Personal Comments Submitted on the NYS DEFR Proceeding

This post summarizes comments that I submitted in response to comments submitted by Sierra Club and Earthjustice in the Proceeding on Motion of the Commission to Implement a Large-Scale Renewable Program and a Clean Energy Standard – Zero Emissions Target Case No. 15-E-0302.  This proceeding addresses the need for a dispatchable emissions-free resource (DEFR) to resolve problems associated with a drought of wind and solar resource availability.  My comments explain why I believe that the Sierra Club and Earthjustice fail to appreciate the potential magnitude and duration of the wind and solar resources “gap” and its impact on the DEFR requirements.

I have followed the Climate Leadership & Community Protection Act (Climate Act)since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition.  I am a meteorologist with over 40 years’ experience in the electric generating sector.  I represent the Environmental Energy Alliance of New York on the New York State Reliability Council Extreme Weather Working Group (EWWG).  The opinions expressed in this comment do not reflect the position of the Alliance, the Reliability Council, the Extreme Weather Working Group, or any of my previous employers or any other company I have been associated with, these comments are mine alone.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.”  In brief, that plan is to electrify everything possible using zero-emissions electricity. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  Since then there have been regulatory and legislative initiatives to implement the recommendations but progress has been slow.

In May 2023, the Public Service Commission (PSC) initiated a process to “identify technologies that can close the gap between the capabilities of existing renewable energy technologies and future system reliability needs, and more broadly to identify the actions needed to pursue attainment of the Zero Emission by 2040 Target” for New York electric generating sources intended to address that need.  This resulted in the PSC commencing Proceeding 15-E-0302.  In a Technical Conference held under the PSC’s auspices on December 11 and 12, 2023 entitled “Zero Emissions by 2040”  included a session titled “Gap Characterization.”  I addressed this session in an earlier post.

Sierra Club and Earthjustice Comments

The comments submitted by Sierra Club and Earthjustice (“SC&E) covered four topics associated with the December Technical Conference:

1. The Hydrogen Panel’s claim that there are “no technical issues” with hydrogen transportation and storage is misleading.
2. The claim that pipelines are the most efficient way of moving energy does not account for the roundtrip efficiency of green hydrogen versus direct transportation of electricity produced by renewable sources
3. The Panel did not dispel the serious doubts facing the potential use of hydrogen combustion as a “zero emissions” fuel source due to the inevitability of harmful NOx emissions
4. Significant Modeling Gaps in NYISO’s presentation at the Technical Conference cast doubts on the Operator’s conclusion that New York will have a DEFR need of 30 GW+

Except in passing, I did not address the first three topics.  For the record, I agree with underlying premise of the SC&E comments that hydrogen transportation and storage is more of a problem than admitted by the Panel.  I do not think that the choice of either hydrogen pipelines or electric transmission of hydrogen produced power matters much because of all the other enormous problems.  I disagree that NOx emissions are a deal breaker for hydrogen combustion because NOx emissions from a modern combustion turbine are so low that they will not contravene the National Ambient Air Quality Standards which I maintain is the proper acceptability criterion. 

My comments addressed the fourth topic.  I believe that the Sierra Club and Earthjustice fail to appreciate the potential magnitude and duration of the wind and solar resources “gap” in their comments

Ultimate Reliability Problem

In my January comments I focused on the second attribute in Smith’s presentation about the ten attributes for reliability that must be provided by DEFR.  His second attribute explained DEFR must be “non-energy limited and capable of providing energy for multiple hours and days regardless of weather, storage, or fuel constraints”.  This is a particular concern of mine.  Wind and solar resources correlate in time and space as shown by the NYISO analysis referenced in Smith’s presentation (Figure 1).  The seven-day wind lull example in the dispatchable resources needed figure illustrates the problem.  If there are insufficient resources during a wind lull, then load cannot be met.  The consequences of that situation would be catastrophic.

Figure 1: Dispatchable Resources Needed from Zero Emissions by 2040 Technical Conference Slide Presentation Dispatchable Emission-Free Resources (DEFRs) by Zachary Smith NYISO

Feasibility Concern

My primary concern is the feasibility for the New York Climate Act implementation plan or more appropriately, the lack of a proper feasibility analysis, that addresses the worst-case wind and solar energy resource drought.  I explained that a proper analysis for the worst-case drought must use as long a period as possible of historical meteorological data to provide the basis for projections of future load and estimates of electric resource availability based on projected deployment of wind, solar, energy storage, and other technologies needed to supply the expected load.

