DEFR Implications on Solar Power Viability

I recently published an article summarizing a Syracuse Post Standard description of the transition problem by Tim Knauss who described the work done by Cornell’s Anderson Lab headed by Dr. Lindsay Anderson. I submitted a letter to the editor describing the implications of Anderson’s work arguing that pausing renewable energy development would be appropriate.  This post responds to the rebuttal of my letter by Peter Wirth, Vice President, Climate Change Awareness and Action who claims that pausing renewable energy is the last thing we should do.

I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act) net-zero mandates will do more harm than good if the electric system transition relies on wind, solar, and energy storage because of reliability and affordability issues.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 480 articles about New York’s net-zero transition.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% GHG reduction by 2030. Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantified the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation.  New York Department of Public Service (DPS) Proceeding 15-E-0302 addresses DEFR but there is no schedule for resolving the future plans for DEFR in New York.

My primary reliability concern is the challenge of providing electric energy during periods of extended low wind and solar resource availability.  Experts, including those that are responsible for electric system reliability, agree that a new category of generating resources called Dispatchable Emissions-Free Resources (DEFR) is necessary during those periods.  I have dedicated a page to DEFR which I described in an article that summarized six analyses describing the need for DEFR: the Integration Analysis, New York Department of Public Service (DPS) Proceeding 15-E-0302 Technical Conference, NYISO Resource Outlook, Richard Ellenbogen, Cornell Biology and Environmental Engineering Anderson Lab, and Nuclear New York. 

My Letter to the Editor

On the same day that the Syracuse Post Standard published the Knauss article they published the following letter to the Editor:

The Tim Knauss article on Cornell Professor Anderson’s evaluation of the future New York electric grid is a readable summary of the issues associated with the need for a new dispatchable emissions-free resource (DEFR). 

However, it does not address the implications on current NY energy policy.

The Hochul Administration has finally started its update of the NY Energy Plan.  The draft scope of the plan describes an electric system that relies on wind and solar generation.  No jurisdiction anywhere has successfully developed such a system.  The State agencies responsible for a reliable electric system agree with Professor Anderson that a wind, solar, and energy storage system requires DEFR.  It is prudent to fund a demonstration project to prove that such an electric system will work or, at the very least, complete a comprehensive renewable feasibility analysis to determine whether such a system will maintain affordability and reliability standards.

The most likely DEFR backup technology is nuclear generation because it is the only candidate resource that is technologically ready.  Nuclear power has a proven record for resilient electric production, development would not require changes to the rest of the electric system, it is not limited by weather extremes, it has lower environmental impacts, and when life cycle costs are considered is likely cheaper.   Its use as backbone energy would eliminate the need for wind, solar, energy storage, and new DEFR deployment to meet Climate Act mandates.  Renewable development should be paused until proven feasible because it is likely a dead-end approach.

Rebuttal to My Letter

Two weeks later the Syracuse Post Standard published a rebuttal to my letter by Peter Wirth entitled “Pausing cheap, renewable energy is the last thing NY should do

Roger Caiazza’s letter, “NY must not rely on wind, solar to meet its energy needs” (Nov. 20, 2024), might make sense if it were written in 1954, when Bell Labs announced the invention of the first silicon solar cell.

Today, solar power is the least expensive form of energy, growing in leaps and bounds and the technology improving year by year.

In 1954, the cell developed by Bell Labs was about 6% efficient at converting sunlight into electricity. Today’s solar cells convert 20% to 22% of sunlight into electricity. Advanced research panels have reached as high as 30% efficiency. Every year the rate of efficiency improves.

Solar energy per kilowatt is cheaper than coal, which is less expensive than gas. Nuclear energy is, by far, the most expensive. In 2019, it was reported that New York utility customers subsidized nuclear reactors in Upstate NY to the tune of $540 million.

Given that solar energy is the least expensive, we should not be surprised that solar power has seen massive growth in the U.S. Between 2000 and 2022, solar capacity increased by an average of 37% per year, doubling every 2.2 years. As of the end of 2023, the United States had nearly 210 gigawatts (GW) of solar capacity installed, enough to power 36 million homes.

Solar energy is the energy of the future!

The study by Cornell Professor Lindsay Anderson does raise valid, serious questions. The grid needs to be upgraded. Storage capacity needs to be increased. Can we bring enough renewable energy on line quick enough? What is the role of nuclear energy in the short run? This is a complex problem with many moving parts.

However, to pause renewable energy — which has a track record of being the least expensive, becoming more efficient every year and emitting no greenhouse gases, the cause of climate change — is the last thing we want to do.

My Response

There are two problems with Wirth’s response.  If the consumer cost for delivered energy is considered, then solar is not the “least expensive”.  Secondly, Wirth did not acknowledge that until the feasibility of DEFR technology is resolved solar and wind resources may not be viable.

First, I will address the Wirth claim that the “solar energy per kilowatt is cheaper” than coal or natural gas which are both cheaper than nuclear.  I agree that is true.  For example, in this Energy Information Agency analysis the total overnight cost (2022$/kW) states that nuclear is 5.8 times more expensive than solar.  However, I think most consumers care about the cost of getting electric energy delivered to their homes on a kilowatt-hour basis which is what we pay for.  When that metric is used solar is not cheaper than nuclear

For starters in 2023 the New York Independent System Operator reported in the  2024 Load & Capacity Data Report that the energy produced by all the New York utility-scale solar facilities relative to the maximum they could have produced was only 16.6% whereas the nuclear facilities generated 92.5% (Table 1).  Using the two years of data available it is reasonable to say that the ratio between nuclear capacity and solar capacity is around five.  That means to get the same kilowatt-hour production you need five times as much capacity. 

Table 1: Comparison of New York Nuclear and Solar Capacity Factors

Wind and solar resources are intermittent, and energy storage must be included to address that.  Nuclear units operate at full load for months at a time.  Solar only works during daylight.  The cost of energy storage for diurnal variations and seasonal variations must be included in the costs to deliver energy to our homes.  The implication of the study by Cornell Professor Lindsay Anderson is that DEFR is also needed beyond the short-term energy storage capacity. 

Consider the Scoping Plan projected capacity of different resources shown in Table 2.  In 2040 the Climate Act mandates that all electricity generated be 100% “zero emissions”.  The Scoping Plan projects that 40,860 MW of solar capacity and 26,580 MW of wind from various sources will be required.  To back that up an additional 15,388 MW of battery storage and 17,868 MW of zero-carbon firm resource, aka DEFR, are needed.  The cost of the solar share of the backup sources need to be considered for a “apples to apples” comparison of the cost of solar relative to nuclear.

Table 2: Scoping Plan Mitigation Scenario Summary Fuel Mix (Capacity)

But wait there is more.  The life expectancy of solar panels is on the order of 25 years whereas nuclear is at least 50 years.  Solar facilities are spread out and require transmission development. There are additional ancillary support services provided by nuclear that are not provided by solar so there are additional costs there as well.

To sum up, the solar capacity needed to produce the same capacity as nuclear is five times larger.  It is reasonable to assume that the short-term energy storage costs needed for solar and the DEFR requirement will another doubling of capacity costs.  Solar lasts half as long as nuclear so over the long-term, so there is another doubling of capacity costs.  I have no idea what the costs to provide ancillary support services would be or how much the additional transmission development would cost so I won’t include them in the total.  Overall, the long-term cost of solar power is roughly 15 times as much as nuclear power.  Even if solar energy per kilowatt is six times less than nuclear power, the delivered cost over the long term is 2.5 times higher than nuclear.

It is more disappointing that Wirth missed the point I tried to make about the implications of DEFR feasibility on the viability of solar.  Assuming that the reason was my poor description, let me try another way to explain that DEFR is a necessary requirement for renewables deployment as envisioned by the Climate Act.

Anderson and responsible agencies all agree that new DEFR technologies are needed to make a solar and wind-reliant electric energy system work reliably.  No one knows what those technologies are.  I believe the only likely viable DEFR backup technology is nuclear generation because it is the only candidate resource that is technologically ready, can be expanded as needed, and does not suffer from limitations of the Second Law of Thermodynamics. I do concede that there are commercial issues that need to be resolved. 

Here is the key point, if the only viable DEFR solution is nuclear, then the wind, solar, and energy storage approach favored by Wirth cannot be implemented without nuclear.  I estimate that 24 GW of nuclear can replace 178 GW of wind, water, battery storage, and DEFR which eliminates the need for a huge DEFR backup resource and even more massive buildout of wind turbines and solar panels sprawling over the state’s lands and water.  I suggested that it be prudent to pause renewable development until a DEFR technology is proven feasible because the choice and even the viability of any DEFR technology will affect the entire design of the future electric structure necessary to meet the Climate Act net-zero energy system.  Throwing money at renewable energy is the last thing we should do because New York cannot afford to invest in “false solutions”.

Conclusion

Over the years I have had many conversations with people who understand the electric system.  Universally they all agree that the wind, solar, battery storage, and DEFR electric system will never work.  Most also agree that the momentum of the political mandates for this approach will only be checked when there is a catastrophic blackout caused by over-reliance on renewable resources.  I have no doubt that advocates like Wirth will argue that such a blackout was caused by industry not transitioning to renewables correctly despite evidence to the contrary. 

In a recent meeting, someone from the New York State Energy Research & Development Authority suggested that there would be a five-year plan to address DEFR technologies.  In a rational world, the fact that New York is proceeding to implement a “zero emissions” electric system by 2040 that requires a new technology to be developed, tested, and deployed in that time frame would concern the Hochul Administration enough to pause implementation until a DEFR technology is proven feasible in the suggested five year plan.  The fact is that without such technology the renewables approach cannot work, and  if nuclear power is determined to be the only viable DEFR technology, then renewable investments are not needed.

Keith Schue: New York Needs Nuclear

Keith Schue alerted me to his piece for the Empire Report titled New York Needs Nuclear, a Balanced Approach to Clean Energy.  I am always happy to publish pragmatic discussions of New York energy policy so I am re-publishing his article in this post.

Keith Schue is an electrical engineer and technical adviser on energy policy. Schue has been engaged in New York energy policy since 2010 and currently volunteers as a technical advisor for several organizations, including New York Energy & Climate Advocates. Before moving to New York, he was employed with the Florida chapter of The Nature Conservancy.  He recently co-authored a commentary in the Albany Times Union with climate scientist James Hansen, making a persuasive case for using nuclear in the future. 

Overview

The Climate Leadership & Community Protection Act (Climate Act) established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes an interim 2030 GHG reduction target of 40%. Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and a requirement that all electricity generated be “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation. 

I recently published Schue’s summary of draft documents that covered three of these implementation initiatives.  In this article he references the New York Power Authority (NYPA) Draft Renewables Plan.  He noted that the Build Public Renewables Act adopted last year now forces NYPA to try installing solar, wind, and batteries even faster than the private sector is already doing with subsidies.  He suggested that comments on the NYPA renewables plan should say:

Achieving carbon-free electricity requires firm reliable power. Therefore, throwing more public money and resources at intermittent generation not only jeopardizes reliability and affordability, but also ensures that NY will remain dependent on fossil fuels. Instead of focusing on solar panels and wind turbines that the private sector can install on its own, NYPA should do what it has historically done best by working on reliable public projects for the common good, like nuclear energy, hydropower, and utility infrastructure.

In the following section I present Schue’s article that first appeared in Empire Report in its entirety.

New York Needs Nuclear, a Balanced Approach to Clean Energy

Global warming is real, as is the urgency for action to address it. However, New York will only make good on its promise of tackling the climate crisis if it pursues solutions that work in the real world.

Unfortunately, the strategic plan recently drafted by the New York Power Authority (NYPA) falls short of what’s needed—not because it fails to install enough solar panels, wind turbines and batteries, but because that is all it proposes to do.

For decades, NYPA has spearheaded vital energy projects that serve the public good. From the construction of large hydroelectric plants to positioning New York as a leader in nuclear power, the authority has consistently delivered electricity that is reliable, clean, and affordable to communities and business upstate. Indeed, NYPA is the reason why New Yorks’ upstate grid is already 90% carbon-free.

Yet, instead of building upon that impressive legacy, the plan currently proposed threatens grid stability by marginalizing firm resources and focusing on those that are fragile, intermittent, and incredibly land-intensive. It is an approach that jeopardizes greenhouse gas reduction, perpetuating dependence on fossil fuels while making electricity less reliable and more expensive.

