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State of the 2020 New York Energy Market (Webinar)

September 11, 2020



The Empire State was poised for a dynamic 2020 as Governor Cuomo’s Reforming Energy Vision (REV) enters its sixth year. As New York State now works its way through the COVID-19 pandemic’s maze, organizations are reexamining their energy management strategies in search of optimization for an increasingly uncertain future.

Topics to be covered include:

  • Policy and regulatory changes in New York
  • An update of the REV and its renewable pursuits
  • Opportunities to monetize storage and other energy assets
  • Maximizing returns on demand response in NYISO and NY utility programs
  • And more…

CPower’s New York energy market experts Michael Mindell and Peter Dotson-Westphalen host this webinar that includes a question and answer session.

 

NY’s ‘Change of Status’ Rule Poses Challenges, Opportunities for Commercial Real Estate Industry

June 11, 2020

Before the Covid-19 lockdown, Special Case Resource’s Change of Status Rule wasn’t much of a concern for commercial real estate organizations participating in demand response (DR) in New York City.

Way back in 2019, when most commercial buildings were at or near full occupancy, energy consumption was high as were participating curtailable loads that could be called by the NYISO in times of grid stress or unusually high energy prices. 

What a difference a year makes. 

Anyone in the commercial real estate sector participating in DR in 2020 should take notice. That’s because the revenue previously earned from successful DR curtailment could soon flow in the wrong direction as underperformance penalties are assessed on organizations that have committed to curtailing loads they no longer have due to low occupancy in their buildings.

Established in 2009 and updated in 2014, SCR’s Change of Status rule defines the criteria of a qualified change of load condition as defined in Section 2.17 of the NYISO Services Tariff. The rule’s intent has always been to negate credit for passive curtailment in cases where a participating organization no longer had load to curtail for demand response. 

With occupancy in their buildings at record lows due to the Covid-19 lockdown, the Commercial Real Estate organizations in New York participating in lucrative demand response programs now find themselves in the crosshairs of a rule with steep penalties for non-compliance.

Here’s why:

Low building occupancy means low electrical consumption, resulting in a baseline for a given commercial building that will inevitably be far lower in 2020 during the lockdown than was established in 2019 when the building operated at normal occupancy. 

Here’s the problem for commercial buildings in New York participating in demand response in 2020: the baseline in 2019 is the one that counts for this year’s DR participation. 

Consider a commercial real estate organization that is currently operating at a fraction of last year’s occupancy and is enrolled in DR for the summer of 2020. If the organization’s summer load is less than 70% of its baseline established in 2019, the organization will likely face heavy penalties since they no longer possess enough load to curtail and will underperform in the Special Case Resource DR program.   

Here is what DR participants in New York’s commercial real estate industry can do to mitigate the rule’s penalties:

Contact your curtailment service provider (CSP) and ask them to provide a plan for navigating SCR’s Change of Status rule. A good CSP should be able to outline a set of actions aimed to minimize underperformance risks and maximize possible DR revenues.  

Such an outline of appropriate mitigation tasks might look like this:

  • Analyze load data
  • Review baselines
  • Review performance factors
  • Review previous seasons’ DR performances
  • Identify and/or update curtailment opportunities
  • Work with facility staff/engineering team to understand their energy systems operations and changes, occupancy changes, any other load changes, baseline changes
  • Conduct engineering analysis, preparing, reviewing and updating curtailment plans, as needed
  • Provide technical support and recommendations 
  • Provide enrollment recommendations for other DR programs that might fit the organization

In other words, a thorough CSP will work side-by-side with your organization and devise a customized mitigation plan based on your unique needs and capabilities.

Your CSP should work with you on a month-by-month basis to help you understand any enrollment changes and adjustments that need to be done to minimize the possible penalty risks associated with SCR’s Change of Status. 

The Covid-19 pandemic and lockdown have levied enough uncertainties on the commercial real estate industry in 2020. Whether or not demand response participants will earn or owe money this season in New York doesn’t have to be one of them. 

Peter Dotson-Westphalen and Arusyak Ghukasyan also contributed to this article.

PSC Order on NY Utility DR Program Changes for Summer 2020 – Market Minute (Video)

June 02, 2020



 

On May 14th, in response to COVID-19 related challenges and recommendations raised by stakeholders,  the New York Public Service Commission issued an Order directing most of the utilities to implement several changes to their Dynamic Load Management (DLM) tariffs to become effective as of June 1st. These changes will impact the Commercial System Relief Program (CSRP) and the Distribution Load Relief Program (DLRP) for Summer 2020 and are intended to increase program flexibility for DR aggregators and participants.

The PSC Order directs the utilities to make the following changes to their DLM tariffs:

First, there will be an additional enrollment window to allow new participants to participate in the programs in July through September if enrollments are submitted by June 1st.

Second, for customers currently enrolled will have an opportunity to adjust their committed kW reduction amounts for July through September if this is submitted by June 1st.

Third, testing will occur only if an event has not already occurred, and the PSC has directed utilities to not administer a test before July 1st.

Lastly, for customers that have utility interval or AMI metering installed but have not been able to establish communications between the meter and the utility will be provisionally approved to participate, pending establishment of the necessary communications and providing that meter data for the CBL baseline calculations and test/event performance can be retrieved to assess program performance for settlement and payment.

