Climate Leadership and Community Protection Act Generation Advisory Panel Draft Enabling Initiatives

Since mid-February the Power Generation Advisory Panel has been discussing “enabling” initiatives or strategy recommendations for the Climate Action Council.  Unfortunately, as I show in this post, there has been insufficient focus on affordability and reliability.  In this instance reliability necessarily has to incorporate feasibility because the zero-emissions energy production necessary to meet the Climate Leadership and Community Protection Act goal for a zero-emissions electric system by 2040 is unprecedented.

I have written extensively on implementation of the CLCPA closely because its implementation will affect reliability, affordability and I believe the environmental impacts will be significantly worse than doing nothing.  I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulations, listed the scoping plan strategies, summarized some of the meetings and complained that its advocates constantly confuse weather and climate.  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.

Background

The CLCPA mandated an implementation plan that specified that the Climate Action Council would get recommendations from advisory panels for the development of the Scoping Plan that outlines how the CLCPA goals will be met.  The law specified that membership should represent individuals with direct involvement or expertise in matters to be addressed by the advisory panels.  The panels have been drafting enabling initiatives and discussing them in open meetings since the beginning of the year.

However, the law did not specify the topics that panels should address in the recommendations to the Council.  That is the first problem with this panel.  I believe that this is the most important panel because in order to meet the CLCPA targets electrification of everything is necessary.  The only way to electrify everything is to generate that power with zero-emissions.  Unfortunately, that is an enormous technical challenge and, frankly, most of the members of this panel don’t have the necessary direct involvement or expertise to appreciate the problem and I have seen little suggestion that some of the more vocal members have attempted to understand them.  As a result, the draft initiatives are disappointing.

The Power Generation Advisory Panel meetings since the middle of February have been discussing their draft initiatives.  The draft initiatives are discussed in the meeting materials and are available:

February 12, 2021

February 22, 2021

March 10, 2021

Discussion

There is a standard format for the discussion presentation slides.  The first slide includes a description of the initiative with an estimate of cost and ease of implementation.  Risks and barriers to success as well as possible mitigating factors are also listed.  The second slide presents components of the initiative including the entity responsible for completion, schedule, and stakeholders that have to be included.  On the final slide, the anticipated benefits and impacts are presented.  Note, however, that the focus in the final slide is on justification of the initiative as its topics cover disadvantaged communities, health and co-benefits, and transitional effects on businesses, industries and workers.  In my opinion this focus is mis-placed because the slide does not specifically address affordability, reliability, and feasibility.

The CLCPA Power Generation Advisory Panel Enabling Strategy Initiatives Summary table lists 15 different initiatives for possible recommendations.  At the time of this writing ten of the initiatives have been discussed.  I assume that the remaining initiatives will be discussed at upcoming meetings.

As noted previously, I am disappointed with the initiative topics addressed by the panel.  Given that no jurisdiction anywhere has actually implemented a zero-emissions electricity generating system I believe that the emphasis of this advisory panel should be on initiatives that enable or implement zero-emissions generation and the necessary supporting infrastructure including transmission necessary to deliver the power generated when and where needed.  I have categorized the initiatives in the CLCPA Power Generation Advisory Panel Enabling Strategy Focus of the Initiatives Summary table. Enabling generation initiatives should address the technological challenges for various aspects of the components needed to provide 100% zero-emissions electricity generation.   Note that at the last meeting two additional components were presented for the first initiative, Technology Solutions.  That means that five of the fifteen initiatives address this challenge. They include storage technologies, distributed generation, and advanced fuels.  The initiative with the most components was technology solutions.  I think it would have been appropriate to divvy that up into several specific initiatives rather than have so many components.

It is not enough to just have the generation technology available.  It has to be implemented.  For example, because the electrical generation market in New York is de-regulated, market mechanisms to provide the necessary resources have to be developed.  The other initiatives address siting, development concerns, and transmission delivery.

In my opinion the fundamental implementation criteria should be reliability and affordability.  Because each initiative did not explicitly address those factors, I agree that the Access and Affordability for All and the Reliability for the future grid initiatives should be included.

Those eleven initiatives, especially because the technology solutions initiative could easily be separated into other initiatives, are more than enough for this panel to tackle.  Unfortunately, a lack of focus on enabling technologies and implementation requirements by the advisory panel leadership allowed the panel to waste resources on four out of scope topics.  Workforce development is so important that there is a working group dedicated to it.  The only reason methane leakage was considered is that some members of the panel are fervently against natural gas use and want to eliminate the possibility of future use.  The other two topics, fossil fuel-fired electricity generation and electrification of buildings and transportation, have not been discussed.  In order to meet the CLCPA target fossil fuels cannot be used so the only issue is timing.  Timing should be contingent upon the availability of alternate technologies although I am not sure that is universally accepted by panel members.  There are advisory panels dedicated to both buildings and transportation so any time spent on that is duplicative and unnecessary.

The resources squandered on duplicative efforts are particularly galling because I believe that the feasibility of a zero-emissions electric system has not been adequately addressed.  I have noted previously that the lack of a comprehensive assessment of renewable resource availability for New York could be a problem. Until the availability of those resources are understood much better then we won’t know how much wind, solar and energy storage is needed for the worst case multi-day winter doldrum period.  Coupled with the fact that the current GHG emissions won’t be available until early next year, it is impossible for anyone to project what resources will be needed.  Until the Climate Action Council has that information to work with it is not possible to determine if the proposed strategies will prevent future reliability issues.

Conclusion

This overview of the generation advisory panel initiatives shows that it is not focused on affordability and reliability.  I should note that the initial discussion points did not even include reliability.  That was added but it still is treated more like an afterthought than a priority requirement.  I will follow up with another post on the reliability initiatives relative to the recent Texas energy debacle.

Unfortunately, that is not the only problem.  The initiatives also appear to me to be overly dependent upon technologies and/or fuels that ‐ at the scales that would be required ‐ are currently neither proven nor economic.  It is not clear from the discussions that all the panel members recognize those technical limitations.  The CLCPA law specified that panel membership should include individuals with direct involvement or expertise in matters to be addressed by the advisory panels but the Cuomo Administration chose members based more on who they knew than what they know.  The energy system of the state is too important to be left to idealogues who don’t understand the technology and physics of the electric system so I am really worried how this will play out.

Texas Lessons to Keep the Lights On Dangers

On March 14, 2021 the Syracuse Post Standard published a commentary “To keep the lights on, take these lessons from Texas” by Dr. David Murphy, an associate professor of environmental studies at St. Lawrence University.  Unfortunately, most of what he said is incorrect and what he proposed will guarantee that New York’s lights will go out.

Unsaid in the commentary is that much of what Dr. Murphy proposed is being incorporated into the implementation plans for the Climate Leadership and Community Protection Act (CLCPA).  I have summarized the schedule, implementation components, and provide links to the legislation itself at CLCPA Summary Implementation Requirements.  I have written extensively in long posts on implementation of the CLCPA because I believe that it will negatively affect reliability, affordability and the environment.  I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulations, listed the scoping plan strategies, summarized some of the meetings and complained that its advocates constantly confuse weather and climate.  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.

Dr. Murphy has a Ph.D. in Environmental Science and Master of Science in Environmental Science, State University of New York, College of Environmental Science and Forestry, Syracuse, NY and Bachelor of Arts in Biology, The College of the Holy Cross, Worcester, MA.  He has authored a textbook Renewable Energy in the 21st Century and according to his webpage at St. Lawrence University, he “has also published widely in the popular press.”  Note in particular that “has been featured on a number of episodes of the podcast The Energy Transition Show with Chris Nelder, a popular podcast in energy technology and climate change activist circles.”  Based on this I characterize Dr. Murphy as a professional climate change activist whose career depends on the narrative that climate change is an existential threat.

To keep the lights on, we should take these lessons from Texas

In the following section I will provide my italicized and indented comments on his commentary.  For a detailed overview of the Texas deep freeze I recommend this article by Weather Blogger Chris Martz.  He explains that Arctic cold weather events have occur regularly, the weather conditions associated with these events always include high pressures with very light winds so wind resources will always stop working, and that “to blame weather events that have occurred many times before on man-made climate change is absurd”.

 The tragedy in Texas is viewed by many as another glimpse of our uncertain future, and that brings up the question of whether it is possible to be prepared for scenarios we can’t even imagine in the new, climate-changing world.

In climate change activist circles any unusual weather is due to climate change.  Martz points out that cold waves are an expression of natural atmospheric variability and result in record cold temperature.  This was a record-breaking event.  He goes on to point out that the earth is warming and that the “frequency of cold waves, the number of record low temperatures, and the percent of land area observing unusually cold temperatures have all declined over the last century”.  Nonetheless, the important point is that similar cold snaps occurred in 2011, 1991, 1990, 1989, 1983, 1963, and 1961 and electrical outages occurred in some of those cold snaps.  The real question is whether Texas adequately planned for the past, not whether we can plan for an uncertain future.

The storm wreaked havoc on almost all major power-producing technologies. A nuclear generator supplying electricity to 1 million homes tripped off-line due to the cold weather impacting a pump system. Natural gas supplies for heating homes froze up. And wind turbines froze in place. The more climate changes, the harder it will be to predict, and outages like the one in Texas are all but guaranteed. The Biden administration must develop a resilient power grid where outages impact fewer people for less time. To build a resilient grid, we should focus on redundancy and decentralization.

This was not a climate change problem.  Instead, it was poor planning for a variety of reasons and, in my opinion, something similar is not likely in New York because the New York electric market has different rules and priorities.  However, given that New York’s CLCPA mandates a transition to zero-emissions electric sources the question becomes is this more likely in the future?  I agree with Dr. Murphy when he says we should focus on redundancy to prevent something similar in the future but disagree what counts as valuable redundancy.  I see no value in de-centralization.

Redundancy means that if there is a failure in one part of the system, another can perform that same task, avoiding a large-scale outage or an outage altogether. Slightly more than half of Texas’ electric grid relies on one fuel source — natural gas —and another quarter relies on wind.

Compared to Texas New York currently has a more redundant electric system because there are more options for generating electricity and used to be much more redundant.  In 2019, New York electricity was generated 38% by natural gas, 23% by hydro, 33% by nuclear, 3% by wind and solar and 2% by other sources.  In 2001, New York electricity was generated 16% by coal, 27% by natural gas, 11% by oil, 16% by hydro, 28% by nuclear, 0% by wind and solar and 2% by other sources.  One key aspect of redundancy is the ability to store fuel on-site which is a feature of coal, oil, hydro and nuclear.  All three fuels are used much less than in 2001.  It is also important to be able to transport the fuel different ways which is another feature of coal and oil that has disappeared.  Based on these trends New York electric generation is becoming less redundant and thus more likely to have blackouts.

Microgrids, small grids within a larger system, are another form of redundancy. Microgrids can operate in “island mode” — if the larger grid is collapsing, the microgrid shuts communication and operates alone, keeping lights on. Alaska —with expansive land and isolated populations — has a number of microgrids. The Longhorn State has few.  Decentralizing power production systems also is important. When one reactor at the South Texas Nuclear Power Station went offline due to the cold temperature, power to supply 1 million homes went off-line. This makes entire cities, not just small towns, vulnerable.  We need many microgrids using many energy sources, both large and small — and by small I mean as small as rooftop solar panels and battery storage systems.

