On August 5 Governor Hochul announced a Future Energy Economy Summit that will “gather feedback on strategies to accelerate renewable energy deployment and explore the potential role of next generation clean energy technologies”. I described my initial thoughts on the summit and followed up with a second pre-meeting post. This post describes my initial reaction to the meeting. I will follow up with another post when the meeting recording is posted.
I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 450 articles about New York’s net-zero transition. The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.
Overview
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. It includes an interim 2030 reduction target of a 40% reduction by 2030. Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies. That material was used to develop the Draft Scoping Plan outline of strategies. After a year-long review, the Scoping Plan was finalized at the end of 2022. Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation.
Setting the Stage for the Meeting
As I have noted previously there are many reasons why an assessment of the future energy economy is needed. Three recent reports top the list. The Public Service Commission (PSC) Clean Energy Standard Biennial Review Report found that the 70% renewable energy goal will likely not be achieved until at least 2033. The New York State Comptroller Office Climate Act Goals – Planning, Procurements, and Progress Tracking audit found that the PSC and NYSERDA implementation plans did not comprise all essential components, including “assessing risks to meeting goals and projecting costs.” The New York Independent System Operator (NYISO) 2023-2042 System & Resource Outlook described issues that threaten reliability and resilience of the current and future electric system. The Department of Public Service Proceeding 15-E-0302 may also be influencing the Governor and precipitating the need for the summit. The Business Council of New York has cited those reports and gave other reasons why it is needed. As a result, the governor said the state’s climate goals are something she “would love to meet, but also the cost has gone up so much. I now have to step back and say, ‘What is the cost on the typical New York family?’ Just like I did with congestion pricing.”
Annotated Agenda
Welcome
Doreen Harris, President and CEO, New York State Energy Research and Development Authority
Reason to meet in Syracuse was because of Micron chip fabrication plant
Administration is committed to Climate Act goals but refinements may be necessary
She managed to appeal to a wide range of her constituents with specific statements
Fireside Chat: State of Technology
David Crane, Under Secretary for Infrastructure, U.S. Department of Energy
Richard Kauffman, Chair, New York State Energy Research and Development Authority
I was not impressed with this session
Neither speaker has a technical background and it showed
Upton Sinclair’s quote is apropos: “It is difficult to get a man to understand something when his salary depends upon his not understanding it.
Accelerating Renewable Energy Deployment in New York State
Moderator, Georges Sassine, Vice President, Large Scale Renewables, New York State Energy Research and Development Authority
Laura Beane, President North America, Vestas
Lori Bird, Director of U.S. Energy Program and Polsky Chair for Renewable Energy, World Resources Institute
Eric Cohen, Head of Green Economy Banking, JP Morgan Chase
Frank Macchiarola, Chief Policy Officer, American Clean Power Association
Jonah Wagner, Senior Advisor to the Director, U.S. Department of Energy Loan Programs Office
All of these speakers have a vested interest in the clean energy transition so my notes are sparse
I posted a question asking if it was a good idea to build as much renewable energy as possible before the necessary dispatchable emissions-free resource technology is specified. There was no response to the question.
Status of Next Generation Energy Technologies
Moderator, Brandon Owens, Vice President, Innovation, New York State Energy Research and Development Authority
Dr. William Acker, Executive Director, New York Battery and Energy Storage Technology Consortium
Dr. Monterey Gardiner, Chief Engineer, National Renewable Energy Lab
Dr. Benjamin Houlton, The Ronald P. Lynch Dean, Cornell College of Agriculture and Life Sciences
Dr. Jack Lewnard, Program Director, Advanced Research Projects Agency – Energy, U.S. Department of Energy
Jeffery Preece, Director of Research and Development, Electric Power Research Institute
Julie Tighe, President, New York League of Conservation Voters
One of the significant points made during the Summit is that certain industries are willing to pay more for reliable high-quality electric power.
This broaches the idea that those companies would be willing to make investments in reliable power
It also acknowledges that certain industries recognize that a future grid that relies on wind, solar, and energy storage will not be reliable enough
Lunchtime Keynote Speaker Clean Energy Supply for Large Loads
Rich Powell, Chief Executive Officer, Clean Energy Buyers Association
He explained how large companies signal their climate virtue by claiming credits for zero-carbon generation virtually
Insights from Large Consumers of Electricity
Moderator, Hope Knight, President, CEO, and Commissioner, Empire State Development
Miranda Ballentine, Senior Advisor, Green Strategies
Amber Bieg, Lead Senior Program Manager for Global Sustainability, Micron
Moshe (Mo) Bonder, Director, Business Development Low Carbon Solutions, National Grid Ventures
Jennifer Lupo, Vice President, Energy Solutions, Supply Chain & Leasing, The Raymond Corporation
Dr. Varun Sivaram, Senior Fellow for Energy and Climate, Council on Foreign Relations
This session gets into the real reason for the Summit
In order to do justice to the commentary I need to review the meeting recording
All these companies subscribe to the belief that it is important that the electricity they use be “clean”
There was even a suggestion that to be competitive, companies demand clean energy. My impression was that affordability and reliability were weighed equally with cleanliness. That does not seem appropriate, so I need to get exact quotes
Global Perspective: Advanced Nuclear Development in Other States and Nations
Moderator, Rory Christian, Chair, New York State Public Service Commission
Nicolle Butcher, Chief Operations Officer, Ontario Power Generation
Steve Chengelis, Senior Director of Future Nuclear, Electric Power Research Institute
Dr. John Parsons, Deputy Director for Research, MIT Center for Energy and Environmental Policy Research
Dr. Andrew Whittaker, SUNY Distinguished Professor, University of Buffalo
This session addressed the status of nuclear elsewhere
Questions were posed and answers debunking common anti-nuclear talking points were included
Blueprint for Consideration of Advanced Nuclear Technologies
Moderator, John Williams, Executive Vice President of Policy and Regulatory Affairs, New York State Energy Research and Development Authority
In an earlier post I noted that the State must confront the possibility that the safety valve criteria in New York Public Service Law § 66-p (4) for unsafe and inadequate electric service, impairment of existing obligations and agreements, and unacceptable increase in arrear or service disconnections will be exceeded. There was no suggestion whatsoever that the Hochul Administration has any doubts that a zero-carbon electric grid that relies on wind and solar will work.
It seems obvious that there are large consumers of electricity that want to at least be able to say that they use 100% renewable energy. I think this summit was in no small part designed to cater to those companies. However, there were some hints that high quality electric power was enough of a concern that nuclear might be an acceptable option.
The other reason for this meeting was to broach the nuclear power option to the State. The draft blueprint is potentially a referendum on its use. I have no doubts that the anti-nuclear activists are frantically developing their plan to inundate the comment process with negative comments. The political calculus of weighing the squeaky wheel crowd relative to the reliability of the wagon realists will be interesting. Will the Administration admit that reliability and resiliency are not just slogans.
Conclusion
I remain convinced that the current Scoping Plan implementation will do more harm than good. The Energy Summit could have been the start of a correction process that might reduce the inevitable increased risks to reliability, extraordinary price increases, and significant environmental impacts but that does not appear to be the case. As I said before the Summit is another Macbeth story: “A tale told by an idiot, full of sound and fury, signifying nothing”.
Last month I described a flurry of offshore wind related news and last week I provided an update describing additional news. In my opinion these latest revelations suggest that a reassessment of the viability of offshore wind projects is in order. I did not address the costs but a couple of articles that have appeared since then do suggest that costs should also be considered in the reassessment.
I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 450 articles about New York’s net-zero transition. The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.
Overview
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. It includes an interim 2030 reduction target of a 40% reduction by 2030. Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity has to be generated be “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies. That material was used to develop the Draft Scoping Plan outline of strategies. After a year-long review, the Scoping Plan was finalized at the end of 2022. Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation.
Offshore wind developments are a key Climate Act decarbonization strategy. There is a mandated target of 9,000 MW of offshore wind by 2035. The Integration Analysis projects that offshore wind capacity will exceed 13 GW by 2040. However, there are overlooked risks to this strategy that are now becoming obvious. The fact is that the huge, proposed wind turbines have not been field tested.
Why Is Cheap Wind Power So Expensive?
Willis Eschenbach poses the cost question that is ignored by the green energy activists. First he describes the overarching Biden Administration goals released in Marh 2021:
Eschenbach is a numbers guy and was immediately suspicious:
Hmmm, sez I, seems a mite ambitious. Current US grid-connected offshore wind is a mere 0.17 gigawatts … so we’d need to do ~ 175 times as much as we’ve done to date and do it in a short six years.
So I divided it out. There are 65 months until 2030. Thirty gigawatts is thirty thousand megawatts, less the 174 megawatts in place, that’s 29,826 megawatts more total generating capacity needed.
29,826 megawatts divided by 65 months means we’d have to add offshore wind generation to the tune of 465 additional megawatts of generation capacity per month. Every month. Starting now.
Get real. That’s not remotely possible. The biggest US offshore windfarm just came on line, 132 MW capacity. To reach the White House goal, every month we’d need to build three new windfarms of that size. No way that can happen. It’s just numbers picked out of the air to gain popular support.
Then he researched the expected time to get an offshore wind farm on line:
The time from the proposal of an offshore wind farm to its grid connection typically ranges from 7 to 10 years. This timeline can be broken down into several phases:
Pre-development and Planning (1-2 years): This phase involves site identification, feasibility studies, and initial environmental assessments.
Permitting and Approvals (3-5 years): Securing the necessary permits and approvals is often the most time-consuming part of the process. This includes detailed environmental impact assessments, consultations with stakeholders, and obtaining state and federal permits.
Construction (2-3 years): Once all approvals are secured, construction of the wind farm, including the installation of turbines and subsea cables, takes place. This phase also includes the grid connection process.
Commissioning and Testing (several months): After construction, the turbines are tested, and the wind farm is gradually brought online.
The bottom line is that if a project is not well along it will not be available by 2030. He found cost information for South Fork Wind which in New York’s first offshore wind farm:
South Fork Wind just came online. This gives us a chance to look at some actual cost figures. It’s the biggest wind farm to date, a 132-megawatt addition to offshore wind. It cost $637 million.
However, Federal subsidies added $191 million to that, plus another couple of hundred million or so from Bureau of Ocean Energy Management (BOEM), the National Oceanic and Atmospheric Administration (NOAA), and the New York State Energy Research and Development Authority (NYSERDA).
Stop and consider. Some private company is building a six-hundred-million-dollar white elephant in the middle of the ocean, and it’s getting paid four hundred million of taxpayer money to do so.
So … what does the New York consumer get for all of this more than generous support?
The consumer gets wind power costing FOUR TIMES AS MUCH as the current cost of power in New York.
Stop and consider. Even when the developer gets two-thirds of the cost paid by the taxpayer, offshore wind power is still four times as expensive.
Eschenbach sums it up:
What’s next?
Well, I’m sure that what’s next is the Harris/Walz campaign will declare that they are 100% behind expensive, intermittent, unreliable wind power, and will claim that if elected, they’ll do what they already said they’d do when Ms. Harris was last elected, which was to screw the consumer and the taxpayer with the huge subsidies, tax breaks, and electricity costs of offshore wind.
