The Institute for Policy Integrity submitted comments in the New York Public Service Commission’s (the Commission) Proceeding on Motion of the Commission in Regard to Gas Planning Procedures, responding to a notice posing various questions about non-pipeline alternatives (NPAs). Our comments focused on how NPAs can be compared fairly to conventional infrastructure alternatives. Key recommendations include:
- The Commision should clarify what gas-system information is minimally sufficient to conduct a meaningful benefit-cost analysis. Specifically, utilities should be instructed to provide:
- Detailed baseline scenarios on how peak load would be managed through traditional investments to understand how the NPA modifies infrastructure use
- Valuations of avoided infrastructure costs using granular estimates from Marginal Cost of Service studies rather than system-wide averages
- NPAs may impact electricity load. To ensure full consideration of the interactions between NPAs and the electric system, the Commision should ensure that a benefit-cost analysis:
- Examines peak impacts on seasonal electricity load for all NPA projects, not just ones involving electrification
- Considers transmission and distribution infrastructure impacts in light of planned electric system upgrades
- In valuations of expected emissions reductions from NPAs, the Commission should:
- Shift away from valuing emissions using location-based marginal price methods which are not applicable to natural gas
- Value natural gas and electricity emissions based on the uninternalized externalities caused by an incremental increase in pollutant emissions
- Use granular valuations for local pollutants based on the location and time at which they are expected to occur
- The Commission should direct the development of a new Gas System Transition BCA Framework that requires gas utilities to
- Standardize evaluation of gas-sector impacts
- Assess cross-fuel costs and emissions implications of NPAs on both gas and electric systems
- Reevaluate utility cost test and ratepayer impact measures to capture fiscal benefits and costs of cross-fuel impacts
In addition to the comment regarding NPAs, Policy Integrity also responded to Staff Straw Proposal concerning the modification of the Commission’s regulation governing gas main extensions by filing in this docket a letter attaching a law journal article addressing the tensions between the Climate Leadership and Community Protection Act and relevant provisions of the Public Service Law, and the Commission’s options for mitigating those tensions, including modification of this regulation.