In my last post I explained that the New York Public Service Commission has initiated a process to “identify technologies that can close the gap between the capabilities of existing renewable energy technologies and future system reliability needs, and more broadly identify the actions needed to pursue attainment of the Zero Emission by 2040 Target”. In order to implement the Climate Leadership & Community Protection Act (Climate Act) net-zero transition the Integration Analysis, the New York Independent System Operator and the New York State Reliability Council all agree that a new resource that has all the characteristics of a natural gas fired turbine but no emissions is needed. This post reviews an article about this topic: New York Begins Exploring Non-Renewable Energy to Meet Climate Target.
I am a retired air pollution meteorologist who specialized in the electric generating sector. I have been following the Climate Act since it was first proposed. I submitted comments on the Climate Act implementation plan and have written over 300 articles about New York’s net-zero transition because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good. 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.
Climate Act Background
The Climate Act established a New York “Net Zero” target (85% reduction and 15% offset of emissions) by 2050 and an interim 2030 target of a 40% reduction by 2030. The Climate Action Council is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.” In brief, that plan is to electrify everything possible and power the electric grid with zero-emissions generating resources by 2040. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies. That material was used to write a Draft Scoping Plan. After a year-long review the Scoping Plan recommendations were finalized at the end of 2022. In 2023 the Scoping Plan recommendations are supposed to be implemented through regulation and legislation.
My previous article described the reason why a new proceeding on this topic is required. The professional staff at the agencies responsible for keeping the lights on in New York and the analysts who developed the Integration Analysis used for the Scoping Plan all believe that a new resource that can be dispatched as necessary but has zero emissions will be needed. In the discussion section of the order the PSC agrees that efforts to meet the Climate Act targets “must include exploration of technologies that can support reliability once conventional fossil fuel generation has been removed from the system”. The order states:
We see this exploration as integral to our responsibility under the PSL to ensure reliable electric service as we approach the Zero Emissions by 2040 Target. With this Order, we are initiating process to determine appropriate next steps to address this gap including consideration of whether it is appropriate for the Commission to allocate ratepayer funds to incentivize the deployment of zero-emission technologies.
I concluded that on one hand it is encouraging that there is finally an effort underway to define “zero emissions” resources and there is recognition that new technologies must be evaluated. On the other hand, this is a recognized problem that should have been the priority of Climate Action Council and the Scoping Plan from the start. I have always decried the lack of a feasibility analysis of the affordability, reliability, and permitting acceptability of zero emission resource options and the net-zero transition as a whole. I believe that the Climate Action Council reliance on non-experts is a leading cause for this delay. I wrote this article because it interviewed some of the non-experts that caused the delay and had some mis-understandings that deserve clarification.
New York Focus
The article was published at the New York Focus website. According to the about link:
New York Focus is an independent nonprofit newsroom investigating power in the Empire State. Launched in October 2020, New York Focus publishes in-depth journalism that explains how the state really works.
As the state’s only nonprofit statewide newsroom, our goal is to help rebuild a local news ecosystem that has faced years of relentless cuts: Almost half of New York’s newspapers have died in the last two decades. We focus on decisions made in Albany and how they impact communities around the state; Albany is the state’s center of power but receives a fraction of the scrutiny it warrants.
We’re guided by the belief that politics is not a sport. Decisions made in New York’s executive mansions, legislative chambers, state administrative offices, courts, nonprofits, union halls, and campaign headquarters don’t stay there. They determine how many New Yorkers sleep on the street each night; how large public college classes are; how many hospital beds are available during a pandemic.
The New York Begins Exploring Non-Renewable Energy to Meet Climate Target article was written by Colin Kinniburgh.
He is a reporter at New York Focus, covering the state’s climate and environmental politics. Over a decade in media, he has worked in print, television, audio, and online news, and participated in fellowship programs at CUNY’s Graduate School of Journalism and the Metcalf Institute. His reporting has appeared in outlets including France 24, Grist, Dissent, and The Nation.
New York Begins Exploring Non-Renewable Energy to Meet Climate Target
I have annotated the article in this section.
Biofuels, hydrogen, carbon capture, and nuclear: These are some of the technologies that will be on the table as New York weighs how to clean up its grid over the next 17 years.
When New York passed its climate law four years ago, it declared wind, solar, and battery storage to be the energy sources of the future. The law not only required the state to get 70 percent of its electricity from renewables by 2030, but set precise benchmarks for technologies like offshore wind.
As I have written before, the Climate Act is a political statement. The implication here is that the Legislature developed a plan that was based on an understanding of the power system and developed schedules based on evaluation of technology. That was not the case.