 De-centralized microgrids powered by wind and solar are a climate activist talking point but I don’t believe they stand up to scrutiny.  While it is true that a microgrid can operate without being connected to the grid the question is whether the factors that caused the grid to collapse also affect the microgrid.  In the case of extreme weather events, damage to microgrids powered by wind and solar is also likely. 

 The bigger problem is whether a microgrid can provide necessary power when and for as long as it is needed. Murphy neglects to point out that the Alaskan micro-grids are powered by fossil fuels that can be stored on-site.  His vision is for micro-grids powered by wind and solar.  Martz points out that energy demand is highest during both periods of extreme cold and extreme heat and that such weather conditions are associated with high pressure and very light wind speeds, which means, wind turbines will stop working.  Coupled with the fact that New York solar radiation is reduced by day length, cloudy conditions, and snow cover, I am very leery that sufficient renewable energy resources are available to meet the demands of winter peak load.

 In order to meet New York’s climate law goals heating and transportation will have to be electrified.  As a result, even more electricity will be needed.  Because renewable energy is intermittent, energy storage is required. This is a particular problem because demand varies and when the demand is highest it is also needed most.  Murphy’s rooftop solar panels and battery storage system approach may work most of the time but in order to provide reliability during the coldest periods the amount of energy storage needed for one or two days a year may be uneconomic.  This is precisely what happened in Texas.  Ratepayers enjoyed low rates because the electric market did not incorporate a mechanism for generators to pay for measures that would ensure they could provide power during intense cold snaps.  When the record-breaking cold weather occurred, the system could not provide the necessary energy at any cost so the system broke down.

All this requires a paradigm shift in thinking. For the past century, we have built grids that take what energy guru Amory Lovins calls the “hard energy path.” This means building big, centralized generators that produce massive amounts of electricity in a one-way grid system to deliver power to customers.  We need a 21st century version of Lovins’ “soft energy path” that focuses on energy conservation, solar and wind power. These technologies, in contrast to huge nuclear generators, are smaller and more flexible. And, since many more will be needed and spread across the country, they will be much less prone to massive outages like that in Texas.

Climate activists love to disparage the current electrical system with its centralized generating stations but the fact is that they provide affordable and reliable electricity.  There are inherent economies of scale that enable large power plants to provide power for millions cheaply and efficiently.  Moreover, different types of fuels at these power plants truly provide a redundant and flexible power system that can provide reliable electricity when needed.  In contrast wind and solar power which are utterly dependent upon the vagaries of weather cannot be called flexible and certainly are not dependable without additional energy storage and grid support services that markedly increase the cost.  The claim that wind and solar are less prone to massive outages is absurd given that every night with calm winds causes an outage of both of these generating resources. Furthermore, he point out that “many more will be needed and spread across the country” means that wind turbines and solar panels will sprawl across New York with significant  impacts to birds and bats.

The Biden plan calls for a modern grid system, but details are unclear. The Green Act of 2020 introduced in the House doesn’t address grids. If we want to avoid crises, the plan must include redundancy and decentralization. We must encourage more people to produce their own energy.  Investing in local production and ownership of energy systems makes energy systems more resilient and creates jobs.

One climate alarmist cherished belief is that because the wind is always blowing somewhere the solution to local wind calms is a transmission system that can move the power from those locations to calm locations.  There are problems however. 

 The fundamental issue for keeping the lights on is that wind is intermittent.  I found that in New York in 2018 there were 1,982 MW of onshore wind energy nameplate capacity that generated 3,985 GWh of electrical energy for a state-wide annual capacity factor of 24.5%.  The problem is that I also found that over a sixteen-month period there were 25 hours when none of the 24 wind facilities in the state produced any power, that 36% of the time less than 200 MW per hour was produced and that half the time hourly wind output was less than 324 MW.  The worst case is a long duration period with light winds. I found 12 periods when less than 100 MW of the state’s total wind capacity of 1,982 MW was available for 24 hours, 5 periods for 36 hours, and one period of 58 hours. Evaluation of wind energy on continental scales in Australia shows that large high pressure systems can cause light winds over continental scales.  The grid solution to intermittency is fatally flawed.

 New York’s worst case wind energy deficit was 58 hours long when wind output was less than 100MW meaning that in order to replace the total onshore wind capacity 1,800 MW has to be generated elsewhere and transmitted to New York.  In order to be absolutely positive that amount of power is available, dedicated renewable resources someplace where the winds are guaranteed to not also be calm are required.  In other words, both the wind turbines and the transmission capacity necessary cannot be used for anything else.  I expect that would be uneconomic.   Alternatively, energy storage could be developed but the problem is there is no long-duration energy storage technology currently available that can be deployed in the necessary quantities.

 It is not clear to me how wind and solar resources can be considered redundant.  Putting all our energy production into two limited types of intermittent resources seems anything but redundant and given their susceptibility to weather impacts it certainly is not a resilient option..

Clean energy jobs account for roughly 40% of energy sector jobs in the U.S., and according to a Brookings Institution report, they are also better paying than most jobs across the country.

While I am not sure that I reviewed the Brookings Institution report referenced, I suspect that the Brookings report Advancing Inclusion through Clean Energy Jobs has the same biases are present in all their work.  I believe the appropriate jobs metric limits clean energy jobs to those that would not exist in the absence of clean energy initiatives.  However, the Brookings definition of clean energy jobs encompasses jobs that go well beyond the work necessary for a clean energy economy.  For example, in the environmental management sector they include hazardous materials removal workers, refuse and recyclable material collectors, and septic tank servicers and sewer pipe cleaners.  Consequently, they are taking credit for “clean energy” jobs that would exist anyway which makes the claim that 40% of the jobs in the energy sector are in clean energy exaggerated.

By encouraging individuals and local communities to produce their own energy, we will also increase energy democracy, so that not just the downtown, wealthy areas remain with power while the poorer neighborhoods experience outages, such as what happened in Texas. We can’t predict the future, and outages will continue to occur, we can only hope to minimize their impact, and focusing on a resilient future is the only path to do so.

The presumption that individuals have the desire and means to produce their own energy is a great theory but in practice I suspect most people have a greater desire for affordable and reliable electricity. Until it is demonstrated that investing in the capability to provide reliable power as proposed when I need it is cheaper than current costs, I suspect that I am not the only skeptic of the economics of this approach.  As to viability my roof line runs north-south so I do not have the optimal setup for solar panels and I live in the cloud and snow belt downwind of Lake Ontario so solar is not dependable in the winter.

 Energy democracy is a slogan long on emotion but short on content.  I don’t understand what is meant by energy democracy or the basis of the argument so I cannot respond.

 The Texas lesson should be that they did not develop an electric market that rewarded development of infrastructure to withstand cold temperatures that have been observed in the past.  My concern is that while community energy approach may work most of the time there will be times, likely when the power is needed the most, that it won’t work.  Any resources diverted to this aspirational, feel-good approach reduce what is available to a solution that provides power all the time. 

 The other Texas warning should be the pitfalls of an over-dependence upon wind energy.  The coldest air of the winter and the highest demand occurs when cold air moves in behind a cold front.  This Arctic air is associated with a cold core high pressure system pushing the front.  Those high pressure systems have very little wind.  Martz nailed it when he said “When it comes to a life and death situation, what would you do? Use fossil fuels to keep warm and survive, or freeze yourself to death once wind power fails in order to save the planet?”

Conclusion

Dr. Murphy concludes that “We can’t predict the future, and outages will continue to occur, we can only hope to minimize their impact, and focusing on a resilient future is the only path to do so.”  The real cause of the Texas energy debacle was to fail to address obvious impacts associated with observed cold weather outbreaks in the winter.  Our first priority should be to plan for the future based on what has happened in the past because if we cannot do that then there is no way we can plan for future changes.

His recommendation is to build a resilient grid which focuses on redundancy and decentralization.  A redundant electric system exceeds what is normally needed and necessary for as wide a range of conditions as possible.  It is unclear how solar energy that is only available half the time, is reduced when it is cloudy, and can go to zero when panels are covered with snow can be considered redundant.  His suggested approach relies on energy conservation, solar and wind power and that might work most of the time.  Unfortunately, an electric system that fails to provide power when it is needed most is a recipe for catastrophe, just like Texas.

Energy conservation is a no regrets approach but it is naïve to expect that energy loads won’t continue to peak and grow when the weather is very cold or very hot, especially when New York’s CLCPA mandates heating electrification.  When the electric system transitions to solar and wind power, the critical weather period will be a multi-day wind lull in the winter because both wind and solar energy availability is very low.   In order to provide power during those periods for Murphy’s de-centralized large energy sources and rooftop solar panels, the energy storage systems necessary for them to be independent of the centralized system will have to be large.  I expect that installing large batteries for short periods of the year will be uneconomic.  Advocates for this approach have to prove otherwise.

Like it or not New York is rushing ahead to incorporate the themes in Dr. Murphy’s commentary in the implementation plans for the CLCPA.  It cannot be over-emphasized that these concepts have not been implemented anywhere on the scale necessary to transition the New York electric grid.  Moreover, initial attempts in other jurisdictions have shown that costs have gone up and reliability has gone down.  The real lessons of the Texas energy debacle should be caution is needed, that reliance on intermittent resources is risky, and that failure will have catastrophic impacts.

 

New York Value of Carbon Calculation of Benefits Issue

I have been trying to get involved and stay involved in the Climate Leadership and Community Protection Act (CLCPA) implementation process over the past year.  There are many pieces and parts to this process so keeping track of everything much less providing comments is difficult for stakeholders and New York agency staff.  I readily admit that agency staff also have a challenge keeping track of all the components and deciding priorities for what needs to be addressed and when.  This post documents one particular issue that I have raised and the lack of response.

I have written extensively on implementation of the CLCPA closely because its implementation affects my future as a New Yorker.  I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulations, listed the scoping plan strategies, summarized some of the meetings and complained that its advocates constantly confuse weather and climate.  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.

Background

One key component is the New York State guidance document Establishing a Value of Carbon, Guidelines for Use by State Agencies (the “Guidance”).  My particular concern is that the Guidance includes a recommendation how to estimate emission reduction benefits for the strategies that will be used to justify costs.  I believe that the guidance approach is wrong because it applies the social cost multiple times for an emission reduction.  As documented earlier, I sent an email to the DEC Climate Office explaining that the example they used to estimate emission reduction benefits claims that the value of carbon should be calculated for each year.  However, the standard damages approach value is the net present benefit of reducing carbon dioxide emissions by one ton because the calculation methodology estimates benefits out to 2300.  It is incorrect to claim credits for those benefits more than once.

I did not get any response for a couple of weeks and so I mentioned it as part of the article’s description of a general lack of responsiveness to comments on the CLCPA.  Soon after publishing the article I did get a response.  Dr. Suzanne Hagel said that it was “really useful” and that it would be raised with others as they “develop the accounting for the Scoping Plan”.  She went on to say that “I expect that we will be making additional updates to the Value of Carbon guidance and this would be one update that could be addressed”.

