Author: rogercaiazza

On November 29, 2023 the New York Independent System Operator (NYISO) released its 2023-2032 Comprehensive Reliability Plan (CRP).  This is a key part of New York’s reliability planning process and addresses the Climate Leadership & Community Protection Act (Climate Act) net zero transition mandate for the 70% renewable energy by 2030 and the zero-emissions grid by 2040.  The report includes recommendations that are odds with climate activists’ demands.  This post summarizes recommendations related to the Climate Act.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 350 articles about New York’s net-zero transition.  I have devoted a lot of time to the Climate Act because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good by increasing costs unacceptably, threatening electric system reliability, and causing significant unintended environmental impacts.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.”  In brief, that plan is to electrify everything possible using zero-emissions electricity. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan.  After a year-long review, the Scoping Plan recommendations were finalized at the end of 2022.  In 2023 the Scoping Plan recommendations are supposed to be implemented through regulation, PSC orders, and legislation. 

In order to ensure that the onslaught of regulations and orders is feasible the NYISO follows its reliability planning process.  The press release for the 2023-2032 Comprehensive Reliability Plan (CRP) says that it “highlights growing risks to electric system reliability, including: projected increases in peak demand due to electrification of the transportation and building sectors; additional generator deactivations; delayed implementation of planned infrastructure projects; and extreme weather.” It is a part of the NYISO reliability planning process that “sets forth a plan to maintain a reliable bulk electric grid based on expected changes and conditions over a ten-year planning period.”  It is issued every two years.  The report and appendices are available from the NYISO.

Press Release Highlights

In this section I will annotate the points made in the press release.  The first paragraph after the introduction notes:

In addition to rising demand due to continued electrification, several large commercial projects in upstate New York are in development and are forecasted to significantly increase energy use over the planning period.  Further, state legislation enacted last year will require the phase-out of the New York Power Authority’s small natural gas plants located in New York City by December 31, 2030. If demand on the grid grows at a rate greater than the buildout of new generation and transmission, reliability deficiencies could arise within the CRP’s ten-year planning period. 

Electrification of the transportation and building sectors is a direct consequence of the Climate Act plan to reduce greenhouse gas emissions (GHG) by electrifying everything possible.  The building and transportation sectors are the two largest sectors of emissions.  There is no question that replacing energy used by direct combustion of fossil fuels with electricity will increase loads.  NYISO is particularly concerned that this transition will not only increase the loads but also shift the peak loads from summer to winter and affect the daily load patterns as well.

The electric grid is an incredibly complex system best left to experts.  The hubris of the progressive wing of the Democratic majority in the New York State Legislature that they should get involved in power planning is blatant pandering to favored constituencies.  The NYPA legislation is a case in point.  Phasing out the New York Power Authority’s small natural gas plants in New York City by any date certain is a risk that is major issue in the CRP.  Increasing load on one hand and retiring generation at the same time is a primary risk identified in the report.

The press release explains how the problem can be addressed:

The potential risks and resource needs identified in the CRP may be resolved by new capacity resources coming into service, construction of additional transmission facilities, increased energy efficiency, integration of distributed energy resources and/or growth in demand response participation.

I do not think that there are any surprises in these recommendations.  It is imperative to build more, connect more, and reduce load to the extent possible but electrification of buildings and transportation means we cannot expect much help there.

The press release highlights risks related to deployment of new resources:

“Our latest report demonstrates the continued importance of the NYISO’s in-depth planning process and the need to closely monitor the rapidly changing electric grid,” said Zach Smith, Vice President, System and Resource Planning.  “In this CRP, we highlight several risk factors that could adversely affect system reliability in the months and years ahead.”

The plan underscores the importance of the timely completion of planned transmission projects – primarily the Champlain Hudson Power Express (CHPE) project – to maintain system reliability. Without the CHPE project in service by May 2026 or other offsetting solutions, reliability margins within New York City would be deficient beginning in 2026.

