Category: Climate Act Feasibility

My Comments on the NYPA Draft Strategic Renewables Plan

The 2023-24 Enacted State Budget authorized and directed the New York Power Authority (NYPA) to advance renewable energy and support other state priorities.  Last month NYPA published its Draft Renewables Strategic Plan (Dreft Plan) which describes how NYPA will “operationalize our renewables work, along with our continued and critical obligations to our existing generation, transmission, customer, and community commitments.”  This article describes my comments on the Draft Plan.  I encourage New Yorkers to also submit comments.

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 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.  The Build Public Renewables Act (BPRA) is an legislation example.

Draft Renewables Strategic Plan

The Executive Summary states:

The Power Authority of the State of New York (“NYPA” or the “Power Authority”) is pleased to publish for public comment and hearings its inaugural draft Strategic Plan for developing new renewable energy generation projects to supply New Yorkers with affordable, reliable, and emissions-free electricity.

The main point in my comments is that there is no evidence that renewable energy generation projects can provide affordable and reliable electricity so that presumption must be addressed first.

The 2023-24 Enacted State Budget authorized and directed the Power Authority to engage in the largest expansion of our responsibilities in decades to advance renewable energy and support other state priorities. This expanded authority will enable NYPA to accelerate the development of renewable energy, support workforce training for jobs in the renewable energy sector, and to establish the Renewable Energy Access and Community Help (REACH) program to provide bill credits for low- and moderate-income ratepayers in disadvantaged communities served by New York’s investor-owned utilities.

The Climate Act is a Progressive “Green New Deal”.   Addressing climate change is just a front to achieve other social aims like job creation, economic growth, and environmental justice.

In the time since Governor Kathy Hochul signed the State Budget into law on May 3, 2023, NYPA has made major progress toward the development of new renewables. This progress includes establishing the business structures, filling key personnel roles, and garnering other necessary resources to carry out our new missions, all while advancing the first tranche of projects.

Like any bureaucracy, NYPA’s primary business goal is to get bigger, and this is a golden opportunity for growth.  However, when the costs to comply with the Climate Act goals are totaled, I guarantee that the bureaucratic expenses for these resources will never be included. 

With the opportunity to become a leader in responsible development of new renewables, NYPA aims to expeditiously build affordable projects, staying grounded in our commitment to the communities in which we operate now and, in the future, all while ensuring fair and family-sustaining worker wages.

One of the worst outcomes of the Climate Act implementation has been the destruction of “home rule” whereby local governments have “the ability to craft ordinances and make decisions based on local needs, rather than having to follow a one-size-fits-all state code that’s decided by state legislators.”  State generation permitting rules and transmission siting rules have been modified specifically to enable a faster buildout of renewable energy facilities short circuiting the ability of affected towns to object.  This law adds to that problem because now projects that are not privately feasible will be pushed ahead by NYPA.

We are proud to present this inaugural NYPA Renewables Strategic Plan, which describes how the Power Authority will operationalize our new renewables work, along with our continued and critical obligations to our existing generation, transmission, customer, and community commitments.

My Comments on the plan also raise three points all related to the inanity of politicians thinking they should dictate energy policy.  The overarching problem is the feasibility of a renewables-based electric system was the first concern addressed.  I responded to one of the specific political components in the BPRA the mandate to shut down NYPA’s peaking power plants in New York City.  Finally, state officials have a way of overlooking inconvenient aspects of their programs which I addressed with respect to solar siting.

Feasibility

This has been a recurrent theme at this blog since the beginning but the last few months the necessity of a pause in implementation to determine whether New York should be planning to rely on wind, solar, and energy storage has become clear.  As a result, I have been saying the same thing repeatedly which must bore regular readers.  Bear with me in this section.

The authors of the Climate Act believed that no new technologies are needed to implement their aspirational electric system mandates.  That is wrong.  The experts responsible for electric reliability planning in New York and independent experts capable of refined analyses of the electric grid agree that during periods of extended low wind and solar resource availability a new category of generating resources called Dispatchable Emissions-Free Resources (DEFR) is required.  The problem is that there is no commercially available DEFR technology that can be expanded as needed to support projected wind and solar resources necessary to comply with the 2040 “zero-emissions” mandate.  I maintain a feasibility study to address this requirement is necessary.

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 huge DEFR backup resource and even more massive buildout of wind turbines and solar panels sprawling over the state’s lands and water.  Therefore, it would be prudent to pause renewable development until a proven DEFR technology is proven feasible because nuclear generation may be the only viable path to zero emissions.  That would make any further renewable investments a bad choice.

Peaking Power Plants

The authors of the enabling legislation for the NYPA renewables responsibilities also included a specific mandate for New York City peaking power plants owned by NYPA.  Environmental justice advocates like the Peak Coalition, have convinced state officials that New York City peaking power plants are “perhaps the most egregious energy-related example of what environmental injustice means today.”  The enacting law for the Draft Plan specifically directed NYPA to publish a plan by May 3, 2025, to end generating electricity with fossil fuel at its 11 small natural gas power plant (SNGPP) units located at seven sites in New York City and on Long Island by the end of 2030 if reliability and environmental requirements are met.  I have documented that the presumption of egregious harm is based on selective choice of metrics, poor understanding of air quality health impacts,  and ignorance of air quality trends. In brief, the continued operation of these facilities will have no discernable impact on local neighborhood air quality and shutting them down is solely political virtue-signaling.  On the other hand, these facilities serve specific reliability needs that are not easily replaced. 

Someday, someone in the Hochul Administration is going to have to confront the advocacy organizations and explain that tradeoffs are often required to balance different societal needs.  In this instance it is the tradeoff between the desire for zero pollutant impacts against the need to keep the lights on.  At least in this instance the law does mandate that a feasibility analysis is necessary before the plants get shut down because the law states they can only be shut down “if reliability and environmental requirements are met.”

