Are New York's Energy Planners Planning to Fail? It Sure Looks Like It As They Bull Ahead with Plans That Cannot Work.

Guest Post by Roger Caiazza of Pragmatic Environmentalist of New York.

Recently the New York Independent System Operator (NYISO) released Power Trends 2025. This is the NYISO’s annual analysis of factors influencing New York State’s power grid and wholesale electricity markets. This post highlights some of the key points made.

New York State Public Service Law, Section 66-P Establishment of a renewable energy program, requires the Public Service Commission establish a program to meet the interim targets for 70% of the energy delivered in 2030 “shall be generated by renewable energy systems” and that “by the year two thousand forty the statewide electrical demand system will be zero emissions”.

The Power Trends Resources landing page provides documentation and links to the Power Trends 2025 report itself, and a Power Trends Fact Sheet. The Fact Sheet describes the report and summarizes the findings:

Power Trends explores the issues and challenges shaping the grid of the future based on the latest economic data, forecasts of peak demand and changing generation mix. Our 2025 report underscores the heightened uncertainty of future system conditions and key assumptions such as population and economic growth, installation of behind-the-meter renewable resources, electric vehicle adoption and charging patterns. Specifically, the impact on the load forecast of several energy-intensive economic development projects, such as data centers and semiconductor manufacturing, provides additional forecasting and planning challenges.

I have summarized the key points made in the Fact Sheet, the Power Trends report and the press release, offering my comments.

Reliability Margins

The Fact Sheet, Power Trends Report, and Press Release emphasize the concern about declining reliability margins. The Press Release explains:

Generator deactivations are outpacing new supply additions. Electrification programs and new large-load customers associated with economic development initiatives are pushing projected demand higher. Together, these forces are also narrowing reliability margins across New York and increasing the risk of future reliability needs.

Recent Power Trend reports have included the declining reliability margins issue. The following figure shows last year’s status compared to this year. The decline in margin is mostly because fossil units are retiring faster than zero emissions replacements are coming on-line.

Fossil Plants

All three NYISO documents note that the average age of the fossil fleet is increasing. They also point out the advantages of modernizing old fossil facilities. The Press Release explains:

Repowering aging power plants can lower emissions, meet rising consumer demand, and provide reliability benefits to the grid that are needed to integrate additional clean energy resources.

The declining margin and the age of the fossil plants reflects a lack of foresight by the New York Department of Environmental Conservation (DEC) who has been pressuring existing power plants to reduce emissions or shut down.

Power Trends states that: “Repowering aging power plants can lower emissions, meet rising consumer demand, and provide reliability benefits to the grid that are needed to integrate additional clean energy resources.” DEC has rejected several repowering applications to replace existing old generators with modern new facilities because of the Climate Act. Unfortunately, there is no direct link between the proposed facilities and a particular reliability issue, so DEC rejected the applications.

This is an example of poor New York energy planning – the permit decisions were considered in isolation not in the context of the system. While I applaud the fact that this is a recommendation of Power Trends, it is also fair to ask why the NYISO did not intervene in the repowering applications.

New Load Growth

Future reliability margins will also be affected by new load growth. The Fact Sheet and Report note that “New high-tech, AI and data center projects are having an impact on future electric demand and load growth”. Figure 1 from the Report notes that 2,567 MW of new load capacity is needed by 2035 and the document notes that other projects could add around 1,900 MW of capacity after that.

I am disappointed that the NYISO Report did not mention that these new load centers require constant energy and clean power that is free from electrical noise, surges, voltage spikes, and drops which exacerbates the challenge of the Public Service Law Section 66-P “Establishment of a renewable energy program” requirements.

Winter Shift

The three NYISO documents all note that the peak loads are projected to shift to the winter from the summer. The Press Release notes that:

New York is projected to become a winter-peaking electric system by the 2040s, driven primarily by electrification of space heating and transportation. On the coldest days, the availability of natural gas for power generation can be limited, and interruptions to natural gas supply will introduce further challenges for reliable electric grid operations.

There is another unmentioned issue with winter peaking. When the Public Service Law Section 66-P “Establishment of a renewable energy program” electric system that relies on wind and solar generating resources is in place, the winter solar availability is much lower than in the summer. This is another challenge that I think the Power Trends report should have acknowledged.

Competitive Market

The Fact Sheet, Power Trends Report, and Press Release all extoll the power of competitive markets to support the transition while maintaining reliability and minimizing consumer costs. The NYISO is a product of the de-regulated competitive market. The report explains that:

“We are committed to administering and overseeing the competitive electricity markets as the most cost-effective way to attract and retain new resources to meet our reliability needs as we transition to a decarbonized grid.”

