Category: Climate Act

Comparison of NYISO Resource Outlook and Draft Scoping Plan Generating Resource Projections

The final version of the important New York Independent System Operator (NYISO) 2021-2040 System & Resource Outlook that addresses New York’s Climate Leadership and Community Protection Act (Climate Act) was released on September 22, 2022.  This post compares the projections for resources needed to meet the Climate Act targets in this report and the Draft Scoping Plan. 

Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies.  I submitted comments on the Climate Act implementation plan and have written extensively on New York’s net-zero transition because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that this supposed cure will do more harm than good.  The opinions expressed in this post 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.

Background

The implementation for the New York’s Climate Act “Net Zero” target (85% reduction and 15% offset of emissions) by 2050 is underway.  The Climate Action Council has been working to develop plans to implement the Climate Act.  Over the summer of 2021 the New York State Energy Research & Development Authority (NYSERDA) and its consultant Energy + Environmental Economics (E3) prepared an Integration Analysis to “estimate the economy-wide benefits, costs, and GHG emissions reductions associated with pathways that achieve the Climate Act GHG emission limits and carbon neutrality goal”.  Integration Analysis implementation strategies were incorporated into the Draft Scoping Plan when it was released at the end of 2021.  Since the end of the public comment period in early July 2022 the Climate Action Council has been addressing the comments received as part of the development of the Final Scoping Plan that is supposed to provide a guide for the net-zero transition.

I have previously written that the Climate Action Council has not confronted reliability issues raised by New York agencies responsible for keeping the lights on.  The first post (New York Climate Act: Is Anyone Listening to the Experts?) described the NYISO 2021-2030 Comprehensive Reliability Plan (CRP) report (appendices) released late last year and the difficulties raised in the report are large. The second post (New York Climate Act: What the Experts are Saying Now) highlighted results shown in a draft presentation for the 2021-2040 System & Resource Outlook that all but admitted meeting the net-zero goals of the Climate Act are impossible on the mandated schedule.  Recently I wrote about the “For discussion purposes only” draft of the 2021-2040 System & Resource Outlook report described in the previous article and the concerns raised.  It is amazing to me that these issues continue to be ignored.

Description of Resource Outlook and Draft Scoping Plan Mitigation Scenarios

This section compares two alternate approaches to meeting the Climate Act net-zero transition requirements. 

The NYISO Resource Outlook report includes two scenarios that “reflect full achievement of the Climate Act targets”. 

Outlook Scenario 1 – Utilizes industry data and NYISO load forecasts, representing a future with high demand (57,144 MW winter peak and 208,679 GWh energy demand in 2040) and assumes less restrictions in renewable generation buildout options.

Outlook Scenario 2 – Utilizes various assumptions consistent with the Climate Action Council Integration Analysis and represents a future with a moderate peak but a higher overall energy demand (42,301 MW winter peak and 235,731 GWh energy demand in 2040).

The Resource Outlook describes the scenarios:

In both Policy Case scenarios, a significant amount of land-based wind capacity was built by 2040. The model selected land-based wind due to its assumed capital cost, energy output, and capacity ratings. In both scenarios, land-based wind capacity builds to the assumed capacity build limits imposed (~16 GW).

In both scenarios, a significant amount of capacity from renewable generation and dispatchable emission free resources (DEFRs) is projected by 2040, with the most installation forecasted in the last five years, to help offset the projected fossil-fueled generation retirements. Dispatchable emission free resources are a proxy generator type assumed for generation expansion in the Policy Case to represent a yet unavailable future technology that would be dispatchable and produces emissions-free energy (e.g., hydrogen, RNG, nuclear, other long-term season storage, etc.). As noted above, all existing fossil-fueled generation (~26 GW) was modeled as retired by 2040 due to the CLCPA requirement of a zero emissions grid by 2040. In addition, in Scenario 2 the age-based retirement assumption captured the retirement of 12 GW, nearly half the fossil fleet. The models expanded to approximately 111 GW of total capacity for Scenario 1 and 124 GW of total capacity for Scenario 2, inclusive of NYCA generators, BTM-PV, and qualifying imports from Hydro Québec. This level of total installed capacity would be needed in 2040 to satisfy the state policy, energy, and resource adequacy constraints for Scenario 1 and Scenario 2, respectively. Of this total, approximately 85 GW to 100 GW represent generation expansion for Scenario 1 and Scenario 2, respectively, beyond the 9.5 GW planned through state contracts.25 For comparison, the Contract Case has approximately 51 GW of total installed capacity by 2040.

In general, resources take years from development to deployment. By year 2030, roughly seven years from the publication of this report, an estimated 20 GW of additional renewable generation needs to be in-service to support the energy policy target of 100% zero-emission generation by 2040. For reference, 12.9 GW of new generation has been developed since wholesale electricity markets began more than 20 years ago in 1999. Over the past five years, 2.6 GW of renewable and fossil-fueled generators came on-line while 4.8 GW of generation deactivated26. This Outlook demonstrates the need for an unprecedented pace of project deployment, which will require significant labor and materials available for New York over a long period of time.

Offshore wind capacity buildout remains near the 9 GW policy objective through 2040 for both scenarios. This outcome results primarily from the assumed high capital cost of offshore wind technology in the model, which was the highest cost renewable technology available. Additionally, considering the declining marginal capacity reliability value curves assumed, offshore wind at the levels modeled is an inefficient resource to meet peak capacity needs and Locational Capacity Requirements because the capacity contribution of intermittent renewable resources declines as more are added to the system.

Overall, results for Scenario 2 showed a higher level of renewable buildout than Scenario 1, most notably in utility-scale solar capacity, and had a different projection of the capacity expansion throughout the study period as compared to Scenario 1 for all generator types. The main factors for these differences are the assumptions for load forecasts and differences in generator types eligible for capacity expansion as well as the maximum allowable capacity builds by technology type modeled between the two scenarios. One major difference in Scenario 2 is that a reduced land-based wind capacity limit was used, which changed the projection of capacity builds for all types. Notably, the projections for offshore wind were higher earlier in the model horizon (e.g., 2030) in Scenario 2 as compared to Scenario 1 to help achieve the 70 x 30 target.

Two primary drivers are attributable to increased renewable resources in capacity expansion: (1) high operating cost of dispatchable generators, and (2) low capital costs for renewable generators. High fuel (e.g., natural gas prices, clean DEFR fuel prices) and/or high CO2 emissions prices result in significant decrease in fossil generation and subsequent increase in renewable generation earlier than otherwise projected. Low capital costs for renewable generators result in capacity builds much earlier than otherwise projected, and often an increase in the total amount of capacity built.

In terms of the zonal location for capacity buildouts determined by the capacity expansion model, limitations were imposed on the zonal level as to which generator type(s) could build in each zone. For instance, land-based wind was eligible for expansion in upstate regions (Zones A-G), utility-scale solar was eligible for expansion in upstate regions and Long Island (Zones A-G and Zone K), and offshore wind was eligible for expansion in New York City and Long Island (Zones J and K). Dispatchable emission free resource (DEFR) technologies and battery storage were included as generation resource options in all NYCA zones.

The Draft Scoping Plan includes a reference case and four mitigation scenarios.  The first mitigation scenario only includes the initial recommendations of the Climate Act Advisory Panels but it did not meet the targets.  The three remaining mitigation scenarios meet or exceed GHG emission limits and achieve carbon neutrality by 2050.  They all include:

  • Zero emission power sector by 2040
  • Enhancement and expansion of transit & vehicle miles traveled (VMT) reduction
  • More rapid and widespread end-use electrification & efficiency
  • Higher methane mitigation in agriculture and waste
  • End-use electric load flexibility reflective of high customer engagement and advanced technologies

The three mitigation scenarios that meet the Climate Act targets address concerns raised by the Climate Action Council membership:

Draft Scoping Plan Scenario 2: Strategic Use of Low-Carbon Fuels: Includes the use of bioenergy derived from biogenic waste, agriculture & forest residues, and limited purpose grown biomass, as well as green hydrogen, for difficult to electrify applications

Draft Scoping Plan Scenario 3: Accelerated Transition Away from Combustion: Includes Low-to-no bioenergy and hydrogen combustion and accelerated electrification of buildings and transportation

Draft Scoping Plan Scenario 4: Beyond 85% Reduction:  Accelerated electrification + limited low-carbon fuels: This scenario adds additional VMT reductions; additional innovation in methane abatement; and avoids direct air capture of CO2

I prepared Draft Scoping Plan comments on these mitigation scenarios that includes descriptions and a comparison of the differences between them based on Appendix G of the Draft Scoping Plan.  Unfortunately, the documentation is so poor that it does not explain the rationale for the generation sector differences described in the next section.

Comparison of Scenarios

The following table provides an overview of the capacity (MW) and energy generated (GWhr) generating resources in the five scenarios described above.  Because it is difficult to read the table I have also provided a spreadsheet with the table and the input data extracted from the NYISO and Integration Analysis spreadsheets.  I will compare each of the resource categories in the following from 2019 up to 2040 when the state’s electric grid is supposed to be zero-emissions.

The first resource category is nuclear.  There is no significant difference in the capacity and power generated between the scenarios.  They all reflect the irrational shutdown of over 2,000 MW at the Indian Point Nuclear Station and continued operation of the remaining nuclear facilities to 2040.  Despite the fact that nuclear is the only dispatchable emissions-free generating resource that can be scaled up neither analysis believes that additional nuclear power generation could be part of New York’s future.

There are interesting differences between the scenarios in the fossil generation resource category.  Resource Outlook Scenario 1 reduces fossil capacity 19% from 2019 to 2030, keeps it the same in 2035, and then goes to zero in 2040.  Resource Outlook Scenario 2 reduces fossil capacity 33% from 2019 to 2030, reduces it another 9% by 2035, and then goes to zero in 2040.  Note that the energy produced is the same for both scenarios in 2030 but in 2025 Scenario 1 is reduced 8% more. So even though there is more fossil capacity in 2035 in Scenario 1 it is used less.  This is problematic for me because it means that the production resource model is treating the fossil resources differently between the scenarios.  It is not clear what would cause this difference.

The Integration Analysis scenario fossil projections raise similar concerns.  Scenario 2, Accelerated Transition from Combustion, capacity and generation is higher in 2030 compared to the other two scenarios but then does show a marked decrease in 2035.  If it is accelerated, why is it higher in 2030?  Integration Analysis Scenarios 2 and 4 are comparable to Resource Outlook Scenario 1 and Integration Analysis Scenario 3 is comparable to Resource Outlook Scenario 2.  I assume that this reflects similar assumptions by the analysts at NYISO and NYSERDA.

All the Hydro category scenarios show an increase in capacity between 2019 and 2030.  I assume that a large part of that is due to the Clean Path New York (CPNY) and Champlain Hudson Power Express projects. 

The remaining categories are the key parts of the transition.

The land-based wind (LBW) resource category is the first where there are significant differences between the Resource Outlook and the Integration Analysis scenarios.  Resource Outlook Scenario 1 increases LBW capacity 3.1 times whereas Scenario 2 only doubles the amount in 2030.  Integration Analysis Scenario 2 also doubles capacity by 2030, Scenario 3 goes up 2.7 times, and Scenario 4 goes up 2.4 times.  The differences between scenarios disappear by 2035 but the Resource Outlook projects land-based wind capacity will be 53% higher than the mitigation scenarios in the Integration analysis with 42% more generation.

The NYISO production resource model apparently does not think that offshore wind is a cost-effective option because both scenarios do not increase the projected capacity significantly beyond the Climate Act mandate of 9,000 MW.  On the other hand, the Integration Analysis scenarios nearly double the amount of offshore wind resources projected.   Overall, the Resource Outlook offshore wind capacity is 40% lower than the average of the Integration Analysis scenarios and generation is 43% lower. 

For the solar resource there is a significant difference between Resource Outlook Scenario 1 and all the other scenarios.  The capacity is 63% lower and the generation is 71% lower than the averages of the other scenarios.  In 2040 the capacity factor for the projected resource capacity and expected generation is a reasonable 15% for Resource Outlook Scenario 1 whereas Resource Outlook Scenario 2 is 17% but 21% for the Integration Analysis scenarios.  In my opinion I question why there is a difference for the Resource outlook scenarios. I don’t think that the Integration Analysis expectation that the solar capacity factor can bas high as 21% in 2040 is reasonable for New York’s latitude and snowfalls.

The energy storage resource category capacity values are pretty much the same all the scenarios.  However, the generation projections are presented differently so that it is not possible to compare them.

As noted in the Resource Outlook, the Dispatchable Emissions-Free Resource (DEFR) category is a proxy generator type that represents a yet unavailable future technology that would be dispatchable and produces emissions-free energy (e.g., hydrogen, RNG, nuclear, other long-term season storage, etc.).  The DEFR capacity and generation is substantially higher in Resource Outlook Scenario 1 and all the other scenarios.  Even Resource Outlook Scenario 2 is higher than the Integration Analysis scenarios.  In addition, Resource Outlook Scenario 1 capacity factor is 9% whereas the others are all around 2%.

Getting to 100%: Six strategies for the challenging last 10%

My most recent post described a recent paper, Getting to 100%: Six strategies for the challenging last 10%, that provides a concise evaluation of six zero-emissions technologies.  It is instructive to consider these strategies in the context of these projections.  The authors from the National Renewable Energy Laboratory provided the following summary of the challenge:

Meeting the last increment of demand always poses challenges, irrespective of whether the resources used to meet it are carbon free.  The challenges primarily stem from the infrequent utilization of assets deployed to meet high demand periods, which require very high revenue during those periods to recover capital costs.  Achieving 100% carbon-free electricity obviates the use of traditional fossil-fuel-based generation technologies, by themselves, to serve the last increment of demand—which we refer to as the ‘‘last 10%.’’

The Getting to 100% paper describes six strategies that are summarized in the following table.  Note that the strategies are compared to an ideal solution.  Ideally, the solution for peak loads would have low capital expenses and low operating expense, low resource constraints, be technologically mature, have low environmental impacts, and work well with other resources.  Needless to say, no technology comes close to meeting those ideal conditions.  The authors note that: “Although existing studies generally highlight the same fundamental causes associated with the last 10% problem, there is a lack of consensus on the preferred strategies for meeting this challenge. This is not surprising, given the diversity of possible solutions and the speculative nature of their costs, given their early stage of development.”

The Getting to 100% paper described strategies for the last 10% challenge which for this resource refers to increasing the use of wind, solar, and storage to cover what I call the ultimate problem.  Both the Resource Outlook and the Integration Analysis models predict that the primary resource for this challenge will be seasonal storage using DEFR.  Although there are mentions of the other strategies the emphasis is on the dispatchable emissions-free resource.  The proxy technology in the Integration Analysis is hydrogen although the production and use options are not specified. 

