New York State Reliability Council Draft Scoping Plan Comments

The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050 and the comment period for the Draft Scoping Plan that outlines how to meet that goal recently ended.  Here I describe comments submitted by New York State Reliability Council.  This is another instance in which the experts are not explicitly saying this is nuts but a little bit of reading between the lines indicates that they believe the proposed Climate Act transition will end badly.

Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies.  I submitted comments on the Plan and have written extensively on implementation of New York’s response to that risk because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that it will adversely affect reliability, impact affordability, risk safety, affect lifestyles, and will have worse impacts on the environment than the purported effects of climate change in New York.  New York’s Greenhouse Gas (GHG) emissions are less than one half one percent of global emissions and since 1990 global GHG emissions have increased by more than one half a percent per year.  Moreover, the reductions cannot measurably affect global warming when implemented.   The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Climate Act Background

The Climate Act establishes a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council.  Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that tried to quantify the impact of the strategies.  That material was used to write a Draft Scoping Plan that was released for public comment at the end of 2021. The Climate Action Council states that it will revise the Draft Scoping Plan based on comments and other expert input in 2022 with the goal to finalize the Scoping Plan by the end of the year.

New York State Reliability Council

The New York State Reliability Council (NYSRC) is the other organization that has reliability responsibilities in New York.  According to their Draft Scoping Plan comments:

The NYSRC was established to promote and preserve the reliability of the New York State Power System by developing, maintaining and, from time to time, updating the reliability rules (“Reliability Rules”) that govern the NYISO’s operation of the state’s bulk power system. The NYSRC develops Reliability Rules in accordance with standards, criteria and regulations of North American Reliability Corporation (“NERC”), Northeast Power Coordinating Council (“NPCC”), FERC, the Commission, and the Nuclear Regulatory Commission  The NYISO/NYSRC Agreement provides that the NYISO and all entities engaged in transactions on the New York State power system must comply with the Reliability Rules adopted by the NYSRC.  The NYSRC Reliability Rules have been adopted by the New York State’s Public Service Commission under its Public Service Law authority prescribing reliability rules necessary to ensure safe and adequate service.

Installed Reserve Margin

The standard for the required generating capacity relative to the expected load is called the Installed Reserve Margin.  The NYSRC comments on the Draft Scoping Plan defined the standard and talked about the expected changes in what is required now and what is expected in the future:

One of the major responsibilities of the NYSRC is to set the annual Installed Reserve Margin (IRM) for the New York Power System. The IRM is the reserve resource capacity over and above that required to meet peak load and is needed to maintain minimum levels of reliability in New York. This is necessary based on the recognition that the availability of generation resources may be limited by forced outages or loss of fuel supply, including periods with little to no sun or wind. Typical unavailability figures for fossil fueled generation in New York is in the order of ~15% (~85% availability) largely based on forced outage performance.

NYSRC determined that the IRM for the 2022 – 2023 capability year is 19.6% and that IRM was adopted by the New York Public Service Commission for the New York Control Area on March 16, 2022 (Case 07-E-0088).

The table shows the increase in required reserve capacity from 22,577 MW (78.15% IRM) in 2025 to 102,517 MW (205.94% IRM) in 2050. These numbers need to be pondered in perspective. To supply a forecasted peak load of 49,780 MW in 2050, 152,297 MW of capacity will be needed, roughly 3 times the peak load at that time. The corresponding numbers for 2030 are that for a peak load of 29,640 MW, a capacity of 68,244 MW is needed, more than twice as much. Given that the 2020 installed capacity is 44,023 MW, around 22,000 MW of additional capacity must be built in the next 7-8 years.

NYSRC Comments

The NYSRC comments included an illustration of the magnitude of future resource requirements based on the Draft Scoping Plan for Scenario 3, Annex 2.  The following table shows the amount and type of installed capacity required to meet Climate Act goals and meet NYSRC’s resource adequacy reliability criterion of 1-day-in-10-years. The text in red was added to demonstrate the total installed capacity, the peak load, the required reserve capacity and the IRM for the years 2025 through 2050.

The comments describe the ramifications of these results:

The table shows the increase in required reserve capacity from 22,577 MW (78.15% IRM) in 2025 to 102,517 MW (205.94% IRM) in 2050. These numbers need to be pondered in perspective. To supply a forecasted peak load of 49,780 MW in 2050, 152,297 MW of capacity will be needed, roughly 3 times the peak load at that time. The corresponding numbers for 2030 are that for a peak load of 29,640 MW, a capacity of 68,244 MW is needed, more than twice as much. Given that the 2020 installed capacity is 44,023 MW, around 22,000 MW of additional capacity must be built in the next 7-8 years. 

The analysis makes a couple of assumptions:

The table assumes that intermittent generation capacity from wind and solar resources increases from 13,319 MW in 2025 to 96,629 MW in 2050.

The table also assumes that the magnitude of new technology requirements for Zero-Carbon Firm Resource (RNG, green hydrogen or other) increases from 5,489 MW in 2035 to 25,359 MW in 2050. Long-Term Battery Storage or other increases from 1,500 MW in 2025 to 19,212 MW in 2050. None of these technologies presently exist commercially for utility scale application.

It is politically impossible for these experts to explain that not only do these technologies not exist commercially but there are physical limitations that suggest that a commercially viable and affordable resource like this may never be developed.  The reality is that this is not just a stretch, it is a massive leap in technology.

