On Nov. 18, 2025, the Board of Directors of the New York Independent System Operator, Inc. (NYISO), as anticipated, approved the 2025-2034 Comprehensive Reliability Plan (CRP). This blog post highlights two aspects of the CRP that may have significant repercussions related to future electric generation and transmission planning and development. The first relates to the NYISO's proposal to refine its reliability planning process from one that identifies needs based on a single probabilistic base case to one based on several plausible scenarios to more adequately capture numerous risk factors that may directly impact the state energy system both in the short term and over the long run. The second is the NYISO's potential future finding – if its proposed or a similar enhanced framework were to be adopted – that the state's electric system may need several thousand megawatts (MW) of new dispatchable generation by 2034. Based on the current state of technology innovation and options, gas-fired power plant technology may be required to meet some significant portion of this need under that timeframe.
New Planning Approach Based on a Range of Plausible Futures
The NYISO utilizes a two-step biennial Reliability Planning Process. Under the first step, the NYISO performs a Reliability Needs Assessment (RNA) on even years that studies the system over the next 10 years and identifies any Reliability Needs over a 10-year horizon on the State's bulk power transmission system starting in year four. Under the second step of the process, the NYISO prepares a CRP on odd years to identify the plan for the planning horizon, including, as necessary, solutions to Reliability Needs found in the RNA and remain subject to resolution.
In the recently released CRP, the NYISO found that its current Reliability Planning Process structure is no longer sufficient to adequately identify reliability needs in future iterations; in particular, it found that relying on a single baseline set of assumptions under the pre-existing RNA process to determine whether a Reliability Need exists "does not reflect the growing range of combinations of demand, resource availability, and system conditions." The NYISO found that it "must evolve its methodology so that Reliability Needs are identified under a broader range of credible combinations of system conditions, not just a single deterministic [base] case." Underlying this proposed change in approach are several risk factors the NYISO identified that might adversely affect system reliability over the planning horizon.
Perhaps the biggest risk factor relates to the enormous potential increase in large electric loads associated with semiconductor manufacturing plants, data center projects, and hydrogen production facilities. The NYISO points out that, at the end of 2024, the interconnection queue included roughly 4,000 MW of large load projects; however, by September 2025, that figure has more than doubled to over 10,000 MW of load seeking to be in service prior to 2031. Rather than considering a single large load input into a base case, the CRP illustratively examines the effects that would arise under different scenarios that address the variability of projected large load growth, considering further potential growth and the possibility that some projects may not timely move forward.
Another important risk factor the NYISO identified relates to the supply side of the equation, particularly with respect to the state's existing generation facilities. Twenty-five percent of the state's total generating capacity is thermal generation that has been in operation for more than 50 years, with an average age of 65 years for thermal generators located in New York City. The NYISO notes that, based on national data, fossil-fuel thermal generators tend to experience more frequent and longer outages as they age, and difficulties in maintaining such generators may drive them to deactivate or be more susceptible to catastrophic failure. The NYISO offered a statistical retirement risk mode to illustratively account for the risks that may arise due to the state's reliance on aging generation as information to potentially guide its future reliability planning studies. The model predicts that as much as 3,000 MW of capacity is at risk of retirement by the end of the planning horizon. This is in addition to 517 MW associated with New York Power Authority's seven simple-cycle combustion turbines, located in New York City and Long Island, which are currently under state law to be removed from service by 2031 if reliability can be maintained, despite having a relatively young age of 27 years.
As for potential new generation over the planning horizon, the CRP accounts for the fact that "[r]ecent actions taken by the federal government have drastically impacted the prospects for the development and construction of offshore wind and other renewable resources." These recent actions call into question whether anything beyond the two offshore wind projects currently under construction (Empire Wind 1 and Sunrise Wind) will be in service over the next 10 years. The NYISO also builds into its analysis framework the reality that supply chain issues have led to long lead times for the delivery of equipment needed to construct energy infrastructure and persistent delays in acquiring the permits that are required as a prerequisite to developing generation and bulk transmission projects.
Application of Plausibility Scenarios
The CRP assesses the uncertainty around each individual key system factor and offers illustrative information bounding; e.g., combinations of these uncertainties to understand and highlight how different plausible configurations may benefit or harm system reliability margins during summer and winter peak conditions. At a high level, the NYISO found that most of the combinations of scenarios show decreasing reliability margins through 2034 with the range of future margins narrowing over time. The most optimistic scenario combinations show positive margins by 2034 in the 2,000 MW range, while the most conservative scenario combinations show deficiencies of up to 10,000 MW by 2034. Similarly, using a Loss of Load Expectation (LOLE), the NYISO is forecasting reliability violations as soon as 2030 presuming a high demand forecast and a substantial risk of thermal generator deactivations.
Why it Matters?
The NYISO reliability planning process is not an academic exercise; it provides the NYISO with critical information to seek reliability-based solutions in the name of keeping the lights on and air conditioning working during the hottest days of the year. The CRP – a core part of that process – projects increasingly narrow reliability margins through 2034 using various illustrative scenarios for the purpose of shedding light on the fact that reliability needs may well be becoming more pressing. The NYISO uses this information to support its recommendation in the CRP to strengthen its reliability planning across a broad spectrum of plausible outcomes.
In light of the various, significant factors that have thwarted development in the electric industry post-COVID, exacerbated by the significant change in federal policy beginning in 2025, and matched against expected large load growth due to the State's extensive economic development efforts and its public policy initiatives, gas infrastructure may remain one of the core supply components for the foreseeable future, a fact that the draft State Energy Plan also echoed. Under the new plausibility framework recommended under the CRP – if ultimately adopted and approved by the Federal Energy Regulatory Commission, over the next 10 years –gas-fired power plants may need to be built and existing gas-fired facilities repowered to address the growing risks to reliability.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
