{"document":{"slug":"report-el26-69-nyiso","title":"NYISO reports on resource adequacy and large-load proposals","issued":"2026-07-20","accession":"20260720-5217","docket":"EL26-69-000","group":"NYISO filings","filer":"New York Independent System Operator, Inc.","kind":"informational report","file":"sources/originals/20260720-5217_01.pdf","url":"https://elibrary.ferc.gov/eLibrary/filelist?accession_Number=20260720-5217","sha256":"a8d77161c68268e5ddc6b3be3fa72e6b6d1a15b6cd5746ba268b80a01821bffe","pages":15,"tokens":7259,"emptyPages":[]},"pages":[{"page":1,"startToken":0,"endToken":384,"text":"10 Krey Boulevard, Rensselaer, NY 12144 \n \nPh: 518.356.6000  |  Fax: 518.356.8899 \n \n \n \nJuly 20, 2026 \n \nBy Electronic Delivery \n \nHonorable Debbie-Anne A. Reese, Secretary \nFederal Energy Regulatory Commission \n888 First Street, NE \nWashington, DC 20426 \n \nRe: \nNew York Independent System Operator, Inc., Informational Report \nRegarding Resource Adequacy Measures and Proposals, Docket No. EL26-69-\n000 \nDear Secretary Reese: \n \nIn compliance with the directive in the “Order Instituting Proceeding under Section 206 \nof the Federal Power Act” (“June 2026 Order”) issued by the Federal Energy Regulatory \nCommission (“Commission” or “FERC”) on June 18, 2026,1 the New York Independent System \nOperator, Inc. (“NYISO”) submits this informational report.  This report explains the findings \nfrom the NYISO’s recent planning studies; the existing markets and processes to plan for and \nmaintain resource adequacy, including new large loads; and proposals that the NYISO is \nconsidering through its stakeholder process to support resource adequacy in the New York \nregion.  While the changing nature of the New York system, including the projected pace of new \nlarge load entry, presents challenges, the NYISO’s markets and existing planning processes \nremain available to address resource adequacy.  As detailed in this filing, the NYISO, as a single-\nstate independent system operator (“ISO”), is coordinating closely with the New York State \nPublic Service Commission (“NYPSC”), the New York State Reliability Council, L.L.C. \n(“NYSRC”), and stakeholders to consider enhancements to meeting the rapidly evolving grid for \nthe New York region. \nI. \nBackground \nOn June 18, 2026, the Commission issued the June 2026 Order that, among other things, \nfound that the NYISO’s existing Open Access Transmission Tariff (“OATT”) appears to be \nunjust, unreasonable, and unduly discriminatory or preferential as it relates to providing \ntransmission and interconnection service needed to serve the ongoing influx of large loads while \nmaintaining reliability and affordability.  Accordingly, the Commission instituted a proceeding \npursuant to Section 206 of the Federal Power Act (“FPA”) that directed the NYISO to show \ncause as to why the NYISO’s OATT remains just and reasonable and not unduly discriminatory \nor preferential or explain changes to the OATT that would remedy the concerns identified by the \nCommission.2   \n \n1 New York Indep. Sys. Operator, Inc., et al., Order Instituting Proceeding under Section 206 of the Federal \nPower Act, 195 FERC ¶ 61,216 (2026). \n2 Id. at P 3."},{"page":2,"startToken":384,"endToken":899,"text":"Honorable Debbie-Anne A. Reese \nJuly 20, 2026 \nPage 2 \n \nIn the June 2026 Order, the Commission noted that it has resource adequacy concerns due \nto “[t]he rapid addition and proliferation of large loads without commensurate additions of \nsupply or demand-side resources”3 and “NYISO and load serving entities [being] unable to plan \nadequate generation to serve all load at the pace such load seeks to connect.”4  Therefore, the \nCommission directed the NYISO to submit an informational report within 30 days of the date of \nissuance of the June 2026 Order on how the NYISO intends to ensure that adequate generation \nwill be available to serve existing and new large loads.5  Specifically, the Commission directed \nthat the informational report contain any proposals under consideration in the NYISO’s \nstakeholder process to address the issue of resource adequacy to serve new large loads, as well as \nany ongoing stakeholder processes that aim to increase the pace of adding generating capacity in \nthe NYISO region.  The Commission required that the informational report include a detailed \nschedule of such initiatives, including timing of the stakeholder process and dates of any \nanticipated filings with the Commission.6 \nII. \nResource Adequacy of the NYISO System, Measures to Address Resource \nDeficiencies, and Potential Reforms under Consideration \n \nA. \nNYISO’s Current Planning for Resource Adequacy  \nThrough the NYISO’s Comprehensive System Planning Process,7 as well as its \ncompliance with applicable reliability standards and rules, the NYISO conducts recurring long-\nterm and near-term reliability analyses to assess and plan for the New York Control Area \n(“NYCA”), including the identification of solutions to needs on the bulk power system.8  \nSpecifically, in its Reliability Planning Process, the NYISO, in coordination with the NYPSC, \nTransmission Owners, and stakeholders, plans for the adequacy and reliability of the system \nbased on established reliability criteria.9  The biennial evaluation is complemented by quarterly \nshort-term assessments of reliability over a five-year horizon in accordance with the Short-Term \nReliability Process, which is the principal mechanism to evaluate generators seeking to \ndeactivate and to provide for interim service and reliability-must-run arrangements.10  The \nReliability Planning Process contains the following essential steps: the identification of \nreliability needs, the solicitation of proposals for both market-based and regulated solutions, the \n \n3 Id. at P 128. \n4 Id. at PP 4, 128. \n5 Id. at P 129. \n6 Id.  \n7 Capitalized terms that are not otherwise defined in this filing shall have the meaning specified in \nAttachments Y or FF of the NYISO’s OATT, and if not defined therein, in the OATT and the NYISO’s Market \nAdministration and Control Area Services Tariff (“Services Tariff”). \n8 Attachment Y of the OATT contains the components of the Comprehensive System Planning Process, \nincluding the Reliability Planning Process, and Attachment FF contains the Short-Term Reliability Process.  \n9 The applicable reliability criteria include “[t]he electric power system planning and operating policies, \nstandards, criteria, guidelines, procedures, and rules promulgated by the North American Electric Reliability \nCorporation (“NERC”), Northeast Power Coordinating Council (“NPCC”), and the [NYSRC], as they may be \namended from time to time.”  