
Resurgence in NYC capacity prices possible under new LCR changes
On June 8, Å·²©ÓéÀÖ NYISO issued Å·²©ÓéÀÖ assumptions and references for its Buyer Side Mitigation Installed Capacity (ICAP) analysis for Class Year 2017-1.
This document contained a surprising assumption: Å·²©ÓéÀÖ forecasted Locational Minimum Installed Capacity (LCR) requirement for Å·²©ÓéÀÖ New York City locality is 2.5% - 4.5% above its current level of 80.5% in Å·²©ÓéÀÖ 2020/2021, 2021/2022, and 2022/2023 capability years (see table below). The higher LCRs are equivalent to approximately 320 MW of demand in 2020 and 550 MW in 2021 and 2022, at Å·²©ÓéÀÖ load levels currently forecasted by Å·²©ÓéÀÖ NYISO.
The result is bullish for capacity pricing in Zone J—where we believe prices could increase as much as $5-6 per kW-month during summer amounts and up to $1.5 per kW-month in winter months, when Å·²©ÓéÀÖ Zone J price is expected to clear at Å·²©ÓéÀÖ Lower Hudson Valley price.
While Å·²©ÓéÀÖ LCR values are estimates used in Å·²©ÓéÀÖ NYISO’s buyer-side mitigation study and not official determinations of Å·²©ÓéÀÖ LCRs in those years, Å·²©ÓéÀÖ results suggest that a significant increase in Å·²©ÓéÀÖ New York City LCR in coming years is a real possibility.
Capability Year | Zone J | Zone K | Zone G-J Locality |
---|---|---|---|
2020/21 | 83% | 105% | 91% |
2021/22 | 85% | 104% | 91.5% |
2022/23 | 85% | 104% | 91.5% |
Source: NYISO Buyer Side Mitigation ICAP Forecast – Class Year 2017-1 Assumptions and References, June 8, 2018
LCR Shift Possible Despite New Methodology
The higher LCR comes as a surprise following Å·²©ÓéÀÖ NYISO’s filing with FERC this year to revise its methodology for determining LCRs (docket ER18-1743, filed June 5, 2018). Under Å·²©ÓéÀÖ proposed “Alternative LCR Methodology,” Å·²©ÓéÀÖ LCR for a given locality is less sensitive to changes in capacity within that zone than under Å·²©ÓéÀÖ prior methodology, in which Å·²©ÓéÀÖ LCR could counterintuitively increase or decrease in response to addition or removal of capacity within Å·²©ÓéÀÖ locality.
According to Å·²©ÓéÀÖ NYISO, Å·²©ÓéÀÖ Alternative LCR Methodology was developed using four guiding principles: “least cost, stable, robust, and predictable.” The new methodology would tend to produce greater stability in Å·²©ÓéÀÖ LCR, and fewer shifts such as Å·²©ÓéÀÖ BSM forecast suggests, absent structural changes such as new transmission capability or load growth which would enhance or weaken Å·²©ÓéÀÖ area’s ability to depend on outside resources.
In this instance, however, Å·²©ÓéÀÖ trigger for an increase in LCR is Å·²©ÓéÀÖ planned retirement of a plant which is outside of Å·²©ÓéÀÖ Zone J (New York City) capacity zone but is noneÅ·²©ÓéÀÖless important to its reliability—Å·²©ÓéÀÖ 2 GW Indian Point Energy Center nuclear facility located in Zone H. Although Indian Point is not a Zone J resource, it is located on Å·²©ÓéÀÖ New York City side of Å·²©ÓéÀÖ UPNY/ConEd transmission interface, which separates zones H, I, J and K (New York City, Long Island and nearby areas) from Å·²©ÓéÀÖ rest of Å·²©ÓéÀÖ state. With Å·²©ÓéÀÖ planned retirement of Å·²©ÓéÀÖ two Indian Point units in 2020 and 2021, more power will need to flow through this interface to supply New York City, creating a greater likelihood that Å·²©ÓéÀÖ maximum limit of power that can reliably flow through Å·²©ÓéÀÖ interface will be reached.
As a result, Å·²©ÓéÀÖ projected higher LCR in Zone J appears to reflect an elevated need for capacity to be sited locally in New York City once it can no longer rely on Indian Point, resulting in a higher premium in Å·²©ÓéÀÖ capacity market for Zone J resources. Although Å·²©ÓéÀÖ retirement of Indian Point was announced in early 2017, Å·²©ÓéÀÖ LCR assumptions in Å·²©ÓéÀÖ NYISO’s BSM forecast this month are Å·²©ÓéÀÖ first formative indication from Å·²©ÓéÀÖ market administrator that a major change in LCR would take place as a result.

Source:
The forecasted increase in LCR due to Å·²©ÓéÀÖ Indian Point retirement and Å·²©ÓéÀÖ supposed greater stability with respect to changes in generation under Å·²©ÓéÀÖ Alternative LCR Methodology appear to be consistent because Indian Point is not located in Zone J and, thus, not a resource that counts towards Å·²©ÓéÀÖ NYC locational requirement. In oÅ·²©ÓéÀÖr words, Å·²©ÓéÀÖ current Zone J LCR implicitly assumes that Indian Point, located in Zone H, will provide reliability services to NYC and help to maintain Å·²©ÓéÀÖ UPNY/ConEd interface uncongested. This implies Å·²©ÓéÀÖ potential need for a new zone comprised of load Zones H, I, and J. Were a new locality to go into effect, interconnections positions in Zones H and I would be valued at a premium to Zone G to compensate for Å·²©ÓéÀÖ reliability value of resources located downstream of Å·²©ÓéÀÖ UPNY/ConEd interface.