Solar Development

It is very frustrating to me that New York utility-scale solar development has no requirement to protect prime farmland.  In my draft Scoping Plan  comments I called for a moratorium on solar development because the Hochul Administration has not required solar developers to adhere to all the NYS Department of Agriculture and Markets (NYSDAM) guidelines protecting prime farmland.  As of November 25, 2024, my Solar Project Scorecard shows that  3,414 MW of solar projects have been permitted on project areas of 46,981 acres. These projects will take 7,588 acres of prime farmland out of production.  Of the 21 solar projects permitted only 8 meet the NYSDAM guidelines.  NYPA solar projects should meet the NYSDAM guidelines.

There are two other solar deployment issues that the Draft Plan should address.  The Integration Analysis projections for solar capacity presume that the facilities use tilting axis solar panels to maximize production.  However, the Hochul Administration has not made that a requirement so there are facilities being subsidized that will produce less energy than expected.  This means that the Scoping Plan projections for capacity and costs are underestimated.  NYPA solar projects should use tilting-axis panels.  Finally, a simple constraint to maximize availability when needed the most should be included.  Specifically, subsidizing solar panels that lay flat on rooftops should not be supported by NYPA because they could be covered by snow when temperatures are lowest and loads highest.

Discussion

New York State residents who read this can comment on the Draft Plan until December 8. 

The New York Power Authority welcomes your views on how we can most effectively and equitably build new renewable resources to support the State’s efforts to advance its ambitious renewable energy goals. If you have feedback or comments, please contact us using the form here. 

I suggest that you make the following points:

  • No jurisdiction has successfully built an electric system that relies primarily on wind, solar, and energy storage without fossil fuel backup.
  • The agencies that are responsible for electric system reliability agree that a new resource is required for periods of prolonged poor wind and solar availability.
  • Therefore, an analysis to identify technologies that can maintain current standards of affordability and reliability must be completed before NYPA provides funding to support renewable projects.

Conclusion

In my opinion, experts who understand the electric system agree that the wind, solar, and energy storage system envisioned by the authors of the Climate Act needs a new technology.  I believe experts agree with me that the only feasible DEFR technology is nuclear power and that cannot be deployed fast enough to meet the aspirational schedule of the Climate Act.  There is tremendous pressure for agency experts and responsible organizations to not speak out against the politically correct façade that renewables are the solution for decarbonizing New York’s electric system.  I understand why they do not speak out but it is frustrating.  I only hope that in private conversations with responsible public officials the experts are recommending a feasibility study. 

The more people who say “Please provide evidence that the enormous changes to the existing system proposed in the Climate Act can work” the better.  Climate Act proponents have never provided well-documented cost estimates to reach net-zero from a base case where decarbonization is not considered.  The requirement to develop, test, and deploy sufficient wind, solar, energy storage, and DEFR by 2040 is a tremendous challenge to reliability.  It is also fair to ask for an environmental assessment of the cumulative impacts of all the resources needed for the wind, solar and energy storage system proposed.  All those concerns should be considered against the backdrop that the climate change issue is a global problem and our contributions are negligible.

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.

DPS Definitions for Establishment of a Renewable Energy Program

I believe that the biggest shortcoming of the Hochul Administration’s implementation of the Climate Leadership & Community Protection Act (Climate Act) is the lack of a plan.  For example, in order to implement a transition to meet the mandate that all electricity must be generated by “zero-emissions” resources by 2040 it is necessary to define “zero emissions”.  On November 4, 2024, the Department of Public Service (DPS) staff finally proposed definitions for two key components of the 2040 target.   This post describes my impressions of the definitions.

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 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.

Background

On November 4, 2024, the DPS staff proposal concerning definitions for key terms (Staff Proposal) in Public Service Law §66-p.  The Introduction of the Staff Proposal explains:

In this proposal, the Department of Public Service Staff (Staff) suggests interpretations of key terms in the provisions of the Climate Leadership and Community Protection Act (Climate Act), codified in Section 66-p of the Public Service Law (PSL), which directs the Public Service Commission (Commission) to establish a renewable energy program and design it to achieve particular targets. At issue in this proposal is the language of PSL §66-p(2)(b), which directs the Commission to establish a program pursuant to which, by the year 2040, the “statewide electrical demand system will be zero emissions.” Of particular note, neither of the terms “statewide electrical demand system” nor “zero emissions” are expressly defined in the Climate Act or in the PSL. This lack of statutory definition requires the Commission’s interpretation of these terms to ensure proper regulatory implementation.

The last sentence understates the obvious – it is impossible to implement a plan if we don’t define these terms.  I have highlighted the two terms in the law that are the focus of the definitions, § 66-p, 2:

No later than June thirtieth, two thousand twenty-one, the commission shall establish a program to require that: (a) a minimum of seventy percent of the state wide electric generation secured by jurisdictional load serving entities to meet the electrical energy requirements of all end-use customers in New York state in two thousand thirty shall be generated by renewable energy systems; and (b) that by the year two thousand forty (collectively, the “targets”) the statewide electrical demand system will be zero emissions. In establishing such program, the commission shall 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.  The commission may, in designing the program, modify the obligations of jurisdictional load serving entities and/or the targets upon consideration of the factors described in this subdivision.

Note that the program to implement these mandates has already been established so these definitions have not been addressed thus far.  Also note that there is specific language mandating consideration of the implementation program impacts on “safe and adequate electric service”.  On one hand, they have been working on the implementing programs without defining these key terms and on the other hand, they have a mandate to make sure it works.  I do not think they can protect reliability without a plan that addresses definitions of these terms.