That riled power companies, who have long argued that picking technologies in advance will stifle innovation needed for the energy transition. There was still an opening for them to make their case. New York’s climate law requires the state to produce 100 percent of its energy from “zero emissions” sources by 2040, but what exactly that means is still up for debate.
Power plant operators’ lead trade group, the Independent Power Producers of New York (IPPNY), have spent years pushing the state to focus on that more distant goal. The group’s president, Gavin Donohue, pressed the legislature, the Public Service Commission, and the Climate Action Council to back a new subsidy for technologies that will close the gap in New York’s energy supply when the sun isn’t shining and the wind isn’t blowing. Those could include hydrogen; nuclear; alternative fuels like waste products from agriculture; or carbon capture and storage, which could allow plants to keep burning fossil fuels as long as they keep emissions out of the air.
Donohue wasn’t alone in this effort. Along the way he won support from the AFL-CIO, the leading voice of organized labor in the state.
The reference to new technologies that will close the gap in energy supply refers to the Dispatchable Emissions-Free Resource (DEFR). The article does not recognize that the professional staff at the New York Independent System Operator and the New York State Reliability Council who are responsible for keeping the lights on in New York and the analysts who developed the Integration Analysis used for the Scoping Plan all believe that DEFR will be needed to keep the lights on.
But environmentalists pushed back, arguing that the effort was a ploy to keep polluting plants open with the help of expensive technologies that have yet to be proven commercially. For much of the last two years, they’ve maintained the upper hand: the IPPNY-backed bill died in committee last session, and the state’s climate plan de-emphasized the kinds of alternative fuels the power industry says will be needed.
The environmentalist push back is rooted in a mis-understanding of the way the electric system works and an overly optimistic expectation for wind and solar resource availability. I have given a presentation explaining my skepticism of the Climate Act benefits relative to its risks. My article describing that presentation focused on electric grid reliability risks that environmentalists do not consider.
Now, state regulators are signaling that the issue deserves a fresh look. On Thursday, the Public Service Commission ordered the state to begin studying which new technologies — beyond renewables — it will need to meet its climate targets.
Announcing the decision at a Public Service Commission meeting on Thursday, chair Rory Christian called it an important step. “If we’re successful, this will give us the tools to address many of the emerging issues that we’re seeing, and help us hit our various reliability needs and long-term goals,” Christian said.
State officials have stressed that the effort is intended to complement, not supplant, the central role of renewables. New York is already planning a massive buildout of wind, solar, and transmission lines: To meet the climate law’s requirements, it will need to build 100 times as much large-scale solar in the next five years as it did in the last ten, for example.
Yet even that explosion of renewables won’t be enough to ensure reliable energy while phasing out fossil fuels, studies by the state energy authority NYSERDA and the New York Independent System Operator have found. New York will also need to build new clean energy systems that don’t rely on the weather, and can be turned on at a moment’s notice.
As is the case with many of the green technology solutions advocated by proponents of the Climate Act, the idea that just existing wind and solar technology is all that is needed for the electric grid is flawed. The general green technology problem is that the technologies do not work all the time. For the electric system the issue is that there can be extended wind lulls in the winter when solar resources are inherently low is exacerbated because those periods coincide with the coldest weather and thus the highest loads. The professionals responsible for reliability all conclude that DEFR is necessary for those periods.
The state’s climate plan asks the PSC, along with NYSERDA , to draw up the final criteria for those “firm” or “dispatchable” resources, and that’s what it started doing on Thursday. Like many regulatory decisions, the order published on Thursday is only the start of a lengthy process. It kicks off a two-month public comment period, which will be followed by a technical conference — likely in the fall — to decide what kinds of technologies qualify as “zero emissions” under state law.
Donohue, the head of the power plant lobby, said the move was a long time coming. “The fact that the commission has finally said, ‘We need these technologies,’ and the fact that they did not limit technologies in this order, is a positive thing,” Donohue said. Still, he called it “incremental progress,” coming nearly two years after IPPNY petitioned the state to take the issue on.
The PSC’s order, which responds explicitly to IPPNY’s petition, meets the group halfway. It stops short of creating a state-backed market for the technologies that ultimately meet the criteria, as IPPNY has sought. The state currently has such markets for wind, solar, and other renewables: Through a mechanism known as the Clean Energy Standard, the state signs contracts for qualifying renewable energy projects, guaranteeing a buyer for the power they generate. The cost of underwriting those contracts trickles down to New Yorkers through their utility bills.
