Category: Peaking Power Plants

New York State energy and environmental policy is more about optics than facts.  Nowhere is this more apparent than the recent spate of opinion pieces, reports, and even policy proposals related to peaking power plants.  I evaluated the basis of these items in a series of three posts but because they are very technical I have elected to summarize this issue in this post.

I think this is an important because the vilification of peaking power plants is getting all sorts of undeserved attention.  Although the peaking plants are alleged to be a primary driver of the environmental burden in neighboring environmental justice communities that is unlikely to be the case.  Combine that with the enormous costs of energy storage and the difficulty siting enough renewables within the city to replace these plants that means that a clean energy “solution” is likely not in the best interests of society, particularly in the admittedly over-burdened environmental justice communities.

This post is a summary of three detailed technical posts.  The PEAK Coalition recently released a report entitled: “Dirty Energy, Big Money”.  My first post provided information on the primary air quality problem associated with these facilities, the organizations behind the report, the State’s response to date, the underlying issue of environmental justice and addressed the motivation for the analysis.  My second post addressed the rationale and feasibility of the proposed plan 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.

I am a retired electric utility meteorologist with nearly 40 years-experience analyzing the effects of meteorology on electric operations.  I have been involved with 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.  This background served me well preparing this post.  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.

The Problem

There are two drivers for peaking power plant issues.  In order to provide electricity to everyone who needs it when they need it, the New York Independent System Operator (NYISO) has to balance power availability with the load on the system.  NYISO is responsible not only for the real-time deliver of power but also for reliability planning.  If the load did not vary this would be much less difficult, but the reality is that load varies diurnally and seasonally.  Most important is meeting demand when loads are highest in the summer and winter when it is necessary to provide electricity to maintain the health and well-being of customers. Ultimately the problem boils down to the fact that there are short periods when so much load is needed that there are units dedicated by intent or circumstances to provide just that load during the year.  This is expensive and inefficient but is, in my opinion, a problem with no easy solution.

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

The reports both suggested that the payments for the peaking power were unreasonable.  The PEAK Coalition believes that these plants “receive exorbitant payments from utilities and other energy service providers just for the plants to exist”.  This is not my area of expertise but based on the turnover of ownership and other factors, I don’t believe that they are the profit centers the PEAK Coalition believes they are.  Importantly, the units do run when power is needed most so there is a reason for them to exist.

The Analysis

I found that the basis for the technical aspects of the PEAK Coalition report is work by Physicians, Scientists, and Engineers (PSE) for Healthy Energy.  PSE evaluated Federal data peaking power plants across the country based on fuel type, capacity, technology and how much they ran.  This is a blunt approach that cannot address any of the nuances that have resulted in some units running for short times.  In New York for example, there are simple cycle turbines in New York City that were built specifically to provide peaking power.  There also are some large oil-fired units that run little because their fuel costs are so high.  Off the top of my head I also note that there are units that burn oil and run only when needed due to natural gas supply constraints, but there certainly could be other reasons some units run so little.  As a result the simplistic proposal for replacement is only valid for some of the facilities at best.

In order to prove the need for a clean energy alternative, PSE combined the peaking power plant data with ambient air quality data to show that the peaking plants often run at the same time that there are National Ambient Air Quality Standard exceedances.  That is a well-known fact.  PSE also developed a “cumulative vulnerability index that integrates data on health burdens (asthma, heart attacks, premature birth rates); environmental burdens (ozone, particulate matter, toxics, traffic proximity, lead paint, and hazardous facilities); and demographic indicators (low-income, minority, linguistically isolated, and non-high school-educated populations)”.  All of these data were combined to make the claim that these plants need to be replaced.

However, I don’t think that the PSE approach made a convincing case that the peaking power plants are a primary driver of environmental burdens on neighboring communities.  Their vulnerability index lists other factors but makes no attempt to attribute impacts to each factor.  The ultimate problem with this approach is that the peak unit justification 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 PM2.5 from power plants is also a secondary pollutant.  As a result, there is enough of a lag between the time emissions are released and creation of either ozone or PM2.5 that the impact is felt far away from the adjacent communities.  That means that the accused peaking power plants do not create 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.

