SEA NY Flash 24-12: Issued: March 25, 2024

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Headlines

• 2024 New York Legislative Tracking Spreadsheet Update

New York

• NYSERDA and DPS release update to 6GW energy storage roadmap; cost estimates increase across residential, retail, and bulk programs
• NYISO discusses data submittal requirements necessary to implement capacity accreditation reforms
• NYISO provides NYC PPTN updates on evaluation criteria and project data submission forms, solicitation to open April 4
• NYISO provides EV and building sector electrification modeling and forecasting updates and methodology
• NYISO provides incremental updates to Order 2023 compliance plan (and associated tariff revisions) ahead of April 3 compliance filing deadline
• PSC issues Order approving modifications to DLM program procurements, requests utility proposal(s) by June 7
• NYISO continues development of 2023-2042 System & Resource Outlook, provides preliminary results for the capacity expansion scenarios
• PSC issues CPCN to 290 MW Canisteo Wind, 90 MW Homer Solar projects
• ORES denies Shepherd’s Run siting permit due to loss of land use rights
• New York DPS forms Electric Vehicle Infrastructure Interconnection Working Group, first meeting April 4
• In medium and heavy-duty EV charging proceeding, DPS posts presentations and recordings from Business and Environmental Justice Workshops
• Gov. Hochul announces $16 million in funding for green hydrogen available through NYSERDA solicitations
• NYPA issues RFP for 6 MW community solar project on SUNY Niagara campus; bids due April 17
• Other News of Note

Regional and National

• Federal Appeals Court vacates portion of FERC Order that amends PJM Tariff mid-auction
• FERC accepts CAISO Subscriber PTO Model, revising Open Access Transmission Tariff and authorizing transmission lines outside CAISO to serve subscribers
• BOEM announces environmental review for Atlantic Shores North offshore wind project; Scoping meetings to be held in April; Comments due May 2
• PJM Market Monitor releases 2023 State of the Market Report for PJM, finds between 24 and 58 GW of thermal capacity at risk of retirement “with no clear source of replacement”
• RGGI CO2 allowances clear at $16.00 in 63rd auction, raises $388.4 million in total
• NREL releases Atlantic Offshore Wind Transmission Study, finds benefits outweigh to costs 2 to 1
• DOE announces $750 million in funding for 52 clean hydrogen projects
• Interior Department Proposes Second Offshore Wind Sale in Gulf of Mexico
• Other Regional and National News of Note

2024 New York Legislative Tracking Spreadsheet Update

SEA's up-to-date online Legislative Tracking Spreadsheet for New York can be found here.

This spreadsheet tracking tool is designed to keep subscribers informed of legislative activity by indicating the most recent dates of legislative action, the next potential legislative action, a short summary, as well as a direct link to the bill docket to learn more.

Please contact Andrew Lidington with any questions regarding New York legislative tracking.

New York

NYSERDA and DPS release update to 6GW energy storage roadmap; cost estimates increase across residential, retail, and bulk programs

In December 2022, the New York State Department of Public Service (DPS) and the New York State Energy Research and Development Authority (NYSERDA) jointly filed, with the New York Public Service Commission (PSC), the New York’s 6 GW Energy Storage Roadmap: Policy Options for Continued Growth in Energy Storage (2022 Roadmap), which called for a new Indexed Storage Credit for bulk storage procurement and expanding existing retail and residential programs. An overview of the 2022 Roadmap’s key provisions is available in NY Flash 23-1.

On March 15, 2024, in Case 18-E-0130, DPS and NYSERDA submitted an updated Roadmap reflecting increased cost estimates for the residential, retail, and bulk storage program. The table below details programmatic cost estimates from the 2022 Roadmap as well as the recent update.

DPS and NYSERDA attributed their increased estimates to a “material increase in costs due to factors such as inflation and wholesale capacity price forecasts.” DPS and NYSERDA expect to issue a request for public comments on the updated Roadmap in “the coming weeks.”

NYISO discusses data submittal requirements necessary to implement capacity accreditation reforms

As last discussed in NY Flash 24-9, on November 27, 2023, NYISO finalized its suite of capacity accreditation related proposals. The proposals are intended to improve NYISO’s modeling of different resource types to more accurately quantify various resources’ contributions to maintaining resource adequacy. On March 4, 2024, NYISO provided final capacity accreditation factor (CAF) values to stakeholders (detailed in NY Flash 24-9).

On March 20, 2024, NYISO provided another presentation to the Installed Capacity (ICAP) working group (see agenda) to highlight incremental tariff revisions to accommodate NYISO’s capacity accreditation reforms and to discuss the data submittal requirements that NYISO plans to impose when collecting operational data from ICAP suppliers. Specifically, NYISO proposed to allow ICAP suppliers to submit their MW-level operational data for the 2025/2026 capability year starting on March 20, 2024, so that final participation elections can be made by August 1, 2024. NYISO is seeking the following information from ICAP suppliers:

• Point identifier (PTID)
• Unit Name
• Market Participant
• Nameplate
• Unit Type
• Fuel Type
• Subject Capability Year
• Date of Submission
• Summary of Submission
• Main Contact (name)
• Main Contact (email)
• Main Contact (phone)
• Total Firm Election (MW)

Moreover, NYISO noted that data submitted for preliminary NYISO review prior to August 1, 2025, must be confirmed after August 1, 2025, to meet the December 1, 2025, data submission requirement for the 2025/2026 Capability Year.

It is not currently clear what the next steps are on this topic; NYISO highlighted that questions on this topic can be directed to ntubbs@nyiso.com.

NYISO provides NYC PPTN updates on evaluation criteria and project data submission forms, solicitation to open April 4

At the joint Electric System Planning Working Group (ESPWG), Transmission Planning Advisory Subcommittee (TPAS), and Load Forecasting Task Force meeting on March 21, 2024 (agenda here), NYISO gave a presentation providing a status update on the New York City (NYC) Public Policy Transmission Need (PPTN) process.

