Climate Leadership and Community Protection Act: NYISO Resilience Study and the Texas Energy Debacle – Reliability Resources

I recently wrote that the energy debacle that occurred in Texas is unlikely in New York today because of market and system differences but if the Climate Leadership and Community Protection Act (CLCPA) is implemented incorrectly something similar is inevitable.  This is the second post reviewing the Analysis Group Climate Change Impact and Resilience Study (“Resilience Study”) prepared for the New York Independent System Operator (NYISO) relative to the Texas energy debacle.  The Resilience Study evaluated different resource scenarios that meet the 2040 CLCPA zero-emissions mandate for various weather and load scenarios.  The first post compared weather considerations between the recent Texas event and this study.  In this post I will compare the CLCPA power generation advisory panel strategy recommendations and Integration Analysis plans to the Resilience Study.

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.

Texas Energy Debacle

In brief, the ultimate cause of the blackouts and resulting problems in Texas was due to poor planning.  The weather in Texas during the storm was extreme but not unprecedented.  Similar cold snaps occurred in 2011, 1991, 1990, 1989, 1983, 1963, and 1961 and there were electrical outages in 2011.   Because there is no apparent trend in low daily maximum temperatures (see Tony Heller’s graph), climate change is not a factor.  This was a weather event.

Chuck DeVore explains that poor planning led to two problems that caused the blackouts but policy failures over many years were the root cause.  He states that “had every Texas generator powered by natural gas, coal, nuclear and hydro operated at full output during the height of the storm’s demand, Texas still would have experienced planned blackouts”. The policy failure that led to this situation is that “Federal and state tax policy have encouraged the overbuilding of wind, and to a lesser extent, solar power, resulting in cheap, subsidized power flooding the Texas grid” and that in turn has discouraged building new natural gas power plants and keeping existing coal and gas plants on-line.  Clearly the extremely cold weather did reduce wind turbine output and it also affected fossil and nuclear output.  The more worrisome problem for me is that as ERCOT struggled to keep the lights on, “the grid became unstable, tripping additional power plants offline to protect their massive generators from destructive interaction with a fluctuating line frequency”.  This appears to have been largely caused by large fluctuations in wind output.   “As ERCOT issued the order to start load shedding – rotating blackouts – some of the darkened circuits included vital oil and gas infrastructure. This uncoordinated move starved natural gas power plants of their fuel – leading to a further loss of power and the widespread and incorrect rumor that wellhead and pipeline freeze off contributed to the disaster.”

Clearly the Texas electricity market failed to provide adequate resiliency for these conditions.  I agree with Becky Klein, former commissioner and chairman of the Public Utility Commission of Texas who writes that the questions that need to be considered now are:

      • Are we prepared to pay more for electricity and water to ensure higher levels of reliability?
      • And if so, how much more?
      • How can we be better prepared for “outlier” events, regardless of their probability?
      • Would it make sense to require state-wide scenario planning that includes coordinated drills that test both our operational and communication capabilities across multiple entities?

As New York transitions its electric system to one dependent upon renewables all of these questions need to be addressed.  Fortunately, the NYISO Climate Change Impact and Resilience Study lays the foundation to start to address those questions in New York.

New York Reliability Planning

According to the 2020 NYISO Reliability Needs Assessment: “The New York system is deemed to have sufficient resources if the probability of an unplanned disconnection of firm load (loss of load expectation, or “LOLE”) is equal to or less than the standard of once in every 10 years or 0.1 events per year.”  In my previous post I explained that if reliability needs are identified the ultimate output of the NYISO reliability planning process is to ascertain the amount and location of compensatory MW required for the New York Control Area NYCA to eliminate the reliability problem.  The post then looked at whether this planning process adequately protects New Yorkers from blackouts similar to Texas.  I concluded that the current system offers protection but could not draw a conclusion for the future because NYISO could only guess at the resources that the CLCPA energy plan will specify.

