New York Ratepayers Deserve Better, IPPNY Says
Albany, NY – Today, the Independent Power Producers of New York (IPPNY) filed initial comments on the New York State Energy Research Development Authority’s (NYSERDA) petition for the Public Service Commission’s (PSC) review of proposed awards under Tier 4 of the Clean Energy Standard. NYSERDA’s petition requested the PSC’s approval of two contracts for the purchase of renewable energy credits under Tier 4 by NYSERDA from Clean Path New York LLC (CPNY) and the H.Q. Energy Services’ (HQUS) Champlain Hudson Power Express project to deliver renewable energy and reduce reliance on fossil fuel generation in New York City (Zone J).
IPPNY President and CEO Gavin J. Donohue said, “It is entirely possible that the 2040 zero emissions goal can be met at a lower cost with greater net benefits with the CPNY project, along with other zero emission technology that does not require expensive new transmission lines. New York ratepayer dollars should invest in New York-sited projects, not a transmission line connected to generation resources in another country. Also, New York electricity consumers should not have to bear the staggering costs of two transmission projects. Instead, NYSERDA should hold a solicitation to allow all potential zero emitting technologies to compete to meet the State’s 2040 goal. The HQUS project would be a costly mistake that does not have the public’s interest in mind.”
One major downside to the HQUS proposal is that the project would bypass both existing and new upstate renewable generation. In contrast to the CPNY project, the HQUS project would not allow the delivery of renewable energy from upstate regions to New York City. The purpose of the Tier 4 program is to increase the quantity of renewable energy consumed in the state, not just in New York City. As a result, NYSERDA should seek additional instate resources to meet Tier 4 goals.
IPPNY stands by the rejection of the HQUS project because it will only help meet New York’s summer peak demand for electricity by providing installed capacity in the summer. This is because the Champlain Hudson Power Express project will not meet the supply and demand needs of New York City during winter months due to Quebec taking priority. The CPNY project would help meet peak demand in both the summer and winter by providing the installed capacity to New York City in all season capability periods. As the State looks to electrify its economy, our electric system is projected to become a winter peaking system by 2041 as we transition away from the use of fossil fuels to meet the emission reduction requirements of the Climate Leadership and Community Protection Act. With this trend, it is concerning that the HQUS project was selected despite being only able to provide capacity during nearly half the life of the proposed 25-year contract, raising serious questions regarding the reliability benefits of the project.
Lastly, of the two proposed transmission projects, CPNY is a better option for New Yorkers than HQUS and the PSC should require NYSERDA to solicit additional alternatives to the HQUS contract. Per IPPNY’s comments, should the Commission approve NYSERDA’s proposed project with CPNY, which is the lower cost of the two projects, it should reject the proposed contract with HQUS. According to NYSERDA’s own benefit cost analysis, the CPNY project would produce 34% greater net benefits than those yielded by the HQUS project. Furthermore, the State would see lower net benefits if NYSERDA contracted both CPNY and HQUS compared to contracting CPNY alone.
Reply comments to the petition are to be submitted by Tuesday, February 21, 2022.
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IPPNY is an Albany-based trade association representing companies in the competitive power supply industry in New York State. IPPNY Members generate the majority of New York’s electricity using a wide variety of generating technologies and fuels including hydro, nuclear, wind, natural gas, solar, energy storage, biomass, oil, and waste-to-energy. For more information, please visit our website at www.ippny.org.