As discussed in NY Flash 23-25, on June 22, 2023, in Case 22-E-0633, the New York Public Service Commission (PSC) announced that it had issued an Order to establish a new PPTN to interconnect at least an additional 4,770 MW of offshore wind into the New York City (NYC) area, i.e., NYISO Zone J. The PPTN and the offshore wind, together, would facilitate reaching the State’s 9 GW of offshore wind by 2035 target, established by the Climate Leadership and Community Protection Act (CLCPA). In the Order, the PSC directed NYISO to initiate a solicitation for projects to address this PPTN. Under the solicitation, projects selected are required to come online by January 1, 2033, and should be complete “end-to-end” solutions including both offshore and onshore components.

In its presentation, NYISO provided a high-level example of a Viability and Sufficiency Assessment for a notional project. NYISO also provided updates to the evaluation and selection criteria that it will consider in its assessment of projects, in particular regarding project impact on operating reserves. NYISO also provided updates on project data submission forms and requests. NYISO noted that the solicitation window will open April 4 and close June 4. NYISO noted that it intends to open the window by posting a solicitation letter to its website and notifying developers via email. Parties that are interested in being added to the distribution list should email Kirk Dixon, kdixon@nyiso.com, or check the NYISO’s website for updates.

NYISO provides EV and building sector electrification modeling and forecasting updates and methodology

On March 21, 2024, the  Electric System Planning Working Group (ESPWG), Transmission Planning Advisory Subcommittee (TPAS), and Load Forecasting Task Force (LFTF) held a joint meeting (agenda here), at which NYISO provided updates for electric vehicle (EV) energy demand forecasting & analysis as well as building electrification demand and electric heating adoption assumptions.

NYISO gave a presentation on building electrification assumptions, discussing heat pump load, comparing air source heat pumps (ASHP) to gas furnaces, and a possible need for additional supplemental heat in cold climates.

NYISO also gave a presentation on EV forecasting, discussing their EV forecast methodology, EV sales and stock forecasts, and energy demand forecasts. See the below table for a summary of preliminary estimates:

NYISO provides incremental updates to Order 2023 compliance plan (and associated tariff revisions) ahead of April 3 compliance filing deadline

As last discussed in NY Flash 24-10, NYISO has been finalizing its FERC Order 2023 compliance approach. As detailed in NY Flash 23-31, Order 2023 requires independent system operators (ISOs) and regional transmission organizations (RTOs) to transition to a first-ready, first-served cluster study process, and implements a number of changes to the large-scale facility interconnection process designed to increase the speed and certainty of the process. We detailed NYISO’s most recent (March 1, 2024) compliance plan in NY Flash 24-10.

On March 15, 2024, NYISO provided an updated presentation to the Interconnection Issues Task Force (see agenda) to summarize NYISO’s compliance plan and associated tariff revisions necessary to accommodate NYISO’s compliance plan. The presentation also highlighted NYISO’s proposed revisions to its compliance plan updated since its March 1 plan. We summarize key changes from NYISO’s previous compliance plan as follows:

• NYISO proposed several revisions to a new section—Attachment HH—of NYISO’s Open Access Transmission Tariff (OATT) to clarify wording and add necessary definitions. The tariff language is presented in the linked presentation.
• NYISO plans to circulate an executable version of the cluster study agreement to the interconnection customer, connecting transmission owner, and any identified affected transmission owner(s)/affected system operator(s) as soon as practicable after validating the interconnection request/capacity resource interconnection service (CRIS)-only request in the application window.
• Regarding COD extensions and demonstrating reasonable progress, NYISO inserted “completion of applicable permitting process” as an additional critical milestone that can demonstrate reasonable progress.
• NYISO proposes to develop and employ Normal Operating Procedures to mitigate reliability impacts triggered by storage, solar and wind projects on 100kV+ transmission facilities. NYISO plans to do this through out-of-merit (OOM) dispatch orders but noted that there will be instances where OOM redispatch does not provide an adequate solution and upgrades will still be necessary.
• NYISO raised a concern regarding FERC’s Order 2023 prescriptive penalty structure, and noted that, FERC denial of rate recovery could cause insolvency because NYISO, as a 501(c)3 organization, has no source of revenue to fund penalty payments other than rate schedule. Thus, NYISO proposes to request an independent entity variation under which it would not adopt Order 2023’s pro forma penalty rules. Instead, NYISO would propose to implement enhanced informational reports on study metrics that will be posted on NYISO’s website at the end of each Phase of the Cluster Study and on an annual basis for Affected System Studies.

• NYISO noted that Order 2023 specified that penalty rules would not go into effect until the third study cluster cycle after a compliance filing is accepted, which for NYISO, would be in 2027 or 2028, so NYISO’s proposed independent entity variation would not have any practical impact for several years.

Looking ahead, NYISO plans to submit its Order 2023 compliance package to FERC by the April 3, 2024, filing deadline.

PSC issues Order approving modifications to DLM program procurements, requests utility proposal(s) by June 7

On March 15, 2024, in Case 18-E-0130, the New York Public Service Commission (PSC) issued an Order directing Central Hudson Gas & Electric Corporation (Central Hudson), New York State Electric & Gas Corporation (NYSEG), Niagara Mohawk Power Corporation d/b/a National Grid (National Grid), Orange and Rockland Utilities, Inc. (O&R), and Rochester Gas and Electric Corporation (RG&E) (the Indicated Utilities) to file a proposal outlining proposed modifications to their Dynamic Load Management (DLM) Programs. As detailed in NY Flash 20-39, DLM is a demand response program in which distributed energy storage resources can participate. The PSC’s December 2018 Energy Storage Order required the IOUs to develop competitive DLM procurements, with contract terms of at least three years (“Term-DLM”), to supplement the existing tariff-based DLM programs. The Order also required the utilities to develop a premium, “Auto-DLM” program with higher performance requirements. As discussed in NY Flash 23-31, on August 1, 2023, the Indicated Utilities filed a Petition to modify procurement requirements under the Term-DLM and Auto-DLM Programs. The Indicated Utilities noted that the programs’ currently employed “sealed-bid, pay-as-bid” procurement structure has resulted in little to no participation and argued that some flexibility in the DLM model would lead to more participation in the programs.

