As part of my review of the Texas energy debacle relative to New York I assessed whether the implementation of the Climate Leadership and Community Protection Act (CLCPA) would affect reliability. I wrote a couple of articles 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 and compared their findings relative to the CLCPA power generation advisory panel strategy recommendations. This is an update addressing additional recommendations that have been presented since the earlier article and a more detailed examination of the enabling initiatives components addressing reliability.
I have written extensively on implementation of the CLCPA closely because I worry that its impacts on affordability, reliability and the environment affect 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.
Generation Advisory Panel Draft Enabling Initiatives
At the February 12 and 22 and March 10, 2021 Power Generation Advisory Panel meetings ten “enabling” initiatives or strategy recommendations for the Climate Action Council were discussed. The CLCPA Power Generation Advisory Panel Enabling Strategy Initiatives Summary table lists 15 different initiatives for possible recommendations. At the time of this writing ten of the initiatives have been discussed. I assume that the remaining initiatives will be discussed at upcoming meetings.
In a recent post I said I was disappointed with the initiative topics addressed by the panel. Given that no jurisdiction anywhere has actually implemented a zero-emissions electricity generating system I believe that the emphasis of this advisory panel should be on initiatives that enable or implement zero-emissions generation and the necessary supporting infrastructure including transmission necessary to deliver the power generated when and where needed. Affordability and reliability should also be considered. The reason I am disappointed is that resources were squandered on four topics that are out of the scope of power generation and are being considered by other advisory panels.
I believe that the enabling initiatives should specifically address three concerns derived from these Resilience Study conclusions: “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” and “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 course, the third concern is what are they going to do about the missing energy resources gap 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.
The focus of this post is whether the draft initiatives adequately address the reliability resource issues described in the Resilience Study. In a previous post I explained that the Integration Analysis will incorporate the recommended initiatives in the development of the economy wide analysis of energy supply, energy demand and other aspects of the economy affected by the CLCPA.
Discussion
In this analysis I looked at all the initiative to see how many components specifically addressed reliability issues. The Generation Advisory Panel Enabling Initiative Components that Explicity Address Reliability Issues table lists eight initiatives that have components that explicitly address reliability and categorizes which components address it. There are 36 components and 29 address reliability in some fashion. The key question is whether the enabling initiatives address the three concerns in the Resilience Study.
The first enabling initiative addresses reliability more than any other. As such it is instructive to consider the notes from the February 12 meeting where this was discussed as well as the draft summaries. I extracted the relevant notes for this initiative, annotated my comments in the linked document and will summarize the discussions here. There are two categories of technology solutions in this enabling initiative: those required to meet the 2030 goal and those to meet the 2040 goal.
The Technology Solutions initiative has two components for the 70 by 30 goal: “focus on energy delivery, the economics of long duration and seasonal storage, siting, and identifying technology gaps” and “aggressive deployment of current renewable energy and storage technologies”. It appears to me that these components are simply calls to build as much as possible as fast possible and worry about whether that will work, much less address whether this plan is effective, later. I think this might lead to problems. For example, at the 19 January 2021 Climate Action Council meeting the meeting presentation announced that New York’s 2020 renewable energy standard solicitation includes 22 new large-scale renewable energy projects including the 110 MW Rutland Center Solar One project due east of Lake Ontario in the north central part of the state. This may not be an appropriate location if the multi-day winter period of calm is the critical worst-case period because this site is in the Lake Ontario snow belt. As a result, it is likely that during the worst-case renewable resource availability period the panels will be covered by snow and provide no support at all for the New York electric system. To effectively address that period, solar in similar locations should be discouraged.
I do not believe the components described to meet the 2030 goal adequately address reliability. From what I understand in the summary and notes, the panel believes that meeting the 70% reduction of GHG emissions by 2030 will not require technological breakthroughs, only accelerated deployment and investments. I think that presumes that we are not that far away from the target, but we don’t know how far we have to go because current levels of emissions using New York’s methodology have not been released. The key question is whether the New York inventory adjustments for methane are so large that could make this a more difficult goal to achieve than is commonly believed today. I believe that it might be necessary to have long-duration storage in the energy mix needed to meet the 2030 goal and that means natural gas is going to be needed until long-duration energy storage can be implemented at scale and in time. It appears that is a controversial presumption within the panel. I am also concerned that the reality of current energy storage technology does not comport with what will be needed. No jurisdiction has implemented energy storage at the levels likely needed so there may be unforeseen issues. Finally, I believe we do not know enough about renewable energy resources worst case availability to determine whether present technology can provide enough power to keep the lights on.
