Author: rogercaiazza

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

On February 17, 2021 Rick Karlin at the Albany, NY Times Union wrote an article comparing the Texas electrical grid and the New York grid relative to the power failures in Texas caused by extreme cold.  I agree with his conclusion that New York’s grid is sufficiently different than Texas so that something similar is unlikely to happen in New York.  However, I disagree with the experts that he interviewed that believe the primary problem going forward is the transmission system.  Instead, I think that trying to meet the Climate Leadership and Community Protection Act (CLCPA) zero-emissions mandate by 2040 for the electric system is the biggest challenge to future electric system reliability.

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.

Could a Texas-size power failure hit New York

Mr. Karlin interviewed a number of experts who argued that a mass failure of the state’s power grid was unlikely for a number of reasons. However, he went on to say “that doesn’t mean Empire State residents don’t have other threats to worry about.”  First, I will comment on the statements from the experts and then I will argue that their transmission threats are secondary to what I think is the primary threat for a future blackout.

I agree that one of the Texas problems is that their power grid has relatively few links to other transmission systems.  Karlin quoted Luigi Vanfretti, a professor of electrical engineering at Rensselaer Polytechnic Institute, who said “It’s about the ability to route the power”.  In this line of thought, if one state has a shortfall, electricity can easily be moved from another state.  Nick Bassill, a meteorologist and director of research and development at the University at Albany’s Center Of Excellence in Weather and Climate Analytics claimed that “Neighboring Oklahoma was also hit with record cold and snow but they didn’t have the mass outages Texas did since they could easily get power from other states”.  However, since the time of the article it became clear that neighboring grids were having similar problems and their own outages.  In the final analysis I believe that this is not the root cause of the problem.

Karlin pointed out a difference between Texas and New York is that Texas power plants “operate with looser regulations compared to New York, particularly when it comes to the Empire State’s stringent rules about having certain levels of capacity and spare fuel”.  He explained that:

“Power plants in New York have to demonstrate a certain maximum capacity, or the amount of power they can produce running at full steam, even though they may only rarely have to do so. These requirements are enforced through credits that can be sold in a capacity market, which Texas doesn’t have. There’s more.  In New York City, for instance, gas plants, which typically use either gas or oil, must have backup supplies of oil in case there is a gas line disruption or shortage.”

Another claimed difference is that Texas is heavily reliant on natural gas and wind whereas New York has a more diversified energy supply.  Although some have blamed the lack of wind production during the outage as a primary driver “most experts contacted by the Times Union said the stuck turbines were minimal compared to the frozen gas infrastructure”. “The gas pipes freezing was key,” said Vanfretti.  In New York Karlin explained that:

“Thirty nine percent of New York state’s power comes from fossil fuels meaning the plants can burn gas or oil (gas has been in favor lately due to low prices).  Another 22 percent is hydropower and about 30 percent is nuclear, as of 2019. Wind was 3 percent as of 2019.”

Karlin also explained that “Texas isn’t built for blizzards”.  Clearly “homes as well as gas line infrastructure in Texas aren’t designed or built for snow and cold, just as New York isn’t built for extreme heat.”  He went on to say that:

As temperatures plummeted, Texans turned their electric heaters or gas furnaces to the maximum, putting extra demand on gas lines that would normally feed power plants, leading to rolling blackouts.  “When you’re plunging down close to zero in northern Texas, suddenly there is a huge demand for heating,” said UAlbany’s Bassill, meaning that there may not be enough for power plants. “It’s the worst of both worlds.”

Finally, Karlin argued that New York’s bigger threat “likely lies with the state’s creaky system of power lines – many of which are above ground and vulnerable to storm damage”.  He explained that:

Venfretti believes the outdated transmission system, along with what he said is the primitive 1980s-era hardware used to monitor and control many power line substations, are among the biggest vulnerabilities.  The push for clean renewable energy is driving innovation in power generation but the transmission part of the equation is lagging, said Venfretti. It’s like a person buying a shiny new Mercedes to drive down a crumbling pot-holed road.  “The last thing people think about is the road they are going to drive their Mercedes on,” he said.

