Category: Micron

My Comment on the Micron Draft Environmental Impact Statement

In 2022, Micron announced its plans to build the largest semiconductor fabrication facility in the history of the United States. Micron intends to invest up to $100 billion over the next 20-plus years to construct a new chip fab plant in Clay, New York.   This post describes my comments on the Draft Environmental Impact Statement (DEIS) filed for the facility.  I recommended that the DEIS should include an option for a Combined Cycle Gas Turbine (CCGT) co-generating facility.

I am following developments at Micron because the facility is going to be built within five miles of my home.  I also follow the Climate Leadership & Community Protection Act (Climate Act) because of its impacts on New York. I acknowledge the use of Perplexity AI to generate summaries and references included in this document.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Micron Chip Fab Facility

The description in the Environmental Assessment Form states:

Micron intends to invest approximately $100 billion over the next 20 years to build a leading-edge semiconductor manufacturing campus in the Town of Clay on the approximately 1,400-acre White Pine Commerce Park. Micron intends to acquire the White Pine Commerce Park from the Onondaga County Industrial Development Agency (OCIDA) and construct a campus for four (4) memory fabrication plants (also known as Fabs) on the site. Each Fab, and their related facilities, would take approximately three to five years to construct. Interior fit-out of each Fab would continue after the building is complete, resulting in continuous site activity over approximately 20 years. It is anticipated that the first two (2) Fabs would be complete within approximately 10 years, and the second two (2) Fabs would be complete approximately 10 years thereafter. Skilled trade labor will be employed throughout the 20-year period. Each Fab would occupy approximately 1.2 million square feet (sf) of land and contain approx. 600,000 sf of cleanroom space, 290,000 sf of clean room support space, and 250,000 sf of administrative space. Each set of two fabs would be supported by approx. 360,000 sf of central utility buildings, 200,000 sf of warehouse space, and 200,000 sf of product testing space housed in separate buildings.

I queried Perplexity AI for a description of energy use at the facility.  The following describes the massive amount of energy required:

The Micron facility represents an unprecedented energy demand for Central New York. When fully operational with all four fabrication plants (fabs) completed by around 2043, the Clay complex will consume 16 billion kilowatt-hours (16,000 GWh) of electricity annually.

The Micron facility will require 1.85 gigawatts of continuous power from the grid, operating 24 hours a day, 7 days a week. This around-the-clock operation is critical because semiconductor manufacturing cannot tolerate even brief power interruptions – any outage would cost Micron tens or hundreds of millions of dollars in lost production and could take days or weeks to recover from.

Cogeneration Option

Earlier in the permitting process, both Richard Ellenbogen and I submitted comments on the draft scoping plan suggesting that the environmental impact assessment include a CCGT co-generation option. 

The OCIDA final response to comments document basically blew off our recommendation.  The following represents the entire response.  The responses were listed by number: Ellenbogen (24) and Caiazza (25) comments.Comment

3: Commenters suggest that the Draft Environmental Impact Statement should include an alternative to add a Combined Cycle generating plant on the Micron Property. (24, 25).

Response: See Response to NYSDEC Comment 5.NYSDEC Comment 5: The DEIS should include a discussion of potential alternatives and mitigation that could reduce energy and fuel demands during construction and the long-term operation of the facility, including renewable energy sources.

Response: The Scope has been revised to indicate that the DEIS will include a summary of other alternatives previously considered but determined not to be feasible, including an alternative that relies exclusively on alternative sources of energy (beyond use of renewable energy for purchased electricity). The DEIS will also assess the proposed use and conservation of energy (including provisions for renewable energy sources). The DEIS will include an evaluation of energy impacts from construction and long-term operation of the facility, along with potential mitigation of those impacts.

Unfortunately, there is no mention of a combined cycle generating plant in the DEIS.  My comments explained why that is a mistake.

