Category: Air Quality Issues

On February 6, 2024 the PEAK Coalition sponsored a webinar entitled “Replacing NYC’s Peaker Plants With Clean Alternatives: Progress, Barriers, and Pathways Forward” that follows up on their recent report: Accelerate Now! The Fossil Fuel End Game 2.0.  There are disconnects between the findings of that report and the first webinar of this year’s New York Cap-and-Invest (NYCI) Program stakeholder engagement process: The Role of Cap-and-Invest (slides and webinar video) and the material presented at the Department of Public Service Proceeding 15-E-0302 technical conference held on December 11 and 12, 2023 entitled Zero Emissions by 2040.    

I did not intend to write so much about this topic but Pragmatic Environmentalist the Baloney Asymmetry Principle came into play.  Alberto Brandolini has explained that: “The amount of energy necessary to refute BS is an order of magnitude bigger than to produce it.” My apologies for the length.

I have followed the Climate Leadership & Community Protection Act (Climate Act) since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 380 articles about New York’s net-zero transition. The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The PEAK coalition has stated that “Fossil peaker plants in New York City are perhaps the most egregious energy-related example of what environmental injustice means today.”  The influence of this position on current New York State environmental policy has led to this issue finding its way into multiple environmental initiatives. I have prepared a summary of this issue for this blog that explains why the presumption of egregious harm is based on selective choice of metrics, poor understanding of air quality health impacts,  and ignorance of air quality trends.  The page documents my concerns based on my extensive experience with air pollution control theory, implementation, and evaluation over my 45+ year career as an air pollution meteorologist.  Before I discuss their latest report and the webinar I provide some background information from the Role of Cap-and-Invest webinar and the Zero Emissions by 2040 technical conference.

Relevant “Role of Cap-and-Invest” Webinar Findings

I explained in my post on this webinar that the “Current Emissions” section of the webinar set the stage for the webinars that covered  emissions and costs.  One of the primary points made was that inhalable particulate (PM2.5) emissions are primarily from non-peaking power plant sources.  The following slide shows that “Individually controlled (permitted) stationary sources, including electric generation units, large industrial sources, and large commercial and institutional sources represented approximately 4% of the total.”

The next slide in the webinar described the sources that create inhalable air pollution burdens in New York.  It points out that:

• Individually controlled (permitted) stationary sources yield a minority of the air pollution emissions in New York.
• In 2020, electric generation units represented 8.5% of non-wood fuel combustion PM25 emissions in NY, and other permitted sources represented approximately 3.5%.
• Area and mobile sources dominate, which means that individual stationary source-focused policy is important but doesn’t address the bulk of sources.

The webinar slides also explicitly address power plant emissions in New York.  The next slide addressed electricity sector emissions.  It states that:

• Existing policies will go a long way to addressing sources of emissions in the electric sector.
• RGGI, the Clean Energy Standard, and other programs will substantially reduce the use of fossil fuels for our electricity needs.
• The Peaker Rule will ultimately retire the most polluting plants in New York. 35 peaking units representing 955 MW have already retired and an additional 265 MW are expected to retire in 2025.
• NYCI cannot be designed to compel the closure of individual generators, and pricing may not reduce the use of peaking facilities.

Relevant Zero Emissions by 2040 Technical Conference Findings

Unfortunately, the Public Service Commission has not announced availability of a recording of the Zero Emissions by 2040.  technical conference held on December 11 and 12, 2023 so details are still not available.  I published a summary of  the presentation given by Zachary Smith from the New York Independent System Operator (NYISO) describing a new category of generating resources called Dispatchable Emissions-Free Resources (DEFR) that are needed to keep the lights on during periods of extended low wind and solar resource availability.  It is important to note that the meteorological conditions that cause the low wind and solar resource availability also are the same that cause the highest load peaks.  As a result, DEFR will eventually be needed to replace peaking power plants.

I think the ultimate problem for reliability in an electric system that depends on wind and solar is illustrated in the following slide from Smith’s presentation.  It highlights a 7-day wind lull when the average wind capacity is 25%.  The sum of the grey area under the load curve during that period is the amount of energy (MWh) that must be provided by DEFR sources based on an analysis of historical weather data. Note that the load curve peaks during the low wind and solar resource availability drought.   If there are insufficient resources during a wind lull, then electric load cannot be met, and a blackout will occur.

Zachary Smith included a slide (shown below) that describes the generating resource expected for the Climate Act to make the point that a large amount of new generating resources needs to be developed.  Note that in both scenarios the amount of DEFR required (purple column) is on the order of the current existing fossil capacity (orange column). 

Accelerate Now! The Fossil Fuel End Game 2.0

The web page announcing the availability of  Accelerate Now! The Fossil Fuel End Game 2.0   states:

New York City has the densest concentration of urban power plants in the US, impacting the health of 750,000 New Yorkers and increasing the cost of electricity for all utility customers.

