Category: NYISO Reports

Implications of the NYISO 2025-2044 System & Resource Outlook

The New York Independent System Operator (NYISO) has released its 2025-2044 System & Resource Outlook (Outlook).  It’s a long-term planning assessment that finds New York will need “substantial new investment in reliable generation and transmission infrastructure to serve growing electricity demand and state policy targets.”  The report supports my contention that the rapid electric system transition to a zero‑emissions grid mandated by New York politicians is technically and institutionally constrained, and that reliability can be put at risk if policy timelines outrun feasible infrastructure and resource development.

I am convinced that implementation of the 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 risks, unacceptable costs, and adverse environmental impacts.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 650 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.  I acknowledge the use of Perplexity AI to generate summaries and references included in this document. 

Background

The NYISO is responsible for electric resource planning for New York State.  The Comprehensive System Planning Process (CSPP) consists of four components: the Local Transmission Planning Process (LTPP), the Reliability Planning Process (RPP), the Economic Planning Process, and the Public Policy Transmission Planning Process. My particular interest is the RPP.

Last December a NYISO update on the CSPP described the Reliability Planning Process.  It is a two‑year process that starts in even years and has two components. The Reliability Needs Assessment (RNA) “evaluates the adequacy and security of the Bulk Power Transmission Facilities (BPTF)

over a seven-year Study Period (years four through ten of the next ten years) and identifies Reliability Needs defined as violations of Reliability Criteria” established by regulatory authorities.  The second component is the System & Resource Outlook that is developed in the years between RNA.s  It includes the following:

  • 20-year study of system and congestion
  • Identifies, ranks, and groups congested elements
  • Assesses the potential benefits of addressing the identified congestion
  • Provides information to developers and marketplace regarding future challenges in the New York power system

The current analysis covers 2025 to 2044, so it must consider the transition requirements of the Climate Act.  NYISO’s long‑term scenarios show that reaching very high levels of zero‑emissions generation is a serious challenge.  This post is an overview of the Outlook emphasizing key insights and recommendations.

NYISO Summary and Key Findings

The press release provides a good overview of the Outlook.

The Outlook is a scenario-based planning study intended to help policymakers, regulators, market participants, and developers understand how different policy choices can shape New York’s future resource mix, transmission needs, system costs, and reliability risks over the next 20 years.

Key findings from the Outlook include:

  • New York’s electricity demand is expected to grow over the next two decades, driven by electrification and emerging large loads that increase total energy needs and reshape when and where demand occurs.
  • All scenarios require significant new generation, and policy-driven scenarios require far more installed capacity than exists today to reliably meet demand.
  • Transmission capability is increasingly central to system performance, public policy achievement, congestion reduction, and the ability of new resources to serve consumers.
  • The Outlook also shows that the final increments of emissions reductions carry the greatest infrastructure challenges. Scenarios that move from 95 percent to 100 percent emissions-free electricity require substantially more investment in replacement resources and anticipate technologies not yet available at commercial scale. By comparison, other scenarios that also lower emissions significantly do so with much lesser investment in generation and transmission.

These analyses compare alternate projections of policy mandates against a business as usual or base case.  NYISO describes the modeling scenarios:

The Outlook is structured around three groups of scenarios that represent the various futures evaluated in the Outlook. The Base Case is a reference future that aligns with the NYISO’s Reliability Planning Process assumptions1 to define the load, generation, and transmission assumptions. The Contract Case builds on the Base Case by adding generation projects with financial commitments (e.g., NYSERDA and offshore wind REC contracts) and approved transmission projects, as well as incorporating projected fossil retirements, to evaluate near-term system conditions as renewables come online and aging thermal units exit. The Policy Case, which includes eighteen scenarios, reflects relevant state policy targets by modeling pathways to meet (existing or delayed) targets like 70% renewables and 100% zero-emissions electricity and evaluates alternative resource mixes—including potential new nuclear and/or fossil—to assess progress toward policy achievement and resulting system conditions.

