Author: rogercaiazza

Update: I have prepared three technical posts on this report: Once I completed these three posts, I realized that they were too wonky for a general audience.  The first post discussed their findings, the second post addressed their renewable energy forecast to meet the CLCPA, and the third post calculates the energy storage requirement for a winter peak period.  Because the CBC study is so important, I have prepared a less-technical summary that hits the highlights of all three posts.

On December 9, 2019 the Citizens Budget Commission (CBC) released a report entitled Getting Greener: Cost-Effective Options for Achieving New York’s Greenhouse Gas Goals  that addresses the impacts of the Climate Leadership and Community Protection Act (CLCPA).   There is much to like about the report but I disagree with a few of their recommendations and have concerns about some of the methodology.  In order to do this report justice, I have prepared three posts.  If you have an interest in New York energy policy I recommend that you read the entire document.  It is well written, comprehensively covers many of the issues associated with the CLCPA, and makes estimates of the resources needed to implement the CLCPA.  This post concentrates on their findings.  The second post addresses their energy forecast to meet the CLCPA and the final post calculates the energy storage needed.

Background

The CBC is a nonpartisan, nonprofit civic organization whose mission is “to achieve constructive change in the finances and services of New York City and New York State government”.  They claim to serve the public rather than narrow special interests try to preserve public resources, whether financial or human; and focus on the well-being of future New Yorkers which they say are “the most underrepresented group in city and state government”.

The CBC Energy Policy Committee managed the development of the report.  It was prepared for CBC by Seth Hulkower, President of Strategic Energy Advisory Services.  Apparently, this project has been in the works for a long time because the “initial findings of this report were presented at a CBC research conference held in New York City in December 2018”. The report was not completed until December 2019 because of New York’s changing policies over the past year.  In particular, the Climate Leadership and Community Protection Act (CLCPA) was promulgated in July 2019. They made revisions based on feedback from external reviewers and staff at the Public Service Commission and the New York League of Conservation Voters but noted that their willingness to assist in the research does not “imply any endorsement of the report’s findings and recommendations”.

Annotated CBC Findings

The report notes that New York is already green: “compared to other states it produced the fewest per-capita GHG emissions in 2016 and experienced the greatest percentage decrease in emissions– 13 percent– between 1990 and 2016”. Most of New York’s decrease occurred in the electric power sector as NY power plants shifted almost entirely away from coal and oil to increased use of natural gas and nuclear power.  They also say that during this time GHG emissions also decreased significantly in the industrial sector and declined slightly in the residential and commercial sectors. In contrast, emissions grew 25 percent in the transportation sector and that represents more than one-third of all GHG state emissions and over 40 percent of end-use energy.

The report explains that New York’s ability to continue to make such gains and to meet CLCPA goals is uncertain and gives the following reasons.  My comments are italicized.

