Category: New York State Energy

The New York Power Authority (NYPA) recently published for public comment the draft first update to its inaugural Strategic Plan for “developing new renewable energy generation projects to supply New Yorkers with affordable, reliable, and emissions-free electricity.”  Dennis Higgins graciously agreed to let me publicize his comments on the draft.

Dennis Higgins passes on his commentaries associated with New York’s Climate Leadership and Community Protection Act (Climate Act) to me.  He taught for just a few years at St Lawrence and Scranton University, but spent most of his career at SUNY Oneonta, teaching Mathematics and Computer Science.  He retired early, several years ago, in order to devote more time to home-schooling his four daughters. Dennis and his wife run a farm with large vegetable gardens where they keep horses and raise chickens, goats, and beef.  He has been involved in environmental and energy issues for a decade or more. Although he did work extensively with the ‘Big Greens’ in efforts to stop gas infrastructure, his views on what needs to happen, and his  opinions of Big Green advocacy, have forced him to part ways with their renewable energy agenda.

NYPA Strategic Plan

The New York political process and its one party rule uses the threat of shutting down state agencies to hijack annual budget vote to also include major policy legislation like the Climate Act.  Recently it seems that every budget bill includes another New York energy policy mandate.  The NYPA renewables responsibilities is an example:

The 2023-24 Enacted State Budget significantly expanded the New York Power Authority’s role in the renewable energy sector. Specifically, the new authority allows NYPA to plan, design, develop, finance, construct, own, operate, maintain and improve renewable energy generation projects to maintain an adequate and reliable supply of electric power and energy and support New York State’s renewable energy goals established in the Climate Leadership and Community Protection Act.

I think that mixing energy policy and politics is a recipe for disaster.  The hubris of the supporters of energy policy knows no bounds.  It is not only that their legislation mandates the impossible, but they also hamstring organizations in the state responsible for providing affordable, clean, and reliable electricity.  Upset that the deployment of renewable energy was not progressing fast enough to save the planet, the legislation forced NYPA to develop a strategic plan to deploy more renewable energy. 

NYPA published a draft of its Updated Strategic Plan on July 29, 2025, which details NYPA’s efforts to develop, own and operate renewable generation and energy storage projects to improve the reliability and resiliency of New York’s grid. The draft Updated Strategic Plan includes 20 new renewable generation projects and four energy storage projects. The plan also includes three new project portfolios that contain 152 storage systems. The new projects are located in every region throughout the state and represent a combined capacity of more than 3.8 gigawatts (GW). Including the first tranche of projects identified in the inaugural strategic plan—approved by the NYPA Board of Trustees in January—NYPA’s draft Updated Strategic Plan includes 64 projects and portfolios representing nearly seven gigawatts of capacity—enough electricity to power nearly seven million homes.

Cult Comments

Submitted comments on the 2025 NYPA Renewables Draft Updated Strategic Plan can be viewed. To give you a flavor of the political constituency that advocated for NYPA to have a role in renewables development I extracted the most common scripted comment.  Gary Abernathy perfectly describes the people who submitted the scripted comments as “Worshipers at the altar of climate calamity”.

The worshipers have no concept of energy reality.  There are multiple reasons that deployment is slower than envisioned by the authors of the Climate Act.  They demand that NYPA double down on the number of public renewables going from the proposed 7 GW to 15 GW by 2030 because we need to “comply with the Climate Act, lower electricity bills, create 25,000 green union jobs, and end our fossil fuel dependence.”  The reason is “we face life-threatening heat waves, flash floods, skyrocketing energy bills, and an attack on climate action from the federal government.”  All emotion and no substantive justification.  In the real world wishing hard will not overcome the supply chain issues, permitting concerns, financing problems with higher interest rates, and skilled tradesmen shortages problems that have delayed deployment.

Higgins Comments

Higgins prepared extensive comments that questioned whether any energy plan “reliant upon low-capacity factor, land hungry assets will prove reliable or affordable.”  He also raises an important consideration for Upstate New Yorkers: will requiring the upstate region to forfeit land in what will prove a failed effort to power metro New York pass the ‘environmental justice’ litmus test.

His comments cover six points:

1. NERC on the NY plan
2. Neither academic nor empirical evidence indicate the state plan will succeed
3. NERC warning — IBRs undermine grid reliability
4. Capacity markets hammered by intermittent resources increasing energy costs and undermining reliability
5. Intermittent resources will not prove economical or reliable according to Sweden and others
6. NYISO has repeatedly warned of reliability issues

The first point addresses interconnection issues with neighboring jurisdictions.  He notes that the New York plan “assumes markets will be available for our excess wind and solar energy” so that we can sell excess when it is not needed.  He also points out that we will also be dependent upon our neighbors when New York wind and solar resources are not enough to support our needs.  Higgins explains that the North American Energy Reliability Corporation (NERC) has highlighted risks to the bulk power system from wind and solar deployments that require the massive transmission upgrades needed for those energy transfers.

Higgins second point is one I constantly reiterate.  Academic studies and empirical evidence do not support New York’s renewable push.  He references the following National Renewable Energy Laboratory (NREL) chart that he says “shows the asymptotic costs of a system as penetration of renewables increases. Expensive battery energy storage can somewhat solve the “short term” variability of intermittent resource generation. But there is no day-night or seasonal solution.”  I would add that the chart should also include the long duration dark doldrum event problem in the upper right portion of the curve.  New York organizations responsible for the electric system all agree that a new dispatchable emission-free resource (DEFR) is needed.  I believe that including it would extend the graph exponentially higher.

