STATE OF NEW YORK

PUBLIC SERVICE COMMISSION

CASE 18-E-0130 - In the Matter of Energy Storage Deployment

Program.

ORDER ESTABLISHING UPDATED ENERGY STORAGE GOAL

AND DEPLOYMENT POLICY

Issued and Effective: June 20, 2024

 TABLE OF CONTENTS

LIST OF ACRONYMS..............................................iii
INTRODUCTION................................................- 1 -
BACKGROUND..................................................- 4 -
NOTICE OF PROPOSED RULE MAKING..............................- 7 -
LEGAL AUTHORITY.............................................- 8 -
STATE ENVIRONMENTAL QUALITY REVIEW ACT......................- 9 -
TRIENNIAL REVIEW...........................................- 10 -
Role of Energy Storage.....................................- 19 -
DISCUSSION.................................................- 24 -
Bulk Energy Storage Procurement Program Design .......... - 24 -
Retail Energy Storage Procurement Program Design ........ - 39 -
Residential Energy Storage Procurement Program Design ... - 44 -
WHOLESALE MARKET ACTIONS...................................- 48 -
GENERAL PROGRAM DESIGN CONSIDERATIONS......................- 54 -
Prevailing Wage ......................................... - 54 -
Periodic Review ......................................... - 55 -
Rollover of Project Funds ............................... - 56 -
Disadvantaged Communities ............................... - 56 -
In-Service Date ......................................... - 59 -
OTHER ISSUES...............................................- 61 -
NYPA and LIPA Participation in Storage Procurement Programs - 61
-
New York Municipal Power Association (NYMPA) ............ - 63 -
Utility Ownership of Energy Storage Systems ............. - 64 -
Vehicle-to-Grid ......................................... - 67 -
Establishment of a BTM Energy Storage Incentive ......... - 68 -
Bridge-to Wires ......................................... - 71 -
Rate Design ............................................. - 72 -
Fire Safety ............................................. - 79 -
IMPLEMENTATION PLANS.......................................- 81 -
LONG DURATION ENERGY STORAGE AND INNOVATION................- 83 -
PROGRAM COSTS AND RECOVERY.................................- 84 -
CONCLUSION.................................................- 93 -
APPENDIX A- SUMMARY OF STAKEHOLDER COMMENTS
APPENDIX B- SUMMARY OF STAKEHOLDER REPLY COMMENTS
APPENDIX C- Summary of Stakeholder Comments on Updated Roadmap
APPENDIX D- Supplemental Generic Environmental Impact Statement
Findings Statement
APPENDIX E- NYSERDA Retail and Residential Energy Storage
Program Recovery Mechanisms
APPENDIX F- NYSERDA Retail and Residential Energy Storage
Program Cost Allocations
APPENDIX G- Residential and Retail Energy Storage Program Annual
Costs (including Administration, Implementation, Program
Evaluation and NYS Cost Recovery Expense) Allocation and
Collection Schedule for Utilities and LIPA
APPENDIX H- Bulk Storage Program Forecasted Annual Costs ($
millions, nominal)

ii
 LIST OF ACRONYMS

BTM - Behind-the-meter
BTW - Bridge-to-Wires
CAF - Capacity Accreditation Factors
CES - Clean Energy Standard
CLCPA - Climate Leadership and Community Protection Act
CRF - Cost Recovery Fee
CSR - Co-located Storage Resource
DEC - Department of Environmental Conservation
DER - Distributed Energy Resource
DPS - New York State Department of Public Service
EV - Electric Vehicle
FDNY - Fire Department of New York
FERC - Federal Energy Regulatory Commission
GHG - Greenhouse gas
GW - Gigawatt
HSR - Hybrid Storage Resource
ICAP - Installed Capacity
IRA - Inflation Reduction Act
ISC - Index Storage Credit
ISO - Independent System Operator
ITC - Investment Tax Credit
kW - Kilowatt
LDES - Long Duration Energy Storage
LIPA - Long Island Power Authority
LSE - Load Serving Entity
MW - Megawatt
MWh - Megawatt hour
NNYESP - Northern New York Energy Storage Project
NYGB - New York Green Bank
NYISO - New York Independent System Operator
NYPA - New York Power Authority
NYSERDA - New York State Energy Research and Development
Authority
PSL - Public Service Law
PV - Photovoltaic
RCP - Reference Capacity Price
REAP - Reference Energy Arbitrage Price
REC - Renewable Energy Credit
RES - Renewable Energy Standard
RFP - Request for Proposals
RTE - Round Trip Efficiency
RTO - Regional Transmission Organization
SGEIS - Supplemental Generic Environmental Impact Statement
UDR - Utility Dispatch Rights
VDER - Value of Distributed Energy Resources

iii
 STATE OF NEW YORK
PUBLIC SERVICE COMMISSION

At a session of the Public Service

Commission held in the City of
Albany on June 20, 2024

COMMISSIONERS PRESENT:

Rory M. Christian, Chair

James S. Alesi
David J. Valesky
John B. Maggiore, concurring
Uchenna S. Bright
Denise M. Sheehan, recusing

CASE 18-E-0130 - In the Matter of Energy Storage Deployment

Program.

ORDER ESTABLISHING UPDATED STORAGE GOAL

AND DEPLOYMENT POLICY

(Issued and Effective June 20, 2024)

BY THE COMMISSION:

INTRODUCTION
New York State is committed to developing a zero-
emission electric grid. Over the next five to ten years, large,
planned increases in the amount of intermittent renewable
generation at both the bulk and distribution level, primarily in
the form of on- and off-shore wind and photovoltaic (PV) solar,
will require new methods and resources to balance supply and
demand, including the use of energy storage. As discussed in
more detail below, energy storage technologies are a key piece
of the solution to ensure the reliability of New York’s electric
system during this historic transition.
On December 13, 2018, the New York State Public
Service Commission (Commission) issued the Order Establishing
CASE 18-E-0130

Energy Storage Goal and Deployment Policy (Energy Storage

Order). The Energy Storage Order, among other things, outlined
a framework of programs intended to spur the development and
deployment of 3 gigawatts (GW) of energy storage projects in New
York through the creation of competitive solicitations by each
of the State’s investor-owned utilities. 1 Since the issuance of
the Energy Storage Order, the Climate Leadership and Community
Protection Act (Climate Act or CLCPA) has become law. The CLCPA
requires 70 percent of New York’s electricity generation to come
from renewables by 2030 and 100 percent by 2040. 2 Additionally,
in 2022, New York announced a new goal of 6 GW of energy storage
by 2030. The enactment of the CLCPA and the new energy storage
goal only further accentuate the need for increased development
of energy storage in New York.
In compliance with the periodic review requirements of
the Energy Storage Order, to update previous analyses, and to
respond to New York’s expanded 6 GW energy storage target, New
York State Department of Public Service Staff (DPS or Staff) and
the New York State Energy Research and Development Authority
(NYSERDA) jointly filed “New York’s 6 GW Energy Storage Roadmap:
Policy Options for Continued Growth in Energy Storage” (Roadmap)
on December 28, 2022, in this proceeding. The Roadmap makes
several recommendations aimed at achieving the 6 GW goal,
discussed in detail below. Broadly speaking, the Roadmap
proposes general program design considerations, market rule

1 New York’s investor-owned utilities are: Central Hudson Gas &

Electric Corporation (Central Hudson), Consolidated Edison
Company of New York, Inc. (Con Edison), New York State
Electric & Gas Corporation (NYSEG), Niagara Mohawk Power
Corporation d/b/a National Grid (National Grid), Orange and
Rockland Utilities, Inc.(O&R), and Rochester Gas and Electric
Corporation (R&G) (collectively, the Joint Utilities).
2 CLCPA §66-p(2).

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CASE 18-E-0130

changes, and procurement strategies, with specific

considerations for both bulk and retail/residential storage in
order to meet the 6 GW target.
In the Roadmap, Staff indicates that New York will
need approximately 12 GW of energy storage by 2040 to support a
decarbonized and reliable electric system. The target of 6 GW
by 2030 is an important steppingstone to achieve the amount of
energy storage that will ultimately be needed, and makes it
clear to developers that New York values investments in energy
storage. Through the Commission’s continued collaboration with
NYSERDA, the Long Island Power Authority (LIPA), the New York
Independent System Operator, Inc. (NYISO), the New York Power
Authority (NYPA), the New York Green Bank (NYGB), the New York
State Department of Environmental Conservation (DEC), New York’s
investor-owned utilities, and other stakeholders, New York is
poised to effectively transition to an emissions-free energy
future.
By this Order, the Commission adopts an updated
statewide deployment goal of 6 GW of energy storage resources by
2030, with an interim goal of 1.5 GW by 2025. As further
discussed below, with consideration for the numerous stakeholder
comments, the Commission adopts many of the Staff
recommendations from the Roadmap. The successful implementation
of the programs and recommendations contained herein will move
the State closer to reaching its climate goals. 3

3 Codified in the Environmental Conservation Law (ECL), the

CLCPA established the target of reducing greenhouse gas
emissions 40 percent by 2030 and 85 percent by 2050, compared
to 1990 levels. ECL §75-0107.

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CASE 18-E-0130

BACKGROUND
Enacted in 2017, Public Service Law (PSL) Section 74
required the Commission to establish a statewide energy storage
goal for 2030 alongside a deployment policy to support this
goal. In response, DPS Staff and NYSERDA filed the “New York
State Energy Storage Roadmap and DPS/NYSERDA Recommendations”
(2018 Roadmap) on June 21, 2018, in this proceeding. The 2018
Roadmap made several recommendations for Commission
consideration that were intended to help spur the growth of the
energy storage market in New York. Those recommendations
focused around seven areas: (1) retail rate actions and utility
programs; (2) utility roles and business models; (3) direct
procurement; (4) market acceleration incentives; (5) soft-cost
reductions; (6) clean peak actions; and (7) wholesale market
actions. The Energy Storage Order adopted many of the
recommendations specified in the 2018 Roadmap.
In the years since the Commission issued the Energy
Storage Order, there has been a tremendous effort to effectuate
the ambitious energy storage deployment, coordination, and
market rule changes needed to successfully build out the robust
storage network that is crucial to New York’s energy transition.
Energy storage procurement programs include a combination of
NYSERDA market acceleration incentives and utility dispatch
rights (UDR) contract solicitations.
The Energy Storage Order directed NYSERDA to implement
an Energy Storage Market Acceleration Bridge Incentive (Bridge
Incentive) using uncommitted ratepayer funds capped at $310
million. 4 The purpose of the Bridge Incentive is to provide
revenue certainty for a predetermined timeframe, by providing a
fixed, upfront incentive rate in dollars per kilowatt hour (kWh)

4 Energy Storage Order, p. 65.

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CASE 18-E-0130

of energy storage capacity during the nascent stage of energy

storage development, to make projects economically viable. As
the energy storage market matures and incentives are no longer
required, the level of support declines.
The Energy Storage Order also directed the Joint
Utilities to issue a Request for Proposals (RFP) in 2019, and
subsequent RFPs as-needed on an annual basis, to competitively
procure dispatch rights for bulk-level energy storage projects. 5
The selection of projects is intended to address the local needs
of the area in which the projects are located, including local
reliability needs, load relief, environmental benefits through
the reduction of use of peaking plant units and associated
emissions, and wholesale market services such as Frequency
Regulation, Spinning Reserves, Energy, and Capacity. 6 The
Commission directed the Joint Utilities to procure a total of
350 megawatts (MW) of energy storage projects statewide, broken
down into utility-specific goals with 300 MW targeted for Con
Edison and 10 MW for each of the other five investor-owned
utilities. 7 The Energy Storage Order required any projects
procured in the RFP to be in-service by December 31, 2022, with
a seven-year maximum dispatch rights contract. 8 Subsequent
petitions and orders modified the in-service date of contracted
projects to December 31, 2028, and increased the maximum
dispatch rights contract term length to fifteen years for any
future solicitation rounds. 9

5 Energy Storage Order, p. 53.

6 Energy Storage Order, p. 54.
7 Energy Storage Order, p. 55.
8 Energy Storage Order, p. 54.
9 Case 18-E-0130, Order Directing Further Modifications to
Energy Storage Solicitations (issued March 26, 2023) (2023
Modification Order).

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CASE 18-E-0130

In addition to direct storage procurement strategies,

the Commission also encouraged actions in the wholesale market
to facilitate the integration of storage onto New York’s bulk
power system. 10 These actions included eliminating the
application of buyer-side mitigation rules for public policy
resources, including energy storage resources, and development
and deployment of a distributed energy resource (DER)
aggregation model. Since the issuance of the Energy Storage
Order, the NYISO has implemented tariff revisions filed with the
Federal Energy Regulatory Commission (FERC) to eliminate buyer-
side mitigation for energy storage and other public policy
resources, as well as launched its DER Participation Model. 11
In parallel to the actions taken at the NYISO, Staff
has lead the development of distribution and wholesale market
coordination protocols for DERs by way of the Market Design and
Integration Working Group. 12 The working group efforts will help
define the clear delineation and establishment of coordination
procedures for the dispatch of DERs, including energy storage
resources, which is critical to ensuring both the reliability of
the electric system and to maximize the benefits and services
that energy storage can provide.
Thereafter, on December 28, 2022, DPS and NYSERDA
jointly filed the Roadmap, which recommends updates to the
programs established in the Energy Storage Order and examines
how to best achieve the increased energy storage goal. The

10 Energy Storage Order, p. 94.

11 On May 10, 2022, FERC issued an Order accepting NYISO’s tariff
revisions related to the elimination of buyer-side mitigation,
New York Independent System Operator, Inc., 179 FERC ¶ 61,102.
On April 15, 2024, FERC issued an Order accepting NYISO’s
tariff revisions related to DER Participation, New York
Independent System Operator, Inc., 187 FERC ¶ 61,022.
12 Energy Storage Order, pp. 102-103.

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CASE 18-E-0130

Roadmap looks at necessary market reforms, procurement

mechanisms, research and development needs for long duration
storage, and optimal approaches to energy storage deployment in
addition to summarizing progress made since the issuance of the
Energy Storage Order. The Roadmap also analyzes the current
market for energy storage in New York State, thereby serving as
the basis for the Commission’s triennial review of storage
markets, policies and programs as required in the Energy Storage
Order. 13
The analysis used to inform the recommendations
contained within the Roadmap shows a large need for energy
storage in the future, with approximately 12 GWs required by
2040 and more than 17 GWs by 2050. The Roadmap concludes that
updating the current 3 GW goal to 6 GW is necessary to ensure
that the pace of development for energy storage is sufficient to
meet the State’s future energy needs.
On March 14, 2024, DPS and NYSERDA filed an update to
the Roadmap. The update accounts for increased costs related to
inflation that were not present at the time the Roadmap was
filed in 2022.

NOTICE OF PROPOSED RULE MAKING

Pursuant to the State Administrative Procedure Act
(SAPA) §202(1), a Notice of Proposed Rulemaking (Notice) was
initially published in the State Register on January 18, 2023
[SAPA No. 18-E-0130SP13]. The time for submission of comments
pursuant to the Notice expired on March 20, 2023. Moreover, in
the Secretary’s Notice Announcing Webinars and Soliciting
Comments, issued on February 6, 2023, stakeholders were invited
to submit written comments by March 20, 2023, and reply comments
by April 3, 2023.

13 Energy Storage Order, p. 12.

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CASE 18-E-0130

A Notice of Revised Rulemaking (Revised Notice) was

published in the State Register on April 3, 2024 [SAPA No. 18-E-
0130SP13]. The time for submission of comments pursuant to the
Revised Notice expired on May 20, 2024.
In response to the Notice, the Secretary’s Notice, and
the Revised Notice, numerous comments and reply comments were
filed by organizations and individuals. A complete summary of
these comments is included in the Appendices, and responses to
specific comments are addressed in the relevant sections of the
discussion below.

LEGAL AUTHORITY
The Commission has broad jurisdiction, power, and
duties over the “[m]anufacture, conveying, transportation, sale,
or distribution of ... electricity ....” Furthermore, PSL §5(2)
instructs the Commission “[t]o encourage all persons and
corporations subject to its jurisdiction to formulate and carry
out long-range programs ... with economy, efficiency, and care
for the public safety, the preservation of environmental values
and the conservation of natural resources.” The Commission’s
supervision of electric corporations includes the responsibility
to ensure that all charges made by such corporation for any
service rendered shall be just and reasonable. Public Service
Law §66 empowers the Commission to “[p]rescribe from time to
time the efficiency of the electric supply system.” The
Commission may exercise this broad authority to direct
regulatory standards to execute the provisions contained in the
PSL. Additionally, the Commission has the authority to direct
the treatment of DERs by electric corporations.
Pursuant to PSL §74, the Commission is required, by
December 31, 2018, to establish, in consultation with NYSERDA
and LIPA, a statewide energy storage goal for 2030, and a
deployment policy to support that goal. As prescribed therein,
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CASE 18-E-0130

the energy storage deployment policy shall address the

following:
1) avoided or deferred costs associated with
transmission, distribution, or generation capacity;
2) minimization of peak load in constrained areas;
3) systems that are connected to customer facilities
and systems that are directly connected to
transmission and distribution facilities;
4) cost-effectiveness;
5) the integration of variable-output energy
resources;
6) reducing GHG emissions;
7) reducing demand for peak electrical generation;
8) improving the reliable operation of the electrical
transmission or distribution systems; and
9) any other issues deemed appropriate.

The Commission is also required to submit annual

reports on the achievements and effectiveness of the policy to
the Governor, the Temporary President of the Senate, and the
Speaker of the Assembly. 14 The actions directed by this Order
are within the Commission’s regulatory authority indicated
above, and fulfill the requirement that the Commission establish
a statewide energy storage goal and deployment policy.

STATE ENVIRONMENTAL QUALITY REVIEW ACT

On September 15, 2023, in compliance with the State
Environmental Quality Review Act (SEQRA), the Commission
accepted, as complete, a Draft Supplemental Generic
Environmental Impact Statement (SGEIS) which analyzed the
possible environmental impacts related to potential actions

14 PSL §74(4).

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CASE 18-E-0130

recommended in the Roadmap. 15 A Notice of Completion of the

Draft SGEIS was issued by the Secretary on September 15, 2023,
the Notice announced that comments on the Draft SGEIS will be
accepted until October 27, 2023. Additionally, a Notice was
posted in the Environmental Notice Bulletin (ENB) on October 4,
2023. Two parties submitted comments in support of the Draft
SGEIS and suggested the Commission consider additional topics in
the Final SGEIS. The Final SGEIS expanded upon, and responded
to, the topics recommended by the commenters. The Commission
accepted the Final SGEIS as complete on December 14, 2023. A
Notice of Completion of the Final SGEIS was posted in the ENB on
December 27, 2023.

The Commission has considered the information in the

Final SGEIS with respect to the decisions made in this Order,
and hereby adopts the SEQRA Findings Statement, attached to this
Order as Appendix C, prepared in accordance with Article 8 of
the Environmental Conservation Law and 6 NYCRR Part 617.

TRIENNIAL REVIEW
The Commission conducts this triennial review to help
provide certainty to market participants, as directed in the
Energy Storage Order. Based on this review, and the
recommendations in the Roadmap, the Commission expands the
energy storage goal and policies supporting that goal, as
discussed below.

Current Progress and Market Overview

It has been more than five years since the Energy
Storage Order was issued. Since that time, New York has made

15 Case 18-E-0130, Order Accepting Draft Supplemental Generic

Environmental Impact Statement as Complete (issued
September 15, 2023).

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CASE 18-E-0130

significant strides towards achieving its energy storage

targets. The Bridge Incentive, which was created in the Energy
Storage Order with the goal of providing revenue certainty to
the energy storage market for a defined period and deployment
level, accounts for 811 MW of the total energy storage
contracted, with the rest coming from a variety of sources
including the utility bulk storage dispatch rights procurement
process and projects that resulted from the Renewable Energy
Standard (RES).
Today there are more than 40 GWs of energy storage
projects that are in either wholesale or distribution
interconnection queues in New York. Over 38 GWs of these
proposed projects seek to interconnect into the bulk power
system. Although it is possible that many of these proposed
projects will not progress to the construction and operation
stage, the large number of projects that developers are seeking
to construct signals that New York has established itself as a
place where energy storage is highly valued and desired.
The Energy Storage Order established numerous
programs, as discussed above, including the Bridge Incentive and
RFP process for UDR contracts. Each program came with its share
of successes and shortcomings. As of April 24, 2024, the Bridge
Incentive has procured 400 MW of bulk storage projects. Revenue
certainty on the part of developers remains a critical
prerequisite for bulk storage projects to come to fruition.
Through this Order, the Commission aims to maintain this
certainty in the face of challenges such as supply chain issues
and changing market forces.
On the retail side, the Bridge Incentive proved
successful with 320 MW procured on the distribution system

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CASE 18-E-0130

statewide using a declining block structure. 16 Even with this

success, there remains room for improvement by providing longer-
term certainty for funding allotments and block incentive
levels, as discussed in the procurement section below.
The Long Island Residential Incentive is a pilot
residential energy storage incentive program administered by
NYSERDA. 17 This program is intended to spur the deployment of
solar PV coupled with energy storage for use in the LIPA’s
Dynamic Load Management (DLM) program. In addition to the
benefits related to load management, the residential energy
storage incentive provides direct resiliency benefits for the
household during blackout events. After two blocks of
incentives, a total of 1,125 residences on Long Island installed
25.3 megawatt hours (MWh) of energy storage projects. 18 Though
small on an individual level, continued residential adoption of
energy storage on Long Island and all areas of New York will
undoubtedly improve resilience for those homes and the grid in
general.
LIPA has also been in the process of procuring bulk
storage projects. It currently has 10 MW of 8-hour duration
battery storage at two installations on the South Fork of Long
Island. 19 In addition, LIPA has an active bulk energy storage

16 Roadmap, p. 14.
17 NYSERDA, Incentives for Long Island Residents, available at:
https://www.nyserda.ny.gov/All-Programs/Energy-Storage-
Program/Energy-Storage-for-Your-Home/Incentives-for-Long-
Island-Residents.
18 Roadmap, p. 15.
19 LIPA, 2023 Integrated Resource Plan, IRP Summary Guide,
available at: https://www.lipower.org/irp/.

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CASE 18-E-0130

solicitation for at least 175 MW that was issued in 2021. 20

Currently, contract negotiations are nearing the final stages
for three projects (79 MW at Kings Substation, 50 MW at Shoreham
Substation, and 50 MW at West Babylon Substation) totaling 179
MW of 4-hour duration energy storage capability. LIPA board
consideration of the final contracts is expected in June 2024
for the Kings project, November or December 2024 for the
Shoreham project, and March 2025 for the West Babylon project. 21
As discussed above, the UDR contract procurement
process has been refined in order to better attract competitive
bids from developers, through subsequent Commission actions,
resulting in more contracted energy storage MWs and ultimately
built projects. 22 Over time, as the market matures and projects
can expect predictable market revenues, the cost of bids from
developers will likely decrease, increasing the chances of a
successful dispatch rights contract. The dispatch rights
contract framework allows for both new bulk-level energy storage
projects to be deployed in a timelier manner than otherwise
would happen, as well as gives the utility hands-on experience
in operating and dispatching the energy storage resource.
The RES established the requirement that NYSERDA
administer annual solicitations that allow for the pairing of
energy storage resources with large-scale renewable generation

20 PSEG Long Island, 2021 Bulk Energy Storage RFP, available at:
https://www.psegliny.com/aboutpseglongisland/proposalsandbids/
2021bulkenergystoragerfp.
21 LIPA Board Meeting Presentation, Briefing on Energy Storage
RFP, May 22, 2024, available at:
https://www.lipower.org/wp-content/uploads/2024/05/4.-
Briefing-on-Energy-Storage-RFP-1.pdf.
22 See Case 18-E-0130, Order Directing Modifications to Energy
Storage Solicitations (issued April 16, 2021) (2021
Modification Order); see also 2023 Modification Order.

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CASE 18-E-0130

to increase the value of the proposed project. 23 As of April 1,

2024, the RES awarded a total of 20 MW of energy storage
projects, primarily solar and energy storage facilities. The
current solicitation seeks proposals for energy storage and
offshore wind facilities to help integrate the thousands of
megawatts of offshore wind generation that is expected to come
online over the next fifteen years. 24
A New York-sponsored investment fund, the NYGB works
to accelerate the deployment of clean energy in the State by
working with the private sector to transform energy financing. 25
Through this collaborative effort, the NYGB has invested $25
million of its committed $50 million to support energy storage
projects statewide as of December 31, 2023. 26 The primary
finance method utilized by developers so far has been a project
loan where a lender relies on the revenues of the individual
project as the means of repayment and security of the loan. The
NYGB offers alternative finance methods depending on which stage
of development a storage project is in. Products offered by the
NYGB include equipment financing and interconnection loans, tax
equity and incentive bridge loans, and senior term loans.
Combined, these tools help to spur the energy storage market in
New York. This alternative strategy recognizes that a vetted
creditworthy developer, with a long-term contracted project that

23 Case 15-E-0302, et al., Large-Scale Renewable Program and a

Clean Energy Standard, Order Adopting a Clean Energy Standard
(issued August 1, 2016) (CES Framework Order).
24 NYSERDA, Solicitations for Large-Scale Renewables, available
at: https://www.nyserda.ny.gov/All-Programs/Large-Scale-
Renewables/RES-Tier-One-Eligibility/Solicitations-for-Long-
term-Contracts.
25 New York Green Bank, available at: https://greenbank.ny.gov/.
26 Case 13-M-0412, NY Green Bank, Metrics, Reporting & Evaluation
Quarterly Report No. 38 (filed February 29, 2024).

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CASE 18-E-0130

is operational, presents less risk than a proposed project early

in its development that will rely primarily on merchant revenues
in a market that is not yet well tested.
The FERC issued Order No. 841 in February 2018,
requiring Independent System Operators (ISOs) and Regional
Transmission Organizations (RTOs) to revise their tariffs to
enable energy storage resources to participate in the wholesale
markets. 27 Later on, as part of the NYISO’s effort to reform
capacity accreditation values for all resources, FERC approved
its capacity accreditation changes which determine the capacity
value of 4-hour energy storage resources and other 4-hour
duration limited resources based on their marginal capacity
contribution. This new capacity accreditation methodology was
implemented starting in May 2024. Each resource is assigned its
applicable Capacity Accreditation Factor based on its resource
classification.
In addition to the actions the NYISO has taken to
comply with Order No. 841, the NYISO has also implemented a co-
located storage resource (CSR) participation model that allows
an energy storage resource to pair with an intermittent solar or
wind resource behind a single point of interconnection. 28 Each
of the resources operate and are compensated under their
respective participation model, but both are allowed to proceed
in the interconnection process under a single interconnection
request, which saves interconnection costs. The CSR
participation model allows storage and renewables to efficiently

27 Electric Storage Participation in Markets Operated by Regional

Transmission Organizations and Independent System Operators,
Order No. 841, 162 FERC ¶ 61,127 (2018).
28 FERC Docket No. ER21-1001, New York Independent System
Operator, Inc., Proposed Tariff Revisions to Implement Co-
located Storage Resources (filed January 29, 2021).

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CASE 18-E-0130

interconnect and maximizes the benefits of both energy storage

resources and renewable generation effectively.
Building off the CSR model, the NYISO developed a
hybrid storage resource (HSR) model in its stakeholder process. 29
The HSR model design is intended to allow an energy storage
resource and intermittent power resource to participate in the
NYISO markets under a single point identifier, bid, schedule,
and settlement and effectively act as one single resource. Like
the CSR model, the HSR model will allow this combination of
resources to share a single interconnection request.
The NYISO further advanced the integration of energy
storage resources into the wholesale market through FERC’s
acceptance of its DER participation model in January 2020. This
model enables DER aggregations between 100 kW and 20 MW,
including aggregations that contain energy storage, to
participate in the market as one resource. The model also
specifies that each individual resource within a DER aggregation
must be a minimum of 10 kW. FERC also issued Order No. 2222 in
2020, which requires all ISOs and RTOs to revise their tariffs
to allow for the full participation of DERs in the wholesale
market to the maximum extent of their capabilities. 30 As a
result of FERC Order No. 2222, the NYISO was required to revise
its already accepted DER model in order to fully comply with
FERC’s directives. Deployment of the NYISO’s DER model occurred

29 NYISO, Co-located Storage Resource Model Updates (March 20,

2024), available at:
https://www.nyiso.com/documents/20142/43713211/4%20Co-
located%20Storage%20Resource%20Model%20Updates%20032724%20mc.p
df/f6247348-5c8d-8f90-9691-9aa2ea013ad4.
30 Participation of Distributed Energy Resource Aggregations in
Markets Operated by Regional Transmission Organizations and
Independent System Operators, Order No. 2222, 172 FERC ¶
61,247 (2020).

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CASE 18-E-0130

in April 2024. Full implementation of an aggregation model

compliant with Order No. 2222 is estimated in 2026.
On the distribution side of the electric system, the
Commission issued the VDER Order in March 2017. 31 The VDER Order
created a new compensation structure for DERs 5 MWs or smaller,
including energy storage, termed the Value Stack. The Value
Stack is comprised of several components which use price and
locational signals to incent desired operation of the resource.
These components include Energy and Capacity Values based on
NYISO pricing, Demand Reduction Value, Environmental Value, and
Locational System Relief Value. A Market Transition Credit and
Community Credit are also available for Community Distributed
Generation (CDG) projects, although at present each utility has
fully utilized their respective credits. Energy storage
projects benefit from the VDER Order’s compensation structure by
incenting a shift in their output to higher priced hours.
In August 2022, President Biden signed the Inflation
Reduction Act of 2022 (Inflation Reduction Act) into law.
Embedded within this wide-ranging piece of legislation is the
modification of the existing investment tax credit (ITC) that
will help drive development of stand-alone energy storage
projects. 32 Previously, only energy storage projects paired with
solar were eligible to receive the credit. Now, qualified

31 Case 15-E-0751, In the Matter of the Value of Distributed

Energy Resources, Order on Net Energy Metering Transition,
Phase One of Value of Distributed Energy Resources, and
related Matters (issued March 9, 2017) (VDER Order).
32 “The Investment Tax Credit is a tax credit that reduces the
federal income tax liability for a percentage of the cost of a
qualified system that is installed during the tax year.”
Department of Energy, Overview of Inflation Reduction Act
Incentives for Federal Decarbonization, available at:
https://www.energy.gov/femp/overview-inflation-reduction-act-
incentives-federal-decarbonization.

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CASE 18-E-0130

stand-alone residential and commercial storage systems are

eligible for the ITC, which is equal to 30 percent of the cost
of the installed equipment for the energy storage project.
Projects are eligible to receive more than the 30 percent credit
under certain circumstances, such as if the project is located
near a brownfield site or if the energy storage project is
paired with renewable generation and benefits a low-income
community or Native American territory. Further guidance from
the Department of Treasury is forthcoming regarding the specific
use cases where a credit of more than 30 percent is available,
which in turn will inform developer investment decisions in New
York.
NYPA is responsible for generating and transmitting
zero-carbon power to several commercial, industrial, municipal,
and governmental customers. To support this effort, NYPA built
a 20 MW energy storage project in Chateaugay, New York. 33 The
Northern New York Energy Storage Project (NNYESP) takes
advantage of the wind energy in the North Country and St.
Lawrence hydropower plant and has the capacity to power
approximately 3,000 homes. The NNYESP further demonstrates how
storage can help maximize the integration of renewable
generation into New York’s grid. The project became operational
in summer 2023.
The Roadmap recognizes the value and importance of
long-duration energy storage (LDES) in helping maintain a
reliable system. To help spur the development and demonstrate
the efficacy of LDES, NYSERDA has made over $33 million

33 Governor Hochul Announces New York’s First State-Owned

Utility-Scale Energy Storage System Now Operating in North
Country, August 25, 2023, available at:
https://www.governor.ny.gov/news/governor-hochul-announces-
new-yorks-first-state-owned-utility-scale-energy-storage-
system-now.

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CASE 18-E-0130

available in funding for LDES demonstration projects, through

its Innovation Program. Currently, four projects that are aimed
at renewable integration and emission reductions have received
funding. 34 NYSERDA conducted an additional solicitation to
contract with LDES projects with the aim to highlight cost,
performance, siting, and renewable integration difficulties. 35
Role of Energy Storage
The development, installation, and operation of energy
storage in New York is imperative to meet the emission reduction
targets outlined in the CLCPA, and codified in the ECL. 36 As the
State’s electric grid transitions from one historically
dominated by large, fossil-fueled baseload generation to one
comprised of DERs and intermittent renewable generation, energy
storage is one of the key ingredients to ensure this transition
takes place in a reliable manner.
Currently, the peak demand for electricity in New York
usually occurs in the summer months on hot and humid days, when
consumers are maximizing air conditioning use. Over the next 20
years, as electric heat pumps and electric vehicles (EV) become
more prevalent, this historical consumption pattern is expected
to shift towards a winter peak. This shift in demand, coupled
with the expected retirement of high-emitting peaking power
plants downstate, further highlights the need and role for

34 NYSERDA, Nearly $15 Million Awarded to Four Demonstration

Projects to Advance Long Energy Duration Energy Storage
Technology Solutions, August 17, 2023, available at:
https://www.nyserda.ny.gov/About/Newsroom/2023-
Announcements/2023-08-17-Governor-Hochul-Announces-Nearly-15-
Million-in-Long-Duration-Energy-Storage.
35 NYSERDA Long Duration Energy Storage Technology and Product
Development, Product Opportunity notice 5472, available at:
https://portal.nyserda.ny.gov/servlet/servlet.FileDownload?fil
e=00P8z0000034APIEA2.
36 ECL §75-0107.

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CASE 18-E-0130

energy storage. 37 With the retirement of peakers, energy storage

will help meet future peak demand statewide, regardless of the
season, especially in load pockets in New York City and Long
Island.
The transition of the fleet of generation in New York,
from one that can be dispatched for long durations to one in
which there are large quantities of intermittent renewable
generation, requires solutions, such as energy storage, to fill
in the generation gaps. Short-duration energy storage can help
to manage this intermittency on an hourly basis, as well as
store renewable generation and inject it back onto the grid
during high demand and priced hours, or the ability of LDES to
shift renewable generation across days, weeks, or seasons.
Analysis completed for the Climate Action Council
projects that over 60 GWs of solar capacity, 16-19 GWs of
offshore wind, and 16-17 GWs of land-based wind could be added
onto New York’s electric system by 2050. 38 These large,
projected increases in renewable generation highlight the need
for energy storage deployment in order to keep pace. The
analysis completed for the Roadmap indicates that 12 GWs of
short-duration energy storage by 2040 and more than 17 GWs by
2050 are needed to decarbonize the grid in a cost effective and
reliable way. This projected amount of installed energy storage
is a multi-fold increase compared to the current amount of
energy storage in the state; as such, a more aggressive goal of

37 In 2019, DEC established the “Peaker Rule” which requires

owners or operators of simple cycle and regenerative
combustion turbines that are electric generating units with a
nameplate capacity of 15 MW or greater (peaking plants) and
that inject power into the transmission or distribution
systems to comply with emission limits by either retrofitting
controls or shutting down. Six NYCRR Part 227-3.
38 New York Climate Scoping Plan, Chapter 13, p. 221, available
at: https://climate.ny.gov/resources/scoping-plan/.