In the Order, the PSC found that modifications to the Term-DLM and Auto-DLM Programs are appropriate, but that the Indicated Utilities’ proposal lacked details regarding what alternative procurement mechanism or mechanisms should be employed and how the Indicated Utilities would determine which alternative procurement mechanism could be more successful. The PSC directed the Indicated Utilities to file a supplemental proposal outlining the proposed alternative procurement mechanisms, either jointly or individually, by June 7 (within 60 days of the Order).

We note the Indicated Utilities differ from the “Joint Utilities” in that the Joint Utilities include the Indicated Utilities and Consolidated Edison Company of New York, Inc. (ConEd). We also note that ConEd filed a separate Petition for modifications to its DLM Program on November 15, 2023, and the PSC has yet to issue on Order regarding ConEd’s Petition.

NYISO continues development of 2023-2042 System & Resource Outlook, provides preliminary results for the capacity expansion scenarios

As first introduced, NYISO considers its System and Resource Outlook (SRO) a key component of its biennial Comprehensive System Planning Process. NYISO’s key objectives of its 2023-2042 SRO include (i)‑completing a 20-year projection of system conditions for demand, generation, and transmission across New York; (ii) identification and assessment of congestion elements; and (iii) development of scenarios and performance of analyses to inform internal and external stakeholders.

In previous Flash Updates, we discussed NYISO’s introduction of the project (NY Flash 23-25); benchmarking tasks, study improvements, and high-level assumptions (NY Flash 23-29); scope, timeline, preliminary assumptions, and alternative scenarios (NY Flash 23-34); Base Case, Contract Case, and Policy Case assumptions (NY Flash 23-38); preliminary Base Case results (NY Flash 23-44); final Base Case results (NY Flash 23-48); preliminary Contract Case results (NY Special Flash 23-50.1); final Contract Case results (NY Flash 24-4); and a Contract Case sensitivity and an overview and certain assumptions of the Capacity Expansion Model (NY Flash 24-8).

On March 21, 2024, at a joint meeting of the Electric System Planning Working Group (ESPWG), Transmission Planning Advisory Subcommittee (TPAS), and Load Forecasting Task Force (LFTF) (agenda), NYISO presented an update on the 2023-2042 SRO. Specifically, NYISO provided preliminary results for the Lower Demand, Higher Demand, and State Scenarios, which are all variations on the Policy Case using the Capacity Expansion Model. NYISO also refers to these as the “capacity expansion scenarios.” Key findings included that:

• Approximately 65-90 GW of new resources would be needed by 2040 to achieve State policy goals
• There is an increased reliance on Dispatchable Emission Free Resources (DEFRs) to support a high penetration of renewables in later years

NYISO also noted several updated assumptions for the State Scenario (also listed in this March 15 Memorandum), including that:

• The Champlain Hudson Power Express (CHPE) is counted as contributing to, rather than being incremental to, the achievement of the 70×30 goal
• The mathematical formula for calculating the achievement of the 70×30 goal is: Renewable Generation / (Load Forecast + Electrolysis Load + Net Storage Load)
• Large load assumptions are aligned with the Baseline forecast from the 2023 Gold Book
• Implementation of a constraint to limit the annual growth of grid solar over time

For next steps, as explained in the presentation, NYISO intends to continue its renewable pockets analysis, which evaluates transmission constraints affecting future renewable generation buildout across several defined geographic areas (i.e., pockets) for the year 2030 (as discussed in NY Flash 24-8). NYISO also intends to continue development of the Policy Case in the Production Cost Model, which includes converting zonal results from the capacity expansion scenarios to nodal generator placement. NYISO details the methodology for doing so in its update.

PSC issues CPCN to 290 MW Canisteo Wind, 90 MW Homer Solar projects

On March 14, 2024, the New York Public Service Commission (PSC) announced that it issued Orders Granting Certificate of Public Convenience and Necessity (CPCN) for two projects, Canisteo Wind (Case 23-E-0297) and the Homer Solar Energy Center (Case 23-E-0412).

Canisteo Wind is a proposed 290 MW project under development by Invenergy. Invenergy intends for the facility to be operational in 2026. Canisteo Wind was selected in the 2018 Renewable Energy Standard RFP (RESRFP18-1) by the New York State Energy Research and Development Authority (NYSERDA) but opted instead to accept a long-term contract with the New York Power Authority (NYPA). The project is also one of 23 projects included in the resource portfolio that the Clean Path NY (CPNY) Tier 4 transmission project will deliver (as discussed in NY Flash 21-47). 

Homer Solar Energy Center is a proposed 90 MW solar project under development by EDF Renewables (EDF) in the Towns of Homer, Cortlandville, and Solon, all in Cortland County. EDF intends for the facility to be operational in 2026. As discussed in NY Flash 21-2, in September 2019, EDF initiated the siting process for the project with the New York Board on Electric Generation Siting and the Environment (the Siting Board) under Article 10 but transferred to the ORES’ 94-c process in January 2021. Homer Solar Energy Center was previously selected in NYSERDA’s RESRFP20-1, but subsequently cancelled its offtake contract and rebid into NYSERDA’s accelerated RESRFP23-1 (results expected in April; as discussed in NY Flash 24-9).

