No change in NYISO’s Special Case Resources (SCR) program in 2025

Reliability based DR program - SCR stays for now. Modifications coming to DER & Aggregation Participation Model.

NYISO decided not to change its Special Case Resources (SCR) program in 2025. This was announced at the April 1st, 2025, Installed Capacity Working Group (ICAP WG) meeting. This is bad news for Aggregators and others who rely on this reliability-based demand response program. But this news is not entirely surprising because NYISO, under its “Engaging the Demand Side” market initiative, has been talking to Aggregators and listening to their concerns.

Link to my July 2024 post about this SCR issue is at the end of this post.

NYISO did not want to spend the time and money on updating the SCR program because it is an old program, and it is manual from what NYISO had shared in the past. NYISO has a new DER model that FERC approved in 2019 before the Order 2222 DER model discussions started. So, NYISO has a functioning DER model, but there are some issues with this latest model that make the SCR model look good.

This is to say that any change on ISO’s side takes time, and sometimes, that change may not happen if the conditions change, such as there being no consistent stakeholder feedback. For example, on this SCR modification issue, some stakeholders wanted the 4-hour duration requirement to be changed to a 6-hour duration requirement, while others advocated for an 8-hour duration requirement. Some wanted the flexibility of choosing a 6-hour or an 8-hour duration. Eventually, NYISO decided not to go ahead with changing the SCR program because several stakeholders were not in favor of any change beyond the 6-hour requirement.

Another reason NYISO ended up not changing SCR is NYISO’s fault alone. NYISO added three more changes on top of this duration requirement issue and asked stakeholders to choose the entire package. First, NYISO proposed the removal of the 21-hour advance notice in favor of a 4-hour notice. This was hard to accept for Aggregators because the 21-hour advance notice was advisory but the 4-hour notice was mandatory. So, they were asked to trade something they got used to with a long lead time and a suggestion sort of notice to a short lead time and “you shall act on this” sort of notice.

Most ISOs are now moving to much stricter notification times to dispatch demand response programs. MISO, for example, has a filing at FERC for a program called Load Modifying Resource (LMR) Type II that has only 30 minutes of notification time. MISO has designed this program as the last defense in its demand response resources to dispatch during emergency events. MISO has LMR Type I, which has a 6-hour notification time.

[Note - MISO always had LMRs, but the difference is, now MISO has LMR Type I and LMR Type II pending FERC approval. MISO is seeking an effective date of September 1, 2027 for this DR & Emergency Reforms FERC Filing.]

As a result of the 6-hour notification time, LMR Type I is deployed during the Warning stage, not during the actual event. NYISO was probably leaning towards something like this, but if a program like SCR is working, there will always be pushback from stakeholders when they feel there is no better alternative.

The second change that NYISO included in this SCR change package that drove stakeholders away was calculating SCR performance based on the Customer Baseline Load (CBL) baseline instead of the Average Coincident Load (ACL) baseline, with associated changes to the penalties. This is a much bigger change and impacts the bottom line of the SCR program participants. In NYISO’s words, “The NYISO describes this change as directing a resource to reduce their load “by a MW value” with a CBL, rather than directing a resource to reduce “to a MW value” with an ACL measurement”.

NYISO said CBL provides an accurate measurement of SCR’s performance compared to ACL because CBL is calculated based on the highest five consumption days of the last 10 “like” days prior to an SCR event. ACL is the average of SCR’s highest 20 one-hour peak Loads that occurred during the Capability Period SCR Load Zone Peak Hours. [Source: Slide 4, NYISO Engaging the Demand Side: SCR Baseline Changes presentation]

It appears to me that CBL is more restrictive since it uses only the five highest consumption days as opposed to ACL which takes an average of highest 20 data points. I can guess why Aggregators were not in favor of this change as well.

The final change that NYISO proposed concerns testing requirements. NYISO proposed increasing the duration of SCR testing from one hour to six hours. I am glossing over the testing requirements, but the main point is that too much testing or testing over a longer duration for a performing resource feels like a burden. I understand ISOs want to test resources on a periodic basis so that resources continue to be qualified to participate in energy, capacity and ancillary services markets. But if a resource participates during an emergency event, that should count towards successful test performance. Thankfully, NYISO included that aspect in its SCR proposed change package.

Having addressed why the SCR modification package was not palatable to stakeholders, it is worth noting that the current DER model (NYISO calls it the “DER & Aggregation Participation Model”) provides a lot of flexibility to Aggregators and other DER providers. For instance, Market Participants can select 2,4,6, or 8-hour duration lengths for their resources and time stack within aggregations. Qualifying dispatchable resources can also provide ancillary services. SCRs can only provide energy and capacity. However, NYISO is aware of enhancements needed for the DER & Aggregation Participation Model as well.

Bidding obligations, Commitment parameters, such as start-up and minimum run times for large Industrial Loads and Metering and telemetry requirements are some of the enhancements NYISO has mentioned in its April 1^st Engaging the Demand Side presentation. So, we will have to stay tuned to see how this DER & Aggregation Participation Model works along with the SCR program.

Here is a link to my July 2024 posting on this SCR topic (CLICK on it!) -