In his third argument Higgins points out that NERC has also warned that inverter-based resources undermine grid reliability.  He quotes a NERC report:

Since 2016, NERC has analyzed numerous major events totaling more than 15,000 MW of unexpected generation reduction. These major events were not predicted through current planning processes. Furthermore, NERC studies were not able to replicate the system and resource behavior that occurred during the events, indicating systemic deficiencies in industry’s ability to accurately represent the performance of IBRs and study the effects of IBR on the bulk power system (BPS).

The fourth problem is that capacity markets are hammered by intermittent resources that increase energy costs and undermine reliability.  The necessity to have firm dispatchable resources needed to back up intermittent wind and solar means that in jurisdictions that are further down the renewable deployment path there is an increased need for peaker power plants that burn natural gas.  He describes the perverse economics that result.  This will exacerbate New York’s  energy affordability crisis

Higgins makes another point that I often raise.  Evidence from other jurisdictions shows that intermittent resources will not prove economical or reliable.  He cites results that show that

Controlling for country fixed effects and the rich dynamics of renewable energy capacity, we show that, all other things equal, a 1% percent increase in the share of fast reacting fossil technologies is associated with a 0.88% percent increase in renewable generation capacity in the long term.

Translated that means that for every MW of installed renewable capacity fast reacting dispatchable resources are necessary.  The only available resource is fossil-fired generators.  New York’s fossil fleet is aging.  Consequently, we are going to have to replace all the fossil plants in the long term or rely on more expensive battery storage and DEFR.  How can anyone claim that wind and solar are cheaper when they need one for one capacity backup is a mystery to me.

The final point that Higgins makes is that the New York Independent System Operator (NYISO has repeatedly warned of reliability issues.  He quotes the latest Power Trends report:

As traditional fossil-fueled generation deactivates in response to decarbonization goals and tighter emissions regulations, reliability margins on the grid are eroding. Further, the remaining fossil-fueled generation fleet, which provides many of the essential reliability services to the grid, is increasingly made up of aging resources, raising further concerns about grid reliability. Strong reliability margins enable the grid to meet peak demand, respond to sudden disturbances, and avoid outages. They also support the grid’s ability to respond to risks associated with extreme weather conditions. As these margins narrow, consumers face greater risk of outages if the resources needed for reliability are unavailable due to policy mandates or failures associated with aging equipment.

Higgins raises substantive issues that could derail the net-zero transition.  The political mandate to force NYPA to build as much renewable capacity as possible as quickly as possible ignores the very real possibility that the unresolved need for DEFR may mean that the renewable approach is a false solution.  Obviously, New York needs to pause implementation and consider the schedule and ambition of the Climate Act.

Request

Please consider submitting comments for the proceeding.  Written comments on the NYPA Renewables Strategic Plan can be submitted through Sept 12th here: https://publiccomments.nypa.gov/.  Explain that you are worried about costs and reliability and suggest that the strategic plan should take those factors into account.

State agencies tend to count the number of comments that support their positions to justify going ahead with their plans.  Even if you submit a comment that only says you agree with Vincent Gambini’s response to the scripted comments that say NYPA should build 15 GW of renewables by 2030, it would be useful.  For once, I would like to see comments from those of us outside the cult of climate catastrophes outnumber those zealots.

Conclusion

This process is yet another component of the Climate Act net-zero transition.  Even thought the costs are beginning to impact New York utility bills. the impacts of the Climate Act still are flying under the radar of most people.  It is just getting started and it would be better to stop it now than wait.  Contact your elected officials and demand accountability.

I recently wrote an article about the claim that renewable energy can reduce costs in the presentation by Jeff Freedman from the Atmospheric Sciences Research Center, University at Albany at the Energy Planning Board on March 3, 2025.  I concluded that the claim is based on hope not evidence.  Dr. Freedman’s presentation also included slides that support the Hochul Administration narrative that Greenhouse Gases (GHG) are the cause of the observed increases in global temperature and that the impacts of that warming are evident today.  This article explains why I disagree with those claims in Freedman’s presentation.

I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act) net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage 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 over 500 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.

Energy Plan Overview

According to the New York State Energy Plan website (Accessed 3/16/25):

The State Energy Plan is a comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers. The Plan provides broad program and policy development direction to guide energy-related decision-making in the public and private sectors within New York State.

The current Plan was initially published in 2015, and updated in 2020, when it was amended to align with the objectives of the 2019 Climate Leadership and Community Protection Act (Climate Act). Since the last update, the Climate Action Council produced its Scoping Plan, examining many of the energy issues that contribute to climate change and offering recommendations that are currently being implemented by the State.

On September 9, 2024, the Hochul Administration initiated the State Energy Plan process to update the Plan consistent with the Climate Act.  The goal of the planning process is to “map the state’s energy future by showing how the state can ensure adequate supplies of power, reduce demand through new technologies and energy efficiency, preserve the environment, reduce dependence on imported gas and oil, stimulate economic growth, and preserve the individual welfare of New York citizens and energy users.” The major question that must be addressed is whether the Hochul Administration will use the energy planning process as an opportunity to consider the advice of stakeholders in its stakeholder process or just an obligation with no attempt to meaningfully engage with any comments inconsistent with the narrative.

