NYISO Weighs In On The New York State Draft Energy Plan

NYISO is the New York Independent System Operator — the not-for-profit entity created to manage New York State’s electrical grid. Their main job is assuring that there is sufficient electricity generated moment to moment to closely match customer demand. Neighboring states have multi-state ISOs (i.e., PJM and ISO-NE) to do the same job, but being New York, we have our own.

If there is any entity that ought to be loudly outspoken about New York’s ridiculous energy schemes, it is NYISO. After all, when generating most of our electricity from wind and sun proves not to work, as it will, and when the blackouts follow, as they will, NYISO stands to get a large share of the blame.

So where are they? The good news is that they are slowly waking up. The bad news is that even now they are not being nearly as outspoken or as loud as they should be. On October 6 they submitted a long (25 page) Comment on the State’s new Energy Plan. That Comment takes the level of their expressed alarm to a new, if still unjustifiably muted, level.

As background, in 2019 New York State enacted its Climate Leadership and Community Protection Act, mandating, among other things, 70% of electricity generation from “renewables” by 2030, and 100% from “zero emissions” sources by 2040. At the same time, New York City enacted its Local Law 97, mandating (via complex maximum emissions formulas) that most large buildings convert to electric heat by 2030. Supposedly, the State and City would enable fulfillment of these mandates through having developers construct large amounts of wind and solar generators. That process had barely gotten off the ground when, earlier this year, the federal government ended nearly all of the grants and subsidies that had made construction of wind and solar facilities at all feasible.

On July 25 the State’s Energy Planning Board came out with its self-described “Draft Energy Plan.” It’s a “draft” because they are taking comments, and may even make some revisions depending on those (don’t count on it). In a post on August 11 I described the so-called Plan as “hundreds of pages of fluff,” cheerleading for a supposed transition to a renewables-based electricity system, but lacking anything as basic as a feasibility study or a cost projection. I then submitted my own Comment on the Plan, and had a further post describing that on September 27. Key takeaway:

[T]he so-called “Energy Plan” is not an energy plan at all.  It would more accurately be described as random musings and wishful thinking by some completely incompetent people who have no idea what they are doing.

So with that background, let’s take a look at NYISO’s newly-issued Comment. This sentence from page 1 is fairly representative of the overall tone:

The NYISO submits these comments to highlight electric system reliability concerns and to offer approaches that support ongoing electric system reliability through competitive markets for consideration as part of the final State Energy Plan.

They are submitting comments to “highlight . . . concerns.” Yes, I guess so, but I find that a wholly inadequate statement of the problem. In fact, the energy bureaucracies are driving the State down an impossible path from which it becomes increasingly difficult to exit before disaster strikes.

This from pages 2-3 is a little stronger, but still much less specific than it needs to be:

Large energy-intensive economic development projects, such as semiconductor manufacturing plants and data centers, are driving up demand for electricity significantly after relatively flat demand trends over the last decade. Collectively, all these elements create uncertain conditions today, in the near term, and in the longer term, and each uncertainty has the real potential to cause major impacts on electric system reliability. All electric industry stakeholders, including the state agencies involved, must be aware of and factor these concerns into their planning and strategy. Progress towards the CLCPA goals, other public policies, and supplying the electricity that New Yorkers demand requires the State Energy Plan to support a well-functioning, reliable electric power sector. Reliable electric power is the foundation of the State’s plans to electrify other aspects of the economy and to reduce emissions. The NYISO urges the Board and NYSERDA to consider these comments and prioritize electric system reliability in the final State Energy Plan.

They just can’t make themselves say out loud that wind and solar by themselves cannot provide reliable electricity to match demand.

As you move through the Comment, the statements get stronger, little by little. From page 6:

Fossil-fuel-based generation is and will continue to be necessary to meet consumer demand and to maintain electric system reliability. The final State Energy Plan must include a recommendation consistent with the Draft Plan observations that combustion generating units “remain essential parts of electric grid reliability and affordability, and retirement of these units will not be able to occur until resources that provide the same grid reliability attributes are put in place.”

From page 8:

Simply maintaining the existing fossil-fuel-based generation fleet and carefully managing the requirement of these resources over the next fifteen years is not enough to maintain electric system reliability. The electric system needs all existing generation resources and needs new generation resources before the current fleet suffers a catastrophic failure that jeopardizes the health, safety, and welfare of New Yorkers.

“New generation resources” are needed, but the State’s Climate Act requires those to be carbon-emissions-free. We are therefore talking about the magical “dispatchable emissions-free resources” (DEFRs) that will supposedly replace fossil fuel generation to meet the requirements of the CLCPA. Can we somehow get ourselves to say that those don’t exist and are not going to exist in any relevant time frame? We come to a discussion of that subject on page 14:

The NYISO fully supports identifying and developing technologies that have the greatest potential to support electric system reliability and the needs that will arise throughout this energy transition. As noted in the Draft Plan, many of the technologies necessary to meet system needs for firm, dispatchable capacity are not yet commercially available at scale. The development of these technologies must start now as these technologies need to be proven and deployed to the electric grid before the resources that currently supply the energy that consumers demand and the reliability attributes needed to support the grid can be retired.

The DEFRs “are not yet commercially available at scale” and therefore “development . . . must start now.” How lame is that? They just can’t bring themselves to say that “you must admit that this is not going to happen.” With a mandate for tens of thousands of megawatts of these mythical generators by 2030, and it’s almost 2026, we haven’t even started “development.”

At least you don’t need to read between the lines of this Comment to see that the NYISO is issuing a very explicit warning to the State’s energy planners. But still, with the planners offering no idea as to feasibility, cost, or time frame for availability of necessary new resources to support the energy transition, the best the NYISO can say is to “start development now”? What they should be saying is that this can’t work, it won’t work, and continuing further down this path is incompetent, irresponsible, and dangerous.

Unlike the people at the other State energy bureaucracies like NYSERDA and the Energy Planning Board, I’m not saying that the people at NYISO lack competence. However, it is a problem that the entity is organized as a not-for-profit. Nobody there has any skin in the game, and they are unlikely to be held accountable when there are catastrophic system failures. It’s just one more instance of a failed socialist-lite model.