Since his election New York’s Governor Andrew Cuomo has threatened the closure of the Indian Point Energy Center located 25 miles north of New York City and in January 2017 finally announced its closure by April 2021. Cuomo claims that Indian Point produces 2,000 megawatts of electrical power and that “more than enough replacement power to replace this capacity will be available by 2021”.
However, when you look at what has been permitted to be built within that time frame it is not clear that is as straight forward as suggested. In the first place, Indian Point’s nameplate capacity is 2,150 MW not 2,000 as described. Nuclear power is characterized by high capacity factors and because Indian Point provides over 20% of New York City’s power the location of the replacement generation matters. The Champlain Hudson Power Express transmission line has been permitted to bring 1,000 MW of Hydro Quebec hydropower to New York City. The only other large generation resource that has been permitted close to New York City is the Cricket Valley Energy Center, a proposed 1,000 megawatt combined-cycle, electric generating plant. So nominally these two facilities can replace 2,000 MW of Indian Point but as shown in this post the devil is in the details.
Cuomo’s Indian Point Closure Plan
As part of his state of the state proposals, Governor Andrew M. Cuomo announced the closure of the Indian Point Energy Center by April 2021. As described in the press release the Governor’s position is:
- Replacement Power: Indian Point produces 2,000 megawatts of electrical power. Currently, transmission upgrades and efficiency measures totaling over 700 megawatts are already in-service. Several generation resources are also fully permitted and readily available to come online by 2021, after the plant’s closure, including clean, renewable hydropower able to replace up to 1,000 megawatts of power. Together, these sources will be able to generate more than enough electrical power to replace Indian Point’s capacity by 2021.
- Early Close Date: Entergy Corp. has agreed to cease all operations at Indian Point and will shut down the Unit 2 reactor in April of 2020. Unit 3 will be shut down in April of 2021. Unit 1 reactor was permanently shut down in October 1974 because the emergency core cooling system did not meet regulatory requirements. In the event of an emergency situation such as a terrorist attack affecting electricity generation, the State may agree to allow Indian Point to continue operating in 2-year increments but no later than April 2024 and April 2025 for Units 2 and 3 respectively.
- Negligible Bill Impact: The Public Service Commission’s Indian Point Contingency Plan and other planning efforts have ensured that more than adequate power resources are able to come online by 2021 to ensure reliability of the power grid. Given these planning efforts and likely replacement resources, the plant’s closure in 2021 will have little to no effect on New Yorkers’ electricity bills.
- No Net Increase of Emissions Due to Closure: The Governor’s leadership on energy and climate change will ensure that Indian Point’s closure will not have an adverse impact on carbon emissions at the regional level. Through the Regional Greenhouse Gas Initiative, the state will continue to drive reductions in greenhouse gases across the power sector. Further, the Governor’s Clean Energy Standard to get 50 percent of New York’s electricity from renewables by 2030 is the most comprehensive and ambitious mandate in the state’s history to fight climate change, reduce harmful air pollution, and ensure a diverse and reliable energy supply at affordable prices.
Other Side of the Story – Replacement Power
There are two aspects of power generation that have to be considered when discussing replacement power: the potential power output or name plate capacity and the actual generation produced. The New York State Independent Operator annual load and capacity report, the “Gold Book” provides that information. The name plate capacity of Indian Point 2 is 1,070 MW and Indian Point 3 is 1,080 MW. The average net generation from 2011 to 2015 from Indian Point 2 was 8,530 GWh and from Indian Point 3 was 8,422 GWh or 16,953 GWh from the facility. My point is that the net generation is the key parameter for replacement not the capacity.
In order to determine whether the Governor’s plan holds water we have to parse the press release. The first suggested component is “transmission upgrades and efficiency measures totaling over 700 MW that are already in-service”. I have trouble understanding how these measures will replace observed generation. The aforementioned NYISO 2016 Gold Book describes distinct transmission projects approved by the PSC as part of the Indian Point Contingency Plan in October 2013 that were projected by the Transmission Owners to be in service by summer 2016 and also notes that it also included 125 MW of additional demand response and combined heat and power resources to be implemented by Consolidated Edison, some of which is already in effect. Presumably these projects are part of the 700 MW mentioned in the press release.