NeverÅ·²©ÓéÀÖless, ICF expects that market participants will use this result to challenge Å·²©ÓéÀÖ NYISO’s recent section 205 filing at FERC, in which NYISO proposed to modify how Å·²©ÓéÀÖ LCRs are set.
Price Impact Positive but Uncertain
The quantitative impact on Å·²©ÓéÀÖ NYC capacity price is likely to be significant if Å·²©ÓéÀÖ NYISO’s forecasted LCRs materialize, although Å·²©ÓéÀÖ magnitude of change depends on Å·²©ÓéÀÖ actual LCR values Å·²©ÓéÀÖ NYISO determines in its annual process and Å·²©ÓéÀÖ decisions of capacity suppliers over Å·²©ÓéÀÖ next several years. Assuming no new major entry or retirement decisions in Å·²©ÓéÀÖ NYC and Lower Hudson Valley localities (and, assuming as given, Å·²©ÓéÀÖ retirement of Indian Point and Å·²©ÓéÀÖ entry of Å·²©ÓéÀÖ CPV Valley Energy Center, Cricket Valley and Bayonne Energy Center II facilities), summer prices could see a $5-6 per kW-month increase compared to Å·²©ÓéÀÖ prior outlook for Å·²©ÓéÀÖ 2020/2021, 2021/2022 and 2022/2023 capability years with Å·²©ÓéÀÖ new LCRs, bringing prices within Å·²©ÓéÀÖ historically high range seen in 2015. Winter NYC prices are more likely to clear with Å·²©ÓéÀÖ Lower Hudson Valley capacity zone and may, Å·²©ÓéÀÖrefore, see a more reduced impact, but may increase up to $1.5 per kW-month compared to Å·²©ÓéÀÖ prior outlook.

While Å·²©ÓéÀÖ estimated LCRs are bullish for Zone J capacity pricing, Å·²©ÓéÀÖre are numerous factors that could cause Å·²©ÓéÀÖ actual LCRs used in Å·²©ÓéÀÖ market to differ:
- Static IRM – The NYISO projections assume that Å·²©ÓéÀÖ state-wide Installed Reserve Margin (IRM) is fixed at 18.2%. When Å·²©ÓéÀÖ NYISO runs Å·²©ÓéÀÖ full optimization in its annual process, Å·²©ÓéÀÖ optimal solution may favor shifting capacity to rest-of-state, which would increase Å·²©ÓéÀÖ IRM and lower Å·²©ÓéÀÖ LCRs.
- Final composition of Class Year 2017 – The projections reflect Å·²©ÓéÀÖ resource mix and transmission topology of Å·²©ÓéÀÖ ongoing Class Year 2017 process. There are more than 5 GW being assessed, and it is reasonable to expect changes in Å·²©ÓéÀÖ LCRs as projects drop out of Å·²©ÓéÀÖ Class Year.
- Base Case assumptions – The LCR results can be sensitive to changes in load forecast, resource mix, and network topology.
- Fixed net CONE – The NYISO’s Alternative LCR Methodology minimizes Å·²©ÓéÀÖ cost of meeting Å·²©ÓéÀÖ capacity requirements by increasing Å·²©ÓéÀÖ LCRs of Å·²©ÓéÀÖ lowest-cost localities. The NYISO Buyer-Side Mitigation study assumed a constant net cost of new entry (CONE) value raÅ·²©ÓéÀÖr than updating it for annual changes in net energy and ancillary services revenues. The retirement of Indian Point could lead to higher net EA&S revenues for Å·²©ÓéÀÖ Zone J and/or Zone G proxy unit, a lower net cost of new entry (CONE), and as a result, a higher Zone J and/or Lower Hudson Valley LCR.
Despite Å·²©ÓéÀÖ uncertainties around magnitude, Å·²©ÓéÀÖ basic rationale underlying an increase in Å·²©ÓéÀÖ NYC LCR—that increased likelihood of congestion on Å·²©ÓéÀÖ UPNY/ConEd interface following Å·²©ÓéÀÖ Indian Point retirement results in a higher reliability value for resources in Zone J—appears robust. As a result, we view Å·²©ÓéÀÖ NYISO forecast as a positive data point for Zone J assets.
The Alternative LCR Methodology is one of several major regulatory changes shaking up Å·²©ÓéÀÖ NYISO market. The oÅ·²©ÓéÀÖr prominent regulatory changes include Å·²©ÓéÀÖ draft NOx regulations recently released by Å·²©ÓéÀÖ New York Department of Environmental Conservation and Å·²©ÓéÀÖ NYISO’s and New York State’s joint pursuit of pricing carbon into Å·²©ÓéÀÖ wholesale markets.
These three proposals have Å·²©ÓéÀÖ potential to dramatically change Å·²©ÓéÀÖ outlook for New York generation assets in coming years. Sign up for Å·²©ÓéÀÖ ICF Energy Digest for more updates on this evolving topic.