Policy & Regulation

Con Edison Proposed NYC Reliability Contingency Plan

Con Edison filed a market‑focused plan seeking UDR extension and a new RADR program to meet Zone J needs beginning 2033.

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Executive summary

Consolidated Edison Company of New York, Inc. filed a New York City Reliability Contingency Plan on July 17, 2026 that proposed a predominantly market‑based portfolio to address updated Zone J transmission security needs. The Company reported modeled needs beginning in 2033 at 125 MW, growing to 675 MW by 2036, and requested two regulatory changes to implement its approach: (1) an extension of the UDR bulk storage in‑service deadline to December 31, 2036, and (2) approval of a new Reliability Asset Dispatch Rights (RADR) program to transition eligible distribution‑connected VDER storage into 15‑year utility dispatch contracts with prioritized interconnection and cost reimbursements.

The filing emphasized competitive solicitations, consultation with DPS Staff, and a biannual reporting/halting framework for Commission review. Con Edison reported it had issued an RFI that produced 71 responses, developed screening and modeling (with third‑party technical support from EPRI), and proposed a technology‑agnostic RFP for mature firm non‑emitting solutions alongside a transmission ratings enhancement project that could provide up to roughly 300 MW incremental transfer capability into Zone J as a backup.

What Con Edison proposed and why it mattered

The Company framed the Plan around three principal procurement tracks:

  • Transmission‑connected battery storage procured via the existing UDR framework (hence the requested in‑service extension).
  • A new RADR program to bring eligible distribution‑connected storage into utility dispatch contracts for reliability use.
  • A technology‑agnostic RFP to capture mature, firm non‑emitting solutions beyond batteries.

Con Edison argued the portfolio was the most deployable and CLCPA‑consistent set of options available within the identified timeframe, while acknowledging that storage was energy‑limited and that additional generation would ultimately be required if system conditions changed.

RADR program: mechanics and costs

The filing described the RADR structure in detail. Key program features included:

  • Transition of eligible distribution‑connected VDER storage into 15‑year utility dispatch contracts.
  • Prioritized interconnection for RADR‑eligible projects.
  • Reimbursement of charging costs and eligible interconnection costs.
  • Recovery of non‑capital RADR costs as a 15‑year regulatory asset.

Con Edison provided program cost estimates: an initiation cost of approximately $5.0 million, ongoing fixed program costs of roughly $7 million per year, plus an additional $1 million per 50 MW per year to scale with procurement. The Company also reported very wide, non‑binding cost ranges from the RFI — $100,000/MW to $21.9 million/MW — and emphasized that competitive solicitations and DPS Staff consultation (including confidential price ceilings) would be used to refine and bound final procurement prices.

Modeling, RFI outcomes, and backup options

Con Edison reported it had evaluated 71 RFI responses, employed screening and down‑selection criteria, and used external technical support for modeling. The Company concluded that its proposed portfolio could meet identified needs through 2036 subject to the assumption that existing generation remained available. The Plan included a proposed transmission equipment ratings enhancement (cooling/refrigeration) project that could provide up to ~300 MW of additional transfer capability into Zone J as a backup contingency.

Stakeholder positions and docket context

The filing sat against an active docket record and competing stakeholder views:

  • Con Edison’s contemporaneous cover letter reiterated that its plan responded to PSC direction and NYISO‑identified reliability risks and noted an updated analysis showing a near‑term shortfall that was smaller and later than earlier projections, but nonetheless material within the ten‑year planning horizon.
  • The Company had previously opposed petitions from NY‑BEST and NYSEIA seeking interconnection‑practice changes, arguing such proposals would shift substantial infrastructure costs onto utility customers and risk reliability by undermining Con Edison’s two‑part reliability test.
  • Clean energy and environmental groups (including Alliance for Clean Energy NY, Earthjustice, NRDC, NY‑BEST, Sierra Club) had argued elsewhere in the docket that CLCPA‑compliant clean resources — including storage — could meet reliability gaps without fossil resources, illustrating a policy tension over resource type and cost allocation.

Key tensions and uncertainties the filing highlighted

  • Cost uncertainty was pronounced: RFI non‑binding prices ranged from $100k/MW to $21.9M/MW, placing a premium on competitive solicitations and confidential price ceilings to constrain exposures to customers.
  • The Company’s modeling reliance on the continued availability of existing generation meant the portfolio’s adequacy was conditional rather than absolute.
  • Interconnection cost allocation and study methodology remained contested, reflected in Con Edison’s opposition to petitions that sought to change interconnection evaluation practices, a dispute that bore directly on how distributed solutions would be deployed and paid for.
  • Storage’s energy limitation was an explicit constraint the Company flagged, reinforcing that market‑based storage procurements were a bridge solution rather than a permanent substitute for firm generation.

Significance in the docket

At the time of filing, Con Edison’s Reliability Contingency Plan represented the utility’s formal, operational proposal to implement the PSC’s December 2025 direction to address NYC reliability risks. It combined near‑term, market‑based procurement pathways (UDR and a new RADR mechanism), planning for a technology‑agnostic RFP, and an engineering backup (transmission ratings enhancement). The filing set clear procurement and regulatory requests — a UDR in‑service deadline extension and Commission approval of the RADR program — and framed the regulatory tradeoffs that remained central in the docket: cost allocation, interconnection practice, the role of storage versus firm generation, and how to protect customers while procuring reliability in a CLCPA‑aligned manner.