Oh, yeah. They claim that the 30 GW of offshore wind will “avoid 78 million metric tonnes of CO2 emissions”. Tens of millions of tonnes, sounds impressive, right?
But IF the IPCC is correct, and that’s a big if, this will reduce the temperature in the year 2050 by …
… wait for it …
… 0.0016°C. Which is almost three-thousandths of one degree F.
Can we please pass a law saying people proposing any laws or regulations in the name of “climate change” be required to tell us (and show their math) how much actual temperature difference that will make by 2050?
All the points made in this article are direct analogies to what is happening in New York State.
Offshore Trojan Horses
Gordon Hughes from the National Center for Energy Analytics compares the subsidies for offshore wind projects to “the classic warning of the Trojan Horse legend, “Beware of Greeks bearing gifts”—in other words, the hidden dangers of accepting something that seems too good to be true.” He argues that “New York State ignored that warning when it agreed to pay very high prices for the electricity to be supplied from its new offshore wind farms—Empire Wind 1 and Sunrise Wind—located off the coast of Long Island.” He continues:
In announcing the final agreements, New York Governor Kathy Hochul triumphantly claimed that the new projects would create more than 800 jobs during the construction phase and deliver more than $6 billion in economic benefits for the state over 25 years.
Rather less emphasis was given to the fact that New York will pay an average price of over $150 per MWh (megawatt hour) for the electricity generated by Empire Wind 1 and Sunrise Wind.That’s more than four times the average wholesale price of electricity in New York during 2023–24, $36 per MWh. The total annual premium over the wholesale market price for the power from these wind farms will be about $520 million per year at 2024 prices. Over 25 years, New York ratepayers will be paying about $13 billion for alleged benefits of $6 billion.
That is not all. Thanks to tax credits, U.S. taxpayers will cover at least 40% of the costs of constructing the wind farms. At a minimum cost of $5.5 million per MW (million watts) of capacity, the total federal subsidy for New York’s two wind farms will be at least $3.8 billion.
He also evaluates the jobs and economic claims made by the Hochul Administration. He concludes that “The economic benefits of the two offshore wind farms are much lower than claimed by the governor and the jobs are, in large part, temporary assignments for professional services staff”. I would add that the temporary assignments will probably be filled by experienced staff from out of state.
Conclusion
The offshore wind proposed contracts are unsustainable. Eschenbach suggests that folks in New York should be asked” “Are you willing to pay four times the going rate for electricity for the rest of your life to MAYBE cool the globe by three-thousandths of one degree Fahrenheit a quarter century from now?” I agree and think that these facts need to be publicized because most New Yorkers have no clue that Climate Act implementation inevitably will increase costs significantly.
Lastly, note that Climate Act proponents have always argued that one of the goals was to demonstrate leadership for the energy transition. This article presents two examples where New York’s transition leadership is cited. Unfortunately, both are bad examples showing what to avoid.
On August 5 Governor Hochul announced a Future Energy Economy Summit that will “gather feedback on strategies to accelerate renewable energy deployment and explore the potential role of next generation clean energy technologies”. I described my initial thoughts on the summit and possible outcomes earlier. This post provides a pre-meeting update.
I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 450 articles about New York’s net-zero transition. The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.
Overview
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. It includes an interim 2030 reduction target of a 40% reduction by 2030. Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies. That material was used to develop the Draft Scoping Plan outline of strategies. After a year-long review, the Scoping Plan was finalized at the end of 2022. Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation.
Purpose
As I have noted previously there are many reasons why an assessment of the future energy economy is needed. Three recent reports top the list. The Public Service Commission (PSC) Clean Energy Standard Biennial Review Report found that the 70% renewable energy goal will likely not be achieved until at least 2033. The New York State Comptroller Office Climate Act Goals – Planning, Procurements, and Progress Tracking audit found that the PSC and NYSERDA implementation plans did not comprise all essential components, including “assessing risks to meeting goals and projecting costs.” The New York Independent System Operator (NYISO) 2023-2042 System & Resource Outlook described issues that threaten reliability and resilience of the current and future electric system. The Department of Public Service Proceeding 15-E-0302 may also be influencing the Governor and precipitating the need for the summit. The Business Council of New York has cited those reports and gave other reasons why it is needed. As a result, the governor said the state’s climate goals are something she “would love to meet, but also the cost has gone up so much. I now have to step back and say, ‘What is the cost on the typical New York family?’ Just like I did with congestion pricing.”
Never forget that the Climate Act has always been mostly about politics and much less about rational energy policy. I do not think that there is any question that this Summit is intended in part to gauge the reaction of favored political constituencies. I have seen several notices from activist organizations calling for people to rally at the event against “false solutions” which I believe boils down to anything other than wind, solar, and energy storage. With nuclear being at the top of the worst example of a false solution.
In my opinion, the State must confront the possibility that the safety valve criteria in New York Public Service Law § 66-p (4) for unsafe and inadequate electric service, impairment of existing obligations and agreements, and unacceptable increase in arrear or service disconnections will be exceeded. I recently recommended that those criteria be specified so that there are quantifiable targets. I hope that there are discussions that can further that requirement during the summit.
The other missing piece to date is the implementation plan for the transition. The Scoping Plan is no more than a outline list of different strategies that someone has calculated will produce the emission reductions necessary and the energy required for New York State to meet the Climate Act mandates. There is insufficient documentation to meaningfully critique the outline, and the Hochul Administration failed to respond to technical comments on the draft before it approved the Final draft. A feasibility analysis has not been produced and must be included for a credible transition plan. Better still would be a small-scale net-zero demonstration for an isolated jurisdiction that proves that an electric system can rely on intermittent wind and solar resources as the primary source of generation. I hope that there will be discussion of this concept at the Summit.
Attendance
There is still no indication who will be on the panels. In my original post I mentioned that I was worried that this would just be another dog and pony show. I cannot comment on this until I know who is on the panels.
Public participation has been restrictred The meeting announcement mentioned that there was limited seating capacity for the event but at the same time it listed statements from eight different agencies. I fail to see a connection between the Department of Health and Department of Labor with respect to energy policy. If they send representatives, then fewer affected stakeholders or members of the public can attend. I heard from several people who were waitlisted and asked a politician for help but did not get invited. Contrary to my expectations, I managed to get invited.
Summit Agenda
On August 7 when I wrote the first summary of the Summit, I included the following list of sessions that had been posted:
Welcome Remarks and Morning Keynote
State of Technology
Status of Next Generation Energy Technologies
Luncheon Keynote
Insights from Large Consumers of Electricity
Global Perspectives: Representatives from other states and nations who are pursuing advanced nuclear installations.
New Nuclear Blueprint: Vet Draft Blueprint as framework for New Nuclear Master Plan
Wrap up and Next Steps
The agenda for the meeting on September 2 has changed. The original first session “State of Technology” has been changed to “Accelerating Renewable Energy Deployment in New York State”. The original first session “State of Technology” did not seem to be all that much different from the second session “Status of Next Generation Energy Technologies” so this makes sense. However, the title “accelerating renewable energy deployment” suggests that no one is willing to conceded that building as much renewable energy as possible as fast as possible without a plan or feasibility analysis might not be a good idea.
At the PSC Zero Emissions by 2040 Technical Conference last December there were sessions devoted to pandering to real “false solutions” for a future economy. Technology shills and activists subscribe to a dream that with enough energy conservation and “smart planning” the myriad problems identified by the organizations responsible for grid reliability can be ignored. I fear that the Status of Next Generation Energy Technologies panel will include the same proposals without anyone on the panel providing contrary feedback. It is long past time for the Hochul Administration to support the concerns expressed by the PSC, NYISO and other organizations with reliability responsibilities and stop pretending that some of the cockamamie schemes suggested by irresponsible entities can provide meaningful future support.
The opening and luncheon keynote speakers will likely set the tone for the meeting. One hour is set aside for the welcome and keynote presentations. If that is nothing more than bragging about the “success” so far and excuses for the findings of the negative assessments, then I will have little hope for any meaningful results. The same holds for the luncheon speaker.
One of the issues raised by the analyses to date is that loads will increase due to electrification of everything and new “Large Consumers of Electricity”. The huge, proposed Micron chip fabrication plant is the prime example. What are the odds that representatives from those facilities will tell the truth that unless there is demonstrated path to success or an alternative backup plan that it would be madness to invest billions of dollars because there is no assurance of reliable, affordable electricity.
The last two sessions address nuclear energy projects. In my opinion, this is the primary driver of this Summit. The only jurisdictions that have significantly reduced their GHG emissions from the electric sector without relying on hydro or geo-thermal resources used nuclear. However, nuclear is unacceptable to many of the activists who are the strongest supporters of the Climate Act. I have seen several pleas for people to come to rally against the false solutions. The meeting was held in Syracuse and that just happens to be the closest city to three operating nuclear reactors. I will be shocked if there aren’t visible signs of support from staff at those facilities.
Conclusion
There are some encouraging signs that people are catching on that no matter how you feel about doing something about climate change the reality is that New York’s plan is deeply flawed. I am convinced that the plan will do more harm than good. The Energy Summit could be the start of a correction process that might reduce the inevitable increased risks to reliability, extraordinary price increases, and significant environmental impacts if there is no course correction. On the other hand, it could be another story from Macbeth “A tale told by an idiot, full of sound and fury, signifying nothing”.
Recently Rory Christian, Chair and CEO of the Public Service Commission said, “We are modernizing the grid not to just take on the challenge of adopting more renewable energy but to create greater flexibility, greater resiliency and the ability to recover more quickly in the face of these extreme climate events”. I believe that making our electric grid dependent upon weather-impacted resources is anything but resilient. Richard Ellenbogen describes one resilience-related issue in this article.
Ellenbogen is the President [BIO] Allied Converters and frequently copies me on emails that address various issues associated with the Climate Leadership and Community Protection Act (Climate Act). I have published other articles by Ellenbogen including a description of his keynote address to the Business Council of New York 2023 Renewable Energy Conference Energy titled: “Energy on Demand as the Life Blood of Business and Entrepreneurship in the State -video here: Why NY State Must Rethink Its Energy Plan and Ten Suggestions to Help Fix the Problems” and another video presentation he developed describing problems with Climate Act implementation. He comes to the table as an engineer who truly cares about the environment and as an early adopter of renewable technologies going back to the 1990’s at both his home and business two decades ago.
Solar Inverter Resiliency Issue
Joanne Nova recently identified a major issue with Behind-the-Meter (BTM) solar. The article discusses the fact that all new solar inverters are internet connected and many of them are made in China. Last October it was found that they may have communication vulnerabilities where they could be turned off simultaneously. She writes:
What if a few gigawatts of solar power disappeared without a warning or a cloud in the sky?
Imagine a hostile force had control of half your national power generation at lunchtime and could just flip a switch to bring you to your knees? Or how about a crime syndicate wanting a ransom paid by 5 pm?