OATT § 31.1. \n10 OATT § 38."},{"page":3,"startToken":899,"endToken":1512,"text":"Honorable Debbie-Anne A. Reese \nJuly 20, 2026 \nPage 3 \n \nNYISO’s evaluation of these proposed solutions, and the implementation of regulated solutions \nwhen market-based projects do not timely resolve anticipated reliability deficiencies.11 \nOver the last several reliability planning cycles, the NYISO’s studies have identified \nincreasing risks in the long-term planning horizon that indicate potential shortfalls in available \ngeneration across the New York region.  Recent reliability studies have highlighted trends \nleading to increasing risks, such as (1) the deactivation of existing resources and the aging \ngeneration fleet continue to outpace the entry of new resources able to provide the necessary \nattributes for maintaining the reliability of the system; (2) the impact of growing electricity \ndemand from new large loads and electrification; and (3) New York’s reliance on imports from \nexternal control areas. \nIn the most-recently completed Reliability Needs Assessment (“RNA”), the NYISO \nidentified a reliability need in New York City beginning in summer 2033 related to transmission \nsecurity that would continue to reduce margins through 2034 causing a potential statewide \nresource deficiency without further resource additions.12  Following the conclusion of that study, \nthe NYISO received updates to the system conditions (i.e., a reduction in the demand forecast for \nthe affected zone) that resulted in the 2025-2044 Comprehensive Reliability Plan (“CRP”) \ndetermining that the baseline actionable reliability need was no longer observed.13  However, the \nCRP pointed out that there are potential long-term system resource adequacy needs on the \nhorizon and that the “grid is at an inflection point” due to the aging of the existing generation \nfleet, the rapid growth of large loads, and the increasing difficulty of developing new \ndispatchable resources.14  The CRP noted that there are clear pathways to maintaining system \nreliability, including (1) accelerating the entry of resources in the development pipeline, (2) \npreserving or replacing critical dispatchable capability, and (3) adding new firm capacity.  While \nthe NYISO’s role is to evaluate future system conditions, including identification of potential \nviolations of applicable reliability criteria, and send price signals through its wholesale markets, \nthe CRP emphasized there is an imminent need to move the grid to a more proactive framework \nthat involves anticipating risks and enabling timely investment.15  \nThe NYISO is currently preparing the 2026 RNA and targeting completion in November \n2026.  The 2026 RNA evaluates the reliability of the New York bulk electric grid over the ten-\nyear planning horizon with a focus on 2030 through 2036, considering updated forecasts of grid \n \n11 OATT §§ 31.2.4, 31.2.5, 31.2.8 \n12 New York Indep. Sys. Operator, Inc., 2024 Reliability Needs Assessment (RNA) (November 19, 2024), at p \n6, available at https://www.nyiso.com/documents/20142/2248793/2024-RNA-Report.pdf/.  While the 2024 RNA \ndid not find a violation of the resource adequacy criterion, the nature of the transmission security violation was \nindicative of localized resource deficiencies that continued growth in demand or retirement of resources retire could \nresult in a violation of the resource adequacy criterion. \n13 New York Indep. Sys. Operator, Inc., 2025-2044 Comprehensive Reliability Plan (November 21, 2025), at \np 5, available at https://www.nyiso.com/documents/20142/2248481/2025-2034-Comprehensive-Reliability-\nPlan.pdf/. \n14 Id.  Findings from the 2025-2044 CRP continue to be supported in the findings from the recent Short-Term \nAssessments of Reliability.  In the 2026 Quarter 2 Short-Term Assessment of Reliability, the NYISO confirmed that \nthere are continuing to be supply deficiencies in New York City that necessitate retaining existing generation in that \nzone.  See New York Indep. Sys. Operator, Inc., 2026 Quarter 2 Short-Term Assessment of Reliability (July 14, \n2026), available at https://www.nyiso.com/documents/20142/16004172/2026-Q2-STAR-Report-vFinal.pdf/. \n15 2025-2044 Comprehensive Reliability Plan at p 12."},{"page":4,"startToken":1512,"endToken":1998,"text":"Honorable Debbie-Anne A. Reese \nJuly 20, 2026 \nPage 4 \n \ndemand according to the 2026 Load and Capacity Report (“Gold Book”), planned transmission \nupgrades, and projected changes to the generation fleet.  The NYISO recently posted the \npreliminary results for review and discussion in its governance process.  Based on the \npreliminary results, the NYISO could identify a statewide resource adequacy criterion violation \nthat would first occur in 2033 and increase through 2036 with a deficiency greater than 1,800 \nMW when accounting for forecasted large load growth.  More localized reliability needs are also \nlikely to be identified in New York City beginning in 2031.16 \nIdentification of a reliability need is a potential outcome of NYISO’s planning process by \ndesign and does not mean the process is inadequate.  Furthermore, the NYISO believes that \nprudently planning for the New York bulk power system should include assessing risks and \nevaluating whether existing processes should be further strengthened to be able to respond in \ntoday’s and the future’s planning environments.  As a result, the NYISO is continuing to engage \nthe NYPSC, the NYSRC, Transmission Owners, and stakeholders on pursuing targeted reforms \nas more fully detailed in Part II.C, below. \nB. \nNYISO’s Existing Processes to Attract and Retain Resources \nSupported by the findings in its reliability studies, the NYISO recognizes the need to \nconsider opportunities to enhance processes to address emerging reliability challenges, including \nstatewide resource adequacy concerns, increasing uncertainty, and changing resource \ndevelopment timelines.  The NYISO’s existing processes, however, continue to provide a strong \nfoundation to attract and retain resources, including in response to the NYISO’s identification of \nresource deficiencies or reliability needs due to changing system conditions or additions of large \nloads. \n1. \nNYISO’s Wholesale Capacity Market Supports Resource Adequacy \nthrough Efficient Market Signals  \nCompetitive wholesale electricity markets, adopted in New York pursuant to the \nNYPSC’s “Competitive Opportunities” proceeding,17 and operating under this Commission’s \njurisdiction, are an efficient and necessary element in planning for and obtaining sufficient \nresources to address new large loads.  