New York Power Trends Report

Recently the New York Independent System Operator (NYISO) released the latest edition of Power Trends 2024.  This is the NYISO’s annual analysis of factors influencing New York State’s power grid and wholesale electricity markets.  This post highlights some of the key points made.

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 400 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 company I have been associated with, these comments are mine alone.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” 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, State agencies and the legislature have been attempting to implement the plans.

Power Trends includes a letter from the NYISO CEO Rich Dewey.  He highlights concerns about the Climate Act and grid:

New York’s public policies are increasingly prioritizing clean energy production and a rapid transition away from fossil fuels. It is imperative that during this time of rapid change we maintain adequate supply necessary to meet growing consumer demand for electricity. Power Trends shows that achieving this balance will be the central industry challenge over the next decade.

The NYISO power assessment information includes: Power Trends Resources is the landing page for documentation, Power Trends 2024 is the report itself, and there is a Power Trends Fact Sheet.  The report notes:

The shift from fossil fuel-based generation to clean energy resources is advancing with a quickening pace. At the same time, consumer demand for electricity is increasing as state policies decarbonize the building and transportation sectors and attract large economic development projects to New York. The successful transition of the electric grid depends on the careful balance of reliable energy supply with the forecasted increase in demand.

NYISO planning must address public policies intended to drive rapid change in the electric system in the state, impacting how electricity is produced, transmitted, and consumed.  There are two Climate Act direct drivers for the electric system.  In addition to the requirement that all electricity generated be “zero-emissions” by 2040 there is a mandate that the electric grid be 70% renewable energy by 2030. 

This article highlights the following challenges raised in the report: status of the system, electrification challenges, Climate Act schedule, the interconnection process, the technology required, and the electric market.

Status

Power Trends included a discussion of the present status of the electric systems.  It concludes that “electricity supplies are adequate to meet expected summer demand under normal conditions, but extreme weather and other factors pose reliability risks.”  In a recent post about the June heatwave I quoted the following from the Summer 2024 reliability outlook:

For summer 2024, the NYISO expects 34,913 MW of resources available to meet 31,541 MW of forecasted demand under normal conditions. Under extreme summer weather conditions, however, forecasted reliability margins could potentially be deficient without reliance on emergency operating procedures. For example, if the state experiences a heatwave with an average daily temperature of 95 degrees lasting three or more days, demand is forecasted to rise to 33,301 MW, while predicted supply levels are reduced to 34,502 MW. When accounting for the required 2,620 MW of operating reserves that must be maintained, this scenario results in a forecasted reliability margin of -1,419 MW. That reliability margin declines further to -3,093 MW under an extreme heatwave with an average daily temperature of 98 degrees. Under these more extreme summer weather conditions, the NYISO forecasts an available supply of 34,317 MW to meet the required 2,620 MW of operating reserve requirements, plus a forecasted demand of 34,790 MW.

The Climate Act strategy to reduce building emissions through electrification will eventually shift the peak loads to winter.  In the meantime, there are potential issues.  The report notes that “On the coldest days, the availability of natural gas for power generation may be limited and significant interruptions to natural gas supply can disrupt reliable operations.”  In addition, electric planners across the country as well as New York are dealing with “evolving challenges and considerations for ensuring power system reliability under extreme winter conditions.” The increased reliance on natural gas is a problem when there is intense cold weather because it stresses gas networks and electricity grids across the nation.  An unintended consequence of the shift from coal to natural gas is the loss of electricity generated by facilities with on-site storage.  Now there is reliance on the gas network and something else that can go wrong.  New York addresses this with dual-fueled units that can burn oil stored on-site.

The last Power Trends status issue is declining reliability margins as illustrated in the following figure.  As noted, this is mostly because fossil units are retiring faster than the zero emissions replacements are coming on-line.  In addition, the New York Department of Environmental Conservation (DEC) is pressuring existing power plants to reduce emissions or shut down and they have rejected several applications to replace existing old generators with modern new facilities because of the Climate Act.  Unfortunately, there is no direct link between the proposed facilities and a particular reliability issue.  As a result, the permit decisions were considered in isolation and the permits were rejected exacerbating the declining reliability margin.

Electrification Control Strategy

The Power Trends report addresses the trend for higher electric loads.  The primary Climate Act emissions reduction strategy is to electrify everything possible using zero-emissions electricity.   In addition, economic development initiatives are driving projected demand higher. The following graphic describes the proposed energy-intensive projects.  Not included is the potential for new data centers needed to power the artificial intelligence applications coming out.

As shown below, the New York statewide grid is projected to become a winter-peaking system in the 2030s, primarily driven by electrification of space heating and transportation.  This means that the focus on future generating sources will have to change.  In particular, the value of solar resources is lower during the shorter days of winter and reduced solar intensity due to lower sun angles.  Moreover, there is the potential for even more reductions if solar panels are covered in snow.

Schedule

The Climate Act was promulgated without consideration of feasibility.  Nowhere is this more impactful than with respect to the schedule.  A rational New York energy plan would implement the zero-emission resources before retiring existing generating resources.  New York is not rational.  Despite the obvious delays in construction of new supply and transmission due to a whole host is issues the Hochul Administration has not broached the possibility of postponing any Climate Act targets.

The Power Trends report includes a description of their reliability planning process.  Four reports are included:

  • Short-Term Assessment of Reliability (STAR): Conducted every quarter to assess reliability needs within a five-year horizon to determine whether the grid will be able to supply enough power to meet demand.
  • Reliability Needs Assessment (RNA): Evaluates the reliability of the New York bulk electric system considering forecasts of peak power demand, planned upgrades to the transmission system, and changes to the generation mix over the next ten years.
  • Comprehensive Reliability Plan (CRP): integrates STAR reports and the most recent RNA, resolves any identified reliability needs and develops a ten-year reliability plan.
  • System and Resource Outlook (Outlook): The Outlook will provide a comprehensive overview of system resources and transmission constraints throughout New York, highlighting opportunities for transmission investment driven by economics and public policy over a 20 year period.

Implementing the resources necessary to meet the Climate Act is not just a matter of building as many zero-emissions resources as possible as soon as possible. These reliability planning reports indirectly affect the implementation schedule.  The process identifies specific issues which triggers a procedure to address them.  All that takes time.  The bigger issue is NYISO’s interconnection process.  Before any generator can be added to the electric grid NYISO has to evaluate its impact.  This process is so important that it was highlighted.

Improving the interconnection process

The Power Trends report notes that “NYISO’s interconnection processes continue to evolve to balance developer flexibility with the need to manage the process to more stringent timeframes.”  NYISO is trying to speed up the turnaround time and make the process more efficient while protecting grid reliability.  The report notes:

Driven by state and federal policies, an unprecedented number of renewable and clean energy projects are entering our interconnection queue. In 2019, there were 275 projects in the queue. Today, more than 500 projects are under consideration. Recent enhancements to our processes, interconnection team, and technology have led to measurable improvements.

There is another complication.  Wind and solar project electric out has different characteristics than fossil-fired units.  The Federal Energy Regulatory Commission’s Order 2023 addresses those differences and NYISO is incorporating that order into their processes.  They hope that “Those reforms will further shorten the total study period while maintaining a focus on system reliability.”

Despite these improvements it takes years from the time a company starts to develop a wind or solar project until it gets online.

DEFR

The Power Trends report describes a major technological issue:

Renewable energy generation, subject to sudden changes in weather, also provides new challenges to grid operators that must balance supply and demand in real time. These variables highlight the need for new generation technologies that can fill in when weather-dependent resources are unavailable. Such new technologies, collectively referred to as Dispatchable Emission Free Resources (DEFRs), must be dispatchable, emissions free, and able to respond quickly to changing grid conditions. Such technologies do not exist yet on a commercial scale.

The NYISO described this resource in the last System and Resource Outlook:

DEFRs are a classification of emission- free resources that provide the reliability attributes of synchronous generation and can be dispatched to provide both energy and capacity over long durations. DEFRs must be developed and added to the system at scale to reliably serve demand when intermittent generation is unavailable. The lead time necessary for research, development, permitting, and construction of DEFR supply will require action well in advance of 2040 if state policy mandates under the CLCPA are to be achieved.

Both descriptions closed with the caveat that these resources do not exist.  I described other DEFR issues raised at a Department of Public Service technical conference last December.  The report statement that research and development are required before permitting and construction can begin underscores the scheduling challenge that this resource entails.

Markets

When the New York electric system was de-regulated the NYISO was formed to operate the electric system.  To transition the electric markets to meet the Climate Act mandates the NYISO must attract necessary investments.  The report explains:

Managing wholesale electric markets is a core responsibility for the NYISO. We are committed to administering and overseeing the competitive electricity markets as the most cost-effective way to attract and retain new resources to meet our reliability needs as we transition to a decarbonized grid.

For 25 years, competitive electricity markets have provided New Yorkers with reliable, least- cost power. Since 2000, the carbon dioxide emissions rate in the power sector decreased by 45%.  Competitive markets produce real-time price signals that allow power suppliers to respond to the grid’s changing needs. With ever-increasing intermittency, extreme weather, and demand from electrification and economic development, the balancing force of markets is essential.

Our market design team is hard at work developing new tools and programs to encourage investment in resources that are fast-ramping, flexible, dispatchable, and emissions-free ― resource characteristics that are becoming increasingly important for grid reliability.

It is not surprising that NYISO places great faith in markets given that they are the reason for its existence.  However, even market advocates must admit that developing the market for DEFR and all the other components of the grid needed for the transition adds another layer of complexity.  It is not only that a new resource has to be developed but now the NYISO has to develop some sort of market mechanism to ensure that it is available when it is needed.  Given the likely high costs for this new technology and the expected low utilization rate that is a serious challenge.

Discussion

The Power Trends report explains that Climate Act mandates on the electric system will drive electric system planning and development efforts through 2040.  It notes that “The successful transition of the electric grid depends on the careful balance of reliable energy supply with the forecasted increase in demand.”  The NYISO reliability planning analyses are based on decades of experience with dispatchable resources.  Balancing demand with weather-dependent resources is an extraordinary test for the Climate Act schedule.

In its review of the status of the system NYISO notes important reliability caveats.  An extended heatwave or limits on natural gas in winter could cause problems today and New York energy policies are reducing options to address those concerns.  New York energy policy eliminated coal-fired generation and environmental requirements have reduced the number of facilities that provide peaking power.  State policy has also restricted the development of more natural gas pipelines that directly contributes to increasing risk for the problems noted.

The report also describes potential scheduling issues but does not explicitly compare the real scheduling issues with the aspirational schedule.  Other NYISO reports have projected that the number of new resources needed to meet the Climate Act mandates is unprecedented.  Despite obvious delays in deployments today for reasons (e.g., supply chain issues, lack of trade personnel, and inflation) that show no sign of abating, the NYISO has not broached the idea that delays should be considered.  This report describes interconnection issues and the requirement for a new resource that must be developed from scratch that exacerbate the problem.

