This past Friday and Saturday (February 3-4 2023) there was a brief shot intensely cold air to the Northeast US. This post includes a couple of descriptions of the implications of this weather event relative to the Climate Leadership and Community Protection Act (Climate Act) and I present some data describing the event.
This is another article about the Climate Act implementation plan that I have written because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition 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.
I am Thankful – Mark Stevens
Mark is a regular reader at this blog and has contributed several recent items for posting. He is a retired science and technology teacher from Long Island. His email to me this weekend is a perfect introduction to the issues raised by this weather event.
It was 3 degrees F Saturday morning with a wind chill of -3 degrees. All night the north wind raged, rattling “sealed” windows and doors but still blowing frigid air through them. I did everything I could: raise the boiler’s temperature, cover the big expanse of glass on the patio doors windows, pull the shades. I even added an electric heater in the room my tropical parrot resides so he doesn’t get a fatal pneumonia.
The possibility of a power failure crossed my mind with the overhead wires, high winds, many surrounding trees, and almost monthly power interruptions in the past. It would be an absolutely worst-case scenario if the power went out tonight. Frozen pipes next? I have a backup generator but the thought of going out in the howling cold night, fueling it, hooking it up, starting it, and monitoring the systems wasn’t that appealing.
But LIPA’s tree trimming maintenance and generation/distribution system upkeep allowed the power to stay on through the night and into the next day as I write this. We’re cozy, comfortable and safe. This kind of cold can kill.
I’m thankful we have a reliable, cost-effective electrical generation and distribution system. I’m thankful I have a natural gas-fired boiler that works 24/7 keeping me and my family safe and alive. I am thankful that I don’t rely on intermittent, expensive wind and solar generation as electricity sources that can fail at any time leaving me without power. I’m grateful I don’t have to rely on “backup” battery power that is grossly inadequate, expensive, highly polluting to manufacture and can cause a non-extinguishable toxic gas fire. I pray it does not change.
What’s Keeping the Heat On – James Hanley
James is a Fellow at the Empire Center. His post yesterday is a great overview of the problem facing New York as it continues the implementation of the Climate Act.
As another Arctic blast hits the Northeast and temperatures plunge, more energy is needed to keep New Yorkers warm. Where is that energy coming from?
A lot of it comes from natural gas, but there’s a big supply problem. Because of the state’s ban on fracking and its refusal to allow new and upgraded natural gas infrastructure, not enough gas can get to power plants to generate the electricity needed to keep the lights and heat on in everyone’s houses during times of extreme demand.
What gas is available gets bid up to eye-wateringly high prices. It’s hard to speak meaningfully of an average price for natural gas because the market is volatile, but the 2022 high price in Pennsylvania was $12.95 per million British thermal units (mmbtu). According to one energy industry source, during last Christmas’s cold snap, the price in New York hit $100 per mmbtu.
That translated into an electricity price of nearly 90 cents per kilowatt hour, compared to the average New York price of 19 cents.
That assumes the power plant can even get the gas it needs to operate. With such severe gas shortages, some natural gas-fired plants had to shut down for lack of fuel. What gets burned to take their place – fuel oil – is not only expensive, but also much dirtier and producing more carbon dioxide than natural gas.
So, ironically, because New York has limited the supply of the much cleaner burning natural gas in order to prevent pollution and CO2, the power industry has no choice at times but to spew more pollution into disadvantaged communities and add more carbon to the atmosphere.
The hope is that renewables will one day suffice to supply the electricity we need to heat our homes on a day like this. That hope is irresponsible, because wind and solar aren’t reliable and there is no available “clean” backup power source.
Below is a graph from the New York Independent System Operator’s (NYISO) real-time dashboard, showing fuel use on February 2 into the early hours of February 3. On what was otherwise a reasonably good day for wind power (the light green line), we can see it declining in the early hours of February 3 as the cold front moved in, while the use of dual fuel generators (the top line), which can burn fuel oil, dramatically increased. Building more wind turbines has limited effect – as the wind drops across the state, all the turbines decrease in output.
NYISO has repeatedly warned – and the Climate Action Council’s Scoping Plan admits – that wind and solar will not be sufficient. New York will need between 25 and 45 gigawatts of dispatchable power – power that unlike wind and sun, but like natural gas, fuel oil, and hydro, can be turned on and off at will.
To comply with the Climate Leadership and Community Protection Act (CLCPA), these sources are supposed to be emissions free, leading NYISO to coin the ugly acronym DEFRs – dispatchable emissions-free resources. But they coined that term because they can’t identify any source that meets that standard and is currently available at utility scale and a commercially competitive price.
This means that for the foreseeable future, fossil fuels will be the only proven source of dispatchable backup to keep the heat and lights on during weather that is killingly cold. Since New York no longer has any coal plants, that can be oil – which is more polluting and has higher carbon content – or natural gas.
The CLCPA has a clear goal of eliminating all greenhouse gas emitting power production by 2040, which would mean shutting down all natural gas-fired power plants. But it also provides a path for keeping open those plants that are necessary to ensure a reliable electrical supply. That path, however, faces considerable political opposition.
New York will soon be forced to make a choice: plunging forward with shutting down natural gas-fired power plants, risking rolling blackouts during extreme cold, or moving forward more slowly on its emissions goals, but keeping the heat on. There is no third way.
The Numbers
The past two days were ideally suited to staying inside. I am a numbers guy so I spent time the last several days watching the weather and the electric system using two different resources. The go to resource for weather observations in New York is the NYS Mesonet At UAlbany. I watched the arctic air come into the region and then tracked the event over time. The NYISO Real-Time Dashboard is a fascinating link into the New York electricity market. I suspected correctly that this weather would cause a spike in electric load and I could see that play out over the period.
