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PRESS RELEASE | New York ISO Submits Comments to State Climate Action Council on Draft Scoping Plan

July 1, 2022

Highlights the need to move carefully during the grid in transition to maintain system reliability

Rensselaer, NY -- The New York Independent System Operator (NYISO) today submitted comments on the New York State Climate Action Council’s (CAC) draft scoping plan, urging a careful approach to meeting State mandates under the Climate Leadership and Community Protection Act (CLCPA) to maintain electric system reliability during the transition to 100 percent emissions-free electricity.

Signed into law in 2019, the CLCPA directs the State to meet 70 percent renewable energy by 2030 and 100 percent emissions-free electricity by 2040. Established under the CLCPA, the CAC is overseeing a public comment period for the draft scoping plan, which will guide the State’s transition to decarbonization.

In its comments, the NYISO underscores that it is fully committed to reliably achieving the mandates of the CLCPA. The NYISO also discusses how the electric system is already showing evidence of a dramatic shift in how electricity is produced, stored, transmitted, and consumed throughout New York State. The NYISO runs the bulk electric system and is required to meet strict state and federal reliability standards.

“The scoping plan recommends that we address the retirement of fossil resources gradually and safely, an approach the NYISO strongly supports,” said Emilie Nelson, Executive Vice President of the New York ISO. “As we move to a zero-emissions grid, it is critical that we understand how the growth of intermittent resources and extreme weather could impact the ability to maintain reliability of the New York bulk electric system. We will continue to work closely with all stakeholders, including the State, to better understand and prepare for the reliability, operational, and market implications of such a transformation in the resource mix.”

Key Messages

  • Fossil Generator Retirements Must Be Coordinated with Replacement Resources
    • The NYISO’s ability to operate a reliable electric system requires that the introduction of new resources be coordinated with and occur prior to the orderly retirement of additional fossil generators. Electric system reliability margins are already tightening. If these margins are totally depleted, the reliability of the grid would be at risk and power outages could disrupt normal life or negatively impact public health, welfare, and safety.
  • Accelerate Growth of Renewable Generation and Other Resources
    • New resources will be necessary to meet demand and provide reliability to replace the generators that will retire. The draft scoping plan contemplates accelerating the growth of large-scale renewables, offshore wind, distributed generation, and distributed energy resources. This growth is envisioned, in part, through recommendations that the State accelerate adoption of innovative technologies and programs that increase hosting capacity such as flexible interconnection, hybrid systems, and coupling resources with energy storage or controlled energy use.
  • Storage Provides Value and Must Work in Concert with Generation
    • The draft scoping plan states that a portfolio of energy storage technologies will be needed to support balancing the intermittency of energy production as more weather-dependent renewable energy generation connects to the grid. Existing and newer, long-duration, storage will be needed to maintain reliability as the State approaches 2040. This suite of storage technologies, however, will be needed well before 2040 to reach the State’s energy policy goals.
  • Interconnection Process Improvements
    • Interconnection rules that support grid reliability are necessary to effectively respond to the rapid growth of projects being developed in response to the State’s clean energy policies. The NYISO is committed to continue working with stakeholders to assess how its processes can be enhanced to better manage the increasing volume of resources while still providing the critical reliability analysis needed.
  • Markets are Critical to Achieving the CLCPA
    • The NYISO has a proven record of enabling the entry of new technologies into the State’s competitive wholesale electricity markets consistent with State public policy objectives. The NYISO-administered wholesale energy markets are critical to fulfilling the mission and goals of reliability and economic efficiency while also serving as an effective platform for achieving the CLCPA. The NYISO is actively engaged with stakeholders and policymakers in developing plans to meet the future challenges expected to arise from a grid with high levels of intermittent renewables and distributed energy resources.
  • Value of Environmental Attributes
    • The draft scoping plan encourages the State Energy Planning Board to investigate and implement options to develop market mechanisms to assist in the removal of fossil generators from the system. Options include the opportunity for carbon pricing and valuing of environmental attributes either within or outside of the wholesale markets. The NYISO believes an economy-wide environmental attribute market would be the most efficient way to achieve the numerous goals of the CLCPA and to implement the draft scoping plan recommendations, several of which are outside the electricity sector.


The NYISO will continue working closely with the State to help plan a careful approach to maintaining electric system reliability as new, intermittent generators connect to the electric grid and fossil-based generators retire. Achieving the CLCPA mandates and maintaining the reliability and resilience of the electric system demand that the NYISO, electric-system stakeholders, and state agencies work collaboratively to plan for the reduced operation of existing electric generators and, at the same time, develop and integrate the types of resources needed to maintain the reliable electric system that consumers require. Competitive wholesale electricity markets protect consumers from risks taken by developers; align investment signals with system needs; support and enhance grid reliability; create a cleaner, more cost-efficient grid; and drive needed energy infrastructure to achieve the CLCPA goals.

The NYISO’s full comments are available here.

We are an independent, not-for-profit corporation responsible for operating the state’s bulk electricity grid, administering New York’s competitive wholesale electricity markets, conducting comprehensive long-term planning for the state’s electric power system, and advancing the technological infrastructure of the electric system serving the Empire State.