However, the contingency plan was developed to specifically address the problem that New York City is essentially a massive load pocket. Because most of New York City and Long Island are on islands they are a limited number of transmission lines into the City so the location of the generation matters. Moreover, because one of the City blackouts occurred because of a disruption to transmission into the City, reliability planning is a very important. My guess is that these in-service upgrades and measures are critical to that requirement. However because they were in place and Indian Point generation did not go down they do not represent actual displacement of the energy produced. Maybe it won’t be needed in New York City but it was used elsewhere and must be replaced.
The press release notes that “several generation resources are also fully permitted and readily available to come online by 2021, after the plant’s closure, including clean, renewable hydropower able to replace up to 1,000 megawatts of power.” I assume that the hydropower replacement refers to Champlain Hudson Power Express. As noted previously the only other New York City are large generation resource that I know of is Cricket Valley.
According to the Champlain Hudson Power Express web site the project will bring up to 1,000 megawatts (MW) of clean, renewable power to the New York metro area. For the purposes of this analysis assume that this power can be provided 100% of the time. With that assumption, Champlain Hudson Power Express provides 8,760 GWh of power so we only have to replace 8,193 GWh of Indian Point Generation.
According to the Cricket Valley web site this is a proposed 1,000 megawatt (MW) combined-cycle, electric generating plant in Dover, NY. I could not find a proposed capacity factor (actual generation divided by the maximum potential generation) so assumed 80%. In that case, the net generation 7,008 GWh so the remaining generation needed is 1,185 GWh.
Therefore, in order to displace the actual average generation produced by Indian Point additional generation capacity capable of 1,185 GWh is needed. Implicit in the Governor’s plans is that renewable energy will be part of this replacement. Rather than trying to explain the difficulties of that approach myself, I refer you to the Planning Engineer’s explanation that Not all Megawatts are Equal. If the problems enumerated in this post could be overcome the total generation produced by 21 NYS industrial wind facilities in 2015 was 3,983 GWh so it appears that seven more wind facilities could produce the remaining generation. Note however, that the total wind energy nameplate capacity is 1,892 MW with a capacity factor of 28% in 2015. Because Indian Point generation is dispatchable that means true replacement energy has to produce dispatchable power and that requires storage. Moreover, the timing of when wind is available means that more nameplate capacity would be required than necessary at first glance. There are similar concerns relative to the use of solar renewable energy. So I remain unconvinced that replacement will be as easy as proposed.
Other Sides – Timing, Bill Impact and Emissions
Each of these topics could have their own post but I am only going to address each briefly.
The schedule is for Entergy Corp. to shut down the Unit 2 reactor in April 2020 and Unit 3 in April 2021. The State may agree to allow Indian Point to continue operating in 2-year increments but no later than April 2024 and April 2025 for Units 2 and 3 respectively. Both the Champlain Express and Cricket Valley projects have been permitted but neither has started construction. The expected construction time for Champlain Express is three and a half years which means that it will not be ready by April 2020. Because natural gas combined cycle plants have relatively short construction times that facility probably will meet the first closure date if construction begins soon. I strongly believe that no new generation facility greater than 25 MW in New York State can be permitted in less than five years because of the extraordinary permitting requirements in place so nothing else could be permitted and constructed by the second closure date. So I expect that the extensions will be needed.
The Governor claims there will be negligible bill impact because of planning efforts and likely replacement resources. I am not an economist but the expected costs of Champlain Express $2.2 billion and Cricket Valley $1.5 billion have to be paid for somewhere. Surely the costs to continue operating Indian Point are less than that. Why won’t pre-mature retirement of this resource have a bill impact?
This plan is supposed to lead to no net increase of emissions due to closure. The emphasis has always been on carbon “pollution” and the press release is careful to claim no adverse impact on carbon emissions at the regional level skirting the question whether NY emissions will increase. In fact even if Cricket Valley is the only fossil replacement power for Indian Point there were will be an increase of over 3,630,484 tons of GHG emissions (Table 4-2 in the Cricket Valley DEIS). The missing pollutant is Nitrogen Oxides. The final Cross State Air Pollution Rule allowance budget and the Governor’s policies on allowance distributions could very likely lead to a problem covering emissions with allowances (a topic for a separate post). If the generation gap from the closure of Indian Point is made up of New York’s existing natural gas plants and Cricket Valley then there could over 400 tons of additional NOx emissions. Emissions in the 2016 ozone season were 6,521 and the allowance budget is only 5,135 tons. New York State has aggressively pursued NOx reduction policies and there are not many opportunities left for additional reductions so any increase is problematic.