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CASE 18-E-0130

6 GW by 2030, double the current mandate of 3 GW, is not only

prudent but necessary to ensure that sufficient resources are
online and available by 2030.
It remains the case that the pattern of energy storage
deployment in New York will vary by region, duration, and over
time. Downstate, in New York City and Long Island, energy
storage will help to integrate offshore wind onto the grid and
help solve local reliability needs as decades-old peaking plants
retire. In upstate New York, land is cheaper and more plentiful
for land-based wind turbine development which will drive the
need for energy storage. Through 2030, most energy storage is
expected to be installed downstate, with increasing amounts
located upstate over time; more than half of the projected
needed 17.2 GW of energy storage is expected to be sited upstate
by 2050. Over time, the importance of LDES will grow as the
ability to discharge stored energy across all peak hours is
necessary to help maintain reliability, with the Roadmap’s
analysis indicating that over 70 percent of energy storage
projects will be located in New York City and Long Island.
The size and scope of energy storage projects,
associated development lead time, and interconnection complexity
vary depending on whether the project is residential, retail, or
bulk. Each of these market segments exist at different scales
and provide unique benefits to New Yorkers. Residential energy
storage is usually small, at an average of less than 10 kW, and
can be developed and installed quickly, giving the customer
added resiliency during black outs and the ability to
participate in utility demand response programs. Retail
projects, sized under 5 MWs, have a considerably longer
development time, averaging three years; despite the long
development time, attrition in retail projects is low. Bulk
projects, considered 5 MWs and larger, are expected to make up

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CASE 18-E-0130

the most installations in the state on a capacity basis,

highlighting the need for this critical resource, with
development and installation timelines of bulk projects taking
up to six years; these bulk storage facilities can replace
peaking plants and integrate a large amount of renewable
generation.
Storage Deployment Barriers
New York made it clear in the CLCPA that encouraging
the development and installation of energy storage is paramount
to transiting the electric system from one primarily fueled by
fossil fuels to one powered by zero-emission resources. In
furtherance of the policy goals in the CLCPA, progress towards
storage deployment in New York is underway, with a number of
energy storage projects coming online and many more in the
interconnection queue. Despite this progress, there are certain
barriers remaining that prevent energy storage from reaching its
full potential.
One barrier that has hindered the timely development
of energy storage resources is the rise in supply costs for
lithium-ion batteries since 2022. The materials that are used
in battery manufacturing are in high demand as battery use in
all facets of society has proliferated, such as increased
battery demand for EVs. Supply and demand dynamics are
impacting the ease and speed with which energy storage
developers can move energy storage projects from the design
phase to the construction phase. While New York cannot control
all the factors that go into construction costs, by remaining
technology neutral in energy storage deployment and funding, the
State can encourage a variety of technology types to compete for
project incentive awards, which may potentially drive down
costs.

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CASE 18-E-0130

Currently, the revenues available to energy storage

resources in the wholesale electricity markets are not adequate
for merchant storage resources to be economic. 39 The continued
replacement of retired fossil generation with intermittent,
renewable energy on the bulk power system may lead to periods of
low or even negative prices, giving energy storage an
opportunity to charge cheaply and then discharge into the grid
later when energy prices are higher. On the capacity market
side, the final values for capacity accreditation will impact
how much capacity revenue an energy storage resource can expect
to receive. The NYISO’s recent implementation of an Operating
Reserve requirement in New York City provides energy storage
resources with a locationally specific price signal and provides
an opportunity for additional market revenue that energy storage
resources are well situated to compete for. The NYISO is
currently evaluating the need for other geographic specific
Operating Reserve requirements for load pockets in the state.
The Operating Reserve requirements may provide further wholesale
market revenue opportunities to energy storage resources.
Obtaining adequate financing terms for energy storage
projects remains a challenge for developers and impacts the
viability of those projects. The uncertainty of revenue
available under wholesale and distribution tariffs makes
incentives and funding programs critical to getting energy
storage projects from concept to reality. Over time, as revenue
predictions become more accurate due to historical performance
and availability of data, the level of incentives required for
energy storage resources should decrease.
Based on this triennial review, the Commission finds
that while we have made progress, there is a significant amount

39 Merchant storage resources are those that are developed

without receiving subsidies or other outside support.

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CASE 18-E-0130

of work before us. The Roadmap has provided us with many

options to consider that will help us to build upon our success
and to achieve our clean energy targets. We address those
options and next steps forward below.

DISCUSSION

Bulk Energy Storage Procurement Program Design

As the Roadmap notes, bulk scale energy storage is
expected to play the largest role in terms of nameplate capacity
in New York achieving the 6 GW by 2030 goal. The Roadmap
describes six potential paths towards achieving 3 GWs of bulk
level energy storage needed by 2030. These six options are
summarized below.
Bulk Program Design Summary
Upfront Rebate/Standard Offer Incentive: The Upfront
Rebate/Standard Offer Incentive would offer payments to
developers on a per kW or kWh of installed capacity basis.
Projects would receive a contract for a fixed dollar amount over
the contract term length.
Index Storage Credit: The Index Storage Credit (ISC) would
function similarly to the Index Renewable Energy Credit (REC)
approach used in the large-scale renewable procurements. 40
Storage developers would bid in a “Strike Price” which reflects
the developer’s assumption of revenue for the energy storage
project and compare that to a “Reference Price” which would be
calculated based on price indices representing expected revenue
from the NYISO’s Energy and Capacity Markets. The ISC would be

40 Case 15-E-0302, supra, Order Adopting a Clean Energy Standard

(CES Order) (issued August 1, 2016). More information on RECs
can be found at: NYSERDA, FAQs for Load Serving Entities,
available at: https://www.nyserda.ny.gov/All-Programs/Clean-
Energy-Standard/LSE-Obligations/FAQs-for-Load-Serving-
Entities.

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CASE 18-E-0130

equal to the Strike Price minus the Reference Price. If the

Strike Price exceeds the Reference Price, then NYSERDA would pay
out the difference to the developer. On the other hand, if the
Strike Price was lower than the Reference Price, the project
would owe NYSERDA a payment.
Preset Hourly Revenue Support/”Clean Peak Credit”: This option
would give energy storage resources the opportunity to receive
additional compensation for discharging during predefined peak
hours, determined by NYSERDA, to incent operation during the
most critical times for the system.
Utility Ownership with Traditional Market Participation: In this
option, the utility would seek contracts for market-based
projects where the utility would solicit developers to build the
energy storage resource to the utility’s requirements, and then
transfer the project to the utility to own and operate either
immediately or after a period specified in the contract.
Utility Dispatch Rights Contract: This would continue the
existing framework approved in the Energy Storage Order for the
utilities to enter into contracts for operational control of an
energy storage resource developed and owned by a third party. 41
Utility Ownership for Transmission and Distribution Services:
This option recognizes that certain revenue streams, including
transmission and distribution services, are not currently
available to energy storage resources. This option would give
the utilities an opportunity to study their systems and identify
where specific transmission and distribution services are
needed, with the end result being the ability to develop and
provide energy storage resources in appropriately targeted
areas.

41 Energy Storage Order, p. 53.

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CASE 18-E-0130

Roadmap Recommendations
In determining which of the above program designs
offers the best path forward, the Roadmap examined
implementation feasibility, development effectiveness,
efficiency, and compatibility/acceptability. Based on these
criteria, the Roadmap recommends pursuing a program design based
on the ISC mechanism to procure 3,000 MWs of bulk energy storage
through three procurement solicitations, targeting 1,000 MWs in
each solicitation. 42
The proposed ISC mechanism is similar in structure to
the already-approved and in-use Index REC structure where
NYSERDA purchases RECs created by the generation of each MWh of
clean energy by renewable resources. For the proposed ISC
program, an ISC would be generated for each MWh of energy
storage capacity that is operational and available on a given
day (i.e., not during an outage or during maintenance) and not
how much the energy storage resource discharges, to incent
prudent injections to the grid when needed. The relationship
between the Strike Price and Reference Price, as described
above, would ensure that energy storage owners remain exposed to
market prices and maintain an incentive to inject energy when
wholesale prices are high.
Based on historical and previous program data, the
Roadmap recommends a contract term of 15 years. The Roadmap
reasons that this length of time is long enough to reduce
financial risks for the energy storage resource and short enough
that the contract would not extend beyond the useful life of the
asset.
The Roadmap recommends that any electric, chemical,
mechanical, or thermal-electric energy storage technology be

42 Roadmap, p. 49.

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CASE 18-E-0130

eligible for the bulk program. Additionally, the Roadmap

recommends that the Commission require projects to electrically
interconnect into New York’s transmission and distribution
systems.
The Roadmap suggests giving NYSERDA flexibility to
determine specific duration requirements for bulk solicitations.
In the near term, the solicitations are expected to attract
energy storage resources with durations ranging from 4 to 8
hours, with the Roadmap recognizing the value that energy
storage with an 8-hour or more duration adds in maintaining
reliability and integrating large amounts of renewable energy in
later years. Giving flexibility for NYSERDA to determine if
specific durations are necessary in a bulk procurement would
help drive the investment of the type of required energy storage
resource when they are needed.
The Roadmap recommends against applying a payment cap
in the ISC program. A payment cap establishes a maximum payment
level that can be paid from a project to NYSERDA or vice versa.
The Roadmap describes the benefits of the ISC design (e.g.,
being able to avoid incentive payments when unnecessary and
provide ratepayer benefits by reducing financing costs for
projects) and therefore a payment cap would interfere with this
mechanism.
Similar to NYSERDA’s onshore and offshore large-scale
renewable procurement program, the Roadmap recommends allowing a
one-time inflation adjustment for pre-determined cost indices in
the time between the project’s bid and when it commences
construction. This inflation adjustment would reduce the risk
that inflation and cost uncertainties have on bulk energy
storage projects that have multi-year development timelines.
The Roadmap recommends that the NYISO zonal locational
based marginal pricing (LBMP) day-ahead energy market pricing be

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CASE 18-E-0130

used for the energy price component of the Reference Price

calculation, consistent with the Index REC structure, as day-
ahead pricing is more stable and easier to implement than real-
time pricing.
Energy storage is uniquely situated in that it is not
solely a generation resource, as it needs to charge by using
grid or other site-generated power. As such, an energy storage
resource’s ability to earn energy revenue derives from its
ability to capitalize on arbitrage opportunities by charging
during low energy price periods and discharging when prices are
high. The Roadmap recognizes this and recommends establishing a
Reference Energy Arbitrage Price (REAP) that calculates the
arbitrage opportunity using the difference between the prices in
the top and bottom 4 hours in the day-ahead market for a 4-hour
duration resource and in the same manner for longer duration
resources (e.g., top and bottom 8 hours for an 8-hour energy
storage resource). The use of a REAP gives flexibility to allow
for more hours for longer duration resources; the average of
this daily calculation would apply over the calendar month. The
Roadmap notes the presence of round-trip efficiency losses but
recommends excluding these losses from the REAP due to the
additional complexity of determining roundtrip losses that vary
by project and the fact that this incents the most efficient
energy storage technology to participate in the bulk procurement
program.
The other component of the Reference Price is the
Reference Capacity Price (RCP). The Roadmap recommends
utilizing the NYISO locational-specific Installed Capacity
(ICAP) spot auction prices to calculate the RCP due to its ease
of implementation and high level of participation in the auction
which results in an optimal hedging structure. The Roadmap
further recommends calculating the RCP by adjusting the monthly

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CASE 18-E-0130

spot NYISO ICAP auction locality price according to the relevant

Capacity Accreditation Factor for each duration length of energy
storage. The Roadmap contemplates that NYSERDA would publish
the final RCP formula that will be used in the solicitations
after the NYISO’s accreditation process concludes. To balance
administrative efforts with maintaining sufficient value for
selected bulk energy storage projects, the Roadmap recommends
monthly settlements, consistent with previous program designs.
The Roadmap also recommends that ISC contracts be designed in a
way that allows them to be modified if future wholesale market
rule changes alter the available revenue streams to energy
storage resources.
The Roadmap recommends that NYSERDA evaluate both
price and non-price factors when evaluating bulk energy storage
solicitation bids. Price factors would include ISC costs based
on zonal energy and spot capacity price forecasts, while non-
price factors could include the viability of a project, economic
and social benefits, or ability of the project to displace
peaking plants. The Roadmap contemplates that NYSERDA would
describe such qualitative evaluation criteria in each
solicitation. The Roadmap also recommends that the ISC
procurements apply a maximum bid price evaluation metric, in the
form of a maximum levelized ISC cost, to help protect ratepayers
and help in the screening of bids, similar to the Clean Energy
Standard (CES) large-scale renewable program procurements.
The Roadmap also recognizes the value of energy
storage statewide but notes particular importance in the near-
term of locating storage assets in New York City and Long
Island. These densely populated areas are home to many of the
oldest and highest-emitting peaking power plants in the State,
presenting an opportunity for energy storage to help replace
these high-pollution-emitting resources.

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CASE 18-E-0130

The most valuable attribute for energy storage

resources on the electric system is the ability to quickly
provide energy to the grid when needed, including for periods
over multiple hours. The Roadmap’s analysis indicates that over
4 GWs of 8-hour storage will be needed by 2035, with 70 percent
of this sited in New York City and Long Island.
Lastly, the Roadmap suggests that the contract terms for
bulk energy storage projects can be renegotiated if there are
market rule changes that make the existing terms obsolete or
unworkable.
Comments
Most stakeholders, representing various sectors
including developers, trade organizations, and utilities,
expressed support for adoption of the ISC mechanism. Multiple
Intervenors (MI), an unincorporated association of over 55 of
New York State’s industrial, commercial, and institutional
energy consumers, opposes the ISC and adoption of the Roadmap in
general, stating the Commission needs to take a holistic look at
the cost of the proposed energy storage programs and other
Commission approved programs and the negative impact this has on
large power consumers and businesses in New York. Alliance for
Clean Energy New York (ACE NY), AES Clean Energy Development
(AES), New York City (City), the investor-owned utilities,
Convergent Energy and Power (Convergent Energy), Hydrostor, Key
Capture Energy, New York Solar Energy Industry Association
(NYSEIA), NY-BEST, and Rise Light & Power all request that the
Commission approve the ISC mechanism. New York City recommends
that a performance metric that evaluates energy storage
operations be implemented as part of the bulk procurement
program, as battery performance is more important than installed
MWs of energy storage capacity.

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CASE 18-E-0130

Several stakeholders including NY-BEST, ACE NY,

Hydrostor, and Alsym Energy disagree with the Roadmap’s
recommendation to not include Round Trip Efficiency (RTE) as
part of the REAP calculation, as RTE can greatly impact an
energy storage resource’s charging costs and is reflective of
how an energy storage resource operates. NY-BEST suggests an
assumed 85 percent RTE for 4-hour energy storage.
Commenters note that one of the biggest unknowns in
the bulk storage solicitation process is how much of the
contracted MWs will actually proceed through the development and
interconnection phase and enter commercial operation. Attrition
remains a large problem for bulk energy storage. 43 Noting both
the need for 3,000 MWs of bulk energy storage and the
historically high attrition rates of bulk energy storage
projects, several commenters, including ACE NY, Key Capture
Energy, and NY-BEST, recommend accounting for potential
attrition as part of the solicitation process. Commenters
suggest procuring more than the proposed 1,000 MWs in each of
the three planned solicitations and in the event that a project
is cancelled, the project’s expected MW can be re-allocated to a
future solicitation. The City recommends yearly assessments of
attrition to ensure sufficient bulk energy storage, especially
in New York City, is timely developed.
To help better gauge how likely an energy storage
project is to advance from concept to development to operation,
several commenters including BlueWave, Convergent Energy, ACE
NY, Strategic Project Management (SPM), and NY-BEST recommend
implementing maturity milestone requirements as part of the bid
evaluation process. These milestones could include having the
necessary permits to begin construction or making

43 100 MWs of bulk energy storage were withdrawn from NYSERDA’s

bulk energy storage program during the planning stage.

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CASE 18-E-0130

interconnection queue deposits. The idea behind maturity

milestone requirements is that less project attrition occurs
because projects that are more advanced in their development and
have the necessary permits are more likely to continue to
construction and eventual operation.
AES recommends location specific carveouts as part of
the bulk procurement process to help direct development of
energy storage where they are most needed.
Several commenters, including Bloom Energy, Nucor
Steel, AES, Form Energy, and NineDot Energy (NineDot) recognize
that long duration storage is critical to New York’s clean
energy transition and recommend special consideration be given
to procuring sufficient amounts of these long duration energy
storage resources.
Key Capture Energy comments that limiting ISCs to only
days when an energy storage resource is operational may result
in unwanted market behavior, and suggests that ISCs should be
generated each day an energy storage resource is interconnected
to the electric system.
The 15-year contract term proposed in the Roadmap for
bulk resources is based on best available information for the
typical useful lifespans of common energy storage technologies.
Clearway Energy Group and Hydrostor recommend increasing the
allowable contract length to at least 20 years or longer to
reflect that different energy storage technologies have varied
lifespans. Clearway Energy Group also notes that the longer
contract term allows developers to amortize their costs over a
longer period and in turn receive more favorable financing
terms.
NY-BEST, ACE NY, the Independent Power Producers of
New York (IPPNY), and Key Capture Energy agree that there should
be an avenue available to alter contract terms in the event of a

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CASE 18-E-0130

major new market rule change but cautions that only long-term,
sustained price changes should trigger a contract renegotiation,
rather than the short-term price spikes and falls, for which the
ISC is designed to take into account. Commenters state that any
change of contract provisions should be structured to minimize
adverse financing outcomes.
Commission Determinations
Index Storage Credit
The Commission is persuaded that the ISC mechanism is
a viable path forward for the State to meet its bulk energy
storage deployment goals. The ISC mechanism balances the need
to provide developers with revenue certainty, so that energy
storage projects progress from concept to commercial operation,
while protecting ratepayers from overspending on this bulk
energy storage program if developer revenues from the wholesale
market are more than anticipated. The Commission therefore
adopts the ISC mechanism for bulk energy storage procurements as
described in the Roadmap and directs NYSERDA to conduct a
minimum of three bulk energy storage procurements, to be held no
less than annually, to procure 3 GW of bulk energy storage. The
Commission directs NYSERDA to issue the first RFP no later than
June 30, 2025. NYSERDA shall publish the final RCP formula with
its bulk energy storage solicitations, using NYISO’s capacity
accreditation, and describe the qualitative factors it will
evaluate when ranking bids. 44
Inclusion of Round-Trip Efficiency in the Reference Energy
Arbitrage Price
The Commission notes multiple parties’ comments
advocating for the inclusion of RTE as part of the REAP
calculation. After consideration of these comments, the

44 NYISO, Capacity Accreditation, available at:

https://www.nyiso.com/accreditation.

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CASE 18-E-0130

Commission declines to adopt RTE as part of the REAP

calculation. The inclusion of RTE creates added complexity as
each project, depending on technology and individual operation,
will have a different RTE. Instead, developers should
incorporate RTE losses and associated revenue impacts as part of
their Strike Price bid.
Geographic Carveouts
The Roadmap’s analysis made clear, and the Commission
recognizes, that different areas of New York State vary in terms
of timing and quantity of energy storage. Certain regions, such
as Long Island and New York City, are especially ripe for the
replacement of peaker plants with energy storage resources and
the associated emission reduction directly benefiting those
communities. The Roadmap acknowledges the need to carve out 35
percent of program funding for regions with peaker plants in
accordance with CLCPA guidelines for disadvantaged communities. 45
Therefore, we address specific geographic carveouts later in
this Order where we discuss requirements for disadvantaged
communities under General Program Design Considerations.
Duration Carveouts
NYSERDA and Staff’s analysis in the Roadmap recognizes
that longer duration energy storage resources will be needed to
help replace retiring fossil-fueled generation, meet peak
demand, and maintain reliability. The Roadmap estimates that
over 4 GW of 8-hour energy storage will need to be deployed by
2035 and 6.8 GW by 2050. Acknowledging this need for long
duration bulk energy storage in New York, and the amount of lead

45 The CLCPA defines “disadvantaged communities” as communities

that bear burdens of negative public health effects,
environmental pollution, impacts of climate change, and
possess certain socioeconomic criteria, or comprise high-
concentrations of low- and moderate-income households. ECL
§75-0101(5).

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CASE 18-E-0130

time it takes to develop these types of projects, the Commission

directs NYSERDA to include in each bulk procurement a target of
20 percent of long-duration, 8-hour energy storage resources, to
move New York towards installing the necessary amount of LDES by
the mid-2030s. This 20 percent target is meant to send a clear
signal to developers that LDES is needed in the State and to
recognize the amount of time needed for these resources to
proceed through the planning, development, and interconnection
processes. The Commission also recognizes that, presently, LDES
may not be as competitive compared to shorter duration energy
storage solely based on cost, but that there are attributes and
benefits of LDES that are important to New York’s energy
transition. Therefore, the Commission directs NYSERDA to
include how it would procure and account for the additional
attributes and benefits of LDES in its Implementation Plan, as
discussed in more detail below.
Operational Requirements
The Roadmap contemplates only crediting ISCs on days
when the energy storage resource is operational and available
for dispatch. The Commission agrees with this approach. The
intent of building out energy storage resources statewide is so
that they are available to inject power when it makes economic
sense to do so, or soak up excess renewable output. Generating
ISC credits for energy storage resources on days when there is
no chance for them to benefit the electric system runs counter
to this goal. Projects are incented to discharge when it makes
economic sense due to the Reference Price component of the ISC
calculation; if an energy storage resource does not discharge
when market prices are high it will lose out on that revenue and
potentially be required to make a payment to NYSERDA. The
Commission directs NYSERDA to adopt this operational requirement
for the ISC mechanism when calculating the ISC payment.

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CASE 18-E-0130

Additionally, NYSERDA shall describe this requirement in its

Implementation Plan.
Contract Term
The ISC contract term proposed in the Roadmap is 15
years. In the Roadmap, Staff and NYSERDA reason that the
proposed term of 15 years is appropriate given that it matches
the typical lifespan of the lithium-ion batteries frequently
utilized for bulk energy storage. The Commission acknowledges
that lithium-ion batteries are likely to be the most prevalent
energy storage technology type at this point in time, but also
recognizes the diversity of energy storage technologies that
currently exist, including iron-flow batteries and compressed
air energy storage, among others, as well as future technologies
that do not yet exist.
Technology neutrality is one of the core principles
guiding the State’s energy storage deployment policy. In this
vein, the Commission does not want to artificially limit
contract length terms for technologies that have longer
lifespans than lithium-ion batteries. Many of these non-
lithium-ion technologies are geared towards achieving long
duration output which, as discussed above, are critical to
reliably transition New York’s energy system. Therefore, the
Commission directs NYSERDA to ensure that contract terms for
lithium-ion batteries be allowed for terms of no more than 15
years, while contract terms for non-lithium-ion storage
technologies be allowed for terms of up to 25 years.
Inflation Adjustment
Consistent with the Commission’s finding in the
onshore and offshore large-scale renewable energy procurement
programs, the Commission adopts the Roadmap’s recommendation to
allow for a one-time inflation adjustment as part of the bulk
energy storage program design. This one-time inflation

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CASE 18-E-0130

adjustment, between the time a project developer submits its

Strike Price and the commencement of construction, gives
developers an opportunity to reflect new cost realities that
were not present at the time of submission of their initial
Strike Price bid, such as increased material and labor costs.
The long development timeframe of bulk scale energy storage
resources, similar to that in the large-scale renewables
program, makes this one-time inflation adjustment reasonable.
The Commission directs NYSERDA to implement the one-time
inflation adjustment as it implements the ISC procurement
contracts. Additionally, NYSERDA shall include this requirement
in its Implementation Plan.
Maturity Requirement
The Commission wants to minimize the risk of project
attrition; each project that fails jeopardizes the achievement
of the energy storage goal. A maturity requirement is one way
to help reduce project attrition and delay of the deployment of
energy storage resources. Given the importance of reducing
project attrition, the Commission directs NYSERDA to include
certain project maturity requirements in its bulk energy storage
solicitations and in its Implementation Plan. At a minimum, the
maturity requirements shall include that projects must
demonstrate: (1) proof of a completed Coordinated Electric
System Interconnection Review; (2) a record of making a 25
percent interconnection deposit or have a signed and executed
interconnection agreement if there are no network upgrades
needed; (3) possession of all non-ministerial permits; and (4) a
review of the project pursuant to the State Environmental
Quality Review Act, including a full environmental review if the
project does not meet the criteria for a negative declaration.
NYSERDA may, in consultation with DPS Staff, choose to require
additional maturity milestones in later bulk energy storage

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CASE 18-E-0130

solicitations based on attrition rates from contracted projects

in earlier solicitations.
Utility Dispatch Rights Request for Proposals
The Energy Storage Order established the utility bulk
storage dispatch rights RFP process whereby the State’s
investor-owned utilities were required to conduct bulk energy
storage procurements, with the goal of contracting for a minimum
of 350 MWs statewide, under the framework that the cost of the
contracted megawatts was less than the utility-specific bid
ceiling. 46 The utility would then maintain operational control
of the energy storage resource for the duration of the contract
term, the maximum length of which was originally established in
the Energy Storage Order. At the end of the contract term, the
energy storage resource asset owner has the option to continue
operating as a merchant resource in the market. 47
The Joint Utilities state their support for the
continuation of the bulk solicitation program as another tool to
use to procure bulk energy storage, and notes that solicitations
are currently underway. NYSERDA currently has approximately $68
million in incentive funding allocated for this program still
available; the Commission directs NYSERDA to continue to use
these funds for this purpose. Therefore, while today’s Order
approves the ISC mechanism described in the Roadmap, the
Commission affirms that utilities shall continue the bulk
storage dispatch rights RFP process, and that they can utilize
the NYSERDA incentives for this purpose if necessary. The
Commission directs Staff to continue to monitor the need to make

46 Energy Storage Order, p. 55.

47 Since the establishment of this paradigm, the Commission has
issued two modifying Orders to alter the maximum allowable
contract term length and in-service date requirements. See
2021 Modification Order and 2023 Modification Order.

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CASE 18-E-0130

any additional modifications to the RFP process based on the

results of the current and future bulk storage solicitations.
Retail Energy Storage Procurement Program Design
Roadmap Recommendations
The Roadmap notes the continued importance of retail
energy storage as a contributor to reliability and the
management of peak energy demand on the utilities’ distribution
networks. The region-specific, declining block incentives for
retail level storage, established in the Energy Storage Order,
for projects sized 5 MWs or less was successful in procuring 279
MWs of energy storage projects as of March 2024. Recognizing
this success, the Roadmap recommends continuing funding for the
Retail Storage Incentive and utilizing the same regional
declining block structure as described in the Energy Storage
Order, with the goal of procuring an additional 1,500 MWs of
retail energy storage by 2030. The Roadmap recommends
maintaining a high project maturity requirement to reduce
attrition of contracted projects. As part of program
implementation, the Roadmap recommends sizing funding blocks
based on the system benefits of projects as well as the funding
requirements for each region; the analysis of system benefits
includes whether the project benefits disadvantaged communities
and alleviates system bottlenecks. The Roadmap notes that a
backlog of mature retail energy storage projects has developed
since program funding ran out and recommends the regional
funding block sizes reflect this reality so that these mature
projects can be commissioned expeditiously.
The Roadmap recommends that NYSERDA provide
stakeholders with a detailed analysis of its region-specific
incentive rate and forecasts of future incentive rates. The
Roadmap posits that this transparency would provide certainty
into how NYSERDA calculates the incentive rate blocks, and would

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CASE 18-E-0130

allow developers to plan based on the projected future incentive

blocks. Communicating any changes to the incentive blocks to
developers is important to help guide investment decisions. The
Roadmap further recommends that NYSERDA develop a public-facing
calculator for VDER storage projects statewide, to give
developers and other stakeholders more knowledge on where in New
York energy storage is most valuable under the VDER standard.
Comments
Commenters are generally in agreement regarding the
continuation of the region-specific declining incentive block
structure, noting its popularity and success. ACE NY recommends
an initial block size of at least 750 MWs, as well as
establishing a separate incentive block for solar-plus-storage
projects in NYISO Zones A-G, noting that paired projects are not
subject to demand charges and have additional revenue streams
available to them compared to standalone storage. BlueWave
supports the declining block incentive structure and recommends
a per-project incentive capped at 20 MWh, not the proposed 15
MWh cap, noting the maximum size of 5 MWs for a project and a
minimum of 4-hour duration, in addition to the need for maturity
thresholds such as having all necessary permits and
demonstration of site control for 15 years to limit attrition.
Convergent Energy also recommends increasing the incentive cap
to 20 MWh and establishing a separate upstate solar-plus-storage
paired incentive. The Indicated Utilities, consisting of
Central Hudson, National Grid, and NYSEG/RG&E, support the
proposed retail storage incentive and comment that program
designs should consider how disadvantaged communities will
benefit. NineDot supports the proposed retail storage incentive
as necessary to provide the missing money for developers, and
recommends that a working group form to examine retail storage
deployment on Long Island. NY-BEST recommends increasing the

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CASE 18-E-0130

incentive cap to 20 MWh and including maturity requirements for

projects to receive awards. Sunkeeper Solar recommends a
carveout in the retail storage incentive for projects sized
between 100 kW and 1 MW located in New York City, reasoning that
smaller projects move quicker through the interconnection
process than 5 MW projects.
Commission Determinations
Regional Declining Block Structure Incentive Design
The Commission approves the proposed region-specific
declining block retail storage incentive structure as discussed
in the Roadmap, with the goal of procuring an additional 1,500
MWs of retail energy storage across New York by 2030. The
regional declining block retail incentive design has been shown
to be effective, as evidenced by the more than 275 MWs of retail
energy storage resources that have been procured since the
issuance of the Energy Storage Order. There is no new evidence
that would suggest that a departure from this structure would
result in increased procurements. The Commission directs
NYSERDA to implement the region-specific declining block retail
storage incentive structure.
The Roadmap recognizes that there are several hundred
MWs of mature retail storage projects that were unable to access
the funding approved in the Energy Storage Order before it ran
out, and recommends that the first incentive block be
appropriately sized to accommodate this expected interest. The
Commission declines to establish a specific MW amount for the
first and subsequent incentive blocks, leaving that flexibility
to NYSERDA based on the most current market conditions, but
otherwise agrees with the Roadmap’s recommendations. The
Commission directs NYSERDA to provide a description of how
incentive amounts are calculated and forecasts of future
incentive blocks in its Implementation Plan. This information

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CASE 18-E-0130

will be critical for developers to make informed investment

decisions and propose projects that will provide the most value
to the state’s electric system. In the event that NYSERDA
considers changing the incentive blocks, it shall consult with
DPS Staff and seek stakeholder input. NYSERDA shall document
these changes in an updated Implementation Plan.
The Commission also agrees that NYSERDA should develop
a publicly accessible calculator for VDER storage projects
statewide to maximize the amount of information available for
interested stakeholders. The Commission directs NYSERDA to
develop this statewide storage VDER calculator as part of its
Implementation Plan, as further discussed below, for retail
energy storage.
Maximum Incentive Cap
The Commission agrees with certain commenters that
20 kWh is an appropriate upper cap for retail energy storage
projects. Limiting the incentive cap to 15 MWh precludes 5 MW
projects with a 4-hour duration from receiving an incentive that
covers their entire output. Projects sized at 5 MW with 4-hour
durations are likely to be prevalent, as 5 MW is the maximum
size allowable under the retail storage program, and a 4-hour
duration is an industry standard. Given that proposed retail
energy storage projects are likely to exceed 15 MWh, the
Commission directs NYSERDA to increase the cap for project
eligibility to 20 MWh and detail this change in its
Implementation Plan. This 20 MWh incentive cap is in line with
the size and duration of expected retail energy storage energy
and will encourage larger retail-sized projects to apply for the
incentive because they will have the ability to inject and
withdraw energy to their maximum technical capabilities.

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CASE 18-E-0130

Establishment of Solar-Plus Storage Incentive

Several commenters, including ACE NY and Convergent
Energy, request that the Commission create a solar-plus-storage
incentive for paired projects located in NYISO Zones A-G. These
commenters reason that energy storage resources paired with
solar are not subject to demand charges, give greater
operational flexibility, and allow for more revenue
opportunities through load management. Commenters further note
that a solar-plus-storage incentive is more appropriate in
Upstate New York, where land is more plentiful and affordable,
than compared to the metro New York region of the state, where
land is at a premium.
The Commission recognizes the value of storage
resources paired with solar but declines to establish a separate
incentive for this type of resource at this time. The goal of
the Energy Storage proceeding is to achieve 6 GW of statewide
energy deployment by 2030. There are programs in New York,
including the NY-Sun program, that address making solar energy
more accessible to homes, businesses, and communities. 48 The
programs, incentives, and budget discussed in the Roadmap,
including for retail energy storage, can be used towards
procuring either standalone storage or storage paired with
solar. Establishing a new incentive for storage-plus-solar
resources would be duplicative of already-established programs.
Size Carveout
Sunkeeper Solar advocated for a retail energy storage
carveout for projects sized between 100 kW and 1 MW in Zone J,
explaining that smaller sized projects can proceed through
development and interconnection faster than larger projects.
Sunkeeper Solar reasoned that a carveout incentive is needed for

48 NYSERDA, NY-Sun, available at: https://www.nyserda.ny.gov/All-

Programs/NY-Sun.

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CASE 18-E-0130

retail energy storage projects of this size in New York City in

order to encourage the installation of more projects. They
state that the installation of more projects would lead to the
Fire Department of New York (FDNY) gaining additional experience
with evaluating energy storage safety issues.
The Commission declines to establish a retail energy
storage carveout incentive for 100 kW- to 1 MW-sized projects in
Zone J at this time. While smaller sized projects historically
have had shorter development and interconnection timelines than
their larger counterparts, deployment of retail sized energy
storage of all sizes, up to the 5 MW limit, is important not
only in Zone J but statewide as well. Establishing a carveout
incentive for smaller sized retail energy storage would send the
signal that this sized project is preferable in New York City,
which is not the case. All retail energy storage, regardless of
size, will be important in getting the State to meet its energy
storage deployment goals. The additional challenges with permit
acquisitions and interconnection for larger projects in New York
City will need to be worked through with the appropriate
stakeholders and will serve as learning opportunities for future
retail energy storage deployments. Similarly, FDNY’s experience
with evaluating energy storage safety is paramount. However, as
there are other avenues to address these concerns, these factors
do not warrant a carveout incentive for smaller resources.
Residential Energy Storage Procurement Program Design
Roadmap Recommendations
The Roadmap notes that, up until this point, the focus
on residential energy storage deployment in New York has been on
Long Island, where LIPA’s tariff allows for residential storage
to provide system services such as peak load management.
However, demand for residential storage exists across New York.
Although its potential contribution to achieving the statewide

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CASE 18-E-0130

storage deployment goal is relatively small, residential storage

is important as it can provide local service benefits, including
improving resiliency for residential customers in disadvantaged
communities. Given the benefits of residential energy storage,
the Roadmap recommends launching a statewide residential storage
program with a focus on maximizing local benefits, especially
for disadvantaged communities, with funding for 200 MWs
available through 2030. The Roadmap recognizes that this
program would require coordination across existing programs at
NYSERDA and the need to design and plan the program specifics
with the State’s investor-owned utilities.
Long-term visibility of funding will be important for
residential energy storage developers to maximize deployment and
educate customers on its benefits. The Roadmap therefore
recommends the program design allow for the availability of
large blocks of funding at stable incentive rates over a minimum
of one year. Any changes to the incentive levels should be
communicated with plenty of lead time so that developers and
homeowners can make informed decisions about whether or when to
participate. The Roadmap further recommends that incentives be
provided to the project developer upfront, rather than as a
rebate, so that homeowners do not have to pay for the full cost
of the project before installation.
The Roadmap recommends that program funding come from
ratepayers statewide. To that end, the Roadmap recommends
exploring how residential energy storage can provide system-wide
benefits through aggregations for demand response programs, and
that the Joint Utilities should examine opportunities for
residential storage in their respective service territories that
will maximize the storage resource’s value. Participation in
the NYISO’s wholesale markets in a DER aggregation is an
additional potential avenue for residential storage to achieve

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CASE 18-E-0130

statewide system benefits. No operational or aggregation

requirements are recommended in the Roadmap. Instead, the focus
is on projects that benefit disadvantaged communities and
building out the network of residential energy storage as a
flexible grid asset.
Comments
Commenters generally support the creation of a
statewide residential storage program, with some offering
recommendations for changes to specific aspects of the Roadmap’s
proposal for a residential energy storage program. ACE NY
recommends that the initial block size for residential and
retail incentives be at least 750 MWs, noting that NYSERDA has
discretion to change as needed. It also recommends that 35
percent of the 200 MW residential storage projects be located in
disadvantaged communities, consistent with CLCPA directives.
DER Parties, composed of Sunrun Inc, PosiGen Inc, SunPower Corp,
and Tesla, support the Roadmap recommendation to expand the
residential storage program statewide and to provide an upfront
incentive for developers to support early adoption, with an
added incentive for projects located in disadvantaged
communities. DER Parties and the NYSEIA highlight the need for
the Joint Utilities to explore programs such as “bring-your-own-
device" that would allow customers to participate in utility
load reduction programs, like the program that is currently
approved in LIPA’s service territory. DER Parties agree with
NYSEIA that the Roadmap’s target of procuring 200 MWs of
residential energy storage is too low, and recommend increasing
it to 400 MW to reflect the need and demand for this resource
more accurately.
Commission Determinations
Installation of residential energy storage provides
numerous benefits to New Yorkers, including providing backup

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CASE 18-E-0130

power during power loss events, allowing for participation in

utility load management programs, and charging power for
electric vehicles. The potential for residential energy storage
to positively impact disadvantaged communities further
highlights the importance of establishing a statewide
residential energy storage program. Therefore, the Commission
adopts the Roadmap’s recommendation to launch a statewide
residential energy storage program, to be administered by
NYSERDA. Funding for the program will be available until at
least 2030 to support the buildout of 200 MWs of residential
energy storage across New York, with a minimum of 35 percent of
funding dedicated for projects in disadvantaged communities.
NYSERDA shall include the details of this program in its
Retail/Residential Implementation Plan.
Size of Program
The Commission declines to increase the residential
energy storage target to 400 MWs, as was requested by DER
Parties and NYSEIA. As described in the Roadmap, 200 MWs is an
appropriate statewide target, balancing the need for deploying
residential energy storage statewide to maximize benefits for
homeowners and disadvantaged communities, with achieving
sufficient energy storage buildout to meet the 6 GW goal by
2030. Experience gained through this first iteration of a
statewide residential energy storage program will inform any
subsequent modifications to size and incentive structure. As
such, the adopted 200 MW target should be viewed as an initial
goal, and if additional funding allotments for residential
energy storage is necessary based on demand and pace of
deployment, the Commission may consider such requests and
increase the target and funding at that time.