If the March 3 meeting is any indication, then the Energy Plan will be another political show extolling the virtues of the Climate Act and ignoring anything inconsistent with the political narrative.  In other words, it looks just like the Scoping Plan process.  Many of the appointees to the Climate Action Council chosen to approve the Scoping Plan were chosen because of their position within the Hochul Administration or political connections and not their technical expertise.  One feature of the Scoping Plan process was the New York State Energy Research & Development Authority (NYSERDA) strict adherence to the political narrative rather than full disclosure of inconsistent issues.  This article addresses several arguments made in the NYSERDA presentation by Freedman that misled the Energy Planning Board members.

Narrative Support

Climate Leadership & Community Protection Act Section 1. Legislative findings and declaration, subsection 3 defines the narrative:

Action undertaken by New York to reduce greenhouse emissions will have an impact on global greenhouse gas emissions and the rate of climate change. In addition, such action will encourage other jurisdictions to implement complementary greenhouse gas reduction strategies and provide an example of how such strategies can be implemented. It will also advance the development of green technologies and sustainable practices within the private sector, which can have far-reaching impacts such as a reduction in the cost of renewable energy components, and the creation of jobs and tax revenues in New York.

The  presentation slides for the March 3 meeting included Freedman’s Key Findings slide that support this narrative.   The first finding says that “Climate change is already constraining some sources of energy supply and stressing transmission and distribution infrastructure through extreme heat, changes in precipitation, and increasing storm intensity”.  The implication is that reducing GHG emissions in New York will affect the rate of climate change which they claim has already become evident.  The second finding that “Patterns of energy demand are shifting due to climate change and are expected to continue evolving over the coming decades” explicitly states that impacts are observable.

These findings were presented to the Energy Planning Boad as unequivocal statements of fact.  In reality, there is significant uncertainty that should be considered in the draft Energy Plan.

Comparison of CO2 and Global Temperature

The common basis of the threat of climate change caused by human emissions of GHG is the graph comparing the concentration of CO2 and global temperatures that was included in Freedman’s presentation.  There is no question that increasing the concentration of GHG in the atmosphere will reduce the out-going long wave radiation which will warm the atmosphere, and the graph shows a correlation.  However, the conclusion that reducing New York’s GHG will affect global temperatures and the alleged weather impacts given the small contribution to the global concentration is unwarranted.

Esteemed climate scientist Richard Lindzen describes the energy budget in context:

The energy budget of this system involves the absorption and re-emission of about 200 watts per square meter. Doubling CO2 involves a 2% perturbation to this budget. So do minor changes in clouds and other features, and such changes are common. In this complex multifactor system, what is the likelihood of the climate (which, itself, consists in many variables and not just globally averaged temperature anomaly) is controlled by this 2% perturbation in a single variable?

Lindzen points out that believing this is “pretty close to believing in magic”.  Nonetheless, Freedman presents the graph of CO2 concentration and global temperature without any mention of the shortcomings and complexities of the climate system.

My point is that this is not as obvious a relationship as claimed.  Sabine Hossenfelder produces You Tube videos on science and technology.  Her climate change-related videos generally adhere to the narrative, but she has shown signs of waking up to reality. Peter Ridd commented on her awakening noting that she does not quite get there.  I call your attention to Ridd’s commentary where he talks about uncertainties about how the earth’s weather system works. Especially relevant to Freedman’s graphic is Ridd’s explanation of temperature and CO2 concentrations going further back in time than Freedman’s graph.  Ridd points out in the following graph that temperatures were higher many times in the last 10,000 years at the same time that CO2 concentrations were lower.  That directly contradicts the notion that global temperature is primarily driven by anthropogenic CO2 concentrations.

Climate vs. Weather

Freedman perpetuates the Climate Act myth that climate change is increasing extreme heat, changes in precipitation, and increasing storm intensity with a graph that shows increasing storm events in New York from 2001 to 2024.  In general, climate is what you expect, and weather is what you get.  To determine what you expect from climate, meteorologists use a 30-year climatological average.  Therefore, to have a climate trend you need to look at the difference between two 30-year averages at a minimum.  Freedman’s graph is a weather average trend unsuitable for making any climate trends claims.

After I drafted this article Anthony Watts summed up my problems with claims that climate change is an existential threat in a post entitled “Is Climate Change Real? Short Answer: Yes — But It’s Complicated.”  I published an article that quoted the article with my annotated comments relating the points he made to the Climate Act.  I highly recommend reading that aartilce.

Basis for Narrative Claims

Expert presentations designed to promote the Climate Act narrative to an audience such as the Energy Planning Board often cite the results of modeling.  In this instance there is a slide that describes the “effects of climate change on renewable energy distribution in New York State” based on “results from high-resolution dynamic downscaling”.  Sounds very scientific and above reproach.

The grid size for CMIP5 (Coupled Model Intercomparison Project Phase 5) climate models typically ranges between 125 km to 300 km.  This is too coarse for predicting the impacts of climate change on New York so higher-resolution regional models have been used in projects sponsored by NYSERDA to project impacts.  This process is called dynamical downscaling.  Unmentioned are the errors and inherited biases in the process from the Global Climate Models (GCM) for the following:

• Temperature trends: Persistent warm/cold biases in coastal and inland regions, exacerbated by future GCM projections exceeding historical maxima.
• Precipitation patterns: Systematic underestimation of seasonal rainfall in regions like the Caribbean and Southern Africa.
• Extreme events: Misrepresentation of high-frequency, low-intensity rainfall (“drizzle problem”) due to GCM limitations.

