To her credit Susan Arbetter, the host of Spectrum News Capital Tonight program, has tried to expose viewers to issues related to the Climate Leadership & Community Protection Act (Climate Act). Recently she interviewed Rich Dewey CEO of the New York Independent System Operator (NYISO) about the recent release of the annual NYISO Power Trends report and its findings relative to Climate Act implementation. Both Arbetter and Dewey have roles to play in the Albany political scene that require them to be diplomatic and politically correct. As a result, the severity of the problems mentioned was not made clear.
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. I have extensive experience with air pollution control theory, implementation, and evaluation having worked on every cap-and-trade program affecting electric generating facilities in New York including the Acid Rain Program, RGGI, and several Nitrogen Oxide programs since the inception of those programs. I follow and write about the RGGI cap and invest CO2 pollution control program so my background is particularly suited for the New York Cap and Invest proposal to provide compliance certainty for the Climate Act schedule that has unacknowledged risks associated with the Power Trends report. I have devoted a lot of time to the Climate Act 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. The New York Cap and Invest (NYCI) initiative is one of those recommendations.
According to the NYCI overview webinar documentation, NYCI will “establish a declining cap on greenhouse gas emissions, limit potential costs to New Yorkers, invest proceeds in programs that drive emission reductions in an equitable manner, and maintain the competitiveness of New York businesses and industries.” There is an unrecognized dynamic between the goals of a declining cap and the need to limit potential costs. One touted feature of NYCI is that the declining cap provides compliance certainty so that the Climate Act targets (e.g., 40% reduction in GHG emissions by 2030) will be met. There is no question that there will be massive costs associated with the transition to zero emissions across the economy, but NYCI is supposed to limit potential costs. If the investments necessary to deploy zero emissions resources are insufficient then the energy system will fail to meet the cap limits. Even if the money is available, it may not be possible to build it fast enough to meet the arbitrary CLCPA schedule. My biggest concern is that the ultimate compliance strategy for the NYCI program is stop using fossil fuels even if replacement energy sources are not available. In that case, that means that compliance certainty will lead to an artificial energy shortage.
Interview with Dewey
Arbetter’s interview with Dewey is a good overview of the issues facing the NYISO. That organization has a mission to “Ensure power system reliability and competitive markets for New York in a clean energy future”. Arbetter explained that “Decarbonizing New York while at the same time ensuring the seamless functioning of the state’s electric grid takes a delicate balance”. The description of the interview states:
If fossil fuels are eliminated before enough renewable energy comes on-line, that balance will be disrupted.
The New York Independent System Operator (NYISO), the state’s nonprofit electric grid operator, in part, oversees that balance. Each year, NYISO publishes a report called Power Trends.
This year, the report warns the state is facing “declining reliability margins.”
While the grid operator is “fully committed” to New York state’s aggressive decarbonization goals under the Climate Leadership and Community Protection Act (CLCPA), NYISO President and CEO Rich Dewey told Capital Tonight that they must consider reliability first.
“Reliability is the top job,” he said. “When you’re managing the power grid, you’ve got to make sure that you’ve always got adequate supply to balance that demand.”
Currently, according to Dewey, there’s a “tremendous” buildout of new supply, which is largely renewable. But hooking up those new plants to the grid – a process call interconnectivity — is taking a lot of time.
Meanwhile, older legacy fossil fuel plants are being shut down. NYISO is responsible for the due diligence and research that go into interconnectivity.
According to Dewey, there are efforts underway to make that process more efficient.
“It’s a gigantic priority for me and for our organization,” Dewey said. “The challenge really arises from the fact that the new solar and wind resources are being built and interconnected at points on the grid where there does not exist already a generating plant.”
During the interview itself Dewey explained that NYISO reliability concerns about the transition to zero-emissions intermittent resources must be coordinated with retirements of existing fossil-fired resources. It is necessary to develop wind and solar and get the power from those resources to where it is needed before the existing resources can be retired or problems will ensue. It is often unrecognized that connecting the new resources to the grid is not a trivial task and Dewey explained they are working on the need for more support in this regard. The transition is also complicated by the fact that the decarbonization strategy for other sectors is electrification which will necessarily increase demand.