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CASE 18-E-0130

Residential Energy Storage in Disadvantaged Communities

The Commission agrees with the Roadmap’s observation,
and Commenters’ suggestion, that residential energy storage can
play a role in maximizing local benefits in disadvantaged
communities. The small size of residential energy storage makes
it a potential tool for residential customers to participate in
utility demand response programs, allowing customers to earn
money for shifting their electricity demand to off-peak hours
while helping the utility company manage their distribution
system. Additionally, the Commission is already considering the
participation of residential energy storage in demand response
programs. 49 The Commission notes that the Joint Utilities were
directed to submit proposals for including energy storage in
their Direct Load Control Programs in their 2024 annual report
and expects that this process will help to enable a path for
residential energy storage to participate in utility demand
response programs.

WHOLESALE MARKET ACTIONS

Roadmap Recommendations
It is vital that wholesale market rules and revenue
opportunities work in conjunction with retail-level programs and
revenue streams to help achieve state policy goals for energy
storage at a just and reasonable cost. The Roadmap notes that
the ITC, available under the Inflation Reduction Act, will
provide significant support for storage projects, but is still
insufficient to cover the costs of developing energy storage.
The Roadmap further states that wholesale market revenues are
currently inadequate to support the energy storage development
needed. Wholesale market revenue is a key input into the

49 Case 14-E-0423, Dynamic Load Management Programs, Order

Directing Dynamic Load Management Program Changes (issued
March 15, 2024), pp. 18-9.

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CASE 18-E-0130

calculation of the REAP and RCP, highlighting the need to ensure

wholesale prices accurately reflect system needs. Working with
the wholesale market operator and its stakeholders to close
these gaps and align market rules with state policy goals
remains a critical part of achieving these goals most
efficiently.
The Roadmap states that energy storage projects can
increase efficiency on existing transmission lines by injecting
and absorbing energy, which could defer the need for system
upgrades. Storage resources can also help stabilize power
flows, allowing operators to avoid more costly operations.
Energy storage can also be incorporated into planning processes
to reduce the cost of transmission investment.
The NYISO and its stakeholders are currently working
on a project, Storage as Transmission, which was originally
proposed by NYSERDA. 50 This project seeks to evaluate potential
use cases and market rules for storage to participate and
receive compensation for participating as a transmission asset.
Current market rules only allow storage to act as a generation
asset that can both inject and withdraw energy; there are no
wholesale market rules that would facilitate a storage project
that wishes to act as, supplement, or replace the need for
transmission investment. The Roadmap recommends that any
storage as transmission projects deployed in the NYISO
transmission planning processes count toward the 6 GW target.
The Roadmap also notes that from 2023 to 2025,
significant amounts of fossil fuel plants are likely to retire
due to the DEC Peaker Rule. The retirement of these plants will

50 NYISO, Storage as Transmission, November 2023, available at:

https://www.nyiso.com/documents/20142/41393553/Storage%20as%20
Transmission%20Report.pdf/5c4d7649-2fb7-e165-2aae-
999863f7f9cf.

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CASE 18-E-0130

tighten supply and increase supply scarcity. However, as more

renewable resources enter the market, this may also lead to
periods of low or negative pricing. These pricing outcomes may
provide opportunities for energy storage resources to charge
from the grid.
The Roadmap notes that the elimination of buyer-side
mitigation for storage resources has been a large step in
reducing barriers and providing more certainty to storage
projects. However, other considerations in the capacity market
remain. For example, the NYISO recently updated its capacity
accreditation model for all resources, including storage. The
Roadmap states that long-duration storage maintains high value
over time with increased penetration on the grid, while the
value of short-term storage declines more rapidly with increased
penetration on the grid. This increased penetration of
renewables on the grid over the course of several years has the
opportunity to provide synergistic effects to the value of
storage which could be accounted for as part of the
accreditation process.
The Roadmap acknowledges that the New York State
Reliability Council will have to consider changes to the
Installed Reserves Margin process. 51 The current methodology
for scaling load shapes and load forecast uncertainty can result
in unreasonably high and long peak forecasts, which could lead
to undervaluing shorter-duration resources, including storage.
Improvements to NYISO ancillary services market
pricing and market products can give opportunities to better
compensate storage for the value they can provide to the grid.

51 The New York State Reliability Council is a not-for-profit

that develops rules for participation in the New York State
Power System. New York State Reliability Council, available
at: https://www.nysrc.org.

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CASE 18-E-0130

The Roadmap notes that the external market monitor for the NYISO
has proposed ancillary service market enhancements that would
benefit storage.
The Roadmap states that, while the capacity market
plays a role in valuing storage, the most significant focus
should be on improvements to the energy and ancillary services
market. Specifically, as more renewables come online, new
market products are likely to be necessary including a ramping
product, reactive power, synthetic inertia, and more granular
energy or reserve products. The need for these products is
already being investigated by the NYISO and its stakeholders in
its Balancing Intermittency project, and in other efforts.
Comments
The NYISO supports storage resources participating in
its wholesale markets and states that wholesale market signals
“provide the foundation for economically efficient storage.”
However, it cautions that, while storage will play a vital role
in the energy transition, long-duration energy needs will
materialize that require long-duration solutions. The NYISO
also states that deploying energy storage resources in excess
before sufficient renewable generation is online could lead to
inefficient charging scenarios and ultimately result in higher
electric demand and potentially higher prices. The NYISO also
requests that Staff and NYSERDA encourage energy storage
resources to provide ancillary services to the grid in its
markets. Finally, the NYISO encourages Staff and NYSERDA to
participate in the stakeholder process in the Storage as
Transmission project.
Form Energy notes deficiencies in ability of the NYISO
markets to value storage and allow full participation. It
states that there is currently no market incentive for multi-day

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CASE 18-E-0130

storage and there is no way for a storage asset to participate

as both a transmission and a generation asset.
ACE-NY, EnSynchrony, NY-BEST, and SPM all support
allowing storage to participate as a transmission asset, such as
in the NYISO’s Storage as Transmission project. NY-BEST and SPM
do not support the counting of any energy storage resources as
transmission projects toward the 6 GW goal. NY-BEST states that
such projects are fulfilling needs beyond what originally drove
the 6 GW goal and should not be used to reduce storage programs
outlined in the Roadmap. If storage as transmission is counted
against the goal, NY-BEST asks that reductions in programs be
based solely on contracted projects, not just planned projects.
Commission Determinations
The Commission recognizes the importance of aligning
incentives and goals with the wholesale markets as well as
utilizing all options to enable energy storage to both
participate and offer its full value to the grid. Staff and
NYSERDA already engage in coordination efforts with the NYISO
and participate in NYISO stakeholder meetings. The Commission
directs Staff and NYSERDA to continue these efforts;
specifically, Staff and NYSERDA shall help facilitate the
recommendations and goals described in this Order with focus on
the items discussed below.
The Commission recognizes that the NYISO is currently
working on projects that will affect energy storage
participation in the wholesale markets, including the Storage as
Transmission and Balancing Intermittency projects. The
Commission supports the NYISO’s efforts to evaluate potential
new participation options for energy storage resources. For
example, the Storage as Transmission project has the potential
to provide a new participation option for energy storage
resources that will further allow energy storage resources to

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CASE 18-E-0130

provide services to the grid beyond generation. The Commission

encourages the NYISO to continue efforts on this project. The
Commission directs Staff and NYSERDA to continue their
participation and engagement on the NYISO’s efforts related to
the participation of energy storage as transmission.
The Roadmap recommends that any energy storage
projects that are developed and participate as a transmission
asset count toward the 6 GW goal. The Commission recognizes
that an energy storage project providing a transmission service
is helping meet electric system needs in New York. The
Commission disagrees with those commenters that characterize
storage-as-transmission as fulfilling needs beyond what was
originally intended with the 6 GW goal. The Commission believes
that we should recognize that energy storage helps to meet New
York’s renewable and zero-emissions energy goals in ways beyond
simply acting as a generation asset. Therefore, any future
storage as transmission projects shall be counted toward the 6
GW goal.
The NYISO’s Balancing Intermittency project seeks to
evaluate the future need for ancillary service products as more
intermittent renewable generation connects to the grid. 52 This
project has the potential to help New York find further value of
energy storage in its ability to meet ancillary service needs.
The Commission supports this project and encourages the NYISO to
continue work on this effort. The Commission encourages the
NYISO to take advantage of the capabilities of energy storage
resources to help meet any ancillary service needs of the

52 NYISO, Balancing Intermittency, January 25, 2024, available

at:
https://www.nyiso.com/documents/20142/42590322/BI%202024%20MIW
G%20Kick%20Off_final.pdf/ac2f0112-f542-f4da-3c9c-f43d0309868f.

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CASE 18-E-0130

system. The Commission directs Staff and NYSERDA to continue

their participation and engagement on this project.

GENERAL PROGRAM DESIGN CONSIDERATIONS

The program designs described within this section
apply to the bulk, residential, and retail programs discussed
above.
Prevailing Wage
Roadmap Recommendations
The Roadmap describes the Inflation Reduction Act and
its provision dictating that commercial energy storage systems
with a capacity of 1 MW alternating current (AC) or greater are
eligible for an up to 30 percent ITC rate if the project
complies with federal prevailing wage and apprenticeship
requirements; such projects would otherwise only be eligible for
a 6 percent ITC rate. Given the substantial financial support
offered by the ITC if a project follows federal prevailing wage
and apprenticeship requirements, the Roadmap notes the
likelihood that a large majority of the energy storage
developers, if not all, will adhere to these requirements and
obtain the full ITC credit.
Comments
NineDot and NY-BEST support a prevailing wage
requirement that aligns with federal standards.
Commission Determination
A requirement for developers to pay the prevailing
wage is already in place for NYSERDA’s Large-Scale Renewable REC
procurements, and for NY-Sun projects 1 MW AC and above. The
Commission finds that this requirement is also appropriate for
this updated energy storage goal and deployment policy.
Therefore, the Commission directs NYSERDA to ensure that
developers of any energy storage project with a capacity of 1 MW
AC or more that participates in a NYSERDA energy storage

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incentive program pay the New York State Prevailing Wage, and
that this requirement be explicit in any awarded contract, with
quarterly certifications by a New York State-licensed Certified
Public Accountant during the construction of the project.
NYSERDA shall include details of this requirement as part of its
Implementation Plan.
Periodic Review
Roadmap Recommendations
In compliance with PSL §74, the Energy Storage Order
established a process by which DPS Staff prepares an annual
report and a triennial review for Commission consideration.
These processes are intended to provide stakeholders with
regular updates on the status of energy storage deployment in
New York and potential market and policy changes. The
importance of providing periodic reports to stakeholders should
continue in the coming years, as federal rules evolve, and the
Coordinated Grid Planning Process and Grid of the Future
proceedings play out.
Comments
Con Edison and O&R support a periodic review of the
energy storage proceeding to keep current with current market
trends and energy storage installation progress. NineDot, NY-
BEST, and SPM recommend an annual review process to evaluate the
progress towards the 6 GW target.
Commission Determination
Recognizing the success of the review process
established in the Energy Storage Order and its continued
importance in the future, the Commission directs Staff to
continue the annual reporting and triennial review requirement.
The Commission directs Staff to continue to report on both the
successes and barriers to energy storage deployment in New York
and offer solutions, as appropriate.

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CASE 18-E-0130

Rollover of Project Funds

Roadmap Recommendations
The Roadmap notes that retail and residential storage
projects historically have had low rates of attrition. However,
even if a project is cancelled, it is possible that the funds
that were allocated to the cancelled project could be
reallocated to a different project in a timely manner. The
Roadmap therefore recommends that any funding from cancelled
retail and residential energy storage projects be made available
to new projects. For bulk projects, where there is a longer
development time, rolling over funds to a new project may not
result in a timely completion of a new bulk energy storage
project by the 2030 target; therefore, the Roadmap does not
recommend the same reallocation of funds for bulk storage
projects.
Comments
NY-BEST and SPM recommend that if any projects that
are under contract in the existing energy storage programs drop
out, those MWs and funding be rolled into the new program.
Commission Determination
The Commission notes that the goal is to install 6 GW
of energy storage statewide by 2030. If projects drop out,
leaving unclaimed funding, it is appropriate for other qualified
projects to step in and make use of that funding in order to
move the State closer to its goal. Considering the
recommendations in the Roadmap, and stakeholder comments, the
Commission directs that any funding from cancelled retail and
residential projects be rolled over to new projects.
Disadvantaged Communities
Roadmap Recommendations
The CLCPA is clear that in determining what path to
take to reach its ambitious climate goals, New York must

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CASE 18-E-0130

consider how such actions impact disadvantaged communities. 53

The Roadmap’s vision and plan of reaching 6 GW of storage
statewide by 2030 aims to benefit disadvantaged communities by
bolstering resiliency through local system benefits and help
maximize the use of intermittent renewable generation. Bulk and
off-site retail energy storage projects will inject energy
directly onto the transmission and distribution systems, which
provides zonal benefits, including helping reduce the emissions
associated with peaker plants. The Roadmap recommends that 35
percent of program funding be used in areas which benefit
disadvantaged communities the most and target peaker plant
replacement with clean energy alternatives, consistent with the
requirements of the CLCPA. 54
Comments
Multiple parties commented on the importance of
designing energy storage programs with explicit attention given
to how these projects will improve quality of life in
disadvantaged communities. AES supports the Roadmap’s proposal
to allocate at least 35 percent of program funding to energy
storage projects that will benefit disadvantaged communities.
BlueWave states the importance of allocating 35 percent of
funding for the bulk storage program to disadvantaged
communities to achieve equity. DER Parties comment that
increased rebates may be necessary for projects located in
disadvantaged communities due to higher financing, electrical
upgrade, and marketing costs. The Indicated Utilities state
their support for retail and residential projects to locate in
disadvantaged communities and encourage engaging these
communities to receive input, and possibly create additional

53 ECL §75-0109.
54 ECL §75-0117.

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CASE 18-E-0130

incentives to encourage development of energy storage in

disadvantaged communities. IPPNY supports 35 percent of funding
for bulk energy storage projects locate in disadvantaged
communities that can help displace fossil-fuel generation.
Jupiter Power recommends that any project located in Con
Edison’s service territory or LIPA be considered as benefiting a
disadvantaged community. PowerFlex agrees with the Roadmap’s
recommendation to allocate 35 percent of program funding for
energy storage projects that benefit disadvantaged communities
and suggests an appropriate $/kWh adder for these projects to
incentivize grid resources in these areas. The PEAK Coalition
advocates for at least half of the 6 GW of proposed energy
storage, with a minimum of 2 GW of bulk energy storage, to be
located in New York City where there is a large portion of the
population that live in disadvantaged communities near high
polluting peaker plants. The PEAK Coalition also states that
this investment of energy storage in New York City will help
reduce the amount of pollutants to which residents are exposed.
Commission Determination
The Commission remains committed to transforming New
York’s energy system in a way that invests in disadvantaged
communities to improve air quality in these areas of the State.
Consistent with this commitment, the Commission agrees with the
Roadmap’s recommendation to allocate a minimum of 35 percent of
program funding for energy storage projects in areas of the
State that will most benefit disadvantaged communities and
reduce reliance on high-emitting peaking plants. As broken down
below, the Commission expects that these projects will be
located within disadvantaged communities themselves, as defined
by the Climate Justice Working Group and adopted in March 2023,
but recognizes that energy storage projects need not be located
directly in a disadvantaged community to provide benefits to

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CASE 18-E-0130

that community. The Commission directs NYSERDA to include

details in its Implementation Plans that address disadvantaged
community considerations as part of program participation.
Bulk and off-site retail energy storage can help
reduce emissions in disadvantaged communities and therefore the
Commission directs that a minimum of 35 percent of procurements
for bulk and off-site retail energy storage projects be located
in NYISO’s G-K Capacity Zones, as they are most likely to
benefit disadvantaged communities and reduce peaker plant
emissions. The Commission expects Zone J to be the largest
source of potential peaker plant replacement and disadvantaged
community benefits. Therefore, the Commission further specifies
that of the minimum of 35 percent of energy storage procurements
allocated for bulk and off-site retail energy storage projects
in Zones G-K, at least 30 percent of total procurements shall be
in Zone J and at least 5 percent shall be in Zones G, H, I,
and/or K. These carveouts recognize that the largest potential
pool of peaking plant replacement is in New York City, while
also acknowledging that other areas of the State are deserving
of energy storage investment based on benefits to disadvantaged
communities and associated emission reductions.
On-site retail and residential energy storage projects
will provide benefits directly where they are installed. The
Commission therefore directs that a minimum of 35 percent of
procured energy storage for residential and on-site retail
energy storage projects be located within disadvantaged
community census tracts, consistent with CLCPA requirements and
findings from the Climate Justice Working Group.
In-Service Date
Roadmap Recommendations
The Roadmap proposed that any energy storage projects
procured through the bulk, retail, and residential programs

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CASE 18-E-0130

discussed above be required to be in-service by December 31,

2030, but noted that projects procured after the three initial
bulk energy storage solicitations with an in-service date after
2030 should still be eligible to participate.
Comments
No stakeholders commented on an in-service date
requirement.
Commission Determination
The Roadmap was designed with the intent to procure 3
GW of bulk energy storage, 1,500 MWs of retail energy storage,
and 200 MWs of residential energy storage by 2030. The
remaining 1,700 MWs, as stated in the Roadmap, is already under
contract or has been awarded by NYSERDA. The 2030 date
originated in the CLCPA which requires that 70 percent of
electricity generation come from renewables by 2030, and 100
percent by 2040. This necessitates the interconnection of
energy storage resources onto the grid to help meet load when
renewable generation is not producing energy. As such, the
Commission requires that any bulk, retail, or residential energy
storage projects that access funds made available through this
Order be in-service by December 31, 2030. This required in-
service date is consistent with the State’s energy policy and
goals and language of the CLCPA. The Commission does recognize
the uncertainty inherent with energy storage development at this
time, and therefore gives NYSERDA the ability to extend this in-
service deadline for projects that have been delayed due to
conditions beyond the control of the developer, based on proof
that the project construction has commenced on or before
December 31, 2030. This flexibility is geared towards achieving
an effective buildout of energy storage in New York.
The Commission also recognizes that there may be
certain projects that either received or may receive funding as

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CASE 18-E-0130

part of the Energy Storage Order that are not yet in-service.
These projects, under the parameters of the Energy Storage
Order, are required to be in-service by December 31, 2025.
Employing the same rationale as above, the Commission grants
NYSERDA the flexibility to allow for an in-service date beyond
the December 31, 2025 deadline for energy storage projects
receiving funding through the Energy Storage Order that have
been delayed due to conditions beyond the control of the
developer, based on proof that the project construction has
commenced on or before December 31, 2025. The objective of the
energy storage programs is to help transition New York to a
zero-emissions generation future, and therefore allowing energy
storage projects to come in-service beyond prescribed deadlines
based on proof of construction progress is consistent with this
objective.
The Commission directs NYSERDA to reflect these in-
service dates in its Implementation Plan and program manuals.

OTHER ISSUES
The issues discussed in this section are not specific
to the bulk, residential, or retail programs but are relevant to
the Commission’s energy storage policies as a whole.
Additionally, several parties raised specific topics and issues
that warrant the Commission’s consideration.
NYPA and LIPA Participation in Storage Procurement Programs
Roadmap Recommendations
The Roadmap recommends that NYPA and LIPA voluntarily
participate in the bulk energy storage procurement programs, by
accepting ISC allocations in proportion to their share of
statewide load in the bulk program. Consistent with the
approach in the Offshore Wind Standard, in the event that LIPA
or NYPA directly procure or develop bulk energy storage projects
outside of the NYSERDA procurement program, NYSERDA would take

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CASE 18-E-0130

such independent storage procurement into account in its

assessment of amounts of bulk storage needed through its
solicitations. Such projects, subject to meeting the
requirements of the storage program, could be credited towards
their load share compliance obligation.
For the retail and residential procurement programs,
the Roadmap recommends that NYPA and LIPA voluntarily
participate in collections on a MWh load share basis as well,
consistent with previous programs. 55
Comments
The City states that if NYPA agrees to voluntarily
participate in the energy storage programs, then the Commission
should make clear that NYPA customers are eligible to
participate in the programs and access the relevant incentives.
Convergent Energy, NY-BEST, and FreeWire Technologies (FreeWire)
support the inclusion of NYPA in the energy storage programs.
In its comments, NYPA states its opposition to
voluntary participation, claiming that it has no way to recover
program costs through its existing contracts with customers.
Instead, NYPA requests that the Commission consider alternative
ways for NYPA to recover the program costs.
LIPA recommends that the bulk energy storage program
allow for participation by tax-exempt utilities. LIPA states
that, if it decides to participate in the proposed bulk program
by purchasing its allocated ISCs, it would enter into a contract
with NYSERDA and have its cost share reduced by the amount of
bulk energy storage capacity separately procured by LIPA through
its own solicitations.

55 Case 20-M-0082, Proceeding on Motion of the Commission

Regarding Strategic Use of Energy Related Data, Order
Implementing an Integrated Energy Data Resource (issued
February 11, 2021), p. 19.

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CASE 18-E-0130

Commission Determination
The Commission recognizes that NYPA and LIPA are
involved in many activities that move New York closer to meeting
its CLCPA targets, including the development of energy storage,
and notes that NYPA and LIPA are non-jurisdictional Load Serving
Entities (LSE). Accordingly, the Commission adopts the
Roadmap’s recommendation that both NYPA and LIPA voluntarily
participate and accept ISC allocations proportional to its share
of Statewide load for the bulk program. That said, recognizing
that NYPA and LIPA have the demonstrated ability to
develop/procure bulk storage projects, NYSERDA shall take such
independent storage procurement into account in its assessment
of amounts of bulk storage needed through its solicitations.
Such projects, subject to meeting the requirements of the bulk
storage program, shall be credited towards NYPA and LIPA load
share compliance obligation. This process shall be described in
NYSERDA’s Implementation Plan.
As for the residential and retail programs, the
Commission encourages LIPA to voluntarily participate in both by
accepting its MWh load share cost allocation as described in
more detail later in this Order. Doing so would make LIPA
customers eligible for the NYSERDA residential and retail
storage program incentives. As for NYPA participation in these
programs, the Commission shall allow participation by requiring
cost recovery through electric utility delivery rates that NYPA
customers are subject to, as described in more detail later in
this Order.
New York Municipal Power Association (NYMPA)
Roadmap Recommendations
The Roadmap recommends a funding mechanism for the
bulk energy storage procurement program that would impose a

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CASE 18-E-0130

payment obligation for all jurisdictional LSEs proportional to

their share of statewide load.
Comments
NYMPA opposes the load-ratio share funding mechanism
and claims it would have a disproportionately negative effect on
its members, citing the already high costs of Clean Energy
Standard compliance on its overall small size of member systems.
NYMPA further comments that all of the power its members consume
comes from zero-emissions sources, the bulk of which is from
renewable energy. NYMPA states that, if the Commission does
keep the load-ratio share methodology, only NYMPA load not
served by renewables should be counted.
Commission Determination
The Commission disagrees with NYMPA that its members
should not be allocated costs based on the load-ratio share
methodology discussed in the Roadmap. The benefits of
transitioning to an energy system comprised of renewable energy
will accrue to all New Yorkers, including the NYMPA’s member
systems. Because its members will receive the benefits of
increased renewable generation output, such as decreased
emissions from electric generation, it stands to reason that its
members should be allocated costs in the same manner as other
Commission-jurisdictional LSEs. The Commission therefore
declines to exclude NYMPA load from the cost allocation of the
NYSERDA bulk energy storage procurement program.
Utility Ownership of Energy Storage Systems
Roadmap Recommendations
The Energy Storage Order reaffirmed the policy of
prohibition against utility ownership, except in limited
circumstances, as adopted in the Reforming the Energy Vision

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(REV) Framework Order. 56 The Roadmap recommends that the Joint

Utilities study the potential of energy storage to provide non-
market transmission and distribution services and identify
energy storage projects that can provide cost-effective services
compared to alternatives. The Roadmap further details how the
Advanced Technology Working Group should address this topic,
potentially in a newly formed subgroup focused on energy
storage’s future role in providing grid services.
Comments
IPPNY, NY-BEST, and ACE NY all state their opposition
to utility-owned storage, arguing that there is a growing and
robust private storage market emerging in New York and that
utility-owned storage would negatively impact this burgeoning
industry.
The Indicated Utilities propose that utility-owned
storage for non-market applications be allowed and count towards
the 6 GW goal. The Indicated Utilities highlight the ability of
utility-owned storage to lower cost of capital, quickly address
system constraints, and bolster reliability and resiliency as
reasons why it should be allowed under the energy storage
program. The Indicated Utilities reiterate comments they
submitted in the CLCPA Proceeding, in which they highlight five
utility ownership use cases in support of the transmission and
distribution system, including co-locating at utility
infrastructure, operationally complex reliability/resiliency
projects, real-time operations/controls integration,

56 Energy Storage Order, p. 43; see also Case 14-M-0101,

Reforming the Energy Vision, Order Adopting Regulatory Policy
Framework and Implementation Plan (issued February 26, 2015)
(REV Framework Order).

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CASE 18-E-0130

transmission applications/system integration, and mobile energy

storage systems. 57
Commission Determination
The Commission agrees with certain commenters that
presently there is no reason to reverse precedent on utility-
owned storage. The Energy Storage Order examined the issue of
utility ownership of energy storage. Referring to the REV
Framework Order, the Energy Storage Order confirmed the
following four limited situations where utility ownership of
energy storage may be considered: (1) Procurement of DER has
been solicited to meet a system need, and a utility has
demonstrated that competitive alternatives proposed by non-
utility parties are clearly inadequate or more costly than a
traditional utility infrastructure alternative; (2) a project
consists of energy storage integrated into distribution system
architecture; (3) a project will enable low or moderate income
residential customers to benefit from DERs where markets are not
likely to satisfy the need; or (4) a project is being sponsored
for demonstration purposes. 58 The rationale in the REV Framework
Order and Energy Storage Order continues to hold, and the
Commission finds no need to stray from that established
precedent.
That notwithstanding, the Commission does recognize
the potential of energy storage as a transmission and
distribution asset. According, consistent with the Roadmap’s
recommendation, the Commission directs the Joint Utilities to
conduct a study of the non-market transmission and distribution
services that energy storage projects can provide. This should
include an in-depth engineering and economic review of the

57 Case 22-M-0149, Proceeding Implementing CLCPA Requirements and

Targets, JU Comments (filed August 10, 2022).
58 Energy Storage Order, p. 43; REV Framework Order, p. 69.

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CASE 18-E-0130

applications that energy storage could provide to the utility as

it fulfills is obligations to provide safe and reliable service
in the most efficient and effective manner. The results of the
study shall be filed with the Commission within 120 days of this
Order. The study should include how utilities’ system planning
and operating procedures would be modified to incorporate energy
storage as an alternative tool in the toolbox if applicable. In
addition, the filing should include a proposed process for the
review and approval for such projects, as well as a cost
recovery mechanism, if such a process does not align with the
normal rate case schedules.
Vehicle-to-Grid
Roadmap Recommendations
The Roadmap recognizes the potential value of vehicle-
to-grid (V2G) services. V2G is the allowance of power stored in
EV batteries to discharge back onto the grid and act as a power
resource. If there are two million EVs in New York by 2030,
there may be up to 14 GW of stored energy, collectively, in the
vehicles’ batteries. Even on a small scale, the energy from
participating EVs could equate to hundreds of MWs of available
capacity to inject into the grid when most needed. The Roadmap
notes that NYSERDA’s Clean Transportation Program, federal
initiatives such as the New Electric Vehicle Infrastructure
program, and New York’s Make-Ready Program are focused on EV
infrastructure development and opportunities for V2G
integration. The Roadmap suggests that those venues are more
appropriate for further work on this topic than the Commission’s
energy storage proceeding.
Comments
Fermata Energy and Nuvve recommend that the Commission
consider adopting a V2G deployment target and incentives for
bidirectional charging infrastructure. They explain that

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bidirectional charging infrastructure can help increase grid

flexibility. NineDot recommends that V2G project charger costs
be eligible for incentives through the retail storage program.
NY-BEST recommends that DPS and NYSERDA collaborate with the
industry to create new programs or develop existing ones, such
as those approved in the Make Ready Program, to incentivize
bidirectional chargers and update utility tariffs that reflect
the value of V2G services. The Indicated Utilities recognize
the potential value of V2G but do not recommend establishing a
specific V2G target or incentive through this proceeding.
Commission Determination
The Commission recognizes that establishing pathways
for V2G services would be an opportunity for New York to harness
the full capability of EVs to provide electric capacity to the
grid during high stress times. However, the Commission agrees
with the Roadmap that there are existing forums that are more
appropriate for advancing this technology, including through
other proceedings underway at this Commission. Therefore, at
this time, the Commission declines to establish a V2G deployment
target or incentive for bidirectional charging infrastructure in
this proceeding.
Establishment of a BTM Energy Storage Incentive
Roadmap Recommendation
The Roadmap made no recommendation on the
establishment of a Behind-the-Meter (BTM) energy storage
incentive for the retail energy storage program.
Comments
Con Edison and O&R (collectively, the Companies)
recommend that the Commission direct the Companies to develop a
BTM energy storage incentive under the retail program, with
input from Staff and NYSERDA. The Companies state that the
creation of a BTM incentive will benefit disadvantaged

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communities by giving customers a better opportunity to manage

their electric load, especially when paired with DERs. The
Companies state the importance of education and outreach in the
communities where these projects may be located, and for
developers that are able to implement these projects. The
Companies note that BTM installations generally have lower
interconnection costs because they are behind an existing meter.
The Companies request that the Commission direct them to file a
BTM storage incentive implementation plan within 90 days of this
Order, and that implementation and incentive costs for the
program be recovered over 15 years as a regulatory asset.
FreeWire comments on the importance of BTM storage at
commercial and industrial facilities and recommends establishing
BTM retail energy storage procurement targets and incentives
specific to BTM storage at non-residential sites. FreeWire
states that BTM energy storage has a number of benefits
including energy use and cost management, increased site
resiliency, allowance for load shifting, the ability to
aggregate into a Virtual Power Plant, integration of renewable
energy output, and helping defer location-specific system
upgrades.
Convergent Energy strongly agrees with the Companies’
assessment of the value of BTM energy storage and recommends a
separate adder for BTM energy storage in the retail program.
Convergent Energy also states that retail BTM energy storage
larger than 5 MW is beneficial for the local grid and that the
Commission should consider incentivizing larger sized BTM
projects.
NineDot recognizes the potential value of BTM energy
storage but does not recommend a separate incentive be
established for this resource class, highlighting that the
technology type is still in its nascency and that the market for

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CASE 18-E-0130

this technology is relatively immature. NineDot recommends

community-scale front-of-the-meter projects as a better
investment of ratepayer funds.
NY-BEST opines on the value of BTM energy storage for
ratepayers and the grid. It is supportive of the Companies’
proposal to create a new BTM storage incentive, assuming that
the program would be funded by the utilities and so long as the
program is in addition to the Roadmap’s proposal for the retail
energy storage program.
Commission Determination
The Commission understands that BTM energy storage can
provide reliability and resiliency value to disadvantaged
communities and other segments within the proposed retail energy
storage program, but declines to establish a BTM energy storage
incentive, as requested by the Companies. The proposed retail
energy storage program, as described in the Roadmap, provides
more direct system benefits than a BTM program would, since the
retail projects are expected to be standalone storage projects
built in locations that provide the most economic price signals,
and therefore system value, via the Value Stack mechanism.
Conversely, larger retail customers have customer-specific
retail rate options that provide incentives to install BTM
storage for peak load management via reduced bills. The
Commission believes that the front-of-the-meter retail program
will provide system benefits in a more efficient manner as it
builds upon the successful CDG model. That said, the Commission
directs that Staff, as part of its annual reporting requirement
discussed above, capture the status of deployment of retail BTM
energy storage to the extent possible, and highlight any
challenges, barriers, and successes.

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Bridge-to Wires
Roadmap Recommendations
The Companies proposed a Bridge-to-Wires (BTW)
mechanism under the existing UDR framework. The proposed BTW
mechanism intends to target energy storage development in
specific areas of the Companies’ service territory, add capacity
when and where needed, and relocate the energy storage resource
as needed and appropriate to aid in the electrification of other
areas of the Companies’ service territory. The Roadmap made no
recommendation on the establishment of a BTW mechanism under the
existing UDR framework.
Comments
The Companies propose the creation of a new BTW
mechanism under the UDR framework. The Companies explain that
BTW procurements under UDR would add peak capacity at
constrained locations on their system, enabling faster end-use
electrification compared to building out traditional
infrastructure meant to serve increased load. The Companies
state that such storage systems could be relocated as necessary
to other locations on their system to further enable
electrification. The Companies cite increased opportunities for
developers to propose projects under their proposed BTW
mechanism and request authorization from the Commission to
submit an Implementation Plan detailing the BTW proposal.
NY-BEST responds in its reply comments that, while it
recognizes that energy storage can play an important role in
enabling faster electrification, it remains opposed to utility
ownership of storage.
Commission Determination
The Commission sees the potential value of the
Companies’ proposed BTW mechanism in maximizing the benefits of
energy storage by relocating energy storage resources as needed
on the Companies’ system. However, at this time, the Commission
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CASE 18-E-0130

declines to authorize the Companies’ BTW proposal. While the

Companies did describe their proposed BTW proposal in their
comments, more information is needed before the Commission can
approve, modify, or deny such proposal. Instead, the Commission
directs the Companies, and invites the other Joint Utilities, to
include this as a use case in the study described earlier on
utility ownership of energy storage. The use case shall include
details such as the criteria used to determine when an energy
storage resource would be used as a BTW solution, and how such
criteria would be integrated into utility system planning and
operating procedures.
Rate Design
Roadmap Recommendations
The Roadmap suggests that the Joint Utilities could
examine the need for new tariffs or storage-specific rate
structures to incent the development of residential energy
storage.

