SEA Blog 2020-5: Clean Energy Standard “2.0” Order Advances New Procurement Opportunities in New York State

Yesterday, October 15, the New York State Public Service Commission (PSC) issued a 306-page Order Adopting Modifications to the Clean Energy Standard, in which the PSC approved significant changes to the state’s Clean Energy Standard (CES) program. Tier 1 modifications First and foremost, the Order now incorporates the Climate Leadership and Community Protection Act’s recently codified 70% renewables by 2030 goal into the CES program (up from 50% by 2030). This more ambitious goal requires an increase to the New York State Energy Research and Development Authority’s (NYSERDA’s) Tier 1 Renewable Energy Standard (RES) procurement schedule for new large scale renewable energy projects, up to a flexible target of 4,500 GWh/year. As a reminder, in the first three RES Tier 1 solicitations NYSERDA procured well above its targets of 1,500 GWh/year, sometimes more than double. However, NYSERDA has yet to procure over 3,900 GWh in any given solicitation. Changes to the Tier 1 procurement evaluation and minimum threshold criteria were also adopted in this Order, designed to result in the selection of projects with a high likelihood of success and portfolios that reflect state objectives, as outlined in the June White Paper. This Order also approves a temporary decrease to […]

SEA Blog 2020-4: NYSERDA’s Potential Game-Changing Petition Seeks to Switch Tier 1 Fixed-Price REC Contracts to Index REC Structure

On August 10, 2020, the New York State Energy Research and Development Authority (NYSERDA) filed a Petition with the Public Service Commission (PSC) in Case 15-E-0302. NYSERDA requested that the PSC authorize NYSERDA to offer previous Tier 1 REC award recipients the opportunity to convert their contracts from a Fixed price REC structure to an Index REC price structure. As a reminder, on January 16, the PSC issued an Order Modifying Tier 1 Renewable Procurements to authorize NYSERDA to offer an Index REC structure to bidders in its Tier 1 Renewable Energy Standard (RES) solicitations. An Index REC would provide REC payments to contracted projects based on the net difference between a contracted “strike price” and reference prices for energy and capacity, thereby providing a substantial hedge on commodity market energy and capacity revenues (see our past blog post on Index REC).  NYSERDA argues that allowing currently contracted projects to convert to an Index REC price structure could lower financing costs, which would reduce ratepayer costs and increase the likelihood of projects reaching commercial operation. While a conversion to an Index REC may not be sufficient to change the outlook of projects with significant financial barriers, it could be enough to provide […]

SEA Blog 2020-3: New York State Releases CES 2.0 Whitepaper following Triennial Review

New York’s Clean Energy Standard (CES) is getting an update! CES 2.0, as the new program proposal has been dubbed, includes many interesting new details on how New York State plans to achieve the 70% by 2030 renewable electricity goal mandated by the Climate Leadership and Community Protection Act (CLCPA). Prior to releasing details on CES 2.0, NYSERDA contracted with Sustainable Energy Advantage, LLC (SEA) to conduct a thorough analysis of the CES program to date – in particular the Renewable Energy Standard (RES) portion of the CES – to serve as a factual foundation for the proposed CES 2.0 modifications. RES Program Impact Evaluation + CES Triennial Review The RES Program Impact Evaluation and the CES Triennial Review was filed with the Public Service Commission on June 1. Our report catalogs progress towards meeting policy objectives and targets, and highlights several interesting findings based on the data available (in most cases through the end of 2018). We found that NYSERDA’s RES procurements to date have succeeded in: Contracting with large-scale renewables in quantities over twice NYSERDA’s initial targets, with increasing proportions from utility-scale solar (see Figure 2). Decreasing expected Tier 1 REC prices (see Figure 4). Stimulating a robust […]

SEA Blog 2020-2: New York State Announces New REC Contract Awards for 21 Renewable Energy Projects, Including 3 Existing Wind Projects

