Fossil Fuel Phase Out Claptrap

Truthout is a nonprofit news organization dedicated to providing independent reporting and commentary on a diverse range of social justice issues.  According to the about description “Truthout works to spark action by revealing systemic injustice and providing a platform for progressive and transformative ideas, through in-depth investigative reporting and critical analysis. With a powerful, independent voice, we will spur transformations in consciousness and inspire both policy change and direct action.”  If the article Fossil Fuel Phase Out Must Begin Where the Industry Has Hurt People the Most is any indicator, however, their platform is based on emotion and not facts.  The alleged problems with peaking power plants and neighborhood power plant impacts on local health are exaggerated and nearly fact free.  The proposed solution is untested and likely to make the lives that they want to improve worse.

I am a retired air pollution meteorologist with over 40 years-experience analyzing the effects of meteorology on electric operations.  While doing consulting work for the Environmental Protection Agency I evaluated air quality model performance and later worked at a utility company where I was responsible for ambient monitoring networks in the vicinity of power plants and evaluating their air quality impacts.  I have been involved with peaking power plants in particular for over 20 years both from a compliance reporting standpoint and also evaluation of impacts and options for those sources.  This background served me well preparing this post.  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

The article is prefaced with a note that “this story is part of Covering Climate Now, a global journalism collaboration strengthening coverage of the climate story”.  The author is Leanna First-Arai. “a freelance journalist who covers environmental and climate (in)justice. Her work has appeared in Undark, Sierra Magazine, Yes! Magazine, Outside Magazine, on New England Public Radio and elsewhere”.

The Fossil Fuel Phase Out Must Begin Where the Industry Has Hurt People the Most article describes the claims made in the recently released Fossil Fuel End Game report that I described here.  The basic premise is that New York City peaking power plants only operate a limited days per year, they are usually old and dirty plants located in disadvantaged communities, and they received around $5 billion to keep running in the last decade.  Therefore, they should be the first fossil plants to be replaced by clean energy.

I have been following this peaking power plant initiative for about a year and summarized my work here.  This article is the latest iteration of advocacy releases based on the Physicians, Scientists, and Engineers (PSE) for Healthy Energy report Opportunities for Replacing Peaker Plants with Energy Storage in New York State.  I discussed the PSE report last year and the PEAK Coalition report entitled: “Dirty Energy, Big Money” in two detailed technical posts.  The first post provided information on the primary air quality problem associated with these facilities, the organizations behind the report, the State’s response to date, the underlying issue of environmental justice and addressed the motivation for the analysis.  The second post addressed the rationale and feasibility of the proposed plan relative to environmental effects, affordability, and reliability. 

Oswego Harbor Power Plant

In order to show that this article is based on emotion and not facts consider the description and allegation related to the Oswego Harbor Power Plant.  In this section I have annotated (indented and italicized) my comments after each sentence from the relevant paragraph in the article.

Residents living within a one-mile radius of the Oswego Harbor Power Plant, one of only a handful of such plants left in Upstate New York, are ranked in the 99th percentile for incidence of heart attacks, based on an analysis of New York State Health Department data by the nonprofit research institute Physicians, Scientists and Engineers for Healthy Energy (PSE).

The insinuation here is that the residents within one-mile of the power plant have a high rate of heart attacks because of the power plant. 

The 73-year-old plant only went online six times in 2018 (the most recent year for which data are available).

There is a description of the plant in a US Army Corps of Engineers harbor infrastructure report that explains that there are two 850 MW units in operation and in service since 1975 – 46 years not 73.  The older units have been retired since before the turn of the century. The units burn residual oil that is stored on-site.  At the time of their construction residual oil was cheaper than coal and for many years residual oil was cheaper than natural gas so the units ran a lot in the late 1980’s.  The fuel price differential no longer supports the use of residual oil.  However, in times of great need the facility can generate 1,700 MW of dispatchable power without regard to weather-caused outages.

 The EPA Clean Air Markets Program Database provides data for the most recent quarter within 45 days so more recent data are available than claimed.  Table 1 lists annual data through 2020.  The important point in the context of this discussion is that emissions from the plant are minimal which is not surprising because of the short operating times.