The NYSRC comments go on to explain that there are other implementation factors that complicate the transition that the Draft Scoping Plan cavalierly claims will happen because of political will:

Some of the new renewable resources will be located behind the meter at retail levels (i.e.. solar PV, batteries, and EV charging). This will also require investment in distribution system automation to protect reliability, cyber-security and public safety. The role of the Distribution System Operator will become even more critical in this complex operating environment.

I think that the observation that the logistics of building the infrastructure necessary to meet the Climate Act goals is particularly important:

The amount of new generation that needs to be built to maintain system reliability in a zero-carbon environment is sobering. This change represents an unprecedented increase in capital investment in resource capacity along with a corresponding increase in transmission and distribution capacity. Further, this transition must be managed during a time of high inflation, and supply chain delays, permitting challenges, and high demand for renewable resource equipment, not just in New York, but around the globe.

There is another technical issue.  My comments on the electric system transition pointed out that it is not clear if the Draft Scoping Plan considered ancillary services.  The NYSRC comments explain:

One other aspect that must be kept in mind is that renewables and storage devices work internally with direct current (DC) and must ultimately be interconnected to a grid that works with alternating current (AC). To accomplish this, devices called inverters that transform DC into AC and vice versa are used. These inverter-based resources (IBR) are starting to be used in increasing numbers in the USA and it is becoming clear through actual reliability impact events that more work is still necessary with respect to the reliability of IBRs, and standards need to be adopted for a reliable transition.

I found no mention of this issue in the Draft Scoping Plan spreadsheets of inverter costs.  Finally, it is telling that the NYSRC notes that there will be a learning curve for operating a system based on intermittent and diffuse renewables. 

Furthermore, even if we build all this capacity on time, operating a system largely based on renewable resources is not the same as operating the system of today. The performance and responsiveness of existing generation must be emulated to keep the lights on. We have no experience in operating a bulk power system that we will need to operate by 2030 and beyond.

The fact is that New York’s current stringent reliability rules are based on hard learned experience.  It is incredibly optimistic to think that the system will make the transition without unanticipated issues that result in blackouts.

NYSRC Recommendations

One of the things that I think is most important is a feasibility study.  As a result, I was hearted by the NYSRC recommendation that “the proposed Climate Action Council strategy be reviewed for application in the short-term based upon practical considerations for the period 2025 to 2030”.  The NYSRC comments list the rationale for this review:

Practical considerations affecting the availability, schedule and operability for new interconnections include: interconnection standards; site availability; permitting; resource equipment availability; regulatory approval; large volume of projects in NYISO queue and study process; scalability of long-term battery storage and other technologies; operational control; impact of extreme weather; consideration of a must run reliability need for legacy resources. In addition, the pace of transportation and building electrification, the timing of any natural gas phase-out and their impact on the electric T&D system must also be carefully studied from technical, economic and environmental perspectives. Together, these practical considerations require the development of reliable zero emission resources to be conscientiously sequenced and timed in the near term (through 2030) to ensure broader GHG reductions in all sectors beyond 2030.

It is noted that delaying or changing a CLCPA goal would be preferable to the risk of a wide scale blackout and associated public safety concerns if it should ever appear that the implementation of the CLCPA’s goals may pose a significant risk to electric system reliability, including the potential risk of a system-wide blackout,

In conclusion, there are many unknowns in the transition to CLCPA’s goals. The risks of not reaching a goal in the time required is real. The CAC and all participants in the transition to an emissions free grid need to stay alert to the critical importance of keeping the system functioning within reliability criteria. Each time that an existing unit must retire or stop operating through some regulatory action, there is a need to confirm that reliability criteria will still be met without that unit.


I have written several articles pointing out that the Climate Action Council is not listening to the experts.  The first post (New York Climate Act: Is Anyone Listening to the Experts?) described the NYISO 2021-2030 Comprehensive Reliability Plan (CRP) report (appendices) released late last year.  The difficulties raised in the report are so large that I raised the question whether any leader in New York was listening to this expert opinion.  The second post (New York Climate Act: What the Experts are Saying Now) highlighted results shown in a draft presentation for the 2021-2040 System & Resource Outlook that all but admitted meeting the net-zero goals of the Climate Act are impossible on the mandated schedule.  Finally, I described the “For discussion purposes only” draft of the 2021-2040 System & Resource Outlook report described in the previous article.  This report highlights multiple feasibility concerns that must be addressed to have any hope of this working, shows that implementation on the schedule proposed will be very difficult and highlights the need for implementation planning. 

The NYSRC comments reiterate all the points mad by the NYISO, The organizations responsible for the relatability of the New York electric grid have raised numerous technological issues that must be addressed going forward for the transition.  Unfortunately, the loudest voices on the Climate Action Council have said that anyone saying there are issues related to using renewable resources are misinforming the public and no leaders on the Council have spoken up to reign in those statements.  If Climate Act implementation to net-zero does not address the issues raised then blackouts are inevitable.

Author: rogercaiazza

I am a meteorologist (BS and MS degrees), was certified as a consulting meteorologist and have worked in the air quality industry for over 40 years. I author two blogs. Environmental staff in any industry have to be pragmatic balancing risks and benefits and ( reflects that outlook. The second blog addresses the New York State Reforming the Energy Vision initiative ( Any of my comments on the web or posts on my blogs are my opinion only. In no way do they reflect the position of any of my past employers or any company I was associated with.

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