My Take on the Differences Between New York and Texas

I posted an article on the Texas situation and its implications for New York energy policy on February 18.  One distinction between this article and my analysis and a couple of others I found is that we addressed the systemic cause more than the specifics of this energy problem.  Ultimately the problem boils down to the importance of reliability.  In 2001 the draft New York energy policy stated: “Greater diversity in the types of fuel used for energy production could benefit all market participants, ensuring adequate fuel supplies and dampening price volatility.”  Everyone in the energy planning process at that time took as a fundamental principle that diversity meant a balanced and diverse portfolio with different kinds of dispatchable electric energy: coal, natural gas, oil, nuclear, and hydro.  The greater diversity mantra included different ways to transport oil and coal including railroads and barges as well as the ability to have fuels that could be stored for use as needed.  I believe that the New York energy planners who incorporated that mantra developed an energy system that is much more resilient to extreme weather than the Texas system.

The  systemic problem is the failure of Texas to include capacity payment in their market.  If the system is unwilling to pay for the power needed during rare events then the inevitable result will be a blackout.  It is incredible to me that a similar problem occurred in 2011 and that steps were not taken to fix them in ten years.   A former electric utility Planning Engineer has described his impression of the problems that lead to the debacle.  He agrees that the particular problem is that Texas only pays for the energy produced.  As a result, there is no incentive to develop the capacity needed for rare extreme conditions so when it was needed it simply was not there.  Importantly, he believes that the purpose of the payment for energy only market strategy was “to aid the profitability of intermittent wind and solar resources and increase their penetration levels.”

It appears to me that there is a shift to the same mis-guided policy priorities now underway in New York.  Planning Engineer explains that “Having a strong technical knowledge of the power system along with some expertise in finance, rates and costs can help one see the folly of a variety of policies adopted to support many of today’s wind and solar projects. Very few policy makers possess anything close to the skill sets needed for such an evaluation. Furthermore, while policy makers could listen to experts, their voices are drowned out by those with vested interests in wind and solar technology who garner considerable support from those ideologically inclined to support renewables regardless of impacts.”  This describes New York’s Climate Action Council and advisory panel Climate Leadership and Community Protection Act process perfectly.

Karlin interviewed Gavin Donohue, president and CEO of the Independent Power Producers of New York, who explained that New York’s current diversity of power sources provides a measure of resiliency.  Note, however, that when New York outlawed the use of coal at power plants they eliminated a source of power that used a fuel that could be stored on-site and stockpiled for emergencies.  The Climate Act eliminates the use of fossil fuel by 2040 further reducing balance, diversity, and flexibility to handle weather related load peaks.  It is not clear what will be needed to replace those attributes in the future.

Karlin also noted extreme weather events such as the derecho windstorms that took out power for several days in the Capital Region last fall, Superstorm Sandy in 2012, and the massive ice storm that in 1998 left eastern Ontario, Quebec, New Brunswick and a sliver of northern New York without power for weeks. While that wasn’t due to problems in power plants or a lack of alternate fuels, a diverse and balanced energy system is better able to address the impact of miles and miles of downed power lines.

Up to this point I only had minor issues with the article but then he wrote:

Others stress that redundancy going forward should be in renewables, given the climate havoc that greenhouse gases have caused.  “We need to be moving as swiftly as possible to 100% renewable energy,” remarked Peter Iwanowicz, executive director of Environmental Advocates NY.

Contrary to popular impression it is extremely unlikely that weather events associated with changes in the climate observed to date can be attributed to greenhouse gas impacts.  Advocates constantly confuse weather and climate and every time I have examined a weather event supposedly associated with climate change I have not been able to find a climatic change effect.  Following the usual pattern, there already are claims that the power system impacts were somehow due to climate change and not inadequate planning for this kind of extreme weather event.  Ten years ago, in February 2011, there was a similar extreme cold snap and blackouts also resulted because “coal and natural gas plants and electric utility companies didn’t have the resources to maintain service.”  If these conditions happened ten years ago then changes in climate did not increase the need for planning to meet events of the recent past.

Even more problematic is the suggestion that “moving as swiftly as possible to 100% renewable energy” will make society more resilient because there will be more redundancy.  The fact is that calling wind and solar diverse and redundant is a gross mis-characterization.  Solar energy is not diverse when every single solar facility in the state goes off-line at night.  Wind energy is not redundant when the winds are calm at night.  I believe that a comprehensive analysis of the New York joint frequency distribution of wind and solar energy resource availability is needed to determine the worst-case reliability needs scenario.  It is imperative to consider wind and solar availability over the same period and given that Texas extreme weather had a 10-year reoccurrence period I would say that the analysis should consider a minimum of ten years.  When the wind and solar resource availabilities are known then, and only then, can the wind, solar and energy storage resources necessary to prevent cold weather blackouts be established.  This has not been done.