The weather data presented here is all from the NYS Mesonet at the University of Albany. The following graph lists the last seven days of temperature, dew point temperature, and solar irradiance data at Elbridge, NY which is near my home. Note that at the time I write this it is February 5 at 8:00 AM and that corresponds to 05/13 or 1300 universal coordinated time or Greenwich mean time, the standard for meteorological observations. On the night of February 2 the temperature (red) was around 38oF about 7:00 PM EST or 0000 UTC. Then the front came through and the temperature plunged overnight and during the day before briefly leveling out a few degrees above zero until nightfall when it dropped down to 7 or so below.
The next graph is for the same time period but shows the wind speed, wind gusts, and pressure. Frontal passage was accompanied with a dip in the station pressure. The pressure gradient was strong for most of the period so winds were steady slightly above 10 mph with gusts peaking at 38 mph.
The NYISO Real-Time Dashboard has two relevant graphical displays: the load and real-time fuel mix. The following graph shows the actual and forecast New York total load on February 3-4 (all times are EST). It is noteworthy that the actual loads on both days were significantly higher than forecast loads. The load peaked on 2/3 at 6:50 PM at 23,447 MW and at 6:10 PM on 2/4 at 21,990 MW.
The real-time fuel mix data shows how the existing fleet met the peak loads during this weather event. The following table lists the daily statistics for the different fuel types. The fuel-mix categories are Nuclear; Hydro, including pumped storage; Dual Fuel, units that burn natural gas and other fossil fuels; Natural Gas only; Other Fossil Fuels, units that burn oil only; Other Renewables are facilities that produce power from solar, energy storage resources, methane, refuse or wood; and Wind (at this time exclusively land-based wind).
The graphs show how important the fossil fuel units are to keeping the lights on. One notable feature of the fuel type data on 2/3 is that the wind generation was not very high even though winds across the state were quite high. I believe this is because wind turbines don’t provide optimal power if the winds are too light or too strong. The strong winds on this date apparently affected the wind production so even on a windy day New York’s land based wind provided only 65% of the maximum potential capability.
On 2/4/2023 the wind resource was affected by light winds. On this date New York’s land based wind provided only 32% of the maximum potential capability.
Conclusion
Stevens explains how important it is for our safety and well-being to have fossil fuels available during extremely cold weather. Hanley showed that natural gas played an important role keeping the lights on during this arctic blast and described some of the uncertainty associated with the planned net-zero transition. My contribution was to provide more documentation for the weather, resulting electric load peak, and the contribution of different fuels to meeting that peak. I am going to follow up on this post with a deeper dive into the resource availability and implications to the Scoping Plan recommendations for generating resource allocations.
Hanley’s conclusion is spot on:
New York will soon be forced to make a choice: plunging forward with shutting down natural gas-fired power plants, risking rolling blackouts during extreme cold, or moving forward more slowly on its emissions goals, but keeping the heat on. There is no third way.
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.
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.
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.
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.
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.
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 theClimate 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.
resource adequacy and transmission planning design rules for planning the system to meet “extreme weather and other extreme system conditions.” This post provides background information on the disconnect between weather and climate prevalent in most of the electrical planning reports, identifies resource adequacy requirements, and describes the identified problems in the whitepaper
Everyone wants to do right by the environment to the extent that efforts will make a positive impact at an affordable level. I have written extensively on implementation of New York’s Climate Leadership and Community Protection Act (Climate Act) because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that it will do more harm than good. This post also addresses the mis-conception of many on the Climate Action Council that an electric system with zero-emissions is without risk. The opinions expressed in this post are based on my extensive meteorological education and background and 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.
Weather and Climate
The difference between weather and climate is constantly mistaken by politicians, media, and, as far as I can tell, most electric system planners. According to the National Oceanic and Atmospheric Administration’s National Ocean Service “Weather reflects short-term conditions of the atmosphere while climate is the average daily weather for an extended period of time at a certain location.” The referenced article goes on to explain “Climate is what you expect, weather is what you get.” Also keep in mind that the standard climatological average is 30 years. In order to think about a change in today’s climate averages you really should at least compare the current 30 years against the previous 30 years.
In my experience the common perception that there are observable changes in frequency and intensity of extreme weather events does not withstand close scrutiny. Furthermore, Dr. Cliff Mass has coined the golden rule of climate extremes that says “The more extreme a climate or weather record is, the greater the contribution of natural variability”. I believe that any trends in weather events due to climate change are tweaks not wholesale changes. The best way to evaluate weather trend impacts is to use as long a data set as possible. On the face of it that might seem easy but the reality is that the conditions for a representative trend are difficult to achieve. Ideally you need to use the same instruments, the same methodology, and keep the conditions around the observing location the same. That is almost never the case.
One final point. We are just starting to understand natural variability of ocean temperature and circulations. Many people have heard of the El Niño and La Niña weather patterns. El Niño and La Niña are two opposing weather patterns that make up the El Niño-Southern Oscillation (ENSO) cycle. El Niño and La Niña regimes typically last nine to 12 months, but can sometimes last for up to seven years on average. Over longer periods, the Atlantic Multi-decadal Oscillation (AMO) has been “identified as a coherent mode of natural sea surface temperature variability occurring in the North Atlantic Ocean with an estimated period of 60-80 years”. In the Northern Pacific the Pacific Decadal Oscillation (PDO) is a similar sea surface temperature source of decadal natural variability. These patterns and oscillations all affect our weather but it is not clear exactly how, especially when the combined effects are considered. If we cannot explain how these naturally variable systems affect our weather then it is unlikely that the climate change weather event perturbation imposed by the greenhouse effect can be described.
Resource Adequacy Modeling for a High Renewable Future
The National Regulatory Research Institute (NRRI) report “Resource Adequacy Modeling for a High Renewable Future“ gives an excellent overview of electric resource adequacy planning as performed today and describes what they think will be needed in the future. I did a post on this report that can be used to provide more detailed background information on resource planning standards.
In this article I am only going mention the resource adequacy metrics described in the article. The report describes traditional resource adequacy planning:
Electric utilities have used the resource planning process for decades to develop long-term, least-cost generation supply plans to serve expected customer demand. Resource adequacy planning ensures that a system has enough energy generation throughout the year to serve demand with an acceptably low chance of shortfalls. Resource adequacy is measured by the metrics described in Figure 1. Reliability metrics provide an indication of the probability of a shortfall of generation to meet load (LOLP), the frequency of shortfalls (LOLE and LOLH), and the severity of the shortfalls (EUE and MW Short).