The PEAK Coalition — UPROSE, THE POINT CDC, New York City Environmental Justice Alliance (NYC-EJA), New York Lawyers for the Public Interest (NYLPI), and Clean Energy Group (CEG) —aims to end long-standing pollution from fossil fuel peaker power plants and the negative effects on New York City’s most climate-vulnerable people.

In a new report, the PEAK Coalition documents progress made since the coalition was founded and examines the steps taken by state, city, utility, and energy industry stakeholders to hasten or delay the shift from polluting power plants to clean, zero-emissions alternatives. The report, “Accelerate Now! The Fossil Fuel End Game 2.0“, details evidence of encouraging progress, with 700 MW of the city’s peaking capacity fully retired and announced plans for the retirement of an additional 3,300 MW before 2040, representing nearly two-thirds of the city’s fossil peaking capacity. However, the transition has not progressed at the pace needed to protect the health of environmental justice communities and meet the state’s climate goals. More than 75 percent of the city’s dirty and inefficient fossil peaker capacity may remain online and operating beyond 2025, when stricter peaker plant emissions limits are intended to take full effect. In this webinar, hosted by CEG for the PEAK Coalition, report authors will discuss the negative impacts these power plants are having on surrounding communities, highlight progress and barriers impeding the speed of the transition, and recommend pathways forward to accelerate the transition from peaker plants to clean alternatives.

Below I describe some of the points that the author saw fit to highlight and compare this work to the NYCI webinar and DEFR conference.

Disclaimer

This document is a perfect example of grey literature.  Grey (or gray) literature is defined by the Cochrane Handbook for Systematic Reviews of Interventions as “…literature that is not formally published in sources such as books or journal articles.” “This can include information such as government reports, conference proceedings, graduate dissertations, unpublished clinical trials, and much more.“  The key point with respect to grey literature is that anyone using must independently check the analysis.  If the data, methodology, and results are not transparently available, then the results should be questioned.

It is troubling to me that references to previous reports from the Peak Coalition have not recognized that the work did not fully disclose the data, methodology, and results, was not peer-reviewed, or disclose that it was not endorsed by the Department of Environmental Conservation (DEC). In that regard it is interesting that a new disclaimer section is included in this report that states:

This document is for informational purposes only. The authors make no warranties, expressed or implied, and assumes no legal liability or responsibility for the accuracy, completeness, or usefulness of any information provided within this document. The views and opinions expressed herein do not necessarily state or reflect those of funders or any of the organizations and individuals that have offered comments as this document was being drafted.  The authors alone are responsible for the contents of this report. Before acting on any information, you should consider the appropriateness of the information to your specific situation.  The information contained within is subject to change. It is intended to serve as guidance and should not be used as a substitute for a thorough analysis of facts and the law. The document is not intended to provide legal or technical advice.

It would be interesting to know why this was added because it clearly expresses my concerns with its contents.

Highlights of the Document Fossil Fuel End Game 2.0

Most of the technical aspects of this document I have already addressed in previous posts.  The PEAK Coalition report entitled: “Dirty Energy, Big Money” describes the original analysis designed to vilify all New York City peaking power plants.  I described that work in three posts.  I published a post that provided information on the primary air quality problem associated with these facilities, the organizations behind the report, the State’s response to date, the underlying issue of environmental justice and addressed the motivation for the analysis.  The second post addressed the rationale and feasibility of the proposed plan to replace these peaking facilities with “renewable and clean energy alternatives” relative to environmental effects, affordability, and reliability.  Finally, I discussed the  Physicians, Scientists, and Engineers (PSE) for Healthy Energy report Opportunities for Replacing Peaker Plants with Energy Storage in New York State that provided technical information used by the PEAK Coalition.

For this article I am going to respond to some of the highlighted sections in the report.  For example, one of the big issues in the Dirty Energy, Big Money report is highlighted:

Analysis of capacity payments found that an estimated $4.5 billion in ratepayer dollars flowed to the owners of the city’s fleet of peaker plants over a decade. These exorbitant payments to peaker plant owners make electricity from New York City’s fossil fuel peaker power plants some of the most expensive power in the country.

This is a good example of poor understanding of the role of peaking power plants by the PEAK Coalition.  These facilities operate for a small percentage of the time (typically less than 5%) but fulfill a critical reliability support function.  They only run during peak load periods when insufficient generation resource adequacy could lead to a blackout.  The power market pays the highest prices during peak load periods in part because these facilities must get support for all their annual operating costs during the limited periods.  The Coalition does not acknowledge the tradeoff that without the peaking units, there will be blackouts.