Ultimately the problem is that the worst-case wind and solar renewable resource availability period is rare.  Keep in mind that New York’s Climate Act intends to reduce all fossil fuel emissions so heating and transportation will also have to be electrified.  That means that all the smart planning in the world is not going to be able to shave peak loads much if any.  If the worst-case resource availability period is associated with a period of high energy use then the electric system will be stressed.  In order to be able to provide adequate power during those periods will require expensive energy storage solutions which have not been identified in the Climate Act implementation process.

Conclusion

For the most part I agree with the conclusions in Karlin’s article. Up until this time the chances of extreme winter weather causing an electric energy shortage in New York similar to Texas are essentially nil.  Energy planners in State agencies, the Power Pool and at the utilities were committed to preventing it by developing an electric energy system with different kinds of dispatchable electric energy, developing on-site fuel storage with inventories able to cover extreme cases and enabling transport and delivery alternatives. Their foresight and commitment have given us a resilient electric system.

However, under the Climate Act everything changes when wind and solar replace fossil fuels.  The article did not mention that one reason that Texas does not have a capacity market is that payment for energy only was to aid the profitability of intermittent wind and solar resources and increase their penetration levels.  In New York’s electric market regulators are wrestling with a market design that can provide the appropriate signal for investors to provide power during the rare worst-case weather conditions that caused the Texas power failures.  That will be an experiment that may or not may be successful.

The experts interviewed believe that problems with the transmission system will be the biggest future vulnerability.  I disagree because I believe that reliance on just wind and solar during worst-case weather conditions is going to be a much bigger problem.  The fact is that there are inherent advantages to fossil fuels that cannot be easily overcome with intermittent and diffuse wind and solar.  At one time the New York energy planning process was more concerned about reliability and affordability for New York ratepayers than catering to ideological activists whose precautionary fears of potential climate change impacts override consideration of unintended reliability outcomes and costs.  I conclude that a Texas energy debacle is currently unlikely today but inevitable if New York’s Climate Act is implemented as currently mandated.

As I watched the Texas energy debacle unfold the last several days, I thought that I would end up posting an article about the implications for New York’s Climate Leadership and Community Protection Act (CLCPA).  This is my first response. It is becoming clear that the rolling blackouts and exorbitant electric prices that occurred in Texas were related to a lack of market support for diversity and resilient generation. There is no question in my mind that the CLCPA electric system envisioned by the Climate Action Council will be even less diverse and resilient so something similar in New York is inevitable if the transition unfolds as I expect.

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

As I write this on February 18, 2021 the causes of the electric system problems in Texas are unknown.  What is certain is that power outages left millions in the dark and without heat when a bitter cold snap brought snow, ice and temperatures in the single digits.  Electric loads hit record levels even as the electric system operators instituted rolling electric outages to reduce the power used in order to prevent even bigger blackouts.  There also appear to be issues with the generators not being able to provide enough power.  The wind resources were way down because of icing but apparently the natural gas fired units had trouble getting sufficient gas to run because the priority was for residential use. 

I have one anecdote that may be relevant.  When New York State deregulated the utility companies and I left Niagara Mohawk Power Corporation to go with NRG Energy who purchased the fossil plants I supported, one of the cultural awakenings was going to other power plants across the country.  One vivid memory was a visit to the massive Parish power plant outside of Houston and being able to see all the infrastructure.  I have heard that visitors from the south were also similarly impressed when visiting northern power plants and not being able to see all the infrastructure because the power house was enclosed.  The reason northern power plants are enclosed because trying to run a power plant when things freeze is very difficult.  I have heard that there are indications that monitoring equipment and water lines were failing due to the cold Texas weather.

One other note is that claims that these impacts were somehow due to climate change and not inadequate planning for this kind of extreme weather event are complete baloney.  Ten years ago, in February 2011, there was a similar extreme cold snap and blackouts also resulted because “coal and natural gas plants and electric utility companies didn’t have the resources to maintain service.”  If these conditions happened ten years ago then the root cause is weather and not climate.  Anyone claiming otherwise is ill-informed, naïve or lying.

