My Comments on Draft Blueprint for Consideration of Advanced Nuclear Technologies

On September 4-5, 2024, the Hochul Administration hosted a Future Energy Summit.  After the Summit the State released the draft Advanced Nuclear Technologies Blueprint (Draft Blueprint). This post describes my submittal that explained why I supported the comments presented on behalf of Nuclear New York, New York Energy and Climate Advocates, and Mothers for Nuclear (“NNY comments”).

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 470 articles about New York’s net-zero transition.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% GHG reduction by 2030. Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantified the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation.  The Draft Blueprint is one of the implementation initiatives.

Future Energy Summit

This Summit kicked off the release of the Draft Blueprint.  My thinking about the rationale for the Summit has evolved.  The announcement for the summit said it will “gather feedback on strategies to accelerate renewable energy deployment and explore the potential role of next generation clean energy technologies”.  Initially I thought it was in response to recent reports that reassessment was necessary because of the challenges of a net-zero grid that relies on wind and solar.  I continued to believe that until the Summit even though nuclear technology was emphasized.  My initial impression of the Summit was that the Hochul Administration still has few doubts that a zero-carbon electric grid that relies on wind and solar will work.  I also described the pushback by anti-nuclear activists against the Summit focus on the potential for nuclear power.  I am now convinced that the Hochul Administration is attempting to gauge public opinion on the nuclear option.  The response to the draft Advanced Nuclear Technologies Blueprint will ultimately decide how the Administration proceeds.

My Comments

The announcement requesting comments for the Draft Blueprint said that they wanted to “solicit industry feedback”.  I do not have a background in nuclear technology, so my submittal referenced the comments submitted on behalf of Nuclear New York (NNY), New York Energy and Climate Advocates, and Mothers for Nuclear (NNY comments) that addressed technical issues.  New York Energy and Climate Advocates also submitted a letter with shorter comments.

My comments explained why I supported the NNY comments. Their comments make a persuasive case for the use of advanced nuclear energy in New York’s future.  They clearly document why nuclear has advantages over the proposed wind, solar, and energy storage approach espoused in the Climate Leadership & Community Protection Act Scoping Plan.  The NNY technical comments strengthen the quality of the Draft Blueprint.  Finally, I think the NNY comments addressed the questions posed in the Draft Blueprint very well.

The remainder of my comments support the main point of the NNY comments that nuclear power should be the backbone of the zero-emissions electric grid.  I am an air pollution meteorologist with decades of experience in the electric sector.  I support nuclear power because it addresses an intractable problem with an electric system that relies on wind and solar – weather variability.

There are several proceedings related to the Climate Act implementation that do not acknowledge that the fundamental premise of the authors of the law is fatally flawed.  The authors believed that New York could “rapidly move away from fossil fuels and instead be fueled completely by the power of the wind, the sun, and hydro.” They also believed that “it could be done completely with technologies available at that time (a decade ago) and that it could be cost effective”.  This formed the basis for their belief that implementation of the Climate Act was only a matter of political will.

My comments argue that reality is different, and the time has come to acknowledge that fact.  The Scoping Plan, NYSERDA’s Integration Analysis, New York Independent System Operator (NYISO), and the New York Department of Public Service all have noted that a new category of generating resources called Dispatchable Emissions-Free Resources (DEFR) is necessary to keep the lights on during periods of extended low wind and solar resource availability. 

It is inarguable that DEFR is needed for the future wind, solar, and energy storage dependent electric system.  I believe nuclear power is the only viable DEFR that must be employed if New York is going to proceed without compromising resource adequacy, reliability standards, and affordability for two reasons: technological availability and weather variability risks.  My comments emphasized the value of resolving the problem of weather variability risks.

Technological Availability

The first reason is that DEFR is necessary and using nuclear power for DEFR is the only proven  technology option that can be expanded.  The NNY comments point out that “the availability of fission-based advanced nuclear reactors is a matter of “commercial” readiness, not “technological” readiness.”  All the other candidate technologies that can be expanded as needed are not technologically ready.  Hydrogen was proposed as the placeholder DEFR technology but there are so many physical limitations that I think any feasibility analysis is going to show that relying on hydrogen will never work.  The same problems exist with long-duration storage.

There is one caveat on the use of advanced nuclear for DEFR support.  Resource projections estimate that the DEFR technologies will not run much which makes for a difficult business viability situation for any technology  The NNY comments explain why this calls for a shift in plans:

A more effective system-level architecture will make use of high-capacity-factor “firm” generation like nuclear power not simply as backup, but as part of the backbone of a reliable system serving a sizable portion of total energy demand in a baseload or load-following configuration. Such an arrangement reduces the total amount of generation capacity and support infrastructure needed, thereby reducing land impacts and system-level costs that are ultimately borne by ratepayers and taxpayers. Indeed, this is how upstate New York, which relies largely on baseload hydropower and nuclear, has already achieved a 90% decarbonized grid while maintaining reliable and affordable electricity.