It is also an approach that reflects outdated politics of the past.

Today, there is overwhelming consensus among engineers, industry leaders, the business community, and labor unions that a diverse mix of resources—including advanced nuclear power—will be essential to decarbonize while providing ample energy for a growing economy and workforce. Even Governor Hochul emphasized this reality at her recent Future Energy Economy Summit in Syracuse. Micron’s semiconductor manufacturing operations alone are expected to surpass the electricity demand of Vermont and New Hampshire combined. However, in addition to accommodating unprecedented growth, a zero-emission grid must be robust. Dispatchable Emission-Free Resources (DEFRs) capable of serving demand when renewables cannot are essential.  Moreover, DEFRs that operate a lot more than 2% of the time will be needed in the real world to avoid retaining large amounts of fossil fuel capacity. Batteries and hydrogen simply won’t suffice.

Rather than focusing on sprawling intermittent sources that cannot go the distance, the state should pursue compact solutions that will. NYPA should leverage its technical and financial expertise to support the Governor’s vision of integrating flexible advanced nuclear into New York’s grid. There are communities eager to embrace it. Where possible, responsible hydropower expansion can also be explored, like collaborating with the Green Island Power Authority to increase generation capacity on the Hudson River. Infrastructure improvements should be pursued as well, but in a manner that respects communities.

One thing is certain: New York’s energy strategy must change. Communities are under attack from the Office of Renewable Energy Siting, businesses are questioning whether they can survive in the state, industry is asking whether there will be energy to expand, and skilled labor is wondering if the only jobs left for them will be unpacking solar panels from China.

A successful strategy will require compromise. With a balanced expansion of solar, wind, and firm nuclear power, the state can meet its energy goals. However, NYPA’s leadership in needed more than ever to forge pragmatic solutions that work. The future of New York hinges on its ability to adapt and champion a diverse, reliable, and sustainable energy portfolio. NYPA should be a guiding force in that critical transition.

Commentary

I was happy to re-publish Keith’s article because I agree with him that nuclear power is necessary and that NYPA should be considering it along with solar and wind in the Draft Renewables Plan.  I have one minor point of emphasis difference because I think balanced expansion with wind and solar development is a dead end.  I have come to the conclusion that reliance on those resources will do more harm than good because of reliability and affordability risks.  Importantly, consider that the State agencies responsible for a reliable energy system agree that a wind, solar, and energy storage system needs a new dispatchable emissions free resource (DEFR) to account for low resource availability during periods of extended light wind and cloudiness.  At some point, New York must do a feasibility analysis to determine which DEFR technologies should be used in New York.  I believe that analysis will find that the only viable candidate for DEFR is nuclear power.  That means that a wind and solar energy system must include nuclear power as the DEFR backup technology.  However, economics suggest nuclear resources should be used as much as possible instead of as a backup. Using nuclear as the backbone of the electric system eliminates the need for the massive wind, solar and energy development proposed and addresses my concerns about reliability and affordability.

September New York Dunkelflaute or Wind Lull

I have been meaning to write this article for several months.  In September Parker Gallant noted that industrial wind turbines (IWT) in Ontario “show up at the party, almost always, after everyone has left” in a post that described poor performance of the province’s wind turbines over a five day period in September.  I looked at New York data, found that wind data was also poor in the state at the same time, and planned to do a post.  Other issues came up but a recent Dunkelflaute wind lull in Germany has spurred me to complete the post.  Better late than never, here it is. 

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 470 articles about New York’s net-zero transition.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% GHG reduction by 2030. Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantified the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation.  Unfortunately implementation efforts to date have short-changed addressing issues that have been identified.

Dunkelflaute

The German description of a wind and solar resource lull is Dunkelflaute.  Iowa Climate Science Education explains that the term refers to “dark doldrums”.  A large high pressure system has recently affected wind and solar resources in Europe.  Daniel Wetzel notes that:

At 5 p.m. on Wednesday, solar power was only supplying a single megawatt hour. The 1602 offshore wind turbines in the North and Baltic Seas – each one the size of the Eiffel Tower – were at a complete standstill. Zero electricity production.

Earlier in the week the British electric system faced a similar situation.

Ontario Dunkelflaute

Parker Gallant’s article provided a great example:

Looking at the following IESO Power data chart from September 13th to late in the day on September 18th it is evident Ontario Demand (solid green line) clearly demonstrates the daily swings in Ontario demand during those “summery” days. It is evident, demand fluctuates by almost 6,000 MW from the middle of the night to later in the day!  Those swings in demand are even higher when you examine the data in respect to “market demand” (blue line) which reflects our imports and exports via our intertie connections with our neighbours.

From the top of the chart:  the tiny “red” represents biofuel generation and “yellow” represents generation supplied by solar panels. The “green” tells us what those industrial wind turbines are generating hourly! The “dark blue” is generation from our natural gas plants and the “light blue” is power being supplied by our hydro generation stations some of which are classified as “baseload”! The solid unwavering “orange” represents what our baseload nuclear plants provide us with!

He describes the charts:

Looking at the six days illustrated, the highest peak demand occurred September 16th reaching 21,547 MW at Hour 17 (hour ending at 5 PM) and the lowest peak demand was September 14th reaching 19,288 MW at Hour 17! Interestingly Hour 17 was the peak hour on all six days.

As the Supply chart clearly demonstrates those natural gas plants (dark blue) fluctuated widely as needed to ensure we were able to avoid blackouts each and every day by either ramping up or ramping down as required! Hydro generation also played a role by also modestly, ramping up or down in addition to supplying some of the baseload.

Gallant went on to describe how the IWT performed:

Well, the high for generation by those IWT occurred at Hour 24 (ending at midnight) September 14th when they generated 2,199 MWh or 44.8% of their capacity and the low generation occurred at Hour 11 on September 13th when they only managed to generate 22 MWh or 0.5% of their capacity. Interestingly at Hour 24 on September 14th IESO reported our net-exports were 2,956 MWh at the low price of $24.07/MWh so we apparently didn’t need that power and were forced to sell it off for a cheap price! Also IWT over the six days hit their peak generation at Hours 23, 24 or Hour 1 when peak demand is always near its lowest for each and every day! Coincidently their low generation over the same  6 days occurred at either Hours 10 or 11 when demand is accelerating!

New York Wind Data

I attempted to access the Ontario IESO generation data for the period but could not find it.  On the other hand, the New York Independent System Operator (NYISO) provides access to their data.  New York fuel-mix load available at the NYISO Real-Time Dashboard where there is a link to historical data.

The Real-Time Fuel Mix panel includes links to current and historical five-minute generation (MW) for energy generated in New York State.  I processed that data to calculate hourly averages.  The generator types include “Hydro” that includes pumped storage hydro; “Wind”, mostly land-based wind but does include 136 MW of offshore wind; “Other Renewables” that covers solar energy (394 MW of “front-of-the-meter solar”), energy storage resources (63 MW), methane, refuse, or wood; “Other Fossil Fuels” is oil; “Nuclear”; “Natural Gas”; and “Dual Fuel” which are units that burn both natural gas and oil. As an aside, oil capability is maintained as a reliability measure.

The following graph shows the hourly fuel type generation throughout the period.  Note that there are similarities with the Ontario data.  New York does not have as much nuclear, but both control areas use it as solid, unwavering baseload power. New York hydro has more diurnal variation because there are pumped storage hydro facilities used for load following.  In both control areas natural gas is relied on to provide power when needed.  New York has dual-fuel units that probably burned natural gas during this period.

The focus of this article is the Dunkelflaute, so the wind data are of most interest.  The following figure lists the wind data only.  Because I could not combine data sets, we can only consider a qualitative comparison between New York and Ontario.  The wind output is the similar – low when needed most and picking up when demand drops.

Because I have access to the actual data, I can summarize just how bad the wind was over this 192-hour period.  New York has 2,454 MW of wind capacity.  The maximum wind capacity occurred on 19 September at hour 21 when 502 MW of wind power was generated, an unimpressive 20.5% of the total capacity.  The minimum wind capacity occurred on 13 September at hour 12 when 0.2 MW of wind power was generated.  I summarized the hourly totals by category in Table 1.  There were 96 hours representing half the period when the capacity of all the wind generation in New York was less than 5%.  All but one of the hours had a capacity factor of less than 20%.

Table 1: Categorial Hourly Totals for New York State Wind Power from 12 September 2024 hour 0000 to 19 September 2024 hour 2300

The NYISO Operations Report for September 2024 Wind Performance Figure shows daily wind production over the entire month.  Those data show that the daily capacity factor was less than 10% from 9/10/24 to 9/20/24. 

Discussion

In my opinion, climate scientists tend to over-emphasize potential global warming drivers when explaining weather observations.  For example, I saw a news segment where a climate scientist claimed that warmer temperatures associated with global warming increased the rainfall associated with Hurricane Helene in western North Carolina by 15 to 20% exacerbating the flooding.  Baloney, I say.  The supposed rationale is that warmer weather increases the amount of moisture that the atmosphere can hold and climate change models are used provide numbers for these attribution statements.  I addressed the Helene hype claims earlier.  Given that there was a storm in 1916 that produced higher flood levels I don’t think that moisture content was the primary driver for the flood.  Instead, I believe that an unusual weather pattern caused the storm to stall over the region.  Even if there was some greater water capacity effect, it was small relative to the weather pattern impact.

My whole diatribe was a lead-in to make a point about weather patterns and the observed data in September 2024.  Light winds over 11 days are only possible if there is a large, slow-moving high-pressure system.  I have never seen any observational analyses claiming that they are trends in this kind of weather pattern.

More importantly, there are implications of these observations relative to the Climate Act transition to an electric system that relies on wind, solar, and energy storage capacity.  The fact that all of the New York wind generation only produced 0.2 MW during one hour must mean that the stagnant high pressure system was at least as big as New York including the offshore wind facility south of Long Island. It is hard to conclusively pick out the Ontario wind generation during the worst hour but it appears that there is very little wind generation at that time.  I maintain that to fully understand the geographical implications that a detailed analysis of meteorological data and expected wind and solar generation for New York and all the adjoining electric system control areas is necessary.  Lastly, I believe that the weather pattern that caused this wind lull could occur at any time of the year.  It may be more likely during certain times of the year but there is no reason that similar conditions could occur anytime.  This exacerbates the problem because the high-pressure systems that cause light winds often are accompanied by the most extreme temperatures which are when the observed peak loads occur.

My primary reliability concern is the challenge of providing electric energy during these periods of extended low wind and solar resource availability.  This period perfectly exemplifies this kind of extended wind lull period.  To address this problem the organizations responsible for New York State electric system reliability agree that a new Dispatchable Emissions-Free Resource (DEFR) is need as described here.  In addition to the geographical considerations noted above, planning for must evaluate as long a period as possible.  That work must consider when wind and solar can charge energy storage capacity and when short-term energy storage must be discharged to meet system requirements.  The challenge of that analysis is obvious when looking at these wind output graphs.

Conclusion

The Dunkelflaute wind lull phenomenon occurs worldwide.  The comparison of Ontario and New York data shows that these conditions can cover both jurisdictions.  The New York data show the severity of the wind lull.  It is essential that electric system planners consider the impacts of the Dunkelflaute.  I believe that New York is addressing this issue.  However, I will only feel comfortable that they have considered the worst-case situation when they assess a longer period of data covering adjacent electric system control areas.

Unfortunately, clean energy advocates continue to dismiss the extent of the problem.  Even worse, some do not acknowledge that wind, solar, and energy storage cannot be relied on during those periods and that when the power is needed the most it is most likely to be in a resource lull.  These advocates are simply wrong and should be ignored.

NYCP – Get Charged Up for the New York State Energy Plan

On September 9, 2024 the Hochul Administration initiated the development of the State Energy Plan announcing the release of a draft scope of the plan.  On November 15 New Yorkers for Clean Power (NYCP) sponsored a related webinar titled “Get Charged Up for the New York Energy Plan”.  My first post on this webinar described the response to my question does New York need a Climate Act feasibility analysis. This post addresses the presentation of one of the speakers.