The Solution

Dirty Energy, Big Money states “Experts have found—and real-world examples have proven—that battery storage and renewable generation may be less expensive to develop and manage than the rarely used but heavily polluting fossil fuel power plants, while also meeting or exceeding the same performance standards”.  This statement is just plain wrong as I showed in detail.  As soon as energy storage is added to the renewable “solution” the projected costs rise exponentially and there are no real-world examples supporting this as a proven policy approach.  Moreover, the difficulties and cost of siting enough renewable energy within New York City to meet the in-city generation requirements also suggest enormous costs.

New York’s irrational war on natural gas continues in this vilification of peaking power plants.  I do not dispute that there is a New York City peaker problem where old, inefficient combustion turbines designed to provide peak power are being used to provide critically needed power when needed most. In order to force their replacement the New York State Department of Environmental Conservation (DEC_promulgated new  limits for the simple cycle turbines such that they will be required to install controls or shut down. They should be replaced and probably should have been replaced long ago so the question is why hasn’t this happened.

In my opinion the continued operation of the old simple cycle turbines in New York City is the result of New York’s de-regulated market place.  I am absolutely sure that in a regulated environment the responsible utility would have made a case to the Department of Public Service that replacement with cleaner, more efficient generation was needed, the Department would have agreed  and after it was approved the utility would have built the replacements units and been guaranteed a reasonable return on their investment.  However, in the de-regulated market there wasn’t a strong enough financial incentive to replace the old units.  Before I retired in 2010, I worked on two separate permit applications for new, efficient, and cleaner replacement power for one set of the old combustion turbines.  In both instances the permits were approved but the replacements were never built, apparently because the company decided that the business case was not strong enough to warrant the investment.

According to the plans submitted to comply with DEC’s peaking power plant rule only one company is planning to build replacement peaking power. I fear that in today’s political climate that the proposed re-powering of Gowanus will not be permitted because it is new fossil fuel infrastructure.  However, it is fundamentally different inasmuch as the proposed plant is on a barge.  If New York’s aspirational climate agenda works out  then it won’t be needed and it can simply be moved away to another location to serve as a bridge source of energy elsewhere.  However, I am unconvinced that the clean energy alternatives proposed will work, much less be affordable.  Therefore, this proposed project is invaluable insurance for reliability and affordability.

Conclusion

The claims that peaking power plants are dangers to neighboring environmental justice communities are based on emotion.  In the evaluation I did of the PSE analysis and the PEAK Coalition report, I found that the alleged impacts of the existing peaking power plants over-estimates impact on local communities relative to other sources.  The existing simple cycle peaking turbines in New York City are old, inefficient and much dirtier than a new facility and clearly should be replaced.  However, they reliably produce affordable power when needed most.  In order to maintain that affordability and reliability I think it is best to rely on a proven solution such as the proposed Gowanus re-powering project.  The solar plus energy storage approach advocated by PSE and the PEAK Coalition will likely increase costs significantly if it works.  I cannot over-emphasize the fact that it may not work because solar and energy storage is not a proven technology on the scale necessary to provide New York City’s peaking power requirements.  Sadly in the rush to prove politically correct credentials this unproven technology may be chosen despite the risks to power reliability.

Update June 30, 2020:  I wrote a layman’s summary on this issue here.

Physicians, Scientists, and Engineers (PSE) for Healthy Energy is a multidisciplinary, nonprofit research institute that studies the way energy production and use impact public health and the environment. One of their recent programs is the Energy Storage Peaker Plant Replacement Project.  That work formed much of the technical basis for the PEAK Coalition report entitled: “Dirty Energy, Big Money”.  I have prepared two posts on that document (here and here).  This post addresses the PSE report Opportunities for Replacing Peaker Plants with Energy Storage in New York State.

I am a retired electric utility meteorologist with nearly 40 years-experience analyzing the effects of meteorology on electric operations.  I have been involved with New York peaking power plants in particular for over 20 years from a compliance reporting and operations standpoint and also evaluated impacts and options for this kind of source.  This background served me well preparing this post.  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.

Energy Storage Peaker Plant Replacement Project

PSE defines the alleged problem in the introduction to this project as follows:

The United States relies on more than 1,000 natural gas- and oil-fired peaker power plants across the country to meet infrequent peaks in electricity demand. These peaker plants tend to be more expensive and inefficient to run for every megawatt-hour generated than baseload natural gas plants and emit higher rates of carbon dioxide and health-harming criteria air pollutants. Peaker plants are also typically disproportionately located in disadvantaged communities, where vulnerable populations already experience high levels of health and environmental burdens.

