Revisions to Replacement Power for Indian Point


Since the publication of my original post on this topic I realized that there were two natural gas fired combined cycle electric generating units in development and not just the one I thought. This update to the original post addresses the ramifications of that on replacement power and other emissions. Because the additional facility affects the conclusions I revised the entire post.

New York’s Governor Andrew Cuomo has threatened the closure of the Indian Point Energy Center located 25 miles north of New York City since his election and in January 2017 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, the problem is what are the characteristics of the replacement power relative to Indian Point? Indian Point’s nameplate capacity is 2,311 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. There are three projects that can replace that capacity and are at least located near New York City. Champlain Hudson Power Express transmission line has been permitted to bring 1,000 MW of Hydro Quebec hydropower into New York City but construction has not started. The Cricket Valley Energy Center is a 1,000 megawatt combined-cycle, natural gas fired generating plant that has just started construction and is expected to be on-line the first quarter of 2020. I did not include the CPV Valley Energy Center in the first post. It is a 650 MW combined-cycle, electric generating plant that is scheduled to go on line in February 2018.

In the original post I did not include CPV Valley so the claim of 2,000 MW so I disputed the claim that the replacement power was readily available but with adding it that claim is correct. The remaining and more subtle issue is whether these three facilities can replace Indian Point and not jeopardize other environmental goals.

I have been involved in the RGGI program process since its inception. Before retirement from a Non-Regulated Generating company, I was actively analyzing air quality regulations that could affect company operations and was responsible for the emissions data used for compliance. The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

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.
  • 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.
  • 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.

Other Side of the Story – Replacement Power

There are two aspects of power generation that have to be considered when discussing replacements. 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 1,299 MW and Indian Point 3 is 1,012 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”. In the original post I noted that I had trouble understanding how these measures will replace observed generation, but have since found a reference with an explanation. The New York Independent System Operator (NYISO) publishes an annual description of power trends. This is an absolute necessity due to the changes in the New York State electric system driven by the Governor’s Clean Energy Standard and Reforming the Energy Vision. The 2016 Power Trends document provided an explanation of the transmission projects. These projects were designed to increase the transfer capability into Southeastern NY so that excess upstate NY capacity could be transmitted to the region served by Indian Point. According to this document the transfer capacity was raised by 450 megawatts.

New York State has always had constraints on the amount of power that could be transmitted from upstate to downstate. These projects should be able to replace Indian Point generation that is used in the New York City area. However, I don’t think it is a like kind replacement of no-pollutant generation. While it can clearly move the upstate wind and solar power downstate, the upstate renewable facilities are not constrained by system needs. If they can generate then they do. The same argument can be made for the upstate nuclear power. If the nukes can run then they do. In other words, their generation is already being used elsewhere and is not going to provide added generation that can be transmitted downstate by these upgrades. Instead, the upstate replacement generation that can be transferred to downstate to make up the 450 MW will either be existing under-utilized fossil generation or new renewables. If it is fossil generation then there will be an increase in CO2 and other pollutants. If it is renewable then it is not new renewable that is going to be used to increase the amount of no-CO2 generation. Instead it is only going to replace the loss of the no-CO2 nuclear generation. In either case because Governor Cuomo has established goals for more renewables the source of the power from these transfer capacity improvements should be addressed.

The aforementioned NYISO 2015 Gold Book 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. The problem is that the 450 MW transmission upgrades these additional resources do not sum up to 700 MW.

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. 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. This is consistent with the press release.

However the question is whether the three projects that are permitted can replace all 16,953 GWh of the generation from Indian Point. For the purposes of this analysis assume that Champlain Hudson Power Express power can be provided 100% of the time. With that assumption, it provides 8,760 GWh of power so we still 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, natural gas-fired generating plant in Dover, NY that is expected to be on line by the first quarter of 2020. I could not find a proposed capacity factor (actual generation divided by the maximum potential generation) so assumed 80% which would produce 7,008 GWh. CPV Valley Energy Center is a 650 MW combined-cycle, natural gas-fired generating plant near Middletown, NY that is much further along and expected to be online in February 2018. Assuming an 80% capacity factor for this plant gives 4,555 GWh so these three facilities can provide over 3,300 GWh more than Indian point generated.

Other Side of the Story – Net Emissions

This revised post also addressed the claim that the 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. Cricket Valley and CPV Valley both will emit carbon. Cricket Valley has an annual limit of 3,630,484 tons of GHG emissions and CPV Valley has an annual limit of 2,164,438 tons of CO2. To some extent in any scenario both facilities will displace Indian Point rather other fossil-fired facilities and those emissions will increase New York’s total emissions.

Of more concern to me are Nitrogen Oxides. The final Cross State Air Pollution Rule allowance budget and the Governor’s policies on allowance distributions could 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 by the three projects described above, CPV Valley and Cricket Valley would increase annual NOx emissions by 289 tons. Emissions in the 2016 ozone season were 6,521 and the future allowance budget is only 5,135 tons so any increase in emissions is a further strain on the budget. New York State has aggressively pursued NOx reduction policies and there are not many opportunities left for additional reductions so any increase is problematic.

Other Sides – Timing and Bill Impact and Emissions

These sections from the original post are included for your information. No changes were made to the following paragraphs.

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 it 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 policies 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 is $2.2 billion and Cricket Valley is $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?

Author: rogercaiazza

I am a meteorologist (BS and MS degrees), was certified as a consulting meteorologist and have worked in the air quality industry for over 40 years. Originally I worked for consultants doing air quality modeling work for EPA and then went to work with electric utilities where I was responsible for compliance reporting and analyzed the impact and efficacy of air quality regulations. I retired from working for one utility company full-time in 2010 and then worked part-time for most of the New York utility companies as the Director of an environmental trade association until my full retirement at the end of 2016. Environmental staff in any industry have to be pragmatic balancing risks and benefits and I hope my blog ( reflects that outlook. Jokingly our job description is to bring the companies we represent to the table so that they are not on the menu. Any of my comments on the web or posts on my blog are my opinion only. In no way do they reflect the position of any of my past employers or any company I was associated with.

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