There are other options for seasonal storage.  The report notes:

This group of technologies is not well defined, but it could include batteries with very low-cost electrolytes capable of longer-than-diurnal durations. Because of the requirement for very low-cost energy storage, most seasonal storage pathways focus on hydrogen, ammonia, and other hydrogen-derived fuels stored in geologic formations.

Ultimately the Getting to 100% paper evaluates hydrogen used either in a combustion turbine or a fuel cell for electricity production.  In the New York implementation plan the dispatchable emissions-free resource (DEFR) place holder is hydrogen produced using wind and solar.  There are members of the Climate Action Council that insist that the hydrogen has to be used in a fuel cell rather than a combustion turbine because combustion causes emissions.

The Draft Scoping Plan calls for the use of so-called “green hydrogen” whereby hydrogen is produced by a carbon-free process of electrolysis from water. The Draft does not include a feasibility analysis of the production and use of hydrogen in some form as the placeholder technology for DEFR.  The Resource Outlook does not specify a specific technology but emphasizes the risks of depending upon an unproven technology: “Both scenarios include significant DEFR capacity by 2035, but it is important to note that the lead time necessary for commercialization, development, permitting, and construction of DEFR power plants will require action much sooner if this timeline is to be achieved.”

I submitted a Draft Scoping Plan comment specifically addressing this presumption.  I do not believe that the Integration Analysis correctly accounted for the energy needed to produce the hydrogen needed for the DEFR requirement. I think that there will be siting issues for all the fuel cells, electrolyzers, pipelines, and hydrogen storage facilities.  .  In the exisitng system the generating sources assigned for peaking power for this reliability requirement used the cheapest technology available (simple-cycle gas turbines).  Meeting this requirement in the future using the hydrogen DEFR resource will be using the most expensive generating technology available.  The capacity factors for this resource in the Draft Scoping Plan are 2% for all mitigation scenarios so it will be difficult to cover these costs for the short periods needed.  I guarantee the usual suspects will complain about profiteering when the costs spike during these periods.

In addition, the Getting to 100%: Six strategies for the challenging last 10% report notes that “current high-cost electrolyzers need to operate almost continuously to recover their capital expense”.  The Draft Scoping Plan plans to use intermittent wind and solar that preclude any continuous processes.  That issue has been completely ignored in the Draft Scoping Plan. 

Recall that there are members of the Climate Action Council that insist that hydrogen used for electric generation has to be used in fuel cells.  The Getting to 100% paper addresses fuel cells:

Fuel cells have diverse applications, but their use for bulk power generation is currently limited. Given the range and scale of applications especially for transportation, substantial capital cost reductions for fuel cells are possible. With low capital costs for combustion turbines and future potential cost reductions for fuel cells, the economic case for hydrogen mainly hinges on lowering the cost of electrolytic hydrogen.

According to Table 1 in the Getting to 100% paper, it really is a stretch to say that there are any positive aspects for using hydrogen.  For hydrogen used in combustion turbines the report claims low capital expenses (apparently referring only to the combustion turbine but not including the generation of the hydrogen itself), medium operating expenses and resource constraints, and concerns about hydrogen storage and transport as well as competition for using hydrogen in other sectors.  For hydrogen used in fuel cells there is a potential for low capital expenses, high operating expenses, low resource constraints (apparently referring only to the fuel cell and not assuming that the hydrogen is generated with wind and solar resources), low technological maturity, and the same other considerations as hydrogen used in combustion turbines.

Discussion

This analysis found significant differences between the projections for land-based wind, offshore wind, energy storage and dispatchable emissions-free resources in the Resource Outlook and the Integration Analysis.  I think that those differences should be discussed in an open forum.  Most importantly to New York citizens the costs associated with the different options have to be made available from the NYISO and Climate Action Council.  I am pretty sure costs account for the differences in the NYISO scenarios but without that information we cannot be sure.  Most importantly, the feasibility of a dispatchable emissions-free resource has to be addressed and the projected DEFR utilization difference between Resource Outlook Scenario 1 and all the other scenarios reconciled.  I also believe that both organizations have to address the economic viability challenge of DEFR stemming from the infrequent utilization of those assets deployed to meet high demand periods, which require very high revenue during those periods to recover capital costs. 

Moreover, the forum should also address implementation concerns raised by the New York State Reliability Council in their Draft Scoping Plan comments.  They made the point that the new resources required are enormous and also raised other concerns:

Practical considerations affecting the availability, schedule and operability for new interconnections include: interconnection standards; site availability; permitting; resource equipment availability; regulatory approval; large volume of projects in NYISO queue and study process; scalability of long-term battery storage and other technologies; operational control; impact of extreme weather; consideration of a must- run reliability need for legacy resources. In addition, the pace of transportation and building electrification, the timing of any natural gas phase-out and their impact on the electric T&D system must also be carefully studied from technical, economic and environmental perspectives. Together, these practical considerations require the development of reliable zero emission resources to be conscientiously sequenced and timed in the near term (through 2030) to ensure broader GHG reductions in all sectors beyond 2030.

One final point about the modeling analyses.  The programs are proprietary and the documentation is sparse so it is not possible to fully understand the results.  For example, the Integration Analysis Accelerated Transition Away from Combustion scenario has higher fossil generation projections in intermediate years than the other scenarios.  Untangling the reason for that would be a challenge.  I believe that the models can create projection differences as much by input tweaks as by the projection algorithms.  Because the models are so complicated and include so many input parameters the modelers have to be careful to limit changes between scenarios that could affect the outcomes.

Conclusion

I have repeatedly made the point that the differences between the NYISO projected resources and the Integration Analysis projections need to be reconciled.  This post attempted to explicitly list those differences.  Unfortunately, this concern does not seem to be shared by the Climate Action Council and the Hochul Administration.  It is only a matter of time until the ramifications of this abrogation of responsibility affects reliability and affordability of the state’s electric grid.

The other unresolved issue is the feasibility of any dispatchable emissions-free resource.  It is staggering that the State is pushing ahead without an independent analysis of the options available for this critical resource.  As it stands it will not end well.

Getting to 100%: Six strategiesfor the challenging last 10%

A recent paper, Getting to 100%: Six strategies for the challenging last 10%, provides a concise summary of six technologies that could be used for the Climate Leadership and Community Protection Act (Climate Act) legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050.  I continue to be amazed that the parties responsible for Climate Act implementation continue to ignore the risks associated with these aspirational technologies so this article summarizes this useful paper.

Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies.  I submitted comments on the Climate Act implementation plan and have written extensively on New York’s net-zero transition because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that this supposed cure will be worse than the disease.  The opinions expressed in this post 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.

Background

The implementation plan for New York’s Climate Act “Net Zero” target (85% reduction and 15% offset of emissions) by 2050 is underway.  The Climate Action Council has been working to develop plans to implement the Act.  Over the summer of 2021 the New York State Energy Research & Development Authority (NYSERDA) and its consultant Energy + Environmental Economics (E3) prepared an Integration Analysis to “estimate the economy-wide benefits, costs, and GHG emissions reductions associated with pathways that achieve the Climate Act GHG emission limits and carbon neutrality goal”.  Integration Analysis implementation strategies were incorporated into the Draft Scoping Plan when it was released at the end of 2021.  Since the end of the public comment period in early July 2022 the Climate Action Council has been addressing the comments received as part of the development of the Final Scoping Plan that is supposed to provide a guide for the net-zero transition.

I have previously written that the Climate Action Council has not confronted reliability issues raised by New York agencies responsible for keeping the lights on.  The first post (New York Climate Act: Is Anyone Listening to the Experts?) described the NYISO 2021-2030 Comprehensive Reliability Plan (CRP) report (appendices) released late last year.  The difficulties raised in the report are so large that I raised the question whether any leader in New York was listening to this expert opinion.  The second post (New York Climate Act: What the Experts are Saying Now) highlighted results shown in a draft presentation for the 2021-2040 System & Resource Outlook that all but admitted meeting the net-zero goals of the Climate Act are impossible on the mandated schedule.  Recently I wrote about the “For discussion purposes only” draft of the 2021-2040 System & Resource Outlook report described in the previous article. 

Challenges of a Zero-Emissions Electric Grid

It is generally recognized that as increasing amounts of intermittent wind and solar energy are added to the electric grid, unique issues arise as grid operators balance generation and load.  I maintain that the ultimate problem with a net-zero energy system is that increased electrification will markedly raise loads during weather conditions that cause peak loads but also can have low wind and solar resource availability.  A recent paper, Getting to 100%: Six strategies for the challenging last 10% (“Getting to 100% report”), describes approaches for providing power during peak conditions.  It describes the general peaking problem, how wind and solar will exacerbate the problem, and what the authors think is necessary to solve the future problem.

The authors from the National Renewable Energy Laboratory provided the following summary:

Meeting the last increment of demand always poses challenges, irrespective of whether the resources used to meet it are carbon free.  The challenges primarily stem from the infrequent utilization of assets deployed to meet high demand periods, which require very high revenue during those periods to recover capital costs.  Achieving 100% carbon-free electricity obviates the use of traditional fossil-fuel-based generation technologies, by themselves, to serve the last increment of demand—which we refer to as the ‘‘last 10%.’’ Here, we survey strategies for overcoming this last 10% challenge, including extending traditional carbon-free energy sources (e.g., wind and solar, other renewable energy, and nuclear), replacing fossil fuels with carbon-free fuels for combustion (e.g., hydrogen- and biomass-based fuels), developing carbon capture and carbon dioxide removal technologies, and deploying multiday demand-side resources. We qualitatively compare economic factors associated with the low-utilization condition and discuss unique challenges of each option to inform the complex assessments needed to identify a portfolio that could achieve carbon free electricity. Although many electricity systems are a long way from requiring these last 10% technologies, research and careful consideration are needed soon for the options to be available when electricity systems approach 90% carbon-free electricity.

The Getting to 100% paper describes six strategies that are summarized in the following table.  Note that the strategies are compared to an ideal solution.  Ideally, the solution for peak loads would have low capital expenses and low operating expense, low resource constraints, be technologically mature, have low environmental impacts, and work well with other resources.  Needless to say, no technology comes close to meeting those ideal conditions.  The authors note that: “Although existing studies generally highlight the same fundamental causes associated with the last 10% problem, there is a lack of consensus on the preferred strategies for meeting this challenge. This is not surprising, given the diversity of possible solutions and the speculative nature of their costs, given their early stage of development.”

Although I think the Getting to 100% paper is useful, I want to point out a few issues with it.  It is hardly unexpected that authors from the National Renewable Energy Laboratory appear to over-estimate the maturity and economics of wind and solar technologies.  Also note that in New York, the implementation plan calls for offshore wind capacity to be at least one third to over one half of the projected wind capacity but the report claimed that wind economic factors were low, capital costs low, operational expenses low and that wind has high technological maturity.  All true perhaps for land-based wind but certainly not true for off-shore wind. 

My biggest concern is that the analysis does not consider the ‘‘inverter challenge’’ as a major constraint.  Another report, “The challenges of achieving a 100% renewable electricity system in the United States”, explains that in the existing electrical system synchronous generators provide six services shown in the following table that provide system stability.  Wind and solar resources are asynchronous generators that do not provide those services.  Somebody has to provide them so this analysis that concentrates only on the levelized cost of energy that ignores those services under-estimates the cost and technological challenges to provide electricity to consumers.

The Getting to 100% paper explains that the biggest problem is making sure there is sufficient available capacity during all periods, even if that capacity is seldom used.  This problem is not new and exists in the existing system.  The paper notes:

The increase in costs associated with approaching 100% carbon-free electricity is a special case of the more general problem of meeting peak demand, which has always been part of the planning process for electric power systems. Variations in demand profiles and the existence of demand peaks are caused by variation in weather, end-use technology stock, and, ultimately, consumer preferences and behavior.

The Getting to 100% paper explains that there are differences between daily load and daily renewable energy (RE) generation over the year.  The following figure shows the seasonal patterns in the daily imbalance (daily load minus daily RE generation) for hypothetical high RE systems where about 90% of annual load is met by wind, solar, and other RE generation technologies for New York State. As noted previously the fundamental problem is that when the loads are the highest in the summer and winter, RE generation can be low.  In the spring and fall the RE resources are generally high but loads are low.   As the share of RE increases,” these aspects are increasingly accentuated”.  The paper makes the point that:

Eventually, with high enough VRE shares, the addition of new VRE capacity would offer very little benefit in reducing peaks in net load, while causing additional oversupply conditions where unusable VRE needs to be curtailed. The low capital utilization problem of meeting demand is exacerbated in high VRE systems. These issues shape the characteristics of a last 10% solution.

In the following I will address each strategy.

Variable renewable energy, transmission, and diurnal storage

This approach is “technologically conservative, as it relies only on technologies currently being deployed at gigawatt (GW) scale”. The seasonal mismatch problem is addressed by overbuilding wind and solar resources as well as adding more transmission capacity.  Diurnal storage is deployed to fill hourly supply gaps and excess wind and solar is curtailed during high-resource periods.  The authors claim: “Increasing oversupply during high-resource times decreases the amount of storage necessary to supply low-resource times.”  The authors admit that wind and solar “curtailment in such systems can reach 35%–50%”.  There is an associated problem.  As more wind and solar resources are added to minimize storage requirements, those additional resources markedly increase curtailment rates for all those resources.  

In order to address those issues, the authors claim that new developments could “make this approach more competitive” In particular: “Higher-capacity-factor system designs (low-windspeed and/or high-hub-height wind turbines; tracking PV arrays with high inverter-loading ratios preferentially increase output during low-resource periods, increasing VRE dispatchability”.  My impression however, is that those are tweaks and do not eliminate all issues.  The authors mention hybrid systems, “including concentrating solar power with thermal energy storage”, but neglect to mention that the Crescent Dunes Solar Energy Project that used this technology failed.  They also claim that “Increased long-distance transmission deployment (over distances larger than the extent of weather systems decreases curtailment, cost, and storage needs by exploiting the declining spatial correlation of VRE availability with increasing distance”.  Advocates of this approach never discuss just what distances are needed for it to work and just how it would work in practice.

According to Table 1 in the Getting to 100% paper, on the positive side the economic factors are relatively low cost and technological material is high.  The resource constraints are listed as medium but I think that is optimistic given the volume of these resources required.  Frequent claims of the low costs of wind and solar generation ignore the fact that the real cost that matters is the delivered cost.  When the costs to keep the lights on when the wind is not blowing at night are considered the low cost claims are wrong.

