Reliability Goal of a Renewable-Dependent Electricity System

In early September 2021 I wrote an article, “Reliability Challenges in Meeting New York’s Climate Act Requirements”, that described a presentation made by the New York State Reliability Council (NYSRC) to the New York Climate Action Council.  In this post I describe a recent paper that analyzes synoptic-scale extreme reductions in wind and solar power energy resources that I think raises an important reliability question: when New York relies on fragile intermittent wind and solar energy resources is the current New York reliability goal to prevent a loss of load event due to resource adequacy of no more than once per ten years still appropriate.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, 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.


In my reliability challenge article, I explained that there is consensus that the future worst-case situation in New York will be a multi-day winter time wind lull when both wind and solar availabilities are low.  Coupled with increased electricity load in order to reduce emissions from transportation and heating, any analysis of future renewable energy resources that adequately addresses the worst-case renewable energy resource availability shows the required amounts of wind, solar and energy storage will have to be enormous.  Importantly, the NYSRC analysis indicates that in order to ensure reliability the installed reserve margin will have to be increase substantially above current levels to satisfy anticipated load and the intermittent nature of wind and solar resources.  The NYSRC presentation concludes that the state of New York appears to be headed down a transition path which will require reliance on technologies that do not currently exist in less than ten years.

Wind and Solar Droughts

Dr. Patrick Brown’s blog post describes his recent paper co-authored with David J. Farnham and Ken Caldeira entitled “Meteorology and climatology of historical weekly wind and solar power resource droughts over western North America in ERA5” (Brown et al., 2021).  His post explains that as wind and solar become more indispensable for providing electricity it is important that we understand the intensity, frequency, and duration of droughts of their availability.  In Brown et al., 2021 they use a meteorological database that covers 71 years from 1950 to 2020.  They compared estimated weekly solar and wind availability against cooling and heating degree days as a proxy for electrical load over that entire period. 

The following plot of the weekly values is of special interest.  The plot explanation states:

All weekly values from 1950 to 2020 (average over the western North America domain, Fig. 1) for power supplied by wind and solar resources (x and y axes respectively) and a proxy for power demanded via cooling degree days (color of dots). The mean seasonal cycle in wind and solar power is shown by the black loop (52 black dots for each week of the year). Drought weeks are indicated with black edge colors with wind droughts represented as circles, solar droughts represented as squares and compound wind and solar droughts represented as diamonds.

Of particular concern is the lower left quadrant which represents weeks where both wind and solar resources are lower than the annual mean of long-term availability.  Note that this quadrant is “mostly astronomical autumn. The mean wind & solar power given a wind + solar drought label shows that during a drought you can only expect around 40% of the solar resource and 65% of the wind resource.

There is an animation showing the degree to which there is persistence in time.  In the video each week is sequentially plotted since 1979 over a plot of the seasonal cycle.  As you watch the video keep in mind that you are watching the seasonal progression of plots.  While the majority of weeks with both wind and solar droughts are in autumn there are periods at the start of each year that appear to me to be among the most intense.  That is consistent with New York analyses that define the ultimate problem

that must be resolved to ensure reliability: firm capacity is needed to meet a multi-day period of low solar and wind resource availability during the winter. 

In their presentation to the Power Generation Advisory Panel on September 16, 2020 E3 included a slide titled Electricity Supply – Firm Capacity that states: “The need for dispatchable resources is most pronounced during winter periods of high demand for electrified heating and transportation and lower wind and solar output”.  The slide goes on to say: “As the share of intermittent resources like wind and solar grows substantially, some studies suggest that complementing with firm, zero emission resources, such as bioenergy, synthesized fuels such as hydrogen, hydropower, carbon capture and sequestration, and nuclear generation could provide a number of benefits.  Of particular interest is the graph of electric load and renewable generation because it shows that this problem may extend over multiple days.

Brown et al., 2021 is a promising approach for evaluating the long-term frequency of wind and solar droughts.  However, there are some limitations.  Obviously, the work has to be done for a New York centric domain.  In addition, because previous New York analyses by Energy + Environmental Economics  and The Analysis Group both identified problems on a multi-day basis it would be more appropriate to evaluate New York’s droughts on a daily basis. I strongly recommend that New York sponsor this analysis to determine the frequency and duration of renewable resource droughts. 