We note that the CPCN process is distinct from the aforementioned siting permit process but is a necessary part of the siting process and pertains to construction approval: developers can elect to pursue a CPCN contemporaneously with the siting permit process, or after a siting permit has been granted.

ORES denies Shepherd’s Run siting permit due to loss of land use rights

On February 6, 2024, in Docket 21-02553, the New York Office of Renewable Energy Siting (ORES) issued a Decision granting a Motion to Dismiss filed by the Town of Copake (the Town) and denying the application for siting permit filed by Hecate Energy Columbia County 1 LLC (Hecate Energy) for its Shephard’s Run project, a 42 MW photovoltaic solar facility. As reasoning for the Decision, ORES noted that the project had lost its land use rights. Shepherd’s Run started Article 10 review process in January 2020 and later filed to transfer to Section 94-c approval process in May 2021 (as discussed in NY Flash 21-40). ORES issued a Notice of Complete Application (NOCA) for the project on August 25, 2023.

On January 2, 2024, the Town filed a motion to dismiss the project application, with evidence showing that the land lease agreement between Hecate Energy and a landowner had expired on September 17, 2023, and that 20% of the project’s land parcels were sold to another landowner. The Town argued that due to the end of the lease agreement, and because project amendments are prohibited after issuance of a NOCA, the current project proposal is no longer feasible and Shepherd’s Run project needs a project redesign. Therefore, the Town argued the project application should be dismissed without prejudice. On January 4, 2024, the assigned Administrative Law Judge (ALJ) denied the Town’s motion to dismiss, and the Town appealed. ORES staff filed comments partially supporting the Town’s claim for motion to dismiss. ORES staff agreed with the Town that the loss of land use rights could have a substantial impact on the proposed project, but agreed with the ALJ that the issues determination procedure is the appropriate venue to resolve the issues the Town raises. Hecate Energy argued that it was in the negotiation process with the former landowner after the lease expired, and it did not acknowledge the sale of the parcels until the Town filed for motion to dismiss on January 2, 2024. Hecate Energy requested ORES to file a Notice of Incomplete Application instead of granting a motion to dismiss.

As a result of the Decision, Hecate Energy will be required to submit a new application for the proposed project once it either secures the relevant land use rights or redesigns the project.

New York DPS forms Electric Vehicle Infrastructure Interconnection Working Group, first meeting April 4

On March 15, 2024, the New York Department of Public Service (DPS) announced the launch of the Electric Vehicle (EV) Infrastructure Interconnection Working Group (EVIIWG).  The EVIIWG was formed to (listed verbatim):

• Identify, discuss, and resolve the technical barriers and challenges associated with the EV interconnection process, including queue management and EV-specific standardized interconnection requirements (SIR) in a collaborative, efficient and effective manner
• Streamline identified difficulties and barriers that effect the interconnection of EVs, building electrification, and any other associated processes that include the interconnection application queue, review, and approval process

The EVIIWG will hold its first meeting on April 4, 2024, 1:30-4 PM EST. Meeting registration information can be found here.

In medium and heavy-duty EV charging proceeding, DPS posts presentations and recordings from Business and Environmental Justice Workshops

As discussed in NY Flash 24-10, in Case 23-E-0070, the Medium and Heavy-Duty (MHD) Electric Vehicle Charging Infrastructure Proceeding, the New York Public Service Commission (PSC) held the following two virtual stakeholder workshops, hosted by the New York Department of Public Service (DPS), the New York City Department of Transportation (NYC DOT), and the New York City Economic Development Corporation (NYC EDC).

• Business Stakeholder Workshop – Presentation & Recording
• Environmental Justice Stakeholder Workshop – Presentation & Recording

At the workshops, DPS Staff provided an overview of the MHD proceeding, and NYC DOT and NYC EDC provided an overview of their Smart Truck Electrification and Freight Decarbonization Feasibility Study and findings. Each workshop had a different focus, as noted above, and the workshops included stakeholder participation.

Gov. Hochul announces $16 million in funding for green hydrogen available through NYSERDA solicitations

On March 15, 2024, Governor Kathy Hochul announced $16 million of available funding to be administered by the New York State Energy Research and Development Authority (NYSERDA) to advance innovation in clean hydrogen. This funding aims to support the following:

• Research, development, and demonstration projects
• Leverage federal hydrogen funding opportunities
• Promote the use of clean hydrogen in industrial processes, clean transportation, energy storage, and grid support

This funding is available through the Hydrogen and Clean Fuel Program, which includes two solicitation opportunities:

• $11 million solicitation for research, development, and demonstration (RD&D) projects. Applications for this solicitation are due July 15, 2024, by 3 pm EST.
• $5 million rolling solicitation that “can provide cost share support for entities successfully applying for federal hydrogen funding for New York-based projects.” Applications for this solicitation are due June 26, 2025, by 3 pm EST.

NYPA issues RFP for 6 MW community solar project on SUNY Niagara campus; bids due April 17

On March 14, 2024, the New York Power Authority (NYPA) announced that it is seeking bids to develop an up to 6 MW community solar project paired with up to 3 MW of battery energy storage on the State University of New York (SUNY) Niagara Community College campus in Sanborn, NY. Bids are due April 17 and should be submitted to kylie.murphy@nypa.gov. Bids will be evaluated based on technical competency, implementation approach, strength of management team, price, risk analysis, and schedule for project delivery and completion.