The industry has traditionally framed resource adequacy in terms of procuring enough resources (primarily generation) to meet the seasonal peak load forecast, plus some contingency reserves to address generation and transmission failures and/or derates in the system. This approach and the metric used to define it is called the “reserve margin.” Planners establish a reserve margin target based on load forecast uncertainty and the probability of generation outages. Required reserve margins vary by system and jurisdiction, but planners frequently target a reserve margin of 15 percent to 18 percent to maintain resource adequacy.
New York resource planning analyses use the “one day in ten years,” criteria (LOLE), meaning that load does not exceed supply more than 24 hours in a 10-year period, or its equivalent metric of 2.4 hours loss of load hours (LOLH) per year. This analysis is performed at the “balancing authority” (BA) level. In the past New York BAs were vertically integrated utilities with defined service territories. After deregulation this responsibility passed to the state’s independent system operator (ISO). The region covered now includes many utility service territories. More importantly the New York Independent System Operator (NYISO) has to develop market or compliance-based rules to maintain sufficient system capacity which adds another layer of complexity. The NYISO does their resource adequacy planning using resources within its geographic region or have firm transmission deliverability into the New York Control Area (NYCA). There is another complication in the state. New York City has limited transmission connectivity so there are specific reliability requirements for the amount of in-city generation that has to be operating and other rules to prevent blackouts in the City.
The NRRI report concludes:
The electric grid is transitioning quickly from a system of large, dispatchable generators to a system reliant on high levels of variable renewable energy, energy storage, and bi-directional flow. Against this backdrop, analytical tools used for decision making regarding resource adequacy are more important than ever and those tools need to evolve to meet the modern grid challenges outlined in this paper. Models based in realistic weather-driven simulations more accurately capture the risk of load shedding due to inadequate generation. Simulations derived from historical data ensure models include load and generation patterns as well as correlations among resources and the ability to adjust to future climate conditions. Models that do not account for these factors may lead to decisions that underinvest in resources or invest in the wrong resources. Recent events in California and Texas indicate the importance of getting these projections right to keep the grid reliable.
To model resource adequacy in future power systems with high penetration of renewables, we recommend several enhancements in modeling tools and techniques. Modeling tools should simulate key structural variables and allow for validation of the simulations by benchmarking against the historical data used to create the simulations. While maintaining statistical properties derived from historical data, simulations should also include future expectations of load growth along with changes in seasonal and daily load shapes. Generation-forced outage simulations should include the possibility of correlated outages from extreme weather. Finally, climate change will drive more weather events in the power system and this risk should be accounted for in the models, at least in the form of sensitivity cases or stress tests.
New York State Reliability Council
In addition to the NYISO the New York State Reliability Council has reliability planning mandates. According to their webpage:
The New York State Reliability Council, L.L.C. (“NYSRC”) is a not-for-profit entity, organized as a Delaware limited liability company, whose mission is to promote and preserve the reliability of electric service on the New York State Power System by developing, maintaining, and, from time-to-time, updating the Reliability Rules which shall be complied with by the New York Independent System Operator (“NYISO”) and all entities engaging in electric transmission, ancillary services, energy and power transactions on the New York State Power System. The NYSRC shall carry out its mission with no intent to advantage or disadvantage any Market Participant’s commercial interests.
The NYSRC’s mission also includes monitoring compliance with the Reliability Rules by working in consultation with the NYISO to assure compliance, including when necessary, seeking compliance through the dispute resolution procedure contained in the ISO/NYSRC Agreement, and taking such other actions which may be necessary to carry out the purpose of the NYSRC Agreement.
Extreme Conditions Whitepaper
New York’s Climate Act mandates that the state’s electric system is supposed to be 100% zero emissions by 2040. The authors of the Climate Act envisioned that this transition would use new wind and solar resources without any new nuclear generation. The NYSRC Extreme Conditions Whitepaper reflects the need to address the issues raised in the NRRI report:
A NYSRC 2022 goal for the NYSRC Reliability Rules Subcommittee (RRS) to: “identify actions to preserve NYCA reliability for extreme weather events and other extreme system conditions” and its corresponding action plan to: “evaluate the potential need for new resource adequacy and transmission planning design rules for planning the system to meet extreme weather and other extreme system conditions.” Accordingly, this paper presents Extreme Weather Resilience Plan recommendations which are designed to ensure that the NYS electric system continues to deliver reliable performance in the face of a changing climate.
Two extreme system conditions were explicitly considered: extreme weather events and loss of natural gas supply. Extreme weather events are considered low-probability widespread weather events
or climate conditions occurring within a limited period, with the potential of having a very severe impact on the reliability of the bulk power system. The majority of loss of natural gas supply to generating facilitates are due to operational or scheduling or market deficiency issues. Natural gas pipeline failures account for a relatively minor fraction of loss of gas supply events. I am only going to address the extreme weather aspects in this article.
The section on extreme weather events starts:
Climate change has led to an increase in the frequency and intensity of extreme weather events, raising concerns about the resilience of the electric grid and its ability to successfully address such hazards.
As explained above I don’t subscribe to the increase in the frequency and intensity claim. This sentence includes a reference to an Oak Ridge National Laboratory report “Extreme Weather and Climate Vulnerabilities of the Electric Grid: A Summary of Environmental Sensitivity Quantification Methods” that provides more details on the weather events that cause blackouts. It also repeats the claim that extreme weather is changing due to climate change. It is almost as if they think that they don’t need to document the claim because “everybody” knows it is the case.