I cannot over-emphasize how important the NYISO planning process is during this transition.  It is the most prominent process to introduce reality.  Unfortunately, I am concerned that the transition to weather-dependent resources that cannot be dispatched and do not provide ancillary transmission support services is unprecedented and that even the experts at the NYISO will be unable to anticipate all the possible problems.  This could result in blackouts that will be more impactful than any of the potential impacts of a tweak to climatic conditions due to GHG emissions.

In the politicized energy policy environment of New York the NYISO cannot come out and say that risking the reliability of New York City’s electric grid by counting on a specific transmission project is unacceptable. Underscoring the importance of “timely completion” really means we should not make any changes to the existing system until the Champlain Hudson Power Express project is complete.  In addition there are risks to the technology.  I have heard anecdotal evidence that there have been issues with underwater electric cables connecting Long Island to the mainland that lasted longer than expected.  CHPE is mostly underwater from Quebec to New York City but there are above ground lines in Quebec that are even more liable to disruptions.

The strategy to electrify everything will shift the peak load from summer to winter.  This introduces additional issues:

Transition from a summer peaking system to a winter peaking system also poses challenges to grid reliability. This shift, driven by the electrification of the building and transportation sectors, is forecasted to occur within ten years. A winter peaking system introduces new reliability concerns, particularly around fuel availability for gas-fired generators. Based on a recent assessment of New York’s fuel and energy security, the CRP states the following:

Preliminary results of the 2023 Fuel and Energy Security study demonstrate that NYISO will need to rely significantly on dual-fuel generation resources to support winter system reliability into the next decade and changes to the resource mix may complicate system operations during multi-day cold snap conditions. The frequency and severity of projected potential loss of load events grow over the modeling time horizon as the generation mix evolves and the demand for electricity increases.

One of the prominent claims of the Scoping Plan is that the “zero-emissions” electric grid of the future will be “diverse”.  Nothing could be further from the truth.  The ugly secret of wind and solar resources is that their output is correlated.  The CRP notes: “Solar resources will have little to no output during the evening and nighttime hours and reduced output due to cloud cover, while wind resources can experience significant and sustained wind lulls. Periods of reduced renewable output will occur for short durations due to cloud cover or changes in wind speed and for prolonged periods across a daily/seasonal cycle.”  The CRP does not point out that wind lulls frequently occur over the entire state which magnifies the difficulties.

The New York generating system used to be more diverse than today.  New York regulated coal-firing out of business but the coal plants could store on-site fuel.  Natural gas is cheaper and has less environmental impact, but it is also used for home heating and thus subject to curtailment.  New York has significant oil-fired resources that have the advantage that they can be store oil on-site.  The reference to dual-fuel generation refers to the ability of certain facilities to burn oil and natural gas so that they can provide power when natural gas is curtailed.

The press release closes with the following:

Given the rapid pace of change on the bulk electric system, the NYISO will continue to monitor these and other developments to determine whether changing system resources and conditions could impact the reliability of the New York electric grid.

The competitive wholesale electricity markets administered by the NYISO are an essential tool to mitigate risks on the electric system, as well as facilitate the transition of the grid to increased renewables and decarbonization as required under state law.  The competitive markets continue to evolve and adapt to guide and attract new market entry and retention of resources that support reliability. 

The NYISO is a product of the de-regulated electric system that depends on markets.  I am not as optimistic as NYISO that the markets will succeed as suggested.  Energy developers have to be consider the risks and rewards of all the investments they make.  One of the problems in New York City is that the in-city peaking power plants are old.  I know that many of the facilities had plans to re-power with new and much cleaner units and had all the permits in place to build them. However, market uncertainties led to the decision not to build them.  Without expensive guaranteed subsidies I expect that this will be the case for renewable developments.  That sounds less and less like a de-regulated system to me.

Key Reliability Risk Takeaways

The CRP Executive Summary outlines the reliability risks.  There is an important caveat:

The CRP’s finding of no long-term reliability violations reflects the Reliability Planning Process assumptions, which are set in accordance with applicable reliability design criteria and NYISO’s procedures. There are, however, risk factors that could adversely affect system reliability over the planning horizon. These risk factors may arise for several reasons including climate, economic, regulatory, and policy drivers.