I think that those issues underestimate the problems because the fact is the GCM projections do not include the physics of clouds.  The problem is that coarse grid size cannot incorporate precipitation or extreme events.  This is not to say that the models don’t predict storms, just keep in mind that they are little more than guesses strongly influenced by the biases of the modelers. 

There are structural RCM limitations that introduce their own errors despite higher grid size resolution:

• Simplified physics: Inadequate representation of convective processes and local interactions (e.g., lake effects).
• Scale mismatches: Difficulty resolving sub-grid features even at 10–50 km resolutions.
• Computational constraints: Limited ability to run multiple GCM-RCM combinations, reducing uncertainty sampling.

Those limitations are relevant to the purported New York results.  For five months of the year much of Upstate weather is strongly influenced by the Great Lakes.  Convective processes and local interactions like lake effect are erroneous in the RCM because the scale of the lake effects is smaller than the resolution of the models.  I have been working with weather models and Upstate mesoscale weather regimes for decades and I am positive that the model projections are poor at best.   Combined with the fact that the projections use a totally unrealistic estimate of future emissions (the RCP 8.5 scenario), I do not believe the results presented have any value. 

Discussion

NYSERDA scripted the presentation to the Energy Board so that it was completely consistent with the narrative that climate change impacts are occurring today.  I recently showed that the uncertainty of the historical temperature measurements is similar to the alleged temperature increase due to GHG emissions.  This post explains that the claimed trend in storm events is not a climatic trend because the time range is too short, and that the model projections of weather have limited value. As a result, the Energy Planning Board came away from the meeting erroneously believing that the effects of climate change are occurring now and that reducing New York GHG emissions will reduce those impacts.

This is not in the best interests of New York.  The New York energy plan is supposed to be a roadmap for a “clean, resilient, and affordable energy system for all New Yorkers.”   There are conflicting priorities and challenges for those three goals.  The State Energy Planning Board should be given all the information so that they can “focus on strategies to meet future energy needs and advance economy-wide decarbonization, while balancing reliability, affordability, environmental and public health impacts and economic growth.”  The presentation did not give any of the qualifying information about uncertainties, so it gave the Board a false basis for evaluating the Climate Act approach and schedule.

The basic strategy for decarbonizing the economy is electrification of all sectors.  Authors of the Climate Act believed that no new technology was needed for the transition of the electric sector to “zero emissions” using wind, solar, and hydro.  All the organizations responsible for electric system reliability agree that a new dispatchable, emissions-free resource is necessary for extended periods of low wind and solar resource availability so that presumption is wrong.  That means that the schedule must be adjusted to account for the necessity to develop, test, and deploy this new technology. 

 A primary driver for the Climate Act schedule was the perceived necessity to do something immediately because the effects of climate change are evident now.  As shown here, that argument is not supported when temperature trend uncertainty is considered, long-term trends of weather events are evaluated, and the weaknesses of global climate models are acknowledged.  Those results do not necessarily mean that it is inappropriate to do something, but the results do mean that the claims we must act immediately are unwarranted.  We have time to do this right.  I think that is a primary concept that should be incorporated into the Energy Plan.

Conclusion

I am disappointed that NYSERDA has become so politicized.  The NYSERDA presentation by Dr. Freedman gave the Energy Planning Board misleading information about the threat of climate change and the need to act immediately.  It is becoming increasingly evident that there are so many unanticipated issues associated with the Climate Act implementation that a pause to re-evaluate the schedule and goals is in order.  If NYSERDA documentation had not been politicized the Scoping Plan could have included caveats and achievement milestones to provide an off-ramp to a Plan B that is clearly necessary.  As it stands now, admitting delays and unavailable technologies will be a political embarrassment.  However, it is necessary to ensure that reliability, affordability, environmental and public health impacts, and economic growth goals can be achieved.

On July 14, 2023 the New York Independent System Operator (NYISO) released its quarterly assessment of reliability of the bulk electric system.  The analysis found a deficit in reliability margins for the New York City area beginning in summer 2025. As a result, something must be done or there will be unacceptable risks to reliability that could cause power outages.  Unfortunately, it is difficult to understand the reasons for this finding because of the complexity of the subject.  This post includes a detailed explanation of the report and its implications.  If you want a good non-technical summary, then I recommend James Hanley’s post Get Ready for the New York City Blackout of 2025.

I have been following the Climate Leadership & Community Protection Act (Climate Act) since it was first proposed.  I submitted comments on the Climate Act implementation plan and have written over 300 articles about New York’s net-zero transition.  I have devoted a lot of time to the Climate Act and New York’s energy planning because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good.  Unfortunately, trying to explain the risks and issues associated with the transition is difficult because of the complexity of the problems and the fact that expert reports are dense and filled with jargon.  The opinions expressed in this article do not reflect the position any of my previous employers or any other company I have been associated with, these comments are mine alone.

