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Hydro Coalition Submits Comments in reply to HCF Whitepaper

On October 28, 2019, the Law Offices of Dana Hall prepared comments on behalf of a coalition of hydropower interests in the Value of Distributed Energy Resources proceeding. The comments were in response to a NYS DPS Staff Whitepaper proposing to discount compensation rates for the CDG Community Credit rate component of the “Value Stack” based on assumed capacity factors for all eligible resources.

The Whitepaper was published after the Joint Utilities petitioned for an adjustment in the because of concerns that fuel cells operating at a high capacity factor and receiving the Community Credit would cause Con Edison to exceed the 2% cap on ratepayer impacts mandated by the CDG program. To remedy this perceived problem, the Whitepaper proposed to discount the compensation rates for all resources that have a higher capacity factor than was assumed for solar, at 14%. The resulting discount to hydro participating in CDG is a 78% reduction in compensation for the Community Credit. The hydro coalition comments proposed that the Commission leave the compensation rates for hydro and wind as they are now, and limit their remedy to fuel cells in Con Edison’s territory.

Download the comments as a pdf here:

Visit the VDER docket here: