Reply Comments to New York Resource Adequacy Proceeding

The New York State Public Service Commission (PSC) issued an order commencing a proceeding to examine how to reconcile resource adequacy programs and the State’s renewable energy and environmental emission reduction goals. This post summarizes the reply comments I submitted in this proceeding on resource adequacy primarily as an accessible reference.  If this topic interests you then I suggest you read  my initial comments  and my reply comments .  I previously summarized my initial comments here.

Materials and information are available in the Department of Public Services (DPS) resource adequacy matters docket Case 19-E-0530.   According to the Order Instituting Proceeding and Soliciting Comments, the inquiry is “necessitated by the Commission’s statutory obligations to ensure the provision of safe and adequate service at just and reasonable rates. Costs to consumers are a primary and ultimate consideration, recognizing that the necessary investments in resources must have sound economics.”


A primary point of emphasis in my comments is that I believe that the Commission’s statutory obligations to ensure the provision of safe and adequate service at just and reasonable rates is not being addressed with respect to the Climate Leadership and Community Protection Act (CLCPA). The fact of the matter is that absent a comprehensive evaluation that assesses historical renewable energy resource availability coupled with historical and projected load, no one knows if a 100% fossil-free electric sector is possible in New York.  The legislation that mandated that target naively assumed it was feasible and affordable but those assumptions may violate the laws of physics. It would be far better to determine the consequences of the CLCPA now than to try to muddle through trying to implement something that would have far worse consequences to the citizens of New York than the purported problem.

My reply comments cover several aspects of the comments submitted by others and information that has become available since the initial comment period ended.  I address the lack of representation for the residential consumer in the parties commenting on the proceeding.  My reply comments do not address specifics of any of the initial comments but I do offer cautionary observations on the comments describing the purported success of the de-regulated market and support for the NYISO carbon pricing initiative.

Since the time the initial comments were submitted other feasibility issues came up.  The NYISO had the Analysis Group evaluate winter peak resources for the short-term.  In response to a NYISO press release on a record for wind generation I took another look at the historical wind data.  The Citizen’s Budget Commission did an analysis of the CLCPA that included an estimate of the future load.  I show that all these studies are relevant and underscore the need for the feasibility study.

Finally, I made some recommendations.  I re-iterated my plea for a comprehensive feasibility study and cumulative environmental impact study.  I suggest that the State provide solar energy facility applicants with a site-specific design year database based on the feasibility study meteorological data to improve their applications.   I recommend full payment for renewable resources only if they are dispatchable, i.e., they include energy storage.  I also have a suggestion for the future stakeholder process and recommend that this proceeding endorse energy storage R&D.



Author: rogercaiazza

I am a meteorologist (BS and MS degrees), was certified as a consulting meteorologist and have worked in the air quality industry for over 40 years. I author two blogs. Environmental staff in any industry have to be pragmatic balancing risks and benefits and ( reflects that outlook. The second blog addresses the New York State Reforming the Energy Vision initiative ( Any of my comments on the web or posts on my blogs are my opinion only. In no way do they reflect the position of any of my past employers or any company I was associated with.

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