The text for the New York specific report describes the problem similarly:

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

Their proposed solution:

Renewable energy and energy storage systems are beginning to emerge as competitive replacements for this fossil fuel infrastructure. Simultaneously, numerous states across the country are designing incentives and targets to support energy storage deployment. Together, these developments provide a unique opportunity to use energy storage to strategically displace some of the most polluting peaker power plants on the grid.

In the Energy Storage Peaker Plant Replacement Project PSE did a screening analysis across nine states that identified peaker power plants that “may be prime candidates for replacement based on operational and grid characteristics, and whose replacement may yield the greatest health, environment and equity co-benefits”.  They claim that their approach “aligns state efforts to adopt energy storage with environmental and societal goals”.

The following section is the summary of the report.  Based on my review of the New York State-specific results I believe further study is needed to actually determine if all the peaker units identified can actually be considered candidates for replacement with energy storage and solar.  I also worry that the PSE analysis is mis-leading inasmuch as it does not address the fact that peaker plants fulfill niche operational backup roles that vary widely across the country.  I am familiar with New York State peaker plants and will show why that is important in New York.

PSE Summary

“The majority of New York’s peaker plants are located in densely urban areas in New York City and Manhattan, a region that is in non-attainment for federal ozone standards. These include old, inefficient  and oil-burning units near populations that experience high cumulative environmental health and socioeconomic burdens.  The state’s new emission reduction standards for nitrogen oxides, along with its energy storage deployment goals, provide a clear opportunity to target inefficient and polluting facilities for replacement with cleaner alternatives, particularly in urban areas. In the attached table, we provide operational, environmental and demographic data for New York peakers and nearby populations. Indicators such as nearby population, emission rates, heat rate (a measure of efifciency), operation on poor air quality days, capacity factor, typical run hours, and location in an environmental justice community or in an import-constrained load zones downstate can help inform whether a given plant might be a good target for replacement with storage, solar+storage, demand response, or other clean energy alternatives. These data should be accompanied by engagement with accompanied by engagement with affected communities to determine replacement priorities and strategies.”

The New York report has four sections: New York State Policy and Regulatory Environment, New York State Peaker Plants, Nearby Populations, and Emissions and the Environment.  I will address those sections in the following.

New York State Policy and Regulatory Environment

There isn’t much to comment on in this section.  The PSE report only describes New York’s climate initiatives.  Although the summary notes that New York has new emission reduction standards for nitrogen oxides, it does not highlight the fact that the regulation was specifically intended to address emissions from the old, inefficient simple cycle combustion turbines in New York City.  I described New York’s specific initiatives in my background post on the PEAK Coalition Dirty Energy, Big Money report.

New York State Peaker Plants

This analysis and report were intended to provide background information to support “clean energy alternatives” for peaker plants.  A primary component of that information is identification of peaker plants.  The technical documentation describes peaker power plants and the selection criteria used in their screening analysis.  PSE states “The phrase peaker plant commonly refers to fossil fuel-burning power generation used to meet peak demand on the electric grid, but the term itself does not have a precise definition”.  Actually, for EPA reporting purposes there is an exact, regulatory definition.  40 CFR Part 75  §72.2, states that a combustion unit is a peaking unit if it has an average annual capacity factor of 10.0 percent or less over the past three years and an annual capacity factor of 20.0 percent or less in each of those three years.

PSE chose to select peaking power plants based on the following criteria: fuel type: oil & natural gas; Capacity: ≥ 5 MW; capacity factor: ≤15% (3-yr. avg.); unit technology type: simple cycle combustion turbine, steam turbine & internal combustion; application: entire peaker plants & peaking units at larger plants; and status: existing and proposed units.  Relative to the peaking power plants subject to EPA reporting requirements, the biggest difference is that the PSE criteria selects small units between 5 and 15 MW that are so small that their emissions and impacts are generally considered insignificant.  Those facilities do not report continuous emissions monitoring data that the units >15 MW do.

Briefly, PSE collected data from EPA and EIA then screened it with their criteria to identify peaking units.  They calculated operational and emissions data.  Then they compared operational data with ambient monitoring data and found periods when the peaking units operated during periods of high ambient levels.  This is a straight-forward number crunching exercise and I have no comments on the methodology.

