Failure of the Climate Change Scoping Plan to Meet the Requirements of the Climate Act

This post describes the comments submitted on the Draft Scoping Plan by Herschel Specter. If I knew how to do guest posts on this site, I would have made this a guest post.  My apologies but I am going to have to wing it.

Herschel Specter is the President of Micro-Utilities, Inc. and holds a BS in Applied Mathematics from the Polytechnic Institute of Brooklyn and a MS from MIT in Nuclear Engineering. He is a Licensed Professional Engineer in the New York.  He is a passionate supporter of nuclear power.  While I don’t agree with everything in his comments there are many great points.  I asked Herschel if I could make his comment letter into a post and he agreed.  The following text is from his cover letter.  I have posted his comments here.

Overall Conclusions

(A) The largest challenge facing the CAC and NY State is to regain the confidence of the people of New York that its energy plan is fact-based, technically agnostic and sound, and is forward looking, free of any past political or ideological influences. The Scoping Plan does not convey such confidence-building characteristics, and 

(B) The scoping plan fails to implement the Community Protection (CP) portion of the Climate Leadership and Community Protection Act (CLCPA), detailed below. Even if this NYSERDA scoping plan could work, what good is it if most people cannot afford the electricity this scheme would produce, and,

(C) The claim in Section 3.1 of the scoping plan that NY State is a leader in dealing with climate change is unsupported by the facts. For years NY State has favored imported fracked gas over building renewable energy infrastructure, while also opposing further expansion of clean nuclear power. (See Appendix C, page 43, of the attached critique). It is not convincing that NY is a leader in climate change when a major state agency, NYISO, recently reported that the State, and especially New York City, face dangerous shortages this decade in electricity generation and in electricity transmission. (See Reference 2 of the attached critique).

Specific Comments

1.High Costs. Electricity is a critical commodity, but its cost is regressive. High electricity prices disproportionately burden LIM (low income-to-middle income) families. The scoping plan places near exclusive reliance on renewable energy (solar and wind). Yet other studies have shown a mix of variable energy sources (solar and wind) joined with firm energy sources (nuclear and/or fossil fuels with no net carbon) are far less expensive. In one study a mix of energy sources reduced the electricity costs of a proposed all renewable electricity future from 15 cents/kilowatt hour to 9 cents per kilowatt hour. (See Table A4, page 20, of the attached critique). NYSERDA should have investigated which combinations of variable and firm energy sources are the least burdensome for low and middle income families. High electricity costs can cause businesses to relocate outside of New York, causing job losses.

2.Jobs-1. How many jobs will actually be created in New York when developing offshore wind capacity compared to jobs outside of New York? The Empire Wind Project is instructive. Two huge oil companies, British Petroleum (UK) and Equinor (Norway), have secured a contract from NY State to build the Empire Wind Project.  Not being in the wind turbine business, these oil companies turned to Vestas, a Danish wind turbine company, to build a huge (600 to 700 feet tall) wind turbine off of NYC. This assumes that the conditions of the Jones Act can be met. British Petroleum and Equinor recently filed a request with the Federal Energy Regulatory Commission for a one and a half year delay. Delays do not produce jobs. Importing wind turbines produces  jobs, overseas.

3. Jobs-2. It takes a special type of ship, called a jack ship, to lift the very heavy offshore wind turbine hub (the nacelle) and football field length turbine blades into place while at sea. New York does not make or own such jack ships. There is only one jack ship under construction, for a different state in the USA, large enough to install the huge 15 MW Vestas design. This specialized ship has a cost of $500 million dollars and requires three years to construct. However China makes such huge specialized ships with the latest one deployed off of the east coast of England. It takes an enormous crane to lift the nacelle and turbine blades. New York does not manufacture such huge cranes, but many overseas companies do. What is the NYSERDA plan to install these very large offshore wind turbines? How many MWs/year can be installed considering the limited number of jack ships? Per NY taxpayer dollar, how many pennies go to New York workers to build and install this mammoth offshore project and how much money goes out of state?

4.Jobs-3/ land use. According to the Daily News [“State reaffirms Alle-Catt wind farm”, Matt Surtel, September 30,2020] the 30,000 acre Alle-Cat wind farm will employ 182 jobs during construction, but this will decrease to just 13 permanent jobs to operate the facility. At that rate, a million acres of onshore wind farms would only create 400 permanent jobs, less than half the number of jobs lost when Indian Point was closed. This 340 megawatt wind farm will need 125 times the area of the Indian Point site to produce less than 5% of the electricity that was generated  at Indian Point.