Finally, market mechanisms must be developed to encourage the investments necessary to deploy all these resources.  Despite the optimism of NYISO I suspect that investors are going to be reluctant to jump into the New York market without guarantees.  All that uncertainty adds to potential costs and time to deploy resources.

There is an overarching issue unrecognized by the State and not addressed in this report.  The NYISO resource adequacy planning process is based on decades of experience with independently operating generators.  Probabilistic estimates of their performance are used to evaluate reliability standards.  There is no expectation that many of the facilities will not be available at the same time.  The proposed Climate Act transition to wind and solar resources changes that paradigm.  Weather-dependent resources are highly correlated in space and time, and this is the reason DEFR is needed.  The unresolved issue is that the worst-case wind and solar resource lull is very rare.  Deploying sufficient DEFR to provide adequate resources based on the historical worst-case is likely impractical.  However, if society does not develop those resources, then when those weather conditions inevitably reoccur in the future, there will be a catastrophic blackout.

Conclusion

The Power Trends 2024 report provides an excellent overview of New York State’s power grid and wholesale electricity markets.  Unfortunately, NYISO does not consolidate all the warning signs about Climate Act implementation, nor does it call out state policies that are exacerbating problems.

Ultimately the problem is that New York has no comprehensive energy plan.  The Scoping Plan is just a list of technologies that describe an electric system that is zero-emissions.  However, there is no feasibility study that shows how it will work nor has the Hochul Administration reconciled the differences between the Integration Analysis and NYISO resource outlooks.  As it stands now the apparent Administration plan is to build as many wind and solar facilities as possible and hope someone works out how they are supposed to be integrated into the electric system.  When that does not work, I predict the NYISO will be fall guy.

The only way to ensure the safety of New Yorkers is to do a demonstration project that proves that an electric system that relies on wind and solar will work.  A poor second choice would be a comprehensive feasibility analysis that reconciles the Integration Analysis and NYISO analyses.  Failing to do either is planning to fail.

New York State June 2024 Heat Wave Implications for the Grid

Before last week’s heat wave started my article, Get Out the Popcorn – NYS Heat Wave Might Affect the Grid,  about the potential impact on the New York State grid was published at Watts Up With That.  This post summarizes the implications of the heat wave on the grid.

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 400 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 company I have been associated with, these comments are mine alone.

Power Trends

The New York Independent System Operator (NYISO) recently issued its Power Trends 2024

report which is billed as their “annual analysis of factors influencing New York State’s power grid and wholesale electricity Markets”. In the WUWT post I focused on the NYISO Summer 2024 Reliability Outlook chapter. I highlighted the particular concern for heat waves in the following:

For summer 2024, the NYISO expects 34,913 MW of resources available to meet 31,541 MW of forecasted demand under normal conditions. Under extreme summer weather conditions, however, forecasted reliability margins could potentially be deficient without reliance on emergency operating procedures. For example, if the state experiences a heatwave with an average daily temperature of 95 degrees lasting three or more days, demand is forecasted to rise to 33,301 MW, while predicted supply levels are reduced to 34,502 MW. When accounting for the required 2,620 MW of operating reserves that must be maintained, this scenario results in a forecasted reliability margin of -1,419 MW. That reliability margin declines further to -3,093 MW under an extreme heatwave with an average daily temperature of 98 degrees. Under these more extreme summer weather conditions, the NYISO forecasts an available supply of 34,317 MW to meet the required 2,620 MW of operating reserve requirements, plus a forecasted demand of 34,790 MW.

The intent of the article was to alert readers that the extreme summer weather conditions highlighted by NYISO could occur with the heat wave.

Observations

In brief, the June 2024 heatwave came nowhere near the potential deficit criteria.  Table 1 shows that the average daily temperature did not exceed 84o F over the last four days.  This was not a real stress test for the New York State electric grid.

NYISO Fuel Mix

Even though the heat wave did not push the New York grid the fuel-mix load data from the NYISO Real-Time Dashboard provides some interesting information. I have compiled the data for 17-21 June here.  The following graph shows the hourly fuel type generation throughout the period.  The generator types include “Hydro” that includes pumped storage hydro; “Wind”, land-based wind; “Other Renewables” that covers solar energy, energy storage resources, methane, refuse, or wood; “Other Fossil Fuels” is oil; “Nuclear”; “Natural Gas”; and “Dual Fuel” which are units that burn both natural gas and oil.

The NYISO Summer 2024 Reliability Outlook expects 34,913 MW of resources available to meet 31,541 MW of forecasted demand under normal conditions.  During this period, the maximum hourly generation was 30,525 MW at hour 18 on June 18.  There are important considerations relative to the fuel mix at that time.

The following table lists the fuel mix for generating facilities in New York for June 18.  NYISO does not track behind-the-meter solar that reduces the load that NYISO must provide.  Note that nuclear is constant throughout the day and hydro, dual-fuel, and natural gas increases to match the load peak.

The remaining three categories are of particular interest.  The following graph only includes these three categories because they are small relative to the other fuel types.

In the “Other Renewables” categories the Gold Book lists the following capabilities at the end of 2023:  utility-scale solar energy 254 MW, energy storage resources 20 MW, methane 104 MW, refuse 239 MW, and wood 56 MW for a total of 653 MW.  The graph suggests that solar was providing its peak load during each day.  The methane, refuse, and wood generators are dispatched so that they reduce load at night to a little under 300 MW. 

One of the notable features during this period was that the wind resource consistently was lowest during the daily peak load.  Despite this result New York is continuing to double down on renewable development.  On June 20 the New York State Energy Research & Development Authority announced:

Governor Hochul today announced a new NYSERDA large-scale renewable energy solicitation to deliver clean electricity to New Yorkers. Building on New York’s 10-Point Action Plan , this solicitation seeks proposals for the development of new large-scale land-based renewable energy projects which are expected to spur billions in clean energy investments and create thousands of family-sustaining jobs in the State’s green economy. 

Given that when needed most during the peak load observed here that all the New York land-based wind went to very low levels this solicitation will not solve this problem.  Higher wind capacity with zero wind resource yields zero electricity.

There is another notable feature of the observed wind resources.  The peak winds occurred in the early morning hours which are the lowest load periods.  I believe this is a feature of the nocturnal wind pattern.  Low-level winds affecting wind turbines increase with height as the effect of surface roughness and atmospheric mixing are reduced.  At night the solar surface heating stops and the level of reduced wind speed contracts.  This causes the wind speeds to increase and wind energy resources to improve.  It also is another load balancing issue that must be addressed for an electric grid that depends on wind power generation.

The last of these three categories illustrates another related issue.  The category “Other Fossil Fuels” provides generation for units that are exclusively oil-firing.  In New York there are two types of these units – residual oil-fired steam boilers and simple-cycle peaking turbines.  All the oil-fired boilers must remain at minimum loads higher than the lowest hourly values listed above to be able to ramp up for the diurnal peak.  Therefore, the generation came from simple-cycle peaking turbines.  As I have previously explained, New York City peaking turbines are vilified as “the most egregious energy-related example of what environmental injustice means today.”  However, the presumption of egregious harm is based on selective choice of metrics, poor understanding of air quality health impacts,  and ignorance of air quality trends. I wish I could say that there is no chance that these units will not be shutdown sooner than necessary to mollify Environmental Justice activists who demand it, but I am unconvinced.

Discussion

I am not optimistic that New York State energy policy will be up to the task addressing the future system resources challenge for a zero-emissions electric grid.  One of the issues highlighted by the NYISO Power Trends report is illustrated in the following figure from the Power Trends Fact Sheet.

Overall, the capacity reduction from generator retirements relative to additions is 57%.  However, if you compare the energy capability of the deactivated generators, especially the 2,000 MW of nuclear power retired, with the addition of primarily solar and wind capacity the energy available to the system is even less.

One other recent development is relevant.  The owners of the Danskammer power plant north of New York City have had an application to repower and replace the existing Danskammer generating station with the Danskammer Energy Center, a new state-of-the art, efficient natural gas-fired combined cycle generating unit.  Unfortunately, like a couple of other proposals to replace old fossil generating units with much cleaner and modern units, the New York State Department of Environmental Conservation has denied the permits to construct basically because there are Climate Leadership & Community Protection Act mandates coming.  The fact that there is no feasibility analysis that proves that those mandates can be achieved was ignored.  After years of court battles the developers gave up and withdrew their application this week.  As a result, the electric system will continue to rely on aging and dirtier fossil generation for however long it takes for the State to figure out that existing technology is incapable of replacing fossil fired peaking power plants needed to keep the lights on.

Conclusion

The latest heat wave in New York State did not exceed the criteria determined by the NYISO for potential problems.  Nonetheless, the facts that wind resources were a fraction of potential capacity during the peak hours and the grid relied on peaking power plants that environmental activists demand be shut down as soon as possible suggest that the potential problem is not going to go away anytime soon.  Stay tuned.

Wind and Solar Resource Availability Fatal Flaw

A slightly different version of this article was posted at Watts Up With That.

I have been following issues associated with wind and solar resource availability for many years.  My thinking has evolved to the point where I now believe that in a rational world it would be recognized that any electric grid relying on wind and solar is doomed to failure.  This post explains why.

I am a retired electric utility meteorologist and have taken every opportunity I have had to raise my concerns about wind and solar resource availability in New York regulatory proceedings. I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition. The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The 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 and a requirement that all electricity generated be “zero-emissions” 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.”  In brief, that plan is to electrify everything possible using zero-emissions electricity. 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.  In 2023 the Scoping Plan recommendations were supposed to be implemented through regulation, PSC orders, and legislation.  That process is falling behind as the enormity of the challenge becomes clearer.

Background

The North American Electric Reliability Corporation (NERC) recently convened a webinar for the Cold Weather Preparedness Small Group Advisory Sessions (SGAS) to “provide an educational opportunity for registered entities to meet with NERC and Regional Entity representatives to discuss the cold weather preparedness Standards and possible compliance approaches in an open and non-audit environment.”  The impetus for this initiative was the February 2021 Texas event described in the following slide. The regulatory fallout for this event is not finished but the need to discuss how best to address these events is so acute that SGAS was established in “an open and non-audit environment”.

Source: May 6, 2024 NERC Cold Weather Preparedness Small Group Advisory Session

The takeaway point is that there are already electric grid resource adequacy issues in the existing system during extreme weather events. I am most concerned about the future grid that relies on weather impacted resources. Even though Texas has substantial wind and solar resources their presence did not contribute meaningfully to this Texas blackout. Instead, it was the failure of many components of the traditional generating and transmission systems to be sufficiently hardened to extreme cold. In the future the weather dependent grid will cause similar problems more frequently and, as I will show, may not be able to prevent a catastrophic blackout.

