CJNY Submits Comments on the Initial Report on the New York Power Grid Study
March 22, 2021
Submitted Electronically
Hon. Michelle L. Phillips
Secretary to the Commission
New York State Public Service Commission
Three Empire State Plaza Albany, New York 12223
Re: Case 20-E-0197 Proceeding on Motion of the Commission to Implement Transmission Planning Pursuant to the Accelerated Renewable Energy Growth and Community Benefit Act
Dear Secretary Phillips:
Climate Jobs New York (CJNY) is a growing coalition of labor unions representing 2.6 million working New Yorkers committed to combating both climate change and income inequality. CJNY is dedicated to building a clean energy economy, creating good union jobs, and supporting more equitable communities and a more resilient New York. We appreciate the opportunity to submit comments on the Initial Report on the New York Power Grid Study released on January 19, 2021.
New York’s clean energy economy can only be effectively realized with an efficient and cost-effective transmission infrastructure. We commend the New York State Public Service Commission (the Commission) for authorizing the grid study, and the New York State Energy Research and Development Agency (NYSERDA) and the Department of Public Service (DPS) for preparing the study to address needed upgrades to our electricity grid as we continue to electrify and inject clean renewable energy into New York’s system.
It is clear that robust transmission upgrades are crucial for the state’s long-term energy future. Over the next few years, Phase 1 projects like substation transformers, voltage upgrades, and reconductoring lines to higher capacities must move swiftly. As noted in the report, “proposed Phase 1 local transmission projects would unbottle the delivery of an estimated 6.6 GW of renewable generation,” and local distribution upgrades would unbottle 2 GW of renewables.1 In order to reduce the frequency of congestion, constraints, and curtailments of the electrical grid, as the longer-term Phase 2 projects are being studied we must be sure that this work moves forward as expeditiously as possible. To update the grid in a safe and reliable way requires qualified workers. We must ensure that those who complete the transmission and distribution work are properly qualified, including graduating from a state registered apprenticeship program.
We must also ensure that as we make significant investment in updating New York’s grid, these investments create positive economic development and good jobs for New York communities, as well as building the clean-energy economy of tomorrow.
Successful implementation of the Climate Leadership and Community Protection Act (CLCPA) includes According to the CLCPA, “shaping the ongoing transition in our energy sector to ensure that it creates good jobs and protects workers and communities that may lose employment in the current transition must be key concerns of our climate policy.”2 Additionally, the CLCPA recognizes that “setting clear standards for job quality and training standards encourages not only high-quality work but positive economic impacts.”3
Moreover, to further the goals of the CLCPA and the Accelerated Renewable Energy Growth and Community Benefit Act (Accelerated Renewables Act), the Commission should enact progressive procurement policies for all transmission projects including comprehensive labor standards covering construction, operations, and maintenance employment. These procurement standards will build on the success of recent offshore wind and other large-scale renewable solicitations and are essential to economic development and high-quality, timely completion of clean-energy projects in the State. CJNY proposes the following procurement policies:
● Project Labor Agreements (PLAs) and Community Workforce Agreements for All Construction
The Commission has successfully included PLA requirements for construction workers in its most recent Offshore Wind and large-scale renewables solicitations. These PLAs must cover all phases and locations of construction, including work at dedicated staging and layout areas that may be remote from the actual construction site.
The Commission should expand this proven policy to ensure that all projects that receive financial assistance of more than $100,000 or have a total value of more than $3 million require PLAs.
PLAs generate cost Savings, ensure timely, stable, and efficient project delivery, and provide unparalleled access to the highest quality skilled labor.
● Prevailing Wage (PW) Requirements for Construction and Maintenance Workers
The Commission has included prevailing wage requirements for construction workers in offshore wind and large-scale renewables solicitations.
The Commission should include prevailing wage requirements for all projects that receive financial assistance of more than $100,000 or have a total value of more than $3 million. All of these projects should be required to pay construction and maintenance workers the prevailing wage rate applicable to the classification.4 The transition from fossil fuel-based energy production to energy production based on renewable energy must not be the impetus for slashing living standards for workers.
● Apprenticeship and Labor-Management Training Partnership Utilization Requirement
The Commission should require all construction contractors and subcontractors on all projects, including those that participate in power purchase agreements, energy performance contracts, or other similar programs, to participate in state-approved apprenticeship programs in the trades in which they are performing work.
Apprenticeship utilization requirements ensure a skilled and safe workforce and provide increased employment opportunities for women, minorities, and members of disadvantaged communities. while the Offshore Wind Study is focused only on bulk transmission and assumes on-ramp transmission is created at POIs, “Local transmission upgrades needed for OSW may thus require additional investments on Long Island, such as LIPA’s proposal to convert part of the 138 kV system to 345 kV, and strengthening some of the underlying 69 kV systems, as presented in the Utility Study.”5 We will need to reimagine our local transmission and distribution infrastructure and this must not unduly burden particular host communities.
Regional coordination and planning are also necessary to mitigate curtailments, congestion, and constraints on the grid along with the associated costs to those inefficiencies. Transmission investment and upgrades are necessary statewide. Toward that end, cost allocation for bulk transmission and related on-ramp and significant distribution upgrades should be shared by ratepayers statewide. As the Commission has previously recognized, it is appropriate to share the investment costs of Clean Energy Standard (CES) aspects across the state to meet CLCPA goals. The Commission has demonstrated this approach for Offshore Wind Renewable Energy Credits, Zero Emission Credits, and Tier 4 Renewable Energy Credits. For example, This is reasonable as all New Yorkers benefit from a more sustainable, resilient, and cleaner energy infrastructure, and would be in accordance with CLCPA standards.
As more Wind Energy Areas (WEAs) are leased and auctioned in federal waters and Tier 4 projects are designated, it will be important to commission additional studies for cost-effective grid modernization. Thousands of megawatts of battery storage will need to be strategically integrated at key points of interconnection (POI), and the efficiency and cost-effectiveness of a meshed/backbone offshore grid will need to be thoughtfully analyzed and put into action. Storage and offshore wind backbone systems will increasingly become integral in creating resilience and enhancing the security of an energy system heavily relying upon intermittent renewables.
CJNY is an eager partner in making New York’s transition to a clean-energy economy successful, and updating the grid plays an essential role. We are committed to helping drive forward the required investments in energy transmission. And as we reimagine our energy infrastructure it is crucial that we prioritize working New Yorkers and New York’s most vulnerable communities by securing comprehensive labor standards for transmission projects. These smart procurement policies will create high-road jobs, promote a broad-based and equitable economic recovery, and ensure timely, quality completion of clean energy projects in New York.
1 Initial Report on the New York Power Grid Study, 21.
2 CLCPA Section 1(8). '
3 CLCPA Section 1(8).
4 Construction work associated with these projects are covered by prevailing wages established under Local Law § 220. Maintenance and building service work associated with these projects are covered by prevailing wages established under Labor Law § 230.
5 Initial Report on the NY Power Grid Study, 72.