The Outlook selects two core policy scenarios for detailed production‑cost analysis: one “Higher” pathway that reaches a fully zero‑emissions grid by 2044 and one “Baseline/Policy‑limited” pathway that only achieves roughly mid‑90s percent zero‑emissions by 2044.

Resource Planning

My primary Climate Act implementation concern is the disconnect between the naïve presumption of Climate Act authors that the zero emissions electric system transition was only a matter of political will because the technical, logistical, and economic challenges were small and the reality that those challenges are enormous.  I do concede that at the time the Climate Act was written there was no expectation of significant load growth but that is only one aspect of the problem  The Outlook outlines the real challenges and the approach:

Meeting New York’s future electricity needs will require a significant transformation of the generation fleet, driven by rising demand, evolving policy requirements, and the retirement of existing fossil generation. As conditions evolve, ensuring that sufficient energy and capacity resources are available to serve load becomes increasingly complex. In particular, tradeoffs emerge between the pace, scale, and timing of new resource development, the types of resources available, and the ability of those resources to meet both energy needs and firm capacity requirements across the system.

To explore these dynamics, the Outlook evaluates a range of potential resource pathways that reflect differing assumptions about policy achievement, development pace, and system conditions. These scenarios are not intended to predict a single outcome but rather to illustrate how different combinations of demand, policy, and resource availability can produce materially different system outcomes—and to highlight the implications of those differences for future grid planning.

NYISO explicitly uses alternative futures (including “Higher Demand” and scenarios with advanced nuclear) to highlight that different combinations of resources can hit similar CO₂ outcomes but with very different reliability and feasibility profiles. That is an important distinction.  The statute and agency rhetoric treat “100% zero emissions” as a single, deterministic path in their plans.  In practice resource mix and infrastructure choices matter enormously.

Resource adequacy and reliability risk

The Outlook focuses heavily on resource adequacy through 2044 and shows that preserving reliability under Climate Act‑consistent trajectories depends on how quickly firm capacity is replaced as fossil units retire. NYISO’s analysis indicates that without sufficient dispatchable zero‑emissions resources and/or substantial new nuclear or long‑duration storage, the system faces tighter margins and greater risk, especially under higher load or stressed conditions.

NYISO also examines scenarios where demand is higher and weather or electrification trends deviate from planning baselines, and under those cases the resource and infrastructure requirements to keep reliability within criteria become much more challenging. A long‑standing theme of this blog is that “electrify everything” plus aggressive fossil retirements is a reliability problem, not merely an emissions accounting problem.  Electric systems must be built around reliability during peak demand.  One of my primary concerns with the Climate Act renewable energy mandates is weather variability because the conditions that characterize the highest loads also have the weakest expected wind resource availability.  The Hochul Administration’s planning has emphasized central forecasts and has yet to grapple with the specific challenges associated with extreme cases.

Limits of “100% zero emissions” portfolios

The document notes that alternate scenarios can achieve CO₂ reductions comparable to “100% zero emissions” portfolios while using different mixes of nuclear, storage, and renewables. NYISO explicitly discusses an “Alternate” path and advanced nuclear build‑out with up to 5 GW, limited to Zones A, B, C, and E (Figure 1) as ways to provide firm, clean capacity that ease system stress compared to strictly constrained portfolios.

Figure 1: NYISO New York Control Area Load Zones

Source: NYISO 2025-2044 System & Resource Outlook

Those scenario results essentially validate my arguments that insisting on specific technologies (or excluding others) is a policy choice layered on top of the emissions objective, and that some technology‑constrained paths are significantly more brittle from a reliability and cost perspective. The Outlook’s willingness to model advanced nuclear as a serious resource option contrasts with the Climate Act mandate and lends technical credibility to my arguments about the need for firm zero‑emissions capacity beyond intermittent renewables.