The NYISO’s wholesale markets are designed, and \ncontinue to evolve and adapt, to send efficient price signals to guide and attract new market entry \nand retention of resources that support reliability.  The NYISO’s wholesale capacity market is \ndesigned to provide sufficient resources required to meet resource adequacy needs and are an \nimportant aspect to maintaining reliability of the grid. \nThe NYISO’s capacity market is structured to incentivize the availability of sufficient \nresources to meet New York’s resource adequacy requirements.  Resource adequacy in New York \nState is maintained through a series of related processes administered by the NYSRC and the \nNYISO.  Through these processes and requirements, New York has some of the most stringent \n \n16 New York Indep. Sys. Operator, Inc., 2026 RNA: Preliminary Base Case Draft Results (July 23, 2026), \navailable at https://www.nyiso.com/documents/20142/58620525/03_2026RNA_PreliminaryDraftResults-\nJuly23ESPWG-TPAS.pdf. \n17 NYPSC Case No. 93-M-0229, Order Instituting Proceeding (March 19, 1993)."},{"page":5,"startToken":1998,"endToken":2513,"text":"Honorable Debbie-Anne A. Reese \nJuly 20, 2026 \nPage 5 \n \nreliability standards across the country.  The NYSRC conducts an annual probabilistic, \nengineering-based study to inform its establishment of an installed reserve margin (“IRM”) for \nthe upcoming Capability Year.  The IRM represents an additional quantity of capacity that must \nbe procured above the NYISO’s forecasted peak load to meet a resource adequacy criterion of \nnot exceeding a loss of load expectation (“LOLE”) greater than 0.1 loss of load event days per \nyear.  Each year’s IRM is filed by the NYSRC with both the Commission and the NYPSC.18 \nIn addition to procuring enough capacity to meet the IRM, the NYISO’s capacity market \nprovides fixed cost recovery for investments and essentially acts as a call option on future \nenergy.  Revenues available from capacity market participation also help mitigate extreme price \nand revenue volatility that energy-only markets can be susceptible to.  Taken together, the \nNYISO’s wholesale markets are designed to send efficient price signals to attract and retain \nresources with the necessary reliability characteristics to serve the need presented by the \nevolving grid. \n2. \nRobust Participation in the NYISO’s Interconnection Procedures Shows \nthat the NYISO’s Wholesale Markets are Sending Efficient Price Signals \nThe Cluster Study Process that the NYISO instituted in response to Order No. 2023 has \nalready shortened and improved the process for interconnecting resources to the New York \nsystem.  While the pace of new entry achieving commercial operation has been, and is forecasted \nto continue to be, a concern, a significant number of proposed resources have already completed \nthe interconnection process or are currently participating in the nearly completed inaugural \nTransitional Cluster Study.   \nPrior to the implementation of the Cluster Study Process, a number of projects had \ncompleted their interconnection studies through a Class Year Study or the NYISO’s Small \nGenerator Interconnection Procedures.  As of this filing, the New York region has 89 projects, \nrepresenting over 11 GW of generation, that have completed the interconnection study process \nbut have yet to enter commercial operation. \nThe current Transition Cluster Study, which commenced on August 1, 2024, is nearing \ncompletion and currently has 91 projects, representing over 15 GW of generation.  The \nTransition Cluster is scheduled to be completed later this year.  Interconnection Customers will \nbe required to enter into an interconnection agreement and can then move forward with bringing \nits resource into commercial operation.  The next Cluster Study Application Window is \nscheduled to begin on July 31, 2026.  The NYISO anticipates continued, significant interest by \nInterconnection Customers seeking to interconnect resources to the New York system. \nEven with the efficiency of its Transitional Cluster Study, the NYISO builds on its \nestablished track record of continuous process improvement efforts by pursuing further \nenhancements to its procedures.  In May 2026, the NYISO filed two portfolios of enhancements \n \n18 See, e.g., New York State Reliability Council, L.L.C., Docket No. ER26-885-000 (December 23, 2026); \nNYPSC Case No. 05-E-1180, Installed Reserve Margin for the New York Control Area, Comments of the New York \nState Reliability Council of the Installed Reserve Margin for the 2026-2027 Capability Year (January 23, 2026)."},{"page":6,"startToken":2513,"endToken":3048,"text":"Honorable Debbie-Anne A. Reese \nJuly 20, 2026 \nPage 6 \n \nand improvements pursuant to Section 205 of the FPA aimed at creating further efficiencies in \nthe Cluster Study Process, as well as updating its methodology to appropriately identify \ndeliverability upgrades.19  With these further enhancements, the NYISO’s interconnection \nprocedures will be able to provide further efficiencies and reduce barriers for new entry. \nThe number of resources being proposed in New York is a positive indication that \ninterconnection customers are responding to price signals from the markets and/or findings from \nthe NYISO’s planning studies.  To the extent that these resources become operational, they will \nhelp address the NYISO’s resource adequacy and reliability needs into the future.  However, \nfactors outside the NYISO’s interconnection process significantly impact whether a project is \nconstructed, including, but not limited to, permitting, siting, supply chain issues, and financing.  \nThe NYISO is working with New York State to address issues impacting the barriers to bringing \nnew resources and repowering of existing resources with the necessary reliability attributes to \nmaintain reliability in the future. \n3. \nNYISO’s Reliability Planning Process Provides an “All Resource Type” \nApproach to Maintain Resource Adequacy Over a Ten-Year Horizon \nThe NYISO’s system and resource planning processes further support its wholesale \nmarkets by providing robust studies of the New York bulk power system to provide information \nand prepare plans for, among other things, future system conditions and maintaining reliability \nover a ten-year horizon.  Specifically, the planning processes complement the markets by \nforecasting future system conditions and resource needs beyond the market horizon.  Such \nforward-looking information serves to guide investment decisions so that resources can be \ndeveloped in time to meet future market procurements.  