Just When You Think It Cannot Get Worse – Watts Up With That?

Roger Caiazza

I recently described the Energy Innovation Policy and Technology analysis: Assessing Impacts Of “One Big Beautiful Bill Act” On U.S. Energy Costs, Jobs, Health, Emissions.  The analysis included astoundingly biased claims of the effects of the One Big Beautiful Bill Act.   I really did not think that I would see something that was as bad if not worse in less than a week but never underestimate the New York climate crazies.

Several days ago Earth Justice, Environmental Defense Fund, WE ACT for Environmental Justice, and Evergreen Action wrote a letter to Governor Hochul and the top managers of the Public Service Commission, the Department of Environmental Conservation, and the New York State Energy Research & Development Authority claiming that the New York Independent System Operator (NYISO) messaging in their summary Power Trends 2025 was misleading when they claimed that additional fossil fuel electricity generation is needed for reliability.  The arguments are as bad as the Energy Innovation Policy and Technology analysis.  The worst part is it got publicized by numerous media outlets, for example here, here and here.

A month ago, when the NYISO published Power Trends I wrote it up here because these are the folks that are responsible for keeping the lights on.  They have a group whose sole responsibility is electric resource planning, and they use the most sophisticated tools available.  The results expressed deep concerns about the future of the electric system on its current path to zero-emissions.  My article did note that I was disappointed that the report did not explicitly call out the immense challenges of transiting the New York electric system to one primarily reliant on wind, solar, and energy storage by 2040.  I should have mentioned that in the absence of clear, definitive explanations that the usual suspects would misinterpret their findings.  Guess what happened?

The introductory paragraph of the letter states:

On June 2, 2025, New York Independent System Operator (“NYISO”) issued its annual summary Power Trends report. The undersigned organizations write to correct misleading implications in the report and press release. The report’s messaging—that additional fossil fuel electricity generation is needed for reliability—is not supported by NYISO’s own analysis, and the report should not be used to derail New York’s progress toward a clean energy future. In fact, NYISO’s policies favoring fossil fuel generation and its delays in interconnecting clean energy resources to the grid are the real threats to reliability, and New York should prioritize the buildout of renewable energy and storage, and transmission, to comply with state law and protect New Yorkers’ wallets and health.

Their claims are based on failing to acknowledge the purpose of the report, willful disregard of development schedule constraints, poor understanding of the electric system, and ignorance of weather-related impacts on wind and solar production.

The letter complains that it is “not based on new information or analysis but is rather a summary of prior NYISO reports and analysis”.  The Power Trends report is supposed to be a summary overview of the results of other technical analyses.   I have my doubts that the authors have delved into those analyses in enough detail to understand the implications of the results.

The letter claims that “NYISO’s technical analyses on reliability that are the basis of this report do not support the implication in Power Trends that immediate investment in additional gas resources is necessary to maintain reliability.”  The authors ignore the NYISO concerns about the age of the existing fossil fuel resources and expectations that they may not work when needed most.  For the record, during the recent heat wave just about every fossil unit that could run was running.  It also was an unusual weather event because the source of the hot air was more of a push of heat and humidity from the south instead of a massive high-pressure system settling in place.  As a result, wind resources were higher than as is normal for peak summer loads.

The letter claims that “It seems that NYISO is irresponsibly seeking to create a false narrative that New York needs new gas generation, even though there is no evidence to support that claim.”  The authors ignored an explicit explanation why repowering old gas generation is beneficial.  In addition to addressing the reliability concerns of old equipment, new combined cycle gas turbines are cleaner than existing sources, more efficient, and could be eventually converted to burn green hydrogen.  Repowering extends the lifespans of existing facilities with all the supporting infrastructure and are a more cost-effective alternative than building a new plant.    

The letter went on to claim:

Many gas plants have retired in the state over recent years because they are not being utilized and are uneconomic. In addition, Winter Storm Elliott in 2022 exposed serious risks tied to overreliance on fossil fueled generators, particularly gas generators, where freezing and fuel issues resulted in generators failing to deliver power during extreme cold. In response, NYISO is no longer assuming certain gas generators will be available during winter demand peaks. According to the report, the only shortfall in electricity supply that NYISO anticipates would be due to gas supplies freezing during the winter.

These arguments are misleading.  Many of the retirements are because the electricity system is rigged to use solar and wind power whenever it is available but does not penalize the sources for not providing the ancillary support services necessary to keep the electric system operating well.  Winter Storm Elliott exposed serious reliability risks if fossil fueled generators are not adequately winterized.  No plants failed in New York due to the cold weather.  Gas supply was an issue, but New York addresses that problem by specifying a minimum number of dual-fueled units that can switch to oil during these conditions. They switched to oil and kept the lights on.

The letter claims that “NYISO has not specifically identified any new reliability need.”  That is flat out wrong because Power Trends acknowledges that a new resource for long duration periods of low wind and solar resource availability is needed.  The authors do not understand the intensity and extent of these periods. The dispatchable, emissions-free resources (DEFR) needed to solve this problem are not commercially available.  The people responsible for electric system reliability recognize that deployment of these resources is years away, but the authors don’t acknowledge this challenge and its implications.

In my opinion, the biggest flaw in the letter is that it does not acknowledge the extraordinary challenge that NYISO system planners must plan for the worst-case scenario.  Climate activist preferred alternatives work most of the time, but when needed the most they will not work.  Their myopic outlook ignores long-term historical observations and the schedule necessary to meet the aspirational targets of New York’s Climate Leadership & Community Protection Act.  The NYISO planners must address those issues, and the results are summarized in the Power Trends report.  If anything the report did not describe the severity of the challenges well enough.  It is sad that media outlets picked up the description of the letter without considering the motives of the source.

I could go on with more examples, but time is too short.  Apparently, NYISO did not provide enough explicit evidence to support their results that contradict the environmentalist narrative.  I wonder if the authors could ever be convinced.  At the end of the day, I make it a habit to listen primarily to voices who face consequences when their projections are wrong.  The organizations who authored this letter do not meet that requirement.

Roger Caiazza blogs on New York energy and environmental issues at Pragmatic Environmentalist of New York.  This represents his opinion and not the opinion of any of his previous employers or any other company with which he has been associated.

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