The New York ISO, in Aug. 8 comments filed with the New York State Public Service Commission, said that there continues to be a public policy transmission need in western New York, and that the NYISO should continue to evaluate the proposed viable and sufficient transmission solutions for purposes of selecting the more efficient and cost-effective solution that is eligible for cost allocation and recovery through the NYISO’s tariffs.
As noted in NYISO’s comments, in accordance with the planning process developed in compliance with FERC Order 1000, and the policy statement issued by the PSC, the NYISO initiated the public policy transmission planning process by issuing a letter in August 2014, inviting stakeholders and interested parties to submit proposed transmission needs driven by public policy requirements to the NYISO by Sept. 30, 2014.
In accordance with the open access transmission tariff, the NYISO in October 2014 filed with the PSC secretary eight proposed transmission needs driven by public policy requirements that were provided to the NYISO by, among others, National Grid and the New York Power Authority, the NYISO said.
The PSC in July 2015 issued an order identifying the relief of congestion in western New York, including access to increased output from the Niagara hydroelectric facility and additional imports of renewable energy from Ontario, as a public policy transmission need (Western NY Need) for which the NYISO must solicit and evaluate proposed solutions.
From August through October 2015, the NYISO performed analysis to establish a baseline of constraints on the western New York transmission system against which proposed projects would be measured. The NYISO added that it issued in November 2015 a solicitation for solutions of all types to the Western NY Need.
At the end of December 2015, the NYISO received, from eight developers, 15 proposals, including 12 transmission-only proposals, one hybrid transmission and generation proposal, and two generation-only proposals.
Through 1Q16, the NYISO said that it assessed the viability and sufficiency of all proposed projects, and on June 1, it submitted the Viability and Sufficiency Assessment, which informed the PSC that three of the 15 projects failed to submit a complete response to information requests within the timeframe provided by the OATT, and two projects did not meet the sufficiency criteria.
Accordingly, the NYISO said that it identified 10 viable and sufficient projects to address the Western NY Need and recommended that the PSC determine that certain non-bulk transmission facility upgrades should be made to maximize the benefits of the upgrades to bulk power transmission facilities and fulfill the objectives of the Western NY Need.
Discussing transmission constraints in western New York, the NYISO noted that while a significant and growing portion of the state’s electricity is generated by inexpensive and clean resources, due to constrained transmission paths, much of that electricity is unavailable to the load that it might otherwise serve. When constraints exist and congestion occurs, more expensive generation must run in and near the load pocket in order to serve the load, which results in wholesale electricity market prices being higher than they would be if the constraints did not exist, the NYISO said.
The Niagara area is home to the largest hydroelectric generation plant in the state, and is the primary interconnection between the New York Control Area and Ontario, Canada, the NYISO said. The primary transmission facilities to transfer power eastward out of the Niagara area consist of two 345-kV lines and three 230-kV lines, plus several underlying 115-kV lines.
Most of the power out of the Niagara area flows on the higher voltage, 230-kV and 345-kV lines, and the transfer of large amounts of available power in that area is constrained by the 230-kV transmission lines between the Niagara and Gardenville substations, the NYISO said.
The constraints on the 230-kV transmission lines result in frequent, real-time congestion that limits Ontario imports and Niagara hydropower generation from flowing east, the NYISO said. Those facilities have become more congested in recent years following the mothballing of capacity at the Dunkirk generation plant and the retirement of the Huntley generation plant and several PJM Interconnection units that previously helped relieve congestion on this corridor, the NYISO said.
Among other things, the NYISO said that expanding the bulk power transmission system, as contemplated in the PSC’s “AC Transmission Proceedings” and the governor’s “Energy Highway Blueprint” initiative, would better position the state’s bulk power transmission system to mitigate potential threats to reliability by providing greater operational flexibility and increased access to emergency assistance from neighboring regions, the NYISO said.
New transmission would alleviate congestion and, therefore, enhance the NYISO’s ability to manage the system during extreme weather and storms. The NYISO also said that it expects such improvements to lead to substantial savings for consumers. Transmission additions in western New York would similarly improve reliability, make markets more efficient, and serve various public policy objectives, such as transmitting energy from more renewable resources, lowering air emissions, and making the transmission grid more resilient, the NYISO said.
In its Aug. 8 comments, National Grid, said that a Western New York Public Policy Transmission Need still exists in western New York that can be addressed through transmission investments, and that the NYISO should continue with its evaluation of proposed solutions to address that PPTN.
National Grid said that while it has implemented several transmission reinforcements intended to maintain reliability and improve the operational performance of the system, significant enhancements in system capability to substantially reduce congestion and fully unlock the output of the Niagara Power project have not yet been made. The closure of more fossil-fueled generation and other infrastructure changes further supports the need to reinforce the transmission system, the company said.
National Grid also said that strengthening the western New York transmission grid will facilitate the integration of wind generation and other renewable energy sources in the area, and enhance opportunities to accommodate additional imports of energy from clean generation resources.
Promoting the appropriate development of additional renewable resources, as well as the transition from fossil fuel generation, is vital to achieving the goals of the state’s new clean energy standard, which calls for New York to achieve the goal of 50 percent renewable energy by 2030, and helping to fight climate change, National Grid said.
In its Aug. 8 comments, New York Transco said in part that the need and the benefits continue from the construction of additional transmission resources in western New York, as demonstrated by the NYISO and other commenters.
NextEra Energy’s NextEra Energy Transmission New York, in its Aug. 5 comments filed with the PSC, said that it strongly supports the NYISO’s further evaluation of the proposed solutions for the western New York PPTN, adding that the public policy requirement that drives the need for a potential transmission solution continues to exist.
NextEra also noted that the CES has dramatically heightened the need for new transmission to deliver renewable energy to New York’s electric customers.
In its Aug. 5 comments filed with the PSC, North America Transmission noted that substantial evidence confirms that congestion within western New York has continued and is expected to persist in the future.
The company said that it is clear that a non-transmission alternative cannot resolve the issue. Western New York congestion does not arise from increasing load that can be offset through energy efficiency or demand response, but rather it arises from bottling of low-cost, location-constrained generation, the company said.
Among other things, the company said that as the NYISO embarks on its first comparative analysis of competitive proposals, it would greatly benefit the process for the PSC to provide additional guidance related to the evaluation of cost containment proposals.
NYPA and New York State Electric and Gas, in their comments, recommended that the PSC issue an order finding that the public policy transmission need identified in the PSC’s July 2015 order continues to exist and that the NYISO should proceed to evaluate and rank the viable and sufficient transmission solutions and select the more efficient and cost-effective solutions for cost allocation and cost recovery under the NYISO tariff.