Statewide Electrical Demand System

One of the key definitions describes the statewide electrical demand system.  This is an esoteric concern that is less relevant in my opinion because it is basically just concerns emissions accounting.  The definition problem is that the electricity used in the state comes from sources within the state and imported from other states.  DPS has a good handle on the characteristics of power generated within New York but there is much less information for imported power.  The document does a good job explaining the limitations for New York to impose restrictions on imported electricity based on source type.  DPS Staff basically recommended tracking the emissions and accounting for the different source types. 

There are related concerns with facilities and process emissions.  This boils down to accounting for emissions in specific situations such as those related to co-generation facilities that provide both process energy and generate electricity for on-site use. The Staff Proposal concludes “In sum, Staff reads the legislature’s use of “system” as reflective of an intent to not encompass every power-generating resource in the state, but only those that participate in the operation of the statewide electric grid and do so in a routinized or systematic way.”

In my career I spent a lot of time preparing emission compliance reports.  The accounting issues related to the these definitions make me very glad I will not have to address these problems now that I am retired.

Zero Emissions

The more important definition is for “zero emissions”.  The Staff Proposal states:

The Commission’s interpretation of this term will lay the foundation for decisions about planning, investments, and more in the run-up to 2040. That interpretation must address several issues: whether non-greenhouse gas emissions count; which aspects of a resource’s emissions profile to count; whether and how to count emissions from fuel production processes that arguably occur outside the power sector; whether the emissions attributed to a resource should be counted on a gross basis or on a net basis that recognizes the potential for use of particular feedstocks to reduce or wholly avoid emissions that would occur otherwise; how “zero” should be applied as a threshold; and the significance of the Climate Act’s categorization of a fuel cell that does not consume fossil fuels as a “renewable” resource.

Some of these issues are more important than others.  One of the topics during CAC meetings related to whether non-greenhouse gas emissions count.  Members of the Council who were appointed by Democrats ideologically favored the strict interpretation that zero emissions meant no pollutant emissions whatsoever.  Practically speaking the issue was related to the use of hydrogen which is the recommended zero-emissions fuel technology for hard to convert sectors and the place holder for the new Dispatchable Emissions-Free Resource (DEFR) that the Integration Analysis argues is necessary.  Everyone agrees that compliant hydrogen cannot be produced with fossil fuels, but the question was whether the hydrogen had to be used in fuel cells so that the only emission was water or whether it could be burned to produce energy.

I am sure that the ideologues are having fits over the proposed definition:

Staff recommends that the Commission interpret “zero emissions” to refer to greenhouse gases only and not to emissions of other air pollutants. Several points argue in favor of this interpretation. In New York, “unless a contrary intent is clear, lawmakers employ words as they are commonly or ordinarily employed.” Some commenters argue that no ordinary usage of “zero emissions” can be read to exclude particular pollutants, because ordinary usage would specify which are at issue if the intent was to include only some. But, in this instance, at least three aspects of the Climate Act reflect a contrary intent on the part of the legislature. Those are: (1) the Climate Act’s legislative findings; (2) several of its definitions; and (3) its references to “co-pollutants.” As other commenters note, these point to the same conclusion, namely that the legislature’s primary focus in the Climate Act is on the regulation of greenhouse gas emissions, and that it refers to co-pollutants for specific and discrete purposes that complement the regulation of greenhouse gases.

In my opinion this is a pragmatic decision so I support it.  It will be hard enough and expensive enough to produce hydrogen for the uses proposed without adding to the challenge by insisting that it be used in fuel cells.  While fuel cells are a proven technology for limited applications, trying to deploy them on the scale necessary in this instance would be a problem.

I am not particularly concerned with the other zero emissions issues. 

Conclusion

There are two Climate Act electric sector targets: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040. The DPS has finally defined two terms relevant to those targets in Public Service Law §66-p: statewide electrical demand system and zero emissions. The law mandated that a program be established by 6/30/2021 to meet the targets.  The fact that the terms crucial to the development of an implementation plan were defined 28 months after the program was supposed to be established epitomizes the lack of planning throughout the Hochul Administration’s implementation of the Climate Act.

The definitions themselves are not of particular interest to the public.  The “statewide electrical demand system” definition is an esoteric concern related to emissions accounting.  The practical consequence of the “zero emissions” definition is the pragmatic decision to accept some emissions rather than demanding no emissions for “zero emissions” technologies.  The best example is that this enables the use of technologies that burn hydrogen and emit nitrogen oxides instead of fuel cells that only emit water.

The DPS staff proposal also included a section titled “Reviewing Progress Towards Achieving the 2040 Target” that will be the subject of a future post.  The bottom line for this DPS report is that making progress is a moot point when there is no overall plan.  New York could be headed towards a policy dead-end that could be prevented if a study assessing whether the Scoping Plan outline of strategies is feasible was conducted first.  Given that no jurisdiction anywhere has developed an electric system reliant on wind, solar, and energy storage, a demonstration project would be best.

Navigating the physical realities of the energy transition

This post was also published at Watts Up With That

A recent McKinsey Global Institute report The hard stuff: Navigating the physical realities of the energy transition (McKinsey Report) describes the challenges of the energy transition transformation for those who want a decarbonized society.  This post describes my review of the description of the power sector with respect to my primary concerns for the New York Climate Leadership & Community Leadership Act transition of the electric grid to zero-emissions by 2040.  Those concerns are the need for a dispatchable emissions-free resource (DEFR) and the enormous risk associated with determining how much DEFR must be deployed to prevent blackouts in electric grids that depend on variable renewable energy resources, .i.e., wind and solar.

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 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.

