New York Resource Adequacy Proceeding Comments

Update March 25, 2020: Submittal documents: Caiazza comments Resource Adequacy, Initial Estimate of Energy Storage Required White Paper,Energy Storage White Paper Appendix 1 Solar Irradiance Maps, and Appendix 1 Air Source Heat Pumps

The New York State Public Service Commission (PSC) issued an order commencing a proceeding to examine how to reconcile resource adequacy programs and the State’s renewable energy and environmental emission reduction goals. This post describes the comments I submitted in this proceeding.

Materials and information are available in the Department of Public Services (DPS) resource adequacy matters docket Case 19-E-0530.  .  According to the Order Instituting Proceeding and Soliciting Comments, the inquiry is “necessitated by the Commission’s statutory obligations to ensure the provision of safe and adequate service at just and reasonable rates. Costs to consumers are a primary and ultimate consideration, recognizing that the necessary investments in resources must have sound economics.”

The PSC order solicited comments on the following questions.  Does the New York Independent System Operator (NYISO) have sufficient resource adequacy evaluation mechanisms in place to deal with the State’s ambitious renewable energy and environmental emission reduction goals?  Do the policies and market structure mechanisms insure just and reasonable consumer rates? There were several specific questions about existing products and their value with respect to costs.  Finally, there was a general question about the State’s role with respect to resource adequacy and request for recommendations for what to do next.

I submitted comments because I am not sure that the Climate Leadership and Community Protection Act (CLCPA) can be implemented so that it does not jeopardize safe and adequate energy service at just and reasonable rates. I based the comments on evaluations I did for previous posts on Solar Issues in Upstate New York , CLCPA Solar and Wind Capacity Requirements and CLCPA Energy Storage Requirements.

My filed documents (dated 9/16/2019 as a filing on behalf of an individual) illustrate my concerns with two examples.  I prepared a white paper that provides an initial estimate of the likely energy storage component requirement based on real world data.  It shows that at night when winds are light the energy produced from these sources will have to be supplanted with stored energy if New York shuts down all its fossil generation.  Given the extraordinary cost of battery energy storage I estimate that the batteries alone will cost over $12 billion to replace existing fossil generation and Indian Point after it retires.  The second example describes a potential problem with winter peak loads once the CLCPA is implemented.  Because of the stringency of the law, home heating is going to have to be electrified.  The preferred retrofit option is an air source heat pump.  However, they don’t produce heat when the temperature gets below zero so homeowners will need a backup system and the cheapest alternative is radiant heat which is much more inefficient.  As a result there will be a spike in electrical load that cannot be avoided.

Both examples used data from the NYS Mesonet.  I believe the best way to determine resource adequacy is to base the analysis on historical meteorological information as shown in the examples.  In order to determine the amount of energy storage you have to calculate how much wind and solar power is available and when.  In order to determine the effect of air source heat pumps meteorological data from the winter 2017-2018 peak load period was used.  I recommended that historical meteorological data be used to characterize potential solar and wind energy production to determine the feasibility of the CLCPA emission reduction target that eliminates emissions from electricity production by 2040.

In addition, I believe that the State needs to do a cumulative environmental impact assessment of this regulation.  The problem is that while an individual industrial wind facility or solar facility may not have a significant environmental impact the cumulative impact of all the facilities necessary to provide enough power to meet the reliability needs of the state could have significant environmental impacts.  For example, if one raptor gets killed by every ten wind turbines that might be acceptable but if we need a thousand wind turbines is one hundred raptors per year acceptable?

My final recommendation is for an independent review of the findings of the feasibility studies.  The CLCPA is the result of political pandering and the likelihood that a feasibility study would be subject to political influence is high.  The only way I can think of to prevent that is to establish an independent group to review the findings.  Membership should deliberately be chosen to represent both “sides” of vested interests in the outcomes.  They may not be able to come agree but their evaluation report can list where they have agreed to disagree and that will be useful for the public.

I think it is obvious that the resource adequacy proceeding must determine if the CLCPA can be implemented such that it does not jeopardize safe and adequate energy service at just and reasonable rates.  If renewable resources and energy storage are inadequate during the winter peak, then safe and adequate energy service could easily be jeopardized.  No jurisdiction has ever successfully reduced greenhouse gas emissions by developing renewable energy resources and managed to keep prices down and I see no reason that New York will be able to reverse that result.  Most importantly, the increase in energy prices will affect those who can least afford the increased costs.

If you are a resident of New York I ask that you submit comments to the DPS resource adequacy matters docket Case 19-E-0530 supporting the request for comprehensive, independent feasibility and cumulative environmental impact assessments.

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. I author two blogs. Environmental staff in any industry have to be pragmatic balancing risks and benefits and ( reflects that outlook. The second blog addresses the New York State Reforming the Energy Vision initiative ( Any of my comments on the web or posts on my blogs 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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