EL26-69-000 · 2026-07-20 · New York Independent System Operator, Inc.
NYISO reports on resource adequacy and large-load proposals
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10 Krey Boulevard, Rensselaer, NY 12144
Ph: 518.356.6000 | Fax: 518.356.8899
July 20, 2026
By Electronic Delivery
Honorable Debbie-Anne A. Reese, Secretary
Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC 20426
Re:
New York Independent System Operator, Inc., Informational Report
Regarding Resource Adequacy Measures and Proposals, Docket No. EL26-69-
000
Dear Secretary Reese:
In compliance with the directive in the “Order Instituting Proceeding under Section 206
of the Federal Power Act” (“June 2026 Order”) issued by the Federal Energy Regulatory
Commission (“Commission” or “FERC”) on June 18, 2026,1 the New York Independent System
Operator, Inc. (“NYISO”) submits this informational report. This report explains the findings
from the NYISO’s recent planning studies; the existing markets and processes to plan for and
maintain resource adequacy, including new large loads; and proposals that the NYISO is
considering through its stakeholder process to support resource adequacy in the New York
region. While the changing nature of the New York system, including the projected pace of new
large load entry, presents challenges, the NYISO’s markets and existing planning processes
remain available to address resource adequacy. As detailed in this filing, the NYISO, as a single-
state independent system operator (“ISO”), is coordinating closely with the New York State
Public Service Commission (“NYPSC”), the New York State Reliability Council, L.L.C.
(“NYSRC”), and stakeholders to consider enhancements to meeting the rapidly evolving grid for
the New York region.
I.
Background
On June 18, 2026, the Commission issued the June 2026 Order that, among other things,
found that the NYISO’s existing Open Access Transmission Tariff (“OATT”) appears to be
unjust, unreasonable, and unduly discriminatory or preferential as it relates to providing
transmission and interconnection service needed to serve the ongoing influx of large loads while
maintaining reliability and affordability. Accordingly, the Commission instituted a proceeding
pursuant to Section 206 of the Federal Power Act (“FPA”) that directed the NYISO to show
cause as to why the NYISO’s OATT remains just and reasonable and not unduly discriminatory
or preferential or explain changes to the OATT that would remedy the concerns identified by the
Commission.2
1 New York Indep. Sys. Operator, Inc., et al., Order Instituting Proceeding under Section 206 of the Federal
Power Act, 195 FERC ¶ 61,216 (2026).
2 Id. at P 3.
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Honorable Debbie-Anne A. Reese
July 20, 2026
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In the June 2026 Order, the Commission noted that it has resource adequacy concerns due
to “[t]he rapid addition and proliferation of large loads without commensurate additions of
supply or demand-side resources”3 and “NYISO and load serving entities [being] unable to plan
adequate generation to serve all load at the pace such load seeks to connect.”4 Therefore, the
Commission directed the NYISO to submit an informational report within 30 days of the date of
issuance of the June 2026 Order on how the NYISO intends to ensure that adequate generation
will be available to serve existing and new large loads.5 Specifically, the Commission directed
that the informational report contain any proposals under consideration in the NYISO’s
stakeholder process to address the issue of resource adequacy to serve new large loads, as well as
any ongoing stakeholder processes that aim to increase the pace of adding generating capacity in
the NYISO region. The Commission required that the informational report include a detailed
schedule of such initiatives, including timing of the stakeholder process and dates of any
anticipated filings with the Commission.6
II.
Resource Adequacy of the NYISO System, Measures to Address Resource
Deficiencies, and Potential Reforms under Consideration
A.
NYISO’s Current Planning for Resource Adequacy
Through the NYISO’s Comprehensive System Planning Process,7 as well as its
compliance with applicable reliability standards and rules, the NYISO conducts recurring long-
term and near-term reliability analyses to assess and plan for the New York Control Area
(“NYCA”), including the identification of solutions to needs on the bulk power system.8
Specifically, in its Reliability Planning Process, the NYISO, in coordination with the NYPSC,
Transmission Owners, and stakeholders, plans for the adequacy and reliability of the system
based on established reliability criteria.9 The biennial evaluation is complemented by quarterly
short-term assessments of reliability over a five-year horizon in accordance with the Short-Term
Reliability Process, which is the principal mechanism to evaluate generators seeking to
deactivate and to provide for interim service and reliability-must-run arrangements.10 The
Reliability Planning Process contains the following essential steps: the identification of
reliability needs, the solicitation of proposals for both market-based and regulated solutions, the
3 Id. at P 128.
4 Id. at PP 4, 128.
5 Id. at P 129.
6 Id.
7 Capitalized terms that are not otherwise defined in this filing shall have the meaning specified in
Attachments Y or FF of the NYISO’s OATT, and if not defined therein, in the OATT and the NYISO’s Market
Administration and Control Area Services Tariff (“Services Tariff”).
8 Attachment Y of the OATT contains the components of the Comprehensive System Planning Process,
including the Reliability Planning Process, and Attachment FF contains the Short-Term Reliability Process.
9 The applicable reliability criteria include “[t]he electric power system planning and operating policies,
standards, criteria, guidelines, procedures, and rules promulgated by the North American Electric Reliability
Corporation (“NERC”), Northeast Power Coordinating Council (“NPCC”), and the [NYSRC], as they may be
amended from time to time.” OATT § 31.1.