Her article goes on to describe the problem in more detail. Nova quotes Daniel Croft, CyberDaily (October 2023):
Cyber Security CRC chief executive Rachael Falk said… that an attack on the solar grid could spark a “black start” event, which could result in the entire power grid going down. … “This could bring down an entire power grid, and it could take a week to recover,” she said.
It turns out that security vulnerabilities have been identified in the Netherlands and the US. In Australia half of the grid power can come from solar panels at noon. As a result, Nova suggests that the solution is to test and possibly replace inverters and fix the software.
Ellenbogen recently distributed an email addressing this issue that is quoted below. His solar panels have inverters too. He writes:
This is something that hadn’t occurred to me as my inverters were older and only the power monitor was web connected. I recently replaced the inverters at my house and those are web connected but everything is behind a firewall. The inverters are also, in theory, American made. It did occur to me when I was purchasing thermostats for the factory. I will not buy a NEST or Honeywell internet connected thermostat because they all can be centrally controlled. A few years ago, all the NEST thermostats in the US went offline. They said that it was a computer glitch in their system, but was it? If you don’t remember it, don’t try to Search for it. It’s as though they scrubbed the internet of the event. Google owns NEST. You can find more information with Yahoo. I remember it vividly because it confirmed my worst fears of why I didn’t buy one in the first place.
Ellenbogen explains that this is a problem:
This is a huge issue as, according to the NYISO Gold Book (Table below), there will be 4560 Megawatts at, maximum output, of BTM solar in NY State as of next year and the state is becoming very reliant on it. If a significant portion of that was shut down simultaneously on a hot day at solar noon, the system would find it extremely difficult to respond to maintain stability. If more of the present generation fleet is retired, the NYISO would find it almost impossible to ramp up generation quickly enough to offset the drop in generation. It would be the equivalent of removing the entire nuclear fleet and one-third of the hydro generation from the system in an instant.
He continues:
While many of the panels may not have that vulnerability, in the future they might and there will be even less backup generation to offset that. With renewable projects under extreme financial pressure, the easiest place to cut corners would be in cyber-security because it wouldn’t be noticed until something happened. In light of the article, it could also be the most hazardous place to cut corners.
Ellenbogen summarized:
When I was speaking at the Pelham Picture House last November, someone got up and said that they were glad Indian Point closed because it was a target of a terror attack. That was last decades terrorist technique. The new danger is hackers, or even worse, state actors that have implanted ticking time bombs throughout our energy infrastructure. This is not being paranoid. The Dutch hacker got into 4 million solar arrays in 150 countries.
Conclusion
Ellenbogen concluded his note saying “The question now is, what are the ISO’s and regulators around the country going to do about it?
As far as I can tell the issues that might affect resiliency like this are not on the radar of the people in charge of the Climate Act transition. I am sure staff are aware of the problem described but I am also sure that there is no mandate in New York to minimize this risk. Christian’s claim that adopting more renewable energy will provide greater resiliency is an empty slogan.
Note – This post was revised to clarify my recommendation that the Climate Action Council should propose affordability and reliability criteria to explain the Council should work with the PSC and NYISO for consideration in a stakeholder process similar to the development of the Scoping Plan on 8/21/24.
I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 450 articles about New York’s net-zero transition. The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization have been associated with, these comments are mine alone.
Overview
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. It includes an interim 2030 reduction target of a 40% reduction by 2030. Two targets address the electric sector: 70% of the electricity come from renewable energy by 2030 and a requirement that all electricity generated be “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies. That material was used to develop the Draft Scoping Plan outline of strategies. After a year-long review, the Scoping Plan was finalized at the end of 2022. Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation.
Recently three reports have come out that raise specific concerns about Climate Act implementation: schedule ambition, costs to implement, and electric system reliability risks.
The New York State Comptroller Office released an audit of the NYSERDA and PSC implementation efforts for the Climate Act titled Climate Act Goals – Planning, Procurements, and Progress Tracking (“Comptroller Report”). The audit found that: “The costs of transitioning to renewable energy are not known, nor have they been reasonably estimated”.
The Public Service Commission (PSC) recently released the Clean Energy Standard Biennial Review Report (“Biennial Report”) that compares the renewable energy deployment progress relative to the Climate Act goal to obtain 70% of New York’s electricity from renewable sources by 2030 (the 70% goal). It found that 2030 goal will likely not be achieved until 2033.
The New York Independent System Operator (NYISO) 2023-2042 System & Resource Outlook (“Resource Outlook”) described issues that threaten reliability and resilience of the current and future electric system. The report described current and future challenges for the electric system. The findings suggest that there will be significant reliability risks for the Climate Act transition.
Business Council of New York Statement
BCNY released their statement because it represents concerns expressed by various impacted businesses across New York about “the achievability of key Climate Act mandates and what that means for the future reliability and cost of the state’s energy system.” The statement calls for the “state to identify and make necessary mid-course corrections based on updated information and significant economic and market changes.” The statement argues that “These steps are essential to avoid significant unintended impacts on the well-being of New Yorkers and on the state’s economic competitiveness.” They note that “Importantly, we believe that New York can continue to be a leader in state-level climate policy, but it needs to take a workable, affordable approach to meeting its energy and emission goals.”
The statement notes that the Climate Act implementation process has not provided a “comprehensive, publicly accessible assessment of implementation costs, the comparative costs of policy alternative programs, and the impact of new policies on residential and business energy consumers.” This echoes the Comptroller Audit finding of inadequate cost information.
The statement also describes concerns about “the practical achievability of key CLCPA provisions and the consequences of basing major policy decisions on unworkable statutory mandates”. The Biennial Report notes that one of the statutory mandates will likely not be achieved.
The statement takes pains to note that they are not opposed to many of the proposed control strategies. However, “the state needs to ensure that its push toward emission reductions and the electrification of major sectors are technically and economically achievable.” This is one of the findings of the Resource Outlook.
The statement argues that “implementation challenges call for a reassessment of the underlying statutory mandates.” It notes that they want to work with the Administration, state legislators, and other climate stakeholders to address the issues raised. However, a specific path forward is not proposed. I propose such a path forward below.
Recommendation for Climate Act Review
Although it has received little notice, there is a provision for renewable energy programs that should be the foundation of the recommended reassessment. The Biennial Report refers to New York Public Service Law § 66-p (4). “Establishment of a renewable energy program” that states: “The commission may temporarily suspend or modify the obligations under such program provided that the commission, after conducting a hearing as provided in section twenty of this chapter, makes a finding that the program impedes the provision of safe and adequate electric service; the program is likely to impair existing obligations and agreements; and/or that there is a significant increase in arrears or service disconnections that the commission determines is related to the program”.
The essential first step for reassessment consideration is definition of the safety valve criteria in §66-p (4). What are the criteria for unsafe and inadequate electric service, impairment of existing obligations and agreements, and unacceptable increase in arrear or service disconnections? In my opinion, the Climate Action Council with the PSC and NYISO should propose suitable criteria for consideration in a stakeholder process similar to the development of the Scoping Plan.
The next step would be to provide the data necessary to determine the criteria for unsafe and inadequate electric service, impairment of existing obligations and agreements, and unacceptable increase in arrears or service disconnections. Given this legal provision it is appropriate that the information be tracked somewhere. The BCNY statement recommended an “accessible and understandable “dashboard” of the state’s climate change efforts, including a comprehensive accounting of direct state spending and state “directed” spending, the source of funds and their use, and the impact of these expenditures on achieving GHG emission reduction and renewable energy production goals.” The §66-p (4) criteria parameters should be included in the dashboard.
Conclusion
The three agency reports raise legitimate reasons to be concerned about the mandates and schedule of the Climate Act. The BCNY statement echoes those concerns and recommends a review and consideration of mid-course corrections. There is a legal provision to “temporarily suspend or modify the obligations” of a renewable energy program that defines criteria consistent with the concerns raised by the BCNY, the PSC Biennial Report, the Comptroller Report audit of Climate Act implementation, and the NYISO Resource Outlook. If the §66-p (4) criteria are explicitly defined and compared to observed data, it would form the basis for a pragmatic review of the Climate Act.
In a recent article describing a new category of generating resources called Dispatchable Emissions-Free Resources (DEFR) I noted there still are people who maintain that existing technologies—led by solar and wind—can solve the climate crisis. A recent op-ed titled “With New York’s climate action goals in question, governor’s comments on future role of nuclear power worry environmental advocates” at Riverhead Local provides an example.
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 article do not reflect the position of any of my previous employers or any other company or organization I have been associated with, these comments are mine alone.
Overview
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. It includes an interim 2030 reduction target of a 40% reduction by 2030. Two targets address the electric sector: 70% of the electricity come from renewable energy by 2030 and a requirement that all electricity generated be “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies. That material was used to develop the Draft Scoping Plan outline of strategies. After a year-long review, the Scoping Plan was finalized at the end of 2022. Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation.
Three recent reports all have suggested that implementation of the Climate Act is not going as planned and that reassessment is necessary. The Public Service Commission (PSC) Clean Energy Standard Biennial Review Report found that the 70% renewable energy goal will likely not be achieved until 2033. The New York State Comptroller Office Climate Act Goals – Planning, Procurements, and Progress Tracking audit found that the PSC and NYSERDA implementation plans did not comprise all essential components, including “assessing risks to meeting goals and projecting costs.” The New York Independent System Operator (NYISO) 2023-2042 System & Resource Outlook described issues that threaten reliability and resilience of the current and future electric system.
Dispatchable Emissions-Free Resources
One of the most important reliability issues is the need for a new category of generating resources called Dispatchable Emissions-Free Resources (DEFR) necessary for a future grid that depends upon wind, solar, and energy storage resources. Reputable analyses of the future New York electric system agree that new technologies are necessary to keep the lights on during periods of extended low wind and solar resource availability. Despite the overwhelming consensus of the organizations responsible for keeping the lights on that DEFR is needed there are people who believe otherwise.
One such person is Karl Grossman. According to his bio published with the op-ed:
Karl is a veteran investigative reporter and columnist, the winner of numerous awards for his work and a member of the L.I. Journalism Hall of Fame. He is a professor of journalism at SUNY at Old Westbury and the author of eight books.
The basis of Grossman’s belief is Dr. Mark Z. Jacobson’s 2023 book “No Miracles Needed: How Today’s Technology Can Save Our Climate and Clean Our Air.” Grossman interviewed Jacobson and quoted him as saying: “Whether New York can reach the 70% goal by 2030 is a matter of social and political willpower. It is not a question of technology or economics.”
Grossman describes Jacobson’s claims, but I am not going to respond to those claims in detail. In my recent article about DEFR I explained why I know that Jacobson is wrong. In brief, I found six analyses describing the need for new technology: the Integration Analysis, New York Department of Public Service (DPS) Proceeding 15-E-0302 Technical Conference, NYISO Resource Outlook, Richard Ellenbogen, Cornell Biology and Environmental Engineering, and Nuclear New York. Jacobson and his protégé Dr. Robert Howarth frequently refer to their “peer-reviewed” work as validation but neglect the rebuttal peer-reviewed responses to their work and the many other peer-reviewed analyses that show DEFR is needed. Finally, I also found three books that refute the Jacobson book and his claims that the energy transition can be accomplished with no new technologies at low cost with large benefits.
