Climate Leadership & Community Protection Act Reliability Planning Speaker Session

Note: When this was written and posted the recording was not available. The Session recording was posted on August 30, 2021

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. Over the last year Advisory Panels to the Climate Action Council have developed and submitted recommendations for consideration in the Scoping Plan to achieve greenhouse gas (GHG) emissions reductions economy-wide.   On August 2, 2021, the New York State Energy Research and Development Authority (NYSERDA) held a Reliability Planning Speaker Session to describe New York’s reliability issues to the advisory panels and Climate Action Council.  If reliability is a key condition for CLCPA implementation then the briefing summarized here should have been held a year earlier.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   I briefly summarized the schedule and implementation: CLCPA Summary Implementation Requirements.  My posts describing and commenting on the strategies are available here. I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulations,  summarized some of the meetings and complained that its advocates constantly confuse weather and climate in other articles.  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

There is a long history of blackouts in New York State in general and New York City in particular that is a primary driver of reliability concerns in the state.  After a blackout in July 2019 AMNY published a brief history of blackouts in New York City.  In 1959 and 1961 surges in electrical use caused blackouts and “The outage spurred changes to better protect the city’s power grid from future blackouts”.  The 1965 blackout was the first regional blackout and was caused by a transmission problem in Ontario causing a wave of disruptions in the transmission system.  Over 30 million people and 80,000 square miles in Ontario, New York, Connecticut, Massachusetts, New Hampshire, New Jersey, Pennsylvania, Rhode Island, and Vermont were left without power for up to 13 hours.   There was another blackout in 1977 that was limited to New York City directly related to the fact that most of the City is on islands and is a load pocket.  It was caused by storms cutting off transmission into the City and in-City generation was unable to replace the load without disruptions.  Without sufficient local power, protective devices turn off overloaded lines and transformers to prevent physical damage to the equipment and this led to the outages.  As a result of this blackout, reliability constraints were strengthened to ensure that when storms threaten transmission into the City that sufficient in-City generation is available to prevent a re-occurrence.  In 2003 there was another regional blackout caused by a computer software problem.  Grid operators identified the cause and then developed procedures to prevent it from happening again.  In 2012 tropical storm Sandy caused massive blackouts exacerbated by flood protection weaknesses.  Since then, there have been investments to strengthen the infrastructure to prevent a reoccurrence.  Reliability planning is a constant concern for the electrical system professionals who operate the system and are responsible for keeping the lights on.

The members of the Climate Action Council and the advisory panels who are charged with providing recommendations to meet the CLCPA targets were chosen because of their political connections not their energy system expertise.  During the development of the advisory panel recommendations, it was obvious that reliability was only receiving token consideration and that many of the panel and council members did not understand the issues and requirements for a reliable energy system.  As a result, I was one of many commenters who suggested that a briefing on the topic of electric system reliability would be appropriate.  Obviously, this presentation should have been held early in the process but later is better than never. 

Note:  At one point I found the August 2, 2021 speaker session presentation on a NY website but it not available at this time nor is the recording of the presentation available.  My downloaded copy of the presentation is available here.  I recommend reading the session presentation as it gives a good overview of reliability issues facing New York in the transition to net-zero.

The session included presentations from six organizations with varying levels of reliability background, experience, and responsibilities:

• New York State Reliability Council – Mayer Sasson, Steve Whitley, & Roger Clayton
• New York Independent System Operator (NYISO) – Zach Smith
• Utility Consultation Group – Margaret Janzen (National Grid) and Ryan Hawthorne (Central Hudson)
• New York State Department of Public Service – Tammy Mitchell
• Vote Solar – Stephan Roundtree
• New York Department of State Utility Intervention Unit – Erin Hogan

I will address each organization and their comments below.

Reliability Council

The New York State Reliability Council (NYSRC) is a Federal Energy Regulatory Council (FERC) approved entity responsible for “the promulgation of reliability standards for New York, which are mandatory requirements for the New York Independent System Operator”.   The presentation explains that one of the primary concerns of the NYSRC is the Installed Reserve Margin (IRM) which is the “minimum installed capacity margin above the estimated peak load to meet the Northeast Power Coordinating Council (NPCC) requirement that the probability of shedding load is not greater than one day in ten years”.   In order to determine that value the NYSRC conducts a “complex probabilistic analysis of generation and transmission resources, and demand response”.  Their presentation went on to describe in the following slide all the responsibilities of the operators who keep the system operating reliably.

The presentation explained that as the percentage of renewable resources increases operating the system must change and the planning for those changes must evolve.  It summed up this section as follows: “Limited fuel diversity and over dependence on energy limited resources is a risk to reliability”.

