New York Zero Emissions Proceeding: Richard Ellenbogen Comments

The New York State Public Service Commission (PSC) recently initiated an “Order initiating a process regarding the zero-emissions target” that will “identify innovative technologies to ensure reliability of a zero-emissions electric grid”.  Implementation of the Climate Leadership & Community Protection Act (Climate Act) started soon after the law was passed at the end of 2019.  It was recognized early that “as renewable resources and storage facilities are added to the State’s energy supply, additional clean-energy resources capable of responding to fluctuating conditions might be needed to maintain the reliability of the electric grid”.  I recently summarized the proceeding and my comments.  This post summarizes the comments by Richard Ellenbogen that I think describe the overarching problems of the Climate Act.

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 meteorological aspects of electric generation because I have worked in the sector as a meteorologist for over four decades.  I have devoted a lot of time to the Climate Act and the issues raised in this proceeding 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.  I represent the Environmental Energy Alliance of New York on the New York State Reliability Council Extreme Weather Working Group.  The opinions expressed in this article do not reflect the position of the Alliance, the Reliability Council, the Extreme Weather Working Group, 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 zero emissions analysis is part of that effort.

Ellenbogen Background

I have published other articles by Ellenbogen because he truly cares about the environment and the environmental performance record of his business shows that he knows how to protect the environment while running a business.   At the Business Council of New York 2023 Renewable Energy Conference Energy he [BIO] gave the keynote address (presentation and video) –  Why NY State Must Rethink Its Energy Plan and Ten Suggestions to Help Fix the Problems.”  which I summarized here.  His comment submittal includes more background information.

Comments

Ellenbogen’s comments are available on the DPS DMM website.  Many of the points in the Business Council keynote presentation were incorporated into his comments.

His introduction notes:

While Mr. Ellenbogen is in favor of the decarbonization identified in the CLCPA, the way that the policy is structured cannot possibly work and it is going to cost the state hundreds of billions of dollars, while not reducing atmospheric carbon, and worse yet, it precludes methods of reducing carbon emissions that actually will work much more rapidly based upon the physics of how utility systems actually operate.

Issues Raised in the Comments

He goes on to describe five issues related to Climate Act bet-zero transition:

1. There is a lack of available energy to support the Plan
2. Costs to implement the Plan will far exceed other, better solutions

These costs accrue based upon shortages of materials and skilled labor, high energy storage costs, and a lack of financial adequacy

3. Atmospheric Carbon Levels will rise far above what could be achieved using other alternatives
4. Planned timing mandates are unachievable
5. There are major non sequitur issues contained within the CLCPA

 

He argues that the Scoping Plan does not accurately estimate the energy available from wind and solar and how much energy will be needed when the electrification proposed is in place.  His analyses, indicate that “even if all of the renewables specified in the CLCPA are installed, the state will still be over 100,000 GWh short of what is needed and there will be hundreds of hours of rolling blackouts annually.”   He also notes that renewable facility installation rate is falling behind the Scoping Plan schedule.

Ellenbogen has hands-on experience designing, building and operating a low-carbon energy system for his business.  Based on that background he believes “project costs will far exceed other, better solutions, based upon a shortage of materials, labor, and capital needed to complete Plan implementation”.  This is based on energy storage requirements, transmission upgrades, and the materials and labor needed to resolve those needs.

He points out that GHG emissions will not decrease as quickly as projected because the renewable energy/ carbon free energy resources won’t be available in time.  When other sectors of the economy are electrified that means that the additional loads will be supported by fossil fuel generation.  He points out that the demands for no new fossil fuel infrastructure means that old power plants will be kept on line longer.  He argues that building new, more efficient power plants for the decades long transition is the better solution.

The reason for this proceeding is that there is only one zero-emissions resource that fulfills most of the electric system requirements and nuclear is politically toxic.  In addition, it is unlikely that even if nuclear power were embraced it would be unlikely that the targets of the Climate Act could be met.  His discussion of schedule issues also raise a problem associated with the proposed dispatchable emissions-free resource (DEFR) included in the Scoping Plan.  As envisioned there, these resources will only be used 3% of the time:

That doesn’t work in the real world. Most generating technologies don’t lend themselves well to being dormant 97% of the time. Additionally, based upon the math, the 3% is an extremely low estimate. It would be far more cost effective to build more nuclear generation and fewer renewables. That would remove the intermittency issue and the storage cost issue documented earlier.

