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Our attorneys stay on top of changes in legislation, agency regulations, case law, and industry trends—then craft timely legal alerts to keep clients up to date on legal developments important to their business.

January 21, 2022

New York Regulators Issue a New Power Grid Order

As we previously reported, New York’s Accelerated Renewable Energy Growth and Community Benefit Act required that state authorities, the utilities, and the New York Independent System Operator (NYISO) conduct a “power grid study” to identify distribution and transmission infrastructure investments necessary to meet the clean energy and climate mandates set by the Climate Leadership and Community Protection Act (CLCPA). An initial report on the power grid study was filed with the New York Public Service Commission (PSC) in January 2021. On January 20, 2022, the PSC issued an order on the power grid study recommendations addressing some of the initial report’s recommendations.

While the primary focus of the order is the integration of offshore wind generation with the power grid, it also addressed recommendations on the potential role of energy storage, identification of future needs for onshore bulk transmission investment, identification of renewable energy zones (REZs), and the potential benefits of advanced technologies. 

Mesh Networks 

The order directs the New York State Energy Research Development Authority (NYSERDA) to include eligibility criteria in its future offshore wind procurements that require developers’ proposals to incorporate measures that would allow their projects to be able to connect to a future offshore “mesh network” of transmission lines, or to be “mesh-ready.” The order further directed NYSERDA to incorporate into future contracts the possibility that an offshore wind project may deliver energy to points in more than the NYISO zone as a result of a meshed system. Currently, contracted offshore wind projects rely on a single, radial line connection to shore. According to industry leaders, a mesh offshore network could improve efficiency of the power supply, make more efficient use of the limited onshore interconnection installations, and ultimately lower the CO2 footprint. Also, a single connection means that an outage on one line can result in no deliverable energy from any offshore project. A mesh network addresses this reliability concern by allowing energy to be diverted to another line and delivered to load if on-shore connection experiences an outage. On the other hand, a mesh network would bring certain risks and uncertainties. Mesh offshore networks, including converters and breakers, will make up a large share of the system cost. In addition, there should be clear guidelines for developers who would introduce different manufacturers and equipment to the grid, which would require considerable coordination before construction. As discussed below, currently there are no such standards or guidelines as there are no meshed high voltage direct current (HVDC) grid lines that have been built in the United States waters. In many cases, a meshed offshore grid would mean further regulatory implications for the business models, permitting, and financing. 

High Voltage Direct Current Transmission 

Currently, New York’s offshore wind standard allows project proposals bidding into NYSERDA’s offshore wind procurements to include either alternative current (AC) or direct current (DC) transmission lines. However, AC lines carry less capacity than DC lines and, according to the initial report, require three times as many cables as projects with HVDC lines. As a result, the order directs NYSERDA to include eligibility criteria in its future offshore wind procurements that requires developers’ proposals to incorporate the use of HVDC transmission where appropriate to preserve maximum efficient use of constrained cable corridors. 

The order also directed NYSERDA, in consultation with the Department of Public Service (DPS), to develop uniform design specifications and standards for HVDC radial designs as well as mesh-ready design parameters for all projects and to collaborate with DPS to develop coordinated plans for cable routing for offshore wind. NYSERDA and DPS staff must file a report on the progress of such collaboration no later than September 1, 2022.
 
Con Edison Hub

The initial report had identified the availability of points of interconnection for offshore wind into New York City and the feasibility of different configurations as an area requiring further study and investment. The order partially addresses that concern by directing Con Edison to file a detailed petition providing certain specified information on its proposed plans for a 3,000+ megawatt (MW) “Con Ed hub” in Northwest Brooklyn, which Con Edison preliminarily predicts would cost close to $4 billion. 

Energy Storage

The initial report identified energy storage shortfalls as another issue for offshore wind projects and the downstate area. In response, the order directs NYSERDA to award additional scoring credits in their economic benefits and viability categories of its future offshore wind procurements for proposals that incorporate energy storage facilities interconnected into Zones J or K. It also authorized NYSERDA to define specific areas within Zones J and K where such energy storage should be located.

Transmission Planning and Transmission Technology

The order opted not to adopt the initial report’s recommendation to establish local REZs. Instead, the PSC found that current transmission planning efforts, including NYISO’s public policy transmission planning process and the utilities’ proposed local transmission upgrades, are sufficient to develop cost-effective transmission solutions. Finally, the order directed the recently formed Advanced Technologies Working Group to focus on three priority areas as potential technological developments that could aid the state in reaching its clean energy and climate mandates: dynamic line ratings, power flow control devices, and energy storage for transmission and distribution services. The order also directed the joint utilities, in consultation with this working group, to develop a plan describing the research needs and budget related to the potential deployment of such technologies and file such plan within six months of the date of the order.

Our Regulatory Practice Area will continue to monitor the state’s offshore mesh grid initiatives and other developments affecting the renewable energy industry and the power grid in New York State and will continue to distribute timely legal alerts. 

If you have any questions regarding the content of this alert, please contact Brenda Colella, Regulatory Practice Group leader, at bcolella@barclaydamon.com; Ekin Senlet, Regulatory Practice Area co-chair, at esenlet@barclaydamon.com; or Daniel Krzykowski, law clerk, at DKrzykowski@barclaydamon.com
 

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