Problems

On February 26, 2021 the integration analysis technical resources that will be used to develop the scoping plan for the CLCPA were updated:

They describe the inputs and assumptions for the economy wide analysis of energy supply, energy demand and other aspects of the economy affected by the CLCPA.   My problem is that in the following Cost Accounting Philosophy from the Draft Inputs and Assumptions Summary it notes that “Value of avoided GHG emissions will be calculated based on guidance developed by DEC”. 

My concern is that if the error I identified is not corrected then the integration analysis work will have to be revised.  It is better to get this cleared up sooner rather than later so I sent an email suggesting that this issue should be addressed now.  After waiting two weeks for a response, I prepared this article.

Since the time I sent the email I found another report that uses the guidance as written, that is to say wrong.  A new report “The Fossil Fuel End Game, A frontline vision to retire New York City’s peaker plants by 2030” is “the first detailed strategic and policy road map to retire and replace an entire city’s fossil-fuel peaker power plants”. The report also “highlights the alarming economic, environmental, and social costs of New York City’s existing peaker plants”.  Those calculated costs use the Value of Carbon guidance as published and incorrectly claim social benefits every year for the carbon dioxide reductions proposed.  Over 88% of the purported economic impact of peaker plants in New York City is accounted for by the incorrect emission reduction benefits methodology.

Discussion

In my experience if I find something directly contradicting regulatory guidance, I get second opinions.  In this case, I documented contact with Dr. Richard Tol, Professor of the Economics of Climate Change at Vrije Universiteit Amsterdam and a Professor of Economics at the University of Sussex who has direct experience estimating the value of carbon or social cost of carbon (SCC).  He graciously responded and explained that “The SCC should not be compared to life-time savings or life-time costs (unless the project life is one year).”  I also checked with colleagues who supported my arguments.  I have not mentioned it to DEC but I even went so far as to contact an acquaintance at Resources for the Future about the recommended methodology and after a couple of email exchanges he also agreed that, in this context, it is incorrect to claim GHG emission reduction credits annually.  My point is that I am confident that the proposed methodology is incorrect and must be changed.

Conclusion

I would like to think that all the work I do to provide meaningful comments is appreciated by agency staff.  One way to show that appreciation would be to acknowledge receipt of comments and respond to the issue raised if there is a time sensitivity.  Unquestionably, in many cases the response is likely to be thank you but we disagree.  As long as the record shows my comment and their response explaining why they disagree the public stakeholder process is working.

Once in a while however a real problem is identified.  It is disappointing and not in the best interests of the stakeholders when problems are not addressed in a timely fashion.  In this instance this issue needs to be resolved sooner rather than later so that the consultants responsible for the integration analysis don’t end up having to re-do analyses and documentation so there is a time sensitivity concern.  In addition, every analysis that incorporates the incorrect guidance includes an error that reduces the credibility of the analysis and could affect the recommendations.  Hopefully I will be able to update this post soon to note that the issue has been addressed.

Climate Leadership and Community Protection Act Unpublished Letter to the Editor of the Syracuse Post Standard

New York’s Climate Leadership and Community Protection Act (CLCPA) establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency.  The subject of this post is an unpublished letter to the editor of the Syracuse Post Standard.

The CLCPA was described as the most ambitious and comprehensive climate and clean energy legislation in the country when Cuomo signed the legislation but there is one massive flaw.  The lawmakers who enacted this law presumed that the transition of the state’s energy system could be implemented by political will so did not include feasibility conditions in the targets or schedules.  As a result, I believe the reliability and affordability of electricity will be affected.

I have summarized the schedule, implementation components, and provide links to the legislation itself at CLCPA Summary Implementation Requirements.  I have written extensively in long posts on implementation of the CLCPA because its implementation affects my future as a New Yorker.  I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulations, listed the scoping plan strategies, summarized some of the meetings and complained that its advocates constantly confuse weather and climate.  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.

Background

The CLCPA is going to radically change New York’s energy use in order to reach net-zero greenhouse gas emissions by 2050.  Over the past year, the implementation process has started and I am convinced that most New Yorkers have no clue what is coming so I have been trying to get the local newspaper to print a letter to the editor.

Last fall I submitted a couple of letters specifically arguing that it should be a consideration when voting.  In early January I sent the following commentary, a longer letter to the editor, to the Syracuse Post Standard describing what is coming in an effort to get more people aware of the law.  In my cover letter I offered to discuss the law with the editorial board.  Around the same time, the newspaper sent out an email asking for reader input.  I responded to that too.  The answer in all cases was crickets.

Hyperlinked Submittal – The following is a hyperlinked version of my submittal

New York’s Climate Leadership and Community Protection Act (CLCPA) became effective this year and the implementation process has started. Political appointees on the Climate Action Council and seven advisory panels are currently developing a scoping plan that outlines strategies for attaining the statewide greenhouse gas emissions targets of a 40% reduction of 1990 emissions by 2030 and a zero-emission electric sector by 2040.  The Department of Environmental Conservation (DEC) implemented two regulations supporting the CLCPA implementation late last year.

Only now is it becoming clear what this will mean to the residents of New York but I believe most people have no idea what is coming.  If you are worried about energy affordability and reliability, I recommend that you pay attention in the next several months as the plans to electrify as much of the economy as possible using mostly solar and wind are presented.

DEC implemented a rule setting the 1990 baseline and established a value of greenhouse gas emissions.  Following the precedent set by the CLCPA, the rules follow methodologies established by the Intergovernmental Panel on Climate Change (IPCC) where convenient but veer away when doing so suits the agenda.  In particular, the law and these rules intend to eliminate the use of fossil fuels as soon as possible.  When you hear the phrase no new fossil fuel infrastructure that means you won’t be able to buy gasoline or diesel vehicles by 2035 or heat your homes and water or cook with natural gas, oil, or propane in the same time frame.

By the end of 2024, DEC will promulgate rules and regulations to ensure compliance with the CLCPA targets.  Great Britain has similar targets and has proposed bans on fossil fuel heating systems in 2033 thereby mandating electrifying heating.  There also is a recommendation that properties cannot be sold unless they meet minimum energy efficiency standards in 2028.  To ensure compliance New York will have to do something similar.  Having lived through a couple of multi-day electric blackouts I am very leery about having to depend upon electricity to heat my home.  Despite significant investments in insulation and upgraded windows, my house is still uncomfortable at times during the winter.  I don’t think an electric heat pump is going to be able to adequately heat my home.

You will be told that this will be cost effective because it reduces the negative costs of climate change as established by their value of carbon guidance.  You probably won’t hear that the purported social benefits are based on impacts projected out to 2300, the benefits will accrue almost entirely outside of New York, and that even those benefits are highly dependent upon the assumptions made.  In every instance the values chosen maximize the alleged benefits to reduce carbon emissions.

You might hear that the State has done a wonderful job investing the proceeds from the existing Regional Greenhouse Gas Initiative program that already taxes your electricity.  You won’t hear that New York has the highest administrative costs of any state in the program and you won’t hear that the overall costs per ton reduced exceed the value of carbon benefits.  I am positive you won’t be told that after New York makes all those reductions that the global temperature will be reduced by less than the average temperature between your head and your feet.

I recommend Bjorn Lomborg’s recent book “False Alarm: How Climate Change Panic Costs Us Trillions, Hurts the Poor, and Fails to Fix the Planet”.  He shows that we are committing to try to solve climate change with policies that he demonstrates will not make much of a difference but will cost a lot and not do much to change global warming.  Moreover, “Our extraordinary focus on climate also means we have less time, money and attention to spend on other problems” and lists a host of ways the time and money could be better spent.  All his lessons are relevant to New York.

I am sure everyone agrees that if we could ensure better weather that we would be willing to spend more on energy, accept some inconveniences, and agree to fewer choices for energy systems.  However, the CLCPA will not solve global warming if only because the increases in emissions in developing countries are far greater than reductions we can meet.  How much people are willing to pay to try to set an example is a personal choice but many people are already having trouble paying for energy so this law must make affordability a primary condition.  Despite the claims of the renewable energy developers there are serious issues using solar and wind during a multi-day, light wind period in New York’s winters.  Finally, New York’s record for greenhouse gas emission reductions is not cost-effective relative to their benefits standard.  This all means that New York might better invest money in adapting to extreme weather, improving energy efficiency, and researching alternatives to fossil fuels that could bring down the costs.

Conclusion

I am disappointed that the Syracuse Post Standard chose to not publish this.  I think New Yorkers should be aware of the potential impact of the CLCPA on affordability and reliability as I outlines in this commentary.   None of the advisory panel strategies have included potential costs but I have no doubts that the costs will be extraordinary.  Keep in mind that all this was written before the Texas Energy Debacle showed what can happen if reliability is not adequately addressed.  I wrote that I don’t think something similar could happen in New York but I also am worried that serious challenges must be overcome to make a reliable system sufficiently robust to meet a similar extreme weather event and that meets the CLCPA mandates.

I encourage New York readers to follow the CLCPA and get involved.

Announcing the Pragmatic Environmentalist of New York Facebook Page

In response to suggestions from people that I respect, I am going to publicize articles that are of general interest on my Pragmatic Environmentalist of New York blog.  People need to be made aware of the implications of New York energy and environmental policy.  This article announces this initiative and serves as a test of the methodology.

Disclaimer

I am a retired electric utility meteorologist with nearly 40 years-experience analyzing the effects of meteorology on environmental impacts.  Over that time, I have dealt with a wide range of environmental issues and researched many relevant topics to New York’s environmental and energy sectors.  The opinions expressed in my blog articles do not reflect the position of any of my previous employers or any other company I have been associated with, the comments are mine alone.

My blog describes environmental issues from a pragmatic viewpoint.  Pragmatic environmentalism is all about balancing the risks and benefits of both sides of issues.  Unfortunately, public perception is too often driven by scary one-sided stories that have to be rebutted by getting into details.  This blog will attempt to show the side of environmental issues that gets overlooked too often. My background as a scientist and my responsibilities to provide technical comments on new or revised regulations means that I tend to get bogged down in technical details that are, too be kind, pretty wonky.  I will not announce all the articles that I publish but will alert interested people on topics of general interest that do not delve into all the technical details.

Recent Posts of Interest

The following recent posts would have been announced on the Facebook page if it had been set up.  The Climate Leadership and Community Protection Act (CLCPA)

PEONY Organization

Posts on the Pragmatic Environmentalist of New York blog are classified into different categories as summarized below.  Clicking on the link in each category will take you to all relevant posts in that category.

Pragmatic Environmentalist of New York Principles

Pragmatic environmentalism balances environmental impact and public policy risks and costs.  I believe that pragmatic environmentalism is exemplified by these principles.

RGGI Posts

This page lists my posts on the Regional Greenhouse Gas Initiative (RGGI).   I have been involved in the RGGI program process since its inception and I blog about the details of the RGGI program because very few seem to want to provide any criticisms of the program.  Before retirement from a non-regulated generating company, I was actively analyzing air quality regulations that could affect company operations and was responsible for the emissions data used for compliance.  As a result, I have a niche understanding of the information necessary to critique RGGI.

