Climate Act Ratepayer Cost Scorecard

The Scoping Plan documentation does not include any estimates of ratepayer costs.  This scorecard is intended to provide some of that information.  It lists costs from various Department of Public Service rulemakings that I have discovered.  It is not comprehensive and any input from readers who are following rulemakings that list ratepayer impacts would be appreciated.  Please refer to the caveat section for additional information.


Cost documentation in these proceedings is not transparent and what is provided is misleading.  The energy storage deployment roadmap replicates the Scoping Plan shell game con for hiding the true costs.  In the Scoping Plan costs are compared to a Reference Case that includes already “incremented programs” and in this Roadmap costs are presented relative to “incremental revenues” as documented below.  In both instances the result is a deceptive cost estimate that does not include all the costs for the citizens of New York.  It appears that the Hochul Administration goal is hide the expenditure of hundreds of billions of dollars under hundreds of programs and subsidies making it intentionally impossible to capture the total costs to consumers.  The true “Total Cost” of the Climate Act will be hidden forever from the public by design. 

New York’s 6 GW Energy Storage Roadmap Appendix B: Storage Program Cost Analysis

This Appendix “summarizes the inputs, assumptions, and analysis methodology underpinning the estimates of incremental program costs associated with achieving the proposed 2030 target of 6 GW of short-duration storage”.   The Roadmap states:

The total cost of these proposed procurement programs is estimated at between $1.0 billion and $1.7 billion. This equates to an estimated increase in customer electric bills of 0.32% – 0.54% (or $0.34 – $0.58 per month for the average residential customer) on average across New York for the 22-year period during which these programs would make payments to awarded projects. The range of these projections reflects future uncertainties, most notably those associated with energy and capacity prices.

The way this is written it suggests that the energy storage costs will be manageable because it will only be at most $0.58 per month.  However, Appendix B states:

For the proposed bulk storage procurement program, program costs are calculated as the incremental revenue, on top of revenue that storage assets can realize through commercial operation in the existing energy markets, that would allow such assets to reach their cost of capital. This methodology is broadly consistent with that applied to cost studies under the Clean Energy Standard.66 Key assumptions and inputs include the costs of storage projects, the estimates of market revenue available to them, available federal incentives and the cost of capital.

This approach is disingenuous at best.  They are not providing all the program costs only the costs above what they think an energy storage owner will have above the expected “incremental” revenue.  That incremental revenue has to be paid by someone and that someone is the ratepayers of the state.  As I understand it the “incremental revenues” are composed of at least the subsidies that are being proposed for energy storage that are like renewable energy credits.  Those subsidies are not paid for in the NYISO’s wholesale energy market but are buried in utility rate cases.  Moreover, it is not clear if the Roadmap includes energy storage specific wholesale energy market payments as other “incremental” revenue.  In any event, the insinuation that the energy storage cost is only going to be “between $1.0 billion and $1.7 billion” is clearly misleading and inaccurate.