Stakeholder Comments
ACE NY requests that NYSERDA provide more clarity on
the path for distribution-connected bulk energy storage projects
larger than 5 MWs to enter the market. ACE NY states that these
distribution-connected energy storage resources would be subject
to distribution charging rates that equivalent transmission-
connected energy storage will not and therefore would likely be
uncompetitive in the ISC solicitation process. Key Capture
Energy also requests the Commission open a new docket to
promptly address the application of distribution rates to bulk
storage projects and urges the Commission to provide FERC the
necessary information to approve a rate that is consistent with
state policy. BlueWave agrees with the sentiments of ACE NY and
adds that distribution-connected bulk energy storage can be
sited closer to load and provide more distribution benefits

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compared to transmission-connected bulk energy storage. NY-BEST

agrees with ACE NY and further recommends that the Commission
direct the Joint Utilities to remove surcharges and riders from
delivery rates for charging load of front-of-the-meter energy
storage, and in the short-term to exclude these costs from price
calculation thresholds and in price comparisons during bid
evaluations. The Institute for Policy Integrity states that the
Commission needs to develop and deploy more cost-based rate
designs to encourage the development of distribution-level
energy storage.
NineDot requests that Con Edison restart its Modified
High-Tension program, and that the Commission allow Con Edison
to work with energy storage host sites to select this service
rate. NineDot also urges the Commission to reinstate Con
Edison’s Rider Q pilot program, which was designed to encourage
energy storage to charge during optimal times, while also
advocating for Con Edison to adjust the program so that costs
align with local grid constraints. NineDot further states that
Rider Q should be modified so that the designated “off peak”
hours are adjustable based on the results from interconnection
studies rather than have a global definition for “off peak
hours.”
Commission Determination
The Commission recognizes that prudent rate design is
necessary to help achieve the 6 GW storage target. The
Commission is aware that charging load of energy storage systems
connected at the distribution level will generally pay different
rates than otherwise equivalent transmission-connected energy
storage systems. This issue was raised by ACE NY in its
comments. However, we are also aware of the need for
distribution costs to be fairly recovered from all users of the
system. During charging, energy storage systems will add to

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CASE 18-E-0130

load on the distribution system just like any other load. The
FERC determined that the sale of charging energy to an electric
storage resource that is then resold into the ISO markets is a
sale for resale in interstate commerce and thus subject to FERC
jurisdiction. 59 The Commission understands that utilities are
filing Wholesale Distribution Service (WDS) rates with the FERC
that will be applicable to energy storage projects that are
distribution connected that discharge via the wholesale markets.
The Commission directs Staff to actively participate in the FERC
process to help ensure that the WDS rates are developed
appropriately.
In response to NY-BEST’s comments related to the
removal of surcharges and riders from delivery rates for
charging load of front-of-the-meter projects, the Commission
notes that these surcharges and riders were developed to recover
variable costs or return revenues associated with a variety of
distribution functions, including but not limited to
reconciliations of storm costs, recovery of payments made
through the Value Stack, recovery of Non-Wire Alternative (NWA)
and DLM program costs, as well as Clean Energy Fund costs
recovered through the System Benefits Charge. The Commission
does not find NY-BEST’s requests for front-of-the-meter energy
storage systems to be exempted from delivery surcharges to be
compelling for three reasons. First, many of the project and
program costs recovered through delivery surcharges are related
to initiatives which benefit all utility customers, such as NWA
projects and DLM programs, or are intended to benefit society as
a whole, such as the Clean Energy Fund. Application of the
“beneficiaries pay” principle – the theory that all customers

59 FERC Order No. 841, issued on February 15, 2018, in Dockets

RM16-23-000 et al., paragraph 300.

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CASE 18-E-0130

that benefit from a project or program should pay for its costs
– would require front-of-the-meter storage facilities to help
pay for these projects and programs as they benefit from them.
For example, NWA projects and DLM programs reduce an electric
utility’s need to invest in infrastructure, thereby reducing
revenue requirement. NY-BEST’s comments do not provide
sufficiently compelling arguments to reject this principle for
front-of-the-meter energy storage customers.
Second, the Commission has a longstanding policy of
avoiding technology-specific rate design. Approval of
exclusions to certain delivery surcharges solely on the basis of
which technology a customer utilizes amounts to, in essence, a
technology-specific rate. We are not aware of any instances
where the Commission has approved a technology-specific
exemption to responsibility for delivery surcharges, and we do
not find the information presented in this case to be compelling
enough to revise our general policy against technology-specific
rate design. 60
Third, while most of the components of delivery
surcharges are designed to recover costs which are not included
in base rates, some elements are designed to return revenues to
customers, for example, revenues received through the sale of
Regional Greenhouse Gas Initiative Allowances and sale of energy
and capacity to the wholesale market from utility-owned energy
storage facilities. Completely exempting front-of-the-meter
energy storage customers from delivery surcharges, as NY-BEST
suggests, would unreasonably deprive those customers of their
fair share of the revenues collected and returned to customers.
For these reasons, NY-BEST’s suggestion to exempt front-of-the-

60 NYPA load is exempt from certain surcharges; however, such

exemption is broadly based on all NYPA load and not on the
basis of the presence of any particular technology.

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CASE 18-E-0130

meter energy storage customers from delivery surcharge

responsibility is rejected.
The Institute for Policy Integrity’s recommendation
that the Commission develop and deploy more cost-based rate
designs to encourage the development of distribution-level
energy storage is rejected. Beginning with the REV Track Two
Order issued in 2016, the Commission set out on an initiative to
improve standby service rates. 61 This initiative culminated with
the October 2023 Standby Rates Order. 62 As part of that process,
our March 16, 2022 Order addressed the need for a methodology to
develop the most cost-based delivery rates possible, as well as
thoroughly considered delivery rate exemptions for energy
storage projects. 63 The standby rates designed and filed
following the guidance of the October 2023 Standby Rates Order
reflect the most cost-based rate designs that will encourage the
development of distribution-level energy storage, as the
Institute for Policy Integrity requests.
In the May 16, 2019 Order, the Commission recognized
the importance of Con Edison’s Rider Q rate pilot, then the only
available option for granular As-Used Daily Demand charges with
a less than 10-hour super-peak period, and directed each of the
other utilities to develop similarly granular As-Used Daily

61 Case 14-M-0101, supra, Order Adopting a Ratemaking and Utility

Revenue Model Policy Framework (issued May 19, 2016), pp. 125-
132 (REV Track Two Order).
62 Case 15-E-0751, supra, Order Establishing Updated Standby
Service Rates and Implementing Optional Mass Market Demand
Rates, (issued October 13, 2023) (October 2023 Standby Rates
Order).
63 Case 15-E-0751, supra, Order Establishing an Allocated Cost of
Service Methodology for Standby and Buyback Service Rates and
Energy Storage Contract Demand Charge Exemptions, (issued
March 16, 2022) (March 16, 2022 Order).

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CASE 18-E-0130

Demand Charges. 64 The Commission later adopted four- and five-

hour super-peak periods proposed by Central Hudson, National
Grid, NYSEG, and RG&E, and rejected O&R’s proposed 10-hour
period and directed O&R to develop a meaningfully shorter period
to more closely match the applicable period of peak demands. 65
For Con Edison, the Commission accepted the company’s proposed
10-hour super-peak period, on the basis that peak demand periods
in various areas of the Con Edison service territory range from
11 a.m. to 11 p.m. depending on the characteristics of load in
those areas, but identified that “Rider Q remains a viable
option for customers to participate in for a more temporally and
locationally granular As-Used Daily Demand Charge.” 66 While it
is true that customers already participating in Rider Q will
continue to be able to do so through the end of the remaining
pilot period, which includes a customer-specific 10-year period,
new customers have been unable to join Rider Q since January 1,
2022. 67 Under present conditions, new energy storage customers
in the Con Edison service territory would be the only customers
interconnecting to an investor-owned utility in New York State
without access to a granular As-Used Daily Demand Charge.
NineDot opined that Con Edison’s Rider Q program may
be one potential path forward for energy storage resources. The
Commission generally agrees that the design of Rider Q provides
storage resources a desirable rate option as Option B of Rider Q
offers participants a locational based on Daily As-used Demand

64 Case 15-E-0751, supra, Order on Standby and Buyback Service

Rate Design and Establishing Optional Demand-Based Rates
(issued May 16, 2019), p. 33 (May 16, 2019 Order).
65 October 2023 Standby Rates Order, pp. 70-73.
66 Id. at 71.
67 P.S.C. No. 10, Consolidated Edison Company of New York, Inc.
Schedule for Electricity Service, Leaf 239 (Con Edison
Electric Tariff).

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CASE 18-E-0130

Pricing rate option comprised of both a peak period and a four-

hour period applicable during the summer months (Super-Peak
Period). 68 However, the Commission acknowledges Rider Q would
need to be refined to remain a viable option. First, Rider Q
was established as a rate pilot. 69 As such, participation in
Rider Q was limited in both duration and size. Regarding
duration, Rider Q was opened to new entrants until January 2022,
and all participants may remain in the program for up to 10
years. Regarding size, Rider Q was available to 125 MW of
nameplate rated capacity.
Assuming Option B of Rider Q were to be re-opened to
new participants, the Super-Peak Periods would need to be re-
evaluated, since at the time of Rider Q implementation, the
periods were directly tied to the applicable Con Edison
Commercial System Relief Program (CSRP) demand response event
call-windows. 70 However, the call-windows for certain load
areas, or Networks, have shifted somewhat in recent years, and
are likely to continue shifting as New York undergoes transition
in both generation and customer usage patterns. 71 Processes need
to be in place to allow for adjustment to CSRP call windows to
meet the evolving needs of the grid and the dynamic load
management programs for which the call windows are primarily
designed, independent of potential adjustments to Rider Q.
While the CSRP call window periods may remain a reasonable basis

68 Id.
69 Case 16-E-0060 et al., Con Edison – Electric and Gas Rates,
Order Approving Electric and Gas Rate Plans (issued
January 25, 2017), p. 7.
70 Con Edison regularly updates and maintains a list of CSRP call
windows by Network and load area on its website.
71 Leaf 207 of the Con Edison Electric Tariff specifies that
“Network” refers to a distribution network or load area
designated by the Company.

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CASE 18-E-0130

for setting the geographically varying and temporally granular

As-Used Daily Demand Charge under Rider Q, any modification to
CSRP call windows should trigger an evaluation of Rider Q Super-
Peak Periods.
Therefore, the Commission directs Con Edison to
submit, within 60 days of this Order, a draft tariff filing that
modifies Option B of Rider Q based on the discussion above. The
filing shall include a re-opening of Option B redesigned with
appropriate Super-Peak Periods, subject to re-evaluation and
potential adjustment based on modification to CSRP call windows.
The filing will be subject to a SAPA public notice and comment
period, in order to give stakeholders an opportunity to weigh in
on Rider Q’s applicability and recommend any improvements. This
filing, as well as subsequent comments and stakeholder feedback,
will assist the Commission in determining under what parameters
Con Edison’s Rider Q program should be reinstated.
Fire Safety
In response to three fires that originated at energy
storage facilities in New York in the summer of 2023, Governor
Hochul announced the creation of an Inter-Agency Fire Safety
Working Group (Fire Safety Working Group). The purpose of the
Fire Safety Working Group is to help ensure the safety of energy
storage systems across the state by examining the energy storage
fires and reviewing fire safety standards. 72 The Fire Safety
Working Group’s analysis will include review of emergency

72 The Fire Safety Working Group consists of the Division of

Homeland Security and Emergency Services, Office of Fire
Prevention and Control, NYSERDA, DEC, DPS, and Department of
State.
NYSERDA, New York’s Inter-Agency Fire Safety Working Group,
available at: https://www.nyserda.ny.gov/All-Programs/Energy-
Storage-Program/New-York-Inter-Agency-Fire-Safety-Working-
Group.

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CASE 18-E-0130

response protocols, fire safety standards, and current fire

code. The analysis done by the Fire Safety Working Group will
culminate in recommendations to help prevent fires at energy
storage systems in New York.
On December 21 2023, the Fire Safety Working Group
released its initial findings which included that there were no
harmful levels of toxins detected in the soil or water at each
of the three energy storage locations where fires occurred in
2023. 73 The Fire Safety Working Group is also negotiating to
obtain the Root Cause Analyses for the fires; once available,
subject matter experts will review and analyze. NYSERDA is also
targeting the end of Q2 2024 for site reviews of energy storage
sites in New York to improve best practices.
On February 6, 2024, NYSERDA released the draft Fire
Code Recommendations Report. Updated recommendations,
reflecting comments received in response to the draft, will be
issued in June 2024. The Fire Safety Working Group continues to
run in parallel with the energy storage proceeding.
One of the core mandates of the Commission is to
ensure the safe delivery of energy. As energy storage becomes a
more common and critical source of power in New York, the safety
of these facilities is paramount. The Commission is committed
to fire safety, even if the Fire Safety Working Group
recommendations are not adopted at the time of the issuance of
this Order. Accordingly, the Commission directs NYSERDA to
include which of the applicable recommendations that come out of
the Fire Safety Working Group will be included in its
Implementation Plan. When considering fire safety requirements,

73 NYSERDA, Initial Findings Released From Inter-Agency Fire

Safety Working Group on Emergency Response, December 21, 2023,
available at: https://www.nyserda.ny.gov/About/Newsroom/2023-
Announcements/2023-12-21-Governor-Hochul-Announces-Results-of-
Fire-Safety-Working-Group.

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CASE 18-E-0130

NYSERDA is not limited to the recommendations issued by the Fire

Safety Working Group and may include more stringent
requirements. If the Fire Safety Working Group recommendations
are adopted in the future, NYSERDA shall file an updated
Implementation Plan reflecting those requirements as necessary.
IMPLEMENTATION PLANS
The energy storage programs in the bulk, retail, and
residential sectors, as described above, will be administered by
NYSERDA. This section discusses the Implementation Plans to be
developed by NYSERDA, with consultation from Staff, that will
detail the implementation strategies and program goals of the
energy storage programs. Due to the differences in structure
between the various proposed programs, NYSERDA shall file two
Implementation Plans. One Implementation Plan will address the
bulk energy storage program (Bulk Storage Implementation Plan)
and the other will address the retail and residential programs
(Retail/Residential Implementation Plan). The Bulk Storage
Implementation Plan shall be filed with the Commission for
approval within 120 days of this Order. The Bulk Storage
Implementation Plan shall be subject to a public notice and
comment period, pursuant to SAPA, and subsequent consideration
by the Commission. The Retail/Residential Implementation Plan
shall be filed within 60 days of this Order. This
Implementation Plan will also be subject to a SAPA public notice
and comment period and subsequent consideration by the
Commission. The Energy Storage Order required a similar process
for NYSERDA to develop an Implementation Plan which detailed
program requirements; NYSERDA may use the previously prepared
Implementation Plan as a framework, to be updated as appropriate
to reflect the new program designs discussed above.
At a minimum, NYSERDA shall include the following
topics within the Implementation Plans:

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CASE 18-E-0130

1. Budget details for each of the bulk, retail, and

residential programs;
2. Performance metrics;
3. Incentive Structure for each energy storage program;
4. Project Application Submission Process;
5. Quality Assurance;
6. Measurement and Verification;
7. Technical and Other Requirements;
8. Disadvantaged community access considerations; and
9. Any other topics throughout this Order that the Commission
has directed to be included.
In addition to the topics discussed above, within the
Bulk Storage Implementation Plan, NYSERDA shall detail how
duration and geographic considerations will be evaluated,
consistent with the Commission directives discussed in the Bulk
Energy Storage Program section of this Order. NYSERDA shall
also describe in its Implementation Plans how it will
incorporate any recommendations that come out of the Fire Safety
Working Group. Additionally, as discussed above, NYSERDA shall
specify a 20 MWh cap for retail energy storage projects in the
Retail Energy Storage Program section.
Following Commission review of the Implementation
Plans, NYSERDA shall also develop and file two program manuals,
one for the retail/residential programs and one for the bulk
storage program, based upon the respective approved
Implementation Plan that sets forth specific program provisions
and requirements. These manuals may be updated as needed, after
consultation with Staff.

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CASE 18-E-0130

LONG DURATION ENERGY STORAGE AND INNOVATION

Roadmap Recommendations
The Roadmap discusses the future importance of LDES.
The forecasted peak load period coupled with expected low
renewable output highlights the need for LDES resources. The
Roadmap’s analysis identifies a need for 24 GW of 100-hour
battery storage with 50 percent RTE and 13 GW of in-state
incremental new renewable resources to provide the necessary
energy to charge these energy storage resources. The Roadmap
recommends that NYSERDA’s Innovation Program prioritize research
in LDES that can provide grid value and is likely to be
developed due to strong supply-chain dynamics by 2040. The
Roadmap further recommends that the Innovation Program examine
funding needs within the existing framework with a focus on
enabling large scale LDES demonstration projects sized between
50-100 MWs. These projects are intended to provide insight into
use cases for LDES and information for the utilities and NYISO
to integrate into their planning and operational procedures.
Comments
ACE NY agrees that demonstrating LDES technologies
before 2030 is important to gain experience with this resource
class and recommends that NYSERDA establish a funded
demonstration program to facilitate LDES deployment and develop
a program to support commercial deployment of LDES. Convergent
Energy supports research and development initiatives to help
stimulate LDES development and states that any opportunity to
participate in such a program be transparent and competitive.
Form Energy recommends that multi-day storage be included in all
grid planning processes and be eligible for the ISC, and
supports multiple large-scale long duration energy storage
projects. Hydrostor supports additional funding for innovative
long-term energy storage technologies with a focus on non-
lithium-ion 100 MW+ projects. Plug Power advocates for
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CASE 18-E-0130

incentivizing commercially available hydrogen fuel technology

for LDES.
Commission Determination
As discussed above, the Commission sees the important
role that LDES will have in enabling a reliable energy
transition. NYSERDA’s Innovation Program has several LDES
demonstration and pilot programs currently underway that utilize
a variety of technologies including iron-air batteries, zinc
alkaline batteries, and hydrogen storage. The Commission
directs NYSERDA to continue to work on establishing pilot
projects that span a variety of LDES technologies as part of its
Innovation Program to best position New York to timely develop
and deploy LDES assets when the electric power system requires
it.

PROGRAM COSTS AND RECOVERY

Roadmap Recommendations
The Roadmap recognizes the need for new funding to
deploy energy storage to achieve the goal of 6 GW by 2030. The
Roadmap estimates the cost of deploying 200 MWs of residential
energy storage at $75 million on a net present value basis, or
$100 million on a nominal basis, and the cost of deploying 1,500
MWs of retail energy storage at $489 million on a net present
value basis, or $675 million on a nominal basis. For the bulk
program, cost estimates range between $701.5 million and $1.42
billion on a net present value basis or $1.33 billion to $2.94
billion on a nominal basis to procure 3,000 MWs. The large
range of estimated costs for the bulk program is primarily due
to the uncertainty of future wholesale energy and capacity
prices which are used to estimate the future costs of the
indexed storage credits.
The Roadmap also recommends separate funding for
administrative costs, including costs related to program

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CASE 18-E-0130

administration, implementation support, program evaluation, and

the New York State Cost Recovery Fee. The Roadmap notes that
most of these costs relate to the residential and retail
programs, with a smaller portion going towards startup costs of
the bulk program. Therefore, the Roadmap recommends that bulk
program start-up costs use legacy funding from storage programs
approved in the Energy Storage Order.
The Roadmap estimates total program administration
costs to total $29 million, $14.5 million of which is already
available through the previously approved Bridge Incentive and
the remaining $14.5 million of which is requested from the
Commission. Program administration costs include staffing
requirements, contract management, policy engagement, analysis
to support the energy storage programs, data management and
reporting, and various support services including legal,
marketing, and information technology.
Implementation support costs for the programs are
estimated at $15 million, $1.9 million of which is available
through existing uncommitted funds and the remaining $13.1
million of which is requested from the Commission.
Implementation support costs include costs for technical support
for wholesale and distribution market analysis, interconnection
and hosting capacity, power system modeling, as well as quality
assurance including field and photo inspections, and
measurement/verification.
The Roadmap calls for $3 million in funding for
program evaluation activities. Program evaluation activities
include impact assessments to verify portfolio performance,
market characterization studies needed to uncover market
barriers that slow market transformation, and process evaluation
activities to help understand customer satisfaction with the
program processes.

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CASE 18-E-0130

The New York State Cost Recovery Fee (CRF) is a fee

assessed to NYSERDA and other public authorities by New York for
an allocable share of state governmental costs attributable to
the provision of services to public benefit corporations,
pursuant to Public Authorities Law §2975. NYSERDA’s CRF for the
past six fiscal years averaged 1.1 percent and when applied
across their programs weighted by the average program
expenditures, the proposed retail and residential energy storage
programs account for $8.9 million in new funding related to the
CRF. 74 In total, the Roadmap calls for $30.0 million on a net
present value basis or $39.6 million on a nominal basis in new
funding relating to administration, implementation, program
evaluation, and CRF costs.
Total incentives for the residential, retail, and bulk
program, inclusive of administrative costs, on a net present
value basis, are estimated to cost between $1.29 billion and
$2.01 billion, paid out and collected from ratepayers over 21
years. The Roadmap presented electric customer bill impacts for
residential customers estimated between 0.38 percent and 0.59
percent on average across the 21-year period, which equates to
about $0.40-$0.64 per month for the average residential
customer. The range in estimate is attributable to forecast
uncertainty in wholesale energy and capacity payments which are
used to estimate the future costs of the indexed storage
credits.
The analysis performed for the Roadmap estimated that
deployment of 6 GW of storage by 2030 will yield an estimated
$1.94 billion (net present value) in net societal benefits to
New York, due to increased delivery of renewable energy and
reduced reliance on other more expensive firm capacity

74 Roadmap, pp. 66-7.

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CASE 18-E-0130

resources. These benefits reflect the value of avoided

electricity system expenditures. Further societal benefits, not
quantified here, would include improved air quality in
communities impacted by fossil generation.
The Roadmap contemplates two different funding
mechanisms for the energy storge programs, one for the bulk
program and one for the retail and residential programs. The
different funding mechanisms reflect the variance in program
structure. For the bulk program, the Roadmap recommends a
funding mechanism akin to the one employed for Tiers 2,3, and 4
of the Clean Energy Standard and Offshore Wind Standard, which
would require jurisdictional LSEs to pay in proportion to their
share of statewide load and be collected from customers through
the supply charge over the period 2029 to 2044. 75
The retail and residential energy storage programs are
structured such that payments to awarded projects are made at
the time of commissioning using a fixed-rate incentive. The
Roadmap recommends using a pay-as-you-go methodology, like what
is done in other Clean Energy Fund programs, such as NY-Sun,
collected from jurisdictional electric utilities on a statewide
MWh load ratio share basis and expected to be collected from
customers through the delivery charge over the period 2024 to
2030. 76 As discussed earlier, the Roadmap recommends that NYPA

75 See CES Framework Order.

More information on how the Clean Energy Standard has been
implemented: NYSERDA, Large-Scale Renewables, available at:
https://www.nyserda.ny.gov/All-Programs/Large-Scale-
Renewables.
76 Case 14-M-0094 et al., Clean Energy Fund, Order Authorizing
the Clean Energy Fund Framework (issued January 21, 2016), p.
98 (Clean Energy Fund Order). The Clean Energy Fund Order
authorized the Bill-As-You-Go approach to better match
collections with expenditures. This is the exact methodology
referred to in the Roadmap as “pay-as-you-go”.

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CASE 18-E-0130

and LIPA, as non-jurisdictional LSEs, voluntarily participate in

collections for all three programs.
Comments
NineDot supports the budget proposal described in the
Roadmap as a prudent use of ratepayer funds that will provide
environmental, financial, and social-equity benefits to New York
ratepayers. NYSEIA recommends the Commission approve the budget
for the energy storage programs discussed in the Roadmap. MI
opposes the total proposed cost of the energy storage programs
and urges the Commission to view the proposed energy storage
programs in conjunction with other high-cost initiatives the
Commission has previously authorized.
In response to the Updated Roadmap, Sierra Club states
that the higher cost estimates are modest compared to
alternative methods to achieve the State’s climate goals. The
City explains that the cost estimates in the Updated Roadmap are
likely to increase over time, accelerating the need for the
Commission to approve the Roadmap so that energy storage
procurements can commence. NY-BEST, ACE NY, the Solar Energy
Industries Association, and NYSEIA support the Updated Roadmap’s
revised estimated costs as necessary to build out 6 GW of energy
storage statewide by 2030 and assert that the benefits of doing
so justify the increased costs.
Commission Determination
Retail and Residential Program Costs
The Commission approves the $814.6 million in funding
requested in the Roadmap for the continued expansion of the
retail and residential energy storage programs necessary to meet
our goals. This includes $775 million in program incentives and
$39,648,139 for program administration, implementation support,
program evaluation and the CRF expense as detailed in the
Roadmap. This funding is critical to successfully implement the

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CASE 18-E-0130

retail and residential energy storage programs and will give

developers certainty into what resources are available for the
pursuit of energy storage projects. The NYSERDA retail and
residential program costs collections undertaken in accordance
with this Order shall be allocated across the electric utilities
and LIPA based on a MWh load ratio share. This is an equitable
approach since the programs are intended to achieve statewide
climate goals that will benefit all ratepayers equally. The
pro-rata share allocated to each electric utility and LIPA is
shown in Appendix F. LIPA is encouraged to voluntarily
participate and accept its allocation of the retail and
residential program costs. With this approach, both NYPA and
LIPA customers are eligible to participate in the programs.
The costs for these programs are expected to be incurred over
the period 2024 to 2032. Therefore, electric utilities are
directed to collect their proportional share of the costs, as
identified in Appendix G, annually, over the period 2024 through
2032. For 2024, the amounts shown shall be collected over the
remaining months of 2024 once the applicable tariff changes
become effective.
To effectuate the cost recovery from NYPA customers as
discussed earlier, the electric utilities shall recover
NYSERDA’s retail and residential program costs from all
customers, including NYPA customers that receive delivery
service from the electric utility. The delivery surcharge to be
used for each electric utility is shown in Appendix E and each
has a distinct name, including the System Benefit Charge for
NYSEG and RG&E; the Clean Energy Standard Delivery Charge for
Con Edison, National Grid, and O&R; and the Clean Energy
Standard Surcharge for Central Hudson. Each utility shall file
tariff amendments necessary to effectuate the recovery of costs
associated with the retail and residential storage programs

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CASE 18-E-0130

through each applicable delivery surcharge. The tariffs are to

go into effect on a permanent basis on October 1, 2024, and are
to be filed on not less than 30 days’ notices.
We authorize the use of the Bill-As-You-Go mechanism
to transfer funds for the retail and residential energy storage
programs from the utilities to NYSERDA. This mechanism, which
the Commission has utilized for the transfer of funds from
utilities to NYSERDA for a number of clean energy programs,
allows for NYSERDA to bill the utilities for projected
expenditures of the program based on maintaining a two-month
working capital balance. 77 NYSERDA shall enter into a separate
agreement with LIPA to address LIPA’s proportional contribution
to these programs. NYSERDA is directed to file with the
Secretary to the Commission an updated Bill-As-You-Go Summary
for the retail and residential energy storage program costs,
within 60 days of the issuance of this Order. NYSERDA and the
electric utilities are directed to execute any necessary changes
to the individual Bill-As-You-Go funding agreements within 90
days of the issuance of this Order. 78 NYSERDA shall file an
updated Clean Energy Fund Cash Flow Analysis within 30 days of
the issuance of this Order reflecting the collections and
projected expenditures associated with the Retail and
Residential Energy Storage programs. 79
While the Roadmap included the levelized bill impacts
of the proposed storage programs in total, the Commission also
considers the near-term bill impacts on the typical bill of

77 Clean Energy Fund Order, pp. 96-100.

78 When filing with the Secretary, the updated Bill-As-You-Go
Summary should be filed concurrently within Case-14-M-0094.
79 When filing with the Secretary, the updated Clean Energy Fund
Cash Flow Analysis should be filed concurrently within Case-
14-M-0094.

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CASE 18-E-0130

various customer classes of the program being adopted. 80 Table 1

below provides those estimates for the retail and residential
storage program, for the expected highest program cost year,
2030.

Table 1
Retail / Residential
Storage Program Bill
2030 Cost: $211 million, or $0.00178/kWh
Impacts
Residential Commercial Industrial Industrial
HLF
Increase in Monthly $ $ $ $
bills 1.07 22.43 1,281.94 2,307.50

Central Hudson 0.7% 1.2% 1.6% 2.0%

Con Ed 0.6% 0.6% 0.8% 1.0%
National Grid 1.0% 1.4% 1.8% 2.4%
NYSEG 1.1% 1.5% 2.0% 2.3%
O&R 0.8% 1.0% 1.5% 1.8%
RG&E 1.1% 1.1% 1.7% 2.2%

Bulk Program Costs

The costs associated with the bulk program are not
static due to the nature of the indexed storage mechanism and
the fact that the actual results of future competitive
procurements are unknown. This results in the need to look at a
range of costs associated with the procurement of 3,000 MW of
bulk storage projects. The Roadmap presented an estimated

80 Percentage impacts are based on 2023 typical monthly bills for

Residential-600 kWh, Commercial-50 kW; 12,600 kWh, Industrial-
2,000 kW; 720,000 kWh, and Industrial High Load Factor (HLF)-
2,000 kW; 1,296,000 kWh.

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CASE 18-E-0130

program cost ranging between $701.5 million and $1.42 billion on

a net present value basis, which was derived from the range of
$1.33 billion to $2.94 billion in program costs on a nominal
basis. The forecasted annual amounts expected to be incurred
starting in 2028 and continuing through 2044 are shown in
Appendix H. Comparing this range of costs, in addition to the
fixed costs of the retail and residential program to the
expected net benefits, we find it reasonable to approve the
3,000 MW bulk energy storage program. Since the benefits of
this program will primarily be to enable the reliable transition
to a 100 percent renewable electric system, the proposed cost
recovery mechanism described in the Roadmap, which requires
jurisdictional LSEs to be allocated costs in proportion to their
share of Statewide load, is reasonable and therefore adopted.
NYSERDA shall include the processes for calculating and
collecting bulk storage program costs from all statewide LSEs
and NYPA and LIPA. Each utility shall file tariff amendments
necessary to effectuate the recovery of costs associated with
the bulk storage program through an applicable supply surcharge.
As described earlier, we recognize that NYPA and LIPA
have the demonstrated ability to develop/procure bulk storage
projects and therefore NYSERDA shall take such independent
storage procurement into account in its assessment of amounts of
bulk storage needed through its solicitations. Such projects,
subject to meeting the requirements of the bulk storage program,
should also be credited towards NYPA and LIPA load share cost
allocation. NYSERDA shall propose the details of this crediting
process in the bulk storage program implementation plan.
Similar to the bill impact table above, the Commission
considered the near-term bill impacts related to the bulk
storage program. We provide the high end of the cost range,
which we expect customers to experience in 2030 when the program

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CASE 18-E-0130

has achieved the 3,000 MW of procurement. Those bill impacts

are shown in Table 2 below.

Table 2

Bulk Storage Program

2030 Cost: $227 million, or $0.00176/kWh
Bill Impacts
Residential Commercial Industrial Industrial
HLF
Increase in Monthly $ $ $ $
bills 1.05 22.14 1,265.07 2,277.13

Central Hudson 0.7% 1.2% 1.6% 2.0%

Con Ed 0.6% 0.6% 0.8% 1.0%
National Grid 1.0% 1.4% 1.8% 2.4%
NYSEG 1.1% 1.5% 2.0% 2.3%
O&R 0.8% 1.0% 1.4% 1.7%
RG&E 1.1% 1.1% 1.7% 2.1%

CONCLUSION
Today’s Order establishes a 6 GW energy storage
deployment target in New York by 2030. The programs discussed
in the Roadmap and described in this Order will realize a total
of 4,700 MWs of incremental installed capacity of energy storage
spanning the bulk, retail, and residential sectors and move the
State further in its clean energy transition to a reliable
electric grid powered by zero-emission resources. The
Commission expects that continued collaboration between Staff,
NYSERDA, NYPA, LIPA, the NYISO, and other stakeholders in
effectuating the energy storage deployment programs will be
critical to the success of the New York State energy storage
program.

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CASE 18-E-0130

The Commission orders:

1. The New York State Energy Research and Development
Authority shall conduct a minimum of three bulk energy storage
solicitations, held no less than annually. The New York State
Energy Research and Development Authority shall issue the first
bulk energy storage Request For Proposals no later than June 30,
2025, meeting the requirements described in the body of this
Order.
2. The New York State Energy Research and Development
Authority shall apply a procurement target of 20 percent for
long duration energy storage projects in each of the bulk energy
storage procurement solicitations.
3. The New York State Energy Research and Development
Authority shall implement the Index Storage Credit mechanism for
bulk storage, as described in the body of this Order.
4. The New York State Energy Research and Development
Authority shall allow for a one-time inflation adjustment as it
implements the Index Storage Credit mechanism, as directed in
the body of this Order.
5. The New York State Energy Research and Development
Authority shall adopt the operational requirements for the Index
Storage Credit mechanism, as directed in the body of this Order.
6. The New York State Energy Research and Development
Authority shall include maturity requirements for its bulk
energy storage solicitations as directed in the body of this
Order.
7. The New York State Energy Research and Development
Authority shall establish a 15-year maximum contract term length
for lithium-ion battery bulk energy storage projects and a 25-
year maximum contract term length for bulk non-lithium-ion
battery energy storage projects.

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CASE 18-E-0130

8. The New York State Energy Research and Development

Authority is directed to develop a publicly accessible
calculator for Value of Distributed Energy Resources energy
storage projects, as directed in the body of this Order.
9. Central Hudson Gas & Electric Corporation,
Consolidated Edison Company of New York, Inc., New York State
Electric and Gas Corporation, Niagara Mohawk Power Corporation
d/b/a National Grid, Orange and Rockland Utilities Inc., and
Rochester Gas and Electric Corporation shall continue their bulk
storage dispatch rights Request for Proposals process under the
previously approved Utility Dispatch Rights framework.
10. The New York State Energy Research and Development
Authority shall establish a declining block retail energy
storage program to procure 1,500 megawatts of retail energy
storage, as discussed in the body of this Order.
11. The New York State Energy Research and Development
Authority shall consult with Department of Public Service Staff
and conduct stakeholder outreach prior to modifying the
incentive blocks for the retail energy storage program, as
discussed in the body of this Order.
12. The New York State Energy Research and Development
Authority shall establish a 20 megawatt-hour cap for retail
energy storage projects.
13. The New York State Energy Research and Development
Authority shall establish a residential energy storage program
to support the buildout of 200 megawatts of residential energy
storage statewide by 2030, as discussed in the body of this
Order.
14. The New York State Energy Research and Development
Authority shall include language in contracts with energy
storage developers that require paying the New York State
Prevailing Wage, as discussed in the body of this Order.