The technical and policy documentation for the Energy Storage peaker plant replacement project includes a section titled “Grid requirements: transmission constraints and capacity needs” that includes a discussion of New York.  For the most part PSE relied on the New York Independent System Operator analyses of the peaker plants. They note that the impacts of removing capacity is highly location dependent quoting NYISO reports: “lower amounts of capacity removal are likely to result in reliability issues at specific transmission locations” and that NYISO did not “attempt to assess a comprehensive set of potential scenarios that might arise from specific unit retirements”.  Despite the fact that NYISO cannot make specific recommendations PSE goes ahead and makes recommendations for five plants in New York City and five plants on Long Island that are “replacement opportunities” in PSE Peaker Documentation Table 5.3.

While I am certainly no expert on New York City reliability requirements I believe that there are ramifications not considered by PSE.  The NYISO Gold Book Data for Table 5.3 Replacement Opportunities table provides additional data for the PSE opportunities.  First note that PSE did not identify peaking units that operate at facilities with other units.  There is a combustion turbine at Northport and Arthur Kill that operates with the capacity factor listed.  PSE apparently does not understand that the primary purpose of those units is for black starts, that is to say when they provide power necessary to start the steam turbine units when there is no off-site power available.  In theory battery storage could be used for that but because of reliability considerations the battery would have to always be kept with enough energy to start the plant for the very rare occasion when there is a blackout.  There is no way that could be cost-effective.  My table also lists the fuel burned and it is instructive that all but one of the units listed can burn kerosene or number 2 fuel oil.  There are specific requirements for minimum oil burning when there is a possibility that the gas supply could be cut off.  Because this is not the standard peaking power plant replacement scenario, I am not sure whether battery storage would be cost-effective for this requirement.

Advocates for “clean energy alternatives” point out that New York has a law that requires that no electricity will be generated by fossil fuels in 2040.  Until such time that the State has a plan to meet that goal that explains how reliability and affordability can be maintained, then I will continue to believe that meeting that aspirational goal is more than simply a matter of political will.  For example, the Gowanus power plant has a nameplate capacity of around 540 MW. For all the Article Ten solar energy applications currently in the queue 5.4 acres per MW was the lowest spatial requirement.  That means that solar panels totaling at least 4.6 square miles will be needed to replace this source of in-city generation. While that may be possible, there are a host of logistical issues starting with the need to provide the power where it is needed when it is needed.  New York City is a load pocket relative to the rest of the grid but there are numerous smaller load pockets within the city.

Nearby Populations

The report notes that “Ten of the New York peaker plants each have more than a million people living within a three-mile radius. The most urban plants tend to also be in relatively low-income, minority communities, due to both the location of some facilities in low-income, environmentally overburdened communities of color.”  In my background post on the PEAK Coalition Dirty Energy, Big Money report I described the environmental justice concept of dis-proportionate impacts.  I do not know how to deal with dis-proportionate impacts when the location of some facilities impact rich communities at the same time they impact low-income communities.

PSE developed a “cumulative vulnerability index that integrates data on health burdens (asthma, heart attacks, premature birth rates); environmental burdens (ozone, particulate matter, toxics, traffic proximity, lead paint, and hazardous facilities); and demographic indicators (low-income, minority, linguistically isolated, and non-high school-educated populations)”.  It is vital to determine the effect of the peaker power plants relative to all the other impacts on the admittedly over-burdened environmental justice communities.

Emissions and the Environment – Air Quality Impacts

In order to determine the relative impact of peak power plants we have to consider their air quality impacts.  In order to be permitted to operate, all power plants have to evaluate the potential impacts of their emissions relative to the National Ambient Air Quality Standards (NAAQS).  There are two types of standards.  Primary standards provide public health protection, including protecting the health of “sensitive” populations such as asthmatics, children, and the elderly. Secondary standards provide public welfare protection, including protection against decreased visibility and damage to animals, crops, vegetation, and buildings.  Air quality models combine information about the emissions, operating characteristics, and meteorological conditions to estimate the ambient concentrations from the power plants and those estimates are compared to the NAAQS.  If the contribution from the facility directly causes an exceedance of any NAAQS limit then the plant cannot operate until changes are made to reduce the impact.  If nothing can be done to reduce the impacts lower than the limits then it cannot be permitted to operate.