Other renewable energy

The study claims that “geothermal, hydropower, and biomass are renewable energy resources that do not rely on variable solar and wind resources and have higher capacity credit”. While the report claims that these resources can play an important role in a net-zero-emissions power system the fact is geothermal and hydro resources depend on certain physical site constraints so there is not a lot of potential availability in New York.  The main problem with biomass is that there are limits on how much could be produced and it is not enough to be a major contributor to the overall energy needs.  In New York there are members of the Climate Action Council that believe that zero-emissions means no combustion so there is an ideological constraint as well.

According to Table 1 in the Getting to 100% paper, on the positive side the technological material is high and some of the economic factors are favorable.  However, all the options have high resource constraints that limit the applicability of these options.

Nuclear and fossil with carbon capture

The study notes that “Nuclear and fossil with carbon capture and storage (CCS) are widely cited as potentially important resources in a decarbonized electricity system”.  There is no question that nuclear is the only emissions-free dispatchable resource that could be deployed in sufficient quantities to provide all needed baseload power.  The report notes that: ”The existing nuclear fleet comprises reactor designs with large nameplate capacities and designed to operate near their maximum output potential”, and that “Advanced nuclear reactor designs are typically smaller in scale and more flexible” .  Consequently, nuclear might be viable for the last 10% problem.  Alas New York, for example, on one hand worries about an existential threat of climate change but shuts down 2,000 MW of zero-emissions nuclear generation which suggests that this option is off the table.

The report notes that “Fossil CCS plants have yet to be deployed at scale, but some studies find significant deployment potential, including from retrofits of existing fossil fuel-fired Plants”.   The report sums up the pragmatic dilemma associated with this option:

Fossil CCS has a capture rate of less than 100%; therefore, some emission offsets are needed for fully net carbon-free electricity unless technology advancements, such as through oxy-combustion, can enable zero or near-zero emissions.  he role of fossil CCS could be impacted by how strictly the ‘‘100%’’ requirement is interpreted with respect to any remaining emissions that are not captured and emissions from upstream fuel extraction, including methane leakage.

There is another issue associated with CCS.  A fossil plant capturing CO2 has a derate of about one third because of the energy needed to run the equipment required to capture and compress the CO2 so that it can be transported and sequestered underground.  Finally, in order to safely store the CO2 particular geologic formations are required which limits where these facilities can be located.

According to Table 1 in the Getting to 100% paper, advanced nuclear has high capital expenses and moderate operating expenses; medium resource constraints, medium technological maturity, and security, supply chain, regulatory and cost uncertainties.  Fossil CCS has high capital expenses, medium operating expenses, medium resource constraints, low technological constraints, and issues with upstream emissions, CO2 transport and sequestration.

Seasonal storage

Seasonal storage refers to the use of electricity to produce a storable fuel that can be used for generation over extended periods of time later:

This group of technologies is not well defined, but it could include batteries with very low-cost electrolytes capable of longer-than-diurnal durations. Because of the requirement for very low-cost energy storage, most seasonal storage pathways focus on hydrogen, ammonia, and other hydrogen-derived fuels stored in geologic formations.

Hydrogen produced using electricity to split water (i.e., electrolytic hydrogen) is a form of storage because the energy it carries can be converted back to electricity.  Electrolytic hydrogen technology has been used at an industrial scale since the early 20th century. Although currently higher cost than hydrogen from natural gas reforming, electrolytic hydrogen production costs can be reduced if low- cost electricity, such as zero-cost otherwise-curtailed renewable energy, is used.

In the New York implementation plan the dispatchable emissions-free resource (DEFR) place holder is hydrogen produced using wind and solar.  In addition to the irrational ideological prohibition against combustion sources there are technological issues for New York.  The report notes that “current high-cost electrolyzers need to operate almost continuously to recover their capital expense” and that “Storage and transport costs would add to the delivered cost of hydrogen”. 

The New York ideologues plan is to use hydrogen in fuel cells, but the report notes:

Fuel cells have diverse applications, but their use for bulk power generation is currently limited. Given the range and scale of applications especially for transportation, substantial capital cost reductions for fuel cells are possible. With low capital costs for combustion turbines and future potential cost reductions for fuel cells, the economic case for hydrogen mainly hinges on lowering the cost of electrolytic hydrogen.

According to Table 1 in the Getting to 100% paper, it really is a stretch to say that there are any positive aspects for using hydrogen with combustion turbines or in fuel cells.  For hydrogen used in combustion turbines the report claims low capital expenses (apparently referring only to the combustion turbine but not including the generation of the hydrogen itself), medium operating expenses and resource constraints, and concerns about hydrogen storage and transport as well as competition for using hydrogen in other sectors.  For hydrogen used in fuel cells there is a potential for low capital expenses, high operating expenses, low resource constraints (apparently referring only to the fuel cell and not assuming that the hydrogen is generated with wind and solar resources), low technological maturity, and the same other considerations as hydrogen used in combustion turbines.

Carbon dioxide removal

The report describes carbon dioxide removal (CDR) strategies which are “dedicated efforts to reduce atmospheric CO2 levels.  In theory this can offset emissions from carbon-emitting power generation so that fossil-fired units can operate to fulfill the last 10% requirement. This is too far fetched to be credible in my opinion.

According to Table 1 in the Getting to 100% paper, there are no positive aspects of this technology except that there are low resource constraints for direct air capture and storage. 

Demand-side resources

Net-zero advocates are enamored with “smart planning” approaches that reduce load which reduces generating resource requirements.  The report notes that “Demand-side resources, also referred to as demand response or demand flexibility, have unique properties compared with the supply-side solutions”.  The report explains:

To a limited extent, they are already relied upon for grid planning and operations today. By reducing electricity consumption during times of system stress, these resources help avoid capital expenditures associated with new peaking capacity.  Through flexible scheduling or interruption of electricity consumption, they can also reduce operating costs or be used for important grid reliability services.

While there are indisputable advantages, I think that advocates lose track of the limitations.  There are demand-side programs in place today but the applications are limited.  Today’s programs limit reduction requests to rare instances of limited duration primarily to shave peak loads primarily by large industrial or commercial users. The problem is that applying demand-side options as a last 10% strategy for decarbonization “requires them to be reliably available over extended multi-day periods”. This means that they cannot be used for residential heating and cooling loads and electric vehicle charging. Moreover, the report notes that “Large-scale commercial or industrial customers can provide multi-day response, but extended interruptions would negatively impact these capital-intensive (non-power) applications”.  As a result, I don’t think this approach will provide adequate reductions when needed the most.

According to Table 1 in the Getting to 100% paper there are low capital expenses but there are uncertain opportunity costs.  The paper claims that resource constraints are uncertain and that the technological maturity is medium.  There are concerns about communications, control equipment and reliability.

Discussion

An Inside Clean Energy article on the paper offers a summary from the climate advocacy side.  Of note is a plug for the 100% renewable option:

A growing segment of energy researchers say that the electricity system can run on 100 percent renewable energy, which would mean renewables and energy storage would provide the last 10 percent. This approach sees no good reason to build new nuclear plants or to use carbon capture systems on fossil fuel plants, citing high costs and a variety of other concerns.

The author admits that the myth of low-cost solar and wind resources does not take into account the resources needed for reliability during periods of peak demand:

At the same time, a sizable group of energy researchers maintain that nuclear and carbon capture are essential parts of getting to carbon-free electricity. This side has doubts about the ability of renewable sources to meet all needs, citing concerns about the availability of land and the intermittent nature of wind and solar. They note that wind and solar are not a low-cost option when taking into account the amounts of storage and power line capacity needed to make those resources reliable for meeting peak demand.

I find the author’s conclusion naïve:

Within all of this is something encouraging: Researchers and energy companies have figured out how to start the transition to 100 percent carbon-free electricity and they have a pretty good idea of what the in-between steps will look like. Now, they are beginning to dig deep on how this journey to a carbon-free grid may end.

Academic researchers are not accountable for reliability and have found a cash cow for funding.  No one is funding them to make a responsible estimate of future resources that does not fit the alarmist narrative.  In a de-regulated world energy companies are also not responsible for reliability and are toeing the line of the net-zero narrative.  New York’s organizations responsible for reliability are not as optimistic (here and here). New York’s Draft Scoping Plan presumes that the State can transition to net-zero without addressing reliability and affordability feasibility but the reality is that even this report suggests that substantive issues have to be addressed.

Conclusion

I think this is a biased report that is too optimistic for future projections.  Nonetheless, it does offer a concise summary of potential approaches to address the last 10% problem that is my ultimate concern.  With respect to New York’s implementation plans, if the concerns of the National Renewable Energy Laboratory staff are ignored in the Final Scoping Plan, then New York will surely have a catastrophic blackout with consequences far beyond any impacts that can be attributed to climate change.

New York Zero Emission Vehicle Mandate

The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050.  On September 29, 2022 Governor Hochul directed the New York Department of Environmental Conservation to take major regulatory action that will require all new passenger cars, pickup trucks, and SUVs sold in New York State to be zero emissions by 2035.  As has been the case with all of the Administration’s global warming regulatory initiatives the pronouncement is not supported by any documentation.

Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies.  I submitted comments on the Climate Act implementation plan and have written extensively on New York’s net-zero transition because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that this supposed cure will be worse than the disease.  The opinions expressed in this post 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.

Climate Act Background

The Climate Act establishes a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council.  Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that tried to quantify the impact of the strategies.  That material was used to write a Draft Scoping Plan that was released for public comment at the end of 2021. The Climate Action Council states that it will revise the Draft Scoping Plan based on comments and other expert input in 2022 with the goal to finalize the Scoping Plan by the end of the year.

In 2019 greenhouse gas (GHG) emissions from the transportation sector accounted for 28.2% of total GHG emissions so it is necessary to reduce transportation sector emissions to meet the Climate Act targets.  However, I explained in my comments that the Draft Scoping Plan did a poor job evaluating how a zero-emissions mandate would be implemented and an even worse job projecting the potential costs.  I will highlight some of the points made in my comments and also put this new mandate in context.

Hochul’s Announcement

The following is a substantial portion of the press release announcing the mandate:

Governor Kathy Hochul today commemorated National Drive Electric Week by directing the State Department of Environmental Conservation to take major regulatory action that will require all new passenger cars, pickup trucks, and SUVs sold in New York State to be zero emissions by 2035. This is a crucial regulatory step to achieving significant greenhouse gas emission reductions from the transportation sector and is complemented by new and ongoing investments also announced today, including electric vehicle infrastructure progress, zero-emission vehicle incentives, and ensuring New York’s communities benefit from historic federal climate change investments.

“New York is a national climate leader and an economic powerhouse, and we’re using our strength to help spur innovation and implementation of zero-emission vehicles on a grand scale,” Governor Hochul said. “With sustained state and federal investments, our actions are incentivizing New Yorkers, local governments, and businesses to make the transition to electric vehicles. We’re driving New York’s transition to clean transportation forward, and today’s announcement will benefit our climate and the health of our communities for generations to come.”

Proposing draft State regulations is a crucial step to further electrify the transportation sector and help New York achieve its climate requirement of reducing greenhouse gases 85 percent by 2050, while also reducing air pollution, particularly in disadvantaged communities. The State Department of Environmental Conservation (DEC) is expediting this regulatory process to implement legislation Governor Hochul signed last year and turn those goals into progress in fully transitioning to new zero-emission cars and trucks. California’s action finalizing the Advanced Clean Cars II regulation last month unlocked New York’s ability to adopt the same regulation.

The regulation will build upon existing regulations enacted in New York in 2012 by requiring all new sales of passenger cars, pickup trucks, and SUVs to be zero-emission by 2035. It would require an increasing percentage of new light-duty vehicle sales to be zero-emission vehicles (ZEV) starting with 35 percent of sales in model year 2026, 68 percent of sales by 2030, and 100 percent of sales by 2035. New pollutant standards for model year 2026 through model year 2034 passenger cars, light-duty trucks, and medium-duty vehicles with internal combustion engines would also be required. The regulation provides manufacturers with flexibility in meeting the emission requirements and achieving a successful transition to cleaner vehicles.

Adoption of Advanced Clean Cars II is included among the recommendations in the Climate Action Council’s Draft Scoping Plan and will be instrumental in achieving the greenhouse gas emissions reductions required in the Climate Leadership and Community Protection Act. In addition, reducing emissions will provide significant air quality benefits to many of New York’s disadvantaged communities, predominantly home to low-income Black, Indigenous, and People of Color, and often adjacent to transit routes with heavy vehicle traffic. The regulation will help address disproportionate risks and health and pollution burdens affecting these communities.

Department of Environmental Conservation Commissioner and Climate Action Council Co-Chair Basil Seggos said, “Governor Hochul is demonstrating her sustained commitment to the successful implementation of the Climate Act and ensuring all New Yorkers benefit from the State’s actions to address climate change. DEC will continue to work under her direction to rapidly issue this regulation and reach another milestone in the transition from fossil fuels so that more people, businesses, and governments will have the ZEV options to meet their needs and help improve the health of their communities.”

The directed regulatory action announced today builds on New York’s ongoing efforts to reduce emissions of greenhouse gases, including the adoption of the Advanced Clean Trucks regulation in December 2021. That regulation will drive an increase in the number of medium- and heavy-duty ZEV models available as purchase options for vehicle purchasers and fleets. In addition, several transit agencies including the Niagara Frontier Transportation Authority, the Rochester-Genesee Regional Transportation Authority, and the Metropolitan Transit Authority are leading by example with second wave deployments of electric buses. DEC, New York State Energy Research and Development Authority (NYSERDA), New York Power Authority (NYPA), and DOT (Department of Transportation) are assisting these authorities with these efforts.

Draft Scoping Plan Transportation Comments

I submitted a couple of comments on electric vehicles.  The emphasis in the first comment was my finding that the Integration Analysis is simply making assumptions about future zero-emissions transportation implementation strategies without providing adequate referenced documentation.  I provided numerous recommendations for additional documentation in these comments so that New Yorkers can understand what will be expected and how much it will cost.

As far as I can tell, the electric vehicle costs are based entirely on new vehicle sales. There is no acknowledgement that the used car market will likely change because of the cost of battery replacement.  Sellers will likely get less relative to new cars in the battery electric vehicle market.  Buyers may get a relative deal but will lose in the end when the batteries have to be replaced.  This is a particular concern for low and middle-income citizens who cannot afford new vehicles.

There is no bigger disconnect between the zero-emission vehicle (ZEV) proposed strategy and reality than the ZEV charging infrastructure requirements.  The biggest problem is that millions of cars will have to rely on chargers that cannot be dedicated for the owner’s personal use because the owners park on the street or in a parking lot.  In order to provide a credible ZEV strategy, the final Scoping Plan has to describe a plan how this could possibly work.  It is not enough to simply say it will work.

