NY-GEO Comments on Empire State’s REV Clean Energy Plan

The New York Department of Public Service first proposed its Reforming the Energy Vision (REV) initiative in April to head off aging electric infrastructure, low load growth, and new peak demand with a plan that envisions new technologies helping traditional utilities face the future.

REV is aimed at changing New York’s regulatory regime in ways that promote more efficient use of energy; deeper penetration of renewable energy resources; wider deployment of alternative energy resources; and promotion of advanced energy management practices.

In August, NYDPS staff released a straw proposal outlining a basic framework of “customer-oriented regulatory reform.” The proposal calls for a broad range of Distributed Energy Resources to be coordinated with market and incentive structures designed to enable customers to optimize their energy usage. “By systematizing the cost-effective use of distributed resources, REV will establish New York as a leader in enabling resources and innovating around new market structures for the benefit of its electricity customers,” said NYDPS staff.

The plan contains a dozen individual proposals, but its “big picture” is a Distributed System Platform that would integrate and manage distributed energy resources across the grid. Distributed System Platform Providers would initially be today’s utilities, but the plan leaves the possibility of opening the role up to competition.

Under the REV proposal, distributed energy resources will be coordinated to manage load; optimize system operations; and enable clean distributed power generation. Markets and tariffs will empower customers to optimize their energy usage and reduce electric bills.

The newly formed New York Geothermal Energy Organization (NY-GEO) submitted comments to NYDPS about its straw proposal, urging specific consideration of geothermal heat pumps (GHPs) in the REV final plan. “GHP technology is an excellent way to reduce (carbon) emissions, improve grid performance and save consumers money,” said NY-GEO Executive Director Bill Nowak. “To ensure the most effective results for the REV process, we should take full advantage of the benefits of GHP technology.”

NY-GEO urged a focus on energy and not just electricity. “Although GHPs… increase electricity consumption, they result in reduced overall energy consumption and reduced emissions.” They also pointed out that GHP technology reduces energy costs, creates green jobs, reduces total energy use for heating and cooling, reduces peak demand, increases system utilization, and reduces greenhouse gas emissions.

Nowak described how GHPs have had very limited access to ratepayer contributions in the state due to the way fuel switching prohibitions have been implemented, along with outdated technical data that have been used to evaluate GHP costs. He asked for reform of those prohibitions and cautioned against expanding fossil fuel infrastructure when alternatives are now available to help secure sustain-able and acceptable renewable energy supply for the future.
“NY-GEO proposes that GHPs be specifically included in any listing of Distributed Energy Resources,” said Nowak. “GHPs should be an integral part of the ‘systemic change,’ because they can help address minimal load growth, increasing peak loads, declining system efficiency, and increasing dependence on natural gas.”

NY-GEO Executive Director Bill Nowak can be contacted by email here, or by phone at (716) 882-9237.