The Whitepaper goes on to say:
All components of electricity supply and demand are potentially vulnerable to such events, including electric power generation and transmission. Further, the changing resource mix with higher penetrations of solar and wind generation adds to the vulnerability of the system to extreme weather. Extreme weather events, such as prolonged cold and hot weather spells, wind lulls, hurricanes and storms, are considered one of the main causes of wide area electrical disturbances worldwide. In the United States, 96% percent of power outages in 2020 were caused by severe weather or natural disasters.
The whitepaper lists the types of extreme weather that impact the NYCA.
The whitepaper explains an important consideration:
It should be noted that extreme weather events, by their nature, infrequent but have a large impact on system reliability such as widespread blackouts. This is in contrast to normal or design events such as generator or transmission outage events. Normal events are predictable in a probabilistic sense in terms of, for example, expected forced outage rates for generators, and generally do not result in wide-spread blackouts. In terms of a statistical frequency distribution, normal events occur around the mean of the distribution while extreme weather events occur at the tails of the distribution. This means that a different form of analysis, reliability criteria, and system loading condition may be appropriate for extreme weather events when compared to normal events.
The whitepaper concludes its discussion on the need for new planning rules by looking at recent blackouts in California and Texas:
The risk profiles in Table 2 below depict the reliability impacts of recent extreme weather events in California and Texas10. As a way of comparison, unserved energy or EUE resulting from the California event exceeded the average annual expected unserved energy in the NYSRC 2021 and 2022 IRM Study base cases by a factor of 12, while the unserved energy from the Texas event exceeded these IRM study base case EUEs by a factor of 4400!
The report explains that the NYISO has conducted a “wind lull” study as part of its 2021 Reliability Planning Process to determine the effects of an extreme situation of low wind resource availability. The study evaluated several scenarios for which there is no wind generation output for an extended period of time, i.e., one week. According to the report:
Table 3 below shows the results of one of these scenarios.12 In this scenario each base case LOL event resulted in a loss of energy of 857 MWhr compared to 1,276 MWhr for the wind lull scenario. The NYISO study also calculated the compensatory MW (perfect capacity MW available every hour of the study year) required to bring NYCA back to the LOLE criterion for each of 18 scenarios examined. For these scenarios compensatory MW requirements ranged from 0 to 400 MW in Zones J or K.
One important NYISO lull study conclusion was that using compensatory MW to bring the NYCA LOLE back to criterion level increases the Expected Unserved Energy (EUE) metric over the base case level. This is because non-extreme weather events are mitigated by the compensatory MW, but the wind lull events themselves create a larger energy deficit than in the base case during the week of the extreme weather.
Resource Adequacy Modeling for a High Renewable Future
Based on these analyses the report concludes that there are changes to weather impacts that need to be addressed and new reliability rules need to be developed. In my opinion, the most important weather concern is that changing the resource mix to one relying upon weather-dependent wind and solar generation is the critical vulnerability that has to be addressed. As noted above I think that the trend of extreme weather events due to greenhouse gas concentrations in the atmosphere is much smaller than natural variability. Therefore, using a long record of data for evaluation will cover most of the potential variability. Unfortunately, recent major blackouts due to extreme weather in California and Texas suggest that we haven’t even been able to plan for the past. So far, New York has avoided such a blackout either due to more stringent standards and better policy development or luck. When New York’s resource mix changes due to the Climate Act there is a need for new reliability rules to maintain current levels of reliability.
Whitepaper Recommendations
In order to address the future electric grid requirements, the NYSRC Reliability Rules Subcommittee (RRS) recommends that:
Accordingly, RRS recommends that the NYSRC should adopt an “extreme weather resource adequacy criterion” — such as the 1-in-10-year LOLE criterion or a new criterion (One example of a new criterion could be use of a dual LOLE/EUE criterion) – for mitigating loss of load impacts of extreme weather events. Development of an “extreme weather resource adequacy criterion” shall include the use of the results of probabilistic resource adequacy assessments of the reliability impacts of a range of types of extreme weather events, to be conducted by the NYISO staff.
RRS recognizes that the NYISO and ICS will need adequate time to develop more detailed probabilistic models for extreme weather analyses and that the RRS will need sufficient time to develop and adopt an appropriate extreme weather resource adequacy criterion. Included in these modeling efforts the NYISO and ICS should identify the types of extreme weather events to be considered and modeled, including an estimate of the relative likelihood of occurrence. The NYISO staff and ICS should also discuss and coordinate the development of procedures for using appropriate extreme natural event assumptions and data for NYCA resource adequacy and IRM assessments.
Prior to adopting an extreme weather resource adequacy criterion, RRS recommends that initial rules should be adopted requiring the NYISO to periodically conduct probabilistic resource adequacy assessments of the reliability impacts (LOLE, LOLH, and EUE metrics) of a range of types of extreme weather events similar to the “Wind Lull” analysis reported in Appendix E of the NYISO 2021-30 CRP report. In addition, it is recommended that the NYISO develop extreme weather scenarios based on appropriate system conditions as well as analytical methods with which to test system performance under extreme weather events. These initial assessments should utilize existing NYISO extreme weather probabilistic models which should improve over the near term.
Conclusion
I endorse the recommendations for additional extreme weather criteria proposed in the Whitepaper. However, based on my background in meteorology, I believe that natural weather variability is a much bigger driver of the magnitude of extreme weather events than climate change. As a result, the necessary changes to reliability rules should focus on the observed variability of extreme weather more than any projection of future changes due to climate change. To date no one in the state has done a satisfactory job evaluating observed weather event variability using a sufficiently long data record. In my Draft Scoping Plan comments on renewable energy resource availability I explained that there is a viable approach that could robustly quantify the worst-case renewable energy resources and provide the information necessary for adequate planning.
In the process of preparing an article about the New York State Reliability Council (NYSRC) Executive Committee approval of the Extreme Conditions Whitepaper on July 8, 2022, I found a reference to a very nice report Resource Adequacy Modeling for a High Renewable Future. The report provides important background information necessary to understand the NYSRC whitepaper so my first thought was to include a summary of the report in the NYSRC post. It made the article too long so this post focuses exclusively on the background paper.