I also submitted a comment addressing electric vehicle costs.  the Integration Analysis vehicle cost projections rely on a single vehicle type for light-duty vehicles.  As a result, the projections are not particularly useful for many vehicle owners.  In order to accurately project the costs for this mandate the types of vehicles used has to be updated. 

Discussion

There is a paragraph in the press release that needs to be addressed:

The regulation will build upon existing regulations enacted in New York in 2012 by requiring all new sales of passenger cars, pickup trucks, and SUVs to be zero-emission by 2035. It would require an increasing percentage of new light-duty vehicle sales to be zero-emission vehicles (ZEV) starting with 35 percent of sales in model year 2026, 68 percent of sales by 2030, and 100 percent of sales by 2035. New pollutant standards for model year 2026 through model year 2034 passenger cars, light-duty trucks, and medium-duty vehicles with internal combustion engines would also be required. The regulation provides manufacturers with flexibility in meeting the emission requirements and achieving a successful transition to cleaner vehicles.

In 2026 the State will require 35% of all new vehicle sales to be zero-emission vehicles.  As of May 1, 2022 there were a little over 62,000 electric cars registered in New York out of the over 11 million vehicles registered.  The Integration Analysis projections for battery electric vehicles in 2026 range from 7.8% in the reference case to 24.3% in the most optimistic mitigation scenarios.  One of my criticisms of the Draft Scoping Plan is that the increase in projected sales is not supported by any recommendations for implementation. 

I have documented many electric vehicles issues but it is by no means an exhaustive list of the reasons I will never purchase an electric vehicle.  The State apparently believes that all that is necessary is a proclamation and all the reservations of all the people who are perfectly happy with internal combustion engines will be overcome.

Hochul’s proclamation fails to address the low and middle-income consumer concerns expressed by Robert Bryce in testimony before the House Select Committee on the Climate Crisis:

EVs … impose … societal costs that are likely to exacerbate inequality and lead to more energy poverty,” Bryce continued. “Those costs include taxpayer-funded subsidies given to EV buyers, publicly funded charging stations, and the grid upgrades that will be needed to support the electrification of light and heavy-duty vehicles. Those costs will impose a significant cost burden on low and middle-income consumers, even though those consumers are unlikely to purchase EVs.

Bryce also raised other issues in his testimony that are ignored in the grandstanding announcement:  

Electrifying parts of our transportation system may result in incremental reductions in greenhouse gas emissions, but a look at history, as well as an analysis of the supply-chain issues involved in manufacturing EVs, the resource intensity of batteries, and the increasingly fragile state of our electric grid – which is being destabilized by bad policy at the state and national levels – shows that a headlong drive to convert our transportation systems to run on ‘green’ electricity could cost taxpayers untold billions of dollars, increase greenhouse gas emissions, be bad for societal resilience, make the U.S. more dependent on commodity markets dominated by China, make us less able to respond to extreme weather events or attacks on our infrastructure, and impose regressive taxes on low and middle-income Americans in the form of higher electricity prices.

Finally, the ultimate rationale for this inane policy is to do something about climate change.  The reality is that New York emissions are inconsequential so this is nothing more than politically expedient climate virtue signaling.  New York’s GHG emissions are less than one half a percent of total global emissions and, on average, global GHG emissions have been increasing by more than one half a percent per year.  Anything we do will be wiped out be emissions elsewhere in a year.  Furthermore, the State has never published an estimate of the effect of New York emission reductions on global warming itself.  I estimate that the change to global warming from eliminating New York GHG emissions is only 0.01°C by the year 2100 which is too small to be measured much less have an effect on any of the purported damages of greenhouse gas emissions. 

Conclusion

In the press release Hochul claimed that “New York is a national climate leader and an economic powerhouse, and we’re using our strength to help spur innovation and implementation of zero-emission vehicles on a grand scale”.  The State’s obsession with being a climate leader is pointless.  Worse there is no recognition that the pursuit of zero emissions has unintended consequences and will likely cause more harm than good.  The lack of a public discussion of pragmatic considerations for the net-zero transition will ultimately seriously affect New York.

Climate Act Hubris

The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050.  The Hochul Administration subscribes to the belief that a collective crossing of fingers will ensure that the electric system that has taken decades to develop can transition to a system not using the fossil fuels, the foundational building block of progress and prosperity, by 2040.  This post highlights comments by New York State Department of Environmental Conservation Commissioner Basil Seggos that epitomize this position.

Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies.  I submitted comments on the Climate Act implementation plan and have written extensively on New York’s net-zero transition because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that this supposed cure will be worse than the disease.  The opinions expressed in this post 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.

Climate Act Background

The Climate Act establishes a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council.  Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that tried to quantify the impact of the strategies.  That material was used to write a Draft Scoping Plan that was released for public comment at the end of 2021. The Climate Action Council states that it will revise the Draft Scoping Plan based on comments and other expert input in 2022 with the goal to finalize the Scoping Plan by the end of the year.

The Independent Power Producers of New York hosted a conference on September 14, 2022 that included a couple of relevant presentations.  Writing in the Albany Times Union, Rick Karlin described the presentation by Michael Mehling, deputy director of the Center for Energy and Environmental Policy Research at the Massachusetts Institute of Technology.  Mehling argued that given the affordability and reliability issues evident in Europe at this time, that a Plan B backup using existing technology and natural gas is an appropriate approach.

According to Karlin’s article, Commissioner Seggos disagreed:

“I don’t think there is a Plan B,” state Environmental Commission Basil Seggos told those at the gas conference.  Seggos echoed the thoughts of environmentalists who believe the need to reduce carbon emissions in order to fight global warming is so urgent that the shift to renewables needs to push ahead, even though there will be costs. “I think we are on the edge right now when it comes to global emissions,” Seggos added.

 I will address this supposition in this article.

Some Ohm Truths About the Great Green Fantasy

After I saw the Seggos quotes I was prompted to write this article when I read an article by Peter Smith in Quadrant outline that made points about similar efforts in Australia.  Smith introduces his concerns:

No sane person should be fooled. A climate-cult madness has infected governments and their activist agencies; exemplar, the Australian Energy Market Operator (AEMO). Delusions of grandeur is a common manifestation of madness. Climate cultists fit the profile. Clothing themselves in virtue, they strut about proclaiming that they can save the earth from a fiery end if only we would give away the foundational building block of progress and prosperity; namely, fossil fuels.

New York is different inasmuch as the New York market operator, New York Independent System Operator (NYISO), is not driving the Climate Act bus.  Instead, the state’s politicians passed legislation that gave the keys to the Climate Action Council’s politically-chosen ideologues.  Seggos is co-chair of the Climate Action Council and has gone to the COP26 Glasgow meeting and the signing ceremony for the Inflation Reduction Act to tout New York’s climate virtues. 

I maintain the biggest shortcoming of the Climate Act is the lack of a feasibility analysis.  Smith describes a similar situation in Australia:

As Stephen Kruiser puts it, they act “as if we can go from Point A to Point Z without hitting any of the 24 points between them. They truly believe that they can mandate the future.” As I said, delusions of grandeur; epitomised by AEMO and its “2022 Integrated System Plan.” A plan having the delusional and grandiose objective of engineering “a true transformation of the NEM [National Electricity Market, which excludes WA and NT] from fossil fuels to firmed renewables.”

New York just assumes that they too can get from the current electric system to a zero-emissions electric system by 2040. 

The recently released NYISO 2021-2040 System & Resource Outlook report notes that:

  • Significant new resource development will be required to achieve CLCPA energy targets.
  • To achieve an emission-free grid, dispatchable emission-free resources (DEFRs) must be developed and deployed throughout New York. It is important to note that the lead time necessary for commercialization, development, permitting, and construction of DEFR power plants will require action much sooner if this timeline is to be achieved.
  • As the energy policies in neighboring regions evolve, New York’s imports and exports of energy could vary significantly due to the resulting changes in neighboring grids.

In Australia “The plan calls for the supply of electricity to almost double by 2050; from just under 180 terawatt hours (TWh), to 320 TWh.”  New York load is projected to increase less by 2040, it increases slightly less from 146 TWh to at least 245 TWh.  Smith goes on to explain that the amount of electricity needed when transport, industry, offices and residences are electrified is extraordinary and claims that the official projections are underestimated.  To meet this demand Australia and New York both increase the amount of wind and solar in operation tremendously.  So much in fact that the presumption that the equipment can be permitted, fabricated, and constructed in the time frames required strains credulity.  Both Australia and New York need to build significant amounts of transmission with the same limitations and the same concerns apply to this build out too.  New York has studiously avoided any estimates of consumer costs but surely the build out of all this infrastructure will be enormous.  Smith also points out that the labor needed to install all this infrastructure will also be a constraint.  Smith concludes: “To wit, it’s a case of delusions being not delusional enough. Increased madness required.” 

Conclusion

Seggos believes that “the need to reduce carbon emissions in order to fight global warming is so urgent that the shift to renewables needs to push ahead, even though there will be costs”.  The entire intent of my blog is to discuss tradeoffs between environmental and energy policies.  The political agenda of the Hochul Administration precludes an honest discussion of any tradeoffs.  They just ignore anything inconsistent or inconvenient. 

Seggos claims we are on the edge with respect to global emissions.  If New York’s emission reductions could truly make a difference it would be one thing, but the State has never offered an estimate of the Climate Act effect on global emissions or global warming.  I have found that New York’s emissions are only 0.45% of global emissions.  The change to global warming from eliminating New York GHG emissions is only 0.01°C by the year 2100 which is too small to be measured much less have an effect on any of the purported damages of greenhouse gas emissions.  Furthermore, whatever New York does to reduce emissions will be supplanted by global emissions increases in less than a year.

The Draft Scoping Plan repeats the consensus story that imminent climate catastrophe is inevitable.  However, those claims are based on model assessments and not observations.  A recent paper concludes that “on the basis of observational date, the climate crisis that, according to many sources, we are experiencing today, is not evident yet”.

Pushing ahead with renewables no matter what risks the reliability and affordability of the system.  The comments by the NYISO and the New York State Reliability Council raise significant concerns that the Climate Action Council has to date ignored.  As noted, the State has so far refused to produce any estimate of consumer cost estimates but, surely, they will be significant.  I fear that the ideological agenda of the administration will prevent an open and transparent discussion of these issues before serious impacts occur.

More Reliability Concerns that Need to be Considered by the Climate Action Council

The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050.  I have previously noted that there are members of the Climate Action Council who deny the challenge of the electric grid transition from existing sources to one dependent upon wind and solar resources.  This article describes a couple of recent articles that highlight transition issues.

Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies.  I submitted comments on the Plan and have written extensively on implementation of New York’s response to that risk because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that this supposed cure will be worse than the disease.  The opinions expressed in this post 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.

Climate Act Background

The Climate Act establishes a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council.  Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that tried to quantify the impact of the strategies.  That material was used to write a Draft Scoping Plan that was released for public comment at the end of 2021. The Climate Action Council states that it will revise the Draft Scoping Plan based on comments and other expert input in 2022 with the goal to finalize the Scoping Plan by the end of the year.

In my comments on the Draft Scoping Plan I noted that the Plan and the Climate Action Council have downplayed the reliability risks of the Climate Act transition to renewables.  Equally troubling there are vocal members of the Climate Action Council that deny the existence of any implementation issues associated with a renewable energy resource dependent electric system.  At the May 26, 2022 Climate Action Council meeting, Paul Shepson Dean, School of Marine and Atmospheric Sciences at Stony Brook University claimed that the conversion cannot be unreliable at 23:39 of the recording.  Robert Howarth, Professor, Ecology and Environmental Biology at Cornell (starting at 32:52 of the recording) said: “Clearly one can run a 100% renewable grid with reliability”.   In this article, I describe a couple of recent articles that highlight some of the issues associated with this conversion that the academics overlook.

Renewable Energy Systems

I have prepared a page that documents the work of various authors that describe the complexities of the energy system and problems associated with over-reliance on intermittent wind and solar generating resources.  One of the resources is a series of posts at Climate Etc by Planning Engineer who posts under the pseudonym because he wanted to frankly share his personal views and not have them tied directly to his current employer.  Recently he posted an article entitled Will California “learn” to avoid Peak Rolling Blackouts? that provides a good overview of upcoming reliability issues.

The article presents a graph that shows recorded peaks and the projected 2022 value that caused issues earlier in September.  Then he explains that:

The most basic planning criteria is that a system should be able to survive the loss of the largest generating resource and the most critical transmission element during a peak load with no loss of load and no severe voltage declines or undamped system oscillations. Looking at the variability in load levels here, no particular challenges to planners are apparent. If “green” resources were capable of replacing traditional resources with minor adjustments, we would not see the problems we are seeing.

He goes on to explain why there was a problem.

Why is California challenged now and why might it continue to see challenges in the future?  Primarily because the focus on green energy is increasing the percentage of “green” intermittent resources. “Green” resources are not as dependable as traditional rotating machinery nor do they support the system as well. It is likely that these resources have been credited with more ability to provide capacity than is warranted, and when the rubber meets the road, they don’t perform as “expected”. Intermittent resources cause problems on both the generation side and the load side. Intermittent solar on the residential side serves to reduce load as seen by the Cal ISO. When solar is not performing well available load which is not displaced by solar on the residential side increases concurrent with solar reduction on the supply side.

If California were more honest about the capabilities of “green” intermittent resources planning would be enhanced. However, being honest about the capabilities of “green” resources would have consequences that some would find unacceptable. There has been a big push to make “green” options appear much more economic and capable than they are so that they will be more competitive. Subsidization of “green” resources by traditional uses occurs in many ways. In addition to crediting “green” resources above their dependable capability, others subsidies include directing costs associated with such additions to others. Being honest makes the “green” dream a much harder sell. Assuming that “green” resources work well saves other investment in the grid. This subterfuge tends to limit the cost increase that should be imposed by these resources, but does so at the cost of reliability. This tradeoff takes a while to see as we have built the electric grids to have very high levels of reliability at the bulk level. In the short term it looks like you are getting a cleaner, equally reliable system at a moderate cost increase. But as penetration levels increase, cost get higher and reliability gets much worse.

He points out that California policy makers are responsible for resource investment, resource allocations and how and when grid improvements are made to enhance reliability. Earlier in September there were reliability issues and extreme weather was blamed.  Obviously, the planning failed to account for weather but proper reliability planning has to account for the effects of extreme weather.  Planning Engineer points out that if “there truly was something unusual about the weather as driven by climate change, shouldn’t this have been anticipated by those responsible?” 

