September 14, 2021

ESA Submits Comments on NYISO’s Capacity Accreditation Straw Proposal

ESA submitted comments today on NYISO’s straw proposal to implement a revised capacity accreditation study process to determine the incremental reliability contribution of all capacity resource types, including standalone and hybrid storage resources, in order to establish and update capacity values and duration adjustment factors.

In our comments, we express support for NYISO’s proposal to evaluate all resource types to determine whether they should be subject to this study. ESA also supports NYISO’s proposal to use an Installed Reserve Margin approach for the study base but recommends improving upon deficiencies of the IRM approach by addressing risks of correlated outages associated with extreme weather to ensure that outcomes are just and reasonable.

Additionally, we request flexibility in the modeling approach used each time a capacity accreditation study is performed, as well as more information on the benefits and tradeoffs between a marginal approach versus an average approach in capacity accreditation. We note PJM has recently implemented an average value approach, which avoids undervaluing the resource adequacy contribution of individual energy storage and hybrid storage projects


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