There are four components for the achievement of the 100 by 40 goal. The first component is “detailed, holistic, modeling within a zero-emissions world to identify needed technologies”. Clearly, in order to meet the 2040 goals technological innovations will be required and this kind of modeling is necessary to define the problem. Unfortunately, I don’t think most of the panel understands just how large a challenge this is. Moreover, there is not universal understanding that replacing fossil fuel infrastructure should only be done when those innovations have produced technology that is mature enough to be available for deployment. That takes time. This goes back to the politically correct but technical unreality that replacing fossil fuels is only a matter of political will. It is not clear that all the members of the panel understand the difference between a political slogan and reality.
Finally note that there were complaints about an over-emphasis on the last 5-10%. The comment that the “conversation about the last 5-10% is a distraction” demonstrates a lack of knowledge about the reality problem. The electric system is designed to provide reliable service under all conditions and it turns out that in order to do that the prime consideration becomes how do you handle peak load periods – the last 5-10%. The Texas energy system did not consider the last 1% and look what happened. I believe that not emphasizing the last 5-10% will lead to blackouts sooner and more often.
Also included in the 100 by 40 goal are two other components: “Support NYSERDA in its innovation efforts, including the development of a consortium of stakeholders to develop these solutions” and “supporting utility-scale demonstration projects of new technologies, including storage and transmission and distribution”. Both are necessary steps in order to develop the technology needed for a reliable system.
The final component of this initiative is “during planning, emissions free resources (e.g., storage, energy efficiency, distributed renewable energy) should be prioritized where feasible when considering end uses, technology limitations, and costs. However, should a substitute for natural gas still be needed, advanced green hydrogen and possibly RNG could fill this gap in order to maintain reliability, if scalability, feasibility, and environmental impact issues can be addressed”. These technologies have been disparaged during discussions because they allegedly empower natural gas use. That concerns me because it appears to limit future technologies. Given the magnitude of the challenge and necessity for dispatchable emissions free resources, I think it is premature for anything to be taken out of consideration in the initial strategies.
Subsequent to the first meeting, two other topics were added to “build into Technology Solutions recommendation”. The first was described: “As the State moves towards a zero emissions grid in 2040, flexible and dispatchable resources will be critical. Further analysis, technical development, and research is needed in order to determine the feasibility, climate impact, and health impacts of advanced fuels and nuclear.” The second description stated that: “Under current NYS policy and regulation, upstate nuclear facilities are within the resource mix (with existing financial support) until at least 2030. The contribution of nuclear power to the 2040 resource mix and any additional policy actions needed should be evaluated prior to the cessation of the Zero Emissions Credit (ZEC) Program in 2029.” My impression is that they both were added in response to comments received in the public input sessions included in these meetings. I was surprised by the number of comments made by people supporting nuclear and opposed to shutting down the final unit at the Indian Point nuclear station. I am sure that the Generation Advisory Panel was just a surprised as I was. Obviously, if the climate crisis is an existential threat to society and to address that there is a need for a as yet unidentified new technology to provide zero-emissions dispatchable power, then shutting down 2,000 MW of generation that meets those criteria is the worst thing you can do. However, the odds of not shutting down Indian Point are vanishingly small in the current political climate of New York. I agree with the implication of the nuclear topic that nuclear is needed to help meet the CLCPA targets.
The first topic has a component that states that “During planning, emissions free resources (e.g., storage, energy efficiency, distributed renewable energy) should be prioritized where feasible when considering end uses, technology limitations, and costs. However, should a substitute for natural gas still be needed, advanced green hydrogen and possibly RNG could fill this gap in order to maintain reliability, if scalability, feasibility, and environmental impact issues can be addressed.” This reinforces my impression that the issue of renewable natural gas and advanced green hydrogen as sources of dispatchable zero-emissions energy is a big concern for this panel. It appears that the ideological and irrational fear of natural gas is spilling over to other similar fuels. Four other components in this topic addressed the analysis and research needed to actually implement these technologies.
