On October 13, 2025 the New York Independent System Operator (NYISO) released its quarterly assessment of reliability of the bulk electric system. I recently published an overview of the report that mentioned I was uncomfortable about some aspects of the recommendations. This post describes the unique reliability rules for New York City that I think were not fully addressed relative to the replacement of New York City (NYC) peaker units.
I am convinced that implementation of the Climate Act net-zero mandates will do more harm than good because of reliability and affordability risks. I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written nearly 600 articles about New York’s net-zero transition. The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.
STAR Report and New York City
The NYISO 2025 Quarter 3 Short-Term Assessment of Reliability (STAR report) was released on October 13, 2025. If you want background information about the report I refer you to my take and what Richard Ellenbogen had to say.
Environmental Justice organizations have made peaking power plants in New York City into an overblown issue, insisting that all peaking power plants must be shut down as soon as possible. Even though the presumption of egregious harm from these plants is based on selective choice of metrics, poor understanding of air quality health impacts, and ignorance of air quality trends, pressure by this special interest constituency resulted in the Build Public Renewables Act of 2023 (BPRA) that mandates shutdown of New York Power Authority peaking power plants by 2030. The NYPA units are state of the art, highly efficient, extremely low emissions, and only 27 years old.
The STAR report findings of interest for this post relate to two old, inefficient, and high emitting peaking turbine facilities that were supposed to be retired earlier based on a Department of Environmental Conservation (DEC) rule if the shutdown did not threaten reliability. The STAR report explains:
In this 2025 Quarter 3 STAR, the Gowanus Gas Turbine 2-1 through 2-8, Gowanus Gas Turbine 3-1 through 3-8, Narrows Gas Turbine 1-1 through 1-8 and Narrows Gas Turbine 2-1 through 2-8 units (collectively “Gowanus and Narrows”) have completed their generator deactivation notices and are now all Initiating Generators, requiring the NYISO and Con Edison to evaluate in this STAR if there are any Generator Deactivation Reliability Needs.
The STAR report identified a short-term reliability need beginning in summer 2025 within New York City primarily driven by a combination of forecasted increases in peak demand and the assumed unavailability of certain generation in New York City affected by the DEC regulation to limit emissions of nitrogen oxides, known as the “DEC Peaker Rule”. The report states:
In accordance with the DEC Peaker Rule, the Gowanus and Narrows generators may extend operation for up to an additional two years (until May 1, 2029) if the NYISO or Con Edison determine that the reliability need still exists and a permanent solution has been identified and is in the process of construction but not yet online. The DEC Peaker Rule, however, does not provide for peaker generators to continue operating after this date without meeting the emissions requirements.
This STAR report concluded these facilities are needed until Bulk Power Transmission Facilities (BPTF) can replace them.
NYC Reliability Rules
Before discussing the Bulk Power Transmission Facilities (BPTF) solution it is necessary to understand the unique reliability rules in NYC. I acknowledge the use of Perplexity AI to generate a summary of these rules. The reason for these rules is that NYC is a load pocket and within the City there are areas that are also considered load pockets. To keep the lights on the following rules have been implemented:
- Locational Capacity Requirements Framework – This rule establishes a minimum amount of capacity relative to the expected peak load.
- Reliability Rule G.1: New York City System Operations – This rule includes a set of more stringent requirements than used in the rest of the state.
- Reliability Rule G.2: Loss of Gas Supply – New York City – This rule requires the system to be operated so that the loss of a single gas facility does not cause a blackout. To meet this rule gas-fired units in the City must be able to burn liquid fuel.
STAR Solutions
This STAR report concluded that the Gowanus and Narrows facilities are needed until BPTF can replace them. A BPTF is basically all the components of the transmission system (lines, transformers, and control systems) needed to move large amounts of electricity to where it is needed.
Consistent with the findings in 2023, this STAR continues to find that the New York City locality (Zone J) would be deficient in the summer through the entire five-year horizon without the completion and energization of future planned projects. This includes deficiencies on the BPTF and non-BPTF within Zone J.
Keep in mind that these facilities are needed to provide power during system peak loads. There are four future BPTF projects described as components of the solution.
Gowanus-Greenwood 345/138 kV feeder – This project will upgrade the electric grid to resolve a local problem in NYC. I do not see any issues with this project.
Champlain Hudson Power Express, 1,250 MW HVDC – This project brings hydropower from Quebec through a dedicated transmission line to NYC. When it first was proposed the peak loads were in the summer. The contract does not guarantee power from Hydro Quebec if it is needed within the province. In the future of the Climate Act, peak loads will shift to the winter when New York winter peak loads increase due to heating electrification. Because this is when Quebec peak loads occur there is a high probability that power will not be available when NYC needs it. I am not sure how the reliability rules will handle that contingency.
Empire Wind, 816 MW offshore wind – According to Perplexity AI, this project is “under active construction and approximately 40% complete as of fall 2025. The project is progressing toward its targeted commercial operation date of 2027.” Summer peak loads occur during heat waves and the meteorological conditions that favor the warmest temperatures are high pressure systems that cause light winds. Those conditions will undoubtedly reduce offshore wind output. Without sufficient storage this facility will not provide anywhere near 816 MW of power when it is needed most.
Propel NY Public Policy Transmission Project According to Perplexity AI, is a major electric transmission infrastructure initiative developed jointly by the New York Power Authority (NYPA) and New York Transco LLC to strengthen the electric grid and enable greater renewable energy delivery across southeastern New York State. The infrastructure creates transmission capacity to deliver at least 3,000 megawatts (MW) of offshore wind energy from Long Island into the broader New York grid, This has the same limitation as the Empire Wind project. Without storage it will not provide energy when needed most. In addition, there are issues associated with additional offshore wind development that suggest that 3,000 MW of offshore wind is unlikely.