Other News of Note

• FERC approves interconnection of Empire Wind 1 to NYC grid: On March 13, 2024, Empire Wind issued a press release announcing that the Federal Energy Regulatory Commission (FERC) approved the Large Generator Interconnection Agreement (LGIA) between Equinor’s Empire Wind 1 offshore wind project, New York ISO (NYISO), and Consolidated Edison Company of New York (ConEd). This is the inaugural FERC approval for an offshore wind project to directly connect to the New York City transmission system. As discussed in NY Flash 24-9, the New York State Energy Research and Development Authority (NYSERDA) selected the 810 MW Empire Wind 1 project in NYSERDA’s fourth Offshore Wind Renewable Energy Credit (OREC) Request for Proposals (ORECRFP23-1). 

Back to Headlines

Regional and National

Federal Appeals Court vacates portion of FERC Order that amends PJM Tariff mid-auction

As discussed in NY Flash 23-1, on December 23, 2022, in Docket ER23-729, PJM Interconnection LLC (PJM) submitted an Emergency Request requesting that FERC allow it to, during the Base Residual Auction (BRA) process, exclude resources from a Local Delivery Area (LDA) reliability requirement if units do not bid into the auction as modeled during its reliability planning. PJM explained that in conducting the 2024/2025 BRA, a significant amount of planned generating capacity resources, which were expected to participate in the auction based on the in-service date of the resources’ interconnection agreements, did not ultimately offer into the auction, despite being included in the LDA reliability requirement. As a result, the increased reliability requirement artificially inflated the prices in the Delmarva Power South LDA, which PJM argued was unjust and unreasonable.

As discussed in NY Flash 23-9, on February 21, 2023, FERC issued an Order accepting the Emergency Request with an effective date of December 24, 2022, such that it would be applicable to the 2024/2025 BRA (meaning that the rules would change mid-auction) and future BRAs. FERC reasoned that the rule change would help PJM ensure that load-serving entities are charged for capacity based on an LDA Reliability Requirement that reflects actual reliability needs. FERC asserted that its decision did not violate the “filed rate doctrine,” a legal principle that prohibits retroactive ratemaking.

On March 12, 2024, the U.S. Court of Appeals for the Third Circuit vacated FERC’s February 21 Order as it applies to the 2024/2025 BRA (but not as it applies to future BRAs), finding that the Order did violate the filed rate doctrine.

FERC accepts CAISO Subscriber PTO Model, revising Open Access Transmission Tariff and authorizing transmission lines outside CAISO to serve subscribers

On March 12, 2024, in Docket ER23-2917, FERC issued an Order Accepting Proposed Tariff Revisions which authorize California Independent System Operator Corporation (CAISO) to implement the Subscriber Participating Transmission Owner (PTO) model for its Open Access Transmission Tariff.

In the proposal filed by CAISO on September 22, 2023, CAISO explained that the revision would enable the transmission projects outside the CAISO balancing authority area (BAA) to facilitate delivery to CAISO. As a result, transmission project developers could join CAISO without going through the CAISO transmission planning process. The revisions will establish a new revenue model for transmission project developers. Under the current tariff, participating transmission owners (TOs) receive transmission revenue through CAISO’s Transmission Access Charge (TAC), which charges all ratepayers. The revision will allow PTOs to receive revenue from subscribers separate from TAC process, in which the participating transmission projects only receive fundings from subscribers. Non-subscribers will have to pay for their share for using the subscribers’ PTO facilities.

Some stakeholders objected to the proposed non-subscribers’ rate paying for using the subscribing PTO lines, which they argued that the proposal would be hard to implement and would inevitably increase the bills for ratepayers. CAISO argued that the original costs of constructing subscribing PTO facilities will be excluded from TAC, therefore it largely won’t impact ratepayers.

Commissioner Allison Clements issued a Concurring Statement in support of the Order, noting that the revision will enhance grid’s reliability and lower transmission and distribution costs in CAISO. However, Commissioner Clements also noted that there is not enough evidence and research showing the proposed hybrid cost allocation tariff is just and reasonable for all stakeholders and she encouraged FERC and stakeholders to continue explore and study the proposed fee structure.

BOEM announces environmental review for Atlantic Shores North offshore wind project; Scoping meetings to be held in April; Comments due May 2

On March 15, 2024, the Bureau of Ocean Energy Management (BOEM) announced that it would conduct an environmental review of the Atlantic Shores North offshore wind project, to be sited approximately eight miles off of the New Jersey coast in lease area OCS–A 0549. On March 18, BOEM published a Notice of Intent (NOI) to prepare an Environmental Impact Statement (EIS) for the Project. Atlantic Shores North is proposed by developer Atlantic Shores Offshore Wind, LLC, a 50/50 joint venture between EDF Renewables and Shell New Energies. According Atlantic Shores North’s Construction and Operations Plan (COP), the project will consist of a maximum of 157 wind turbines (potentially up to approximately 2,300 MW, assuming 15 MW turbines).

Atlantic Shores North does not currently have an offtake agreement. Atlantic Shores South (the collective name of the Atlantic Shores Offshore Wind Project 1 and the Atlantic Shores Offshore Wind Project 2) is another project under development by the same developer, in lease area OCS-A 0499. As discussed in NY Flash 21-26, in 2021, Project 1 was selected by the New Jersey Board of Public Utilities to provide 1,510 MW. 

As part of the EIS scoping process, BOEM will accept public comments that focus on identifying reasonable alternatives, potential mitigation measures, and other issues of concern. Comments may be submitted through Docket No. BOEM-2024-0008 on the Regulations.gov website and will be accepted through May 2.

