On October 15, 2015, the New York Public Service Commission (PSC) Staff issued proposed guidance to the New York utilities for the structure and content of their Distributed System Implementation Plans (DSIPs). The DSIPs are the plans through which each utility will establish a Distributed System Platform (DSP), a foundational element of the Reforming the Energy Vision (REV) proceeding (14-M-0101). Per the Track 1 Order, the DSP is envisioned as “an intelligent network platform that will provide safe, reliable, and efficient electric services by integrating diverse resources to meet customers’ and society’s evolving needs. The DSP fosters broad market activity that monetizes system and social values, by enabling active customer and third-party engagement that is aligned with the wholesale market and bulk power system.”¹  A two-phase approach is outlined in the guidance, with an initial DSIP to be filed by each utility individually on June 30, 2016 and a supplemental DSIP to be developed jointly by the utilities and filed on September 1, 2016.

Key Details

• The initial DSIP will seek to be a thorough “self-assessment” addressing each utility’s system and denoting changes that can be made to effectuate REV policies and goals².  It will include the following key topics (with detailed requirements outlined for each):
  • Distribution System Planning – how utilities will forecast DERs, account for DERs in distribution planning, invest in both traditional grid solutions and supporting technology, and identify beneficial locations where DERs provide the most value to the grid
  • Distribution Grid Operations – the impact to the grid of increased DER penetration, the monitoring and control of DERs, the capabilities of the utility for Volt/VAR optimization, and how the utility is facilitating the interconnection of DERs
  • Distribution System Administration – the extent that system data and customer data is available for sharing with customers and third parties, the means by which the utility will share that data, and a description of steps necessary to enhance data sharing
  • Additional items to be included – an overview of current and planned REV demonstration projects, plans to evaluate and incorporate energy storage, and a Benefit Cost Analysis Handbook
• The supplemental DSIP will be a jointly filed document in which the New York utilities will develop the tools, processes, and protocols required to plan and operate a modern grid. The utilities will develop the shared standards and functionalities needed to dynamically manage DER, as well as supporting retail markets that coordinate significant DER investment and efficiently manage resources.³  The supplemental DSIP will include:
  • A description of the stakeholder process used to develop the supplemental DSIP
  • Distribution System Planning – the plan and process to shift from deterministic to probabilistic planning and proposed hosting capacity methodology
  • Distribution Grid Operations – the plan and budget for communications and IT infrastructure, a description of Advanced Meter Infrastructure (AMI) rollout policy, and cybersecurity measures to be implemented
  • Granularity of Pricing – the locational and frequency granularity of data to be used for pricing
  • NYISO/DSP Roles, Responsibilities, and Interaction – the obligations of the DSP and ISO for aggregation and dispatch, how and when they will interact, and the tools needed to visualize DER to enable reliable dispatch
  • Data Access to Facilitate Markets – the system and customer data to animate markets and determining protocols for protecting customer information
  • Market Participant Roles – recognizing relationships between the DSIP and ongoing rulemaking proceedings, identifying settlement procedures, identifying DER procurement methodologies, and reporting progress on joint system planning
• PSC Staff requested comments to the proposed DSIP Guidance, initial comments by the utilities and stakeholders were filed on December 7, 2015, and reply comments are to be filed January 6, 2016. In addition to general comments about the guidance, PSC Staff asked for comments regarding these specific topics:
  • A proposed stakeholder engagement process
  • Detailed description of the benefits of AMI and other advanced metering technologies
  • Customer and third-party data access and the associated protocols, processes, and data standards

Implications

With the PSC Staff proposing a two-phase approach for DSIP development, they are, to some extent, separating the near-term REV activities that each utility will undertake from the long-term changes to be adopted by the state as a whole in order to eventually accommodate significant DER penetration and new utility business models. Within the initial DSIP, the focus is intended to be on the current state capabilities of each utility to plan and forecast for DER, operate the grid in a safe, reliable, and effective manner as DER penetration increases, and collect and share system and customer data. Additionally, the initial DSIP will begin to address the changes necessary to enhance all of those capabilities in accordance with REV objectives. The supplemental DSIP then aims to provide additional information necessary for common approaches to long-term planning and coordination in order to further develop the concepts presented in the initial DSIP filing. The supplemental DSIP is also intended to identify the initial foundational approaches necessary for grid operations to evolve as DER penetration increases and a nascent energy market develops. This initially may include increased granularity of pricing, access to system and customer data, participant rules developed out of ongoing cases, and various approaches for procuring DER.⁴

Along with various other stakeholders, the Joint Utilities (the seven NY investor-owned utilities collectively) filed their comments to the proposed DSIP Guidance on December 7. All aspects of the DSIP Guidance were addressed with a focus on providing recommendations on which topics or requirements should be included in the initial DSIP and which should be addressed collectively in the supplemental DSIP, along with the prioritization of those topics. Additionally, the Joint Utilities addressed the specific questions in the proposed DSIP Guidance surrounding AMI, stating that the capabilities provided by AMI are foundational to achieving many of the goals identified throughout the REV proceedings.

Following reply comments in January by the Joint Utilities and stakeholders, a DSIP Guidance order from the PSC is expected in early 2016. The focused self-assessments and coordinated approach across utilities in these initial DSIP filings represent the first steps toward a more efficient and dynamic distribution system platform. DSIPs are to be filed biennially, and the concepts therein will be advanced based on the output of demonstration projects and other evolutions of technology and methodologies.

Sources

¹ CASE 14-M-0101 – Proceeding on Motion of the Commission in Regard to Reforming the Energy Vision – Order Adopting Regulatory Policy Framework and Implementation Plan, 2/26/15, p. 31

² CASE 14-M-0101 – Proceeding on Motion of the Commission in Regard to Reforming the Energy Vision – Staff Proposal, Distributed System Implementation Plan Guidance, 10/15/15, p. 4

³ Ibid, pp. 4-5.

⁴ Ibid, pp. 28-29

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Contributing Authors: Josh Kmiec, Chris Sturgill