 Table 1: Oswego Harbor Power Annual Emissions and Operations Data

Unit ID	Year	Operating Time	Gross Load	SO2	NOx	CO2
		(Hours)	(MW-h)	(tons)	(tons)	(tons)
5	2016	92	18,071	44	24	17,309
6	2016	146	23,212	63	24	23,659
5	2017	92	19,132	45	25	17,426
6	2017	141	22,678	56	23	20,811
5	2018	186	26,025	68	32	25,075
6	2018	165	26,600	65	24	23,976
5	2019	95	15,394	37	19	14,225
6	2019	240	23,600	58	25	22,407
5	2020	249	26,736	69	34	26,760
6	2020	125	23,906	62	25	21,024

But if residents suspect hazier-than-usual skies, no federal air quality data exists to help make sense of the short-lived plume of pollution, as the closest Environmental Protection Agency monitors are 40 and 70 miles away, respectively, in Syracuse and Rochester.

The insinuation that the DEC, EPA and owner of the plant know nothing about the plume of pollution is completely baseless.  The author clearly knows nothing about air quality regulations, air quality meteorology, or the Oswego Harbor plant.  The New York Department of Environmental Conservation (DEC) is responsible for maintaining air quality that meets the National Ambient Air Quality Standard limits under the guidance of EPA.  They do that by monitoring near emission sources and modeling facility emissions to estimate air quality impacts. 

 At this time there are no DEC air monitoring stations closer than Rochester and Syracuse.  EPA does not monitor air quality in New York.  However, that does not mean that there never was any air quality monitoring closer to the plant.  I know because I as responsible for submitting the data from the network around the Oswego plant.  After several years of not measuring any exceedances from the power plant DEC and EPA agreed that it was no longer necessary to run the monitoring network and it was retired by 1990.   At one time most, if not all power plants, had monitoring networks but one of two things happened.  If, like at Oswego, no measurements indicating problems were found then the networks were retired.  If problems were found then the emission limits were changed for the facility until the monitoring found that there were no problems.  Also note that these data were used to verify that the air quality models used to predict ambient levels near the plants were correct.  Under contract to EPA, I did that verification work using those data sets and later also compared the Oswego Harbor plant modeled impacts to observations.  That work proved that the models correctly characterize nearby air quality.

 It is not surprising that the modeling never showed anything approaching an exceedance of the National Ambient Air Quality Standards or that the highest observed monitored concentrations were accompanied with the smell of chocolate from the Nestles plant that was located in the opposite direction.  The stacks at Oswego are 700’ high and the plume rise from the hot gases pushes the plume higher.  As a result, the pollution plume is nowhere near the ground within a mile of the plant. 

The insinuated claim that the Oswego Harbor Power Plant is somehow associated with local high incidents of heart attacks is unsubstantiated.  The article states that the plant only ran six times in 2018 and the data show it only ran 352 hours so it was online for less than three days at a time.  Present operations are about 1% of the operating times and rates as in 1988 when the monitoring network that showed the plant did not adversely affect air quality.  If I had to guess why there is a high rate of heart attacks my money would be on the fact that Oswego is in the lake-effect snow belt and when it snows, it snows a lot.  Snow removal is a notorious cause of heart attacks.

Peaking Power Plant Replacements

The author and the advocates quoted in the article are unaware of the fundamental problem with the PSE report Opportunities for Replacing Peaker Plants with Energy Storage in New York State.  PSE defined peaking power plants by their current time of operation not by their design capabilities.  The Oswego Harbor Power Plant is the best example of this problem.  The plant was designed to provide base load power when it was thought that residual oil would continue to be a cost-effective fuel.  The two 850 MW units operated well when that was true but with today’s fuel costs it only offers support to system as backup capacity.  There are three nuclear plants within ten miles of the facility and if there is a problem with those units then the power plant can step in to replace their output.  For example, in the 2004 blackout Nuclear Regulatory Commission operating rules required the nuclear units to go offline and the Oswego Harbor Power Plant was called on to support the system until the nuclear units were allowed to go back online.  The units also come online when loads are very high and all power generation is needed.  There are other power plants in New York that operate much less than they were designed to operate that fulfill similar reliability needs.

The PSE report claims that all of the plants that they claim are peakers can be replaced by renewable energy and storage.  The problem with that is that their definition is based solely on operating times and does not consider the capabilities of the peaking units.  The New York electric system has more stringent rules than Texas.  In the wake of the blackouts last February, Texas is wrestling with how to prevent similar problems in the future by asking should power generators be required to guarantee that they can provide a certain amount of electricity?  New York’s response to this issue includes capacity payments to Oswego Harbor Power for 1700 MW of power six times a year.  This resource is dedicated to that need and can provide that capability because the capital investments necessary have already been paid, even though the fuel is relatively expensive it provides concentrated energy capable of 1700 MW, and the costs to maintain that much power capability are relatively low. 