Everyone wants to do right by the environment to the extent that efforts will make a positive impact at an affordable level. I have written extensively on implementation of New York’s Climate Leadership and Community Protection Act (Climate Act) because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that it will do more harm than good. This post also addresses the mis-conception of many on the Climate Action Council that an electric system with zero-emissions is without risk. The opinions expressed in this post are based on my extensive meteorological education and background and 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.
Resource Adequacy Modeling for a High Renewable Future
The National Regulatory Research Institute (NRRI) is the research arm of the National
Association of Regulatory Utility Commissioners (NARUC). NRRI provides research, training, and technical support to State Public Utility Commissions. The June 2022 report “Resource Adequacy Modeling for a High Renewable Future “gives an excellent overview of electric resource adequacy planning as performed today and describes what they think will be needed in the future.
Traditional Resource Adequacy Planning
The report describes traditional resource adequacy planning:
Electric utilities have used the resource planning process for decades to develop long-term, least-cost generation supply plans to serve expected customer demand. Resource adequacy planning ensures that a system has enough energy generation throughout the year to serve demand with an acceptably low chance of shortfalls. Resource adequacy is measured by the metrics described in Figure 1. Reliability metrics provide an indication of the probability of a shortfall of generation to meet load (LOLP), the frequency of shortfalls (LOLE and LOLH), and the severity of the shortfalls (EUE and MW Short).
The industry has traditionally framed resource adequacy in terms of procuring enough resources (primarily generation) to meet the seasonal peak load forecast, plus some contingency reserves to address generation and transmission failures and/or derates in the system. This approach and the metric used to define it is called the “reserve margin.” Planners establish a reserve margin target based on load forecast uncertainty and the probability of generation outages. Required reserve margins vary by system and jurisdiction, but planners frequently target a reserve margin of 15 percent to 18 percent to maintain resource adequacy. Figure 2 shows the standard conceptualization of a load duration curve, rank ordering the level of a power system’s load for each hour of the year from highest to lowest on an average or median basis in a typical weather year. The installed reserve margin is a margin of safety to cover higher than expected load and/or unexpected losses in generation capacity due to outages.
Pechman, C. Whither the FERC, National Regulatory Research Institute. January 2021, available at http://pubs.naruc.org/ pub/46E267C1-155D-0A36-3108-22A019AB30F6.
New York resource planning analyses use the “one day in ten years,” criteria (LOLE), meaning that load does not exceed supply more than 24 hours in a 10-year period, or its equivalent metric of 2.4 hours loss of load hours (LOLH) per year. This analysis is performed at the “balancing authority” (BA) level. In the past New York BAs were vertically integrated utilities with defined service territories. After deregulation this responsibility passed to the state’s independent system operator (ISO). The region covered now includes many utility service territories. More importantly the New York Independent System Operator (NYISO) has to develop market or compliance-based rules to maintain sufficient system capacity which adds another layer of complexity. BA’s typically conduct resource adequacy analysis based on their own load and resources. The NYISO does their resource adequacy planning using resources within its geographic region or have firm transmission deliverability into the New York Control Area (NYCA). There is another complication in the state. New York City has limited transmission connectivity so there are specific reliability requirements for the amount of in-city generation that has to be operating and other rules to prevent blackouts.
The report goes on to note:
The standard metrics shown in Figure 1are generally reported as mean values of simulated power system outcomes over a range of potential future states, but planners also need to understand and plan for the worst-case outcomes and associated probability of such outcomes. Figure 3shows the mean and percentile values for loss of load hours for a power system over a three-year period.
In Figure 3,on average, the power system is resource adequate, remaining below the target of 2.4 hours per year. However, if the power system planner were more risk averse, she might want to bring a higher percentile line under the 2.4-hour target. She would need to add more firm capacity, adding to customer cost. The 95th percentile is the worst-case outcome, providing additional information on the upper bound risk of outages for a given portfolio. Only power systems with no recourse to import energy in a shortage, such as an island, would consider planning to the 95th percentile due to its high cost.
The report’s traditional planning section concludes with this:
Resource adequacy planning is fundamentally concerned with low probability events and planning for average outcomes; although a common practice, this planning is not sufficient and increasingly risky with more uncertain supply, such as renewables. In the past, planners only needed to worry about unusually high loads or high forced outages. Now, they must worry about unusually high loads during periods of unusually low renewable output and limited storage duration. Adding supply uncertainty and, as we discuss later, more extreme weather, compounds risks and thus requires a fundamental rethinking of planning for low probability, high impact tail events.
Problems with Traditional Resource Planning with a High-Renewable System
Despite the fact that the NYISO and the consultants for the Integration Analysis that provides the framework for the Climate Act Draft Scoping Plan have identified a serious resource adequacy problem, there are vocal members of the Climate Action Council who claim there are no reliability concerns for the future 100% zero-emissions New York electric grid. However, analyses have shown otherwise. E3 in their presentation to the Power Generation Advisory Panel on September 16, 2020 noted that firm capacity is needed to meet multi-day periods of low wind and solar output. The NYISO Climate Change Phase II Study also noted that those wind lull period would be problematic in the future.
The NRRI report opens the discussion of the new problems that have to be addressed:
With weather emerging as a fundamental driver of power system conditions, planning for resource adequacy with high renewables and storage becomes an exercise in quantifying and managing increasing uncertainty on both the supply and demand side of the equation. On the load side, building electrification, electric vehicle adoption, and expected growth in customer-sited solar and storage are likely to have pronounced effects on future electric consumption. Uncertain load growth and changing daily consumption patterns increase the challenge of making sure that future resources can serve load around the clock. Simply modeling future load based on past load with added noise does not characterize uncertainty from demand side changes.
The report goes on to explain that supply-side changes create a need for new modeling approaches. In particular, the traditional system consists mostly of dispatchable resources that operators can control as necessary to keep the generation matched with the load. In the future the system will be comprised mostly of resources with limited or no dispatchability. Table 1 compares past approaches with current needs. Note that weather impacts need to be “Incorporated as a structural variable driving system demand, renewable generation, and available thermal capacity”.
