On October 13, 2025 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 and Long Island beginning in summer 2026. As a result, something must be done or there will be unacceptable risks to reliability that could cause power outages. This post provides an overview of these findings. If you want a good non-technical summary of this report, then I recommend Brendan Lyons article: NY’s electric grid operator warns of looming ‘reliability shortfalls’
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
NYISO describes the report as follows:
This report sets forth the 2025 Quarter 3 Short-Term Assessment of Reliability (“STAR”) findings for the five-year study period of July 15, 2025, through July 15, 2030, considering forecasts of peak power demand, planned upgrades to the transmission system, and changes to the generation mix over the next five years.
The risk of deficiencies beyond the needs identified in this STAR is even greater when considering a range of plausible futures with combined risks, such as the statistical likelihood of further generator retirements or failures. New York’s generation fleet is among the oldest in the country, and as these generators age, they are experiencing more frequent and longer outages. The 2025-2034 Comprehensive Reliability Plan, to be issued by the end of 2025, will provide further information regarding reliability risks over the next ten years.
New York City
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 that mandates shutdown of New York Power Authority peaking power plants by 2030. The Draft Energy Plan found that reliability considerations will prevent the shutdown of any of the peaking power plants for the foreseeable future.
There are 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.
In the 2023 Quarter 2 STAR, the NYISO 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”.
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 concluded these facilities are needed until Bulk Power Transmission Facilities (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 from generating stations 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. The future planned projects include:
• Gowanus-Greenwood 345/138 kV feeder – May 2026
• Champlain Hudson Power Express, 1,250 MW HVDC – May 2026
• Empire Wind, 816 MW offshore wind – July 2027
• Propel NY Public Policy Transmission Project – May 2030
The STAR goes on to explain that the NYISO analysis 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 there are 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. Specifically, Zone J may be deficient by 68 MW over 5 hours (871 MWh) in 2029, which grows to 148 MW over 6 hours (1,249 MWh) in 2030. Beyond 2030, these deficiencies are further exacerbated with increasing demand for electricity and the planned deactivation of the NYPA small plants.
Clearly, there are timing issues associated with retiring the peaking units, demonstrating that the planned power capabilities work, and nagging issues associated with increasing load and the potential that other generators may retire or break down.
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.
In my opinion,I think it is unlikely that in-kind replacements will be available by the May 1, 2029 deadline. Eventually another NYISO STAR report will make a similar finding and NYISO will recommend extending the operation of these units.
These are not the only NYC issues identified. The closure of these units would also affect the Lower Hudson Valley. The STAR also notes longer term concerns:
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. Specifically, Zone J may be deficient by 68 MW over 5 hours (871 MWh) in 2029, which grows to 148 MW over 6 hours (1,249 MWh) in 2030. Beyond 2030, these deficiencies are further exacerbated with increasing demand for electricity and the planned deactivation of the NYPA small plants.
The NYPA small peaking plants are state of the art, highly efficient, extremely low emissions, and only 27 years old. In my opinion shutting them down is not only virtue signaling but dangerous because of the reliability issues.
Will the political appointees who run DEC allow revisions to the DEC Peaker Rule? Will the politicians who passed Build Public Renewables Act of 2023 come to their senses when the deadline for those units comes up. Stay tuned.
Long Island
In this 2025 Quarter 3 STAR NYISO also described similar issues for generators on Long Island. The Pinelawn Power 1 (“Pinelawn”) and Far Rockaway Gas Turbine 1 and 2 (“Far Rockaway GTs”) completed their generator deactivation notices requiring the NYISO and LIPA determine if there are any generator deactivation reliability needs. The bulk system deficiencies are driven by the deactivation of Far Rockaway and Pinelawn generators (203 MW nameplate total) in combination with the same factors that affected the New York City units. NYISO explained:
This STAR finds that the BPTF in the Long Island locality (Zone K) is deficient, beginning in summer 2027 and continuing through the remaining five-year horizon, primarily driven by the deactivation of Pinelawn (82 MW nameplate) and the Far Rockaway GTs (121 MW nameplate total). In addition to the BPTF deficiency, LIPA also identified non-BPTF system deficiencies on the 69 kV system through the entire five-year horizon.
Once Sunrise Wind is delivering power as planned, the margins improve in summer 2028, followed by dramatic improvement in 2030 with the planned energization of the Propel NY project such that margins remain positive throughout the remainder of the planning horizon.
Like New York City the NYISO found:
In accordance with filed compliance plans for the DEC Peaker Rule, the Glenwood GT 3 and Shoreham 1 generators are assumed available until May 1, 2027 and unavailable thereafter. Additionally, the assumed capacity purchases from ISO New England into Zone K have been adjusted to account for a LIPA import of 288 MW from ISO-NE until April 2027, with zero flow scheduled thereafter. If these additional resources are available through the five-year horizon, the observed reliability need on the BTPF would be eliminated.
Discussion
This report deserves the attention that it has received but its results were treated differently by stakeholders. The American Public Power Association description exemplified industry takes on the results that simply expressed support for the highlights like I did here. In a statement, the New York State Building Congress called it a “wakeup call” and called for urgent action that “means building, not delaying, critical projects such as the Northeast Supply Enhancement project, expanding transmission, adding storage, and modernizing our generation fleet.”
On the other hand, Earth Justice ignored the conclusions saying that “Governor Hochul must accelerate transmission and battery storage to save New Yorkers money, not prop up expensive, polluting gas plants.” They claimed without evidence that “new battery storage can supply most or all the identified need, and more electric transmission (particularly into New York City) can solve longer-term issues.” Their press release blamed cancellation of transmission projects and stalled projects in the interconnection queue that “would have supplied New York with abundant, affordable, clean energy.”
I mention these differing thoughts about the STAR because I am uncomfortable about some aspects of the recommendations. I will follow up with another post that describes the unique reliability rules for New York City that I think were not fully addressed. I also want to look at the solutions and the underlying problem because I think there is a disconnect. Stay tuned.
Conclusion
If you ever wanted evidence that environmental organizations will never be happy and that they ignore experts when their results don’t fit their preconceived notions look no further than the Earth Justice response. The NYISO is responsible for keeping the lights on. Thomas Sowell has been quoted as saying: “It is hard to imagine a more stupid or more dangerous way of making decisions than by putting those decisions in the hands of people who pay no price for being wrong”. In this instance, there is nothing more stupid or dangerous than ignoring the people who will pay the price if there are problems with the electric system.
Pragmatic Environmentalist of New York 