The ultimate concern is whether the risk factors are so problematic that it is appropriate to consider if a implementation pause is in order.  It is de rigor to say that climate will affect the availability of electricity, but they are really talking about extreme weather not climate. There are economic issues associated with the renewable developers that could slow or cancel developments,  The Hochul Administration is trying to remove all regulatory barriers but the Federal Energy Regulatory Commission, New York State Reliability Council, New York Public Service Commission, and even the NYISO have regulatory requirements that can affect implementation particularly on the arbitrary schedule of the Climate Act. 

The following list of key risks are all the result of the Climate Act net-zero transition.  In this overview I will include some brief comments.

The CRP is concerned with the speed of change in the electric grid.  Unsaid in the following is that there are no in-kind replacements available for the NYPA small gas plants.  Legislators may think that replacement is only a matter of political will, but reality is different.

The pace of generation retirements has exceeded the pace of resource additions to date. Should this trend continue, reliability needs will be identified both locationally and statewide. For example, retirement of the NYPA small gas plants without adequate replacement would result in a deficiency in New York City of more than 600 MW.

The list includes concerns related to the CHPE project which I addressed earlier:

The reliability of the grid is heavily reliant on the timely completion of planned transmission projects, chiefly the CHPE project. Without the CHPE project in service or other offsetting changes or solutions, the reliability margins would be deficient for the ten-year planning horizon.

The Climate Act transition to electrified heating and transportation is unprecedented. 

There is a clear upward trend forecasted in peak demand over the next ten years, with significant uncertainty driven by electrification of heating and transportation coupled with the development of multiple high-electric demand facilities (e.g., microchip fabrication and data centers). As the demand on the grid grows at a rate greater than the build out of generation and transmission, deficiencies could arise within the ten-year planning horizon.

The NYISO is making their best estimates of the effect on peak load but the estimates are uncertain.  Another big concern is the potential addition of major high demand facilities.  At the top of the list of high demand facilities is the proposed Micron chip fabrication plant near Syracuse which is expected to need as much power as Vermont and New Hampshire combined.

Another key risk is imported power:

New York’s current reliance on neighboring systems is expected to continue through the next ten years. Without emergency assistance from neighboring regions, New York would not have adequate resources throughout the next ten years.

Extreme weather has always been the biggest threat to reliability.  This risk is also listed:

Extreme events, such as heatwaves or storms, pose a threat to grid reliability throughout the planning horizon and could result in deficiencies to serve demand statewide, especially in New York City. This outlook could improve as more resources and transmission are added to New York City.

The CRP links imported power and extreme events.  The document states that:

Statewide resource adequacy during these extreme events relies on neighboring regions for assistance during emergencies. Grid analysis demonstrates that New York would not have adequate resources throughout the next ten years if not for emergency assistance. Such emergency assistance assumes availability of resources from neighboring systems to send power to New York in an event that New York resources are inadequate. The NYISO will maintain interregional collaboration with neighboring systems to monitor the availability of emergency assistance as the resource mix transitions throughout the entire Eastern Interconnection.

I think the extent of the reliance on imported power represents a new paradigm.  It is not clear to me that it is in the best interests of New York to be dependent upon other jurisdictions.  This is especially true as the dependency upon wind and solar resources increases throughout the Eastern Interconnection.  The fact is that the winter worst-case coldest temperature extreme events are associated with low wind and solar resource availability.  The under appreciated problem is that the extent of the low resource availability during those events goes beyond adjacent systems.  Those systems may not be able to provide emergency support even if they wanted to.

There is an unmentioned reliability risk with the potential for devasting consequences.  Projections for future New York electrical energy generation (MWh) call for offshore wind to provide between 15 and 20% of the annual energy needs of the grid.  If a category 4 hurricane hits the offshore wind farms, then a significant fraction of the wind turbines could be damaged or destroyed.  Replacing them in a timely fashion would be a huge problem.