New York has seen success in its use of \nthe planning processes to expand the transmission system, including the selection of four \nsignificant transmission projects to address Public Policy Transmission Needs identified by the \nNYPSC through the NYISO’s process.  Continuing to build on such success, the NYISO, \ntogether with its stakeholders, has worked over the past several years to further align its planning \nstudies and market price signals to better reflect operational reliability.  As a result, the NYISO’s \nplanning studies and wholesale markets already provide mechanisms to address resource \nshortfalls due to increased demand from large loads or other system changes. \nThe Reliability Planning Process provides a meaningful avenue for the NYISO, in \ncoordination with the NYPSC, Transmission Owners, and stakeholders, to maintain resource \nadequacy as the grid changes and evolves, including large loads entering operation.  The \nNYISO’s reliability studies currently incorporate large loads through demand forecasts.20  Large \n \n19 New York Indep. Sys. Operator, Inc., Proposed Tariff Revisions Regarding Interconnection Process \nImprovements, Docket No. ER26-2698-000 (May 29, 2026) (proposing revisions to incorporate additional \nimprovements and efficiencies in the Cluster Study Process); New York Indep. Sys. Operator, Inc., Proposed Tariff \nRevisions to Revise the Deliverability Test Methodology, Docket No. ER26-2577-000 (May 19, 2026) (proposing \nrevisions to the existing deliverability methodology to provide Interconnection Customers with clearer, more \nrealistic and more equitable outcomes related to the identified upgrades for a project). \n20 See generally, NYISO Response to Chairman David Rosner’s September 19, 2025 Letter, re: Large Load \nForecasting for America’s Significant Electricity Demand Growth (October 31, 2025), available at"},{"page":7,"startToken":3048,"endToken":3699,"text":"Honorable Debbie-Anne A. Reese \nJuly 20, 2026 \nPage 7 \n \nloads are included when they demonstrate that a project is sufficiently advanced in its \ndevelopment to be included in system planning.21  Using those demand forecasts, the NYISO \nevaluates the 10-year horizon to identify whether there are violations of the resource adequacy \ncriterion or other reliability criteria.  If the analysis results in the identification of a reliability \nneed due to, for instance, a shortfall in supply, the process is structured as an “all resource type” \napproach that enables the NYISO to consider market-based solutions and regulated solutions to \ndevelop a plan that addresses a reliability need.  Specifically, a Responsible Transmission Owner \nmust submit a proposal for a regulated backstop solution, while other developers may submit \nmarket-based solutions or regulated proposals.  Both market-based and regulated solutions can \nconsist of generation, demand response, and transmission.22 \nConsistent with the purpose and structure of the NYISO’s wholesale markets, the \nReliability Planning Process first looks to whether proposed market-based solutions are \nsufficient to address a reliability need.  This process is aimed at limiting the potential costs to \nratepayers by not triggering regulated solutions unless it is essential in order to timely address a \nneed.  Developers with market-based solutions that they believe can address the identified \nreliability need are encouraged to submit their project information for the NYISO to consider \nwhether they are viable and sufficient.23  If there are viable and sufficient market-based solutions \nto address the reliability need, then the NYISO would not trigger a viable and sufficient \nregulated solution to begin permitting and construction.24   \nThe Reliability Planning Process was designed to coordinate the roles of the NYISO and \nthe NYPSC in addressing reliability needs.  Specifically, the NYISO is responsible for \ndeveloping its regional plan, including evaluating the viability and sufficiency of submitted \nproposals and evaluating and selecting transmission solutions that address needs more efficiently \nor cost effectively and are eligible for cost allocation under the OATT.  The NYPSC is \nresponsible for planning for resources and the generation mix, including the permitting of \nprojects and approving cost allocation for generation and demand response solutions under state \nlaw.  Consistent with the NYPSC’s description of its responsibilities in its July 11, 2026 filing in \nthis docket,25 the NYISO’s Reliability Planning Process enables the NYPSC to take the \n \nhttps://www.ferc.gov/media/nyiso-response-chairman-david-rosners-09192025-letter-re-large-load-forecasting-\namericas (detailing how large loads are incorporated into the NYISO’s system and resource planning). \n21 See generally, NYISO Reliability Planning Process Manual at Section 3.2.1. \n22 OATT §§ 31.2.4.3.1, 31.2.4.5, 31.2.4.8.1.  A regulated generation or demand response solution is one “for \nwhich the Developer is seeking to obtain regional cost allocation through the appropriate state agency.”  New York \nSys. Operator, Inc., et al., Compliance Filing, Docket No. ER13-102-000 (October 13, 2013), at n 8; see generally \nOATT § 31.5.6.1 (providing that “[c]osts related to regulated non-transmission projects will be recovered by \nResponsible Transmission Owners, Transmission Owners and Other Developers in accordance with the provisions \nof New York Public Service Law, New York Public Authorities Law, or other applicable state law”). \n23 OATT §§ 31.2.4.5, 31.2.5. \n24 OATT § 31.2.8.1.1 (providing that “[t]he ISO will not trigger a regulated solutions if, based on [its] review, \nit determines prior to or at the Trigger Date for a regulated solution: (i) that sufficient market-based solutions are \ntimely progressing to meet the Reliability Need by the need date or (ii) that, based upon the circumstances at the \ntime of review, there is no longer a Reliability need”). \n25 New York Indep. Sys. Operator, Inc., et al., Notice of Intervention and Preliminary Comments of the New \nYork State Public Service Commission, Docket No. EL26-69-000 (July 9, 2026), at p 3 (“New York . . . is well \npositioned to address any resource adequacy issues that may arise”)."},{"page":8,"startToken":3699,"endToken":4259,"text":"Honorable Debbie-Anne A. Reese \nJuly 20, 2026 \nPage 8 \n \nnecessary and timely action to ensure that adequate generation timely materializes when there is \na reliability need that requires the addition of more generating capacity and there are insufficient \nresponses from the marketplace.  \nTherefore, when there are insufficient market-based solutions to address a Reliability \nNeed and the need cannot be solved through transmission solutions received by the NYISO, the \nReliability Planning Process provides that the NYISO can indicate to a Responsible \nTransmission Owner or other developer that submits a regulated non-transmission solution (i.e., \na solution for which cost allocation and recovery is sought or intended to be sough under state \nlaw) to submit its solution to the NYPSC for consideration.26  The NYPSC then has the \nresponsibility to consider submitted regulated generation or demand response solutions that \nshould move forward and obtain cost recovery under state law.27  The allocation of the costs for \nthe development of the regulated generation or demand response solution would be determined \nby the NYPSC, including for resource adequacy issues caused by, for instance, a large load.28  \nThe NYISO monitors the progress of such solutions to determine whether they are adequately \nmoving forward or whether the NYISO needs to amend its plan to maintain reliability.29  For \ninstance, the NYISO can work with the NYPSC under the NYISO’s gap solution process if \nsolutions do not materialize and there is an imminent need, which could include the NYPSC \nacting on generation solutions through its jurisdiction over their permitting, siting, or cost \nrecovery.30 \n \n \n \n26 See OATT §§ 31.2.8.1.2, 31.2.8.1.4, 31.2.8.1.8.  \n27 In response to the reforms to the NYISO’s Reliability Planning Process to comply with the requirements of \nOrder No. 890, the NYPSC adopted policy statements that provided procedures to allocate and recover costs for \nregulated non-transmission solutions under state law to enable parties to voluntarily propose such solutions through \nthe NYISO’s process.  See NYPSC Case No. 07-E-1507, Proceeding to Establish a Long-Range Electric Resource \nPlan and Infrastructure Planning Process, Revised Policy Statement and Backstop Project Cost Recovery and \nAllocation (June 26, 2009), available at https://documents.dps.ny.gov/public/Common/ViewDoc.aspx? \nDocRefId={D5E49062-1410-400F-A419-A4307019DF92}; NYPSC Case No. 07-E-1507, Proceeding to Establish \na Long-Range Electric Resource Plan and Infrastructure Planning Process, Policy Statement on Backstop Project \nCost Recovery and Allocation (February 18, 2009), available at https://documents.dps.ny.gov/public/Common/ \nViewDoc.aspx?DocRefId={71B60BC7-D5EE-41C3-BB4B-5E1F13B5BD74}&DocTitle=Proceeding%20to%20 \nEstablish%20a%20Long-Range%20Electric%20Resource%20Plan%20and%20Infrastructure%20Planning%20 \nProcess,%20Policy%20Statement%20on%20Backstop%20Project%20Approval%20Process; NYSPC Case No. 07-\nE-1507, Proceeding to Establish a Long-Range Electric Resource Plan and Infrastructure Planning Process, Policy \nStatement on Backstop Project Cost Recovery and Allocation (April 24, 2008), available at https://documents.dps. \nny.gov/public/Common/ViewDoc.aspx?DocRefId={8E7255F6-DBB9-46DC-9DE3-FA35581125F2}&DocTitle= \nLong-Range%20Electric%20Resource%20Plan%20and%20Infrastructure%20Planning%20Process,%20Policy \n%20Statement%20on%20Backstop%20Project%20Cost%20Recovery%20and%20Allocation. \n28 See generally, June 2026 Order at PP 53–54 (recognizing that “the FPA expressly reserves to states the \nauthority over any other sale of electric energy, including retail sales and wholesale sales not in interstate commerce \n. . . , as well as facilities used for the generation and distribution of electricity”). \n29 OATT §§ 31.2.8.1, 31.2.8.3.1. \n30 OATT § 31.2.11."},{"page":9,"startToken":4259,"endToken":4863,"text":"Honorable Debbie-Anne A. Reese \nJuly 20, 2026 \nPage 9 \n \nC. \nPotential Reforms under Consideration that Would Support Resource \nAdequacy and Increase the Pace of Generation Additions \nIn its June 2026 Order, the Commission directed the NYISO to submit any proposals \nunder consideration in its stakeholder process to address the issue of resource adequacy to serve \nnew large loads.31  The Commission also directed the NYISO to identify any stakeholder \nprocesses that aim to increase the pace of adding generating capacity in the NYCA.32  In \nresponse to the Commissions directives, the NYISO identifies below the potential reforms that \nare under consideration that could further enable supply-side solutions through its Reliability \nPlanning Process and enhancements to its markets to further enable maintaining resource \nadequacy in the New York region.  While the identified reforms encompass potential concepts \nthat the NYISO is considering through its shared governance process, the NYPSC has and is \nundertaking other efforts to similarly address ensure resource adequacy for the New York region \nin light of the increasing energy demand challenges.33 \nAs discussed above, the NYISO’s wholesale markets, approach to planning for the \nreliability of the New York bulk power system, and coordination with New York State provide a \nstrong foundation to incentivize new entry and retention of existing supply.34  The NYISO, \nhowever, has acknowledged that the pace of change on the system and difficulties in bringing \nnew resources onto the system following completion of the interconnection studies warrant \npursuing proactive planning approaches to further reduce the risks of shortfalls in supply.35  \nAccordingly, the NYISO identifies the following planning and market initiatives to further \nsupport resource adequacy in the New York region and help to increase the pace of generation \nadditions. \n \n31 June 2026 Order at P 128. \n32 Id. at P 129. \n33 See, e.g., NYPSC Case No. 26-E-0335, Proceeding on Motion of the Commission to Implement a Nuclear \nReliability Backbone, Order Establishing a Nuclear Reliability Backbone Process (June 11, 2026), available at \nhttps://documents.dps.ny.gov/public/Common/ViewDoc.aspx?DocRefId={1059B79E-0000-CE15-AF3E-\nA1872B97EDC3}&DocTitle=Order%20Establishing%20a%20Nuclear%20Reliability%20Backbone%20Process  \n(initiating, in support of New York Governor’s 2026 executive order and State of the State address, a proceeding to \nevaluate the development of five gigawatts of nuclear generation assets and necessary transmission facilities, \nincluding the potential mechanisms for integrating new nuclear timely, cost-effectively, and with maximum benefits \nto New York’s electric grid and ratepayers); NYPSC Case No. 26-E-0045, Interconnection Reforms for Large Loads, \nOrder Instituting Proceeding and Soliciting Comments (February 12, 2026), available at https://documents.dps.ny. \ngov/public/Common/ViewDoc.aspx?DocRefId={B040539C-0000-CB26-AEB3-8C865EF3724D}&DocTitle= \nOrder%20Instituting%20Proceeding%20and%20Soliciting%20Comments (examining the impact of large loads and \nactions that New York State should take to reform the interconnection of large loads to the New York region); New \nYork State Energy Planning Board, 2025 New York State Energy Plan (SEP) (July 23, 2025), available at \nhttps://energyplan.ny.gov/Plans/2025-Energy-Plan (providing an outlook through 2040 that sets New York’s long-\nrange energy planning objectives, including “[i]mproving the reliability of the New York State’s energy systems”); \nNYPSC Case No. 20-E-0197, Transmission Planning Pursuant to the Accelerated Renewable Energy Growth and \nCommunity Benefit Act, Order Approving a Coordinate Grid Planning Process (August 17, 2023) available at \nhttps://documents.dps.ny.gov/public/Common/ViewDoc.aspx?DocRefId={101C058A-0000-C45D-9CD3-A87E49 \nDF7A99}&DocTitle=Order%20Approving%20a%20Coordinated%20Grid%20Planning%20Process.  \n34 New York Indep. Sys. Operator, Inc., et al., Notice of Intervention and Preliminary Comments of the New \nYork State Public Service Commission, Docket No. EL26-69-000 (July 9, 2026), at p 3. \n35 See Part II.A, supra."},{"page":10,"startToken":4863,"endToken":5361,"text":"Honorable Debbie-Anne A. Reese \nJuly 20, 2026 \nPage 10 \n \n1. \nPotential Planning Reforms under Consideration \nAs a result and following the publication of the 2025-2044 CRP, the NYISO has been \nconsidering whether any reforms are necessary to further incentivize increasing the pace of new \nresource additions when a reliability need is identified.  Specifically, the NYISO prioritized a \nproject for 2026 aimed at enhancing the Reliability Planning Process to, among other things, \nimplement scenario planning and incentivize supply-side solutions to address resource adequacy \nand reliability violations caused by insufficient supply.  At the beginning of 2026, the NYISO \nstarted the project first with discussions over the implementation of scenario planning in \nreliability studies in an attempt to have a concrete proposal in time for the 2026 RNA.  However, \nbased on stakeholder feedback and the need for additional consideration, the NYISO revised its \nschedule and targeted reforms for the end of 2026 / beginning of 2027, including further enabling \nsupply-side solutions.  On March 26, 2026, the NYISO solicited high-level feedback on the \nreforms to incentivize supply-side solutions.  The NYISO investigated potential options with \nstakeholders, such as further enabling the consideration of supply-side solutions for system-wide \nreliability needs; differentiating interconnection treatment or processes for supply-side solutions \nthat are needed to address resource shortfalls; and identifying any market impediments to supply-\nside solutions that can be addressed through the NYISO’s process.36   \nThe NYISO returned to its discussions on potential reforms with its Electric System \nPlanning Working Group and Transmission Planning Advisory Subcommittee on July 16, 2026.37  \nThe NYISO focused on considering reforms to the Reliability Planning Process to enhance its \nability to identify solutions to further enable an “all resource type” approach to addressing \nReliability Needs, including the proposed concepts and timeline discussed below.  \na. \nEstablish an Accelerated Interconnection Study Path for Certain \nResources \nThe NYISO is discussing with stakeholders a proposal to establish an accelerated \ninterconnection study path for resources that are needed to address a reliability need identified in \nthe Reliability Planning Process or Short-Term Reliability Process.38  This proposal is intended \nto provide a framework for a separate accelerated interconnection study for generators that have \nbeen identified as viable and sufficient to timely address a reliability need in the Reliability \nPlanning Process.  While the Cluster Study Process has resulted in improved processing times \nfor projects, this separate study path could accommodate a new resource that is on a shorter \ntimeframe than the Cluster Study Process.  The NYISO is considering eligibility for facilities to \nuse this path, including those that are proposed to address an urgent reliability or resource \nadequacy need identified by the NYISO. \n \n36 New York Indep. Sys. Operator, Inc., Reliability Planning Process Reforms: Updated Schedule (March 26, \n2026), available at https://www.nyiso.com/documents/20142/57510547/02_RPP_Reform_ESPWG_032626.pdf/. \n37 New York Indep. Sys. Operator, Inc., Reliability Planning Process Reforms: Enabling Supply-Side \nSolutions (July 16, 2026), available at https://www.nyiso.com/documents/20142/58534496/RPP_Reform_ESPWG \n_071626.pdf/. \n38 See id."},{"page":11,"startToken":5361,"endToken":5867,"text":"Honorable Debbie-Anne A. Reese \nJuly 20, 2026 \nPage 11 \n \nHaving already introduced stakeholders to this concept, the NYISO will continue to \ndiscuss and develop this proposal to establish the framework and parameters of a separate \naccelerated interconnection study path for generators needed to address reliability needs.  For \ninstance, the NYISO will work to develop criteria that will apply to an interconnection request \nsubmitted in the accelerated interconnection study, as well as other parameters, to limit the \nnumber of interconnection requests to those that are necessary to address a reliability need and \nlimit disruptions to the Cluster Study Process.  In developing the criteria, the NYISO will \nconsider similar approaches that the Commission has accepted in other regions.39 \n \nWhile the NYISO acknowledges that this targeted reform will not remove all barriers \naffecting the addition of resources in the New York region, it will reduce the potential that the \ninterconnection process will impede the ability of a generation solution to address a need.  \nb. \nEnhancements to the Criteria Used to Consider Modifications to \nExisting Resources \nThe NYISO is also discussing enhancements to its existing interconnection process to \nbetter align the parameters for modifications to an existing generator to allow changes, such as \nrepowering, with the ability to address emerging needs related to reliability, including resource \nadequacy.  This proposed reform would further enable existing facilities to be modified without \nthe need for restudy through a full Cluster Study, provided that there are no impacts to reliability \nof the system based on the NYISO’s assessment.  The proposed revisions would not seek to \nchange the material modification provisions in the Cluster Study Process for interconnection \nrequests undergoing a study.  