The Peak Coalition narrative relies on emotion.  There is a specially highlighted section entitled: “Peakers and a Legacy of Community Harm:  A Story from the Bronx” written by Victor Davila, Community Organizer, THE POINT CDC;  He writes:

The people of the South Bronx share a universal trauma. Whatever the particulars of their life circumstances, every child growing up in the South Bronx is acutely aware that the city does not care about them. The moment they step outdoors, it is clear that their neighborhoods are unimportant to the city. The infrastructure reflects historical scorn for their existence. The Bronx burned for a decade in the 1970s and 1980s, and city officials stood by and watched. Landlords set fire to buildings for insurance, and in reaction, local legislators slashed fire department funding to the Bronx in the hopes of driving residents out.

But thanks to the strength of community members, the spirit of the Bronx was able to resist the decade of fire; however, since then its infrastructure has continued to slowly choke the health of its residents.

There is no question that there has been disproportionate harm to disadvantaged communities (DACs), but the emotional implication of this text is that it has been the result of a deliberate action by outsiders.  Never mentioned in the Peak Coalition reports is that there have been marked improvements in air quality and that most DACs are in compliance with most National Ambient Air Quality Standards. Instead, the report highlights asthma effects: “In the Hunts Point neighborhood of the Bronx, one in every three children and one in every four adults suffer from asthma.”

The number of confounding variables associated with asthma is very large including things like smoking and indoor air quality. One inconsistency never reconciled by the Peak Coalition is why asthma rates are increasing at the same time air quality is improving.

Another highlighted section notes that: “In 2022, 7 percent of the electricity produced in upstate New York came from oil and fracked gas, whereas more than 95 percent of electricity produced in and around New York City came from oil and gas plants.”

This is another example of a poor understanding of the electric system and tradeoffs associated with the peaking units.  Upstate load is near the hydro projects on the Niagara and St Lawrence Rivers and four nuclear power plants so oil and gas is not needed as much as in the City where these same groups cheered on the closure of 2,000 MW of zero-emissions nuclear power.  In addition, there are specific reliability rules for in-city generation limit the amount that can be transmitted into the City.  The rules were added because insufficient in-city generation caused the 1977 blackout.  Lightning strikes abruptly reduced the amount of generation transmitted into the city and the in-city power plants were unable to ramp up load in time to prevent the blackout.  The quick start capability of many of the peaking units is a service that must be replaced before all units can retire.

Progress to Date Chapter

The Peak Coalition admits that the New York State Department of Environmental Conservation (DEC) has recently adopted the so called “Peaker Rule” that sets more stringent ozone season NOx emissions limits for simple cycle and regenerative combustion turbines that will eventually phase out old, inefficient, and relatively dirty units.  A highlight points out that: “Replacing and retiring these older fossil units could reduce 1,849 tons of NOx emissions on some of the highest ozone days of the year, with its biggest impact felt in nearby communities.”

A point of clarification is that the tonnage refers to the annual total emissions not daily totals.  It is also important to note that the emission limits include specific reliability provisions that affect implantation timing.  The units can only be retired if the New York Independent System Operator (NYISO) signs off that they will not be needed for resource adequacy.

A prominent argument in this report is summarized in this highlight: “Despite the Peaker Rule taking full effect, New York City may still have more than 75 percent (4,591 MW) of its fossil peaking capacity online and operating in 2025.”  The tradeoff between keeping these units online and operating and their contribution to keeping the lights on is not emphasized.

Generating Company Plans

From what I can see, the advocates representing the Peak Coalition will be satisfied with nothing less than zero-emissions.  The report addresses each company that has power plants in New York City and includes the following quotes from the highlights in each section:

“We remain steadfast in our fight for an emissions-free future for Asthma Alley residents and all New Yorkers in line with New York’s climate goals.” – Daniel Chu

“Can NYC become the first city in the nation to have all its peaker plants replaced? We believe we can—especially if we follow the visionary direction established by the New York State Climate Leadership and Community Protection Act.” – Eddie Bautista

I think there is a disconnect between what the Peak Coalition thinks this represents and the electric market itself.  The report sums up Eastern Generation plans as follows:

In June 2022, the PSC approved Eastern Generation’s permit to build a 135-MW energy storage system at the Astoria Generating Station facility. In a statement about the approval, Eastern Generation again noted that the company is planning to submit applications for additional storage projects at Gowanus and Narrows, totaling 350 MW of energy storage capacity across the two sites. Eastern Generation has submitted a deactivation notice to NYISO for the 16-MW peaker at the company’s Astoria facility; however, the Peaker Rule does not apply to the three 60-year-old steam turbines at the site. It is unclear whether the development of battery storage at the site will result in the retirement of these peaking units, which have a combined capacity of 943 MW.

Under the existing market dynamic, Eastern Generation is proposing to redevelop its assets at the Gowanus, Narrows and Astoria Generating Station locations.  In a de-regulated market developers like Eastern Generation make development decisions based on the market situation which currently favors energy storage assets.  Importantly, they have no responsibilities for system reliability.  On the other hand, the NYISO must ensure that sufficient resources are available. 