10 OATT § 38.
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Honorable Debbie-Anne A. Reese
July 20, 2026
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NYISO’s evaluation of these proposed solutions, and the implementation of regulated solutions
when market-based projects do not timely resolve anticipated reliability deficiencies.11
Over the last several reliability planning cycles, the NYISO’s studies have identified
increasing risks in the long-term planning horizon that indicate potential shortfalls in available
generation across the New York region. Recent reliability studies have highlighted trends
leading to increasing risks, such as (1) the deactivation of existing resources and the aging
generation fleet continue to outpace the entry of new resources able to provide the necessary
attributes for maintaining the reliability of the system; (2) the impact of growing electricity
demand from new large loads and electrification; and (3) New York’s reliance on imports from
external control areas.
In the most-recently completed Reliability Needs Assessment (“RNA”), the NYISO
identified a reliability need in New York City beginning in summer 2033 related to transmission
security that would continue to reduce margins through 2034 causing a potential statewide
resource deficiency without further resource additions.12 Following the conclusion of that study,
the NYISO received updates to the system conditions (i.e., a reduction in the demand forecast for
the affected zone) that resulted in the 2025-2044 Comprehensive Reliability Plan (“CRP”)
determining that the baseline actionable reliability need was no longer observed.13 However, the
CRP pointed out that there are potential long-term system resource adequacy needs on the
horizon and that the “grid is at an inflection point” due to the aging of the existing generation
fleet, the rapid growth of large loads, and the increasing difficulty of developing new
dispatchable resources.14 The CRP noted that there are clear pathways to maintaining system
reliability, including (1) accelerating the entry of resources in the development pipeline, (2)
preserving or replacing critical dispatchable capability, and (3) adding new firm capacity. While
the NYISO’s role is to evaluate future system conditions, including identification of potential
violations of applicable reliability criteria, and send price signals through its wholesale markets,
the CRP emphasized there is an imminent need to move the grid to a more proactive framework
that involves anticipating risks and enabling timely investment.15
The NYISO is currently preparing the 2026 RNA and targeting completion in November
2026. The 2026 RNA evaluates the reliability of the New York bulk electric grid over the ten-
year planning horizon with a focus on 2030 through 2036, considering updated forecasts of grid
11 OATT §§ 31.2.4, 31.2.5, 31.2.8
12 New York Indep. Sys. Operator, Inc., 2024 Reliability Needs Assessment (RNA) (November 19, 2024), at p
6, available at https://www.nyiso.com/documents/20142/2248793/2024-RNA-Report.pdf/. While the 2024 RNA
did not find a violation of the resource adequacy criterion, the nature of the transmission security violation was
indicative of localized resource deficiencies that continued growth in demand or retirement of resources retire could
result in a violation of the resource adequacy criterion.
13 New York Indep. Sys. Operator, Inc., 2025-2044 Comprehensive Reliability Plan (November 21, 2025), at
p 5, available at https://www.nyiso.com/documents/20142/2248481/2025-2034-Comprehensive-Reliability-
Plan.pdf/.
14 Id. Findings from the 2025-2044 CRP continue to be supported in the findings from the recent Short-Term
Assessments of Reliability. In the 2026 Quarter 2 Short-Term Assessment of Reliability, the NYISO confirmed that
there are continuing to be supply deficiencies in New York City that necessitate retaining existing generation in that
zone. See New York Indep. Sys. Operator, Inc., 2026 Quarter 2 Short-Term Assessment of Reliability (July 14,
2026), available at https://www.nyiso.com/documents/20142/16004172/2026-Q2-STAR-Report-vFinal.pdf/.
15 2025-2044 Comprehensive Reliability Plan at p 12.
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Honorable Debbie-Anne A. Reese
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demand according to the 2026 Load and Capacity Report (“Gold Book”), planned transmission
upgrades, and projected changes to the generation fleet. The NYISO recently posted the
preliminary results for review and discussion in its governance process. Based on the
preliminary results, the NYISO could identify a statewide resource adequacy criterion violation
that would first occur in 2033 and increase through 2036 with a deficiency greater than 1,800
MW when accounting for forecasted large load growth. More localized reliability needs are also
likely to be identified in New York City beginning in 2031.16
Identification of a reliability need is a potential outcome of NYISO’s planning process by
design and does not mean the process is inadequate. Furthermore, the NYISO believes that
prudently planning for the New York bulk power system should include assessing risks and
evaluating whether existing processes should be further strengthened to be able to respond in
today’s and the future’s planning environments. As a result, the NYISO is continuing to engage
the NYPSC, the NYSRC, Transmission Owners, and stakeholders on pursuing targeted reforms
as more fully detailed in Part II.C, below.
B.
NYISO’s Existing Processes to Attract and Retain Resources
Supported by the findings in its reliability studies, the NYISO recognizes the need to
consider opportunities to enhance processes to address emerging reliability challenges, including
statewide resource adequacy concerns, increasing uncertainty, and changing resource
development timelines. The NYISO’s existing processes, however, continue to provide a strong
foundation to attract and retain resources, including in response to the NYISO’s identification of
resource deficiencies or reliability needs due to changing system conditions or additions of large
loads.
1.
NYISO’s Wholesale Capacity Market Supports Resource Adequacy
through Efficient Market Signals
Competitive wholesale electricity markets, adopted in New York pursuant to the
NYPSC’s “Competitive Opportunities” proceeding,17 and operating under this Commission’s
jurisdiction, are an efficient and necessary element in planning for and obtaining sufficient
resources to address new large loads. The NYISO’s wholesale markets are designed, and
continue to evolve and adapt, to send efficient price signals to guide and attract new market entry
and retention of resources that support reliability. The NYISO’s wholesale capacity market is
designed to provide sufficient resources required to meet resource adequacy needs and are an
important aspect to maintaining reliability of the grid.