The McKinsey Report describes the realities of the global clean energy transition that proponents claim is necessary to address the existential threat of climate change.  I think the authors did a good job explaining many of the complicated issues associated with the energy transition.  The scope of the report is enormous because they are trying to cover the entire global energy system:

The energy system consists of the production, conversion, delivery, and consumption of energy resources across sectors as both fuels and feedstocks (that is, inputs for the production of different materials).  The system is a massive, interlocking physical entity that has been optimized over centuries. It has served billions of people—if not yet all of humanity—well. But in an era in which countries and companies around the world are aspiring to address climate change, the high emissions resulting from the current energy system are now firmly in focus. The world has duly embarked on a huge transformation, centered on switching from the high-emissions assets and processes on which the system is largely based to new low-emissions solutions.

The summary describes the key points in the report:

  • The energy transition is in its early stages, with about 10 percent of required deployment of low-emissions technologies by 2050 achieved in most areas. Optimized over centuries, today’s energy system has many advantages, but the production and consumption of energy account for more than 85 percent of global carbon dioxide (CO2) emissions. Creating a low-emissions system, even while expanding energy access globally, would require deploying millions of new assets. Progress has occurred in some areas, but thus far has largely been in less difficult use cases.
  • Twenty-five interlinked physical challenges would need to be tackled to advance the transition. They involve developing and deploying new low-emissions technologies, and entirely new supply chains and infrastructure to support them.
  • About half of energy-related CO2 emissions reduction depends on addressing the most demanding physical challenges. Examples are managing power systems with a large share of variable renewables, addressing range and payload challenges in electric trucks, finding alternative heat sources and feedstocks for producing industrial materials, and deploying hydrogen and carbon capture in these and other use cases.
  • The most demanding challenges share three features. First, some use cases lack established low-emissions technologies that can deliver the same performance as high-emissions ones.  Second, the most demanding challenges depend on addressing other difficult ones, calling for a systemic approach. Finally, the sheer scale of the deployment required is tough given constraints and the lack of a track record.
  • Understanding these physical challenges can enable CEOs and policy makers to navigate a successful transition. They can determine where to play offense to capture viable opportunities today, where to anticipate and address bottlenecks, and how best to tackle the most demanding challenges through a blend of innovation and system reconfiguration.

I am only going to consider the power sector and not the other six end-use sectors discussed.  Twenty-five physical challenges are described for these sectors.  Each of the challenges is described relative to the difficulty of the challenge.  This review focuses on the power sector energy transition physical challenges that are shown in the following figure.

Exhibit E1: McKinsey Global Institute The hard stuff: Navigating the physical realities of the energy transition

The description of the power sector physical challenges explains:

Addressing physical challenges in power is fundamental to the entire transition because abating emissions in the huge energy-consuming sectors—mobility, industry, and buildings—requires sweeping electrification under typical decarbonization scenarios. Two difficult challenges arise: managing the variability of renewables such as solar and wind, as they grow their share of total generation; and doing so specifically for emerging power systems that need to grow, often more rapidly and by more than advanced power systems. These two are classified as Level 3 because addressing variability challenges would require the use of novel technologies that have not yet been deployed commercially and face other substantial barriers. Four other challenges, classified as Level 2, relate to constraints on scaling more established technologies, inputs, and infrastructure, where accelerated progress would be needed for the transition.

Quality Review Concerns

The two review concerns for a power sector depend upon weather-dependent resources that I think must be addressed in any assessment of the quality of the report are the need for a new resource to address long-term wind and solar deficits and the challenge of specifying how much of those resources is needed.

In my opinion, all credible analyses of future electric energy systems depending upon wind and solar must acknowledge the need for a new resource to backup up weather dependent resources that New York has named DEFR.  Francis Menton explains that this creates a likely impossible challenge: 

The reason is that the intermittency of wind and solar generators means that they require full back-up from some other source. But the back-up source will by hypothesis be woefully underused and idle most of the time so long as most of the electricity comes from wind and sun. No back-up source can possibly be economical under these conditions, and therefore nobody will develop and deploy such a source.

There is another aspect of DEFRs that needs to be considered.  Menton also did a post on September 28, 2023 that covered a Report then just out from Britain’s Royal Society dealing with issues of long-term energy storage to back up wind and solar generators that concisely describes my other quality concern.  He explains that the Royal Society had collected weather data for Britain for some 37 years and documented that “there are worst-case wind and sun “droughts,” comparable to rain droughts, that may occur only once every 20 years or more.” 

The Royal Society: Large-scale electricity storage, Issued: September 2023 DES6851_1, ISBN: 978-1-78252-666-7

To be a credible analysis of future power sector projected needs, ten both of these concerns need to be considered.  If they are not included, then the complexity will be underestimated and the magnitude of resources required overlooked.

McKinsey Report Analysis of Concerns

For the power sector the McKinsey report addressed six challenges.  I will describe the relevant challenges and mention the challenges that affect the global system but not the New York power sector.

Challenge 1: Managing renewables variability (Level 3):

With the energy transition, Variable Renewable Energy (VRE) sources, such as solar and wind, would be required to grow and reach a relatively high share of total generation. As this happens, the output of power systems would become progressively more variable, exceeding demand on some days but falling substantially short on others. Consider Germany. VRE could potentially account for 90 percent of all power generation by 2050, in the McKinsey 2023 Achieved Commitments scenario. Nonetheless, there could still be about 75 days a year when VRE generation would be insufficient to meet a large share of demand (meaning that at least one-quarter of demand would have to be met by other sources) (Exhibit 6). VRE-heavy power systems would therefore require much more supply-side flexibility. This could come from storage (both power and heat), backup generation capacity (including thermal generation like gas power and beyond), and interconnections. Such flexibility solutions may need to scale by as much as two to seven times faster than overall power demand globally in the next three decades.  However, these forms of flexibility in turn face significant barriers relating, for example, to critical inputs (for some forms of energy storage) and other factors such as market design mechanisms (for backup generation). Most critically, some of the technologies that would be crucial for providing flexibility to the power system over the course of seasons, including novel long-duration energy storage (LDES) and hydrogen-based generation, would need to scale hundreds of times by 2050 from a negligible base today.