Environmentalist Responses
I recently noted that Governor Hochul seems to be floating the idea that reassessment is necessary. Grossman noted that Newsday headlined a two-page spread two weeks ago: “Hochul Says New York Won’t Meet 2030 Climate Goal.” In the article, Newsday cited Gov. Kathy Hochul’s comments in an Albany Times Union newspaper podcast.
“We’re gonna get to our goals, but if we miss it by a couple of years—which is probably what’ll happen—the goals are still worthwhile,” Hochul said. But we have to think about the collateral damage of all of our major decisions… either mitigate them or you have to rethink them.” In the podcast, she also termed herself as “a staunch environmentalist.”
The Grossman op-ed described how environmentalists are reacting. Not surprisingly they still claim that the state has not done enough on renewable energy.
Judith Enck, for seven years regional administrator of the U.S. Environmental Protection Agency for an area that includes New York State and before that deputy secretary for the environment for two New York governors, said delaying the 70% goal “is a terrible decision by the governor. I hope she revisits it. We’re in a climate crisis. She says things have changed—and they have: the climate crisis has gotten worse. The governor should look at ways to accelerate meeting the goals, not delaying them.” Renewable energy, she said, is not a priority for state government.
Liz Moran, New York political advocate for the group Earthjustice, said: “The administration has been appearing to slow walk it from the jump. It’s a fear-based approach rather than a brave and bold approach that we need in the face of this crisis.”
“We’re certainly not ready to wave the white flag,” said Julie Tighe, president of the New York League of Conservation Voters.
Environmental advocates such as these ignore or disparage analyses such as the NYISO 2023-2042 System & Resource Outlook that describes issues that threaten reliability and resilience of the electric system. I recently described how the proposed transition that relies on wind and solar exacerbates their concerns. Unfortunately, the document is full of technical jargon and politically correct terminology, so the full implications of this analysis are not readily apparent. NYISO cannot bluntly say this cannot work as proposed on the schedule mandated but that is the underlying message.
Environmental advocates also ignore New York’s role in this global problem. Using GHG emissions data from Our World In Data I looked at recent NY emissions with global data. In 2021, NYS GHG emissions (GWP-100) were 247 million metric tonnes (MMT). GHG emissions from China were 13,774 MMT and from India were 3,879 MMT. The increase in emission from 2020 to 2021 were 498 MMT in China and 265 MMT in India. New York emissions will be supplanted by emissions from China or India in less than one year. Overall, New York’s emissions are less than a half a percent of global emissions. This does not necessarily mean that we should not do something, but it does mean that meeting the arbitrary goals of the Climate Act will not have a meaningful impact on global warming impacts.
Grossman’s op-ed goes on:
Meanwhile, Politico published a report in May headlined “New York policymakers thaw on nuclear energy.” The piece by Marie J. French began: “Gov. Kathy Hochul has cracked the door open to the potential for new, small nuclear power plants as a way for the state to try to meet its ambitious climate coals.”
The article told of this happening “at a private dinner with environmentalists April 29, according to two attendees who spoke on the condition of anonymity because of the private conversations. It’s not the first time that her administration has raised the idea. One of her top aides suggested as much earlier this year.”
Enck said last week: “I think the governor even speculating on nuclear power in New York is trouble.” Enck spoke of how decades were spent in “shutting down the Indian Point nuclear plants” 25 miles north of New York City. We “shouldn’t promote the same thing again.”
Nuclear is the only proven DEFR technology that can be expanded sufficiently to fulfill the energy requirements of the Climate Act goals. Nuclear energy generates zero-emissions electricity, provides firm power that does not require supplemental ancillary transmission support, has low land-use requirements, and requires less transmission development than wind and solar. The dangers of nuclear are consistently over-hyped. Bill Gates has pointed out that “nuclear energy, in terms of an overall safety record, is better than other energy.” It is a mystery to me why any environmental advocate continues to harbor this irrational fear of nuclear power and consider its use troubling,
Discussion
Grossman concludes:
The central message of Jacobson’s “No Miracles Needed” book is how existing technologies—led by solar and wind—can solve the climate crisis, and he emphasizes how nuclear power is not needed and also investing in it would obstruct a transition to green renewable energy.
I conclude Grossman has naively backed the wrong source for this op-ed. Even the Climate Act Scoping Plan acknowledges the need for the new DEFR technology directly contradicting Jacobson’s primary claim. The Scoping Plan also contradicts all the other cost, schedule, and technology requirement claims made by Jacobson. The NYISO 2023-2042 System & Resource Outlook findings are consistent with the Scoping Plan. In my opinion, the arguments of anyone who does not face any repercussions if proven wrong should be given much less weight than arguments from those who have responsibilities.
With regards to the nuclear power recommendations Grossman is also wrong. The article does not provide any rationale for not developing nuclear other it would obstruct the transition to green renewable energy. The fact is that France successful cut its GHG emissions using nuclear power, but no jurisdiction has managed similar electric sector reductions relying on wind and solar. As a utility meteorologist with over 40 years’ experience I think the variability of wind and solar is an insurmountable challenge for a reliable electric grid. In my opinion, one of the advantages of nuclear is that it would preclude the need for “green renewable energy”.
Conclusion
On August 5 Governor Hochul announced a Future Energy Economy Summit that will “gather feedback on strategies to accelerate renewable energy deployment and explore the potential role of next generation clean energy technologies”. Grossman’s op-ed is the first article I have seen to suggest that nuclear power should not be one of the next generation clean energy technologies. In my article describing the announcement of the summit I noted that it will be interesting to see how legislators, the Big Green NGOs, climate activists, and the renewable energy shills react to nuclear power. Based on this article it appears Big Green NGOs and climate activists will not acknowledge that nuclear and other pragmatic considerations are necessary for the Climate Act implementation.
The New York Independent System Operator recently released the 2023-2042 System & Resource Outlook (“Outlook”). It examines “a wide range of potential future system conditions and compares possible pathways to an increasingly greener resource mix.” This post summarizes the key findings of Appendix E: New York Renewable Profiles and Variability.
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 article do not reflect the position of any of my previous employers or any other organization have been associated with, these comments are mine alone.
Overview
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. It includes an interim 2030 reduction target of a 40% GHG reduction by 2030, a 70% electric system renewable energy mandate by 2030, and a requirement that all electricity generated be “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies used to reduce greenhouse gas emissions. That material was used to develop the Draft Scoping Plan outline of strategies. After a year-long review, the Scoping Plan was finalized at the end of 2022. Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, Public Service Commission orders, and legislation.
The Outlook examines a wide range of potential future system conditions and compares possible pathways to an increasingly greener resource mix. By simulating several possible future system configurations and forecasting the transmission constraints for each, the NYISO:
Postulates possible resource mixes that achieve New York’s public policy mandates, while maintaining reserve margins, and capacity requirements;
Identifies regions of New York where renewable or other resources may be unable to generate at their full capability due to transmission constraints;
Quantifies the extent to which these transmission constraints limit delivery of renewable energy to consumers; and
Highlights potential opportunities for transmission investment that may provide economic, policy, and/or operational benefits.
Renewable Resource Characterization
The information presented in Appendix E was developed by DNV. They modeled “long-term hourly simulated weather and generation profiles for representative offshore wind (OSW), land-based wind (LBW), and utility- scale solar (UPV) generators” in two phases. Initially DNV assessed the OSW production for seven locations. In the second phase, the analyzed LBW and UPV generation for nearly 80 LBW and UPV locations each throughout the state. The projections were used to “determine the zonal or county aggregate net capacity factor (NCF) profiles that the NYISO used as inputs for this Outlook.
The goal of this work is to estimate the energy production of LBW, OSW, and solar—both UPV and behind the meter (BTM) PV. The report explains:
The production amounts of each type of generation are considered when determining the representative days selected for the capacity expansion model and are used as hourly generation shapes in the production cost model for this Outlook. The NYISO acknowledges that advances in renewable energy technology are continuously occurring and can lead to improved performance among generators built in the later years of the study period. Offsetting this effect, however, is that better sites may be utilized before less favorable resource sites leading to older technology on more favorable sites. Moreover, once installed, equipment performance can degrade over time. While these impacts are known, the exact magnitude of the impacts is difficult to quantify. Accordingly, this Outlook does not make any assumptions about improved performance of renewable generators built in the later years of the study period or performance degradation of resources once in operation.
The NCF data can be combined with hypothetical wind and solar projects sited throughout the state and in the New York Bight on the Outer Continental Shelf to estimate the generation production that represents actual historical weather conditions. As the report notes: “The increasing weather dependent supply resources and electrified load will necessitate more attention be paid to the modeling of spatiotemporally correlated renewable generation and loads in long-term planning studies.”
These data can be used in multiple ways: “Resource production profiles can be characterized in various ways to describe interannual variability in, for example, resource output, hourly ramps, variability, and duration of low output.”
Metrics for Characterizing Renewable Production
There is a lot of information in this report that can be used to describe how renewable energy production will be affected by weather. For example, Figure 1 shows the interannual variation for the net capacity factor of land-based wind (LBW), utility-scale solar photovoltaic (UPV), and offshore wind (OSW). Net capacity factor (NCF) is the annual amount of electrical energy produced divided by the maximum potential energy that could be produced. This parameter is used to determine how many resources need to be built to provide sufficient generation production to supply the necessary load. The Integration Analysis assumed a single capacity factor value for the three generating resources and these figures show that a proper analysis of resource requirements needs to address the variability shown.
Figure E-1: Annual Capacity Factor of UPV, LBW, and OSW: 2030 Contract Case
I derived the latest Integration Analysis capacity factors from the total capacity (MW) and annual energy production (MWh). I calculated that the 2040 projected LBW capacity factor was 37%, OSW capacity factor was 47%, and the solar capacity factor was 21%. I eyeballed the capacity factors in Figure E-1 for Table 1 that lists annual capacity factors. The projected mean annual capacity factors were less than the Integration Analysis for LBW and OSW while the solar projection was more than the Integration Analysis value. This means that the wind generation capacity resources projected by the Integration Analysis are insufficient to meet the average resource availability. It would be much easier for electric resource projections if planners only had to worry about average resource availability, but to provide electricity all the time planners need to consider the worst-case scenario. The minimum average annual capacity factor over this 22-year period was less than the Integration Analysis projections for all three resource categories. This means that the Integration Analysis underestimates the average generating resources needed and thus the costs of implementation.
Table 1: Annual Capacity Factors
The figures in Appendix E include results for the entire 22-year period of record and 2018. The NYISO report supports their resource adequacy planning efforts that focus on an individual year, in this case 2018. Appendix E notes that “understanding the variation in production over the years by comparing the annual capacity factors by technology type provides an initial indication of the energy impact of the choice of 2018 relative to other years in the DNV database.” For this article, I only present the combined 2000-2001 results and have modified the following quoted text to exclude any references to 2018. The Appendix describes the characterization approach:
Renewable production profiles can be characterized on a more granular level by examining statistics within individual month and hour bins. Commonly referred to as “twelve by twenty-fours” (12×24), this calculation allows the diurnal and seasonal contributions of different renewable generation types to be accessed from the hourly timeseries. Further comparison of the net load provides insight on when and how much other supply resources are needed across the year and when there is a potential for renewable oversupply (i.e., negative net loads).