The NYISO’s capacity market is structured to incentivize the availability of sufficient
resources to meet New York’s resource adequacy requirements. Resource adequacy in New York
State is maintained through a series of related processes administered by the NYSRC and the
NYISO. Through these processes and requirements, New York has some of the most stringent
16 New York Indep. Sys. Operator, Inc., 2026 RNA: Preliminary Base Case Draft Results (July 23, 2026),
available at https://www.nyiso.com/documents/20142/58620525/03_2026RNA_PreliminaryDraftResults-
July23ESPWG-TPAS.pdf.
17 NYPSC Case No. 93-M-0229, Order Instituting Proceeding (March 19, 1993).
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Honorable Debbie-Anne A. Reese
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reliability standards across the country. The NYSRC conducts an annual probabilistic,
engineering-based study to inform its establishment of an installed reserve margin (“IRM”) for
the upcoming Capability Year. The IRM represents an additional quantity of capacity that must
be procured above the NYISO’s forecasted peak load to meet a resource adequacy criterion of
not exceeding a loss of load expectation (“LOLE”) greater than 0.1 loss of load event days per
year. Each year’s IRM is filed by the NYSRC with both the Commission and the NYPSC.18
In addition to procuring enough capacity to meet the IRM, the NYISO’s capacity market
provides fixed cost recovery for investments and essentially acts as a call option on future
energy. Revenues available from capacity market participation also help mitigate extreme price
and revenue volatility that energy-only markets can be susceptible to. Taken together, the
NYISO’s wholesale markets are designed to send efficient price signals to attract and retain
resources with the necessary reliability characteristics to serve the need presented by the
evolving grid.
2.
Robust Participation in the NYISO’s Interconnection Procedures Shows
that the NYISO’s Wholesale Markets are Sending Efficient Price Signals
The Cluster Study Process that the NYISO instituted in response to Order No. 2023 has
already shortened and improved the process for interconnecting resources to the New York
system. While the pace of new entry achieving commercial operation has been, and is forecasted
to continue to be, a concern, a significant number of proposed resources have already completed
the interconnection process or are currently participating in the nearly completed inaugural
Transitional Cluster Study.
Prior to the implementation of the Cluster Study Process, a number of projects had
completed their interconnection studies through a Class Year Study or the NYISO’s Small
Generator Interconnection Procedures. As of this filing, the New York region has 89 projects,
representing over 11 GW of generation, that have completed the interconnection study process
but have yet to enter commercial operation.
The current Transition Cluster Study, which commenced on August 1, 2024, is nearing
completion and currently has 91 projects, representing over 15 GW of generation. The
Transition Cluster is scheduled to be completed later this year. Interconnection Customers will
be required to enter into an interconnection agreement and can then move forward with bringing
its resource into commercial operation. The next Cluster Study Application Window is
scheduled to begin on July 31, 2026. The NYISO anticipates continued, significant interest by
Interconnection Customers seeking to interconnect resources to the New York system.
Even with the efficiency of its Transitional Cluster Study, the NYISO builds on its
established track record of continuous process improvement efforts by pursuing further
enhancements to its procedures. In May 2026, the NYISO filed two portfolios of enhancements
18 See, e.g., New York State Reliability Council, L.L.C., Docket No. ER26-885-000 (December 23, 2026);
NYPSC Case No. 05-E-1180, Installed Reserve Margin for the New York Control Area, Comments of the New York
State Reliability Council of the Installed Reserve Margin for the 2026-2027 Capability Year (January 23, 2026).
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Honorable Debbie-Anne A. Reese
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and improvements pursuant to Section 205 of the FPA aimed at creating further efficiencies in
the Cluster Study Process, as well as updating its methodology to appropriately identify
deliverability upgrades.19 With these further enhancements, the NYISO’s interconnection
procedures will be able to provide further efficiencies and reduce barriers for new entry.
The number of resources being proposed in New York is a positive indication that
interconnection customers are responding to price signals from the markets and/or findings from
the NYISO’s planning studies. To the extent that these resources become operational, they will
help address the NYISO’s resource adequacy and reliability needs into the future. However,
factors outside the NYISO’s interconnection process significantly impact whether a project is
constructed, including, but not limited to, permitting, siting, supply chain issues, and financing.
The NYISO is working with New York State to address issues impacting the barriers to bringing
new resources and repowering of existing resources with the necessary reliability attributes to
maintain reliability in the future.
3.
NYISO’s Reliability Planning Process Provides an “All Resource Type”
Approach to Maintain Resource Adequacy Over a Ten-Year Horizon
The NYISO’s system and resource planning processes further support its wholesale
markets by providing robust studies of the New York bulk power system to provide information
and prepare plans for, among other things, future system conditions and maintaining reliability
over a ten-year horizon. Specifically, the planning processes complement the markets by
forecasting future system conditions and resource needs beyond the market horizon. Such
forward-looking information serves to guide investment decisions so that resources can be
developed in time to meet future market procurements. New York has seen success in its use of
the planning processes to expand the transmission system, including the selection of four
significant transmission projects to address Public Policy Transmission Needs identified by the
NYPSC through the NYISO’s process. Continuing to build on such success, the NYISO,
together with its stakeholders, has worked over the past several years to further align its planning
studies and market price signals to better reflect operational reliability. As a result, the NYISO’s
planning studies and wholesale markets already provide mechanisms to address resource
shortfalls due to increased demand from large loads or other system changes.
