CLP today filed comments with the PSC (Case 16-M-0411) on Central Hudson’s “Distribution System Implementation Plan” or “DSIP”--yes, it is a jargony mouthful, but also a very important document in which Central Hudson is supposed to lay out how the utility will move forward in its new role in managing the shift to a more distributed energy system. All utilities are required to file this multi-year implementation plan, and then update it annually. The plan must include the following, at a minimum:
- Actual and forecast system loads;
- capital spending projections specific enough to inform market planning and participation by third parties;
- actual and forecast levels of distributed energy resources (DER), including detailed analysis of system needs that DER may be able to meet (as an alternative to costly transmission investments);
- plans for encouraging market development of DER;
- plans for increasing DER deployment in underserved markets;
- specific plans, including cost estimates for building DSP capabilities;
- and a description of the internal organization of DSP and traditional utility functions.
CLP welcomes the valuable information and data that Central Hudson’s DSIP makes available for the first time; however, the document falls short in important areas, and we are very concerned generally about the apparent view of Central Hudson that there is little need to actively encourage and support a vibrant market for DER in its service territory because of “meager” electric load growth. The utility gives no attention to the important system-wide value and environmental benefits of investments in energy efficiency, demand reduction, and distributed renewable generation, as well as the enormous community and public benefits of such investments.
In addition to submitting party comments specifically on the Central Hudson DSIP, CLP also signed on to comments submitted by the Clean Energy Organizations Collaborative that address utility DSIPs, generally. Those comments can be found here.