NERC’s 2025 Long-Term Reliability Assessment paints too gloomy a picture of the electric grid’s risks over the next 10 years, according to a report from Grid Strategies that purports to present “a more comprehensive picture of adequacy risks … given different … underlying assumptions.”
The LTRA, released Jan. 29, warned that the resource adequacy outlook of the North American grid was “worsening,” with 13 of 23 assessment areas potentially developing into high or elevated risk between 2026 and 2030.
High risk means planned resources as of July 2025 would lead to energy shortfalls more than RA targets or baseline criteria for unserved energy or loss of load, while elevated risk areas meet RA targets but are likely to experience energy shortfalls in extreme weather conditions. (See NERC Warns of ‘Worsening’ Resource Adequacy Through 2035.)
MISO, PJM, Texas RE-ERCOT, WECC-Basin and WECC-Northwest fell into the former category, and the latter included MRO-Manitoba, MRO-SaskPower, MRO-SPP, NPCC-Maritimes, NPCC-New England, NPCC-New York, NPCC-Quebec and SERC-East.
NERC’s risk projections for most areas were driven by concerns about “demand growth … outpacing planned resource additions.” The ERO observed that new large loads such as data centers and industrial centers were projected to come online in nearly every assessment area, with the electrification of transportation and the spread of heat pumps further raising demand.
At the same time, many of the resources planned to replace existing thermal generation facilities are weather-dependent assets like wind and solar plants, or natural gas generation that will require investment in gas infrastructure to ensure the availability of fuel.
The LTRA did not arrive without skepticism: Members of the Organization of MISO States objected to the ERO labeling MISO as a high-risk area. State regulators said NERC should have counted resources in MISO’s fast-track interconnection queue among planned resources, which would have neutralized the 7-GW shortfall NERC expects to materialize by 2028. (See MISO States Dispute ‘High Risk’ Designation from NERC.)
Grid Strategies’ report similarly described the LTRA as “too pessimistic” because of overly strict assumptions about generation resource additions. The authors also claim NERC underestimated regions’ ability to import power and may have exaggerated data centers’ potential demand, further tightening reserve margins. However, they acknowledged the LTRA “highlights important reliability concerns” grid planners will need to address.
Some Tier 2 Exclusions Unwarranted
The authors’ first criticism of the LTRA concerned NERC’s practice of considering generators only under construction or with a signed interconnection agreement as “Tier 1” resources that can be counted as planned capacity additions. Tier 2 resources are those that are in earlier stages of development, such as an interconnection planning study, which NERC considers to “have more uncertainty in being realized.”
This understanding of Tier 1 resources is too limited, Grid Strategies argued, drawing on data from Lawrence Berkley National Laboratory to show that more projects exist with signed IAs than NERC acknowledged. The authors suggested the “mismatch in data could be due to different processing methods, collection periods and … resource accreditation methods.”
Using the LBNL data, the authors claimed a potential shortfall NERC missed in the SERC-Central subregion, and two near-misses in WECC-Basin and MRO-SPP, could be resolved, though the projected shortfalls in MISO and PJM still would remain and another near-miss could develop in New York.
The authors also questioned the decision to exclude all Tier 2 resources from the LTRA. They acknowledged these additions might not complete the interconnection process but suggested treating them as nonexistent for planning purposes was too extreme. Applying what they called “historic region-specific and phase-specific withdrawal rates to the LBNL data,” they suggested that already-planned Tier 1 and Tier 2 resources could be enough to avert shortfalls for all regions except PJM.
The biggest concern about resource additions is “delays in the study, permitting and/or construction phases” that push resources already in the queues past their projected start dates, including planned wind and solar resources. Adjusting the previous projection to account for likely withdrawals introduced shortfalls in WECC-Basin, SERC-Central, MISO and PJM, the authors wrote. They recommended permitting reforms and more efficient interconnection queues for all resources to reduce this chance.
Imports and Demand
Energy imports also have a role to play in addressing energy shortfalls, but the LTRA did not fully include this option either, Grid Strategies observed. NERC counted only firm interregional capacity transfers, but considering “non-firm imports over interregional transmission lines that have been available during historical grid stress events” could alleviate additional strain, the authors wrote.
Going further, the authors suggested that implementing interregional transmission additions proposed in NERC’s Interregional Transfer Capability Study could provide “even more security to avoid shortfalls.” While they acknowledged this would be a harder lift, they also claimed that “legislative and regulatory action taken now could accelerate the construction of these prudent additions.”
Finally, Grid Strategies asserted that utility projections of load growth on which NERC relied to create the LTRA “are based on overstated assumptions.” Data centers, which were a significant part of many utilities’ projections, were a key example in Grid Strategies’ report; citing data from TD Cowen, the authors suggested that limits in the supply of key computer chips could restrict data center growth in the U.S. by as much as one-third.
In addition, the authors observed that data centers could manage their demand to reduce their need for on-peak grid power, such as by using local generation and storage resources, or by curtailing demand when energy prices are high. Such activities “are unlikely to appear in utility forecasts of expected load,” the authors claimed.
To reduce uncertainty, Grid Strategies suggested updating data center load forecasts to take the chip industry and other outside data sources into consideration. Reducing data center load might eliminate all shortfalls in the LTRA, even without factoring in the generation adjustments, the authors wrote.