This is an obvious solution, and it addresses my concerns about weather variability.

Weather Variability Risks

The second reason I support the use of advanced nuclear is that there is a huge unacknowledged risk related to an electric system that relies on weather-dependent resources.  All the analyses that showed the need for DEFR determined that there are extended periods with persistently low solar and wind generation that required additional firm zero-carbon resources beyond the contributions of expected zero-emissions resources.  I believe that characterizing these extended periods introduces an unacceptable risk for future electric resource planning.

I am planning to raise this issue as a problem in my responses to several draft documents and the New York Department of Public Service (DPS) staff proposal concerning definitions for key terms (Staff Proposal) in Public Service Law §66-p.  I provided an exhaustive explanation of my concerns in a recent article describing my impression of the Staff Proposal so I will only summarize the concerns here.

I think that the characterization of the gap between renewable resource generation projections and expected load should be based on analysis of historical meteorological data.  Observed meteorological data can be sed to generate the necessary information to estimate wind and solar resource production across New York and elsewhere.  In New York this type of analysis has generated estimates of onshore, offshore, wind, and solar production for a 22-year period for the New York control area.  There is a technique that has been applied elsewhere that enables a similar type of analysis back to 1950.  I believe that the State must invest in a comprehensive analysis of this data for as long a period as possible and for a region that encompasses adjoining electric control areas.

An unresolved problem is what reliability criteria should be used to determine resources necessary for these lulls. If the resource planning process does not provide sufficient backup resources to provide capacity for a peak load period, then reliability issues are inevitable.  Two factors exacerbate the severity of this problem and the importance of the reliability criteria to prevent reliability issues:

1. The periods of highest load are associated with the hottest and coldest times of the year and frequently correspond to the periods of lowest wind resource availability. 
2. The decarbonization strategy is to electrify everything possible so the impacts of a peak load blackout during the coldest and hottest periods will be greater.

Today’s resource planning concentrates on one-in-ten-year loss of load reliability criteria.  This period is acceptable because observations of existing generating resources over many years show that unplanned outages do not happen at the same time.  As a result, there is not much variability between ten-year periods.  However, wind and solar resources are strongly correlated.  When the wind is light at one location it is likely that many more locations have light winds.  The most recent New York Independent System Operator (NYISO) analysis found a continuous 36-hour period when 90% of the offshore wind, land-based wind and utility solar resources were unavailable for a 22-year period of record.  My concern is that if the reliability analysis had only evaluated ten years of data, they would have missed the 22-year period described.  If the reliability analysis uses the period of record back to 1950, I am confident that a more severe resource lull would be discovered. 

There are three issues.  Firstly, resource planning for the gap is necessary to ensure adequate resources are available to cover the gap.  Secondly, weather variability means that whatever period of analysis is used there always is a chance that a more severe resource drought will occur.  Finally, the DEFR projected need is large and expensive.  The unaddressed issue is the tradeoff between the planning horizon and the resources needed.  I cannot imagine a business case for the deployment of resources to address for a resource that is needed for a reliability event greater than the expected lifetime of the resource.  Consequently, there will be pressure to choose a less restrictive reliability standard even though that means that when the conditions that cause the worst-case lull inevitably occur there will be major problems.

This risk goes away if nuclear resources are used as the backbone of the future electric system.  Given the magnitude of the potential problems when renewable resources are unable to provide reliable power for the extreme weather case, this is a major reason to rely on nuclear power for a zero-emissions electric grid.  The Staff Proposal presumes that an electric system reliant on wind, solar, and energy storage will somehow work and ignore the reliability risk described here.  My comments argued that DPS staff should address this feasibility issue as soon as possible.

Conclusion

I support the NNY comments because there are fundamental reliability risks of a wind, solar, and energy storage dependent electrical system that can be eliminated by making nuclear the primary source of electrical power.  If New York wants to decarbonize without compromising resource adequacy, reliability standards, and affordability then the only feasible solution is to rely on advanced nuclear power as the primary provider of firm generation capacity and this should be reflected in the Draft Blueprint.  At some point the electric energy experts responsible for the system must tell the politicians that the arbitrary schedule and unproven technologies of a wind, solar, and energy storage zero-emissions approach are too big a risk to reliability to continue down that path.  The Blueprint document should make that case.