Resource Adequacy Assessments

The NYISO is responsible power system reliability and competitive markets for New York.  As part of that mission NYISO determines whether generating resources and the transmission system can adequately meet expected load.  They describe the resource adequacy analyses as follows:

Resource adequacy is the ability of the electric system to supply the aggregate electrical demand and energy requirements of the firm load at all times, considering scheduled and reasonably expected unscheduled outages of system elements. The NYISO performs resource adequacy assessments on a probabilistic basis to capture the random nature of system element outages. If a system has sufficient transmission and generation, the probability of an unplanned disconnection of firm load is equal to or less than the system’s standard, which is expressed as a loss of load expectation (LOLE). Consistent with the Northeast Power Coordinating Council and New York State Reliability Council criterion, the New York State bulk power system is planned to meet an LOLE that, at any given point in time, is less than or equal to an involuntary firm load disconnection that is not more frequent than once in every 10 years, or 0.1 event days per year.

So what does that mean?  The first point is that the electric system is very complicated.  I summarized my skepticism of the net-zero transition earlier this year in an article that included an overview of the electric system.   Incredibly all the fossil, hydro, and nuclear generating stations in the Eastern Interconnection shown below work together.  In order to provide electricity, the generating turbines are synchronized to turn at 1800 revolutions per minute.  Operators keeps the voltages as constant as possible in the entire area but rely on those turbines to provide inertia as well as voltage control and that can be dispatched as necessary to match load.  The NYISO operates the New York State control area within the Interconnection.  In addition to the day-to-day operation, they plan for resource adequacy to ensure that the operators have generating resources available so that they can constantly match load. 

The NYISO resource adequacy assessments rely on decades of observed characteristics of generating resources, the transmission system, and system load to develop the likelihood  of system element outages. If a system has sufficient transmission and generation, then when a problem occurs (say lightning hits a transmission line) the system can respond without an extended outage.  The NYISO has a well-established process to identify reliability needs. The analyses consider how the system can react to various combinations of issues based on historical observations of the existing system to determine the loss of load expectation (LOLE). The organizations overseeing New York reliability,  the Northeast Power Coordinating Council and New York State Reliability Council, mandate that the New York State bulk power system is planned to meet the LOLE standard that any involuntary firm load disconnection  is not more frequent than once in every 10 years, or 0.1 event days per year.

Annotated Executive Summary

This section quotes the Executive Summary in the report and explains the contents.  As part of an on-going reliability assessment process the NYISO analyzes any expected changes to the generation and transmission system:

This report sets forth the 2023 Quarter 2 Short-Term Assessment of Reliability (“STAR”) findings for the five-year study period of April 15, 2023, through April 15, 2028, considering forecasts of peak power demand, planned upgrades to the transmission system, and changes to the generation mix over the next five years.

The analysis finds that there are issues associated with peaking power plants in New York City.  I have been involved with this problem and these facilities since 2000.  This topic has been the subject of multiple articles on this blog and I have summarized my articles as on overview that I can reference when the issue resurfaces.  The Executive Summary notes: 

This assessment finds a 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 “Peaker Rule.”  In 2019, the New York State Department of Environmental Conservation adopted a regulation to limit nitrogen oxides (NOx) emissions from simple-cycle combustion turbines, referred to as the “Peaker Rule” (https://www.dec.ny.gov/regulations/116131.html)  

The Peaker Rule culminated a decade-long process whereby the New York State Department of Environmental Conservation (DEC) instituted a framework to retire or control the “peakers”.  The DEC, NYISO, facility owners and Consolidate Edison, the load serving entity for New York City, all worked together to ensure that the retirement would not endanger reliability.  This latest analysis suggests that there are still issues to be resolved:

Combustion turbines known as “peakers” typically operate to maintain bulk power system reliability during the most stressful operating conditions, such as periods of peak electricity demand. As of May 1, 2023, 1,027 MW of affected peakers have deactivated or limited their operation. An additional 590 MW of peakers are expected to become unavailable beginning May 1, 2025, all of which are in New York City.   With the additional peakers unavailable, the bulk power transmission system will not be able to securely and reliably serve the forecasted demand in New York City (Zone J). Specifically, the New York City zone is deficient by as much as 446 MW for a duration of nine hours on the peak day during expected weather conditions when accounting for forecasted economic growth and policy-driven increases in demand.

The following paragraph explains that the reliability need is expected because the latest projections of generation, load, and transmission availability have changed over time:

The reliability need is based on a deficient transmission security margin that accounts for expected generator availability, transmission limitations, and updated demand forecasts using data published in the 2023 Load & Capacity Data Report (“Gold Book”). The transmission security margin represents the balance between demand for electricity and the power supply available from generation and transmission to serve that demand. This assessment recognizes that there is uncertainty in the demand forecast due to uncertainties in key assumptions including population and economic growth, the proliferation of energy efficiency, the installation of behind-the-meter renewable energy resources, and electric vehicle adoption and charging patterns. These risks are accounted for in the transmission security margin calculations by incorporating the lower and higher bounds as a range of forecasted conditions during expected weather, specified in the Gold Book as the policy scenario forecasts. The lower and higher demand policy scenario forecasts reflect achievement of policy targets through alternative pathways and assume the same weather factors as the baseline demand forecast.

The Gold Book is the standard for electric data in New York. The following figure shows the range of the demand forecasts for New York City.  I want to point out one thing.  The emphasis is on providing generation for the peak load.  This is a significantly more difficult problem than estimating the generation necessary for an average year.  There are more short-term constraints that could affect generation and load that can be ignored on average.  

