Category: Climate Act Feasibility

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.

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.

An article by Todd Snitchler originally published by RealClearEnergy  and republished at Watts Up With That provides an excellent overview of the issues confronting the electric system today.  It is also a response to clean energy advocates that demand that New York double down on its efforts to meet the Climate Leadership & Community Protection Act (Climate Act) mandates using wind and solar resources.  This post annotates the Snitchler article with comments framing the New York context.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 450 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 reduction target of a 40% GHG reduction by 2030, and two targets that 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 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.

On September 4-5 the Hochul Administration hosted a Future Energy Summit.  I have written several preliminary impression articles about it and plan to do a final summary after the video is posted.  My impression is that Hochul suggested the idea for the Summit, but the primary rationale is not obvious.  Initially I thought it was in response to three recent independent reports that found that there were schedule issues, inadequate cost support and potential reliability risks.  Those findings coupled with a Business Council of New York letter that cited those reports in a plea for a reassessment I thought were compelling reasons for a meeting.

However, the Summit did not address the problems identified.  There were a couple of passing mentions of some of the problems but none of the panelists made any statements contrary to the Administration’s narrative.  However, two sessions were devoted to incorporating nuclear energy in the implementation plan and a draft blueprint for consideration of advanced nuclear technologies was released for comment.  I now think that the purpose was to gauge the political blowback for that option.

In this context, Spectrum News with Susan Arbetter has recently hosted guests (here and here) to discuss the “benefits of nuclear energy, specifically as a dispatchable resource that can fill in the gaps that arise with solar and wind.”  The most recent interview was with Blair Horner from the New York Public Interest Research Group (NYPIRG).  I address his comments in my annotations of the article below.

Has the Electricity Reality Check Arrived?

The author of the article is Todd Snitchler.  He is President and CEO of the Electric Power Supply Association (EPSA).  He introduces the article by noting that dispatchable generation is needed.  For background keep in mind that electric system operators must balance the load with available generation constantly.  That challenge is much easier if they have resources available that can be dispatched, that is to say controlled, as needed. Wind and solar are not dispatchable.

At meetings of energy regulators, policymakers, consumer advocates, and industry this summer, the content and tone of the conversations around electric system reliability have changed dramatically. Executives from across the industry all agree that dispatchable generation is needed now and will be needed for many years to come.

Electric system owners have economic goals that are inordinately affected by politicians.  As a result, they are reticent to say anything that is inconsistent with the current political narrative.  In this case the political narrative is the constant refrain about the need to do something about the “existential” threat of climate change.  Consequently, everyone who knows better that works for the utilities or the state has not been speaking out about the risks of relying on generating resources that cannot be dispatched. However, reality is forcing their hands and suggestions that laws like the Climate Act might not work as touted are coming out.

Most prominently, the realization and willingness to say publicly that dispatchable resources like natural gas-fired generation will be needed as the energy expansion continues and load growth accelerates for the first time in decades is a welcome admission.

For several years the discussion around the future of the electrical grid was about how inexpensive it will be and how “out of political favor” resources would be moved off the grid in favor of politically favored ones without creating any disruptions or reliability challenges. And just like that, the story has changed – dramatically. Why?

Privately all the experts who really understand the electric system admit that the proposed Climate Act transition plan is very unlikely to work and certainly cannot work on the arbitrary schedule mandated by the Climate Act.  On the other hand, advocates like NYPIRG’s Horner cling to the incorrect notion that no new technologies are needed.  That belief underpinned the Climate Act law’s schedule and presumption that meeting the schedule was just a matter of political will.  Snitchler describes three reasons why plans like the Climate Act cannot work as advertised in the real world.

First, load growth – and a substantial amount of it is expected in the short term. The second is the pace of dispatchable generation retirements, without replacement generation with similar performance characteristics. The third is consistent and increasing warnings coming from reliability organizations and grid operators that a crisis is coming and coming quickly if system planning does not improve.

The authors of the Climate Act did not understand how the electric grid operates and the impacts of wind and solar intermittency on the proposed changes to the system.   In the interview with Arbetter at about the 2:00 mark Horner makes the point that the law established a schedule that must be met.  Ignoring all the issues related to the massive shift in resources proposed and all the difficulties associated pandemic impacts to supply chains, he whines that the Hochul Administration is not doing what they are supposed to be doing.  Snitchler’s description of grid operation realities is inconsistent with the Climate Act mandates so the State is in an impossible situation relative to the schedule.