I do not share their optimistic outlook for the ability to attract and retain new resources. At this time, it is not clear what kind of resources and how much of those resources are needed, so the presumption that they can design a market to attract those resources is questionable.

Interconnection Process

The three NYISO documents all note that there are interconnection issues. The Press Release states:

New supply, load, and transmission projects are seeking to interconnect to the grid at record levels. NYISO’s interconnection processes continue to evolve to balance developer flexibility with the need to manage the process to more stringent timeframes.

This is an issue that is directly within the purview of NYISO, and it is a problem. Power Trends describes proposed modifications to the process but does not acknowledge that there are fundamental issues.

Many of the new projects are inverter-based resources and integrating this new category of resources is problematic for grid stability and reliability. Regulatory frameworks are under development to address this problem, and this has contributed to the interconnection delays.

Discussion

The Climate Act was promulgated without consideration of feasibility. Nowhere is this more impactful than with respect to the schedule. A rational New York energy plan would implement the zero-emission resources before retiring existing generating resources. New York is not rational. Despite the obvious delays in construction of new supply and transmission due to a whole host is issues the Hochul Administration has not broached the possibility of postponing any Climate Act targets.

The current Climate Act implementation plans appears to just be a matter of building as many zero-emissions resources as possible as soon as possible. These reliability planning reports indirectly affect the implementation schedule. The process identifies specific issues which triggers a procedure to address them. All that takes time. Coupled with the interconnection process it is no wonder that deployments are lagging behind the Scoping Plan schedule.

In my opinion the biggest reliability challenge for the Public Service Las Section 66-P “Establishment of a renewable energy program” is the necessity of a new category of electric system support technology that can be reliably dispatched to provide both energy and capacity over long durations with no emissions.

NYISO calls this resource the Dispatchable Emissions-Free Resource (DEFR). They are “crucial for meeting energy demands when intermittent renewable sources like solar and wind are unavailable.” The challenge is we don’t know what will work and we don’t know how much is needed because an analysis of potential renewable resource availability using the longest duration dataset available has not been completed.

I think NYISO has become more forthcoming about the Climate Act issues in this edition of the report. I am still disappointed with the NYISO for several reasons. In the first place, it is still necessary to read between the lines in all their reports to understand that they know there are enormous challenges associated with the transition to a renewable energy electric system. I think that is a disservice to the residents of New York. A truly independent agency should explicitly describe the reliability and affordability difficulties facing the electric system without holding back.

I am also disappointed that the Power Trends document did not describe specific issues with the key points presented. As noted above, this edition of Power Trends does not acknowledge challenges associated with the need for clean and reliable electric energy for proposed new load centers, fossil retirements and repowering policies, weather-related complications associated with the shift to winter peaking, interconnection feasibility concerns, and DEFR

Finally, I wish that NYISO would be more assertive in New York energy policy matters. It is understandable given the bully-tactics of the Cuomo Administration but New York State needs to hear from the experts. Power Trends notes that we need to do repowering, but NYISO did not intercede directly to advocate for repowering applications that were rejected.

Conclusion

The following conclusion is identical to last year’s summary here because nothing has changed.

The Power Trends 2025 report provides an excellent overview of New York State’s power grid and wholesale electricity markets. Unfortunately, NYISO does not consolidate all the warning signs about Climate Act implementation, nor does it call out state policies that are exacerbating problems.

Ultimately the problem is that New York has no comprehensive energy plan. The Scoping Plan is just a list of technologies that describe an electric system that is zero-emissions. However, there is no feasibility study that shows how it will work nor has the Hochul Administration reconciled the differences between the Scoping Plan and NYISO resource outlooks.

As it stands now, the Administration plan is to build as many wind and solar facilities as possible and hope someone works out how they are supposed to be integrated into the electric system. When that does not work, I predict the NYISO will be blamed.

The only way to ensure the safety of New Yorkers is to do a demonstration project that proves that an electric system that relies on wind and solar energy will work. A poor second choice would be a comprehensive feasibility analysis that reconciles the Integration Analysis and NYISO analyses.

Failing to do either is planning to fail.

#NewYork #ClimateAct #Renewables #Subsidies #NYISO #NYSERDA #PowerTrends2025

Roger Caiazza blogs on New York energy and environmental issues at Pragmatic Environmentalist of New York. This post represents his opinion alone and not the opinion of his previous employers or any other company with which he has been associated. Roger has followed the Climate Leadership & Community Protection Act(Climate Act) since it was first proposed, submitted comments on the Climate Act implementation plan, and has written over 500 articles about New York’s net-zero transition.