No such guarantees exist for technologies like hydrogen, making them a riskier bet to develop. That isn’t changing for now. But IPPNY hopes the PSC decision will pave the way toward such a subsidy before long.
Setting up a subsidy for these technologies is putting the cart before the horse. They must find something that might possibly work before they can consider how much it might cost. Getting something that will work may well be impossible because of the Second Law of Thermodynamics. I do not consider myself an electric system expert but I have talked to experts and they all say this is a challenge because of physics.
The effort’s most vocal backer among state regulators is Commissioner Diane Burman, who was appointed by then–Governor Andrew Cuomo in 2013 and is PSC’s longest-serving member.
“We need all the tools in the toolkit to help us achieve our clean energy goals,” she said on Thursday, echoing longstanding talking points from the power industry. “To do that, we need to not be so focused on picking winners and losers, in that we are actually going to chill the opportunities that may be there.”
A week earlier, Burman spoke at IPPNY’s annual conference, where Donohue called her a “good friend.” The conference dedicated a 90-minute session to the issue of dispatchable resources, featuring a program manager at NYSERDA, a chemical engineer, an executive at a fuel cell company, and a pipefitters’ union leader.
“We don’t have to displace middle-class union jobs to achieve our goals,” said John Murphy, the pipe trades union representative. “Intermittent renewables can’t do it alone.”
Speaking to New York Focus on Thursday, Donohue said the PSC’s expected decision on IPPNY’s petition shaped the conference lineup.
“I didn’t do this in the dark,” he said, adding that the PSC’s decision was a sign of regulators warming up to IPPNY’s agenda.
Given the expert concern about this technology it is encouraging that it is finally being addressed. I worry that it will become politicized with environmental groups disparaging the very idea that it is needed. The next section in the article, Environmental Groups Wary, confirmed my suspicions.
Environmentalists, who came out in uniform opposition last year to IPPNY’s push, remain wary. Environmental justice advocates in particular have condemned biofuels and hydrogen as “false solutions” that would roll back hard-fought commitments in the state’s climate law.
The “false solution” slogan is the mantra of environmental activists. To date they have been very successful pushing their emotion-laden agenda that the only acceptable pollution burden is zero based on a selective science. Anything that is inconsistent with that is labeled as a “false solution”. See, for example, my work on the peaker power plant issue that discusses tradeoffs.
“If the intention is to have an honest discussion about what actually is zero emissions, and what’s industry hype and… gaslighting, then that’s one thing,” said Eddie Bautista, executive director of the NYC Environmental Justice Alliance. “However, a lot of us are skeptical and worried because of actions that we’ve seen of late by the Hochul administration themselves, looking to potentially undermine the climate law.”
Bautista pointed to the sudden proposal from Hochul’s office in late March, just days before the state’s budget deadline, to overhaul how New York counts carbon emissions. The shift could have allowed polluters to continue burning gas and other fuels for longer, and could have opened the door to more fuels derived from biological sources like wood, or methane gas captured from farms or landfills. Hochul dropped the proposal from budget talks following an uproar from climate groups, but officials have said they intend to revisit it.
Bautista is referring to a proposed change in the emissions accounting proposed earlier this year. I don’t think very many people understand the actual ramifications to the Climate Act targets. I don’t agree that it would have “allowed polluters to continue burning gas and other fuels for longer”. They only proposed to change the accounting label. The actions necessary to meet the percentage reductions don’t care whether the starting number is 200 and the 2030 40% emissions limit is 120 or the starting number is 100 and the 2030 40% reduction emission limit is 60. The control strategies still have to get a 40% reduction. The environmental community is wound up about bio-fuels but ignore the fact that most other jurisdictions with similar programs enable their use.
The plan adopted by the state’s Climate Action Council in December rejected most uses of alternative fuels, to the relief of environmental justice advocates — and the dismay of the three industry-aligned members, including Donohue, who voted against. Now, Bautista is nervous that Hochul might be wavering on the council’s recommendations. “It’s hard not to see signs of the Hochul administration not fully embracing the plan,” he said.
Raya Salter, an environmental justice advocate and lawyer who sat on the Climate Action Council, was not surprised to see the state moving forward with IPPNY’s petition. She said it was up to climate groups to “hold the line” against any move that would “increase costs to New Yorkers and put disadvantaged communities at risk.” “We set the bar high in New York, in terms of what any technology that will be used in our state will do in terms of affordability, health, cost, etc.,” she said. “Through the fog, we’re talking about emerging technologies that are unproven and really have a long way to go before clearing any bar.”
