The NYISO Management Committee voted to approve the ISO’s 2025-2034 Comprehensive Reliability Plan, though stakeholders and the Market Monitoring Unit again voiced concerns with how it is structuring its planning.
The Natural Resources Defense Council voted against the plan at the committee’s meeting Oct. 29, while Energy Spectrum, the New York Utility Intervention Unit, Multiple Intervenors and New York City abstained.
The biennial CRP looks ahead 10 years to plan for long-term reliability. The latest plan did not identify a specific actionable reliability need but said that “New York’s electrical system faces an era of profound reliability challenges” and called for several thousand megawatts of additional dispatchable generation. (See NYISO Reliability Plan Calls for ‘New Dispatchable Generation’.)
It calls for looking at a wider range of scenarios for transmission planning and relying less on emergency measures for maintaining resource adequacy. Ross Altman, senior manager of reliability planning for NYISO, said implementing the plan could require manual and tariff changes.
“You want to consider a range of potential forecasts coupled with your ability to go ahead and procure through solicitation resources to meet whatever potential gap is in necessary resources,” said Howard Fromer, director of regulatory affairs for Bayonne Energy Center. “What do you propose to do about aligning our markets so that they are going out and procuring resources that are consistent with your reliability needs through your planning process?”
“I don’t have anything for you today because this is the beginning of the road,” Altman said. “What we actually plan for requires additional conversations in the next months.”
Altman said staff took Fromer’s point very seriously and that aligning markets with reliability planning was something the ISO was actively working on.
“My expectation is that you would want to conduct the [upcoming] Reliability Needs Assessment [RNA] with the new structure,” said Doreen Saia, chair of the energy and natural resources practice for Greenberg Traurig. She said this would require very fast action from NYISO and its stakeholder committees and asked the ISO to create a public schedule quickly. “Transparency is important. Notice is important.”
Zach Smith, NYISO vice president of system and resource planning, thanked Saia for pointing this out but cautioned that the ISO was not sure that tariff revisions were needed. If they were, the ISO would need to be mindful of the tight timeline to get revisions filed before the next RNA.
“I want to push back on the idea that we can commence the RNA without understanding how NYISO is going to determine actionable reliability,” the NRDC’s Chris Casey said. “The assumption that the ISO is planning to use different scenarios gets colored differently if those scenarios are informational versus actionable.”
“I actually fully agree with you,” Altman replied. He said the broad range of scenarios the ISO had previously shown was intended to illustrate what it had to account for. “The actual implementation of that, and the assumptions that will go into the RNA, will be very detailed.”
Casey pointed to a graph in the CRP that showed the state hitting a 4,000-MW shortfall and compared it to a more detailed slice of the same data. He said the ISO was overemphasizing the worst-case scenarios and that those scenarios did not have a sufficient basis to justify centering them.
Altman said these weren’t actually the worst cases and that staff actually excluded several outliers that assumed nuclear plants would not get relicensed. As the process continued, stakeholder feedback would be used to “find the balance.”
A representative from Earthjustice said that amid all the discussion of schedules and changes to the markets, they had not heard any evidence from NYISO that the changes it was presenting were necessary. They asked if the ISO had called in independent consultants to look at the changes to the reliability planning process to see if they made sense.
“I would strongly encourage the consideration of this before there’s this dramatic shift in the way the markets are planned and the way that reliability planning occurs,” they said.
The MMU said it was concerned that there is a growing gap between planning and the markets.
“We’ve been seeing that open up in the past couple of years, and I think it’s a concern because it’s going to provide the wrong incentive,” said Pallas LeeVanSchaick, vice president of Potomac Economics. He said that gap undermines the market’s ability to maintain reliability. It could also result in the ISO keeping more capacity than is needed to meet the needs of the system.
The CRP now goes before the Board of Directors, which is expected to pass it before the end of November. Discussions over the proposed planning process changes would then begin in December.