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CASE 18-E-0130

15. The Department of Public Service Staff shall

prepare an annual report and perform a triennial review for
Commission consideration on the status of the energy storage
programs and progress to date, as well as barriers to success,
consistent with the process initiated in the Energy Storage
Order.
16. The New York State Energy Research and Development
Authority shall use any funding from cancelled retail and
residential projects and apply them to new qualifying projects.
17. The New York State Energy Research and Development
Authority shall procure a minimum of 35 percent of bulk and off-
site retail energy storage projects in the New York Independent
System Operator’s G-K Capacity Zones, as discussed in the body
of this Order.
18. The New York State Energy Research and Development
Authority shall procure energy storage projects in the bulk,
residential, and retail programs in disadvantaged communities
consistent with the allocations described in the body of this
Order.
19. The New York State Energy Research and Development
Authority shall ensure that the procurement of energy storage
projects is consistent with the in-service date requirements
described in the body of this Order.
20. Central Hudson Gas & Electric Corporation,
Consolidated Edison Company of New York, Inc., New York State
Electric and Gas Corporation, Niagara Mohawk Power Corporation
d/b/a National Grid, Orange and Rockland Utilities Inc., and
Rochester Gas and Electric Corporation shall study the non-
market transmission and distribution services that energy
storage can provide, including a bridge to wires use case, as
discussed in the body of this Order; the results of this study

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CASE 18-E-0130

shall be filed with the Commission within 120 days of this

Order.
21. Consolidated Edison Company of New York, Inc. shall
submit a filing within 60 days of this Order detailing the Rider
Q Program, including any suggestions for improvement, as
described in the body of this Order.
22. The New York State Energy Research and Development
Authority shall consider and include fire safety requirements in
its Implementation Plans, as discussed in the body of this
Order.
23. The New York State Energy Research and Development
Authority shall file a bulk storage program Implementation Plan
with the Commission within 120 days of this Order, consistent
with the requirements outlined in the body of this Order.
24. The New York State Energy Research and Development
Authority shall file a retail/residential storage program
Implementation Plan with the Commission within 60 days of this
Order, consistent with the requirements in the body of this
Order.
25. The New York State Energy Research and Development
Authority’s Innovation Program shall continue efforts to
commission Long Duration Storage pilot projects that utilize a
variety of technologies spanning of use cases.
26. As discussed in the body of this Order, funding
for the Retail and Residential energy storage programs and
administrative costs totaling $814.6 million shall be collected
in the manner prescribed in the body of this Order and made
available to the New York State Energy Research and Development
Authority through the Bill-As-You-Go Mechanism.
27. The New York State Energy Research and Development
Authority is directed to file an Updated Bill-As-You-Go Summary,

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CASE 18-E-0130

as discussed in the body of this Order, within 60 days of the

issuance of this Order, as described in the body of the Order.
28. The New York State Energy Research and Development
Authority and Central Hudson Gas & Electric Corporation,
Consolidated Edison Company of New York, Inc., New York State
Electric and Gas Corporation, Niagara Mohawk Power Corporation
d/b/a National Grid, Orange and Rockland Utilities Inc., and
Rochester Gas and Electric Corporation are directed to execute
any necessary modifications to their individual Bill-As-You-Go
Funding Agreements within 90 days of the issuance of this Order.
29. The New York State Energy Research and Development
Authority shall file an updated Clean Energy Fund cash flow
analysis incorporating the collections and projected
expenditures for the Retail and Residential Energy Storage
Programs, within 30 days of the issuance of this Order.
30. The New York State Energy Research and Development
Authority shall enter into an agreement with the Long Island
Power Authority to address its proportional contribution to the
Retail and Residential Energy Storage Programs within 90 days of
the issuance of this Order.
31. Central Hudson Gas & Electric Corporation,
Consolidated Edison Company of New York, Inc., New York State
Electric & Gas Corporation, Niagara Mohawk Power Corporation
d/b/a National Grid, Orange and Rockland Utilities, Inc., and
Rochester Gas & Electric Corporation shall file tariff
amendments necessary to effectuate the recovery of costs
associated with the New York State Energy Research and
Development Authority Bulk, Residential and Retail storage
programs, on not less than 30 days’ notice, to become effective
on a permanent basis on October 1, 2024, as discussed in the
body of this Order.

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CASE 18-E-0130

32. Funding for the bulk energy storage program

incentives shall be collected by jurisdictional load serving
entities in proportion to their share of Statewide load as
described in the body of this Order.
33. Bulk, retail, and residential energy storage
projects procured under the programs described in this Order
shall have an in-service date by December 31, 2030, unless they
meet the criteria described in the body of this Order for an
extension. Energy storage projects procured under the programs
established in the Energy Storage Order may have their in-
service date extended after December 31, 2025, if they meet the
criteria described in the body of this Order.
34. In the Secretary’s sole discretion, the deadlines
set forth in this Order may be extended. Any request for an
extension must be in writing, must include a justification for
the extension, and must be filed at least three days prior to
the affected deadline.
35. This proceeding is continued.

By the Commission,

(SIGNED) MICHELLE L. PHILLIPS

Secretary

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CASE 18-E-0130 APPENDIX A

APPENDIX A- SUMMARY OF STAKEHOLDER COMMENTS

Alliance for Clean Energy New York (ACY NY)

ACY NY recommends that the Commission adopt the ISC
for bulk storage procurement. ACY NY agrees with NYSERDA/Staff
that the ITC allows for hedging opportunities which will reduce
project attrition and reduces financing costs. The similarity
of the ITC structure with NYSERDA’s Tier 1 structure for the
Clean Energy Standard will make it more appealing to developers
as well. ACE NY states that NYSERDA should award more than
1,000 MWs per year in procurements, and at least 1500 MWs in the
first three procurements, to account for attrition and
permitting/interconnection delays, as well as run the
procurements throughout the duration of the life of the ITC
federal tax credit.
ACY NY recommend that NYSERDA publish procurement
goals that detail desired project sizes and locations as a guide
but allow NYSERDA to give out awards that do not necessarily
align with these goals. ACE NY states that distribution-
connected bulk storage will be subject to distribution charging
rates that transmission-connected storage will not and
highlights the need for a pathway for these types of resources
to competitively participate in the ISC procurement process.
ACE NY further states that NYSERDA should make awards for
projects upstate that help with renewable generation
integration.
ACE NY cautions that renegotiating contracts should
only occur in the event of significant market changes so that
developers remain confident they will meet their bid strike
price. They further recommend that NYSERDA incorporate a
uniform round-trip efficiency adjustment as part of the ISC
calculation for the Reference Energy Arbitrage Price to account
for the actual operating characteristics of energy storage
systems more accurately. ACE NY opposes utility ownership of
bulk storage in competitive markets and states that it will
chill private developer investment and create an uneven playing
field between a potentially utility-owned rate-based energy
storage asset and a privately developed project. Ultimately,
this will lead to less investment of storage in New York.
For retail and residential storage, ACE NY recommends
that NYSERDA set an initial total block size of at least 750
MWs, noting that NYSERDA can adjust levels as necessary. In
Zones A-G ACE NY recommends that NYSERDA consider establishing
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CASE 18-E-0130 APPENDIX A

separate incentive blocks for solar-plus storage vs. standalone

storage as paired solar and storage is not subject to demand
charges and has additional revenue streams available.
Standalone storage provides benefits such as enabling greater
operation flexibility and shifting feeder demand, therefore
providing adequate incentives for these sorts of projects is
important.
ACY NY supports NYSERDA implementing maturity
requirements, such as permitting approvals and interconnection
deposits, for projects to reserve incentives. ACE NY cites
interconnection challenges and needed reforms as a motive to
expediently interconnect retail storage and points to
suggestions proffered in the Interconnection Policy Working
Group and Interconnection Technical Working Group as suggestions
of where improvements can be made. Regarding residential
storage, ACE NY states that upfront incentives for residential
storage should not be tied to future performance, as this is
burdensome to the industry. ACE NY supports SATA and states the
need for state and regional transmission planning to incorporate
SATA as a potential solution. It further states SATA should be
open to independent developers as this will maximize the cost
effectiveness of the technology. ACE NY recommend that the
Joint Utilities be directed to modify their Coordinated Grid
Planning Process to explicitly require soliciting storage as
transmission as a non-wires alternative to meet local needs, as
well as recommending that the State request the NYISO implement
tariff changes to incorporate SATA into their planning processes
and adopt cost recovery/allocation methodologies expeditiously.
ACY NY recognizes that benefits of Long Duration
Energy Storage (LDES) and recommends that the Commission define
LDES as 8+ hour duration and encourage investment in a wide
variety of LDES technologies through a NYSERDA funded
demonstration project program. ACE NY recommends NYSERDA reach
out to municipalities to educate on the purpose and need for
energy storage and get ahead of any local permitting issues.
ACE NY recommends NYSERDA conduct separate 4- and 8-
hour storage solicitations as the price differences between the
two are difficult to compare. Additionally, ACE-NY recommends
that NYSERDA include a Disadvantaged Communities incentive adder
for retail standalone and solar-plus storage projects upstate,
and states that the residential storage program should allocate
a minimum of 35 percent of the 200 MWs for projects located in
disadvantaged communities.

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CASE 18-E-0130 APPENDIX A

AES Clean Energy Development

AES supports the adoption of the 6 GW energy storage target

and comments that a successful program is not necessarily the
least cost option but rather that the program should prioritize
peaker replacement and integration of renewables. AES comments
that mature storage projects bids are necessary to reduce
attrition and recommends bidders offer transparency into their
strike price bid and revenue assumptions, have certainty of
battery costs, wholesale market participation strategy, and show
evidence of progress regarding permitting and outreach to
Disadvantaged Communities.
AES states that NYSERDA should continue the bulk
storage dispatch rights requirement and consider stringent rules
to remove or cancel projects that are not timely progressing.
AES further comments that flexibility is important for
procurements and that there should be carve outs for specific
locations and duration where needed so that storage deployment
benefits are maximized by reducing grid operational costs and
helping balance supply and demand. AES recommends that projects
should be grouped by NYISO Load Zone so that accurate cost
comparisons can be done.
AES supports the ISC design as the most feasible
procurement option that gives long term certainty to developers.
AES comments recommends that NYSERDA include round-trip
efficiency when calculating the reference energy arbitrage price
to account for the actual operating characteristics of energy
storage systems. AES also states that if the targets are not
met by 2030 that future procurements specify duration
requirements so that the right type of storage resource is
installed when and where needed. AES supports the 35 percent
target of projects installed in Disadvantaged Communities and
recommends that NYSERDA give projects that directly benefit
Disadvantaged Communities a higher value when selecting projects
to contract.
AES recommends that NYSERDA prioritize demonstration
projects for 100-hour storage technologies and make the project
smaller than 24 MWh so that reliability or operational issues
can be dealt with and to observe market reactions. AES states
that multiple long-duration storage pilot projects with multiple
technologies, including redox flow batteries, metal-hydrogen
storage solution, and iron-air solution should be tested; non-
lithium storage proposals should be prioritized to incentivize
innovation.

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CASE 18-E-0130 APPENDIX A

Armada Power
Armada Power supports the goals and intent of the
Roadmap, particularly loosening the requirement to pair
residential storage with renewable generation. Armada Power
urges the Commission to design programs in a technology neutral
manner, including the adoption of thermal, mechanical, and
battery storage. Armada Power recommends that the Commission
and Joint Utilities create opportunities for residential storage
systems to be aggregated and used in demand response programs,
noting that this will help achieve compliance with FERC Order
2222. Armada Power states that storage programs should consider
the needs of different customer types within a customer class,
notably multifamily properties that have high rental turnover
and therefore low residential storage adoption.
Alsym Energy
Alsym Energy comments that the definition of LDES is
too general and that a better definition that delineates
specific use cases would result in more effective LDES
deployment. Alsym Energy notes that LDES with a range of
discharge from 6-100 hours is preferable, as it covers two
different technology types and further comments that charging
time needs to be accounted for when evaluating solutions.
Alsym Energy states that Round-trip efficiency is
important in establishing cost viability and disagrees with the
Roadmap to not take it into account as it can greatly impact
charging costs. Alsym Energy recommends a minimum AC round-trip
efficiency of 70 percent to be considered viable as a grid asset
as well as a self-discharge rate of no more than 15% per month,
although preferably less than 10% as this will reduce operating
costs.
Alsym Energy comments that the installed cost ($/kWh)
of an ESS should be considered before subsidies, as the
installed costs are an indication of project viability; Alsym
Energy recommends a short-term target of $200/kWh and that
NYSERDA establish a standard methodology for calculating total
installed and operating costs. Alsym Energy also states the
importance of taking the cost of land into account when
evaluating the strength of a proposed project.

Bloom Energy

Bloom Energy supports the Roadmap’s conclusion that

both LDES and firm zero-carbon resources are needed to help New

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CASE 18-E-0130 APPENDIX A

York State reach its climate goals and maintain grid

reliability. Bloom Energy recommends that the Commission remain
technology neutral when evaluating LDES technologies and
consider spearheading efforts to develop in-state hydrogen
production and capabilities. Bloom Energy comments that
appropriate compensation structures for hydrogen-based
technologies should be developed, and that the Commission should
consider developing a separate procurement process specifically
for LDES.

BlueWave

BlueWave supports the proposed retail storage program

and ISC for the bulk storage program. BlueWave recommends that
any solicitations not be divided by geography or otherwise to
maximize supply. BlueWave states that NYSERDA and DPS need to
be quick to make any program modifications to the ISC structure,
if necessary, as it is a first of its kind paradigm so there may
be kinks that need ironing out. BlueWave further recommends
that NYSERDA provide information as to the definition of a
peaking plant, and additional guidance as to how benefits to
Disadvantaged Communities will be evaluated so that the 35
percent of program funds dedicated to Disadvantaged Community
benefits is realized.
Regarding distribution-connected bulk storage,
BlueWave states that NYSERDA needs to provide a pathway to the
market for these resources, as they will likely remain
uncompetitive in the ISC solicitation process compared to
transmission-connected bulk storage, as distribution-connected
storage is subject to retail charging rates.
BlueWave recommends that ISC solicitations require
project maturity milestones so that there is a reasonable
expectation that bids are from a developer who has a realistic
chance at moving a project forward. To accomplish this,
BlueWave suggests that projects be in Stage 9 or later of the
NYISO queue or an analogous queue for the distribution system.
For retail storage, BlueWave recommends that per-
project incentives should at a minimum be 20 MWh. Similar to
their view regarding bulk procurements, BlueWave states the need
for maturity thresholds to prevent delays in interconnection and
recommends that eligibility for funding allocation be contingent
on the project having their coordinated electric system
interconnection review and deposit, all necessary municipal and
state permits, demonstration of site control for 15-years, and a
negative SEQR designation.

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CASE 18-E-0130 APPENDIX A

BlueWave states their support for storage as a

transmission asset and recommends that SATA have the flexibility
to provide other services, such as reactive power, if able to
maximize the benefits of the resource. BlueWave further
comments that funding should be appropriated for projects that
demonstrate the ability of storage resources to participate in
the wholesale market and simultaneously provide transmission
services that can defer costly distribution upgrades.

City of New York (The City)

The City supports the expanded energy storage goals
discussed in the Roadmap and provides several recommendations
for improvement.
The City comments that the cost of the proposed
programs is estimated at $1.0 billion-$1.7 billion and is
concerned at the level of uncertainty with these estimates and
how any deviations may impact ratepayers. The City notes that
the Roadmap only estimated residential customer bill impacts,
not major end users and recommends that NYSERDA provide
potential bill impacts analyses for all customer service classes
in their Implementation Plan. The City further recommends that
NYSERDA conduct cost impacts before the first bulk procurement
and annually thereafter. The City recognizes the Roadmap’s
attempt at cost containment but cautions that allowing
developers to seek price increase too easily would negate the
bid cap’s intent. To combat this, the City recommends that the
Commission require developers to include a reasonable cost
increase component into their bid, and that cost increases only
be approved if future prices rise to an unforeseeable amount.
The City shares the concerns outlined in the Roadmap
regarding attrition and recommends that yearly reassessments of
bulk storage inventories are necessary to ensure that sufficient
bulk storage gets built to meet the 6 GW target. This yearly
evaluation is needed due to cost and attrition uncertainty.
The City generally agrees with the ISC proposal and
recommends that the Commission consider implementing a mechanism
to measure battery system performance as part of the bulk
storage procurement program. The City notes that the deployment
and more importantly the actual use of energy storage in or near
New York City is critical in achieving grid decarbonization and
retirement of peaking plants that negatively impact
Disadvantaged Communities, and it is therefore critical that the
Commission direct NYSERDA to include a performance verification

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CASE 18-E-0130 APPENDIX A

mechanism, potentially through verification testing, as part of

their Implementation Plan.
The City comments that it is critical that the
Commission ensure sufficient development of downstate energy
storage capacity and supports the Roadmap’s recommendations to
make downstate specific carve-outs for the bulk storage program
and to recover costs of the program from each LSE on a load-
share basis. The City recommends that NYSERDA assess downstate
energy storage rewards before each procurement to ensure
sufficient energy storage capacity addition, and if they are not
sufficient, give NYSERDA the ability to increase downstate carve
outs. The City also recommends that the utilities and NYSERDA
work with the City to overcome unique permitting and land use
issues to expand the potential number of downstate energy
storage projects.
The City states that the Commission needs to make
clear that NYPA customers are eligible to participate in the
energy storage programs and receive eligible funds if NYPA
voluntarily accepts their funding obligations, as recommended in
the Roadmap.
The City recommends that Con Ed complete their current
solicitation for the current Joint Utilities’ bulk storage
dispatch rights contracts procurement and report on the results,
noting any needed improvements and monitoring for attrition so
that any canceled energy storage capacity is added into a
subsequent bulk procurement.

Clearway Energy Group

Clearway states that they support the joint comments
submitted by the Alliance for Clean Energy New York (ACE-NY),
Advanced Energy United, and the Solar Energy Industries
Association.
Clearway suggests two modifications to the Bulk
Storage Incentive Program. It believes that these changes are
necessary in order to enable NYSERDA to achieve its target of
procuring 3,000 MW of energy storage.
First, Clearway recommends that NYSERDA should revise
its proposal for the Reference Energy Arbitrage Price (REAP) so
that the REAP derives from the nodal price at which the project
settles in the New York Independent System Operator (NYISO) day-
ahead energy market. Clearway states that the proposal does not
consider the significant potential for an invisible gap between
a zonal REAP and actual energy revenue realized at a project.
By tethering the REAP to the nodal price, it ensures that
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CASE 18-E-0130 APPENDIX A

projects can secure financing by eliminating what they call

“basis risk.” Clearway points to its own experiences in
California and Texas where differences between nodal prices and
zonal settlement constrain tax equity appetite for hub-settled
offtake agreements.
Second, Clearway recommends reconsidering the
employment of a “change of law” provision in Bulk Storage
Incentive Program contracts. Clearway states that this
provision is inconsistent with the design of an ISC mechanism.
Finally, Clearway suggests that NYSERDA and DPS staff
consider program design elements from California’s state-led
procurements of utility-scale energy storage assets. Clearway
states that states that ascribe underlying value to projects for
their contribution to system reliability will be most successful
in attracting long-term investment in battery storage projects.
Clearway Energy Group submitted supplemental comments
on April 3, 2023, regarding the bulk energy storage procurement
proposal.
Clearway Energy Group states their concern that the
ISC design will not result in bulk storage projects at scale.
Clearway Energy Group further comments that developers are not
guaranteed any minimum revenue for the contract term and that
merchant revenue in the NYISO markets is so uncertain that it is
extremely difficult for developers to calculate a competitive
Strike Price. It also states that tax equity investors favor
stable revenues over merchant revenues for a nascent resource
class.
Clearway Energy Group comments that under the current
proposal there are not sufficient guardrails to protect against
irrational bidding which occurs when developers do not
accurately reflect their costs, resulting in a lower Strike
Price. NYSERDA could then choose such a project that later
withdraws due to poor economics.
Clearway Energy Group recommends that DPS/NYSERDA
pursue bulk storage procurements using Utility Dispatch Rights,
described in Option #5 in the Roadmap. It states that the long-
term fixed-price contract offered under the UDR paradigm reduces
cost uncertainty for NYSERDA compared to the ISC proposal.
Clearway Energy Group recommends several changes to
the ISC proposal if the proposal moves forward. It comments
that the Reference Arbitrage Price should derive from nodal
prices to attract for capital. It also recommends offering a
fixed-price, long-term credit alongside the ISC so that
developers of bulk storage projects see two revenue streams,
guaranteeing a minimum payment which would entice developer
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CASE 18-E-0130 APPENDIX A

participation in the bulk storage program. Clearway Energy

Group recommend extending contract lengths up to 20-years so
developers can amortize costs over a long period, receive better
financing, and aligns more closely with developer costs. It
also states that the Roadmap’s program cost estimates need to be
broader than the proposed +/- 15% of the base estimate to
account for forecasting and market revenue uncertainty.

Consolidated Edison Company of New York/Orange and Rockland

Utilities (The Companies)
The Companies recognize the ambitious energy storage
targets of the Roadmap and comment that any mechanism must have
enough flexibility to account for and respond to the quickly
changing conditions of the energy storage market and challenges
of the downstate grid.
The Companies support the ISC bulk storage proposal
and in conjunction recommend The Companies be allowed to
continue and improve upon the utility dispatch right (UDR)
procurements for third party or utility-owned storage. The
Companies propose the creation of a “Bridge-to-Wires” (BTW)
mechanism under the UDR intended to enable faster end-use
electrification through deferring the building of traditional
infrastructure with the idea that these storage projects could
be relocated when no longer needed to other areas of the system
to further enable end-use electrification. The Companies point
out the potential of BTW to procure projects that can provide
wholesale services and alleviate distribution needs, increasing
projects’ estimated revenue leading to lower bids and increased
competition. The Companies request Commission approval of the
BTW UDR design and authorization for The Companies to submit an
Implementation Plan detailing the design.
The Companies recommend the existing UDR energy
storage target goals of 300 MWs and 10 MWs for Con Edison and
O&R respectively should not decrease, and that the Commission
should allow flexibility of the targets between the UDR, BTW,
and ISC processes to maximize installed energy storage. The
Companies further recommend the removal of a firm commercial
operation date and establish project timelines through the
contracting process.
The Companies propose to work with Staff to determine
how to include the value of enabling faster electrification
through the proposed BTW framework in their Implementation Plan.
They further recommend that the Commission retain the net
benefits incentive described in the Energy Storage Order and

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expand it to include transmission and distribution benefits, as

well as wholesale revenues. The Companies also propose a 15-
year amortization period for UDR payments which is consistent
with other programs and moderates bill impacts for customers.
The Companies support the continuation of the retail storage
program and an expansion to include the creation of a behind-
the-meter storage incentive, in consultation with NYSERDA and
Staff. They reason that this would enable quicker energy
storage deployment in Disadvantaged Communities. The Companies
request to develop a BTM implementation plan within 90 days of a
Commission Order.
The Companies support the recommendation in the
Roadmap to undertake a comprehensive study for utility storage
that is integrated into the distribution system. The Companies
state that this study may take a while and therefore recommend
that the Commission allow the Companies to submit a filing
within 90 days of an Order that outlines defined storage use
cases with a solicitation and implementation framework that
could allow for quicker deployment of individual projects. In
general, The Companies support utility-owned storage because of
its value in providing grid services and that utility-owned
storage should be incorporated into local and transmission
planning processes.

Convergent Energy and Power

Convergent Energy and Power (Convergent) supports
Staff’s analysis and the adoption of an energy storage
deployment goal of 6 gigawatts (GW) by 2030. Convergent notes
that both the growing sophistication of storage solutions and
the concurrent opportunity to leverage the Federal Investment
Tax Credit and other sources of financing makes this window of
time both a critical but advantageous one to deploy energy
storage and create solutions for the State’s changing grid.
Convergent supports the proposed funding and capacity
allocation framework in the Roadmap. While it appreciates the
inclusion of both NYPA and LIPA, it notes that their progress
should be regularly reviewed in order to inform adjustments to
the size and scope. In addition to regular review of both NYPA
and LIPA, Convergent recommends that Staff provide opportunities
for public review of the Roadmap and its programs to allow for
adjustments to ensure uninhibited progress towards the 2030
goal. Convergent states that potential changes, in categories
enumerated in its comment, ensure that the Roadmap’s well-
founded principles will not conflict with real-world conditions

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CASE 18-E-0130 APPENDIX A

in the future, and will not impede continued storage

development.
Convergent makes a number of recommendations
specifically about the Bulk Storage Program. Specifically,
Convergent concurs with Staff’s selection of the Index Storage
Credit as a means to incentivize bulk storage development.
However, Convergent notes that differing duration times require
the creation of separate Reference Prices to appropriately
assess proposals. Additionally, Convergent states that the
assumptions and formulas used to craft Reference Prices must be
made transparent and subject to stakeholder feedback.
Convergent recommends that the derivation of the
Reference Energy Arbitrage Price should include a Round Trip
Efficiency (RTE) factor. Convergent goes on to state that Staff
should adopt a standard RTE assumption for each duration class.
In order to facilitate financing and mitigate risk,
Convergent states that the Commission should create a ceiling
value for the differential between Reference Prices exceeding
Strike Prices and provides different methods for how this could
be enacted. Convergent states that enacting this ceiling value
ensures that projects are not punitively subject to situations
in which price and operating conditions are both wildly altered,
but still incents projects to optimize performance.
Convergent agrees with Staff’s recommendation
regarding a one-time adjustment to Strike Price for accepted
projects to adjust for inflationary changes but cautions that
this should be accompanied by clear parameters. Convergent
urges staff to take this suggestion a step farther and establish
a one-time option for assets to reapply their interconnection
agreement in a following Class Year. Convergent states that
this would allow developers to avoid scenarios in which cost
allocation deviates from initial estimates and impacts project
economics.
Convergent also agrees with staff’s inclination to
include non-price factors in the evaluation of bids and further
recommends that projects should be recognized and encouraged to
demonstrate advanced maturity, local grid emission reduction, or
unique project design and configuration when submitting bids.
Finally, as it relates to bulk storage, Convergent
cautions that the design and administration of the Bulk program
must be considered to avoid excluding smaller bulk storage in
the 5 to 20 MW range. Convergent states that by providing a
different incentive level and/or carve-out for this segment, the
State could capitalize on the benefits of the smaller bulk
storage systems.

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CASE 18-E-0130 APPENDIX A

Regarding the Retail Storage Program, Convergent

supports staff’s recommendation and believes that the Retail
Storage program should be opened as soon as possible to allow
for a strong start to the program.
Convergent recommends increasing the 15 MWh incentive
cap to 20 MWh, to encourage longer durations, incentivize
efficient project design, and improve economics in a wider
geographic reason. Also related to valuations, Convergent
supports Staff’s recommended public Value of Distributed Energy
Resources calculator for storage assets.
Regarding the upstate retail storage market,
Convergent recommends that an inventive be provided for upstate
solar-paired storage, which would encourage the development of
value-accretive solar assets that can bolster storage economics
and deliver benefits to the region.
Convergent states that behind the meter non-
residential assets must be incentivized and recognized as a
subset of the retail program for their unique ability to curb
demand, provide resiliency, and support the private sector’s
commitments to decarbonization.
Convergent supports Staff’s assessment of the need for
long duration energy storage. Furthermore, Convergent states
that long duration R&D initiatives and opportunities be made
transparent, competitive, and well-defined in order to encourage
innovation.
As it relates to storage as a transmission asset or a
non-wires alternative, Convergent commends Staff for
acknowledging the value and promise of these systems.
Convergent notes the value that storage assets have and the
different scenarios in which they can be used. Convergent
states that non-wires alternative programs should not be
excluded outright from deriving incentives. Despite their
enthusiasm for these assets, Convergent cautions including these
solutions towards the 6 GW target as it could skew market
signals. Convergent instead recommends that non-wire
alternatives should be considered under grid planning
initiatives.
Convergent highlights the need for alignment and
transparency in utility processes. Convergent supports the
Roadmap’s emphasis on wide participation and encourages Staff to
hold stakeholder forums on the dual participation model.

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CASE 18-E-0130 APPENDIX A

Sunrun Inc, PosiGen Inc, SunPower Corp, Tesla (Collectively, DER

Parties)
DER Parties support the recommendation to expand the
residential storage program statewide. DER Parties state that
an upfront incentive for statewide deployment of residential
storage will support early adoption, increase residential
storage deployment, and inform best practices for
interconnection, siting, and permitting.
DER Parties state that eligibility for an upfront
incentive should not require participation in other programs.
They believe that storage provides grid benefits on its own, and
currently there are limited opportunities for residential
storage to participate in other programs. However, DER Parties
emphasize that there should also not be a restriction on
participation in performance programs that become available.
DER Parties request that Staff and NYSERDA expand directives for
the Joint Utilities to explore programs that provide benefits
like load reduction and energy exports, and specifically,
opportunities for “Bring-Your-Own-Device” programs.
DER Parties support the recommendations of NYSEIA to
increase the Residential Storage Program’s target capacity of
200 MW to at least 400 MW. DER Parties also support increasing
the residential storage program initial funding target of $72
million on a $/MW basis stating that the current incentive
amount will not be enough to animate the market.
DER Parties recommend that the upfront storage program
should provide a clear timeframe for which a project must
receive permission to operate after it receives an incentive
reservation in order to remain eligible for that incentive. DER
Parties also support maintaining the current timeline for solar
PV incentives.
DER Parties agree with Staff and NYSERDA that
residential storage projects located within disadvantaged
communities should be deemed to be providing local benefits.
DER Parties asks that Staff and NYSERDA consider providing an
increased rebate for projects located in disadvantaged
communities.
DER parties note the importance of Authorities Having
Jurisdiction fire code issues and ask Staff and NYSERDA to
support engagement on these issues where possible.

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CASE 18-E-0130 APPENDIX A

Council Member Julie Won, Assemblymember Robert Carroll, Senator

Kevin Parker, Council Member Rafael Salamanca, Jr. (the Elected
Officials)

The Elected Officials strongly urge the Commission to codify a

downstate carveout of two-thirds of the energy storage to be
procured under the bulk storage program. They reason that this
carveout is necessary in order to ensure compliance with the
CLCPA directives. The comments express concern that without the
carveout, there is a risk that the procurement does not result
in a sufficient number of energy storage projects downstate to
reduce the usage of fossil-fueled peaker plants in disadvantaged
communities.
Elevate Renewables “Elevate”
In its initial comments, Elevate supports the proposed 6GW
energy storage deployment target. Elevate recommends that
energy storage deployment be paired with fossil generation sites
and utilize their existing electrical interconnections to
minimize system upgrade costs. Elevate supports locating
significant amounts of bulk energy storage sites in Zone J to
reduce transmission bottlenecks from upstate to downstate.
Elevate states that energy storage projects should be
located within Environmental Justice and Disadvantaged
Communities to improve reliability, integrate renewable
generation, and reduce the use of high-emitting peaking plants.
Elevate further recommends that a portion of the proposed 3GW
bulk energy storage program be directed towards the
redevelopment and remediation of brownfield sites.
Elevate supports the ISC as the primary financial mechanism
of the bulk energy storage program and declining block structure
for the retail and residential energy storage programs. Elevate
states that NYSERDA procure the full 6GW of energy storage
irrespective if other state agencies conduct their own energy
storage procurements due to the possibility of canceled projects
and supply chain disruptions.
Elevate states that investor-owned utilities should be
prohibited from owning and operating energy storage resources
due to their disproportionate market power and instead
recommends independent and private ownership of energy storage
facilities.

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CASE 18-E-0130 APPENDIX A

Energy Hub
EnergyHub supports the Roadmap’s recommendation to
adopt an ambitious, but necessary, deployment target of 6 GW of
energy storage by 2030.
EnergyHub is encouraged by the proposed continuation
and expansion of the retail and residential storage incentive
program. Specifically, EnergyHub notes that the 200 MW
residential storage target is reasonable and an appropriate
approach. EnergyHub supports the use of up-front incentives and
incentive blocks. Additionally, EnergyHub is supportive of the
procurement schedule, but notes that we may see more significant
growth than initially anticipated early in the program
lifestyle. EnergyHub recommends that future load management
participation mechanisms should include options for both
“passive” discharge, as adopted in other jurisdictions, and
“active” demand reduction.
EnergyHub supports the Roadmap’s encouragement of
examining program designs and mechanisms for enabling energy
storage owners to participate in demand response programs.
Regarding load management participation models, EnergyHub agrees
with survey respondents that utility Bring Your Own Device
programs have a proven history of success. EnergyHub suggests
that grid services participation mechanisms should recognize the
full complement of grid benefits, maximize system configurations
and hardware eligibility, and allow for flexibility in the
administration of incentive payments. Moreover, EnergyHub
recommends that load management mechanisms should allow
customers and third-party aggregators to be compensated for bulk
system services as well as distribution-level services.
Additionally, EnergyHub suggests that various grid
service participation models, including utility-managed
programs, direct aggregator participation in the NYISO markets,
a parallel combination of both, or consolidation of these
models, should be considered. EnergyHub also recommends that
retail and residential incentive programs should limit incentive
eligibility to the battery technologies and vendors that support
third-party operational control and integration with modern
DERMS platforms.
EnergyHub makes specific recommendations for
geographic and demographic considerations. EnergyHub supports
the Roadmap’s emphasis on deployment of residential storage in
disadvantaged communities. While EnergyHub suggests that
stakeholders evaluate incentive mechanisms to accelerate program
adoption in marginalized customer segments, it notes that

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CASE 18-E-0130 APPENDIX A

incentives and future load management mechanisms be open to all

regions and customer classes in order to reduce complexity and
encourage project installers. EnergyHub concurs with the
Roadmap’s recommendation to design the program to ensure a
significant portion of energy storage is deployed downstate.
However, EnergyHub notes that the program should not cap
deployment in the upstate service areas.
Responding to question 7.5, EnergyHub states that up-
front incentive adders for Disadvantaged Community customers
should be considered. These incentives must be healthy enough
to entice installers to incorporate incentive administration
into their customer offering and acquisition process. EnergyHub
makes the same recommendation for load management incentives.
EnergyHub suggests that stakeholders should consider a
variety of grid and societal benefits in the development of
hardware installation incentives and future load management
pathways. In addition, EnergyHub suggests that customers “at
the edge of the grid” should be eligible for additional up-front
hardware incentives. Moreover, the assignment of installation
incentives should be allowed in order to increase attractiveness
of the programs to home electrification providers.
EnergyHub recommends that simple customer eligibility,
technology qualification, program enrollment and data reporting
requirements should be development to maximize participation and
interest. Additionally, EnergyHub suggests leveraging the IT/OT
infrastructure that utilities already have in place in the
development of load management program designs. EnergyHub
endorses the eligibility of standalone storage for residential
block incentives and future load management participation.
EnergyHub further recommends that load management
program designs should allow for the use of device-level
telemetry for the determination of delivered energy or capacity
from participating systems. The load management programs should
also permit discharge to the grid. EnergyHub states that
programs that prohibit grid export or limit demand response
participation to household self-consumption will leave valuable
capacity on the table, while struggling to incentivize
meaningful levels of customer enrollment. Finally, EnergyHub
reasons that as load management participation options for energy
storage mature, it will be important to consider mechanisms for
combining ongoing performance incentives with up-front
residential block incentives as they are a powerful tool for
customer acquisition and accelerating the deployment of
residential storage on the grid.

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CASE 18-E-0130 APPENDIX A

EnSynchrony
EnSynchrony recommends broadening the Roadmap to
consider energy storage in the transmission environment. It
states that “Storage as Transmission” as described in the
Roadmap will not provide sufficient revenue and recommend that
storage be designated a “Transmission Facility” for purposes of
NYISO planning studies; absent this designation EnSynchrony
comments that storage as transmission will not come to fruition.
Fermata Energy
Fermata Energy (Fermata) commends NYSERDA and DPS for
assembling a visionary and thoughtful straw proposal for the
Commission. However, Fermata encourages the Commission to
consider mobile energy storage resources enabled by vehicle-to-
grid (V2G) charge management of electric vehicles.
Fermata proposes a V2G target in addition to the 2030 6 GW
stationary storage target based on the inverter capacity of
installed bidirectional charging infrastructure. Specifically,
Fermata recommends a minimum 1.5 GW V2G target based on existing
projection of EV sales and conservative estimates of V2G
technology adoption. Fermata notes that its estimates are based
on the NYISO Gold Book projections.
Fermata states that New York could be the first state
to adopt a V2G deployment target. Fermata recommends the
Commission engage a consultant to evaluate the potential
capacity and value to the grid and ratepayers. Further, Fermata
notes that incentivizing bidirectional infrastructure investment
can ensure New York has the grid flexibility resources necessary
to achieve its grid decarbonization goals.