There is an important technical qualifier for this discussion that needs to be clarified.  All of the numbers provided in the quoted section refer to the instantaneous electric power available from the facilities or the capacity as rated in MW.  Consumers pay for energy used per month in kWh.  The NYISO resource adequacy planning is also primarily concerned with electric energy in MWh which is 1000 kWh.  The existing capacity at the Eastern Generation facilities totals 1,915 MW of nameplate capacity and they can run 24 hours a day during extreme load conditions so can produce 45,960 MWh of energy.  The proposed energy storage capacity is just 350 MW and current energy storage lasts only four hours, so the total energy production is a paltry 1,400 MWh or 32 times less potential available energy than the existing facility. The lower energy availability is not Eastern Generation’s problem but is the crux of the NYIOSO resource adequacy concerns for New York City.  

I don’t think the Peak Coalition understands the implications of the difference between capacity and energy.  The report states:

“These findings support previous reports put out by PEAK—that battery storage could replace

the operations of each individual NYPA peaker power plant in NYC, coupled with clean renewable energy sources on the grid, by 2030”. – Eddie Bautista

Next, I will review the report’s section on transition challenges that provides the support for this statement.

Challenges Impeding the Transition

Supporters of the Climate Act maintain that the net-zero transition is only a matter of will.  The introduction for this chapter notes that “market barriers, regulatory obstacles, and other challenges have slowed progress and threaten the state’s ability to meet its climate mandates.”  There is no indication that the challenge identified previously, or the issues raised at the Public Service Commission technical conference have been considered in the analysis.

The report correctly notes that as sectors reduce their GHG emissions by electrification the inevitable result is increasing demand.  The report downplays the effect. 

However, increased electrification also represents an opportunity to shift and shape demand in new ways. The timing of EV charging is often flexible, with most vehicles just sitting around most of the time.  This creates an opportunity to shift charging to times when demand is lower and renewable generation is plentiful. Many high-power building loads, such as heating and cooling, can also be automatically adjusted to shift the majority of electricity demand to non-peak times while maintaining comfortable temperatures for occupants.

In my opinion, the biggest problem with all the net-zero technology solutions proposed including these, is that they don’t work all the time.  EV charging is “often” flexible, but during the coldest periods charging does not work as well so EV owners are going to want to charge when electric heating demand is highest.  The opportunity to shift charging to times when “renewable generation is plentiful” ignores the intermittency problems with renewables in general and the worst-case high load and low availability conundrum. Shifting heating and cooling loads to non-peak times presumes that consumers will lose control of their ability to choose their comfort levels.  Details matter for these claims!

The report argues that virtual power plants are a potential solution.  A highlighted section notes:

Unlike nearby states that have implemented statewide customer battery storage programs to meet peak demand, New York has yet to realize the important role that virtual power plants can play in reducing reliance on fossil peaker plants.

The implication that New York is not considering this option is incorrect.  I am very pessimistic about the technology but I could be convinced otherwise if the Department of Public Service Proceeding 15-E-0302 that is addressing the technology determines that it is feasible.  Until then claiming that this technology is a suitable replacement for existing peaking power plants is premature.

The report addresses reliability with another highlighted section:

“UPROSE, alongside the PEAK Coalition, is deeply concerned by the NYISO Reliability Report.  Emergency rooms get full, and the work and school day is interrupted because of the health impacts our communities have suffered from peaker plant pollution for too long. The 2025 energy reliability gap highlights the urgent need for a swift transition to clean, equitable energy solutions like renewable generation and storage. We urge the state to act decisively in accelerating this transition and ensuring environmental justice for the most vulnerable.” – Elizabeth Yeampierre

There are two problems with this characterization.  The first is the mistaken idea that no new technology is needed for the net-zero transition.  The Climate Act Integration Analysis, the NYISO resource adequacy evaluations, and the Department of Public Service Proceeding 15-E-0302 all argue otherwise because they point to the need for new DEFR.

The other problem with this is the emotional argument that peaker plant pollution is the root cause of the alleged health effects.  The “Role of Cap-and-Invest” webinar confronted this misconception and dismissed the claim.  The analysis found that “Individually controlled (permitted) stationary sources, including electric generation units, large industrial sources, and large commercial and institutional sources represented approximately 4% of the total”; for inhalable air pollution burdens in New York “Area and mobile sources dominate, which means that individual stationary source-focused policy is important but doesn’t address the bulk of sources”; and “Existing policies will go a long way to addressing sources of emissions in the electric sector.”  The point that “individual stationary source-focused policy is important but doesn’t address the bulk of sources” explicitly contradicts the idea that focusing on peaker power plants will have a discernible effect.  In fact, it could have a negative effect by mis-allocating resources to a lower impact problem.

The reliability section also includes this highlight:

All of New York City’s projected load growth and peak demand needs could be reliably met, hour-by-hour, with the right mix of renewables, short-duration battery storage, and efficiency.

