From: Sustainable Energy Advantage, LLC
<sea-deliverables@seadvantage.com>
Sent: Wednesday, January 27, 2021 11:28 AM
To: Bob Grace
Subject: New York Eyes & Ears Special Flash Update 21-3.1,
January 27, 2021
New York Eyes & Ears Special Flash Update 21-3.1, January 27, 2021
Time sensitive articles are identified with the following icon:
As discussed in Flash Update
21-2.2, on January 22, 2021, the New York State Energy Research and Development
Authority (NYSERDA) issued its first Competitive Tier 2 Solicitation for existing
wind and non-State-owned run-of-river hydroelectric renewable energy resources.
The request for proposals (RFP) document is available here. As discussed in Flash Update 20-42, on
October 15, 2020, the Public Service Commission issued an Order Adopting Modifications to the Clean Energy Standard
in Case 15-E-0302, authorizing NYSERDA to hold a
competitive procurement for existing renewable resources. Bids are due
February 24 at 3:00 pm and must include the project’s technology type and
commercial operation date.
NYSERDA will procure “a majority” of existing eligible supply
(in-state, uncontracted wind and run-of-river hydro built before 2015) over
three annual solicitations. NYSERDA has a target quantity of resources that it
is seeking to procure, but this quantity will remain confidential. Projects
currently under Maintenance Tier contracts with NYSERDA are eligible to
participate in the Tier 2 competitive solicitations but may only receive RECs
for generation incremental to that which is already under contract. Projects
may not replace Maintenance Tier contracts with Tier 2 contracts. All bids must
be for Fixed RECs. There is no minimum bid quantity and no penalty for
producing fewer RECs than a project bid, but the bid quantity cannot exceed the
highest annual generation that a project has had in the most recent three years
of operation. The REC quantity will be fixed for the entirety of the three-year
REC contract.
NYSERDA will evaluate bids based on price only. Any bids that
exceed NYSERDA’s maximum bid price will be disqualified. NYSERDA’s maximum bid
price will also remain confidential.
On January 26, NYSERDA held a webinar to provide additional
information to potential bidders and answer stakeholder questions. NYSERDA will
post slides from the webinar here but will not post a recording of the
webinar. During the webinar, NYSERDA clarified that it will have first position
to purchase RECs produced by a bid facility up to the bid quantity. In other
words, in a given contract year, a generator must sell all RECs produced by the
bid facility up to the bid quantity to NYSERDA first; such RECs will be marked
as non-transferrable in NYGATS. Only when the bid quantity is reached can the
generator then sell additional RECs (produced beyond the bid quantity) to other
entities, such as voluntary market participants or to RPS markets in adjacent
regions. We note that this requirement could potentially (i) reduce the level
of participation in the Tier 2 competitive solicitations, as it may preclude
some generators who may have already sold forward (irreversibly committed) a
portion (e.g., as a percentage of their monthly production) of their existing
resources to other entities; and (ii) limit generators’ flexibility to conduct
transactions with incremental RECs (beyond the bid quantity) in the future.
NYSERDA also confirmed that it will not accept any modifications to its Competitive Tier 2 REC Agreement and that the
contract term will begin on January 1, 2022. (There was a typo in the Agreement
that had erroneously indicated that the contract term would be on January 1,
2021.)
NYSERDA expects to determine winning bidders in March or April but
did not state when it expects to announce the winning bidders to the public.
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As discussed in Flash Update 20-45,
on October 29, 2020, the Interconnection Policy Working Group (IPWG, consisting
of the investor-owned electric utilities, Department of Public Service Staff,
New York State Energy Research and Development Authority (NYSERDA) staff, and
distributed energy developers) submitted a Petition to the Public Service Commission
(PSC) in Case 20-E-0543 seeking to amend
interconnection cost sharing rules in the Standardized Interconnection
Requirements (SIR) process. The SIR process is the interconnection procedure
for generation and storage projects 5 MWAC or less interconnecting
to the investor-owned electric utilities' distribution systems.
Under the current SIR process, pursuant to the PSC's December 13,
2019, Order (discussed in Flash Update 19-51),
projects that require substation upgrades to interconnect must pay for the full
upgrade costs but may be reimbursed by subsequent projects interconnected to
the same substation that benefit from those system upgrades. In the Petition,
the IPWG noted that no developers have moved forward with projects having
significant upgrades costs that would be eligible for this "
first-mover" cost treatment, arguing that the risk that there will not be
subsequent interconnecting projects with which to share those costs is too
great to justify moving forward, despite the potential for reimbursement. The
IPWG argued that a revised interconnection cost sharing methodology would
reduce risk for distributed energy developers, increasing the amount of distributed
energy that could be cost-effectively developed in the state. The IPWG proposed
that upgrades be eligible for the cost sharing program if they benefit multiple
projects, are not located on a secondary network system, and have a gross cost
of at least $250,000.
As discussed in Flash Update 21-3, on January 19, 2021, the Joint
Utilities filed a supplement to the IPWG Petition, in which they
included provisions to make secondary network system upgrades eligible for cost
sharing. The Joint Utilities stated that they filed the supplement because they
did not have time to include secondary network system cost sharing provisions
by the date that their initial filing was due. On January 21, the PSC issued a Notice requesting comments on the Joint
Utilities’ Supplement by February 2.
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On January 20, 2021, the New York Public Service Commission (PSC)
issued a Notice of public statement hearing and procedural
conference in Case 20-E-0551 to solicit stakeholder comments
on New York Transco LLC’s (Transco’s) New York Energy Solutions (NYES) Project.
The NYES Project is a proposed transmission upgrade and reconditioning project
with a total effective line-length of 56.7 miles, located in Rensselaer,
Columbia, and Dutchess Counties. The virtual public statement hearing is
scheduled for 4:00pm on January 28 and can be accessed via webex with event number “179 062 4796” and
password “Jan28-4pm”.
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On January 25, 2021, the New York State Energy Research and
Development Authority (NSYERDA) announced that it will begin to hold quarterly
webinars for the [https://www.nyserda.ny.gov/All-Programs/Programs/NY-Sun/Communities-and-Local-Governments/Predevelopment-and-Technical-Assistance
Affordable Solar Predevelopment and Technical Assistance] program. As discussed
in Flash Update 19-50, the program is designed to provide funding for
initiatives that reduce barriers to entry for solar installations that serve
low-to-moderate income households.
NSYERDA will host the first webinar on January 28 at 1:00 pm.
Webinar registration is available here.
Best regards,
The SEA Team

Sustainable Energy Advantage, LLC
Kate Daniel – Consultant
Tel. 508-665-5863 | kdaniel@seadvantage.com
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