In the last section of the NYSRC presentation results from some planning work already done were presented.  Using an example of solar resource impact on resource adequacy it was shown that the “addition of 26,000 MW of new solar generation raises the reserve requirement to ≈22,000 MW & allows the retirement of only 4,000 MW of current resources” (my emphasis added).  The presentation went on to show that the addition of all the projected renewable energy resources needed to eliminate the use of fossil fuels in 2040 results in a reserve requirement of ≈50,000 MW in order to meet the CLCPA 2040 goals and the NYSRC Resource Adequacy IRM Reliability Criterion.  The current reserve requirement is around 6,000 MW.  It is important for readers to realize that this means that 50 GW of renewable capacity have to be developed in addition to the 12 GW of onshore wind, 10 GW of offshore wind, 17 GW of utility-scale solar, 6 GW of behind the meter solar, and 15 GW of energy storage projected in the NYS DPS/NYSERDA “Initial Report on the New York Power Grid Study” annual installed capacity supply mix for 2040 because that study did not address the IRM requirement.

The takeaway message of the NYSRC to the Climate Action Council was:

With the intermittency of renewables and the electrification of the economy, substantial clean energy and dispatchable resources, some with yet to be developed technology, over and above the capacity of all existing fossil resources that will be replaced, will be required to maintain reliability in the transition to meeting CLCPA requirements.

New York Independent System Operator

The NYISO Frequently Asked Questions webpage explains how the organization originated. After the Northeast Blackout of 1965, New York’s seven investor-owned utility companies established a predecessor organization, the New York Power Pool (NYPP), to address the reliability problems exposed by the blackout.  In the 1990s New York’s electric system was de-regulated and the Federal Energy Regulatory Commission (FERC) recommended the formation of independent entities to manage energy transmission and the NYISO was established to replace the NYPP.  Because the change to the wholesale electricity market is the reason for their existence, the NYISO unquestioningly supports market driven responses to any problem.

The NYISO manages the electric system.  They have to balance the instantaneous supply of electricity between the generators and customers across the state in the de-regulated electricity market.   They manage the supply of power and maintain the frequency across the state and with their connections to other operating systems.  In addition, the NYISO has to plan for future changes to the system.  At this time the biggest factor for change is the CLCPA. 

Unfortunately, in my opinion, the NYISO is not as independent as it should be.  In a recent post I explained how the Cuomo Administration has co-opted the NYISO to the point that their recommendations are couched in terms that do not adequately convey the enormity of the technical issues associated with this transition.  Moreover, their faith in market solutions de-values the risks of developing those solutions in the face of the fact this has never been done before.

In this light it is not surprising that the NYISO presentation emphasized their recent Power Trends 2021: New York’s Clean Energy Grid of the Future report that describes current and emerging trends transforming the grid and electricity markets.  The report describes how hourly demand patterns fluctuate diurnally and seasonally today.  It goes on to explain that the CLCPA de-carbonization efforts will change the magnitude and demand plans in the future, most notably the peak load will occur in the winter instead of the summer.  One NYISO analysis projected future winter energy production by resource type.

The important reliability finding of the NYISO work is that the worst-case future resource concern will be a winter-time wind lull.  During those periods solar resources are low because days are short and the sun is at a low angle, and wind resources can be less than 25% of the wind capacity for seven days at a time.  Consequently, there is a need for a large quantity of installed dispatchable energy resources needed for a small number of hours.  They must be able to come on line quickly and be flexible enough to meet rapid and steep ramping needs. The report does not come out and emphasize the important point that there is no current utility-scale resource that meets those criteria.

Utility Consultation Group

This is “A consortium of New York’s gas and electric utilities, focused on providing expertise and perspective to the Climate Action Council and its advisory panels”.  Given that most of these utilities are dependent upon rate case decisions made by representative hand picked by the Cuomo Administration there is an obvious reluctance to take a strong contrary position.  Given that Cuomo has threatened to revoke a utility operating license over a disagreement in gas supply, I have no doubt that there is real concern that a difference of a fraction of percentage point in any rate case  increases could easily make a difference in the stock price colors any statements by this organization.

The consortium fully supports the CLCPA goals even while noting that “customers will continue to value reliability, resiliency, and safety of the energy system during and after decarbonization”.  There is the hint that technology development is necessary which may make this a bit difficult and a plea that cost effective solution are necessary.  Finally, there is the obligatory shout out that environmental and economic justice need to be considered.