Diversity and Resiliency

At one time the New York energy planning process was more concerned about reliability and affordability for New York ratepayers than catering to ideological activists whose precautionary fears of climate change override consideration of unintended consequences.  For example, the Draft New York State Energy Plan and Draft Environmental Impact Statement dated December 2001 includes this ultimate truth: “Greater diversity in the types of fuel used for energy production could benefit all market participants, ensuring adequate fuel supplies and dampening price volatility.”  Unfortunately, the first inklings of the renewable energy initiatives to come also showed up: “Moreover, a balanced portfolio of energy resources provides greater economic development opportunities within the State, particularly in the development of indigenous energy resources, including renewable energy resources, and energy service reliability.” 

The 2001 draft was the oldest energy plan I could find.  You will have to trust me when I say that everyone involved in this energy plan and earlier iterations, took as a fundamental principle that diversity meant a balanced and diverse portfolio with different kinds of dispatchable electric energy: coal, natural gas, oil, nuclear, and hydro.  The greater diversity mantra included different ways to transport oil and coal including railroads and barges as well as the ability to have fuels that could be stored for use as needed.  Arguably New York’s concern for reliability and avoiding blackouts is linked to New York City blackouts and the looting and vandalism that occurred during the 1977 blackout.  After every blackout extensive steps were taken to prevent a re-occurrence due to the same conditions and, more importantly, drove self-examination to address similar situations that might cause blackouts.  Although this process improved resiliency that term was not in use in 2002 and it was not used once in the draft energy plan.

Texas Lessons for the CLCPA

Alex Epstein summarized the resiliency problems that caused the Texas energy debacle in the following tweet and provided more details on his blog.

In my opinion the Texas debacle occurred because the energy regulators failed to manage the system to address the problems that occurred in 2011.  Epstein persuasively explains that a large part of the reason that they did not address those problems was because energy policy priorities were hijacked to policy that has prioritized the adoption of unreliable wind/solar energy over reliable energy.  A former electric utility Planning Engineer has described his impression of the problems that lead to the debacle.  He thinks that the particular problem is that Texas only pays for the energy produced.  As a result, there is no incentive to develop the capacity needed for rare extreme conditions so when it was needed it simply was not there.  The purpose of the payment for energy only market strategy was “to aid the profitability of intermittent wind and solar resources and increase their penetration levels.”

It appears to me that the same mis-guided policy priorities are underway in New York.  Planning Engineer explains that “Having a strong technical knowledge of the power system along with some expertise in finance, rates and costs can help one see the folly of a variety of policies adopted to support many of today’s wind and solar projects. Very few policy makers possess anything close to the skill sets needed for such an evaluation. Furthermore, while policy makers could listen to experts, their voices are drowned out by those with vested interests in wind and solar technology who garner considerable support from those ideologically inclined to support renewables regardless of impacts.”  This describes New York’s Climate Action Council and advisory panel process perfectly. 

What About New York?

In the early afternoon of February 15, I found out about the Texas problems and on a whim checked the New York Independent System Operator real-time dashboard to see what how much wind energy was available from the 24 facilities and nameplate capacity of 1,985 MW.  In hour 12 the entire on-shore wind fleet of New York generated 2 MWh.  Later I downloaded data and found that 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 totaled New York’s on-shore wind turbines produced a total of 765 MWh for a capacity factor of 2.6%. 

What about solar?  The NYISO does not provide solar generation data like it does for wind.  However, we know that nine hours were basically dark so there was no solar.  The CLCPA goal is 6,000 MW by 2025. That much solar and New York’s 2020 on-shore wind turbines that produced a total of 519 MWh those nine hours results in a pathetic capacity factor of 0.7%.  I also used the NYS Mesonet data to estimate that the total solar insolation available on February 15 was around 16% of the insolation available at the peak of availability near the summer solstice when the days are longest.  Clearly relying on wind and solar when these conditions occur is going to be a challenge because energy storage will be required to bridge the gap.