Because wind and solar are naturally intermittent the amount of energy storage needed to balance output must be determined.  The Brown et al., 2021 technique can also be used to identify periods that should be evaluated in more detail to determine the intensity of the droughts so that energy storage requirements can be determined.  This is important not only for grid planning but also for distributed energy resources (DER).  In theory DER can “generate smaller amounts of clean electricity closer to end-users, to increase energy efficiency, reduce carbon pollution, improve grid resiliency, and potentially curtail the need for costly transmission investments”.  However, unless they incorporate sufficient energy storage these resources won’t work when the system is stressed the most, so they may not be the panacea that advocates claim.

Reliability Planning

New York’s electric system is de-regulated so reliability planning is provided by the New York Independent System Operator, various state agencies and the NYSRC.  The NYSRC presentation describes the NYSRC and the Installed Reserve Margin (IRM) parameter.  The IRM is defined as the “minimum installed capacity margin above the estimated peak load to meet the Northeast Power Coordinating Council (NPCC) requirement that the probability of shedding load is not greater than one day in ten years”.   Load shedding occurs when the demand for electricity exceeds supply and grid operators have to turn power off for groups of customers in order to prevent the whole system from collapsing. 

To this point, reliability planning has been primarily focused on an electric system powered by conventional dispatchable generating resources. In that context resource obtainability is not particularly concerned with long-term availability of the resource because the resources are not intermittent.  That changes when the system becomes dependent upon wind and solar because there are short-term and long-term availability concerns.  It is in this context that the results from Brown et al., 2021 climatology becomes important and raises the question whether planning based on a ten-year metric is still appropriate in the future.  Using this approach, we can determine the frequency and duration of the expected worst case over ten years consistent with current IRM planning.  However, because we can consider a longer period, we can also consider the frequency and duration of droughts over the whole 70 years and get expected worst cases over other time periods.  If there is a marked difference over say the 30-year time period, it may be appropriate to expand the IRM planning period in order to prevent the probability of shedding load due to more severe drought.

Black Swan Events

To this point in this article, I have only addressed normal weather variability effects. During the preparation of this post, I came to believe that there is another reliability concern related to renewable resource adequacy that has to be addressed.  What happens to the electric system when unprecedented extreme weather cripples the relatively fragile renewable generating and transmission system?  These statistical outliers are described as a “black swan event”.

A Black Swan event is an event in human history that was unprecedented and unexpected at the point in time it occurred. However, after evaluating the surrounding context, domain experts (and in some cases even laymen) can usually conclude: “it was bound to happen”. Even though some parameters may differ (such as the event’s time, location, or specific type), it is likely that similar incidences have had similar effects in the past.

In this context the conclusion that “it was bound to happen” has to be discussed.  At an Our Energy Policy (OEP) panel discussion on New York State’s emerging offshore wind market, someone asked an off-shore wind industry expert whether wind turbines in New York would be able to withstand a Category 5 storm.  Clint Plummer the head of market strategies and new projects for Ørsted, the world’s largest owner, developer, and operator of offshore wind responded: “wind turbines are designed to withstand a Category 3 hurricane, and they have built into their permit applications an insurance fund that can pay for repairs in cases of catastrophic loss from a storm more severe”. He said “a Category 5 hurricane has a return period in excess of 100 years, while the design life of a wind farm is 30-35 years, so wind turbines are not designed to withstand a Category 5 storm because they are not expected to experience one”. “Anything less than that up to a certain speed is just a really good day for producing a lot of wind power,” he said.

In the October 1, 2021 Climate Action Council meeting presentation Carl Mas described the initial results of the integration analysis that will be used to develop the plan to implement changes to New York’s energy system to meet the CLCPA targets.  Four scenarios have been developed with different renewable resource, load reduction and sequestration strategies.  The new findings indicate that 20 GW of offshore wind resources will be necessary.  Assuming that New York builds the latest generation offshore wind turbine, e.g. the GE Haliade-X 12 MW turbine, that equates to over 1,600 turbines with 220 m or 722 foot rotors. 