He concludes:

Ideally the power system represents the best balance between economics, reliability and public responsibility. California has reached a balance skewed by false expectations that “green” resources cannot meet. Creating a balance that looks at the true costs and reliability impacts of green resources should benefit electric users in California.

Ramping Up Renewables Can’t Provide Enough Heat Energy in Winter

Gail Tverberg writing at Our Finite World explains that one of the unappreciated benefits of fossil fuels is their ability to store energy that can be used to provide heat in the winter.  She notes that:

In some ways, the lack of availability of fuels for winter is a canary in the coal mine regarding future energy shortages. People have been concerned about oil shortages, but winter fuel shortages are, in many ways, just as bad. They can result in people “freezing in the dark.”

The article goes on to describe eight issues involved with winter energy use.  She points out that “batteries are suitable for fine-tuning the precise time during a 24-hour period solar electricity is used” but they cannot be scaled up to store solar energy from summer to winter.  There is no long duration energy storage resource available.

The article addresses hydro and wind energy resources in this context.  She argues that “ramping up hydro is not a solution to our problem of inadequate energy for heat in winter” and that “wind energy is not greatly better than hydro and solar, in terms of variability and poor timing of supply”.

She also lists five specific reasons that “when wind and solar are added to the grid, the challenges and costs become increasingly great”.  All of these concerns are concerning by themselves and the combination of problems directly contradicts the Climate Act narrative that there are no serious challenges to reliability.  Two deserve attention.  The inherent variability of wind and solar generation creates power transients and those fluctuations need to be addressed.  The problem is that the magnitude of this problem is new and it is likely that learning how to address it is difficult to anticipate so corrections will be reactions to problems.  Supporters of the Climate Act transition seem to think that existing wind, solar and energy storage resources only need to be scaled up to the quantity needed.  What they miss is that the more resources built the less those resources will be used.  Tverberg points out that low-capacity factors hurts energy return on investment payback.  All of these issues should be considered but have not been addressed in the Scoping Plan.

Tverberg also point that the word “sustainable” has created unrealistic expectations with respect to intermittent wind and solar electricity.  She illustrates this issue as follows:

A person in the wind turbine repair industry once told me, “Wind turbines run on a steady supply of replacement parts.” Individual parts may be made to last 20-years, or even longer, but there are so many parts that some are likely to need replacement long before that time. An article in Windpower Engineering says, “Turbine gearboxes are typically given a design life of 20 years, but few make it past the 10-year mark.”

She notes that “energy modeling has led to unrealistic expectations for wind and solar”.  This is evident in the Integration Analysis projections.  It should be obvious that the Scoping Plan projections for future generating resources have to be reconciled with the work of the New York Independent System Operator but, so far, no plan has been announced to do that.

Finally, Tverberg argues that current pricing plans that enable the growth of wind and solar electricity have consequences.  They are displacing existing dispatchable resources such that those resources are no longer viable.  The result is “pushing a number of areas in the world toward a “freezing-in-the-dark” problem”.  She concludes: “The world is a very long way from producing enough wind and solar to solve its energy problems, especially its need for heat in winter.”

Conclusion

I cannot improve on Planning Engineer’s conclusion.  Substitute New York for California and his conclusion sums up the issue that the Climate Action Council should address in the Scoping Plan:

Will California learn to avoid peak rolling blackouts?  If reliability were a primary concern, this situation shouldn’t bubble up again in a few years. California should be able to properly credit the ability of its power resources and match them to projected weather ensuring adequate power. If other priorities prevent responsible steps to ensure reliability, then those priorities, not the weather, should claim responsibility for the consequences. If California wants to continue as they have, they should be honest and make statements such as the following:

This is the end of affordable, reliable electric service as we understood it for most of the last 50 years. We are choosing to go with “green “technology to deal with the climate crisis. Keeping past reliability levels will raise your costs tremendously. As we try to put on limit on costs this will decrease your reliability. At times the power will not be there. We’ve all got help each other out.

New York Independent System Operator Draft Scoping Plan Comments

The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050.  The comment period for the Draft Scoping Plan that outlines how to meet that goal recently ended.  Here I describe comments submitted by the New York State Independent System Operator (NYISO). 

Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies.  I submitted comments on the Plan and have written extensively on implementation of New York’s response to that risk because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that this supposed cure will be worse than the disease.  The opinions expressed in this post 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.

Climate Act Background

The Climate Act establishes a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council.  Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that tried to quantify the impact of the strategies.  That material was used to write a Draft Scoping Plan that was released for public comment at the end of 2021. The Climate Action Council states that it will revise the Draft Scoping Plan based on comments and other expert input in 2022 with the goal to finalize the Scoping Plan by the end of the year.

New York State Independent System Operator

The predecessor organization to the  NYISO was created after the Northeast Blackout of 1965.  New York’s seven investor-owned utility companies established the New York Power Pool (NYPP), to address the reliability problems exposed by the blackout.  In the 1990s New York’s electric system was de-regulated and the Federal Energy Regulatory Commission (FERC) recommended the formation of independent entities to manage energy transmission and generation and the NYISO was established to replace the NYPP.  Because the change to the wholesale electricity market is the reason for their existence, the NYISO unquestioningly supports market driven responses to any problem.  This is evident in their Draft Scoping Plan comments.

The NYISO manages the electric system.  They have to balance the instantaneous supply of electricity between the generators and customers across the state in the de-regulated electricity market.   They manage the supply of power and maintain the frequency across the state and with their connections to other operating systems.  In addition, the NYISO has to plan for future changes to the system.  At this time the biggest factor for change is the Climate Act so their comments are important to understand.

Comments on Draft Scoping Plan Recommendations

The NYISO comments included comments on four aspects of future power generation strategies:

  • Fossil Generator Retirements Must Be Coordinated with Replacement Resources,
  • Accelerate Growth of Renewable Generation and Other Resources,
  • Storage Provides Value and Must Work in Concert with Generation, and
  • Interconnection Process Improvements

The NYISO comments emphasized that the drive to retire fossil-fired generating units has to be coordinated with replacements. They explained (their emphasis added) that:

A sufficient fleet of new generation resources that satisfy the CLCPA, with the appropriate reliability attributes, must be available before the existing, traditional generators retire voluntarily or are forced out of service. An essential step to facilitate the orderly transition from traditional generators to emission-free electricity is promulgation of environmental regulations with defined milestones and ample lead time for new resource development. For example, firm regulatory milestones that define emission limits to be achieved on specified dates and compliance plan obligations that require generators to describe their approach to compliance give the NYISO planning processes essential information to consider and share with stakeholders.

NYISO is very concerned that Administration policy appears to build as many renewables as possible and shut down as much fossil infrastructure at the same time without a strategic plan.  The comments stated:

Proposing environmental regulations with defined milestones to facilitate the CLCPA mandates would help protect electric system reliability by allowing the existing reliability processes to more accurately review and evaluate reliability needs. The Draft Scoping Plan provides that the DEC should assess regulatory options to reduce emissions from fossil generators to the maximum extent practicable to achieve the requirements of the CLCPA while maintaining electric system reliability. The DEC should examine all potential regulatory options, including new regulations and/or permit requirements or amendment of current regulations and/or permitting requirements, to determine the most efficient, effective, and enforceable format to achieve the determined emissions reduction targets and the CLCPA requirements. The process should include effective mechanisms for input and comments from stakeholders prior to a formal proposal under the State Administrative Procedures Act, similar to the process used in promulgating the DEC “Peaker Rule,” 6 NYCRR Subpart 227-3

The NYISO strongly encourages the DEC and other state agencies to pursue new or amended regulations to implement emissions reductions in an orderly, predictable manner. The process should include effective mechanisms for input and comments from stakeholders prior to a formal proposal. This exact approach proved effective when the DEC developed the Peaker Rule in 2018-2019.

NYISO commented on the pace of accelerated growth of renewable generation and other resources necessary to meet the timeline and targets of the Climate Act. 

New resources will be necessary to serve load and provide reliability services in place of the generators that will retire. The Draft Scoping Plan contemplates accelerating the growth of large-scale renewable generation, offshore wind generation, distributed generation, and distributed energy resources. This growth is envisioned, in part, through recommendations that the state accelerate adoption of innovative technologies and programs that increase hosting capacity such as flexible interconnection, hybrid systems, and coupling resources with energy storage or controlled load.

NYISO makes the point that even the Draft Scoping Plan recognizes that wind, solar, and energy storage are inadequate to meet the requirements of a zero emissions electric system in 2040.

The Draft Scoping Plan also correctly observes that dispatchable and emissions-free resources, with operating characteristics similar to fossil generators, will be equally, if not more important, to protect consumers from electric service interruptions. It states:

“The current system is heavily dependent on existing fossil fueled resources to maintain reliability. To ensure reliability and that generation is available when needed, dual fuel capability currently provides oil back up during periods of high gas and electric demand. To replace these units, dispatchable and emissions-free resources will be needed to balance the system and must be significant in capacity, be able to come on-line quickly, and be flexible enough to meet rapid, steep ramping needs. The importance of developing large amounts of dispatchable generation is echoed in the Power Grid Study, Pathways Study, and NYISO Grid-in Transition and Climate Change Study.”

There is an additional complication that is often overlooked outside of the industry.  NYISO not only has to figure out how the infrastructure has to be changed to meet the Climate Act requirements they also have to design market mechanisms that will induce the development of the required infrastructure.

The NYISO supports the State’s consideration of how the wholesale markets can work in conjunction with financial incentives, e.g., Clean Dispatch Credits (“CDC”) or a renewable energy credit (“REC”)-like product, to increase the number of new flexible resources interconnecting to the electric grid. Such salable attributes could encourage new technologies that run on storable fuels, as opposed to wind or solar energy. Incentives could also encourage storage resources to possess the capability to charge from the grid, regardless of whether they are coupled with generation or load resources. The option, or technical capability, to charge from the wholesale electric grid improves provision of reliability services by increasing the overall ability of resources to inject or withdraw energy from the grid and lowers overall prices for consumers when the storage resource charges at a lower cost.

The NYISO commented that storage provides value and must work in concert with generation.  Their comments stated:

The Draft Scoping Plan observes that a portfolio of energy storage technologies will be needed to support balancing the intermittency of energy production as more weather-dependent renewable energy generation connects to the grid. Existing and newer, long-duration, storage will be needed to maintain reliability as the state approaches 2040. This suite of storage technologies, however, will be needed well before 2040 to reach the State’s energy policy goals.

The comments also provide an explanation why storage requirements are complicated.

While storage is a critical part of the future resource fleet, it is only capable of being part of the solution. The electric system will require electricity production to reliably meet demand across a wide range of conditions, every day of the year. Battery storage resources can help to fill in short term reductions in renewable resources output, but extended periods of low- or zero-renewable resource output will rapidly deplete the short duration storage capabilities of existing battery technologies. The resource fleet must include generators that operate on storable fuels in addition to renewable resources and batteries. At times, renewable resource production may be insufficient to serve other load and to provide the charging capability needed for the large levels of storage expected to enter the system.  These circumstances could extend the periods when storage resources are unable to supply energy to serve load. A successful transition requires replacing the reliability contributions of the existing fleet of generation as their performance capabilities will be no less essential in a future grid than they are today.

The concerns about market mechanisms for energy storage devices are also included in the comments:

The NYISO seeks the lowest production costs for consumers. To allow the markets to seek the lowest production cost, all technologies that can support the system needs must be able to participate. The NYISO regularly reviews market rules to accommodate participation of new and emerging resources, such as energy storage resources through market participation. When the capabilities of a particular technology require changes to existing market rules, the NYISO has evolved its markets and its Tariffs to accommodate participation along the lines of the Draft Scoping Plan description of expanding wholesale market eligibility participation rules for new policy resources. For example, in 2020, the NYISO implemented a participation model for energy storage resources (“ESRs”) and, in 2021, the NYISO expanded the participation model to accommodate co-located resources consisting of a combination of storage and other generating technologies, such as wind or solar. The NYISO integrated ESRs as supply resources in both instances, not as providers of transmission service.  Although ESRs, like other resources, can be dispatched to prevent an overload of a transmission facility, they do not change the thermal capability of a transmission facility and, therefore, do not change the ratings of transmission facilities. Like other types of suppliers, ESRs can provide dispatchable services to help mitigate transmission constraints and can serve load to meet local reliability needs and defer infrastructure investments.

The electric grid has been described as the world’s largest machine because the generators and users are all connected. The NYISO comments address interconnection process improvements:

To support development of new generation resources, the Draft Scoping Plan recommends that the state speed up the pace of processing interconnection applications and emphasize the need for right-sizing human resources at utilities to mitigate delays in application processing. Interconnection rules that support grid reliability, along with siting and other regulatory processes that facilitate timely review and consideration of projects, are necessary to effectively respond to the rapid growth of projects being developed in response to the state’s clean energy policies. The NYISO is committed to continue working with stakeholders to assess how its processes can be enhanced to better manage the increasing volume of resources while still providing the critical reliability analysis needed.

An underlying premise of the NYISO comments is the insinuation that there are significant logistical issues associated with schedule.  The comments describe changes to the process for connecting new generating sources to the grid:

The NYISO’s generation interconnection study process identifies potential adverse reliability impacts associated with new resources interconnecting to FERC jurisdictional distribution and transmission. The process, which requires significant coordination among the NYISO, facility developers, and affected transmission owners, identifies necessary system upgrades and their estimated costs to protect electric system reliability. This allows investors to make more informed investment decisions. To facilitate the dramatically increasing number of interconnection requests, the NYISO has been working with stakeholders to implement improvements to the interconnection study process. NYISO completed a comprehensive redesign of the interconnection study process in 2019. The redesign offers greater flexibility and expedited study options to developers seeking the necessary information to interconnect to the grid. The enhancements have proven effective in accelerating the interconnection study process.

The numbers for new projects are notable:

The improvements were applied for the first time to the Class Year 2019, the largest in the NYISO’s history, with 66 projects representing 7,254 MW of capacity, and helped the NYISO to bring the Class Year process to closure in record time. Since 2019, the number of new interconnection requests has continued to increase, reaching 197 requests per year and 387 projects with ongoing interconnection studies at the end of 2021.

Nonetheless, more changes are needed:

The NYISO continues to review and improve its interconnection process, including a current initiative under discussion with stakeholders regarding improved coordination between the various interconnection processes. In addition, the NYISO anticipates significant additional interconnection process changes will be required in later 2022 and 2023 prompted by FERC’s Notice of Proposed Rulemaking regarding Improvements to Generator Interconnection Procedures and Agreements (Docket No. RM22-14-000). Given the volume of interconnection requests it is imperative to further streamline interconnection processes.