In addition, BOEM has scheduled a series of scoping meetings. The meetings are scheduled for the following dates and times (all times ET):

Virtual meetings:

• Wednesday, April 3 at 1:00 PM (register here); and
• Tuesday, April 16 at 5:00 PM (register here)

In-Person meetings:

• Tuesday, April 9, 5:00 – 9:00 PM, The Berkeley Hotel, 1401 Ocean Avenue, Asbury Park, NJ
• Wednesday, April 10, 5:00 – 9:00 PM, NY Grand Oaks Country Club, 200 Huguenot Avenue, Staten Island, NY
• Thursday, April 11, 5:00 – 9:00 PM, Dyker Beach Golf Course, 86th Street and 7th Avenue, Brooklyn, NY

PJM Market Monitor releases 2023 State of the Market Report for PJM, finds between 24 and 58 GW of thermal capacity at risk of retirement “with no clear source of replacement”

On March 14, 2024, Monitoring Analytics LLC (Monitoring Analytics), the Independent Market Monitor for PJM Interconnection LLC (PJM), released its 2023 State of the Market Report for PJM (Report). According to the Report, Monitoring Analytics estimates between 24 and 58 GW of thermal resources are at risk of retirement through 2030, including 4.3 GW of announced retirements, 19.6 GW of retirements due to state and federal environmental regulations, and 33.6 GW of retirements for economic reasons (i.e., “based on expected forward prices”).

Critically, Monitoring Analytics asserts that there is “no clear source of replacement capacity” because while renewables “can replace a significant amount of the energy output” the “retiring capacity can only be replaced by gas fired or dual fuel generation,” for which new capacity is constrained by the limitations of the existing gas pipeline system and is not adequately represented in the PJM interconnection queue.

Monitoring Analytics thus made several recommendations, including that PJM:

• Undertake a process to “identify the available and potential sources of gas supply … to permit an evaluation of the risks to reliability and the related need for dual fuel capacity”
• Apply the same definition of reliability in the capacity market as is used by PJM transmission planners
• Require units to provide notice at least 18 months in advance of their intended retirement date
• Clarify “the rules governing compensation” for Reliability Must Run (RMR) agreements to ensure that RMR units are not overcompensated
• Develop rules that would permit PJM to advance projects in the interconnection queue if those projects “would resolve immediate reliability issues that result from unit retirements”
• Make capacity interconnection rights (CIRs) from retiring units “available to the next resource in the queue that can use them, on [the retiring unit’s] retirement date”

RGGI CO2 allowances clear at $16.00 in 63rd auction, raises $388.4 million in total

On March 15, 2024, the Regional Greenhouse Gas Initiative (RGGI) announced the results of its 63^rd carbon dioxide (CO­₂) allowances auction. RGGI reported that 24,272,157 allowances, which includes the 8,416,278 Cost Containment Reserve (CCR) allowances, were sold at a record high clearing price of $16.00/ton (a 7.5% increase from the 62^nd auction, which cleared at $14.88/ton, as discussed in NY Flash 23-50). Bids ranged from $2.56 to $25.00 per allowance. CCR allowances were sold by RGGI states when the clearing price reached $15.92. $388.4 million was raised in total for states to reinvest. Though they have not always done so, states have primarily invested auction proceeds in strategic programs including energy efficiency, renewable energy, bill assistance, and greenhouse gas (GHG) emission abatement programs.

Virginia and Pennsylvania Participation

As discussed in NY Flash 24-3, Virginia is no longer a RGGI participating state and thus did not participation in the 63^rd auction, and Pennsylvania’s participation is currently under appeal to the Pennsylvania Supreme Court as it was barred from offering allowances by a lower court (as discussed in NY Flash 23-45). As discussed in NY Flash 24-11, Pennsylvania may withdraw from RGGI regardless of a successful appeal to institute its own GHG cap-and-invest program.

NREL releases Atlantic Offshore Wind Transmission Study, finds benefits outweigh to costs 2 to 1

On March 21, 2024, the U.S. Department of Energy announced the release of the National Renewable energy Laboratory’s Atlantic Offshore Wind Transmission Study. The two-year study investigated the transmission options to enable offshore wind development across the Atlantic states. A map of the three proposed transmission scenarios is shown below.

Key findings from the Study are listed below (listed verbatim):

• Offshore wind energy is projected to be a key part of achieving a low-carbon future for Atlantic states.
• Offshore transmission can be planned while considering ocean co-uses and environmental constraints.
• Benefits of networking offshore transmission come from reduced curtailment, reduced usage of higher-cost generators, and contributions to reliability.
• Offshore transmission networks contribute to grid reliability by enabling resource adequacy and helping manage the unexpected loss of grid components (contingencies).
• Benefits of offshore transmission networking outweigh the costs, often by a ratio of 2 to 1 or more. Offshore networks with interregional interlinks provide the highest value.
• Building offshore transmission in phases can help reduce development risk, but early implementation of high-voltage direct current technology standards is essential for future interoperability.

As part of the study a wide variety of factors were considered including expansions to offshore wind capacity out to 2050; cost-benefits of different transmission technologies; operational, environmental, reliability aspects of different transmission topologies sub-station and cable costs; environment and ocean co-use concerns; among others. The authors emphasized that the feasible transmission corridors identified in the study are to highlight the possibility of interconnected offshore transmission only and further analysis is needed completed for actual site identification.

The study did not present a favored alternative, but instead suggested a phased approach that can efficiently take advantage of infrastructure development capabilities. One example of this phased approach is shown in the graphic below. The study did, however, note that “defining a common interoperability standard before HVDC is deployed in topologies like the interregional scenario will be critical to meeting the development timelines and achieving the benefits quantified in this study.”

Answers to frequently asked questions regarding this study and developing offshore transmission overall are available on the study website. This study also informed the An Action Plan for Offshore Wind Transmission Development in the U.S. Atlantic Region (last discussed in NY Flash 23-38).   