Power Trends 2023
The annual Power Trends report describes recent history and trends on the electric system. NYISO has prepared a key takeaways fact sheet in addition to the Power Trends 2023 report itself. The following graphic summarizes the key messages.
I will address each of these takeaways in the rest of this section.
The first takeaway “Public Policies are driving rapid change in the electric system in the state, impacting how electricity is produced, transmitted, and consumed” states the obvious that the Climate Act mandate to completely transform the energy system of the state affects everything in the electric system.
The second takeaway address’s reliability margins which are shrinking because fossil-fired generators are retiring at a faster pace than new renewable supply is entering service. What are they talking about? The Installed Reserve Margin (IRM) is “the minimum level of capacity, beyond the forecasted peak demand, which utilities and other energy providers must procure to serve consumers”. Power Trends notes “The IRM for the 2023-2024 capability year is 20.0% of the forecasted New York Control Area peak load, an increase from 19.6% last year. Based on a projected summer 2023 peak demand of 32,048 MW and the IRM, the total installed capacity requirement for the upcoming summer capability period is 38,458 MW”.
There is a significant underlying issue with this metric. In order to determine resource adequacy for the IRM, NYISO has a process that has been developed and refined over decades. Over the years this work has determined just how much extra power capacity is necessary to cover the unexpected loss of operating capacity at any one time. Importantly, a fundamental presumption based on observations in the NYISO analyses is that conventional generating resources operate independently. One of the biggest issues with a generating system dependent upon wind and solar resources is that there is a very high correlation between wind and solar output across the state. At night every solar resource provides zero energy. The primary cause for low wind energy output is a high-pressure system which is typically larger than New York. That means that the output for all the wind facilities in New York are highly correlated now and even when offshore wind comes on line this will continue. NYISO and the New York State Reliability Council are just coming to grips with this problem and how future resource adequacy analyses will have to be modified to refine the IRM standard. Finally, note that this problem is exacerbated by the fact that the hottest and coldest periods in New York associated with the highest electrical loads correlate very well with high pressure systems with light winds. In the winter when the solar resource is low because days are shorter and irradiance lower this problem is even more difficult.
The reliability margin takeaway discussion also raises implementation schedule concerns: “The potential for delays in construction of new supply and transmission, higher than forecasted demand, and extreme weather could threaten reliability and resilience of the grid.” This is one of my primary concerns with NYCI. Even if the technologies needed actually work, they might not be deployed fast enough to meet the NYCI cap limits.
The next takeaway addresses the issue of interconnection. It notes that “The NYISO’s interconnection process balances developer needs with grid reliability”. There is a lot of pressure on the NYISO to approve facility interconnection requests by those who will bear no responsibility if the rush to approve creates unanticipated issues. This is complicated. A reliable electric power system is very complex and must operate within narrow parameters while balancing loads and resources and supporting synchronism. New York’s conventional rotating machinery such as oil, nuclear, and gas plants as well as hydro generation provide a lot of synchronous support to the system. This includes reactive power (vars), inertia, regulation of the system frequency and the capability to ramping up and down as the load varies. Wind and solar resources are asynchronous and cannot provide this necessary grid ancillary support. The New York State Reliability Council (NYSRC) has proposed a new reliability rule for large asynchronous resources that is necessary but will likely add unavoidable delays to the interconnection process.
The Climate Action Council has the responsibility to develop the Scoping Plan to implement the Climate Act. Unfortunately, the members were chosen more for ideology than technical expertise and one of the primary ideological beliefs of many on the Council was that existing technology is sufficient for the transformation of the electric sector. The next takeaway argues otherwise: “To achieve the mandates of the CLCPA, new emission-free supply with the necessary reliability services will be needed to replace the capabilities of today’s generation.” Note that this position is supported by the Integration Analysis, the NYSRC, and even the Public Service Commission (PSC) that recently convened a proceeding to address this particular issue. The Council’s misunderstanding of this requirement could have serious consequences.