I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act) net-zero mandates will do more harm than good if the electric system transition relies only on wind, solar, and energy storage because of reliability and affordability risks.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 470 articles about New York’s net-zero transition.  The opinions expressed in this article 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.

Takeaway Message – If you don’t have ~15 minutes to read the whole thing

This article describes the presentation by Janet Joseph who was deeply involved in the development of the Scoping Plan.  She noted that issues associated with reliability and affordability are real problems that the advocacy community must address. The insurmountable problem with that is reality bats last. 

Her presentation and the others in the webinar did not provide solid support for the listeners to address the reliability and affordability problems. In my previous post about this webinar I documented that the claim by Dr. Robert Howarth that no new technology is necessary is contradicted by the agencies and organization responsible for electric system reliability.  Janet Joseph’s presentation disparaged those professionals so I expect that will be the essence of advocate comments.   Her presentation also argued that the energy plan should align with the Scoping Plan ignoring the fact that there hasn’t been a response to critical comments on that document.  Worse, the Hochul Administration has never proven that the list of strategies in the Scoping Plan are feasible. 

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% GHG reduction by 2030. Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantified the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation. 

Although related, the Energy Plan should not be confused with the Scoping Plan.  Every several years the New York Energy Planning Board is required to update its overall energy plan for the state. The process begins with an initial document that identifies a “scope” of work–meaning the set of things to be evaluated in the plan with a defined planning horizon of 2040. This makes the Climate Act’s 2040 goal of carbon-free electricity particularly relevant. That plan is to rely on wind, solar, and energy storage.  In my opinion, the Energy Plan must prove this will work.

Key Takeaways from the Event

The description of the New Yorkers for Clean Power sponsored a webinar titled “Get Charged Up for the New York Energy Plan” stated:

on November 15th. We are electrified by the demonstrated interest and information shared to support New York’s climate goals through the development of an ambitious and equitable State Energy Plan. To recap, our featured speakers were:

  • Janet Joseph, Principal, JLJ Sustainability Solutions (Former VP of Strategy and Market Development, NYSERDA
  • Dr. Robert Howarth, Member, New York’s Climate Action Council, and David R. Atkinson Professor of Ecology and Environmental Biology at Cornell University
  • Christopher Casey, Utility Regulatory Director for New York Climate and Energy, Natural Resources Defense Council (NRDC)

We’re excited to share the recording and slideshow from the event: Here is the recording of the event and check out the Presenters’ slides here.

Key Takeaways from the Event

  • Energy Plan is foundational to achieving New York’s climate and energy goals, aligning policies with the CLCPA.
  • Engagement from advocates, community members and developers is critical for ensuring equitable and actionable outcomes.
  • Challenges like building decarbonization and system reliability require innovative solutions and statutory changes.

This post addresses the presentations of Janet Joseph with respect to my concern that transitioning the New York electric grid to one that relies primarily on wind, solar, and energy storage will adversely affect reliability and affordability. 

Janet Joseph Presentation

The introduction for Janet Joseph notes that before her present gig with her own consulting firm she worked at the New York State Energy Research & Development Authority (NYSERDA).  In that role she was involved in the development of the Scoping Plan and earlier iterations of the Energy Plan.  Her

presentation noted that now that she is on her own, she can say what she “really thinks” about the transition dictated by the Climate Act.

One of my issues with New York’s unilateral net-zero transition is that we are such a small player in this global problem that whatever we do really cannot make a difference.  Joseph argued the opposing view that New York’s climate agenda is important.  She believes that New York needs to lead the way showing other jurisdictions how decarbonization can be accomplished.  “Mother nature’s accounting system is the only one that matters means we have to push for things that can be replicated in other regions”.  She did note that political accounting means we must push for policies that provide real co-benefits.  There were many things stated during the webinar that I take exception to, and this is one of them.  The calculation of co-benefits is largely a values judgement exercise that the Scoping Plan has biased by over-estimating benefits and ignoring disbenefits.  I could go on, but this is a minor issue relative to the Energy Plan.

Joseph explained the differences between the Energy Plan and Scoping Plan.  Her description of the Energy Plan concerns me.  She stated that the energy plan is the original place where NY’s “progressive energy policies and practices originated” due to the energy crisis of the 1970’s.  In my opinion one of the major tenets of progressivism is the preference for equity over equality which I believe adds unnecessary risks to electric system planning.  Note that the NYCP takeaways include the desire for “equitable and actionable outcomes”.  Joseph also said that the Energy Plan is “the vehicle used to push many progressive policies in New York”.    Equity “recognizes that each person has different circumstances and allocates the exact resources and opportunities needed to reach an equal outcome”.  On the other hand, “equality means each individual or group of people is given the same resources or opportunities”.   Translating that difference into electric system planning is a distraction for safe and adequate power for everyone.

Jospeh’s presentation notes that policies like renewable portfolio standards, energy efficiency, solar and storage issues all came from the energy plan.  I am disappointed by her remarks related to renewable energy.  She stated that “In the 1990’s, get this, we were debating 300 MW of renewable energy” because the opposition at the time said, “it would bring the system down”.  She concluded “Same arguments and same barriers in different decades” insinuating the proposed transition is simple.  In the first place, the scale of the renewable development is different – in 2030 wind and solar is expected to be over 100 times greater than 300 MW.  I think it is irresponsible to demonize the people who are responsible for keeping the lights on by anyone who will suffer no consequences by being wrong.  The biggest issue is that we are now debating whether the existing electric system of New York can be converted to one that relies on renewables even though no jurisdiction anywhere has successfully done so.  Disparaging New York’s electric experts gives the advocates who listened to the presentation false security and hope.

Joseph noted that while we have a comprehensive climate plan, we still must do the energy plan.  This is another point of disagreement.  In my opinion, the Scoping Plan is not comprehensive, it is just an outline of strategies that the Integration Analysis claims will comply with the Climate Act mandates. There has never been any responses to critiques raised during the Scoping Plan comment process but, more egregious from my perspective, there has never been a feasibility analysis. 

In the presentation she said that there were five things advocates should be looking  to be included in the Energy Plan but in her presentation she only described four things.

She said that the first aspect that needs to be included in the Energy Plan is alignment between the scoping plan and the energy plan.  Joseph argued that confusion and conflict between the two documents would cause delays, and we do not have time for that.  She wants “at a minimum, high level alignment, and ideally all the way down to perfect synergy of these documents”. In my opinion, the presumption made by the presenters that the Scoping Plan is feasible is simply crossing our fingers and hoping.  I raised many issues in my Draft Scoping Plan comments that were not addressed by the Climate Action Council and remain unresolved to this day.  Therefore, the Energy Plan offers the opportunity to correct the oversights and errors in the Scoping Plan.  It is inappropriate to assume alignment of the documents is appropriate.  We need to determine feasibility.

The second aspect raised was that the Energy Plan is a medium range plan from 2025 to 2040.  Her presentation urged the advocates to not debate how we will achieve the last 20%.  Joseph said that her experience has led her to believe we should focus on what we need to do to achieve the next 20% of reductions.  I disagree with this concept because it is likely that when the technologies for dispatchable emissions-free resources are selected nuclear power will be the best choice.  If that is the case, then renewables are not needed, making the current approach a costly dead end.

The third item she mentioned was that the Energy Plan has its roots in system reliability.  She said opponents to the renewables approach will be harping on reliability and affordability.  She admitted that those issues are real and that they will resonate politically.  Then she said that “the advocacy community must be armed to fight that battle and address the impact on reliability and affordability as best you can.”  She went on “System reliability issues will be the primary lenses through which recommendations will be filtered.”  Then she gave an example where the Urban Green Council partnered with a utility and a “credible analytical entity” to determine where reliability issues would not be an issue for New York City residential building electrification.  This is a common advocacy approach where “results for hire” consultants develop an analysis that supports the pre-conceived conclusions of funding organizations.  In my previous post on this webinar I documented that a similar targeted analysis that runs contrary to the findings of all the agencies of responsible for New York electric system reliability is being used to support renewable development.  In my opinion, the only way to refute concerns about reliability issues associated with renewables is to cherry pick analyses and ignore reality.

The fourth aspect energy plan she made is particularly concerning.  She said that (my transcript):

We have to evolve and expand from a narrow technocratic focus on the engineering requirements that keep the fuel flowing and the lights on to one that considers how our system, our infrastructure, and our practices need to change to increase the resiliency of human beings to survive within the new energy system dynamics and new climate extremes.

This aspirational baloney is difficult to interpret.  The interpretation and weighting of the proposed energy plan effects on “new energy system dynamics” and “new climate extremes” makes all the difference in the interpretation of her comments.  When advocates ignore the difference between weather and climate to ascribe every extreme weather event to climate change then the concept that everything needs to change to deal with the supposed existential threat is necessary.  She could be arguing that the Energy Plan must address this effect.  On the other hand, the reference to “new energy system dynamics” could be a tacit acknowledgement that relying on weather-dependent resources is an inherently less reliable approach.  I believe that relying on weather-dependent resources will inevitably mean that someday electricity will not be available when needed most.  She goes but does not clarify this distinction in my opinion:

“In short we need more focus not on just system reliability in this energy plan but resiliency.  We cannot be afraid to talk about what happens when the lights go out and how people remain safe in that event.  We will have storms, we will have downed power lines, and the lights will go out.  We need to think through this.  It is not just a New York issue.  This is a certainly a global issue.  We will have extreme weather that will affect the totality of our infrastructure. 

This is bigger than an emergency preparedness plan.  Our future energy and related infrastructure policies and practices need to be shaped with these considerations in mind.  Here too, I sat in too many conversations over the years where people are debating – That shouldn’t be in an energy plan – it should be in an adaptation plan.  “That’s not a climate plan – it should be in a resiliency plan”.  It doesn’t matter where it is folks.  We have to start thinking through the weather extremes that we will be faced with, this rapidly changing energy system and how it affects people.  We need more focus on resiliency. 

She then threw out some ideas to “make it real”.  She suggested both heating and cooling capabilities should be mandated for landlords in our future climate.  She recommended more “community resiliency facilities with backup power”.  She also suggested that home designs should include “climate-safe zones” and maybe “requirements for solar and storage on every new home and subsidies for those who can’t afford it”.  She recommended weatherization to increase passive survivability in the event of a power outage.    She admitted that we have “GW of solar that is “not going to help us from a resiliency standpoint” and concluded that we need to determine what to do to improve upon this.

She concluded that:

I think that we have made tremendous progress in New York State in the Climate Scoping Plan developing really comprehensive GHG mitigation strategies.  I am proud to have participated in that activity.  But I don’t think we really have moved the needle on policies and practices that would develop a more resilient system at the central community and local level.  Just to be clear

I am not in the camp of those people who think every change we are making to reduce GHG emissions and increase renewables is going to take the system down.  I am in the camp that we have to think through this and make sure we are building in resiliency all the way down to the local level.  So I am hopeful that this energy plan will pick up on those hard resiliency discussions in a very meaningful and substantive way.  These are hard conversations but we have to start having them. 

The interpretation of which factors affecting resiliency she is concerned about is important.  She has enough experience and background to know that the new energy system dynamics have real risks.  I have no doubt that she sincerely believes that “new climate extremes” is a real thing.  If she believe that the primary resiliency driver is more extreme weather, her suggestions boil down to whether the emphasis should be on mitigation or adaptation.  On the other hand, she could be admitting that the new energy system dynamics are a real concern that could be addressed by accepting less reliability and just dealing with blackouts better.  That is not outside the realm of possibility because I have read climate advocates who have argued that it is appropriate.  However, that response is antithetical to New York electric resource planning doctrine and I think most electric users in the state would not accept more frequent and longer blackouts as an acceptable risk for reducing GHG emissions.

Conclusion

It was interesting that Janet Joseph recognized that reliability and affordability are real.  Then she said that “the advocacy community must be armed to fight that battle and address the impact on reliability and affordability as best you can.”  The insurmountable problem with that is reality bats last.  I have three related concerns about presentations at this webinar.

The presentations gives Climate Act proponents false confidence that the proposed transition to an electric system that relies on wind, solar, and energy storage has few risks.  In my previous post about this webinar I documented that the claim by Dr. Robert Howarth that no new technology is necessary is contradicted by the agencies and organization responsible for electric system reliability.  Janet Joseph’s presentation disparaged those professionals inappropriately in my opinion.

