The Northeast Supply Enhancement (NESE) pipeline is a proposed pipeline to bring natural gas to New York City and Long Island. This post documents additional comments I have submitted in a New York Department of Public Service proceeding related to denial of service requests by National Grid in New York City and Long Island which is associated with the project.
In NESE Pipeline Alternatives for National Grid I included an overview of the proceeding and described my comments. Since then I submitted three additional comments addressing particular aspects of comments submitted by others. Opponents of the pipeline alternative that claim that additional energy efficiency efforts can eliminate the need for a pipeline. The Eastern Environmental Law Center submitted a report to the docket by Synapse Energy Economics entitled “Assessment of National Grid’s Long-Term Capacity Report: Natural gas capacity needs and alternatives” on April 14, 2020. Several commenters suggested that “climate realities” mean that the current criteria for the coldest day can be revised.
Energy Efficiency Performance Comments
I do not dispute that the theory that investments in energy efficiency will reduce the need for additional generating resources is a good idea because there is no benign way to generate electricity. Nor do I dispute that New York has a good energy efficiency record. However, I don’t think that past performance is necessarily an indicator of future results simply because the easiest and most effective, aka low hanging fruit, energy efficiency projects have already been implemented. Any future reductions will not be as cheap or effective.
The comments I submitted attempted to determine how well the existing energy efficiency programs have been doing. Supporters of increased energy efficiency claim that energy growth is decreasing and increased investments will reduce growth even more. There is a fundamental problem when evaluating energy efficiency, namely it is difficult to compare different time periods because energy use is not just a function of how efficiently it is used but also varies because of weather, the economy. and number of customers. In order to address that I used the average natural gas use per customer averaged over the latest five-year period of data compared to the previous five years of data. I found that residential, commercial, and industrial use per customer all went up over the ten-year period for the state as a whole and residential and commercial use per customer went up in New York City and Long Island.
I concluded that in order to justify National Grid’s high-demand (80% of future efficiency targets) and a low-demand scenario (100% of future efficiency targets) bounds to their analysis and the feasibility of the no-infrastructure project option for incremental energy efficiency that the fact that energy use per customer has been going up has to be reconciled. If the Public Service Commission ultimately requires National Grid to include the incremental energy efficiency project as part of the solution, then it is up to them to show why the future results will differ from the recent past.
Synapse Report Comments
The Eastern Environmental Law Center submitted a report to the docket by Synapse Energy Economics entitled “Assessment of National Grid’s Long-Term Capacity Report: Natural gas capacity needs and alternatives” on April 14, 2020. The report concludes: the supply gap most likely does not exist, National Grid has multiple cost-effective demand-side options to meet any foreseeable need, and National Grid’s analysis of long-term capacity options is not compatible with New York’s climate change policies.
The comments on the supply gap primarily addressed purported problems with the worst case (design day) which I address below. They also complained that National Grid should try to maintain the number of customers who are willing and able to shift from natural gas to other sources of energy. This disregards the fact that the most used alternative source is fuel oil which New York City is in the middle of prohibiting so they cannot keep those customers.
The Synapse report claims that National Grid has multiple cost-effective demand-side options to meet any foreseeable need including energy efficiency, demand response, and alternative energy systems such as heat pumps. As described previously there are issues with energy efficiency that Synapse ignores. Demand response advocates assume that the load shifting opportunities available in the summer will also be available in the winter. I argued that when 85% of your load is heating and the diurnal heating load cycle does not vary as much as the summer cooling cycle, how can you shift the load? As a result, I believe that a demand response should not be considered a viable alternative to a proven technology for winter heating. Alternative heating systems are electrified systems. Air source heat pumps are touted as a viable alternative to natural gas furnace but when the temperature drops below 20° Fahrenheit there simply is not enough energy available for this technology to work. Ground source heat pumps don’t have that problem but are difficult to retrofit anywhere and have siting demands that are likely not achievable in New York City.
The Synapse report concludes that National Grid’s analysis of long-term capacity options is not compatible with New York’s climate change policies. In a rational world New York’s plan to implement the Climate Leadership and Community Protection Act would be available to determine compatibility but there is no plan now and one will not be available for several years. Because the timing for the state plan is incompatible with the needs of this project and the State has yet to show that an electric system that relies only on non-fossil fueled sources can meet that peak load condition I concluded that National Grid cannot afford to wait to integrate their plan with the CLCPA plan.
Design Day Criteria Comments
I submitted this comment because other comments submitted recommend changing the design day criteria and downplay future energy needs during the worst-case cold weather periods based on “climate realities”. I showed that when you look beyond the superficial and mis-represented IPCC science it becomes clear that climate model results and even the current observed trend of local temperatures are no reason to conclude that warmer temperatures are inevitable. Poorly understood natural variation is as likely to be the primary driver of temperature as GHG concentrations. Unfortunately, natural variation and climate modeling estimates of the future are very uncertain. Therefore, I argued that it is inappropriate to change the design day criteria and that using the entire period of record for temperatures to determine the design day is the most appropriate approach.
“It is hard to imagine a more stupid or more dangerous way of making decisions than by putting those decisions in the hands of people who pay no price for being wrong”, Thomas Sowell.
Unfortunately, New York State energy policy appears to be driven by the mis-informed and innumerate squeaky wheels who respond to the request for comments with a veritable flood of responses. Moreover, the bullying tactics of the Governor coupled with his micro-management of all decisions to cater to the aforementioned squeaky wheels that represent a political base he apparently counts on means that professional opinions of all companies in the state and agency staff are not considered. Sowell’s comment portends bad things happening for New York energy policy in general and this proceeding in particular.
In my comments I showed that the fact that cold snaps are dangerous to health requires a plan that ensures adequate energy is available is necessary. The theory that energy efficiency, demand response and electrification can actually provide the energy necessary should be considered relative to the real world. Coupling those aspirational efforts with a lack of understanding about climate and climate change projections are a recipe for unanticipated problems and unintended consequences.
I urged the Public Service Commission to choose the Northeast Supply Enhancement pipeline and the other pipeline distribute infrastructure projects based on my evaluation of the alternatives. The other proposed solutions are based on theory and not proven results. I believe it is in the best interests of New York to implement a proven technology solution for current and future heating requirements as soon as possible.