On September 10th, 2026, NYSEIA submitted comments in response to the Coordinated Grid Planning Proceeding (CGPP) Cycle 1 Report (Case 20-E-0197).

Our core critique of the Joint Utilities (JU) CGPP Cycle 1 report is that they eliminated the Low Transmission Impact Scenario from the analysis, which was designed to test a future in which DERs and flexible load are more prominent. Eliminating this forecloses on a potential least-cost option.

The low transmission impact scenario is a potential least-cost pathway that warrants full consideration as a primary planning scenario. The JU acknowledged that this scenario offsets the  need for upstate hydrogen capacity and UPV expansion, reducing transmission constraints and infrastructure requirements. NYSEIA recommends a high-DER, high-flexibility pathway be treated as a primary planning scenario with increased BTM-PV and flexibility assumptions.

NYSEIA also notes that Stage 1 of the CGPP Cycle 1 did not accurately evaluate the potential impact of a low transmission scenario, as transmission cost estimates have tripled. NYSEIA asserts that a re-run of the Low Transmission Scenario with more accurate transmission capacity expansion costs would produce materially different results. NYSEIA recommends the CGPP Cycle 2 reevaluate the Low Transmission Impact Scenario using a proxy that more accurately represents the local transmission costs identified by the JU.

NYSEIA also asserts that Sensitivity 6 demonstrates a high-DER, high-flexibility pathway can produce materially different outcomes, reallocating generation. Further, Cycle 1 does not consider distribution investments needed to host or enable BTM-PV. NYSEIA is concerned about this because it departs from the intent established in the original CGPP order and the coordinated, system-wide planning framework, and second the Cost Sharing 2.0 framework has not been effective in enabling or mobilizing major distribution investments such as transformer upgrades. Finally, the three principal scenarios in the CGPP do not represent an appropriate range of BTM-PV deployment and load flexibility.

NYSEIA acknowledges that the distribution modeling limitations present in Cycle 1 have been a key barrier to performing a truly coordinated grid-planning assessment across the transmission and distribution systems. NYSEIA therefore strongly urges the Commission to direct the CGPP to develop the modeling capability necessary to perform a more coordinated assessment. NYSEIA recommends the CGPP consider grid-enhancing technologies and flexible interconnection for BTM-PV.

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