The Reliability Planning Process provides a meaningful avenue for the NYISO, in
coordination with the NYPSC, Transmission Owners, and stakeholders, to maintain resource
adequacy as the grid changes and evolves, including large loads entering operation. The
NYISO’s reliability studies currently incorporate large loads through demand forecasts.20 Large
19 New York Indep. Sys. Operator, Inc., Proposed Tariff Revisions Regarding Interconnection Process
Improvements, Docket No. ER26-2698-000 (May 29, 2026) (proposing revisions to incorporate additional
improvements and efficiencies in the Cluster Study Process); New York Indep. Sys. Operator, Inc., Proposed Tariff
Revisions to Revise the Deliverability Test Methodology, Docket No. ER26-2577-000 (May 19, 2026) (proposing
revisions to the existing deliverability methodology to provide Interconnection Customers with clearer, more
realistic and more equitable outcomes related to the identified upgrades for a project).
20 See generally, NYISO Response to Chairman David Rosner’s September 19, 2025 Letter, re: Large Load
Forecasting for America’s Significant Electricity Demand Growth (October 31, 2025), available at
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Honorable Debbie-Anne A. Reese
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loads are included when they demonstrate that a project is sufficiently advanced in its
development to be included in system planning.21 Using those demand forecasts, the NYISO
evaluates the 10-year horizon to identify whether there are violations of the resource adequacy
criterion or other reliability criteria. If the analysis results in the identification of a reliability
need due to, for instance, a shortfall in supply, the process is structured as an “all resource type”
approach that enables the NYISO to consider market-based solutions and regulated solutions to
develop a plan that addresses a reliability need. Specifically, a Responsible Transmission Owner
must submit a proposal for a regulated backstop solution, while other developers may submit
market-based solutions or regulated proposals. Both market-based and regulated solutions can
consist of generation, demand response, and transmission.22
Consistent with the purpose and structure of the NYISO’s wholesale markets, the
Reliability Planning Process first looks to whether proposed market-based solutions are
sufficient to address a reliability need. This process is aimed at limiting the potential costs to
ratepayers by not triggering regulated solutions unless it is essential in order to timely address a
need. Developers with market-based solutions that they believe can address the identified
reliability need are encouraged to submit their project information for the NYISO to consider
whether they are viable and sufficient.23 If there are viable and sufficient market-based solutions
to address the reliability need, then the NYISO would not trigger a viable and sufficient
regulated solution to begin permitting and construction.24
The Reliability Planning Process was designed to coordinate the roles of the NYISO and
the NYPSC in addressing reliability needs. Specifically, the NYISO is responsible for
developing its regional plan, including evaluating the viability and sufficiency of submitted
proposals and evaluating and selecting transmission solutions that address needs more efficiently
or cost effectively and are eligible for cost allocation under the OATT. The NYPSC is
responsible for planning for resources and the generation mix, including the permitting of
projects and approving cost allocation for generation and demand response solutions under state
law. Consistent with the NYPSC’s description of its responsibilities in its July 11, 2026 filing in
this docket,25 the NYISO’s Reliability Planning Process enables the NYPSC to take the
https://www.ferc.gov/media/nyiso-response-chairman-david-rosners-09192025-letter-re-large-load-forecasting-
americas (detailing how large loads are incorporated into the NYISO’s system and resource planning).
21 See generally, NYISO Reliability Planning Process Manual at Section 3.2.1.
22 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
which the Developer is seeking to obtain regional cost allocation through the appropriate state agency.” New York
Sys. Operator, Inc., et al., Compliance Filing, Docket No. ER13-102-000 (October 13, 2013), at n 8; see generally
OATT § 31.5.6.1 (providing that “[c]osts related to regulated non-transmission projects will be recovered by
Responsible Transmission Owners, Transmission Owners and Other Developers in accordance with the provisions
of New York Public Service Law, New York Public Authorities Law, or other applicable state law”).
23 OATT §§ 31.2.4.5, 31.2.5.
24 OATT § 31.2.8.1.1 (providing that “[t]he ISO will not trigger a regulated solutions if, based on [its] review,
it determines prior to or at the Trigger Date for a regulated solution: (i) that sufficient market-based solutions are
timely progressing to meet the Reliability Need by the need date or (ii) that, based upon the circumstances at the
time of review, there is no longer a Reliability need”).
25 New York Indep. Sys. Operator, Inc., et al., Notice of Intervention and Preliminary Comments of the New
York State Public Service Commission, Docket No. EL26-69-000 (July 9, 2026), at p 3 (“New York . . . is well
positioned to address any resource adequacy issues that may arise”).
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Honorable Debbie-Anne A. Reese
July 20, 2026
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necessary and timely action to ensure that adequate generation timely materializes when there is
a reliability need that requires the addition of more generating capacity and there are insufficient
responses from the marketplace.