In 2040 all electricity currently produced by fossil fuels is supposed to be produced by zero emissions sources.  The “vested interests in wind and solar technology who garner considerable support from those ideologically inclined to support renewables regardless of impacts” intend that the replacement power will come from wind and solar.  Over the entire 17-hour winter doldrum fossil units produced 1,424,942 MWH and during the no-solar 9-hour period fossil units produced 588,838.  The best thing that can be said is that at least load is low in the early morning when solar energy is non-existent.  However, that does not help the fact that a minimum of 1,424,942 MWH less whatever solar energy can come from hopefully not snow-covered solar panels will have to come from storage. 

Note that a more detailed analysis to determine when wind and solar was able to replace all the energy produced by fossil units is needed to determine the total needed.  Assuming that the total energy will be at least equal to the 15-hour period energy when solar energy included and that the energy storage systems can provide power for four hours that means that 356,911 MW of energy storage are needed.  New York’s energy storage goal is 3,000 MW of energy storage by 2030.  That means that a minimum of two orders of magnitude more energy storage is needed just to cover this one period chosen simply by chance.  I believe that the State must do a comprehensive analysis of the joint frequency distribution of wind and solar energy resource availability to determine the worst-case reliability needs scenario.  It can be argued that even that analysis is inadequate because it would presume that wind and solar generating sources haven’t been damaged by an ice storm.  If New York fails to do this kind of analysis then an energy debacle comparable to Texas is the inevitable result.

Conclusion

The fact is that there are inherent advantages to fossil fuels that cannot be easily overcome with intermittent and diffuse wind and solar.  In the past the chances of extreme winter weather causing an electric energy shortage in New York were essentially nil.  Energy planners in State agencies, the Power Pool and at the utilities were committed to preventing it by developing an electric energy system with different kinds of dispatchable electric energy, developing on-site fuel storage with inventories able to cover extreme cases and enabling transport and delivery alternatives.  In the future, however, politicians have subverted energy policy for their agendas pushing reliance on just wind and solar. That is going to be an extreme challenge and calling that kind of system “diverse” is simply wrong.

To date all the analyses of wind and solar extremes have been limited to separate evaluation periods over shorter periods than I think are needed.  It is imperative to consider wind and solar availability over the same period and given that Texas extreme weather had a 10-year reoccurrence period I would say that the analysis should consider a minimum of ten years.  When the wind and solar resource availabilities are known then, and only then, can the wind, solar and energy storage requirements to prevent cold weather blackouts be established.

I encourage you to read Planning Engineer’s description of his impression of the problems that caused the Texas energy debacle.  New York’s de-regulated electric market is going to have to develop a market mechanism to support both the wind and solar generation facilities but also the energy storage needed to provide all the energy needed for a cold snap and the increased load when heating and transportation are electrified.  For example, say that the CLCPA planners determine that 200,000 MW of energy storage are needed to meet 90% of the energy requirements annually for their wind and solar development scenario, but 300,000 MW is needed for 95%, and 400,000 is needed for 99.9%.  Using those numbers means that 100,000 MW of energy storage will have to be supported in only 4.9% of the year so prices must be very high for a market solution.  Renewable energy advocates claim that “smart planning”, which I believe incorporates real-time pricing, will reduce the peaks but that is only theory.  The more likely reality is that because energy is really needed during these extreme weather events people will do whatever it takes to stay warm and end up paying exorbitant prices for that power.  It cannot end well for those least able to pay for their energy needs.

I conclude that a Texas energy debacle is currently unlikely today but inevitable if the CLCPA is implemented as currently mandated.

The 3 February 2021 Power Generation Advisory Panel included a chance for public input that deserves comment. Twenty-three people were given two minutes to speak.  More than half the presenters argued that nuclear power needs to be considered.  Only three speakers representing environmental advocacy or justice spoke.  Finally, the concluding thoughts of Department of Public Service Commissioner Rhodes claimed that the process has been unbiased.

On July 18, 2019 New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act (CLCPA), which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency.  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.

Public Input

At the 3 February 2021 Power Generation Advisory Panel there was a brief overview of the efforts of the Climate Action Council and the panel’s focus areas and discussions to date.  Most of the meeting was opened to the public to provide their thoughts and input. The meeting notes provide a brief summary of those comments and I have summarized the speaker’s affiliations and categorized their positions in a table.  My speaker categories included customer advocates, environmental justice and environmental activists, renewable energy development advocates, and a couple of people representing miscellaneous concerns.

