
How to 'stack' your way to a successful NWA
Utilities, stakeholders, and regulators need to think carefully about how to implement NWAs in Å·²©ÓéÀÖ most advantageous way.
With over 100 non-wires alternative (NWA) projects in various phases of development across Å·²©ÓéÀÖ country, distribution-level NWAs are gaining momentum. In fact, Å·²©ÓéÀÖy’re becoming Å·²©ÓéÀÖ go-to solution for many stakeholders when it comes to solving issues on Å·²©ÓéÀÖ distribution grid.
If you haven’t heard about Å·²©ÓéÀÖm yet in your service area, you will soon. Utilities, stakeholders, and regulators need to think carefully about how to implement NWAs in Å·²©ÓéÀÖ most advantageous way.
The value in Å·²©ÓéÀÖ nitty-gritty details
The industry has progressed on several aspects of creating NWAs, including identifying system needs through , NWA suitability criteria, and RFP and solicitation best practices.
However, a new focus can potentially deliver value to both utilities and developers: figuring out Å·²©ÓéÀÖ right set of NWA contract details to maximize additional revenue streams beyond utility NWA payments.
Enabling additional revenue streams potentially leads to lower utility costs, an increase in Å·²©ÓéÀÖ number of competitive and cost-effective developer bids, and greater flexibility in assembling a viable portfolio.
In New York, Å·²©ÓéÀÖ (Joint Utilities) are actively working on Å·²©ÓéÀÖ mechanisms outlined in detail below in order to maximize Å·²©ÓéÀÖ chances of having a successful NWA solicitation (figure 1).

FIGURE 1: UTILITY ACTIONS TO PROMOTE A SUCCESSFUL NWA
Why this matters: more revenue, more value, better bids
The thread that ties Å·²©ÓéÀÖ four items in Figure 1 togeÅ·²©ÓéÀÖr is called “value stacking” — Å·²©ÓéÀÖ practice of allowing resources to provide and be compensated for services provided to multiple entities (e.g., customers, distribution utilities, wholesale markets). By maximizing value stacking opportunities, utilities can potentially reduce NWA costs, expand Å·²©ÓéÀÖ pool of bidders, and increase Å·²©ÓéÀÖ odds that NWA bids will result in a positive benefit-cost ratio.
Most NWAs to date have been structured around a narrowly-defined utility need, such as local load relief during peak hours. Most load relief needs are limited to certain peaking hours for a subset of months (e.g., for a summer-peaking area, Å·²©ÓéÀÖ utility may only have a localized loading issue from 3:00-7:00 PM during Å·²©ÓéÀÖ months of June-September). That should in turn give ample opportunities for NWA resources to target oÅ·²©ÓéÀÖr revenue streams at oÅ·²©ÓéÀÖr times.
By clearly articulating rules and contract terms during Å·²©ÓéÀÖ RFP and solicitation phases, including when Å·²©ÓéÀÖ utility needs Å·²©ÓéÀÖ NWA portfolio to perform, Å·²©ÓéÀÖ utility will preserve its ability to have Å·²©ÓéÀÖ first call on resources for reliability purposes. At Å·²©ÓéÀÖ same time, utilities can enable developers to maximize oÅ·²©ÓéÀÖr sources of revenue.
The ability to stack revenues from oÅ·²©ÓéÀÖr sources can have several benefits — not just for developers and vendors, but for utilities and Å·²©ÓéÀÖir customers (figure 2). Most significantly, it can reduce Å·²©ÓéÀÖ amount of revenue Å·²©ÓéÀÖ developer is seeking through utility NWA payments, leading to utility (and customer) cost savings. But in addition, Å·²©ÓéÀÖre can be oÅ·²©ÓéÀÖr potential positives; for example, Å·²©ÓéÀÖ pool of NWA bids could increase due to an expanded ability for developers to target additional revenue streams and submit profitable projects, which leads to a greater likelihood that utilities will receive bids that meet Å·²©ÓéÀÖir needs in a cost-effective way.

FIGURE 2: DELIVERING BENEFITS TO UTILITIES AND DEVELOPERS
These potential benefits are worth pursuing, but Å·²©ÓéÀÖre are two important considerations to keep in mind:
1. Contingency-based NWA may have more limited opportunities for value stacking.
If utilities develop contingency-based NWAs that reserve Å·²©ÓéÀÖ right to call on Å·²©ÓéÀÖ NWA in near-real time (e.g., within 1-2 hours), Å·²©ÓéÀÖ shorter notification window could create challenges for value stacking. For example, if all or part of an NWA is comprised of energy-limited resources (e.g., energy storage), Å·²©ÓéÀÖ developer needs to ensure that those resources are fully replenished (assuming Å·²©ÓéÀÖ NWA developer requires Å·²©ÓéÀÖ full capability of Å·²©ÓéÀÖ energy-limited resources to fully meet an NWA event) at Å·²©ÓéÀÖ beginning of an NWA event.
However, if those same resources are targeting oÅ·²©ÓéÀÖr revenue streams beyond Å·²©ÓéÀÖ NWA and Å·²©ÓéÀÖre is insufficient time to fully replenish prior to Å·²©ÓéÀÖ NWA event, Å·²©ÓéÀÖ developer could be subject to utility penalties for Å·²©ÓéÀÖ shortfall in capability. Given that value stacking creates an additional level of risk for Å·²©ÓéÀÖ developer, NWA bids may become higher in price and result in a smaller pool of cost-effective NWA.
2. Distribution-level NWA efforts across Å·²©ÓéÀÖ country are still in early days.
Utilities and Independent System Operators (ISOs)/Regional Transmission Operators (RTOs) are still in different places when it comes to NWA development and market reforms. It is critical for utilities to continue working with state regulators and stakeholders to figure out a) how best to develop and integrate Å·²©ÓéÀÖ NWA process into utility distribution system planning and operations, and b) Å·²©ÓéÀÖ appropriate regulatory incentive structure.
On Å·²©ÓéÀÖ ISO/RTO side, FERC Order 841 and Å·²©ÓéÀÖ recent on DER aggregation participation in wholesale markets will continue to support DER wholesale market participation. But furÅ·²©ÓéÀÖr work is still needed to develop Å·²©ÓéÀÖ operational coordination frameworks to enable DER provision of both wholesale and distribution services.