The NYISO Operating Committee voted to approve the ISO’s draft Comprehensive Reliability Plan (CRP), though environmental groups and the Market Monitoring Unit voiced concerns with the wide range of predictions, the lack of identification of needed market changes and the potentially growing disconnect between other planning studies.

An early draft of the CRP, issued Oct. 7, called for “several thousand megawatts of new dispatchable generation by the 2030s,” based on a broad range of possible scenarios for load growth and supply. (See NYISO Reliability Plan Calls for ‘New Dispatchable Generation’.)

The newest draft, which will go before the Management Committee on Oct. 29, accounts for the third-quarter Short-Term Assessment of Reliability (STAR) and its identification of an immediate reliability need for New York City. (See related story, NYISO Again Identifies Reliability Need for NYC.) It was approved over the opposition of the Natural Resources Defense Council.

“The way this is all being presented in this reliability report is going to create great levels of alarm and confusion,” NRDC’s Chris Casey said at the committee’s meeting Oct. 16. “The technical experts understand it’s informational, but I don’t think it’s going to be interpreted that way.”

In a newly added sentence to the draft, the ISO acknowledges that, “as demonstrated by the study-by-study fluctuation in the system conditions and associated risks, the NYISO’s current approach in evaluating the reliability of the system is no longer sufficient for future planning studies.”

Casey argued that while the CRP talked up the importance of a strong market to meet reliability needs, parts of the report gave the impression that markets will not be able to solve the need. Some of the recommendations would exacerbate the disconnect between reliability studies and the Installed Reserve Margin on which prices are based, he said.

“Your point is really well taken,” said Ross Altman, senior manager of reliability planning for NYISO. “We need to discuss with stakeholders which specific range of forecasts or any of these factors we should consider an actionable reliability determination. What we are trying to say strongly is that it shouldn’t just be based on one. Combine that with the narrowing margins, and we are on a knife’s edge with every analysis we do.”

Much of the committee’s discussion centered on how to quantify reliability risks on the grid and how this would interact with existing planning processes.

“I definitely share some of the concerns that were shared by previous commenters,” said Pallas LeeVanSchaick, vice president at Potomac Economics, the grid operator’s MMU. He said NYISO’s analysis acknowledges a broad range of supply and demand outcomes but treats them as “random events.”

“The reality is the role of the market is to help moderate excess supply or insufficient supply,” LeeVanSchaick said. “The reality is when you look at the risks of aging generation and lack of supply, by far the biggest factors for those outcomes are not the age of the resources but a mix of environmental policies and market incentives for maintaining the generation and repairing significant failures.”

Liam Baker, senior vice president of regulatory affairs at Alpha Generation, weighed in as “the owner of the largest aging fleet.”

“When these things break … they break in such a manner that they need to be completely rebuilt,” Baker said. “The replacement parts we use nowadays are bespoke. We are … cannibalizing our existing fleet. … We are literally cannibalizing Gowanus 1 and 4 to keep Gowanus 2 and 3 and Narrows 1 and 2 running.”

Baker said NYISO was “wise” to highlight aging generation, but he wanted to make sure the ISO and other stakeholders understood how dire the situation was: Replacement parts for the plants often have to be custom made — or even purchased on eBay.

Matt Schwall, director of regulatory affairs for Alpha Generation, said this point was “critical.” The retirement dates for Gowanus and Narrows, which drove the reliability needs findings in the Q3 STAR, were not based solely on environmental rules, he said.

“We are proposing to retire these units because they are no longer economic to operate,” Schwall said. “There are other things driving generator retirements other than being unable to comply with state regulations.”