Therefore, when there are insufficient market-based solutions to address a Reliability
Need and the need cannot be solved through transmission solutions received by the NYISO, the
Reliability Planning Process provides that the NYISO can indicate to a Responsible
Transmission Owner or other developer that submits a regulated non-transmission solution (i.e.,
a solution for which cost allocation and recovery is sought or intended to be sough under state
law) to submit its solution to the NYPSC for consideration.26 The NYPSC then has the
responsibility to consider submitted regulated generation or demand response solutions that
should move forward and obtain cost recovery under state law.27 The allocation of the costs for
the development of the regulated generation or demand response solution would be determined
by the NYPSC, including for resource adequacy issues caused by, for instance, a large load.28
The NYISO monitors the progress of such solutions to determine whether they are adequately
moving forward or whether the NYISO needs to amend its plan to maintain reliability.29 For
instance, the NYISO can work with the NYPSC under the NYISO’s gap solution process if
solutions do not materialize and there is an imminent need, which could include the NYPSC
acting on generation solutions through its jurisdiction over their permitting, siting, or cost
recovery.30
26 See OATT §§ 31.2.8.1.2, 31.2.8.1.4, 31.2.8.1.8.
27 In response to the reforms to the NYISO’s Reliability Planning Process to comply with the requirements of
Order No. 890, the NYPSC adopted policy statements that provided procedures to allocate and recover costs for
regulated non-transmission solutions under state law to enable parties to voluntarily propose such solutions through
the NYISO’s process. See NYPSC Case No. 07-E-1507, Proceeding to Establish a Long-Range Electric Resource
Plan and Infrastructure Planning Process, Revised Policy Statement and Backstop Project Cost Recovery and
Allocation (June 26, 2009), available at https://documents.dps.ny.gov/public/Common/ViewDoc.aspx?
DocRefId={D5E49062-1410-400F-A419-A4307019DF92}; NYPSC Case No. 07-E-1507, Proceeding to Establish
a Long-Range Electric Resource Plan and Infrastructure Planning Process, Policy Statement on Backstop Project
Cost Recovery and Allocation (February 18, 2009), available at https://documents.dps.ny.gov/public/Common/
ViewDoc.aspx?DocRefId={71B60BC7-D5EE-41C3-BB4B-5E1F13B5BD74}&DocTitle=Proceeding%20to%20
Establish%20a%20Long-Range%20Electric%20Resource%20Plan%20and%20Infrastructure%20Planning%20
Process,%20Policy%20Statement%20on%20Backstop%20Project%20Approval%20Process; NYSPC Case No. 07-
E-1507, Proceeding to Establish a Long-Range Electric Resource Plan and Infrastructure Planning Process, Policy
Statement on Backstop Project Cost Recovery and Allocation (April 24, 2008), available at https://documents.dps.
ny.gov/public/Common/ViewDoc.aspx?DocRefId={8E7255F6-DBB9-46DC-9DE3-FA35581125F2}&DocTitle=
Long-Range%20Electric%20Resource%20Plan%20and%20Infrastructure%20Planning%20Process,%20Policy
%20Statement%20on%20Backstop%20Project%20Cost%20Recovery%20and%20Allocation.
28 See generally, June 2026 Order at PP 53–54 (recognizing that “the FPA expressly reserves to states the
authority over any other sale of electric energy, including retail sales and wholesale sales not in interstate commerce
. . . , as well as facilities used for the generation and distribution of electricity”).
29 OATT §§ 31.2.8.1, 31.2.8.3.1.
30 OATT § 31.2.11.PDF page 9
Honorable Debbie-Anne A. Reese
July 20, 2026
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C.
Potential Reforms under Consideration that Would Support Resource
Adequacy and Increase the Pace of Generation Additions
In its June 2026 Order, the Commission directed the NYISO to submit any proposals
under consideration in its stakeholder process to address the issue of resource adequacy to serve
new large loads.31 The Commission also directed the NYISO to identify any stakeholder
processes that aim to increase the pace of adding generating capacity in the NYCA.32 In
response to the Commissions directives, the NYISO identifies below the potential reforms that
are under consideration that could further enable supply-side solutions through its Reliability
Planning Process and enhancements to its markets to further enable maintaining resource
adequacy in the New York region. While the identified reforms encompass potential concepts
that the NYISO is considering through its shared governance process, the NYPSC has and is
undertaking other efforts to similarly address ensure resource adequacy for the New York region
in light of the increasing energy demand challenges.33
As discussed above, the NYISO’s wholesale markets, approach to planning for the
reliability of the New York bulk power system, and coordination with New York State provide a
strong foundation to incentivize new entry and retention of existing supply.34 The NYISO,
however, has acknowledged that the pace of change on the system and difficulties in bringing
new resources onto the system following completion of the interconnection studies warrant
pursuing proactive planning approaches to further reduce the risks of shortfalls in supply.35
Accordingly, the NYISO identifies the following planning and market initiatives to further
support resource adequacy in the New York region and help to increase the pace of generation
additions.