Rather, it will consider whether certain changes to technology, fuel, \nequipment, and level of interconnection service of existing facilities that do not affect reliability \nshould be permitted without the need for a new interconnection request, particularly for \nrepowering and other projects that can support reliability, including resource adequacy. \nc. \nEnhancements to the Processing and Identification of Needs and \nSolutions in the Reliability Planning Process \nThe NYISO also is considering whether enhancements to the Reliability Planning \nProcess could further incentivize developers’ involvement in proposing viable and sufficient \nsolutions to timely meet a future reliability need. \nFirst, the NYISO is considering the treatment of a large load’s contribution to a resource \ndeficiency identified in the Reliability Planning Process.  The NYISO’s Reliability Planning \nProcess includes large loads in the RNA’s system representation when they have reached a \nspecified level of development.  If the NYISO identifies a resource deficiency and the large \nload(s) directly contributes to such deficiency, then the NYISO is considering assigning the \n \n39 See, e.g., Midcontinent Indep. Sys. Operator, Inc., Revisions to the Open Access, Energy and Operating \nReserve Tariff Expedited Resource Addition Study Filing, ER25-2454-000 (June 6, 2025), accepted, subject to \ncondition Midcontinent Indep. Sys. Operator, Inc., 192 FERC ¶ 61,064 (2025); PJM Interconnection, L.L.C., Tariff \nRevisions for Reliability Resource Initiative, Docket ER25-712-000 (December 13, 2024), accepted by PJM \nInterconnection, L.L.C., 190 FERC ¶ 61,084 (2025)."},{"page":12,"startToken":5867,"endToken":6430,"text":"Honorable Debbie-Anne A. Reese \nJuly 20, 2026 \nPage 12 \n \nresponsibility for addressing that resource deficiency, including the addition of resources, to the \nlarge load(s). \nSecond, the NYISO is considering targeted enhancements to the current Reliability \nPlanning Process to, among other things, clarify the types of solutions that can be submitted; \nclarify how the NYISO performs the viability and sufficiency assessment when separately \nproposed solutions when combined can address a need; and encourage solutions that can address \nmultiple, identified reliability needs.  For instance, the NYISO’s Reliability Planning Process \nlooks at all solution types in addressing a reliability need, which the tariff specifically references \ngeneration, demand response, and transmission.  However, there are other proposals that \ndevelopers or facility owners could offer that change the manner in which existing facilities \nperform on the system resulting in a positive impact on an identified reliability need.  For \ninstance, firm fuel contracts, flexibility of a load, and repairs or other adjustments to a generator \nor transmission facility that improve its performance or lifespan could potentially address or \nreduce a violation on the system.  Having rules that detail how interested parties can make such \nproposals—and how the NYISO will consider them—will facilitate potentially cost-efficient \nsolutions.40   \nThese reforms, when paired with the NYISO’s ongoing reform proposal to establish \nscenario planning in the Reliability Planning Process, are intended to provide a more \ncomprehensive, proactive approach to addressing resource adequacy issues where transmission \nsolutions would be unable to by themselves due to the unavailability of supply within the \nNYCA.41  The NYISO, however, notes that these are contemplated reforms within its \nresponsibilities, and it plans on continuing to work with the NYPSC and other entities to reduce \nother barriers to resources entering service beyond the NYISO’s processes. \nThe NYISO plans to continue discussions with its stakeholders in the preparation of \nabove-referenced potential reforms to address maintaining resource adequacy and increasing the \npace of generation additions.  The NYISO seeks to implement any reforms to support the \nidentification of solutions in the 2027-2036 CRP to any identified reliability needs.  As a result, \nthe NYISO will continue to discuss concepts with stakeholders to fully develop through October \n2026 and finalize any proposals by the end of 2026.  The NYISO targets review and approval \nfrom the NYISO’s Operating Committee, Management Committee, and Board of Directors \n \n40 Similar to the Commission’s requirements in Order No. 1920 to consider and evaluate the benefits of \nincorporating certain alternative transmission technologies into a transmission provider’s consideration of the more \nefficient or cost-effective transmission solution, certain modifications or changes to existing facilities that could \naddress the need without the need for more significant investments should be considered on a comparable basis in \nthe NYISO’s evaluation.  See Building for the Future Through Electric Regional Transmission Planning and Cost \nAllocation, Final Rule, Order No. 1920, 187 FERC ¶ 61,068 (2024), at PP 1163–66, 1239–41. \n41 New York Indep. Sys. Operator, Inc., Reliability Planning Process Reforms: Enabling Supply-Side \nSolutions (July 17, 2026); New York Indep. Sys. Operator, Inc., Reliability Planning Process Reforms: Updated \nSchedule (March 26, 2026), available at https://www.nyiso.com/documents/20142/57510547/02_RPP_Reform \n_ESPWG_032626.pdf/; see also New York Indep. Sys. Operator, Inc., Reliability Planning Process Reform: STRP \nProcess Proposal, RPP Tariff Revisions (February 26, 2026), available at https://www.nyiso.com/documents/20142/ \n57254820/02a_RPP_Reform_ESPWG_022626_final.pdf/."},{"page":13,"startToken":6430,"endToken":6946,"text":"Honorable Debbie-Anne A. Reese \nJuly 20, 2026 \nPage 13 \n \nbetween January and March 2027 with a filing submitted to the Commission under Section 205 \nof the FPA in or around March 2027, subject to necessary approvals. \n2. \nPotential Market Reforms under Consideration \nThe NYISO endeavors to continually align market price signals with its evolving \nreliability needs, creating incentives for investments to ensure resource adequacy.  Expected \nreforms to the NYISO’s ancillary services market include: (1) an initiative for balancing \nintermittency with the introduction of Uncertainty Reserve Requirements in the Day-Ahead and \nReal-Time Markets to procure reserves for forecast uncertainty in net load and intermittent \ngeneration and (2) an initiative to enhance Dynamic Reserves through the introduction of reserve \nrequirements that dynamically reflect actual grid and market conditions by including the largest \ncontingencies and transmission constraints.  