1. 1. “Immense scaling up of renewable generation capacity is necessary and is likely infeasible by 2030. Much of New York’s GHG strategy rests upon continued reductions in the electric sector; specifically, state plans are to more than double renewable generation capacity, mostly from offshore wind turbines. However, it will be challenging to install the required resources by 2030: too few projects are underway and project timelines are lengthy and are likely to be delayed by extensive permitting procedures and often community opposition. New York is poised to direct the expenditure of billions of dollars and still fall short of the stated goals.”
      • I agree with these concerns. It is not clear to me what the amount of offshore wind turbines relative to other renewables will be because there is no state comprehensive plan.
   2. “The focus on building renewable resources, particularly offshore wind, and entering into long-term power contracts limits flexibility and diminishes consideration of other cost-effective approaches. Efforts to scale up renewables are necessary, but projects planned require the State to offer supplemental payments to make them work. Furthermore, the massive infrastructure investment required to procure offshore wind capacity will require long-term contracts that will lock in increased costs for electric customers for years to come. Based on analysis of a recent offshore wind project contract, meeting the renewable target entirely with offshore wind will increase electricity costs by $2.3 billion annually, an increase of between 8 and 12 percent to New Yorkers’ electric bills, which could be a significant increase in monthly living expenses for some low-income and working class New Yorkers. Other options may be more cost-effective, particularly as technology evolves in the long term.”
      • The importance of concern about locking in long-term contracts cannot be over-estimated. If the State does this wrong then we will be locked into significant cost increases for a long time.  Moreover, I think that their cost estimates are low because they only consider the cost of the turbines themselves and do not include the extra costs necessary to make off-shore wind power dispatchable.
   3. “State policies on nuclear, natural gas, and hydropower are counterproductive. First, the state’s six nuclear power plants are scheduled to shut down between 2020 and 2046. Elimination of the nuclear fleet will erase nearly all previous emissions gains as that power supply by necessity will likely be replaced in the near-term by natural gas, which produces greater emissions than nuclear power. Second, attempts to expand natural gas pipelines have been blocked, which resulted in moratoria on new gas installations downstate. Natural gas provides an economical alternative to dirtier fossil fuels and is a dependable source when renewable sources like solar and wind are not available. Third, while hydro is a key renewable resource, state policies have not supported use of hydro when construction of a new dam is involved, limiting the ability to access additional affordable and clean power from Canada.”
      • I admire the restraint of this section. Calling the policies counterproductive is kind.  The massive hypocrisy of on one hand calling for a response to an existential threat while at the same time shutting down operating nuclear plants begs out to be called stupid at least.  Energy facts undermine the current administration’s irrational war on fracked natural gas which is based purely on emotions.  Throw in the lack of support for hydro and the State’s energy future is not going to go through tough times.
   4. “The focus on other sectors—particularly transportation—is insufficient. The State’s strategy to tackle growing transportation emissions is focused on facilitating expanded use of electric vehicles, which is expensive and challenging for some parts of the state. Furthermore, achieving the long-term goals to cut GHGs by 85 percent will require electrifying almost all heating and transportation, affecting every home and business and nearly every vehicle in the state. This conversion from direct fossil fuel consumption to electric power will necessitate a dramatic further increase in renewable energy supply and energy efficiency: New York State will need to add an additional 94,000 Gigawatt hours of renewables, more than double existing renewable resources. It will also require an expansion of the state’s transmission capacity, which is already constrained from upstate to the downstate area, where most energy is used. The construction of offshore wind facilities will bring more renewable energy directly to the downstate market, but a larger mix of resources, some operating intermittently, will require an expanded transmission grid to deliver power throughout the state.”
      • This paragraph summarizes a fundamental issue with the CLCPA very well. On one hand the State proposes to completely re-make the energy production system while simultaneously increasing our dependency upon reliable power.  The only thing I would add to this discussion is a concern about resiliency.  What happens when everyone depends on electric heat and an ice storm takes out the power lines?

The report introduces the recommendation summary with the following:

While GHG emissions have risen in other large states like Texas and Florida, New York has been a leader in reducing GHG emissions; the focus on further emissions reductions is necessary and important. The challenge now is to find the most efficient approaches to secure the greatest amount of incremental carbon reduction per each dollar spent. Doing so will require tackling emissions across all sectors; maintaining optionality in the approaches used; and partnering with other states and Canada.

• • • • I take exception to the comment “the focus on further emissions reductions is necessary and important” because the State has never provided its estimates of the effects these policies on global warming potential. By my calculations, the ultimate impact of a 100% reduction of New York’s 1990 218.1 million metric ton of emissions on projected global temperature rise would be a reduction, or a “savings,” of approximately 0.0032°C by the year 2050 and 0.0067°C by the year 2100.  This small a temperature difference cannot be measured.  I don’t accept those changes as necessary and important.

The report offers the following six recommendations:

1. Establish an economy-wide carbon pricing system to deliver effective price signals to energy consumers. Two options for such a system are: (1) a carbon fee and (2) a cap-and-trade system. To be most effective, these policies should be implemented on at least a regional, if not national, scale, so that dollars are directed most effectively toward the dirtiest energy sources and states. CLCPA tasks the New York State Department of Environmental Conservation with estimating a “social cost of carbon,” that is, a monetary figure capturing the costs of an incremental increase in carbon emissions, an important step for implementing a pricing scheme. New York is already a member of the Regional Greenhouse Gas Initiative (RGGI), an effective 9-state cap-and-trade system covering the electrical generation power sector. To be most effective RGGI should be expanded to other sectors of the economy, including transportation.
   • Carbon pricing has theoretical appeal but in practice I am very pessimistic that the results will work out as planned based on the results of the Regional Greenhouse Gas Initiative. CBC correctly recognizes that carbon pricing should be economy-wide and regional, if not national, to be successful but appears to favor a tax where “dollars are directed most effectively”.  The problem with that is that it is regressive and hurts those least able to afford it the hardest.  Trying to address a regressive tax makes this approach less effective.
   • CLCPA notes that determining a social cost of carbon is part of the CLCPA. Aside from the very real issues associated with that value it is not clear that the social cost of carbon is an adequate price signal for renewable energy development.
   • CBC states that RGGI is an “effective 9-state cap and trade system”. In the first place it is not a cap and trade program it is simply a tax masquerading as a cap and auction   More importantly, it is not particularly effective because I have shown that RGGI itself was responsible for only 5% of the observed reductions since the inception of the program.  Finally, the Accumulated Annual Regional Greenhouse Gas Initiative Benefits table shows that the cost per ton reduced from RGGI investments ($897) are far in excess of the $50 global social cost of carbon at a 3% discount rate.  Because the social cost of carbon is an estimate of the economic damages that would result from emitting one additional ton of greenhouse gas this means that RGGI investments are much more costly than the economic damages.
2. Look beyond New York’s borders for low-cost, low-emission energy supplies and to cut GHG emissions. New York should explore the possibility of a multi-state buyers’ consortium to purchase large-scale low- and zero-GHG energy resources. New York, New Jersey, Connecticut, Rhode Island, and Massachusetts are all in the process of developing offshore wind energy projects. The states are seeking low-cost electricity, but also vying for jobs from the burgeoning offshore wind industry. Rather than compete, these states should work together to bring the most cost-effective resources to the market. Another opportunity is to import Canadian hydropower, which is competitively priced and clean.
   • No comment – this seems reasonable.
3. Retain nuclear energy to retain the benefits of carbon avoidance. The state’s nuclear facilities operate with the help of subsidies, known as Zero Emissions Credits, that expire in 2029. If these subsidies are not extended, the nuclear plants may shut down while still holding valid operating licenses. The state should explore further extensions of these operating licenses with the U.S. Nuclear Regulatory Commission. The implementation of a properly priced carbon fee would be a benefit to the nuclear plants, which generate no greenhouse gases.
   • CBC recognizes that if there is a climate emergency then reducing power from the largest source of carbon free electric generation in the state is counter-productive.
4. Avoid self-imposed constraints such as limiting gas pipeline capacity. A strong preference for renewable energy has resulted in constraints on expansion of natural gas. Denying permits to several natural gas pipelines is constraining energy markets to the point that New York will not be able to reap the GHG reduction benefits of converting home heating from oil to natural gas. Likewise, a lack of stable natural gas supply for new businesses may harm the state’s economic competitiveness. Regulatory and legal actions should not hamper use of resources that can continue to reduce GHG emission and provide reliable energy solutions. New York should create a competitive market of options to reduce greenhouse gases.
   • CBC recognizes that renewable energy implementation for the entire energy sector is a long-term process and that natural gas should be an interim part of the transition or a rational energy plan when the State realizes it cannot afford the CLCPA boondoggle.
5. Promote broad transportation solutions that build on existing infrastructure. New York has made a large commitment to electric vehicles that will subsidize both car buyers and the construction of charging stations. This is an expensive GHG emissions reduction strategy. Greater emphasis should be placed on one of the areas that has made New York a low GHG-emitting state: energy-efficient public transportation. While a hybrid or electric vehicle produces fewer GHGs than a gasoline powered vehicle, public transportation produces even less per passenger mile traveled.
   • CBC recognizes that the commitment to electric vehicles is expensive and suggest greater emphasis on energy-efficient public transportation. I agree with the sentiment but the problem is what do you do in rural and suburban areas where cost-effective public transportation is out of the question.
6. Establish a prioritization system to pursue renewables that provide the greatest GHG reductions at lowest cost. Renewables are and must be an increasing part of the state’s energy portfolio; however, policymakers should allow price signals to determine how much wind capacity, distributed solar, utility-scale solar, and hydropower is built rather than mandating specific technologies. All these projects should be put on a common basis of cost to consumer for tons of GHG avoided and those with the lowest net cost should be prioritized for development and contracts. A balanced portfolio of resources and contract term lengths will provide New York with the greatest security and stability to reach its long-term GHG reductions goals. This also will allow for competition from new resources so that if newer projects can be completed at lower cost, New York will reap the benefit. It also allows for the possibility that leaps in technology will be able to fill the mix rather than being locked into old technology for 20 years. New York is now leading the way on greenhouse gas reductions, but it should also lead the way in using competition to provide the greatest emissions reductions at the lowest cost.
   • I agree that spending priorities should be established based on emission reduction cost effectiveness but I think if CBC spent some time looking at the numbers, they would be surprised how expensive these technologies are. I fully support their suggestions to minimize future financial exposure.