My primary concern is the feasibility for the New York Climate Act implementation plan. or more appropriately the lack of a proper feasibility analysis, that addresses the worst-case wind and solar energy resource drought.  In September 2021, I described the reliability challenges for the Climate Act described by the organizations responsible for electric system reliability.  All the credible analyses done for future grid reliability point out the expected worst-case scenario – When New York electrifies heating and transportation the peak load will be in the winter when temperatures are coldest.  The Integration Analysis identified a multi-day period winter wind lull.  The New York Independent System Operator has done similar analyses and showed that winter wind lulls that coincide with low solar availability and high loads will be the ultimate problem.  The New York Department of Public Service also has identified the Renewable Energy Gap as a major issue.  In my opinion, however, no analysis done to date has identified the worst-case scenario because they have all used relatively short periods of historical data.

All credible renewable resource projection analyses use historical meteorological data, projections of future load during those periods, and estimates of electric resource availability based on assumed deployment of wind, solar, energy storage, and other technologies needed to supply the expected load.  Hourly profiles of weather variables produced via the weather forecast modeling techniques are used to develop hourly demand forecasts and energy output profiles for wind and solar resources for the periods being studied.  The credible analyses only differ in their assumptions for the characteristics of the buildouts and the sophistication of potential availability based on climatological and geographical constraints.  Once the analysis is complete the resulting data can be used to identify the worst case.

The New York Independent System Operator (NYISO) is working with its consultant DNV to develop 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 looking at the North American continent.  Researchers outside of the industry have also done analyses of wind and solar power droughts using the ERA5 reanalysis data from 1950 to the present.  The reanalysis data analysis uses current weather forecast models and historical observations to provide hourly meteorological fields.  These data can be further refined to finer scales to project the wind and solar resource availability.

Results

All these analyses find there are 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.

The NYISO/DNV analysis used a 21-year database.  In a similar type of analysis, the Independent System Operator of New England (ISO-NE) Operational Impact of Extreme Weather Events, the ERA5 data were used to prepare a database covering 1950 to 2021.  The analysis evaluated 1, 5, and 21-day extreme cold and hot events. 

One of the important results presented in the ISO-NE analysis was a table of projected system risk for weather events over the 72-year data record.  In the analysis, system risk was defined as the aggregated unavailable supply plus the exceptional demand during the 21-day event.  Note that the analysis considered sliding windows for the 21-day events by shifting the 21-day window every seven days.  The unsurprising point I want to highlight is that the system risk increases as the lookback period increases.  If the resource adequacy planning for New England only looked at the last ten years, then the system risk would be 8,714 MW, but over the whole period the worst system risk was 9,160 and that represents an resource increase of 5.1%.

Source: ISO-NE Operational Impact of Extreme Weather Events, available here

Note that there was an EWWG analysis of Historical Weather and Climate Extremes for New York performed by Judith Curry and myself that identified the January 1961 event as the probable worst-case scenario.  We found that there was a 15-day period from January 20 until February 3, 1961 that will likely turn out to be the worst-case cold wave. This was a period when high-pressure systems dominated the weather in the Northeast and those conditions mean light wind speeds.

Discussion

I do not think we can ever have an electric grid that will provide reliable power when it is needed the most. Today electric system resource adequacy planners don’t have to worry that many generating resources might not be available at the same time. In a future electric grid that relies on wind and solar the fact that those resources correlate in time and space is what I think is the insurmountable planning problem. All solar goes away at night and wind lulls affect entire regional transmission organization (RTO) areas at the same time. This issue is exacerbated by the fact that the wind lull will cover multiple RTO areas at the same time the highest load is expected.

The reason we can never trust a wind, solar, and energy storage grid is because if we depend on energy-limited resources that are a function of the weather, then a system designed to meet the worst-case is likely impractical. Consider the ISO-NE events where it was found that the most recent 10-year planning lookback period would plan for a system risk of 8,714 MW.  However, if the planning horizon covered the period back to 1961, the worst-case to 1950, an additional 446 MW would be required to meet the system risk.  I cannot imagine a business case for the deployment of energy storage or the magical dispatchable emissions free resource 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 without subsidies and very high payments when they do run.

As I described in an earlier article, the New York Department of Public Service (DPS) Proceeding 15-E-0302 technical conference Zero Emissions by 2040  highlighted concerns about this Gap resource gap and how it could be addressed.  Besides the fact that the preferred candidate technologies have not been commercially proven, they all will be extraordinarily expensive.  I believe that makes worst-case solutions impractical.

On the other hand, the alternative to ignore the worst case is unacceptable.  In the net-zero fantasy world that is supposed to rely on wind and solar when heating and transportation is supposed to be electrified the need for reliable electricity is magnified. If we don’t provide resources for the observed worst case, when those conditions inevitably reoccur then there will be a blackout when electricity is needed the most to keep people from freezing to death in the dark because they are unable to flee.

The tradeoff between practicality and necessity is not going to be resolved by the resource adequacy planning groups doing the analyses described.  I don’t think organizations like the New York State Reliability Council or NERC will make the decisions either.  This is something that will have to be decided by politicians at the highest levels.  Hopefully the problem will be considered in an open and transparent manner, but political lobbying pressures will be immense because the viability of the politically correct current plan to depend on wind and solar in New York and elsewhere is threatened.

Conclusion

I have long argued that New York should perform a feasibility study to determine if the net-zero outline to comply with the Climate Act in the Scoping Plan could possibly work.  Francis Menton has convinced me that it would be better to do a demonstration project in some smaller jurisdiction to prove that it can work.   The described tradeoff between the practicality of deploying resources for the observed worst-case resource deficit and the necessity to do so to prevent a catastrophic blackout should be a key consideration in either workability evaluation.

In my opinion any electric system that depends on wind and solar is impractical.  Obviously, if the goal is a zero-emissions electric system then nuclear must be the cornerstone.  If affordability is a concern, then the pragmatic acceptance of a large reduction in emissions rather than a zero target would allow the use of some natural gas as proposed by Russell Schussler and myself last year.  Given the entrenched crony capitalists and special interests supporting wind and solar any shift in direction, even if necessary to protect health and safety, will be a tremendous lift.

Status Update on New York Wind and Solar Capacity Factors

Last year I published an article describing the New York Independent System Operator (NYISO) Load & Capacity Data Report (also known as the “Gold Book”) and how I used it.  This post uses the latest edition to determine the wind and solar capacity factors last year.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition. The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The 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 and a requirement that all electricity generated be “zero-emissions” 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.”  In brief, that plan is to electrify everything possible using zero-emissions electricity. 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.  In 2023 the Scoping Plan recommendations were supposed to be implemented through regulation, PSC orders, and legislation.  That process is falling behind as the enormity of the challenge becomes clearer.

Capacity Factor

The capacity factor is a useful metric to understand electric generation resources.  The annual capacity factor for a generator equals the actual observed generation (MWh) divided by maximum possible generation (capacity in MW times the hours in a year).  Projections for the amount of future wind and solar generation capacity needed for the Climate Act depend on capacity factor assumptions.

Not surprisingly, the aspirational schedule of the Climate Act has proven to be more difficult to implement than planned and many aspects of the transition are falling behind.  Worse, there has not been any indication that the Scoping Plan is being refined to incorporate the lessons learned in the years since it was drafted or address any of the issues u raised in the comments.  The capacity factor assumptions are a prime example of an issue that needs to be addressed.

Wind and Solar Capacity Factor Projections

I have previously summarized future resource projections. The New York Independent System Operator (NYISO) 2021-2040 System & Resource Outlook is part of the NYISO Comprehensive System Planning Process.  That analysis included several scenarios for the future grid that includes capacity factor projections.  The Integration Analysis also included several scenarios and capacity factor projections.  In both instances the capacity factor projections determine how much wind and solar capacity will be needed in the future.

I am not the only one who submitted comments about the Scoping Plan capacity factors.  I pointed out that the Integration Analysis land-based wind capacity factors were unrealistically high.  The model projected the 2020 generation with a capacity factor of 29% but the 2021 observed capacity factor was only 22%.  The Integration Analysis model could not even get the starting year correct.  As a result, the Integration Analysis projections for the land-based wind capacity needed to meet the load are too low.  It is particularly disturbing that the State has never attempted to reconcile the NYISO projections and assumptions with the Integration Analysis.  For all renewable resources the Integration Analysis capacity factors are higher than the NYISO projections as shown below.

2023 Wind and Solar Observed Capacity Factors

The New York Independent System Operator (NYISO) 2024 Load & Capacity Data Report (also known as the “Gold Book”) is now available and has been posted on the NYISO website: 2024 Load & Capacity Data Report (Gold Book).  Many of the most useful tables are also provided as spreadsheets.  The following supplemental materials have also been posted:

The Existing Generating Facilities spreadsheet was used to calculate New York capacity factors.  The first table sums the capacities and net energy for all the combinations of primary fuel type and secondary fuel type for all the generators tracked by the NYISO.  This includes units that are in the market system as well as others that are not.  The nameplate capacity of generating units that use natural gas and can also burn number 2 fuel oil is the largest category in the state.

2024 NYISO Gold Book Tables III – 2a NYISO Market Generators and Table III – 2b Non-Market Generators 2023 Capacity, Energy, and Capacity Factors

The next table lists the capacity data and net energy produced for the wind generating units in New York.  Using that data, it is possible to calculate the capacity factors for each facility.  The NYISO Resource Outlook and the Integration Analysis both assume a 34% capacity factor in 2030.  Only two wind farms exceeded 34% and there were only three more that were over 30% capacity of the 31 wind farms in New York.  The overall capacity factor was 21.8%.  In order to achieve the assumed capacity factor for 2030 most of the existing wind farms will have to be replaced.  The Integration Analysis does not retire any of the existing wind farms which I suspect is so that the cost estimate does not have to include those costs.

I have been tracking the wind farm capacity factors since 2006 as shown in the next table.  There is nothing to suggest that 2023 was an abnormal year.  In order to meet the 2030 projections these wind farms are going to have to be replaced or a large number of wind farms with much higher capacity factors that will bring the average up will have to be built.  The data shown are also interesting as they show large interannual variation by site and the state overall.  Finally note that the NYISO wind capacity factor for 2019 was modeled as 25% but the observed capacity factor was  22.3%.  The Integration Analysis did not get their first year correct either.  It modeled the 2020 capacity factor as 29% but the observed capacity factor was only 23.9%.

New York State Wind Facility Capacity Factors Based on NYISO “Gold Book” Load & Capacity Data Reports Table III-1

There is much less historical information available for solar facilities so only the 2023 data are presented.  In 2023 the capacity factor of the solar facilities in New York was 16.8%, the highest capacity factor was 21.7% and the lowest credible capacity factor was 14.9%. The NYISO assumed a capacity factor of 15% from 2019  to 2040.  On the other hand, the Integration Analysis assumed a capacity factor of 17% in 2020 increasing to 20% by 2030. 

Discussion

The NYISO has interesting generation resource information available in its Gold Book.  As shown here, that information can be used to calculate the capacity factors for wind and solar resources in New York.  The annual capacity factors observed are consistently lower than the values used in the Integration Analysis which is being used to implement the state plan to meet the Climate Act mandates.  As a result, The Scoping Plan is underpredicting the wind and solar resources necessary to generate the energy they project will be needed. That also means that their cost projections are too low.