The problems of a winter-peaking system are another reliability risk.  I cannot add anything to the CRP summary:

The New York statewide grid is projected to become a winter-peaking system in the mid-2030s, primarily driven by electrification of space heating and transportation. The New York statewide grid is reliable for normal weather in the winter for the next ten years, but deficiencies would arise as early as winter 2027-2028 for an extreme 1-in-100-year winter cold snap coupled with a shortage of gas fuel supply. This deficiency would grow to a 6,000 MW shortfall by winter 2032-2033. Additional deactivations of dual-fuel generation beyond what is planned will exacerbate the winter reliability risk.

The final reliability risk addresses changes to the planning process:

Planning for the more extreme system conditions of heatwaves, cold snaps, and fuel availability is currently beyond established design criteria. However, several reliability organizations are investigating whether applicable reliability rules and design criteria should be revised to account for these events.

I am disappointed that the CRP did not mention the link between low wind energy resource availability and heatwaves and cold snaps.  Large and intense atmospheric high-pressure systems lead to the most extreme temperatures and cause light winds over enormous areas.  The reliability organizations are just getting their heads around the ramifications of the magnitude, duration, and extent of these events.  They have not addressed the effect on design criteria.  One of the primary criteria today is the loss of load expectation over a ten-year period.  If analysis determines that once every fifteen years that the expected availability of wind resources requires additional support, that means a new planning horizon. 

The unaddressed issue is where do you stop.  A 15-year criterion could require a substantial investment for some resource that will only be used once every fifteen years.  The problem is that you must make the investment because the weather conditions that cause the problem will occur- it is only a question of time.  If the investments are not made, then electricity won’t be available and a catastrophic blackout will occur.  In February 2021, the Texas electric grid failed to provide sufficient energy when it was needed.  The storm was the worst energy infrastructure failure in Texas history and 4.5 million homes and residences were without power, at least 246 people died, and total damages were at least $195 billion. 

Conclusion

The North American electric power grid has been described as the  largest machine in the world.  Incredibly all the fossil, hydro, and nuclear generating stations in the Eastern Interconnection from Saskatchewan to Florida, Oklahoma to Nova Scotia are connected and work together. It relies on the ability of operators to constantly match load demand with generation output.  In order to provide 60 Hz power, the generating turbines are synchronized to run at 3600 revolutions per minute.  Operators keep the voltages as constant as possible in the entire area but have the advantage that those turbines provide inertia, and they can dispatch generating resources as necessary.

The CRP raises important reliability issues, but I think it does not fully convey the magnitude of the proposed “zero-emissions” transition challenge.  The success of the existing power grid and the benefits of affordable and reliable power it provides developed over decades.  Converting the existing system to one that relies on weather-dependent resources and does not inherently provide the ancillary services such as inertia that are inherent to the turbines relied on presently is a massive challenge.  Meeting the ”zero-emission” by 2040 schedule mandated by politicians without relying on nuclear energy exacerbates that challenge.  It is not politically correct for the NYISO to call out this challenge in detail or to explicitly suggest that it is not possible without enormous reliability risks.  I have no such restraints.  Unless the Climate Act mandates are modified and the schedule changed, blackouts will result, and people will freeze to death in the dark;

I believe that single biggest flaw in the Climate Leadership & Community Protection Act (Climate Act) net zero transition is the failure to include a feasibility analysis.   I agree with Francis Menton, the Manhattan Contrarian, that the ultimate test would be a demonstration project to determine the feasibility of a fully wind/solar/battery electric generation system.  This post describes a series of articles by Ed A. Reid, Jr. at the Right Insight blog describing what he believes should be included in a grid-scale demonstration project.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 350 articles about New York’s net-zero transition.  I have devoted a lot of time to the Climate Act because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good by increasing costs unacceptably, threatening electric system reliability, and causing significant unintended environmental impacts.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.”  In brief, that plan is to electrify everything possible using zero-emissions electricity. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan.  After a year-long review, the Scoping Plan recommendations were finalized at the end of 2022.  In 2023 the Scoping Plan recommendations are supposed to be implemented through regulation, PSC orders, and legislation. 