The second initiative is “Market Solutions”. New York’s electricity market is de-regulated so implementation is not simply a matter of telling the state utilities to do it. Instead, market rules have to be designed to entice companies to provide the necessary services. With all due respect to market economists, my impression is that anticipating all the consequences, potential opportunities for market manipulation, and market signals needed is more likely to be a trial-and-error process than a success story in the first try. The Texas electricity market is not trying to incentivize 100% zero-emissions electricity and did not successfully pull that off.
The third and fourth initiatives address energy storage. Given that the membership of the panel includes people from the energy storage industry it is not surprising that the initiative is a blueprint for the expansion of that industry. While unquestionably necessary, this is another instance where it appears to me that these are simply calls to build as much as possible, as fast possible and worry about whether everything will out work later, much less address whether this approach is feasible and affordable. In addition, the existing storage technology initiative presumes that current technology can be deployed at the scale needed in the time needed. Given the infancy of the technology I think that is unlikely.
Enabling initiative 7, “Grow Renewables” follows the pattern of initiatives that call for implementation before analysis. One component notes that most renewable energy has been installed upstate but that it needs to be available downstate as well. It seems to me that a feasibility analysis to see if that is possible would be appropriate. The last component states that new and upgraded transmission will be needed but the need for transmission support services is not mentioned.
Given that my main concern is reliability, Initiative 8: Reliability for the Future Grid promised to be the answer to that concern. Unfortunately, the initiative is more for a reliability tracking system during implementation than a comprehensive plan to maintain reliability from the get go. My over-riding concern is the lack of a comprehensive assessment of renewable resource availability for New York. Instead, it is just presumed that there is enough energy available from wind and solar resources coupled with energy storage to make it work. The Resilience Study also makes that point but their availability analysis did not consider the joint distribution of wind and solar resources and was over a relatively short period. Given that the New York reliability standard for a loss of load is a once in ten-year occurrence and that the last time Texas had a similar cold weather event was ten years ago, a minimum of ten years needs to be studied to ensure reliability.
Conclusion
I believe that this is the most important advisory panel because electrification of as many current fossil-fueled sources as possible is necessary to meet the CLCPA targets. Therefore, the zero-emission electric system has to provide reliable and affordable electrical energy for what I believe will be higher loads than today.
To be clear, the 2021 Texas energy debacle was not caused by the lack of wind and solar resources but it does foreshadow the difficulty replacing them when the wind isn’t blowing at night. The lesson to be learned is that Texas energy policy prioritized and subsidized unreliable energy sources (wind and solar) at the expense of reliable ones (natural gas, coal and nuclear) for decades but did not incorporate market mechanisms to ensure that the system could operate under conditions that had occurred in the past. It is incumbent upon the Power Generation advisory panel to ensure that New York’s transition to a zero-emissions electric energy grid does not result in a similar fiasco. Unfortunately, the enabling initiatives do not explicitly address the factors needed to ensure this will not be the case.
I believe that the enabling initiatives should specifically address three concerns derived from these Resilience Study conclusions: “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” and “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 course, the third concern is what are they going to do about the energy storage gap. In order to understand meteorological variability it is necessary to understand how many renewable resources are available during the likely worst case, the multi-day winter wind lull and an initiative addressing this should be included. There are initiatives included to address energy storage resources but they should be re-framed to recognize that this technology is not mature and that there are significant implementation challenges to overcome even to meet the 2030 goal. It cannot be over-emphasized that the only firm, dispatchable and zero-emissions technologies available today are nuclear and hydro and it is unlikely that we can expect significant increased energy from them. The relevant initiative does not adequately address the Analysis Group points that: “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 economical” 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”. A separate initiative should be included that spells out a planning process to meet this challenge and notes that until this technology is available and deployable the 2040 zero-emission target cannot be met without reliability consequences.
I am very concerned that there appear to be members of this panel that either do not understand or do not want to understand the necessary planning needed to ensure reliability and that maintaining reliability is a prime responsibility for any recommendations to the Climate Action Council. There should be an initiative that specifically addresses that prime directive in addition to the initiative that tracks reliability.
Pragmatic Environmentalist of New York 