On July 18, 2019 New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act (CLCPA), which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency. This post addresses fundamental concerns raised about the CLCPA technology requirements and the framing of those concerns to the policy makers.
I am following the CLCPA closely because its implementation affects my future as a New Yorker. Policy makers are trying to choose between many expensive policy options to meet the CLCPA targets while at the same time attempting to understand which one (or what mix) will be the least expensive and have the fewest negative impacts on the existing system. If they make a good pick then state ratepayers spend the least amount of a lot of money, but if they get it wrong, we will be left with lots of negative outcomes and even higher costs for a long time. 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.
The law established the Climate Action Council and gave them the responsibility to develop a scoping plan to meet the aspirational schedule and targets summarized at CLCPA Summary Implementation Requirements. At the same time, the New York Independent System Operator (NYISO) is supposed to manage New York’s power grid and energy market to “coordinate and direct the flow of electricity over the state’s high-voltage transmission system”. That management includes long-range planning responsibilities. The NYISO is supposed to be “independent” and that would accordingly allow them to be critical of the CLCPA targets if their expertise leads them to believe that the schedule and targets threaten the reliability of the power grid and energy market.
I have previously described what I think is ultimate problem with the CLCPA, namely what non-emitting power sources will be able replace the loss of intermittent wind and solar energy when electricity is needed the most during the winter. In the E3 presentation to the Power Generation Advisory Panel on September 16, 2020 this issue was raised. The slide titled Electricity Supply – Firm Capacity 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”.
On October 8, 2020 the Climate Action Council meeting included a presentation by Rich Dewey, President of NYISO, that gave an overview of their planning process used to maintain system reliability and raised the same concern. The presentation included a description of Dispatchable Emissions-Free Resources (DER) that are needed to maintain reliability. They were described as resources that must be able to come on line quickly when needed, and be flexible enough to meet rapid, steep ramping needs. In other words, they are fossil-fired generating units without the emissions. Dewey’s presentation slides concluded “The current system is heavily dependent on existing fossil-fueled resources to maintain reliability. Eliminating these resources will require investment in new and replacement infrastructure, and/or the emergence of a zero-carbon fuel source for thermal generating resources.”
Dewey’s presentation was based on work by The Analysis Group’s NYISO Climate Change Phase II Study. Their presentation at the NYISO Electric System Planning Group Meeting on September 10, 2020 had some important caveats regarding the CLCPA transition and Dispatchable Energy Resources. The Analysis Group noted that “There is no historical precedent for this pace of renewable generation development and integration” referring to the CLCPA schedule. They also noted that: The “DE Resource” category is included in the model to achieve reliable solutions” but stated that they did not “presume to know what resource or what fuel will fill this gap twenty years hence”.
For those who are new to New York energy policy politics it might seem odd that Dewey did not mention those caveats that reflect the enormity of the challenge facing New York’s CLCPA energy transition. But for those of us who remember the last time that NYISO raised similar concerns it is not a surprise. In 2016 NYISO filed comments with the state saying its goal to power the state with 50 percent renewable energy by 2030 was unrealistic unless a massive investment in new transmission lines were undertaken. In response, the Cuomo Administration pitched a fit.
“We are dismayed, however, that your recent filing to the Public Service Commission (PSC) and recent press reports on the Clean Energy Standard (CES) are misleading, incomplete, and grossly inaccurate. The filing reveals an alarming lack of developed analysis and understanding into the imperative to address climate change by transitioning to a clean electric system, and how a modern grid can be developed and operated. The NYlSO’s paradigm of analysis is outdated – a world where large power plants produce electricity based upon a fixed demand and where electrons flow in one direction. Thus, NYISO has not adequately taken into account the way new technology can balance electricity load in response to intermittency, to renewable resources or to dynamic price signals, nor has NYISO considered how market-based approaches to stimulate energy efficiency will change the amount of renewable energy needed to achieve the Governor’s 50 percent renewables goal by 2030.”
“It is apparent from the filing and subsequent information, that the NYISO is held captive by your stakeholders, the majority of whom represent the status quo interests that are threatened by the renewable future that New Yorkers want and deserve. Indeed your critique only makes sense in this context. It is, therefore, hardly surprising that in recent press reports, the Independent Power Producers, an industry advocacy group that represents the interests of fossil fuel producers, has been so quick to endorse the views of the NYISO when it appears that its interests are so well served.”
“The Public Service Commission has vast expertise in system planning and operations. They will no doubt work with all of the stakeholders to identify the challenges associated with the energy future we are designing. As necessary, we will find ways to address those challenges in a manner that is independent of the economic interest of incumbent fossil generators that you seem to be protecting. Again, I am dismayed by your filing and public comments. We want and expect better from our local grid operator.”
In that light it is no surprise that Dewey’s slides included the following statement: “We believe State policy goals can be achieved while maintaining grid reliability.” The treatment of his predecessor no doubt affected the tone and content of his presentation. There is no organization or agency better able to independently assess future alternatives for the electric system than the NYISO. It is in the best interests of the State that the Climate Action Council and Cuomo Administration accept that they are independent and acknowledge their concerns even if it runs contrary to their ideological beliefs.
In conclusion, I wonder if the NYISO, or anyone else for that matter, can say anything to the Climate Action Council that suggests that the CLCPA goals and schedule are unrealistic. The Analysis Group caveats and viability issues with the E3 list of potential resources to meet the DER adequacy problem need to be fully understood by all the Council members. That information is not only complex and difficult to understand but also raises doubts about the practical viability of New York’s energy policy. The fundamental tenet of the CLCPA is that there is nothing aside from political will holding back implementation of an energy transition to clean, affordable, reliable, and resilient electric power. I believe that anyone raising questions about that will be accused of being defeatist and in the CLCPA war on climate such defeatism is tantamount to treason.