We help electric and natural gas utilities address strategic questions, formulate positions on specific issues, and prepare policy comments and implementation filings. Our engagement teams combine regulatory, operations, market, financial, and business model expertise. We are experts at preparing nuanced communications to regulatory agency commissioners and senior staff.
Our offerings include:
Concentric collaborated with Avangrid’s distribution system planning, grid operations, capital investment, and regulatory Subject Matter Experts to develop resilience plans for its New York and Maine service areas. These plans were informed by data analytics and consisted of proposals to reconfigure several circuits, adding sensors and automatic distribution capabilities, coordinated with tree-trimming plans. Concentric prepared a robust report and accompanying testimony for rate case panels in the two jurisdictions. Concentric’s lead consultant was a member of each panel.
A major objective of these plans was to convey the need for enhanced resilience based on historical storm experience, the work performed by Avangrid’s distribution system planners to develop and prioritize proposed projects, and the expected value of focusing on resilience as a distinct goal of regulation. This begins with understanding the difference between “reliability” and “resilience.”
- Reliability refers to the ability of an electric distribution utility to deliver the desired quantity of quality power to all customers when needed.
- Resilience refers to a utility’s ability to withstand storms and restore power quickly after a major outage.
The industry has widely accepted metrics for reliability and is continuing to establish metrics for resilience, presenting a challenge to both utilities and regulators when evaluating incremental investments to enhance resilience.
As part of a statewide heat pump program for a consortium of New York investor-owned electric utilities, Concentric provided collaborative leadership and facilitation services to a group that included New York’s investor-owned utilities, New York State Energy Research and Development Authority (NYSERDA), and New York Department of Public Service Staff.
Heat Pumps represent a vital and growing opportunity for electric utilities and their customers in the clean, dual heating and cooling of spaces and water. Recent technology advances have improved heat pump efficiency and capability—particularly in cold climates—enabling high performance, energy bill reductions, and greenhouse gas emission reductions.
Concentric support included working with the client team to draft and finalizing several program filings, including a detailed Implementation Plan and Program Manual. The filings addressed a range of heat pump program design topics, including:
- Incentive Structure
- Technology Eligibility and Criteria (e.g., ground source heat pump systems, heat pump water heaters, cold climate air source heat pump systems (both centrally ducted and ductless mini-split))
- Contractor Management
- Program Qualification and Application Requirements
- Quality Assurance and Control
As part of New York Public Service Commission Case 18-E-0130, “Matter of Energy Storage Deployment Program,” the Joint Utilities of New York (Joint Utilities) requested consulting support to help develop market design and integration concepts as input to a Joint Market Design and Integration Report.
Concentric’s engagement leader has been an active participant in all Market Design and Integration Working Group (MDIWG) meetings since the commencement of the project in 2019. We have acted as a facilitator for the Joint Utilities team members, and as a facilitator and coordinator for the Distribution sub-team of the MDIWG. Our key responsibilities include:
- The development of relevant market design efforts in different jurisdictions, including an examination of emerging flexibility markets in Great Britain and other countries.
- The development of a catalog of potential Distribution Market products and services, with key attributes to guide client identification of market designs that will create value for customers.
- The development of Entity Category Profiles and an Entity Relationship Matrix that inform market transactions.
- Collaborative design and leadership for client Subject Matter Experts.
The work is expected to continue through June 2021 with the creation of a final report from the Market Design and Integration Working Group.
The New York State Public Service Commission (PSC) was an early adopter of the Value of Distributed Energy Resources (VDER) as a methodology to succeed Net Energy Metering to compensate Distributed Energy Resources (DER). The March 9, 2017 order in Case E-15-0751 established a methodology to compensate DER for five distinct sources of value:
- Demand reduction
- Locational system relief
Concentric provided collaborative leadership, facilitation, regulatory advisory, and comment drafting support for New York’s large investor-owned electric utilities on this major policy initiative. VDER implementation was established in a September 17, 2017 order and continues to be refined by the PSC, with Concentric continuing its role to support New York’s investor-owned utilities.
A northeast investor-owned utility retained Concentric to examine the potential business and operational impacts of increasing amounts of distributed energy resources on their distribution system. At the same time, our client wanted to explore the strategic implications of the Distribution System Operator (DSO) concept. The goal was to develop a Design Model for the DSO that could be shared with executive management to inform long-term strategy.