The air quality modeling used to permit a power plant to operate considers pollutants like sulfur dioxide and nitrogen dioxide that are directly emitted by the plant.  Power plants also emit pollutants that are precursors to other pollutants that form in secondary reactions.  Modeling secondary pollutants is more complicated and ascribing the impacts of particular facilities on air quality is more difficult.  Permit conditions for secondary pollutants such as ozone and inhalable particulate matter can also limit emissions of the precursor pollutants.

In my opinion the most difficult air quality issue today is ozone attainment because the emission source characteristics and meteorological conditions are not only complex and difficult to understand but also because making the reductions necessary are costly and impactful.   Ground-level ozone is created by chemical reactions between oxides of nitrogen (NOx) and volatile organic compounds (VOC). Those pollutants are emitted by cars, power plants, industrial boilers, refineries, chemical plants, natural sources and other man-made sources and when they chemically react in the presence of sunlight, they create ozone.  Ozone is most likely to reach unhealthy levels on hot sunny days in urban environments but because NOx and VOC as well as ozone can be transported long distances by wind, rural areas are affected and urban areas are affected by sources far upwind.

It has been observed that when widespread transportation restrictions are implemented (e.g. during the Atlanta Olympics) that there is a marked improvement in ozone levels.  However, the fact is that there is little societal desire to maintain the draconian restrictions of automobile use that produce those improvements.  For peaking power plants, the problem is that the conditions most conducive to create ozone are also the hot and muggy conditions that increase electricity demand for cooling, so the peak load of electric generation produces the most emissions at the worst time.  However, in order to provide the power necessary to keep the lights on when people really want and need it, the existing power grid has peaking facilities.  In my second post on the PEAK coalition report I described the process used to determine if these units are needed and why I think they have not been replaced yet.

Recall that PSE developed a cumulative vulnerability index that integrates data on environmental burdens including ozone and particulate matter.   The point of this entire discussion is that ozone is a secondary air pollutant and the vast majority of ambient PM2.5 from power plants is also a secondary pollutant.  In other words, there is a lag between the time of relevant emissions and creation of either ozone or PM2.5.  As a result, the accused peaking power plants do not create the air quality impact problems alleged to occur to the environmental justice communities near the peaking power plants.  In fact, because NOx scavenges ozone the peaker plants reduce local ozone if they have any effect at all.

Conclusion

The PSE report notes that “These data should be accompanied by engagement with accompanied by engagement with affected communities to determine replacement priorities and strategies.”  I do not want anyone to misunderstand that I am not arguing that something should not be done about New York City’s simple cycle combustion turbine peaking power plants.  They are old, inefficient and relatively dirty.  However, in order to do the right thing, we need to understand all the background information.  The PSE analyses and the PEAK Coalition vilification of fossil-fired power plants only tells one side of the story and, inasmuch as most of the alleged environmental impacts are based on ozone and PM2.5 impacts, they misleadingly imply much more of an environmental benefit to the affected communities than will actually occur if the existing power plants are replaced by the latest generation of natural-gas fired power plants.

As noted in my post on the feasibility of the “clean energy alternative”, I have reservations about that proposed solution.  Even though the cost for developing renewable energy resources is allegedly cheaper than the cost of equivalent fossil-fired energy resources, the cost to ensure that electricity is available when and where it is needed for the two resources are not even close.  Because renewable energy is intermittent energy storage is required and my feasibility post demonstrated those costs are immense and would have to drop by an order of magnitude to make the solar+storage option comparable in cost.

Post Script

The PSE report Opportunities for Replacing Peaker Plants with Energy Storage in New York State includes a table that lists all the power plants in New York State that meet their screening criteria defining a peak plant.  The title of the report suggests that this list contains facilities that could be replaced by energy storage.  However, it includes steam turbine units that burn residual oil.  Because those units burn an expensive fuel, they don’t run much but because their operating costs are relatively low, they can be kept available for the rare occasions when they are needed. I was working at one of the named Upstate plants, Oswego, when the 2003 Northeast blackout occurred.  When the transmission system lost power, three nuclear units nine miles east of the plant had to shut down.  In order to bring the system back on-line, both of Oswego’s 850 MW units were turned on, ran for a combined 231 hours and generated 71,684 MWh.  I cannot think of any scenario where it would be in the best interest of New York to build enough energy storage to replace the Oswego power plant for this type of incident.

Update June 30, 2020:  I wrote a layman’s summary on this issue here.