The graphics below present the hourly and monthly average NCF by technology type and present the NCF of the capacity weighted aggregation of UPV, LBW, and OSW. The figures show the averages over the 22-year period (2000-2021)
A number of salient features of the input data can be observed using this methodology. The concentration of UPV generation in the summer and mid-day hours is clearly observed, as well as comparably lower UPV generation in the winter months due to shorter daytime periods. In the shoulder months, UPV production is slightly higher in the spring relative to the fall. On the other hand, production of both LBW and OSW is concentrated on average to the winter evening hours, with this impact more pronounced for OSW than LBW. Across the board, OSW produces at higher NCF levels than LBW. The combined impact of the wind and UPV display clear features of each of the technologies with the highest overall renewable production during the summer mid-day. The lowest production persists during the evening hours in the summer and early fall with fleet capacity factors under 20% on average.
Electric resource planners need to consider these observations in their capacity resource projections. As noted previously, the planners cannot rely on projections based on annual averages because generation must always match load. The proposed dependence wind and solar means the resource availability considerations described above must be considered for future resource projections. These results are the most comprehensive estimates for New York to date. In short, they make all the Integration Analysis projections obsolete.
Figure E-2: “12×24” Average Net Capacity Factors for UPV, LBW, OSW, and Combined: 2030 Contract Case
The Appendix explains why this information is important:
By comparing renewable energy supply to the timing of the expected load, the remaining supply resources needed to serve demand (e.g., hydro, nuclear, imports, fossil-fuel and other generation, storage, and DEFRs) can be better understood. Using a similar framework to simplify the comparison, the figure below displays the variability in net load by displaying 12×24 charts for average, minimum, and maximum net load in GW. The figure displays net load over the 22-year period (assuming the same load in each year but varying the renewable energy shapes).
The Appendix goes on to describe an alternate way to present the data that focuses on supply requirements:
Average net loads are highest in the summer and winter evening hours after sunset. This indicates the need for additional supply beyond the assumed wind and solar resources to meet expected demand. Net loads are lowest during the mid-day spring and fall months when loads are lower and renewable energy production is generally high. The minimum net loads, which may be negative, provide an indication of the minimum generation levels needed from the remaining fleet when loads are lowest and renewable output is high. Negative net loads indicate intervals where the renewable energy supplied by wind and solar resources exceeds the demand on the New York Contral Area and coincides with times of low average net load during the shoulder mid-day periods, primarily due to the concentration of solar output.
Figure E-3: “12×24” Average, Minimum, and Maximum Net Loads (GW): 2030 Contract Case
The Appendix briefly describes how these observations could be addressed:
Storage resources would potentially be able to shift a significant amount of this excess mid-day renewable output during the day or across a few days. However, storage resources may not be fully capable of economically addressing the seasonal mismatch between times of low and negative net loads in the shoulder seasons and high positive net loads during peak season after the sun goes down. This impact is only exacerbated as weather-dependent electrified load (e.g., building heating) increases the potential peak load sensitivity of the system during temperature or weather extremes. This results in the requirement for even further supply resources to meet the larger net load peak without significant efforts to mitigate the potential peak load growth impacts.
After a discussion of ramping rate implications, the Appendix goes on to address low renewable resource availability ramifications and the analysis performed:
Characterization of the magnitude and frequency of low output intervals of renewable output is an important consideration when analyzing the impact of serving demand during longer duration events of low renewable production. Different output levels and durations must be considered, and one threshold must be selected to perform this analysis on an input renewable generation profile. For this analysis, low output events, or lulls, are defined as continuous durations where the production is below the identified threshold. Events are then binned by the duration of the number of hours for each event for each year. This analysis was performed for LBW, OSW, and a combination of LBW, OSW, and UPV to examine the impact of the combined assumed renewable fleet on the number of lulls of a given set of duration bins.
This issue has always been my biggest concern, so I was glad to see it addressed. Note, however, that the threshold selected makes all the difference in the results. The analysis presented uses a 10% NCF threshold which means that 90% of the resource capacity is unavailable. The question is what threshold should be used. This is a new planning criterion that should be watched carefully. The results show:
Figure E-6 presents the results of reviewing the LBW profiles over the 2000-2021 period on an annual basis assuming a 10% hourly NCF threshold (i.e., lull hours are defined as those with a NCF less than 0.1). The x-axis displays the event duration bins (e.g., “[1,4]” collect all one-to-four-hour events while “97+” collects all events that are 97 hours or longer) except for the last bin that displays the longest duration event in hours during the year. Each bar within a bin going from left to right represents the number of events in each duration bin for one year from 2000-2021, with 2018 labeled with black bars and the corresponding number of events. The dashed line across each bin shows the average value of the number of lulls (and maximum duration) across the 22-year period. The analysis shows that, in 2018, the longest event where LBW output stayed below 10% of capacity across New York was 83 hours long and there were 12 events between 25 and 48 hours long. The chart also shows that there were less short duration LBW lull events in 2018 relative to the 22-year average but that there were in general more lulls longer than one day in duration than in a typical year.
The Appendix also presents results for OSW:
Comparison of the DNV renewable production shapes shows that LBW has more and longer wind lulls than the OSW shapes. This is expected, in part, as OSW has higher average capacity factors as shown in the monthly-hourly analysis earlier in this section.
The combination of resource lulls is most useful for planning:
Combining the LBW, OSW, and UPV shapes on a capacity weighted basis and performing the same analysis results in less lulls of all durations because the diversity in timing of production from the different generation types has the effect removing or splitting longer lulls into more shorter events.
I modified Figure E-8 to highlight the worst-case duration of a combined lull as shown by the red line. It appears that there was a 36 period when 90% of the OSW, LBW and UPV resources were unavailable. Keep in mind that light winds are associated with high-pressure system weather that also correlates highly with extreme cold and hot temperatures that mean high electric loads. This has resource planning ramifications that must also be addressed.
The Appendix concludes:
Analysis of the input renewable and load shapes over the course of a single year can provide significant information about when additional resources will most likely be needed to provide additional supply to the system. Using the 22-years of simulated renewable NCF profiles applied to the zonal capacity mix in the 2030 Contract Case provides significant insight into general system characteristics and potential needs for additional supply resources. Comparative review of these metrics for the 2035 Lower and Higher Demand scenarios in the Policy Case shows largely similar features across all of the discussed metrics but with larger impacts due to the higher loads and slightly larger renewable builds present in the 2035 Policy Case relative to the 2030 Contract Case.
Discussion
The NYISO has started to incorporate weather variability in future planning for an electric system that depends on wind and solar resources. I want to make two points.
The current NYISO resource adequacy planning process is based on decades of experience with the existing system that relies on fossil, nuclear, and hydro resources. Over the years, the resource planners have developed a good idea how much surplus capacity is needed on the system to ensure that when the load peaks that there will be adequate generation in place to service the load. Those projections are based on the fact that outages across the system are not correlated for the most part. These data show that there are frequent periods when all of the wind and solar resources are expected to provide much lower output than their rated capacity. It appears that planners must account for a 36 hour period when all the LBW, OSW, and solar combined provide less than 10% of their rated capacity. This is a huge challenge.
The second point is that the developing adequate resource to backup the wind and solar resources during these extended low resource periods must now account for weather variability. These results are based on a 22-year data set and is analogous to the 100-year flood metric. For flood management planning, analysts use the 100-year flood probability of a certain flood height to develop a resilient plan for the flood plain. Future electric resource planning is going to have to develop something similar. I am concerned that while the ramifications of a flood that exceeds the planning criteria are bad, the effects of inadequate electric power when New York has electrified homes, businesses, and transportation will be catastrophic.
I have long advocated a similar analysis that expands on this one. Because New York depends on imports from adjoining regional transmission operators the geographical scope should be expanded to cover those regions. The period of record should be as long as possible. There are data available that could be used to extend the analysis to 1950. Even if the resource planning is based on such a study, the over dependence upon weather related resources means that eventually there will be an even worse resource lull that causes a catastrophic blackout. There is a limit to how much society can invest to avoid such an outcome, and I think that dynamic will inevitably lead to disaster.
In addition, note that these results show that the Integration Analysis projections for future wind and solar capacity are underestimated. The net capacity factors used are greater than the observed capacity factors. This is another aspect of the state plan that needs to be reconciled with the most current NYISO work.
Conclusion
These results highlight the complications that weather-dependent electric grid planning must address. Given the magnitude of the planning challenges I am not optimistic that planners will be able to anticipate all the effects to prevent reliability crises. The results also destroy the myth that the wind and solar future grid will be more resilient than the existing grid. That is just an empty slogan with no basis.
This is an intriguing development. On August 5 Governor Hochul announced a Future Energy Economy Summit that will “gather feedback on strategies to accelerate renewable energy deployment and explore the potential role of next generation clean energy technologies”. In this post I offer some thoughts on the reason for the summit and possible outcomes.
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 article do not reflect the position of any of my previous employers or any other organization that I have been associated with, these comments are mine alone.
Overview
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. It includes an interim 2030 reduction target of a 40% GHG reduction by 2030, a 70% electric system renewable energy mandate by 2030, and a requirement that all electricity generated be “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies used to reduce greenhouse gas emissions. That material was used to develop the Draft Scoping Plan outline of strategies. After a year-long review, the Scoping Plan was finalized and approved by the CAC at the end of 2022. Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, Public Service Commission orders, and legislation. However, recent reports have raised problems with the implementation process and Hochul has threatened to pause the process due to costs.
Announcement for Clean Energy Technology Summit
The press release for the Clean Energy Technology Summit stated:
Governor Kathy Hochul today announced New York State will convene global experts to discuss the role of next generation clean energy technologies and strategies to accelerate renewable energy deployment while collectively supporting economic development in New York. The “Future Energy Economy Summit,” to be held on September 4-5, will convene relevant state agencies and authorities, global and federal leaders, power producers, technical experts, labor groups, environmental groups, business groups and other interested stakeholders. The summit will explore how next generation clean energy technologies can support the establishment and expansion of commercial and industrial enterprises, as well as how the state can accelerate the deployment of dispatchable emissions-free resources that will be needed to bolster its notable and ongoing efforts to scale renewable energy.
Note that the summit is only one day. Registration is the only activity available the evening before the meeting. After the obligatory political bragging that I am not going to include, the press release went on to say:
The Governor has appointed New York State Energy Research and Development Authority (NYSERDA) Board Chair, Richard Kauffman, to serve as chair of the summit with contributions from leadership and staff from NYSERDA, the Department of Public Service (DPS), Empire State Development (ESD), New York Power Authority (NYPA), Department of Environmental Conservation (DEC), Department of Health (DOH), Division of Homeland Security and Emergency Services (DHSES) and Department of Labor (DOL).