These changes will be applicable to all utilities within New York, except for PSEG-LI. The PSC Order directs Department of Public Service staff to work with LIPA/PSEG-LI staff to see if similar changes can be implemented for their CSRP and DLRP programs for this program season.

If your organization is currently participating in one or both of the CSRP and DLRP programs in 2020, or had opted not to enroll in these programs due to operational and electric load changes for the season, you now have one more opportunity to enroll to participate in July through September, or to adjust your level of participation through adjusting your enrollment value.

If you have any questions or would like to enroll, or adjust your current enrollment amount, in the CSRP or DLRP programs by June 1st, or have any other New York energy question, contact CPower and we’ll help you in any way we can.

On May 14th, in response to COVID-19 related challenges and recommendations raised by stakeholders,  the New York Public Service Commission issued an Order directing most of the utilities to implement several changes to their Dynamic Load Management (DLM) tariffs to become effective as of June 1st. These changes will impact the Commercial System Relief Program (CSRP) and the Distribution Load Relief Program (DLRP) for Summer 2020 and are intended to increase program flexibility for DR aggregators and participants.

The PSC Order directs the utilities to make the following changes to their DLM tariffs:

  1. Enrollment – an additional enrollment window has been added. New enrollments must be submitted by June 1st for participation in the CSRP/DLRP for July through September.
  2. Enrollment Adjustment – participants may adjust their committed kW to the CSRP and DLRP programs by submitting updated enrollments by June 1st, to become effective July 1st.
  3. Testing – utilities have been directed to not administer tests in their programs until July 1st at the earliest, and to not administer a test if an event has already been called.
  4. Metering – customers that have utility interval or AMI metering installed but have not been able to establish communications between the meter and the utility will be provisionally approved to participate, pending establishment of the necessary communications and providing that meter data for the CBL baseline calculations and test/event performance can be retrieved to assess program performance for settlement and payment.

These changes will be applicable to all utilities within New York, except for PSEG-LI. The PSC Order directs Department of Public Service staff to work with LIPA/PSEG-LI staff to see if similar changes can be implemented for their CSRP and DLRP programs for this program season.

If your organization is currently participating in one or both of the CSRP and DLRP programs in 2020, or had opted not to enroll in these programs due to operational and electric load changes for the season, you now have one more opportunity to enroll to participate in July through September, or to adjust your level of participation through adjusting your enrollment value.

If you have any questions or would like to enroll, or adjust your current enrollment amount, in the CSRP or DLRP programs by June 1st, or have any other New York energy question, contact CPower and we’ll help you in any way we can.

New York’s Rule 222 for Distributed Generation (Video)

April 20, 2020



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2020 State of Demand-Side Energy Management in North America

March 25, 2020
Last year, nearly 2000 organizations nationwide downloaded the State of Demand-Side Energy Management in North America book by CPower’s energy experts.
This year, we pick up where we left off with a market-by-market analysis of the issues, trends, and regulations organizations like yours should understand in 2020 to make better decisions about your energy use and spend.

Rule 222: NYS DEC cracks down on NOx emissions from commercial generators

March 24, 2020

The New York State Department of Environmental Conservation (NYSDEC) has approved a new regulation called 6 NYCRR Part 222 Distribution Generation Sources. The proposed rule would replace the March 1, 2017 adopted Part 222, which was challenged in the Supreme Court in the County of Albany and stayed. 

Controlling nitrogen oxide emissions from distributed generation sources is Rule 222’s essential goal. The proposed rule will apply only in the New York City metropolitan area as defined at 6 NYCRR Part 200.1(au), which covers New York City, Westchester, Rockland, and Nassau counties.

DG sources enrolled in demand response programs sponsored by the NYISO or electric utilities as well as sources used during times when the cost of electricity supplied by utilities is high (defined separately in Part 222 as price-responsive “economic” generation sources) are subject to the new rule. 

Rule 222 was approved on March 11, 2020, and will be implemented effective May 1, 2021. Both new and existing distributed generation sources that intend to participate in DR will need to notify the NYSDEC by March 15, 2021 or 30 days prior to beginning participation, whichever is later.  That said, organizations in the New York City metro area that use a stationary generator for demand response should contact CPower since the rule could ultimately affect their ability to earn revenue by helping the grid reduce load in times of stress or high economic prices. 

Any organization curious to learn more about Rule 222 and whether or not their generator is affected should contact a licensed curtailment service provider.


This post was excerpted from the 2020 State of Demand-Side Energy Management in North America, a market-by-market analysis of the issues and trends the experts at CPower feel organizations like yours need to know to make better decisions about your energy use and spend.

CPower has taken the pain out of painstaking detail, leaving a comprehensive but easy-to-understand bed of insights and ideas to help you make sense of demand-side energy’s quickly-evolving landscape.

Download Your Copy 

Seasonal Readiness 2020

February 18, 2020
Are you ready for the 2020 demand response season? Our program information and On Demand Webinar resources will help make you successful in your programs in 2020. Here, you'll find program information, key dates (like communication drills), your CPower contacts, market information, dispatch information and more.