The first problem with the PSE report claims that the steam turbine units like Oswego that provide peak capacity support can be replaced by renewable energy and storage is that the capital cost to develop enough energy storage to replace all those units has to be paid for a rarely used resource.  A major reason that New York’s capacity payments are as low as they are is because the resources needed to meet New York’s requirements has paid off those costs.  Replacing those facilities with anything will be much more expensive.  The second problem is that the renewable and energy storage approach proposed has never been implemented at the scale needed for New York’s electric resource requirements.  Replacing a system that has worked for decades with unproven technology could very well lead to reliability issues as the system is de-bugged.

Conclusion

All these analyses vilify peaking power plants oblivious to their value to the grid.  The PSE study estimated that they received around $5 billion in the last decade but only ran less than 5% of the time.  The New York electrical system pays for these units to provide capacity and ancillary services so that the electric system can reliably provide power when it is needed most.  The Texas energy system does not have a similar policy in place.  While Texas average prices are lower than New York prices their system is vulnerable to blackouts when peaking power is unavailable.  Simply put, New York peaking power plants are an insurance policy to prevent Texas-style blackouts.  The February 2021 Texas blackouts caused dozens of deaths and tens of billions of dollars in damages.  The New York peaking power plant insurance policy looks like a good deal to me.

Another big driver in the vilification of peaking power plants is the claim that they adversely affect air quality in neighboring disadvantaged communities. However, I don’t think that the PSE approach made a convincing case that the peaking power plants are a primary driver of environmental burdens on neighboring communities.  My primary objection to this claim is that the health effects attributed to peaking power plants are based on air quality impacts from ozone and particulate matter.  However, ozone is a secondary air pollutant and the vast majority of ambient PM2.5 from power plants is also a secondary pollutant.  As a result, there is enough of a lag between the time emissions are released and creation of either ozone or PM2.5, that the impact is away from the adjoining neighborhoods.  That means that the accused peaking power plants do not create the air quality impact problems alleged to occur to the environmental justice communities located near the plants.  In fact, because NOx scavenges ozone the peaker plants reduce local ozone if they have any effect at all.

The claims that peaking power plants are dangers to neighboring environmental justice communities are based on emotion.  The existing simple cycle peaking turbines in New York City are old, inefficient and much dirtier than a new facility and clearly should be replaced.  However, they reliably produce affordable power when needed most. Importantly regulations are now in place that ensure that they are retired or that their pollution control equipment is upgraded on a schedule that guarantees in-kind replacement of capacity and ancillary services.   In order to maintain existing levels of affordability and reliability I think it is best to rely on a proven solution using fossil fuels.  The solar plus energy storage approach advocated by PSE and the PEAK Coalition will likely increase costs significantly if it works.  I cannot over-emphasize the fact that it may not work because wind, solar, and energy storage is not a proven technology on the scale necessary to provide New York City’s peaking power requirements.  Sadly, in the rush to prove politically correct credentials this unproven technology may be chosen despite the risks to power reliability.  It is the height of hubris that the New York legislature has pending bills to over-ride the reliability planning process and existing environmental regulations without including a feasibility study to define the wind, solar and energy storage resources needed, the technological readiness of those resources at the scale needed and the costs of that approach.

Finally, I do not disagree with the premise that disproportionate environmental risks to disadvantaged communities need to be addressed.  However, that goal has limits.  First, and foremost, it simply is not good policy to expect the removal of all environmental impacts.  For example, a replacement state-of-the-art natural gas fired combustion turbine that reduces existing impacts substantially should be an acceptable choice because it provides a proven affordable solution and reduces well-known impacts.  The proposed alternative of renewable energy and energy storage is unproven technology at the scale needed, is costly when the cost to provide uninterruptable power is considered, and could very well lead to worse overall environmental impacts especially when the effects of the rare earth metals needed for those resources is included.  The result is there is a high likelihood of problems with affordability, reliability, and environmental impacts due to the implementation of the proposed solution.  If those problems occur then the disadvantaged communities that these advocates want to protect will be disproportionately impacted.  I don’t think that the advocates understand that those impacts could be worse than the problems that they want addressed.