NYS Reforming the Energy Vision Link to submitted comments: http://documents.dps.ny.gov/public/MatterManagement/CaseMaster.aspx?MatterCaseNo=14-00581
Link to the REV Staff Straw Proposal: http://energystorage.org/system/files/resources/nyrev_dpsstaffproposal_8_22_14.pdf
Submit comments on the PSC website (filing deadline is 2/17) for Case 14-M-0101: http://documents.dps.ny.gov/public/Comments/PublicComments.aspx?MatterCaseNo=14-m-0101
REV TALKING POINTS forwarded by Hal Bauer1. Achieve 50% Renewable Energy for New York by 2025.NY needs to transition to more clean, renewable energy to address climate change, reduce pollution, reduce public safety risks from fossil fuel infrastructure, and to protect New Yorkers from the volatile price swings of oil and gas. To make sure the REV effort is moving in the right direction, it should be conducted in the context of a Commission Order committing NYS to 50% renewable electricity by 2025. After this commitment is made, all the REV initiatives should be moving towards this goal. NY’s current renewable energy portfolio standard (RPS) expires this year, and it must be replaced by a new policy that will require utilities to buy renewable energy and get NY to 50% renewable energy by 2025.2. Build a More Energy Efficient New York for all.New York has a strong record on energy efficiency, and REV rightly recognizes that this has to continue and grow. New York needs to affirm new energy efficiency goals of 2% reduction per year. REV efforts to foster energy efficiency should continue on a parallel track with continuation of the existing EE programs (either at NYSERDA or implemented by utilities), so that there is a smooth transition to a more market–based REV end vision. Backstop mechanisms should be put in place to ensure that clean energy deployment is not permitted to falter if the new marketplace does not develop. In the short term, distributed utilities should be required to pursue all cost-effective energy efficiency opportunities, and the rate system should provide both a carrot and a stick to utilities to meet and exceed energy efficiency goals. Other REV initiatives should ensure that utilities are not the only route through which New Yorkers can pursue energy efficiency projects for their home and business; there should be a thriving separate market for EE. Utilities shouldn’t have too much power over the market to push out other EE businesses and contractors. Finally, low and medium income New Yorkers should have access to EE programs, either through targeted or subsidized programs.3. Conduct REV so that New Yorkers Can Speak Out.We appreciate these hearings and the first opportunity for regular New Yorkers to weigh in on REV. Allowing for public participation should be a central principle of the REV process. There should be more Hearings around the state before major decisions are made. There should be more public outreach to advertise public comment periods. And all major, important decisions should be decided in this generic REV proceeding rather than in individual rate cases for the utilities. Participation in rate cases is enormously time consuming and complex, and severely limits participation by regular New Yorkers.4. New York needs a Next Generation RPS.New York’s current renewable energy portfolio standard (RPS) expires in 2015, and we have yet to make it to our goal of 30% renewable energy. To attract land based and offshore wind, micro-hydro, and fuel cell projects to New York – and to reassert its leadership role – New York needs the next generation RPS that will get New York to 50% renewable energy. Analysis has shown that there is still significant renewable energy development potential in New York and we need to realize its value and continue to progress NY towards a clean energy future. The Commission should commit to 50% renewable energy for NY and start a proceeding to define the utilities’ role in purchasing renewables through power purchase agreements and other flexible renewable energy contracts such as contracts for differences and feed in tariffs.5. REV should introduce a price for carbon.We strongly support that the reduction of carbon emissions is a policy goal within REV, as New York needs to contribute to a solution that will help avoid the dire impacts of climate change as projected in the 2014 Intergovernmental Panel on Climate Change and the National Climate Assessment. Climate must remain central to REV. REV promises to use a new cost-benefit analysis (CBA) that incorporates all of the values for clean, distributed energy. This CBA should value carbon emission reductions – that is, if a distributed resource like solar or energy efficiency is going to reduce carbon emissions, the project should get “paid” for those emissions reductions. Meanwhile, New York also needs a comprehensive plan to address climate change and carbon emissions reductions from the electricity sector – and other sectors -- to demonstrate how New York will achieve the 80% carbon reduction goals by 2050 outlined in the Draft State Energy Plan.6. Don’t prop up old, polluting power plants.REV can be a revolution in energy system oversight, by changing the game for utilities and giving them every incentive to promote EE, clean DG, and demand response, and invest in grid-tied clean energy that will allow them to meet new carbon goals. In the midst of this potential process, New York shouldn’t be extending