I was surprised by the number of people who spoke out for nuclear power and I suspect so was the Panel.  I believe they were all associated with a pro Indian Point group.  All their comments were similar.  Clearly shutting down 2,000 MW of zero emission nuclear generating capacity is counter-productive if you really believe that climate change caused by anthropogenic greenhouse gas emissions is the existential threat used as the rationale for the CLCPA.  Commenters pointed out that CO2 emissions will go up as a result of the shutdown and that developing additional nuclear power should be considered as a strategy for the zero-emissions future.

I was also surprised by the fact that there were only four people arguing that wind and solar development needs to be supported more and accelerated.  I am not sure about the propriety of an organization represented on the panel to have a speaker present public comments.  Two people claimed community solar deserves more support.  The final speaker in this category was from Generate Capital, a sustainability investment firm who suggested new renewable technology is ready to implement.

I was one of two consumer advocates speakers.  It is difficult to say much in two minutes but I tried to point out concerns with affordability, reliability and feasibility.  The other speaker also addressed affordability and made the point that investments have be prioritized and cost-effective.

I was shocked that only three environmental activists spoke and two of them were worried about specific issues.  The one true believer said we have to act faster because we are running out of time.    I predict that future public sessions will be inundated with people making those claims and suggesting that wind and solar will solve all energy problems.  A lady from Fossil Free Tompkins County complained that behind the meter natural gas facilities are inimical with the CLCPA and that allowing a former coal-fired power plant to run on gas was wrong.  The environmental justice speaker was worried about a gas pipeline that was being built in her neighborhood.

The last two categories only had one speaker.  One lady who was worried about renewable development equity because most of the renewables will be sited Upstate and coincidentally some near her.  A student in a masters program in sustainability made the good point that reginal planning efforts to date have concentrated on transportation and more emphasis should be placed on renewable development.

Rhode Concluding Remarks

The lead person for the panel is Department of Public Service Commissioner John Rhodes.  I will end this post with an evaluation of his remarks.  The meeting notes described his concluding thoughts as follows:

• • • Appreciates and takes seriously the various comments that have been made. A thread of pro-nuclear environmentalism has been quite a presence of this chat.
    • Assures everyone that nothing nefarious in the composition of the panel.
    • Panel was selected by the CAC after a lot of input and deliberation, no bias desired, trying to make the most helpful recommendations.
    • Panel able to respond with better recommendations now that public has voiced this input

I believe that “thread of pro-nuclear environmentalism has been quite a presence of this chat” confirms my suspicion that the agency staff who are supporting this panel had no idea that was going to happen.  They are going to have to go into damage control mode because the arguments that retiring Indian Point is counter-productive are persuasive.  I suspect that the response will be to close ranks and ignore the issue.

The other nuclear speaker concern was that there was no one representing nuclear issues on the panel.  Rhodes response rings hollow.  He claimed that there was nothing nefarious in the composition of the panel.  Based on the definition “infamous by way of being extremely wicked: wicked in the extreme; heinous; abominable; atrociously sinful or villainous; or detestably vile” that may be true but claiming that no bias was desired is baloney.

I researched the membership of the Power Generation Advisory Panel last year.  The CLCPA Power Generation Advisory Panel attachment summarizes each member with a link to their organization including, where appropriate, a brief description of their organization’s mission, along with a summary of the individual named to the panel.  In order to be unbiased, the membership of the panel should have included members with expertise in all energy sectors.  The lack of a nuclear representative is a concern but the lack of anyone from the transmission utility industry is clear evidence of bias.  I understand from sources is that the utility industry tried to get representation but “after input and deliberation” a decision to exclude them was made by the Cuomo Administration.  That was clearly a mistake as evidenced by the fact that some sort of utility support group is currently being organized to provide expertise to the process.

The Advisory Panel is made up of people more representative of organizations supporting the political narrative of the CLCPA than the technical expertise necessary to implement the transition to zero emissions.  In an earlier post, I categorized the organizations represented by the 14 non-state agency members: three members work for generating companies, two renewable and one fossil oriented; one member is from the New York Independent System Operator, the state’s grid operating company; one member is a consultant for energy and sustainability issues; and the remaining eight members were from advocacy organizations representing either renewable technologies, the environment, or trade unions, with one representing ratepayers.