I find it troubling that there will be so many agencies involved in the summit. The heavy involvement of different agencies suggests that his may end up being no more than a dog and pony show to highlight the Administration’s commitment to fighting climate change. Among the real issues that have to be addressed are those raised at last December’s technical conference entitled Zero Emissions by 2040 held as part of the Department of Public Service Proceeding 15-E-0302. The conference confirmed the need for a new category of generating resources called Dispatchable Emissions-Free Resources (DEFR) but there hasn’t been any public progress addressing this resource. The problem is DEFR technologies simply do not exist yet on a commercial scale, and it is very unlikely that the they will be available when needed to meet the arbitrary Climate Act schedule. There are hints in the next paragraph that the summit might be intended to address this problem.
New York State anticipates major growth in electric demand in coming years driven by historic economic development projects and the increased adoption of electrification technologies in the building and transportation sectors. Building upon New York State’s unprecedented and continued commitment to scaling up and accelerating renewable energy such as offshore wind, hydropower, solar and onshore wind statewide, a key component of the summit will be gathering further input on technologies including next generation geothermal, advanced nuclear, clean hydrogen, long duration energy storage, as well as other emerging technologies. The input received will inform State strategies in the use of these technologies to support economic development across the state and provide context for the Public Service Commission (Commission) proceeding that is investigating technologies that can help meet the 2040 zero-emissions electricity system target established through New York’s Climate Act.
The technologies mentioned, next generation geothermal, advanced nuclear, clean hydrogen, and long duration energy storage are all potential DEFR solutions. The following paragraph reinforces the idea that the summit is intended to address the need to implement currently unavailable DEFR technologies.
NYSERDA and DPS staff are currently developing technology and economic studies of diverse generation technologies that could complement the state’s wide scale deployment of renewable energy and play an expanded role in a decarbonizing economy. These studies will gather information and examine technologies ranging from small modular nuclear reactors to long-duration energy storage technologies to grid-forming inverters. The studies will complement the outputs from this summit and inform the State’s options for future generation including through the Commission’s proceeding.
So far the NYSERDA and DPS studies like the Scoping Plan are long on ambition and short on facts. Worse, there hasn’t been any meaningful attempt to engage stakeholders by responding to comments submitted. I worry that this summit is part of the packaging for whatever the Administration has already decided to do. We can only wait and see what happens at this meeting.
Unfortunately, resolving the technological challenge for DEFR development and implementation is not the only implementation problem. The green new deal aspect of the Climate Act mandates investments in disadvantaged communities which complicates implementation. While I agree that all the factors described in the following paragraph are important, I am worried that there is no mention of a feasibility analysis. The presumption of the state is that once they set a goal, it will happen despite the lack of any evidence that it is possible.
This summit will address advancing key factors to develop these technologies’ supply chain investments in New York, workforce opportunities, and how these investments can be leveraged to support large load growth and low-carbon economic development across New York while benefiting disadvantaged communities. The summit will also inform the development of a blueprint to advance issues and considerations for the deployment of advanced nuclear power generation and potentially leverage federal funding programs, including but not limited to, nuclear planning grants.
Summit Agenda
The only information on the summit itself is the following list of sessions:
Welcome Remarks and Morning Keynote
State of Technology
Status of Next Generation Energy Technologies
Luncheon Keynote
Insights from Large Consumers of Electricity
Global Perspectives: Representatives from other states and nations who are pursuing advanced nuclear installations.
New Nuclear Blueprint: Vet Draft Blueprint as framework for New Nuclear Master Plan
Two of the five panel discussions at the daylong conference will be focused on “new nuclear” technology such as small advanced nuclear reactors, according to a draft agenda.
The meeting also will include discussions about accelerating the deployment of renewable power sources like wind and solar. And there will be a focus on developing new power sources that can be dispatched when renewable power falls short.
Knauss interviewed Doreen Harris, president and CEO of the New York State Energy Research and Development Authority. She said the summit “will explore a wide variety of technologies for achieving a clean system” and went on to say:
At this point, nuclear power is a more mature technology than many alternatives, she said.
“It is actually a more, I’d say, advanced area of commercial viability, as opposed to some of the other resources that we see on the technical horizon at this point,’’ Harris said in an interview Monday.
NYSERDA plans to develop a roadmap for the potential deployment of new nuclear power, similar to the Offshore Wind Master Plan the authority crafted to guide development of that resource, Harris said. NYSERDA plans to gain expert feedback at the Syracuse summit to help prepare a policy for new nuclear power, she said.
“New nuclear is a resource that we see strong federal support for,’’ Harris said. And frankly, we see deployment of these technologies — such that it is, I would say, ripe for consideration. Is this a resource that New York would consider? But it’s not to say we have the answer to that.”
Discussion
Three recent reports all have suggested that reassessment is necessary. The Public Service Commission (PSC) Clean Energy Standard Biennial Review Report found that the 70% renewable energy goal will likely not be achieved until 2033. The New York State Comptroller Office Climate Act Goals – Planning, Procurements, and Progress Tracking audit found that the PSC and NYSERDA implementation plans did not comprise all essential components, including “assessing risks to meeting goals and projecting costs.” The New York Independent System Operator (NYISO) 2023-2042 System & Resource Outlook described issues that threaten reliability and resilience of the current and future electric system.
As a result of these findings and perhaps pressure by the business community, the governor said the state’s climate goals are something she “would love to meet, but also the cost has gone up so much. I now have to step back and say, ‘What is the cost on the typical New York family?’ Just like I did with congestion pricing.” The Department of Public Service Proceeding 15-E-0302 may also be influencing the Governor and precipitating the need for the summit.
The fact is that reality is an energy policy that was promulgated by motivated politicians without a vetted analysis of the scope and schedule was never going to be successful. This summit might be an attempt to provide political cover to broach the need for schedule adjustments and to consider alternatives that have thus far not been considered seriously in the implementation process. At the top of the list is the nuclear power that is the only technology that has a proven record of deep decarbonization success but most certainly cannot be deployed on the Climate Act schedule. It will be interesting to see how legislators, the Big Green NGOs, and the renewable energy shills react to this development. Will they acknowledge that nuclear is necessary for the Climate Act goals? Stay tuned.
The New York Independent System Operator recently released the 2023-2042 System & Resource Outlook (“Outlook”). It examines “a wide range of potential future system conditions and compares possible pathways to an increasingly greener resource mix.” This post summarizes the key findings of the report.
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 article do not reflect the position of any of my previous employers or any other organization have been associated with, these comments are mine alone.
Overview
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. It includes an interim 2030 reduction target of a 40% GHG reduction by 2030, a 70% electric system renewable energy mandate by 2030, and a requirement that all electricity generated be “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies used to reduce greenhouse gas emissions. That material was used to develop the Draft Scoping Plan outline of strategies. After a year-long review, the Scoping Plan was finalized at the end of 2022. Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, Public Service Commission orders, and legislation.
Recently two reports have come out that raise specific concerns about Climate Act implementation: schedule ambition and costs to implement.
The Public Service Commission (PSC) recently released the Clean Energy Standard Biennial Review Report (“Biennial Report”) that compares the renewable energy deployment progress relative to the Climate Act goal to obtain 70% of New York’s electricity from renewable sources by 2030 (the 70% goal). It found that 2030 goal will likely not be achieved until 2033
The New York State Comptroller Office released an audit of the NYSERDA and PSC implementation efforts for the Climate Act titled Climate Act Goals – Planning, Procurements, and Progress Tracking (“Comptroller Report”). The audit found that: “The costs of transitioning to renewable energy are not known, nor have they been reasonably estimated”.
The Outlook provides a third analysis that addresses issues that could affect electric system reliability.
Overview of the Outlook Report
The document and 11 appendices are available at the NYISO website:
The Outlook examines a wide range of potential future system conditions and compares possible pathways to an increasingly greener resource mix. By simulating several possible future system configurations and forecasting the transmission constraints for each, the NYISO:
Postulates possible resource mixes that achieve New York’s public policy mandates, while maintaining reserve margins, and capacity requirements;
Identifies regions of New York where renewable or other resources may be unable to generate at their full capability due to transmission constraints;
Quantifies the extent to which these transmission constraints limit delivery of renewable energy to consumers; and
Highlights potential opportunities for transmission investment that may provide economic, policy, and/or operational benefits.
This overview uses slides included in the presentation made by Zachary Smith from the NYISO to the New York State Reliability Council on July 12, 2024. I include all the slides in the presentation with my comments. The first slide is the introduction.
The analysis identified key findings that are grouped into three main drivers of the changes to the system: demand, resources, and transmission. The presentation described nine themes that characterize the state of the grid and incorporate the key findings.
The first theme is that “Public policies continue to drive rapid change in the electric system in the state.” As shown in the following slide there are numerous specific mandates in the Climate Act that will affect the electric grid. Another key theme is that “The wholesale electricity markets administered by the NYISO exist as an important tool to attract necessary investments to facilitate the transition of the grid in the coming decades.” The NYISO is a product of the de-regulated electric system that relies on market-based policies to maintain a “reliable, sustainable grid”. I mention this because the following slide states: “Competitive markets will channel investment to achieve these goals while maintaining reliability at the lowest possible cost” and I want to make a point. Transforming the electric grid to the extent mandated by the Climate Act is an enormous technological challenge. It is hard enough to figure out how this can be accomplished, but the NYISO has the added task of creating market mechanisms to implemeent the proposed technological solutions. Despite my tremendous respect for the technical capabilities of the NYISO I am worried that these two challenges may be too great to maintain reliability at a reasonable cost.
Two key findings were described relative to demand.
Electric energy consumption is projected to increase significantly in response to the economic development and decarbonization energy policies. The figure showing the new large load projects lists 10 projects totaling 1,846 MW.
Another of the Demand key findings was “Siting large loads in electrical proximity to renewable resources, or siting resources near large loads, may benefit both the loads and the resources, particularly if located upstream of known constraints.” It is not clear to me whether this has any relevance to the new load projects. The four North Country projects are near the St Lawrence hydro projects but all the power there is spoken for. On the other hand, there are no obvious renewable resources close to the 480MW Micron project in Central New York. The projected increase in demand shown in the next slide is extraordinary.
The NYISO has been arguing for a long time that the peak annual load will shift from the summer to the winter. The timing of the shift depends on the electrification of heating and transportation.
The next slide shows that the summer peak will increase due to building and transportation electrification. Note that the increase in load is not large.
One of the key themes in the presentation was that “New York is projected to become a winter-peaking system in the 2030s, primarily driven by electrification of space heating and transportation.” The next slide shows that they expect demand to nearly double in the winter.
The second main driver of changes to the system is supply resources. The following slide identifies four key findings.
A primary NYISO concern is narrowing reliability margins. One of the key themes noted that “electrification programs and economic development initiatives are driving projected demand higher” and at the same time “Generator deactivations are outpacing new supply additions.” This was addressed as a key finding for supply resources: “The coordination of new generator additions and existing generator retirements is essential to maintain the reliability of the New York power system while simultaneously pursuing achievement of CLCPA” and “Uncertainty in siting new renewable generation could lead to delays in or inefficient expansion of the transmission and distribution systems.” The following slide illustrates the problem.