My primary concern is generation but of course the NYISO has to also worry about transmission and distribution strategies for the use of diffuse renewable resources.  The NYISO comments described their concerns:

The Draft Scoping Plan recommends that the state expand electricity transmission and distribution systems to support energy delivery, and, building on the Power Grid Study, continue research, development, and demonstration (“RD&D”) and rapid deployment of advanced grid technology. The transmission-focused efforts should strive to alleviate transmission system bottlenecks to allow for better deliverability of renewable energy throughout the state and unbottle constrained resources to allow more hydro and/or wind imports and the ability to reduce system congestion. In addition, the Draft Scoping Plan encourages optimized utilization of existing transmission capacity and rights of way by utilities to accelerate investments in their local systems. These actions will facilitate renewables development and enhance the electrification of transportation and grow safety and resiliency.

The rest of the comments described the planning processes used.  I mentioned the NYISO’s unwavering support of market mechanisms to solve any electric system issue.  There are descriptions how public policy requirements are addressed with public planning.  Similarly, they address economic issues associated with transmission constraints. 

Relative to the Climate Act the most important planning process is related to reliability.  There is a good summary of the process that they use.

NYISO reliability planning processes evaluate reliability needs that are arising due to a shifting resource mix, as higher-emitting, controllable fossil generators deactivate and new renewable, intermittent generation, and other clean energy supply resources enter service. The NYISO’s reliability processes form a baseline system that identifies transmission and resources expected to enter into service, and transmission that is needed to maintain reliability. Additional transmission infrastructure needed for public policy requirements, like the CLCPA, build on these reliability analyses and solutions.

The NYISO comments seems to be satisfied that the Draft Scoping Plan adequately addresses the NYISO reliability planning process:

The Draft Scoping Plan recommends that the State conduct established biennial evaluations to assess the state of bulk power system reliability in consultation with the NYISO and the New York State Reliability Council. The NYISO supports this recommendation and agrees that ongoing evaluations and transmission system reliability planning are critical to maintaining an energy secure and sustainable system for New York. The NYISO has established processes that should be used to support the Draft Scoping Plan recommendation. The NYISO’s reliability planning processes identify reliability risks and, if found, include actions such as solicitations of transmission and resource solutions needed to maintain reliable electric service. These processes are designed to provide the baseline reliable system on which to build the grid of the future, integrating renewable resources and storage to attain the requirements of state climate change laws. The frequency and structure of these planning studies allow the NYISO and stakeholders to regularly review study assumptions and scenarios based on up-to-date operational experience. Review of the State’s power system performance in conformance with established operations requirements will be critically important throughout the clean energy transition.

The reference for this commitment (footnote 37) is:

Draft Scoping Plan at p. 171 (“Continual Evaluation: The State should conduct established biennial evaluations to assess the state of bulk power system reliability in consultation with the federally designated electric bulk system operator (NYISO) and the State and federally jurisdictional entity the New York State Reliability Council. These evaluations should ascertain if any program adjustments are needed to ensure continued safe and adequate electric service. They should be informed by the review of the State’s power system performance in conformance with established operations requirements and by relevant studies including the NYISO’s Reliability Needs Assessment”). 

There are two issues related to this continual evaluation requirement.  First and foremost, I believe that this evaluation should be a prerequisite for any implementation regulations. Once the Scoping Plan is complete it is the guideline for the New York’s energy planning but regulations have to be developed to implement the changes.  It is inappropriate to start implementing rules if the organization responsible for reliability has reservations about continued safe and adequate electric service. Secondly, I am not privy to the discussions between the NYISO and the Administration and neither are most members of the Climate Action Council.  To this point no one on the Council has spoken up to reign in the loudest ideological voices who believe the reductions have to be instituted no matter what, that the intent of the Climate Act is to ban all combustion sources, and that there are no reliability issues related to an electric system that depends upon renewable energy.

The NYISO resource adequacy comments are at odds with the vocal ideologues.  The comments emphasize that all options have to be considered at this time:

The Draft Scoping Plan recommends that the State and the NYISO examine all resource adequacy options and continue to improve compensation for resource adequacy contributions. It specifically calls for the state to continue working with the NYISO “on market enhancements that facilitate the resource transition, support investment, minimize costs to consumers, eliminate buyer- side mitigation (BSM) for Climate Act resources, and meet reliability.” The NYISO is continuously evaluating the accuracy and robustness of its underlying resource adequacy models, reliability metrics and probabilistic tools, and updating them to incorporate changing characteristics of the power system and resource fleet. The NYISO welcomes the opportunity to continue working on these efforts with the state and to build on the recent success of the comprehensive mitigation reform effort.

The only concession made by the Climate Action Council to the reliability concerns of the state’s experts and organizations who are responsible for keeping the lights on was a listening session last summer.  The NYISO comments summarize the issues:

The combination of solar, wind, and today’s battery storage technologies are not sufficient on their own to provide the services necessary to support reliability on the power grid. The resource adequacy challenge becomes attracting and retaining sufficient resources, including flexible resources, to maintain reliable service. The NYISO-administered energy and ancillary service markets alone do not provide enough revenue to attract sufficient investment to maintain adequate resources for system reliability. Thus, capacity markets provide and will need to continue to provide an additional revenue stream to support adequate investment to maintain the required levels of resource adequacy. As the fleet transforms and new challenges emerge, ongoing efforts will be needed to ensure that together the energy, ancillary service, and capacity market designs continue to support adequate investment.

The final comment I want to mention discusses the markets that are critical to achieving the Climate Act.  It is only possible to fully comprehend the magnitude of the challenge of a zero-emissions electric system if you understand the markets described.  I have seen no indication that the majority of the Council members have that knowledge.

The NYISO supports reliability primarily through three complementary markets: energy, ancillary services, and capacity. Wholesale electricity markets have successfully delivered efficiency gains on the grid and cleaner energy production, making them an effective platform for reflecting public policy and technological influences efficiently and reliably. In these markets, energy, regulation, and operating reserves are simultaneously procured to meet demand while respecting transmission limits. The NYISO has a proven record of enabling the entry of new technologies into the state’s competitive wholesale electricity markets consistent with state public policy objectives. The NYISO-administered wholesale energy markets are critical to successfully fulfilling the mission and goals of reliability and economic efficiency while also shifting investment risk from ratepayers to asset owners and serving as an effective platform for achieving New York State environmental objectives. As such, the NYISO is actively engaging stakeholders and policymakers in developing plans to meet the future challenges expected to arise from a grid characterized with high levels of energy supply from intermittent renewable and Distributed Energy Resources (“DER”).

Conclusion

It is telling that the NYISO comments had to emphasize the point that it is not good policy for the state to force fossil generator retirements until appropriate replacement generating resources are available.  Unfortunately, state agencies are promulgating policies that are not consistent with this obvious point.  The NYISO comments state the obvious point that an enormous quantity of renewable resources is going to have to be developed and point out that energy storage will be needed.  The comments also point out that dispatchable and emissions-free resources will be needed to balance the system.  Unfortunately, the comments do not explain the difficulty and challenge of developing this new resource and the risk of relying on this technology for a future electric system.

Never forget that the Climate Act is all about politics. It is evident that there are reliability concern disconnects between the public face of the Administration, the Climate Action Council scoping plan development, and the NYISO.  In order to address the problems raised by the NYISO the Administration is going to have to burst the bubbles of one or more of the pet positions of some of the Climate Act’s fervent supporters and their organizations.  The alternative is putting the state’s residents at unacceptable reliability risks.

Initial Impression of Climate Action Council Response to Public Comments on Transportation

The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050.  The comment period for the Draft Scoping Plan that outlines how to meet that goal recently ended.  The last two meetings of the Climate Action Council have offered some insights into the plans to address those comments.  I am not encouraged by what I have seen so far.

Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies.  I submitted comments on the Plan and have written extensively on implementation of New York’s response to that risk because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that this supposed cure will be worse than the disease.  The opinions expressed in this post 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.

Climate Act Background

The Climate Act establishes a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council.  Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that tried to quantify the impact of the strategies.  That material was used to write a Draft Scoping Plan that was released for public comment at the end of 2021. Since the close of the public comment period in early July staff has been updating the Integration Analyses and working through the comments to provide the Council with summaries for their review.

In this article, I will describe the response to the Transportation sector comments relative to the comments I submitted on this sector.  I submitted two comments on electric vehicles.  I noted that the Integration Analysis is making assumptions about future zero-emissions transportation implementation strategies without providing adequate referenced documentation.  The other comment addressed electric vehicle costs.  I also submitted a comment on high-speed intercity passenger rail transportation that is relevant to the September 13, 2022 Climate Action Council Presentation that will be the focus of this article.

Transportation Comments Response

The discussion of Transportation Summary Themes at the September 13, 2022 Climate Action Council meeting included “Several commenters suggested investments in rail infrastructure, to connect cities and move freight”. 

The staff recommendations stated that few changes in response to public comments were needed.  Relative to the railroad theme they noted that: “Emphasize that improving intercity passenger rail service, including High Speed Intercity Passenger Rail transportation, and strengthening the freight rail system is an important component of New York State’s economic future and environmental sustainability.”

I submitted a comment on high-speed intercity passenger rail transportation that is ignored in this response.  The Federal Railroad Administration (FRA), in cooperation with the New York State Department of Transportation (NYSDOT) completed the Empire Corridor Environmental Impact Statement (EIS) in 2014 to “evaluate proposed system improvements to intercity passenger rail services along the 463-mile Empire Corridor, connecting Pennsylvania (Penn) Station in New York City with Niagara Falls Station in Niagara Falls, New York.” This is the primary reference for Draft Scoping Plan Scenario 4 high speed intercity passenger rail transportation upgrades.

I evaluated the transportation sector vehicle miles traveled difference between Scenarios 2 and 3 compared to Scenario 4 due to rail passenger improvements.  Note that this basically proposed the development of a dedicated high-speed rail corridor between Buffalo and Albany.  The Draft Scoping Plan claims that “Incremental reductions from enhanced in-state rail aligning with 125 MPH alternative detailed in Empire Corridor Tier 1 Draft EIS” will provide a reduction of 200 million light duty vehicle miles at a per unit cost of $6 per mile or $1.2 billion.  I estimated that the only valid cost for the difference between the rail alternatives is $8.4 billion and that it would only provide a vehicle mile reduction of 64.7 million miles. 

Discussion

There are multiple issues associated with the presentation response to comments.  At the previous meeting the State acknowledged that they had not worked their way through the comments submitted as attachments.  My comment was submitted as an attachment so it is possible that it has not even been reviewed yet.  In my opinion, the only way to make detailed comments is through an attachment so I think many of the substantive comments may not have been evaluated yet.

It is not clear whether this presentation was only meant to be an overview of the comments received.  Alternatively, it could represent the entirety of the discussion of the comments for each of the sectors (Transportation, Agriculture and Forestry, Land Use, Local Government, and Waste) discussed. My specific comment was not mentioned and it is not clear if this was because they have not reviewed it yet or whether it was inconvenient for them to respond.  If this is supposed to be the final word on the comments for each of these sectors then it is clear that the stakeholder public comment process is just window dressing and that no meaningful revisions will be incorporated.

At one point the Council promised to provide all the comments for public review.  Of course, the odds that the comments will be provided in format that enables it to be evaluated easily is another thing.  I believe all the comments should be available by topic in a searchable formatted document.

I believe my specific comment has to be addressed on two levels.  On the first level, I identified a problem with their numbers.  Shouldn’t they have to respond to that error?  While it might not rise to the level where an explicit Climate Action Council decision is needed, I do think the Council has to decide what level of high-speed intercity passenger rail transportation improvements they are recommending. The response to this topic at this meeting “Emphasize that improving intercity passenger rail service, including High Speed Intercity Passenger Rail transportation, and strengthening the freight rail system is an important component of New York State’s economic future and environmental sustainability” is just a bunch of words devoid of meaningful comment.

I also noticed a bias in the comment descriptions.  For example, “Generally, there was strong support for electrification policies in the draft plan” compared to “Some commenters expressed concern over the costs of electrification, particularly in rural communities and for larger vehicles” inappropriately indicates the rates the level of support based on numbers.  The value of a comment is the quality of the argument not the number of people who submitted the argument.  The statement “Several detailed comments supported the development of renewable and/or low-carbon fuels, while many commenters expressed opposition, describing such fuels as a ‘false solution’ “ is particularly problematic because it suggests that no matter how strong the technical argument, if enough ideologues using slogans oppose it that the Council is going to side with the slogans. 

Conclusion

I am not surprised that my comments were ignored.  However I am terrified that the Council may ignore the comments submitted by the New York Independent System Operator and the New York State Reliability Council.  There was no mention of any need to reconcile the Integration Analysis with the recent NYISO 2021-2040 System & Resource Outlook report.  The projections are significantly different and the citizens of New York deserve to have them reconciled clearly and transparently.  It is entirely inappropriate for the state to be committed to go down a transformational energy policy path based on the work of unelected bureaucrats who are not responsible for keeping the lights on without incorporating the input of the state’s experts who are responsible.

New York State Reliability Council Draft Scoping Plan Comments

The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050 and the comment period for the Draft Scoping Plan that outlines how to meet that goal recently ended.  Here I describe comments submitted by New York State Reliability Council.  This is another instance in which the experts are not explicitly saying this is nuts but a little bit of reading between the lines indicates that they believe the proposed Climate Act transition will end badly.

Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies.  I submitted comments on the Plan and have written extensively on implementation of New York’s response to that risk because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that it will adversely affect reliability, impact affordability, risk safety, affect lifestyles, and will have worse impacts on the environment than the purported effects of climate change in New York.  New York’s Greenhouse Gas (GHG) emissions are less than one half one percent of global emissions and since 1990 global GHG emissions have increased by more than one half a percent per year.  Moreover, the reductions cannot measurably affect global warming when implemented.   The opinions expressed in this post 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.

Climate Act Background

The Climate Act establishes a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council.  Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that tried to quantify the impact of the strategies.  That material was used to write a Draft Scoping Plan that was released for public comment at the end of 2021. The Climate Action Council states that it will revise the Draft Scoping Plan based on comments and other expert input in 2022 with the goal to finalize the Scoping Plan by the end of the year.

New York State Reliability Council

The New York State Reliability Council (NYSRC) is the other organization that has reliability responsibilities in New York.  According to their Draft Scoping Plan comments:

The NYSRC was established to promote and preserve the reliability of the New York State Power System by developing, maintaining and, from time to time, updating the reliability rules (“Reliability Rules”) that govern the NYISO’s operation of the state’s bulk power system. The NYSRC develops Reliability Rules in accordance with standards, criteria and regulations of North American Reliability Corporation (“NERC”), Northeast Power Coordinating Council (“NPCC”), FERC, the Commission, and the Nuclear Regulatory Commission  The NYISO/NYSRC Agreement provides that the NYISO and all entities engaged in transactions on the New York State power system must comply with the Reliability Rules adopted by the NYSRC.  The NYSRC Reliability Rules have been adopted by the New York State’s Public Service Commission under its Public Service Law authority prescribing reliability rules necessary to ensure safe and adequate service.