This is another statement that contradicts the Integration Analysis, NYISO resource adequacy analyses, and the Department of Public Service Proceeding 15-E-0302 that all conclude that DEFR is needed for a reliable electric system.

In 2023 delays in renewable energy development due to supply chain issues, interest rate increases, and contract negotiations have slowed the pace of renewable developments that could be used to displace the peaking units.  A statement from the POINT CDC, UPROSE, and NYC-EJA highlights their concerns with renewable energy economics:

Significant delays for critical renewable energy projects disproportionately impact the health and well-being of communities suffering from fossil fuel power generation. More years of poor air quality will only exacerbate poor health outcomes for Black and Brown communities, and other communities of color. It is also a lost opportunity for a Just Transition for places like Sunset Park and Hunts Point, where offshore wind projects may be a transformative opportunity to ensure that communities most impacted by pollution can grow and flourish under a new green re-industrialization.

The report does not make specific recommendations how this can be resolved but says “These unforeseen interruptions and economic uncertainties must be addressed by the state to ensure that fossil peaking resources are still able to retire on time or even ahead of schedule.”  I suspect that this is easier said than done.

The report admits that there are challenges to replacing the peaking power plants in New York City. 

In addition to limited space for large-scale renewable energy and energy storage development within the city, New York City has some of the strictest building codes and zoning regulations in the country. These stringent regulations add cost and complexity to the development of solar and energy storage and the implementation of building efficiency measures. Fire department setback and clearance requirements limit the availability of rooftop space for solar panels, and energy storage fire code regulations continue to prevent lithium-ion batteries from being installed indoors, severely curtailing commercial storage development.

The report suggests that these regulatory constraints rather than the limited space and higher in-city development costs are the reason that in-city buildout of clean energy resources in New York City has lagged the rest of the state.  I disagree with the suggestion in the report that the “perceived” safety concerns should be revised to accelerate development because I think safety risks are more significant than the report acknowledges and the other factors affecting in-city generation will still slow development relative to the rest of the state.

The section titled “False solutions” epitomizes the single-minded devotion to the demand for zero emissions.  The idea that compromise and tradeoffs might lead to a pragmatic lower emissions solution is not acceptable to the ideologues because there still would be some emissioins.  The highlight for this section states:

Misguided support for polluting false solutions, such as burning blue or green hydrogen and RNG in power plants, has served as an unnecessary distraction that threatens the state’s ability to achieve its emissions goals mandated by the Climate Act.

False solutions is a commonly used slogan to vilify any technology that does not comport with zero-emissions dogma.  Although there are emissions associated with hydrogen combustion and renewable natural gas there are benefits for their use.  The placeholder technology for DEFR in the Climate Act Scoping Plan is green hydrogen but it is not commercially viable currently.  On the other hand, the technology to burn it in combustion turbines to generate electricity is viable.  The ideologues demand that the hydrogen be used in fuel cells which is another technology not in commercial use at the scale needed.  This ideological demand makes the DEFR challenge using hydrogen for nthe net-zero transition that much more difficult.

Furthermore, the motives of those who suggest more practical solutions are questioned.  Even the widespread support for an analysis of DEFR is characterized as a fossil fuel lobbying effort:

However, at the request of the Independent Power Producers of New York, a trade group representing owners of the state’s fossil fuel power plants, the PSC has initiated a process to “examine the need for resources to ensure the reliability of the 2040 zero-emissions electric grid mandated by the Climate Leadership and Community Protection Act” and is seeking input on how to define zero-emissions, including whether the definition should include green hydrogen.

The highlight for that section notes:

Fossil fuel interests and legacy power plant and pipeline owners continue to push for ways to continue operating existing infrastructure and perpetuate reliance on fossil fuels.

The fact is that until we have suitable replacement technology premature retirement of fossil fuel infrastructure risks serious impacts.  The perspectives described are not conducive to developing sound energy policy. As a result, I am not going to bother describing the Peak Coalition’s ideas for a path forward. 

The final highlighted section states:

The clean energy transition does not mean sacrificing the reliability of the electric grid, and ensuring the reliability of the grid should not mean sacrificing the health and well-being of New Yorkers.

This is a slogan from biased ideologues who do not understand the complexities of the electric system.  I have no doubt that premature shutdown of peaking power plants without acceptable DEFR technologies available will adversely affect the reliability of the electric grid.

Discussion

There are disconnects between the Peak Coalition Fossil Fuel End Game 2.0 report and the findings of the NYCI webinar “The Role of Cap-and-Invest” and the material presented at the Department of Public Service technical conference Zero Emissions by 2040.   The rationale that peaking power plants are responsible for all the health effects claimed by the Peak Coalition is contradicted by the DEC/NYSERDA analysis reported in the webinar.  The reality is that other emission sources are a much more likely source of health effects. The report states that all the technology necessary is available which contradicts the webinar and PSC proceeding on DEFR and casts aspersions on the motives of the organizations responsible for reliability.   