What does this mean? In short, it is a long-awaited recognition of the reality of grid operations combined with the acknowledgment (albeit grudgingly in some circles) that dispatchable resources, like natural gas, will need to be retained and operated for a longer time horizon than many were willing to admit. This recognition matches the significant number of credible studies, including work done by McKinsey and EFI, that all said dispatchable natural gas generation would be needed even in a high renewable resource penetration scenario.

The problem of dispatchability is compounded in New York because natural gas generation is prohibited by the Climate Act.  Instead, the credible plans for the future electric system plan to use a not yet commercially available “Dispatchable Emissions-Free Resource (DEFR)”.  It is long past time that anyone who denies this need should be ignored in the conversation but unfortunately the Hochul Administration has not done anything to confront this problem.

That is not all.  Snitchler describes other issues that have impacted the Climate Act schedule that Horner ignores when he whines that the State is not meeting the schedule:

As the reality of load growth, supply chain issues, permitting, siting, and construction challenges impacting all types of resources settled in and the sharp warnings of imminent reliability issues combined, it became clear that the rhetoric was far ahead of reality. Recognizing the problem is the first step in solving it.

Unfortunately, there is a crisis brewing as the reliability margins shrink.  This summer there were operator alerts for generation emergencies.  Snitchler explains that this is largely due to retirements of fossil-fired generating resources before adequate replacements were available.  He goes on to recommend a solution.

Because all resources are now accountable for reliability, including dispatchable, intermittent, and storage resources, the requirement to acknowledge and adapt to grid realities is no longer optional – it’s mission critical. The retirement of significant amounts of dispatchable resources without adequate replacements has pushed us ever closer to a system with zero margin of error.

To correct this situation, policymakers and regulators should take steps to minimize the risk to customers. First, the timing gap between retirements and additions to the system must be addressed; we can’t let existing resources off the grid before the replacements are ready. The process for connecting new generation to the grid must be reformed to ensure projects match system needs, not just policy pronouncements. Permitting and siting reforms are needed so we can deliver development of all types of energy projects.

I agree with Snitchler that one thing that must be done is to readjust the aspirational targets of energy transition laws like the Climate Act.  I endorse the idea that offramps for reliability is necessary. 

Second, policymakers must temper enthusiasm and set goals that align with the reality of system needs and operational constraints. This could mean pausing policies that hinder the deployment of needed resources or including offramps in legislation to ensure grid reliability.

I do have a concern with his plea for siting reforms and pausing policies that hinder deployment of needed resources.  I do not agree if that approach is used to justify deploying wind and solar faster because I think there is a fundamental issue that has not been addressed.  Analyses of renewable resource availability have identified periods where DEFRs are required.  What has not yet been addressed is the risk that designing an electric system to meet a weather-dependent requirement will inevitably mean that practicality and affordability constraints will lead to a situation where an extreme event exceeds the planning criteria.  That would lead to blackouts.  I do not believe this has received adequate evaluation and discussion.  As a result, I think it is more appropriate to consider reliability constraints before proceeding to build as much solar and wind as possible as fast as possible.

Snitchler raises another practicality issue that is not on the radar of advocates like Horner.  New York policies must be consistent with other states or bad outcomes will result.  In addition, there must be a plan for developing a market signal for DEFRs.  This will be an expensive resource that is not used much raising market viability concerns.

Third, grid operators must move more quickly to adjust markets to send the appropriate signals that will drive investment of the required resources. States must recognize the broader benefits of market participation and positive outcomes for their constituents and stop merely demanding grid operators do what one state wants to the detriment of another. States must again appreciate that the benefits of their utilities joining markets far outweigh their ability to dictate resources and timelines and then disclaim responsibility for the issues those decisions create.

Advocates like Horner are first to accuse market participants of biased motives when there are inconsistencies with their goals.  Everyone wants a better environment and would like to reduce the risks of extreme weather impacts due to climate change.  Snitchler correctly points out that unrealistic goals raise the risk of reliability problems that, in my opinion, are a much worse outcome than effects of climate change that these policies could possibly alter.

To close, lest anyone accuse market participants of not wanting to reduce emissions or only wanting to profit from their current resources, this reality check in no way means walking away from striving to meet policy goals. Bottom line – we can set goals, but they must be tethered to operational reality to ensure success and reliability are both achieved.

Discussion

I think this is a good summary of issues confronting all the electric grid operators in the United States.  The risks in New York are even greater because of the unrealistic Climate Act mandates and the attitude of many that because it is a law the mandates must be met with no acknowledgement that there has never been a feasibility analysis to confirm whether it can be done and how fast it could be done.  It is unfortunate that the Future Energy Summit did not address these concerns.  I believe that a reassessment is overdue.