The Challenge 1 description emphasizes the need for supply-side flexibility.  Exhibit 6 notes that at least one quarter of the days will require backup resources to resolve VRE intermittency explaining that “novel long-duration energy storage (LDES) and hydrogen-based generation” is needed “over the course of seasons”.  The example resources can be used for DEFR but it does not address my second concern, the worst-case wind and sun drought.  This study appears to only consider average conditions, which is a common flaw in academic assessments.  For electric system resource planners, the emphasis on reliability for all periods mandates that the analysis addresses extreme conditions.    As a result, the magnitude of DEFR support necessary to keep the lights on at all times is underestimated in this analysis.

The second challenge, “scaling emerging power systems”, is also rated as Level 3. The description notes that “Many countries, especially those that are lower-income, need faster and more significant growth in their power systems to increase access to electricity.”  This is not an issue for New York. 

The description of Challenge 3: Flexing power demand (Level 2) notes that “Alongside supply-side flexibility, there may be more opportunity for demand-side flexibility in power as the world electrifies” and does not address either concern. The McKinsey Report claims that this kind of flexibility could provide as much as 25 percent of the total amount needed to accommodate VRE in 2050, in the IEA’s Net Zero scenario.  However, it exposes a weakness in studies that use averages.  Industry planners do not rely on demand-side flexibility because in the worst-case scenarios the capability of those resources is much lower and can be essentially worthless.  This means that studies that only look at averages miss the point that to keep the lights on demand-side resources may not displace as many supply-side resources during the worst-case scenario as they project.  In my opinion, the value of any resource that does not provide firm energy during the worst-case scenario should be downrated.

Challenge 4, “securing land for renewables” is rated as Level 2.  This is a problem for any jurisdiction that tries to rely on VRE because wind and solar resources are diffuse.  This challenge does not address either of my concerns.

Challenge 5: Connecting through grid expansion (Level 2):

With the growth of the power system and the addition of more geographically dispersed energy sources such as VRE, grids would need to become larger and more distributed, interconnected, and resilient. They may need to more than double in size by 2050, growing 40 to 50 percent faster than they are currently. However, lead times for the permitting and construction of transmission lines are long, especially in mature markets such as the EU and the United States, where they have tended to be between five and 15 years. Among other initiatives, accelerating permitting with new streamlined processes could facilitate the expansion of grids.

This challenge does not address either of my concerns.

Challenge 6: Navigating nuclear and other clean firm energy (Level 2):

Increased deployment of clean firm power, such as nuclear, geothermal, and low-emissions thermal plants (for example, hydrogen, biogas, and natural gas with CCUS), could reduce the challenges of variability, land use, and grid expansion. Nuclear is an example of a clean firm technology that is mature and gaining momentum. At COP28, for example, a group of economies announced commitments to triple nuclear capacity by 2050.  Nonetheless, increasing the deployment of nuclear requires managing complex engineering, supply chain, skills, and siting issues as well as safety considerations. In combination, these issues could result in long lead times, frequent delays, and cost overruns. Addressing these would require, for instance, standardizing the design of nuclear plants and building multiple plants using the same designs to leverage shared learning, training workforces in the skills they need, and developing necessary supply chains.

These issues affect the deployment of DEFR but do not address my concerns directly.

Discussion

Although there is useful information in this report, it fails to address my concerns about the need for a new resource to address the specific problem of worst-case wind and solar “droughts” and the related problem of defining just how much of the new resources will be needed to prevent blackouts for the worst of the worst-case periods.

I think the main problem can be traced to the use of averages rather than worst-case conditions for evaluation of resource requirements.  I searched the document for the terms “worst” and “extreme”.  The term “worst” did not appear.  The term “extreme” did show up relative to battery electric vehicle use and heat pumps.  The McKinsey Report noted that special considerations were needed for the worst-case extremes for those applications.  Unfortunately, the authors did not extend that consideration to the power sector.

There is one other consideration unmentioned in the power sector challenges.  Wind and solar resources do not provide the ancillary services necessary to support the transmission system.  The McKinsey Report did note that transmission requirements would be a challenge but overlooked this aspect.

Conclusion

The report concludes that:

The path of the energy transition will not be straightforward, and stark trade-offs and consequences lie ahead. Taking time for the transition to play out, as in many physical transformations of the past, could allow for the physical realities of the transformation to be confronted more gradually with time to innovate and scale new low-emissions technologies, address bottlenecks, and reconfigure the system. While this may make navigating the physical challenges easier, such a path would almost certainly involve compromising on the climate goals that countries and companies across the world have agreed to, with consequences for rising physical risks. However, driving the transition forward without confronting physical realities would most likely compromise the performance of the energy system—and as a result challenge energy access, growth, prosperity, and support for the transition itself.

Alternatively, stakeholders could confront difficult physical challenges head-on—in fact, they could use an understanding of physical realities to guide the way forward to an affordable, reliable, competitive path to net zero. While many open questions remain on what precise path would enable the physical challenges to be addressed, this analysis sheds light on some crucial ingredients that would have to be present in a successful energy transition.

The power sector analysis appears to use averages to project future needs.  As a result, it fails to address my concerns about the need for DEFR and the related risk that improper assessment of the amount of DEFR needed threatens the reliability of the electric system.  The ultimate concern is that the conditions associated with extreme wind and solar droughts are also associated with extreme hot and cold weather when the electrified society will be most vulnerable if there is a blackout.  The report sheds some light on crucial ingredients but overlooks a potential fatal flaw.

