On January 19, 2021, the New York Department of Public Service staff, the New York State Energy Research and Development Authority (NYSERDA), and their consultants, the Brattle Group and Pterra Consulting, released their initial report on the New York Power Grid Study. The initial report includes three main components, all related to New York State’s bulk electric system: (1) a study on local transmission and distribution needs, conducted by the states’ utilities (the “Utility Study”), (2) a study of offshore and onshore bulk-power infrastructure to ascertain pathways to New York’s mandate of 9,000 megawatts (MW) of offshore wind generated electricity (OSW) by 2035 (the “OSW Study”), and (3) a statewide examination of transmission, generation, and storage options to achieve the Climate Leadership and Community Protection Act’s (CLCPA) targets of 70 percent renewable electricity generation by 2030 and a zero emissions grid by 2040 (the “Zero Emissions Study”).
The Utility Study
Previously filed by the Utility Transmission and Distribution Investment Working Group on November 2, 2020, the Utility Study addresses local transmission and distribution upgrades necessary to accelerate renewable energy deployment and achieve CLCPA mandates. This study defines local transmission and distribution as infrastructure that operates at less than 200 kilovolts (kV). In preparation of the Utility Study, the working group utilized the New York Independent System Operator’s (NYISO) 2019 Congestion Assessment and Resource Integration Study (CARIS) 70x30 scenario, approximating 30,000 MW of utility scale renewable generation. The working group then identified potential projects to improve headroom for generation in constrained areas, categorizing them as either “Phase 1,” projects that are immediately actionable, or “Phase 2,” projects not yet in a utility’s capital plans but that would facilitate the onboarding of new generation resources once the projects are planned according to investment criteria and benefit cost analysis. Phase 1 transmission projects were estimated to unbottle roughly 6.6 GW of renewable energy delivery, with proposed distribution projects unbottling an estimated 2 GW. The report notes the Utility Study provided less detailed Phase 2 proposals, but an estimated 12.7 GW and 2.8-4.3 GW of renewable integration benefits for the transmission and distribution systems are expected to be achieved through these proposals, respectively.
The OSW Study
The OSW Study examines the existing state of transmission infrastructure in New York City and Long Island to evaluate each location’s ability to support the addition of power generated by the upcoming offshore wind facility projects. In short, this study notes that integrating 9 GW of offshore wind generation is achievable by 2035 without major bulk transmission upgrades, but such upgrades are nonetheless recommended to better facilitate this goal and future-proof the grid for the CLCPA targets beyond 2030.
The OSW Study focuses on bulk transmission systems located in the New York City and Long Island areas, given that OSW will largely interconnect to facilities located in NYISO Zones J and K. Assuming 6 GW of OSW connects in New York City and the remaining 3 GW landfalls in Long Island, integration is technically feasible but not without challenges. The OSW Study indicates a preference for maximizing interconnection in the New York City area given the large load and strong bulk interconnection system already existing in Zone J. Included in the OSW Study are analyses of potential points of interconnection (POIs), available cable technology and feasibility of routing such lines in New York City and Long Island, existing bulk transmission needs in relation to OSW, and potential methods of harmonizing interconnection as wind generation facilities are developed and added to the downstate energy mix. Key takeaways of each are:
- Based on the POIs suitable for interconnection, New York City can shoulder two-thirds or more of the 9 GW mandate, alleviating constraints that exist in Long Island. However, transmission upgrades should be contemplated in Long Island in case issues arise with routing power to the New York City POIs (see the next point) and in general to accommodate future buildout beyond the mandate.
- In order to deliver 6 GW of wind power to New York City, six cables will need to be sited within the New York Harbor. The study concludes this is technically feasible based on existing rights-of-way but could nonetheless could face significant siting and permitting challenges.
- In terms of system impacts, the OSW Study reports an expectation of low curtailment. Assuming 6 GW interconnects in New York City and 3 GW interconnects in Long Island, curtailment was expected to be less than 4 gigawatt-hours (GWh) in 2035. Even under “modified Zone K [Long Island] parameters” (to account for input from the Long Island Power Authority), curtailments only increased to 24 GWh. The study attributes these results to wind production not greatly exceeding local demand, and that curtailment would mostly be due to localized congestion or over-generation situations. Further, in such cases of over generation, the study was enthusiastic that the excess power could be utilized by energy storage solutions. However, the study notes this is based on several conditions that in essence make the above conclusions optimistic.
- The OSW Study recommends the reconductoring of some existing 69 kV and 138 kV lines as well as the possibility of constructing a new 345 kV line from East Garden City to Dunwoodie, New York. While the study reiterates the 345 kV line may not be absolutely necessary to achieve the 9 GW mandate at this stage, if constraints in New York City limit capacity there, the new line would permit Long Island to accommodate the difference. Further, this line or like upgrades are likely inevitable assuming New York procures additional offshore wind capacity beyond the CLCPA mandate.
- In examining configurations of interconnections for currently planned and future wind projects, the OSW Study supports a meshed approach, linking interconnections from several projects together to optimize landfalls rather than conventional radial connections by each individual project.
Zero Emissions Study
Similar to the results of the OSW Study, the Zero Emissions Study concludes New York’s 2030 goals can be met at low levels of curtailment and congestion, without significant system upgrades not already planned or under development. However, by 2040, the study expects transmission upgrades will be necessary. Based on projected capacity and annual generation, the report expects roughly 12 GW of gas-fired capacity, however the expectation is that such facilities would run on renewable gases, such as green hydrogen, and only for a few hours each year, resulting in a 3 percent capacity factor. In contrast, projections across various sources utilized by the study estimate 53-66 GW of installed renewable capacity by 2040. The adjustment to a greater reliance on renewables will necessitate bolstering transmission infrastructure to and from areas where solar and wind resources are greatest.
The observed difficulty in projecting future transmission infrastructure needs is ascertaining how much each renewable resource accounts for the state’s total renewable generation capacity and where such projects will be sited. Unsurprisingly, offshore wind is expected to lead buildout in downstate zones, whereas onshore wind and utility solar will grow across the rest of the state. The result will be increased congestion in downstate transmission infrastructure by 2040, which if unaccounted for in system upgrades over the next two decades would result in substantial curtailment. This problem will also be exacerbated if the state fails to complement renewable capacity buildout with corresponding energy storage. The study assumed total storage capacity to be 15 GW by 2040, with at least 4 GW located in New York City and 3 GW in Long Island, which the study acknowledges is optimistic given the complexity of procurement and regulatory processes, especially in downstate. Therefore, the Zero Emissions Study recommends an emphasis on evaluating existing energy storage planning frameworks to determine the state’s ability to effectively coordinate deployment and minimize congestion and curtailment. The study also finds curtailments and congestion can be mitigated through transmission projects in four specific grid locations: downstream of Coopers Corner into Zones G, H, and I, at the Millwood South Interface, at the Dunwoodie to Shore Road cables, and in the New York City and West Long Island area.
Our Regulatory Practice Area will continue to monitor the state’s bulk transmission initiatives and will continue to distribute timely legal alerts. If you have any questions regarding the content of this alert, please contact Ekin Senlet, Regulatory Practice Area co-chair, at esenlet@barclaydamon.com; Brenda Colella, Regulatory Practice Group leader, at bcolella@barclaydamon.com; or David Solimeno, associate, at dsolimeno@barclaydamon.com.