Summary

The findings support my position that the State needs to do a feasibility study to determine how the CLCPA could be implemented. I will address their renewables analysis in a future post but the spoiler alert is that it requires massive renewable development.  This will require enormous investments and the findings point out the financial and flexibility risks if those investments are funded incorrectly.  They also raise the concern that existing sources of nuclear and hydro zero emitting generating power are not currently encouraged to remain in operation and suggest that discouraging natural gas infrastructure is counter-productive.  The final finding is the observation that there is much work to be done to implement the CLCPA targets for other sectors.  I agree with all these concerns.

The report makes a number of recommendations.   I agree that the State should prioritize investments based on performance, look beyond New York for additional sources of reduction support, eliminate self-imposed constraints on natural gas use, and retain our existing nuclear energy capacity as long as possible.  I do not think that a carbon pricing system will work if it only applies to New York or a limited region so I disagree with their recommendation for one even if it is across all sectors. Their transportation recommendation to think beyond electric vehicles for reductions makes sense where public transit investments could be cost-effective but that precludes rural areas.

Although I am not on board with the CBC’s desire to do something because it is “necessary”, I am encouraged that an organization that feels that is necessary realizes the magnitude of the effort and the very real possibility of massive future financial exposure.  The CBC report underscores the potential that doing something wrong would not be in the best interests of the State no matter how noble the intention.

A new report prepared at the request of the New York Independent System Operator (NYISO) addresses issues associated with an electric system reliant on renewable energy sources during the winter.  This post compares these results with my previous work related to New York’s Climate Leadership and Community Protection Act (CLCPA) and discusses the implications on that law.

The Citizens Budget Commission developed an overview of the CLCPA targets in Green in Perspective: 6 Facts to Help New Yorkers Understand the Climate Leadership and Community Protection Act.  The goals of the law are truly aspirational:

Reduce greenhouse gas (GHG) emissions:

• • • Reduce GHG emissions to 60 percent of 1990 emissions levels in 2030;
    • Generate zero GHG emissions from electricity production by 2040; and
    • Ensure GHG emissions are less than 15 percent of 1990 emissions levels in 2050, with offsets to reduce net emissions to zero.
    • GHG offsets means that for every ton emitted into the air one ton is removed via GHG capture of some sort. For example, a company or individual can pay a landowner to leave trees standing that would otherwise be removed or plant additional trees to offset GHG emissions.

Increase renewable electricity:

• • • Increase renewable sources to 70 percent by 2030; and

Develop or support:

• • • 9 gigawatts (GW) of offshore wind electric generation by 2035;
    • 6 GW of distributed photovoltaic solar generation by 2025; and
    • 3 GW of energy storage capacity by 2030.
    • Conserve 185 trillion British thermal units (TBTUs) of annual end-use energy use by 2025, of which at least 20 percent should be from energy efficiency improvements in disadvantaged communities.
    • The CLCPA also requires between 35 percent and 40 percent of spending on clean energy or efficiency programs be in disadvantaged communities and mandates an air monitoring program in at least four such communities.

I have evaluated winter peak impacts in previous posts on New York Resource Adequacy Proceeding Comments, Solar Issues in Upstate New York , CLCPA Solar and Wind Capacity Requirements and CLCPA Energy Storage Requirements.  My primary concern is the requirement to generate zero GHG emissions from electricity sector production by 2040 coupled with the increased load needed to electrify the heating and transportation sectors enough to meet the 85% reduction by 2050 target.