The Problem

In my opinion a feasibility analysis that addresses reliability, affordability, and cumulative environmental impacts should be a prerequisite for the proposed changes to the New York energy plan.  State leaders claim that the Scoping Plan is sufficient, but I disagree.  The Scoping Plan lists various control strategies that it claims meets the Climate Act requirements but no where does it document the expected costs, emission reductions, and assumption for the components of the control strategies in sufficient detail to verify the total costs necessary to determine expected costs to New Yorkers.  It does not even include projected ratepayer costs or an affordability standard.  Even though Climate Action Council members claimed that the Scoping Plan adequately addressed reliability, and some went so far as to say that no new technology was needed, the reality is that the New York Independent System Operator (NYISO) has raised many unaddressed reliability issues.  Furthermore, the NYISO, the Integration Analysis and the New York State Public Service Commission (PSC) agree to the need to “identify innovative technologies to ensure reliability of a zero-emissions electric grid”.  The most recent cumulative environmental impact assessment does not include between 20% and 40% more onshore wind, about twice as much offshore wind, and over three times as much distributed and utility-scale solar projected in the Scoping Plan.  In addition, no previous cumulative environmental impact analysis considered the impacts of massive energy storage facilities or the “zero-carbon firm resource” that the Integrated Analysis presumes will be provided by hydrogen resources. 

The NYISO is responsible for keeping the lights on in New York.  They have a very sophisticated resource adequacy modeling process and are required to provide regular reliability assessments.  There are staff dedicated to addressing those requirements and I have a lot of respect for their skill and body of knowledge.  They have been analyzing the electric system for many years and have a great understanding of the current electric system.  However, I have enough modeling experience and background to still be skeptical that the existing resource adequacy process will be able to address all the inter-related components and unintended consequences of the transition to an electric system that relies on weather-dependent and inverter-based resources.  As a result, I worry that some combination of circumstances will occur that causes unexpected reactions that will result in blackouts despite their best efforts.  We know that an electric grid that relies on nuclear and hydro “zero-emissions” resources will work.  What is needed is a demonstration project that can be used to test whether wind, solar, and energy storage resources can work and refine the resource adequacy modeling to address those resources.

Reid’s Renewable Demonstration

Ed Reid agrees with this need and writes “I believe it is essential that at least one large scale demonstration of a completely freestanding renewable plus storage powered grid be conducted under carefully controlled conditions.”  Even if such a project was implemented, he points out an important caveat: the long duration storage or alternative “zero-carbon firm resource” cannot be tested because neither resource is currently commercially available.

He proposes a demonstration for a selected zone within the grid. His proposal would only consider sources within the zone isolated from external sources of power and incorporate storage initially using “pseudo-storage” by tracking exports from the isolated zone and what is needed from outside the isolated zone. He suggests an iterative development process whereby:

The demonstration managers would be able to import electricity from external sources if required to avoid demonstration grid failure but would then be required to install additional generation capacity or contract for more pseudo-storage to avoid a repeat of the imminent grid failure condition. The demonstration managers should not be permitted to deliver electricity outside the demonstration zone, other than to pseudo-storage.

His first demonstration project article concludes:

It might be ideal to site the demonstration zone in the metropolitan Washington, DC area to assist agencies of the federal government and federal legislators to understand the various issues with a renewable plus storage grid in real time and work to resolve them in a timely fashion.

In the next article Reid argues that transparency should be a key component of the demonstration.  He proposes that the first step be complete documentation describing the generation and energy storage resources within the demonstration zone.  He goes on to explain:

The next step in the process would be the initial design of the renewable plus storage system to replace the existing conventional, dispatchable fossil generation resources. This would include designation of the types and capacities of the wind and solar generators, plus designation of the capacities and delivery rates of short, intermediate and long duration storage to be installed or simulated by pseudo-storage.

After a period of testing, the wind, solar, and energy storage resources “would be used to meet the contemporaneous demand of the grid and to charge both actual and pseudo-storage”.  The reporting system would track all the generation and energy usage.  He suggests that in order to address the affordability component that “all renewable generation and storage resources installed in the demonstration zone be capitalized at their full cost, with no federal or state incentives of any kind”.  

Market costs also must be tracked. 