The rhetoric of these two ideologues is frightening. Neither has ever acknowledged the concerns of the agencies responsible for electric system reliability. I suspect that they would prefer to risk the current standards for reliability and affordability than concede that some of their aspirational goals are threats to them.
The PSC’s order acknowledges some uncertainties around new nuclear, biofuels, and hydrogen, but it doesn’t rule any technologies out. Aside from possible pollution, critics worry that many of these technologies remain prohibitively expensive — though new federal funding, mostly from the Inflation Reduction Act, could change the economics.
Critics of the technologies are worried about the costs of these technologies. They should be but apparently do not understand that the potential risks of not having this technology dwarf those costs. In February 2021, the Texas electric grid failed to provide sufficient energy when it was needed. As a result, over 4.5 million homes and residences were without power, at least 246 people died, and total damages were at least $195 billion. Those are real costs and deaths not some contrived benefits and projected health impacts associated with GHG emissions.
It is hypocritical to worry about the DEFR costs but ignore the costs of the rest of the net-zero transition. Both Bautista and Salter support the narrative that the costs of inaction for the net zero Climate Act transition outweigh the costs of action. That too is nothing more than a slogan. It is misleading, because the costs in the Scoping Plan do not include the costs of “already implemented” programs. In other words, it does not cover the costs to get to net-zero only the costs of the Climate Act itself. My analyses of costs found that there are significant “already implemented” program costs that likely would make the statement false. It gets worse because as far as I can tell the Integration Analysis does include the benefits of already implemented programs while it excludes the costs. My analysis of the benefits shows that they over-estimated the benefits in any event.
Officials say some state investment is necessary to bring emerging, zero-emissions resources to market, just like the technologies that came before them. “All of our energy infrastructure, at some point, was built with public injection of funds,” said NYSERDA operations manager Richard Bourgeois at the IPPNY conference.
There is one difference overlooked by proponents however. In the past there was an end to the public injection of funds. The public injection of subsidies for wind and solar have been on-going for decades. Given the technological risk of DEFR it is likely that similar on-going subsidies will be required. There is likely no end for the new “zero-emissions” technologies.
The state will need at least 17 gigawatts’ worth of these clean, “firm,” systems by 2040, NYSERDA estimates — about two-thirds the capacity of all the fossil fuel plants that serve New York today. Those dispatchable systems will run very rarely, generating only about 1 percent of the power New Yorkers actually end up using, according to a recent presentation by Vlad Gutman-Britten, assistant director of policy and markets at NYSERDA.
The current business model for peaking generation resources is to use the cheapest technology available (simple cycle natural gas turbines) because cost recovery for a facility that only runs 5% or less of the time for the rare conditions is challenging. It seems unrealistic to expect that any of the new DEFR technologies will be cheaper than a gas turbine which means that cost recovery will be much more difficult. Somebody, somewhere is going to have to pick up that tab.
Bautista says that limited role means there’s no need for the state to rush into supporting these technologies, particularly given advances in battery storage. “Their solution is always shooting an elephant gun to kill a fly,” he said. “They can’t say in 10 years where battery technology is going to be.”
Gutman-Britten sees things differently. “That resource is really going to carry New York through some of the most difficult weeks of every year, when renewables are not generating at the times when demand is highest,” he said.
Gutman-Britten has it right. Without this resource there will be serious reliability problems. In my opinion failure to provide DEFR will inevitably result in a Texas February 2021 blackout disaster. Bautista’s naïve position is dangerously wrong.
Conclusion
The Hochul Administration’s deference to a few naïve individuals is increasing the threat to reliable and affordable electricity in New York. The responsible experts all say that this new resource that can be dispatched as needed without any emissions is necessary for the net-zero transition. Instead of confronting the discrepancy between the activists who believe that existing technology is sufficient and the Integration Analysis that said that this new technology was needed, the Climate Action Council frittered away a couple of years arguing semantics and nomenclature on less critical issues.
Even if the technologies necessary for the transition turn out to be affordable and work as necessary, the arbitrary schedule of the Climate Act is a problem. The proposed cap and invest program promises compliance certainty with respect to the mandated schedule. What is missing is implementation certainty. There are a whole host of reasons (e.g., funding, supply chain issues, and lack of trained workers) why the generating resources necessary to meet the mandates might not get built as fast necessary. If that happens the final compliance option is to shut down when the cap is reached. I do not think that an artificial energy shortage to meet the targets is in the best interest of anyone. Are the climate activists so naïve as to believe that rationing gasoline, heating fuels and electricity will be selling points for their vision of the future?
Pragmatic Environmentalist of New York 