31 June 2026 Order at P 128.
32 Id. at P 129.
33 See, e.g., NYPSC Case No. 26-E-0335, Proceeding on Motion of the Commission to Implement a Nuclear
Reliability Backbone, Order Establishing a Nuclear Reliability Backbone Process (June 11, 2026), available at
https://documents.dps.ny.gov/public/Common/ViewDoc.aspx?DocRefId={1059B79E-0000-CE15-AF3E-
A1872B97EDC3}&DocTitle=Order%20Establishing%20a%20Nuclear%20Reliability%20Backbone%20Process
(initiating, in support of New York Governor’s 2026 executive order and State of the State address, a proceeding to
evaluate the development of five gigawatts of nuclear generation assets and necessary transmission facilities,
including the potential mechanisms for integrating new nuclear timely, cost-effectively, and with maximum benefits
to New York’s electric grid and ratepayers); NYPSC Case No. 26-E-0045, Interconnection Reforms for Large Loads,
Order Instituting Proceeding and Soliciting Comments (February 12, 2026), available at https://documents.dps.ny.
gov/public/Common/ViewDoc.aspx?DocRefId={B040539C-0000-CB26-AEB3-8C865EF3724D}&DocTitle=
Order%20Instituting%20Proceeding%20and%20Soliciting%20Comments (examining the impact of large loads and
actions that New York State should take to reform the interconnection of large loads to the New York region); New
York State Energy Planning Board, 2025 New York State Energy Plan (SEP) (July 23, 2025), available at
https://energyplan.ny.gov/Plans/2025-Energy-Plan (providing an outlook through 2040 that sets New York’s long-
range energy planning objectives, including “[i]mproving the reliability of the New York State’s energy systems”);
NYPSC Case No. 20-E-0197, Transmission Planning Pursuant to the Accelerated Renewable Energy Growth and
Community Benefit Act, Order Approving a Coordinate Grid Planning Process (August 17, 2023) available at
https://documents.dps.ny.gov/public/Common/ViewDoc.aspx?DocRefId={101C058A-0000-C45D-9CD3-A87E49
DF7A99}&DocTitle=Order%20Approving%20a%20Coordinated%20Grid%20Planning%20Process.
34 New York Indep. Sys. Operator, Inc., et al., Notice of Intervention and Preliminary Comments of the New
York State Public Service Commission, Docket No. EL26-69-000 (July 9, 2026), at p 3.
35 See Part II.A, supra.PDF page 10
Honorable Debbie-Anne A. Reese
July 20, 2026
Page 10
1.
Potential Planning Reforms under Consideration
As a result and following the publication of the 2025-2044 CRP, the NYISO has been
considering whether any reforms are necessary to further incentivize increasing the pace of new
resource additions when a reliability need is identified. Specifically, the NYISO prioritized a
project for 2026 aimed at enhancing the Reliability Planning Process to, among other things,
implement scenario planning and incentivize supply-side solutions to address resource adequacy
and reliability violations caused by insufficient supply. At the beginning of 2026, the NYISO
started the project first with discussions over the implementation of scenario planning in
reliability studies in an attempt to have a concrete proposal in time for the 2026 RNA. However,
based on stakeholder feedback and the need for additional consideration, the NYISO revised its
schedule and targeted reforms for the end of 2026 / beginning of 2027, including further enabling
supply-side solutions. On March 26, 2026, the NYISO solicited high-level feedback on the
reforms to incentivize supply-side solutions. The NYISO investigated potential options with
stakeholders, such as further enabling the consideration of supply-side solutions for system-wide
reliability needs; differentiating interconnection treatment or processes for supply-side solutions
that are needed to address resource shortfalls; and identifying any market impediments to supply-
side solutions that can be addressed through the NYISO’s process.36
The NYISO returned to its discussions on potential reforms with its Electric System
Planning Working Group and Transmission Planning Advisory Subcommittee on July 16, 2026.37
The NYISO focused on considering reforms to the Reliability Planning Process to enhance its
ability to identify solutions to further enable an “all resource type” approach to addressing
Reliability Needs, including the proposed concepts and timeline discussed below.
a.
Establish an Accelerated Interconnection Study Path for Certain
Resources
The NYISO is discussing with stakeholders a proposal to establish an accelerated
interconnection study path for resources that are needed to address a reliability need identified in
the Reliability Planning Process or Short-Term Reliability Process.38 This proposal is intended
to provide a framework for a separate accelerated interconnection study for generators that have
been identified as viable and sufficient to timely address a reliability need in the Reliability
Planning Process. While the Cluster Study Process has resulted in improved processing times
for projects, this separate study path could accommodate a new resource that is on a shorter
timeframe than the Cluster Study Process. The NYISO is considering eligibility for facilities to
use this path, including those that are proposed to address an urgent reliability or resource
adequacy need identified by the NYISO.
36 New York Indep. Sys. Operator, Inc., Reliability Planning Process Reforms: Updated Schedule (March 26,
2026), available at https://www.nyiso.com/documents/20142/57510547/02_RPP_Reform_ESPWG_032626.pdf/.
37 New York Indep. Sys. Operator, Inc., Reliability Planning Process Reforms: Enabling Supply-Side
Solutions (July 16, 2026), available at https://www.nyiso.com/documents/20142/58534496/RPP_Reform_ESPWG
_071626.pdf/.
38 See id.
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Honorable Debbie-Anne A. Reese
July 20, 2026
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Having already introduced stakeholders to this concept, the NYISO will continue to
discuss and develop this proposal to establish the framework and parameters of a separate
accelerated interconnection study path for generators needed to address reliability needs. For
instance, the NYISO will work to develop criteria that will apply to an interconnection request
submitted in the accelerated interconnection study, as well as other parameters, to limit the
number of interconnection requests to those that are necessary to address a reliability need and
limit disruptions to the Cluster Study Process. In developing the criteria, the NYISO will
consider similar approaches that the Commission has accepted in other regions.39
While the NYISO acknowledges that this targeted reform will not remove all barriers
affecting the addition of resources in the New York region, it will reduce the potential that the
interconnection process will impede the ability of a generation solution to address a need.
b.