Clearly there is no question in the minds of the authors that the transformation to net-zero is necessary. The conclusion talks about trade-offs and consequences but does not acknowledge that there may not be an “affordable, reliable, competitive path to net zero” using VRE.   Given the vulnerability risk, I remain convinced that the VRE transition will do more harm than good in New York and elsewhere.  I think the nuclear option is the only path forward for those who want to decarbonize.

Draft NYISO Reliability Needs Assessment Regulatory Policies Affecting Reliability

It has been a while since I have written about New York Independent System Operator (NYISO) reliability planning process documents.  This post summarizes the section describing regulatory policies affecting reliability in the draft October 2024 draft Reliability Needs Assessment (RNA). 

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 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 rationale for the Climate Act is the existential threat of climate change and the Hochul Administration never misses an opportunity to describe every weather extreme as a more proof.  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. 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.

NYISO Reliability Planning

The NYISO reliability planning process consists of two analyses: the Reliability Needs Assessment (RNA) and Comprehensive Reliability Plan (CRP). The RNA evaluates the adequacy and security of the bulk power transmission facilities over a ten-year planning period, the resources in megawatts (MW), and the locations where required to meet projected needs.  If necessary, the NYISO will request solutions for identified needs.  The CRP determines if the proposed solutions are viable and sufficient then documents the solutions meet the identified reliability needs. 

As part of this continuous process the NYISO has released a “draft for discussion purposes only” of the 2024 RNA on October 4, 2024.  The Regulatory Policies Affecting Reliability section caught my attention, so I wrote this article.

Regulatory Policies Affecting Reliability

A common theme in this blog is the risks to reliable electricity posed by political machinations.  Although the NYISO is technically an independent organization there is tremendous political pressure for the organization to comport with the politically driven narrative of the Hochul Administration.  The section discussing regulatory policies is carefully written so as not to offend the politicians:

Increasingly ambitious environmental and energy policies, evolving market rules, technological advancements, and economic factors impact the decisions by market participants and are accelerating the transition in the state’s resource supply mix. During this transition, the pace of both the addition of new resource additions and the retirement of older, higher-emitting resources are projected to exceed historical levels. Changes to demand patterns and the generation fleet driven by federal, state, and local government regulatory programs may impact the operation and reliability of New York’s bulk power system.

“May impact” operation and reliability is a massive understatement.  Consider the following:

Compliance with federal and state regulatory initiatives and environmental and permitting requirements may require investment by the owners of New York’s existing thermal power plants in order to continue operation. If the owners of those plants must make significant investments to comply, the increased cost to continue operating could lead to the retirement of these resources needed to maintain the reliability of New York’s bulk power system and, therefore, could necessitate replacement.

The document lists eight public policy initiatives that could require investment.  One of the initiatives is the “Peaker Rule:” that targets Nitrogen Oxide (NOx) emission limits for simple cycle and regenerative combustion turbines that provides an example of the challenges.  This initiative should be a model for New York energy policy.  The rule was needed for the state to comply with EPA requirements to reduce NOx to help reduce ozone concentrations.  On the other hand, the simple cycle “peaker” turbines fulfill a critical reliability function.  Recognizing this tradeoff the NY Department of Environmental Conservation (DEC), the generating companies, and NYISO worked out a plan to ensure that the facilities would eventually retire or install control equipment to reduce emissions on a proscribed schedule.  The non-regulated owners of the facilities all determined that the market would not support control equipment investment and submitted plans to retire.  The NYISO determined that temporarily retaining the peaker generators on the Gowanus 2 & 3 and Narrows 1 & 2 barges is necessary to address a reliability requirement, but the others have retired.

Another of the initiatives, “New York Power Authority (NYPA) Small Gas Power Plant Phase Out” is an example of an inappropriate energy planning initiative.  The document describes it as impacting 517 MW nameplate capacity in New York City and Long Island. It requires a plan to phase out production of electricity from fossil fuels, considering clean replacement resources and impacts on emissions and system reliability.  In particular,

NYPA is required to publish a plan by May 2025 to phase out the production of electricity from its seven small natural gas plants (simple-cycle combustion turbines) in New York City and Long Island by December 31, 2030, unless those plants are determined to be necessary for electric system reliability or emergency power service or energy from other sources that may replace energy from NYPA’s small plants would result in more than a de minimis net increase in emissions within a disadvantaged community.

The peaking power plant issue has become a major point of focus of the environmental justice community and proponents managed to convince politicians to include this legislation in the 2023-2024 enacted state budget.  I described many issues with this bogus problem last February.  In short, while there is no question that power plants do affect adjacent neighborhoods, their impacts are all less than the National Ambient Air Quality Standards and the contributions from buildings and transportation sectors are more impactful.  In my opinion, that means that they are not as evil as portrayed,  Furthermore, a DEC Cap and Invest program presentation noted that the power plants had negligible emissions relative to total state-wide emissions.  On the other hand, they fulfill a critical reliability need. 

The draft RNA explains that there are challenges for the replacing these resources:

Balancing the grid throughout this transition not only requires maintaining sufficient capacity to meet demand but also requires that new resources entering service comparably replace the capabilities and attributes of the resources leaving the system (e.g., fast starting/ramping and dispatchable both up and down, available when and for as long as needed, providing essential reliability services such as voltage and frequency control, support system’s stability during disturbances). Continued dialogue and engagement among Market Participants, policymakers, and the NYISO will be essential to support the planning processes in order to identify the needs and services required to maintain a reliable system during and after this transition period.