I have some experience with the resource modeling projections and cannot over-emphasize the complexity of all the factors incorporated in the models.  Unfortunately, there is a lot of uncertainty associated with projecting all those factors.  That is why the NYISO is constantly re-evaluating the model inputs and projections.  In addition, they are always looking to refine the model itself.  Based on their latest estimates:

Under the baseline forecast for coincident summer peak demand, the New York City transmission security margin would be deficient by 306 MW in 2025 for a duration of 7 hours. However, accounting for uncertainties in key demand forecast assumptions, the higher bound of expected demand under baseline weather conditions (95 degrees Fahrenheit) in 2025 results in a deficiency of 446 MW over 9 hours. The deficiency would be significantly greater if New York City experiences a heatwave (98 degrees Fahrenheit) or an extreme heatwave (102 degrees Fahrenheit).

The NYISO is banking on one project to address this problem after 2025.

Overall, the New York City transmission security margin is expected to improve in 2026 if the Champlain Hudson Power Express (CHPE) connection from Hydro Quebec to New York City enters service on schedule in spring 2026, but the margin gradually erodes through time thereafter as expected demand for electricity grows. Beyond 2025, the forecasted reliability margins within New York City may not be sufficient if (i) the CHPE project experiences a significant delay, (ii) additional power plants become unavailable, or (iii) demand significantly exceeds current forecasts. Without the CHPE project in service or other offsetting changes or solutions, the reliability margins continue to be deficient for the ten-year planning horizon. In addition, while CHPE is expected to contribute to reliability in the summer, the facility is not expected to provide any capacity in the winter.

I am uncomfortable that there is this much reliance on a single project to address the problems identified.  I discussed the start of construction late last year for the Champlain Hudson Power Express (CHPE) project.  It is a 339-mile underground transmission line capable of bringing 1,250 MW from the Province of Quebec to Astoria Queens in New York City.  I explained that I was worried about the schedule and costs of the project.  The NYISO Resource Adequacy analyses must necessarily rely on the developer’s prediction for completion.  Richard Ellenbogen and I share the timeliness concern.  Richard noted that the project was proposed in 2011 and the PSC authorized it on 4/18/13.  It has been 11.5 years since it was proposed, 9.5 years since it was authorized, and construction started a year after the funding contract was signed.  In addition, it has recently come out that landowners on sections of the right-of-way that are on land have just been informed that they will be impacted.  The likelihood of additional delays seems high.  Given that other renewable projects are being re-evaluated because of price increases due to inflation and increased cost of materials it seems that this project will also have the same problems.  Given its importance to New York City reliability, I cannot conceive of any scenario in which the State will not grant any cost overruns requested by the developers. This project is already expensive equating to an estimated increase in customer electric bills of 2.1 – 4.1% (or $2.08 – $4.08 per month for the average residential customer.  I am confident that at the end of the day the final costs will be much higher.

The STAR quarterly report did not limit its analysis to just New York City.

In addition to New York City, this assessment also evaluated the transmission security margins for the statewide system as well as Lower Hudson Valley and Long Island localities. For these localities, the planned Bulk Power Transmission Facilities (“BPTF”) through the study period are within applicable reliability criteria based on the baseline summer coincident peak demand forecast with expected weather and with the planned projects meeting their proposed in-service dates. The NYISO assessed the resource adequacy of the overall system and found no resource adequacy reliability needs.

The NYISO is a product of the de-regulated New York electric system.  As such they are ardent supporters of “market” solutions.  This adds a layer of uncertainty because NYISO must develop some sort of incentive for a developer to provide the necessary resources.  If it was an attractive investment, then I would expect that someone would already be developing the necessary resources.  In addition, Con Ed must also determine if local transmission upgrades can resolve the problem.

The short-term need observed in 2025 is a Near-Term Reliability Need. As a result, solutions will be solicited, evaluated, and addressed in accordance with the NYISO Short-Term Reliability Process. The need arises within the Con Edison Transmission District; therefore, Con Edison is the Responsible Transmission Owner for developing a regulated solution.(Reference NYISO’s Open Access Transmission Tariff Section 38.3.6)

The report identifies another particular issue that illustrates why regular STAR analyses are required and why this issue is coming up now.  Although all the affected parties may know that there will be changes to the system and have reasonable expectations what they will be, the NYISO cannot officially act until certain filings are made.

Central Hudson identified transmission security issues in its transmission district on its non-BPTF system. These are primarily driven by the assumed unavailability of certain generation in its district affected by the Peaker Rule. Given that those generators have not yet provided complete Generator Deactivation Notices to the NYISO, the local non-BPTF criteria violations identified by Central Hudson are being provided for information but were not assessed to identify possible Generator Deactivation Reliability Needs at this time.

The report also describes an upcoming issue that will be considered officially in a subsequent report. The “informational scenario” considers interconnecting large loads:  the Micron New York semiconductor manufacturing (530 MW in 2030), the Air Products and Chemicals (Q#1446), and other load changes that increase load another 694 MW.

As an informational scenario, this STAR includes an evaluation of the impact of additional large load interconnection projects primarily in western and central New York. The anticipated increases to the demand forecast due to these large loads in 2025 is 764 MW which results in a corresponding reduction to the available margin, such that in 2025 the statewide system margin is projected to be deficient of 145MW. By 2033, additional large loads increase the demand by 1,224 MW which results in a corresponding deficient margin of 104 MW. If CHPE does not begin operation, the state wide system margin is projected to be deficient for all years 2025 through 2033 when considering the additional large loads. The 2023 Quarter 3 STAR will include these load projects and the associated system margin impacts. The solution to the New York City reliability need identified in this STAR may also address the state wide system margin concern.