Form Energy
Form Energy notes that prior decarbonization studies
identified that New York needs more than 20 GW of dispatchable
emission-free resources by 2040, which emerging long-duration
storage technologies can provide. Relatedly, Form Energy states
that the Storage Roadmap analysis does not evaluate needs for
emerging long-duration energy storage resources or how they can
fulfill needs for dispatchable emission-free resources in spite
of the availability of these technologies by 2030.
Form Energy expresses concern that the State is at
risk of significantly under-investing in emerging long-duration
and multi-day energy storage in the near-term because of
limitations in Storage Roadmap modeling. Form Energy cites,

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CASE 18-E-0130 APPENDIX A

what they believe are, three key limitations: 1) limited

technology representation; 2) limited grid chronology; and 3)
limited evidence of 2030 needs. Despite these limitations, Form
Energy acknowledges that Storage Roadmap modeling is
directionally correct about long-term needs.
Form Energy conducted analysis to identify the least-
cost portfolio of diverse emerging long-duration and multi-day
energy storage to meet New York’s 2030 and 2040 clean energy
goals and fulfill needs for dispatchable emission-free
resources. Based on this analysis, Form Energy recommends that
NY should establish a minimum deployment target for long-
duration energy storage by 2030 that is at least half of the
remaining storage target. Form Energy states that this could be
done in one of two ways: 1) reserve half of the Roadmap’s
proposed 3 GW bulk storage target for emerging long-duration and
multiday energy storage; or 2) establish a pathway for
discussions to advance an additional 3 GW bulk storage target
dedicated to non-lithium-ion long-duration and multi-day energy
storage resources.
Form Energy supports the proposed Index Storage Credit
Program. Form Energy recommends that multi-day energy storage
should be explicitly eligible to participate in the Index
Storage Credit Program, not solely 4- and 8-hour storage. Form
Energy states that actions to exclude long-duration and multi-
day energy storage resources from the program would be
arbitrarily prejudicial and would harm the ability of those
resources to compete in the market. Form Energy also recommends
that under the Index Storage Credit Program, NYSERDA should have
flexibility to separately procure long and multi-day storage
resources if the program preferentially favors short-duration
storage.
Form Energy recommends that credits should be awarded
for every MWh of rated energy storage capacity available.
Taking this approach can help ensure neutrality between storage
resources, regardless of storage duration.
Regarding reference price periods, Form Energy agrees
that to accommodate energy storage technologies with different
durations and efficiencies, it is reasonable for the periods
used to evaluate the Reference Energy Arbitrage Price to vary
based on the x-hour duration of the resources. Form Energy
further agrees that it is administratively efficient to omit
round-trip efficiency losses from the Reference Price
calculation.
Form Energy notes that there are barriers to multi-day
energy storage. Specifically, NYISO’s capacity market and

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CASE 18-E-0130 APPENDIX A

ancillary services markets do not differentially value and

compensate multi-day storage or firm zero carbon resources for
their reliability services. Form Energy also states that
another limitation with the NYISO market is that there is not a
means for multi-day storage to directly access both transmission
enhancing value and energy value – storage must either
participate as transmission or in the energy market.
Additionally, Form Energy points out that NYSERDA’s clean energy
procurement programs currently seek and prioritize the lowest-
cost as-available renewable energy on a per REC basis and do not
preferentially seek or compensate paired renewable energy and
storage resources.
Form Energy recommends that New York lift round-trip
efficiency and experience requirements on existing bulk storage
procurement and incentive programs, and avoid establishing such
eligibility barriers in the future.
Regarding demonstration projects, Form Energy supports
large-scale demonstration projects of emerging long-duration and
multi-day energy storage resources. Form Energy suggests that
NYSERDA and the Commission fund multiple technologies and
multiple use cases in multiple locations; prioritize use cases
including demonstrating firm dispatchable capacity, optimizing
transmission system value, and supporting grid reliability and
resilience during atypical weather and grid conditions; and
prioritize resources that can deliver firm capacity to meet
future DEFR needs.
Form Energy recommends that NYSERDA should support at
least three large-scale demonstration projects with commercial
online dates before the end of 2028. Form Energy suggests that
these projects have a commercial online date no later than the
end of 2028 and to contract projects no later than the end of
2025. Additionally, Form Energy proposes that NYSERDA and DPS
should ensure that NY pairs demonstration project support with
additional procurement opportunities.
Form Energy encourages New York to create a diverse
set of procurement and incentive programs for emerging long-
duration and multi-day energy storage resources. Regarding the
bulk-dispatch rights program, Form Energy recommends removing
the program’s minimum efficiency and experience requirements.
Form Energy recommends that New York create new programs that
specifically contract for firm, dispatchable emission-free
capacity, and recommends expedited efforts to establish the
performance that such resources must deliver.
Form Energy supports NYSERDA’s intention to maintain
the eligibility of co-located and separately located energy

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CASE 18-E-0130 APPENDIX A

storage projects in bids submitted to the Tier 1 and OSW

solicitations. Further, Form Energy recommends modifications to
Tier 1 and OSW procurement to specifically seek firm
dispatchable resources enabled by energy storage.
Form Energy suggests that the Commission should allow
some limited utility ownership of emerging multi-day storage
technologies that act as reliability assets to support system
benefits, reliability, innovation, and benefits for
disadvantaged communities. Form Energy notes that utility
ownership can be more expedient and beneficial in the near-term
than the administratively complex Bulk Dispatch Rights
procurement program.
Attached to Form Energy’s comment is their Analysis of
the Value of Multi-Day Energy Storage in New York.

FreeWire
FreeWire asks the Commission to explicitly include
storage integrated into charging infrastructure in their
programs. FreeWire supports the recommendation of DPS and
NYSERDA for NYPA and LIPA to participate in the roadmap. It
specifically mentions that LIPA’s C&I customers would benefit
from the roadmap’s retail and residential programs.
FreeWire states that the roadmap fails to distinguish
between FTM and BTM storage in the retail segment and suggests
that this would lead to non-residential BTM installations
competing with larger FTM projects, to their detriment.
FreeWire recommends that non-residential BTM storage receive its
own procurement target and incentive that is separate from
retail FTM installations.
FreeWire states that BTM systems can increase demand
flexibility by responding to retail programs and rates, such as
charging when prices are low and discharging when prices are
high on a time-of-use rate.
FreeWire states that BTM C&I facilities increase
resiliency by providing backup power, which can have broader
community benefits, such as keeping the power on in a store,
community center, or first responder station.
FreeWire states that a Virtual Power Plant which
aggregates BTM systems can reduce the need for peaking
facilities, which are often located in LMI, disadvantaged, and
Tribal communities.
FreeWire notes that BTM storage can help avoid or
defer costs of building out the distribution system in
constrained areas and suggests that utilities could publish
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CASE 18-E-0130 APPENDIX A

locations where BTM storage would benefit the system and target
incentives toward those areas. FreeWire also supports doing
this by further developing the Joint Utilities’ hosting capacity
maps.

GreenSpark Solar
GreenSpark supports the approval of the Energy Storage
Roadmap as an important step in reaching New York State’s
climate goals. GreenSpark comments that consistent funding is
necessary to provide market certainty, and that the proposed
retail incentive funding is not enough to make projects economic
even after accounting for the federal Investment Tax Credit and
VDER revenue. GreenSpark notes that utilizing a variety of
storage technologies of different durations will bolster grid
reliability and that adequate compensation is needed to support
diverse storage technologies. GreenSpark also comments on the
importance of local zoning laws to a project’s success and the
need to develop a battery recycling industry in New York State.
Hydrostor
Hydrostor recommends that the remaining Joint
Utilities’ Bulk Storage Dispatch Rights procurement should be
combined with the bulk storage target and be procured by
NYSERDA.
Hydrostor supports the conclusions that there is a
clear benefit to storage with durations of 8-hours, and that
NYSERDA bulk storage solicitations should explicitly carve out
part of each procurement for 8-hour storage resources.
Hydrostor recommends that NYSERDA procure 1.5 GW of 8-hour
storage in the bulk storage procurements for a number of
reasons.
Regarding location, Hydrostor recommends against a
mandatory location requirement or specific downstate carveout
for NYSERDA’s RFPs. Hydrostor cites to the fact that land
downstate is either expensive or unavailable, and could limit
the MW scale of projects. Instead, Hydrostor recommends that
NYSERDA should consider location as just one factor in the
evaluation process.
Hydrostor is supportive of the Index Storage Credits
(ISC) concept. However, Hydrostor is concerned with the Round-
Trip Efficiency (RTE) as it is potentially not technology
agnostic, and disadvantage innovative, low-cost non-lithium-ion
technologies, causing higher costs and less technology diverse
and reliable electricity system. Hydrostor also recommends that
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CASE 18-E-0130 APPENDIX A

RTE should be used in determining how many hours of arbitrage

are economical. While Hydrostor agrees with NYSERDA and
Commission staff that accounting for duration and RTE add
complexity, in this case, the significant negative impact to
development effectiveness for long duration storage outweighs
the potential complexity; therefore, Hydrostor recommends that
project specific RTE should be used.
Hydrostor recommends contract length terms that can
extend to at least 25 years and potentially to 40 years for
certain technologies. Hydrostor notes that the 15-year contract
term is likely based on program date of lithium-ion based
batteries and is not applicable to all storage technologies.
In order to incentivize benefits to disadvantaged
communities, Hydrostor recommends additional incentives for
development in certain communities of New York. Hydrostor notes
that construction of an -CAES and ongoing operation will create
many direct and indirect local jobs.
Hydrostor is supportive of additional funding that
would be accessible for innovative long duration (8 hours and
more, but less than 24 hours). Moreover, Hydrostor states that
additional funding should also be available for innovative
technologies, no limitation in procurement participation, and
that projects should be large-scale.
Hydrostor recommends that NYSERDA and DPS staff should
consider the following metrics when evaluating LDES projects: 1)
cost; 2) commercial readiness; 3) environmental issues; 4)
synchronous inertia; and 5) service life.
Hydrostor highlights what it sees as benefits to A-
CAES including that it is emissions free, is lower cost and has
a longer life, is able to be sited in more locations, provides
ancillary services, and has customized system design.

Central Hudson, National Grid, NYSEG/RG&E (Collectively,

Indicated Utilities)

The Indicated Utilities support utility-owned storage

to enable a resilient transmission and distribution system.
They state that through utility-owned storage the Indicated
Utilities can lower the cost of capital and quickly address
reliability needs during extreme weather events, optimize
storage deployment in high value areas, and help integrate
renewable resources onto the grid, all of which is necessary for
the reliable operation of the transmission and distribution
system. The Indicated Utilities reiterate that utility-owned

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CASE 18-E-0130 APPENDIX A

storage would complement other storage procurement efforts,

would not compete with private developers, and would return any
wholesale market revenue as a credit to customers as is
consistent with prior Commission rulings regarding utility-owned
storage.
The Indicated Utilities comment that utility-owned
storage projects need a quick pathway to operation rather than
wait for utility investment approval through rate cases and
recommend that utilities have the ability to propose projects in
other venues, such as through the Accelerated Renewable Energy
Growth and Community Benefit Act Proceeding and associated
coordinated grid planning processes.
The Indicated Utilities support the ISC proposed in
the Roadmap and recommend that the utilities continue to conduct
bulk storage dispatch rights procurements. The Indicated
Utilities also support the retail and residential incentive
programs described in the Roadmap and comment that the utilities
work with NYSERDA and Staff to maximize benefits to customers by
leveraging utility experience and customer relationships. The
Indicated Utilities comment that energy storage program designs
should consider how disadvantaged communities will benefit.
The Indicated Utilities comment that long-duration
storage demonstration projects should utilize a variety of
technology that can store energy for more than ten hours,
including over multiple days both in front of and behind-the-
meter with the goal to guide the development of cost-effective
solutions. These demonstration projects should be a chance for
the utility to partner with stakeholders and community. The
Indicated Utilities state that the Commission should ultimately
encourage market- and utility-driven development of long-
duration storage that meet the performance requirements
necessary to ensure a reliable system.

New York City Coalition for a Cleaner Grid (NYCCCG) - comprised

of Bishop Mitchell Taylor, Urban Upbound, Mr. Chris Hanway,
Jacob A. Riis, Neighborhood Settlement, Ms. Carol Wilkins, NYCHA
Ravenswood Residents Association, Ms. Corinne Haynes, NYCHA
Queensbridge Residents Association, Mr. Costa Constantinides,
Variety Boys & Girls Club of Queens, Dr. Anju J Rupchandani ED
Zone 126, The Queens Chamber of Commerce, Eolian Energy,
Flatiron Energy, Hecate Energy, and Rise Light & Power, LLC
(NYCCCG)
NYCCCG states that the Roadmap does an excellent job of
detailing the myriad benefits energy storage can provide to the
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CASE 18-E-0130 APPENDIX A

New York State electricity system. It refers to the CLCPA and

its intention to empower the state to fight climate change,
protect Disadvantaged Communities (DACs), and prioritize the
retirement of fossil-fueled peaking plants. It explains that
DACs impacted by fossil-fueled peaking facilities are
disproportionately located in New York City and Long Island and
an analysis found that 77 percent of the population that met
Disadvantaged Community criteria lived in New York City (Zone J)
and 12 percent lived in Long Island (Zone K), with the remaining
upstate.
NYCCCG explains that the New York transmission system
currently suffers a series of binding constraints, most notably
between Zones J and I and between Zones J and K and that these
constraints mean that generation located outside of Zones J and
K cannot serve these zones in a capacity call event. As such,
new energy storage generation built upstate, including in Zones
G, H, and I, will be insufficient for NYISO to allow retirement
of peaking plants in Zones J and K required for reliability.
Only clean capacity built within Zones J and K can enable the
replacement of those peaking plants consistent with NYISO
reliability standards.
Independent Power Producers of New York (IPPNY)
IPPNY supports the 6 GW storage goal and suggests
periodic reviews of progress toward the goal. IPPNY supports
using an Index Storage Credit over having Investor-Owned
Utilities own storage systems and cites the high number of
storage systems in the NYISO interconnection queue to show there
is no need for utility ownership. If the Commission allows
utility ownership for projects to provide transmission and
distribution services, IPPNY asks that the Commission prohibit
the utilities from bidding these resources into the NYISO
markets.
IPPNY supports the Index Storage Credit Option 2.
IPPNY recommends that incentives target investment in locations
where it would be most beneficial. IPPNY also recommends that
Round Trip Efficiency be incorporated in the Reference Energy
Arbitrage Price in the monthly index storage credit calculation.
Further, it asks that the calculation be open to future
amendments should market conditions change and warrant different
considerations.
IPPNY requests that the Commission direct NYSERDA to
hold separate competitive solicitations for long-duration (10+
hour) storage, including hydrogen-based storage and other

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carbon-free technologies that can act as storage. It cites the

Roadmap’s conclusion that short- and medium-duration storage
will not be enough to maintain reliability to emphasize the need
for long-duration storage solicitations. Additionally, IPPNY
requests that the Commission direct NYSERDA to conduct its first
solicitation as soon as possible so that energy storage projects
can enter service in 2023.
Finally, IPPNY supports the goal of targeting
disadvantaged communities. To achieve that, it recommends that
NYSERDA be allowed to award bonus credit to projects that reduce
the demand for peaking plants. It states that requiring a
project to be located in load pockets with existing fossil
generation can help increase the likelihood that the benefits
reach disadvantaged communities.

Jupiter Power
Jupiter Power commissioned a study analyzing and
comparing the emissions and deliverability/capacity market
impacts of a 500 MW, 4-hour duration storage project sited in
each of NYSIO zones H, J, and K.
Jupiter Power states that the study compares regional
emissions impacts of a 500 MW/4-hour storage project
interconnected at Buchanan 345 kV (Zone H) and Gowanus 345 kV
(Zone J). According to Jupiter Power, the study indicates that
1) the Buchanan storage project has the same or better New York
City power plant NOx reduction benefits as the Gowanus project;
and 2) the Buchanan storage project reduces statewide NOx and CO2
emissions the same or more than the Gowanus project.
Jupiter Power states that the study also analyzed the
deliverability and LCR impacts of the 500 MW/4-hour storage
project at Buchanan. According to Jupiter Power, the study
concluded that 1) at least 500 MW of storage is deliverable from
Buchanan to Zone G-J; and 2) LCR requirements may be shifted
from Zones J and K to Zone G-J and served by resources in G-J.
Further, Jupiter Power notes that storage at Buchanan
can bring economic developments to Buchanan, a disadvantaged
community located downstate. Other benefits, according to
Jupiter Power, include 1) lower land costs than in New York
City; 2) allows for more alternative siting opportunities and
ability to find willing host communities; 3) projects connecting
at substations like Buchanan do not compete with offshore wind
or Tier 4 transmission for limited substation space; and 4)
disadvantaged communities would benefit from the development in
storage.

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CASE 18-E-0130 APPENDIX A

In response to Roadmap Question 7.5.1, Jupiter Power

recommends incentive programs and procurements designed to
ensure that “at least 35% of proposed program funding is
utilized to benefit DACs” should include any project sited in
the service territories of Con Ed. Additionally, Jupiter Power
suggests bid points for locational emissions benefits should be
awarded equally between projects within the Con Ed or LIPA
service territories, up to at least 500 MW of procurement beyond
what is contemplated in the Roadmap.

Key Capture Energy

Key Capture Energy (KCE) enthusiastically supports New
York’s 6 GW Roadmap: Policy Options for Continued Growth in
Energy Storage (Roadmap) and its recommendations.
KCE strongly supports Index Storage Credit
procurements as the primary procurement program for bulk energy
storage. KCE notes three key benefits of the ISC program
design: 1) value; 2) cost-effectiveness; and 3) risk sharing.
KCE urges NYSERDA and DPS to swiftly implement a program design
and conduct ISC procurements to realize these benefits.
KCE counsels NYSERDA to award bulk storage contracts
promptly to achieve the State’s energy storage target. KCE
supports the procurement timeline proposed in the Roadmap and
suggests that the NYSERDA and NYISO Class Year process should
align. KCE states that Staff’s proposed timeline of
procurements is prudent and necessary to ensure that New York
meets the target of 6,000 MW by 2030.
KCE recommends that NYSERDA should award more than
3,000 MWs in Index Storage Credit procurements to account for
project attrition. Additionally, KCE suggests that NYSERDA
should also plan for attrition among projects awarded under
existing programs.
KCE suggests that NYPA and LIPA programs should be
additive to ISC procurements. KCE posits that if NYSERDA
reduces its planned ISC procurements due to procurement
announcements from NYPA or LIPA, and the NYPA or LIPA
procurements never materialize, New York will miss its 6,000 MW
target and fall behind in deploying sufficient energy storage to
achieve its renewable energy mandates.
KCE recommends that ISCs be generated by an ESS under
contract each day it is interconnected to the NYISO system. KCE
notes that limiting ISC production only to operational days may
have unintended consequences for ESS market behavior.
Additionally, under a model that provides for ISCs for
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all interconnected days, energy storage resources are

incentivized to keep uptime high to earn NYISO revenues and to
maximize capacity payments. KCE suggests that because limiting
ISC generation to operational days is unnecessary and could
potentially motivate unintended market behaviors, KCE recommends
that ISCs are generated each day the ESS is interconnected,
including days on outage.
KCE advises that NYSERDA and DPS should ensure
contracts are financeable while accommodating future wholesale
market uncertainty. KCE recommends that any “change of law”
provision in ISC contracts should be designed to trigger only if
necessary and should restrict potential changes to ensure
finance-ability of contracted projects. In the event that a
change of law is triggered, KCE recommends that any reduction in
the price formula must be based on an index of revenues
practically available to the ESS from the new ancillary service.
KCE recommends the use of transparent and objective
metrics to calculate the price threshold. Subjective complex
calculations of expected value to calculate price thresholds
should be avoided. KCE also suggests that price thresholds
should not include costs from system benefits charges. As an
interim solution, KCE recommends excluding these costs from
price thresholds and price comparisons in bid evaluation since
they are not costs to ratepayers or the state.
KCE recommends that NYSERDA offer ESS projects
participating in ISC procurements and interconnection cost
sharing mechanism similar to the option offered in the most
recent Offshore Wind Solicitation. This proposed cost sharing
mechanism will allow projects with high and uncertain
interconnection costs to participate in ISC solicitations by
allocating a portion of the interconnection cost to a cost-
sharing adder paid separately from the ISC.
KCE notes that energy storage will help displace
peaker plants in the same NYISO zone. KCE suggests that NYSERDA
should consider location in its bid evaluation criteria, and
through its bid selection seek to achieve at least 35 percent of
the total MWs through projects located in Zones J and K.

Long Duration Energy Storage Industry Coalition (LDES Coalition)

The LDES Coalition recommends that the Commission
carve out at least 2GWs of the Roadmap’s procurements for long-
duration and multi-day energy storage resources and that NYSERDA
separately evaluate short, long, and multi-day energy storage
bids as part of the bulk energy storage program. The LDES
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Coalition states that long- and multi-day energy storage are not
as commercially mature as short-term energy storage and face
different barriers to entry. The LDES Coalition comments that
policy support is needed for developers to receive the private
investment necessary to make LDES a reality.
Long Island Power Authority (LIPA)
LIPA supports the Roadmap and the 6 GW energy storage
goal. LIPA recommends that the bulk storage program allow
participation of tax-exempt utilities that can take advantage of
the Investment Tax Credit due to the Inflation Reduction Act.
LIPA states that they have already begun discussions with
NYSERDA on how they can participate in the bulk storage program.
LIPA recommends that energy storage procurements use a
“Top and Bottom X hours” mechanism to determine reference
prices. For 8-hour storage, LIPA recommends requiring projects
to offer rated capacity with a TB8 mechanism for calculating
reference prices. LIPA also recommends that NYSERDA consult the
TOs to identify locations with storage needs and establish a
carve-out for these locations.
LIPA asks that NYSERDA consider expanding the
program’s focus to Zone K as a method to further help reduce the
need for peaking units and to benefit disadvantaged communities.
Finally, for long-duration storage, LIPA suggests
coordination with the NYISO and notes that the NYISO’s Security
Constrained Unit Commitment model will likely require
modification to properly incorporate long-duration storage.

Multiple Intervenors
Multiple Intervenors (MI) is an unincorporated
association of over 55 of New York State’s industrial,
commercial, and institutional energy consumers.
MI states that the proposal to establish a statewide
energy storage target of 6 GW by 2030 is unjustified and unduly
aggressive. MI posits that the justifications in the Roadmap
are insufficient to impose the additional costs to customers.
Moreover, MI argues that there is insufficient information
regarding the pace of storage deployments that may be needed
between 2030 and 2040. MI states that it is impossible to
predict the future economics of energy storage.
As it relates to the CLCPA, MI states that paying for
the CLCPA is extremely challenging for customers and recommends
that the Commission should restrain from adding to customers’
financial burdens unnecessarily. Additionally, MI states that
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the possibility of potential challenges in the future does not

warrant adding to the financial challenges of customers to try
to satisfy CLCPA mandates. MI recommends that the Commission
should refrain from adopting an energy storage target in excess
of the 3 GW mandate enacted in the CLCPA as there is no
compelling reason to do so.
MI recommends that the potential costs of the storage
roadmap’s proposals should be evaluated in the aggregate with
all of the other costs being imposed on customers. MI outlines
a number of potential negative consequences that may be occur if
the cumulative energy and program costs are not considered. MI
states that they have serious concerns over whether customers
can afford an energy storage target that is double what is
mandated by the CLCPA.
MI expresses concern that the statewide procurement
approach is unlikely to result in the optimal mix of energy
storage projects. MI notes that the benefits, economics, and
environmental impacts of energy storage projects are extremely
contingent upon the specific facts and circumstances of the
installations themselves.
MI states that the Storage Roadmap proposals would result
in inequitable costs increases to large energy-intensive
customers. MI suggests that the costs of the proposed Storage
Roadmap should be allocated and recovered primarily based on
demand, not energy.

New York Power Authority (NYPA)

NYPA generally supports the goals of the Roadmap but
disagrees with the recommendation that NYPA voluntarily agree to
participate in funding storage programs when NYPA cannot recover
those costs through their existing contracts with customers.
NYPA notes that unlike utilities under the Commission’s
jurisdiction, NYPA’s contracts and tariffs with their customers
do not provide a pathway to pass the costs associated with the
Roadmap to their customers.
NYPA comments that it has no electric delivery
customers or retail tariffs and therefore cannot recover any
retail program costs with a delivery bill surcharge and
recommends an alternative cost recovery mechanism.
NYPA further states that it lacks a mechanism to
recover the ISC costs allocated to NYPA under the Roadmap
proposal which would result in NYPA absorbing millions of
dollars in bulk program costs without any way to recover them

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CASE 18-E-0130 APPENDIX A

through their customers, which would cut into other programs

NYPA is involved in that further the CLCPA goals.
NYPA urges the Commission to consider alternative
means for NYPA to recover energy deployment costs so that it can
fruitfully participate in the energy storage programs.

New York Municipal Power Agency (NYMPA)

NYMPA urges the Commission to reject the proposed
load ratio share funding mechanism for NYMPA members described
in the Roadmap as it would disproportionately negatively impact
NYMPA members. NYMPA states that its members’ power is already
produced from zero emissions resources and that it already
complies with the Clean Energy Standard, which is costly, so
adding another cost obligation through a load ratio share as
proposed in the Roadmap will be especially burdensome. NYMPA
notes that its members’ rates are generally lower than those of
investor-owned utilities, so any increased bill impacts are
acutely felt. The small size of NYMPA’s members also make it so
interconnecting storage at any size is difficult and therefore
the members would not be able to realize any benefits from the
program while still paying into it. NYMPA states that if the
Commission does decide to adopt the load ratio share funding
mechanism that only NYMPA members whose load is served by non-
renewable resources be counted.

New York Solar Energy Industry Association (NYSEIA)

NYSEIA overall supports the Roadmap and states that
the program cost is “modest” while the “environmental,
resilience and economic benefits are significant.” NYSEIA
supports the Index Storage Credit as it will create revenue
certainty for developers while sharing risks and revenue
benefits between the State and ratepayers. Further, NYSEIA
supports the descending block incentive program design and
requests that the Commission monitor progress and consider
increasing program funding if needed. It believes there should
not be a requirement to participate in a grid services program
to be eligible for a capacity-based incentive. NYSEIA further
states that NYSERDA has ample experience in administering
descending-block incentive programs and should launch their
program in 2023, rather than wait until 2024.
NYSEIA recommends prioritizing small (below 5 MW)
distributed resources at the retail level with an increased
capacity allocation. It states that this could incent locating

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CASE 18-E-0130 APPENDIX A

resources closer to load where it can have direct benefits to

consumers, reduce the need for costly transmission upgrades, and
where community projects can target disadvantaged communities.
NYSEIA recommends doubling the residential capacity
allocation to 400 MW. It forecasts that supply chain and
technology improvements, as well as implementation to time-of-
use rates will encourage energy storage retrofits to existing PV
systems. It also states that residential aggregations can be
implemented quickly, increase local resiliency, and avoid
transmission upgrades.
NYSEIA supports developing price signals and grid
service programs to help incent storage development. It states
that currently a residential flat-rate customer has no
opportunity to earn a return on investment for a storage system.
It supports encouraging time-of-use rates in other regions of
NYS.
NYSEIA recommends allowing projects with
interconnection approval who are awaiting municipal permits to
submit a non-refundable deposit to be eligible for a NYSERDA
incentive. It also encourages Staff and NYSERDA to work with
stakeholders on permitting and interconnection reform.
Finally, NYSEIA encourages NYSERDA to leverage
successes from NY-Sun LMI solar programs to encourage storage
development by considering things like, incentives for projects
that participate in NY’s Community Distributed Generation
program, establishing incentive adders for projects owned by
multifamily affordable housing, community facilities, and LMI
households.

New York State Reliability Council (NYSRC)

The NYSRC stresses the importance of reliability as NY
shifts toward a renewable and carbon-free grid and states that
reliability rules will need to evolve through the process. It
notes that, based on the 2023-24 Installed Reserve Margin Study,
potential reliability events range from 1.2 hours to 9.3 hours,
with an average of 3.6 hours. It explains that this means 4-
hour storage will not be sufficient to cover more than half of
the modelled reliability events.
The NYSRC notes that inverter-based resources have
operating limitations. Specifically, they lack fault ride-
through and voltage recovery capabilities. As a result, the
NYSRC has established a goal to consider rules for inverter-
based resources.

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CASE 18-E-0130 APPENDIX A

NineDot
NineDot supports the recommendations outlined in the
Roadmap and urges the Commission to approve it and adopt the 6
GW target and proposed budget.
NineDot supports the geographic-specific, upfront
declining block incentive for retail storage as proposed in the
Roadmap. It states that as the proposed structure is built upon
the already authorized Market Acceleration Bridge, it should be
implemented as soon as possible with a large early block size.
NineDot further recommends several solutions to
address market structure barriers for energy storage, including
modifying rate structures, addressing permitting and siting
challenges in New York City, and the creation of a working group
to examine retail storage deployment on Long Island. NineDot
supports the proposed retail incentive budget as necessary to
fill in the “missing money” developers need to get retail
storage projects into service. It comments that a steady
pipeline of projects will be necessary for the State to achieve
its storage targets and therefore support a large initial block
incentive for retail storage to account for interconnection
delays.
NineDot supports a prevailing wage requirement that
aligns with Federal regulations and notes the potential of
energy storage to improve the quality of life in disadvantaged
communities by replacing high-emitting peaking plants,
especially downstate. NineDot recommends that the funding for
cancelled projects automatically get reallocated within the open
funding block. NineDot supports the creation of a Clean Energy
For All opt out program for disadvantaged communities designed
to pass on benefits to low-income subscribers and that the
retail storage incentive should include bidirectional electric
vehicle chargers to enable vehicle-to-grid services.
NineDot offers several recommendations to the VDER
tariff to better enable the buildout of energy storage systems.
The recommendations include introducing a study performed every
seven years for energy storage systems greater than 1 MW to
update the operating profile of the asset, better aligning the
VDER Capacity Component Alternative structure, future-proof and
extend the VDER Demand Reduction Value component, and revise the
VDER and SIR limits to 10 MWs.
NineDot recommends that Con Ed restart its Modified
High-Tension program which would enable energy storage sites to
have equitable delivery rates in all neighborhoods in New York
City, resulting in increased energy storage deployment across

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CASE 18-E-0130 APPENDIX A

all boroughs. NineDot also recommends that utility capacity

hosting maps get updated frequently so that developers
understand the current interconnection landscape and to
reinstate and expand network-optimized delivery service rate
design.
NineDot states its support for including Dynamic Load
Management (DLM) compensation in the VDER framework and dual
participation in demand reduction value and DLM. It further
comments that DLM contracts should be 15-years to mirror the ISC
bulk solicitation process and that the customer baseline
methodologies need modification to allow for the optimal use of
batteries by measuring the performance of energy storage system
exports during DLM events.
NineDot recommends establishing an NYC based NYSERDA
siting team to help streamline the permitting process for energy
storage projects, which can require obtaining several permits
over a multiyear process and standardizing the permitting
process in other areas of New York State. It also supports the
formation of a working group comprised of NYSERDA, DPS, LIPA,
and PSEG-LI to examine rate structures and incentives for retail
storage to meet the Roadmap’s target of 1.5 GW of energy storage
on Long Island by 2030.

Nuvve
Nuvve supports the recommendation to increase the
storage deployment goal to 6 GW. Nuvve requests that the State
establish a target of 1.5 GW for bidirectional charging
infrastructure (Vehicle to Grid, or V2G) deployment by 2030.
This target would be in addition to, and not count toward, the 6
GW goal. Nuvve also requests that the State formally
investigate the benefits to decarbonization and resiliency of
V2G systems and use that to inform an incentive program to meet
the above proposed target. Nuvve states that current EV charger
incentives are not sufficient to incent buildout of
bidirectional charging systems and therefore should provide an
additional incentive on a $/kW basis and on the condition that
the project participates in VDER or a utility demand response
program.
New York State Battery and Energy Storage Technology Consortium
(NY-BEST)
NY-BEST supports the 6 GW energy storage goal and the
proposed funding allocations. NY-BEST recommends that projects
under current contracts that are withdrawn have their MWs and
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CASE 18-E-0130 APPENDIX A

funding rolled into the proposed programs. Further, it

recommends that NYSERDA size their program solicitations with
the inclusion of an attrition rate.
NY-BEST supports the proposed Index Storage Credit
funded through bill collections from LSEs based on load. NY-
BEST also supports participation by NYPA and LIPA in the
program. Further, it proposes that NYSERDA annually assess the
need for 4-hour, 8-hour, and longer-duration storage.
NY-BEST disagrees with Staff’s recommendation not to
include Round Trip Efficiency (RTE) in the Reference Energy
Arbitrage Price. To address the issue of complexity in
calculating RTE, it proposes a uniform RTE factor that is part
of the monthly index and specifically recommends an RTE of 85
percent for 4-hour storage.
For 8-hour systems, NY-BEST proposes four potential
paths for consideration: 1) Set the reference price based on
each individual project’s RTE; 2) have a standard RTE in the
mid-range (around 70 percent) for anticipated participants; 3)
use the 4-hour RTE assumption and accept that a risk premium
must be included in the strike price for systems with a lower
RTE; or 4) calculate the reference price using only the top 4
hours. NY-BEST suggests the Commission place a limit on what a
project could owe NYSERDA if the reference price exceeds the
strike price to lower the cost of financing.
NY-BEST agrees with the proposal to allow projects to
have a one-time adjustment for inflation. NY-BEST also
recommends that contract language be tightly structured to only
allow modifications in response to larger and longer changes in
compensation levels rather than responding to smaller and
shorter-term market changes.
NY-BEST agrees with the proposal to include non-price
factors in the bid evaluation. Specifically, it recommends
allowing bonus points for projects that have met
maturity/viability thresholds, projects in or directly
benefitting Zones J and K in a way that would reduce reliance on
peaking plants, and selecting a diverse set of projects. In
addition, it proposes to allow a developer to exercise a one-
time option to not accept NYISO cost allocation and to reapply
in the next Class Year.
NY-BEST suggests that the Commission direct the
utilities to remove surcharges and riders from delivery rates
for charging load of front-of-the-meter storage.
NY-BEST recommends the Joint Utilities’ bulk storage
dispatch rights procurements are continued and that the
utilities be required to meet the targets in the Energy Storage

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CASE 18-E-0130 APPENDIX A

Order. If any targets are not met, NY-BEST recommends

reallocating that funding to the Index Storage Credit program.
NY-BEST supports the recommendation to continue a
Retail Storage Incentive targeting 1.5 GW of retail storage by
2030. NY-BEST encourages NYSERDA to implement the storage
program as soon as possible, ideally in 2023. Further, it
suggests increasing the incentive cap from 15 MWh to 20 MWh.
It also supports project maturity requirements but ask that
NYSERDA not require FDNY and Department of Buildings approval in
NYC.
For Upstate regions, NY-BEST suggests creating
distinct incentive blocks for solar-plus-storage and standalone
storage or a higher incentive level for standalone storage. NY-
BEST also suggests that the incentive program target both FTM
and BTM projects.
NY-BEST urges strong support for having LIPA
participate in the program. In addition, it recommends that the
Commission and NYSERDA explicitly allow storage supporting EV
charging in the program.
NY-BEST encourages the Commission to consider a
proceeding that would create utility locational value tariffs
for energy storage. It also encourages the Commission to
initiate a proceeding to create a Clean Energy for All Program.
This program would enroll disadvantaged communities as
beneficiaries to CDG savings, with the option to opt out.
NY-BEST recommends adopting 8+ hours as the definition
of long-duration energy storage. Further, it recommends the
State create a program to fund demonstration projects with
different long-duration storage technologies.
NY-BEST recommends DPS and NYSERDA request that the
NYISO expedite their Storage as Transmission project. It also
stresses the importance of coordinating with the Coordinated
Grid Planning Process.
NY-BEST supports the idea that Vehicle to Grid
technologies will be important in the future and asks DPS and
NYSERDA to create and expand programs to enable bi-directional
chargers.