The NYPA Small Gas Power Plant Phase Out regulation affects modern units that have emission rates far lower than the old units affected by the Peaker Rule.  The environmental justice advocates have the mistaken impression that they can be replaced by battery energy storage powered by wind and solar resources.  This description lays down a marker. The bottom line is that the only resource that can provide the necessary attributes at this time is a fossil-fired generating unit.  Wind, solar, and battery energy storage cannot replace the capabilities and attributes described.

However, given that there have been multiple attempts to permit new replacement fossil-fired generating units to replace the existing peaker units do not underestimate political attempts to deny reality..  The DEC has, under considerable political pressure in my opinion, refused to permit any of these proposed resources citing nothing more than the project being inconsistent with the Climate Act.  Consequently, nothing to replace the old resources has been built.

Conclusion

The “Peaker Rule” promulgation and implementation predated the Climate Act.  It was a common sense approach that provided environmental benefits and protected electric system reliability, Since then reliability concerns have been given short shrift and practical reliability solutions have not been permitted.  The NYPA Small Gas Power Plant Phase Out regulation codifies the irrational New York energy policy approach whereby politicians claim to know better than the electric planner professionals responsible for maintaining a reliable electric system.  Now the NYISO must deal with this legislation that is supposed to shut down existing power plants in favor of a magical resource that does everything needed without any environmental impacts in response to a mostly non-existent problem.  At some point the Hochul Administration is going to have to step up and support the resources necessary to keep the lights on.

The Math Does Not Support New York’s Climate Plan

I frequently collaborate with Richard Ellenbogen regarding issues related to the Climate Leadership & Community Protection Act (Climate Act).  This post describes his recent blog article The Math Does Not Support New York’s Climate Plan published at the Empire Center for Public Policy.  He explains why the numbers show that the Climate Act implementation plan is doomed to failure based on his experience adopting renewable and lower-emission combustion technologies in his home and business.  This post condenses his findings and publicizes his work.

Ellenbogen is the President [BIO] Allied Converters and frequently copies me on emails that address various issues associated with the Climate Act. I have published other articles by Ellenbogen including a description of his keynote address to the Business Council of New York 2023 Renewable Energy Conference Energy titled: “Energy on Demand as the Life Blood of Business and Entrepreneurship in the State -video here:  Why NY State Must Rethink Its Energy Plan and Ten Suggestions to Help Fix the Problems” and another video presentation he developed describing problems with Climate Act implementation.   He comes to the table as an engineer who truly cares about the environment and as an early adopter of renewable technologies going back to the 1990’s at both his home and business two decades ago.

Overview and Background

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.

Introduction

Ellenbogen introduces the problem:

I have been analyzing the numbers coming out of Albany regarding the Climate Leadership and Community Protection Act (CLCPA), New York’s plan to drastically reduce the use of fossil fuels, for over five years now.  

I am not anti-renewable and I am not a climate denier. What I am is an engineer that lives by numbers. The numbers underpinning the CLCPA—namely the belief that New York can replace most of its natural gas-fired electricity generation with renewables in the next six or even nine years—are a fantasy.

  • New York is letting the perfect be the enemy of the good, prohibiting or frustrating viable solutions that could reduce emissions. 
  • Instead, New York is relying on older, less efficient power plants, in hopes that wind and solar—built in more rural areas or offshore—can someday replace them. 
  • Even if New York were to build the wind, solar and battery backup necessary to keep the lights on without fossil fuels, the storage requirements, either onsite or grid-based, would be cost-prohibitive. 

State Comptroller Tom DiNapoli in July described “inadequate planning, monitoring and assessment of risks and challenges” by state energy officials. That’s just the tip of the iceberg. 

Greener Than The Grid

In the next section of the article, Ellenbogen describes his manufacturing business and the steps he has taken to reduce energy use at his facility.  His company, Allied Converters, manufactures food packaging for large bakeries and supermarket chains. The machinery is thermally intensive and uses large amounts of electricity.  

In 2002 he “installed the first microturbine-based Combined Heat and Power (CHP) system in the Con Ed service area.”  This approach generates electricity by burning natural gas.  Waste heat is recovered “to heat the building in the winter, or to be sent to absorption chillers to cool the building in the summer.”  This approach allows him to recover 70 to 75 percent of the energy content of the fuel. 

He compares the factory efficiency to the grid:

Most of downstate’s electricity comes from burning natural gas. New York’s single-cycle gas generating plants are in the neighborhood of 30 to 35 percent efficient. Newer combined-cycle plants are in the range of 55 to 60 percent efficient. For both, about 7 percent of energy produced is lost as heat in the transmission lines, a loss we avoid by generating electricity onsite. 

Contrast that with New York’s plan to replace gas and oil furnaces at homes and businesses with electric heat pumps, which will—at least for the foreseeable future—require more electricity generation from fossil fuels, farther away from where the electricity is needed (and therefore more line losses). 

In 2007 he installed the first commercial-scale solar array in New Rochelle.  His article describes the tribulations related to being an early adopter with the planning agency and the utility.  Later that year he added a “Reactive Power Mitigation System and in conjunction with the onsite generation, reduced load on the utility by 80 percent.  To top it off he collects data on all the electric parameters in the building. 

This massive amount of data, along with my training as an electrical engineer, has formed my frame of reference regarding the CLCPA. Renewable generation has a place in the energy mix but it cannot be used as the backbone of the utility system. Renewables are a tool and when you misuse a tool, bad things will happen. When you need a hammer, you don’t use a screwdriver, but that is essentially what the state is trying to do with renewables.

Energy System Model

His facility is a template for a pragmatic energy system:

The factory is a microcosm of NY’s energy system. It has a fossil fuel-based high efficiency generator to provide baseline load which it supplements with a solar array. The balance of the energy is dispatched by the utility when we need more.