The Executive Summary summarizes their approach:

The wholesale electricity markets administered by the NYISO are an important tool to help mitigate these risks. The markets are designed, and continue to evolve and adapt, to send appropriate price signals for new market entry and the retention of resources that assist in maintaining reliability. The potential risks and resource needs identified in the NYISO’s analyses may be resolved by new capacity resources coming into service, construction of additional transmission facilities, and/or increased energy efficiency and integration of demand-side resources. The NYISO is tracking the progression of many projects that may contribute to grid reliability, including numerous offshore wind facilities that have not yet met the inclusion rules for reliability assessments. The NYISO will continue to monitor these resources and other developments to determine whether changing system resources and conditions could impact the reliability of the New York bulk electric grid.

Note that there are three ways the problem identified can be resolved: building new capacity resources, construction of additional transmission facilities, and/or reducing load expectations with increased energy efficiency and integration of demand-side resources.  Even if the Hochul Administration came to its senses and decided to facilitate the construction of dependable generating capacity, that is to say, fossil-fired generators, there is no way that any generating resource to support reliability could get built in this timeframe.  My rule of thumb for just getting permits in New York City is a minimum of three years.  The summer of 2025 is only two years away.  Of course, the possibility of any new fossil infrastructure is very unlikely anyway.  Designing, permitting, and building additional transmission facilities may not take quite as long but I cannot imagine this solution could be available in two years.  There already are great expectations for reducing load so I cannot imagine any scenario that could reduce additional load on the order necessary to meet the identified load shortfall.

The final paragraph in the Executive Summary describes the specific filings that will trigger further STAR revisions.

As generators that are subject to the DEC’s Peaker Rule submit their Generator Deactivation Notices, the NYISO and the responsible Transmission Owners will continue to evaluate in future STARs whether Generator Deactivation Reliability Needs arise from the deactivation of Initiating Generators. (Reference NYISO’s Open Access Transmission Tariff Section 38.1 state that an “Initiating Generator” is “a Generator with a nameplate rating that exceeds 1 MW that submits a Generator Deactivation Notice for purposes of becoming Retire or entering into a Mothball Outage or that has entered into an Installed Capacity (ICAP) Ineligible Forced Outage pursuant to Section 5.18.2.1 of the ISO Services Tariff which action is being evaluated by the ISO in accordance with its Short-Term Reliability Process requirements in this Section 38 of the ISO Open Access Transmission Tariff.

Discussion

The Findings section expands the description of the problem found.  Without changes to existing load pattern the summer peak load demand in New York City would be “deficient by 306 MW in 2025 for a duration of 7 hours”.  There are uncertainties in the load demand forecasts.  Assuming the upper bound of “demand under baseline weather conditions (95 degrees Fahrenheit) in 2025 results in a deficiency of 446 MW over 9 hours.” If the weather is hotter or lasts for an extended period the “deficiency would be significantly greater.” This exemplifies the tradeoffs the NYISO and NYSRC must make when assessing resource adequacy and reliability standards.  If the deficiency is “significantly greater” then it will be impossible to manage the load without rolling blackouts.

The NYISO writes: “The deficient margin is primarily due to the increased demand forecasts within New York City combined with the planned unavailability of simple-cycle combustion turbines to comply with the DEC’s Peaker Rule in 2025”.   Apparently, it is not politically correct to point out that Hochul Administration’s policy that finalized the shutdown of 2,000 MW of nuclear power and the disapproval of a plan to build a 1,040 MW, eventually reduced to 437 MW, combined cycle facility exacerbated this problem and that if those resources were available there would not be a problem.

As it stands now, I expect that the solution will be an extension of the operating permits for the peaking turbines because there is no other viable solution to maintain reliability.

The NYISO describes the process and explains how it will be resolved in the following figure.  They have identified the reliability need.  They will ask Consolidated Edison if the problem can be resolved with transmission system revisions in Step 2.  At the same time in Step 3, NYISO will solicit  market-based solutions from other developers.  In the next step NYISO reviews the proposed solutions “to determine if they are viable and sufficient to address the identified need.”  The NYISO description of the last step notes:

Timing is an essential component of the NYISO’s evaluation. If proposed solutions are not viable or sufficient to meet the identified reliability need, interim solutions must be in place to keep the grid reliable. One potential outcome could include relying on generators that are subject to the DEC’s Peaker Rule to remain in operation until a permanent solution is in place. The DEC’s Peaker Rule anticipated this scenario when it authorized the NYISO to designate certain units to remain in operation beyond 2025 on an as-needed basis for reliability. Based on findings from its Short-Term Reliability Process, the NYISO may designate certain units, in sufficient quantity, to remain in operation for an additional two years (until May 1, 2027) with the potential of an additional two-year extension (to May 1, 2029) if a permanent solution that is needed to maintain reliability has been selected but is not yet online. The NYISO would only temporarily retain peakers as a last-step approach if it does not expect solutions to be in place when the identified reliability need is expected in 2025.

Reaction

Utility Dive described the report.  Their article quotes Zach Smith, vice president of system and resource planning for the NYISO as saying the assessment “reflects the extraordinary challenges of the grid in transition.”  It also notes that the report acknowledges “uncertainty” in the demand forecast surrounding assumptions including population and economic growth, the proliferation of energy efficiency, the installation of behind-the-meter renewable energy resources, and EV adoption and charging patterns.