There is another fundamental change. In the past the resource adequacy modeling could use average annual generation profiles to meet expected loads. In the future, there will have to be: “multiple renewable generation simulations using historical generation and weather data”. The modeling scenarios will need to meet future expected resource development and maintain the correlation
between renewable availability and load. In particular, the highest and lowest temperatures and thus the expected high loads are typically associated with large high-pressure systems that have low wind speeds and thus low wind resource availability.
The NRRI report shows an approach that addresses these concerns in Figure 5. The report notes:
Weather, primarily in the form of temperature, but potentially including insolation, humidity, wind speed, etc., drives simulations of renewable generation and customer load. Generation outage simulations can be modeled as random (the traditional approach) or as correlated with extreme heat or cold events. Once the simulations are in place, models can compute multiple future paths on an hour-by-hour basis to determine when load cannot be fully served with the available resources. For every hour of the model time horizon, there are independent simulations of load, renewables, and forced outages to determine if load shedding must occur. If a particular model contains 100 simulations and four show a lack of resources to serve load for a particular hour, the hour in question would have a loss of load probability of 0.04 (4/100).
In my opinion, the weather drivers have to be carefully considered. In my Comment on Renewable Energy Resource Availability on the Draft Scoping Plan, I explained why an accurate and detailed evaluation of renewable energy resource availability is crucial to determine the generation and energy storage requirements of the future New York electrical system. I showed that there is a viable approach using over 70 years of data that could robustly quantify the worst-case renewable energy resources and provide the information necessary for adequate planning.
The problem however is what will be the worst case? The NRRI report brings up the issue of energy storage:
Energy storage presents a unique challenge in resource adequacy models. Unlike traditional resources, storage devices such as batteries, compressed air, or pumped-hydro act as both load and generation depending on whether they are charging or discharging. Modern resource adequacy models need to simulate this behavior when determining the capability of energy storage to serve load during periods of resource scarcity. What state of charge should we expect for energy storage at times when the storage is truly needed? Are batteries likely to be fully charged at 6:00 PM on a weekday in August? What about grid charging versus closed systems where batteries must charge from a renewable resource? At the high end of renewable penetration, how much storage would be required to cover Dunkelflaute, the “dark doldrums,” that occur in the winter when wind ceases to blow for several days. Questions surrounding the effective load-carrying capability of energy storage significantly increase the complexity in modeling resource adequacy.
The worst-case meteorology has to consider the energy storage resource. The worst-case may not be the lowest amount of wind and solar resources over a few days. Instead, it could be an extended period of conditions that prevent battery re-charging. I suspect that the long-term historical records will be used to identify potential problems and then a set of scenarios based on different meteorological regimes will be developed that can be used to address the questions raised in the previous paragraph.
The NRRI report explains how this might work:
Figure 6 provides an illustration of modeling the use of batteries in resource adequacy. The figure shows battery storage in blue, load in orange, and the available thermal generation in grey. When load exceeds thermal generation, the system is forced to rely on battery discharge for capacity. If the event lasts long enough to fully discharge the battery, the green line (generation minus load) will turn negative, indicating a load shed event.
The report goes on to explain how the modeling analysis is done. It notes that:
Simulations of random variables fit Monte Carlo methods by creating multiple future time series of the random variables, while maintaining correlation across time within variables (if wind is high in hour 1, it will likely be high in hour 2) and correlations between the variables, such as the strong relationship between temperature and load. If wind tends to be higher in the spring and fall, the simulations will exhibit that trend. Monte Carlo applications differ dramatically between resource adequacy models, with some models using a sequential approach that solves the model in hourly steps whereas others use techniques that solve the models quickly without stepping through each hour. Accurate representation of energy storage in resource adequacy models necessitates sequential solution techniques to account for the time dependencies for storage state of charge inherent in models.
I believe it is necessary to use the worst-case meteorological scenarios as the primary driver of these simulations. In other words, the Monte Carlo weather parameter adjustments should be small increments on top of the observed values. The report is talking primarily about correlations in time but spatial correlations are a critical wind resource availability consideration too.
The NRRI report addresses my concerns.
When using the Monte Carlo approach with weather as a fundamental driver, individual simulations represent independent futures for weather, load, and renewables. Realistic simulations maintain the statistical properties of the underlying resource and correlation between resources and load. For example, if historic data show no correlation between load and wind generation, the simulations should maintain this relationship unless a reasonable expectation exists for correlations to change in the future
However, they use simple examples of the load and resource correlations. There are those that believe that because the wind is always blowing somewhere that transmission upgrades will ensure reliability. However, if during the worst-case conditions New York has to rely on wind resources in Iowa because the high-pressure system is huge, that may not be practical. I cannot over-emphasize the need for an analysis that simulates wind and solar resource availability over wide areas. As the report notes analyses that fail to replicate the proper correlation between wind, solar, and load for the electric grid can underestimate the risk of load shedding.
The report goes on to explain other adjustments to traditional resource planning that will be necessary to address a high renewable future. That discussion is beyond the scope of my concern. The report concludes:
The electric grid is transitioning quickly from a system of large, dispatchable generators to a system reliant on high levels of variable renewable energy, energy storage, and bi-directional flow. Against this backdrop, analytical tools used for decision making regarding resource adequacy are more important than ever and those tools need to evolve to meet the modern grid challenges outlined in this paper. Models based in realistic weather-driven simulations more accurately capture the risk of load shedding due to inadequate generation. Simulations derived from historical data ensure models include load and generation patterns as well as correlations among resources and the ability to adjust to future climate conditions. Models that do not account for these factors may lead to decisions that underinvest in resources or invest in the wrong resources. Recent events in California and Texas indicate the importance of getting these projections right to keep the grid reliable.