Joseph’s remarks also argued that the upcoming Energy Plan must align with the Climate Act’s Scoping Plan.  I do not think that the Scoping Plan proved that its proposed strategies would maintain system reliability standards or that it would be affordable.  In her leadership role on the Energy Efficiency and Housing Advisory Panel she never responded to related comments and questions on the Draft Scoping Plan.  That lack of acknowledgement of criticism was true of all the critical comments made.  As a result, I think the Scoping Plan is flawed and must not be used as the template for the Energy Plan.

Finally, I disagree with the Joseph’s support for progressive equity concepts relative to the electric system.  That approach would require treating the availability and affordability of electricity differently to certain constituencies.  That is anathema to me because I think there will be serious unintended consequences.

Does New York Need a Climate Act Feasibility Analysis

On September 9, 2024 the Hochul Administration initiated the development of the State Energy Plan announcing the release of a draft scope of the plan.  On November 15 New Yorkers for Clean Power (NYCP) sponsored a webinar titled “Get Charged Up for the New York Energy Plan” that was intended to brief their supporters about the Energy Plan.  This article will be the first of two posts addressing this webinar. I have a tendency to write comprehensive posts that are too long for my readers so I am going to break this story up.

I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act) net-zero mandates will do more harm than good if the electric system transition relies on wind, solar, and energy storage.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 470 articles about New York’s net-zero transition.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% GHG reduction by 2030. Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantified the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation. 

Although related, the Energy Plan should not be confused with the Scoping Plan.  Every several years the New York Energy Planning Board is required to update its overall energy plan for the state. The process begins with an initial document that identifies a “scope” of work–meaning the set of things to be evaluated in the plan with a defined planning horizon of 2040. This makes the Climate Act’s 2040 goal of carbon-free electricity particularly relevant. Unlike the 70% renewable goal which only applies in 2030, the 2040 goal does not mandate an arbitrary quota of “renewables”. Instead, it simply mandates carbon-free electricity, which can include nuclear power. 

Key Action Items from the Webinar

The description of the New Yorkers for Clean Power webinar titled “Get Charged Up for the New York Energy Plan” stated:

Thank you for joining us for the “Get Charged Up for the New York State Energy Plan” Teach-In on November 15th. We are electrified by the demonstrated interest and information shared to support New York’s climate goals through the development of an ambitious and equitable State Energy Plan. To recap, our featured speakers were:

  • Janet Joseph, Principal, JLJ Sustainability Solutions (Former VP of Strategy and Market Development, NYSERDA
  • Dr. Robert Howarth, Member, New York’s Climate Action Council, and David R. Atkinson Professor of Ecology and Environmental Biology at Cornell University
  • Christopher Casey, Utility Regulatory Director for New York Climate and Energy, Natural Resources Defense Council (NRDC)

We’re excited to share the recording and slideshow from the event: Here is the recording of the event and check out the Presenters’ slides here.

Key Takeaways from the Event

  • Energy Plan is foundational to achieving New York’s climate and energy goals, aligning policies with the CLCPA.
  • Engagement from advocates, community members and developers is critical for ensuring equitable and actionable outcomes
  • Challenges like building decarbonization and system reliability require innovative solutions and statutory changes.

I am going to address the presentations of Janet Joseph and Robert Howarth in a later post.  I disagree with their comments that downplay my concern that transitioning the New York electric grid to one that relies primarily on wind, solar, and energy storage will adversely affect reliability and affordability.  This post is going to describe Dr. Howarth’s response to my specific question about the need for a feasibility analysis.   

Feasibility Analysis Background

Dr. Howarth is venerated by New York environmental advocates but I think their faith is misplaced.  His Introduction at the webinar extolled his role in vilifying methane’s alleged importance as a greenhouse gas.  I think that obsession is irrational.  The hostess also lauded his work supporting a Biden Administration pause on applications for LNG export terminals.  However his analysis was “riddled with errors” and he eventually retracted some of the more extreme claims that received media attention.

Howarth claims that he played a key role in the drafting of the Climate Act and his statement  at the meeting where the Scopng Plan was approved claims that no new technology is needed:

I further wish to acknowledge the incredible role that Prof. Mark Jacobson of Stanford has played in moving the entire world towards a carbon-free future, including New York State. A decade ago, Jacobson, I and others laid out a specific plan for New York (Jacobson et al. 2013). In that peer-reviewed analysis, we demonstrated that our State could rapidly move away from fossil fuels and instead be fueled completely by the power of the wind, the sun, and hydro. We further demonstrated that it could be done completely with technologies available at that time (a decade ago), that it could be cost effective, that it would be hugely beneficial for public health and energy security, and that it would stimulate a large increase in well-paying jobs. I have seen nothing in the past decade that would dissuade me from pushing for the same path forward. The economic arguments have only grown stronger, the climate crisis more severe. The fundamental arguments remain the same.

As I will show in this article, I think his claim that the transition can be implemented using wind, sun, and hydro using existing technologies is wrong.        

Do We Need a Feasibility Analysis?

I thought it would be appropriate to give Howarth the opportunity to recant his feasibility claim so I submitted the following question:

On November 4, 2024, the New York Department of Public Service (DPS) staff proposal concerning definitions for key terms notes that “Pursuing the 2040 target will require the deployment of novel technologies and their integration into a changing grid”.  Should there be a feasibility analysis in the energy plan to address their concern about the new technologies?

In his response, Howarth admitted that he was not familiar with the particular reference to the DPS proceeding that is implanting the Climate Act mandates.  Then he answered (my lightly edited transcription of his responses):

I can give you the perspective of three years of discussion on the CAC.  That it is we firmly stated that the goals can be met with existing technologies. We don’t need novel technologies.

One of my unresolved questions relative to Howarth’s position and the Scoping Plan is that he voted to support the Scoping Plan.  However, the Scoping Plan explicitly contradicts his statement that technologies available in 2013 were sufficient for the transition away from fossil fuels.  In particular, the Final Scoping Plan Appendix G, Section I page 49 states (my highlight included):

During a week with persistently low solar and wind generation, additional firm zero-carbon resources, beyond the contributions of existing nuclear, imports, and hydro, are needed to avoid a significant shortfall; Figure 34 demonstrates the system needs during this type of week. During the first day of this week, most of the short-duration battery storage is quickly depleted, and there are still several days in which wind and solar are not sufficient to meet demand. A zero-carbon firm resource becomes essential to maintaining system reliability during such instances. In the modeled pathways, the need for a firm zero-carbon resource is met with hydrogen-based resources; ultimately, this system need could be met by a number of different emerging technologies.

In addition to the Scoping Plan statement that a zero-carbon firm resource is needed, the organizations responsible for New York State electric system reliability agree.  The New York Independent System Operator (NYISO) 2023-2042 System & Resource Outlook, and Power Trends 2024 analyses and the New York Department of Public Service (DPS) Proceeding 15-E-0302 Technical Conference determined that DEFR was needed.  Independent analyses by the Cornell Biology and Environmental Engineering, Richard Ellenbogen, and Nuclear New York also found that it was needed.  For example, a very readable description of the DEFR problem by Tim Knauss describing the work done by Cornell’s Biology and Environmental Engineering Anderson Lab found that “Just 15 years from now, the electric grid will need about 40 gigawatts of new generating capacity that can be activated regardless of wind speeds, cloud cover or other weather conditions”.

While this is not directly applicable to the DEFR requirement I want to highlight the following Howarth quote:

Now having said that.  There are a lot of details to work out, energy storage is going to be critical.  Lisa made the point that ground source heat pumps and thermal networks are better than air source heat pumps.  They are hugely more effective in the peak time in January.  If we go that route we don’t need as much electrical capacity overall. I would add that thermal storage is cheaper than electrical storage for energy.  Particularly if you have a thermal network because you can store heat that can provide a community with heat for weeks to months to even on an annual basis.  There is a community in Saskatchewan I believe where they store heat six months at a time which is very cheap compared to other things

I believe Howarth’s thermal network reference is to Calgary’s Drake Landing solar heating community.   There is only one problem. The system established in 2006 is failing and will be decommissioned less than 20 years after it was built.  In my opinion, the New York Energy Plan must include a critique of the Drake Landing experiment and the implications for New York thermal networks. This is another feasibility analysis that I think is necessary.

Howarth went on to double down on his position that no new technologies are needed:

We don’t need new technologies to meet the goals of our climate law.  Mark Jacobson from Stanford, who I think is the most brilliant engineer I know.  He and I and others wrote a plan back in 2013, more than ten years ago, laying out specifically how to make the state of New York fossil fuel free on a realistic time frame.  We made the case then, more than ten years ago, that we did not need new technologies, and it was cost-effective then.  It is even more so now. The whole idea of waiting for the next new technology is an excuse for inaction.  We don’t need to wait.

I have assembled a page that describes the analyses that contradict the Jacobson and Howarth work and includes a critique of their results.  To adequately characterize the New York electric system, it is necessary to simulate the details of the New York electric transmission system.  Not surprisingly, of the 11 New York Control Areas the New York City area requires the most energy.  That fact coupled with geographical constraints because New York City is basically a load pocket means that transmission details are important.  To characterize wind and solar it is necessary to evaluate meteorological conditions to generate estimates of wind and solar resource production.  When that is coupled with projections of future load, the sophisticated analyses all conclude that the new dispatchable emissions-free resource is needed because simply adding much more short-term storage will not work.  In my opinion, academic studies like Jacobson and Howarth short-change transmission constraints and/or weather variability leading to false solutions and conclusions.

Advocates for the Scoping Plan energy approach demand action now because the law mandates renewables.  Invariably they overlook New York Public Service Law  § 66-p (4). “Establishment of a renewable energy program” that includes safety valve conditions for affordability and reliability that are directly related to the zero emissions resource.   § 66-p (4) states: “The commission may temporarily suspend or modify the obligations under such program provided that the commission, after conducting a hearing as provided in section twenty of this chapter, makes a finding that the program impedes the provision of safe and adequate electric service; the program is likely to impair existing obligations and agreements; and/or that there is a significant increase in arrears or service disconnections that the commission determines is related to the program”. 

Conclusion

The Climate Action Council should have established criteria for the three § 66-p (4) requirements so that there is a clear test to suspend or modify obligations.  New York State law has restrictions that protect citizens from irrational adherence to a dangerous energy future and I believe that a feasibility analysis for the new DEFR technology should be part of the evaluation for this mandate.

In my opinion, the most promising DEFR backup technology is nuclear generation because it is the only candidate resource that is technologically ready, can be expanded as needed and does not suffer from limitations of the Second Law of Thermodynamics. If the only viable DEFR solution is nuclear, then renewables cannot be implemented without it.  But nuclear can replace renewables, eliminating the need for a massive DEFR backup resource.  Therefore, it would be prudent to pause renewable development until DEFR feasibility is proven because nuclear generation may be the only viable path to zero emissions.

Jonah Messinger summarizes my worry that New York has placed undeserved reliance on the work of Robert Howarth:

That an activist scholar with a history of contested and critiqued claims could influence the Biden administration with such an obviously erroneous study is more than concerning. It demonstrates how faulty science in the name of climate can derail important policy debates, and make the global energy transition far harder.

I am sure that none of the advocates who venerate his work will ever be convinced that his work is fatally flawed.  However, it is time that the energy experts in the state step up and confront public officials with the reality that the Climate Act schedule and mandates are only possible with a new technology.  Evaluating the potential technologies and determining if they can be feasibly implemented affordably and without risking reliability standards is an obvious approach.

DEFR Concerns Update

I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act) net-zero mandates will do more harm than good if the electric system transition relies on wind, solar, and energy storage.  My primary reliability concern is the challenge of providing electric energy during periods of extended low wind and solar resource availability.  Experts, including those that are responsible for electric system reliability, agree that a new category of generating resources called Dispatchable Emissions-Free Resources (DEFR) is necessary during those periods.  This article summarizes a very readable description of the DEFR problem by Tim Knauss who describes the work done by Cornell’s Anderson Lab headed by Dr. Lindsay Anderson.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 470 articles about New York’s net-zero transition.  The opinions expressed in this article 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.

