On January 11, 2021 the Climate Leadership and Community Protection Act Power (CLCPA) Generation Advisory Panel met as part of the Climate Action Council Scoping Plan development process. The meeting tested a consensus building process to address the “problem” of peaking power plants. I recently published a post on that issue. It has come to my attention that Consolidated Edison recently submitted a petition to the New York Department of Public Service (DPS) proposing a solution to the peaking power plant problem. This post describes that solution relative to the CLCPA.
On July 18, 2019 New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act, which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency. I have written extensively on implementation of the CLCPA closely because its implementation affects my future as a New Yorker. I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulations, listed the scoping plan strategies, summarized some of the meetings and complained that its advocates constantly confuse weather and climate. 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.
Background
As described in my previous post, peaking power plants are used to ensure that there is sufficient electricity at the time it is needed most. The problem is that the hot, humid periods that create the need for the most power also are conducive to the formation of ozone. In order to meet this reliability requirement ~ 100 simple cycle turbines were built in New York City in the early 1970’s that were cheap and functional but, compared to today’s standards, emitted higher levels of nitrogen oxides that are a precursor to ozone. In 2020 the Department of Environmental Conservation promulgated a new regulation that will result in the retirement of these simple-cycle combustion turbines presently used exclusively for peaking power uses in order to address ozone nonattainment.
On December 30, 2020 Consolidated Edison (Con Ed) submitted a petition for “approval to recover costs of certain transmission reliability and clean energy projects” as part of DPS Case 19-E-0065 as part of their currently effective rate plan. They propose three transmission reliability and clean energy projects that will address reliability issues associated with DEC’s new regulation affecting these peaking units.
Concerns
The biggest CLCPA Power Generation Advisory Panel problem with the Con Ed solution is that it only addresses the simple-cycle combustion turbines used for peaking services. The environmental justice community and some members on the Advisory Panel use a more expansive definition of peaking power plants including generating units that are not covered by this proposal. In the Physicians, Scientists, and Engineers (PSE) for Healthy Energy report Opportunities for Replacing Peaker Plants with Energy Storage in New York State peaking power plants are defined based on the following criteria: fuel type: oil & natural gas; Capacity: ≥ 5 MW; capacity factor: ≤15% (3-yr. avg.); unit technology type: simple cycle combustion turbine, steam turbine & internal combustion; application: entire peaker plants & peaking units at larger plants; and status: existing and proposed units. This definition of peaking units includes boilers used for electric power, boilers used for steam, and recently built combined cycle combustion turbines as well as the 100 or so peaking turbines that industry considers peaking units. The Peak Coalition definition includes units that do not necessarily exist solely to address peak load problems but also have other uses.
In October 2020, The New York Power Authority (NYPA) and the PEAK Coalition “unveiled an agreement to assess how NYPA can transition its natural gas fired ‘peaker’ plants, six located in New York City and one on Long Island with a total capacity of 461 megawatts, to utilize clean energy technologies, such as battery storage and low to zero carbon emission resources and technologies, while continuing to meet the unique electricity reliability and resiliency requirements of New York City”. As far as I can tell, the Con Ed transmission projects will not address the NYPA combined cycle combustion turbines. Also note that the Con Ed Petition specifically dismissed the clean energy technologies in the NYPA agreement:
“The Company also evaluated whether non-wires solutions, load reductions and/or load transfers, renewable resource or energy storage deployment within the Transmission Load Area (TLA), local transmission additions, or a combination of these solutions, could address both the local reliability need and the constraints. The Company determined that only the Transmission Reliability and Clean Energy (TRACE) projects would both solve the local system reliability needs and alleviate transmission system constraints to enable the State to achieve its clean energy goals. Specifically, physical space limitations within the TLAs challenge or virtually foreclose the addition of utility scale photovoltaic (“PV”) and large-scale energy storage systems there. And, as described below, storage within the TLA can only partially address reliability needs because the TLA deficiencies, which extend over 10 to 14-hour periods often over consecutive days, exceed the capability of storage technologies to respond.”
It may be that the physical space limitations may differ near the NYPA turbines but we are dealing with New York City which is notorious for limited space.
There is another aspect that I know exists but don’t have sufficient knowledge to address in this context. The power still has to come from somewhere. There are specific requirements for in-city generation that were developed to address previous blackouts in New York City. I am not sure how those requirements will be satisfied within the constraints of the CLCPA.
The Con Ed petition claims that their projects are necessary to “facilitate achievement of the State’s clean energy goals as defined in the CLCPA” by enabling retirement of the peaking power plants and solving the associated reliability needs without the addition of any new fossil-fired power plants. Note however that the proposed cost of these projects is $780 million and only provides delivery of the power not replacement power production.
Conclusion
I agree with the Con Ed petition’s claim that the three transmission projects are “multi-value, ‘no regrets’ solutions”. Not only do they “provide critical reliability contributions that require their construction to meet established reliability design criteria, but also put in place the necessary foundation to achieve the CLCPA’s goals.” Unfortunately, the public will never know the comparative cost of this CLCPA-consistent solution relative to an alternative solution that used fossil fuels. As a result there will be a hidden CLCPA cost.
The bigger problem is the ramifications relative to the environmental justice advocates and their allies on the Power Generation advisory panel. In the first place, even though Con Ed’s solution checks all the CLCPA technology boxes it only addresses the facilities that have generally been considered “peakers”, not the facilities that the Peak Coalition considers “peakers”. Secondly, Con Ed considered and discarded as technically inappropriate, the alternatives that the Peak Coalition is advocating for the NYPA peaking turbines. Those turbines provide peaking services but they also are clean and efficient. It boils down to whether the environmental justice advocates can accept minimal risks from those facilities or will only be satisfied if there is zero risk from their pre-conceived notion of the problem. I am not comfortable that they understand the trade-offs of different risks from different options.
Pragmatic Environmentalist of New York 