Category: Climate Act

This article was also published at Watts Up With That.

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

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

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

Estimating Metals Needed to Replace Fossil Fuels

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

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

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

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

Scope of the Replacement System

The reference to the first article is:

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

The Abstract states:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Quantity of Metals Required

The second article was referenced: 

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

The abstract states:

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

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

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

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

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

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

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

Source: Published in Geological Survey of Finland Bulletin 416

Conclusion

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

This post was also published at Watts Up With That

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

I have followed the Climate Leadership & Community Protection Act (Climate Act)since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 450 articles about New York’s net-zero transition. The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

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

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

The summary describes the key points in the report:

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

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

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

The description of the power sector physical challenges explains:

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

Quality Review Concerns

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

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

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

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

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

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

McKinsey Report Analysis of Concerns

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

Challenge 1: Managing renewables variability (Level 3):

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

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

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

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

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

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

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

This challenge does not address either of my concerns.

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

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

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

Discussion

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

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

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

Conclusion

The report concludes that:

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

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

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

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

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

I have followed the Climate Leadership & Community Protection Act (Climate Act)since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 450 articles about New York’s net-zero transition. The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The rationale for the Climate Act is the existential threat of climate change and the Hochul Administration never misses an opportunity to describe every weather extreme as a more proof.  The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% reduction. Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and a requirement that all electricity generated be “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation.

NYISO Reliability Planning

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

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

Regulatory Policies Affecting Reliability

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

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

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

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

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

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

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

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

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

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

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

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

Conclusion

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