Installed Reserve Margin

The standard for the required generating capacity relative to the expected load is called the Installed Reserve Margin.  The NYSRC comments on the Draft Scoping Plan defined the standard and talked about the expected changes in what is required now and what is expected in the future:

One of the major responsibilities of the NYSRC is to set the annual Installed Reserve Margin (IRM) for the New York Power System. The IRM is the reserve resource capacity over and above that required to meet peak load and is needed to maintain minimum levels of reliability in New York. This is necessary based on the recognition that the availability of generation resources may be limited by forced outages or loss of fuel supply, including periods with little to no sun or wind. Typical unavailability figures for fossil fueled generation in New York is in the order of ~15% (~85% availability) largely based on forced outage performance.

NYSRC determined that the IRM for the 2022 – 2023 capability year is 19.6% and that IRM was adopted by the New York Public Service Commission for the New York Control Area on March 16, 2022 (Case 07-E-0088).

The table shows the increase in required reserve capacity from 22,577 MW (78.15% IRM) in 2025 to 102,517 MW (205.94% IRM) in 2050. These numbers need to be pondered in perspective. To supply a forecasted peak load of 49,780 MW in 2050, 152,297 MW of capacity will be needed, roughly 3 times the peak load at that time. The corresponding numbers for 2030 are that for a peak load of 29,640 MW, a capacity of 68,244 MW is needed, more than twice as much. Given that the 2020 installed capacity is 44,023 MW, around 22,000 MW of additional capacity must be built in the next 7-8 years.

NYSRC Comments

The NYSRC comments included an illustration of the magnitude of future resource requirements based on the Draft Scoping Plan for Scenario 3, Annex 2.  The following table shows the amount and type of installed capacity required to meet Climate Act goals and meet NYSRC’s resource adequacy reliability criterion of 1-day-in-10-years. The text in red was added to demonstrate the total installed capacity, the peak load, the required reserve capacity and the IRM for the years 2025 through 2050.

The comments describe the ramifications of these results:

The table shows the increase in required reserve capacity from 22,577 MW (78.15% IRM) in 2025 to 102,517 MW (205.94% IRM) in 2050. These numbers need to be pondered in perspective. To supply a forecasted peak load of 49,780 MW in 2050, 152,297 MW of capacity will be needed, roughly 3 times the peak load at that time. The corresponding numbers for 2030 are that for a peak load of 29,640 MW, a capacity of 68,244 MW is needed, more than twice as much. Given that the 2020 installed capacity is 44,023 MW, around 22,000 MW of additional capacity must be built in the next 7-8 years. 

The analysis makes a couple of assumptions:

The table assumes that intermittent generation capacity from wind and solar resources increases from 13,319 MW in 2025 to 96,629 MW in 2050.

The table also assumes that the magnitude of new technology requirements for Zero-Carbon Firm Resource (RNG, green hydrogen or other) increases from 5,489 MW in 2035 to 25,359 MW in 2050. Long-Term Battery Storage or other increases from 1,500 MW in 2025 to 19,212 MW in 2050. None of these technologies presently exist commercially for utility scale application.

It is politically impossible for these experts to explain that not only do these technologies not exist commercially but there are physical limitations that suggest that a commercially viable and affordable resource like this may never be developed.  The reality is that this is not just a stretch, it is a massive leap in technology.

The NYSRC comments go on to explain that there are other implementation factors that complicate the transition that the Draft Scoping Plan cavalierly claims will happen because of political will:

Some of the new renewable resources will be located behind the meter at retail levels (i.e.. solar PV, batteries, and EV charging). This will also require investment in distribution system automation to protect reliability, cyber-security and public safety. The role of the Distribution System Operator will become even more critical in this complex operating environment.

I think that the observation that the logistics of building the infrastructure necessary to meet the Climate Act goals is particularly important:

The amount of new generation that needs to be built to maintain system reliability in a zero-carbon environment is sobering. This change represents an unprecedented increase in capital investment in resource capacity along with a corresponding increase in transmission and distribution capacity. Further, this transition must be managed during a time of high inflation, and supply chain delays, permitting challenges, and high demand for renewable resource equipment, not just in New York, but around the globe.

There is another technical issue.  My comments on the electric system transition pointed out that it is not clear if the Draft Scoping Plan considered ancillary services.  The NYSRC comments explain:

One other aspect that must be kept in mind is that renewables and storage devices work internally with direct current (DC) and must ultimately be interconnected to a grid that works with alternating current (AC). To accomplish this, devices called inverters that transform DC into AC and vice versa are used. These inverter-based resources (IBR) are starting to be used in increasing numbers in the USA and it is becoming clear through actual reliability impact events that more work is still necessary with respect to the reliability of IBRs, and standards need to be adopted for a reliable transition.

I found no mention of this issue in the Draft Scoping Plan spreadsheets of inverter costs.  Finally, it is telling that the NYSRC notes that there will be a learning curve for operating a system based on intermittent and diffuse renewables. 

Furthermore, even if we build all this capacity on time, operating a system largely based on renewable resources is not the same as operating the system of today. The performance and responsiveness of existing generation must be emulated to keep the lights on. We have no experience in operating a bulk power system that we will need to operate by 2030 and beyond.

The fact is that New York’s current stringent reliability rules are based on hard learned experience.  It is incredibly optimistic to think that the system will make the transition without unanticipated issues that result in blackouts.

NYSRC Recommendations

One of the things that I think is most important is a feasibility study.  As a result, I was hearted by the NYSRC recommendation that “the proposed Climate Action Council strategy be reviewed for application in the short-term based upon practical considerations for the period 2025 to 2030”.  The NYSRC comments list the rationale for this review:

Practical considerations affecting the availability, schedule and operability for new interconnections include: interconnection standards; site availability; permitting; resource equipment availability; regulatory approval; large volume of projects in NYISO queue and study process; scalability of long-term battery storage and other technologies; operational control; impact of extreme weather; consideration of a must run reliability need for legacy resources. In addition, the pace of transportation and building electrification, the timing of any natural gas phase-out and their impact on the electric T&D system must also be carefully studied from technical, economic and environmental perspectives. Together, these practical considerations require the development of reliable zero emission resources to be conscientiously sequenced and timed in the near term (through 2030) to ensure broader GHG reductions in all sectors beyond 2030.

It is noted that delaying or changing a CLCPA goal would be preferable to the risk of a wide scale blackout and associated public safety concerns if it should ever appear that the implementation of the CLCPA’s goals may pose a significant risk to electric system reliability, including the potential risk of a system-wide blackout,

In conclusion, there are many unknowns in the transition to CLCPA’s goals. The risks of not reaching a goal in the time required is real. The CAC and all participants in the transition to an emissions free grid need to stay alert to the critical importance of keeping the system functioning within reliability criteria. Each time that an existing unit must retire or stop operating through some regulatory action, there is a need to confirm that reliability criteria will still be met without that unit.

Conclusion

I have written several articles pointing out that the Climate Action Council is not listening to the experts.  The first post (New York Climate Act: Is Anyone Listening to the Experts?) described the NYISO 2021-2030 Comprehensive Reliability Plan (CRP) report (appendices) released late last year.  The difficulties raised in the report are so large that I raised the question whether any leader in New York was listening to this expert opinion.  The second post (New York Climate Act: What the Experts are Saying Now) highlighted results shown in a draft presentation for the 2021-2040 System & Resource Outlook that all but admitted meeting the net-zero goals of the Climate Act are impossible on the mandated schedule.  Finally, I described the “For discussion purposes only” draft of the 2021-2040 System & Resource Outlook report described in the previous article.  This report highlights multiple feasibility concerns that must be addressed to have any hope of this working, shows that implementation on the schedule proposed will be very difficult and highlights the need for implementation planning. 

The NYSRC comments reiterate all the points mad by the NYISO, The organizations responsible for the relatability of the New York electric grid have raised numerous technological issues that must be addressed going forward for the transition.  Unfortunately, the loudest voices on the Climate Action Council have said that anyone saying there are issues related to using renewable resources are misinforming the public and no leaders on the Council have spoken up to reign in those statements.  If Climate Act implementation to net-zero does not address the issues raised then blackouts are inevitable.

The Latest from the Experts on New York’s Climate Act Implementation

This article was first published at Watts Up With That

I have published two previous articles about New York Independent System Operator (NYISO) analyses related to New York’s Climate Leadership and Community Protection Act (Climate Act).  This post describes what I believe is an important new analysis of the future of New York’s electric system.

New York’s Climate Leadership and Community Protection Act (Climate Act) Act establishes a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050.  I have written extensively on implementation of the Climate Act.  Everyone wants to do right by the environment to the extent that efforts will make a positive impact at an affordable level.  My analysis of the Climate Act shows that the ambitions for a zero-emissions economy outstrip available renewable technology such that the transition to an electric system relying on wind and solar will do more harm than good.  The opinions expressed in this post 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.

Background

The implementation plan for New York’s Climate Act “Net Zero” target (85% reduction and 15% offset of emissions) by 2050 is underway.  The Climate Action Council has been working to develop plans to implement the Act.  Over the summer of 2021 the New York State Energy Research & Development Authority (NYSERDA) and its consultant Energy + Environmental Economics (E3) prepared an Integration Analysis to “estimate the economy-wide benefits, costs, and GHG emissions reductions associated with pathways that achieve the Climate Act GHG emission limits and carbon neutrality goal”.  Integration Analysis implementation strategies were incorporated into the Draft Scoping Plan when it was released at the end of 2021.  Since the end of the public comment period in early July 2022 the Climate Action Council has been addressing the comments received as part of the development of the Final Scoping Plan that is supposed to provide a guide for the net-zero transition.

Unfortunately, the Climate Action Council has not confronted reliability issues raised by New York agencies responsible for keeping the lights on.  The first post (New York Climate Act: Is Anyone Listening to the Experts?) described the NYISO 2021-2030 Comprehensive Reliability Plan (CRP) report (appendices) released late last year.  The difficulties raised in the report are so large that I raised the question whether any leader in New York was listening to this expert opinion.  The second post (New York Climate Act: What the Experts are Saying Now) highlighted results shown in a draft presentation for the 2021-2040 System & Resource Outlook that all but admitted meeting the net-zero goals of the Climate Act are impossible on the mandated schedule.  This article describes the “For discussion purposes only” draft of the 2021-2040 System & Resource Outlook report described in the previous article.  While there may be minor changes to the document itself, I am comfortable saying that the major findings will not change substantively.

System and Resource Outlook Summary

The Executive Summary makes the point that the Climate Act is driving changes to the generating system, the transmission grid and the demand landscape.  As a result, this “leads to re-thinking how and where electric supply and storage resources evolve, and how to efficiently enable their adoption to achieve energy policy targets”.  The summary goes on to note:

This 2021 – 2040 System & Resource Outlook (the Outlook), conducted by the New York Independent System Operator (NYISO) in collaboration with stakeholders and state agencies, provides a comprehensive overview of potential resource development over the next 20 years in New York and highlights opportunities for transmission investment driven by economics and public policy in New York State. The Outlook together with the NYISO’s 2021-2030 Comprehensive Reliability Plan (CRP) represent the marquee planning reports that provide a full New York power system outlook to stakeholders, developers, and policymakers.

The Outlook examines a wide range of potential future system conditions and enables comparisons between possible pathways to an increasingly greener resource mix. By simulating several different possible future system configurations and forecasting the transmission constraints for each, the NYISO:

  • Projected possible resource mixes that achieve New York’s public policy goals while maintaining grid reliability;
  • Identified regions of New York where renewable or other resources may be unable to generate at their full capability due to transmission constraints;
  • Quantified the extent to which these transmission constraints limit delivery of renewable energy to consumers, and;
  • Identified potential opportunities for transmission investment that may provide economic, policy, and/or operational benefits.

There are many potential paths and combinations of resource and transmission builds to achieving New York’s climate change requirements. As the current power system continues to evolve, evaluating a multitude of expansion scenarios will facilitate identification of common and unique challenges to achieving the electric system mandates New York State has set for 2030 and 2040. A thorough understanding of these challenges will help build a path for investors and policymakers to achieve a greener and reliable future grid efficiently and cost effectively. Through this Outlook several key findings were brought to light:

Four potential futures are evaluated to best understand the challenges ahead. A Baseline Case evaluates a future with little change from today. A Contract Case includes approximately 9,500 MW of renewable capacity procured by the state and evaluates the impact of those projects. Finally, a Policy Case postulates and examines two separate future scenarios that meet New York policy mandates.

Energy planning analyses such as this work normally evaluate different scenarios of the future by comparing them to a business-as-usual scenario.  In this instance the business-as-usual scenario does not include any of New York’s climate initiatives.  On the other hand, Climate Act Draft Scoping Plan analyses were perverted to “prove” the desired conclusion that the benefits were greater than the costs by comparing future scenarios against a reference scenario.  The Integration Analysis used a semantic trick to claim that some de-carbonization costs (such as de-carbonizing transportation costs) necessary to meet Climate Act targets did not have to be included in the comparison scenario because the electric vehicle conversion legislation was already “implemented”.  That approach took legitimate implementation costs out of the projections.  Of course, this also makes comparison of the NYISO work relative to the Draft Scoping Plan problematic.

The second estimate of the future in the Resource Outlook considered only those projects currently under contract:

Through an annual request for proposals, NYSERDA solicits bids from eligible new large-scale renewable resources and procures Renewable Energy Certificates (RECs) and Offshore Renewable Energy Certificates (ORECs) from these facilities. This Outlook included approximately 9,500 MW of new contracted renewable resources, including 4,262 MW of solar, 899 MW of land-based wind, and 4,316 MW of offshore wind. The addition of these resources to the existing system representation provides insights regarding their impact on system performance in the future.

The Outlook report noted the following Key Takeaways for the contracted renewables scenario:

The pace of renewable project development is unprecedented and requires an increase in the pace of transmission development. Every incremental advancement towards policy achievement matters on the path to a greener and reliable grid in the future, not just at the critical deadline years such as 2030 and 2040. In general, resource and transmission expansion take many years from development to deployment.

Coordination of project additions and retirements is essential to maintaining reliability and achieving policy. Coordination of renewable energy additions, commercialization and development of dispatchable technologies, fossil fuel plant operation, and staged fossil fuel plant deactivations over the next 18 years will be essential to facilitate an orderly transition of the grid.

