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.
Pragmatic Environmentalist of New York 