However, hurricanes likely exceeding the threshold described by Ørsted expert Plummer have occurred in the area New York plans to build its offshore wind facilities.  In 1635 the “Great Colonial” Hurricane hit New York and New England and the “Great Storm of 1693” devastated Long Island. There were other hurricanes that made landfall in the Tri-State area – 1788 (left the Battery in ruins), 1821, 1893 (the second hurricane that year, different from the one that hit Halifax, Nova Scotia), 1944 (“Great Atlantic” hurricane), 1954 (Carol), and 1991 (Bob). The 1938 “Long Island Express” made landfall in Long Island as a Category 3 hurricane with sustained winds of 125 mph and wind gusts up to 150 mph bringing waves surging to 35 feet.  Given that part of the rationale for the CLCPA is that extreme weather events such as hurricanes are becoming more frequent and severe there should be no question that a contingency plan is necessary for the time that a hurricane inevitably affects, if not destroys, the New York offshore wind resource.  Moreover, should that not be a part of the reliability planning process?

Unfortunately, that is not the only extreme weather event that can have extreme consequences on a more fragile wind and solar electricity network.  I am particularly worried about ice storms.  On a local level it is not clear how the public will be able to survive a multi-day power outage caused by an ice storm when the CLCPA mandates electric heat and electric vehicles but the bigger reliability concern is that fact that ice storms can take out transmission lines.  For example, consider, the January 1998 North American ice storm:

The North American Ice Storm of 1998 (also known as Great Ice Storm of 1998) was a massive combination of five smaller successive ice storms in January 1998 that struck a relatively narrow swath of land from eastern Ontario to southern QuebecNew Brunswick and Nova Scotia in Canada, and bordering areas from northern New York to central Maine in the United States. It caused massive damage to trees and electrical infrastructure all over the area, leading to widespread long-term power outages. Millions were left in the dark for periods varying from days to several weeks, and in some instances, months. It led to 34 fatalities, a shutdown of activities in large cities like Montreal and Ottawa, and an unprecedented effort in reconstruction of the power grid. The ice storm led to the largest deployment of Canadian military personnel since the Korean War, with over 16,000 Canadian Forces personnel deployed, 12,000 in Quebec and 4,000 in Ontario at the height of the crisis.

New York Governor Kathy Hochul recently announced “two major green energy infrastructure projects to power New York City with wind, solar and hydropower projects from upstate New York and Canada”.  The press release claims that the combined project will deliver 18 million megawatt-hours of upstate and Canadian renewable energy per year.  Clean Power New York plans on over 20 wind and solar generation projects – all located in New York State – and a new 174-mile, underground transmission line. Champlain Hudson Power Express is a 338-mile underground power line from Quebec hydroelectric facilities to New York City.  The problem is that not all the associated infrastructure in these projects is underground and immune from ice storms.

Photo from 1TAC Survival Blog


The requirements for New York reliability planning will have to change for a future grid that relies on intermittent and diffuse wind and solar.  Current planning for the electric system is based on decades-long experience with a system powered primarily by sources that are dispatchable and includes sources that have on-site storage.  The potential for lack of source availability over days, weeks, and even months is not a serious concern today because the New York system has been diverse, redundant, and resilient to the vagaries of weather.

The CLCPA requirement for a zero-emissions electric system that relies on wind and solar energy resources changes the reliability planning requirements.  Previous analysis has highlighted the need to address multi-day wind lulls in the winter as a particular problem.  Brown et al., 2021 have developed a technique that can be used to determine the climatological frequency and duration of those periods of low wind and solar resource availability that clearly should be included in New York reliability planning.  Their analysis technique can also be used to identify the worst-case periods of wind and solar droughts so that more detailed resource availability analyses can estimate how much energy storage is needed not only for the electric grid but also the distributed energy resources proposed for the CLCPA.  This analysis is needed to prevent the kind of Texas February 2021 disaster from happening in New York.

The existing New York system has evolved over years of trial-and-error experience to the point where it is relatively resilient to extreme weather events.  While there have been exceptions, the possibility of widespread, weeks-long outages is extremely low.  However, because wind and solar resources are more fragile to wind and ice crippling damage than existing generating sources, the likelihood of the conditions that cause that level of damage should be determined.  Brown et al., 2021 can determine the occurrence of events over a 71-year period.  If, for example, their analysis suggests that the return period of a crippling event is one in thirty years, then should New York reliability planning incorporate a longer time horizon for its planning?

At this time, the off-shore wind strategy calls for 20 GW of development.  The ramifications of a Category 4 or greater hurricane destroying or significantly damaging those facilities should be at least be considered.  Repairing them will take months if not years and the ramifications if insufficient resources are available are immense. If nothing else the statements claiming that the future wind and solar dependent electric system will be more resilient should be toned down.