New York Climate Leadership and Community Protection Act

In July 2019 Governor Cuomo signed the Climate Leadership and Community Protection Act which is described as the “most aggressive climate law in the United States”.   This is a huge effort and will affect every New Yorker but I don’t think many people are aware of its existence much less its potential impacts.  The following posts describe various aspects of the law.

CLCPA Overview

These posts generally describe the CLCPA and its benefits.

CLCPA Feasibility

This law does not provide for an analysis to determine if it can be implemented affordably and with no impact on reliability.  Suffice to say that the lack of a feasibility study before picking the emission reduction and renewable energy targets makes for a target rich environment.

CLCPA Costs

This page summarizes the results of my calculations of the observed costs of the environmental initiatives of New York Governor Andrew Cuomo in general and the Climate Leadership and Community Protection Act in particular.  I also provide links to estimates by others outside the Administration as I find them.

CLCPA Supporting Regulations

The CLCPA mandates regulations to support the implementation of the law.  This page provides links to my posts on those regulations.

CLCPA Scoping Plan Strategies

This page describes the implementation strategies proposed by the Climate Action Council advisory panels.

CLCPA Weather vs. Climate

The difference between weather and climate is constantly mistaken by Climate Leadership and Community Protection Act (CLCPA) advocates.  This page references my evaluations of climatic effects that turned out to be weather events and examples by other authors.

CLCPA Meeting Summaries

This page provides links to Climate Action Council and advisory panel meetings.

CLCPA Comments Submitted

This page provides links to the comments I submitted.

Accelerated Energy Growth and Community Benefit Act

This legislation provides expedited permitting for CLCPA renewable energy developments.

NYS Carbon Pricing Initiative Page

The New York Independent System Operator (NYISO) has been evaluating a carbon pricing plan for New York’s electricity market.  This page covers that initiative and other similar proposals.  My background with trading programs and the electric industry has prompted me to delve into the details of this plan.

New York Energy Policy

There is a movement underway to transform the New York State electric energy system because we have to do something about climate change.  I am motivated to prepare blog posts on this topic so that there is at least one voice of the unaffiliated public whose primary interest is keeping the electric energy system as resilient and affordable as it is currently.

New York State Environmental Policy

New York environmental policy is too often driven by ideology and not science.  These posts address example policies that are not a pragmatic balance of risks and benefits.

Global Warming

As a meteorologist I have the background, education and experience to have what I think is a learned opinion on the risk of global warming.  These posts address the science of global warming.

Transportation and Climate Page

This page lists posts on transportation initiatives related to climate including those published at Watts Up with That.

Personal Comment Submittals

This page lists posts on this blog that describe and archive my public submittals to various regulatory agencies.

 Air Quality

My niche experience is air quality meteorology.  These posts address particular topics in that realm.

Reforming the Energy Vision

New York energy policy is too often about style rather than substance.  Reforming the Energy Vision (REV) is the Cuomo label for clean and green energy policies.  In 2018 I started a blog to address specific REV topics but the fast-changing political label game has mixed these efforts up with the CLCPA.  This category link is to my other blog.

New York Green New Deal Page

On January 15, 2019 New York State Governor Andrew M. Cuomo did his State of the State Address that included his version of the Green New Deal environmental agenda.  Incredibly, in July 2019 the NYS Legislature promulgated an even more ambitious law, the Climate Leadership and Community Protection Act, that he signed into law.  As a result, these posts are not the drivers of NY energy policy that I thought they would be.  This page is no longer being updated.

National Grid Northeast 80 by 50 Pathway

With the passage of the Climate Leadership and Community Protection Act this blatant attempt by National Grid to curry favor with the Cuomo Administration and other politicians is so passé.  Imagine only proposing to get an 80% reduction by 2050 when the race to the bottom to be the most aggressive is now set at 85% with 15% offsets – the 100% target.  These posts describe this effort but it is no longer being updated because it so old school to only get an 80% reduction.

Conclusion

Stay tuned and if my articles are of interest please consider sharing them with others.

Climate Leadership and Community Protection Act: NYISO Resilience Study and the Texas Energy Debacle – Reliability Resources

I recently wrote that the energy debacle that occurred in Texas is unlikely in New York today because of market and system differences but if the Climate Leadership and Community Protection Act (CLCPA) is implemented incorrectly something similar is inevitable.  This is the second post reviewing the Analysis Group Climate Change Impact and Resilience Study (“Resilience Study”) prepared for the New York Independent System Operator (NYISO) relative to the Texas energy debacle.  The Resilience Study evaluated different resource scenarios that meet the 2040 CLCPA zero-emissions mandate for various weather and load scenarios.  The first post compared weather considerations between the recent Texas event and this study.  In this post I will compare the CLCPA power generation advisory panel strategy recommendations and Integration Analysis plans to the Resilience Study.

I have written extensively on implementation of the CLCPA closely because its implementation affects my future as a New Yorker.  I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulations, listed the scoping plan strategies, summarized some of the meetings and complained that its advocates constantly confuse weather and climate.  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.

Texas Energy Debacle

In brief, the ultimate cause of the blackouts and resulting problems in Texas was due to poor planning.  The weather in Texas during the storm was extreme but not unprecedented.  Similar cold snaps occurred in 2011, 1991, 1990, 1989, 1983, 1963, and 1961 and there were electrical outages in 2011.   Because there is no apparent trend in low daily maximum temperatures (see Tony Heller’s graph), climate change is not a factor.  This was a weather event.

Chuck DeVore explains that poor planning led to two problems that caused the blackouts but policy failures over many years were the root cause.  He states that “had every Texas generator powered by natural gas, coal, nuclear and hydro operated at full output during the height of the storm’s demand, Texas still would have experienced planned blackouts”. The policy failure that led to this situation is that “Federal and state tax policy have encouraged the overbuilding of wind, and to a lesser extent, solar power, resulting in cheap, subsidized power flooding the Texas grid” and that in turn has discouraged building new natural gas power plants and keeping existing coal and gas plants on-line.  Clearly the extremely cold weather did reduce wind turbine output and it also affected fossil and nuclear output.  The more worrisome problem for me is that as ERCOT struggled to keep the lights on, “the grid became unstable, tripping additional power plants offline to protect their massive generators from destructive interaction with a fluctuating line frequency”.  This appears to have been largely caused by large fluctuations in wind output.   “As ERCOT issued the order to start load shedding – rotating blackouts – some of the darkened circuits included vital oil and gas infrastructure. This uncoordinated move starved natural gas power plants of their fuel – leading to a further loss of power and the widespread and incorrect rumor that wellhead and pipeline freeze off contributed to the disaster.”

Clearly the Texas electricity market failed to provide adequate resiliency for these conditions.  I agree with Becky Klein, former commissioner and chairman of the Public Utility Commission of Texas who writes that the questions that need to be considered now are:

      • Are we prepared to pay more for electricity and water to ensure higher levels of reliability?
      • And if so, how much more?
      • How can we be better prepared for “outlier” events, regardless of their probability?
      • Would it make sense to require state-wide scenario planning that includes coordinated drills that test both our operational and communication capabilities across multiple entities?

As New York transitions its electric system to one dependent upon renewables all of these questions need to be addressed.  Fortunately, the NYISO Climate Change Impact and Resilience Study lays the foundation to start to address those questions in New York.

New York Reliability Planning

According to the 2020 NYISO Reliability Needs Assessment: “The New York system is deemed to have sufficient resources if the probability of an unplanned disconnection of firm load (loss of load expectation, or “LOLE”) is equal to or less than the standard of once in every 10 years or 0.1 events per year.”  In my previous post I explained that if reliability needs are identified the ultimate output of the NYISO reliability planning process is to ascertain the amount and location of compensatory MW required for the New York Control Area NYCA to eliminate the reliability problem.  The post then looked at whether this planning process adequately protects New Yorkers from blackouts similar to Texas.  I concluded that the current system offers protection but could not draw a conclusion for the future because NYISO could only guess at the resources that the CLCPA energy plan will specify.

Ultimate Problem

I have described what I believe is the ultimate problem previously.  Both E3 in their presentation to the Power Generation Advisory Panel on September 16 and the Analysis Group  in their September 10, 2020  presentation to NYISO explained that in order to meet the CLCPA emissions reduction goals that a resource category that provides firm, dispatchable and zero-emissions generation is needed.  The Analysis Group labels these resources as dispatchable and emissions‐free resources (“DE Resources”) but gives no specific examples.  On the other hand, E3 gives examples such as “such as bioenergy, synthesized fuels such as hydrogen, hydropower, carbon capture and sequestration, and nuclear generation”.  The  International Energy Agency (IEA) recently published “Special Report on Clean Energy Innovation” that classified the technology readiness level of the technologies that could possibly be both dispatchable without GHG emissions.  The bottom line is that none of the E3 examples of firm, dispatchable and zero-emissions technologies are close to being ready for adoption except nuclear and hydro which I believe are unlikely to provide any meaningful support for New York.

This post will address the CLCPA power generation advisory panel strategy recommendations relative to the Resilience Study description of the firm, dispatchable and zero-emissions resources issue.

DE Resources

The Resilience Study explained the criteria used to “establish a system that; (a) has demand consistent with the Climate Change Phase I Study, (2) has a set of resources that comply with the requirements of the CLCPA, and (3) that meets electricity demand in every hour all year.”  They went on to explain the uncertainties for these initial “starting point” resources:

      • The New York power system is currently heavily dependent on natural gas fired generating units to provide energy, to be available during high load hours, to provide critical reserves on the system, and to be able to ramp up and downs on timescales of seconds, minutes, hours, and days to manage net load variability. At least as currently configured and fueled, these resources cannot operate in 2040;
      • Even retaining existing low‐carbon (nuclear, hydro) resources, there is an enormous amount of energy and capacity needed to meet projected demand in 2040;
      • Currently‐available and reasonably economic resources available to make up the zonal and system‐wide energy deficits include solar and wind resources, yet their availability is uncertain and somewhat unpredictable. In fact, data reviewed for this report reveal that there would be long (multi‐day) “lulls” in production from these resources. This means that almost no quantity of nameplate capacity from these resources is sufficient to meet demand in all hours of the year;
      • Energy storage resources that are currently and expected to be available can fill part, but not all of the gap needed to maintain system reliability;
      • There is a void that will need to be filled with technologies and/or fuels that ‐ at the scales that would be required ‐ are currently neither proven nor economic; and
      • There is no doubt a major amount of technological change that will happen over the next twenty years, rendering it very difficult to forecast a future resource set with reasonable confidence.

On October 8, 2020 Kevin DePugh, Senior Manager for NYISO Reliability Planning, made a presentation to the Executive Committee of the New York State Reliability Council that gave an overview of the Reliability Study and emphasizes the results in the context of reliability planning.  In a post at the time I noted that his presentation listed the following characteristics of the DE resource:

      • Large quantity of DE Resource generation is needed in a small number of hours;
      • DE Resource has low capacity factor (~12%) during the winter;
      • DE Resource has only a 3.7% capacity factor in the summer;
      • DE Resource is not needed at all during spring and fall;
      • Substantial quantity of DE Resource capacity is needed, the energy need is minimal;
      • DE Resource must be able to come on line quickly, and be flexible enough to meet rapid, steep ramping need;
      • On an average day, storage can meet evening peaks, but the DE Resource must generate if storage is depleted and renewable generation is low; and
      • In the Winter CLCPA scenario, the DE Resource output across the state must increase from 362 MW (1.1% of DE Resource nameplate capacity) to27,434 MW (85.4% of name plate capacity) in six hours of the most stressed day.