Fuel and Energy Security In New York State Report

NYISO  had the Analysis Group do a forward-looking assessment of the fuel and energy security of the New York electric grid during winter operations.  The November 2019 final report was titled: Fuel and Energy Security In New York State: An Assessment of Winter Operational Risks for a Power System in Transition.  The objective was to assess winter fuel and energy security risks and identify key factors that would affect risks. Specifically, the study targeted potential reliability risks and impacts under severe winter conditions and adverse circumstances regarding system resources, physical disruptions, and fuel availability.  Importantly it is a snapshot of the winter of 2023-2024 before the CLCPA renewable energy and electrification of other sectors implementation really kicks in

Previously I have analyzed the effect of winter peaks and I chose 12/29/17 to 1/12/2018, a period that is included in their analysis.  The Analysis Group defined extreme weather events including the largest increase above average daily load over a long period as 14 days from 12/25/2017 to 1/8/2018 and more extreme shorter periods where they found in the last 25 years the fourth lowest 3-day cold snap was 1/4/2018 to 1/7/2018.  Then they evaluated different scenarios that included different combinations of “(a) timeframe for the development of new renewable resources; (b) capacity imports from neighboring regions; (c) potential retirement of units affected by the peaker rule; and (d) availability of natural gas for power generation”. The evaluation determined where these scenarios might cause problems.

The analysis included the following relevant conclusions (two key points underlined by my emphasis):

• • With the continued operation and availability of most of the assets currently expected to be in place in the winter of 2023/2024, the NY grid contains sufficient diversity and depth of fuel supply to support reliable winter operations. This result is consistent with the historical operating experience in recent past winters, including during severe weather conditions.
  • Meeting the state’s renewable and clean energy goals can provide valuable reliability support, and may be particularly true with respect to offshore wind. Delayed realization of renewable resource additions (as compared to the 2017 CARIS Phase 1, System Resource Shift case levels that are assumed under initial conditions) can lead to potential LOL events that would not otherwise occur when combined with other adverse system conditions. The potential magnitude and pace of change to the resource fleet stemming from requirements under the CLCPA may be of far greater importance for evaluation than the considerations, scenarios and physical disruptions evaluated in this fuel and energy security study with respect to winter operational risks.
  • The availability and contributions of adequate levels of natural gas-fired and oil-fired (or dual fuel) generating resources is necessary to maintain power system reliability in cold winter conditions in the near-term. This is particularly true for Long Island and New York City. Simply put, avoidance of potential loss of load events in these load centers, under plausible adverse winter conditions, requires operation of natural gas and oil-fired units. Reduction in the generation available from such resources – whether through capacity retirements, low initial oil inventories, reduction in natural gas availability for power generation, or interruptions in the ability to refuel oil tanks throughout the winter represents the most challenging circumstances for reliable winter system operations in New York over the coming years.

Implications for CLCPA

The analysis notes that the “potential magnitude and pace of change to the resource fleet stemming from requirements under the CLCPA may be of far greater importance for evaluation than the considerations, scenarios and physical disruptions evaluated in this fuel and energy security study with respect to winter operational risks”.  I agree because I believe that it is absolutely necessary for the State to prove that when the energy load increases when other sectors are electrified that fuel and energy security can be maintained without using fossil fuels.

The analysis also states that “Simply put, avoidance of potential loss of load events in these load centers, under plausible adverse winter conditions, requires operation of natural gas and oil-fired units”.  The CLCPA requirement that all electric energy must come from non-fossil fired sources in 2040 is an extraordinarily difficult goal to meet.  The political calculus to include this in legislation was not backed up by any analysis.  The state has to show how this can be done as soon as possible lest New York resources be squandered on an impossible quest.  As I show below, the actual renewable resource may not support this target because of logistical issues and even if it does there may be immense costs.

Need for Renewable Energy Resource Analysis

In my back of the envelope analysis of the summer peak energy storage requirements I used actual wind speed data to estimate the New York off-shore wind resource.  New York State awarded the first two contracts for off-shore wind projects in July 2019.  The Equinor 816 MW winning project press release said “The project is expected to be developed with 60-80 wind turbines, with an installed capacity of more than 10 MW each”.  Among the many details redacted in the public version of their proposal was specific information on the proposed wind turbines.  The public version included a diagram of the proposed wind turbine size as compared to the Chrysler building and showed that top tip of the blade at 250 m.  I estimated the hub height to be 173 m by scaling the drawing.  In this analysis I characterized wind energy output as a function of observed wind as follows.   I found a wind turbine power output variation curve that had a cut-in speed of 3.5 m/s and a cut-out wind speed of 25 m/s. Using that wind variation curve, I estimated that output of each 10.2 MW wind turbine will equal 0.971 times the wind speed minus 3.4.