New York Independent System Operator and the Climate Leadership and Community Protection Act

On July 18, 2019 New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act (CLCPA), which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency.  The Ney York Independent System Operator (NYISO) is the “organization responsible for managing New York’s electric grid and its competitive wholesale electric marketplace”.  This post addresses the relationship between the CLCPA and NYISO.

I have written extensively on implementation of the CLCPA closely because its implementation affects my future as a New Yorker.  I briefly summarized the schedule and implementation CLCPA Summary Implementation Requirements.  I have described the law in general, described the enabling strategies, evaluated its feasibility, estimated costs, described supporting regulationssummarized some of the meetings and complained that its advocates constantly confuse weather and climate in other articles.  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.


The NYISO Frequently Asked Questions webpage explains how the organization originated.  After the Northeast Blackout of 1965, New York’s seven investor-owned utility companies established the New York Power Pool (NYPP) to address the reliability problems exposed by the blackout.  The NYPP “balanced electricity supply and demand, maintained transmission voltage, monitored system contingencies, managed operating reserves, and dispatched generation”. In the 1990s New York’s electric system was de-regulated and the Federal Energy Regulatory Commission (FERC) recommended the formation of independent entities to manage energy transmission. “At the same time, the New York State Public Service Commission (PSC) established retail electric competition to allow customers to choose their electric supplier. The PSC supported the formation of competitive wholesale markets as the basis of retail choice, and approved restructuring plans by which utilities divested most of their power plants to competitive generation companies.”  In 1999, the NYISO was established to replace the NYPP.

The NYISO manages the electric system.  They have to balance the instantaneous supply of electricity between the generators and customers across the state.  In the de-regulated market electricity is supplied by multiple types of agreements between the suppliers and the NYISO.  Some of the power is contracted by purchase power agreement contracts, some by day-ahead auctions, and the rest by real-time auctions that cover any additional power needed.  They manage the supply of power and maintain the frequency across the state and with their connections to other operating systems.  In addition, the NYISO has to plan for future changes to the system.  At this time the biggest factor for change is the CLCPA. 

There are a few other relevant aspects in the NYISO description:

The NYISO is a not-for-profit, independent company unaffiliated with any state or federal agency or energy company. The NYISO is led by an independent Board of Directors. The NYISO’s federally-approved tariffs contain strict requirements for our Board of Directors and all employees to have no financial relationship with any of the companies that participate in our wholesale energy markets. The NYISO is dedicated to transparency in how we operate, the information we provide, and our role as an impartial system operator, planner, and broker of New York’s wholesale electricity markets.

The NYISO is accountable to both federal and state regulatory bodies and maintains compliance with nearly 1,000 reliability requirements. The NYISO’s independent Board of Directors collaborates with our stakeholders via a robust shared-governance process that facilitates input from interested stakeholders. The establishment of the NYISO created a system of shared governance that provides all market participants — from utility companies to electric generators — a voice in the operation and evolution of the marketplace.

Under the NYISO’s transparent, inclusive process, representatives from market participants have voting power to exercise responsibilities such as preparing the NYISO’s annual budget, reviewing and recommending candidates for Board vacancies, developing and adopting technical guidelines for operation of the bulk power system, and market design and system planning. NYISO stakeholders share responsibility with the NYISO Board to approve proposed changes to the NYISO’s governing documents, including its federally approved tariffs.

The NYISO’s description of their process and the very name suggest that they are independent of New York politics but that is not the case with the current administration.  In the following I will explain why I think that the NYISO is pulling its punches vis-à-vis the feasibility of the CLCPA.

NYISO and the Cuomo Administration

I am not an admirer of Governor Cuomo because my impression is that his administration has always been about his best interests.  Whenever any organization has disagreed with Cuomo’s energy agenda the response has been bluster and threats.  For example, when National Grid’s plan for natural gas supply in New York City contradicted Cuomo’s agenda, he threatened to revoke the operating license for National Grid if they did not comply with his plans.  Another example, is NRG Energy’s Dunkirk power plant which was deemed uneconomic and scheduled for closure.  For some political reason, Cuomo announced an agreement to repower the plant with natural gas.  In a de-regulated market making a grant to one facility to continue operations is sure to upset competitors and a lawsuit was filed.  In addition, certain rules have to be followed that include fee requirements and NRG decided to not pursue re-powering.  Cuomo’s response was to seek a PSC probe of the business decision.