5.Public anger-1 Upstate communities have taken NY State to court because they were stripped of  Home Rule protection while solar and  wind farms are being imposed on them. This hardly seems like implementing the Community  Protection portion of the CLCPA. Fishermen off of Long Island are similarly aggravated with the State’s offshore wind  program and complain of being ignored by the State. Where is consent-based siting? About 1,000 high paying jobs were lost, as well as substantial tax revenue, as a result of NY State’s actions to press for the closure of Indian Point nuclear plants and replace these two nuclear units with gas. Citizens of New York have not forgotten that they were told by former Governor Andrew Cuomo that Indian Point would be replaced by non-carbon sources. That never happened. Such actions are not confidence building. After years of reducing the carbon intensity per KWh of NY’s electricity, it is on the rise again because clean electricity from Indian Point was replaced by gas. The price  for electricity and home heating and making hot water with gas has skyrocketed. This is partly due to world conditions, but as  newspapers in the Hudson Valley point out, it is also due to the closure of Indian Point which did not burn fossil fuels, but rather produced 80% of the carbon-free electricity in downstate New York..

6. Public anger-2  The Danskammer plant in  Newburgh, NY, originally was an old coal burning plant that  was shutdown. It was refurbished to run on gas, but a special regional surtax on people was set up to pay for this refurbishment. If the people are paying  for new gas infrastructure, why don’t they own this gas infrastructure? Moreover, people were told that this refurbished plant would only be used infrequently; during times of peak demand. Later there was an effort to allow Danskammer to run full time, which angered local people, many of whom live in nearby environmental justice areas. Thanks to Governor Hochul and the DEC, this expansion of Danskammer use was not permitted, nor was a large new gas plant in Astoria, Queens approved. But as NYISO makes clear, this compounds the dangerous electricity reliability issue. No State agency has come forward with a plausible plan to provide clean electricity while reducing greenhouse gases in a time frame that would avert the potential blackouts this decade that NYISO has warned about. How does NY State simultaneously deal with climate change and continue to meet reliability requirements using realistic renewable energy manufacturing and installation capacities? This emerging crisis NYISO identified would not be pending if the Indian Point units were still operating.

7. Still more public anger-3. It appears that the CPV gas plant has been allowed to operate without all required permits and this plant has EJ areas nearby. If this lack of all necessary permits is still true, the DEC should require full compliance or shut CPV down.

8. Security issues. Increased use of natural gas for electricity production, home heating, and in making hot water has prompted gas delivery utilities to seek additional pipeline infrastructure. The former Governor was opposed to this, which led to open conflict between the former Governor and these gas utilities. This has been temporarily resolved by allowing some gas to be delivered by trucks, even though pipelines are safer and less expensive. This compromise has created a new class of terrorist targets; “truck bombs” that drive on our neighborhood streets.

9. Land use. In order to implement the NYSERDA scoping plan an estimated 24.4 million solar panels, each 25 square meters in size, would be needed. (See page 43 of the critique). A “rule of thumb” published in recent solar literature is that each megawatt of solar energy capacity requires about ten acres of land. At that rate it would take about 950 square miles. of New York farm and forest lands to accommodate this massive solar buildout. What will be the reaction of upstate New Yorkers to such a huge expansion? Yet solar energy is the least attractive choice for dealing with climate change. It is inherently less resilient to climate change than firm energy sources (See section 6.3 of the attached critique) It has the lowest capacity factor of any clean energy source, around 14%, as reported by NYISO, while nuclear is over 90%. Without expensive storage It is not dispatchable and is incapable of reducing the peak demand in winter which occurs after sunset. As NY State moves towards being a winter peaking state, this winter limitation of solar energy becomes an even larger negative attribute. Further, such extensive reliance on solar energy furthers  upstate/ downstate friction. Upstate people are to make sacrifices in values they hold dear, such as not being a victim of renewable energy industrialization in their back yard, just  to provide electricity  to downstate areas and NY City. NYSERDA should clearly and completely discuss the future use of present upstate nuclear plants which many upstate people support, particularly since their land use per KW hour is far less than renewable energy sources and jobs at these units pay well..

Land use is a highly charged subject. Not only is it an issue in upstate NY, it shows up  everywhere. For example, people in White Plains recently rejected the installation of solar panels in a cemetery because doing so  would have required the cutting down of a large stand of trees.  The two nuclear units at Indian Point supplied enough clean electricity to power 25% of the electricity in New York City and Westchester County, yet their land use was less than one half of one square mile. 

10.Data  errors. The NYSERDA plan has serious data errors in the capacity factors it used (See Section 8 of the attachment) . These data errors, collectively, would produce a capacity shortfall are almost the size of the whole NY State present electricity capacity.

