Reliability Challenges in Assembly New York Local weather Regulation Necessities – Anticipate them?

By Roger Caiazza

On July 18, 2019, Former New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act (Climate Act), which sets goals to reduce greenhouse gas emissions, increase electricity production from renewable sources, and improve energy efficiency. Over the past year, committees made up of politically elected representatives have developed recommendations for a scoping plan to reduce greenhouse gas (GHG) emissions across the economy. On August 2, 2021, the New York State Energy Research and Development Authority (NYSERDA) hosted a speaker session on reliability planning that offers some interesting insights into reliability planning for electrical systems dominated by renewable energy generation.


Reliability planning in New York is a priority because New York State in general, and New York City in particular, has a long history of power outages. Following a power outage in July 2019, AMNY published a brief history of power outages in New York City. In any case, following the power outages of 1959, 1961, 1965, 1977, 2003 and 2012, new infrastructure and operational requirements were introduced to prevent future repetitions. Reliability planning is an ongoing concern of the electricians who operate the system and are responsible for keeping the lights on. With all due respect to the professionals attempting to develop a reliable system that incorporates large amounts of intermittent and diffuse wind and solar production, the power outage track record shows that historically not all problems have been predictable and that retroactive reliability improvements are the norm.

Over the past year, electrical systems professionals have viewed the transition process and climate law recommendations with increasing concern as it is evident that many of the appointed representatives do not understand New York’s unique reliability requirements. After a year and many comments, the state finally responded with an overview presentation of these requirements for the people who are to lead the transition plan. The lecture session (recorded here) included presentations from six organizations with different backgrounds, experience and responsibilities:

In a post on my blog I created an overview of all presentations. The warning in five of the six presentations was similar: relying on today’s technology will not be enough to develop a reliable electrical system with net zero emissions. “In a few hours, a large amount of installed switchable energy resources is required” and it “must be able to go online quickly and be flexible enough to meet fast, steep ramp requirements”. This technology does not exist for utility scale applications. In order to do justice to the environmental zealots involved in the process, a presentation by Vote Solar was unfortunately recorded, which claimed that “the integration of renewable energies into the grid while maintaining reliability is possible and actually inexpensive”. This presentation was based on the Why Local Solar for All Costs Less report, which has fatal flaws because it is based on annual estimates of renewable resource availability rather than worst-case conditions.

NYSRC presentation

The New York State Reliability Council presentation succinctly describes the organization of how the New York electricity system operates to maintain reliability and some of the challenges that arise when renewable energy sources are increased significantly. It was so well done that I thought it would be of interest to the readers here.

New York’s electrical system is deregulated so reliability planning is provided by the New York Independent System Operator, various state agencies, and the NYSRC. The introduction describes the NYSRC and the Installed Reserve Margin (IRM) parameter. The IRM is defined as the “minimum margin of installed capacity above the estimated peak load to meet the Northeast Power Coordinating Council (NPCC) requirement that the probability of load shedding is no greater than one day in ten years”. Load shedding occurs when the demand for electricity exceeds the supply and network operators have to switch off electricity for customer groups in order to prevent the entire system from collapsing. Note that one of the lessons learned from previous blackouts was that New York City must maintain a significant amount of electricity generation in the city in order to prevent blackouts. The NYSRC has specific rules regarding this.

The next slide described how to operate the system reliably. Note that in addition to short-term operation of the system, long-term planning is also required. To meet the one-in-ten year IRM criteria, planning must take into account the development of new generation and transmission resources, which can take ten years to build.

The slide with the title “Reliably operate a sustainable system” explained that with the changing mix of generation resources, planning and operation must also change. One focus is that “limited fuel diversity and excessive reliance on energy-limited resources pose a risk to reliability”. In the past, New York had a truly diverse energy system, with significant coal, residual oil, natural gas, water, and nuclear resources. Significant resources were available from sources that could store fuel on-site and run on more than one fuel. However, the state has banned the use of coal and the residual oil has become so expensive that consumption has fallen sharply. The conclusion on the slide that additional switchable and sustainable energy resources are required to manage the vastly different system of maintaining reliability relates in part to New York City’s inner-city capacity requirements. Today this means, for example, that plants must be able to burn oil when natural gas is not available.

The next slide (not shown here) again underlines the importance of the IRM, which turns out to be a future challenge with a significant increase in renewable resources. This is illustrated in the slide entitled “Solar Impact on Resource Adequacy”. The slide shows the daily variation of the load compared to solar generation, which is also known as the “duck curve”. Typical discussions about the duck curve focus on the operational challenge that arises from the loss of solar generation while the load is high. This slide reviews the changes in reserve needs with the addition of 26,000 MW of new solar power generation in New York. Due to the huge fluctuations in available solar energy, adding this amount of solar generation would increase the reserve requirement to approximately 22,000 MW compared to the current reserve requirement of 6,600 MW. It also means that the state can only decommission 4,000 MW of the current resources.

The Climate Act has a zero emissions target for the electrical system by 2040. The Department of Public Service (DPS) and the New York State Energy Research & Development Authority (NYSERDA) have made a preliminary estimate of the resources that will be required to achieve this goal as shown below. The key numbers from this slide are that in 2040 they are expected to need 88,337 MW for an expected load of 38,000 MW. To meet this load, and with a loss of load expectancy no more than once in ten years, the NYSRC estimates that total reserves will be approximately 50,000 MW.

The presentation points out that the New York reserve margin must increase from around 20% to over 100% compared to the current reserve margin. The estimates of the resource requirements to achieve the goals of the climate law did not take this issue into account, so that they significantly underestimate the resource requirements. In addition, the new technologies must be emission-free and meet the properties of fossil fuels (disposable, rapidly increasing and long storage). The presentation noted that “these resources rely on technologies that do not currently exist for utility-scale applications”.


I recommend reading and listening to the session presentation as it gives a good overview of reliability issues New York or any other jurisdiction is facing in moving to net zero. One caveat is not to waste time reading the Vote Solar presentation as it is based on a fatally flawed analysis.

There is consensus that the future worst-case situation in New York will be a lull in wind for several days in winter, when both wind and solar availability are low. In connection with an increased electricity load to reduce emissions from traffic and heat, any analysis of future renewable energy resources that adequately takes into account the worst-case availability of renewable energy resources shows that the required amounts of wind, solar and energy storage must be enormous. Importantly, the NYSRC analysis suggests that to ensure reliability, the installed reserve margin must be added to the total required to balance the expected load. While the focus of the highlighted presentation was on New York, I believe similar issues will become apparent in any other jurisdiction attempting to develop a net zero emissions power system.

The NYSRC’s conclusion that New York state appears to be on a transition path that in less than a decade will require reliance on technologies that don’t currently exist should be a wake-up call. The final question is whether the proposed transition plan addresses the issues raised by the professionals or does justice to the naive dreams of the politically elected members of the transition program. I’m afraid New York consumers are becoming lab rats for a politically motivated virtue that signals an empty gesture that costs huge sums of money and does far more harm than good in the event of a major power outage.


Roger Caiazza blogs about New York energy and environmental issues at Pragmatic Environmentalist of New York. He has written extensively on the implementation of the Climate Law as the proposed solutions compromise reliability and affordability, have worse environmental impacts than the alleged effects of climate change and global warming cannot measurably affect their implementation. This is his opinion and not the opinion of any of his previous employers or any other company he was affiliated with.

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