the life of old, polluting power plants. Any efforts to keep these plants operating should be very short term, or there will never be opportunities for the entrance of new clean technologies into the portfolio. etc. Doing so allows the pollution to continue and prevents new, clean generation from getting built.7. The Goals of REV are Good; the Transition Must be Smooth.Clean energy organizations strongly support the REV vision, including a growth in clean, distributed energy resources like energy efficiency, demand response, on-site wind and solar, and battery storage; as well as more customer choice; lower electricity bills; and pollution reductions. With careful planning and thoughtful execution, REV could really break new ground and bring New Yorkers less carbon emissions and cleaner energy. The transition to this end vision should be careful; programs that are working shouldn’t end until we can see that new REV programs have begun to work.8. Allow New Yorkers to Pursue ‘Shared Renewables’ projects.Allow groups of New Yorkers to jointly own a renewables project and take advantage of net metering. This should be part of an overall effort to ensure that the maximum number of New Yorkers can gain access to clean energy, even if they are of moderate income, don’t own their roof, or live in the shade. Groups of individuals, farmers, churches, schools, or small businesses could together invest in fuel cells, solar energy, small wind power, micro-hydro, or anaerobic digester gas projects and share in the power generated and together take advantage of net metering. Shared renewables projects could be further incentivized in areas of the grid that would otherwise require expensive grid investments.9. Keep Net Metering - It’s Working!Net metering is a policy that has allowed New Yorkers that invest in on-site clean energy technologies, like solar, to sell excess energy back to the grid. While it is not a perfect tool (It does not, for example, have increased incentives for solar energy in a location that needs it the most), it is working. The REV framework of valuing and incentivizing clean distributed generation (DG) should not replace net metering immediately, but be offered as an alternative that customers will choose if it is a better deal than net metering. This will allow this successor tariff structure to be tested and tweaked, and then fully launched when there is certainty that it is a better tool than net metering to meet all of New York’s policy goals.10. Give Utilities the right incentives.The new REV regulatory structure must give utilities the incentive to reduce the demand for electricity and aggressively encourage wind, solar, geothermal, microgrids, and storage. How utilities are rewarded needs to change to promote clean energy, both distributed and grid-tied, and efficiency. The distribution utility should be compensated in accordance with its performance toward metrics like the percentage of clean energy distributed, the amount of kWh demand avoided through efficiency measures, or the amount of carbon emissions reductions. This is an important foundational aspect of REV: to change the traditional way utilities are regulated to a system that rewards performance based on metrics related to clean energy, affordability, carbon reductions, and customer participation.REV TALKING POINTS from Bob CiesielskiThe Public Service Commission (PSC) will be accepting testimony concerning the important Reforming the Energy Vision (REV) plan in 5 cities from January 28 through February 2, 2015. We are encouraging our members to attend the sessions and make oral comments.Here are some detailed points which may help you in your written comments or testimony at hearings.The REV proposes a market-based approach to the energy questions facing New York for the foreseeable future. The REV itself leaves a number of questions unanswered, including what measures will be utilized to develop renewable energy and to promote energy efficiency. The REV has statedly sidelined the discussion of future large-scale renewable energy development. While the REV discusses promoting “clean energy” to advance greenhouse gas (GHG) reductions, it is unclear as to whether the plan seeks to reduce only carbon emissions or all greenhouse gases including methane gas obtained from high volume hydrofracking. The ambiguous definition of greenhouse gases leads to further questions about energy sources for “clean energy” which the REV indicates may include methane gas. Of concern is the New York Green Bank’s program which has been already funding co-generation plants utilizing gas generators. REV also proposes a policy of “fuel neutrality” to be used in an effort to reduce carbon emissions, which also implies support for methane gas projects in the State.Some of the points you can make to the PSC include:1. New York must turn away from dirty and dangerous energy and double down on our investments in renewable energy and energy efficiency now. REV must include a commitment to extending the state’s renewable energy target to ensure that 50% of New York’s electric energy comes from renewable energy sources by 2025 and set targets and benchmarks to reduce electric use statewide 20% by 2025. Utility companies should also be held to enforceable renewable energy and energy efficiency targets and failure to meet targets should include penalty payments to invest directly in renewable energy.