As I feared the representatives with the technical expertise to recognize the technological challenges are being drowned out by those that believe the myth of renewable energy magical solutions.  For example, in an electric energy system powered primarily by wind and solar, the transmission system has to be supported by services that are currently provided by fossil, nuclear and hydro generation but not available from wind and solar.  The power generation advisory panel should be leading the charge to make sure the transmission ancillary service problem is addressed but the issue has not even been raised at their public meetings.  Instead, there have been extensive discussions about the peaker power plant issue which I believe is an emotional problem not supported by reality.   I have seen no sign of any response to the comments I submitted to this panel on that topic.

Conclusion

The first public input session for the CLCPA power generation advisory panel was encouraging because there were comments presented by environmentalists arguing for the development of nuclear power in the future and pointing out that retiring existing nuclear facilities was counter-productive and someone else supported my affordability concerns.  However, I predict that future public input sessions will be dominated by environmental activists and renewable energy supporters.

John Rhodes claims that the advisory panel makeup was designed to be unbiased rings hollow when you look at the makeup of the members.  Representatives from the nuclear sector and transmission utilities should be on the panel.

As part of the implementation process of the Climate Leadership and Community Protection Act, on February 4, 2021 Energy Efficiency and Housing Advisory Panel had a public engagement session.  The agenda included their preliminary draft recommendations that are under consideration.   This post presents those recommendations with minimal comment.  I believe that most New Yorkers have no clue about the Climate Act, much less what will be required to meet the target goals.  These recommendations ought to be a wakeup call to them.

The Climate Leadership and Community Protection Act (CLCPA) establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency.  I have summarized the schedule, implementation components, and provide links to the legislation itself at CLCPA Summary Requirements and have also developed a summary of the implementation requirements.  In addition, I have written extensively on various aspects of the law.  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

Preliminary Draft Recommendations

The summary of the recommendations included six slides.  The screen captures of each slide is shown below with a few brief notes. Update 2/6/21: The meeting presentation with these slides is available here.

There have been similar strategies proposed for some cities but the recommendation to ban gas/oil for space heating, water heating, cooking and dryers for an entire state is a first.  I doubt that many in New York have any inkling that this is seriously being considered.

This strategy is for multi-family apartment buildings as well as commercial and industrial buildings.  

If they go through with these strategies then a lot of workers will be required but any claims about the number of jobs should be sure to consider the jobs lost too.

My particular concern is home heating and the transition away from fossil fuel options.  According to the most recent NYSERDA Patterns and Trends document in 2016 NYS residential fuel use was 75% fossil fuels.  The same document notes that there were 7,209,054 occupied housing units and 6,061,315 or 84% of them used fossil fuels for space heating.  If non-fossil fuel alternatives were cheaper, then those percentages would be smaller. Even access to “low-cost capital” comes at a price.  How much is needed and where will it come from?

The costs of these programs is going to be huge and this strategy does not include the cost of electrical service upgrades in neighborhoods.  When heating and transportation is electrified it is unlikely that existing distribution networks will be able to handle the loads without upgrades.

Every Advisory Panel includes anti-natural gas ideologues amongst its membership.  The language in this strategy reflects that.  I also think this obsession to get rid of fossil-fuel heating sources will lead to much greater reliance on wood-fired stoves for heat.  If that comes to pass the public health impacts will be much greater than the health impacts alleged to be associated with natural gas and oil.

Conclusion

When I was growing up during the 1950’s I remember the excitement when natural gas came to town so that my family no longer had to deal with maintaining our coal-fired furnace fire, dealing with the ashes and having a coal bin in the basement.  My first house had an oil-fired furnace and I do not miss dealing with an oil tank in the basement and worrying about oil deliveries.  Natural gas is simply more convenient and cleaner than other alternatives.  As a result, I like natural gas for heat, hot water, cooking, drying clothes, and, I even have a whole-house generator powered by natural gas.  In addition to cost savings, I am not comfortable that an all-electric home would protect my family in the event of a prolonged power outage.  In the last 40 years we have only had a couple of multi-day outages but we survived because we had access to natural gas. 

Frankly I was taken aback by these recommended strategies.  I have been following this implementation process and it was clear that fossil fuels would have to be banned but seeing that spelled out still was a shock.  In the introduction I said that I thought most people have never heard of the CLCPA much less had any idea of what would be required to meet the law’s mandates.  When people start hearing about these plans, I imagine enormous pushback.  I can only hope.