Generation Advisory Panel Draft Enabling Initiatives

At the February 12 and 22, 2021 Power Generation Advisory Panel meetings seven “enabling” initiatives or strategy recommendations for the Climate Action Council were discussed.  Among the initiatives discussed were: technology solutions, market solutions, existing storage technology, long duration storage technology, and growth of large-scale renewable energy generation.  I have reviewed them and I conclude that none directly address the issues raised in the Resilience Study.  The February 12 presentation also included a list of seven other initiatives.  The only one that appears to address this issue is “reliability for the future grid”.  I will update this article if that initiative does in fact address the Resilience Study issues.

I am generally concerned with the initiatives that even are peripherally related to reliability.  My first concern is, as noted previously, the lack of a comprehensive assessment of renewable resource availability for New York. Coupled with the fact that the current GHG emissions won’t be available until early next year, it is impossible for anyone to project what resources will be needed.  Until you have something to work with it is not possible to determine if the plans will prevent future reliability issues.  The initiatives also appear to me to be overly dependent upon technologies and/or fuels that ‐ at the scales that would be required ‐ are currently neither proven nor economic.

Integration Analysis

On February 26, 2021 the integration analysis technical resources were updated:

They describe the inputs and assumptions for the economy wide analysis of energy supply, energy demand and other aspects of the economy affected by the CLCPA.  Once all the advisory panel recommendations are provided to the Climate Action Council responsible for implementing the plan to meet the CLCPA targets, this is the study that will combine the recommendations for the Scoping Plan.  I briefly reviewed the summary report to see if it addressed reliability issues relevant to this article.

Previously I mentioned that it was that there were fluctuating line frequency issues associated with the Texas blackouts.  I wrote an article recently about transmission grid ancillary services and my particular concern that no one appears to have the responsibility to incorporate this in their CLCPA planning efforts.  These services are needed to keep the transmission system from, among other things, having line frequency issues.  If this reliability concern is actually going to be explicitly considered by the integration analysis, I would think it would be mentioned. Because the word ancillary is not included in the summary and my review of the slides did not find any suggestion that this aspect was being considered I don’t think that this issue is currently in the plans for the integration analysis.

There also is no mention of a renewable energy resource evaluation.  As a result, I am not confident that the reliability issues that caused the Texas blackouts will be covered by the integration analysis.

Conclusion

The Analysis Group writes: “The variability of meteorological conditions that govern the output from wind and solar resources presents a fundamental challenge to relying on those resources to meet electricity demand.”  Because wind and solar resources are intermittent energy storage is necessary, but the Generation Advisory Panel has not yet explicitly addressed the Resilience Study conclusion that “Energy storage resources that are currently and expected to be available can fill part, but not all of the gap needed to maintain system reliability”.  Of the initiatives discussed to date, the long-duration storage initiative comes closest when it states that “Achieving the CLCPA’s high renewable energy, zero emission electricity system will require substantial amount of energy storage operating over various timescales spanning from minutes to hours, days, weeks and even longer to maintain grid flexibility and reliability.”  Note, however, that Pugh’s characteristics of the DE resource listed above (large quantity only needed for a short time) are not conducive to a business case for this resource.

The integration analysis is supposed to address all aspects of energy use in the entire New York economy.  This is a massive undertaking and necessarily will depend upon other studies for input.  Unfortunately, I could find no sign that the issues raised by the Texas blackouts will be considered.

The Resilience Study outlined significant technological challenges for a transition to a zero-emission electric sector that will maintain current reliability standards.  The Analysis Group found that no amount of solar and wind resource development is “sufficient to meet demand in all hours of the year; Energy storage resources that are currently and expected to be available can fill part, but not all of the gap needed to maintain system reliability; There is a void that will need to be filled with technologies and/or fuels that ‐ at the scales that would be required ‐ are currently neither proven nor economic; and There is no doubt a major amount of technological change that will happen over the next twenty years, rendering it very difficult to forecast a future resource set with reasonable confidence.”  Because I could not find explicit language addressing the challenges identified in CLCPA Power Generation Advisory Panel strategy recommendations and the E3 Integration Analysis summary report, I am not confident that current reliability standards will be maintained.

New York Pollution Justice Act of 2021 – What Were They Thinking?

Just when I think New York politicians cannot do anything more stupid something comes out that proves me wrong.  On March 3, 2021 the New York State Senate passed the New York Pollution Justice Act of 2021.  According to this law power plants that only run during peak periods are ripping off consumers, causing health impacts, and can be replaced with renewable energy systems.  The premise is wrong, the rationale is incorrect, and the solution is risky.  Coming so close to the Texas energy debacle any rational politician might think it would be inappropriate to try to dictate energy policy but the New York Senate majority thinks otherwise.

I am a retired electric utility meteorologist with nearly 40 years-experience analyzing the effects of meteorology on electric operations.  I have been involved with peaking power plants in particular for over 20 years both from a compliance reporting standpoint and also evaluation of impacts and options for these sources.  This background served me well analyzing this issue.  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.

Overview of the New York Pollution Justice Act of 2021

The law affects a power plant that is located within one mile of an environmental justice community and is a “Replaceable peaker plant” defined as a major electric generating facility as defined in paragraph b of subdivision one of section 19-0312  that burns coal, oil, diesel or natural gas and was operational and generated electricity less than fifteen percent of the year during at least two years between two thousand ten through two thousand  nineteen.  Such plants must be replaced by the construction and operation of a renewable energy system, battery or energy storage, or transmission and distribution infrastructure that enables the provision of the equivalent maximum annual power output achieved by the replaceable peaker.

The owner or operator of a replaceable peaker plant has to include a mandatory replacement and compliance plan with an application to renew an operating permit.  That plan has to include a proposed strategy to “replace the plant with renewable energy systems or battery storage or a combination thereof”.  A timetable for implementation of the proposed replacement strategy is required that “shall not exceed five years from the date of renewal of the operating permit and that shall ensure that the renewable energy systems and battery storage are fully operational, and the operations of the peaker plant can be completely replaced, on or before five years from the date of renewal of the operating permit”

Background

The genesis of this law is the Physicians, Scientists, and Engineers (PSE) for Healthy Energy report Opportunities for Replacing Peaker Plants with Energy Storage in New York State.  The text for the New York specific report describes the alleged problem:

“Across New York, 49 oil- and gas-fired peaker power plants and peaking units at larger plants help meet statewide peak electric demand.  These include both combustion turbines designed to ramp quickly to meet peak demand, and aging steam turbines now used infrequently to meet peak needs. More than a third of New York’s peaker plants burn primarily oil, and three-quarters are over 30 years old resulting in numerous inefficient plants with high rates of greenhouse gas and criteria pollutant emissions for every unit of electricity generated. Some of these plants are in very urban areas: ten plants have more than a million people living within three miles. One-third of the plants are located in areas the state considers to be environmental justice communities, where vulnerable populations typically already experience high levels of health and environmental burdens. New York has set energy storage targets and recently designed peaker plant emission reduction targets, providing an opportunity to replace inefficient, high-emitting peaker plants in vulnerable communities throughout the state with energy storage and solar.”

These findings were picked up on by the New York City PEAK Coalition.  They released a report in the spring of 2020 entitled: “Dirty Energy, Big Money”.  Last year I wrote three posts on this topic.   The first post provided information on the primary air quality problem associated with these facilities, the organizations behind the report, the State’s response to date, the underlying issue of environmental justice and addressed the motivation for the analysis.  The second post addressed the rationale and feasibility of the proposed plan relative to environmental effects, affordability, and reliability.  Finally, I discussed the Opportunities for Replacing Peaker Plants with Energy Storage in New York State document that provided technical information used by the PEAK Coalition.  I  summarized all three of the technical posts in simpler fashion.  Finally note that I looked at the trends of inhalable particulates in New York City relative to the claims of a dire health threat.

Statement of Findings

In this post I will address the points made in § 19-1301, Statement of findings in the text of the Pollution Justice Law.  I will list the text and follow that with italicized and indented comments.

  1. Electric generating units that generally operate during periods of peak electricity demand are known as peaker plants. Many peaker plants in the state are older fossil fuel-fired units that emit greenhouse gases and a variety of other harmful air pollutants including sulfur oxides, nitrogen oxides, particulates and mercury.

In order to identify peaking power plants PSE evaluated data from power plants across the country based on fuel type, capacity, technology and how much they ran.  This is a blunt approach that cannot address any of the nuances that have resulted in some units running for short times.  These units are typically vilified as old, inefficient, and high emitters but the PSE classification includes newer efficient units with low emission rates. There are simple cycle turbines in New York City that were built specifically to provide peaking power which have been the focus of regulatory efforts that are old, inefficient and high emitters but last year the Department of Environmental Conservation promulgated regulations to phase them out.  Large oil-fired units that run little because their fuel costs are so high are also included and the proposed legal remedy is not a cost-effective replacement for those units.

 The pollutants listed are misleading.  Greenhouse gases are emitted but there is a law specifically designed to address them.  No New York power plants burn coal so only natural gas and oil are burned and that means that mercury is not emitted at detectable levels.  There are stringent sulfur in fuel limits for oil across the state but particularly in New York City, so sulfur oxides emissions are low.  Particulate emissions from oil-firing are also low.  Natural gas emissions of particulates and sulfur oxides are essentially zero.  In my opinion then, the emissions of those pollutants are non-issues.  The New York metropolitan area is in non-attainment for ozone so the real pollutant of concern is nitrogen oxides because it is a precursor to ozone. 

  1. A substantial number of peaker plants are located in or adjacent to environmental justice communities in the city of New York and Long Island that already bear disproportionate pollution burdens due to a history of siting pollution sources in those communities. More than one million New Yorkers live within one mile of a peaker plant.

Potential environmental justice areas, based on DEC Commissioner Policy 29 on Environmental Justice and Permitting (CP-29), are U.S. Census block groups of 250 to 500 households each that, in the Census, had populations that met or exceeded at least one of the following statistical thresholds:

          1. At least 51.1% of the population in an urban area reported themselves to be members of minority groups; or
          2. At least 33.8% of the population in a rural area reported themselves to be members of minority groups; or
          3. At least 23.59% of the population in an urban or rural area had household incomes below the federal poverty level.

I closed out my career working at the NRG Oswego Harbor Power plant. It turns out that the neighborhood surrounding the plant is a potential environmental justice area. This plant has two 850 MW oil-fired boilers and because the cost of oil is usually higher than natural gas the unit does not run much.  Therefore, because this is a peaking power plant and in an environmental justice neighborhood, I believe the law applies to the plant.

  1. Pollutants from peaker plants contribute to significant public health problems. According to the New York city department of health and mental hygiene’s air pollution and the health of New Yorkers report: “each year, PM2.5 pollution in (New York City) causes more than 3,000 deaths, 2,000 hospital admissions for lung and heart conditions, and approximately 6,000 emergency department visits for asthma in children and adults.” According to the report, each year exposures to ozone concentrations above background levels cause an estimated “400 premature deaths, 850 hospitalizations for asthma and 4,500 emergency department visits for asthma.”