Finally, Ellenbogen explains that the conclusions of the Climate Act are based on fantasy.   He notes that the projected solar annual energy production from the listed capacity requires an annual capacity factor of 22% but that the state has a solar capacity factor of 13% when the arrays are new.  As a result, the calculated solar output is overestimated by 72% or 51,000 GWh. Using the correct solar capacity factor results in only 70,768 GWh of solar output in 2050, 51,000 GWh less. Combined with his estimate that the amount of energy needed is going to be 120,000 GWh more than the 2050 Scoping Plan projections is the reason he believes “that we can expect hundreds of hours of rolling blackouts every year if the Climate Act is executed as planned. “

Viable Alternatives in the Comments

Ellenbogen argues that natural gas-fired combined cycle power plants are a viable alternative during the transition.  They can be built relatively quickly and would replace the old more inefficient power plants that have to be kept on-line in the absence of adequate resources.  He makes a persuasive case that the huge electricity load of the proposed Micron chip fabrication plant north of Syracuse should include a combined cycle co-generation plant that would provide both electricity and heat for the facility.  He explains:

With regard to Micron Technologies, one could be built on-site that would eliminate 350 GWh of line loss while also providing Micron easy access to high temperature thermal energy. The Energy on Demand aspect of the generating plants also eliminates the need for trillions of dollars of battery storage. It is not a perfect solution, but it is a far better solution than “ideal” solutions that can’t be executed because of the previously documented issues. As hydrogen technologies are perfected and a sufficient supply of hydrogen is developed, hydrogen injection technologies can help to further reduce the GHG emissions of the plants.

Overview Conclusion

He concludes:

The prior analysis is based upon facts, math, and physics, not opinions or wishful thinking.. The issues don’t require an understanding of calculus. They just require an open mind and a knowledge of arithmetic. People can’t only say, “Follow the science” when it tells them what they want to hear. Any engineer knows that science, math, and reality can screw up the best plans.

Einstein defined “Insanity” as repeating the same thing over and over again and expecting different results. Why is NY State repeating Germany’s failed renewable experiment that hasn’t worked in 33 years and expecting it to work in seven years or seventeen years. The results in NY State are going to be just as bad as they have been in Germany. However, time is now an issue and significant GHG reductions need to be achieved quickly. The CLCPA in New York State will not be any more successful than Germany policy has been in their efforts to combat climate change.

NY State is currently in the CLCPA, mandating a non-functional utility system which will be plagued by greater fossil fuel use, higher carbon emissions, energy failures, and stability issues that will result in deaths, and a mass exodus of people and businesses that will destroy the tax base and with it, the state economy.

Response to Questions

The zero-emissions proceeding request for comments included 14 questions.  He did not respond to specific questions  Instead, I quote his response “Regarding Answers to Some of the 14 Questions”:

“How should zero be defined?” Zero is zero. If they meant otherwise, they should have used the word “low”. Carbon offset projects still have to be distinguished from true zero emission technologies such as solar, wind, and nuclear. If the state wants to offer credits to a process that offsets carbon for accounting purposes, that’s fine but don’t call it zero. It should be in a separate “offset” category.

Regarding Carbon Capture, many of the technologies cool the exhaust to separate the CO2 as a liquid and either use it in other materials or pump it underground in a deep well to sequester it. While that will greatly reduce atmospheric CO2, it will greatly increase energy use. That energy has to be accounted for. Where is it going to come from?

Regarding “Green Hydrogen”, hydrogen electrolysis should not qualify. There is going to be an enormous shortage of electrical energy to support the utility system, even if all of the renewables are magically installed. A recent study done in Australia found that if all of their current proposals to produce green hydrogen by electrolysis were implemented, the total energy required would exceed all of Australia’s generating capacity. The math will be no different in NY State. A better solution would be to generate hydrogen by investing in a thermo-chemical process using the waste heat of the nuclear plants to power or by using the NYSERDA Biomass Power Guide qualifying waste to energy plants to generate the hydrogen.

Pragmatic Environmentalist Conclusion

I highly recommend reading his comments.  Ellenbogen offers alternatives that would be cheaper, will reduce GHG emissions in the short term, and are technologies that will actually “work much more rapidly based upon the physics of how utility systems actually operate.”  Alas he argues that going to zero is not appropriate.  The ideologues on the Climate Action Council who shaped the Scoping Plan demand perfection but do not seem to comprehend that the real world makes that impossible.

I don’t think the ideologues understand the risk to their goals.  The proposed Scoping Plan cannot work as written and will cost enormous amounts of money.  There is no indication that proponents understand the risks to reliable energy inherent in the Scoping Plan and that poor energy policy will cause greater health and economic damage than climate change.  When these problems get to the point that they cannot be denied, I believe it is likely that public backlash will be so strong that there will be no appetite for any of the idealistic dogma in the Scoping Plan energy policy.  Moreover, even the alternatives proposed by Ellenbogen will be off the table for future energy policy.