It is troubling that the differences shown here between the NYISO capacity factors and the Integration Analysis capacity factors have not been reconciled.  Worse, none of the differences between the two sets of projected resource projections have been addressed.  This matters not only because the differences affect the projected outcomes and the costs, but also because Integration Analysis projections are being used for the New York Cap-and-Invest (NYCI) Program proposal.  A key component of the NYCI plan is the trajectory for allowance allocations.  NYCI’s reduction trajectory is based on the Integration Analysis and the overly optimistic capacity factors used means that they are projecting lower emissions than is likely to occur.  That imbalance could have significant consequences to the allowance market.

One other point is that these are annual metrics.  In order to assure that the electric grid will be able to provide energy when it is needed the most the NYISO must deal with resource availability over shorter periods.  Think of it as the capacity factor over the coldest week of the year.  That is a much more difficult issue and one that the Scoping Plan has not addressed.

Conclusion

This post documents the most recent wind and solar capacity factors observed in New York.  It is notable that the wind data show a lot of interannual variation that should be considered when projecting future resource availability.  These data have not been incorporated into an updated analysis of the generating resources needed to achieve the Climate Act goals. 

I have long argued that the State’s plans for implementing the Climate Act mandates must include a feasibility study that could address the observed variability and lower capacity factors.  Given the tremendous uncertainties like these shown here, I have recently decided that a feasibility study is not enough.  No jurisdiction anywhere has successfully demonstrated an electric grid that depends on wind and solar to the extent that the Scoping Plan does.  Before New York goes any further it should prove it can be done with a demonstration project.  Anything less risks catastrophic blackouts and enormous costs.

Grid Planning to Meet Climate Act Goals Documentation

Note:  This documents all the slides in the Grid Planning to Meet Climate Act Goal presentation.  I also prepared a summary of the material in this post.

In order to meet the Climate Leadership & Community Protection Act (Climate Act) mandates for a zero-emissions electric grid by 2040 a massive effort to deploy wind, solar, and energy storage resources and an enormous upgrade to the electric transmission system is needed.  I have previously described issues associated with generating portion of this transition.  This post documents the Alliance for Clean Energy New York (ACENY) webinar “Grid Planning to Meet Climate Act Goals” that addressed the transmission challenges in a lot of detail.  A summary is also available.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition. The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The 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 and a requirement that all electricity generated be “zero-emissions” 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.”  In brief, that plan is to electrify everything possible using zero-emissions electricity. 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.  In 2023 the Scoping Plan recommendations were supposed to be implemented through regulation, PSC orders, and legislation.  Not surprisingly, the aspirational schedule of the Climate Act has proven to be more difficult to implement than planned and many aspects of the transition are falling behind. 

ACENY Webinar

On April 11, 2024, Alliance for Clean Energy New York (ACENY) hosted a webinar entitled “Grid Planning to Meet Climate Act Goals” that was recorded on a video.  The webinar was moderated by Chris Casey, from the NRDC and featured speakers from the Department of Public Service (DPS), New York Independent System Operator (NYISO), and National Grid.  This article describes each speakers presentation and provides links to sections of the video so that readers can follow the presentations.

Chris Casey, a lawyer from the NRDC opened the webinar with an overview. It was not surprising that his Chris Casey, a lawyer from the NRDC opened the webinar with an overview. It was not surprising that his introduction ticked all the boxes.  New York is on the “forefront of the transition to address the “impacts of destructive climate change”, increase access to “affordable” renewable energy, bolster “resilience against life-threatening extreme energy events”, all while “creating jobs and delivering substantial economic benefits”.  Behind the rhetoric, however, reality lurks, and it does not look so grand.  In the following sections I include slides and links to the section of the video that discusses the slide.

DPS Presentation

Elizabeth Grisaru (Senior Policy Advisor) from the DPS made the first presentation “Planning for Future Electric System Needs”.  One of her main job responsibilities is transmission planning associated with the Climate Act transition.  During her introduction she included a slide that illustrates the connections between generators and customers that were the focus of the webinar.

The “Impact of Climate Objectives” slide describes the general issues associated with the transition.

The description of the slide “PSC Initiatives since 2020” outlined projects costing over $6 billion that are over and above what is needed to keep the system running.  The investments are for both Climate Act needs and reliability issues.  What was not included was the breakdown between the two needs or any estimate of how much more will be needed.  It is clear that many more investments will be required.

The transition to an electric system that depends upon diffuse wind and solar requires a significant upgrade to the transmission system.  The PSC has a new “Coordinated Grid Planning Process” to address this issue. 

Note, however, that the first of the new CGPP reports is not going to be available until the Fall of 2025.  It is not clear if the CGPP is going to help at all to meet the 2030 target.

The DPS final slide addresses outstanding issues.  On one hand existing sources of generation are being forced to retire while on the other hand electrification initiatives are increasing loads.  She claimed that at the PSC “We all agree reliability is the most important thing we have to worry about”.

NYISO Presentation

NYISO Director of System Planning Yachi Lin talked about their plans to implement a clean and reliable grid.  Her introductory explanation gave a good overview of the NYISO.  The following slide describes the planning process.  There is a two-year cycle of reliability planning that includes quarterly checks on the status of the system. 

The following slide describes the generation system and the investments expected to be needed.  Existing generating capacity is 37.4 GW, but an additional 20 GW must be in service in seven years to meet the 2030 goal.  The unanswered question was whether this is feasible.

Lin explained that additional transmission is needed to meet the 2030 70% renewable energy goal.  The following slide shows different areas of the state that do not have adequate transmission capabilities to prevent curtailments.

To respond to the need for additional transmission the NYISO planning process is supporting “unprecedented expansion”.

The quarterly Short-Term Assessment of Reliability (STAR) reports should be required reading for anyone interested in the New York electric system so Lin’s explanation is important.  The following slide notes that last years second quarter report noted that there was a reliability deficit of 446 MW in the summer of 2025.  The deficit was projected because of fossil unit deactivations.  In response, NYISO opened a solicitation for market solutions or regulatory solutions.  No feasible market solution was submitted. 

To maintain reliability, NYISO had to resort to a regulatory solution.  They designated two peaking generation plants as reliability needs and postponed their retirement for two years.  The NY Department of Environmental Conservation “Peaker Rule” incorporates this provision and there is a potential for an additional two-year extension. If the Champlain Hudson Power Express transmission project is delayed beyond 2026 the additional extension might be required.

The Comprehensive Reliability Planning report incorporates changes associated with demand growth. In the following slide NYISO describes expected changes.  As mentioned previously, fossil generator retirements and growth in demand are primary changes to the system.  Part of the load demand shift changes the peak loads from summer to winter.  This is troublesome because the winter diurnal peak will occur when there is no solar.  She also mentioned the dual-fuel units.  Many New York generating units normally burn natural gas because it is cheaper but have the capability to switch to oil firing when natural gas is needed by residential consumers.  The increased reliance on these units which at the same time are targeted for retirement is a problem.  The CRP analysis also identified added risks.  The addition of the Micron chip fab plant near Syracuse will add load equivalent to the total load of Vermont and New Hampshire.  The New York Power Authority operates small natural gas plants in New York City that are supposed to be phased out by December 2030 due to political pressure.  Lin had to make the obligatory gesture to climate change extreme weather as a risk.  Finally, the shift to a weather-dependent generating system mans that reliability design criteria need to be revised to account for extreme weather conditions outside current planning horizons.

The next four slides summarize the challenges to meet the 2040 Climate Act mandate for a “zero-emissions” electric grid.  The next slide repeats the points raised in the previous slide.  Lin remarked that the year of the cross over from summer to winter peaking can only be guessed at this time.  Depending on the trends in load it could be almost anytime in the next decade.  The 90/10 and 99/1 forecasts are probability estimates for the likelihood of extreme weather events.  The final bullet in the slide points out that there could be substantial load growth needed to provide reliability services.  The NYISO includes a high load policy case that incorporates this load.

The next slide lists the challenges on the generation side.  Lin makes the point that generation issues extend beyond simply evaluating the capacity needed to match the load projections.  Wind, solar, and energy storage are inverter-based resources that require ancillary service support to make the transmissions system reliable.  Weak-grid interconnection and common mode failures are issues that most people, including me, do not understand well.  The key point is that all the people that I know understand these issues are worried but there was never any indication of concern by the Climate Action Council.  Consequently, the Scoping Plan outline produced by the Hochul Administration to guide the energy transition is incomplete.  Lin makes the little recognized point that the Dispatchable Emissions Free Resources are not needed just for the long periods of low renewable resource availability but also to provide these ancillary services.

The next slide addresses DEFR specifically. I will not discuss this much because I covered the Department of Public Service (DPS) two-day technical conference last December that focused on characterization of the potential “gap” caused by low renewable energy resource availability over long periods of time.  I mentioned but did not emphasize the importance of providing the “reliability attributes of retired synchronous generation”.

The focus of this webinar was on the transmission challenges as covered in the following slide.  Lin explained that transmission expansion is required to get the diffuse wind and solar energy from where it is collected to where it is needed.  The existing system is not adequate for this task.

In the next slide Lin explained how the NYISO is working with the PSC to identify the needed bulk and local transmission needed. 

The final slide in Lin’s presentation presented the planning process expected progress.  There is an enormous amount of work underway but the analysts have a big challenge dealing with changes in the development of resources.  As noted earlier, the 2026 expectation is that the Champlain Hudson Power Express project will be online.  Even after years of development work the right of way is still not fully permitted and there are numerous examples of supply chain issues delaying other projects so the planning process is subject to massive uncertainty.

National Grid Presentation

Brad Franey Vice President Clean Energy Development explained how National Grid is addressing the need for transmission support.  As he points out the utilities receive funding for their transmission and distribution (T&D) system investments from rate cases.  Those rate cases are, in no small part, influenced by politics.    As a result, none of New York’s utility companies are going to overtly challenge the political narrative that the Climate Act objectives can be achieved on schedules mandated by the law.  The following slide probably went through multiple iterations to achieve a description of plans that checks all the boxes for what the company thinks that the politicians want to hear. 

I live in Upstate New York so I was particularly interested in the “Upstate Upgrade” described in the following slide.  The following slide rationalizes the costs for the upgrades to over 1,000 miles of lines.  In his description Franey gave the example of a town that attracts snow mobile tourists in the winter.  The last two years there have been snow droughts because they “no longer have the snow like they used to.” Construction of a line nearby brought in a lot of business and locals said that those saved businesses.  The entire slide is devoted to the mantra that the Climate Act will create jobs and investments.  Last year I described the DPS rulemaking that foisted these projects on the Upstate ratepayers.  This slide avoids the things I found: National Grid residential ratepayers will see their bills increase 3.8%, the fact that these upgrades are needed to get renewable energy to Downstate so don’t benefit the ratepayers directly, or that the percentage increase for upstate ratepayers will be greater than the increase for ratepayers who directly benefit from the investments. 