 The claim that there are significant public health problems is based on the New York City Department of Health and Mental Hygiene’s (DOHMH) Air Pollution and the Health of New Yorkers report.  Based on their results the report notes that: “Even a feasible, modest reduction (10%) in PM2.5 concentrations could prevent more than 300 premature deaths, 200 hospital admissions and 600 emergency department visits”.  In my analysis of New York City inhalable particulates, I found that between the time of this study and the most recent comparable three-year period the PM2.5 concentrations decreased 38%.  In order to convince me that the PM2.5 health impacts claimed by MOHDOH and this law are correct I need to see confirmation with observed data showing health improvements on the order of the claimed health impacts.

  1. Peaker plants often operate during summer months when air pollution levels are highest and their emissions add to existing pollution burdens in environmental justice communities and contribute to adverse health effects in those communities from air pollution.

There is a well-established peaking power plant problem.  In the first place, in order to provide electricity to everyone who needs it when they need it the New York Independent System Operator (NYISO) has to balance power availability with the load on the system.  NYISO is responsible not only for the real-time deliver of power but also for reliability planning.  If the load did not vary this would be much less difficult but the reality is that load varies diurnally and seasonally.  Most important is meeting demand when loads are highest in the summer and winter when it is necessary to provide electricity to maintain the health and well-being of customers. Ultimately the problem boils down to the fact that there are short periods when so much load is needed that there are units dedicated by intent or circumstances to provide just that load during the year. 

 The second driver for this issue is that the hot and humid conditions that cause the high energy use in the summer peak are also the conditions conducive to ozone formation and higher levels of PM2.5.  New York State has been working on the issue of emissions and air quality on high electric demand days specifically since at least 2006.  While there is an undeniable link between high energy demand and the high emissions that create peak ozone levels there also should be an over-riding requirement to keep the power on when it is needed most.

 The argument made here is that these peaking plants are dis-proportionally dis-advantaging the neighboring environmental justice communities.  However, the health impacts that they cite are from inhalable particulates and ozone.  Both of the these are secondary pollutants not directly emitted by power plants.  It takes time for inhalable particulates and ozone to be created by emissions from the plants and in that time the pollution has been transported away from neighboring communities.  It is simply incorrect to ascribe health impacts from these pollutants to neighborhood power plants.  Finally, claiming neighborhood impacts at Oswego is absurd because the pollutants are emitted from stacks that are 700 feet high.  It is virtually impossible for any pollutants to reach the ground in the adjacent neighborhood.

  1. The owners and operators of peaker plants have received billions of dollars in capacity payments from ratepayers over the last decade to subsidize operation of their plants, even though the plants primarily operate during peak load periods.

One of the reasons that there were blackouts in Texas during a period of peak load was that Texas does not pay for capacity.  Simply put, the politicians in Texas decided that subsidizing power plants to run when you need them most was not necessary.  New York Senators apparently agree that a power plant that makes money by providing blackout protection for consumers is such a bad thing that they are willing to risk it in New York. However, the fact that these units are paid to only operate during peak load periods is an insurance feature not a flaw.

  1. Fossil fuel-burning peaker plants can be replaced with renewable energy systems that will eliminate or significantly reduce air pollution impacts to environmental justice communities from peaker plant operations.

Renewable advocates rarely acknowledge that there are inherent advantages to fossil fuels.  At the top of the list is the fact that fossil-fired power plants can be dispatched when needed.  The Oswego power plant burns oil that is stored on-site and can operate throughout any peak load period.  Many of the other plants targeted by this legislation also store oil on-site for precisely the same reason.  In order to replace these units with renewable energy it is not enough to just build wind turbines and solar panels but enough storage has to be provided for at least a couple of days of operation.

 The 2030 Climate Leadership and Community Protection Act (CLCPA) energy storage target is 3000 MW.  Conspicuous by its absence is how many hours are associated with that figure but my guess is they are talking about 4 hours so the total is 12,000 MWh.  In order to replace just the Oswego power plant’s capability to run for say 36 hours with renewable and storage would take over half the 2030 power storage capacity goal but over five times as much energy would be needed.  In order to replace the Oswego’s peaking capability energy storage and renewable power has to be dedicated to that purpose.  It does not make economic sense to invest in that much renewable power and energy storage only to be used less than 10% of the time.

 NYISO’s reliability planning process determines if there are sufficient resources when the probability of an unplanned disconnection of firm load (loss of load expectation, or “LOLE”) is equal to or less than the standard of once in every 10 years or 0.1 events per year.”  In Texas there were seven cold snaps similar to the one that caused the outages in the last 60 years so the probability is 0.13 events per year.  The peaking power plants targeted by this legislation are part of the solution to LOLE reliability planning.  It is not clear to me what combination of solar, wind, and energy storages would be required to meet replace the peaking power plants in a multi-day winter wind lull but I am sure that the numbers would be extraordinary.  Presumably at some time the CLCPA implementation process will address this but at this time no one knows.

  1. Replacement of fossil fuel-burning peaker plants with renewable energy systems is in the public interest, will save millions of dollars in environmental and human health-related damages, will promote environmental justice and will assist in meeting the greenhouse gas emission reduction and energy storage goals of the climate leadership and community protection act.

The public interest is affordable and reliable electricity.  State agencies have not identified the renewable resources necessary to replace all fossil-fired generation by 2040 and meet current reliability standards so it is presumptuous of the New York Senate to presume that their mandated solution is possible in the time frame in this law.  The millions of dollars in damages claims is not substantiated and given that the emissions from units that run so little are small it is unlikely.  The purported effect on environmental justice communities is based on air quality impacts from inhalable particulates and ozone that are not direct impacts on those communities.  It is unclear why another law is needed to assist in meeting the CLCPA and logic suggests that it is likely that a better choice to let the CLCPA play out than to add a complicating factor.

Implementation

Besides the facts that the premise is wrong, the rationale is incorrect, and the solution is risky, there are a couple of implementation concerns.  Peaking power plants are a critical resource during peak load periods.  However, definition 8 in § 19-1303 says “’Replace’ or ‘replacement’ means the construction and operation of by the construction and operation of a renewable energy system, battery or energy storage, or transmission and distribution infrastructure that enables the provision of the equivalent maximum annual power output achieved by the replaceable peaker”.  Power output is the capacity in MW and the peak load need is the energy in MWh.  The critical parameter for peak load is energy output.  This language directly benefits renewable developers who cannot provide dispatchable energy but it puts New York at risk of a blackout similar to Texas because renewables may not be available to provide all the energy needed during peak loads whatever their maximum annual power output is.

I am also concerned about the language requiring a replaceable peaker plant owner or operator to include a proposed strategy to “replace the plant with renewable energy systems or battery storage or a combination thereof” in an operating permit.  Developing such a strategy requires a major investment in time and money that could well be beyond the capabilities of an owner or operator.  My suspicion is that in such a case the independent power producer will simply surrender the permit and walk away from the state.

The bill authors have not identified the affected units nor has any study been done that shows proposed replacement solutions can keep the system reliable.  I could find no list of units to be affected by this bill. It only seems decent that the authors should identify the units, provide notice to the affected generators and host communities. What about the real property tax implications?  The existing fossil generating stations pay taxes but replacement renewables won’t by located in the same communities nor will they pay taxes at a rate equivalent to fossil plant.

Conclusion

This is deeply flawed legislation.  The premise is wrong because peaking power plants are not inherently bad because they provide critical support to the electric system when needed most.  The rationale that these peaking power plants are directly affecting air quality in adjacent environmental justice neighborhoods is incorrect because the health impacts are claimed from secondary pollutants that do not form before they are transported away from the neighborhood.  Replacing all the peaking plants covered by this law in the time frame mandated is extremely risky because the technology available today is not up to the task as shown in the Power Generation Advisory Panel emphasis on research and development.

Given that there was a power outage disaster in Texas less than a month ago I am extremely disappointed that the New York Senate as taken it upon themselves to dictate energy policy to the electric sector.  Although the complete story of what happened in Texas is unknown at this time, it is clear that extremely cold weather caused a major peak load event.  Past New York energy policy has emphasized the need for diverse set of dispatchable resources to prevent reliability problems in these situations.  This legislation risks reliability in its mandate for resources that are not diverse and technology that have not been tested at the scale needed.

 

Climate Leadership and Community Protection Act – NYISO Resilience Study and the Texas Energy Debacle: New York Worst Case

I recently wrote that the energy debacle that occurred in Texas is unlikely in New York today because of market and system differences but if the Climate Leadership and Community Protection Act (CLCPA) is implemented incorrectly something similar is inevitable.  Last fall the Analysis Group completed their Climate Change Impact and Resilience Study (“Resilience Study”) for the New York Independent System Operator (NYISO).    The study evaluated different resource scenarios that meet the 2040 CLCPA zero-emissions mandate for various weather and load scenarios.  The findings do not portend well for New York’s energy future and raise important questions for New York’s planning.  In this first post discussing the Resilience Study findings relative to the Texas Energy Debacle I will compare New York’s future reliability problem relative to the Texas weather that caused their problems.  This is a long detailed post but will provide background for future posts on other aspects of this issue.

I have written extensively on implementation of the CLCPA closely because its implementation affects my future as a New Yorker.  I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulations, listed the scoping plan strategies, summarized some of the meetings and complained that its advocates constantly confuse weather and climate.  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.

Texas Energy Debacle

In brief, the ultimate cause of the blackouts and resulting problems in Texas was due to poor planning.  The weather in Texas during the storm was extreme but not unprecedented.  Similar cold snaps occurred in 2011, 1991, 1990, 1989, 1983, 1963, and 1961 and there were electrical outages in 2011.   Because there is no apparent trend in low daily maximum temperatures (see Tony Heller’s graph), climate change is not a factor.  This was a weather event.

Clearly the Texas electricity market failed to provide adequate resiliency for these conditions.  I agree with Becky Klein, former commissioner and chairman of the Public Utility Commission of Texas who writes that the questions that need to be considered now are:

      • Are we prepared to pay more for electricity and water to ensure higher levels of reliability?
      • And if so, how much more?
      • How can we be better prepared for “outlier” events, regardless of their probability?
      • Would it make sense to require state-wide scenario planning that includes coordinated drills that test both our operational and communication capabilities across multiple entities?

As New York transitions its electric system to one dependent upon renewables all of these questions need to be addressed.  Fortunately, the NYISO Climate Change Impact and Resilience Study lays the foundation to start to address those questions in New York.

Ultimate Problem

I have described what I believe is the ultimate problem previously.  Both E3 in their presentation to the Power Generation Advisory Panel on September 16 and the Analysis Group  in their September 10, 2020  presentation to NYISO explained that in order to meet the CLCPA emissions reduction goals that a resource category that provides firm, dispatchable and zero-emissions generation is needed.  E3 gives examples such as “such as bioenergy, synthesized fuels such as hydrogen, hydropower, carbon capture and sequestration, and nuclear generation” but the Analysis Group avoids being specific.  The  International Energy Agency (IEA) recently published “Special Report on Clean Energy Innovation” that classified the technology readiness level of the technologies that could possibly be both dispatchable without GHG emissions.  The bottom line is that none of the E3 examples of firm, dispatchable and zero-emissions technologies are close to being ready for adoption except nuclear and hydro which I believe are unlikely to provide any meaningful support for New York.

