New NYISO Report Could Lead to Higher Energy Bills and More Dirty Energy

ALBANY, NY (11/21/2025) (readMedia)-- Today, the New York Independent System Operator (NYISO) put out its Comprehensive Reliability Plan (CRP) for 2025-2034. The CRP should be an informative resource for stakeholders and policymakers. But it takes an unrigorous approach that, if taken at face value, could lead to higher energy bills and further spending on unreliable and unnecessary dirty energy, with harmful consequences to New Yorkers' lives and livelihoods. Earthjustice is clarifying the record and sounding the alarm about the dangerous and expensive implications if NYISO's report is used to guide planning, market, regulatory, and legislative decisions.

The CRP fails to provide support for its claims about projected energy shortfalls. Much of the content in its executive summary is not backed up by NYISO's analysis, like the claims about the need for dispatchable resources (which is often industry jargon for fossil fuel-burning generators). And where the CRP does include analysis, the methodology falls far short of industry standard approaches to ensuring adequate resources. Those industry standard approaches demonstrate the statewide system is far more protective than the already conservative thresholds required by the New York State Reliability Council and other professionals responsible for maintaining reliability (see Earthjustice's letter to NYISO at page 2). And in another recent report, NYISO recognizes that New York City, Long Island, and the Lower Hudson Valley have significantly more resources than required to meet the conservative threshold (see NYISO's February 2025 Report at page 26).

"NYISO's Comprehensive Reliability Plan does not back up its rhetoric. New Yorkers do not want their electricity bills driven ever higher by unneeded payments to dirty energy generators. Instead of doubling down on yesterday's expensive technologies–like burning fracked gas, which NYISO leaders themselves warn presents the greatest risk to winter reliability–policymakers and stakeholders should follow the facts, which point to the many benefits of investments in transmission and modern technologies like solar, wind, and batteries. Just look at this past summer, when renewables overperformed expectations during the heatwave, reducing peak demand and pulling down prices. At the same time, the dirty generators underperformed yet again," said Michael Lenoff, Senior Attorney at Earthjustice.

NYISO'S CRP is problematic in a number of ways:

• Failing to explain the economic burden placed on New Yorkers by needlessly overspending on fossil fuel infrastructure. There are diminishing benefits to investing more money into a system that already has adequate resources, and at a certain point New Yorkers could be asked to spend more for basically no benefit. Even the NYISO market monitor warns that changing the market to follow NYISO's CRP approach "would result in a market designed to inefficiently retain more capacity than is needed to satisfy reliability criteria at great cost to ratepayers." (see Market Monitor's Letter at page 7)
• Failing to explain that standard metrics indicate the system is already overprotected. According to NYISO's own metrics, New York's electric grid has more than enough protection against blackouts: For the next ten years, the grid has between 192% to 2,125% of the industry standard protection against inability to meet electricity demand, even at peak demand in the summer and winter (see Earthjustice's letter to NYISO, page 2).
• Claiming that "the system may need several thousands of MW of new dispatchable generation." The report, however, does not substantiate this claimed potential need, and does not discuss the amount, location, type, or other details of this claimed potential need (see Earthjustice's letter to NYISO, page 5). In industry terms, dispatchable generation often means burning fossil fuels. But the report gives no analysis to back up a claim that New York needs fossil fuels more than it needs renewables. In fact, during the Summer 2025 heatwave, NYISO acknowledges in the CRP that renewables performed better than expectations and fossil fuels performed worse (CRP, page 63).
• Leaning on "plausible futures" without explaining why these future scenarios are allegedly plausible. This means there's no ability for stakeholders or policymakers to gauge the reasonableness of NYISO's findings.
• Ignoring many resources and mechanisms available to NYISO to balance supply and demand and prevent blackouts. These ignored resources include operating reserves (for which New Yorkers pay), demand response and other "Special Case Resources" able to reduce demand, and other emergency procedures like assistance from neighboring regions and voltage reductions flexibilities. The NYISO's own market monitor advises against NYISO's suggestion to ignore these resources in planning, explaining to NYISO that this approach "does not have an obvious reliability rationale" and "would make it difficult to construct a market design that would provide efficient incentives to support this standard" (see Market Monitor's Letter at page 3). The impact of ignoring these resources is significant; as compared to the industry standard approach, the CRP undercounts the 2026 margin in New York City by almost 1,400 MW, roughly three times the size of the worst-case reliability issue that NYISO found in the 2025 Q3 quarterly short-term assessment of reliability (STAR) report (see Market Monitor's 2023 Letter at 5). And the 1,400 MW figure does not include operating reserves, suggesting the comparative undercount is even greater.

The CRP is part of a series of recent NYISO reports that are similarly problematic. In October, NYISO issued its Q3 STAR report, predicting shortfalls in New York City, Long Island, and the Lower Hudson Valley. But NYISO has already had to correct that report, diminishing the supposed concern. Moreover, the quarterly report depends on unsupported scenarios, like assuming away a transmission line that resolves the alleged concern in New York City until at least 2029, despite NYISO elsewhere indicating the transmission line is "nearing completion" and "scheduled to enter service in May of 2026." (see NYISO's October 29 Presentation at page 6 and NYISO's September 24 Presentation at page 5) And the quarterly report uses a similar limited methodology as the CRP, ignoring resources and mechanisms available to meet demand. Before that, in July, the organization's Power Trends report outright called for more fossil-burning generation without any demonstration of where, when, or how much of the generators are supposedly needed. Meanwhile, the report failed to reconcile this blast to the past with the reality that fossil-burning generators are increasingly unreliable at the times the grid most needs resources, while solar and wind overperform NYISO's expectations.

Even in the face of NYISO's reliability claims, New York leaders have repeatedly failed to follow through on building new clean energy infrastructure, including the delayed 175-mile Clean Path NY transmission line, that would bring 1,300MW into New York City. In July, the New York State Public Service Commission also abandoned efforts on a transmission project to connect multiple offshore wind farms to provide clean energy and meet growing demand. That project could have lowered costs to produce electricity by $40 to $70 billion from 2033 to 2052. That's on top of the approximately 50,000 MW of mostly clean energy projects stuck in the NYISO generator interconnection queue, and the possibilities for surplus interconnection, which would connect new renewable energy to the power grid and could be built faster and cheaper than new gas.

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