The next slide gives an example of their proposed reliability solutions. He included the obligatory argument that we are seeing more “frequent storms” that ignores the differences between weather and climate.  He went on to give examples where a reduction in outages would positively impact their community.  The proposed solution is a microgrid with battery energy storage.  In my opinion, however, this is another example of a clean energy solution that works well most of the time but will fail when needed most.  The problem here is the specification for battery storage.  In the future New York system when home heating and transportation are both electrified the worst case will be an extended outage due to an extreme weather event like an ice storm.  Specifying the battery storage for an ice storm event that occurs every 20 years will probably be too costly but when the inevitable ice storm does occur everyone in the microgrid will be at extreme risk because the energy storage system will run out of power.  Fossil fuels are energy dense and can be stored making them much better for emergency backup.

Another initiative that National Grid is starting to support is public charging.  Again ratepayers get to pick up the tab for something that most will not use and don’t ever want to use.  Their analysis indicates that the load at the service plazas along the thruway could go up to 20 to 40 MW which is the same load as “a small town or major sports stadium.”  In order to provide that load they need to upgrade the local infrastructure.  They are planning to use mobile energy storage along the Thruway until infrastructure is developed.  This bridge to wires solution is a pragmatic approach given the likely futility of heavy duty electric trucks.

The latest rate case included funding for smart meters.  Franey describes this initiative in the next slide.  Ostensibly this is supposed to help consumers better understand their energy use and facilitate outage response but the ability to try to reduce peak loads either through rate mechanisms or eventually managing electric use are certainly on the table.

Questions and Answers

The question and answer portion of the webinar was interesting.   The first question asked was “Is reliability a prerequisite for everything else or is it co-equal with our policy objectives?”  I have heard suggestions that policy objectives should be considered more than they are currently but anyone hoping to hear that there have been changes to protections in place to make sure that our policies don’t get ahead of reliability would have been disappointed in the answers.  Elizabeth Grisaru from the DPS made it clear that reliability comes first, that there are “off ramps” for the implementation schedule and that the PSC will not let our zeal for meeting de-carbonization goals get out in front of reliability.  Yachi Lin from the NYISO emphasized the point that they are constantly evaluating reliability.  The quarterly Short term assessment of reliability and the longer term reliability needs assessment both address it.  She admitted that we are going to have outages because the network is not built to be 100% risk-free or outage free.  The alternative it “gold plating the system” which we cannot afford. 

The next question asked about interconnections when the grid is not ready to take new renewables.  How does that come into play and how will this be alleviated?  Grisaru from the DPS acknowledged that if the system is not ready then developer has to pay for interconnection upgrades.  They are trying to address this but it takes time. Franey from National Grid said that they are working on the issue but reliability has to be maintained.

There was a question about the different planning cycles.  I think this question came before the NYISO described their processes.  Grisaru from the DPS explained that the Coordinated Grip Plan Process is supposed to put it all together.  Liu from NYISO explained that constant planning is responding to continual changes to the system.  Every new development changes some aspect of the T&D system in some way.

The panel responded to the question how does the public policy planning processes differ.  Grisaru explained that when the DPS sees a need on the bulk transmission system they contact the NYISO to start a process to look for a solution.  The NYISO system outlook can also identify bulk transmission requirements.

A question about longer planning processes planning and deployment timing was also addressed.  Liu explained that the NYISO resource adequacy process identifies risk factors and the timelines to develop the responses.  Franey explained that the building component is the fastest but still takes years.  The process has to determine what is needed and where before the planning permitting, and construction plans can be developed.  Only when all that is done can construction begin but there are procurement and supply chain issues that also have to be addressed.

How can the state policies that affect energy use affect transmission planning.  Climate activists are proponents of smart grids, energy efficiency, and other technologies that reduce energy use as a way to minimize the need for transmission development.  In response, Grisaru explained that non-wires solution have been used for a long time and is incorporated into the Coordinated Grip Plan Process.  The problem is that the de-carbonization transformation is going to require transmission solutions.  Franey explained that urban city electrification (bringing rural diffuse renewables to the cities) is going to be the next challenge,

Discussion

My impression of the speakers at this meeting is that they were desperately trying to make the point that the transmission challenges for the Climate Act mandates and schedule were impossible goals without actually saying that.  I believe that all the technical people who really understand the electric grid in the DPS, NYISO and the electric companies are being held hostage to the political narrative that “All is well”.  That did not work out for Kevin Bacon in Animal House and it won’t work out here either.

The transmission challenges are different than the generation challenges.  While it may not be necessary to develop and deploy a not yet commercially available technology like the generation sector to make this all work there still are inverter-based resource integration issues that need to be resolved.  I have the utmost respect for the electric system engineers, but I fear that they will be hit by unanticipated combinations of conditions that they could not foresee.  The result will be blackouts.

In my opinion the bigger problem is the scale of the transmission upgrades and additions needed.  New York has already committed to $6 billion to start “unbottling” renewable resources which is code in New York for Upstate utilities paying for support for New York City access to renewables.  New York also has plans for three major bulk transmission projects to get hydroelectric power from Quebec, another to collect the energy from part of Upstate to New York City, and the third to start the process of connecting the expected 9 GW of offshore wind into the grid.  Nobody has admitted to the total costs.

The other New York problem that I suspect is common elsewhere is that the politicians who enacted these net-zero laws were more concerned with the optics of aspirational timelines and not the feasibility of those schedules.  A question about longer planning processes planning and deployment timing made the point that the NYISO resource adequacy process that identifies specific need for transmission development, New York’s de-regulated market process to propose, bid, and choose the development, and the project planning, permitting, and construction plans development which all need to  be completed before construction can begin takes a lot of time.  Reading between the lines all the speakers are highly skeptical that the artificial deadlines of the Climate Act can be achieved.

One final point not addressed in the webinar but certainly affecting the viability of New York’s energy transition goal is the decarbonization of heating and transportation.  That is going to require a complete rewiring of the distribution network.

Conclusion

The magnitude, costs, and technical challenges of the generation and transmission electric grid transition ensure that that there is no question that New York will hit the Green Energy Wall.  The Hochul Administration has not provided a feasibility analysis that includes the expected costs, ensures that current reliability standards can be maintained, and documents the cumulative environmental impacts of the generation resources and the transmission and distribution deployments for the electric system to meet the 2030 70% renewable energy mandate.  The fact that no jurisdiction anywhere has developed a system that depends on wind and solar as in the proposed New York system suggests that a proof of concept demonstration is appropriate.

Zero Emissions by 2040 Gap Characterization

A different version of this article was published at Watts Up With That.

As part of the Department of Public Service Proceeding 15-E-0302 a technical conference was held on December 11 and 12, 2023 entitled Zero Emissions by 2040.  A  zero-emissions electric system is a key part of New York’s Climate Leadership & Community Protection Act (Climate Act) and all credible projections for the generating resources needed for the zero emissions Climate Act target  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.  Previously I published an article describing the slide presentation by Zachary Smith from the New York Independent System Operator (NYISO) describing DEFR.  The video of the meeting is available now and this article describes the first session of the meeting – Gap Characterization.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition. The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The 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 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.”  In brief, that plan is to electrify everything possible using zero-emissions electricity. 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.  In 2023 the Scoping Plan recommendations were supposed to be implemented through regulation, PSC orders, and legislation.  Not surprisingly, the aspirational schedule of the Climate Act has proven to be more difficult to implement than planned and many aspects of the transition are falling behind.  DEFR is a particularly challenging problem.  When political fantasies meet reality, reality always wins.

Gap Characterization

The Department of Public Service (DPS) convened a two-day technical conference on December 11,  2023.  The conference focused on characterization of the potential “gap” discussed in the May 14, 2023 Proceeding 15-E-0302 Order and technologies that could shrink or fill that gap.

The first session (video) of the conference was titled Characterizing the potential “gap”.  It addressed resource adequacy, transmission security, and grid stability arising from shuttering fossil fuel-fired resources and increased loads due to the Climate Act electrification strategies.  It was moderated by Schuyler Matteson from DPS.  There were four panelists and I have included links to the location in the video with their introductions: 

  • Deidre Altobell, Chief Transmission Planning Engineer Consolidated Edison.  She represented the concerns of the New York City electric system provider.  New York City has unique issues within the New York State electric power market that are a particular challenge for a transition to a system dependent upon renewables.
  • Prof. C. Lindsay Anderson, Chair of Department of Biological and Environmental Engineering Cornell.  Professor Anderson provided an independent check on the work of other electric system planning analysts because her group has modeled resources necessary for the New York electric system transition.
  • Zach Smith, VP System Resource Planning, New York Independent System Operator (NYISO).  NYISO is “responsible for operating wholesale power markets that trade electricity, capacity, transmission congestion contracts, and related products, in addition to administering auctions for the sale of capacity.”  As part of those responsibilities NYISO has done extensive modeling resource projections of the net-zero transition.
  • Kevin Steinberger, Director, Energy and Environmental Economics (E3).  As part of the New York Climate Act transition plan an Integration Analysis was performed that included an assessment of the electric system net-zero transition resources.  E3 provided the quantitative analysis for that effort.

The description for the meeting described the items for discussion:

  • Existence of a “gap,” based on physical and planning requirements of the grid.
  • Resource adequacy, transmission security, and grid stability components of the potential resource-reliability gap that is expected to emerge in New York as fossil-fired generation resources are shut down pursuant to CLCPA requirements.
  • How models used by NYISO, the Climate Action Council, and others identify this “gap” and estimate its size and timing.
  • Information to seek/develop through additional studies conducted as part of the Coordinated Grid Planning Process and/or ongoing NYISO Reliability Needs Assessment.

This article only discusses one of the sessions in the Technical Conference.  The DPS website provides information on the other sessions and links to the videos of the discussions.  There is plenty of fodder for additional posts, but I also have a long list of obligations and other topics to cover so I am not going to address anything else here.

Gap Characterization Session

After the introductions the moderator asked a series of questions.  This section lists the questions with a link to that location in the video.  I highlight some of my concerns and points made by the panelists

The first questions was: “How do we know if there is a gap?”  Professor Anderson described an analysis her group did.  They made projections for expected loads and potential resources then used 22 years of hourly historical data to model the system.  Without considering cost constraints they assessed system vulnerabilities to evaluate periods where there was insufficient generation to meet projected loads.  Even with optimistic projections they found there will be periods during the coldest and hottest periods where there will be insufficient generation from wind, solar, and energy storage resources.  Steinberger also responded that their modeling consistently showed the need for a new resource that is firm, dispatchable, and has no emissions that can power the system for days without significant recharge from wind and solar resources.  He stressed the importance of considering actual historical meteorological conditions because renewable energy production is dependent on weather conditions.

Zachary Smith gave an overview summary presentation of the DEFR issue that was the focus of an earlier post of mine.  In his first slide (shown below) he gave an overview of the generating resource outlook to make the point that a large amount of new generating resources needs to be developed.  The estimates shown are from the 2021-2040 System & Resource Outlook and represent two plausible load projections.  He noted that there are “a lot of attributes that fossil fuel resources provide today that wind, solar, and energy storage simply cannot provide”.  He also made the point that the DEFR replacements do not have to be a single technology but could be several technologies that in aggregate can replace the fossil generation.