This new resource is an instance where the NYISO must placate the supporters of the Climate Act by downplaying the difficulty of developing this resource. The Power Trend takeaway states: “Such new supply is not yet available on a commercial scale” but they have not publicly come out bluntly and said how difficult this might be. In my draft scoping plan comments I argued there is a real concern because any resource that is emission-free and provides necessary reliability services must overcome the Second Law of Thermodynamics. Any energy storage system must lose energy as it is stored and then again as it comes out of storage. This limits the viability of every storage system touted for this resource.
The final takeaway addresses the wholesale electricity market. The NYISO is a creation of the deregulated electric system and its market. It is not surprising that the NYISO touts their critical role in the transition in this regard. However, in my opinion, the market adds a layer of complexity. It is not enough to just determine what resources are necessary to keep the lights on but it is also necessary to develop a market incentive to provide that resource. What happens if the PSC proceeding recommends an emissions free resource that provides the grid support needed but nobody wants to risk the money for a resource that is needed for a limited period during critical demand peaks?
Peaking Power Plants
There were other press reports describing Power Trends. Reuters emphasized the “balanced and carefully planned transition” theme. New York Focus chose to point out that the report indicates that “Air-polluting “peaker” plants were a top priority for closure in New York’s green transition. But the state isn’t building clean energy fast enough to replace them on time.” Arbetter also raised the “peaker” power plant issue. Dewey said there are “dirty” units that reside in “underprivileged communities” and Arbetter said they cause “lots of pollution and environmental racism”.
This is a complicated problem that has become embroiled in emotional arguments. There are some old power plants that are only used to provide power during the highest load demand periods. They are old, relatively dirty, and many are located in low- and middle-income disadvantaged communities in New York City so have become the poster child of disproportionate impacts on over-burdened communities. No politically correct organization dares raise any objections to the argument that this is a problem. On the other hand, I not only have subject matter expertise but also have no voice. I have shown that the alleged peaker power plant problems are based on selective choice of metrics, poor understanding of air quality health impacts, and ignorance of air quality trends. In other words they are not as much of a problem as environmental advocates claim.
This is a particular problem for the NYISO. The new resource that must be developed is needed for this particular problem. These are the facilities that Dewey wants to be kept available in New York City until a viable alternative is provided. Someone with a voice is going to have to come out and say that until we have alternatives that will work, have lower risks to the communities where they reside, and are affordable, some peaker power plants may have to remain available. Whether or not they ever point out that the arguments used to vilify the facilities don’t hold water is another matter.
Conclusion
I agree completely with the following. The New York Focus article quotes C. Lindsay Anderson, an energy specialist at Cornell University’s school of engineering, who said it’s hard to avoid such gaps in an energy transition with so many moving parts.
“Everything has to move sort of in sync to make the plan work,” Anderson said. “Taking [peakers] offline is an important signal that we’re making progress. But with many other pieces of the plan having been delayed, it’s not surprising that we may need to delay this a little bit to let the other pieces catch up.”
The necessity to toe the line of political correctness in the Capital District prevented Dewey from explicitly connecting some of the Power Trends takeaways and the Climate Act implementation process. For example, the concern about timing and suggestions that delays are inevitable directly impacts the NYCI emission caps. The caps are based on the arbitrary Climate Act deadlines that were not chosen based on any kind of a feasibility analysis. To my knowledge, NYISO has not been asked to provide their best estimate of the timing of the wind and solar resources necessary to displace the existing resources required to meet the Climate Act mandates. Their resource adequacy modeling and other work is the only credible way to determine if the schedule is reasonable and would likely show the current schedule is not viable. Because GHG emissions are primarily associated with energy use meeting the unrealistic NYCI emission caps means the only compliance strategy is to create an artificial energy shortage.
New York GHG emissions are less than one half of one percent of global emissions and global emissions have been increasing on average by more than one half of one percent per year since 1990. While this may not be a reason to not do something about climate change, it certainly suggests that adjustments to the arbitrary Climate Act schedule are justified. The Power Trends report certainly implies that adjustments to the schedules appear to be necessary.
Pragmatic Environmentalist of New York 