As concluded by the Commission in its January 20, 2022 Order on Power Grid Study Recommendations, both near and long-term efforts are necessary to take advantage of the benefits that technology may offer to ratepayers. The Commission further states that many of the technologies being considered by the ATWG have already been tested and/or implemented by utilities, and that the deployment of such advanced technologies “must continue to take fullest practical advantage of new technology and other innovation.” However, while the stated goal of the ATWG is to “identify, discuss, and resolve technical barriers and challenges associated with developing and deploying advanced technologies on the New York electric T&D systems” (including distribution systems), the research and development process proposed by the JU Plan is seemingly limited to activities that support longer-term operation and integration of renewable energy into the transmission system.

NYSEIA respectfully recommends that the ATWG include a focus on the implementation of tested and cost-effective near-term solutions, especially in relation to distribution grid systems. This should include technologies that may serve as a “stopgap measure” until cost-effective grid upgrades can be identified, designed, and built. There is an immediate opportunity to accelerate the deployment of technologies that can offer significant near-term benefits by increasing renewable generation integration headroom of existing grid facilities (i.e. Flexible Interconnection, or FICS, or Active Resource Integration, or Dynamic Curtailment solutions), as highlighted in previous comments submitted by NYSEIA in Case 20-E-0197. The near-term application of these established advanced technologies can serve to increase headroom and facilitate distributed energy resource development in the short term, while also supporting and even de-risking longer-term efforts for robust and coordinated transmission and distribution grid planning by providing real world market indicators for potential future grid upgrades.