Ultimate Problem

I have described what I believe is the ultimate problem previously.  Both E3 in their presentation to the Power Generation Advisory Panel on September 16 and the Analysis Group  in their September 10, 2020  presentation to NYISO explained that in order to meet the CLCPA emissions reduction goals that a resource category that provides firm, dispatchable and zero-emissions generation is needed.  The Analysis Group labels these resources as dispatchable and emissions‐free resources (“DE Resources”) but gives no specific examples.  On the other hand, E3 gives examples such as “such as bioenergy, synthesized fuels such as hydrogen, hydropower, carbon capture and sequestration, and nuclear generation”.  The  International Energy Agency (IEA) recently published “Special Report on Clean Energy Innovation” that classified the technology readiness level of the technologies that could possibly be both dispatchable without GHG emissions.  The bottom line is that none of the E3 examples of firm, dispatchable and zero-emissions technologies are close to being ready for adoption except nuclear and hydro which I believe are unlikely to provide any meaningful support for New York.

This post will address the CLCPA power generation advisory panel strategy recommendations relative to the Resilience Study description of the firm, dispatchable and zero-emissions resources issue.

DE Resources

The Resilience Study explained the criteria used to “establish a system that; (a) has demand consistent with the Climate Change Phase I Study, (2) has a set of resources that comply with the requirements of the CLCPA, and (3) that meets electricity demand in every hour all year.”  They went on to explain the uncertainties for these initial “starting point” resources:

      • The New York power system is currently heavily dependent on natural gas fired generating units to provide energy, to be available during high load hours, to provide critical reserves on the system, and to be able to ramp up and downs on timescales of seconds, minutes, hours, and days to manage net load variability. At least as currently configured and fueled, these resources cannot operate in 2040;
      • Even retaining existing low‐carbon (nuclear, hydro) resources, there is an enormous amount of energy and capacity needed to meet projected demand in 2040;
      • Currently‐available and reasonably economic resources available to make up the zonal and system‐wide energy deficits include solar and wind resources, yet their availability is uncertain and somewhat unpredictable. In fact, data reviewed for this report reveal that there would be long (multi‐day) “lulls” in production from these resources. This means that almost no quantity of nameplate capacity from these resources is sufficient to meet demand in all hours of the year;
      • Energy storage resources that are currently and expected to be available can fill part, but not all of the gap needed to maintain system reliability;
      • There is a void that will need to be filled with technologies and/or fuels that ‐ at the scales that would be required ‐ are currently neither proven nor economic; and
      • There is no doubt a major amount of technological change that will happen over the next twenty years, rendering it very difficult to forecast a future resource set with reasonable confidence.

On October 8, 2020 Kevin DePugh, Senior Manager for NYISO Reliability Planning, made a presentation to the Executive Committee of the New York State Reliability Council that gave an overview of the Reliability Study and emphasizes the results in the context of reliability planning.  In a post at the time I noted that his presentation listed the following characteristics of the DE resource:

      • Large quantity of DE Resource generation is needed in a small number of hours;
      • DE Resource has low capacity factor (~12%) during the winter;
      • DE Resource has only a 3.7% capacity factor in the summer;
      • DE Resource is not needed at all during spring and fall;
      • Substantial quantity of DE Resource capacity is needed, the energy need is minimal;
      • DE Resource must be able to come on line quickly, and be flexible enough to meet rapid, steep ramping need;
      • On an average day, storage can meet evening peaks, but the DE Resource must generate if storage is depleted and renewable generation is low; and
      • In the Winter CLCPA scenario, the DE Resource output across the state must increase from 362 MW (1.1% of DE Resource nameplate capacity) to27,434 MW (85.4% of name plate capacity) in six hours of the most stressed day.