Climate Change Impact and Resilience Study

According to the report:

“In 2020, NYISO contracted with Analysis Group (AG) to complete this Climate Change Phase II Study (“Phase II Study”). The Phase II Study is designed to review the potential impacts on power system reliability of the (1) the electricity demand projections for 2040 developed in the preceding Climate Change Phase I Study, and (2) potential impacts on system load and resource availability associated with the impact of climate change on the power system in New York (“climate disruptions”).The climate disruptions considered include items that could potentially occur or intensify with a changing climate and that affect power system reliability, such as more frequent and severe storms, extended extreme temperature events (e.g., heat waves and cold snaps), and other meteorological events (e.g., wind lulls, droughts, and ice storms).”

As the Texas experience shows, it is necessary to address potential impacts of extreme weather on power system reliability.  However, in my opinion, there is a significant weakness in the Analysis Group’s team because it does not include a meteorologist.  If one was on the team this language probably would have been modified to make the point that natural variability in weather events such as extended extreme temperature events (e.g., heat waves and cold snaps), and other meteorological events (e.g., wind lulls, droughts, and ice storms) currently is much larger than any climate change induced variations.  As a result, I refer to this report as the Resilience Study rather than the Climate Study.  The report continually refers to climate disruptions which in reality are actually extreme weather events but that does not detract from the value of the analysis itself.

I refer you to the report for a detailed description of the Analysis Group modeling approach summarized in their Figure ES-1.  As input they used two long-term hourly zonal-level load forecasts that reflect state policy goals and climate effects developed by ITRON.  The Analysis Group energy balance model analyzed two load scenarios: a reference case and the CLCPA case that includes the expected increases in load due to heating and transportation electrification.  Four sets of generating system resources were considered.  The Resilience Study estimated what they thought would be needed to meet the load requirements and they also include the NYISO Grid in Transition estimates.  A reference scenario and an expected resource scenario for both were evaluated.  They considered weather disruptions including heat waves, cold snaps, wind lulls, wind storm disruptions, ice storms, and droughts.  The result was a set of 72 analyses projecting the amount of each type of energy resource needed and the potential for resource inadequacy for a 30-day evaluation period.

Last October, soon after the Climate Change Phase II study came out, I prepared a post evaluating whether it adequately addressed the weather disruptions.  Unfortunately, I don’t think it does.  The evaluation period was too short and importantly they did not evaluate extreme wind and solar availability over the same periods.  I also believe that monitoring data from a network with more spatial resolution must be done to adequately represent the effect of lake-effect clouds and precipitation.  Nonetheless the analysis represents a good start addressing the problem of extreme weather.

NY LOLE planning

According to the 2020 NYISO Reliability Needs Assessment: “The New York system is deemed to have sufficient resources if the probability of an unplanned disconnection of firm load (loss of load expectation, or “LOLE”) is equal to or less than the standard of once in every 10 years or 0.1 events per year.”  The reliability planning process starts with the Reliability Needs Assessment (RNA) followed by the Comprehensive Reliability Plan.  I will only discuss the RNA here.  It evaluates “the reliability of the New York bulk electric grid through 2030, considering forecasts of peak power demand, planned upgrades to the transmission system, and changes to the generation mix over the next ten years.”  A base case “includes projected impacts driven by limitations on generator emissions”.  Different scenarios “include an in-depth look at certain policy goals from the CLCPA” and “reliability risks associated with the cumulative impact of environmental laws and regulations”.

The RNA document explains that:

“Resource adequacy is the ability of the electric system to supply the aggregate electrical demand and energy requirements of the customers at all times, taking into account scheduled and reasonably expected unscheduled outages of system elements. Resource adequacy considers the transmission systems, generation resources, and other capacity resources, such as demand response. The NYISO performs resource adequacy assessments on a probabilistic basis to capture the random natures of system element outages. If a system has sufficient transmission and generation, the probability of an unplanned disconnection of firm load is equal to or less than the system’s standard, which is expressed as a loss of load expectation (LOLE).  The New York State bulk power system is planned to meet an LOLE that, at any given point in time, is less than or equal to an involuntary firm load disconnection that is not more frequent than once in every 10 years, or 0.1 events per year. This requirement forms the basis of New York’s Installed Reserve Margin (IRM) requirement and is analyzed on a statewide basis.”

“If Reliability Needs are identified, various amounts and locations of compensatory MW required for the NYCA to satisfy those needs are determined to translate the criteria violations to understandable quantities. Compensatory MW amounts are determined by adding generic capacity resources to NYISO zones to effectively satisfy the needs. The compensatory MW amounts and locations are based on a review of binding transmission constraints and zonal LOLE determinations in an iterative process to determine various combinations that will result in reliability criteria being met. These additions are used to estimate the amount of resources generally needed to satisfy Reliability Needs. The compensatory MW additions are not intended to represent specific proposed solutions. Resource needs could potentially be met by other combinations of resources in other areas including generation, transmission and demand response measures.”

The relevant question after the Texas energy debacle is whether this planning process adequately protects New Yorkers from a similar blackout.

Climate Change Impact and Resilience Study Loss of Load Occurrences

The Resilience Study includes a generic resource intended to “identify the attributes of any additional resources that may be needed to avoid or reduce Loss of Load Occurrences (LOLO).  This is similar to the NYISO Loss of Load Event but does not imply a specific frequency of occurrence like the LOLO.  The Analysis Group labels these resources as dispatchable and emissions‐free resources (“DE Resources”).  They “cover any circumstances where the resource sets are insufficient to meet identified demand, and to evaluate what attributes such a resource must have to help meet reliability needs”.  These are the resources described in the Ultimate Problem section above.

The Resilience Study identified LOLO periods in 26 of the 72 scenarios evaluated.  Overall, there were 414 hours with a loss of load identified totaling 331,065 MWh.  Fourteen periods were associated with extreme weather events such as hurricanes, wind storms or icing while the other twelve were associated with a scarcity of renewable wind and hydro resources.  Note that there was no specific scenario for a solar energy lull analogous to the wind energy lulls evaluated.

The extreme weather events are outliers.  Over the 14 periods, 323 hours totaling 258,504 MWh were identified as having loss of load.  Recall that Becky Klein wrote that one of the questions that need to be considered now is “How can we be better prepared for “outlier” events, regardless of their probability?”  The key question is probability of occurrence for these events and a logical first step would be to determine how often these events happen.  It is also important to determine what could be done to reduce impacts.  Recall that the NYISO RNA process determines the various amounts and locations of compensatory MW required to reduce the probability of these events.  It is not clear to me that any amount of additional resources could mitigate these impacts.  Preparation for the outliers would probably focus on hardening infrastructure which is beyond the scope of this article.

On the other hand, the scarce renewable energy resources scenarios can be addressed by specifying compensatory MW requirements.  For the twelve periods identified there were 91 hours totaling 72,561 MWh.  Nine of the periods were associated with periods of calm winds and three with droughts.  I agree with E3 who has highlighted the critical period of concern to be a multi-day winter period of light winds.

For example, consider scenario 13 which considers CLCPA conditions during a state-wide wind lull in the winter with the set of resources chosen to handle the CLCPA target of zero emissions.   Over the 30 day analysis period the Resilience Study estimates that 9,043,988 MWh will be generated by 35,200 MW of land-based wind, 5,288,985 MWH will be generated by 21,063 MW of offshore wind, 503,859 MWh will be generated by 10,878 MW of behind-the-meter solar, 1,951,742 MWh will be generated by 39,262 MW of utility-scale grid solar, 2,027,789 MWh will be generated by 4,486 MW of hydro pondage and run of the river hydro, 2,422,224 MWh will be generated by 4,364 MW of nuclear, 2,023,200 MWh will be imported, 98,672 MWh will be generated by 1,170 MW of pumped storage, 800,462 MWh will be provided by 15,600 MW of battery energy storage over 189 hours, demand response will displace 3,412 MW and 566,429 MWh over 276 hours, and the 32,317 MW of the DE resource will generate 3,653,404 MWh over 278 hours.  Over the 30 days 28,380754 MWh will be generated but even these resources will be unable to prevent LOLO totaling 13 hours and 14,404 MWh.

I believe it would be more appropriate for future analyses to consider shorter time periods in greater detail.  In this case consider the seven-day period from hour 192 to hour 360.  This is the critical period where the most DE resources are required and when the hours with load loss occurred.  I think that the uncolored area under the load curve around hour 264 represents the load loss period.  Note that battery storage was used up early in the critical period.  In order to fully replace all the DE resources MWh would take an extraordinary amount of additional energy storage.  Clearly the big problem is a lack of land-based and offshore wind.  In the winter, solar is just not going to be able to cover the loss of wind across the state.  Furthermore, it is not clear to me that the solar energy output reflects snow cover impacts.  It appears that no amount of over-building of wind and solar coupled with battery energy storage is going to be able to solve this renewable resource problem.

The Resilience Study analysis reinforces the fact that the multi-day winter wind lull is a critical period for reliability. In my comments on the resource adequacy hearing and elsewhere I have argued that actual short-term meteorological data from the NYS Mesonet system must be used to correctly characterize the renewable resource availability for New York in general and in areas downwind of the Great Lakes in particular. This type of evaluation is necessary to completely characterize the resource availability during the multi-day winter wind lull.  I believe that using those data in conjunction with a meteorological evaluation of the weather systems that cause these conditions could also develop a frequency of occurrence distribution that could be used to extend the Loss of Load Occurrence estimates to Loss of Load Expectation projections.

Independent System Operator – New England (ISO-NE) recently had an analysis done, Analysis of Stochastic Dataset for ISO-NE, that purports to provide frequency of occurrence information.  I am not comfortable that they have actually done what they thought they did.  In their analysis they used a statistical re-sampling technique that I am not sure adequately considers serial correlation and the relationships between wind and solar resource availability.  In their February 20, 2020 presentation to the ISO-NE Planning Advisory Committee, Wind and Power Time Series Modeling of ISO-NE Wind Plants, Methodology and Analysis of Results, they describe a wind mapping system that generates high-resolution mesoscale wind maps.  The report notes that “wind generation is very likely to be high during the peak load hour” and goes on to say that “this appears to be due to passing cold fronts associated with strong low-pressure systems that drive wind speeds across New England”.  In the February 2020 presentation there is a table with wind turbine power curve basics that shows a cutoff speed for low wind speeds and high wind speeds.  I am very sure that the Analysis Group cutoffs were different than the ones used in this study because there is a difference in wind output for wind storms.  While another good start I believe that this analysis also comes up short adequately characterizing the lowest renewable energy resource availability period.

Conclusion

The Analysis Group writes: “The variability of meteorological conditions that govern the output from wind and solar resources presents a fundamental challenge to relying on those resources to meet electricity demand.”  I agree completely.