Takeaway Message – If you don’t have time to read the whole thing

This post summarizes a readable description of DEFR in an article by Tim Knauss.  He described the work of Dr. Lindsay Anderson regarding the necessary DEFR component of the proposed transition of the electric system to zero emissions.  The article explains how Anderson’s team calculates the gap between future wind, solar, and energy storage generating resources needed and projected electric load during periods of low renewable resource availability.  I believe that the work of the Anderson Lab provides support to my contention that renewable development should be paused.  A renewable-based electric system needs DEFR, the most likely DEFR solution is nuclear, but if you have zero emissions nuclear then you don’t need renewables.  That makes renewables a dead-end approach.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% GHG reduction by 2030. Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantified the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation.  New York Department of Public Service (DPS) Proceeding 15-E-0302 addresses DEFR but there is no schedule for resolving the future plans for DEFR in New York.

Because of its importance to the feasibility of the Climate Act, the subject of DEFR rates its own Pragmatic Environmentalist of New York page.  I described the page contents last July in an article that summarized six analyses describing the need for DEFR: the Integration Analysis, New York Department of Public Service (DPS) Proceeding 15-E-0302 Technical Conference, NYISO Resource Outlook, Richard Ellenbogen, Cornell Biology and Environmental Engineering Lindsay Lab, and Nuclear New York.  I have updated the page with references to the Tim Knauss article on Cornell Professor Anderson’s work.

Syracuse Post Standard “Mind-Boggling Gap”

On November 19 the article There’s a mind-boggling gap in NY’s plan for a clean electric grid. ‘We are so far behind’ by Tim Knauss was published on the Syracuse dot com website. It is not clear to me whether the official link is accessible by non-subscribers so I have posted a version here and reproduce some of it with some annotations below.

Knauss poses the critical question: “What technology will grid operators turn to when solar and wind fall short?”.  He notes:

Maybe it will be advanced nuclear reactors. Or hydrogen-burning power plants. Nobody knows for sure. Operators will need some emission-free power source they can turn on and off at will.

At Cornell University, Professor Lindsay Anderson and fellow researchers have been studying this problem. Given the specific layout of New York’s electric grid, they asked, how much of this new power source would be needed in addition to all the solar and wind?

A staggering amount, it turns out.

Just 15 years from now, the electric grid will need about 40 gigawatts of new generating capacity that can be activated regardless of wind speeds, cloud cover or other weather conditions, according to Anderson’s research.

How much is that? It’s roughly equal to the total capacity of all of New York’s current power plants – nuclear, natural gas, hydro, wind, all of it.

You read that right. To back up the massive quantities of solar and wind power that will provide most of our future electricity, the state power grid will need some new, mystery resource equal in size to the entire generating fleet of today.

The need for new, mystery DEFR, the potential quantity required, and the technological challenges for the resource are issues well known by those who understand the electric system.  However, there is a loud and passionate segment of society who disagree that anything new is needed and reject the scale of the projected resource need.  Anderson and Knauss understand that this is a touchy subject.  Knauss writes:

Anderson knows that’s not easy to hear.

“That’s the thing, right?’’ she said. “Where people are going to start to worry is (to) say, ‘Okay, wait, so you’re telling us that we’re going to spend all this money building out all this wind and solar and batteries — AND we have to put in 40 gigawatts of this?”

But there will have to be a backup.

Knauss describes the analysis work done to generate the “mind-boggling” projections.

Anderson chairs Cornell’s department of biological and environmental engineering. She has a PhD in applied math and a master’s degree in engineering.  For the past decade, she has worked with a shifting assortment of doctoral candidates and other graduate students in her eponymous Anderson Lab, housed in a large room full of cubicles and computers. They examine issues related to the growing importance of renewable energy.

The Anderson Lab is looking at the physics of how all that will work. To do so, they built an elaborately detailed computer model – a “digital twin’’ — of New York’s electric grid.

That level of detail sets their work apart. Many of the studies that look at phasing in renewable energy pretend that the electric grid is a single pool of electrons that flow from point to point without constraint. It‘s known as the “copper plate’’ assumption.

In reality, the New York electric grid is a complex, lopsided network that has been stitched together piece by piece over a century. There are limits on how much electric current can move from one area to another.

The six analyses that are described on my DEFR page all handle the electric system in similar fashions and all unequivocally conclude DEFR is needed.  The reference to studies that use the “copper plate” assumption refers to the analysis that was used by the politicians who authored the Climate Act.  It is the basis of the Climate Act presumption that implementation was simply a matter of political will because no new technology would be required.  New York’s electric grid experts disagree.  This contradiction needs to be resolved.

The Knauss article goes on to describe DEFR:

carbon-free generating plant that can be turned on and off as needed. It’s pronounced DEE-fur.

Today, dispatchable power is provided mostly by natural gas power plants. Energy planners hope to replace them with something that does not produce greenhouse gases. Nobody knows what that will be.

“They’ve come up with a name for something that they don’t know what it is, but their modeling shows that they need something. It kind of seems like dark matter in the universe,’’ said environmentalist Tim Judson, executive director of the Nuclear Information and Referral Service.

When the state’s Climate Action Council issued their December 2022 report on how the state will eliminate greenhouse gases from the grid by 2040, they estimated a need for 18 to 23 gigawatts of DEFRs. Anderson’s study concluded that the estimate should be roughly doubled, to 37 to 40 GW.  In its most recent forecast, the NYSIO estimated a need for at least 20 GW of DEFRs, and as much as 40 GW, by the year 2040.

Knauss explains that Anderson is concerned about the need for DEFR and the quantity required as well as the ramifications of this new resource:

The need stems from two main vulnerabilities, Anderson said.

First, there will be lulls when the wind dies down for days on end and the skies cloud over, resulting in power shortages that exceed the current ability of batteries to compensate. Second, there will be periods when the state has plenty of renewable energy but not enough transmission capacity to get it where it’s needed.

There would even be times when Upstate produced too much renewable energy, which must be disconnected to keep from overloading the grid, even as blackouts rolled across Downstate due to bottled up transmission lines.

Most of those problems are likely to occur in the coldest part of winter and the hottest part of summer, when demand for electricity will surge to peak levels. And the region most vulnerable to blackouts would be Downstate, where communities with massive electricity needs sit at the end of transmission lines from Upstate that are often overloaded.

These issues raise a concern of mine.  I maintain that there are unacknowledged challenges associated with weather variability risks associated with planning for the DEFR resources needed.  The first challenge is calculating the resources needed which requires analysis of meteorological data to estimate resource availability and expected loads.  I believe no one has done a comprehensive enough analysis because they haven’t used the longest period of data available, and they have not included adjacent regional transmission operator areas.  The second challenge is more concerning to me.  The evaluation of the meteorological data develops a probabilistic estimate of the resources needed that are analogous to the one in a hundred-year flooding parameter.  The problem is that we often see a flood exceeding the one in hundred probabilities.  It is inevitable that the weather conditions that caused the worst-case resource drought planning scenario will also be exceeded.  When that happens there will not be enough electric energy available, blackouts are likely, and the consequences of blackouts on a society that decarbonized by using electricity will be catastrophic. 

There is another issue relative to the aspirational Climate Act mandate to go to “zero emissions” by 2040.  We need DEFR but the technology is not available.  Knauss describes potential DEFR technologies:

Some experts propose converting power plants to burn hydrogen rather than natural gas. Or hydrogen could be used in fuel cells, which rely on chemical reactions rather than combustion to make electricity.

Others promote the idea of sequestering the carbon emissions from gas plants underground. Or burning “renewable” methane recovered from landfills and other sources.

Recently, New York officials have expressed interest in small advanced nuclear plants, which are under development by various companies. State energy planners are developing a “roadmap’’ that should be released early next year detailing how new nuclear technology might be encouraged.

None of the possible technologies is ready for commercial application. Which will emerge?

“That’s the million-dollar question,’’ said Lanahan Kevin Lanahan, a spokesman for NYISO, the grid operator.

The article goes on to note a difference of opinion regarding DEFR deployment.  On one side is the electric industry who are obligated to provide reliable electricity.

New York is long overdue to identify DEFR technologies and to support their development, said Gavin Donohue, executive director of the Independent Power Producers of New York, a trade group representing power plant owners.  IPPNY formally asked the Public Service Commission three years ago to decide what it will accept as “zero-emission’’ generating plants. The PSC is still mulling that over in a regulatory proceeding.  “The timely development of fully dispatchable zero emitting resources is crucial to maintain reliability as the economy electrifies and reliance on intermittent renewable and duration limited resources increases,’’ the group wrote.

On the other side are the special interests who have no accountability.

But some environmentalists argue against a rush to develop DEFRs, saying it could distract from building wind and solar resources and could lead state officials to hastily subsidize unproven technology such as hydrogen combustion.

Following a technical presentation to the state Public Service Commission last year by Anderson and a NYISO planning director, representatives from Sierra Club and Earthjustice submitted rebuttal comments claiming that NYISO’s forecast of the need for DEFRs was “alarmist.” (The forecast presented by NYISO that day was about 25% lower than the Anderson Lab’s estimate.)

The critics said the state should focus on proven techniques such as importing power from out of state, improving transmission, and encouraging demand response programs under which customers cut their power consumption during peak periods.  “Rushing to deploy expensive and untested DEFRs risks committing New York to flawed technologies, as it is unclear at the present time which technologies will emerge as commercially scalable and cost effective,’’ they wrote.

I responded to some of the referenced rebuttal comments because I think their analyses are naïve.  In the first place, their analytical methodologies are not as sophisticated as the Anderson Lab.  Secondly, they don’t acknowledge the correlation of wind energy across New York so their estimates of the magnitude of the problem are flawed.  Knauss mentions the critics “solutions”.

It’s a complicated issue, in part because there are strategies other than adding power plants to help reduce demand for electricity during peak periods.  Improvements in meter technology, for example, will enable residential customers to respond during power shortages by reducing their demand, as some commercial and industrial customers do already. Likewise, grid operators could one day draw power from electric vehicle batteries during peak periods.

This line of reasoning is naïve because it ignores the fact that DEFR is needed when the electric system energy requirements are highest.  The conditions that cause light winds and low wind power output also cause extreme temperatures which lead to peak electrical loads.  Those are the conditions when residential customers are not going to want to reduce power consumption.  They will want to keep their homes warm! 

The article goes on to discuss practical alternatives to the “mind-boggling” gap and the aspirational Climate Act schedule.  Dr.  Anderson suggested looking at slightly less stringent emission limits at least as a bridge until a DEFR solution is found.

Knauss also points out that the Anderson Lab work makes the optimistic assumption that all the wind and solar projected by the Hochul Administration actually gets built on schedule.

In reality, siting battles and other issues have stalled many large wind and solar projects for years. And as inflation drives up the capital costs of renewable energy, Gov. Kathy Hochul is under mounting pressure from business and consumer groups to keep the cost of the energy transition under control.

Because of those barriers, there is a vast gap between New York’s renewable energy capacity today and what would be needed to retire all the fossil fuel plants. Developers would have to build about 10 times the wind and solar power that exists now.

“It’s a huge problem, and we are so far behind,’’ Anderson said.

Conclusion

I think that the Knauss article does a great job explaining the intricacies of the DEFR issue and the work of the Anderson Lab.  I believe they appropriately describe the challenges of DEFR.  However, the article does not address the policy implications of DEFR.

The Hochul Administration has finally started its update of the NY Energy Plan.  The draft scope of the plan considers an electric system that relies on wind and solar generation consistent with the Climate Act Scoping Plan.  No jurisdiction anywhere has successfully developed such a system.  The State agencies responsible for a reliable electric system agree with Professor Anderson that a wind, solar, and energy storage system requires DEFR.  I believe that it is prudent to fund a demonstration project to prove that such an electric system will work.  At the very least, the energy plan must provide a comprehensive renewable feasibility analysis to determine whether such a system will maintain affordability and reliability standards.

The most likely DEFR backup technology is nuclear generation because it is the only candidate resource that is technologically ready.  Nuclear power has a proven record for resilient electric production, development would not require changes to support the transmission system and buildout the system, it is not limited by weather extremes, it has lower environmental impacts, and when life cycle and backup costs are considered is likely cheaper.   Its use as backbone energy would eliminate the need for wind, solar, energy storage, and new DEFR deployment to meet Climate Act zero-emissions mandates. 

