New York’s ambitious carbon reduction goals have left the state at risk of blackouts or reliability gaps, the New York Independent System Operator (NYISO) has warned, unless regulators take steps to ensure that “flexible, long-duration, and controllable” assets, including natural gas and conventional generators, stay online.
In comments filed with the New York State Climate Action Council, NYISO made the case that achieving the state’s energy transition goals should not come at the expense of reliability and cautioned against abandoning conventional generation assets too quickly.
“Decarbonization of the electric system in the state by simply deactivating existing generation without having in place resources capable of providing comparable reliability services would risk the reliability of the electric system,” NYISO warned in the filing.
NYISO’s comments were filed as New York’s Climate Action Council examines a draft scoping plan that will guide the state toward meeting the goals of the Climate Leadership and Community Protection Act (CLCPA), which directs the state to achieve 70 percent renewable energy by 2030 and 100 percent emissions-free electricity by 2040.
While supporting the state’s goals, NYISO maintains that completely abandoning fossil fuels in the next few years will harm grid customers—especially during periods of bad weather, which could threaten transmission lines or reduce renewable generation output.
The energy transition must be done “gradually and safely,” said Executive VP of NYISO, Emilie Nelson.
“As we move to a zero-emissions grid, it is critical that we understand how the growth of intermittent resources and extreme weather could impact the ability to maintain reliability of the New York bulk electric system.”
It is vital to maintain excess generation capacity in order to meet surges in demand and ensure continued reliability in a changing system. The current pressure to close natural gas or fossil fuel generation plants threatens those margins, and the risk of blackouts and outages looms closer with that pressure. Having backup resources available while in the process of retiring existing generation will provide the needed reliability during the transition. Furthermore, having the new resources available before the current generation fleet is retired is imperative to maintaining reliability.
Since the passage of the CLCPA in 2019, power generation sources are retiring more quickly than new resources are being added to the system and, according to NYISO, the system is quickly approaching a point where new renewable generation capacity must be built before any existing fossil fuel generators can retire.
“A diverse resource mix that integrates sufficient levels of predictable, reliable, and dispatchable generators currently promotes grid resilience and minimizes the risk of power disruptions,” NYISO states in the filing.
“This resilience is increasingly important as extreme weather conditions place power systems across the nation at risk of not reliably serving electricity customers.”
Though reliability is a top concern for consumers, NYISO also expressed concern about energy transition costs and urged a technology-neutral regulatory approach where “all technologies that can support the system needs” participate freely in capacity markets.
NYISO notes that it has already made changes to its market system to promote the increased adoption and integration of renewables into the market. However, because these changes were well designed, they did not come at the cost of overall system reliability.
And it should be the goal of state regulators to achieve something similar. According to NYISO’s remarks, the best way of achieving this will be to adopt market-based approaches like those already used in capacity markets.
“Capacity markets provide and will need to continue to provide an additional revenue stream to support adequate investment to maintain the required levels of resource adequacy,” NYISO wrote. “As the fleet transforms and new challenges emerge, ongoing efforts will be needed to ensure that together the energy, ancillary service, and capacity market designs continue to support adequate investment.”
As is the case throughout the rest of the country, the process of the energy transition in New York is ongoing. While the generators that participate in NYISO have already achieved an impressive buildout of renewable power resources, partnership between stakeholders, regulators, and ISOs is needed for continued success. The comments that NYISO made about New York’s plan will likely prove to be good advice for regulators in other states in the future.