One of the most important topics for a reassessment is that the need for dispatchable resources destroys the myth that wind, solar, and energy storage are the only technologies needed.  Energy storage can provide some of the necessary dispatchability, but the overwhelming consensus is that new DEFR technology is necessary.  It is time to stop giving Robert Howarth, the self-avowed author the Climate Act, any platform to say “We can meet all of the energy needs of New York with solar, with hydro and wind and appropriate (energy) storage.’’  That statement is wrong and incorrectly influences advocacy groups like NYPIRG.

Conclusion

Snitchler summarizes the reality check issues that need to be confronted nationally and in New York.  If these issues continue to be ignored and unresolved, then the only outcome will be grid reliability problems.  I fear that there are many who will only admit that these problems are real only after there has been a catastrophic blackout.

On August 5 Governor Hochul announced a Future Energy Economy Summit that will “gather feedback on strategies to accelerate renewable energy deployment and explore the potential role of next generation clean energy technologies”.  I described my initial thoughts on the summit and followed up with a second pre-meeting post.  This post describes my initial reaction to the meeting.  I will follow up with another post when the meeting recording is posted.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 450 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% 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 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.

Setting the Stage for the Meeting

As I have noted previously there are many reasons why an assessment of the future energy economy is needed.  Three recent reports top the list.  The Public Service Commission (PSC) Clean Energy Standard Biennial Review Report found that the 70% renewable energy goal will likely not be achieved until at least 2033.  The New York State Comptroller Office Climate Act Goals – Planning, Procurements, and Progress Tracking audit found that the PSC and NYSERDA implementation plans did not comprise all essential components, including “assessing risks to meeting goals and projecting costs.”  The New York Independent System Operator (NYISO) 2023-2042 System & Resource Outlook described issues that threaten reliability and resilience of the current and future electric system. The Department of Public Service Proceeding 15-E-0302 may also be influencing the Governor and precipitating the need for the summit.   The Business Council of New York has cited those reports and gave other reasons why it is needed.  As a result, the governor said the state’s climate goals are something she “would love to meet, but also the cost has gone up so much. I now have to step back and say, ‘What is the cost on the typical New York family?’ Just like I did with congestion pricing.” 

Annotated Agenda

Welcome

• Doreen Harris, President and CEO, New York State Energy Research and Development Authority
  • Reason to meet in Syracuse was because of Micron chip fabrication plant
  • Administration is committed to Climate Act goals but refinements may be necessary

Morning Keynote

• Kathy Hochul, Governor Press Release
  • Reiterated commitment to Climate Act goals because of all the climate events
  • Governor does not know difference between weather and climate
  • She managed to appeal to a wide range of her constituents with specific statements

Fireside Chat: State of Technology

• David Crane, Under Secretary for Infrastructure, U.S. Department of Energy
• Richard Kauffman, Chair, New York State Energy Research and Development Authority
  • I was not impressed with this session
  • Neither speaker has a technical background and it showed
  • Upton Sinclair’s quote is apropos: “It is difficult to get a man to understand something when his salary depends upon his not understanding it.

Accelerating Renewable Energy Deployment in New York State

• Moderator, Georges Sassine, Vice President, Large Scale Renewables, New York State Energy Research and Development Authority
• Laura Beane, President North America, Vestas
• Lori Bird, Director of U.S. Energy Program and Polsky Chair for Renewable Energy, World Resources Institute
• Eric Cohen, Head of Green Economy Banking, JP Morgan Chase
• Frank Macchiarola, Chief Policy Officer, American Clean Power Association
• Jonah Wagner, Senior Advisor to the Director, U.S. Department of Energy Loan Programs Office
  • All of these speakers have a vested interest in the clean energy transition so my notes are sparse
  • I posted a question asking if it was a good idea to build as much renewable energy as possible before the necessary dispatchable emissions-free resource technology is specified.  There was no response to the question.

Status of Next Generation Energy Technologies

• Moderator, Brandon Owens, Vice President, Innovation, New York State Energy Research and Development Authority
• Dr. William Acker, Executive Director, New York Battery and Energy Storage Technology Consortium
• Dr. Monterey Gardiner, Chief Engineer, National Renewable Energy Lab
• Dr. Benjamin Houlton, The Ronald P. Lynch Dean, Cornell College of Agriculture and Life Sciences
• Dr. Jack Lewnard, Program Director, Advanced Research Projects Agency – Energy, U.S. Department of Energy
• Jeffery Preece, Director of Research and Development, Electric Power Research Institute
• Julie Tighe, President, New York League of Conservation Voters
  • One of the significant points made during the Summit is that certain industries are willing to pay more for reliable high-quality electric power. 
  • This broaches the idea that those companies would be willing to make investments in reliable power
  • It also acknowledges that certain industries recognize that a future grid that relies on wind, solar, and energy storage will not be reliable enough