He concludes the second article:

These approaches to the demonstration should assure that the demonstration zone facilities would be designed to be a reliable and flexible renewable electric system and that the electricity costs in the demonstration zone would representative of a renewable plus storage grid on a national scale.      

The third article suggests a reporting format for the renewable plus storage demonstration proposed.  If you are interested in those details, I refer you to the article.

The fourth article raises an important point about the ultimate viability of renewable energy plus storage electric system.  Climate Act accounting requirements mandate that fossil-fired generating resources include upstream emissions.  Reid points out that a true “zero-emissions” electric system should also eliminate emissions in the supply chain.  He argues:

The supply chain begins with the use of electric mining equipment to mine the raw materials required to fabricate the wind, solar and storage components of the renewable plus storage grid in US mines and the use of electric transportation to move these raw materials to the manufacturing facilities at which the components of the system would be fabricated. The fabrication of the components would occur in US plants using electric processing equipment.

The steel and cement required for installation of the system components would also be produced in US plants. In the case of the calcining of limestone to produce cement, carbon capture and storage (CCS) systems would be required to capture the CO2 released from the limestone.

Preparation of the installation sites for the wind and solar generators and the storage systems would be performed by US manufactured electric earthmoving equipment. The system components would be transported to the installation sites by US manufactured electric trucks or electrified trains and erected using US manufactured electric cranes.

Considering supply chain emissions introduces much more complexity.  He argues that all the claims about clean energy job creation ignore the current reality that the “current supply chains for wind turbines, solar collectors and storage batteries, all of which currently require mining and processing of minerals in Asia and Africa and frequently rely on foreign manufacture, particularly of solar collectors and wind turbines” has many jobs outside of the United States.  My concern is that it is not only the jobs but also there are lower environmental and safety considerations.  Finally, there is a moral aspect because the “mining and processing jobs in Asia and Africa and the manufacturing jobs in Asia reputedly rely on child, forced and prison labor”.

Conclusion

I think there is a clear need for a feasibility demonstration project.  Attempting to convert the current electric system that has evolved over decades to a system relying on significantly different resources by 2040 is such an enormous challenge that I think it is inappropriate to rely on modeling to check feasibility.  Reid describes a feasibility demonstration on a utility-scale.  Menton has argued for a smaller project:

Before embarking on “net zero” for a billion people, how about trying it out in a place with, say, 10,000, or 50,000, or 100,000 people.  See if it can actually work, and how much it will cost.  Then, if it works at reasonable cost, start expanding it.

While there are some large jurisdictions that have achieved very low-carbon grids, they did not do so by relying on underperforming intermittent wind and solar generation.  Instead, they achieved low emissions by using high-capacity-factor firm resources—namely hydropower and nuclear. To my knowledge no jurisdiction has demonstrated the ability to achieve “zero-emissions” using wind, solar, and energy storage.  Ideally a large-scale test such as the one proposed by Reid should be done before New York goes any further.  However, I think that even the small-scale demonstration proposed by Menton would show that the Climate Act “zero-emissions” electric system is infeasible on reliability and affordability grounds.

I believe that the fatal flaw of all “green” technologies is that they do not work all the time.  “On average”, “in general”, or for “many people”, it may be possible to argue that electric vehicles, heat pumps, or renewable generation technologies are feasible.  However, when the criteria are raised to include 24-7, 365 reliability and overall affordability with all the hidden costs included, then these technologies fail to deliver.  The only way I will be convinced otherwise is if there is a demonstration project that proves otherwise.

A coalition of community-based environmental groups and a few individuals, including me, recently filed comments with the New York Public Service Commission (PSC).  Our comments called for reconsideration of the PSC’s plan for reducing power plant emissions principally with large-scale renewables to meet the mandates in the New York Climate Leadership & Community Protection Act (Climate Act).  This post describes the submitted comments.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 350 articles about New York’s net-zero transition.  I have devoted a lot of time to the Climate Act because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good by increasing costs unacceptably, threatening electric system reliability, and causing significant unintended environmental impacts.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.”  In brief, that plan is to electrify everything possible using zero-emissions electricity. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan.  After a year-long review, the Scoping Plan recommendations were finalized at the end of 2022.  In 2023 the Scoping Plan recommendations are supposed to be implemented through regulation, PSC orders, and legislation.  The comments described follow a recent decision by the PSC to deny petitions seeking to amend contracts with renewable energy projects. 