The presentation claims that the “Transition to a clean energy future is feasible, but must be orderly, responsible and cost effective”.  Heaven forbid that they suggest the transition is anything but feasible but where in the world is there proof that it is possible much less responsible and cost effective?  Given their situation they cannot say this is unlikely to work but it is disappointing that they did not respond with more concern about the potential difficulties.

New York State Department of Public Service (DPS)

DPS has oversight of utility reliability planning.  This covers traditional transmission & distribution investment planning and the utilities’ obligation to “reliably serve forecasted customer loads”.  There is a nuance to this that is not universally understood.  This process is used to ensure adequate transmission and distribution capability to serve customers but the production of the electricity itself is not included.  Instead, the wholesale market overseen by the NYISO provides the power.  Note that the power producers have no similar obligation to generate electricity.  The market is supposed to provide that incentive.  I believe there is a common misconception that somehow if things don’t work out that the generators are covered by some sort of obligation to serve but that is not true in the same sense as the T&D utilities.

The presentation explained that DPS constantly evaluates on a real time and forward-looking basis electric system reliability based on a multitude of factors and impacts including customer demands, planned and unplanned outages, weather, regulatory requirements, interconnection requests, and state policy.  It was noted that staff works with utilities on these matters but that the PSC has regulatory authority and responsibility to ensure reliability is maintained.  The presentation does not explicit make the distinction between T&D reliability planning and planning for generation.  Instead, it was explained that DPS staff participates actively in the NYISO planning process, NYSRC committees, and the NPCC board who do have the generation responsibilities.

In response to the CLCPA and Accelerated Renewable Growth Act, the Public Service Commission (PSC) issued orders directing the Utilities to undertake a study and to propose a planning and investment framework for local transmission and distribution investments driven by CLCPA.  The Utilities filed the study and their proposals for CLCPA investment criteria on November 2, 2020.  At the same time, the PSC and NYSERDA undertook two other studies.  One identified “possible grid interconnection points and offshore transmission configurations and assessed onshore bulk transmission needs to reliably integrate 9,000 MW of offshore wind generation”.  The second study identified “bulk transmission upgrades potentially necessary to support the State’s path to a 100% decarbonization of the electricity sector by 2040”.  The Power Grid Study filed on January 19, 2021 combines all three studies.

The presentation implicitly suggests that this work addresses all the problems.  It is important to note that their summary of reliability considerations makes many of the same points addressed in the NYSRC and NYISO as shown in the following slide.

Vote Solar

The purpose of this reliability presentation was to present the concerns of the organizations and professionals who are responsible for maintaining electric reliability.  In a blatant example of the political machinations that underly the CLCPA and implementation of the law, Stephan Roundtree, Jr., Northeast Director of Vote Solar  presented his take on reliability.  Mr. Roundtree holds a B.A. in History from Boston College, a J.D. from Northeastern School of Law, and a Master’s in Environmental Policy from Vermont Law School.  My point is that in addition to the fact that he is a crony capitalist representing an organization dependent upon the largesse of subsidies from laws like this, he has no apparent relevant utility-scale power system experience. 

Unfortunately, not only does he have no experience he is a member of the Power Generation Advisory Panel.  As such his presentation mirrors the reliability mis-understandings of many of the members of that panel.  Those mis-understandings are precisely the reason that many asked for this presentation.  In my opinion the reliability presentation is a year late in its attempt to provide the background information necessary for the panel to adequately do their job.  A reliability presentation should have been given to the Council and the Power Generation panel at the start of the process.  Admittedly it is not clear that the political appointees would have tried to understand the reliability difficulties described by those responsible organizations and people responsible for keeping the lights on.  As far as I can tell their politically valuable vested interests preclude listening to inconvenient facts much less trying to reconcile them with their pre-conceived notions.

Roundtree’s first slide lays down the gauntlet: “Not a question of whether we can or should shift the grid to be 100% renewable and maintain reliability; it’s the law”.  As someone with no reliability responsibilities that is easy for him to say.  Sadly, because the virtue-signaling politicians that wrote the law did not include a feasibility requirement before implementation of the “best in the nation” emission reduction targets it is the law.  However, if the scoping plan honestly describes the technical difficulties and costs, I cannot see how they can describe implementation of the law as feasible or affordable.  The big question is then what?

Roundtree describes three key takeaways: 

1. Reliability is paramount, particularly for vulnerable communities in climate crisis;
2. Integrating renewables into the grid while maintaining reliability is possible, and in fact cost effective;
3. Aggressive adoption of a renewables-based grid is arguably the only lawful path to decarb and equity mandates

He accepts that reliability is “paramount” as the first takeaway.   He notes that “Lack of electricity service during extreme weather events impacts disadvantaged community members first and worst” and that “Interruption of electricity, combined with lack of wealth & resources, can lead to deepening poverty, housing insecurity, illness, and death”.  I agree with what he says.  However, I am sure he does not understand that the greatest threat to electric system reliability is ill-considered implementation of renewable resources in the manner he proposes.