Enhancements to the Criteria Used to Consider Modifications to
Existing Resources
The NYISO is also discussing enhancements to its existing interconnection process to
better align the parameters for modifications to an existing generator to allow changes, such as
repowering, with the ability to address emerging needs related to reliability, including resource
adequacy. This proposed reform would further enable existing facilities to be modified without
the need for restudy through a full Cluster Study, provided that there are no impacts to reliability
of the system based on the NYISO’s assessment. The proposed revisions would not seek to
change the material modification provisions in the Cluster Study Process for interconnection
requests undergoing a study. Rather, it will consider whether certain changes to technology, fuel,
equipment, and level of interconnection service of existing facilities that do not affect reliability
should be permitted without the need for a new interconnection request, particularly for
repowering and other projects that can support reliability, including resource adequacy.
c.
Enhancements to the Processing and Identification of Needs and
Solutions in the Reliability Planning Process
The NYISO also is considering whether enhancements to the Reliability Planning
Process could further incentivize developers’ involvement in proposing viable and sufficient
solutions to timely meet a future reliability need.
First, the NYISO is considering the treatment of a large load’s contribution to a resource
deficiency identified in the Reliability Planning Process. The NYISO’s Reliability Planning
Process includes large loads in the RNA’s system representation when they have reached a
specified level of development. If the NYISO identifies a resource deficiency and the large
load(s) directly contributes to such deficiency, then the NYISO is considering assigning the
39 See, e.g., Midcontinent Indep. Sys. Operator, Inc., Revisions to the Open Access, Energy and Operating
Reserve Tariff Expedited Resource Addition Study Filing, ER25-2454-000 (June 6, 2025), accepted, subject to
condition Midcontinent Indep. Sys. Operator, Inc., 192 FERC ¶ 61,064 (2025); PJM Interconnection, L.L.C., Tariff
Revisions for Reliability Resource Initiative, Docket ER25-712-000 (December 13, 2024), accepted by PJM
Interconnection, L.L.C., 190 FERC ¶ 61,084 (2025).
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Honorable Debbie-Anne A. Reese
July 20, 2026
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responsibility for addressing that resource deficiency, including the addition of resources, to the
large load(s).
Second, the NYISO is considering targeted enhancements to the current Reliability
Planning Process to, among other things, clarify the types of solutions that can be submitted;
clarify how the NYISO performs the viability and sufficiency assessment when separately
proposed solutions when combined can address a need; and encourage solutions that can address
multiple, identified reliability needs. For instance, the NYISO’s Reliability Planning Process
looks at all solution types in addressing a reliability need, which the tariff specifically references
generation, demand response, and transmission. However, there are other proposals that
developers or facility owners could offer that change the manner in which existing facilities
perform on the system resulting in a positive impact on an identified reliability need. For
instance, firm fuel contracts, flexibility of a load, and repairs or other adjustments to a generator
or transmission facility that improve its performance or lifespan could potentially address or
reduce a violation on the system. Having rules that detail how interested parties can make such
proposals—and how the NYISO will consider them—will facilitate potentially cost-efficient
solutions.40
These reforms, when paired with the NYISO’s ongoing reform proposal to establish
scenario planning in the Reliability Planning Process, are intended to provide a more
comprehensive, proactive approach to addressing resource adequacy issues where transmission
solutions would be unable to by themselves due to the unavailability of supply within the
NYCA.41 The NYISO, however, notes that these are contemplated reforms within its
responsibilities, and it plans on continuing to work with the NYPSC and other entities to reduce
other barriers to resources entering service beyond the NYISO’s processes.
The NYISO plans to continue discussions with its stakeholders in the preparation of
above-referenced potential reforms to address maintaining resource adequacy and increasing the
pace of generation additions. The NYISO seeks to implement any reforms to support the
identification of solutions in the 2027-2036 CRP to any identified reliability needs. As a result,
the NYISO will continue to discuss concepts with stakeholders to fully develop through October
2026 and finalize any proposals by the end of 2026. The NYISO targets review and approval
from the NYISO’s Operating Committee, Management Committee, and Board of Directors
40 Similar to the Commission’s requirements in Order No. 1920 to consider and evaluate the benefits of
incorporating certain alternative transmission technologies into a transmission provider’s consideration of the more
efficient or cost-effective transmission solution, certain modifications or changes to existing facilities that could
address the need without the need for more significant investments should be considered on a comparable basis in
the NYISO’s evaluation. See Building for the Future Through Electric Regional Transmission Planning and Cost
Allocation, Final Rule, Order No. 1920, 187 FERC ¶ 61,068 (2024), at PP 1163–66, 1239–41.
41 New York Indep. Sys. Operator, Inc., Reliability Planning Process Reforms: Enabling Supply-Side
Solutions (July 17, 2026); New York Indep. Sys. Operator, Inc., Reliability Planning Process Reforms: Updated
Schedule (March 26, 2026), available at https://www.nyiso.com/documents/20142/57510547/02_RPP_Reform
_ESPWG_032626.pdf/; see also New York Indep. Sys. Operator, Inc., Reliability Planning Process Reform: STRP
Process Proposal, RPP Tariff Revisions (February 26, 2026), available at https://www.nyiso.com/documents/20142/
57254820/02a_RPP_Reform_ESPWG_022626_final.pdf/.