Coalition Calls for Rethinking of Energy Plan

All Otsego recently described the comments submitted by an ad hoc coalition.  The submittal was filed to the Proceeding on Motion of the Commission to Implement a Large-Scale Renewable Program and a Clean Energy Standard, Case Number:15-E-0302.  The following listed parties submitted the comments: Glen Families Allied for the Responsible Management of Land (GlenFARMLand), Protect Columbia, Farmersville United, Freedom United, Litchfield United, Flyway Defense, No Big Wind, Centerville’s Concerned Citizens, Concerned Citizens of Rushford, Save Sauquoit Valley Views, StopCricketValley, Protect Orange County, Cattaraugus County Legislator Ginger D. Schroder, Esq, Gary Abraham, Esq., Roger Caiazza, David Sunderwith, and Greg Woodrich.

The All Otsego article provides a good summary of the comments:

TOWN OF COLUMBIA—A coalition of community-based environmental groups around the state filed comments with the New York Public Service Commission last week, calling for a reconsideration of the PSC’s plan for reducing power plant emissions principally with large-scale renewables.

According to the press release, the coalition is comprised of environmentally-minded people participating in the review of large-scale renewable energy projects around the state. The coalition points to physical constraints on the ability of wind and solar to contribute to carbon emission reductions and energy analysts who project that the electric grid will become less reliable as more intermittent renewables are connected. Backup power plants to ensure grid reliability and extensive infrastructure changes are needed to utilize wind and solar energy, coalition members contend, saying these are not warranted given the environmental damage renewables cause, along with potential health and safety hazards associated with the projects, including their battery storage systems.

“Large-scale renewables are being sited on prime agricultural land and are clearing thousands of acres of forests,” according to Ginger Schroder, a Cattaraugus County legislator and member of the coalition.

Schroder pointed to the 100-square-mile project area needed for the proposed Alle-Catt wind farm in western New York.

“Renewables require massive amounts of land, not only for sprawling solar and wind projects, but also for all of the additional transmission, storage, and backup generation needed. These are destroying communities,” Schroder said.

Steve Helmin with GlenFARMLand in the Town of Glen said, “Small rural communities across New York are being targeted as a result of poor planning and over-zealous expectations. The commission needs to step back and review what can work to meet our climate goals.”

Coalition member Nathan Seamon, with Protect Columbia in the Town of Columbia, added, “Since the passage of the Climate Leadership and Community Protection Act, New York State has moved from a 60 percent carbon-free grid in 2019 to one that is only 50 percent carbon-free today. Meanwhile, energy costs—for both natural gas and electricity—continue to rise.

“Upstate communities have been robbed of robust environmental review and fair tax revenue from underperforming industrial solar and wind projects which they are forced to host. How this makes any sense should be baffling to anyone who has paid attention to this over the past several years,” Seamon said.

The group is calling on the PSC to support a jobs and cost analysis of an energy transition that uses a diverse set of technologies, including nuclear and expanded hydropower, compared to one that relies on intermittent, unreliable, and environmentally unsound wind and solar.

“The Public Service Commission needs to put the words ‘leadership’ and ‘community’ back into the Climate Leadership and Community Protection Act,” coalition members insist. “Real climate leadership requires solutions that work in the real world and that do not destroy communities in the process.”

The 22-page document filed with the PSC on November 2 concludes: “…by respecting communities and embracing a balanced energy plan that supports the expansion of all carbon-free resources—including those capable of generating reliable electricity within an energy-dense footprint—the state can meet its climate goals, protect the environment and natural beauty of New York, and meet the needs of a vibrant economy. We urge the Commission to exercise its authority to help New York chart a course that accomplishes the latter.”

Can the State Respond?