For the input meteorological data, I found a National Oceanic and Atmospheric Administration buoy located 30 nautical miles south of Islip, NY (40°15’3″ N 73°9’52” W) that I used to represent NY offshore wind resource availability. The observed wind speed at the hub height is proportional to the logarithm of the height above ground.  For that calculation I assumed a hub height of 173 m and a surface roughness of 0.0003 using the buoy anemometer height of 4.9 m. I downloaded hourly NDBC data for 2018 and 2017 and calculated the wind energy output for every hour in the period 12/25/2017 to 1/8/2018 using that relationship and the wind turbine output variation equation I derived.

The key finding is that there were two no wind energy output periods on 3-4 January 2018 during an intense cold snap when electric load is high as shown in the New York Off-Shore Wind Generation Estimate for 9000 MW CLCPA Off-Shore Target table.  I was surprised to see that the wind resource went to zero during a high load period not only when the winds were light on January 3 but also when a deep low pressure developed and the wind speeds exceeded 25 m/s on the very next day.  The wind generation estimate table lists the output from a single 10.2 MW wind turbine, 80 turbines in the Equinor proposed wind facility and for all 9,000 MW of Cuomo’s CLCPA target of 9,000 MW of off-shore wind.  It is important to note that adding even more wind turbines still does not preclude the need for substantial energy storage.  While all the New York off-shore wind resource may not go to zero simultaneously that resource is going to be highly correlated across the available area so they all will track closely.

Conclusion

Every time I look at the meteorological data relative to the winter peak I get a surprise.  I expected that the winter observed peak load would occur during very cold weather associated with a slowly moving high pressure system that originated in the cold northern plains large enough to cover the entire northeastern US.  The resulting multi-day period of clear skies, light winds, and inherent cold temperatures would result in very high energy demand for heating.  The early January 2018 high load period was very different.  Weather maps for this period show (January 2018 Weather Maps) a relatively small high pressure system in the central US on January 2 that moved east ahead of a storm system on January 3.  The high pressure was strong enough over the New York offshore wind region that winds were less than 3.5 m/s for five hours on January 3.  However, the storm system moved eastward and re-developed into a strong storm just off the coast on January 4 with an eleven-hour period of greater than 25 m/s wind speed 13 hours after the light wind period ended.  By January 5 the storm had raced northeast to the Canadian Maritimes but was pumping cold air back across New York State.

This period must be analyzed in more detail by New York State to determine whether the CLCPA requirements endanger fuel and energy security.  If the assumptions I used for no wind power due to light winds and strong winds are correct then there will be 16 hours of no wind power in a 29-hour period during the coldest extended duration cold weather event that the Analysis Group identified after analyzing 25 years of data.  Furthermore, it also overlaps fourth worst 3-day cold snap.  The State needs to estimate what the future load will be when the home heating and transportation sectors are electrified to meet the CLCPA emission reduction goal and then assess whether renewable resources will be adequate during the entire extended duration period using the proprietary energy output information in the renewable energy proposals submitted to the State not only in the NYSERDA off-shore wind program but also the Article Ten applications.  This analysis has to be done for the entire state and obviously will lead to an estimate of the amount of energy storage necessary in 2040 when no electric energy from fossil-fired facilities is allowed.  It is not clear to me if there is enough space available where it is needed to site all the renewable and energy storage necessary.  Even if there is enough space, this analysis will provide the information needed to estimate how much all this will cost.

Frankly, it is laughable that the New York State legislature and Governor Cuomo enacted a law mandating specific energy and emission reduction goals without doing such an analysis first.  I believe it is time for the energy professionals in the State to step up and demand such an analysis before the State squanders money on a system design that can only be implemented with massive wind, solar and energy storage development.  Even if this system could be developed it will surely be expensive.  Just how much is anyone’s guess until such a study is completed.

The Brattle Group recently released a report entitled “Achieving New England’s Ambitious 2050 Greenhouse Gas Reduction Goals Will Require Keeping the Foot on the Clean Energy Deployment Accelerator”.  The primary emphasis of this blog is on New York environmental and energy policy issues so this post applies their renewables needed estimate to the New York’s Climate Leadership and Community Protection Act (CLCPA) requirements.