The ultimate problem for reliability in an electric system that depends on wind and solar is illustrated in the following slide from Smith’s presentation.  It highlights a 7-day wind lull when the wind, solar, and energy storage are insufficient to meet demand.  The replacement resources must be able to ramp up quickly, stay online for a long period, and provide ancillary services to support the transmission system.  The sum of the grey area under the curve during that period is the amount of energy (MWh) that must be provided by DEFR sources based on an analysis of historical weather data. If there are insufficient resources during a wind lull, then the load cannot be met.  The consequences of that situation would be catastrophic.

To meet this need for dispatchable resources Smith explained that dispatchable emission-free resources (DEFRs) must be developed and deployed throughout New York:

  • As resources shift from fossil generators to zero emission resources, essential grid services, such as operating reserves, ramping, regulation, voltage support, and black start, must be available to provide New Yorkers with a reliable and predictable electric system that consumers require.
  • DEFRs will be required to provide both energy and capacity over long durations, as well as the reliability attributes of retiring synchronous generation. The attributes do not need to be encapsulated in a singular technology, but in aggregate the system needs a sufficient collection of these services to be reliable.

The NYISO must toe the political correctness line, so Smith downplays the enormity of the challenge to bring DEFR online in the timeframe necessary to meet the arbitrary Climate Act schedule.  I have no such restrictions so I will note that I think that anyone who thinks that this can be done is crazy.  Smith lists the attributes needed by DEFR in his presentation.  In the following I offer my comments on his list of attributes.

Smith’s first attribute for DEFR is that it must have “dependable fuel sources that are carbon free and allow these resources to be brought online when required”.  Clearly intermittent wind and solar do not meet this fundamental requirement. 

The second DEFR attribute is that it must be “non-energy limited and capable of providing energy for multiple hours and days regardless of weather, storage, or fuel constraints”.  This is a particular concern of mine.  Wind and solar resources correlate in time and space.  In other words, when the wind is light at one wind farm in New York it is very likely that all the wind farms in the state are experiencing light winds.  The seven-day wind lull example in the dispatchable resources needed figure illustrates the problem.  If there are insufficient resources during that wind lull, then the load cannot be met.  My concern is that I think we do not know what the worst case low renewable resource availability period is.  Until there has been more analysis done then I believe that planning to prevent reliability issues is inadequate.

The NYISO operators balance generation with load constantly.  Smith describes several attributes necessary for this requirement.  DEFR must be able to “to follow instructions to increase or decrease output on a minute-to-minute basis”.  There must be “flexibility to be dispatched through a wide operating range with a low minimum output”. Finally, DEFR must be “fast ramping to inject or reduce the energy based on changes to net load which may be driven by changes to load or intermittent generation output”. 

In addition to the attributes needed when units are operating, there are startup attributes.  DEFR must be “quick start to come online within 15 minutes” and capable of “multiple starts so resources can be brought online or switched off multiple times through the day as required based on changes to the generation profile and load”.  Smith explains that a range or DEFR generation will likely be required.  Not every DEFR must be capable of every attribute for matching load but sufficient amounts each attribute for the system requirement will be required.

In addition to the generating requirements that cannot be supplied by wind and solar, there are ancillary support services for the transmission system.  Smith describes three transmission support DEFR attributes:

  • Inertial Response and frequency control to maintain power system stability and arrest frequency decline post-fault;
  • Dynamic Reactive Control to support grid voltage; and
  • High Short Circuit Current contribution to ensure appropriate fault detection and clearance.

Smith’s presentation lists the attributes of twelve sample technologies in the following slide.  This represents the NYISO opinion of the capability of different technologies to meet the attributes necessary to maintain a reliable system.  In the future grid the insistence that all fossil fired units must be shut down means that numerous technologies that meet some of the necessary attributes will be required.  The added complexity of these technologies does not increase resiliency because wind, solar, battery and demand response are all energy limited.  Ancillary support services will be a major consideration because wind, solar and battery do not provide those services.  Just from this overview, it is clear that affordability and reliability will be challenges.

Attributes of Sample DEFR Technologies

The moderator asked for Altobell’s reaction relative to the situation in New York City.  She noted that Con Ed agrees with NYISO analyses and that their work has shown similar results.  She made the point that there is a minimum amount of generation that must be on-line in New York City to provide reactive support.   She explained that the location of that generation is important.  Importantly, she noted that we cannot let any more fossil retire until replacement services are provided.

Altobell also described some of the reliability standards that they are required to address.  For example, the reliability standard N-1-1 addresses the loss of the two largest components on the system and the ability to recover from the loss of those two components.  This criterion is considered on a daily and on a long-term basis.  Currently the system relies on quick start units to get the system back to normal after the loss of large components but the peaking turbines that have historically been used for this are being retired which complicates compliance with the requirement.

In another example of a hidden cost of the net-zero transition Altobell explained that the New York City transmission system needs to be modified to eliminate load pockets.  Historically Con Ed has relied on generating resources that were located to serve those load pockets.  To replace those resources, the load pockets have to be eliminated to open up the system.  This is complicated by the fact that there isn’t much room available for infrastructure like substations.

I was interested in her comments on inverter-based resources relative to a dispatchable resources.   She noted that 1,000 MW of offshore wind is equivalent to 100 MW of dispatchable resources in transmission security analyses.  That means to replace the 2,000 MW of dispatchable Indian Point power that the State shut down, 20,000 MW of offshore wind must be deployed.  Note that the Climate Act mandates 9,000 MW of offshore wind which is far less than what is needed to simply replace Indian Point.

The next question from the moderator addressed the quantity of resources necessary to address the gap.  Specifically, he asked can wind, solar, short-duration solar, and improvements to the transmission system eliminate the gap.  Professor Anderson explained that her team’s work found that adding more of each technology is not going to solve the gap problem.  It is not just that we need more, we need it in the right places. 

The moderator reflected the consensus of the panelists when he noted the New York gaps cannot be solved using existing technology because of the physical characteristics of the grid and the location of load in the state.  He followed up by asking Steinburg when the gap will show up, how quickly do we need to react, and what is the magnitude of the resources necessary to respond.  Steinburg said the work his group did for the Integration Analysis showed that the timing of the gap problem depends on the rate of electrification and retirements of existing fossil resources.  The problem will be worse in the winter once the load peak shifts to account for electric heating and electric vehicles.  Smith noted that the NYISO expects that New York will be a winter peaking system in the ”early to mid- 2030’s”.

Schyler Matteson, the moderator, pointed out that before the DEFR resources can be deployed a long period of planning, permitting, construction, and inter-connection is required.  He stated that this could be on the order of seven years.  He followed up with a question to Smith about how planning for the system reserve margins and the local transmission security issues most prevalent in New York City will affect the process to develop DEFR to replace existing fossil.  Smith emphasized the point that this is a challenge that will require extensive collaboration between agencies.  In order to address the retirement issues NYISO has instituted a quarterly “short-term assessment of reliability” process.  While this reactively addresses generator deactivation notices, NYISO is also trying to consider longer-term issues.  In particular, the Department of Environmental Conservation has a rule promulgated to retire old peaking combustion turbines.  In that process, NYISO temporarily extended the retirement dates until reliability solutions could be deployed.  Smith emphasized that a similar process needs to be incorporated as part of the Climate Act net-zero transition.  Smith went on to point out that some of the DEFR required is not yet commercially available so there is even more lead time than required to simply deploy the resources.  Altobell explained that there is another consideration – outage scheduling.  The existing system still has to operate and the outages when changes can be made without threatening reliability are getting smaller and smaller.

The moderator gave his summary of the panel discussion and asked for comments.  He said a gap “definitely exists”, that gap is flexible based on the future load characteristics, the generation mix, load profiles, and transmission constraints.  The gap is starting to show up around 2035 and is definitely an issue by 2040.  DEFR needs to be commercially available during the deployment planning period.  Three different analyses showed that on the order of 20 to 30 GW of capacity is needed.  Gaps of four maybe five days occur as much as every few years.  Smith pointed out that future planning also has to address extreme events and the need for resilience.

The session ended by discussing a question raised in the chat.  The question raised was how do we characterize what the maximum DEFR need is?  Smith replied that more analysis is needed.  He mentioned that the New York State Reliability Council is charged with addressing this issue.  It is necessary to define the worst-case conditions and then decide how to design the system to deal with it.  Altobell supported his comments and pointed out that the Reliability Council has an Extreme Weather Working Group that is looking at gap characteristics.  They are also addressing the reliability rules that will be needed when the projected amounts of inverter-based resources (wind, solar, and energy storage) are deployed. 

Discussion

At the Climate Action Council meeting to vote on the approval of the Scoping Plan Dr. Robert Howarth summarized his statement  supporting his vote to approve the Scoping Plan.  His statement notes that:

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.

The position that “it could be done completely with technologies available at that time” had an out-sized influence on the Climate Action Council decision to approve the Scoping Plan.  After all, if there are no technological barriers then it is simply a matter of political will. 

This session is proof that this belief is wrong.  The work of  Prof. C. Lindsay Anderson, Chair of Department of Biological and Environmental Engineering Cornell; Zach Smith, VP System Resource Planning, New York Independent System Operator; and Kevin Steinberger, Director, Energy and Environmental Economics all found that a new resource that has all the attributes of fossil-fired peaking units but without any emissions is needed.  Ultimately, the failure of the Hochul Administration to step and point out that the Integration Analysis that formed the basis of the Scoping Plan pointed out the need for this resource will have serious implications.

I have two worries. The first concern is that there are resource candidate technologies that are not commercially available.  There is a long road between theory and lab prototype tests and having a technology available that can be deployed to maintain reliability.  It is likely that many of the candidate technologies will fail this test.  Secondly, even if the technologies are viable there are issues related to deployment time and costs.  The Climate Act net-zero transition includes an ambitious schedule and there are affordability concerns.  Neither issue can be addressed at this time.

A more immediate concern is the push to retire existing fossil-fired resources as soon as possible.  This panel discussion showed that the belief that wind, solar, and energy storage are resources that can just be plugged into the New York City electric system to replace peaking power plants is dangerous.  Those existing facilities provide much more than electric energy and wind, solar, and energy storage don’t provide those other necessary services.  The session made the point that location matters and that there are spatial limitations in the City that could very well preclude development of alternative technology with different footprint requirements.  Eventually, someone is going to have to stand up and tell the vocal environmental justice advocates that their demands to shut down peaking power plants cannot be met.

Conclusion

It is not clear where the Department of Public Service is going to go with issues raised at this technical conference.  So far, the transition plan narrative has been based on the misplaced belief that no new technologies are needed.  This gave the crony capitalists selling the wind, solar, and energy storage resources the opportunity to make the plan all about building as much as possible as fast as possible.  Is there any chance that these technical issues will cause a change in direction? 

