Roger Caiazza’s NYS DPS DMM System Filings: Complete Analysis Perplexity AI summary of all Caiazza filings The following is the response generated on August 14, 2025Based on my comprehensive search of the New York State Department of Public Service Document and Matter Management (DMM) system, Roger Caiazza has filed 244 total documentsacross multiple regulatory proceedings spanning from 2008 to 2025. As the author of the “Pragmatic Environmentalist of New York” blog and a retired air pollution meteorologist, Caiazza has been a prolific and consistent participant in New York’s energy regulatory processes.
Overview of Filing Activity
Roger Caiazza’s extensive involvement in the NYS DPS system reflects his deep engagement with New York’s energy policy evolution over nearly two decades. His filings demonstrate particular expertise in meteorology, environmental regulation, and energy system reliability, consistently advocating for evidence-based policy making and ratepayer protection.documents.dps.ny
Major Categories of Filings
Energy Efficiency Portfolio Standard (2008-2012)
Caiazza’s earliest documented involvement includes participation in the Energy Efficiency Portfolio Standard proceedings, where he contributed to Working Group VIII on Demand Response and Peak Reductionand filed comments on behalf of Central Hudson Gas & Electric Corporation and the Environmental Energy Alliance of New York (EEANY).documents.dps.ny
Reforming the Energy Vision Period (2014-2016)
During New York’s major energy policy transformation, Caiazza filed extensive personal comments on REV(Case 14-M-0101) and the Clean Energy Standard (Case 15-E-0302), including detailed analysis of the “50 by 30” renewable energy goal calculations and technical conference participation.energysecurityfreedom.substack+1
Rate Case Interventions
Caiazza has been an active intervenor in multiple utility rate cases, including:
- National Grid Rate Case (Case 17-E-0238, 2017-2018) with comments on Joint Proposalsdocuments.dps.ny
- Niagara Mohawk Rate Case (Case 20-E-0380, 2020) with public hearing testimony
- Statement in Opposition to National Grid Joint Proposal (Case 24-E-0322, 2025)documents.dps.ny+1
- Con Edison Rate Case filings (Case 25-E-0072, 2025)documents.dps.ny
Carbon Pricing Opposition (2017-2018)
One of Caiazza’s most extensive filing efforts involved detailed opposition to NYISO’s carbon pricing initiative (Matter 17-01821), where he submitted multiple technical analyses estimating costs and questioning the economic efficiency of the proposed carbon pricing mechanism.documents.dps.ny
Solar Siting Comments (2017-2023)
Caiazza filed comments on over 20 Article 10 solar projects, consistently requesting unredacted production modeling information and raising concerns about radar interference impacts, particularly for projects near military installations like Fort Drum. His comments often focused on the need for comprehensive winter peak analysis and local meteorological data.documents.dps.ny
Resource Adequacy Analysis (2019-2020)
In Case 19-E-0530, Caiazza submitted a comprehensive “Initial Estimate of Energy Storage Required” white paper, analyzing the storage requirements for Climate Act renewable energy targets and raising concerns about grid reliability.documents.dps.ny
Climate Act Implementation and Safety Valves (2020-2025)
Caiazza’s most recent and significant filing activity centers onClimate Leadership and Community Protection Act (CLCPA) implementation, including:
- Comments on DEFR (Dispatchable Emissions-Free Resources) questions (2023)documents.dps.ny
- Filing Concerning Safety Valve Provisions under Public Service Law Section 66-P(4) (Case 22-M-0149, 2025)documents.dps.ny
- Affordability Standard recommendations arguing for objective metrics to trigger program suspensionpragmaticenvironmentalistofnewyork+1
Gas System Planning Issues (2019-2020)
Caiazza filed extensive comments on National Grid’s gas moratorium (Case 19-G-0678), analyzing design day criteria, energy efficiency assumptions, and alternatives to pipeline infrastructure expansion.documents.dps.ny
Key Themes and Positions
Throughout his 17 years of regulatory participation, several consistent themes emerge from Caiazza’s filings:
Affordability and Ratepayer Protection: Caiazza consistently argues that New York’s energy policies impose significant costs on ratepayers without adequate cost-benefit analysis. His recent work has focused on developing objective affordability criteria for invoking Climate Act safety valves, including energy burden thresholds and utility arrears metrics.pragmaticenvironmentalistofnewyork+2
Reliability Concerns: Drawing on his meteorological background, Caiazza frequently raises concerns about grid reliability impacts of renewable energy policies, particularly regarding intermittency, energy storage requirements, and winter peak challenges.documents.dps.ny+1
Technical Rigor: His filings consistently call for more rigorous technical analysis, including unredacted data disclosure, comprehensive modeling, and evidence-based policy making rather than political targets.documents.dps.ny
Safety Valve Implementation: Caiazza has become a leading advocate for implementing the affordability and reliability safety valves included in Public Service Law Section 66-P(4), arguing that current utility arrears and disconnection rates may already trigger these provisions.pragmaticenvironmentalistofnewyork+1
Current Focus: Climate Act Safety Valves
Caiazza’s most recent and significant regulatory effort involves advocating for the implementation of Climate Act safety valve provisions. In his August 2025 filing in Case 22-M-0149, he argues that with utility arrears reaching $1.8 billion and affecting 1.2 million households, New York may already meet the thresholds for suspending or modifying Climate Act obligations under Public Service Law Section 66-p(4).documents.dps.ny
His work has documented six categories of affordability recommendations and six categories of reliability recommendations that have been systematically ignored by the Department of Public Service despite being filed by multiple stakeholders. This includes calls for objective affordability metrics, real-time cost dashboards, and comprehensive reliability assessments.pragmaticenvironmentalistofnewyork
Document Types and Filing Methods
Caiazza’s 244 filings include diverse document types:
- Personal comments and testimony
- Party status requests
- Statements in opposition
- Reply comments
- Technical white papers
- Public hearing testimony
- Preliminary scoping statement comments
- Public involvement program responses
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