The New England power grid is growing more resilient and reliable thanks to state renewable energy and energy efficiency laws that are reducing the region’s dependence on natural gas and other imported fossil fuels. That’s the evidence-based message NRDC and many other stakeholders in the region delivered to the Federal Energy Regulatory Commission (FERC), the nation’s power grid regulator, in comments we filed today to respond to FERC’s question about the resilience of America’s grid.
Our comments amplify and explain a new analysis by the region’s grid operator—the New England Independent System Operator (ISO New England)—showing that clean energy is making the region’s power grid more resilient and reliable, not less, in the face of extreme events like blizzards.
Critically, this new analysis corrects an earlier, incomplete study from ISO New England that falsely suggested that the grid serving Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, and Vermont was at risk. In its earlier study, ISO New England suggested that retirements of dirty coal and oil-fired power plants and potential shortages in wintertime natural gas supplies—an issue the ISO referred to as “fuel security”—could make the grid less resilient and more vulnerable to blackouts. As I wrote at the time, ISO New England’s study contained numerous errors and was widely disputed by stakeholders in the region.
Now, the ISO’s updated analysis, which was requested by NRDC and others, shows that we were correct. Rather than creating fuel security problems, New England’s clean energy trajectory will benefit homes and businesses by reducing dependence on fossil fuels and making the grid more resilient, including during winter storms.
Our comments to FERC
NRDC submitted comments to FERC specifically on ISO New England’s fuel security concerns, as well as a set of comments focused on FERC’s broader examination of the resilience of the nation’s power grid, of which fuel security is one part. My colleague Gillian Giannetti explains our broader comments while I summarize our New England-specific comments.
Following ISO New England’s January release of its initial draft fuel security study, a broad cross-section of the region’s electricity stakeholders—including environmental groups, consumer advocates, and power companies—cried foul. That’s because the ISO’s study, which focused on potential fuel security concerns in 2024 and 2025, contained clear factual errors as well other assumptions that are highly unlikely and, in some cases, contrary to state laws that help customers reduce their electricity use and bills through energy efficiency and that require a growing percentage of electricity to come from renewable resources.
One glaring example: ISO New England assumed the region would build less renewable energy than New England’s state laws currently mandate, by over a thousand megawatts. Another: ISO New England assumed the “maximum” level of onshore wind power that the region could have in 2024 would be even less wind power than we already have operating today.
In comments we filed with RENEW Northeast and as part of the Sustainable FERC Project—two coalitions that collectively represent dozens of state, regional, and national environmental and other public interest organizations and renewable energy companies—we explain these and other factual errors and shortcomings in ISO New England’s original analysis. We further note that previous suggestions by the ISO that renewable energy could exacerbate fuel security problems in the region have been thoroughly debunked—by ISO New England itself. Both the ISO’s original analysis and its newer, updated analysis unambiguously show that expanding renewable energy in the region will lower fuel security risks and make the grid more resilient and reliable.
We also filed a second set of comments together with the Massachusetts Attorney General’s Office, Conservation Law Foundation, and others, that provides FERC with a new report from Synapse Energy Economics that clearly explains the results of ISO New England’s recent updated analysis. As Synapse notes, when the ISO incorporated the most up-to-date projections of future electricity demand, renewable energy, and energy efficiency resources, and corrected several errant assumptions from its original analysis, the fuel security and resilience concerns it previously raised disappeared.
Both sets of comments explain that New England’s expanding clean energy resources are moving the grid in the right direction by reducing our dependence on fossil fuels and lessening the electricity system’s vulnerability to cold-weather disruptions in natural gas supplies.
Moving forward on “fuel security”
While the corrected study results are good news, we remain concerned that ISO New England continues to cite its now-debunked original findings and isn’t incorporating the newest study results into its work. For example, the ISO recently filed a new request with FERC asking for authority to keep the natural gas-fueled Mystic power plant in Connecticut online even though the owner plans to retire it. The ISO has again cited “fuel security” concerns as the primary basis for wanting to keep the plant running, while relying on many of the same errant assumptions from its original fuel security analysis. FERC should look skeptically on this request and ensure that any proposal to address fuel security in New England—or other regions—is fully justified by accurate analysis and the best available information.
As other regional grid operators, such as PJM, look to evaluate fuel security, they should also ensure that they avoid ISO New England’s mistakes. One important way of doing so is to bring stakeholders into the discussion early, which helps to ensure that study assumptions are accurate and reasonable and that errors can be corrected and avoided from the beginning.
In the context of its broader consideration of grid resilience in New England, our message to FERC is simple: ISO New England’s analysis shows that to ensure fuel security in the region, we need to continue what we are already doing: implementing current state clean energy laws that improve energy efficiency and grow renewable energy. We do not need expensive new natural gas pipelines or to develop counterproductive bailouts to uneconomic fossil fuel generators, which would only raise electricity bills, bring more polluting energy into the region, exacerbate climate change, and slow New England’s progress toward a clean, resilient, and fuel secure grid.