Sierra Club and Earthjustice argue that DEFR is a distraction to their preference for wind and solar development.  I believe that the work of the Anderson Lab provides support to my contention that renewable development should be paused because that development cannot work until DEFR is proven feasible.  If the DEFR solution is nuclear then renewables are a dead-end approach.

Renewable Transition Raw Materials Challenge

This article was also published at Watts Up With That.

The Bulletin of the Geological Survey of Finland “publishes the results of scientific research that is thematically or geographically connected to Finnish or Fennoscandian geology.”  Bulletin 416 Special Issue publishes two articles by Simon P. Michaux should be a warning to proponents of New York State’s Climate Leadership & Community Protection Act (Climate Act). 

I have followed the New York Climate Leadership & Community Protection Act (Climate Act) since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 470 articles about New York’s net-zero transition.  The opinions expressed in this article 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.

Note: This is a long technical post.  The takeaway message is this analysis of the metals required to transition away from fossil fuels compared to the capacity to mine those metals suggests that available metals are “manifestly inadequate for meeting projected demand”. Metals availability has not been addressed by the Climate Act implementation plan.

Estimating Metals Needed to Replace Fossil Fuels

The Preface to the Bulletin explains the purpose of the report:

The two contributions published in this Special Issue of the Bulletin of the Geological Survey of Finland highlight that a successful transition to renewable energy requires a comprehensive raw materials strategy that considers both the upstream metal demands and the downstream infrastructure needs. In technological and innovation space, exploring alternative battery chemistries, improving recycling rates, and developing more resource-efficient technologies will be crucial to mitigating the strain imposed on metal supply chains.

The earlier work of the sole author of these two papers has been widely quoted, debated, and criticized in the media and amongst policy makers and academic audiences in the past few years. The premises, process, and conclusions of these studies have questioned the validity of some of the basic assumptions underlying the current energy and natural resource policy, but have still, largely mistakenly, been taken as a statement in favor of the status quo. On the contrary, these contributions are intended as the beginning of a discourse and attempt to bring alternative, often overlooked, views into the discussion about the basic assumptions underlying the material requirements of the energy transition. Out of necessity, they make simplifications in recognizing and mapping out the scale of some key challenges in the raw materials sector that need to be overcome if the energy transition is to be realized. Calculations and estimations need to be refined and, naturally, in addition to raw materials production and the material transition, other crucial aspects such as technology and infrastructure development, workforce requirements, land use changes, and societal impacts, among others, also need to be considered.

Nevertheless, the challenges related to the complex and interconnected nature of the problem should not be taken as a cause to halt the development and innovation needed to overcome it. Further research, policy interventions, and international collaboration are all essential in securing sustainable supply chains, promoting responsible sourcing practices, and ensuring a just and equitable green and digital transition for everyone.

Scope of the Replacement System

The reference to the first article is:

Michaux, S. P. 2024. Scope of the replacement system to globally phase out fossil fuels. Geological Survey of Finland, Bulletin 416, 5–172, 50 figures, 51 tables and 10 annexes.

The Abstract states:

The task to phase out fossil fuels is now at hand. Most studies and publications to date focus on why fossil fuels should be phased out. This study presents the physical requirements in terms of required non-fossil fuel industrial capacity, to completely phase out fossil fuels, and maintain the existing industrial ecosystem. The existing industrial ecosystem dependency on fossil fuels was mapped by fuel (oil, gas, and coal) and by industrial application. Data were collected globally for fossil fuel consumption, physical activity, and industrial actions for the year 2018.

The estimated sum total of extra annual capacity of non-fossil fuel power generation to phase out fossil fuels completely, and maintain the existing industrial ecosystem, at a global scale is 48,939.8 TWh.

A discussion on the needed size of the stationary power storage buffer to manage intermittent energy supply from wind and solar was conducted. Pumped hydro, hydrogen, biofuels and ammonia were all examined as options in this paper. This study uses four stationary power buffer capacities: 6 hours, 48 hours + 10%, 28 days and 12 weeks. This power buffer is assumed to be supplied through the use of large battery banks (in line with strategic policy expectations).

An estimate is presented for the total quantity of metals required to manufacture a single generation of renewable technology units (EV’s, solar panels, wind turbines, etc.) sufficient to replace energy technologies based on combustion of fossil fuels. This estimate was derived by assembling the number of units needed against the estimated metal content for individual battery chemistries, wind turbines, solar panels, and electric vehicles. The majority of the metals needed were to resource the construction of stationary power storage to act as a buffer for wind and solar power generation.

It was shown that both 2019 global mine production, 2022 global reserve estimates, 2022 mineral resources, and estimates of undersea resources, were manifestly inadequate for meeting projected demand for copper, lithium, nickel, cobalt, graphite, and vanadium.

The analysis takes a bottom-up approach to determine what is needed for global fossil fuel replacement.  For example, Michaux estimates how many vehicles were used for transport by class and the miles traveled to estimate how much fossil fuel was used and the energy needed for replacement.  He proposes non-fossil fuel technology as replacements.  The work estimates “the quantity of electrical energy required to charge the batteries of a complete EV system” and “the quantity of electrical energy to manufacture the required hydrogen for a complete H2 Cell system” as an alternative. Estimates for “electrical energy generation, building heating with gas and steel manufacture with coal” were also determined.  The analysis found that:

The estimated sum total of extra annual capacity of non-fossil fuel power generation to phase out fossil fuels completely, and maintain the existing industrial ecosystem, at a global scale is 48,939.8 TWh. This builds upon an existing 9,528.7 TWh of non-fossil fuel electrical energy generation annual capacity. If a non-fossil fuel energy mix was used (based on an IEA prediction for 2050, IRENA 2022) was assumed, then this translates into an extra 796,709 new non-fossil fuel power plants will need to be constructed and commissioned. A discussion on the needed size of the stationary power storage buffer to manage intermittent energy supply from wind and solar was conducted. Four calculations of the size of the power buffer were done (6 hours, 48 hours, 28 days and 12 weeks). Pumped hydro, hydrogen, biofuels, battery banks and ammonia were all examined as options in this paper.

Given that Michaux is trying to estimate global energy use it is understandable that there are many simplifying assumptions.  For the intended purpose I do not think any of my observations would change the general results, i.e., I believe the estimates are close enough for results that are the right order of magnitude. My primary interest is the electric sector.  Section 14: Performance of existing fleet of electricity generation power stations estimates the availability and power production in Table 36.  In Table 38 the assumptions and estimated number of power stations needed to replace fossil-fired power stations are listed.  In the following table I combined data from both tables.

I have a few observations about these results.  Michaux had to estimate the energy split between the power systems. Solar thermal is included, which I think is a niche system suitable only for deserts.   Back calculating from the total energy requirement, he estimated the energy needed for each generation type.  The average installed plant capacity was from a reference and used to estimate the power produced by an average plant of each type.  The availability across the year parameter is close enough to capacity factor that they are interchangeable. I think nuclear availability is low. I am sure that wind and solar advocates would argue that the availabilities used are also low.  The result is a conservative estimate of the number of new power plants needed.

I did not see a distinction between onshore and offshore wind in this article, but the second article described below states:

This study projects that 1.3 million wind turbines (each one assumed to be a 6.6 MW (Megawatt capacity) will need to be operational as part of the task to completely phase out fossil fuels. Onshore units will account for 70% of this number, corresponding to 910,000 wind turbines. Offshore units will account for 30%, requiring 390,429 wind turbines.

In my opinion it would have been better to split onshore and offshore wind into two categories because the availabilities will differ.

The analysis also calculates the size of the power buffer needed to back up the predicted generation resources which is a particular interest of mine.  I will postpone a discussion of that for another post.  For the purposes of this article note that the report includes an exhaustive analysis of energy storage requirements and potential technologies to provide the necessary storage.

The first article estimates the energy necessary for the transition which was used in the second article to determine the materials resources needed for the transition.  The article notes that a massive number of new facilities will be required and that a “large wind and solar power systems would need to be internally self-sufficient and need a buffer for stable operation”.  Despite the caveat that the author did not intend to support the status quo reality intervenes.  Michaux notes: “If there are technical issues in storing the needed quantity of power for the needed time period, then it is concluded that wind and solar power generation systems are not practical as the primary energy source for the next industrial era after fossil fuel based technology.”

Quantity of Metals Required

The second article was referenced: 

Michaux, S. P. 2024. Quantity of metals required to manufacture one generation of renewable technology units to phase out fossil fuel. Geological Survey of Finland, Bulletin 416, 173–293, 38 figures, 60 tables and 2 annexes.

The abstract states:

An estimate is presented for the total quantity of raw materials required to manufacture a single generation of renewable technology units (solar panels, wind turbines, etc.) sufficient to replace energy technologies based on combustion of fossil fuels. This estimate was derived by assembling the number of units needed against the estimated metal con- tent for individual battery chemistries, wind turbines, solar panels, and electric vehicles. The majority of the metals needed were to resource the construction of stationary power storage to act as a buffer for wind and solar power generation.

This study uses four stationary power buffer capacities as modelled in a previous study: 6 hours, 48 hours + 10%, 28 days and 12 weeks. This power buffer is assumed to be supplied through the use of large battery banks (in line with strategic policy expectations). Metal quantities were calculated for all four capacities and compared with mining production, mineral reserves, mineral resources, and known under sea resources. It was also assessed whether recycling could deliver this metal quantity by comparing calculations against the sum total mined metal between 1990 and 2023. The quantity of metal mined over the last 34 years was inadequate, which means recycling cannot deliver the needed capacity, and the mining of minerals would have to be the primary source of metals for at least the first generation of non-fossil fuel technology. If a metal has not yet been mined, then that metal cannot be recycled.

There are two highlights in the following: the quantity of metals available is “manifestly inadequate” and technological scaling up issues mean wind and solar “may not be viable as the primary energy source” for the transition:

It was shown that both 2019 global mine production, 2022 global reserve estimates, 2022 mineral resources, and estimates of undersea resources, were manifestly inadequate for meeting projected demand for copper, lithium, nickel, cobalt, graphite, and vanadium. Comprehensive analysis of these calculations suggest that lithium-ion battery chemistry (on its own) is not a viable option for upscaling to meet anticipated global market demand. This then implies that battery banks would not be viable as a power buffer for wind and solar in the quantities needed. As previous work had shown that pumped hydro storage and hydrogen storage face logistical issues in scale up, the belief of strategic policy makers was that battery banks were the solution. As all of these technologies face scale up issues, wind and solar may not be viable as the primary energy source to support the next generation of industrialization.

Consequently, the development of alternative battery chemistries is recommended. The calculated shortfall in copper and nickel production was also of concern, as both metals are vital to the existing economy and there is no known viable substitute or alternative for either commodity. Another alternative would be to develop an entirely new form of electrical power generation that did not need such heavy resource supply in construction or operation.

The calculations in the first article provided the number of generating resources needed provided.  This article determined how many metals would be required for each resource based on those numbers.  For anyone wanting to evaluate material requirements for wind, solar, and battery equipment the analysis provides a lot of documentation.  Also note that Michaux included metals needed for doubling the current nuclear energy capacity, additional hydropower, and more geothermal.

In an analogous process Michaux calculated the number of zero-emission “technology units” needed to replace fossil fuels in industry and transportation.  Electric vehicles are an example of a technology unit.  Fuel cell vehicles are also included.  Table 49 from the article is the sum of all metal from all parts of this study into one quantity by metal (split into the four different power buffer storage capacities).

Source: Published in Geological Survey of Finland Bulletin 416

Conclusion

This is an ambitious analysis that covers the entire global energy system.  As such there are bound to be oversights and limitations as well as interpretative assumptions that could be issues.  In my opinion, however, the approach and assumptions are reasonable and should give a reasonable estimate of the metals needed.  The mass of metals available is another challenge but I think there is better historical data available.  Comparing the metals needed to the metals available leads to the inescapable conclusion that the dreams of replacing fossil fuels will be unable to overcome reality. The Climate Act implementation plan must evaluate the implications of this analysis before we continue down the current path.

My Comments on Draft Blueprint for Consideration of Advanced Nuclear Technologies

On September 4-5, 2024, the Hochul Administration hosted a Future Energy Summit.  After the Summit the State released the draft Advanced Nuclear Technologies Blueprint (Draft Blueprint). This post describes my submittal that explained why I supported the comments presented on behalf of Nuclear New York, New York Energy and Climate Advocates, and Mothers for Nuclear (“NNY comments”).