In particular, the Brattle report notes that in order to reduce greenhouse gas emissions from the whole economy it will be necessary to electrify transportation and heating which will increase electric load.  They estimate that in order to meet New England’s goal of an 80% reduction by 2050 that electricity demand could be “twice the current level by 2050”.   I have yet to see any New York agency estimate of future load for the CLCPA so I decided to try to estimate how much renewable energy would be needed if New York electric load doubles by 2040 at the same time that New York electric load is supposed to eliminate fossil-fired generation.  I used that estimate to estimate how much renewable energy capacity (MW) in the form of on-shore wind, off-shore wind and solar could be needed in New York in 2040.  I determined how much power (MWh) was used in 2018, doubled that, and then guessed how the necessary capacity could be distributed between on-shore wind, off-shore wind and utility solar.

Brattle Key Findings

The Brattle Group prepared their report on behalf of the Coalition for Community Solar Access.  According to the news release there were several key findings:

• • • Electricity will play a critical role in decarbonizing the New England economy. As a result, electricity demand will grow substantially and could well be twice the current level by 2050.
    • In supplying this growing demand for power, both solar photovoltaic (PV) and offshore wind will likely play a critical role.
    • Merely maintaining the current rate of clean energy resource deployment will cause the region to fall short of its targets. Currently planned clean energy resource generation for 2019–2030 in New England amounts to approximately 830 MW per year. This represents a significant increase from the historical generation of 280 MW per year from 2010–2018.
    • However, to achieve the 2050 targets, New England will need to accelerate clean energy resource additions to between 4 and 7 GW per year on average between 2021 and 2050.
    • To reach these levels, annual clean energy resource additions will need to continue to grow by approximately 9% per year through 2050.

Procedure

The first step is to determine how much generation was used in 2018.  I used the 2019 NYISO  Load & Capacity Report “Gold Book” Summary of Table III-3c 2018 Annual Net Energy Generation by Zone and Type to estimate 2018 energy generation by generator type and I have included a consolidated summary of data by fuel type.  Note that fossil fuel accounted for 41.9% of the generation in 2018.  Total load was 135,585 GWh so a 2040 doubled load will equal 271,170 GWh.

Estimating the feasibility for future development scenarios is difficult.  The Projected Net Energy Generation in 2040 table lists the assumptions I made to determine how New York generation could meet the doubled load.  There are three main components of the response: expand output from pumped storage and conventional hydro, maintain nuclear, and expand renewable combustion (landfill gas and municipal waste incineration); reduce load through energy efficiency, tighter codes & standards, behind-the meter (BTM) distributed solar and BTM non-solar distributed generation; and utility scale on-shore wind, off-shore wind and solar.

In the first component I estimated future generation as a function of fuel type.  The CLCPA law requires that all fossil-fired electric generation be replaced by 2040 so I zeroed out potential generation in those categories.  Although I have seen claims that additional hydro generation can be developed, I doubt that those resources could ever exceed a 10% increase over current levels.  In 2040 I estimated that only Nine Mile 2 nuclear would be operating because all the other nuclear generating stations would be over 60 years old.  The renewable combustion category includes internal combustion from landfill gas as well as wood and refuse fired steam generators.  I assumed that those resources could only increase 10% over current levels.  The result is that Component 1 can only cover 18.4% of the estimated load.

Reducing energy use through energy efficiency, improvements in codes and standards for energy use, behind the meter solar, and behind the meter non-solar distributed generation will reduce the amount of energy needed in Component 2.  Table I-b: Summary of NYCA Annual Energy Forecasts in the Gold Book lists GWh projections for these categories in 2040. The Gold book also includes tables that provide the net energy and the estimated capacity for each of these categories.  Since the publication of the 2019 Gold Book, the distributed solar deployment target was increased to 6,000 megawatts by 2025, up from 3,000 megawatts by 2023.  I adjusted my projection for that by assuming 6,000 MW in 2025, that observed energy per capacity would remain the same and that the annual increase after 2025 would be the same as the Gold Book projection.  Instead of 5,928 GWh from 4,525 MW of distributed BTM solar I estimate 9,847 GWh from 7,517 MW in 2040. The result is that Component 2 can only cover 13.6% of the estimated load.

The last component of the expected load is utility-scale wind and solar. On the basis of the assumptions for components 1 and 2, these resources will have to provide 68% of the load or 184,285 GWh.  In my opinion, this requirement will lead to a large increase in imported generation but if we assume that is not the case, this will require a massive buildout of large renewables.  In round numbers this buildout will require development of 9,214 GWh of generation output per year as shown in the Projected Renewable Energy Resources Needed to Meet Doubled Annual Electric Load in 2040 table.