The Balancing Intermittency enhancements are \nscheduled to be effective this year, and the Dynamic Reserves initiative is expected to be \nimplemented in 2028. \nLikewise, reforms are underway in the NYISO’s capacity market to help incentivize \ninvestment for resource adequacy.  These include, implementing improvements this year to the \ncapacity accreditation framework under the “Installed Capacity Accreditation Rules for Fuel \nSupply Constraints” to value resources with firm access to natural gas or fuel oil in response to \nincreasing winter resource adequacy challenges to further incentivize winter fuel supply \navailability.  Next year, the NYISO will be moving from an annual Capacity Market that is based \nsolely on reliability needs in the summer to a seasonal market incorporating winter reliability \nneeds.42  This enhancement will help send price signals for investment during the periods of \nincreased resource adequacy risk.  Additionally, the NYISO is pursuing several reforms to \nsupport resource adequacy through the capacity market demand curve determination process, \nwhich is a part of the stakeholder project referred to as “Demand Curve Reset Process and \nMethodology Improvements.”43  The objectives of these reforms are to strengthen investor \nconfidence by creating more durable and predictable Installed Capacity (“ICAP”) demand curves \nand enhancing long-term investment planning decisions.  The NYISO has been actively engaged \nwith its stakeholders in this effort and expects to finalize the reforms in 2026 so that they may be \nincluded in the next Demand Curve reset process starting in 2027. \nAlso, in collaboration with the NYSRC, the NYISO annually assesses desired \nimprovements to the resource adequacy modeling assumptions to reflect emerging reliability \nneeds.  A multi-year strategy44 is being developed to prioritize modeling improvements that are \naligned with key NYSRC and NYISO initiatives.  The current focus in the 2026-2030 strategic \nplan is on improving the representation of winter reliability risks; developing improvements to \n \n42 New York Indep. Sys. Operator, Inc., 195 FERC ¶ 61,250 (2026). \n43 See New York Indep. Sys. Operator, Inc., Demand Curve Reset Process and Methodology Improvements \n(January 12, 2026), available at https://www.nyiso.com/documents/20142/56339181/DCR%20Process%20 \nImprovements%20-%2001122026%20ICAPWG%20Final.pdf/.  \n44 See New York Indep. Sys. Operator, Inc., NYISO Resource Modeling Improvements: Strategic Plan (2026-\n2030) (October 1, 2025), available at https://www.nysrc.org/wp-content/uploads/2025/10/4.1.3-RA-Modeling-\nImprovement-2026-Strategic-Plan-10012025-ICS-Attachment-4.1.3.pdf."},{"page":14,"startToken":6946,"endToken":7178,"text":"Honorable Debbie-Anne A. Reese \nJuly 20, 2026 \nPage 14 \n \nload modeling to capture evolving winter load shapes, the impacts from new large loads, and \noffsets from behind the meter solar resources; and ensuring that energy limited resources are \nrepresented consistent with operational experiences.  The plan is refreshed annually to ensure \nimprovements are focused on the most up-to-date strategic priorities. \nIII. \nCommunications \nAll communications and service with regard to this filing should be directed to: \nRobert E. Fernandez, Executive Vice President,  \n  Chief Compliance Officer & General Counsel \nKaren Georgenson Gach, Deputy General Counsel \nStephanie Amann, Senior Manager, Regulatory & \n  Government Affairs \n*Brian R. Hodgdon, Senior Attorney \nNew York Independent System Operator, Inc. \n10 Krey Boulevard \nRensselaer, NY 12144 \nTel:  (518) 356-6000 \nFax: (518) 356-4702 \nbhodgdon@nyiso.com \n \n*Ted J. Murphy \nHunton Andrews Kurth LLP \n2200 Pennsylvania Avenue, NW \nWashington, D.C. 20037 \nTel: (202) 955-1500 \nFax: (202) 778-2201 \ntmurphy@hunton.com \n \n \n* Persons designated for receipt of service. \n \nIV. \nConclusion \nWherefore, the NYISO respectfully requests that the Commission accept this \ninformational report in response to the requirements of the directive in the Commission’s Order \nInstituting Proceeding Under Section 206 of the Federal Power Act issued in the above-\ncaptioned docket. \n \nRespectfully submitted, \n/s/  Brian R. Hodgdon  \n \nBrian R. Hodgdon \nSenior Attorney \nNew York Independent System Operator, Inc. \n \ncc:   \nJanel Burdick  \n \nEmily Chen \n \nJames Dawson \n \nJignasa Gadani \n \nLeanne Khammal \n \nJaime Knepper \n \nDavid Morenoff \n \nJason Rhee \n \nDouglas Roe"},{"page":15,"startToken":7178,"endToken":7259,"text":"CERTIFICATE OF SERVICE \n \nI hereby certify that I have this day served the foregoing document upon each person \ndesignated on the official service list compiled by the Secretary in this proceeding in accordance \nwith the requirements of Rule 2010 of the Rules of Practice and Procedure, 18 C.F.R. §385.2010. \nDated at Rensselaer, NY this 20th day of July 2026. \n /s/ Alexander Morse \n  \n \nAlexander Morse \nNew York Independent System Operator, Inc. \n10 Krey Blvd. \nRensselaer, NY 12144 \n(518) 285-7826"}],"sections":[{"p":1,"at":0,"title":"Opening text","method":"opening text","endPage":1,"endAt":1646,"startToken":0,"endToken":239},{"p":1,"at":1646,"title":"I. Background","method":"printed heading","endPage":1,"endAt":1650,"startToken":239,"endToken":240},{"p":1,"at":1650,"title":"Background","method":"printed heading","endPage":2,"endAt":1231,"startToken":240,"endToken":578},{"p":2,"at":1231,"title":"II. Resource Adequacy of the NYISO System, Measures to Address Resource","method":"printed heading","endPage":2,"endAt":1364,"startToken":578,"endToken":595},{"p":2,"at":1364,"title":"A. NYISO’s Current Planning for Resource Adequacy","method":"printed heading","endPage":4,"endAt":1277,"startToken":595,"endToken":1707},{"p":4,"at":1277,"title":"B. NYISO’s Existing Processes to Attract and Retain Resources","method":"printed heading","endPage":9,"endAt":57,"startToken":1707,"endToken":4268},{"p":9,"at":57,"title":"C. Potential Reforms under Consideration that Would Support Resource","method":"printed heading","endPage":14,"endAt":413,"startToken":4268,"endToken":7005},{"p":14,"at":413,"title":"III. Communications","method":"printed heading","endPage":14,"endAt":1124,"startToken":7005,"endToken":7100},{"p":14,"at":1124,"title":"IV. Conclusion","method":"printed heading","endPage":14,"endAt":1129,"startToken":7100,"endToken":7101},{"p":14,"at":1129,"title":"Conclusion","method":"printed heading","endPage":15,"endAt":0,"startToken":7101,"endToken":7178},{"p":15,"at":0,"title":"CERTIFICATE OF SERVICE","method":"printed heading","endPage":15,"endAt":501,"startToken":7178,"endToken":7259}]}