New York State energy and environmental policy is more about optics than results.  Nowhere is this more apparent than the recent spate of opinion pieces, reports, and even policy proposals related to peaking power plants.  In May 2020, the PEAK Coalition released a report entitled: “Dirty Energy, Big Money”.  The focus of the study is the “peaker” power plants that operate when energy demand in New York City spikes above normal levels.  Because I have been involved with this issue and these plants for over 20 years, I want to review this report.

At first glance there are enough technical issues for a blog essay but when I started to research the article, I realized that I needed to do a background post 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 address the motivation for the analysis.  This post addresses those aspects of the report and will be followed up by a post on technical issues and another post on the analysis that was the basis of the technical claims.

I am a retired electric utility meteorologist with nearly 40 years-experience analyzing the effects of meteorology on electric operations.  I have been involved with 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.  This background served me well preparing this post.  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.

 Air Quality Background

In my opinion the most difficult air quality issue today is ozone attainment.  Ground-level ozone is created by chemical reactions between oxides of nitrogen (NOx) and volatile organic compounds (VOC). Those pollutants are emitted by cars, power plants, industrial boilers, refineries, chemical plants, natural sources and other man-made sources and when they chemically react in the presence of sunlight, they create ozone.  Ozone is most likely to reach unhealthy levels on hot sunny days in urban environments but because NOx and VOC as well as ozone can be transported long distances by wind rural areas are affected and urban areas are affected by sources far upwind.  Ultimately the problem is that the conditions most conducive to create ozone are also the conditions that increase electricity demand for cooling so the peak load of electric generation produces the most emissions.  In order to provide the power necessary to keep the lights on when people really want and need it, the existing power grid has facilities that were designed to operate infrequently.  In New York City that capability is exemplified by 86 simple-cycle turbines currently operating.

The PEAK Coalition defines their problem with the existing situation as follows:

“On days with extreme weather, like heat waves or sub-zero temperatures, residents consume more energy to stay cool and warm, which puts excessive demand on the grid. In response to this increased demand in electricity, highly polluting power plants known as “peakers” fire up in the South Bronx, Sunset Park, and other communities of color throughout New York City. These inefficient peakers spew harmful emissions into neighborhoods already overburdened by pollution, exacerbating widespread health problems. Peaker plants are a prime example of how low-income communities and communities of color bear the brunt of a host of energy and industrial infrastructure that poses significant public health and environmental hazards.”

Note that the Coalition quite rightly points out that these power plants also operate in the winter when energy demand also increases.  As New York State implements its aspirational greenhouse gas emission reduction goals natural gas and oil heating will have to be replaced by electric heating so demand will be further increased.

State Response

The air quality problem in the Northeast is so complicated that the Clean Air Act created the Ozone Transport Commission (OTC) specifically to with EPA on transport issues and for developing and implementing regional solutions to the ground-level ozone problem in the Northeast and Mid-Atlantic regions.  New York State has been actively involved with this organization since its inception. The first related presentation that I could find that specifically addressed emissions and air quality on high electric demand days was in 2006.  While there is an undeniable link between high energy demand and the high emissions that create peak ozone levels there is on over-riding requirement to keep the lights on.

DEC worked for years with other agencies, the New York Independent System Operator and other stakeholders to address this aspect of the peaking units.  Ultimately in late 2019 they promulgated new  limits for the simple cycle turbines such that they will be required to install controls or shut down. The compliance date for that regulation is May 2023 and the state may grant a two-year compliance extension to peaker plants deemed a “reliability resource by the NYISO or transmission owner”.  The reliability analyses and expected responses are evolving at this time.

Advocates believe that EJ communities are New York City’s most climate-vulnerable people.  New York State recently enacted the Climate Leadership and Community Protection Act (CLCPA) that establishes Statewide GHG emission reduction requirements and renewable and clean energy generation targets. The CLCPA also includes “multiple provisions that recognize that historically disadvantaged communities often suffer disproportionate and inequitable impacts from climate change”. The DEC is currently revising its proposing revisions to 6 NYCRR Part 242, “CO2 Budget Trading Program” that implement regulations for the Regional Greenhouse Gas Initiative (RGGI).  The proposed revisions expand its applicability to include certain smaller sources that are also named in this report.