This overt insistence on toeing the administration’s political agenda extends to all the agencies under his thumb.   The Department of Public Service (DPS) and Public Service Commission are supposed to be independent however this is not the case.  In the summer of 2019 a group of retired Department of Public Service employees submitted a letter that stated “Until the current administration, Governors have generally respected the plain language of the Public Service Law (PSL), which … safeguards the mission of the DPS to serve not political interests but the public interest.” The letter signed by fifteen retired department workers states: “Governor Andrew Cuomo, however, has not done so.”

Unfortunately, the NYISO is not immune to the Governor’s tactics. In a filing to the Public Service Commission, the NYISO noted that in order to meet Cuomo’s Clean Energy Standard, a predecessor regulation to the CLCPA, New York would have to install over 1,000 new miles of bulk transmission lines at great cost and effort which exposed one of the short-comings of the Governor’s clean energy agenda.  In response, Cuomo’s energy czar, Richard Kauffman, accused NYISO Director Brad Jones and his NYISO report as “misleading, incomplete, and grossly inaccurate…revealing an alarming lack of developed analysis into the imperative to address climate change…” Kauffman’s letter accused Jones of protecting fossil fuel generators and said that he was “dismayed by [Jones’] public comments.  

In this political climate it is not surprising that rather than standing up to the bully, the “independent” NYISO caved, Jones left, and was replaced by Rich Dewey.  Now the NYISO reports carefully word every document so as to not invoke the wrath of Cuomo’s bullies. 

NYISO Raison D’être

There is another aspect of the NYISO’s operations that colors their responses.  It is not surprising that the NYISO completely endorses the idea that wholesale electricity markets have the ability to solve any problems because that is the reason for their existence.  Unfortunately, I think some of their faith in market mechanisms is unwarranted.

I am not an expert on market design but I fear we are heading towards an energy crisis.  In a regulated market the Public Service Commission (PSC) tells the vertically integrated electric utilities to meet a specific mandate, the utilities develop a response, the PSC oversees their responses relative to reliability and affordability, and the necessary infrastructure gets built.  In New York’s de-regulated market, planners at the NYISO and various state agencies do the planning and then the NYISO and PSC develop “innovative market rules necessary to meet the objectives of the CLCPA” that they hope will engender market participants to build the necessary infrastructure. 

There are tremendous technological challenges converting from the current electric system to one dependent upon renewable energy sources and I am convinced that the only way unexpected kinks will be worked out is by trial and error.  The Texas electricity market design did not work well in February and I have no reason to expect that some new wrinkle introduced by relying on intermittent and diffuse renewable energy will only be resolved after the problem occurs. Robert Bradley recently explanation of what happened during the big freeze relative to the Texas electricity market and the difference between managed markets like New York’s wholesale electricity market and a “free market” supports my concern.

In addition, the problem may occur because the NYISO identifies a problem that the politicians who are running New York energy policy decide to ignore.  Of course, when it occurs the blame will be place on the NYISO.  In this regard Donn Dears book “The Looming Energy Crisis” provides a detailed description of potential problems that are a challenge to overcome and might require imposition of politically unpopular policies.  In the current political environment these issues are more likely than not.

Finally, I want to give an example where the market did not produce the obvious environmental solution.  New York State energy and environmental policy is more about optics than facts.  Nowhere is this more apparent than the recent spate of opinion pieces, reports, and even policy proposals related to peaking power plants.  In brief there are old simple cycle turbines in New York City that were built to provide reliable power during peak load periods.  However, there are old, inefficient and much dirtier than today’s technology.  In my opinion the continued operation of the old simple cycle turbines in New York City is the result of New York’s de-regulated market place.  I am absolutely sure that in a regulated environment the responsible utility would have made a case to the Department of Public Service that replacement with cleaner, more efficient generation was needed, the Department would have agreed,  and, after it was approved, the utility would have been guaranteed a reasonable return on their investment so the turbines would have been replaced.  However, in the de-regulated market there wasn’t a strong enough financial incentive to replace the old units.  Before I retired in 2010, I worked on two separate permit applications for new, efficient, and cleaner replacement power for one set of the old combustion turbines.  In both instances the permits were approved but the replacements were never built, apparently because the company decided that the business case was not strong enough to warrant the investment.  The fact is that sometimes the market signals are too weak to provide the desired result.