Another key finding for supply resources is that “New York will require three times the capacity of the current New York generation fleet to meet projected future electricity demands.” The following slide shows the expected changes in capacity.
A key point is that the challenge is not just building more capacity there are other features needed in the future grid. The following slide notes that renewable energy needs to be supported by dispatchable resources. Those resources need to be able to respond quickly and be ‘energy secure”. In addition, there are other grid support services required to support “power system stability, strength, and minimize operational risk”.
One of the key themes for the transition is “To achieve the mandates of the CLCPA, new emission-free supply capable of providing the necessary reliability services are needed to replace the capabilities of today’s generation. Such new supply is not yet available on a commercial scale. “ One of the key findings for supply resources states “Dispatchable emission-free resources must be developed to provide the capacity, energy, and other essential grid services required to achieve the policy mandate for a zero-emissions grid by 2040.” In other words, this is the resource that is needed to provide the system needs described in the previous slide. Appendix F is devoted to this resource. Dispatchable Emissions-Free Resources (DEFR) are needed for a future grid that depends upon wind, solar, and energy storage resources to keep the lights on during periods of extended low wind and solar resource availability. In my opinion, one of the important unresolved issues is the resource allocation difference between the NYISO projections and the Integration Analysis State Scenario shown in the following slide.
There are enough issues associated with this topic that I will come back to this in a subsequent post For this overview I will continue with the final main driver of electric system change – transmission. The following slide lists four key findings.
The first key finding is that “Historic levels of investment in the transmission system are happening but more will be needed.” The following slide lists seven ongoing transmission projects.
As noted, more transmission will be needed. The following slide describes the process for more transmission projects.
Another key finding is that there are “Actionable expansion opportunities: To fully utilize the transmission facilities already in place, additional dynamic reactive power support must be added to the grid in upstate New York to alleviate curtailment over the Central East interface.” This is illustrated in the following slide. I am not conversant in the technical details of this issue so I will quote from the Outlook report:
To fully utilize the transmission facilities already in place, additional dynamic reactive power support must be added to the grid in upstate New York to alleviate congestion caused by the Central East interface voltage performance. Reactive power supports the overall voltage performance of the grid and maybe provided by generators, dedicated fast responding dynamic reactive power devices, such as synchronous condensers or other power electronics (e.g., STATCOMs], or potentially other specialized Grid-Enhancing Technologies (GETs). This kind of specialized technology can improve the delivery of electricity via existing transmission lines. As the fossil fuel generators tied to the Central East voltage collapse limit are deactivated by 2040 to comply with the CLCPA mandate, the full benefits of the Segment A transmission project will be diminished leading to transmission congestion and renewable curtailment if left unaddressed.
The Outlook finds that by replacing the dynamic support services from these fossil fuel generators to support the Central East interface voltage performance, the future potential congestion across Central East could be largely eliminated and curtailment of renewable energy reduced by approximately 40-220 GWh in 2035.
The important point is that someone is going to have to pay for the dynamic support services necessary to get the renewable electric energy to where it is needed. When wind and solar supports brag about the low costs of solar and wind generation they are most certainly not including hidden costs like this in their estimates.
There were no slides specifically associated with the following key themes. Three themes address current reliability concerns:
The potential for delays in construction of new supply and transmission, higher than forecasted demand, and extreme weather are threatening reliability and resilience to the grid
Summer 2024: Electricity supplies are adequate to meet expected summer demand under normal conditions, but extreme weather and other factors pose reliability risks.
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.
Lastly, in order to expedite new renewable development, the NYISO processes have to be accelerated. Note however, that NYISO must worry about the unintended consequences of these new resources so there are limits on this:
NYISO’s interconnection processes continue to evolve to balance developer flexibility with the need to manage the process to more stringent timeframes.
Discussion
The key themes that describe the Resource Outlook state of the grid outline potential issues. In this section I describe the themes that posed issues threatening reliability and resilience to the grid but add some context that was not included in the slide presentation.
The themes describe the status of the electric system. This summer the electric system should be able to meet demand but “extreme weather and other factors pose reliability risks.” In the winter, “the availability of natural gas for power generation may be limited and significant interruptions to natural gas supply can disrupt reliable operations.” Unsaid were the ramifications of State policy decisions to limit natural gas pipelines to alleviate this availability problem.
The themes also address changes to the electric system. Public policies are one of the causes of rapid changes to New York’s electric system in the state. One of the consequences of the electrification mandate is that New York peak loads will occur in the winter in the 2030s. Another driver of change is the marked increase in loads partially due to electrification mandates but also due to economic initiatives and increased demand for computing resources. These changes have resulted in narrower reliability margins compounded by the unmentioned State policy decisions to force generator deactivations and preclude replacement with new fossil-fired generation.
Another issue raised in the themes is the schedule. There have been and will be delays in construction of new supply and transmission. NYISO recognizes that the interconnection process must change to keep up with the schedule but in this presentation did not describe the technological changes that complicate interconnection of inverter-based intermittent wind and solar resources.
I maintain that NYISO does not acknowledge that the need for “significant changes to the wholesale electricity markets administered by the NYISO” significantly complicates the transition. NYISO not only must identify the technology needed to provide a reliable and resilient system but must also conjure up a market mechanism that will entice developers to provide those resources.
A primary concern expressed in the presentation was the need for “new emission-free supply capable of providing the necessary reliability services are needed to replace the capabilities of today’s generation.” NYISO descriptions of DEFR always mention that “such new supply is not yet available on a commercial scale” but never articulate the risk to the reliability and resilience of the system of a policy that presumes that the resource will be developed as required. Another related concern is that planning for this resource in a weather-dependent electric grid must address the challenge that wind and solar resource output is frequently low at the same time. Alarmingly, the low resource availability typically occurs when the loads are highest which exacerbates the importance of a reliable DEFR solution.
Conclusion
The NYISO System and Resource Outlook describes issues that threaten reliability and resilience of the electric system. In my opinion, it is frustrating that the issue descriptions are couched in qualifying statements that disguise the magnitude of the challenges. It is left up to the reader to figure out that it is unlikely that the Climate Act mandates can be implemented without causing reliability crises. In my opinion, the requirements of the Climate Act demand too much, too soon and the proposed plan to rely on wind and solar will cause catastrophic blackouts.
In the past couple of weeks there has been a flurry of offshore wind related news. This post consolidates several of the important items. Climate Change Dispatch describes an analysis that implicates offshore wind surveys with whale deaths. Bud’s Offshore Energy has posted numerous articles describing the recent Nantucket offshore wind turbine failure and David Wojick explains the risk implications to further development.
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 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” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies used to reduce greenhouse gas emissions. That material was used to develop the Draft Scoping Plan outline of strategies. After a year-long review, the Scoping Plan was finalized at the end of 2022. Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, Public Service Commission orders, and legislation.
Offshore wind developments are a key decarbonization strategy. There is a target of 9,000 MW of offshore wind by 2035. However, there are overlooked risks to this strategy has described here.
Offshore Wind Impact on Whales
Climate Change Dispatch reports that a recent study finds that offshore wind survey vessels are causing whale deaths. The article explains:
Apostolos Gerasoulis, a Rutgers professor emeritus of computer science who co-created the search engine that powers Ask.com developed a software system dubbed Luna to identify any relationship between the dead whales and offshore wind survey vessels. He loaded NOAA data on whale deaths, the zigzag courses of survey ships, and even wave action into his computer system. Luna revealed patterns that Gerasoulis believes point to offshore wind survey vessels as the cause of the whale deaths.
Luna generates maps of the U.S. East Coast and plots the locations of offshore wind farms; the deaths of whales, dolphins, and porpoises; and the routes taken by various survey ships. The central region, including New York, New Jersey, and Rhode Island, had minimal survey traffic before 2016. After [2016], survey vessel traffic was an average of 50,300 miles per year, double the amount of the southern region. The number of humpback whale deaths also doubled, to 10.625 per year.
‘When comparing the south and central regions after offshore wind surveying started, the averages show an almost linear increase in humpback whale deaths – doubling the traffic results in doubling the whale deaths.”
Nantucket Wind Turbine Blade Failure
Bud’s Offshore Energy (BOE) blog covers “Energy Production, Safety, Pollution Prevention, and More” topics with an emphasis on offshore projects. In the last couple of weeks he has posted 12 articles about the wind turbine blade failure off Nantucket. I have briefly summarized them below.
On Saturday night (7/13) the Coast Guard warned Mariners as follows: “Coast Guard received a report of 03 floating debris 10 meters by 2 meters in the vicinity of approximately 26 NM SE of Marthas Vineyard and 22 NM SW of Nantucket in position 40 59.559N 070 25.404W. All marines are requested to use extreme caution while transiting the area.“
On Monday (7/15), Vineyard Wind confirmed that a turbine blade incident occurred on 7/13: “On Saturday evening, Vineyard Wind experienced blade damage on a wind turbine in its offshore development area. No personnel or third parties were in the vicinity of the turbine at the time, and all employees of Vineyard Wind and its contractors are safe and secure.”
On 7/16, Vineyard Wind issued another statement advising that they were deploying teams to Nantucket to clean up debris from the incident.
He also described the risks to marine mammals in Debris poses a significant risk to marine mammals. He said that the debris is a particular concern for baleen whales, like the endangered right whale, which filter large amounts of water. Per NOAA:
Marine Mammals: Many species of marine mammals have also been confirmed to eat marine debris. A review by Kühn and van Franeker found that 69 species of marine mammals have been found to ingest debris – that’s 56% of all marine mammals! This includes 44 species of odontocetes (toothed whales), manatees, and multiple seal species. Marine mammals are highly protected, which can make it difficult to research them. Most research on marine mammals takes place after an animal dies, making it difficult to understand what marine debris live animals eat. However, we do know that because baleen whales filter extremely large amounts of water while feeding, they may get plastic debris entangled in their baleen plates.
“This morning, a significant part of the remaining GE Vernova blade detached from the turbine. Maritime crews were onsite overnight preparing to respond to this development, though current weather conditions create a difficult working environment.”
“We are staying apprised of GE Vernova’s efforts to manage the situation, including the removal and recovery of the remaining blade attached to the turbine.”
Staying apprised? As operator, Vineyard Wind is fully responsible. This is their situation to manage.
BSEE has ordered Vineyard Wind to suspend power production and wind turbine generator construction.
Kudos to BSEE for their decisive and timely action. They need to better understand what happened before allowing operations and construction to continue.
Imagine the pressure on the regulator if the project was providing a significant portion of the region’s electricity.
BSEE’s comment that there has been “no harm to any marine resources or mammals from the incident” is premature given the extensive marine debris and the associated risks to mammals.
What about the CVA?
The regulations at 30 CFR § 285.707-712 assign important responsibilities to Certified Verification Agents (CVAs), independent third parties with established technical expertise. These responsibilities include detailed reviews of the design, fabrication, and installation plans.
Oddly, the CVA’s “Statement of Qualifications” and “Scope of Work and Verification Plan” have been redacted in their entirety from Vineyard Wind’s Construction and Operations Plan (COP) (see Appendix I-C and I-D).