The Outlook finds that “policy design significantly impacts the scale of new resource development”.  For example. “Outlook scenarios without clean energy targets require approximately ~10–35 GW, scenarios with relaxed or partial zero-emissions scenarios require ~30–60 GW, and scenarios targeting a fully zero-emissions system require substantially higher additions— approaching ~105 GW of new resources by 2044 under higher demand conditions.  The difference in costs for all the new resources necessary for zero emissions versus costs for the relaxed emission scenarios relative to the differences in emissions should be an energy policy discussion point.  Furthermore, relaxed emission scenarios eliminate the need for developing hydrogen-fueled generation capacity and infrastructure development that the Outlook estimates at upwards of 30 GW.

Infrastructure, siting, and transmission constraints

NYISO’s long‑range analysis implicitly underscores how much new transmission and bulk infrastructure is required to move large quantities of upstate renewable and nuclear output to downstate loads, and to integrate storage at scale. The scenarios with substantial new nuclear and renewables in upstate zones make clear that geography, siting limits, and zonal restrictions are binding constraints, not footnotes.

By identifying zonal limits NYISO is effectively quantifying some of the siting and societal impacts that disproportionately impact Upstate New York. The Outlook notes:

Downstate capacity requirements continue to shape where firm resources are needed. Because the highest and most constrained load centers remain in downstate New York, locational capacity requirements continue to drive firm and dispatchable resources near those areas. Even in futures with substantial upstate renewable development, additional firm capacity is often needed closer to load centers to satisfy capacity requirements that cannot be met through statewide totals alone.

Resource availability assumptions create a persistent tension between where clean energy is most developable and where it is most needed. Land-based wind and utility-scale solar are more available in upstate zones, while demand remains concentrated downstate. This creates a recurring planning challenge. The system may have strong opportunities to add clean energy where development potential is greatest, but it still requires transmission capability and additional downstate resources to ensure that energy and capacity can serve load.

This supports my concerns that Climate Act implementation treats land use, transmission corridors, and community opposition as solvable details, whereas the system modeling shows they materially shape feasible resource portfolios.

Recommendations

NYISO finds that growing demand and planned fossil retirements mean the system needs “substantial new investment in reliable generation and transmission infrastructure” across all futures. They recommend prioritizing timely development of new resources, especially in policy driven scenarios that require much more installed capacity than exists today.

A central recommendation is to “establish a viable path for the development of resources capable of providing firm capacity and operational flexibility as the generation mix evolves,” explicitly recognizing the need for dispatchable, firm resources even in highly decarbonized futures. NYISO also calls for coordinating the timing of resource additions, repowering, and retirements to reduce transition risk and avoid tightening system conditions during the Climate Act transition.

On the transmission side, the Outlook urges targeted enhancements to increase transfer capability across the Central East interface (e.g., dynamic voltage support) and bulk transmission upgrades to support zero emissions generation development in Northern New York. These are framed as necessary to reduce congestion, improve deliverability, and allow new renewables and firm resources to actually serve downstate load.

Conclusion

The NYISO recommendations address my concerns that: (1) reliability requires firm capacity (DEFRs or equivalent), not just wind/solar/storage; (2) the timing of retirements versus new builds is critical; and (3) transmission constraints are central to Climate Act implementation feasibility, and (4) it is long past time that a feasibility analysis be completed to define New York’s energy future. NYISO’s call for “a viable path” for firm resources and its acknowledgment that policy driven zero emissions futures demand far more capacity than today are similar to my warnings about the DEFR gap and the risk of retiring peakers without firm backup.  Until Climate Act implementation policy aligns with the NYISO Outlook the risks of reliability problems is a serious concern.  The difference in costs for all the new resources necessary for zero emissions versus costs for the relaxed emission scenarios relative to the differences in emissions for the two approaches should be an energy policy discussion point.

NYISO 2026 Power Trends – Reality is Catching Up

The New York Independent System Operator (NYISO) prepares an annual report on “forces shaping the electric grid and wholesale electricity markets.”  NYISO’s Power Trends 2026 is a notable document because it says many of the right things, even if it still does not say them quite as bluntly as the situation deserves. The report acknowledges that electrification, large new energy-intensive loads, retirement of conventional resources, and weather-dependent generation are combining to make the system more uncertain and more fragile. It also says reliability margins are shrinking and that winter conditions are becoming a defining challenge. That is an important step forward, but it is also an implicit admission that the Climate Leadership & Community Protection Act (Climate Act) implementation process has been pushing the grid toward a level of risk that the state has not honestly grappled with.