My comments incorporated the information in a recent post Wind and Solar Resource Availability Fatal Flaw.  In that post I described various current studies that use the historical data-based approach. All these analyses find there are periods of low renewable resource availability.  The Independent System Operator of New England (ISO-NE) Operational Impact of Extreme Weather Events analysis is particularly relevant because it includes a table of projected system risk for weather events over ta72-year data record.  In the analysis, system risk was defined as the aggregated unavailable supply plus the exceptional demand during each evaluated time block.  The Important point is that the system risk increases as the lookback period increases.  If the resource adequacy planning for New England had only looked at the last ten years, then the system risk would be 8,714 MW, but over the whole period the worst system risk was 9,160 MW and that represents a resource increase requirement of 5.1%.

Source: ISO-NE Operational Impact of Extreme Weather Events, available here

SC&E Comment Issues

SC&E raised concerns in Section 4 of their comments: “Significant Modeling Gaps in NYISO’s Presentation at the Technical Conference Cast Doubts on the Operator’s Conclusion that New York Will Have a DEFR Need of 30 GW+.”  The NE-ISO report results directly contradict the SC&E concern that “NYISO’s presentation at the December technical conference overstates the need for dispatchable, emissions-free resources (“DEFRs”) and downplays the value of taking steps in the near term to minimize this gap.”  

The SC&E comments characterized Zachary Smith’s slideshow at the “Characterizing the potential ‘gap’” Panel presentation during the technical conference as “particularly alarming”. The comments said that the slideshow suggested that New York will require 30 GW of DEFRs, but said that “the analysis shown in slide 3 of Mr. Smith’s presentation has multiple flaws”:

The first flaw relates to the “Wind Lull” analysis. The “Wind Lull” analysis only uses three wind profiles (including just two upstate wind profiles) to determine whether a “Wind Lull” occurs. An analysis of “Wind Lulls” limited to two upstate profiles likely misses the diversity of wind in the NYISO footprint which includes wind in Zones B, C, and E in addition to other wind sites in Zones A and D aside from Niagara and Plattsburgh. Further, despite a maximum winter “Wind Lull” of five days in the historical record evaluated, the analysis determined that the winter “Wind Lull” period should be 7 days because “it is possible that there have been more severe wind lulls than in the time span we analyzed, and that there could be more severe wind lulls going forward, particularly if such outcomes are made more likely by climate change.” While this may be true, this assumption was not substantiated by any climate models or other analysis and should not be used as the basis for determining the length of winter “Wind Lull” periods to be evaluated. The limited number of wind profiles evaluated and unsubstantiated lengthening of the “Winter” wind lull period arbitrarily increase “wind lull” period lengths leading to a conservative assumption on wind availability and an overestimate of the DEFR gap.

My comments explained why I disagree.  In the first place, there is a very high correlation of wind resources in New York.  For example, I used a NYISO resource that provides 2021 wind production and 2021 wind curtailment data that list the hourly total wind production and curtailments for the entire New York Control Area (NYCA) as shown in the following table. All of the wind in the state must be highly correlated if 25% of the time only 7% of the state total wind capacity is available.  Only using two upstate wind profiles is not the best practice but neither is it particularly bad for the highly correlated New York data.  In addition, this concern is addressed in the more recent work by the NYISO that was not available at the time of the Technical Conference.

The concern about assuming a 7-day wind lull when the short period analyzed only found a 5-day wind lull is not an issue.  As the period of record increases the length of the gap increases and the NE-ISO found that it was appropriate to evaluate 21-day periods.  In addition, SC&E comments overlook the need to consider the state of the energy storage resources going into a shorter poor resource availability period.  If moderate weather conditions prevented full energy storage capacity, then that will affect the ability of the system to provide sufficient electric energy when it is needed the most.

As a result, the SC&E comments underestimate the DEFR requirement in their evaluation.  They argue that it is premature to “deploy expensive and untested DEFRs risks committing New York to flawed technologies, as it is unclear at the present time which technologies will emerge as commercially scalable and cost effective”.  I agree that we should be cautious but all the analyses I have seen in my own attempts to estimate necessary resources indicate that the SC&E  proposal to “focus on accelerating the build out of storage, solar, and wind, along with other existing methods to minimize the DEFR gap” is inadequate.  Solar, wind, and storage are insufficient in these gaps as shown in the Climate Act Scoping Plan analysis and work done by the NYISO – DEFR is needed. 