The point of this post is to document the importance of the NYISO but to also point out that their policies and recommendations are necessarily colored by their belief that markets are a viable solution to the challenges of the CLCPA energy transition and by the political climate of New York.  The NYISO has done a good job analyzing the challenges of the energy transition.  Unfortunately, many members of the CLCPA advisory panels and the Climate Action Council don’t understand, don’t want to understand, or choose to ignore the warnings in those analyses.  In my opinion, there are enough technical challenges in the transition that maintaining reliability will be a problem but the added challenge of designing some market mechanism to get the market to provide the resources necessary all but assures that reliability will become an issue. 

Finally, I sympathize with the NYISO position.  All their work not only has to fully explain the problems they identify but the wording has to pass a political optics text.  This means that all their reports have to toe the existential threat of climate change narrative without any suggestion that the potential risks to reliability, affordability, and environmental impacts of the proposed solutions far out-weigh the alleged impacts of climate change.  It is similar to the symbiotic relationship between the Egyptian plover and crocodile.  NYISO is performing a service to the state but you never know if the Cuomo crocodile is going to snap.

Fossil Fuel Phase Out Claptrap

Truthout is a nonprofit news organization dedicated to providing independent reporting and commentary on a diverse range of social justice issues.  According to the about description “Truthout works to spark action by revealing systemic injustice and providing a platform for progressive and transformative ideas, through in-depth investigative reporting and critical analysis. With a powerful, independent voice, we will spur transformations in consciousness and inspire both policy change and direct action.”  If the article Fossil Fuel Phase Out Must Begin Where the Industry Has Hurt People the Most is any indicator, however, their platform is based on emotion and not facts.  The alleged problems with peaking power plants and neighborhood power plant impacts on local health are exaggerated and nearly fact free.  The proposed solution is untested and likely to make the lives that they want to improve worse.

I am a retired air pollution meteorologist with over 40 years-experience analyzing the effects of meteorology on electric operations.  While doing consulting work for the Environmental Protection Agency I evaluated air quality model performance and later worked at a utility company where I was responsible for ambient monitoring networks in the vicinity of power plants and evaluating their air quality impacts.  I have been involved with peaking power plants in particular for over 20 years both from a compliance reporting standpoint and also evaluation of impacts and options for those sources.  This background served me well preparing this post.  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.


The article is prefaced with a note that “this story is part of Covering Climate Now, a global journalism collaboration strengthening coverage of the climate story”.  The author is Leanna First-Arai. “a freelance journalist who covers environmental and climate (in)justice. Her work has appeared in Undark, Sierra Magazine, Yes! Magazine, Outside Magazine, on New England Public Radio and elsewhere”.

The Fossil Fuel Phase Out Must Begin Where the Industry Has Hurt People the Most article describes the claims made in the recently released Fossil Fuel End Game report that I described here.  The basic premise is that New York City peaking power plants only operate a limited days per year, they are usually old and dirty plants located in disadvantaged communities, and they received around $5 billion to keep running in the last decade.  Therefore, they should be the first fossil plants to be replaced by clean energy.

I have been following this peaking power plant initiative for about a year and summarized my work here.  This article is the latest iteration of advocacy releases based on the Physicians, Scientists, and Engineers (PSE) for Healthy Energy report Opportunities for Replacing Peaker Plants with Energy Storage in New York StateI discussed the PSE report last year and the PEAK Coalition report entitled: “Dirty Energy, Big Money” in two detailed technical posts.  The first post provided information on the primary air quality problem associated with these facilities, the organizations behind the report, the State’s response to date, the underlying issue of environmental justice and addressed the motivation for the analysis.  The second post addressed the rationale and feasibility of the proposed plan relative to environmental effects, affordability, and reliability. 

Oswego Harbor Power Plant

In order to show that this article is based on emotion and not facts consider the description and allegation related to the Oswego Harbor Power Plant.  In this section I have annotated (indented and italicized) my comments after each sentence from the relevant paragraph in the article.

Residents living within a one-mile radius of the Oswego Harbor Power Plant, one of only a handful of such plants left in Upstate New York, are ranked in the 99th percentile for incidence of heart attacks, based on an analysis of New York State Health Department data by the nonprofit research institute Physicians, Scientists and Engineers for Healthy Energy (PSE).