Comments

The supporting documentation for the DEIS included the July 2025 Micron Climate Leadership and Community Protection Analysis (CLCPA Analysis).  This document explains how the project will comply with the Climate Act.  Micron and New York State have committed to meeting 100% of the facility’s electricity needs through renewable energy sources.

Unfortunately, the commitment to source 100% of the facility’s electricity needs through renewable energy source is more consistent with Micron’s sustainability commitments than energy reality.  The chip fab plant will not only require enormous amounts of electric energy but also firm capacity, stable voltage, and frequency in a narrow range.  Providing electricity with those characteristics using renewable energy sources is an enormous challenge and failure risks viability of the facility.

I explained that while it is laudable that they intend to rely on renewable energy sources mandated by the Climate Act, reality is catching up to that fantasy.  In May DPS finalized a biennial review of implementation document.  They found that the implementation of the 2030 renewable energy goal is behind schedule and suggested the target could be reached by 2033 when factoring in load growth and contributions from offshore wind and distributed generation.  They proposed to maintain the trajectory toward eventual achievement by increasing renewable energy solicitations.

The Biennial Report issued in July 2024 was based on an assessment of potential renewable energy deployments at a time when there was significant federal financial and regulatory support available from the Biden Administration.  It is not currently clear at this time what, if any, support will be available from the Trump Administration, but there is no question that there will be significant change to renewable deployments.  These uncertainties were not incorporated into the Order that accepted the Biennial Review.  This makes the proposal to double down on renewable procurements unlikely to succeed.

There is another recent issue that results in additional unacknowledged uncertainty in Micron’s plans.  A Perplexity AI response notes that Governor Hochul recently acknowledged that the Biennial Review findings mean that the current schedule is untenable and that there are significant cost impacts.  Proponents for clean energy are arguing that the CLCPA targets are legal mandates but there are heretofore unacknowledged legal safety valves.  Public Service Law Section 66-P Establishment of a Renewable Energy Program is the law that implements the Climate Act renewable energy mandates.  It includes provisions for bounds on implementation that can modify the obligations of the Climate Act.  In my opinion, it is inevitable that political pressure is going to force reconsideration of the schedule and ambition of the Climate Act, and this law provides an excuse.

Recommendation

The current energy sourcing plan is to rely on the local utility (Niagara Mohawk Power Corporation (NMPC) doing business as National Grid) as the source of energy for the facility.  My recommendation is based on the Independent Intervenor Statement in Opposition to the Joint Proposal (Opposition Statement) in the NMPC rate case.  In that statement we described an alternate approach to provide electric power to Micron.  The Opposition Statement projected the necessary renewable resources needed for Micron’s energy requirements in comparison to the alternative CCGT approach. 

I recommended that the Final EIS include an option for a current generation Combined Cycle Gas Turbine (CCGT) powerplant.  A facility with a nameplate rating of 1.25 GW will provide equivalent output to the PSL 66-P renewable energy approach with the same or better reliability, but without the need for energy storage or ancillary support.  The chip fab manufacturing process requires process heat.  It is not as energy efficient to use electricity from the grid to generate process heat as using on-site combustion that could be provided from the CCGT.  On-site generation also eliminates transmission line loss.  These efficiency benefits warrant consideration of this option.  The Opposition Statement also argued that if the CCGT facility is co-located with an agricultural park that uses the CO2 from the power plant to boost productivity, GHG emissions are reduced significantly.  The fact that this option will be cheaper, more reliable, and provide better quality electricity makes this a viable option that should be considered in the DEIS

Conclusion

There is growing evidence that the schedule and ambition of Public Service Law 66-P renewable energy program deployment cannot be achieved.  Micron’s commitment to meet 100% of the facility’s electricity needs through renewable energy sources is laudable but indications are that it is not going to be available.  The existence of safety valve provisions, the acknowledged program delays, and the current changes in Federal clean energy policies suggest that Micron must consider an alternative plan for sourcing its energy requirements.  If Micron is to truly lead, then they must advocate for options that will work.  Blind adherence to a flawed net-zero transition plan will affect the viability of the plant.  It is time to step up and offer a pragmatic solution that will work.  The recommended CCGT approach with co-generation and agricultural park option fulfills that objective.