Last Friday, March 13, New York State announced the winners of its third round of “Tier-1” solicitations for large-scale renewables (RESRFP19-1) under the Clean Energy Standard (CES), with 21 projects selected totaling 1,278 megawatts (MW) of new clean energy capacity. This 2019 award group includes 17 new solar facilities – the largest 2 paired with 20 MW energy storage projects – and 1 new wind facility. In addition, 3 existing wind facilities were selected for “repowering” (we note the 1,278 MW of new capacity appears to reflect just the incremental capacity of the three repowered projects). The Governor’s press release states that all projects are expected to be operational by 2024, with several projects expected to commence construction by the end of this year. The selections award contracts to 8 bidders – Boralex (4 solar projects, 180 MW), Suneast Development (8 solar projects, 220 MW), NextEra Energy Resources (2 solar projects, 380 MW), ConnectGen (1 solar project, 270 MW), East Light Partners (1 solar project, 19.99 MW), Empire Renewables, LLC (1 solar project, 19.99 MW), Terra-Gen (1 wind project, 145 MW), and TerraForm Power (3 repowered wind projects, 43.2 MW increase in capacity). Pace, Scale and Cost of Procurement Over […]

SEA Blog 2020-1: A Review of New York Administration’s Proposal to Overhaul Renewable Energy Siting Process

New York’s Governor Cuomo has formally proposed the Accelerated Renewable Energy Growth and Community Benefit Act (“Siting Act”) in his 30-day amendments to the executive budget (see Part JJJ), released February 21, 2020. The proposal includes several significant revisions to the process for siting renewable energy projects and transmission buildout in NYS. The Siting Act would establish a new program to replace the existing Article 10 permitting process, as well as other key revisions across various areas of state law designed to help New York achieve its recently enacted 70% by 2030 renewable energy target enshrined by the 2019 Climate Leadership and Community Protection Act (CLCPA). Overall, this proposal has the potential to restructure the siting and permitting process for renewable energy projects over 10 megawatts (MW), carrying with it the potential for market uncertainty until ultimately either adopted in some form or rejected, and could prove a key component to New York State achieving its clean energy goals. Overview of Key Provisions in the Siting Act The Siting Act includes the proposal of a new Article 23 “Major Renewable Energy Development Program” to serve as a consolidated permitting process for renewable energy facilities. This would require all new renewable […]

SEA Blog 2019-2: The RESRFP19-1 Bid Cohort: Assorted Thoughts, Trends, and Observations

The Basics On October 3, 2019, the New York State Energy Research and Development Authority (NYSERDA) released high-level information for the cohort of projects that submitted bids in response to its 2019 Renewable Energy Standard Request for Proposals (RESRFP19-1). Similar to its first two RFPs under the Renewable Energy Standard (RES) program, NYSERDA is offering 20-year contracts for the purchase of fixed-price RES Tier 1 renewable energy credits (RECs), and the RFP seeks deliveries of approximately 1.5 million per year. However, in each of its two previous RESRFPs, NYSERDA ultimately selected and contracted for REC deliveries well above its announced procurement targets, which NYSERDA could do again this year.   In response to RESRFP19-1, developers submitted bids from 54 eligible projects totaling 4,323 MW of capacity. All of the bids were for either in-state solar or wind resources, with six projects providing optional battery storage offerings. In addition to 5 greenfield wind projects, the wind projects bid into the RFP include 3 repowering projects owned by Terraform Power (we note that the current eligibility requirements treat repowering projects as “upgrades,” and only consider the incremental energy production to be Tier 1 eligible). As with the prior RESRFP18-1, there were no […]

SEA Blog 2019-1: A Fresh Look at Index REC Procurement in New York

New York’s 50% by 2030 renewable goal is supported by NYSERDA’s massive large-scale renewable procurement program to help get needed facilities financed and built. Dating back to its first Main Tier RPS solicitation in 2005, NYSERDA has offered contracts for fixed-price RECs. While offering more hedge to generators than its PJM neighbors, New York’s approach has (in contrast to its neighbors in New England) placed commodity electricity market risk on generators, with such risk dampening the market’s attractiveness to investors and leading to higher financing costs. On March 12, 2019, the Alliance for Clean Energy New York (ACE NY) and the American Wind Energy Association (AWEA) petitioned the New York Public Services to consider offering generators commodity revenue risk hedge through an Index REC hedging structure in future NYSERDA large-scale renewable procurements. In light of increasing uncertainty of future wholesale electricity revenues driven by aggressive clean energy targets and NYISO’s proposed introduction of a carbon price in its wholesale market, transitioning to an Index REC approach – if New York ultimately chose to move in that direction – would move the state along the continuum toward providing substantially more commodity electricity market price hedge (and revenue certainty) to generators. This transition […]