The reaction of parties in New York State was predictable.  Marie French writing at Politico solicited comments from the Hochul Administration:

“To be clear: The reliability of our grid is not in question,” Hochul spokesperson Katy Zielinski said in a statement. “We are committed to ensuring New Yorkers have a reliable and affordable power supply — and we can do this while accomplishing our nation-leading climate goals. Governor Hochul remains fully committed to rapidly decreasing emissions and setting an example for how clean energy and reliability can go hand-in-hand.”

French said that Zielinski cited the planned Canadian hydropower line, the Clean Path line and offshore wind projects as ways to bring more renewables into New York City.   There is a fundamental issue with these projects because they all rely heavily on distant  transmission that is overly vulnerable to outages  One of the New York City blackouts occurred because a transmission line into the city went down and in-city generation could not be brought up fast enough to react to the loss of energy supply.  There are specific reliability rules in place that mandate a minimum capability of in-city generation when storms threaten transmission lines into the City.  I am not sure how this will be addressed in the future.  The Canadian hydropower line may not be affected by storms but still could go down unexpectedly for other reasons.  The Clean Path project is “is comprised of more than 20 renewable energy generation projects and an approximate 175-mile, underground transmission line.  I am guessing that the argument is that an underground line can provide power that is not subject to storm outages so is exempt from the transmission line reliability rule.   However, even if they are much less likely to go out, when they do have problems fixing them is much more difficult.  Counting on offshore wind as a viable replacement in the City is very risky unless it is coupled with sufficient energy storage to cover the energy needs for an entire heat wave because the meteorological conditions that cause extreme heat are associated with high-pressure systems that also have light winds.

The Peak Coalition has been the primary mover for peaking power plant environmental justice.  French mentioned their statement that notes:

PEAK Coalition is gravely concerned with the impact that the reliability deficit estimated in the Short-Term Assessment of Reliability (STAR) report for Q2 of 2023 released by the New York Independent Systems Operator (NYISO) will have on communities that live near power plants. We encourage all stakeholders involved in the energy planning process to take concrete action to prevent delaying the closure of fossil fuel peaker plants in 2025 and beyond.  These plants harm the communities that surround them every hour that they operate. PEAK refuses to accept a scenario in which environmental justice communities must suffer further harm to guarantee further profligate summertime energy consumption in commercial buildings and wealthy communities.

I have evaluated the EJ claims.  The PEAK coalition has stated that “Fossil peaker plants in New York City are perhaps the most egregious energy-related example of what environmental injustice means today.”  The influence of this position on current New York State environmental policy has led to this issue finding its way into multiple environmental initiatives. However, the presumption of egregious harm is based on selective choice of metrics, poor understanding of air quality health impacts,  and ignorance of air quality trends.  

As noted previously the NYISO is invested in market solutions. French also got a statement from the NYISO that is completely consistent with that approach:

“We’ve identified the reliability need, so we’re confident that’s present for summer 2025,” said NYISO spokesman Kevin Lanahan. “We’re also confident that we can solve the reliability [need]. That’s the nature of our planning process, to identify those issues with enough time to solve the problems so we’re confident we can find the solution and keep the system reliable.”

French also got a statement from Gavin Donohue at the Independent Power Producers:

“The pace of play is not keeping up with pace of promises, and this report makes that clear,” said Independent Power Producers of New York president and CEO Gavin Donohue, who represents the state’s existing nuclear, renewable and predominantly fossil fuel power plants. “This report should draw attention from state officials in shaping realistic public policies. I encourage the NYISO to identify solutions that are market-based so we can set ourselves on the pathway to a cleaner energy future, while maintaining the reliability of our grid at affordable rates.”

James Hanley from the Empire Center summarizes the implications well.  He concludes:

The mistake New York has made is not its goal to eventually reduce NOx emissions but its rush to shut down the peakers — and Indian Point — before developing reliable replacement sources of power. Notably, the Department of Environmental Conservation rejected proposals by NRG Energy to update nearly 1,000 megawatts of electricity production in the city to newer, cleaner-burning, and NOx-standard compliant combined-cycle power plants, claiming that NRG “failed to demonstrate the need or justification for the proposed project.”

This “shutdown first, replace later” model was a major cause of rolling blackouts on the West Coast, but New York authorities didn’t bother to learn from California’s experience. Simple common sense would indicate that the wise approach would be to find assured sources of reliable and dispatchable electricity production before taking critical power plants offline. Sadly, common sense was the first victim of New York energy policy. Even more sadly, it won’t be the last.

Conclusion

Despite assurances from Hochul spokesperson Katy Zielinski, the reliability of the New York City grid is in question. The plans rely on resources that are new to New York and that increases uncertainty.  Presuming that proposed projects will replace operational facilities on the schedule proposed is very risky. 

There is another dynamic here that will be interesting to watch.  Peaker power plants are a primary scapegoat for the New York City EJ community.  The PEAK Coalition has already gone on record stating that “If NYISO is forced to issue reliability-must-run orders, New Yorkers will know that electric utilities and state governments willingly failed to act to protect communities most impacted by fossil fuel emissions and climate change”.  The electric utilities and state government have failed to explain the potential impacts to the disadvantaged communities if fossil-fired peaking units are not replaced with proven technology.  The risks to those communities imposed by the presence of such resources are not nearly as large as the risks to those communities from blackouts.  Keeping the lights on is the better social choice.

Thanks to Russell Schussler for review and helpful comments.  Any technical errors are mine.