The agency that enacted the new rule is the New York Public Service Commission (PSC). It hopes that demanding the new studies would act as a sort of deliverability test to make sure new wind projects will be able to get their power to the market without stressing the entire electricity grid or supplanting other generation. PSC called for the additional studies because transmission constraints in New York can sometimes lead to some electricity generation being curtailed or bottlenecked in certain parts of the state.
Carol Murphy, executive director of the Alliance for Clean Energy New York (Aceny), says it makes little sense for PSC to demand transmission studies from wind developers, because the developers already conduct their own internal deliverability tests for proposed projects. "You're not going to build something if you can't get your power out," she says.
The new studies would also go above and beyond the usual analysis done by developers, potentially increasing the cost of projects by $100,000 to $500,000 and possibly revealing competitive information. The timing makes little sense, adds Murphy, because major transmission studies will be released in the coming weeks by the state's grid operator and the major transmission companies in the state.
Murphy and developers also fear the studies would grant the PSC - which doles out permits for wind plant construction - more data that could be used as a reason to deny a permit. "We are very suspicious of why they want this information," says Murphy. "What are they looking at this for? Is it information that is nice to have and will help determine where there needs to be transmission or is this going to be used as yet another criteria for permitting a project?"
She says the PSC should be looking at this information in a different way. Instead of making developers pass a deliverability test, the state should be looking actively to identify where corridors of strong renewable energy potential exist but are hampered by transmission weaknesses needing upgrades.
Developers also lament what they perceive as a double standard. "We are concerned that the deliverability test is only being applied to renewables and not other new sources of power generation," says Paul Copleman, a spokesman for wind development giant Iberdrola. "In light of the state's goals to dramatically expand the supply of clean, homegrown energy, this additional hurdle is unproductive, - unless the goal is to use the information gathered by this new test to expand and upgrade transmission infrastructure on a broad shared-cost basis in order to better accommodate renewables' growth, which is not clear."
Vagueness surrounding PSC's order is leaving the wind industry uncertain on what to provide, because a vast range of scenarios could be modelled by developer studies showing everything from little or no impact of a new project to scenarios when a wind plant could force another type of plant to stand down from the grid. "But what does that mean?" asks Murphy. "If you (push) somebody down and for how many hours, it is going to be a problem? Does that mean they could potentially deny the wind project a permit?"
On behalf of New York's wind developers, Aceny has filed an appeal and has already had at least one follow-up meeting with commission staff. If the order stands - as it appears it will - developers hope the PSC will accept some variation on the internal studies typically undertaken by developers instead of insisting that developers undertake a more costly and comprehensive study.