DOE announces $750 million in funding for 52 clean hydrogen projects

On March 13, 2024, the U.S. Department of Energy announced funding for 52 hydrogen projects totaling $750 million. These projects will “help advance electrolysis technologies and improve manufacturing and recycling capabilities for clean hydrogen systems and components, directly supporting more than 1,500 new jobs.” A full breakdown of the projects is available here. We summarize the projects in ISO-NE, NYISO, and the PJM Interconnection regions below:

Interior Department Proposes Second Offshore Wind Sale in Gulf of Mexico

On March 20, 2024, the U.S. Department of the Interior (DOI) announced its recommendation for a second offshore wind sale in the Gulf of Mexico. The offshore wind sale for the gulf of Mexico was held on August 29, 2023 (discussed in NY Flash 23-29). In parallel to the DOI announcement, the Bureau of Offshore Energy Management (BEOM) has published Public Sale Notice in the Federal Register (Docket No. BOEM-2024-0017). BOEM has proposed four lease areas for sale, as shown in the table and map below.

Additional maps and material, such as the forms to become a qualified bidder, are available on BOEM’s Gulf of Mexico website. BOEM is seeking public comment on the prosed sale, with particular interest in stakeholder feedback on the following topics:

• Number, size, orientation, and location of the proposed Lease Areas
• Considerations for the delineation of a Lease Area
• Transit corridors
• Existing uses that may be affected by the development of the proposed Lease Areas
• Benefits to underserved communities
• Bidding Credit for Workforce Training or Supply Chain Development
• Bidding Credit for Fisheries Compensatory Mitigation Fund
• Native American Tribes, ocean users, and stakeholder engagement
• Coordinated engagement
• Prescribed layouts
• Removal of Limits on the Number of Lease Areas per Bidder
• Industry standards for environmental protection
• Production of Hydrogen on the Lease

Comments are due May 20, 2024.

Also of note, BOEM plans to use new auction software and as a result there will be changes to the previous auction rules. Before the final sale, BOEM will host a mock auction for qualified bidders to ask questions and become familiar with the new software. Information on the revised auction procedure can be found here.