The importance of the PSC proceeding should not be underestimated.  The Integration Analysis and all the projections by the NYISO pointed to this need and the Public Service Commission recognized that there are fundamental unanswered questions that need to be addressed.  DEFR is a recognized response to the problem that the meteorological conditions that cause the low wind and solar resource availability also are the same that cause the highest load peaks.  The Peak Coalition report does not recognize that until adequate DEFR technologies are available and deployed it would be inappropriate to retire any more of the peaking power plants.

It is very frustrating that the environmental justice advocates do not prioritize prevention of blackouts as much as the organizations responsible for reliability.  Victor Davila, Community Organizer, The Point CDC claimed that “The Bronx burned for a decade in the 1970s and 1980s, and city officials stood by and watched”.  The picture of Davila on the staff page for the The Point CDC looks like he is younger than 46 so has no firsthand knowledge of the impact of the 1977 blackout which included fires in the Bronx.

Consider the effects of the 1977 blackout:

The impact of the 1977 blackout was felt long after the lights came back on: The blackout cost the city more than $300 million, both directly and indirectly. In neighborhoods affected by burning buildings or looting, the recovery process was lengthy—in some places, it took years to recover. And the blackout led Con Edison to “move[] to avoid the mistakes that led to the blackout, adding sophisticated monitoring equipment and modifying the flawed procedures that drew public acrimony and thousands of lawsuits, some still unsettled,” according to a New York Times article from 1987.  

—–

In some places—perhaps most memorably, Bushwick and parts of the Bronx—the extended power outage led to looting and instances of arson.

The effects of an extended blackout are immediate, acute, and, in my opinion, a greater threat to disadvantaged communities than peaking power plants.  The Peak Coalition Fossil Fuel End Game 2.0 report does not adequately account for the complexities of the New York City electric system.  Zach Smith’s presentation on DEFRs at the PSC technical conference outlined the need for this resource.  There was a panel discussion that addressed other relevant issues, but the recording is not available.  One point made was that the location and capacity of generating resources matters.  Given the spatial power density of the peaking power plants relative to the proposed energy storage solutions the possibility that they cannot be replaced cannot be dismissed.

Conclusion

Peak Coalition members passionately want the best the communities that they represent.  I do not think that electric energy policies that risk reliability and, affordability for that matter, are properly prioritized in their report.  The complete focus on peaking power plants is simply not in the best interest of the communities that they purport to represent.

Nonetheless, appeasing these environmental advocacy organizations is a priority for the Hochul Administration. Unfortunately, I do not think that the ideologues will ever be satisfied with anything less than their demands. Their demands are incompatible with a reliable electric system. It will be fascinating to see how this plays out.

The PEAK coalition has stated that “Fossil peaker plants in New York City are perhaps the most egregious energy-related example of what environmental injustice means today.”  The influence of this position on current New York State environmental policy has led to this issue finding its way into multiple environmental initiatives. However, the presumption of egregious harm is based on selective choice of metrics, poor understanding of air quality health impacts,  and ignorance of air quality trends. 

I am a retired electric utility meteorologist with over 45 years-experience analyzing the effects of meteorology on electric operations.  I have been involved with the peaking power plants in particular for over 20 years both from a compliance reporting standpoint and also evaluation of impacts and options for these sources.  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.

Caveat

There is no question that disadvantaged communities suffer disproportionate environmental impacts but it is important to understand what causes the harms and balance expectations and potential solutions.  I believe the concerns about fossil peaker plants are misguided.  Moreover, there is no currently available technology that has been proven at the scale necessary that can replace fossil-fired generation in New York City safely, reliably, and affordably. If safety, reliability, and affordability are not prioritized, then it could easily result in an electric system that does not maintain current standards.  More importantly, problems associated with them impact disadvantaged communities more than other communities so those concerns must be considered when decisions are made about peaking power plants. 

Peaker Power Plant Articles

I have written multiple articles about peaking power plants and alleged health impacts of these facilities in response to opinion pieces, reports, and policy proposals

I believe that the PEAK Coalition report entitled: “Dirty Energy, Big Money” is the reason that environmental justice organizations vilify all New York City peaking power plants.  I have described this work in three posts.  I published a post that provided information on the primary air quality problem associated with these facilities, the organizations behind the report, the State’s response to date, the underlying issue of environmental justice and addressed the motivation for the analysis.  The second post addressed the rationale and feasibility of the proposed plan to replace these peaking facilities with “renewable and clean energy alternatives” relative to environmental effects, affordability, and reliability.  Finally, I discussed the  Physicians, Scientists, and Engineers (PSE) for Healthy Energy report Opportunities for Replacing Peaker Plants with Energy Storage in New York State that provided technical information used by the PEAK Coalition.