Many more renewable resources have to be developed to meet the overall Climate Act net-zero goal by 2050 and the interim 2040 goal of “zero-emissions” electricity generation.  The NYISO analysis looked at two Policy Case scenarios that meet those targets:

Scenario 1 utilizes industry data and NYISO load forecasts, representing a future with high demand (57,144 MW winter peak and 208,679 GWh energy demand in 2040) and assumes less restrictions in renewable generation buildout options.

Scenario 2 utilizes various assumptions consistent with the Climate Action Council Integration Analysis and represents a future with a moderate peak but a higher overall energy demand (42,301 MW winter peak and 235,731 GWh energy demand in 2040).

Both scenarios project a blend of land-based wind, offshore wind, utility-scale solar, behind-the-meter solar, and energy storage will be needed to meet the CLCPA policy mandates through 2035. There are significant differences between these scenarios and the equivalent Draft Scoping Plan mitigation scenarios.  One of the big differences is the magnitude of a new generating resource called “dispatchable emission-free resources” (DEFRs):

These resources represent a proxy technology that will meet the flexibility and emissions-free energy needs of the future system but are not yet mature technologies that are commercially available (some examples include hydrogen, renewable natural gas, and small modular nuclear reactors). As more wind, solar, and storage plants are added to the grid, dispatchable emission-free resources must be added to the system to meet the minimum statewide and locational resource requirements for serving system demand when intermittent generation is unavailable.

The report warns:

Both scenarios include significant DEFR capacity by 2035, but it is important to note that the lead time necessary for development, permitting, and construction of DEFR power plants will require action much sooner if this timeline is to be achieved.

As part of the analysis the NYISO considered what would be needed if the DEFR capacity is not developed. They found that “The exclusion of DEFRs as a new technology option, while enforcing the retirement of fossil generators via the zero-emission by 2040 policy, exhausts the amount of land-based wind built and results in the replacement of 45 GW of DEFR capacity in Scenario 1 with 30 GW of offshore wind and 40 GW of energy storage.”  They also noted that the alternative did not address ancillary service requirements needed for the transmission system.

The Outlook report noted the following Key Takeaways for the Policy Case Scenarios:

Significant new resource development will be required to achieve CLCPA energy targets. The total installed generation capacity to meet policy objectives within New York is projected to range between 111 GW and 124 GW by 2040. At least 95 GW of this capacity will consist of new generation projects and/or modifications to existing plants. Even with these additions, New York still may not be sufficient to fully meet CLCPA compliance criteria and maintain the reliable electricity supply on which New York consumers rely. The sheer scale of resources needed to satisfy system reliability and policy requirements within the next 20 years is unprecedented.

To achieve an emission-free grid, dispatchable emission-free resources (DEFRs) must be developed and deployed throughout New York. DEFRs that provide sustained on-demand power and system stability will be essential to meeting policy objectives while maintaining a reliable electric grid. While essential to the grid of the future, such DEFR technologies are not commercially viable today. DEFRs will require committed public and private investment in research and development efforts to identify the most efficient and cost-effective technologies with a view towards the development and eventual adoption of commercially viable resources. The development and construction lead times necessary for these technologies may extend beyond policy target dates.

As the energy policies in neighboring regions evolve, New York’s imports and exports of energy could vary significantly due to the resulting changes in neighboring grids. New York is fortunate to have strong interconnections with neighboring regions and has enjoyed reliability and economic benefits from such connections. The availability of energy for interchange is predicted to shift fundamentally as policy achievement progresses. Balancing the need to serve demand reliably while achieving New York’s emission-free target will require continuous monitoring and collaboration with our neighboring states.

The important findings in the report led to the following recommendations:

Future uncertainty is the only thing certain about the electric power industry. From policy advancements to new dispatchable emissions-free resource technology innovation and ultimate development, the system is set to change at a rapid pace. Situational awareness of system changes and continuous assessment are critical to ensure a reliable and lower-emissions grid for New York. The Economic Planning databases and models will be continually updated with new information and the Outlook study will be improved and performed on a biennial basis.

To meet the minimum capacity requirement in 2040, at least 95 GW of new emission-free resources, including approximately 9.5 GW of new renewable resources, will be required to come on-line. Furthermore, to fully achieve the emission-free grid target by 2040, even more resources will likely be needed along with transmission to deliver the clean power to consumers. The scope of the additional renewable resource need is both substantial and unprecedented. Compared to the 2.6 GW capacity entering service in the past five years while New York experienced a net loss of approximately 2.2 GW, the installation rate in the next 20 years must increase significantly to achieve state law climate change requirements. State agencies should consider releasing a more detailed procurement schedule for renewable resources to guide the long-term system planning and provide clarity to the market.

Discussion

I noted earlier that I was comfortable saying that the major findings in this draft report will not change substantively when it is finalized.  I base that mostly on the fact that the NYISO Market Marketing Unit has reviewed the draft.  As part of their market monitoring responsibilities Potomac Electricreviewed the document relative to implications to New York’s de-regulated electric markets.  If you are interested in that particular aspect of electric system planning, I suggest checking out the memo.  For the rest of us, I only note that they state: “The 2021 Outlook is a major improvement to NYISO’s previous planning studies and provides important insights on the potential impacts of state policies on the NYISO system.”

More importantly, what about the Climate Action Council?  Unfortunately, as I pointed out before the Climate Action Council has not confronted reliability issues raised by New York agencies responsible for keeping the lights on.  In a series of meetings over the next couple of months the Council will have to address the Draft Scoping Plan comments made by the NYISO and the New York State Reliability Council that raised reliability concerns.  I hope. without any supporting evidence, that the Integration Analysis team is working with the NYISO planning staff to reconcile the differences between this analysis and theirs.

In the meantime, there are vocal members of the Climate Action Council that deny the existence of any implementation issues associated with a renewable energy resource dependent electric system.  At the May 26, 2022 Climate Action Council meeting Council members described their impressions of comments made at the public hearings.  I have prepared an overview summary of all the comments made during the Update on Public Hearings and Comments agenda item and wrote an article highlighting relevant comments.  In this regard, Paul Shepson Dean, School of Marine and Atmospheric Sciences at Stony Brook University talked about mis-representation at 23:39 of the recording:

Mis-representation I see as on-going.  One of you mentioned the word reliability.  I think the word reliability is very intentionally presented as a way of expressing the improper idea that renewable energy will not be reliable.  I don’t accept that will be the case.  In fact, it cannot be the case for the CLCPA that installation of renewable energy, the conversion to renewable energy, will be unreliable.  It cannot be.

Robert Howarth, Professor, Ecology and Environmental Biology at Cornell (starting at 32:52 of the recording) picked up on that theme.  He said that fear and confusion is based on mis-information but we have information to counter that and help ease the fears.  He stated that he thought reliability is one of those issues: “Clearly one can run a 100% renewable grid with reliability”.   Obviously, these views are at odds with this report.

There is one other point.  In addition to the reliability concerns of the net-zero transition I am very concerned about affordability.  The Draft Scoping Plan has avoided any mention of ratepayer impacts to date.  The NYISO projection methodology has that information because it is inherent in the models. It is a shame that it is not being reported.

Conclusion

This is an important report for New York but I also believe that there are ramifications for other net zero transition programs.  These findings must be reconciled with the Draft Scoping Plan projections for the future generating system.  The leadership of the Climate Action has repeatedly punted the responsibility for a feasibility study down the road as somebody else’s problem. This report highlights multiple feasibility concerns that must be addressed to have any hope of this working.  I believe that it shows that implementation on the schedule proposed will prove impossible.  The report also highlights the need for implementation planning.  Currently there is no plan for siting renewable resources where they are needed for the future system and this shows that it must be done.

With respect to other net-zero transition programs I think the discussion and implications of the dispatchable emissions-free resource are of interest.  The analysis shows that in order to minimize the storage and renewable over-build requirements this resource could be a better choice.   However, the report notes that DEFRs such as hydrogen, renewable natural gas, and small modular nuclear reactors are not commercially viable today. “DEFRs will require committed public and private investment in research and development efforts to identify the most efficient and cost-effective technologies with a view towards the development and eventual adoption of commercially viable resources.”  There is that nasty planning and feasibility is necessary component again.

NYISO Offshore Wind Profile Development

The implementation plan for New York’s Climate Leadership and Community Protection Act (Climate Act) “Net Zero” target (85% reduction and 15% offset of emissions) by 2050 is underway.  I think the biggest problem confronting any net-zero transition effort is matching variable wind and solar generation with load at all times.  This post describes an effort by the New York Independent System Operator (NYISO) to address that problem for offshore wind resources.  It is a great start but needs to be expanded for other sources of renewable generation and for as long a period as possible.

I have written extensively on implementation of the Climate Act.  Everyone wants to do right by the environment to the extent that efforts will make a positive impact at an affordable cost.  Based on my analysis of the Climate Act I don’t think that will be the case as proposed.  I believe that the ambitions for a zero-emissions economy outstrip available renewable technology such that the transition to an electric system relying on wind and solar will do more harm than good.  I am a retired meteorologist who started working for Niagara Mohawk in 1981 and have continued to work in the New York electric generating industry continuously since then.  Over that time, I have been involved in many energy planning activities that included meteorological components. The opinions expressed in this post 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.

Climate Act Background

The Climate Act established the Climate Action Council who is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  They were assisted by Advisory Panels who developed and presented strategies to meet the goals.  Those strategies were used to develop the Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies.  That analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021 and will be finalized in 2022. 

Renewable Resource Adequacy

I called the renewable resource adequacy problem the ultimate problem for the Climate Act as early as September 2020.  On August 2, 2021, the New York State Energy Research and Development Authority (NYSERDA) held a Reliability Planning Speaker Session to describe New York’s reliability issues to the advisory panels and Climate Action Council.  All the speakers but one made the point that today’s renewable energy technology will not be adequate to maintain current reliability standards and that a “yet to be developed technology” will be needed.  A recent article by David Wojick at PA Pundits International titled Unreliability Makes Solar Power Impossibly Expensive does a great job describing how renewable resource availability affects reliability.  I adapted his work to New York to analyze the impact on the Draft Scoping Plan.

There are serious problems when extreme weather affects the grid.  The Federal Energy Regulatory Commission (FERC) and the North American Electric Reliability Corporation (NERC) report on the February 2021 cold weather outages in Texas and the South Central United States described the event, the impacts and made recommendations.  According to the report this event was the fourth cold-weather event in the last ten years to affect bulk electric system reliability.  Cold weather caused problems that required rolling blackouts to avoid system instability and even worse problems for the electric grid.  Given that the weather conditions that caused these problems occurred recently I am taken aback that resources were not devoted to preventing re-occurrence.  Among the many recommendations two are relevant: “improving near-term load forecasts for extreme weather conditions” and additional study of “potential effects of low-frequency events on generators in the Western and Eastern Interconnections”.

In order to address this renewable resource variability problem, it is necessary to determine the worst-case meteorological conditions affecting wind and solar availability.   As long as the NYISO and other agencies responsible for electric system reliability understand the worst-case renewable availability conditions they can plan to prevent low availability impacts.  I submitted comments on the Draft Scoping Plan’s treatment of wind and solar resource availability and concluded that it was inadequate in this regard. I recommended that the State undertake a more comprehensive analysis of wind and solar availability to serve as input for future reliability planning.  I have also been trying to get the NYISO and New York State Reliability Council to consider the recommendations I made for a comprehensive availability analysis.  So far, I have not had any success getting a response.

Offshore Wind Power Profile Study

Despite my personal lack of success I was encouraged that the NYISO started a project in July to address offshore wind profile development.  In particular, they plan to develop wind power estimates for the New York offshore wind development areas that will estimate resource availability for a 20-year period.  I am going to highlight some of the slides in the presentation by DNV describing their work for the NYISO ICAP/MIWG/PRLWG Meeting on September 07, 2022.  Note that all the slides are copyrighted to either NYISO or DNV and are labeled as draft for discussion purposes only.  I am including a couple of slides to show what should be done on a more comprehensive basis for the Final Scoping Plan.

In my opinion, the critical consideration is the frequency, duration, and severity of periods when wind and solar resources are in “droughts” or low resource availability.  I described several recent applicable papers in my comments describing analyses to estimate the frequency and duration of periods with those conditions.  In order to provide a robust estimate of the wind and solar availability during worst case conditions I believe it is necessary to analyze as long a time period of historical meteorological data as possible. Fortunately, meteorological reanalysis descriptive data generated by modern weather forecast models but using observed data from decades ago is available for this application. This is exactly what DNV is proposing to do.

The DNV project description slide explains that they will use the historical data to generate detailed wind maps using a weather forecast model.  This output is combined with their model that projects wind energy output as a function of wind speed.  They are going to model wind energy production for seven potential development areas off Long Island and New Jersey.

The weather model slide describes their approach.  They are going to use a forecast model that takes historical data and calculates wind speed and direction on an hourly basis.  The inputs for their modeling include not only the observed meteorological data but also surface characteristics and surface temperatures.  Note that the model inputs extend far beyond the offshore wind study area.

The presentation also includes slides on wind power modeling, wind turbine power curve output, and describes their validation analyses.  They also described four different aspects that cause reductions in power output in their analysis.  At some point I should compare their assumptions with those used in the Draft Scoping Plan.  In order to minimize wake effects DNV is proposing 1 nautical mile spacing which seems higher than I have noticed elsewhere.

Discussion

I think that this analysis is a great start.  I only have one concern relative to the scope of work.  As far as I could tell the meteorological input data is available back to 1980.  However, this project only goes back to 2000.  I think it would be better to evaluate the 1980 to 2000 data specifically looking for wind droughts.  I know there was a huge ozone episode in August 1988 that had to include very light winds.  I have no idea how that period compares to “normal” but we won’t know because this analysis does not cover that period. 

This analysis is entirely appropriate for the offshore wind resource.  However, it does not address the onshore wind and solar resources.  The same type of analysis has to be done for those resources covering not only the entire state but also the area where New York could expect to import power.   Ideally, the ERA5 global reanalysis data base that goes back to 1950 should be used in the analysis to find the worst-case conditions.  It is not necessary to determine the renewable power output over the entire period and region.  Once the worst cases are identified then a power output model can be applied to those periods to determine how the electric system can be setup to avoid bulk electric supply disruptions. 

It is my professional opinion that until this comprehensive renewable energy resource evaluation is completed that New York State will unnecessarily risk catastrophic blackouts.  Because the worst-case resource availability is associated with the coldest or hottest periods, the loads are highest and the need to prevent blackouts most acute.