NEW YORK’S LANDMARK PROCEEDING TO BRING THE ENERGY INDUSTRY INTO THE 21ST CENTURY ENTERS A NEW PHASE
New York’s REV proceeding was initiated two years ago, yet many significant policy issues remain to be resolved, even as the State’s investor-owned utilities embark on a multi-year implementation effort. REV aims to expand the role of electric distribution utilities by emphasizing their accountability to (i) provide a platform that enables and accelerates the deployment of distributed energy resources; (ii) consider lower-cost alternatives to traditional utility investments without sacrificing network performance; and (iii) promote new customer products and services. New York’s “clean” objectives are woven throughout the REV fabric and are addressed through a separate Clean Energy Standard that was announced by Governor Cuomo on January 21, 2016.
Numerous policy questions remain unresolved and are being addressed in a growing number of related dockets. These issues include, but are not limited to:
• The design of Earnings Impact Mechanisms (“EIMs”) to incentivize utility performance;
• The design of a Benefit-Cost Analysis (“BCA”) framework to guide utility investments;
• Identification and prioritization of distribution investments that could be deferred or displaced by Non-Wires Alternatives;
• The procurement of clean energy resources through community-based programs;
• Ownership models for the renewable assets on which the Clean Energy Standard relies;
• Standardized approaches to protect the privacy and security of customer and system data; and
• Provision of benefits for low- and moderate-income customers.
Many of these issues have been litigated through a paper hearing process and are awaiting Commission orders. Certain other issues have been addressed in technical conferences, with less formal evidence. A new initiative is addressing the controversial subject of the future of Net Energy Metering and the appropriateness of transitioning to an alternative resource compensation model that recognizes its energy, local distribution system value, and environmental attributes (referred to as “Value of D”). Initial responses to a set of questions issued by Staff were filed by parties on April 18, 2016.
While these policy issues are yet to be resolved, New York’s investor-owned electric utilities are preparing Distributed System Implementation Plans (DSIPs) scheduled to be filed on June 30, 2016. These filings will document existing capabilities, and each company’s plans to (i) implement a new integrated distribution system planning process that considers distributed energy resources (“DERs”) as a distribution system resource, (ii) build new distribution and information technologies, information systems, and processes to manage a more complex grid network, and (iii) facilitate customer engagement through RFP and tariff mechanisms. The initial DSIPs will identify utility investments in infrastructure and systems that will promote market development, and will document opportunities for market participants to develop non-wire alternatives (“NWAs”) to alleviate resource needs on the system.
New York’s investor-owned utilities are working together to engage stakeholders to develop a common State-wide approach to technical issues that will facilitate the evolution of a statewide platform for bringing energy consumers and energy service providers together. The utilities will make a joint filing reporting on the progress of these stakeholder engagement efforts (the “Supplemental DSIP”) on November 1, 2016. The utilities are also implementing demonstration projects to test these technologies and new business models that will change the way that utilities work with third-party vendors and customers.
Concentric’s work for the Joint Utilities, on this broad and growing range of regulatory and implementation requirements, encompasses advisory support on technical regulatory issues, coordination of efforts to achieve alignment with external stakeholders, and overall project management for the joint efforts to approach the REV proceeding. Our goal is to ensure that REV provides significant benefits for customers, while ensuring that utilities are appropriately rewarded for continuing to provide exceptional service to customers throughout New York State.
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