A post describing my comments on the New York State Department of Environmental Conservation (DEC) decision to deny the NRG Astoria Gas Turbine Power Replacement Project Title V Permit Application summarizes issues and implications of premature retirements.

In February 2023 I wrote an article about the risks of the zero-risk philosophy of environmental justice advocates who vilify peaking power plants.  However noble the concept of eliminating any risks from any source of pollution, if it is construed to mean that anything that might be contributing to bad health must be prohibited, then society basically cannot function.  Peaking power plant issues were discussed as an example of this problem in the article.  The over-arching concern in this article is that the Environmental Rights Amendment to the New York constitution will inevitably set a high hurdle for permitting a new facility or keeping an existing source in operation.  The amendment states: “Each person shall have a right to clean air and water, and to a healthful environment.”  It is likely that a debate about what constitutes clean air will ensue for every permit application.

Air Quality and Health Metrics

The Clean Air Act established the primary metric to protect human health and welfare codified in a scientifically-based regulatory program.   The National Ambient Air Quality Standards (NAAQS) “provide public health protection, including protecting the health of ‘sensitive’ populations such as asthmatics, children, and the elderly”.  My air pollution meteorology career is based on the presumption that air quality that meets the NAAQS is acceptable.

Over my career air quality has improved markedly.  The Environmental Protection Agency keeps track of air quality trends in the country.  The following graph shows air pollution concentration averages.

There is no graph available for the Northeastern US but the data show similar decreases.

For the most part New York air quality reflects national and regional trends.  According to the EPA nonattainment/maintenance status summary, there are multiple counties In New York that do not attain the NAAQS for ozone and New York County does not meet the coarse particulate matter standard.  Note that all of New York State meets the inhalable particulate (PM_2.5) NAAQS.  All the other pollutants are in attainment. 

Despite the fact that there have been significant improvements and New York is mostly in attainment with the NAAQS there is another approach to air quality health impacts that regulators and activists have used to claim more reductions are necessary.

Even though New York City is in attainment for inhalable particulates, this pollutant is used as a rationale for shutting down peaking power plants because of claims that reducing inhalable air quality impacts is beneficial.   For example, the New York City Department of Health and Mental Hygiene’s (DOHMH) Air Pollution and the Health of New Yorkers report is often referenced in this regard.  The DOHMOH report concludes: “Each year, PM_2.5  pollution in [New York City] causes more than 3,000 deaths, 2,000 hospital admissions for lung and heart conditions, and approximately 6,000 emergency department visits for asthma in children and adults.” These conclusions are for average air inhalable particulate pollution levels in New York City over the period 2005-2007 of 13.9 µg/m³.

In my comments on the Draft Scoping Plan I explained that the following paragraph from Scoping Plan Appendix G: Section II summarizes the fundamental assumption for these health impacts:

Nevertheless, the health impact functions included in COBRA were developed from a specific population exposed to specific levels and compositions of PM_2.5, and conditions in NYS have changed since these functions were developed. For example, the health impact function from the Krewski study was based on examining mortality impacts from 500,000 people in 116 U.S. cities between 1980 and 2000. The levels and compositions of PM_2.5 have decreased substantially since 2000, as discussed above, with sharp declines in ammonium sulfate, making ammonium nitrate and secondary organic aerosols relatively more important components of PM_2.5 However, the synthesis of the research into PM_2.5 impacts on public health conducted for EPA’s draft Integrated Science Assessment for Particulate Matter indicates that the literature provides evidence that the health impact functions may be linear with no threshold below which reductions in exposure to PM_2.5 provides no benefits. In other words, even though PM_2.5 concentrations have been reduced in NYS in the time since the health impact functions were developed, the evidence suggests that the functions can adequately estimate changes in health impacts even at relatively low levels of PM_2.5 Similarly, EPA’s draft Integrated Science Assessment finds that the literature is unclear as to whether changes in the composition of secondary PM_2.5 species results in differential changes to health impacts. For this reason, this health analysis, along with most other similar benefits analyses, uses the total change in PM_2.5 concentrations to evaluate health impacts rather than looking separately at impacts by the different PM_2.5 species.

In brief, the Scoping Plan air quality health assessment depends on a linear no-threshold model.  Originally used for radiation assessment, it suggests that each time radiation is deposited in the susceptible target there is a probability of tumor initiation.  Note, however, that its use in radiation assessment is controversial. 

It is important to note that these relationships are not Clean Air Act mandates despite the fact that they are used constantly to justify further emission reductions.  Furthermore, their use in air quality assessments is also controversial.  The epidemiological data used by the Environmental Protection Agency have never been independently reviewed and another health impact study of all deaths in California between the years 2000 to 2012 (more than 2 million) reported no correlation between PM_2.5 and death.  Furthermore, I also submitted comments on the Draft Scoping Plan where I showed that the 2018-2020 average PM_2.5 concentration was 7.4 µg/m³ which is substantially lower than the DOHMOH goal of 10.9 µg/m³.  If the epidemiological linear no-threshold model is correct, then because inhalable particulate levels have come down uniformly across the country then there should be significant observed health benefits across the country and in New York City.  DOHMOH has not verified their projections against observations.  Until such time that the projected health impacts using this approach are validated with observed data, I will be skeptical of this metric.