In his introduction the second takeaway states that “Integrating renewables into the grid while maintaining reliability is possible, and in fact cost effective”.  In the presentation the second takeaway morphed into “Repowering or perpetuating fossil generation is not necessary for reliability”.  That was a majority position of the Power Generation panel but there was a minority opinion arguing that it is too soon to say whether that is possible.  As proof of the feasibility of a renewable power grid he argues that “Centralized fossil-based grids are proving to be unreliable in our changing climate and cannot withstand increasingly frequent extreme weather events” and cites the Texas energy debacle last February.  I don’t believe the 2021 Texas energy debacle was caused by renewable 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 market conditions that had occurred in the past. 

He goes on to say that “modernizing the grid by adding demand flexibility, efficiency, and distributed energy resources including rooftop solar and storage but also EVs and microgrids is the solution we need to meet reliability needs of tomorrow” and that “renewables pair cost effectively with local grid modernizing infrastructure like storage and microgrid tech don’t have to pay the huge external cost of fossil”.  These claims are articles of faith amongst environmental advocates perpetuated by the grifters selling renewable solutions. 

The proof offered is a Rocky Mountain Institute analysis.  I reviewed their work and found that they selectively choose how they want to treat resources.  There are hopeful assumptions for distributed resources and battery energy storage that have no track record in utility-scale applications (hundreds of MW of capacity).  There is no consideration of life-cycle resources needed for all the batteries, solar panels and wind turbines. Finally, while the treatment of the technological components necessary to provide the resources are overly optimistic in my opinion, their treatment of costs is much worse.  Both current costs and expected cost expectations in the future are more aspirational than rational.  Roundtree also cites an advocate analysis that is contradicted by the NYISO analyses. Frankly I believe that Roundtree’s experience and background are ill-suited for him to realize that his cited proof is anything but evidence that his approach can work to keep the lights in New York City on during the worst conditions.

In the introduction his final takeaway was another veiled threat that “aggressive adoption of a renewables-based grid is arguably the only lawful path”.  This also morphed into “Local generation & storage promotes equity” in the presentation.  Again, his claims are articles of faith.  “Fossil pollution causes vast public health challenges which largely aren’t included in reliability vs transition discussion” is always highlighted as a religious tract but the fact that air pollution reductions from fossil pollution have led to large improvements in air quality while the purported health impacts haven’t also improve sis never addressed.  The true believers also claim that “Building renewables, batteries, and microgrids in high load disadvantaged communities results in improved public health and better preparedness / functionality during grid stresses and shocks”.  The first claim that green energy leads to better public health ignores the environmental and health impacts of the mining of rare earth minerals used in batteries and wind turbines.  The proposed solution will not eliminate environmental and health impacts it will just move them and, arguably, make them worse elsewhere.   The claim that renewables and batteries will improve functionality during grid stresses is unproven on the utility-scale.  The final rationale for this takeaway states that: “Prioritizing state investment in disadvantaged community local grid infrastructure is a pathway to meet CLCPA investment equity mandate” is probably true but should not be a prime reliability concern.

New York Department of State Utility Intervention Unit

The Division of Consumer Protection’s Utility Intervention Unit (UIU) is supposed to act on behalf of the ratepayer.  They represent “the interests of New York consumers before federal, state and local administrative and regulatory agencies engaged in the regulation of energy, water and telecommunication services”.  According to their about webpage:

The UIU participates in the deliberations of the Public Service Commission (PSC), the New York Independent System Operator (NYISO) and the Federal Energy Regulatory Commission (FERC), as well as utility and energy-related interagency working groups, task forces and committees. The UIU analyzes filings, submits testimony and briefs, engages in settlement discussions and participates in evidentiary hearings in PSC and FERC regulatory proceedings and participates in NYISO governance.

Their presentation starts off with an interesting quote by Peter Fox Penner, Institute for Sustainable Energy: “In a nutshell our challenge is to steer clear of the technical and institutional pathway that together yield poor service, expensive power, or a failure to decarbonize quickly.”  I agree that is the key challenge but question whether all of these goals are possible.  Of course, that it is possible to have affordable, reliable and emissions-free electricity is the fundamental basis of the CLCPA so no state agency can question the orthodoxy of it.  Nonetheless including this quote suggests that the agency representing consumer interests is aware of the problem.