I have written over 650 articles about the Climate Act and I am convinced that implementation of the 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.  The opinions expressed in this post and in my filing do not reflect the position of any of my previous employers or any other organization with which I have been associated; these comments are mine alone.  I acknowledge the use of Perplexity AI to outline this post and draft the text used in this document. 

Power Trends 2026

The Executive Summary states:

Power Trends explores the issues shaping New York’s electric system as it undergoes a historic transformation driven by simultaneous changes in supply, demand, and infrastructure.

The report highlights increasing and more uncertain electricity demand, a changing generation mix, and a system that is more geographically dispersed, weather‑dependent, and operationally complex. Maintaining reliability depends on disciplined planning, timely investment, and market structures that align investment with system needs and value operational performance during stressed conditions.

NYISO provides the report, a key trends fact sheet, a note from the NYISO president and CEO, and report figures and resources.

Key Findings

The report highlights five big trends: declining reliability margins, rapid and uncertain load growth, shifting seasonal risks, a changing resource mix, and expanding system uncertainty. That is a polite way of saying the grid is getting harder to run while the policy environment keeps adding complexity. NYISO is also explicit that the system needs generation, storage, transmission, and demand-side solutions that can perform during extended periods of high demand.

The press release makes one point especially clear: NYISO wants an “all-of-the-above” investment approach supported by competitive markets. In plain English, that means New York cannot afford to bet the system on a single preferred technology or an aspiration about how fast a transformation will happen. It needs resources that are available when needed, not just resources that look good in a policy presentation.

Where this fits my concerns

My long-running concern with Climate Act implementation has been that the process has treated emissions targets as if they were operational plans. The result has been an unfortunate habit of confusing policy preference with system capability. NYISO’s report does not use that language, but it does describe the consequences: less margin for error, greater weather dependence, more uncertainty, and increasing pressure on winter operations.

That is exactly the kind of caution that should have been part of the implementation process from the beginning. Instead, the state has often acted as though the answer to every reliability question was “more renewables, more quickly,” with insufficient attention to the timing and performance of the resources that keep the lights on. NYISO now says the system needs disciplined planning and timely investment, which is a far cry from the casual optimism that has often accompanied Climate Act roll-out discussions.  I remain concerned that there still are unresolved differences between the New York State Energy Research & Development Authority (NYSERDA) implementation descriptions of the transition in the Scoping Plan and the State Energy Plan and NYISO planning reports.

The report also reinforces a point that has been obvious for years: load growth is not a static assumption anymore. Electrification, data centers, and other large projects are changing demand in ways that can swamp neat planning narratives. The idea that energy efficiency and energy conservation efforts will prevent load growth is also no longer valid.  That means the state’s implementation process should be more conservative, not less, because uncertainty is rising on both the supply and demand sides.

Not so Independent NYISO

One reason NYISO’s documents are often carefully crafted to not contradict NYSERDA’s transition planning documents is that they must operate in a political environment where outright candor can be punished. That does not mean the report is wrong; it means the language is often muted. In my view, that restraint is not accidental. It reflects years of pressure on NYISO to avoid sounding too skeptical about the transition path the state has chosen.

“Energy Czar” Richard Kauffman’s role in that pressure campaign should not be forgotten. In 2016 NYISO filed comments with the state saying its goal to power the state with 50 percent renewable energy by 2030 was unrealistic unless a massive investment in new transmission lines were undertaken.  Kauffman sent a letter saying it was misleading, incomplete, and grossly inaccurate.  Even though the NYISO filing has since proven to be correct NYISO has every incentive to soften language that might be interpreted as resistance. I believe that dynamic has contributed to NYISO documents pulling their punches when discussing the risks of the zero-emissions transition and the practical limits of the Climate Act pathway.