New York City Coalition for a Cleaner Grid (NYCCCG) - comprised

of Bishop Mitchell Taylor, Urban Upbound, Mr. Chris Hanway,
Jacob A. Riis, Neighborhood Settlement, Ms. Carol Wilkins, NYCHA
Ravenswood Residents Association, Ms. Corinne Haynes, NYCHA
Queensbridge Residents Association, Mr. Costa Constantinides,
Variety Boys & Girls Club of Queens, Dr. Anju J Rupchandani ED
Zone 126, The Queens Chamber of Commerce, Eolian Energy,

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CASE 18-E-0130 APPENDIX A

Flatiron Energy, Hecate Energy, and Rise Light & Power, LLC
(NYCCCG)
NYCCCG states that the Roadmap does an excellent job
of detailing the myriad benefits energy storage can provide to
the New York’s electric grid. It refers to the CLCPA and its
intention to empower the state to fight climate change, protect
Disadvantaged Communities (DACs), and prioritize the retirement
of fossil-fueled peaking plants. It explains that DACs impacted
by fossil-fueled peaking facilities are disproportionately
located in New York City and Long Island and an analysis found
that 77 percent of the population that met DAC criteria lived in
New York City (Zone J) and 12 percent lived in Long Island (Zone
K), with the remaining upstate.
NYCCCG explains that the New York transmission system
currently suffers a series of binding constraints, most notably
between Zones J and I and between Zones J and K and that these
constraints mean that generation located outside of Zones J and
K cannot serve these zones in a capacity call event. Because of
this, new energy storage generation built upstate, including in
Zones G, H, and I, will be insufficient for NYISO to allow
retirement of peaking plants in Zones J and K required for
reliability. Only clean capacity built within Zones J and K can
enable the replacement of those peaking plants consistent with
NYISO reliability standards.
NYCCCG opines that the language in the upcoming Order
must be strengthened compared to that in the Roadmap to ensure
sufficient storage is procured downstate. While the Roadmap,
recommends that at least 35% of program funding be utilized to
support projects in areas of the state with the highest benefits
to DACs and peaker reductions, NYCCG believes that stronger
language is needed to ensure adequate investment is directed
downstate and towards the protection of DACs. More
specifically, NYCCCG states that language in the Roadmap is
problematically vague in that the term “highest benefits to DACs
and peaker reductions” is not further defined. Without further
clarification, this language could be interpreted to justify
storage procurement almost anywhere in the state. While
transmission scale storage does provide a myriad of statewide
benefits, only storage located in Zone J and Zone K can provide
locational capacity sufficient to enable the replacement of
fossil-fueled generation in and around densely populated
Disadvantaged Communities

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CASE 18-E-0130 APPENDIX A

New York Independent System Operator (NYISO)

The NYISO explains that energy storage resources will
be important to helping meet demand when renewable energy output
is low but stresses that energy storage resource deployment
should not outpace renewable deployment. It explains that
energy storage resources increase net load because they use more
energy to charge than they can later discharge. It states that
if renewable development does not keep pace, energy storage
resources could end up charging from fossil-based resourced or
at prices that are not cost-effective. This could also lead to
grid imbalances.
The NYISO states that, while they recognize financial
incentives may be necessary to facilitate storage deployment,
they believe the price signals from NYISO markets “provide the
foundation for economically efficient storage.” The NYISO also
states that incentives for storage development should encourage
resources that are capable of charging from the wholesale grid.
The NYISO notes that storage will play an important
role in helping fill short-term needs during the energy
transition, but stresses that long-duration needs will become
apparent, and current battery storage cannot sufficiently meet
those needs.
The NYISO encourages participation by DPS and NYSERDA
in their stakeholder meetings regarding the Storage and
Transmission project.
The NYISO states that, since energy storage resources
both charge and discharge, they have the opportunity to provide
services to the grid. It recommends that the Commission and
NYSERDA encourage energy storage resources to take advantage of
these services in the wholesale markets.
Finally, the NYISO encourages NYSERDA and DPS to
closely follow the demand curve reset process, which will
consider energy storage resources as a peaking plant technology
option.

PEAK Coalition

The PEAK Coalition, which consists of New York City

Environmental Justice Alliance, UPROSE, The POINT CDC, New York
Lawyers for the Public Interest, Clean Energy Group, as well as
Earthjustice and El Puente as signatories, submits comments in
support of the Roadmap. PEAK Coalition urges the Commission to
explicitly allocate no less than half of the 6 GW target,
including at least 2 GW of bulk storage, to Zone J and to
prioritize funding projects that relieve the energy burdens of
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CASE 18-E-0130 APPENDIX A

communities surrounding peaker plants in New York City. In

explanation, PEAK Coalition states that the communities
overburdened by peaking facilities are disproportionately
located in New York City and Long Island; these communities face
an increased burden of air pollution. Additionally, as
electricity from peaker plants is up to 1,300 percent more
expensive than the average cost of electricity, these
communities pay higher energy costs. PEAK Coalition comments
that although there has been legislation mandating higher
standards for generation emissions, there are other hurdles that
prevent the retirement of peaker plants. PEAK Coalition
recommends that the language of the Order clarify and provide
stronger language to ensure that the deployment of energy
storage downstate is prioritized; for example, requiring that
population density and proximity to peakers be considered. PEAK
Coalition also recommends that the Commission require energy
storage projects to be located in the same zone as the peaking
plants targeted for replacement. Finally, PEAK Coalition
recommends a specific carveout for Zone J to ensure that rapid
deployment of storage resources occurs as quickly as possible.
PEAK Coalition reasons that without this carveout, energy
storage developers may be unable to develop projects downstate.

Plug Power
Plug Power requests that hydrogen and hydrogel fuel
cells be counted in the Roadmap as both short- and long-duration
resource options. It adds that the Roadmap should explicitly
target incentives at storage capable of providing for longer
than 10 hours and emphasize that NYSERDA should support R&D in
technologies that can achieve this. Further, Plug Power
requests that NYSERDA’s Clean Energy Citing Team work to help
remove barriers to transporting and citing hydrogen and
hydrogen-resources. Finally, Plug Power recommends supporting
off grid EV charging in the short-term.
PowerFlex
PowerFlex supports a region-specific storage incentive
in declining blocks. It notes that lithium carbonate prices in
China have increased fivefold from 2021 to 2023 and therefore
they support a beginning incentive range of $350-550/kWh with
higher incentives downstate. It also supports aligning funding
levels with solar incentives and increasing funding downstate.

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PowerFlex supports the Roadmap’s goal to prioritize

disadvantaged communities and suggests a $/kWh adder for
projects in these communities.

Queens Climate Project

The Queens Climate Project (QCP) submits comments in

support of the Roadmap. Specifically, QCP supports the expanded
energy storage target, the emphasis on the need for storage
downstate as soon as possible, and the future savings and
related improved air quality as a result of energy storage
deployment. QCP also notes that the Roadmap aligns with the
CLCPA, especially the goal of ensuring energy storage projects
deliver benefits to disadvantaged communities through the
retirement of peaker plants. Additionally, QCP urges the
Commission to direct NYSERDA to conduct bulk storage
procurements that prioritize Zone J, by allocating funding based
on the benefits of replacing peaker plants in disadvantaged
communities.

Rise Light & Power, LLC (Rise)

Rise supports the Storage Roadmap and requests that
the Commission 1) approve the Roadmap recommendations requiring
NYSERDA to adopt criteria in future Index Storage Credit (ISC)
solicitations that favor projects that can facilitate the
reliable replacement and redevelopment of New York’s fossil
fueled power generating facilities; and 2) direct NYSERDA to
adopt criteria that favors projects that benefit disadvantaged
communities.
Rise recommends that NYSERDA and DPS Staff integrate
any unutilized capacity and funding from the Joint Utilities
Bulk Storage Dispatch Rights procurement into the proposed ISC
solicitations.
Rise recommends that requirements based on the likely
future-state scenarios under the CLCPA point to location
requirements for energy storage to maintain reliability should
be reflected in ISC solicitations in order to allow developers
to propose projects where they are needed the most to maintain
system reliability. However, Rise recommends against specific
carve-outs in the ISC solicitations as they may drive up the
costs of the proposed solutions. Instead, Rise recommends
adjustments to the scoring system to provide additional
weighting to favor projects that address location requirements,
as this would enable NYSERDA to balance cost against

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CASE 18-E-0130 APPENDIX A

preferences. Rise also recommends that the ISC solicitation be

agnostic on duration. Additionally, Rise recommends that the TB
mechanism align with the duration of the storage project.
Rise commends the focus on disadvantaged communities
in designing the storage program, but cautions that replacing
peakers with energy storage projects may not be sufficient to
maintain system reliability. Rise recommends that additional
action be taken to diversify renewable energy sources.
Rise recommends that NYSERDA and DPS Staff should seek diversity
in project sizes, developers, and locations. Additionally, Rise
suggests that NYSERDA and DPS Staff should consider
incorporating Zonal Net Emissions Reduction in the ISC
solicitations.

Serium Energy Storage

Serium is supportive of the Roadmap and states that
expanding storage procurement from 3 GW to 6 GW is necessary to
achieve the State’s renewable energy and carbon reduction goals.
Serium recommends that a procurement of diverse
technologies should be considered. Serium suggests that the
Commission consider diversification beyond chemical battery
storage technologies, such as underground, closed-loop, pumped
storage, which can reduce the concentration of technology risk
and offer longer duration storage, operational flexibility, and
a permanent storage resource based.
Serium suggests that long duration storage should be
procured concurrent with short-duration projects. Specifically,
Serium suggests that given the use proven technology and
environmentally friendly attributes, accelerating the deployment
of pumped storage by mitigating the need for small scale
demonstration as a prerequisite to building at scale would be a
sensible option for bridging the gap between the need for long
duration storage, and the time that it will take to complete the
robust development process for more nascent storage
technologies. Serium also notes that pumped storage also has to
go through a FERC licensing process and is currently eligible
for investment tax credits, both of which are time sensitive.
Serium proposes that LDES can utilize Index Storage
Credits but will require different terms than short-duration
battery storage. Serium makes a series of recommendations
related to long duration storage procurement including: 1) an
express set aside for bulk LDES projects; 2) contract terms from
20 to 30 years; 3) evaluation of the operational benefits of
individual LDES projects; 4) evaluation of the unique
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CASE 18-E-0130 APPENDIX A

environmental impacts and benefits of individual LDES projects;

5) evaluation of the economic development benefits of individual
LDES projects; and 6) allowance for creative financing
mechanisms.
Serium recognizes that NYPA would be a constrictive
participant in facilitating a near-term bulk procurement of LDES
storage due to its expertise in hydro, pumped storage, and power
system management.

Strategic Project Management (SPM)

SPM strongly supports the Roadmap’s analysis and the 6
GW energy storage deployment goal. It also recommends an annual
review of progress toward the goal. SPM strongly agrees with
the Roadmap’s recommendation to use an Index Storage Credit and
supports funding the programs through bill collections from LSEs
in proportion to load. Additionally, SPM suggests that, if
projects are withdrawn, those MWs and their associated funding
be reallocated into new programs.
SPM urges NYSERDA to annually look at the need for 4-
and 8-hour resources and asks NYSERDA to consider other
durations such as 6-hours or 8+ hours.
SPM disagrees with the recommendation to exclude Round
Trip Efficiency (RTE) from the REAP calculation and states that
failing to account for this “will erroneously assume revenue
that is unrealizable for most energy storage systems”. To
decrease complexity, SPM recommends that the RTE calculation use
a uniform assumption that is part of the monthly Index Storage
Credit calculation. Specifically, it recommends an 85 percent
RTE for 4-hour batteries. It states that the calculation for 8-
hour systems is more complex and suggests that the State work
with stakeholders to develop the appropriate reference price.
SPM recommends that contract language should be
sufficiently tight to only allow responses to market changes
that would significantly increase or decrease compensation
levels rather than allowing smaller and shorter-term changes.
SPM recommends incorporating non-price factors in the
bid evaluation including, awarding bonus points to projects that
have achieved maturity/viability thresholds, focusing on
projects in (or directly benefitting) Zones J and K in a way
that reduces the need for Peakers, and supporting diverse
projects (based on size, location, developer, and technology
type variation).

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CASE 18-E-0130 APPENDIX A

SPM asks that the Index Storage Credit program allow a

one-time option to not accept cost allocation and reapply in the
next NYISO Class Year to allow COD flexibility.
SPM supports NY-BEST’s recommendation to continue with
the Joint Utilities’ bulk storage dispatch rights procurements
and asks that the Joint Utilities be required to meet the MW
targets in the Energy Storage Order.
SPM requests that Staff and NYSERDA ask the NYISO to
move forward with its Storage as a Transmission Asset project.
In addition, SPM recommends directing the Joint Utilities to
modify the Coordinated Grid Planning Process proposal to allow
third party developers to have storage as transmission and NWAs
considered to meet local transmission needs. However, SPM does
not support allowing storage as transmission to count toward the
6 GW goal.

Sunkeeper Solar
Sunkeeper Solar supports the comments of NYSEIA and in
particular recommends an accelerated timeframe for deploying the
retail storage program as well as increasing the incentive
capacity for this sector, particularly in the Con Ed service
territory. Sunkeeper Solar strongly recommends that the retail
storage incentive have a carveout for projects sized between 100
kW-1,000 kW, as smaller projects move quicker through the
interconnection process as compared to 5 MW projects where costs
remain high.

Urban Electric Power (UEP)

UEP noted that NYSERDA has spent $33.6 million through

the Renewable Optimization and Energy Storage Initiative Program
to support long-duration storage and suggests that NYSERDA scale
this up over the next three years, provide additional funding,
and include long-duration systems below 5 MW in size. It states
that long-duration storage increases on-site usage of renewables
while also increasing resiliency, but VDER and other programs
have not been adequate to incent investment in longer-duration
projects.
UEP agrees with the Roadmap’s goal to focus on
resources developed in the United States, and locally, where
possible. UEP believes an Index Storage Credit would be
effective at increasing the development of long-duration storage
and specifically supports including “economic and societal
benefits” in the Reference Price calculation. It believes that
this will best help incent long-duration resources, which have
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CASE 18-E-0130 APPENDIX A

benefits beyond those that can be more easily quantified.

Finally, UEP emphasizes that upfront incentives and rebates
should also remain in place as having both rebates and the Index
Storage Credit will help decrease financial risk.

Vote Solar & PEAK Coalition

Vote Solar & PEAK Coalition appreciate that NYSERDA
and Commission acknowledge that the deployment of energy storage
systems will allow New York to meet its peak power needs without
relying on peak-generating plants, which negatively impact
disadvantaged communities that are disproportionately affected
by the increased energy burden.
Vote Solar & PEAK Coalition note that there are
economic, environmental, and public health risks of planning for
hydrogen-based resources. They state that they do not support
prioritizing hydrogen at the expense of known decarbonization
pathways as it is a false solution.
However, Vote Solar & Peak Coalition do support long-
duration storage and renewable additions to replace hydrogen
based firm capacity. They agree that in order to ensure New
York’s long-term resource adequacy needs are met, efforts should
begin as soon as feasibly possible to develop, test, and
demonstrate long-duration energy storage technologies that are
capable of providing reliable power for extended periods of time
with zero emissions.

Zinc8 Energy Solutions (Zinc8)

Zinc8 states the need for LDES to address congestion
relief, reducing peak demand which can defer the need for
otherwise needed investments, and displace dirty peaking units
in Disadvantaged Communities. Zinc8 comments that the Roadmap
supports short term lithium-ion batteries but does not describe
the competitive landscape for LDES. Zinc8 suggests that
incentives be designed based on energy and duration rather than
power. Zinc8 recommends that LDES demonstrations showcase the
different applications of the technology, with the goal to move
high performing LDES to commercialization. Zinc8 also
recommends that the bulk storage capacity minimum threshold be
reduced from 5 MW to 1 MW with 8+ hours duration and the
elimination of duration and energy capacity requirements for
retail storage.

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CASE 18-E-0130 APPENDIX B

APPENDIX B- SUMMARY OF STAKEHOLDER REPLY COMMENTS

AES Clean Energy Development

AES supports carveouts for storage based on location
and duration. Specifically, it proposes a locational allotment
of 40 percent to NYC, 25 percent to Long Island, and 35 percent
spread evenly across the rest of NY in 1 GW/year increments from
2024-2026. However, it also suggests a margin of +/- 10%
subject to reliability needs and other analysis. For a
duration-based carveout, AES proposes to evaluate same-duration
resources against each other.
AES encourages procuring projects of various sizes,
based on reliability needs across regions. It also supports the
currently established rules for utility ownership. It agrees
with the proposal by NY-BEST to direct the Joint Utilities to
study the ability for storage to provide non-market transmission
and distribution services. However, it doesn’t support having
these projects be limited to utility ownership.
AES agrees with NY-BEST’s comments stating that
NYSERDA should consider non-price factors in bid evaluations.
AES goes further to state that NYSERDA should have the
flexibility to determine which non-price factors should be
included in each solicitation.
AES supports the comments of NYC and NY-BEST regarding
flexibility for unforeseen price fluctuations. NY-BEST stated
that any contract changes should only happen in response to
significant market changes and not for short-term issues. AES
agrees.
AES expresses support, along with numerous other
stakeholders, for using the Index Storage Credit mechanism.
AES states that NYSERDA should direct funding to local
and community outreach to increase public awareness of
renewables and storage and their benefits.
AES recognizes the need for long-duration storage
beyond 2030 and believes NYSERDA should prioritize 100-hour
batteries of varying technologies. It further supports the
proposal by NY-BEST to first establish a demonstration project
program to support earlier adoption of long-duration storage and
then use the learnings to later scale up deployment.
Finally, AES agrees with the proposal by NYC to have
Staff and NYSERDA monitor project attrition levels and update
the bulk procurements accordingly.

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CASE 18-E-0130 APPENDIX B

Bloom Energy
Bloom Energy supports a technology-neutral approach to
all storage development, particularly for long-duration storage.
It reiterates its original proposal to consider performance-
based criteria for storage that is open to varying technologies.
Bloom Energy agrees with NY-BEST that there is a
strong need to focus on long-duration resources. Specifically,
it calls out the need to meet intraday, interday, multi-day, and
seasonal needs. It emphasizes that, since these technologies
are still being developed, it is important to begin looking at
solutions sooner than later. It agrees with IPPNY’s statement
that incentives should be targeted at locations where there is
the greatest need.
Lastly, Bloom Energy reiterates that hydrogen-based
resources should be eligible for incentives. It also encourages
demonstrations projects that are modular as well as prioritizing
the development and use of green hydrogen.

Clean Energy Advocates (CEA)

CEA asks the State to implement a community outreach
program to help communities understand the benefits of clean
energy and to dispel misinformation. It specifically supports
community outreach recommendations in the Climate Action
Council’s Scoping Plan; these include the Scoping Plan’s
Electricity Chapter 13 strategy E.4, Land Use Chapter 19
strategy LU8, and Local Government Chapter 20 strategy LG 3.
CEA supports NYSERDA’s Clean Energy Siting program and
suggests integrating this effort into the Roadmap process. It
also adds that community outreach should include education on
NYSERDA’s new IEDR platform.
CEA supports using non-price factors in evaluations in
a way that encourages and promotes community acceptance of
projects. Further, it states that NYSERDA should consider
whether additional siting incentives could be included in the
storage program.

Con Edison/Orange & Rockland (Collectively, the Companies)

The Companies note that they are optimistic about
procuring substantial quantities of bulk storage in future
solicitations. The Companies agree with stakeholders that the
Index Storage Credit is not designed in a way that accounts for
the distribution value of distribution-connected bulk storage.

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CASE 18-E-0130 APPENDIX B

As a result, The Companies state that utility procurement should

remain the preferred mechanism for targeting distribution-
connected bulk storage. They believe that utility procurement
can send location-specific price signals for both the
transmission and distribution system. The Companies agrees with
Clearway Energy’s comments on Utility Dispatch Rights (UDRs)
where Clearway states that this mechanism provides revenue
certainty through tolling agreements.
The Companies reiterate their support for a BTM
storage program and noted that Convergent and FreeWire also
similarly call out the value BTM storage, including support by
FreeWire for a separate carveout for BTM projects.
The Companies support utility ownership of storage and
state that utility-owned projects have the opportunity to
pioneer new use cases. They also support allowing third parties
to participate in utility-owned projects as equipment suppliers,
contractors, consultants, etc.
The Companies recognize that many comments on the Roadmap
concern related but separate proceedings, like VDER and Demand
Response programs. The Companies recommend that storage
developers that seek 15 years of revenue certainty bid into
future UDR procurements.

Convergent
Convergent reiterates its strong support for the 6 GW
storage goal and cites analysis by E3 and the NYISO to show
there is great need for storage by 2040 and beyond. Convergent
states that the NYISO’s comment that storage penetration should
not outpace renewable generation fails to account for other
benefits of storage. It states that having separate timelines
for renewables and storage would hinder the process of planning
for the most optimal resource mix. It supports regular review
of the storage program, its assumptions, and its goals to adjust
for conditions going forward to the 6 GW 2030 goal.
Convergent supports the participation of NYPA and LIPA
in the Roadmap.
Convergent notes their concern in their initial
comments that the Index Storage Credit program may encourage
short-term “flippers” who drive down the bid floor. It asks
that Staff keep watch on this and adjust rules as necessary to
prevent this. Convergent also emphasizes that an asset class of
5-20 MW should be considered so these medium-sized projects are
not left out.

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CASE 18-E-0130 APPENDIX B

Convergent supports the comments of Con Edison/Orange

and Rockland to focus on BTM storage projects and consider a
separate adder for these projects. It also asks for BTM
projects larger than 5 MW to be considered. In addition, it
states that incentives for collocated storage projects may help
alleviate the NYISO’s concerns about storage outpacing
renewables.
Convergent asks that the inclusion of disadvantaged
communities “not be treated as an afterthought” and expresses
concerns with the Roadmap’s implication that the Investment Tax
Credit will help incentivize development in these areas since
standalone storage does not qualify for the low-moderate income
adder.
Convergent agrees with IPPNY’s concerns about utility
ownership of storage projects and states they do not support
utility ownership, including for storage as transmission
projects.

Cyprus Creek Renewables (Cyprus Creek)

Cyprus Creek reiterates its strong support for the
Roadmap and the 6 GW goal. It cites the NYISO System and
Resource Outlook, and the number of Tier 1 projects authorized
by NYSERDA show the need for and plans to build large amounts of
renewables. It states that this shows the NYISO’s concerns
about storage outpacing renewables are not sound, and in fact,
waiting to develop storage could actually put storage
development behind.
Further, Cyprus Creek explains that any delays in
storage procurement could cause developers to miss out on
federal incentives from the Inflation Reduction Act.
Cyprus Creek supports the Index Storage Credit but
shares the concerns raised by Clearway Energy that it can lead
to bidders not accounting for uncertainties when bidding their
strike price. It agrees with Clearway’s proposed solution to
change the weighting of consideration of price and non-price
factors. Specifically, it recommends a higher weight on project
viability criteria.
Cyprus Creek does not support utility ownership of
storage. It states that this would expose ratepayers to risk
and emphasize that the reason utilities have lower cost of
capital is because they are guaranteed to have cost overruns
covered by ratepayers. Investors should carry that risk, not
ratepayers.

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CASE 18-E-0130 APPENDIX B

FreeWire Technologies (FreeWire)

FreeWire supports the proposal by Con Edison/Orange
and Rockland to establish a BTM storage incentive. Further, it
states that they support NY-BEST’s statement that BTM projects
are “instrumental” to meeting storage goals. It also agrees
with NY-BEST’s statement that there is demand in the C&I space
for TOU rate-based demand management, resiliency/backup power
solutions, and greenhouse gas reduction.
FreeWire adds support for NY-BEST’s recommendation to
initiate a separate proceeding that would create utility
programs that compensate storage on its locational value.
Finally, FreeWire supports LIPA’s participation in the Roadmap
process.

Hydrostor
Hydrostor reiterates its support for the Roadmap’s
conclusion that long duration energy storage of 8+ hours are
necessary for system reliability and continue to recommend a 1.5
GW carve out of 8-hour storage through the bulk procurement
process, including non-lithium-ion storage technologies.
Hydrostor points to potential attrition of LDES and recommends
that the long duration energy storage carve out procure 1 GW in
2024, and the balance in 2025 and 2026. Hydrostor comments that
long duration energy storage compared to 4-hour storage comes
with less risk of cost overruns to ratepayers due to their
higher reliability contribution over time and lower likelihood
of needing payments from NYSERDA to be made whole. Hydrostor
states its support for a project specific RTE for 8-hour
projects so that bids received are at the most competitive
level. Lastly, Hydrostor again states its support for contract
term lengths for a minimum of 25 years and up to 40, as the
currently recommended 15-year length is more appropriate for
lithium-ion storage technology, not Advanced Compressed Air
Energy Storage that Hydrostor develops.

Indicated Utilities
The Indicated Utilities reiterate their support for
utility owned energy storage utility-owned storage and oppose
parties that are against this approach. The Indicated Utilities
note that most parties did not comment on utility-owned storage
and several parties recognized the potential reliability and
resilience benefits that UOS can provide.

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CASE 18-E-0130 APPENDIX B

The Indicated Utilities refute parties’ claims that

utility-owned storage is inconsistent with Commission precedent
and point out that the Commission has the discretion to permit
utility-owned storage in certain situations, such as where UOS
provides benefits to the distribution system. The Indicated
Utilities state that UOS would likely not sell into the
wholesale market, and if they did those revenues would be
returned to customers so the claim that UOS will chill energy
storage development and depress market prices is misplaced.
The Indicated Utilities object to parties’ claims that
services offered by utility-owned storage need to be
competitively solicited. They point to the Roadmap’s conclusion
that certain use cases, including distribution services, are not
currently available in the market and that UOS is a way to fill
this gap. The Indicated Utilities state that contracting for
critical transmission and distribution infrastructure can result
in challenges for the utility in ensuring proper operation to
maximize the value of the storage asset. The Indicated
Utilities comment that there is opportunity for collaboration
between third-parties and UOS in the form of competitive
procurements with third-parties for the construction and
installation of energy storage projects while the utility
maintains ownership and operational control.
The Indicated Utilities further comment that while
they do support the proposed ISC structure, they urge the
Commission to keep the UDR procurement approach as an additional
tool available for bulk storage procurements.
The Indicated Utilities reiterate their support for
the establishment of retail and residential storage incentive
programs and state their willingness to work with DPS and
NYSERDA to see how utility relationships with their customers
may help advance these initiatives.
The Indicated Utilities support all potential storage
technologies to meet the aggressive goals of the State,
including hydrogen-based resources that are long duration and
have the potential to integrate large amounts of renewables on
the electric system.
The Indicated Utilities recognize the importance and
value of vehicle-to-grid integration but oppose Nuuve’s proposal
that the Commission establish a target of 1.5 GW of
bidirectional charging infrastructure by 2030.

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CASE 18-E-0130 APPENDIX B

Institute for Policy Integrity (Policy Integrity)

Policy Integrity recommends that the Reference Price
reflect all expected market payments, including real-time energy
prices which is currently omitted as part of the REAP. Policy
Integrity also recommends minimizing market distortions by
prioritizing wholesale market participation and restricting out-
of-market payments. Policy Integrity states that by assuming
100 percent RTE as part of the REAP more efficient technologies
will not be rewarded sufficiently which may result in a less
efficient storage fleet statewide. Policy Integrity further
recommends the establishment of a performance requirement for
ISC recipients, similar to the comments made by NYC to ensure
that resources are operating and providing services as expected
and ratepayer money is prudently spent.
Policy Integrity states that all externalities
associated with air emissions be fully recognized as part of the
procurement procedures and point to Zone J as a location where
there is a large opportunity for storage to assist pollution
reduction. Policy Integrity recommends improving rate design so
that there are strong price signals in place for behind-the-
meter resources. Policy Integrity stresses the importance of
implementing cost-based rate designs that vary by time and
location so that the correct incentive exists to attract
distribution-level energy storage.

IPPNY
IPPNY emphasizes that it does not support allowing
utility-owned storage or loosening the current restrictions on
when utilities can own storage. It states that utilities have
no incentive to build in the most effective location as they do
not compete with one another or outside their territory. It
also states that customers would have to pay for cost overruns
on projects that are guaranteed cost recovery.
IPPNY further states that, while it does not oppose
looking into the value of storage as a transmission asset, these
assets should be divested from the IOUs and participate in the
wholesale market if possible.

Key Capture Energy (KCE)

KCE supports the ISC contract proposal because it
mitigates significant risks for storage developers in New York,
including market risks associated rule design changes,
uncertainty of when incumbent generators will retire, and timing
and size of new renewable generation. KCE also notes the
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CASE 18-E-0130 APPENDIX B

operational risks with energy storage resources and highlights

the importance of intelligent operation of the asset that
considers price uncertainty and states the connection between
smart operation of the resource, maximizing revenues, and
receiving favorable financing. KCE supports a limitation of
liability for the energy storage resource to pay NYSERDA in the
case of a negative settlement for “black swan” events such as
during a period of multi-day volatile prices and the inability
of the energy storage resource to capture wholesale market
revenues but cautions any limitation should not protect an
energy storage resource operator from ongoing operational
mismanagement.
KCE recommends implementing a cost-sharing mechanism
for bulk energy storage resources similar to that offered in the
offshore wind procurements. KCE specifies that cost-sharing
thresholds ($/kW) should be set and published by NYSERDA in the
solicitation.

NineDot Energy (NineDot)

NineDot reiterates its support for the Roadmap and the
6 GW storage goal.
NineDot does not support the expansion of utility
ownership of storage beyond the very limited use cases that are
currently allowed. It states that utility ownership will not be
needed to help meet the goal and cite the successes of the NY
Sun program as evidence. NineDot recommends focusing on items
that would reduce barriers to interconnection. Specifically, it
proposes an Interconnection Earnings Adjustment Mechanism that
rewards the investor-owned utilities for projects that are
timely interconnected.
NineDot states that the current exceptions for utility
owned storage were put in place before commercially viable
storage systems were available and are no longer necessary due
to major developments in the storage landscape since then.
NineDot believes the proposal by Con Edison/Orange and
Rockland to incentivize BTM storage projects is premature. It
believes a better way to target disadvantaged communities would
be to support community-scale FTM projects. It notes that BTM
project costs are 3-5x higher than FTM projects on a $/kWh basis
due to the differences in scale. NineDot would support
incentivizing BTM storage in the future if these conditions
change but emphasizes that funding should come out of a separate
budget from the Retail Storage Incentive Program and be
administered by NYSERDA, not the utilities.

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CASE 18-E-0130 APPENDIX B

NineDot supports LIPA’s comments on how Zone K will be

important to the energy transition but states that a working
group should be formed to update VDER Value Stack compensation.

Nucor Steel (Nucor)

Nucor states that the proposed ISC procurement
mechanism is not suitable for energy storage due to the nature
of energy storage performance, the need for storage, and
inefficiency of centrally administered storage procurements.
Nucor also comments on the importance of maintaining affordable
electric service and that the proposals in the Roadmap, as well
as other Commission led initiatives, will result in large cost
increases for New York consumers, especially for energy
intensive businesses.
Nucor offers several recommendations to better focus
the Roadmap. It suggests prioritizing storage investments
downstate that are needed to meet the needs of New York City,
securing energy storage projects through utility planning
processes, be agnostic towards utility or third-party energy
storage operation and ownership, adopt flexible policies that
account for needed pace of deployment, reject statewide cost
allocation as upstate customers currently and authorize cost
recovery for storage similar to how other utility capital assets
are recovered, and reject or substantially modify the proposed
ISC compensation method to reflect realistic assumptions and
require demonstrated unit performance.
Nucor comments that the proposed ISC mechanism shifts
costs to ratepayers and ignores roundtrip efficiency losses,
which will result in an inaccurate valuation of an energy
storage resource and could especially harm long-duration storage
which is critical to New York State reaching its storage goal
because long-duration storage takes longer to charge and
typically have lower efficiency levels. Nucor further comments
that a performance mechanism is necessary to ensure that money
paid for an ISC actually goes towards a functioning energy
storage system that can deliver actual grid benefits.

NY-BEST
NY-BEST reiterates its support for the adoption of the
6 GW goal by 2030. NY-BEST disagrees with NYISO’s comment that
storage deployment should align with the pace of the integration
of renewable resources, as NY-BEST states that this would limit

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CASE 18-E-0130 APPENDIX B

New York’s ability to successfully integrate this new renewable

generation.
NY-BEST continues to support the proposed ISC
structure for bulk procurements and urges NYPA and LIPA to
participate in the program in the same way as the investor-owned
utilities to maximize system benefits. NY-BEST further states
that a limitation as to how much money a project owes NYSERDA if
the Reference Price exceeds the Strike Price may be necessary to
lower the cost of financing for developers of bulk storage
projects.
NY-BEST states its strong opposition to LIPA’s
proposal that they be allowed to compete against private
developers with their own bulk storage projects for ISC credits.
NY-BEST further states their opposition to LIPA’s comments that
energy storage on Long Island be required to be located at or
near existing generation sites to replace peaking plants and
points out that energy storage resources can help displace
peakers without being located near the displaced generator. NY-
BEST supports LIPA’s participation in the storage retail program
in the near term and recommends a working group headed by DPS,
NYSERDA, LIPA, and PSEG-LI form to examine rate structures and
charging tariffs to accelerate this process.
NY-BEST recognizes the important role that the
investor-owned utilities will play in enabling storage
deployment in New York but reiterates its opposition to utility
ownership of storage due to potential harm of the competitive
and that utility ownership of storage is counter to Commission
precedent. NY-BEST points to the success of the private market
in energy storage investment as further rationale as to why
utility-owned storage assets are unnecessary. NY-BEST also
states that utility owned storage puts ratepayers at risk of
cost overruns and that any utility-owned storage used for
transmission and distribution services be precluded from
participating in the NYISO wholesale markets due to the
competitive advantage that regulated utilities have in terms of
interconnection costs and charging tariffs over private
merchants.
NY-BEST supports comments from Con Edison and Orange
and Rockland to establish a new and separate utility BTM
incentive, establishing a path to enable large distribution
connected storage, storage as a transmission asset, and
preference given to proposed projects that use products made in
New York.

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CASE 18-E-0130 APPENDIX B

Solar Energy Industries Association (SEIA)

SEIA supports NYSEIA’s comments to increase the
residential storage requirement from 200 MWs to a minimum of 400
MWs. SEIA also recommends increasing the proposed funding for
residential storage from $72 million as well as on a $/MW basis
to further animate the market and points to the important
services that residential storage provides, including customer
backup power and load management to lower bills. SEIA points to
other states’ incentive amounts as an example for Staff and
NYSERDA consideration.

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CASE 18-E-0130 APPENDIX C

APPENDIX C- Summary of Stakeholder Comments on Updated Roadmap

AES Clean Energy Development

AES Clean Energy Development (AES) urges that
Commission to adopt the 6GW energy storage goal by 2030. AES
suggests that NYSERDA review its target for 4- and 8-hour energy
storage. AES also requests that NYSERDA share more data on its
modeling of storage costs and/or how they will evaluate bids.
AES asks that NYSERDA clarify that its capacity assumptions are
in line with assumptions about energy, ancillary services, and
capital expenditures and provide more information on the blend
of independent third-party capacity price forecasts used for the
updated Roadmap analysis.