The SC&E comments go on to claim that the NYISO Table 1 analysis did not reflect correlated wind, solar, and load data.  If true, then I agree.  However, subsequent analyses by the NYISO and NE-ISO do use correlated hourly meteorological data, estimate wind and solar resource availability, and project loads based on that data.  All those results show that the magnitude of this problem is greater than appreciated in the comments.  The SC&E conclusion that “If correlated wind, solar, and load shapes (without arbitrary adjustments) were used, it is likely that the DEFR Capacity need would be significantly reduced” is wrong.  Correlated data over the period of record show that the DEFR capacity requirement will be greater than shown in the Smith analysis at the Technical Conference.

I also addressed the SC&E comments about alternative DEFR technologies, deployment timing, and requirements for hydrogen storage.  If interested, then please check out my comments.

Related Issue

The SC&E comments raised a related critically important electric planning issue that I discussed in the Wind and Solar Resource Availability Fatal Flaw post and incorporated into my comments.  Today electric system resource adequacy planners do not have to be concerned that many generating resources may not be available at the same time. All solar goes away at night and wind lulls affect entire regional transmission organization (RTO) areas at the same time. Therefore, when a future electric grid relies on wind and solar those resources will correlate in time and space.  This issue is exacerbated by the fact that the wind lull will cover multiple RTO areas at the same time the highest load is expected. This paradigm shift for electric planning must be addressed.

It is an overarching issue.  I do not believe we can ever trust a wind, solar, and energy storage grid because if we depend on energy-limited resources that are a function of the weather, then a system designed to meet the worst-case is likely impractical. Consider the ISO-NE events where it was found that the most recent 10-year planning lookback period would plan for a system risk of 8,714 MW.  However, if the planning horizon covered the period back to 1961, the worst-case to 1950, an additional 446 MW would be required to meet the system risk.  I cannot imagine a business case for the deployment of energy storage or the yet to be identified DEFR that will only be needed once in 63 years.  For one thing, the life expectancy of these technologies is much less than 63 years.  Even over a shorter horizon such as the last ten years, how will a required facility be able to stay solvent when it runs so rarely without large subsidies and very high payments when they do run.

On the other hand, the alternative to ignore the worst case is unacceptable.  In the net-zero future, the electric grid is supposed to rely on wind and solar at the same time heating and transportation are electrified the need for reliable electricity is magnified. If we do not provide resources for the observed worst case, when those conditions inevitably reoccur, there will be a catastrophic blackout.  Electricity will not be available when it is needed the most. 

Recommendation

I recommend a detailed feasibility analysis that determines the worst-case observed wind and solar resource drought.  The meteorological data reanalysis techniques that enable a period of record back to 1950 should be used.  It should be a continental-scale analysis with realistic estimates of maximum available buildout of resources.  Obviously, this is a major effort but everyone else in the country needs the same information so that we can determine how much energy will be available for import and export.  The worst-case resource availability analysis will define the conditions and then resource planners can determine what must be deployed.  Using a long period of record will allow planners to analyze return time relative to life expectancy of resources.  The Commission should encourage coordination amongst all the RTOs to prepare this analysis.

Given the magnitude of the electric system transition I also recommend proof before proceeding. If it is feasible and economical to have an electrical grid powered predominantly by wind and solar generation, then it should not be difficult to put together a zero-emission demonstration project on a small or intermediate scale to prove how that can be done.  Such a project does not exist anywhere in the world, which suggests that this might not be feasible.

My final recommendation is to establish safety valve guard rails for implementation.  New York Public Service Law  § 66-p (4). “Establishment of a renewable energy program” includes safety valve conditions for affordability and reliability that are directly related to the zero emissions resource.   § 66-p (4) states: “The commission may temporarily suspend or modify the obligations under such program provided that the commission, after conducting a hearing as provided in section twenty of this chapter, makes a finding that the program impedes the provision of safe and adequate electric service; the program is likely to impair existing obligations and agreements; and/or that there is a significant increase in arrears or service disconnections that the commission determines is related to the program”. 

Because of the enormity of the challenge, the lack of a feasibility study, and a successful model operating elsewhere, I believe that the zero emissions resource could be a primary driver of the reliability and affordability provisions of § 66-p (4) so it is incumbent upon the Commission to address these considerations in this Proceeding.  The criteria used to define “safe and adequate electric service” and “significant increase in arrears or service disconnections” should be defined.  This is necessary so that there is a clearly defined standard for invoking the § 66-p (4) safety valve.

I concluded that the importance of the resource gap and the DEFR technologies necessary to address it cannot be overstated.  Simply put, if no technological and cost-effective DEFR solutions are feasible, then the current strategy to depend on solar and wind generating technologies is impossible.