PEAK Coalition

The PEAK Coalition has been organized to “end the long-standing pollution burden from power plants” in New York City’s environmental justice communities.  According to their overview the following organizations are in 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).  UPROSE promotes “sustainability and resiliency in Brooklyn’s Sunset Park neighborhood through community organizing, education, indigenous and youth leadership development, and cultural/artistic expression”.  THE POINT Community Development Corporation is “dedicated to youth development and the cultural and economic revitalization of the Hunts Point section of the South Bronx”.  NYC-EJA is a “non-profit, city-wide membership network linking grassroots organizations from low-income neighborhoods and communities of color in their struggle for environmental justice”.  NYLPI has “fought for more than 40 years to protect civil rights and achieve lived equality for communities in need”.  CEG is a “leading national, nonprofit advocacy organization working on innovative policy, technology, and finance strategies in the areas of clean energy and climate change”.

Report Acknowledgements

The following is the text from the report’s acknowledgement section:

Dirty Energy, Big Money was prepared by the PEAK Coalition and produced in collaboration with a national network of research partners. This report would not have been possible without the help of many dedicated people. We want to thank the exceptionally hard working and talented teams at Strategen Consulting and at Physicians, Scientists, and Engineers for Healthy Energy for their assistance.

The authors would also like to thank the New York State Energy Research and Development Authority, New York Power Authority, and New York City Council member Costa Constantinides for their continued support in helping advance the transition to a cleaner and more equitable energy system.

Finally, PEAK also thanks the numerous individuals and organizations that provided constructive technical feedback during the stakeholder review period. These efforts dramatically improved the quality of the final product.

This report was made possible through the generous support of the Scherman Foundation’s Rosin Fund. The views reflected in the report are entirely those of the authors.

Environmental Justice

This section provides an overview of environmental justice as background to the report.  EPA defines environmental justice as “the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income, with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies”. They state that this goal will be achieved “when everyone enjoys: the same degree of protection from environmental and health hazards, and equal access to the decision-making process to have a healthy environment in which to live, learn, and work”.

The New York State Department of Environmental Conservation (DEC) defines environmental justice as the “fair and meaningful treatment of all people, regardless of race, income, national origin or color, with respect to the development, implementation, and enforcement of environmental laws, regulations and policies. Environmental Justice allows for disproportionately impacted residents to access the tools to address environmental concerns across all of DEC’s operations”.

Ultimately environmental justice (EJ) is another way of expressing the Golden Rule and I fully support the concept and intent of incorporating specific requirements to address this in environmental decision-making.  So far so good.  However, I am a numbers guy and have had trouble figuring out how this should be applied in practice.  New York State’s Article 10 permitting process for siting major electric generating facilities references the DEC regulation Part 487 “Analyzing Environmental Justice Issues in Siting of Major Electric Generating Facilities Pursuant to Public Service Law Article 10”.  In my opinion, New York’s approach to environmental justice is keyed to disproportionate impacts.

The definition of disproportionate is critical to the ramifications of New York EJ regulation.  However, the definition is so vague that interpretation is a problem.  Disproportionate impact analysis requires comparison between the EJ community and a “Comparison Area”.  The Comparison Area is defined as a community in the same county and adjacent to the EJ community.  Section 487.9 Comprehensive Demographic, Economic and Physical Descriptions (d)(2) defines the measures used for the comparison:

In evaluating the significance of any adverse environmental and public health impacts of the proposed facility, the applicant shall measure the impacts against regulatory thresholds or standards, as applicable, and shall also consider the following:

1. 1. scope, magnitude, frequency, and duration of the impacts on the environment, public health, and quality of life in the Impact Study Area;
   2. nature of the impacts on sensitive populations including children and the elderly;
   3. degree of increased risk in the event of natural or man-made disasters; and
   4. any other information necessary to evaluate significance of the adverse impacts.

For the purposes of illustrating the potential difficulties defining disproportionate impacts, consider the following example for the air quality impacts of a facility on three communities.  In all the examples, the total impact is less than the National Ambient Air Quality Standard so the concern is whether the effect of the facility is disproportionate.  Mediterranean Avenue and Baltic Avenue represent the Environmental Justice Community of Monopoly where the lowest rents are charged.  The comparison communities are the adjacent properties of Oriental, Vermont and Connecticut Avenues (grey community) and Park Place and Boardwalk (blue community) where the highest rents are charged.

