In the summer of 2019 Governor Cuomo and the New York State Legislature passed the Climate Leadership and Community Protection Act (CLCPA) which was described as the most ambitious and comprehensive climate and clean energy legislation in the country when Cuomo signed the legislation. This is another in a series of posts on the feasibility, implications and consequences of the CLCPA. This post addresses the first meeting of the power generation advisory panel.
I am a retired electric utility meteorologist with nearly 40-years-experience analyzing the effects of meteorology on electric operations. I believe that gives me a relatively unique background to consider the potential quantitative effects of energy policies based on doing something about climate change. 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.
I have several concerns with the CLCPA potential effect on energy affordability and reliability. I am convinced that the general public has no idea what is going on with these energy policies and the possible ramifications. I do not believe that the CLCPA implementation process includes sufficient provisions for the general public to find out what this law will cost them until it is too late to prevent the inevitable higher costs of energy. Contrary to the perception of “clean energy” advocates the transition away from fossil fuels is not simply a matter of political will. There are significant implementation issues that imperil current reliability standards.
Background
Rather than repeat all the background information I have included in previous posts I have prepared CLCPA Summary Implementation Requirements and offer that if a reader wants more information. In brief, the CLCPA establishes the New York state climate action council (CAC) that is required to “prepare and approve a scoping plan outlining the recommendations for attaining the statewide greenhouse gas emissions limits”. That document will “inform the state energy planning board’s adoption of a state energy plan” and “shall incorporate the recommendations of the council”.
The CLCPA also provides for advisory panels to “provide recommendations to the council on specific topics, in its preparation of the scoping plan, and interim updates to the scoping plan, and in fulfilling the council’s ongoing duties”. The CLCPA (§ 75-0103, 7) states that the CAC “shall convene advisory panels requiring special expertise and, at a minimum, shall establish advisory panels on transportation, energy intensive and trade-exposed industries, land-use and local government, energy efficiency and housing, power generation, and agriculture and forestry”. I interpret that to mean that the membership of the panels will have specific expertise in those sectors.
New York State has an existing energy planning process. The State Energy Plan is a comprehensive roadmap to build a “clean, resilient, and affordable” energy system for all New Yorkers. It focuses on “reliably meeting projected future energy demands, while balancing economic development, climate change, environmental quality, health, safety and welfare, transportation, and consumer energy cost objectives”. Importantly that process is integrated with the responsibilities of the New York Independent System Operator (NYISO), New York State Reliability Council (NYSRC) and Department of Public Service (DPS). In my opinion, the requirement that the scoping plan “inform” the energy plan is a major risk. It appears that the transition plan places as much value on the opinions of the CAC and advisory panels as the electric energy system professional staff at NYISO, NYSRC, and DPS who all have many years experience with all aspects of the reliability needs of the energy system.
I am only following the power generation advisory panel closely because of my concern that the membership of the CAC and advisory panel are not focused on reliability and affordability because of their background or naïveté. I previously described the membership of the generation advisory panel in a post on the announcement of the membership of the advisory panels approved at the Climate Action Council meeting on August 24, 2020. Meeting materials for all the advisory panel meetings have been posted.
This post describes their first meeting with a section on each of the major agenda items listed in the Power Generation Advisory Panel 9/16/2020 meeting materials. John Rhodes, Chair of the Public Service Commission, is the chair for this advisory panel. He presented most of the material.
Introductions and Panel Member Priorities
The Climate Action Council approved 14 members, a chairman and a co-chair to the power generation advisory panel but left open consideration to add more people at their August meeting. There was no indication at this meeting that anyone would be added. In my earlier post I documented the background and affiliations of the CLCPA Power Generation Advisory Panel. I categorized the organizations represented by the 14 non-state agency members: three members work for generating companies, two renewable and one fossil oriented; one member is from the New York Independent System Operator, the state’s grid operating company; one member is a consultant for energy and sustainability issues; and the remaining eight members were from advocacy organizations representing either renewable technologies, the environment, or trade unions, with one representing ratepayers.
At this meeting each member was given the opportunity to introduce themselves and list their priorities for this process. The introductions confirmed one of my concerns. All but two of the members clearly plan to advocate for their organization or company in this process. This is understandable but could very well not be in the best interest of the state. Everybody had an opportunity to mention that their priorities include reliability and affordability but only four did so. Only the representative of the New York Independent System Operator could be considered neutral for any particular technology and mentioned reliability and affordability as priorities.