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 470 articles about New York’s net-zero transition.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% GHG reduction by 2030. Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantified the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation.  The Draft Blueprint is one of the implementation initiatives.

Future Energy Summit

This Summit kicked off the release of the Draft Blueprint.  My thinking about the rationale for the Summit has evolved.  The announcement for the summit said it will “gather feedback on strategies to accelerate renewable energy deployment and explore the potential role of next generation clean energy technologies”.  Initially I thought it was in response to recent reports that reassessment was necessary because of the challenges of a net-zero grid that relies on wind and solar.  I continued to believe that until the Summit even though nuclear technology was emphasized.  My initial impression of the Summit was that the Hochul Administration still has few doubts that a zero-carbon electric grid that relies on wind and solar will work.  I also described the pushback by anti-nuclear activists against the Summit focus on the potential for nuclear power.  I am now convinced that the Hochul Administration is attempting to gauge public opinion on the nuclear option.  The response to the draft Advanced Nuclear Technologies Blueprint will ultimately decide how the Administration proceeds.

My Comments

The announcement requesting comments for the Draft Blueprint said that they wanted to “solicit industry feedback”.  I do not have a background in nuclear technology, so my submittal referenced the comments submitted on behalf of Nuclear New York (NNY), New York Energy and Climate Advocates, and Mothers for Nuclear (NNY comments) that addressed technical issues.  New York Energy and Climate Advocates also submitted a letter with shorter comments.

My comments explained why I supported the NNY comments. Their comments make a persuasive case for the use of advanced nuclear energy in New York’s future.  They clearly document why nuclear has advantages over the proposed wind, solar, and energy storage approach espoused in the Climate Leadership & Community Protection Act Scoping Plan.  The NNY technical comments strengthen the quality of the Draft Blueprint.  Finally, I think the NNY comments addressed the questions posed in the Draft Blueprint very well.

The remainder of my comments support the main point of the NNY comments that nuclear power should be the backbone of the zero-emissions electric grid.  I am an air pollution meteorologist with decades of experience in the electric sector.  I support nuclear power because it addresses an intractable problem with an electric system that relies on wind and solar – weather variability.

There are several proceedings related to the Climate Act implementation that do not acknowledge that the fundamental premise of the authors of the law is fatally flawed.  The authors believed that New York could “rapidly move away from fossil fuels and instead be fueled completely by the power of the wind, the sun, and hydro.” They also believed that “it could be done completely with technologies available at that time (a decade ago) and that it could be cost effective”.  This formed the basis for their belief that implementation of the Climate Act was only a matter of political will.

My comments argue that reality is different, and the time has come to acknowledge that fact.  The Scoping Plan, NYSERDA’s Integration Analysis, New York Independent System Operator (NYISO), and the New York Department of Public Service all have noted that a new category of generating resources called Dispatchable Emissions-Free Resources (DEFR) is necessary to keep the lights on during periods of extended low wind and solar resource availability. 

It is inarguable that DEFR is needed for the future wind, solar, and energy storage dependent electric system.  I believe nuclear power is the only viable DEFR that must be employed if New York is going to proceed without compromising resource adequacy, reliability standards, and affordability for two reasons: technological availability and weather variability risks.  My comments emphasized the value of resolving the problem of weather variability risks.

Technological Availability

The first reason is that DEFR is necessary and using nuclear power for DEFR is the only proven  technology option that can be expanded.  The NNY comments point out that “the availability of fission-based advanced nuclear reactors is a matter of “commercial” readiness, not “technological” readiness.”  All the other candidate technologies that can be expanded as needed are not technologically ready.  Hydrogen was proposed as the placeholder DEFR technology but there are so many physical limitations that I think any feasibility analysis is going to show that relying on hydrogen will never work.  The same problems exist with long-duration storage.

There is one caveat on the use of advanced nuclear for DEFR support.  Resource projections estimate that the DEFR technologies will not run much which makes for a difficult business viability situation for any technology  The NNY comments explain why this calls for a shift in plans:

A more effective system-level architecture will make use of high-capacity-factor “firm” generation like nuclear power not simply as backup, but as part of the backbone of a reliable system serving a sizable portion of total energy demand in a baseload or load-following configuration. Such an arrangement reduces the total amount of generation capacity and support infrastructure needed, thereby reducing land impacts and system-level costs that are ultimately borne by ratepayers and taxpayers. Indeed, this is how upstate New York, which relies largely on baseload hydropower and nuclear, has already achieved a 90% decarbonized grid while maintaining reliable and affordable electricity.

This is an obvious solution, and it addresses my concerns about weather variability.

Weather Variability Risks

The second reason I support the use of advanced nuclear is that there is a huge unacknowledged risk related to an electric system that relies on weather-dependent resources.  All the analyses that showed the need for DEFR determined that there are extended periods with persistently low solar and wind generation that required additional firm zero-carbon resources beyond the contributions of expected zero-emissions resources.  I believe that characterizing these extended periods introduces an unacceptable risk for future electric resource planning.

I am planning to raise this issue as a problem in my responses to several draft documents and the New York Department of Public Service (DPS) staff proposal concerning definitions for key terms (Staff Proposal) in Public Service Law §66-p.  I provided an exhaustive explanation of my concerns in a recent article describing my impression of the Staff Proposal so I will only summarize the concerns here.

I think that the characterization of the gap between renewable resource generation projections and expected load should be based on analysis of historical meteorological data.  Observed meteorological data can be sed to generate the necessary information to estimate wind and solar resource production across New York and elsewhere.  In New York this type of analysis has generated estimates of onshore, offshore, wind, and solar production for a 22-year period for the New York control area.  There is a technique that has been applied elsewhere that enables a similar type of analysis back to 1950.  I believe that the State must invest in a comprehensive analysis of this data for as long a period as possible and for a region that encompasses adjoining electric control areas.

An unresolved problem is what reliability criteria should be used to determine resources necessary for these lulls. If the resource planning process does not provide sufficient backup resources to provide capacity for a peak load period, then reliability issues are inevitable.  Two factors exacerbate the severity of this problem and the importance of the reliability criteria to prevent reliability issues:

  1. The periods of highest load are associated with the hottest and coldest times of the year and frequently correspond to the periods of lowest wind resource availability. 
  2. The decarbonization strategy is to electrify everything possible so the impacts of a peak load blackout during the coldest and hottest periods will be greater.

Today’s resource planning concentrates on one-in-ten-year loss of load reliability criteria.  This period is acceptable because observations of existing generating resources over many years show that unplanned outages do not happen at the same time.  As a result, there is not much variability between ten-year periods.  However, wind and solar resources are strongly correlated.  When the wind is light at one location it is likely that many more locations have light winds.  The most recent New York Independent System Operator (NYISO) analysis found a continuous 36-hour period when 90% of the offshore wind, land-based wind and utility solar resources were unavailable for a 22-year period of record.  My concern is that if the reliability analysis had only evaluated ten years of data, they would have missed the 22-year period described.  If the reliability analysis uses the period of record back to 1950, I am confident that a more severe resource lull would be discovered. 

There are three issues.  Firstly, resource planning for the gap is necessary to ensure adequate resources are available to cover the gap.  Secondly, weather variability means that whatever period of analysis is used there always is a chance that a more severe resource drought will occur.  Finally, the DEFR projected need is large and expensive.  The unaddressed issue is the tradeoff between the planning horizon and the resources needed.  I cannot imagine a business case for the deployment of resources to address for a resource that is needed for a reliability event greater than the expected lifetime of the resource.  Consequently, there will be pressure to choose a less restrictive reliability standard even though that means that when the conditions that cause the worst-case lull inevitably occur there will be major problems.

This risk goes away if nuclear resources are used as the backbone of the future electric system.  Given the magnitude of the potential problems when renewable resources are unable to provide reliable power for the extreme weather case, this is a major reason to rely on nuclear power for a zero-emissions electric grid.  The Staff Proposal presumes that an electric system reliant on wind, solar, and energy storage will somehow work and ignore the reliability risk described here.  My comments argued that DPS staff should address this feasibility issue as soon as possible.

Conclusion

I support the NNY comments because there are fundamental reliability risks of a wind, solar, and energy storage dependent electrical system that can be eliminated by making nuclear the primary source of electrical power.  If New York wants to decarbonize without compromising resource adequacy, reliability standards, and affordability then the only feasible solution is to rely on advanced nuclear power as the primary provider of firm generation capacity and this should be reflected in the Draft Blueprint.  At some point the electric energy experts responsible for the system must tell the politicians that the arbitrary schedule and unproven technologies of a wind, solar, and energy storage zero-emissions approach are too big a risk to reliability to continue down that path.  The Blueprint document should make that case.

DPS Reviewing Progress Towards Achieving the 2040 Target

This is a lengthy post. If you want a condensed version I recommend the article published at Energy Security and Freedom blog by Tom Shepstone.

On November 4, 2024, the New York Department of Public Service (DPS) staff proposal concerning definitions for key terms (Staff Proposal) in Public Service Law §66-p was released. I described my impression of the draft definitions earlier.  The DPS Staff Proposal also included a section titled “Reviewing Progress Towards Achieving the 2040 Target” that is the subject of this post.    

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 470 articles about New York’s net-zero transition.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% GHG reduction by 2030. Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantified the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation.  The DPS Proceeding on “Motion of the Commission to Implement a Large-Scale Renewable Program and a Clean Energy Standard” case number 15-E-0302 is the primary implementation proceeding.  The Staff Proposal was posted as part of that proceeding.

Background

On November 4, 2024, the DPS staff proposal concerning definitions for key terms (Staff Proposal) in Public Service Law §66-p was released.  I described the definitions earlier.  This post coves the provision to review progress. The Introduction of the Staff Proposal explains:

The primary purpose of this proposal is to clarify what is encompassed within the term “statewide electrical demand system” and articulate broad criteria for compliance with a “zero emissions” standard. In addition to proposing definitions – and in light of the proposed definitions’ implications – Staff also recommends that the Commission direct Staff to develop a review process consistent with the provisions of PSL §66-p that tracks progress toward the power sector energy transition targets.

Reviewing Progress Towards Achieving the 2040 Target

The Staff Proposal acknowledges my fundamental concern that there is no real plan for implementation.  The Scoping Plan is an outline of strategies that NYSERDA’s Integration Analysis claims will reduce emissions consistent with the Climate Act mandates but there never has been a feasibility analysis of the strategies.  DPS Staff “believes that it is timely to interpret provisions of PSL §66-p that authorize the Commission to consider impacts of the zero emissions by 2040 target on safe, reliable, and affordable electric service in the state.”  Unfortunately, the Staff Proposal focused on timeliness and short-changed discussion of safe, reliable, and affordable electric service.

The Hochul Administration and all the state agencies involved with the Climate Act transition have ignored the fact that no jurisdiction has demonstrated that an electric system relying on wind, solar, and energy storage is viable.  Francis Menton, Rich Ellenbogen and I have argued that a demonstration project that proves that the proposed transition will work is necessary before implementation proceeds.  This is a fundamental safety, reliability, and affordability constraint that is not addressed in the Staff Proposal.  At the very least, I believe a feasibility analysis should be the next step.

The Staff Proposal addresses the timeliness of the wind, solar, and energy storage deployment but just assumes that an electric system reliant on wind, solar, and energy storage will somehow work:

Pursuing the 2040 target will require the deployment of novel technologies and their integration into a changing grid. Further, as recent experiences with pandemic, supply chain disruptions, inflation, changes to interest rates, the effects of federal policy on domestic manufacturing, and revised expectations about load growth have made plain, progress toward the target will be heavily contingent on pressures beyond New York State’s control. Staff believes the 2040 target must be interpreted and implemented without compromising resource adequacy, reliability standards, and affordability.