In Texas there were seven cold snaps similar to the one that caused the outages in the last 60 years so the frequency of occurrence is 8 divided by 60 or 0.13 events per year.  New York’s LOLE standard is 0.1 events per year so the NYISO planning process is supposed to address this kind of event.  The relevant question for New York is how often do we expect a multi-day winter wind lull.  My answer to that is every year but the intensity varies.  For example, from 2/14/21:2300 until 2/15/21:1600 there were 15 of 17 hours when the wind output was less than 10% of the nameplate capacity and all of New York’s on-shore wind turbines produced a total of 765 MWh for a capacity factor of 2.6%.  This period wasn’t as intense as the Resilience Study conditions and I did not determine the duration of the wind lull but it was just a random choice.  We won’t know how often and how intense these periods are until an analysis specifically designed to evaluate New York’s renewable resource potential is completed using fine-resolution meteorological monitoring data.

As to whether New York’s reliability planning process adequately protects New Yorkers I must reserve judgement.  NYISO has the responsibility for this protection but can only guess at what the CLCPA process will propose as its resource mix.  Until that time, they cannot do the evaluation work necessary to determine future reliability so it is unfair to pass judgement.  I will note however that the Analysis Group and NYISO have identified serious challenges that must be overcome to make a reliable system that meets the CLCPA mandates.

In my opinion, those challenges will prove to be impossible to meet without a marked degradation of reliability.  Future posts will explain why I believe that to be the case.

Climate Leadership and Community Protection Act Lack of Responsiveness to Comments

Update 2/26/21: On Date: Fri, Feb 26, 2021 at 1:44 PM Suzanne Hagell, PhD, a Climate Policy Analyst, Office of Climate Change from the New York Department of Environmental Conservation responded to the email that precipitated this post.  The response is added at the end.  I will leave it to the reader to determine if the response was appropriate.

I have been trying to get involved and stay involved in the Climate Leadership and Community Protection Act (CLCPA) implementation process over the past year.  This post documents the lack of responsiveness within the process to this point.

I have written extensively on implementation of the CLCPA closely because its implementation affects my future as a New Yorker.  I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulations, listed the scoping plan strategies, summarized some of the meetings and complained that its advocates constantly confuse weather and climate.  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.

According to the Climate Act webpage the Climate Action Council will lead the transition:

The New York State Climate Action Council (Council) is a 22-member committee that will prepare a Scoping Plan to achieve the State’s bold clean energy and climate agenda. The Council will also oversee the establishment of sector-specific advisory panels and working groups and will work in consultation with the Climate Justice Working Group and the Environmental Justice Advisory Group.

In order to get involved with the process I have been following the advisory panel activities as well as I can.  The webpage explains how the public can provide input:

The advisory panels of the Climate Action Council and the Just Transition Working Group will host public meetings throughout 2021. The advisory panels will hold sector-specific discussions that will provide recommendations to the Council for consideration as it develops a Scoping Plan to achieve New York’s ambitious greenhouse gas reduction targets. The Just Transition Working Group will help ensure an equitable transition for New York’s workforce in the State’s renewable energy economy.

The Advisory Panel meetings and materials page announces meetings and provides summaries of the public meetings.  However, the lack of updates in general and the  process in particular does not lend itself well to providing meaningful comments.  In the first place the Power Generation panel has not updated its meeting materials for three weeks despite the fact that there have been two meetings held at the date of this writing.  I blame that panel for some of the lack of responsiveness.

However, there is a systemic problem.  At the bottom of the page it says “Past meeting materials are updated on this page every Friday. Meeting notes and presentations received from Panels by 5 p.m. ET. Tuesday will be added to the website by Friday of that week.”  I take issue with it taking three working days to get ready to post the material.  That is not that big an effort but is an inconvenience for some state worker.  Furthermore, why wait until Friday?  If the State process truly wants to have public involvement then assign several people who make posting material received from the advisory panels within two working days.

Unfortunately, that is not the biggest problem.  The CLCPA law mandates that there be public involvement.  However, whether any of the information received is actually considered by any of the panels or addressed by any of the agencies is another matter.

Consider, for example, that I found an error in New York State guidance document Establishing a Value of Carbon, Guidelines for Use by State Agencies (the “Guidance”).  I sent an email to several staff who I know have responsibilities associated with the issue and two weeks after submitting my comments I have not received any response.

In particular the Guidance includes a recommendation how to estimate emission reduction benefits for a plan or goal.  I believe that the guidance approach is wrong because it applies the social cost multiple times for an emission reduction so I recommended that the Guidance be revised.

In the Guidance section entitled “Estimating the emission reduction benefits of a plan or goal” an example is included that states:

The net present value of the plan is equal to the cumulative benefit of the emission reductions that happened each year (adjusted for the discount rate). In other words, the value of carbon is applied to each year, based on the reduction from the no action case, 100,000 tons in this case. The Appendix provides the value of carbon for each year. For example, the social cost of carbon dioxide in 2021 at a 2% discount rate is $127 per metric ton. The value of the reductions in 2021 are equal to $127 times 5,000 metric tons, or $635,000; in 2022 $129 times 10,000 tons, etc. This calculation would be carried out for each year and for each discount rate of interest.

The IWG damages approach value is the net present benefit of reducing carbon dioxide emissions by one ton.  The calculation methodology determines that value from the year of the reduction out to 2300.  It is inappropriate to claim the benefits of the annual reduction over any lifetime.  Consider that in this example, if the reductions were all made in the first year the value would be 50,000 times $127 or $6,350,000, but the guidance approach estimates a value of $37,715,000 using this methodology.

I did not catch this error until after the comment period ended so I sent the email.  However, in my comments on their stakeholder webinar I made the comment that the New York State Energy Research and Development Authority practice of calculating lifetime savings in a similar fashion was incorrect.  In order to verify my understanding, I contacted Dr. Richard Tol, Professor of the Economics of Climate Change at Vrije Universiteit Amsterdam and a Professor of Economics at the University of Sussex who has direct experience estimating the social cost of carbon.  He graciously responded and explained that “The SCC should not be compared to life-time savings or life-time costs (unless the project life is one year).”

My email concluded that the Value of Carbon guidance example methodology in the Guidance section “Estimating the emission reduction benefits of a plan or goal” inappropriately considers lifetime benefits.  That is inconsistent with social cost damages approach methodology used to derive the social costs so it should be revised.

Conclusion

While the CLCPA mandates that the public be involved in the development of scoping plan, those are just words and the reality is different.  The system does not encourage meaningful participation because meeting information is available promptly after the meetings.  There is no indication that the panel members are aware of comments received.  Worse is the lack of response from agency staff responsible for guidance documentation when errors were noted.  I posted this article to document these issues.

Update 2/26/21: In response to the email I sent Wednesday, February 10, 2021 2:27 PM I received this:

From: Hagell, Suzanne E (DEC)
Date: Fri, Feb 26, 2021 at 1:44 PM
Subject: Re: Value of Guidance Document Emission Reduction Benefit Calculation Example
To: Roger Caiazza
Cc: Pandich, Jason P (DEC)

Hi, Roger. My apologies for not getting back to you right away. This is really useful. Jason and I will take a look at the issue that you’re raising and talk to our colleagues at NYSERDA as we develop the accounting for the Scoping Plan.

I expect that we will be making additional updates to the Value of Carbon guidance and this would be one update that could be addressed.

Suzanne

 

Environmental Justice Risks from Hyper-Local Monitoring are Exaggerated

Note:  This post was also published at Watts Up With That

According to Bloomberg Law, Biden’s Hefty Clean Air To-Do List Follows Early Big Promises means that air quality standards have to be revised and must incorporate social justice and climate concerns.  Based on what I have seen this push will rely less on science and more on emotion.

The Bloomberg article states:

“Revising clean air rules is a cornerstone of climate and justice policies, two areas that the Biden administration has set as priorities.  Clean air experts in areas that carry a disproportionate burden of dirty air say that runaway air pollution remains a chronic problem, reflecting neglect of low-income neighborhoods and communities of color, exacerbated by air monitor disparities.”

“Portable air quality monitors used in the South Bronx and Brooklyn caught particulate matter quantities 20 times higher in some areas than levels reported by state-run monitors, according to new data from a neighborhood-level air monitoring study by the New York City Environmental Justice Alliance, or NYC-EJA.  The findings highlight insufficient air monitoring for targeted environmental justice communities, and show why one generalized air policy may not be enough to mitigate pollution for hard-hit areas, said Jalisa Gilmore, research analyst for NYC-EJA.  “That’s why we have a little bit more emphasis on hyper local monitoring, and making sure that we actually get the interventions that are most appropriate for the community,” she said.”

The New York City hyper local monitoring program is described in the Community Air Mapping Project for Environmental Justice (CAMP-EJ) findings and recommendations report.  In brief:

“Because New York City has only 13 high-performance ambient air monitoring sites, air pollution exposures are poorly characterized at the neighborhood level. To address this data gap, CAMP-EJ utilized dozens of low-cost, portable air quality monitors to measure hyperlocal air quality and characterize air pollution exposures at more refined spatial and temporal scales than is possible using existing City and State data. The results of our air monitoring campaign shed light on the disproportionate public health burdens imposed on environmental justice communities from industrial pollution, trucking, and transportation infrastructure.”

The analysis found that local facilities and expressways are big polluters, traffic congestion fouls the air twice every day, and that hyperlocal measurements show inhalable particulate matter are twenty times higher than state-run monitors.  I was not surprised by the first two findings but the claim that hyperlocal measurements were much higher than state-run monitors surprised me.

I have experience running air quality monitoring networks with particulate matter monitors.  I found that measuring particulates was always difficult to do correctly and more so with smaller aerodynamic particles like the inhalable or 2.5 micron particles.  In the project, “CAMP-EJ participants used the AirBeam2, a low-cost, palm-sized air quality instrument that measures PM2.5, and AirCasting, an open-source environmental data visualization platform that consists of an Android app and online mapping System”.

The going price for an AirBeam 2 is around $250 and the state-run monitors systems use instruments that go for $25,000.  The state-run system has a detailed quality assurance plan and includes quality control tests which I doubt were included in the community monitoring program so my first thought is just how accurate are these personal monitors?  According to the report: “The AirBeam2’s PM2.5 measurements are “quite accurate” according to a performance evaluation conducted by South Coast Air Quality Management District, which compared the performance of the AirBeam2 to reference monitors.”

However, the South Coast Air Quality Management District evaluation report I found told a different story.  Three sensors were tested against a reference FEM FRIMM PM 2.5 monitoring instrument similar to the one used in the New York State network.  According to the concluding discussion:

“Accuracy: Overall, the three AirBeam sensors showed very low accuracy compared to FEM GRIMM at 20 °C and 40% RH, when varying PM2.5 mass concentration from 10 to 50 μg/m3. The AirBeam sensors significantly overestimated the FEM GRIMM readings. According to the method of calculating accuracy, the % accuracy for the sensors were all negative. When PM2.5mass conc. was over 50 μg/m3, Airbeam sensors reached plateau of 315 μg/m3.”

Don’t get me wrong, I have no doubt that the CAMP-EJ main conclusions, local facilities and expressways are big polluters and traffic congestion fouls the air twice every day, are correct.  However, the monitors used over-estimated inhalable particulate concentrations considerably, particularly at the higher rates they claimed are hurting local communities.  As a result, the numbers that they claim prove the need to act are incorrect.