New York State GHG Emissions Trends

This is my 400th article on the Climate Leadership & Community Protection Act (Climate Act) net-zero transition.  It seems appropriate to look at where the state stands relative to the time when I started writing these articles and the Climate Act targets.  This summary supplements the progress status summary described by Francis Menton and the generation trend status prepared by Nuclear New York by looking at Greenhouse Gas (GHG) emissions.

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

Overview

The 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 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.”  In brief, that plan is to electrify everything possible using zero-emissions electricity. 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.  In 2023 the Scoping Plan recommendations were supposed to be implemented through regulation, PSC orders, and legislation.  Not surprisingly, the aspirational schedule of the Climate Act has proven to be more difficult to implement than planned.  Many aspects of the transition are falling behind, and the magnitude of the necessary costs is coming into focus.  When political fantasies meet reality, reality always wins.

Nuclear New York – Generation Trends

In a press release on January 8, 2024 Nuclear New York, “Independent Advocates for Reliable Carbon-Free Energy” explained that “four years since passing the Climate Act, New York struggles to replace shuttered clean energy “.  Their release stated (foot notes removed):

In 2023, nuclear power was once again the largest single source of clean energy in New York State. Electricity generation from this carbon-free source totaled 27.6 terawatt hours (TWh), up 2.7% over 2022. Nuclear covered 18.1% of the state’s total electricity demand (including behind-the-meter “rooftop” solar generation), and amounted to 42.7% of in-state clean electricity.

Hydro, the second largest source of carbon-free power, recovered 2.1% in 2023 to 27.2 TWh, covering 17.9% of demand. These two ‘firm clean’ generation sources provide on-demand power regardless of the time of day or weather.

Despite increasing deployed wind capacity in 2022 by 13% over 2021, generation from this source declined 3.9% in 2023 over 2022 to 4.7 TWh, demonstrating the perils of relying on weather-dependent renewable energy. New York Independent System Operator (NYISO) does not report grid-connected solar as a separate category, given its currently minuscule contribution to the generation mix. However, rooftop solar generation increased 18% to 5.2 TWh, covering 3.4% of demand.

New York’s electricity demand declined by 4.8 TWh over 2022 (-3.1%), which enabled the state to reduce net imports by 4.3 TWh. In-state fossil fuel combustion decreased by 2.3 TWh, but remained 11.0 TWh (21%) above 2019 levels, when clean energy generation peaked.

Updates on the March to the New York Great Green Future

Francis Menton’s update on the net-zero transition asks the question where are we and responds:

The Manhattan Contrarian Energy Storage Report of December 1, 2022, led off by sounding a clear alarm: getting electricity from intermittent wind and solar well past 50% of total generation would require enormous quantities of energy to be stored, with technical requirements, including duration of storage, well beyond the capability of any battery currently existing or likely to be invented any time soon. Essentially, if fossil fuels are to be eliminated, there is only one realistic possibility for meeting the storage requirements: hydrogen.

In mid-2023, the New York Independent System Operator, to its credit, recognized the problem — although it buried that recognition deep in a report when it should be shouting about the problem from the rooftops. From NYISO’s Power Trends 2023 Report, revised August 2023, page 7, starting in the middle of a paragraph and without any emphasis:

[T]o achieve the mandates of the CLCPA, new emission-free generating technologies with the necessary reliability service attributes will be needed to replace the flexible, dispatchable capabilities of fossil fuel generation and sustain production for extended periods of time. Such emission-free technologies, either individually or in aggregate, are not yet available on a commercial scale.

With hydrogen as the only possible such “emissions-free generating technology,” how much would hydrogen cost as the solution to this problem, particularly if one follows the hypothesis that it must be created without any use of fossil fuels? My Report, page 14, noted that existing commercial production of this so-called “green” hydrogen was “negligible,” leaving no good benchmark for understanding what the costs might be. As a substitute, I ran some rough numbers based on cost of wind and solar generators to make the electricity and efficiency of the electrolysis process. The result was a very rough estimate that this “green” hydrogen would cost “somewhere in the range of 5 to 10 times more” than natural gas (page 17).

Well, now some new precision has come into view. In July 2022 the UK government launched what it calls its First Hydrogen Allocation Round (HAR 1), to obtain bids and award contracts to produce this so-called “green” hydrogen using wind power. The process took a while, but here from December 14, 2023 is the announcement of the first round of contract awards. Excerpt:

Following the launch of the first hydrogen allocation round (HAR1) in July 2022, we have selected the successful projects to be offered contracts. We are pleased to announce 11 successful projects, totalling 125MW capacity. HAR1 puts the UK in a leading position internationally: this represents the largest number of commercial scale green hydrogen production projects announced at once anywhere in Europe. . . . The 11 projects have been agreed at a weighted average strike price of £241/MWh.

£241/MWh? At today’s exchange rate of 1.27 $/£, that would be $306/MWh. Prices of natural gas are generally quoted in $/MMBTU rather than per MWh, but here is EIA’s latest Electricity Monthly Update, dated December 21 and covering the month of October 2023. It gives natural gas prices in the per MWh units. The “price of natural gas at New York City” is given as $11.32/MWh. That would make the price that the UK has just agreed to pay to buy this “green” hydrogen stuff approximately 27 times what we can buy natural gas for here in New York to obtain the same energy content.

And that $306/MWh is just for the hydrogen. It includes nothing for the massive new facilities (underground salt caverns?) to store the stuff, for a new pipeline network to transport it, and for a new collection of power plants to burn it.

Electric Generating Unit Emission Trends

Electric generating units report emissions to the Environmental Protection Agency Clean Air Markets Division as part of the compliance requirements for the Acid Raiin Program and other market-based programs that require accurate and complete emissions data.  The 2023 emissions data submittal date was January 31 and I downloaded the data the next day.  Something has changed in the data access system so I could not check to see if all the facilities reported on time.  If some facilities had to ask for a delayed submittal this could mean that the totals are lower that actual emissions.

The following table lists the emissions since 2009 when the Regional Greenhouse Gas Initiative started.  Emissions of CO2, SO2, and NOx are down dramatically over this period.  The primary reason is that the fracking revolution made the cost of natural gas so cheap relative to other fuels that every facility that could convert to natural gas did so.  New York banned the use of coal in 2021 which forced the retirement of the remaining coal plants.  The state still has some facilities that primarily burn residual oil but those run infrequently.  The takeaway message is that the fuel switching options are no longer available so future reductions will only come as zero-emissions resources displace facilities burning fossil fuels.

The following graph shows the emission trends.  Note that I divided the CO2 emissions by 1,000 so that all the parameters would show up on the same plot.  The impact of the closure of the Indian Point nuclear facility mentioned in the Nuclear New York presentation is clearly shown as CO2 rose over the last three years until the 2023 emissions started down.  Importantly that could be mostly due to weather variations and not necessarily the addition of the renewables shown above.

New York State GHG Emission Trends

A relevant question is where we stand in regards to the Climate Act mandate for a 40% reduction from a 1990 baseline in GHG emissions by 2030.  Unfortunately, that is not easily answered in sufficient detail to be able to figure out what is going on.

The regulation setting the 1990 baseline emissions values that form the basis for the 2030 40% reduction and the 2050 85% reduction was promulgated in 2020.  It sets the limits

§ 496.4 Statewide Greenhouse Gas Emission Limits

(a) For the purposes of this Part, the estimated level of statewide greenhouse gas emissions in 1990 is 409.78 million metric tons of carbon dioxide equivalent, using a GWP20 as provided in Section 496.5 of this Part.

(b) For the purposes of this Part, the table below establishes statewide emission limits for the year specified, as a percentage of estimated 1990 statewide greenhouse gas emissions of 60 percent and 15 percent, respectively, measured in millions of metric tons of carbon dioxide equivalent gas using a GWP20 as provided in Section 496.5 of this Part.

YearStatewide greenhouse gas emission limit (in million metric tons of carbon dioxide equivalent)
2030245.87
205061.47

The Regulatory Impact Statement for the regulation included a table that breaks down the 1990 emissions by Intergovernmental Panel on Climate Change Sectors and gases.  As shown below there is not much of a breakdown.  Note that all the rest of the emissions will be reported as the CO2 equivalents so you do not need to worry about the component gases.

According to the 2023 Statewide GHG Emissions webpage “The Climate Act requires the New York State Department of Environmental Conservation (DEC) to issue an annual report on statewide greenhouse gas emissions, pursuant to Section 75-0105 of the Environmental Conservation Law.”  The most recent report covering the years 1990 through 2021 was released in late December 2023. The following reports were released at that time:

I extracted summary data from each of the sectoral reports to provide some idea of where New York stands relative to the 2030 targets in the following table.  The Part 496 1990 column lists the regulatory baseline numbers.  The estimated emissions in the 2023 Statewide GHG Emissions are listed for 1990, 2005, and the last five years.  I list the sector 2030 targets (40% of 1990 emissions) and the percentage reduction necessary to meet the targets. 

The first thing that pops out is that the 2023 inventory has a different estimate for 1990.  GHG emission inventories require indirect estimates of many of the emission sources and the assumptions regarding the emission factor that estimates emissions with an activity and the activity rate.  This is a fundamental problem with emission factors and means that for full transparency all the emission factors and associated activity levels should be clearly documented.

The second thing of note is that none of the IPCC sectors are even close to the 2030 targets.  The Scoping Plan’s quantitative assessment in the Integration Analysis essentially is a list of control strategies, presumed control efficiencies, and expected emission reductions that when added up meet the limits.  That assessment was poorly documented, contains inconsistencies with similar New York Independent System Operator (NYISO) analyses, and there has never been any response to comments about inconsistencies and other issues identified in the Scoping Plan comments.  There is no feasibility analysis to determine if those targets can be met with any assurance.

I tried to analyze the data used for the 2023 Statewide GHG Emissions.  Those data are available for download from Open Data NY.  This is another instance where it is not easy to break down the components of the IPCC sectors to determine if it is realistically possible to meet the 2030 targets because state agencies do not provide consistent data.

The Regulatory Impact Statement for Part 496 included Table 4 that broke down fuel combustion GHG emissions within the IPCC energy sector.  Because I used the dataset itself, I picked the sector categories that I believe match the Table 4 categories.  Note that I did not include fuel combustion from petroleum refining in the table because I could not find categories that I thought matched it.  The following table lists the results for the last ten years and compared the 2021 emissions to the 2030 target. Fuel combustion in the electric and industrial sectors are already lower than the equivalent 2030 targets.  On the other hand, transportation and fuel combustion in the commercial and residential sectors will require significant reductions to meet the targets. 

Is that feasible?  Consider what is needed for just one parameter.  To determine if the transportation fuel combustion reductions are feasible, the expected reductions per gasoline vehicle must be estimated.  Miles per gallon and the annual mileage need to be estimated for a range of users and locations so that a reasonable estimate of state-wide fuel use can be estimated.  Once you know that then you can determine how many zero-emissions vehicles must be deployed.  Is that estimate realistic?  That is not all because zero-emissions vehicles also require charging infrastructure and that affects the distribution infrastructure. It is easy to say the model projections meet the 2030 targets but the range of parameters that can be tweaked is so large that any pre-conceived answer can be produced. 

