On July 14, 2025, the Flex Coalition submitted comments in the NY Grid of the Future Docket, 24-E-0165. The comments highlight how the Grid of the Future Initiative can unlock the full potential of grid flexibility by instituting best practices across planning, deployment, dispatch, and settlement functions, including through the adoption of a demand flexibility tariff to align utility, customer, market participant, and ratepayer interests in a common, easy to navigate framework.
Key points include:
- Prior DSIPs assessed demand flexibility integration on a technology by technology basis, instead of structuring around delivered flexibility benefits in a technology-agnostic way. While this is understandable given the different capabilities and limitations of DER technologies, the current state of the industry now allows aggregators to build portfolios behind- and at-the-meter to respond to grid needs.
- To enable a functioning market, the DPS will need to establish frameworks for participant compensation based on performance against fulfilling those needs (i.e. capacity, power quality, etc.). The proposed DSP framework described in chapter 4 of the Plan provides a detailed analysis of the various pillars, enablers, capabilities, and functions necessary to transition to integrated and technology-neutral grid solutions.
- To ensure clarity for market actors, the DPS will need to implement clear, understandable guidance and structures – such as the flexible demand tariff described below – to provide transparency to the market and streamline the DSP framework. Innovation at the grid edge is happening in jurisdictions across the country, but often in isolation, with unique design approaches, system and DER requirements, and jargon.
- While different States and utility service territories have different DER resource capabilities and customer requirements, there is much opportunity for reducing friction and confusion in the stakeholder and solution provider ecosystem by building consensus around common approaches. These include the adoption of the National Standard Practice Manual for DER valuation and building standard data security requirements across the US. The PSC should continue collaboration with other States in order to develop common frameworks to eliminate friction and facilitate transfer of emerging best practices.
The full comments are available here.