Incentives can be provided where necessary by the Public Service Commission (PSC), NYSERDA and/or the newly established Green Bank.If the PSC is to adopt a market-based approach to energy, it must contain an effective program to ensure the development of renewable energy. Besides penalties and incentives, the following mechanism can be used to develop renewable energy.· Power Purchase Agreements using flexible long-term contracts to purchase renewable energy.· The establishment of a feed-in-tariff (FIT), would allow for the involvement for all stakeholders, from homeowners to multi-unit buildings to industrial users and utilities themselves to develop renewable energy generation. Feed-in-tariff was successfully used in a 150 MW solar pilot project by the Long Island Power Authority (LIPA). Feed-in-tariff involves long-term (20 year) contracts between renewable energy producers and utilities, which provide a reasonable rate of return for investors, based upon a set price which may be adjusted for future contracts. Feed-in-tariff in Germany has led to 28% of the nations’ energy being produced from solar and wind sources, with almost $50 billion annually in energy investments, some 370,000 jobs (the equivalent of 1.5 million in the US) and stable energy prices which permit business to flourish.· Maintaining the current Renewable Portfolio Standard (RPS) model, side by side with market development, with enforceable renewable energy based and energy efficiency goals.2. Curtailing climate change is of crucial importance in the development of an energy plan for New York State. 35% of the greenhouse gases (GHG) emitted in New York come from the electricity sector. A “fuel neutrality” approach to New York State’s energy future does not address the challenge of climate change.3. The State’s goals of achieving a reduction of greenhouse gases must not be limited solely to the reduction of carbon emissions, but of all greenhouse gas emissions, including methane, black soot, and other greenhouse gases.4. Methane itself is a much more potent greenhouse gas than carbon dioxide. Funding the use of energy production through methane is contrary to the emission reduction goals of NYS. Methane is 86 times more potent a greenhouse gas than CO2 in the first twenty years of its release to the atmosphere. Any release of methane above 2% from its use makes methane a greater contributor to global climate change than does the use of other fossil fuels. Field studies by the National Oceanographic and Atmospheric Association (NOAA) demonstrate leakage of methane in the Western States to be between 2.3% and 17% gas produced. In December 2014, the existence of a 2,500 square mile plume of methane gas in the Western United States was announced near high volume hydrofracking installations.5. The definition of “clean energy” sources should not include methane gas or nuclear energy. The banning of high volume horizontal drilling for methane gas in NYS, with its accompanying adverse health and environmental effects, is a further reason not to include methane as a “clean energy” source.6. A cost-benefit analysis of all fuels, including nuclear, fossil fuels and renewables, should be conducted to monetize the health, environmental and social costs of each.7. Sources of “clean energy” must be limited to energy produced only from renewable sources such as solar power, wind power, low temperature geo-thermal for cooling and heating, and run of the mill hydro.8. Low-temperature geothermal, while not a producer of electricity, can act as a valuable replacement for electric driven heating and cooling systems. Geothermal does not emit greenhouse gases and is a proven technology.9. The REV does not address the future development of renewable energy and energy efficiency programs in New York. Any State energy plan must address future of renewable energy development, which has until now been developed through the Renewable Portfolio Standard (RPS) and the administration of NYSERDA.Pending the development of an effective renewable energy, energy efficiency program, the current funding of the RPS should be maintained. This would include funding through the systems benefit charge currently on utility bills and other sources of revenue.10. A market-based approval to the development of renewable energy will mean that many policy decisions will be made at meetings and utility rate hearings. It is important that these meeting and hearings be made transparent so as to enable the public to meaningfully participate in the hearings. Public interest organizations and public advocates should be funded to intervene to protect consumers and the environment. Local municipalities and community organizations must have a strong role in implementing efficiency and renewable programs.11. A State policy to promote wind power, similar to NYSun initiative for solar, is important. Offshore Atlantic wind power should be made a priority.12. The funding of microgrids, which utilize methane gas, is inappropriate and contributes to a gas infrastructure build-out and greater utilization of methane obtained from high volume fracking. Microgrids utilizing renewables proper energy storage facilities, renewable energy and smart metering should be considered for funding and development.13. The REV process should prioritize genuine public participation and transparency. As New York established a new framework for our energy future this is the opportunity to ensure ratepayers have an active role in determining their energy future.14. REV should include community owned and shared renewable development so that we can ensure good, local jobs, investments that keep energy dollars in our own communities, and gain collective control over our energy choices.REV should guarantee affordable access to a basic level of energy necessary to provide for a comfortable and healthy living space.Access to energy efficiency retrofits and energy saving technologies as well as pathways to clean energy ownership, credit scores, wealth, income, tax credits, or anything that disproportionately excludes low-income people.15. Renewable energy is cheaper than fossil fuels or nuclear energy in many parts of the world including, Germany, Australia and areas in the US which have ramped up renewable energy development, such as west Texas. Renewable energy should be developed quickly for the sake of low-income citizens. Renewable energy development also stops the boom and bust cycles of the fossil fuel industry. Spikes in prices are crippling to all homeowners utility bills and also to businesses.