Micron Rational Option not in the Final Scoping Plan

In 2022, Micron announced its plans to build the largest semiconductor fabrication facility in the history of the United States. Micron intends to invest up to $100 billion over the next 20-plus years to construct a new chip fab plant in Clay, New York.   My most recent article on this project documented my suggestion that the facility consider co-generation to supply the energy needs of the facility based on the energy density of wind and solar resources.  I made the same recommendation in a comment on the Draft Scope of Work for the State Environmental Quality Review Act requirement to address the environmental impacts of the facility.  This post describes the response to my comment.

I am following developments at Micron because the facility is going to be built within five miles of my home.  I also follow the Climate Leadership & Community Protection Act (Climate Act) because of its impacts on New York. The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Micron Chip Fab Facility

The description in the Environmental Assessment Form states:

Micron intends to invest approximately $100 billion over the next 20 years to build a leading-edge semiconductor manufacturing campus in the Town of Clay on the approximately 1,400-acre White Pine Commerce Park. Micron intends to acquire the White Pine Commerce Park from the Onondaga County Industrial Development Agency (OCIDA) and construct a campus for four (4) memory fabrication plants (also known as Fabs) on the site. Each Fab, and their related facilities, would take approximately three to five years to construct. Interior fit-out of each Fab would continue after the building is complete, resulting in continuous site activity over approximately 20 years. It is anticipated that the first two (2) Fabs would be complete within approximately 10 years, and the second two (2) Fabs would be complete approximately 10 years thereafter. Skilled trade labor will be employed throughout the 20-year period. Each Fab would occupy approximately 1.2 million square feet (sf) of land and contain approx. 600,000 sf of cleanroom space, 290,000 sf of clean room support space, and 250,000 sf of administrative space. Each set of two fabs would be supported by approx. 360,000 sf of central utility buildings, 200,000 sf of warehouse space, and 200,000 sf of product testing space housed in separate buildings.

In August I prepared an article that described the reaction of Richard Ellenbogen to the massive amount of energy needed by the facility. I correspond with him regularly because he has spent a lot of time evaluating the Climate Act net-zero transition.  I recently described his comprehensive  presentation on the transition.  When I let him know that the original projection for energy use that would be the same as the state of Vermont has been expanded to be the same as Vermont and New Hampshire he responded with the following:

I have been using the Micron facility as an example of how the Climate Act is actually going to increase NY State’s carbon footprint because transmitting all of that energy to the Micron site, as much as is used by the state of Vermont, over long distances was going to result in an amount of lost energy on the wires that could operate 1-3/4 Cornell Universities.  One of my readers sent me an update of energy use because now it is projected that the Clay complex will consume 16 billion kilowatt-hours of electricity per year, as much as Vermont and New Hampshire combined, or 16,000 Gigawatt Hours annually (16 Tera-watt hours).  That is double the original projections and the idea that this could be supported with renewable generation is laughable.  16,000 GWh is an 11%  increase in NY State electric usage just related to the one facility.  The line loss will also double to consume the output of about  a 100 megawatt fossil fuel plant under continuous operation.

To put the Micron facility’s usage into perspective, in its last full year of operation the 2 Gigawatt Indian Point nuclear plant generated 16.3 Tera-watt hours so the Micron facility will need to be supported by a 2 Gigawatt fossil fuel or nuclear plant on site or  2.1 Gigawatts of generation off site, 5% more.  NY State’s policy makes absolutely no sense.  To run the Micron facility would require using about 4 GW of the projected 9 GW of offshore wind to support the plant or 16 GW of solar arrays covering 128,000 acres (80 acres per 10 MW)  or 200 Square miles.  NY State has 7 million acres of farmland so solar arrays to support the Micron facility  would use almost 2% of the farmland in the state and would also require an enormous amount of battery storage, the cost of which would greatly exceed the cost of a nuclear plant on site.  A combined cycle generating plant on site would be about 75% less than the cost of the nuclear plant.  Both the combined cycle gas plant and the nuclear plant on-site offer the option of recovering the waste heat and using it in the plant to make Micron even more energy efficient.  With regard to the solar and wind, NY State is having major difficulties getting all of their renewable projects finished because of cost issues and interconnection issues, let alone adding this gigantic lead weight to the Camel’s back.