I also put these data in a graph.  I am not sure it adds much value, but I spent enough time on it that I don’t want to waste the effort.  The overall trend suggests that it might be possible to meet the targets if, and only if, the historical rate of emission reductions can be replicated.  Given that the electricity and industrial sectors have achieved the greatest reductions but have no readily available additional reductions, I am not optimistic. 

Conclusion

The 400 articles I have written on the Climate Act all lead to the same result.  When you look at the numbers as shown in this post, the enormity of the challenge is clear. Paraphrasing Francis Menton:

No person looking at these charts would ever conclude that New York has spent the past five years embarked on a crash program to replace fossil fuels with wind and solar. That process is going absolutely nowhere.

Someday Scrooge Will Say No

Richard Ellenbogen recently sent an email to his distribution that highlighted an inevitable problem with New York State’s net-zero mandate of the Climate Leadership and Community Protection Act (Climate Act).  The plan is to electrify everything possible using renewable energy.  That brings up the problem that the local electric distribution system is not up to the task so it is likely that electric use could be limited at times in New York’s future.

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 and 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.” I recently described his presentation on New York’s Energy Transition that is a detailed explanation why the State’s quest for zero emissions electricity generated by wind and solar is doomed to failure.

There are only a few people in New York that are trying to educate people about the risks of the Climate Act with as much passion as I am but Richard certainly fits that description.  He comes at the problem as an engineer who truly cares about the environment and how best to improve the environment without unintended consequences.  He has spent an enormous amount of time honing his presentation summarizing the problems he sees but most of all the environmental performance record of his business shows that he is walking the walk.  

Climate Act Overview

The Climate Act established a New York “Net Zero” target (85% reduction and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.”  In brief, that plan is to electrify everything possible using zero-emissions electricity. 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.  After a year-long review, the Scoping Plan recommendations were finalized at the end of 2022.  In 2023 the Scoping Plan recommendations were supposed to be implemented through regulation and legislation.  Ellenbogen’s discussion describes one of the issues that was not addressed in 2023.

Record Christmas Lights

Ellenbogen described a home in Union Vale, NY where the residents set the world record for most lights in a residential Christmas display with 720,420 lights in the display.  He provided links describing the the record lights from the New York Times:

I cannot get around the Times paywall so I could not see those articles but found a relevant story at Good Morning America that includes a video.

Ellenbogen writes:

Independent of any issues raised in the article, the following comment by a neighbor stands out.

Bernadette and William Burke, who love to watch the show from their hot tub, but for years could not use their washing machine or dishwasher while the lights were on. Mr. Gay said the problem was resolved when the electric company put the Gay house on its own transformer.

He estimated the power requirements:

Below is a table of power consumption of various Christmas bulbs. Using a back-of-the-napkin calculation, the display probably draws about 75 – 100 KVA.   Most utility transformers in residential areas are sized between 70 KVA and 150 KVA.  Below are photos from a NYSERDA report that I wrote in 2010 for the reactive power project I did for them.  Note that a transformer used to support five buildings in a Garden Apartment complex had a capacity of 150 KVA and a transformer for two buildings had a capacity of 75 KVA.  Both of these transformers operated near their capacity on a hot summer day and would far exceed that capacity with widespread installation of heat pumps.

Ellenbogen compared the power consumption of the display to heat pumps and car charging that are components of the Scoping Plan outline of control strategies to meet the Climate Act mandates:

The three heat pumps in my home will draw about 22 KW at peak load for 250,000 BTU of heat transfer in heating mode (1000 watts per ton  COP=3.52 ).  The power draw in cooling mode is about 60 % of that (600 watts per ton  COP=5.86 ).  We also have gas furnaces with an output of 400,000 BTU that will operate on extremely cold days or will operate if there is an issue with the heat pumps.

My car charges at a peak load of 14,000 watts.  I have seen loads of 38,000 watts on the power monitor at my house when I am charging the car during the winter.  When I built my house, I had a 400 amp 3phase service installed.  It can deliver 144 KVA ( 144,000 watts) at peak load and the transformer across the street is 150 KVA.  Most newer homes might have a 200 amp single phase service (40 KVA) and older homes will have a 100 amp or 150 amp service (20 – 30 KVA).

Discussion

Ellenbogen argues that the fact that a neighbor was impacted by a large load by a neighbor has ramifications when everyone has to increase their electrical requirements:

The point is that if the utility system can’t support a Christmas display, even a large one, and allow the neighbors to wash their clothes at the same time, how is it going to support the massive load of heat pumps and vehicle charging that is being mandated.  That combination will far exceed the demand of a Christmas light display.  As I have mentioned previously, every transformer in the state is going to have to be replaced or have their service upgraded as occurred at the home in the article.  The problem is that there is an acute transformer shortage along with a shortage of electricians and utilities are worried about having a sufficient number of transformers to recover after a bad storm, let alone having enough to rebuild the entire system.

Also note that the GMA piece on the record light display mentioned that the owners claim that their electric bill is only $300.  New York utilities are installing smart meters that will eventually enable them to charge customers different rates at different times of the day.  The idea is that they will increase rates to incentivize customers to reduce use during peak load periods.  In the all-electric future the peak load will be in the early evening when homeowners get home from work and turn on appliances.  I would not be surprised at all if the costs for the massive display might increase so much that they would be unable to afford the costs even with LED lights.

Although the utilities claim that customers will not lose control of their electric use, I suspect that is also inevitable because of the scale of the problem.  As a result, someday Scrooge will say no you cannot have a record light show.

Conclusion

Ellenbogen said he was going to send a magic wand to the Public Service Commission to help them with the Climate Act transition because they are going to need all the help that they can get.  I agree with his conclusion: “Since math and science have been thrown out the window in New York State, we might as well turn to the occult.”

New Year’s Resolution – Methane Response

Happy New Year!

I wrote an article for Watts Up With That  that described my New Year’s resolution: I resolve that when I hear anyone say that methane is more potent than carbon dioxide because the radiative forcing produced is greater, I will say that is only true in the laboratory on a dry molecular basis.  In the atmosphere, where it counts, methane is not nearly as potent.  I had hoped to get feedback and recommendations and I was not disappointed.  This post provides the rationale for my resolution.

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

Rationale

I have heard the methane scare story everywhere but my primary concern is New York.  As part of New York’s Climate Act methane is irrationally disparaged as part of the war on natural gas.  The rationale used always revolves around the potency of methane relative to CO2.  I believe that the preponderance of information shows that the argument is incorrect.  I have developed a page that consolidates reasons why methane should not be vilified and updated it based on comments made.  The following summarizes my rationale.

Clyde Spencer explained that changes to radiation effects occur on a molecule-by-molecule basis in the atmosphere in an article titled The Misguided Crusade to Reduce Anthropogenic Methane Emissions.  The Climate Act tracks emissions by weight.  In the atmosphere CO2 is more than two orders of magnitude more abundant than CH4 on a molecular basis. The Climate Act uses the global warming potential that estimates the mid-range, long-term warming potential of CH4 is 32 times that of CO2.  However, that equivalence is for equal weights of the two gases!  Using a molecular basis (parts per million-volume mole-fraction) to account for the lighter CH4 molecule reveals that the annual contribution to warming is a fraction of that claimed for CO2.  Methane emissions on a molecular basis are increasing at a rate of 0.58% of CO2 increases.   Therefore, changes in methane emissions have insignificant effects.

Several commenters pointed out that that methane and water vapor affect the same area of the spectrum of outgoing radiation thus reducing the effect of any changes in methane concentrations. .Rud Istvan explained that:

Methane is a potent GHG in the lab because the lab uses a standard dry atmosphere.  I”n the real world methane’s two main infrared absorption bands (at about 3.5 and 8 microns) are completely overlapped by two of the several broader and much stronger water vapor absorption bands, specifically those from about 2.5-4 and 6-9 microns. In a world averaging about 2% specific humidity, any methane effect is literally swamped by water vapor effect.

Cyan quantified the effect of the spectral overlap “Water vapor reduces the potency of methane by about 82 percent at 80%RH. At 46% RH (from the US Standard Atmosphere) the reduction is less, at 75%.”

Andy May’s excellent summarization of Wijngaarden and Happer’s important paper “Dependence of Earth’s Thermal Radiation on Five Most Abundant Greenhouse Gases” takes a slightly different approach.  He explains that the greenhouse effect of methane is not only related to the effect on longwave radiation itself but also the concentration in the atmosphere.  Because the atmospheric concentration of methane is so small doubling concentrations change the “outgoing forcing by less than one percent”.  In other words, doubling emissions or cutting emissions in half of methane will have no measurable effect on global warming itself. A comment by “It does not add up” pointed out that Wijngaarden and Happer also produced a separate paper concentrating specifically on methane.

Ralph B. Alexander describes another molecular consideration ignored in the Climate Act.  Each greenhouse gas affects outgoing radiation differently across the bell-shaped radiation spectrum   One of the reasons that CO2 is considered the most important greenhouse gas is that its effect coincides with the peak of the bell shape.  On the other hand, the effect of CH4 is down in the tail of the bell shape.  As a result, the potential effect of CH4 is on the order of only 20% of the effect of CO2.

The residence time of the two gases is different.  Methane only has a lifetime of about 10-12 years in the atmosphere.  The “consensus” science claim is that 80% of the anthropogenic CO2 emissions are removed within 300 years.  (Note however that there are other estimates of much shorter residence times.) This means that CO2 is accumulating in the atmosphere.  CH4 is converted to CO2 and is then counted in the monthly CO2 measurements as part of the CO2 flux.  Because methane does not accumulate the same way as CO2 it should be handled differently.  However, the Climate Act doubles down.  Climate Act authors claimed it was necessary to use 20-year global warming potential (GWP) values because methane is estimated to be 28 to 36 greater than carbon dioxide for a 100-year time horizon but 84-87 greater GWP over a 20-year period.

Conclusion

The Climate Act uses explicit language to magnify the accounting for methane emissions that make the use of natural gas more expensive.  Last spring I described legislation that was proposed and endorsed by the Hochul Administration that would have changed the accounting to be consistent with the Intergovernmental Panel on Climate Change, the Environmental Protection Agency, and most other jurisdictions.  The climate activist community went nuts and the legislation never progressed. 

The problem is that I show here that the basis for their indignation is flawed as I point out in my resolution.  Methane does not have greater impacts than carbon dioxide and should not be treated as mandated by the Climate Act.  My recent article about righteous risks noted that the activists who push the evil methane narrative are driven more by moral idealism than pragmatic concerns.  In this instance, their demand for different treatment means that the proposed New York Cap-and-Invest program cannot join other jurisdictions because the emissions accounting will be different.  New York will have to develop all the infrastructure and regulations for its program on its own.