Co-author Morgan M. Gerard
On December 23rd, 2015, The New York State Public Service Commission (NYPSC) issued a Notice under which it is soliciting comments concerning the value that Distributed Energy Resources (DERs) contribute to the distribution grid system. It is also soliciting feedback on a successor methodology to its current Net Energy Metering (NEM) policy that will help drive development in the interim. Both of these issues are being tackled by the NYPSC as part of New York’s broader Reforming the Energy Vision (REV) initiative.
New York needs critical energy infrastructure to the tune of billions of dollars at the same time that utility revenues are falling. Additionally, more distributed generation (DG) is coming online, including DG resources that net meter to the grid, and therefore potentially shift the pro rata costs of grid maintenance onto non-DG owners. In response, the NYPSC opened the REV docket in an attempt to reconcile these trends as well as prepare for a more resilient and energy efficient future.
It is hoped that the policies and rules promulgated under REV will facilitate the adoption of greater on-site and near-site energy resources and efficiency approaches, known under REV as Distributed Energy Resources (DERs). Under this new framework, DER owners will be able to sell their generation to utilities as well as directly to commercial and retail customers. Due to the complexities inherent in such a model, the Commission has worked with incumbent utilities who will help achieve ambitious DER goals by operating as Distributed System Platforms (DSPs), which will coordinate grid-wide DER activities as a market administrator, not unlike a distribution level independent system operator.
However, a complication has arisen under this new paradigm: What is the value of these DERs to the system? Assessing the value of DERs is a key component in constructing an efficient market as transactions will consist of interactions among customers and service providers, and also between utilities and DER providers. It is also true that in the absence of clarity regarding the value of DERs it will be difficult to attract private capital to projects under development. Because of these complications, and the need to both resolve uncertainty and ensure that the burdens of systemic grid maintenance and upgrades are not being bypassed by DER and grid-exiting customers, a mechanism is required to establish accurate pricing.
It was made clear in the NYPSC Staff’s Track Two White Paper that the system value of DERs will be divided into two components: 1) the energy value and 2) all other values associated with distribution-level resources. The energy value in New York is established by power markets and is called the location-based marginal pricing (LMP), a methodology where the price of energy at each location in the New York State Transmission System is equivalent to the cost to supply incremental load at that location. The full value of a particular DER can be expressed as the LMP plus the distribution delivery value (the value of D); together known as “LMP+D.” In the NEM Interim Ceilings Order, the Commission further elaborated that “[the] ‘value of D’ can include load reduction, frequency regulation, reactive power, line loss avoidance, resilience and locational values as well as values not directly related to delivery service such as installed capacity and emission avoidance.” The Notice indicates that the NYPSC is seeking to establish a new methodology and process for determining the full value of DERs prior to December 31, 2016.
Determining the value of DERs to the grid system implicates possible changes to the future of net energy metering (NEM), which in the Empire State is a statute-based incentive that allows small generators of electricity to sell their excess generation into the grid subject to an overall cap. If a new value is being placed on all DERs, and DER outputs can be purchased by the utility and non-utility actors in real-time, the question of how the current NEM regime can co-exist within the REV marketplace is begged. Despite this gray space, Staff saw no reason to adjust NEM for the mass-market per the Track Two White Paper, and stated that a bill-crediting mechanism used in NEM should continue to be considered as part of a successor to NEM. It also stated that changes to NEM should be focused on larger projects with substantial net export of electricity.
The Commission decided in the subsequent Net Metering Ceilings Order that “until these valuation efforts [the value of D] are completed, and incorporated in tariffs that recognize the full benefit of DER, net metering must continue, to avoid the disruption of DG development efforts that would contravene the State’s energy policies.” Despite an overall lack of change, the cap on NEM under the Ceilings Order is now allowed to float to avoid “repeated disputes over the proper level of the ceiling . . . and shall be allowed to float in the interim until the calculation and application of ‘the value of D’ and other issues affecting valuation of DER is decided.” In addition, and in recognition of the various paths NEM policy could take going forward, the current solicitation also seeks comment on how the Commission should consider the transition “from NEM,” and indicates that they favor a scenario where “a single comprehensive process should be embarked upon to adequately address the range and complexity of the questions raised [in this matter].”
The “value of D” may be the necessary component to determine how DERs, specifically on-site generation and microgrids, contribute to the efficiency and resiliency of the grid. Although New York is starting the process of targeting the valuation metric, and many DER providers and NEM advocates may disagree with the method, for the purpose of project financing the “value of D” may lend the clarity needed to ensure the stability of the REV-driven marketplace. To take part in the discussion over NEM and the value of DER to the distribution system, potentially interested parties are able to respond and comment to the Notice until April 18, 2016.