Draft Scoping Plan Comments

The Onondaga County Office of Economic Development is the lead agency for permitting the project.  The agency with the office charged with the program is the Onondaga County Industrial Development Agency (OCIDA) whose mission is to “stimulate economic development, growth, and general prosperity for the people of Onondaga County by using available incentives, rights, and powers in an efficient and cooperative manner.”  Needless to say, this massive project is quire a feather in the cap for Onondaga County.

Assigning OCIDA as the lead agency makes sense from the implementation standpoint because governmental agencies have an easier time getting permits.  However, there is a disconnect between the agency and Micron.  Both Richard Ellenbogen and I submitted comments on the draft scoping plan suggesting that the environmental impact assessment include a co-generation option.  I would not be surprised in the least that Micron is not aware of our recommendation.

The OCIDA final response to comments document basically blew off our recommendation.  The following represents the entire response.  The responses were listed by number: Ellenbogen (24) and Caiazza (25) comments:

Comment 3: Commenters suggest that the Draft Environmental Impact Statement should include an alternative to add a Combined Cycle generating plant on the Micron Property. (24, 25)

Response: See Response to NYSDEC Comment 5.

NYSDEC Comment 5: The DEIS should include a discussion of potential alternatives and mitigation that could reduce energy and fuel demands during construction and the long-term operation of the facility, including renewable energy sources.

Response: The Scope has been revised to indicate that the DEIS will include a summary of other alternatives previously considered but determined not to be feasible, including an alternative that relies exclusively on alternative sources of energy (beyond use of renewable energy for purchased electricity). The DEIS will also assess the proposed use and conservation of energy (including provisions for renewable energy sources). The DEIS will include an evaluation of energy impacts from construction and long-term operation of the facility, along with potential mitigation of those impacts.

Unfortunately, there is no mention of a combined cycle generating plant in the Final Scope of Work.  I guess that Micron could include the option for a co-generation plant in the future, but it would certainly affect the permitting schedule.  If they do recognize the value, I believe their best approach would be to do the permitting separately.  I guess there is still hope.

Discussion

The Micron facility could be a tremendous boon to Central New York.  I hope it goes forward but the reality is that New York energy prices are high now and will increase significantly when the Climate Act transition to zero emissions generating resources proceeds.  The cogeneration proposal offers the most likely way to keep energy costs low enough so that Micron can compete with global chip manufacturers.

I previously wrote that the development of Micron within the Climate Act framework will be a good test of pragmatic environmentalism.  The tradeoff between Climate Act absolutism, i.e., demanding nothing less than zero, with the extra costs associated with that approach versus the need to keep the Micron facility in New York competitive with the global chip market by accepting non-zero emissions is an important substantive issue. 

I am not entirely discouraged by the decision not to include co-generation in the Final Scoping Plan for Micron.  It is more important to get the permits in place now so that construction can begin on schedule.  Adding the co-generation scenario would distract from that goal.

Make no mistake, if Micron comes to the same conclusion as Ellenbogen and I that the advantages of co-generation are so indisputable and proposes such an approach the feces will become entangled with the impeller.  The zero emissions ideologues will scream very loudly and invoke every emotional argument they can.  The same politicians that are claiming success for getting Micron to commit are, in many cases also Climate Act supporters.  There will be tremendous pressure on those politicians demanding zero-emissions generation while at the same time making it clear that nuclear is unacceptable even if it is the only zero-emissions generation that we know will work.  What the ideologues cannot do is argue on the basis of the numbers and the science.  Reality is not on their side.