Our visual presentation-style report addressed several sub-tasks, including:
- DSO Capabilities Assessment including a high-level assessment of readiness for high penetration DER within Distribution Planning, Grid Operations, Customer Programs, and Procurement/Market Services.
- DSO Design Model including attributes such as sources of value for customers, DERs, and shareholders, and the regulators’ role in influencing and allocating value and risk among participants.
- DSO Design Model Implications on the organization, including roles and responsibilities to operate in a high-penetration DER ecosystem.
Concentric partnered with a technology firm to develop a Grid Modernization Plan for Fitchburg Gas & Electric (FG&E), the Massachusetts subsidiary of Unitil Corporation. Massachusetts was the first state in the country to mandate the filing of grid modernization plans. The filing demonstrates how FG&E will make progress in meeting the regulator’s four grid modernization goals:
- Reducing the effects of outages
- Optimizing demand
- Integrating distributed resources
- Improving workforce and asset management
Unitil filed a “practical” approach to pursuing grid modernization that focused on delivering value to customers, recognizing that the transformation of the electric industry was just beginning in 2015.
Our team guided the development of a five-year Short-Term Investment Plan (STIP) that screened fifty-two potential projects by applying Benefit-Cost Analyses, ultimately proposing sixteen capital investment projects, one non-capital project, and a research, development, and deployment (RDD) plan. These projects were categorized as Distributed Energy Resource (DER) Enablement, Grid Reliability, Distribution Automation, Customer Empowerment, or Workforce and Asset Management. The filing also included a Time-Varying Rate project and a discussion of DER compensation.
A northeast investor-owned utility sought expert assistance in preparing written comments regarding rate design and compensation for energy storage projects (ESPs), including compensation for avoided transmission and distribution costs and access to wholesale energy markets.
Working with a multi-disciplinary client team, Concentric developed initial and reply comments that provided an analytical framework for Commission Staff to assess the price that storage projects should pay for access to and use of the grid, sources of value provided by energy storage, and compensation for the value provided from the utility or wholesale markets. The framework distinguished among three ESP configurations:
- Co-located with large scale renewable generation (Co-located Storage)
- Behind-the-meter (BTM Storage)
- Front-of-the-meter grid storage (Grid Storage)
The comments also addressed several issues that impact the long-term value of energy storage for utilities, including utility ownership, integration of storage into the utility Intelligent Distribution System Platform, storage as part of a competitive non-wires solution, and alternative rate designs, including the role of time-of-use rates in creating value for energy storage projects.
A “regulatory roadmap’” is needed to execute a corporate vision when the existing regulatory framework does not provide the utility with appropriate authorities and financial incentives to deliver on customer desires and policy goals.
Concentric’s team of regulatory, operations, customer, and planning experts worked with a client team to refine their long-term vision and develop a staged and executable legislative/regulatory plan to achieve their goals. The work involved a detailed review of existing statutory authorities and precedent, current policy and utility-specific proceedings, and client workshops. The roadmap is designed to be maintained and updated by the client as policy and utility-specific circumstances evolve.
Concentric conceived and delivered a regulatory roadmap that will enable a multi-jurisdictional combination utility to achieve its long-term vision. The roadmap is a live document that identifies adjustments to regulation or enabling statutes that are necessary to accommodate the vision, articulates a regulatory strategy for each jurisdiction, and presents a staged ten-year plan to gain approval for specific initiatives that will evolve precedent in a manner that will deliver value to customers, communities, and shareholders.
In light of recent goals established in New York State related to decarbonization of the natural gas industry, two clients engaged Concentric to provide support on this complex issue.
Concentric is working with New York’s large investor-owned LDCs to draft comments related to integrated planning for natural gas utilities. One of the LDCs has separately engaged Concentric to prepare an assessment of the potential impact of decarbonization on system throughput, revenue requirements, customer bills, utility financial circumstances, and depreciation rates.
Concentric developed a financial model linked to a detailed depreciation model and was able to assess the impact of alternative “Economic Planning Horizon” (EPH) assumptions on customer bills and utility rate base under alternative throughput scenarios. We also evaluated the ability to address fixed cost recovery challenges using deferral, securitization, and trust fund policy tools.