State of the Sector
This part of the meeting listed the targets that have been codified into law. The “Alignment with CLCPA” slide is interesting because it starts to quantify the scale of the problem. The slide estimates that in 2030 the estimated load will be 151,678 GWh. The 2030 goal is that 70% of this load or 106,174 GWh will be met by renewable energy sources. According to the slide we are currently generating 39,013 GWh and there are an additional 19,937 GWh of renewable energy under contract but not constructed. That means that 47,224 GWh of renewable energy have to be contracted and constructed by 2030. The slide breaks down the types of renewable energy resources into three categories: land-based renewables, offshore wind and distributed energy resources but the presentation did not explain how those numbers were derived. The slide also states that there are 93 MW of energy storage currently operating but that the 1,400 MW of hydro storage are not included because “it does not count towards the goal”. According to the slide 841 MW of energy storage is under contract and 2,086 MW of energy storage needs to be constructed and contracted by 2030. It was not clear how the energy storage numbers were derived.
The remainder of this portion of the meeting described the Accelerated Renewable Energy Growth and Community Benefit Act (AREGCBA pronounced aargh) and Clean Energy Standard expansion. AREGCBA established the Office of Renewable Energy Siting who on September 16,2020 issued draft regulations. While those regulations require permit application approval in a year there still are significant requirements for permitting that, in my opinion, will require a least a year to prepare. The Clean Energy Standard includes an annual procurement target for off-shore wind of about 4,500 GWh from 2020 to 2023. Note that in order to build off shore wind turbines on-shore infrastructure also has to be developed. The enormous quantity of renewables that need to be contracted, permitted, and constructed by the end of 2029 so that renewable energy output meets the 2030 goal is an ambitious target to say the least.
Pathways Presentation
Energy + Environmental Economics presented the results to the Climate Action Council of their emissions reductions pathway analyses earlier this year. This material was presented to the members of the advisory group at the meeting. There were a few key takeaways. E3 noted that “electrification of buildings and transportation drives significant increase in annual electric load” and that “NYS shifts from summer peak to winter peak around 2040, driven primarily by electrification of heating in buildings and EV battery charging”.
I worry that the members of the advisory group may not grasp the implications of issues mentioned in the “opportunities to decarbonize the electric sector” slide: “Energy efficiency and managed electrification will be critical to mitigating load growth and “peak heat” impacts”; “To decarbonize electricity supply, New York has access to a diverse portfolio of renewable resources”; “Battery storage and demand side flexibility can play a key role in intraday balancing”; and “A number of firm, zero carbon resources can help solve inter-day balancing challenges, e.g. multi-day periods of low renewable output”. Each of these issues is complicated and uncertain. Those who have a vested interest in a particular aspect of any of these issues also have a bias towards glossing over the complications and uncertainty to promote their interests.
There were two slides describing electricity supply considerations. In order to discuss the impacts of these two slides would require its own post so that will have to wait. Instead I want to highlight the Electricity Supply – Firm Capacity slide because it addresses what I think is the ultimate CLCPA problem. The slide states: “The need for dispatchable resources is most pronounced during winter periods of high demand for electrified heating and transportation and lower wind and solar output”. The slide goes on to say: “As the share of intermittent resources like wind and solar grows substantially, some studies suggest that complementing with firm, zero emission resources, such as bioenergy, synthesized fuels such as hydrogen, hydropower, carbon capture and sequestration, and nuclear generation could provide a number of benefits”.
The firm capacity slide prompted discussion. E3 has been trying to come up with a list of resources that will address the problem of high electric loads when there is low renewable energy availability. When they suggest firm, zero emission resources could provide a number of benefits what they are really saying is those resources are needed to keep the lights on. They list five possibilities, three of which are unlikely to provide any meaningful relief in New York. Meaningful additional amounts of hydro-electric power are unlikely because all the good locations have already been developed. Carbon capture and sequestration projects require good locations for sequestration. The Cuomo administration refused to permit a propane storage project adjacent to an already existing storage project so I cannot imagine that sequestration of CO2 would be permitted either even if suitable locations are found. Nuclear would be a great option but New York is closing down viable, operating nuclear facilities so building a new facility seems highly unlikely. Synthesized fuels such as hydrogen may have possibilities but there are enormous technical issues for hydrogen. That leaves bioenergy. However, a couple of people on the panel argued that because renewable natural gas (RNG), which refers to methane generated by anerobic digestion or by other means, is not specifically listed in the CLCPA, it does not qualify as a renewable option. It was very obvious that those arguing against RNG had a bias against methane that was more important to them than solving the problem of firm capacity.