Other Regional and National News of Note

• DOE announces $5 million in energy improvement grants for small to medium manufactures and reopens program for coming year, next round of applications due March 31:On March 14, 2024, the U.S. Department of Energy announced that nearly $5 million has been awarded to 37 small- and medium-sized manufacturers to implement energy saving measures. Energy efficiency upgrades and renewable onsite power projects are two of the main categories receiving grant funding and individual projects can be viewed here. The grants are provided through the Industrial Assessment Center Program and applications are accepted on a rolling basis. The next application deadline is March 31, 2024 and applications can be submitted here. Additionally, monthly Q&A webinars are held, the next one is on April 16, 2024, register here.
• WoodMac report finds record number of wind turbine orders in 2023 totaling 155GW procured: A Wood Mackenzie report found that in 2023, global wind turbine orders reached 155 GW, representing an increase of 16 GW from 2022, and totaling an estimated annual investment of $83 billion. China accounted for roughly 100 GW, while Europe ordered 19 GW and North America ordered 17 GW. 
• DOE issues FOA for Water Power Technologies Office (WPTO) hydropower lab call, $13.5 million in funding available through 2027: The U.S. Department of Energy (DOE) Office of Energy Efficiency and Renewable Energy (EERE) recently posted a call for proposals (DE-LC-0000112) for research and development activities related to the Water Power Technology Office (WPTO) Hydropower Program. The topics include HydroWIRES, Hydrologic Systems Science Activity Area, Fleet Modernization, Maintenance, & Cybersecurity Activity Area, and the Federal Hydropower MOUs. The Concept Paper Submission Deadline is April 1, 2024 and the Full Application Submission Deadline is May 23, 2024.
• LBNL releases report on combining community solar and manufactured homes: On March 15, 0242, the Lawrence Berkeley National Lab (LNBL) announced the release of a report that studied methodologies for combining community solar with weatherization programs for manufactured (mobile) homes. The study “envisions community solar subscriptions for occupants of manufactured homes that have been converted to high-efficiency cold weather heat pumps…which can be used to alleviate seasonal variations in both solar and heating bills.” The Report was written for the Michigan Department of Environment, Great Lakes, and Energy (EGLE), but LNBL aserts that the methodology and recommendations could be applied in any other state.
• NREL releases report on risks and opportunities for new investments in hydropower: On March 13, 2024, the National Renewable Energy Laboratory (NREL) announced that it issued a report analyzing the risks and opportunities for investing in small and medium sized hydropower as well as pumped-storage hydropower (PSH). It found that less than 3% of the 90,000 dams in the U.S. currently produce power, and that currently running dams often have opportunities to increase capacity. Stakeholders who participated in the study emphasized that the U.S. Department of Energy (DOE) and other federal agencies have a role to play in incentivizing the hydropower market.
• NREL releases report “studying the economics of building long-distance, high-voltage transmission lines that are anchored to interregional renewable energy zones”: On March 7, 2024, the National Renewable Energy Laboratory (NREL) and the Pacific Northwest National Laboratory (PNNL) announced that they had released a report studying the economics of developing long-distance, high-voltage transmission lines which anchor to interregional renewable energy zones (IREZs) (areas with very high concentrations of the lowest-cost developable renewable energy potential). The Study found that the savings from the low cost of renewable generation offset the cost of building the transmission, and they could provide more reliable resources than depending solely on local or regional resources.
• Masdar agrees to acquire 50% of Terra-Gen Power Holdings II: On March 19, 2024, Masdar, a clean energy developer based in the United Arab Emirates, announced that it has entered into an agreement with Energy Capital Partners to acquire a 50% stake in Terra-Gen Power Holdings II, LLC (Terra-Gen). Terra-Gen is a renewable energy developer which currently operates 2.4 GW of wind and solar and 5.2GWh of energy storage in the U.S.
• Joint Statement from U.S.-E.U. Energy Council announces intent to intensify nuclear energy: On March 15, 2024, the U.S. Department of Energy (DOE) and the European Union issued a joint statement emphasizing existing goals to reduce European dependence on Russian energy exports and transition towards climate neutrality. The parties also stressed the importance of nuclear power in decarbonization. The statement comes in the wake of the eleventh meeting of the U.S.-European Union Energy Council, which took place in Washington, D.C. during the week of March 11, 2024.
• DOE releases next generation roadmap for Geothermal power: On March 18, 2023, the U.S. Department of Energy (DOE) issued a press release announcing the publication of Pathways to Commercial Liftoff: Next-Generation Geothermal Power (the Report), the ninth installment of its “Liftoff Series,” which seeks to inform capital allocators on pathways for emerging energy technologies to reach commercial adoption. The Report emphasized the importance of leveraging skills and technology from the oil and gas industry in scaling geothermal power and projects that 90 GW in geothermal capacity will be built by 2050, a twentyfold increase over current levels.
• DOE releases Billion-Ton Report assessing bioenergy potential in US: During the week of March 11, 2024, the U.S. Department of Energy (DOE) Bioenergy Technology Office (BETO) issued its “2023 Billion-Ton Report” (BT23), the fourth in a series of assessments of potential biomass resources available in the U.S. In BT23, BETO found that the U.S. can produce from 1.1 to 1.5 billion tons of biomass annually in a future mature market, with potential to provide renewable liquid fuels for hard-to-electrify sectors while meeting demand for food and environmental services.
• National Hydropower Association and Marine Renewables Canada sign memorandum of understanding to accelerate development marine renewable energy: On March 13, 2024, the National Hydropower Association (NHA) issued a press release announcing a Memorandum of Understanding (MOU) with Marine Renewables Canada (MRC) to enhance collaboration and knowledge-sharing in the development of marine energy resources.
• DOE issues FOA for $125 million in hydroelectric production incentive payments, applications due April 23: On March 12, 2024, the U.S. Department of Energy (DOE) issued a Funding Opportunity Announcement (FOA) for the Hydroelectric Incentives Program, which provides payments to existing hydroelectric generators. In an accompanying press release, DOE explained that about $37 million was awarded through the program in 2023, but does not mention the total amount available under the current FOA. Interested parties may access FAQs, a program overview, and application guidance documents. Applications are due on April 23, 2024 at 5:00pm ET.
• NREL launches Distributed Wind Energy Resource Hub: The National Renewable Energy Laboratories (NREL) and the U.S. Department of Energy (DOE) Wind Energy Technologies Office recently launched WINDExchange, a resource directory for parties interested in building distributed wind energy projects. Interested parties may access general information on distributed wind, project funding opportunities, technical assistance opportunities, and analysis tools through the WINDExchange webpage.
• The Energy Modelling Hub and Net Zero Atlantic hosting Atlantic Canadian Conference on Energy System Modelling, June 19-20: The Energy Modeling Hub and Net Zero Atlantic will host the Atlantic Canadian Conference on Energy System Modeling in New Brunswick on June 19-20, 2024. The Conference will discuss how energy models can help the energy transition and policy-making process. The Conference is also solicitating oral presentations and posters with modeling results and insights. The deadline for submitting abstract is March 29, 2024 through the online form.   
• AFLOAT offshore wind technical conference being held at UMaine, September 24-25: The University of Maine (UMaine) will host the American Floating Offshore Wind Technical Summit (AFLOAT) in Portland, ME on September 24-25, 2024. Maine Governor Janet Mills, Senator Susan Collins, Senator Angus King, the representatives from the U.S. Department of Energy (DOE), Bureau of Ocean Energy Management (BOEM) and National Renewable Energy Laboratory (NREL) are the featured speakers. The deadline for submitting an abstract for showcasing research and innovations at the conference is May 1, 2024. Abstracts may be submitted by email at taylor.ward@maine.edu. 
• 220 MW solar facility contracted to UPenn reaches Commercial Operation: According to Penn Today, two solar projects in Central Pennsylvania, Great Cove I and II, started commercial operations in December 2023. The two projects, initially developed by Community Energy and later acquired by AES, have 220 MW capacity in total. The University of Pennsylvania signed a PPA with the developer for 100% of the electricity that projects produce.
• Study finds that heat pumps reduce emissions, even if powered by fossil fueled grid: On February 14, 2024, National Renewable Energy Laboratory (NREL) published a new research published and finds that installation of heat pumps can reduce greenhouse gas (GHG) emissions even if using fossil fuel-powered electricity. The research conducted physics simulations on 550,000 households with three air-to-air heat pumps for each household across the U.S. The findings conclude that air-to-air heat pumps could be cost effective without subsidies in 59% of households and reduce GHG emissions by 5%-9% under 2022-2038 electric grid scenarios.
• DOE announces release of WPTO 2022–2023 Report Highlighting Hydropower and Marine Energy Successes: On March 15, 2024, the U.S. Department of Energy (DOE) announced the release of the Water Power Technology Office (WPTO) 2022-2023 Accomplishments Report. The Report details over 40 hydropower and marine energy projects funded through the WPTO. Notable projects include: The Pumped Storage Hydropower and Market Tool, Marine Wildlife Detection and Tracking System, Deployment of Triton Wave Energy Converter, two Hydrokinetic power systems deployed in Maine, and the INL Cyber SHIELD for Renewables.
• Clean Energy States Alliance webinar: Building Equitable Practices & Programs: A Conversation with Energy Equity Leaders on April 5: The Clean Energy States Alliance has scheduled a webinar titled “Building Equitable Practices & Programs: A Conversation with Energy Equity Leaders,” on April 5, 2024. The webinar agenda includes discussion of best practices to engage with communities when implementing clean energy programs, including topics on selecting partners, developing trust and transparency, and adequately compensating communities. Interested persons can register for the event here.  

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The SEA Team


Sustainable Energy Advantage, LLC
John Keene - Senior Director
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