On April 24, the NE Chapter submitted comments to the New York Public Service Commission regarding the continuation of certain standby rate exemptions. In May 2021, the Commission issued an order which declined the 2-year extension of the standby rate exemption for certain technologies and projects, including CHP systems with a capacity of less than 1 megawatt (MW).
In our comments, we urge the Commission to reconsider the 2021 decision and request that highly efficient CHP systems, fueled by natural gas, biofuels, renewable natural gas (RNG), and clean hydrogen, be reinstated into the Designated Technologies exemption category and thus be eligible for standby exemption status below the 1 MW threshold. CHP is both a short- and long-term solution the which accomplishes New York’s Climate Leadership & Community Protection Act (CLCPA) goals and the Commission’s goals of grid reliability and stability.
The NE Chapter also urges the Commission to use marginal grid emissions when evaluating methodologies to lower carbon which results from power production.
You can view and download a full set of the comments here.