The insinuation here is that the residents within one-mile of the power plant have a high rate of heart attacks because of the power plant. 

The 73-year-old plant only went online six times in 2018 (the most recent year for which data are available).

There is a description of the plant in a US Army Corps of Engineers harbor infrastructure report that explains that there are two 850 MW units in operation and in service since 1975 – 46 years not 73.  The older units have been retired since before the turn of the century. The units burn residual oil that is stored on-site.  At the time of their construction residual oil was cheaper than coal and for many years residual oil was cheaper than natural gas so the units ran a lot in the late 1980’s.  The fuel price differential no longer supports the use of residual oil.  However, in times of great need the facility can generate 1,700 MW of dispatchable power without regard to weather-caused outages.

 The EPA Clean Air Markets Program Database provides data for the most recent quarter within 45 days so more recent data are available than claimed.  Table 1 lists annual data through 2020.  The important point in the context of this discussion is that emissions from the plant are minimal which is not surprising because of the short operating times.

 Table 1: Oswego Harbor Power Annual Emissions and Operations Data

Unit IDYear Operating Time Gross Load SO2 NOx CO2

But if residents suspect hazier-than-usual skies, no federal air quality data exists to help make sense of the short-lived plume of pollution, as the closest Environmental Protection Agency monitors are 40 and 70 miles away, respectively, in Syracuse and Rochester.

The insinuation that the DEC, EPA and owner of the plant know nothing about the plume of pollution is completely baseless.  The author clearly knows nothing about air quality regulations, air quality meteorology, or the Oswego Harbor plant.  The New York Department of Environmental Conservation (DEC) is responsible for maintaining air quality that meets the National Ambient Air Quality Standard limits under the guidance of EPA.  They do that by monitoring near emission sources and modeling facility emissions to estimate air quality impacts. 

 At this time there are no DEC air monitoring stations closer than Rochester and Syracuse.  EPA does not monitor air quality in New York.  However, that does not mean that there never was any air quality monitoring closer to the plant.  I know because I as responsible for submitting the data from the network around the Oswego plant.  After several years of not measuring any exceedances from the power plant DEC and EPA agreed that it was no longer necessary to run the monitoring network and it was retired by 1990.   At one time most, if not all power plants, had monitoring networks but one of two things happened.  If, like at Oswego, no measurements indicating problems were found then the networks were retired.  If problems were found then the emission limits were changed for the facility until the monitoring found that there were no problems.  Also note that these data were used to verify that the air quality models used to predict ambient levels near the plants were correct.  Under contract to EPA, I did that verification work using those data sets and later also compared the Oswego Harbor plant modeled impacts to observations.  That work proved that the models correctly characterize nearby air quality.

 It is not surprising that the modeling never showed anything approaching an exceedance of the National Ambient Air Quality Standards or that the highest observed monitored concentrations were accompanied with the smell of chocolate from the Nestles plant that was located in the opposite direction.  The stacks at Oswego are 700’ high and the plume rise from the hot gases pushes the plume higher.  As a result, the pollution plume is nowhere near the ground within a mile of the plant. 

The insinuated claim that the Oswego Harbor Power Plant is somehow associated with local high incidents of heart attacks is unsubstantiated.  The article states that the plant only ran six times in 2018 and the data show it only ran 352 hours so it was online for less than three days at a time.  Present operations are about 1% of the operating times and rates as in 1988 when the monitoring network that showed the plant did not adversely affect air quality.  If I had to guess why there is a high rate of heart attacks my money would be on the fact that Oswego is in the lake-effect snow belt and when it snows, it snows a lot.  Snow removal is a notorious cause of heart attacks.

Peaking Power Plant Replacements

The author and the advocates quoted in the article are unaware of the fundamental problem with the PSE report Opportunities for Replacing Peaker Plants with Energy Storage in New York State.  PSE defined peaking power plants by their current time of operation not by their design capabilities.  The Oswego Harbor Power Plant is the best example of this problem.  The plant was designed to provide base load power when it was thought that residual oil would continue to be a cost-effective fuel.  The two 850 MW units operated well when that was true but with today’s fuel costs it only offers support to system as backup capacity.  There are three nuclear plants within ten miles of the facility and if there is a problem with those units then the power plant can step in to replace their output.  For example, in the 2004 blackout Nuclear Regulatory Commission operating rules required the nuclear units to go offline and the Oswego Harbor Power Plant was called on to support the system until the nuclear units were allowed to go back online.  The units also come online when loads are very high and all power generation is needed.  There are other power plants in New York that operate much less than they were designed to operate that fulfill similar reliability needs.