Who was the CVA and why was that important information redacted?
Were any of the CVA requirements waived per 258.705?
Will BOEM, the lessor and Federal wind program manager, be making a statement? Will they be reassessing their COP review procedures?
BOEM should temper their over-the-top promotion of offshore wind. The complete shutdown of the first utility scale offshore wind farm heightens public concerns about the intermittency of this power source, and the need for reliable backup sources.
The post included BOE’s comments on the three factors listed in the excerpt:
Factor 1: Those “robust insurance policies” may soon be tested given the costs associated with the turbine blade incident and potential law suits. (The notice pasted below informs that Nantucket officials will meet on Tuesday to consider litigation. A question for attorneys is the extent to which Nantucket is compromised by their good “Good Neighbor Agreement” with Vineyard Wind. That agreement essentially calls on Nantucket to promote the Vineyard Wind projects in return for payments that seem modest relative to the economic benefits from tourism and fishing.)
Factor 2: To the extent that GE Vernova Haliade-X 13 megawatt turbines are proven technology (and that is very much in doubt), the use of proven technology doesn’t prevent premature abandonment associated with unexpected incidents.
Factor 3: Reliable power generation and predictable long-term income remain to be demonstrated.
The Vineyard Wind turbine incident, which littered Nantucket beaches, has also tarnished the US offshore wind program. BSEE has prudently halted Vineyard Wind operations and construction pending an investigation into the blade failure.
Offshore wind development is structure rich, so public confidence in the design of turbines and support platforms is critical. BOEM lists 37 active wind leases on the US OCS. Most of these leases have not yet reached the construction phase. A hold on the approval of any Construction and Operations Plans would seem to be appropriate pending completion of the Vineyard Wind investigations.
Per the leasing schedule below, BOEM intends to hold 4 wind sales during the remainder of 2024, all within a 3 month period. Only 1 sale is scheduled for each of the following 2 years. Deferring the 2024 sales until the investigations are complete would assist potential lessees by ensuring that the issues of concern were fully understood.
Unfortunately, BOEM’s failure to conduct a 2024 oil and gas lease sale has boxed in the wind program. The Inflation Reduction Act prohibits BOEM from issuing wind leases unless an oil and gas sale has been held within the previous year. Lease Sale 261 was held on 12/20/23 meaning that no wind leases may be issued after 12/20/24. BOEM has compressed the wind leasing schedule, presumably to beat the legislative deadline. It would have been better for both the oil and gas and the wind programs if at least one oil and gas sale had been held in 2024 as has been customary since the 1950s.
expressed “strong concerns and outrage” over the fractured Vineyard Wind turbine blade and the debris that washed ashore on Nantucket.
said the foam and fiberglass debris have “potential negative and adverse impact[s]” on the environment, marine life, and human health.
said fragments in the water pose a threat to shellfish, which are a crucial part of both the marine food web and also ingested by humans.
commented that the potential contamination of shellfish with fiberglass and other materials could have severe consequences for human consumption and public health.
criticized the lack of communication from federal officials to the tribe.
called for an “immediate stoppage” of offshore wind construction in U.S. waters until they can be evaluated for microfractures and other damages.
“While we continue to work to finalize our root cause analysis, our investigation to date indicates that the affected blade experienced a manufacturing deviation,” said GE Vernova CEO Scott Strazik. “We have not identified information indicating an engineering design flaw in the blade or information of a connection with the blade event we experienced at an offshore wind project in the UK, which was caused by an installation error out at sea. We are working with urgency to scrutinize our operations across offshore wind. Pace matters here. But we are going to be thorough, instead of rushed.”
“It’s been 11 days since the event, and just to reinforce from the start, we have no indications of an engineering design flaw,” Strazik said. “We have identified a material deviation or a manufacturing deviation in one of our factories that, through the inspection or quality assurance process, we should have identified. Because of that, we’re going to use our existing data and reinspect all of the blades we’ve made for offshore wind. For context, this factory in Gaspé, Canada where the material deviation existed we’ve made about 150 blades.
On July 26 BOE observed that the wind turbine company GE Vernova stock has taken a hit. The Vineyard Wind turbine blade incident, the main reason for the sharp decline in their stock value in mid-July, is described as follows:
VINEYARD WIND OFFSHORE WIND FARM. We are the manufacturer and supplier of turbines and blades and the installation contractor for Vineyard Wind 1 offshore wind farm in the Atlantic Ocean (Vineyard Wind), at which we have installed 24 of 62 Haliade-X 220m wind turbines to date. Subsequent to the period covered by this report, a wind turbine blade event occurred at Vineyard Wind. Debris from the blade was released into the Atlantic Ocean and some has washed ashore on nearby beaches. On July 15, 2024, the U.S. Bureau of Safety and Environmental Enforcement (BSEE) issued a suspension order to cease power production and the installation of new wind turbines at the project site, pending an investigation of the event. As of the date of the filing of this report, we are currently engaged in a root cause analysis of the incident. We do not have an indication as to when BSEE will modify or lift its suspension order. Under our contractual arrangement with the developer of Vineyard Wind, we may receive claims for damages, including liquidated damages for delayed completion, and other incremental or remedial costs. These amounts could be significant and adversely affect our cash collection timelines and contract profitability. We are currently unable to reasonably estimate what impact the event, any potential claims, or the related BSEE order would have on our financial position, results of operations and cash flows.
“Within only two to three years of commercial operation, the GE wind turbine generators have exhibited numerous material defects on major components and experienced several complete failures, at least one turbine blade liberation event, and other deficiencies,”
“The order comes as the bureau continues its oversight and investigation into the July 13, 2024, turbine generator blade failure. The order continues to prohibit Vineyard Wind 1 from generating electricity from any of the facilities or building any additional wind turbine generator towers, nacelles, or blades. This order also requires Vineyard Wind 1 to submit to BSEE an analysis of the risk to personnel and mitigation measures developed prior to personnel boarding any facility. Vineyard Wind 1 is not restricted from performing other activities besides those specifically directed for suspension or additional analysis. For example, Vineyard Wind 1 is still permitted to install inter-array cables and conduct surveys outside of the damaged turbine’s safety exclusion zone.”
“The technology may not be new, but the size and scale of the Haliade-X turbine is novel for the offshore wind industry. And these jumbo-sized turbines have only recently been installed in just two locations in the world within the last year – at Vineyard Wind off Nantucket, and the Dogger Bank Wind Farm off the northeast coast of England. The Haliade-X turbine blades – which are supposed to have at least a 25-year lifespan – have suffered failures in both locations.“
“At the Dogger Bank Wind Farm – which is being completed in three sections which combined will make up the largest offshore wind farm in the world – the first GE Vernova Haliade-X turbine was installed in the fall of 2023 and began producing power on Oct. 10. But little is known about the blade failure that occurred just months later during the first week of May 2024. The damaged blade was disclosed by Dogger Bank’s owners – SSE Renewables, Equinor, and Vårgrønn – a week after the incident. In a statement, the companies said only that “damage was sustained to a single blade on an installed turbine at Dogger Bank A offshore wind farm.”
“One reason the turbine blade incident at the Dogger Bank may not have generated more attention at the time is that the wind farm is located 100 miles off the coast of England, rather than just the 15 miles in the case of Vineyard Wind and Nantucket. If any debris was generated, it would have a far wider area to disperse in before nearing land – if it made it that far at all.“
In this article, I present some technical background on that risk. The facility will be one of the world’s biggest, with 176 enormous turbines. It is just getting started with pile driving, so no turbine blades have been installed to date. This is an opportune time to undertake caution.
The Nantucket turbines are made by GE, and they are the world’s largest in operation today at 13 MW, each driven by three huge 107-meter-long blades. That is 351 feet for those of us who do not speak metric. The Virginia turbines will be even bigger at 14 MW with 108 meters (354+ feet) long. They are made by Siemens Gamesa, or SG for short.
The GE turbines and blades have been in production for going on two years, so have some operational experience. The SG turbines and blades just came into production so there is no experience with them. One could say they are being beta tested off Virginia.
This newness in itself is a great concern. At three blades each, there are an incredible 528 blades with a combined length of over 57,000 meters (187,000 feet or 35 miles) of blades. To take first production blades to these huge lengths is surely very risky.
For context consider that the Nantucket Current article referenced by BOEM noted that:
The Haliade-X turbine is the same one Orsted – a partner in Vineyard Wind – is planning to use for offshore wind farms slated for the waters off New Jersey and Maryland.
Land-based turbines have come apart in Sweden, Germany, Lithuania, Cypress, Brazil, and the US (and presumably elsewhere).
With respect to New York, there are two New York projects that plan to use large turbines. Equinor’s Empire Wind 810 MW project provides comprehensive wind turbine information:
Vestas is the preferred supplier for wind turbine generators for Empire Wind. Vestas will deliver 138 V236-15MW wind turbine generators with a total generating capacity of around 2GW.
15 MW capacity
774 feet rotor diameter
886 feet high tip height
463,000 sqf swept area
On the other hand the 924 MW Sunrise Wind project developed by Ørsted and Eversource does not provide readily accessible turbine information. I could not find what kind of turbines are planned or any details on their characteristics.
Wojick goes on to explain some of the problems with these immense turbine blades.
Now let’s look at the blade stress physics just a bit, as it is amazing. SG has a quick look on their website, saying this:
“The rotational forces found in offshore wind turbines in operation put IMMENSE STRAIN ON THE BLADES and the rest of the wind turbine structure. (Emphasis added) At a tip speed of approximately 90 meters per second – equivalent to 324 kilometers per hour! (201 mph!) – and a projected lifetime of more than 25 years, high-quality and innovative design is imperative. For a 108-meter-long blade, the rotational forces are around a staggering 80 million newton meters, and the strain on the blades and the structure is intense! To put this into perspective, the force pulling on a human shoulder while spinning a 1 kg object around in an outstretched arm is only about 10 newton meters!”
Wojick sums up:
In summary, we have a newly huge blade, subject to immense stresses, made for the first time in an unusual way with a new composition and never tested in a hurricane. The high novelty risk to Virginia is obvious.
I have no doubts that the proposed offshore wind development will have enormous impacts on whales and other mammals. The big green environmental organizations are abandoning whales in general and the remaining North American Right Whales in particular. Bryce quotes an opponent of offshore wind: “What is Big Wind going to say when they kill the last whale? ‘Sorry’?”
Red flag warnings abound for New York’s offshore wind development using these unproven huge wind turbines. Wojick states the obvious “A sound engineering approach would be to build a few and see how they did over time.” He also points out that the existing turbines of this size are in Europe where the dangers of hurricanes are not present.
BOE provides a great concluding statement:
Greater transparency regarding turbine incidents, both in the US and internationally, is clearly needed. As we have learned from decades of experience with the oil and gas industry, most companies prefer reporting systems (if any) that protect details and information about the responsible parties from public disclosure. It’s the responsibility of the regulators to make sure that incident data and investigation reports are timely, complete, and publicly available. This is made more difficult by the promotional role that government agencies have assumed for offshore wind.