11. Modeling errors. In 2021 an estimated 702 people died and almost $200 billion dollars worth of damage occurred in Texas when there was a gap in the supply of electricity during a polar vortex. Two things are happening simultaneously which call for a careful analysis of what is needed to design a NY  future electric grid. We  will experience extreme temperatures, hot and cold, more frequently and for longer durations. Also, we are moving towards a more electrified future we are far more dependent on electricity.. When there is an electricity gap during a time of extreme heat or cold,  people may die.  It appears that the  NYSERDA draft plan is not based on preventing an energy gap during extreme conditions like a polar vortex or very high statewide temperatures, but is just designed to meet the  typical energy needs during a week of cold weather in January, 2050. (See Section 9.2 of the attachment). To prevent loss of lives the grid should be designed to cope with extreme temperatures, with an additional margin  for unanticipated losses of generation and transmission. Further, NYSERDA did not account for very large and long duration wind lulls like that which occurred last year over all of northern England (See Reference 6  in the attached critique). There are other modeling errors identified in the attachment, as well as very questionable assumptions about the rate renewable energy devices, like offshore wind turbines, can be built and installed.

12. Energy storage. Unlike nuclear plantswhere energy storage is built right into the uranium pellets in the fuel rods, renewable energy needs energy storage because of its variability and for times when the sun is not shining and/or the wind is not blowing.  Unlike other New York energy future  studies which relied on Renewable Natural Gas, an undeveloped technology, NYSERDA turned to hydrogen for energy storage. It is hard to imagine a more difficult material to work with. Because of its very small molecular size, hydrogen has a much higher propensity than natural gas to leak out of piping and storage systems. Hydrogen leakage is important from a safety point of view; hydrogen has an ignition range six times wider than what natural gas has. (See TABLE A-8 of the attached critique.)

The volumetric energy density of hydrogen is very low. In order to achieve economically attractive volumetric energy densities, hydrogen would either have to be compressed to pressures in the 10,000 to 15,000 PSI (pounds per square inch) range or cooled to minus 253 degrees C, which is approaching absolute zero. Because of the required very high pressures, hydrogen cannot be distributed through the present natural gas piping or used in present gas storage infrastructure. It takes a significant amount of energy to cool hydrogen down to an extremely low temperature and to maintain this very low temperature. Hydrogen also embrittles steel. How did the NYSERDA plan account for this?

These challenging attributes of hydrogen make it difficult to store or distribute at reasonable costs. In practice, when hydrogen is used in industry, its source and the end user, like a refinery, are co-located on the same site. This co-location minimizes hydrogen storage and distribution issues. The distributed nature of NYSERDA’s energy sources and NYSERDA’s end users greatly limits co-location opportunities. The scoping plan describes a process of using solar energy to make hydrogen from water by  electrolysis. This (compressed?) hydrogen would be stored for months then, assumedly, burned  in some kind of a hydrogen fueled gas turbine (now under development) or fuel cells to convert the stored hydrogen back into electricity. NYSREDA assigns a 50% round trip energy loss for this process. It is not clear if this includes hydrogen losses through leakage while in storage, or the energy it takes to compress or cool the hydrogen, or the energy losses in the gas turbine. If the source of electricity is solar energy and NYISO’s 14% solar capacity factor is used, the overall efficiency of the solar/hydrogen storage/ burning in gas turbines to get back to electricity would be, at best, about (0.14)((0.50) = 0.07. Would a 7% efficient energy storage system result in a low-cost electricity as needed by LIM families? If it becomes obvious that hydrogen storage is unworkable, what is NYSERDA’s backup storage plan?

About the Author

Herschel Specter, President of Micro-Utilities, Inc., holds a BS in Applied Mathematics from the Polytechnic Institute of Brooklyn and a MS from MIT in Nuclear Engineering. He is a Licensed Professional Engineer in the State of New York. At the Atomic Energy Commission in the 1970s he was responsible for the licensing of the Indian Point 3 nuclear power plant. In the 1980s the New York Power Authority hired Mr. Specter to defend its Indian Point 3 nuclear plant in a federal adjudicatory trial. He and his team of experts prevailed in court. Mr. Specter served at diplomat rank for 5 years at the International Atomic Energy Agency in Vienna, Austria where he led an international effort writing design safety standards for nuclear power plants.

Mr. Specter has been Chairman of two national committees on nuclear power plant emergency planning and was a guest lecturer for several years on emergency planning at Harvard’s School of Public Health. He analyzed emergency responses for a hypothetical terrorist attack on the Indian Point power plants which were located in the nation’s highest population density area. Mr. Specter has presented testimony at the National Academy of Sciences on the Fukushima accident and on other nuclear safety matters and has been a guest speaker at many universities on matters of energy policy.Today he is one of 14 Topic Directors in Our Energy Policy Foundation, a group of about 1500 energy professionals who seek to bring unbiased and comprehensive energy information to our political leaders and members of the public.

Mr. Specter has been active in social and environmental matters. He has been a Big Brother and in 1971 had the honor of being selected as “Big Brother of the Year” for all of the USA and Canada. While voluntarily serving as President of Big Brothers of Washington, D.C., the number of boys the agency helped was doubled. He also received a personal letter of commendation from the President of the United States for his work with the Youth Conservation Corps.

Mr. Specter was born in White Plains, NY and lives there now.

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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