Personal Comment Submittals

Before I retired one of my responsibilities was to evaluate proposed environmental and energy regulations and legislation to determine the potential effects on electric generating operations.  From the company standpoint it was necessary that the comments be a dispassionate technically supported argument for changes to increase the likelihood that the comments would be acknowledged much less used to modify the proposal.

Since retirement I have submitted comments as a private citizen and have tried hard to maintain that approach.  I recently realized that I could vent my frustrations in a blog post that explained the proposal, my comments and what I really think is going on.  I can also use the blog as an archive for my comments so that they can be referenced more easily elsewhere.

This page lists posts on this blog that describe and archive my public submittals with the most recent list first.

Climate Leadership and Community Protection Act White Paper Comment July 22, 2020

I commented that renewable natural gas should be considered a renewable energy system.

Part 242 Comments – Background and Rationale for Revisions Submitted June 25, 2020

Part 242 Comments on the Regulatory Impact Statement Submitted June 25, 2020

The proposed revisions to Part 242  reflect the RGGI program changes set forth in the updated RGGI Model Rule.  I commented on a couple of the rule changes and reviewed the rationale in the Regulatory Impact Statement.

My Additional Comments on NESE Pipeline Alternatives  April 30, 2020

Department of Public Service Case 19-02328/19-G-0678 is a proceeding related to denial of service requests by National Grid in New York City and Long Island associated with the Northeast Supply Enhancement (NESE) pipeline.  I addressed comments made by others in three separate submittals documented in this post.

Denial of Service Requests by National Grid aka NESE pipeline alternatives – Submitted March 27, 2020

Department of Public Service Case 19-02328/19-G-0678 is a proceeding related to denial of service requests by National Grid in New York City and Long Island associated with the Northeast Supply Enhancement (NESE) pipeline.  I commented on the options to the pipeline presented.

NYISO Grid in Transition Comments – Submitted March 26, 2020

As part of an effort to evaluate the changes needed within the New York State electric system, the New York Independent System Operator (NYISO) sponsored work by the Brattle Group.  Their report entitled “Grid in Transition: Introduction to the Modeling Methodology and First Discussion of Assumptions” included questions that were the focus of my comments.

DPS Resource Adequacy Matters Comments – Submitted September 16, 2019

Reply Comments to New York Resource Adequacy Proceeding – Submitted January 23, 2020

Department of Public Service Case 19-E-0530  fulfills “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.”  I prepared a white paper that provides an initial estimate of the likely energy storage component requirement based on real world data, developed an example of potential problems with air source heat pumps, and responded to specific questions.