City of New York

The City of New York (the City) states that the
estimated costs in the Roadmap update will likely continue to
increase with time due to inflation and uncertainty in wholesale
market prices. The City urges the Commission to expeditiously
approve the updated Roadmap so that energy storage procurements
can begin. The City reiterates the importance of coordination
between the State, City, and Joint Utilities to maximize
opportunities for bulk energy storage sites, noting that the
City is a landowner and potential developer. The City supports
the proposed inflation adjustment mechanism due to increases in
development costs but cautions that there must be limits to
allowing undefined price increases above the accepted winning
bid, or else this would erode the competitive bidding process.
The City recommends that NYSERDA and DPS Staff create
a community engagement strategy in partnership with the City so
that public knowledge on the local reliability and air quality
benefits of bulk energy storage increases. The City notes that
there have been instances where there has been community
pushback against energy storage development.

Elevate Renewables (Elevate)

Elevate responds to the Updated Roadmap by reinforcing
that one of the main drivers in the price increases is the new
methodologies used to calculate capacity market revenue
potential for battery storage, that is the drastic reduction in
the anticipated capacity service compensation for BESS due to
new accreditation of resources’ capacity value.

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CASE 18-E-0130 APPENDIX C

Elevate explains its support in the Updated Roadmap

for the proposed new competitive Index Storage Credit (“ISC”)
mechanism, similar to other renewable resource incentives in New
York. However, Elevate notes that NYSERDA and DPS considered
but ultimately declined to include other energy market revenue
opportunities, or ancillary services, as part of the
calculation, stating that these revenue streams are too
unpredictable and dependent on location. Elevate posits that
excluding such revenue streams, however, fails to account for
the different entrance barriers that resources will experience
depending on location and contrasts the more expensive entrance
into Zone J (New York City) compared to Zone K (Staten Island).
Elevate supports the need for the greater storage resources in
Zone J.
Elevate refers to the need to develop storage
resources on brownfield sites such as those on previously sited
fossil power plants to realize quantifiable health, economic, and
societal benefits. Elevate reiterates its support to earmark 35%
of program funding to projects that deliver benefits to
environmental justice and DACs, including fossil fuel peaker
plant emission reductions. It points out that as the planned
large scale offshore wind projects are constructed to supply
Zone J, they will require substantial storage capacity onshore
to firm up and facilitate the integration of these intermittent
resources to avoid unnecessary renewable curtailments during
periods of oversupply and transmission constraints. Elevate
provides a caution regarding expenses of brownfield site
development and states that the PSC should appropriately
incentivize energy storage development on brownfields and ensure
that any approval of the Updated Roadmap considers the cost
associated with the liability and risk of taking on
environmental burdens, investigation, and remediation to
facilitate repurposing and revitalization of these locations.

Energy Dome
Energy Dome encourages the Commission to set aside at
least 2 GW of the Energy Storage Roadmap’s 6 GW energy target
for long-duration energy storage resources (LDES). More
specifically, Energy Dome wants to ensure that the Energy
Storage Program separately evaluate short duration energy
storage (SDES) and LDES resources as distinct resource classes.
Energy Dome explains further that the updated costs and
timelines provided in the 2024 Roadmap now reflect greater
urgency to rapidly procure LDES at sufficient scale meet the

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CASE 18-E-0130 APPENDIX C

targets of 2030 and the increasing LDES needs in New York

throughout the 2030s.
Regarding program timing, Energy Dome posits that by
moving the procurement out to 2025, New York only has 5 years to
procure and develop 6 GW of storage. To ensure maximum
competition and allow for diversity in supply chain for energy
storage resources in New York within this short five-year
period, Energy Dome requests that clear policy signals be set
such that developers can begin work on LDES projects that will
benefit the state. It points out that its CO2 Battery LDES
projects, which are categorized as “short lead time” resources—
require only an 18-month period from notice-to proceed to
commercial operation date.

Joint Utilities
The Joint Utilities (JU) recommend that the Utility
Dispatch Rights (UDR), Bridge-to-Wires, and a utility-
administered Behind-the-Meter retail program, as well as utility
paths for ownership of energy storage as valuable methods to
help New York achieve its storage targets. The JU also urge the
Commission to allow for utility ownership of energy storage for
transmission and distribution services and the ability to own
and operate energy storage projects built by developers. The JU
request that they be able to propose energy storage projects or
portfolios and allow for the recovery of costs for projects that
are integrated with transmission and distribution services or
turnkey projects; they state this will allow for greater project
cost certainty.
Con Edison and Orange & Rockland (the Companies)
reiterate their previous comments on the Roadmap, including the
creation of a Bridge-to-Wires program, continuation of the UDR
solicitations, and development of a BTM program. The Companies
highlight the specific complexities of downstate energy storage
deployment, including land use, interconnection costs, disparate
wholesale and local peaks, and combined underground and
overground delivery systems.

Key Capture Energy (KCE)

KCE urges the Commission to issue an Order and
authorize NYSERDA to issue a solicitation for Index Storage
Credit contracts by no later than the end of the current
calendar year. KCE states that while the Updated Roadmap amends
the proposed Procurement Schedule, the Commission, DPS and
NYSERDA should not take this updated timeline to assume any
unnecessary program delays, and they should seek to recover some
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CASE 18-E-0130 APPENDIX C

of the time lost between the issuance of the Proposed Roadmap

and the Final Order. KCE adds that the initial Index Storage
Credit contract will take time, but that NYSERDA can still issue
an RFP before the end of the calendar year and enter into
contracts with projects in 2025.
KCE also requests the Commission open a new docket to
promptly address the application of distribution rates to bulk
storage projects and points to how Central Hudson Gas and
Electric assesses exceptionally high distribution charges on
bulk storage projects. KCE explains that under the proposed
structure of the ISC, and absent any additional mechanism to
compensate for these charging costs that are being returned to
ratepayers, developers would include the additional cost of
charging bulk storage in Central Hudson’s territory in the
strike price of projects developed in that service territory.
In order to help ensure that the ISC costs do not exceed
projected costs in the Roadmap Update and to support the
Roadmap’s goals of deploying bulk storage statewide, KCE urges
the Commission to provide FERC the necessary information to
approve a rate that is consistent with state policy.

Long Duration Energy Storage Coalition

The Long Duration Energy Storage Coalition (LDES
Coalition) urges the Commission to issue an Order approving the
Roadmap quickly. The LDES Coalition recommends carving out 2GW
out of the proposed 6GW of energy storage for long-duration and
multi-day energy storage resources. The LDES Coalition states
that LDES takes several years to develop and that policy signals
are needed immediately to attract the necessary LDES development
acknowledged by the Roadmap to support a zero emissions electric
grid.

Long Island Power Authority

LIPA requests that NYSERDA provide additional details
used to calculate the updated cost impacts for the energy
storage programs proposed in the Roadmap. LIPA states that it
is unclear whether NYSERDA used updated cost estimates that
considered the NYISO’s recently established capacity
accreditation factors for the 2024/2025 Capability Year and
whether they modeled future projections of capacity
accreditation factors, accounting for the planned increase in
energy storage resources. LIPA also states that it is unclear
if the updated cost impacts reflect interconnection costs. LIPA

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CASE 18-E-0130 APPENDIX C

comments that these additional details would allow LIPA to

assess customer bill impacts more accurately.

Multiple Intervenors
Multiple Intervenors recommends that the Commission
not adopt the updated Roadmap in its current form. Multiple
Intervenors comments that the proposed method of cost recovery
through mandatory obligations on LSEs will be another long-term
financial commitment for customers that the Commission requires.
Multiple Intervenors notes that energy storage deployment to
date has been slow and questions the prudency of doubling the
3GW storage goal. Multiple Intervenors states that speculation
on the decline of federal credits in the future for energy
storage should not dictate that current customers today should
pay more and that proceeding slowly in energy storage deployment
is preferable due to technological advancements in the future
that can lower energy storage development costs.
Multiple Intervenors reiterates that the Commission
should assess the total cost of the proposed energy storage
programs in conjunction with other Commission-approved
initiatives. Multiple Intervenors states that ignoring the
totality of costs across all Commission-approved programs can
lead to jobs relocating out of New York and slowdown of
electrification efforts in transportation and heating.
Multiple Intervenors comments that the central procurement
approach proposed in the Roadmap is unlikely to attract energy
storage in the locations where it is most needed, at customer’s
expense. Multiple Intervenors also states that the proposed
load ratio cost allocation methodology based solely on energy
consumption does not align with cost causation principles and
instead the Commission should adopt a cost allocation
methodology where costs are recovered based on demand-based
factors.

New York Battery and Energy Storage Technology Consortium (NY-

BEST), Solar Energy Industry Association (NYSEIA), New York
Clean Energy Industry Association and Alliance for Clean Energy
New York (ACENY), collectively “Commenters”

In their response to the Updated Roadmap, Commenters

support the revised budget allocations provided of between
$1,190,004,228 and $1,910,350,431. They point out that the
analysis for the Final CLCPA Scoping Plan and the latest NYISO
System & Resource Outlook have projected the need for at least

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CASE 18-E-0130 APPENDIX C

15 GW of energy storage by 2040 to achieve the goals of the

CLCPA. However, Commenters state their concern that the update
to the Roadmap delayed the release of the bulk program by over a
year, resulting in even tighter timelines to meet the 6GW by
2030 goal. Therefore, Commenters encourage the Commission to
take swift action to operationalize the program, and recommend
the Commission provide ample flexibility to NYSERDA to adjust
procurement timelines accordingly to achieve the goals in a
timely manner. Commenters explain that if delays continue, the
potential financial harm in obtaining Department of Energy (DOE)
loan guarantees to support energy storage deployment under their
Title 17 Clean Energy Financing Program could be significant.
Commenters explain that according to the DOE, agreements on loan
applications must be completed by September 2026 and disburse
all loans by December 2031. A further delay in the rollout of
Roadmap programs could make this timeline difficult to achieve.
If developers are unable to access federal financing benefits
for energy storage projects, the cost of the projects will
increase, resulting in a higher cost to New York State
ratepayers to achieve the CLCPA.
Another concern with any delays pertains to the costs
of retaining site access for potential development. Storage
developers continue to make significant ongoing investments in
site access with an understanding that the State is committed to
supporting the energy storage market in New York. Given the
continued delay in approving the Order, project costs are
increasing, particularly as some sites’ agreements expire and
need to be reacquired, or as agreements are dropped altogether
and alternative sites identified.
Commenters explain that retirement of peaker plants in
Zone J is being held up by the NYISO reliability concerns and
preventing the closure of peaker plants as required by the DEC.
It explains that this has delayed the retirement of nearly 600
MW of fossil-based generation capacity in New York City.
Commenters posit that faster deployment of energy storage in
Zone J could help address this reliability risk, lowering costs
to ratepayers and contributing to improved local air quality,
particularly for DACs.
Regarding cost containment, Commenters recommend the
Commission initiate a parallel action to investigate and improve
utility rates for energy storage resources at both the bulk and
retail levels and add that energy storage-specific rate designs
would benefit the grid and ratepayers by aligning rate
structures to encourage optimal charge and discharge of energy
storage resources. More specifically, it explains that utility

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CASE 18-E-0130 APPENDIX C

tariffs have not been designed for energy storage and apply many
costs that are inappropriate to resources that are not the end
consumer of the energy. These tariffs, with associated riders
and surcharges, apply to energy storage both on the distribution
system and, in some New York utility territories, on the
transmission system as well.

NineDot Energy (NineDot)

NineDot continues to support the work of DPS and
NYSERDA in updating the Roadmap to reflect increased costs in
New York but also emphasizes the projected net cost savings for
the New York electricity system of nearly $2 billion (net
present value-NPV) through 2050.
NineDot strongly encourages the Commission to
expeditiously issue an Order to adopt a new energy storage goal
of 6 GW by 2030, approve the updated Roadmap, and authorize the
programs that are necessary to implement it. NineDot points out
that over the six-year period since adopting the 2018 Roadmap,
New York State has deployed 396 MW of energy storage
representing only 6.6% of the 2030 6 GW target. It explains
that the long, complex, and costly development cycle for the
Retail energy storage market severely delays project and
specifically that retail project development can take two to
four years to complete due to a variety of factors including
siting, design, permitting, interconnection, construction,
financing, equipment procurement and customer acquisition.
NineDot refers to siting acquisition and control costs (such as
rent, insurance, property taxes and site management) that are
expensive monthly development costs that need to be financed in
this high-rate environment.
NineDot explains that citing of New York City (NYC)
energy storage equipment entails long lead times and that NYC
has one of the most complicated grids in the world. This
equipment includes interconnection hardware such as
transformers, switch gears and electrical houses (e-houses) and
some may have lead times anywhere from 12-24 months. NineDot
posits that a reflection of these NYC issues are energy storage
development costs of land, labor, interconnection, etc., and how
they are much more expensive compared to other New York regions.
NineDot explains that in light of these complex interconnection
storage issues, New York City’s allocation under the program
should have a higher allocation of funding than other
jurisdictions.

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CASE 18-E-0130 APPENDIX C

NineDot proposes that the Commission Order allow for

Non-Wires Alternatives (NWA) to receive RSIP funds and recounts
that NYSERDA released an updated Energy Storage Market
Acceleration Incentives Implementation Plan (the Plan) on May
14, 2024, which stated that “Projects previously selected under
an IOU Non-Wires Alternative, and projects that submitted a
proposal to an open NWA prior to March 11, 2019 for all Retail
incentive Blocks other than NYC Block 5 prior to May 14, 2024
for NYC Block 5 and are pending decision or negotiations.”
While any project that applied for an NWA award before March
2019 could not apply for RSIP; any project that applied to an
NWA after March 2019 could apply.
NineDot recommends that maintaining flexibility to
adjust funding allocation between Retail and Bulk markets will
be necessary and NYSERDA should base that on observed market
activities. As an example, NineDot states that if the
community-scale Retail market displays robust, cost-effective
growth (as CDG has it points out), NYSERDA should shift funding
from the Bulk program to additional Retail Blocks.
NineDot explains that there will be delayed cost
savings and benefits for Disadvantaged Communities due to
presence of peaker plants as explained throughout this document.
However, Battery storage is uniquely suited for displacing
peaker plants, which are disproportionately located in downstate
DACs. The delayed cost savings will very likely be due to the
NYISO’s Reliability Plan and its potential decision to maintain
peaker units to maintain NYC’s grid reliability. This will
entail delay.
In regard to the new (January 2024), Statewide Solar
for All Program (S-SFA), combining a utility-managed Energy
Affordability Program (EAP) and Community Solar program to pass
along clean energy benefits to low-income households, NineDot
states the hope for the program is that it delivers $40 of
annual savings to 800,000 households. However, as NineDot
points out the cost-savings benefits of shared, local, clean
energy generation that S-SFA produces, will require storage
benefits, but with the continued delays of the Roadmap, the
community-scale storage projects that could deliver such
benefits will also be delayed.

Sierra Club
Sierra Club states the cost increases in the updated
Roadmap are modest in comparison to other methods of achieving
the State’s climate goals. Sierra Club comments that the
Commission should collaborate with the NYSDEC to execute a

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CASE 18-E-0130 APPENDIX C

blueprint for the retirement and redevelopment of fossil-fuel

fired electric generation resource which will help guide energy
storage siting decisions. Sierra club also stresses the
importance of support for LDES as a critical tool to achieve the
CLCPA mandates. Sierra Club remarks that the energy storage
procurements should begin quickly as to not jeopardize the
energy storage deployment goals.

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CASE 18-E-0130 APPENDIX D

APPENDIX D- Supplemental Generic Environmental Impact Statement

Findings Statement

State Environmental Quality Review Act

FINDINGS STATEMENT

June 20, 2024

Pursuant to Article 8 (State Environmental Quality

Review Act (SEQRA)) of the Environmental Conservation Law and 6
New York Codes, Rules and Regulations (NYCRR) Part 617, the New
York State Public Service Commission (Commission), as Lead
Agency, makes the following findings.

Name of Action: 18-E-0130, In the Matter of Energy Storage

Deployment Program; Order Establishing Updated Energy Storage
Goal and Deployment Policy
SEQRA Classification: Unlisted Action
Location: New York State
Date Final Supplemental Generic Environmental Impact Statement
(SGEIS) Filed: December 14, 2023
Final SGEIS Available at: http://www.dps.ny.gov

I. PURPOSE AND DESCRIPTION OF THE ACTION

Public Service Law (PSL) §74 directed the Public

Service Commission (Commission)to establish a 2030 goal for the
installation of qualified energy storage systems and a
deployment policy to support the statewide goal. In response,
the Commission issued the Order Establishing Energy Storage Goal
and Deployment Policy (Energy Storage Order) on December 13,

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CASE 18-E-0130 APPENDIX D

2018, in this proceeding. 81 The Energy Storage Order established

a goal of 3 gigawatts (GW) of energy storage by 2030, and an
interim goal of 1.5 GW by 2025.
In compliance with the State Environmental Quality
Review Act (SEQRA), the recommendations contained within the 3
GW Roadmap were analyzed in a Draft Generic Environmental Impact
Statement (GEIS). In the Order accepting the Draft GEIS as
complete, the Commission stated that “[i]f a capacity target
higher than 3,600 MW of incremental energy storage deployment is
adopted, additional potential environmental impacts shall be
analyzed.” The Commission accepted the findings of the Final
GEIS as complete on September 12, 2018, and adopted the SEQRA
Findings Statement in the Energy Storage Order.
On December 28, 2022, DPS and NYSERDA jointly filed
“New York’s 6 GW Energy Storage Roadmap: Policy Options for
Continued Growth in Energy Storage” (Roadmap), in this
proceeding. The Roadmap outlines the market-supported policy,
regulatory, and programmatic actions necessary to achieve the
State’s near-term energy storage goals and recommendations for
the Commission to consider when expanding the energy storage
deployment policy. Broadly, the recommendations are separated
into seven categories: (1) the role of energy storage targets;
(2) bulk energy storage procurement program design; (3) retail
energy storage procurement program design; (4) residential
energy storage procurement program design; (5) wholesale market
actions; (6) program design considerations applicable to every
market; (7) long duration storage; and (8) program costs. The

81 The Energy Storage Order was informed by Department of Public

Service (DPS) and New York State Energy Research and
Development Authority’s recommendations in the New York State
Energy Storage Roadmap, which was filed on June 21, 2018, in
this proceeding (3 GW Roadmap).

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CASE 18-E-0130 APPENDIX D

Roadmap specifically supports the State’s initiative to deploy 6

GW of energy storage by 2030.
The Roadmap is focused on recommendations based on
lessons learned since the issuance of the Energy Storage Order.
As the Roadmap expands upon the recommendations in the Energy
Storage Order and recommends the adoption of a capacity target
higher than 3,600 MW of energy storage, a Supplemental Generic
Environmental Impact Statement (SGEIS) was prepared, analyzing
additional environmental impacts, consistent with 6 NYCRR
§617.9(a)(7). 82 Given that the extent to which each type of
energy storage technology will be used in response to the
Roadmap is uncertain, and consistent with SEQRA §617.10(a), the
SGEIS is broader and more general than a site or project-
specific environmental impact statement (EIS), and identifies
potential areas where environmental impacts may be caused by the
construction, operation, and disposal of energy storage
facilities. The SGEIS also opines upon the safety of energy
storage technologies. By the Order Establishing Updated Energy
Storage Goal and Deployment Policy, issued June 20, 2024, the
Commission adopted several Roadmap recommendations and updated
the statewide deployment policy and an energy storage deployment
goal.

II. FACTS AND CONCLUSIONS RELIED UPON

A. Public Need and Benefits
If successfully implemented, the updates to the
statewide deployment policy should result in reductions in peak

82 In the Order Accepting the Draft GEIS as complete, the

Commission stated that “[i]f a capacity target higher than
3,600 MW of incremental energy storage deployment is adopted,
additional potential environmental impacts shall be analyzed.”
Case 18-E-0130, Order Accepting Draft Generic Environmental
Impact Statement as Complete (issued June 25, 2018), p. 2.

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CASE 18-E-0130 APPENDIX D

load demand during critical periods, increases in the overall

efficiency of the grid, and/or displacement (or accelerated
displacement) of fossil fuel-based generation (e.g., by allowing
greater integration of renewable energy resources). Such
outcomes will lead to an array of public benefits, including
economic, health, and environmental benefits. Specifically,
these benefits may include:
• Public health
Improvement in public health from avoided emissions of
criteria air pollutants, such as carbon dioxide, carbon
monoxide, sulfur dioxide, nitrous oxides, and particulate
matter. To the extent that these avoided air emissions
occur from the displacement of peaker plants located in
Disadvantaged Communities, the associated benefits may
accrue to these vulnerable communities.
• Climate change mitigation and adaptation
As fossil-fuel based generation decreases, the associated
adverse impacts to air, water, land, and ecological
resources decrease. Greater energy storage deployment can
reduce the State’s reliance on fossil fuel energy, and aid
in the prevention of climate change-related impacts.
• Ecosystem services
As energy storage resources are developed, land and water
resource use could improve. Water use and pollutant
releases from fossil fuel generated energy could be
avoided.
• Economic Development
There are both direct and indirect economic benefits of
energy storage development. Regarding indirect economic
benefits, a 2022 study by the National Renewable Energy
Labe (NREL) estimates that between 4,700 and 9,000 jobs
will be needed for the energy storage industry;

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CASE 18-E-0130 APPENDIX D

additionally, the build out of energy storage may result in

additional spending, increased productivity, reduced
physical damage during extreme weather events, and
redistributed resources for more productive economic uses.
Regarding direct economic benefits, the development of
energy storage may create energy cost savings.
• Technological innovation
Investment in the energy storage industry may contribute to
significant cost reductions for the underlying technology.
B. Potential Impacts
Overall findings suggest that adverse direct
environmental impacts of the actions recommended by the Roadmap
are minimal. The SGEIS considers three types of energy storage
technologies: batteries, thermal, and mechanical (i.e.,
flywheels). Risks exist across all three technology types, most
notably: fire safety risks related to the use of lithium-ion
(Li-ion) batteries, and risk of soil and groundwater
contamination due to improper disposal of battery-related waste.
A summary of the environmental impacts across the three
technology types follows.
Land Use
The energy storage technologies considered in the
SGEIS have a relatively small land use footprint that generally
increase as the size of a project increases. There may be site-
specific impacts related to land use, depending on whether the
energy storage is either co-located with existing commercial
facilities or constructed on previously undeveloped land.
Water Resources
Surface water resources may potentially be affected by
the construction of an energy storage facility through storm
water runoff if site-soils are disturbed during construction.
The degree to which the energy storage project would impact

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CASE 18-E-0130 APPENDIX D

water resources depend on the size of the impacted area and the
site’s proximity to protected waters, as well as other site-
specific factors.

Species Biodiversity
Energy storage associated with intermittent generation
sources may enable impact-reduction strategies for protection of
vulnerable species that are susceptible to operational impacts
(e.g., energy storage can enable the curtailment of wind turbine
operation to avoid periods of peak wildlife activity in close
proximity to wind turbines).
Climate and Air Quality
The climate and air quality impacts of energy storage
are influenced by the efficiency of the technology and the
original source of electricity being stored. Although a storage
device outputs less energy than the charging input, the overall
emissions impacts are highly case-dependent. Additionally, as
the distance between generation and storage increases, more
electricity has to be produced due to energy loss during
transmission. Therefore, energy storage devices may result in
increased electricity demand from the grid, resulting in greater
emissions when considered on a standalone basis. When energy
storage technologies complement cleaner generation – as
envisioned by the Reforming the Energy Vision (REV) Order – such
technologies can contribute to lower levels of both local and
global emissions. On a large scale, the use of energy storage
as part of a broader strategy to increase the responsiveness of
demand will facilitate greater development of low-carbon energy
generation.
Community Character
The installation of energy storage systems is not
likely to impact the community character of an area. In the

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CASE 18-E-0130 APPENDIX D

short term, during the construction phase, movement of heavy

machinery may create noise pollution. However, the operation of
energy storage technologies is generally quiet.
Batteries create minimal noise but there may be some
noise pollution from the cooling units that prevent the
batteries from overheating, which could have an impact on
community character if not mitigated. Thermal storage avoids
cooling-related noise, which minimizes daytime noise pollution.
Mechanical storage systems generate operational noise, but this
is relatively low compared to conventional energy storage
technologies.
Socioeconomic
The socioeconomic impacts of energy storage are
similar across technologies. The cost of producing and
supplying renewable energy may be reduced through battery or
flywheel energy storage. Batteries and flywheels can also
recycle energy to the grid (i.e., receive excess energy and
redistribute it to the grid when needed), leading to reductions
in energy costs. Thermal energy storage systems do not supply
electricity to the grid, but reduce demand during peak hours; as
a result, individuals’ energy costs are often reduced.
C. Public Health and Safety
Many types of battery storage technologies contain
toxic and hazardous chemicals that can cause damage to humans
when exposure occurs. However, exposures generally occur when
the battery has been damaged or tampered with and therefore, the
risk of harm can be reduced by following instructions from the
manufacturer.
Fire risk associated with battery storage is an
important safety consideration. With lithium-ion batteries,
there is a risk of thermal runaway – a positive-feedback
incident where excessive heat released in an exothermic process

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CASE 18-E-0130 APPENDIX D

triggers other processes that release eve more heat, resulting

in an uncontrollable increase in temperature. Adequate
preventative measures can decrease the chances of thermal
runaway and limit the impacts of such events.
Hazards associated with large-scale lithium-ion
batteries can be categorized into electrical, thermal, and
mechanical types. Electrical hazards can result from the high
voltage or high charge rate of batteries and can lead to
hazardous events like fire and explosion. Thermal hazards are
related to both high and low temperatures, either of which may
result in decomposition of the battery. Mechanical hazards such
as vibration, shock, or physical impact can lead to disturbances
or create defects which can lead to thermal runaway.
There have been 14 failure events at energy storage
facilities in the U.S., three of which were in New York State in
2023. None of these events resulted in fatalities.
Due to the existence of the aforementioned hazards,
monitoring and mitigation measures are necessary for safely
transporting and operating battery storage systems.
D. Mitigation of Potential Adverse Impacts
Consistent with SEQRA requirements, the SGEIS
describes the variety of measures available to minimize or
avoid, to the maximum extent practicable (incorporating all
practicable mitigation measures), potentially adverse
environmental impacts that may result from the energy storage
activities that may be implemented under the Roadmap. The SGEIS
discusses 1) key federal and state regulations that may apply to
energy storage activities during construction, operation, and
closure of a specific project; and 2), provides an overview of
site-specific project design and planning, which serves as a
primary mitigation measure for site-specific issues. Measures
to mitigate (i.e., minimize or avoid) the potentially adverse

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CASE 18-E-0130 APPENDIX D

environmental impacts that may result from greater deployment of

energy storage, include:
• Federal and state regulations, including U.S. Department of
Transportation’s (DOT) Hazardous Materials Regulations
(HMR) related to the transportation of lithium-ion
batteries, the Clean Air Act (CAA), the Resource
Conservation and Recovery Act (RCRA), the Clean Water Act
(CWA), the New York State Environmental Conservation Law
(ECL), the Public Service Law (PSL), the Climate Leadership
and Community Protection Act (CLCPA), the New York State
Uniform Fire Prevention and Building Code, and the 2020
Fire Code of New York State;
• Site-specific permitting regimes including Articles 4, 7,
and 10 of the PSL, the SEQRA process, and NYSDEC
Commissioner Policy on Environmental Justice Permitting
(CP-29); and
• Use of best management practices during site-specific
design, planning, and siting efforts.
Alternatives Considered
The primary alternative considered in the SGEIS is
described as the “no action” scenario. Because the Roadmap
expands upon the existing 3 GW Roadmap, the “no action”
alternative is defined as no additional action beyond the goals
and programs established in the original 3 GW Roadmap.
Unavoidable Adverse Impacts
There are unavoidable adverse impacts that can be
avoided, minimized, or mitigated through applicable federal and
state laws, regulations, and review processes.
Irreversible and Irretrievable Commitment of Resources
Approval of the Roadmap would not in itself result in
irreversible or irretrievable commitment of resources because no
particular energy storage project, project site, or regulatory

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CASE 18-E-0130 APPENDIX D

modification will be approved or endorsed by approval of the

action. The construction of new energy storage projects in the
future, in response to the Commission’s action on the Roadmap,
may raise such concerns. However, these concerns will be
identified in site-specific environmental analyses and avoided
or minimized in accordance with SEQRA and other applicable laws
and regulations. Any actual impacts and resources commitments
are currently, and will remain, unknown until specific projects
are proposed.
Growth-Inducing Aspects and Socioeconomic Impacts
The SGEIS considers overall potential growth-inducing
aspects and socioeconomic impacts of energy storage. Project-
specific impact analysis may be conducted at the time such
projects have commenced.
Energy storage directly provides a number of different
benefits at all levels of the electrical system, including
meeting capacity and reliability requirements, providing
distribution system relief, reducing the cost caused by peak
electrical periods, and integrating large-scale wind and solar
generating facilities. These energy system benefits in turn
generate additional benefits. The development of energy storage
systems may result in environmental benefits as part of New
York’s strategy to shift generation from fossil fuels to low-
carbon resources. Similarly, there are public health benefits
related to the reduction in criteria air pollutants from the
reduction in fossil-fuel based generation. The economic
benefits of energy storage include the creation of jobs,
additional spending in the economy, increased productivity,
reduced physical damage during extreme weather events, and/or
redistributed resources for more productive economic uses. The
technological benefits associated with energy storage include
incentives designed to promote capacity expansion and improve

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CASE 18-E-0130 APPENDIX D

the cost effectiveness of storage technologies, which can

provide a path towards the level of storage needed for the long
term.
Costs related to the implementation of the increased
storage target and program proposals in the Roadmap are
estimates. The procurement of retail and residential programs
is estimated to cost $775 million, combined. The procurement of
the bulk storage program is estimated to cost between $701.5
million and $1.42 billion. Administrative costs include program
administration (approximately $29.0 million), implementation
support (approximately $15 million), program evaluation
(approximately $3 million), and the New York State Recovery Fee
(approximately $8.9 million). The total cost for the three
incentive programs, is expected to be between $1.29 billion to
$2.01 billion, paid out over 21 years. Electric customers would
see an estimated increase of 0.38 to 0.59 percent on average,
amounting to $0.40-$0.64 per month for the average residential
customer.
Actions taken in response to the Roadmap may occur in
environmental justice (EJ) communities and may have the
potential to affect low-income and minority populations within
these communities. Because the implications of any storage
projects will site-specific, further evaluation of EJ impacts
should occur during the project review stage.
Effects on Energy Consumption
As discussed throughout the SGEIS, penetration and
adoption of energy storage could affect the electrical system in
a number of ways at the generation, transmission, and
distribution levels. Expansion of energy storage may facilitate
the deployment of renewable generation resources and relieve
system pressures during peak demand. These potential changes to
the structure of the electrical system are not expected to

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CASE 18-E-0130 APPENDIX D

directly affect the amount of electricity used or the amount of

energy conserved in the State; rather, energy storage is
expected to change how this demand is met. The programs
proposed in the Roadmap are not expected to indirectly affect
the amount of energy consumed or conserved in New York State.

III. CONCLUSIONS
Based on the discussion set forth in the Final SGEIS,
the Commission makes the findings stated above regarding the
potential environmental impacts, as well as benefits, of the
Energy Storage Deployment Policy, and certifies that:
1. The requirements of the State Environmental Quality
Review Act, as implemented by 6 NYCRR 617, have been
met; and
2. Consistent with social, economic, and other
essential considerations from among the reasonable
alternatives available, the actions being undertaken
yield overall positive environmental impacts to the
maximum extent practicable.

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CASE 18-E-0130 APPENDIX E

APPENDIX E- NYSERDA Retail and Residential Energy Storage

Program Recovery Mechanisms

Electric Utility Surcharge Mechanism

Central Hudson Gas & Clean Energy Standard Surcharge
Electric Corporation
Consolidated Edison Clean Energy Standard Delivery
Company of New York, Inc. Surcharge
Niagara Mohawk Power Clean Energy Standard Delivery
Corporation d/b/a National Surcharge
Grid
New York State Electric & System Benefit Charge
Gas Corporation
Orange and Rockland Clean Energy Standard Delivery
Utilities, Inc. Surcharge
Rochester Gas and Electric System Benefit Charge
Corporation
CASE 18-E-0130 APPENDIX F

APPENDIX F- NYSERDA Retail and Residential Energy Storage

Program Cost Allocations

2023 Annual Delivery

Service Load (MWh) MWh Load Ratio Share
Central Hudson 4,920,811 3.62%
Con Edison 52,901,118 38.87%
NYSEG 16,612,546 12.21%
National Grid 32,356,078 23.78%
O&R 4,096,586 3.01%
RG&E 7,192,770 5.29%
LIPA 18,007,000 13.23%
Total 136,086,909 100.00%
 CASE 18-E-0130 APPENDIX G

APPENDIX G- Residential and Retail Energy Storage Program Annual Costs

(including Administration, Implementation, Program Evaluation and NYS Cost Recovery Expense)
Allocation and Collection Schedule for Utilities and LIPA

Program Costs
(nominal) Central Hudson Con Edison NYSEG National Grid O&R RG&E LIPA
2024 $ 6,905,349 $ 249,693 $ 2,684,319 $ 842,957 $ 1,641,818 $ 207,870 $ 364,977 $ 913,715
2025 $ 9,405,349 $ 340,091 $ 3,656,145 $ 1,148,140 $ 2,236,219 $ 283,127 $ 497,113 $ 1,244,514
2026 $ 14,405,349 $ 520,888 $ 5,599,797 $ 1,758,505 $ 3,425,021 $ 433,640 $ 761,384 $ 1,906,114
2027 $154,405,349 $ 5,583,193 $ 60,022,052 $ 18,848,734 $ 36,711,478 $ 4,648,021 $ 8,160,977 $ 20,430,893
2028 $203,155,349 $ 7,345,961 $ 78,972,659 $ 24,799,796 $ 48,302,297 $ 6,115,528 $ 10,737,621 $ 26,881,486
2029 $206,905,349 $ 7,481,558 $ 80,430,398 $ 25,257,570 $ 49,193,899 $ 6,228,414 $ 10,935,825 $ 27,377,686
2030 $210,655,349 $ 7,617,156 $ 81,888,137 $ 25,715,344 $ 50,085,500 $ 6,341,299 $ 11,134,028 $ 27,873,885
2031 $ 4,405,349 $ 159,294 $ 1,712,493 $ 537,774 $ 1,047,417 $ 132,613 $ 232,841 $ 582,915
2032 $ 4,405,349 $ 159,294 $ 1,712,493 $ 537,774 $ 1,047,417 $ 132,613 $ 232,841 $ 582,915
Total: $814,648,139 $ 29,457,128 $316,678,494 $ 99,446,595 $193,691,068 $ 24,523,124 $ 43,057,607 $107,794,123
CASE 18-E-0130 APPENDIX H

APPENDIX H- Bulk Storage Program

Forecasted Annual Costs
($ millions, nominal)

High Forecast Low Forecast

2028 $ 35 $ 19
2029 $ 70 $ 40
2030 $ 227 $ 152
2031 $ 228 $ 152
2032 $ 226 $ 146
2033 $ 222 $ 136
2034 $ 209 $ 116
2035 $ 198 $ 97
2036 $ 196 $ 91
2037 $ 181 $ 68
2038 $ 181 $ 64
2039 $ 191 $ 74
2040 $ 181 $ 57
2041 $ 171 $ 39
2042 $ 172 $ 37
2043 $ 140 $ 27
2044 $ 110 $ 19
Total: $ 2,938 $ 1,334