Work Plan Development
John Rhodes discussed the development of the work plan. Each advisory group has been charged to “develop sector specific strategies to achieve a 53% to 56% reduction in GHG emissions from 2016 level by 2030 (100% by 2050). For the power sector, the 2030 target is that 70% of the electricity must be generated by renewable energy which complicates this panel’s planning a bit. More importantly, the 2016 GHG emission levels consistent with the CLCPA rules have not been published. In order for the advisory groups to do their work that estimate is needed soon. The slide states that the advisory groups will “Present a list of recommendations for emissions reducing policies, programs or actions, for consideration by the Climate Action Council for inclusion in the Scoping Plan”. It notes that the recommendations may be informed by quantitative analysis or qualitative assessment. I hope that the recommendations rely on quantitative analysis because qualitative assessments may not maintain reliability.
There was an overview of the recommendations for the panel. The panels are supposed to “Evaluate the costs and benefits of recommended strategies, informed by the Value of Carbon established in accordance with Section 75 0113 of the CLCPA; Identify measures to reduce greenhouse gas emissions and co pollutants in disadvantaged communities; Include climate adaptation and resilience considerations; Consider approaches taken by different states and nations; and Identify potential sources of funding necessary to implement the recommended policies.” There is an enormous challenge converting the New York electric system to unprecedented levels of renewable energy and I am not sure adding these additional requirements is consistent with that challenge.
The initial thoughts on “Scope Development” slide included the following topics: clean energy siting, transmission, electrification of buildings and transportation, natural gas system, carbon pricing, downstate peakers, equity issues, reliability of the future grid – storage, flexible/dispatchable resources, instate renewables, downstate renewables, “last” clean megawatts (final x%), resource transition/ramping fossils down, encouraging the needed investment, markets for the future (including resource adequacy), affordability, and jobs/prevailing wage. Each one of these topics is complicated and warrants a briefing for the advisory panel members. If they don’t understand the topic then they cannot incorporate these thoughts on their recommendations.
The last two slides address the timeline for the advisory panel. I think the following schedule is quite an imposition on the members of the panel: October 2020: Work Plan finalized; December 2020: Briefing on priority policies/strategies; and March 2021: Final Recommendations to CAC. By the end of October, they are supposed to seek written external input on priority policies and strategies, meet with the climate justice working group and the environmental justice advisory panel to get input on priority policies and strategies, and then present the work plan to the Climate Action Council.
Conclusion
The implementation process worries me and this meeting reinforced my concerns. I am concerned about the development of recommendations for the power generation sector and the fact that necessary information to develop those recommendations is not available.
Since my retirement ten years ago I have spent a lot of time reading about the energy system and it was humbling how much I didn’t know about the system I had been supporting since I started working directly for a utility in 1981. Unfortunately, I think that the majority of the Climate Action Council and power generation advisory panel members have very little background in the sector. The schedule for the development of recommendations for a transformation of the power generation sector is aggressive and would be a challenge even for people with extensive backgrounds in the sector. The schedule timeline is so short I worry that bringing the members up to speed on the technical constraint issues will necessarily be short-changed. The magnitude of problem is huge and addressing just one issue, providing dispatchable, zero emission electric energy during multi-day periods of low solar and wind resources, is daunting. It was clear on the call that more than one member of the advisory group has a particular agenda that seems to trump the overall need for reliable and affordable power. Finally, it is not clear how the process is supposed to work when there are conflicting priorities.
Another serious issue with the schedule is the unavailability of some key information. In order to provide defendable recommendations for the future power generation sector three data sets are needed. New York State agencies have to provide a future load projection for the year as a whole and for the worst case, the multi-day period of low wind and solar availability. The 2030 goal (70% from renewable sources) is only a function of the source of energy produced but very soon the Climate Action Council has to determine the current level of GHG emissions using the CLCPA methodology. The draft state-wide emission limits based on 1990 emissions have been proposed but not finalized. The emissions inventory for the current levels of emissions has not been released. Finally, the wind and solar resource availability needs to be determined for the worst case. In order to develop a power generation plan for the transition all this information needs to be known.
I intend to follow this to see how it works out. Stay tuned.
Pragmatic Environmentalist of New York 