In order to determine how much capacity will have to be developed to generate that much energy capacity factors have to be used.  In 2018, 1,739 MW of on-shore wind produced 3,985 GWh of net energy and 32 MW of utility solar produced 49 GWh of net energy.  Those observed values can be used to determine an on-shore wind capacity factor of 26% and a utility solar capacity factor of 17%.  I assumed those capacity factors for 2040.  Off-shore wind capacity will be developed by 2040 and I assumed a capacity factor of 50% based on the NYSERDA assumption for its recent awards. Using those capacity factors, I arbitrarily picked an annual development rate to meet the 9,214 GWh annual rate target.  I calculated that 1,050 MW of on-shore wind, 1,500 MW of utility solar and 1,050 MW of off-shore wind which will generate 9,293 GWh additional energy per year which exceeds the target development rate.

Sanity Check

One question is whether my arbitrary future renewable energy choices are reasonable.  I compare those numbers to an earlier wind analysis and NYS announced projects below.

The National Renewable Energy Laboratory sponsored the Eastern Wind Integration and Transmission Study (EWITS) and that report includes an estimate of future NY wind requirements.  The study was designed to examine the operational impact of up to 20% to 30% wind energy penetration on the bulk power system in the Eastern Interconnection of the United States. It included development of a database of wind resource and plant output data for the eastern United States.  One of the scenarios modeled 30% penetration of wind energy into the total energy consumed.  The scenario was labeled “Aggressive On- and Offshore” and required “a substantial amount of the higher quality wind resource in the NREL database” and noted that a “large amount of offshore generation is needed to reach the target energy level”.  The total wind capacity projected for the New York State Independent System Operator to meet a 30% penetration level was 23,167 MW of on-shore wind and 9,280 MW of off-shore wind.  The total on-shore wind capacity projected for the arbitrary choice is 20,000 MW and that compares well with the EWITS value, but the arbitrary choice for total off-shore wind is 23,000 MW more than double the EWITS value.

Another sanity check is to compare the annual generation development predicted with the queue of New York Projects.  In New York all utility scale projects over 25 MW are required to go through an Article 10 review process.  As part of that process all the projects in the review queue are tracked.  The New York State Department of Public Service Article Ten Project Queue table lists the MW capacity for projects summed by technology proposed categories and the year the permitting process began.  In the best year 1,478 MW if wind projects started permitting and in 2019 to date there have been 3,193 MW of solar and solar plus storage projects have started permitting.  Therefore, it appears that my guess that 1,050 MW of on-shore wind and 1,500 MW of utility solar development per year is possible.

Conclusion

The Brattle estimate for the additional energy needed to power all the electrification necessary to reduce CO2 emissions in New England by 80% is double the current load.  Thus, when New York State gets around to proposing how much energy might be necessary for the CLCPA, it is not unreasonable to expect that it will be at least two times the current amount.

At some point the intermittent and diffuse nature of renewables will have to be addressed.  Because renewables are intermittent, storage to cover light winds and low solar irradiance will be required.  Because they are diffuse transmission links to move the power as needed are also required.  As a result, the renewable generating facilities will not only have to replace existing fossil-fired dispatchable load but also provide support to the transmission system that is currently provided by those facilities.  I believe that will add to the amount of renewables needed.

When New York State gets around to proposing how much energy might be necessary for the CLCPA, it is not unreasonable to expect that it will be at least two times the current amount.  The wild guess estimate of the renewable capacity does not appear to exceed any feasibility threshold but there are some caveats.  For all components of the proposed response the problem of diminished returns on investment cannot be dismissed.  For example, it is not unreasonable to expect that the best on-shore wind development sites will be developed first and may in fact be already developed.  Consequently, later developments are going to have to go to sites with a lower potential wind resource so the capacity factor for future developments will be reduced.  The same problem should be expected for distributed solar, utility solar, and energy efficiency investments.

There are other issues of course.  First, and foremost, is cost.  There are also logistical issues developing this much renewable energy over this time frame.  Finally, note that given that the expected lifetime of these renewable projects is on the order of 20 to 25 years, there will be an eventual de-commissioning and re-development steady-state of constant investments required forever in the future.