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LL97 under-estimates value of local PV

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During the 2019 cooling season, 1 MW of local  distributed PV in New York City would have displaced 800 tons of CO2e -- by helping remove the  Brooklyn/Queens marginal baseload generator from NYISO SCUC each week.

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Marginal CO2e emission rates both reveal the opportunity and coordinate the necessary NYC capital and operating improvements.  Anything other than a marginal emission rate undervalues and misdirects investment in local PV, energy efficiency, energy storage and demand response.

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Removing generation from unit commitment each week requires coordinated action at scale -- a portfolio of local PV, energy efficiency, energy storage and demand response capable of displacing 100 to 400 MW of local generation. 

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How to read this graph?

1 MW of distributed PV located in Manhattan would have generated 660 MWh and displaced 800 tons of CO2e during the 2019 cooling season (June 10 to September 29).  Reference:  QCoefficient, Inc., December 2020. “An analysis of New York’s Summer 2019 fossil-fueled electric generation demonstrates that NYC commercial office buildings can dramatically reduce carbon emissions.

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LL97 specifies 660 MWh of credit against building load at an average emission rate of 0.000288962 tCO2e/kWh or 190 tons.  Reference: Section 28-320.3.1.1 of the NYC Administrative Code.

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For this example, the PV azimuth (230°) and tilt (25°) were selected to maximize PV production during ConEd distribution system summer peak hours.

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