Advocates for the Climate Act and the renewable energy developers argue that the energy transition must proceed no matter what because the Climate Act law says so.  However the recent PSC Order Denying Petitions Seeking to Amend Contracts with Renewable Energy Projects suggested that there are conditions that must be considered.  On page 39 of this order, it states:

We recognize that PSL §66-p(2) adds the pursuit of the 70 by 2030 and Zero Emissions by 2040 Targets to the Commission’s obligations but do not read the provisions of the more recent statute as superseding the Commission’s longstanding mandate to ensure that rates are just and reasonable. There is no indication in the statutory language or history that the legislature intended such a result, which could have the undesirable effect of driving ratepayer costs so high as to put the entire program at risk. To the contrary, the legislature provided the Commission with significant discretion under PSL §66-p(2) regarding how to establish the program to implement the 70 by 2030 and Zero Emissions by 2040 Targets by authorizing the Commission to “address impacts of the program on safe and adequate electric service in the state under reasonably foreseeable conditions,” as well as to “modify the obligations of jurisdictional load serving entities and/or the targets” based on consideration of such factors.

I believe that another provision of New York Public Service Law  § 66-p. “Establishment of a renewable energy program” includes safety valve conditions.  Section §66-p (4) states “The commission may temporarily suspend or modify the obligations under such program provided that the commission, after conducting a hearing as provided in section twenty of this chapter, makes a finding that the program impedes the provision of safe and adequate electric service; the program is likely to impair existing obligations and agreements; and/or that there is a significant increase in arrears or service disconnections that the commission determines is related to the program”. 

The PSC has a longstanding mandate to provide safe and adequate electric service.  The comments submitted describe many of the problems with the plan to use intermittent wind and solar resources that I believe will inevitably lead to unsafe and inadequate electric service.  I think that there are mechanisms that can be used to respond to the comments.  However, it is an open question whether the Hochul Administration will risk the wrath of the environmentalist constituency in the progressive left wing of her party and admit that implementation of the Climate Act may not be affordable and has unacceptable risks to reliability.

Discussion

I was asked to join the coalition late in the game so did not have a chance to provide comments to modify anything in the text.  Had I had a voice in the development of the text I would have pointed out that the claim that the New York State Department of Environmental Conservation (DEC) has not provided a Generic Environmental Impact Statement solar and wind development is incorrect.  They have done that evaluation, but it was completed in 2019 and does not consider the much larger number of wind turbines and solar panels that the Scoping Plan projects are necessary for the net-zero transition.  The cumulative ecological impact of the current plan due to its extremely low energy density and permanence of extensive infrastructure still needs to be evaluated. 

My only other quibble is the implication that fossil fuels should not be considered in the future.  Reliance on weather dependent wind and solar resources must address extreme variability in resource availability.  If that constraint is handled incorrectly, then electric energy will run out at the worst possible time.  The challenge of developing a dispatchable emissions-free resource to handle this possibility is immense.  The worst part, in my opinion, is that any long-duration storage option must push the physics envelope so this technology may be impossible.  Even if that challenge is overcome, the comments point out that the projected resources are on the order of the existing fossil fuel system resources and the expectation is that they will be used infrequently.  For example, if the future system is designed to provide support for a once in twenty-year event, then some portion of this resource will only be used every twenty years.  I cannot see any way to overcome the economics needed to pay the huge costs for this entirely new and untested resource such that it would be viable.  In order to address the problem, I think that retaining fossil fired resources for this rare but impactful event makes sense.  Even if the State came to its senses and developed nuclear resources as proposed in the comments, some share of reliable fossil resources probably makes economic sense.  The incremental global warming impact of those rarely fossil-fired resources would be insignificant.

Conclusion

The comments urge the PSC to “exercise its authority to avoid this tragedy by conducting substantive engineering, economic, and logistical analyses that should have occurred long before now.”  Obvious problems in other jurisdictions should be addressed now rather than wished away.  New York should also learn from places that successfully decarbonized. Throughout the world, “large economies that have achieved very low-carbon grids did so not by relying on underperforming intermittent generation, but instead by using high-capacity-factor firm resources—namely hydropower and nuclear—which are capable of producing abundant, reliable energy.”