Generation Advisory Panel Draft Enabling Initiatives

At the February 12 and 22, 2021 Power Generation Advisory Panel meetings seven “enabling” initiatives or strategy recommendations for the Climate Action Council were discussed.  Among the initiatives discussed were: technology solutions, market solutions, existing storage technology, long duration storage technology, and growth of large-scale renewable energy generation.  I have reviewed them and I conclude that none directly address the issues raised in the Resilience Study.  The February 12 presentation also included a list of seven other initiatives.  The only one that appears to address this issue is “reliability for the future grid”.  I will update this article if that initiative does in fact address the Resilience Study issues.

I am generally concerned with the initiatives that even are peripherally related to reliability.  My first concern is, as noted previously, the lack of a comprehensive assessment of renewable resource availability for New York. Coupled with the fact that the current GHG emissions won’t be available until early next year, it is impossible for anyone to project what resources will be needed.  Until you have something to work with it is not possible to determine if the plans will prevent future reliability issues.  The initiatives also appear to me to be overly dependent upon technologies and/or fuels that ‐ at the scales that would be required ‐ are currently neither proven nor economic.

Integration Analysis

On February 26, 2021 the integration analysis technical resources were updated:

They describe the inputs and assumptions for the economy wide analysis of energy supply, energy demand and other aspects of the economy affected by the CLCPA.  Once all the advisory panel recommendations are provided to the Climate Action Council responsible for implementing the plan to meet the CLCPA targets, this is the study that will combine the recommendations for the Scoping Plan.  I briefly reviewed the summary report to see if it addressed reliability issues relevant to this article.

Previously I mentioned that it was that there were fluctuating line frequency issues associated with the Texas blackouts.  I wrote an article recently about transmission grid ancillary services and my particular concern that no one appears to have the responsibility to incorporate this in their CLCPA planning efforts.  These services are needed to keep the transmission system from, among other things, having line frequency issues.  If this reliability concern is actually going to be explicitly considered by the integration analysis, I would think it would be mentioned. Because the word ancillary is not included in the summary and my review of the slides did not find any suggestion that this aspect was being considered I don’t think that this issue is currently in the plans for the integration analysis.

There also is no mention of a renewable energy resource evaluation.  As a result, I am not confident that the reliability issues that caused the Texas blackouts will be covered by the integration analysis.


The Analysis Group writes: “The variability of meteorological conditions that govern the output from wind and solar resources presents a fundamental challenge to relying on those resources to meet electricity demand.”  Because wind and solar resources are intermittent energy storage is necessary, but the Generation Advisory Panel has not yet explicitly addressed the Resilience Study conclusion that “Energy storage resources that are currently and expected to be available can fill part, but not all of the gap needed to maintain system reliability”.  Of the initiatives discussed to date, the long-duration storage initiative comes closest when it states that “Achieving the CLCPA’s high renewable energy, zero emission electricity system will require substantial amount of energy storage operating over various timescales spanning from minutes to hours, days, weeks and even longer to maintain grid flexibility and reliability.”  Note, however, that Pugh’s characteristics of the DE resource listed above (large quantity only needed for a short time) are not conducive to a business case for this resource.

The integration analysis is supposed to address all aspects of energy use in the entire New York economy.  This is a massive undertaking and necessarily will depend upon other studies for input.  Unfortunately, I could find no sign that the issues raised by the Texas blackouts will be considered.

The Resilience Study outlined significant technological challenges for a transition to a zero-emission electric sector that will maintain current reliability standards.  The Analysis Group found that no amount of solar and wind resource development is “sufficient to meet demand in all hours of the year; Energy storage resources that are currently and expected to be available can fill part, but not all of the gap needed to maintain system reliability; There is a void that will need to be filled with technologies and/or fuels that ‐ at the scales that would be required ‐ are currently neither proven nor economic; and There is no doubt a major amount of technological change that will happen over the next twenty years, rendering it very difficult to forecast a future resource set with reasonable confidence.”  Because I could not find explicit language addressing the challenges identified in CLCPA Power Generation Advisory Panel strategy recommendations and the E3 Integration Analysis summary report, I am not confident that current reliability standards will be maintained.

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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