The STAR report explains that these projects could address the identified reliability needs. Note however that there is a caveat that these projects must “demonstrate their planned power capabilities before the Gowanus and Narrows generating stations can be retired.” Even then the STAR report mentions potential issues:
The range in the demand forecast for expected weather is driven by key assumptions, such as
population and economic growth, energy efficiency, the installation of behind-the-meter renewable energy resources, and electric vehicle adoption and charging patterns.
Once CHPE, Empire Wind, and the Propel NY Public Policy Transmission Project enter service and demonstrate their planned power capabilities, the margins improve substantially assuming all existing generators remain available, but gradually erode as forecasted demand for electricity grows. Even with the future planned projects delivering power according to schedule, there remains a risk of a Zone J deficiency in summer 2029, following the deactivation of Gowanus and Narrows, assuming all other generators in Zone J are available.
In my overview article on the STAR report I noted that there were issues associated with timing issues associated with the DEC Peaker Rule retirement deadline of May 1, 2029. In my opinion,I think it is unlikely that in-kind replacements will be available by the May 1, 2029 deadline and that means the regulation must be modified.
The Build Public Renewables Act of 2023 compounds the problem requiring retirement of New York Power Authority (NYPA) peaking plants. The STAR report notes that “Beyond 2030, these deficiencies are further exacerbated with increasing demand for electricity and the planned deactivation of the NYPA small plants.”
Discussion
Although NYISO has become increasingly more vocal about the challenges meeting peaking load in the absence of natural gas peaker generating units, I am uncomfortable with the proposed BPTF projects proposed to solve the Gowanus and Narrows energy shortfall.
The primary reason for the unique NYC reliability rules is experience with blackouts. For example, the NYC blackout of July 1977 occurred when a storm knocked out transmission lines coming into the city and there was insufficient in-city generation to keep the system going. Reliability Rule G.1 includes provisions for special operating rules during severe weather, enhanced operating reserves, and operating the system for a more stringent shutdown contingency that address the problems that led to the blackout.
I have great respect for the state’s electric resource planners. The electric system has been called the most complex machine because it is an extraordinarily intricate and vast network involving thousands of generating plants, millions of miles of transmission and distribution lines, and hundreds of millions of users continuously relying on it. The NYISO operators balance load and generation on a second-by-second basis, and the resource planners have provided the resources necessary for them to prevent blackouts. Those peaking units s all provide dispatchable power without weather limitations and provide other ancillary electric system services precisely where needed. Losing those resources makes the challenges even more difficult.
The STAR report warns that the grid is at a “significant inflection point” with converging threats including an aging generation fleet, rapid load growth, and difficulty developing new supply resources due to policy constraints, supply chain issues, and rising equipment costs. In the future Climate Act grid, the renewable resources are going to require Dispatchable Emissions Free Resources (DEFR) during dark doldrums when wind and solar resources are low to non-existent for extended periods to ensure that sufficient energy is available. Complicating the challenge is the fact that those conditions are also associated with extreme temperatures and peak loads. These factors all tweak the system in complex ways that may be too complicated to anticipate.
I know the NYISO and New York State Reliability Council planners are considering the impact of increasing reliance on weather-dependent resources. However, in my opinion, NYISO is not adequately acknowledging the intractable problem with an electric system that relies on renewables. To date the primary concerns about the commercially unavailable DEFR technology are expected to occur in the late 2030’s as renewable penetration increases. This may give time to address the issue.
However, I worry that this problem could become an issue in NYC sooner. The CHPE, Empire Wind, and the Propel NY Public Policy Transmission Project projects are all weather dependent, and I think there is underappreciated correlation between the generating sources. For an intense wintertime dark doldrum CHPE would not provide power if Hydro Quebec needs it for its ratepayers. If the dark doldrum started with a strong snowstorm that ushered in a large high-pressure system, NYC’s rooftop solar units could be covered with snow reducing their output. At the same time, the offshore wind resources could be becalmed. In that scenario short-term energy storage will not be sufficient, DEFR would be needed.
In a recent Capital Tonight segment Susan Arbetter interviewed Earthjustice attorney Rachel Spector.. I made a transcript and added my comments because I think the responses to her questions exemplify the position of environmental organizations that support the Climate Act. It is troubling that in response to a question about the implications of the STAR report, Spector said “Well, this is a complicated issue, and I could talk for a while about what the NYISO put forward but I will say New York is not facing an energy crisis and the reports that are coming out are extremely conservative.”
Fortunately, the NYISO recognizes their responsibility to protect the citizens of New York requires conservative approaches based on decades of experience. The STAR report recognizes that the BPTF projects must demonstrate their planned power capabilities before the peaking units can be retired. Furthermore, the Draft State Energy Plan found that reliability considerations will prevent the shutdown of any of the peaking power plants for the foreseeable future. If the NYISO warnings are heeded and the ideological zealots are ignored the worst-case catastrophe should be avoided.
Conclusion
Keeping the lights on in NYC during peak load conditions is challenging. In the future, the problem will become even more challenging because the meteorological conditions that cause the peak loads also are associated with low wind resource availability. The STAR report lays the foundation to address these challenges but the usual suspects are whining that their recommendations are too conservative.
The NYC peak load problem addressed by the STAR report cannot be endangered by risky unproven environmentalist strategies. Keeping the lights on is incredibly challenging at the best of times and a rushed transition away from existing system components is too risky to consider. The STAR report describes a safe transition approach. I believe that there is adequate time to address my concerns about the over-reliance on weather-dependent resources in the BPTF projects proposed.
Pragmatic Environmentalist of New York 