-Sun projections for 2025, bring the total to 63,317 GW hours of renewable power already planned, over half of that 2030 goal.
That number does take into account estimated decreases in energy production by aging facilities without potential upgrades.
Another 17,868 GWh will be produced annually by 2030 in wind projects already slated off the shore of Long Island, dropping the total amount of renewable energy that needs to be created by new projects to 24,990 GWh annually by the deadline.
Some of that power will be provided by solar panels on rooftops or in yards of private homes and businesses and a new category of projects proposed in the white paper targeting New York City directly will also help meet that need.
Many of the recommendations in the paper revolve around NYSERDA’s procurement of clean energy projects that fall into various “tiers.”
Generally, tier 1 projects are new renewable energy projects, tier 2 relates to the maintenance and financial viability of existing renewable projects and tier 3 involves nuclear plants and zero-emissions credits purchased from qualifying facilities.
The white paper recommends three adaptations in the Tier 1 approval process, which has been the Article 10 process until this year.
Projects secured by NYSERDA will need to produce 4,500 GWh annually from 2021 to 2026 – 40% more than the 3,200 GWh annual average for projects over the past three years – to ensure goals are met, but there is a caveat.
“NYSERDA should have the flexibility to respond to market conditions which may mean procuring substantially more or less in any given solicitation” than that estimated statewide quantity. The DPS staff and NYSERDA recommendation is that NYSERDA can revise the average amount required to meet the 2030 goals annually using “the divergence test process” based on latest data.
The paper does not recommend a second round of project solicitation if the goal is not met, as is currently required in the 2016 standard.
“Instead, the following year’s regular solicitation would provide the opportunity to address any shortfall,” the paper said.
Viability, instead of being a consideration for potential projects, will be a core principle.
NYSERDA will be given the power to completely reject projects that are not determined to be viable by the Technical Evaluation Panel although projects can be resubmitted for consideration in future solicitations “without prejudice.”
Projects also must have “comparatively low and predictable rates of attrition, along with timely project development and construction,” to move forward.
If the white paper recommendations are accepted, NYSERDA will be required to monitor and balance projects as a whole and their impacts on each other like the potential for curtailment, or lowered energy production; the inclusion of resources that can be used as needed; the development of energy transmission opportunities; and local reliability levels.
In addition to limits NYSERDA and the Public Service staff are already allowed to place on the yearly energy project portfolio, they would like to develop new risk factors to account for the “interactive effects caused by the increasing penetration of renewable energy resources on the grid.”
Those risk factors would include the geographic concentration of projects with similar generation profiles; portfolio-wide dependence on a particular technology type; anticipated impacts of “curtailment;” and the impacts of network upgrade costs, congestion and transmission development among others.
One of the most notable propositions of the white paper is to create a new category for projects, Tier 4, that will ideally help to reposition energy directly into the market where it is most needed: New York City.
According to information provided in the paper, 88% of the energy in the upstate market is supplied by zero-emission resources, but that market only uses about a third of the total energy consumption in the state.
Downstate consumes the remaining two-thirds of the statewide power load, 69% of which is created by fossil fuel. New York City accounts for 30% of the statewide total based on 2019 data, half of which is made with fossil fuel sources.
Tier 4 would allow existing renewable energy projects to send power that is generated beyond the supplier’s three-year average production for use in the New York City market to mitigate fossil fuel use.
“Nothing would be gained from purchasing the renewable attributes of energy that, absent the Tier 4 program, would have simply been delivered to a different buyer who would instead resort to reliance on fossil fuel-fired generation,” the paper stated.
The existing supplier will also have a greenhouse gas baseline created to ensure they don’t sell renewable energy under Tier 4 only and attempt to “back fill” with power generated by fossil fuel to ensure they meet their overall production baseline for eligibility.
Because the purpose of Tier 4 is to get more renewable energy into the New York City market, suppliers must either locate a utility-scale renewable resource directly in the city’s zone, Zone J, or deliver the energy via a new transmission interconnection.
While offshore wind projects will be crucial for the state to meet the 2030 and 2040 goals, only ocean projects off the coast of Long Island have been approved thus far, but NYSERDA and DPS staff lobby in the white paper for a feasibility study for Great Lakes projects.
“Given the ambitious targets of the CLCPA, NYSERDA and Staff believe that a feasibility study to explore and confirm the potential long term benefits of this resource is warranted,” the paper said.
Many of the suggestions made in the white paper indicate the need for NYSERDA to have “flexibilty” to react to various fluctuations they are likely to encounter from market shifts and technology improvements to changes in the electricity the state needs year over year.
“With respect to load, the implications of the increasing energy efficiency in and electrification of buildings, transportation and certain industrial processes will also be clarified over time,” the paper said, “Moreover, the regulatory landscape is likely evolve over time.”
In addition to a number of annual reports that are recommended to monitor the program’s activity and inform any need to make adjustments, a comprehensive review by the Commission is required every two years beginning in 2024.
If the Commission believes the program hinders safe and adequate electric service, does damage to agreements already in place or causes increases in arrears or service disconnections, it has the power, through the Climate Leadership Act, to “temporarily suspend or modify” the program after conducting a hearing.
Comments can be made and the white paper can be read in its entirety along with other documents filed relating to the new siting process at www.dps.ny.gov. Search for case 15-E-0302. using case.
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