The Disproportionate Impact Table illustrates the wide range of relative impacts for this simple example.  If the EJ community is impacted by the facility and impacted by cumulative impacts while the comparison communities are not affected by either, then the impact is clearly disproportionate.  If all the impacts are the same then the impact clearly is proportionate. However, neither situation is likely.  Adjacent communities likely have similar direct and cumulative impacts and must have the same background. Even when dealing with a specific numerical limit, interpretation is ambiguous.  For example, if the impacts to the EJ community and the grey comparison community are the same, but the blue community has very much lower impacts is that disproportionate to the EJ community?

As previously noted, I support the concept that EJ communities should not be disproportionately impacted by power plants.  Assuming that stakeholders can agree on what constitutes a disproportionate impact then we can move forward.  The problem that I believe is coming up now is that the EJ advocacy organizations are demanding zero risks in order to redress past injustices.  For example, in May 2017 Governor Cuomo announced New Locally Sourced Microgrid to Power the Empire State Plaza but the following February the New York Power Authority announced additional studies for the project in response to intense EJ advocacy efforts.  In September 2019 the microgrid plan was cancelled much to the delight of the local EJ advocates.  While the microgrid plan did have effects on the local community they represent orders of magnitude less impacts than the original facility but that was not good enough.  There is no benign way to generate electricity.  I worry that emotional arguments will color future EJ discussions and prevent rational decision-making for cost-effective solutions.

Motivation for the Report

The overview of the report notes that The PEAK coalition will be the “first comprehensive effort in the US to reduce the negative and racially disproportionate health impacts of a city’s peaker plants by replacing them with renewable energy and storage solutions”. Their collaboration brings “technical, legal, public health, and planning expertise to support organizing and advocacy led by communities harmed by peaker plant emissions”. They propose a “system of localized renewable energy generation and battery storage to replace peaker plants”.  This is supposed to “reduce greenhouse gas (GHG) emissions, lower energy bills, improve equity and public health, and make the electricity system more resilient in the face of increased storms and climate impacts”. I will address those claims in another post.

As noted, the CLCPA includes specific requirements to address EJ community concerns, DEC has promulgated a law that will shut down 100 of the old and inefficient simple cycle turbines as soon as possible without endangering reliability and the proposed revisions to New York’s RGGI rules expands applicability to many of the sources that are called out in the report.  It seems to me that this shows that the Cuomo Administration has delivered on its promises to the EJ community so why did this report come out at this time.

The conclusion of the report suggests that the timing is an example of not letting a crisis go to waste.

“As the nation faces an unprecedented public health crisis with the COVID-19 respiratory virus, the historic and disproportionate environmental burdens imposed on the most vulnerable among us by burning fossil fuels can no longer be ignored as a serious public health threat. COVID-19 has cast a light on the existing health disparities and vulnerability in environmental justice communities. New research links the direct correlation between long-term exposure to air pollution and significantly higher rates of death in people with COVID-19, which we are seeing now in environmental justice communities long-plagued by health disparities and vulnerability due to the exposure to air pollution from peaker plants—nearly always sited in under-resourced communities.”

I believe that this “new research” is referring to a Harvard study that on April 24, 2020 claimed “ that an increase of 1 μg/m³ in PM_2.5 is associated with an 8% increase in the COVID-19 death rate (95% confidence interval [CI]: 2%, 15%”.  Several days earlier this report was claiming that the increase in death rate was 15%.  But a new study from University of Washington and Stanford University researchers reports an inverse relationship between smoking and death from COVID-19 — i.e., countries with higher rates of smoking had lower rates of death from COVID-19.  As noted here, smoking is a very intense exposure to PM2.5. In breathing an hour of average US air, you will shallowly inhale less than 9 micrograms of PM2.5. Compare that with smoking a single cigarette during which you will deeply inhale anywhere from 10,000 to 40,000 micrograms of PM2.5.  I suggest that it is premature to claim any effect on COVID-19 from air pollution.

Conclusion

While I support the concept of addressing environmental justice concerns, I also suspect that criticizing aspects of their demands is something akin to disparaging mom and apple pie.  The primary reason I prepare these analyses is that I believe that cheap and reliable energy, in general, and electricity, in particular, is a basic human right so that should be a primary social and environmental justice concern.  I am convinced that that New York State energy policy is going raise the cost of energy significantly and I worry that it will risk electric reliability as well.  I intend to follow this background post up with an evaluation of the technical claims and proposed solutions in this report to see how they rate in that context.