The presentation goes on to show three graphic representations: the electric system of the past, the present, and what is supposed to happen in the future.  Then there is a slide that makes the important point that the one constant in all three cases is that load and generation must balance. Then considerations of changes in load over time are discussed.  In 2021 the question is “how are the decisions now going to impact prices in the future and adoption of electrification?”.  In 2025 the status must be evaluated to see if programs have reached their targets and where they stand.  In 2030 we have to ask if we reached the renewable goal.   In 2035 the question is “Are there any new technologies or improvements to existing technologies?”   In 2040, the question is whether the electric system has weaned itself off fossil fuels.  There are strengths, weaknesses, opportunities and threats every step of the way.  In their conclusion the importance of planning was stressed.  I suspect that the UIU is as uncomfortable as I am that the CLCPA does not include a feasibility mandate.

Conclusion

The warning in most of the presentations was similar: it will not be enough to depend on today’s technology to develop a reliable electric system with net-zero emissions.  The NYSRC notes that “substantial clean energy and dispatchable resources, some with yet to be developed technology, over and above the capacity of all existing fossil resources that will be replaced” needs to be developed.  The NYISO explicitly points out that a “large quantity of installed dispatchable energy resources is needed in a small number of hours” that “must be able to come on line quickly, and be flexible enough to meet rapid, steep ramping needs” but only implicitly points out that these are magical resources that do not exist yet for utility-scale needs.  The utility consultation group explains that “technology development and diversity of clean resources are essential for long term success” but provide no details of the enormity of that task.  Even the DPS makes the point that “evaluating and implementing advanced technologies to enhance the capability of the existing and future transmission and distribution system” is necessary for future reliability.  The Utility Intervention Unit does not provide a comparable warning but does stress the importance of planning and the need to address new technologies.   None of these organizations was in a position to state the obvious that relying on as yet unproven technology to transition the electric system on the schedule of the CLCPA is a serious threat to reliability.

As further proof that the CLCPA is at its root simply political showmanship and virtue signaling, the technical session on reliability allowed an organization with a vested interest in today’s inadequate renewable technology to be included.  Giving Vote Solar a chance to present the message that “integrating renewables into the grid while maintaining reliability is possible, and in fact cost effective” proves that the whole thing is politically motivated because the presenter had neither the background or experience to understand the dangers and the requirements to maintain reliability.  Moreover, the speaker has no relevant responsibility but the organizations and professionals who are responsible for keeping the lights on all made the point that as the need for sufficient levels of new clean energy resources increases during the grid transformation “some of these resources rely on technologies that do not currently exist for utility scale application.” 

Finally, note that problems with a similar transition are already being noted elsewhere.  In August 2020, California grid operators had to impose rolling electric blackouts to maintain grid reliability standards.  The basic problem was that power demand peaks as people turn on their air conditioning in the late afternoon just as the solar power supplies cut off as the sun goes down.  So little power was available the California grid operator had to reduce load to prevent an uncontrolled, much wider scale blackout in the event of a problem at an operating power plant.  The scale of that problem pales compared to the scale of the situation when the CLCPA requirements to electrify heating and transportation increase winter load and the elimination of fossil generation increases the dependency upon wind and solar electricity generation.  In the winter at New York’s latitude the days are short and the solar panels could be covered by snow.  When there is a prolonged cold snap accompanied by light winds both renewable resources will be unavailable and the only question is for how long.  With respect to reliability, planning for this worst-case availability scenario has to develop a system that can prevent a future New York blackout that could result in people freezing to death in the dark unable to flee. 

The ultimate question is whether the Climate Action Council will address the issues raised by the professionals or cater to the naïve dreams of the politically chosen members of the Power Generation Advisory Panel. Absent changes to the law itself I fear New York consumers will be lab rats for a politically motivated virtue signaling empty gesture that is going to cost enormous sums of money, and, in the event of a major blackout, cause much more harm than good.

Post Script: This text was drafted before Governor Cuomo resigned over sexual harassment allegations.  In my opinion his actions towards his accusers were the worst kind of bullying.  They are also symptomatic of his Administration’s micro-managing treatment of any dissent from any individual or organization in the state.  I am sure that there are many technical professionals in the staff of many state agencies involved in the CLCPA implementation that know that you cannot have an affordable, reliable, and emissions-free electric system but have no way to speak out with those reservations lest they jeopardize their careers.  They same can be said of organizations trying to provide value for their shareholders.  Hopefully, the new administration will at least consider the reliability risks brought up by the NYSRC, NYISO, Utility Consultation Group, DPS and Utility Intervention Unit.