Lunchtime Keynote Speaker Clean Energy Supply for Large Loads

• Rich Powell, Chief Executive Officer, Clean Energy Buyers Association
  • He explained how large companies signal their climate virtue by claiming credits for zero-carbon generation virtually

Insights from Large Consumers of Electricity

• Moderator, Hope Knight, President, CEO, and Commissioner, Empire State Development
• Miranda Ballentine, Senior Advisor, Green Strategies
• Amber Bieg, Lead Senior Program Manager for Global Sustainability, Micron 
• Moshe (Mo) Bonder, Director, Business Development Low Carbon Solutions, National Grid Ventures
• Jennifer Lupo, Vice President, Energy Solutions, Supply Chain & Leasing, The Raymond Corporation
• Dr. Varun Sivaram, Senior Fellow for Energy and Climate, Council on Foreign Relations
  • This session gets into the real reason for the Summit
  • In order to do justice to the commentary I need to review the meeting recording
  • All these companies subscribe to the belief that it is important that the electricity they use be “clean”
  • There was even a suggestion that to be competitive, companies demand clean energy.  My impression was that affordability and reliability were weighed equally with cleanliness.  That does not seem appropriate, so I need to get exact quotes

Global Perspective: Advanced Nuclear Development in Other States and Nations

• Moderator, Rory Christian, Chair, New York State Public Service Commission
• Nicolle Butcher, Chief Operations Officer, Ontario Power Generation
• Steve Chengelis, Senior Director of Future Nuclear, Electric Power Research Institute
• Dr. John Parsons, Deputy Director for Research, MIT Center for Energy and Environmental Policy Research
• Dr. Andrew Whittaker, SUNY Distinguished Professor, University of Buffalo
  • This session addressed the status of nuclear elsewhere
  • Questions were posed and answers debunking common anti-nuclear talking points were included

Blueprint for Consideration of Advanced Nuclear Technologies

• Moderator, John Williams, Executive Vice President of Policy and Regulatory Affairs, New York State Energy Research and Development Authority
• Armond Cohen, Chair, Clean Air Task Force
• Judi Greenwald, Executive Director, Nuclear Innovation Alliance
• Christine King, Director, U.S. Department of Energy’s Gateway for Accelerated Innovation in Nuclear Program
• Greg Lancette, Business Manager, United Association of Plumbers and Steamfitters Local 81
• J. Ryan McMahon II, Onondaga County Executive
• Marc Nichol, Executive Director of New Nuclear, Nuclear Energy Institute
  • In the interest of full disclosure I bailed on this session

Wrap up and Next Steps

• Doreen Harris, President and CEO, New York State Energy Research and Development Authority
• I got into the meeting webinar when I got home in time for this
  • Harris read accolades to her boss’s vision to fight the crisis
• • She said there were three takeaways
• • She doubled down on the need for building renewables and making them the primary energy source
• • She acknowledged that dispatchable emission-free resources were needed
• • She argued that we must not miss the opportunity to leverage federal initiatives to fund New York’s transition.
• • She believes that the clean energy transition will grow a prosperous economy
• • She encouraged everyone to review the draft blueprint for consideration of advanced nuclear technologies
• Discussion

In an earlier post I noted that the State must confront the possibility that the safety valve criteria in New York Public Service Law  § 66-p (4) for unsafe and inadequate electric service, impairment of existing obligations and agreements, and unacceptable increase in arrear or service disconnections will be exceeded.  There was no suggestion whatsoever that the Hochul Administration has any doubts that a zero-carbon electric grid that relies on wind and solar will work.

It seems obvious that there are large consumers of electricity that want to at least be able to say that they use 100% renewable energy. I think this summit was in no small part designed to cater to those companies.  However, there were some hints that high quality electric power was enough of a concern that nuclear might be an acceptable option.

The other reason for this meeting was to broach the nuclear power option to the State.  The draft blueprint is potentially a referendum on its use.  I have no doubts that the anti-nuclear activists are frantically developing their plan to inundate the comment process with negative comments.  The political calculus of weighing the squeaky wheel crowd relative to the reliability of the wagon realists will be interesting.  Will the Administration admit that reliability and resiliency are not just slogans.

Conclusion

I remain convinced that the current Scoping Plan implementation will do more harm than good.  The Energy Summit could have been the start of a correction process that might reduce the inevitable increased risks to reliability, extraordinary price increases, and significant environmental impacts but that does not appear to be the case.  As I said before the Summit is another Macbeth story: “A tale told by an idiot, full of sound and fury, signifying nothing”.