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Honorable Debbie-Anne A. Reese
July 20, 2026
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between January and March 2027 with a filing submitted to the Commission under Section 205
of the FPA in or around March 2027, subject to necessary approvals.
2.
Potential Market Reforms under Consideration
The NYISO endeavors to continually align market price signals with its evolving
reliability needs, creating incentives for investments to ensure resource adequacy. Expected
reforms to the NYISO’s ancillary services market include: (1) an initiative for balancing
intermittency with the introduction of Uncertainty Reserve Requirements in the Day-Ahead and
Real-Time Markets to procure reserves for forecast uncertainty in net load and intermittent
generation and (2) an initiative to enhance Dynamic Reserves through the introduction of reserve
requirements that dynamically reflect actual grid and market conditions by including the largest
contingencies and transmission constraints. The Balancing Intermittency enhancements are
scheduled to be effective this year, and the Dynamic Reserves initiative is expected to be
implemented in 2028.
Likewise, reforms are underway in the NYISO’s capacity market to help incentivize
investment for resource adequacy. These include, implementing improvements this year to the
capacity accreditation framework under the “Installed Capacity Accreditation Rules for Fuel
Supply Constraints” to value resources with firm access to natural gas or fuel oil in response to
increasing winter resource adequacy challenges to further incentivize winter fuel supply
availability. Next year, the NYISO will be moving from an annual Capacity Market that is based
solely on reliability needs in the summer to a seasonal market incorporating winter reliability
needs.42 This enhancement will help send price signals for investment during the periods of
increased resource adequacy risk. Additionally, the NYISO is pursuing several reforms to
support resource adequacy through the capacity market demand curve determination process,
which is a part of the stakeholder project referred to as “Demand Curve Reset Process and
Methodology Improvements.”43 The objectives of these reforms are to strengthen investor
confidence by creating more durable and predictable Installed Capacity (“ICAP”) demand curves
and enhancing long-term investment planning decisions. The NYISO has been actively engaged
with its stakeholders in this effort and expects to finalize the reforms in 2026 so that they may be
included in the next Demand Curve reset process starting in 2027.
Also, in collaboration with the NYSRC, the NYISO annually assesses desired
improvements to the resource adequacy modeling assumptions to reflect emerging reliability
needs. A multi-year strategy44 is being developed to prioritize modeling improvements that are
aligned with key NYSRC and NYISO initiatives. The current focus in the 2026-2030 strategic
plan is on improving the representation of winter reliability risks; developing improvements to
42 New York Indep. Sys. Operator, Inc., 195 FERC ¶ 61,250 (2026).
43 See New York Indep. Sys. Operator, Inc., Demand Curve Reset Process and Methodology Improvements
(January 12, 2026), available at https://www.nyiso.com/documents/20142/56339181/DCR%20Process%20
Improvements%20-%2001122026%20ICAPWG%20Final.pdf/.
44 See New York Indep. Sys. Operator, Inc., NYISO Resource Modeling Improvements: Strategic Plan (2026-
2030) (October 1, 2025), available at https://www.nysrc.org/wp-content/uploads/2025/10/4.1.3-RA-Modeling-
Improvement-2026-Strategic-Plan-10012025-ICS-Attachment-4.1.3.pdf.
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Honorable Debbie-Anne A. Reese
July 20, 2026
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load modeling to capture evolving winter load shapes, the impacts from new large loads, and
offsets from behind the meter solar resources; and ensuring that energy limited resources are
represented consistent with operational experiences. The plan is refreshed annually to ensure
improvements are focused on the most up-to-date strategic priorities.
III.
Communications
All communications and service with regard to this filing should be directed to:
Robert E. Fernandez, Executive Vice President,
Chief Compliance Officer & General Counsel
Karen Georgenson Gach, Deputy General Counsel
Stephanie Amann, Senior Manager, Regulatory &
Government Affairs
*Brian R. Hodgdon, Senior Attorney
New York Independent System Operator, Inc.
10 Krey Boulevard
Rensselaer, NY 12144
Tel: (518) 356-6000
Fax: (518) 356-4702
bhodgdon@nyiso.com
*Ted J. Murphy
Hunton Andrews Kurth LLP
2200 Pennsylvania Avenue, NW
Washington, D.C. 20037
Tel: (202) 955-1500
Fax: (202) 778-2201
tmurphy@hunton.com
* Persons designated for receipt of service.
IV.
Conclusion
Wherefore, the NYISO respectfully requests that the Commission accept this
informational report in response to the requirements of the directive in the Commission’s Order
Instituting Proceeding Under Section 206 of the Federal Power Act issued in the above-
captioned docket.
Respectfully submitted,
/s/ Brian R. Hodgdon
Brian R. Hodgdon
Senior Attorney
New York Independent System Operator, Inc.
cc:
Janel Burdick
Emily Chen
James Dawson
Jignasa Gadani
Leanne Khammal
Jaime Knepper
David Morenoff
Jason Rhee
Douglas Roe
PDF page 15
CERTIFICATE OF SERVICE
I hereby certify that I have this day served the foregoing document upon each person
designated on the official service list compiled by the Secretary in this proceeding in accordance
with the requirements of Rule 2010 of the Rules of Practice and Procedure, 18 C.F.R. §385.2010.
Dated at Rensselaer, NY this 20th day of July 2026.
/s/ Alexander Morse
Alexander Morse
New York Independent System Operator, Inc.
10 Krey Blvd.
Rensselaer, NY 12144
(518) 285-7826