All told, the factory’s carbon footprint is 30 to 40 percent smaller than it would be otherwise.  Additionally, our utility bill, including the cost of natural gas, is less than half of what it would have been if we hadn’t added the energy systems. We have not only reduced our carbon emissions but we have also saved money through reduced energy usage and the associated expenses, about $1 million over the past 17 years. Our savings have been relatively higher during recent years as the business has grown and we have used more energy. Contrast that with current bills for other utility customers that are rising at an increasing rate. 

The New York grid relies on nuclear, fossil, and hydro resources for most of its load, wind and solar to supplement the other resources, and imports the rest.  The grid load varies more than the factory.  As a result, resources are called for varying loads depending on their operating characteristics and costs.  Ellenbogen describes current reliability issues.

The New York Independent System Operator (NYISO), the independent nonprofit organization that operates the electric grid and oversees the state’s wholesale electricity market, has been warning about potential blackouts due to closing existing fossil-fuel generators before new generators come online. 

A 2019 plan by the state Department of Environmental Conservation to close smaller “peaker” power plants risked causing rolling blackouts on hot days as soon as 2025, before NYISO officials pushed back and kept some of the plants open. 

As NYISO officials warned earlier this summer, reliability margins—the cushions in each region that ensure there’s enough electricity to meet demand at all times—“are also observed to be narrowing across the grid in New York, which poses significant challenges for the electric system over the next ten years.” 

The reality is that the issue is going to extend well past 2033 and the energy shortages will get worse as gas plants aren’t replaced. 

Future Model

Ellenbogen describes what would be needed at his factory if he were to rely only on solar and not use natural gas.  Note that wind is not a practical source at his location.

To generate the same amount of electric energy that we currently use, we would need a solar array six times the size of what we currently have. Below is a photo of the 25,000+ square foot roof of the factory with the 50,000 watt (50 KW) solar array on it. (The factory is 55,000 square feet across two floors).    

Ellenbogen,s factory, with its 50 KW rooftop solar array, in New Rochelle, NY

We could fit an additional 50 KW array on our roof for a total of 100 KW. However, we would need a roof three times the size of what we currently have to house a large enough solar array to generate the amount of electrical energy that we currently use. That doesn’t include the heat generated by the CHP system. 

If we switched to heat pumps, we would need at least an additional 300 KW of solar arrays to support the building’s thermal load. So in total we would need 12 times the panels—on a roof six times the size. 

Beyond the enormous additional costs needed to build a system of that magnitude, we don’t have the physical space or the roof area to remotely come close to supporting a system of that size. 

The Model Storage Problem

The Climate Act insists on a zero-emissions mandate so that fossil-fired generators cannot be used to support intermittent wind and solar.  This leads to the enormous challenge of storage.

Because of the looming plight of New York utility system, my team and I have been looking for ways to supply the building during a power failure. We first looked at a backup generator but Con Ed wanted $140,000 to run a larger gas line to our building. That being cost-prohibitive, we have been looking at a new type of energy storage that does not have the deficiencies of lithium-ion batteries. 

The newer storage, using supercapacitors, has a comparable cost to lithium-ion, will last 25 to 40 years instead of the eight to 10 years of lithium-ion, and it will not go into a state of thermal runaway and burn at 2600 degrees Fahrenheit as occasionally happens with lithium-ion batteries. It will fit in a space the size of a sea container and it can be charged at night from our CHP system and on weekends from our solar array. With an energy storage system of 720 to 900 KWh in conjunction with the CHP system and the solar array, we could operate 100 percent free of the utility with a carbon footprint 10 percent lower than what we have now. 

However, the Climate Act prohibits the use of the natural gas fired micro turbine currently in use.  That means more storage would be required.

We would have to install nearly sixty times the amount of energy storage as what we currently need for backup purposes—at sixty times the price–to ensure that the panel’s energy was available at night or for extended periods during the winter months. That storage would occupy a volume approximately equivalent to that of fifty large sea containers—for my factory alone.  

When the example for his factory is considered relative to the State the lunacy of the Scoping Plan becomes clear.

NYSERDA, the state’s energy agency, in late 2022 said “complete replacement” of fossil fuel plants with solar and wind generation would require 2,400 gigawatt-hours of storage to get the state through lulls when wind isn’t blowing and output from solar panels is low. At $567 per kilowatt-hour, the recent average cost of new non-residential energy storage, that works out to more than $1.3 trillion in new costs, or about $68,000 per New Yorker.

Summing Up

Ellenbogen describes his misgivings about the Climate Act.

Unlike New York’s plan that is relying on resources that either don’t exist, don’t exist at scale, are prohibitively expensive to install, are opposed by the residents near the sites, double utility costs, and as a result cannot be installed in any reasonable time frame so that they are not reducing GHG emissions, the technologies that we have used to achieve our carbon reductions are just the opposite. My neighbors are unaware of what we have onsite. The only thing that is visible is the solar array on the roof that can be seen with aerial photos or from a distance from the new high rises that have been built. 

The technologies we used existed 20 years ago, reduce GHG emissions, are cost-effective, reduce line losses, reduce transmission and distribution costs, save money for the end user and the utility simultaneously, and can be implemented now in densely populated areas eliminating the need for multi-billion dollar transmission lines. 

This conclusion wasn’t derived from what I like or don’t like, or about what I want or don’t want, and unlike the Climate Act, it is not based upon emotion. It is based upon tens of millions of data points that definitively say that if NY State keeps proceeding on this path, it will be a calamity for the state. If the Comptroller or others in state government wonder why the Climate Action Council never did a financial analysis of the Climate Act that they forced upon the state, with the assistance of unknowing legislators, it is because the costs are so ridiculously high that if the number was actually publicized, it would be political suicide.