New York Unveils the First Iteration of Its Grid of the Future Plan

On March 31, 2024, the New York State Department of Public Service (DPS) filed with the NYS Public Service Commission (Commission) The First Iteration of The Grid of the Future Plan (Plan), which was prepared in cooperation with the New York State Energy Research and Development Authority (NYSERDA).  The Plan represents the first effort by DPS and NYSERDA  examining a broad range of planning data, regulatory actions, and State and Federal policies to craft an actionable plan for incorporating flexible resources into the transmission grid.  The Plan builds upon Volumes I and II of the previously filed Grid Flexibility Study and adds an additional Volume III.  The Plan is the latest installment of ongoing “Grid of the Future Proceeding” (Case 24-E-0165 Proceeding on Motion of the Commission Regarding the Grid of the Future, Order Instituting Proceeding [April 18, ]), and is a significant milestone on the way to achieving New York’s distributed and renewable energy goals. Stakeholders will now have the opportunity to provide feedback on the Plan, which will be incorporated into the next iteration. 

The focus of the analysis and for the Plan was to evaluate and improve the processes for building and operating the Grid of the Future.  The methodology proceeded with five objectives: assessment of the Joint Utilities’ Distributing System Implementation Plans (DSIPs), review of the current regulatory environment: development of an improved DSIP Framework, development of a Prospective DSIP assessment, and providing short and long-term recommendations for future DSIP filings. Ultimately, this effort identified those practices and policies currently in place which act as “tailwinds” or “headwinds” to achieving the states goals for a grid able to efficiently handle flexible resources. 

Based on this iterative review process, the DSIP evaluations revealed that existing data collection and reporting through the DSIPs achieved its original goal of collecting and providing information, but lacked the type of clear objectives or metrics necessary to assesses progress toward a functional DSP.  Problems included inconsistent reporting across the several utilities, incomplete answers where information was unavailable, and difficulty distinguishing between collective action from individual utility actions.  The regulatory assessment found that existing rules and policies generally were not an obstacle to developing a DSP but created both headwinds and tailwinds for different metrics.  Not surprisingly, data access and standardization for interconnection created the most tailwinds, while grid investment costs and market designs created the most headwinds. 

Recommendations for prospective DSIPs  include:

• Implementation of more granular and “bottom up” forecasting capabilities
• Increased granularity and more frequent publication of state-wide hosting capacity data
• More consistent customer engagement across programs
• Better data governance with more certainty around data requirements for future reporting and assessment, and
• Continued participation with stakeholders coupled with comprehensive changes in management practices that guide enterprise-wide initiatives and ensure consistent stakeholder interaction

The Plan asserts that implementation of these measures by the utilities will improve DSIP reporting process and the quality, and usefulness of data being collected.

The Plan also provided recommendations for better aligning Staff DSIP Guidance and polices with the CLCPA goals.   With a focus on improving the current processes rather than sweeping changes, these recommendations included:

• DPS Staff should clarify their recommended guidance for DSIP reporting to elicit more consistent and clear responses
• Staff should eliminate multi-prong questions and redundancies and move toward standardized formats
• The DSIP process should be cultivated as a strategic tool rather than a mere regulatory check-in
• Future DSIPs should focus on the value of processes and activities, as well as outcomes and metrics to track progress toward specified goals
• Reporting should be more streamlined and standardized to make them easier to use and compare, and
• Data and data access standards together with interoperability and technology standards should be used to increase coordination and interconnection

The authors of the Plan readily acknowledge that this iteration was intended to serve as an assessment of the existing process as a step towards building a more reliable and sustainable systems. DPS indicates that the next iteration of the Plan, which will incorporate stakeholder feedback on the first, will be ready for publication in December 2025.   

Hodgson Russ Take:

The Plan is an interim evaluation of existing tools, policies, and practices that reveals both successes and failures in the reporting and planning systems, as well as a comprehensive evaluation of those elements that are working (tailwinds) and those that continue to present challenges (headwinds), making the Plan a useful tool and resource for stakeholders to measure their own experiences against the broader effort to transform the Grid. In this way, the Plan offers a valuable tool for advancing toward the Grid of the Future.  It will be essential, however, for stakeholders to remain actively engaged and constructively contribute to the next iteration of the Plan and ensure that the improved processes will truly improve the critical issues of interconnection costs and delays that continue to represent the most significant “headwinds.” 

For further information, please contact Dan Spitzer, William McLaughlin, or any other member of the Hodgson Russ Renewable Energy Practice.

Disclaimer: This client alert is a form of attorney advertising. Hodgson Russ LLP provides this information as a service to its clients and other readers for educational purposes only. Nothing in this client alert should be construed as, or relied upon, as legal advice or as creating a lawyer-client relationship.