I am concerned with the novel technologies mentioned in this paragraph.  The Staff Proposal mentions the December 2023 technical conference hosted by DPS Staff and NYSERDA discussion of potential technologies.  The New York Independent System Operator 2023-2042 System & Resource Outlook (“Outlook”)  Overview in Appendix F – Dispatchable Emission-Free Resources evaluates three Dispatchable Emissions-Free Resource (DEFR) options that they believe represent the most likely viable approach but concede that there still are concerns even with these:

While DEFRs represent a broad range of potential options for future supply resources, two technology pathways being discussed as potential options for commercialization are: 1) utilization of low- or zero-carbon intensity hydrogen (typically generated by electrolysis derived from renewable generation) in new or retrofit combustion turbine or fuel cell applications or 2) advanced small modular nuclear reactors, which are currently seeking approval from the relevant regulatory bodies to design and operate these resources.  Currently, both technologies have shown limited commercial viability on the proof of concept. Even assuming that they are commercially viable, there remains significant work in the implementation and logistics that must be overcome to economically justify transitioning the dispatchable fleet to some combination of new technologies in the next 15 years. Long-duration energy storage could potentially serve in the role of the modeled DEFRs in the Outlook. In many respects, long-duration energy storage closely mimics various hydrogen production and conversion pathways. Long-duration energy storage adds to load in many hours, similar to electrolysis production of hydrogen. However, a notable difference is that electrolysis production of hydrogen has a lower round-trip efficiency when injecting energy into the system compared to other long duration energy storage technologies under development.

Given that none of these technologies are likely to be available consistent with the needs for the Climate Act schedule, it is understandable that the schedule is a concern.  Nonetheless, I am very frustrated that DPS Staff are only paying lip service to resource adequacy, reliability standards, and affordability because there are unaddressed reasons that the wind, solar, and energy storage approach may never work with those constraints.  First and foremost, the only one of the three DEFR technologies described that has no technology issues is nuclear.  There are commercial readiness issues, but the technology has a proven track record.  On the other hand, there are physical limitations that may prevent hydrogen technology or long-duration storage from ever working.  Because a DEFR technology is needed, it is likely that the DEFR solution will be nuclear.  An assessment of resource adequacy, reliability standards, and affordability impacts of a system using nuclear power would likely find that relying on nuclear instead of weather dependent renewables is a better approach.  Compared to wind and solar, nuclear generation produces synchronous power that requires no additional ancillary service support, has a much lower areal footprint, and fewer life-cycle environmental impacts.

Weather Variability Risk

There is another huge advantage of an electric system relying on nuclear power.  The unacknowledged resource variability risks of the wind, solar, and energy storage electric system proposed would be eliminated.  I believe that there is an enormous risk associated with the specification of just how much DEFR is necessary so bear with me as I describe my concern. The Staff Proposal states that:

Comments filed since the December 2023 technical conference have highlighted the importance and analytical challenges of estimating the size of a potential reliability gap. Staff does not endorse a specific estimate of the potential 2040 gap, but it does take the view that the trends on the supply and demand sides of New York State power sector’s make likely a gap that would require at least 10 to 20 GW of clean firm generating capacity to fill. This view is informed in part by the draft analysis, recently published by Staff and NYSERDA, of recent global disruptions and other factors’ delaying effects on large-scale renewables deployment in New York. As for new technologies that could be deployed in the coming years to help New York hit the 2040 target, panelists at the December 2023 technical conference described how several show promise, but panelists and commenters also noted diverse factors that make deployment at the locations and scale required uncertain.

In my opinion, DPS Staff and NYSERDA have not yet to come to grips with the analytical challenges of estimating the size of the potential reliability gap.  I described analyses of the gap in comments submitted on July 3, 2024 in response to comments submitted by Sierra Club and Earthjustice dated June 14, 2024 in the Case No. 15-E-0302 docket.  I explained that all renewable resource projection analyses should use historical meteorological data to provide the basis for projections of future load and estimates of electric resource availability based on projected deployment of wind, solar, energy storage, and other technologies needed to supply the expected load.  Hourly meteorological data across the state produced using current weather forecast modeling techniques yield hourly demand forecasts and wind and solar energy output profiles for the periods being studied.  I believe that the State must invest in a comprehensive analysis of these data for as long a period as possible.

There has been some analysis that shows the extent of the problem.  The NYISO is working with its consultant DNV to assess New York onshore wind, offshore wind, and solar resource availability.  Their analysis uses a 23-year historical meteorological database for the New York State renewable resource areas. Similar analyses are underway in other regional transmission operator regions.  It has also been recognized that larger areas need to be treated similarly.  The Electric Power Research Institute has a Low-Carbon Resources Initiative that has been evaluating resources across the North America.

All these analyses find there are frequent and extensive periods of low renewable resource availability.  For example, the New York State Reliability Council Extreme Weather Working Group (EWWG) analyzed the high resolution NY offshore wind data provided by NYISO and its consultant DNV for offshore wind resources.  The summary of the report stated:

The magnitude, duration, and widespread geographic impacts identified by this preliminary analysis are quite significant and will be compounded by load growth from electrification. This highlights the importance of reliability considerations associated with offshore wind and wind lulls be accounted for in upcoming reliability assessments, retirement studies, and system adequacy reviews to ensure sufficiency of system design to handle the large offshore wind volume expected to become operational in the next five to ten years.

That analysis used a 21-year database.  I think the DPS staff proposal used a shorter weather analysis database that results in the CGPP estimate being “substantially below the 20-40+ GW range estimate published by NYISO in its 2023-2042 System and Resource Outlook”.  The period of record makes a big difference.  I found that in a similar type of analysis, the Independent System Operator of New England (ISO-NE) Operational Impact of Extreme Weather Events, used a database covering 1950 to 2021 to analyze gap impacts.  The analysis found that if the resource adequacy planning for New England had only looked at the last ten years instead of the period of record that they would have underestimated the resources necessary by 5.1% because there was a longer renewable resource drought outside of the last ten years.

Even if the State uses a longer data period there is a major reliability risk that has not been acknowledged.  Current resource assessments are based on observations of existing generating resources over many years that show that unplanned outages do not happen at the same time.  There is no reason to expect, for example, that all the nuclear plants will be forced offline at the same time.  This characteristic enables the resource planners to conservatively determine how much generating capacity is necessary to meet the probability of losing load not more than once in ten years loss of load expectation (LOLE) reliability criterion.  Importantly, I believe that the lack of correlation also means that the capacity needed above firm system load would not change substantially if the LOLE planning horizon was shifted to a longer period.

Variations in weather affecting wind and solar resource availability will require changes to electric resource planning.  Everyone has heard of a hundred-year flood which is the parameter used for watershed planning.  This is the one in a hundred probability that the water level in a river or lake will exceed a certain level in a given year.  Similar probability estimates of low wind and solar resource availability must be developed and incorporated into electric resource planning.

Electric resource planning is complicated by the observation that the meteorological conditions that cause low wind and solar resource availability are so large that they can affect all of New York and adjacent areas at the same time.  This means that wind and solar outages will be widespread, affecting many facilities at the same time.  The unacknowledged issue is that the design of an affordable and practical system to meet the worst-case weather induced lull will always involve a tradeoff between practicality and affordability versus the probabilistic estimate of the worst-case lull.   

An unresolved problem is what approach is acceptable for addressing these lulls.  If the resource planning process does not provide sufficient backup resources to provide capacity for a peak load period, then reliability issues are inevitable.  Two factors exacerbate the severity of this problem and the importance of the reliability criteria:

  1. Periods of highest load are associated with the hottest and coldest times of the year and frequently correspond to the periods of lowest wind resource availability. 
  2. The decarbonization strategy is to electrify everything possible so the impacts of a peak load blackout during the coldest and hottest periods will be greater.

I think that the reliability planning process should use as much historical data as possible to define the worst case.  Consider the ISO-NE analysis where it was found that the most recent 10-year planning lookback period consistent with current LOLE evaluations would plan for a system risk of 8,714 MW.  If the planning horizon covered the period back to 1950, a worst-case situation in 1961 would be considered and an additional 446 MW would be required to meet system risk. 

The unaddressed issue is the tradeoff between the planning horizon and the resources needed.  I cannot imagine a business case for the deployment of 446 MW electric system resources that will only be needed once in 63 years.  For one thing, the life expectancy of these technologies is much less than 63 years.  Even over a shorter horizon such as the last ten years, how will a required facility be able to stay solvent when it runs so rarely?  Any reliability mandate that requires consideration of the worst-case lull over an extended period of record like this example is going to be expensive.  Consequently, there will be pressure to choose a less restrictive reliability standard even though that means that when the conditions that cause the worst-case lull inevitably occur there will be major problems.

This risk goes away if nuclear resources are used as the backbone of the future electric system.  Given the magnitude of the potential problems when renewable resources are unable to provide reliable power for the extreme weather case, this is a major reason to rely on nuclear power for a zero-emissions electric grid.  The Staff Proposal presumes that an electric system reliant on wind, solar, and energy storage will somehow work and ignores the reliability risk described here.  DPS staff should address this feasibility issue as soon as possible.

Ambiguities in PSL §66-p(2)

I have long argued that implementation of the Climate Act has ignored the safety valve provisions in §66-p (4).  That section of the law states: “The commission may temporarily suspend or modify the obligations under such program provided that the commission, after conducting a hearing as provided in section twenty of this chapter, makes a finding that the program impedes the provision of safe and adequate electric service; the program is likely to impair existing obligations and agreements; and/or that there is a significant increase in arrears or service disconnections that the commission determines is related to the program.”  I believe that the zero emissions resource could be a primary driver of concerns related to the reliability and affordability provisions of § 66-p (4) so it is incumbent upon DPS to address these considerations quickly.  The criteria used to define “safe and adequate electric service” and “significant increase in arrears or service disconnections” must be established to meet this provision. 

It is encouraging that DPS Staff recognize that the definition of some of these terms is appropriate.  The Staff Proposal states:

Staff finds that the Commission’s authority under PSL §66-p(2) to design a program to achieve the 2040 target is ambiguous in several respects. In particular, Staff believes that clarification is needed to determine how and when the Commission should “consider and where applicable formulate the program to address impacts of the program on safe and adequate electric service in the state under reasonably foreseeable conditions,” as called for by the legislature.  While this proposal does not examine this issue, Staff finds that continued proactive evaluation and comparative analysis of potential technologies will play a beneficial role in informing the implementation of PSL §66-p(2).

I agree that the Commission should address impacts of the program on safe and adequate electric service.  It is recognition of the need to address the safety valve provisions.  However, acknowledging that there is an issue and claiming that “continued proactive evaluation and comparative analysis of potential technologies will play a beneficial role” fails to adequately address this issue.  The bottom line is that making progress is a moot point when there are no criteria for checking progress relative to safe and adequate service.  New York could be headed down a policy path that does not provide safe and adequate service, but we cannot make that judgement without established criteria.  The Commission should have addressed the concerns raised by the legislature long ago and further delays are unconscionable.

Conclusion

The implementation planning for the zero-emission electric grid of 2040 is inadequate to protect the mandated provisions for “safe and adequate” electric service.  The Commission acknowledges that a new dispatchable and emissions free resource is needed for the projected gap between wind, solar, and energy storage resource production and expected load during periods of extended low renewable resource availability.  However, the Commission has not done a comprehensive analysis to determine the magnitude and duration of the expected gap or the feasibility of potential gap backup resources. 

Staff also recommends that “the Commission direct Staff to develop a review process consistent with the provisions of PSL §66-p that tracks progress toward the power sector energy transition targets. While the Staff Proposal acknowledges that the acceptability criteria for safe and adequate electric service resources must be defined, it does not fully address this issue. These are fundamental planning requirements that remain unresolved 22 months after the completion of the Scoping Plan.  This should be a priority.

I am convinced that the proposed wind, solar, and energy storage approach will not be able to meet any reasonable acceptability criteria.  The longer the delay in developing the criteria and comparing them to the wind, solar, and energy storage strategy, the more investments will be made in an approach that has never worked in any jurisdiction.  There is no reason to expect it to work in New York.  The Hochul Administration must prove it is possible with a feasibility study or better a demonstration project before continuing with this approach.

The Commission acknowledges that a new DEFR technology is needed to provide backup to wind and solar resources during extended periods of low availability.  I believe that nuclear power is the only viable DEFR technology.  However, using nuclear only as backup to wind and solar is inefficient and not cost effective.  Given the inherent advantages of nuclear over wind and solar the obvious conclusion is that we should stop supporting wind and solar and embrace nuclear as the future backbone of the grid.