Air Quality Impacts of Peaking Power Plants

Even if you accept the inhalable particulate health benefit premise, I don’t think that the arguments made in Dirty Energy, Big Money make a convincing case that the peaking power plants are the primary driver of air quality environmental burdens on neighboring communities.  The ultimate problem with this approach is that the argument relies on environmental burdens from ozone and particulate matter air quality impacts.  However, ozone is a secondary air pollutant and the vast majority of ambient PM_2.5 from power plants is also a secondary pollutant.  As a result, there is a lag between the time emissions are released and creation of either ozone or PM_2.5. By the time the precursor pollutants convert to ozone or PM_2.5 they have moved out of the neighborhood. That means that the peaking power plants do not contribute to the air quality impact problems alleged to occur to the environmental justice communities located near the plants.  In fact, because NOx scavenges ozone the peaker plants reduce local ozone if they have any effect at all. 

Other Consequences

The alleged effects of peaking power plants also is a consideration in the Climate Leadership & Community Protection Act.  Chapter 6. Advancing Climate Justice in the Final Scoping Plan states:

Prioritizing emissions reduction in Disadvantaged Communities should help to prevent the formation or co-pollutant emissions despite a reduction in emissions statewide. A broad range of factors may contribute to high concentrations of pollutants in a given location that create a hotspot. The result can be unhealthy air quality, particularly for sensitive populations such as expectant mothers, children, the elderly, people of low socio-economic status, and people with pre-existing medical conditions.

This contention is based on the arguments in Dirty Energy, Big Money.  I have seen indications that there are people who believe that GHG emissions themselves have some kind of air quality impact exacerbated in disadvantaged community hot spots.  That is simply wrong – there are no health impacts associated with carbon dioxide emissions at current observed ambient levels.  Dirty Energy, Big Money and the Scoping Plan arguments are based on co-pollutant emissions (NOx and PM_2.5) that allegedly cause impactful hot spots that result in unhealthy air quality.  Note that all facilities in New York State have done analyses that prove that any locations with higher concentrations in the vicinity of power plants do not contravene the NAAQS.  Trying to make the cap and invest program, that is appropriate for controlling GHG emissions to mitigate global warming, also address a neighborhood air quality problem already covered by other air quality rules is not in the best interests of a successful cap and invest program.

Conclusion

The argument that peaking power plants are a source of egregious harm to disadvantaged communities is based on selective choice of metrics, poor understanding of air quality health impacts,  unsubstantiated health impact analysis, and ignorance of air quality trends. 

I maintain that the appropriate metric for determining the impact to human health and welfare is the NAAQS process.  Using a linear no-threshold model approach is not an appropriate metric for permitting decisions related to peaking power plants.  Appeasing activists who demand zero-risks ultimately means that no emissions will be allowed and that will shut down society.

The argument that peaking power plants affect neighborhoods as portrayed is flawed.    The air pollutants that are alleged to be the cause of a significant health impacts in disadvantaged communities near peaking plants are the secondary pollutants ozone and PM_2.5.  Because it takes time for the conversion from precursor pollutants, they are unlikely to affect adjacent neighborhoods simply because they are blown downwind during the conversion phase. 

Inhalable particulates (PM_2.5) are frequently cited as the primary cause of health impacts but independent studies offer contrary results.  Taken to the ultimate level this concern would ban camp fires.  When the wind shifts and the smoke blows towards a camper, they got a dose of inhalable particulates.  If one person stays in the smoke for days, then there will be a health impact.  On the other hand the campers that sit around a campfire and get a dose of smoke several times a year get much less of a health effect.  The linear no-threshold approach gets its estimates of health impacts by multiplying low health impacts by many people.  In this case if there are a million campers and if the impact is one millionth of the impact to the guy who stayed in the smoke for days, then it is presumed that one out of a million people would get sick the same way. 

The biggest flaw in the argument is that activists argue that the health-related impacts are increasing at the same time that PM2.5 concentrations in the atmosphere are decreasing.  All the air quality trends are going down.  If proponents can show that there have been substantial benefits associated with the observed concentration reductions then I might be more sympathetic to the arguments.

At some point New York State regulators are going to have to step and be the adults in the room.  It is entirely proper to consider environmental justice considerations in disadvantaged communities.  However, that consideration cannot be the final word on the continued operation of peaking power plants.  This overt deference to environmental justice concerns could easily lead to impacts on the reliability, affordability, and safety of the electric grid.  If problems ensue the communities that will be impacted the most will be the ones this mis-guided deference is intended to protect.