That matters because the public needs more than carefully crafted phrases about “uncertainty” and “scenario-based planning.” It needs a frank explanation that the current policy path creates real reliability risks unless the state changes course on pace, technology assumptions, and resource adequacy. NYISO is getting closer to that point, but it is still speaking in institutional code.

What the report gets right

To NYISO’s credit, Power Trends 2026 is not a celebratory document. It acknowledges declining reliability margins and says retirements and performance problems are outpacing additions to supply. It recognizes that winter is becoming a defining reliability season. It also states that a diverse resource mix is necessary, including generation, storage, transmission, and demand-side measures.

That is a welcome correction to the oversimplified narrative that has dominated much of Albany’s energy policymaking. The report’s emphasis on competitive wholesale markets is also important because markets are where resource adequacy should be tested in practice, not in press releases. If policymakers want reliable electricity, they should listen carefully when the grid operator says performance under stress matters.  It would also be appropriate for the press to qualify any transition story lauding renewables with the concerns described in this report.

What it leaves unsaid

Even so, the report still avoids saying the most uncomfortable thing plainly: Climate Act implementation has been moving faster in policy than in infrastructure. That gap is the heart of the problem. You can mandate a future, but you cannot mandate transmission buildout, generator construction, interconnection readiness, or seasonal fuel security on a slogan-driven schedule. This means that the transition schedule must be reconsidered.

The report also does not dwell on the institutional failure implied by repeated assurances that the transition is manageable without significant tradeoffs. NYISO is now warning that the system’s margin for error is shrinking. That should be read as a warning not just about the grid, but about the policy process that created these pressures in the first place.

A better reading of the outlook

The right takeaway from Power Trends 2026 is not that New York should abandon decarbonization. It is that the future electric system must be treated as an engineering problem, not a moral assertion. Reliability, affordability, and emissions all matter, but they do not obey the same timeline, and they certainly do not respond well to wishful thinking.

Nowhere is this more evident than the undeniable need for Dispatchable Emissions-Free Resources (DEFR). Power Trends 2026 defines this as:

 A resource designed to provide reliable, on-demand electricity without emitting carbon. Unlike intermittent renewable sources like wind and solar, DEFRs can be dispatched as needed to meet demand. Many of the potential technologies are still in development and may face challenges in terms of economic viability and scalability

My concern is that DEFR is indispensable for a wind an solar dependent system, yet there is still no concrete plan to commercialize and deploy any DEFR technology at the scale required. Significant technical, economic, and regulatory uncertainties remain for all proposed DEFR options, so assuming a viable solution will simply emerge when needed amounts to taking an extraordinary reliability risk with the bulk power system.  If nuclear ultimately proves to be the only practical DEFR candidate, then a grid architecture centered on wind, solar, and short duration storage cannot be implemented reliably without large scale nuclear generation. However, nuclear power is best suited to continuous, high-capacity factor operation, so holding it in reserve as an infrequently used DEFR “backup” misuses the technology and wastes its economic advantages.  This problem should be resolved sooner than later.

If the Climate Act implementation process is to become credible, it needs a more honest accounting of resource availability, winter performance, the lead times for transmission and generation, and DEFR technology. NYISO’s latest outlook is useful because it points in that direction, even if cautiously. The report should be read as a signal that reality is asserting itself over rhetoric.

Conclusion

The most important thing about Power Trends 2026 is that it reflects a system under stress and a planning environment that has grown much more complicated than policymakers seem willing to admit. NYISO is telling us that New York needs a broad, reliable, market-based resource buildout, not a narrow ideology dressed up as planning. That is exactly the direction the state should have taken from the start. Instead, it is now being forced to catch up with the consequences of the flawed Climate Act and State Energy Plan implementation process. New York policy has talked as though ambitious emissions targets could be translated into real-world electric system performance simply by declaring them so. NYISO’s latest power trends report is a reminder that physics, infrastructure lead times, fuel availability, and operating reserves do not care about slogans.

NYISO Short-Term Assessment of Reliability October 2025 – Overview

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.