To model resource adequacy in future power systems with high penetration of renewables, we recommend several enhancements in modeling tools and techniques. Modeling tools should simulate key structural variables and allow for validation of the simulations by benchmarking against the historical data used to create the simulations. While maintaining statistical properties derived from historical data, simulations should also include future expectations of load growth along with changes in seasonal and daily load shapes. Generation-forced outage simulations should include the possibility of correlated outages from extreme weather. Finally, climate change will drive more weather events in the power system and this risk should be accounted for in the models, at least in the form of sensitivity cases or stress tests.
Conclusion
I found this report to be a very useful description of the particulars of electric grid reliability analysis now and in the future. It is clear that the transition to a high renewable future introduces issues that could cause problems.
Finally, this report and other similar studies always claim that climate change should be considered in future analyses. As I will explain in my future article on the NYSRC Extreme Conditions Whitepaper I believe that the most important future weather concern is that changing the resource mix to one relying upon weather-dependent wind and solar generation is the critical vulnerability that has to be addressed. I think that the trend of extreme weather events due to greenhouse gas concentrations in the atmosphere is much smaller than natural variability. Therefore, using a long record of data for evaluation will cover most of the potential future variability. Unfortunately, recent major blackouts due to extreme weather suggest that we haven’t even been able to plan for the past. So far New York has avoided such a blackout either due to more stringent standards and better policy development or luck.
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. One of the targets is a zero-emissions electricity grid by 2040. In order to meet that target the plan is to expand wind and solar generating resources. This post looks at the 2021 wind resource availability relative to Climate Act expected wind resource builds.
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 have written extensively on implementation of New York’s response to climate change 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 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 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.
Draft Scoping Plan Wind Resources
The Integration Analysis has three mitigation scenarios. The Mitigation Scenarios Summary Fuel Mix table projects that 9,445 MW of on-shore wind capacity will need to be developed in the Scenario 2, “Strategic Use of Low-Carbon Fuels”; 10,154 MW in Scenario 3, “Accelerated Transition Away from Combustion”; and 11,052 MW in Scenario 4, “Beyond 85% Reductions”.
At this time the New York Independent System Operator (NYISO) is preparing its capacity expansion projections. I previously described that effort and noted that the analysis includes 27 sensitivity cases in addition to the preliminary baseline. With the caveat that those projections are the first draft and could change significantly, it is important to note that the preliminary baseline projection for land-based wind is 22,789 MW and that the sensitivity cases range from 16,702 MW to 31,678 MW. Clearly, at some point the differences between the Integration Analysis and the NYISO projections have to be resolved given that the NYISO is projecting on the order of double the Integration Analysis.
2021 Wind Resources
The NYISO Gold Book summarizes New York load & capacity data. It includes a table that lists pertinent information for every generating unit in New York. I have been extracting wind facility information so that I could calculate capacity factors for many years as shown in this table. In 2021 two new facilities came on line. At the start of the year the nameplate capacity of all the wind facilities was 1,985 MW and it increased to 2,191 MW after the new facilities came on line. However, the capacity factor, the actual generation produced relative to the maximum possible generation was only 22.3%.
I found another NYISO resource dated March 31, 2021 that provides the 2021 wind production the 2021 wind curtailment. The data sets list the hourly total wind production and curtailments for the entire New York Control Area (NYCA). I have summarized the data in the following table. Curtailments are those hours when the system load is small enough that wind production is greater than what is needed so the wind power is curtailed, i.e., not used.
With respect to production, I believe that these data show that the New York wind resource is not particularly good. The percentiles are shown in the first column and the data indicate that wind power is greater than 78% of the total capacity only 87 hours (99th percentile) in 2021. Three quarters of the time the production is less than 696 MW equivalent to one third of the total capacity. If you assume that production less than 10% is the threshold for no value then wind won’t be producing appreciable power 30% of the time.
Discussion
These results have an important ramification for resource planning. The existing wind facilities are spread across the state. NYISO cannot provide individual unit generation so I cannot definitively say that those facilities are highly correlated. However, given that half the time the total generation capacity is only 16% of the total I am sure that is the case. As a result, that improving energy production at the lower levels requires a lot more generation capacity. For example, at the 25th percentile the total capacity is 151.6 MW. If planners predict we need wind generation capacity to equal 1,000 MW 75% of the time. then, based on 2021 data, the state land-based wind capacity would have to increase to 13,900 MW, over six times greater than current capacity
The key point of this article is that there are limitations to New York’s wind resource capability. Dietmar Detering and I have corresponded about the Integration Analysis wind resource projections. He has found that “The Integration Analysis predicts between 10,997 MW and 13,239 MW of land-based wind installed within New York by 2050, and estimates annual generation between 31,224 GWh and 37,896 GWh which corresponds to a capacity factor of about 33%. My capacity factor table shows that the maximum state-wide capacity was 28% in 2014 and was only 22.3% in 2021. The Climate Action Council needs to reconcile those differences.
There are a few possible explanations. New York’s decreasing capacity factors could reflect the age of the fleet. The Integration Analysis could reflect larger wind turbines that have higher capacity factors because they can reach higher wind speed layers. In either case that suggests that all the New York existing land-based wind facilities need to be replaced. There is insufficient documentation available in the Draft Scoping Plan to confirm whether the Plan assumes complete replacement. As far as I can tell the Integration Analysis assumes “indefinite” expected lifetimes for energy storage, wind and solar infrastructure and assigns lifetimes to other resources despite the fact that renewable resource lifetimes are half that of other resources. Given that creative bookkeeping I doubt that existing resource replacements are included in the total costs of the mitigation scenarios.
Conclusion
The Climate Act 2040 zero-emissions target will require much greater reliance on wind and solar generating resources. Unfortunately, the authors of the Climate Act did not recognize limitations for those resources. These results show that land-based wind in New York is not a particularly good resource. Winter time solar is poor because of New York’s high latitude with short days in the winter and excess cloudiness downwind of the Great Lakes. Overall, New York’s has a poor wind and solar resource capability.
It is imperative that the State conduct a detailed evaluation of renewable energy resource availability to determine the generation and energy storage requirements of the future New York electrical system. As these results show, the annual wind resources capabilities are low. I submitted comments in March that explain that in order to ensure electric system reliability for an energy system that depends on renewable generators and energy storage, the resources available during periods of low wind and solar energy production must be known. To date, many studies do not consider the importance of worst-case conditions on reliability planning and I believe that the Draft Scoping Plan also fails to address this issue. The comments explained that there is a viable approach that could robustly quantify the worst-case renewable energy resources and provide the information necessary for adequate planning.
New York’s 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 Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”. This post describes comments I submitted to the Council about the inadequate analyses of renewable energy resources in New York. It is important to get this right because the availability of renewable energy resources informs the basis of resource adequacy planning.
I have written extensively on implementation of the Climate Act because I believe the ambitions for a zero-emissions economy outstrip available renewable technology such that it will adversely affect reliability and affordability, risk safety, affect lifestyles, will have worse impacts on the environment than the purported effects of climate change in New York, and 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 by 2050. The Climate Act requires the Climate Action Council to “[e]valuate, using the best available economic models, emission estimation techniques and other scientific methods, the total potential costs and potential economic and non-economic benefits of the plan for reducing greenhouse gases, and make such evaluation publicly available” in the Scoping Plan. The integration analysis developed by the New York State Energy Research and Development Authority (NYSERDA) and its consultants was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021. The Scoping Plan has to be finalized by the end of 2022 and a recent meeting discussed issues that need to be addressed to meet that schedule.
New York’s unprecedented transition to a zero-emission electric generating system means that the system will be heavily dependent upon wind and solar resources. Because those resources are intermittent it is imperative that New York energy planning determine the frequency and duration of periods when wind and solar resources are low. This article summarizes comments that I submitted on the problem, describes analyses that address this issue completed elsewhere, and recommends that New York agencies develop an appropriate study centered on New York.
Problem
The comments included a description of New York blackouts and the responses made to prevent reoccurrences. I believe that, despite the best efforts of those responsible for the reliability of the electric grid, the transition to an electric power system that relies on intermittent wind and solar resources introduces so many changes that it will be impossible to anticipate them all. As a result, grid resilience will decrease and blackouts are inevitable. For example, consider that a team of researchers from the University of Nottingham recently addressed the effect of renewable energy resources on power grid stability. The abstract from the paper states:
Contemporary proliferation of renewable power generation is causing an overhaul in the topology, composition, and dynamics of electrical grids. These low-output, intermittent generators are widely distributed throughout the grid, including at the household level. It is critical for the function of modern power infrastructure to understand how this increasingly distributed layout affects network stability and resilience. This paper uses dynamical models, household power consumption, and photovoltaic generation data to show how these characteristics vary with the level of distribution. It is shown that resilience exhibits daily oscillations as the grid’s effective structure and the power demand fluctuate. This can lead to a substantial decrease in grid resilience, explained by periods of highly clustered generator output. Moreover, the addition of batteries, while enabling consumer self-sufficiency, fails to ameliorate these problems. The methodology identifies a grid’s susceptibility to disruption resulting from its network structure and modes of operation.
My comments included a description of the Texas blackout of February 2021. Ultimately the reason for the blackout was poor planning. When the people of Texas needed electric power the most the generating resources available were unable to meet those needs. In order to prevent the same thing from happening in New York it is necessary to provide sufficient energy at all times.
Reliability planning in the past relied on dispatchable generating resources. The Climate Act future electric generating system will rely on intermittent renewable wind and solar that is not dispatchable. Energy storage resources are needed to cover periods when wind and sun energy is not available to provide dispatchable electricity. The problem is that we have to know what the worst-case renewable resource availability is in order to size the energy storage resources correctly.
Last year I described issues related to this as the Climate Act’s ultimate problem. Although there have been analyses that have identified winter wind lull periods are a problem, I do not believe that they addressed this analysis correctly because they used relative short periods as the basis for their projections. As far as I can tell the Integration Analysis did not even consider the same period for wind and solar resources in their analysis. As a result, I believe the Draft Scoping Plan projections for the amount of resources during these periods is incorrect.
Proposed Analysis
In order to do this right, 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 that estimate the frequency and duration of periods with those conditions using a meteorological reanalysis data base. In this approach historical observations are re-analyzed using current weather forecast models. The first step in developing a weather forecast is to incorporate meteorological observations to setup the weather maps that are the starting point for weather forecast calculations. That component of the models is used to develop weather maps for the observations and the forecast component is used to provide hourly data until the net observation period.
In order to provide a robust estimate of the wind and solar availability during worst case conditions it is necessary to analyze as long a time period of historical meteorological data as possible. The ERA5 global reanalysis data base generated using this reanalysis technique provides hourly estimates of a large number of atmospheric, land and oceanic climate variables. The data cover the Earth on a 30km grid and resolve the atmosphere using 137 levels from the surface up to a height of 80km. That information is then used to estimate the availability of hourly wind and solar resources for any area of the globe.
Last fall I described a paper that included an approach that might work for an analysis centered on New York. Since then, I have been in touch with the author and I am not confident that using these data would be provide invaluable information.
In my comments I strongly recommended an analysis in New York using the complete (1950 to present) ERA5 meteorological database to determine the frequency and duration of renewable resource droughts in order to estimate the appropriate worst case. The goal of the project would be three-fold:
Determine historical intensity, frequency, duration and seasonality of wind and solar droughts in New York;
Identify co-occurrence of wind and solar droughts with high demand periods (heating/cooling degree days); and
Interpret the droughts and high demand periods: seasonal, weather regimes, interannual variability (e.g. El Niño-Southern Oscillation), multi-decadal climate regimes, and trend associated with global warming
Conclusion
I have submitted comments in various proceedings and have tried to work behind the scenes to get this analysis completed because I don’t think it is possible to adequately project the renewable resources necessary to keep the lights on when needed most without this information. I submitted these comments to get on the record again that this work has to be done to ensure that sufficient renewable energy generation and energy storage is developed to prevent blackouts.
Pragmatic Environmentalist of New York 