The PSE report claims that all of the plants that they claim are peakers can be replaced by renewable energy and storage.  The problem with that is that their definition is based solely on operating times and does not consider the capabilities of the peaking units.  The New York electric system has more stringent rules than Texas.  In the wake of the blackouts last February, Texas is wrestling with how to prevent similar problems in the future by asking should power generators be required to guarantee that they can provide a certain amount of electricity?  New York’s response to this issue includes capacity payments to Oswego Harbor Power for 1700 MW of power six times a year.  This resource is dedicated to that need and can provide that capability because the capital investments necessary have already been paid, even though the fuel is relatively expensive it provides concentrated energy capable of 1700 MW, and the costs to maintain that much power capability are relatively low. 

The first problem with the PSE report claims that the steam turbine units like Oswego that provide peak capacity support can be replaced by renewable energy and storage is that the capital cost to develop enough energy storage to replace all those units has to be paid for a rarely used resource.  A major reason that New York’s capacity payments are as low as they are is because the resources needed to meet New York’s requirements has paid off those costs.  Replacing those facilities with anything will be much more expensive.  The second problem is that the renewable and energy storage approach proposed has never been implemented at the scale needed for New York’s electric resource requirements.  Replacing a system that has worked for decades with unproven technology could very well lead to reliability issues as the system is de-bugged.


All these analyses vilify peaking power plants oblivious to their value to the grid.  The PSE study estimated that they received around $5 billion in the last decade but only ran less than 5% of the time.  The New York electrical system pays for these units to provide capacity and ancillary services so that the electric system can reliably provide power when it is needed most.  The Texas energy system does not have a similar policy in place.  While Texas average prices are lower than New York prices their system is vulnerable to blackouts when peaking power is unavailable.  Simply put, New York peaking power plants are an insurance policy to prevent Texas-style blackouts.  The February 2021 Texas blackouts caused dozens of deaths and tens of billions of dollars in damages.  The New York peaking power plant insurance policy looks like a good deal to me.

Another big driver in the vilification of peaking power plants is the claim that they adversely affect air quality in neighboring disadvantaged communities. However, I don’t think that the PSE approach made a convincing case that the peaking power plants are a primary driver of environmental burdens on neighboring communities.  My primary objection to this claim is that the health effects attributed to peaking power plants are based on air quality impacts from ozone and particulate matter.  However, ozone is a secondary air pollutant and the vast majority of ambient PM2.5 from power plants is also a secondary pollutant.  As a result, there is enough of a lag between the time emissions are released and creation of either ozone or PM2.5, that the impact is away from the adjoining neighborhoods.  That means that the accused peaking power plants do not create the air quality impact problems alleged to occur to the environmental justice communities located near the plants.  In fact, because NOx scavenges ozone the peaker plants reduce local ozone if they have any effect at all.

The claims that peaking power plants are dangers to neighboring environmental justice communities are based on emotion.  The existing simple cycle peaking turbines in New York City are old, inefficient and much dirtier than a new facility and clearly should be replaced.  However, they reliably produce affordable power when needed most. Importantly regulations are now in place that ensure that they are retired or that their pollution control equipment is upgraded on a schedule that guarantees in-kind replacement of capacity and ancillary services.   In order to maintain existing levels of affordability and reliability I think it is best to rely on a proven solution using fossil fuels.  The solar plus energy storage approach advocated by PSE and the PEAK Coalition will likely increase costs significantly if it works.  I cannot over-emphasize the fact that it may not work because wind, solar, and energy storage is not a proven technology on the scale necessary to provide New York City’s peaking power requirements.  Sadly, in the rush to prove politically correct credentials this unproven technology may be chosen despite the risks to power reliability.  It is the height of hubris that the New York legislature has pending bills to over-ride the reliability planning process and existing environmental regulations without including a feasibility study to define the wind, solar and energy storage resources needed, the technological readiness of those resources at the scale needed and the costs of that approach.

Finally, I do not disagree with the premise that disproportionate environmental risks to disadvantaged communities need to be addressed.  However, that goal has limits.  First, and foremost, it simply is not good policy to expect the removal of all environmental impacts.  For example, a replacement state-of-the-art natural gas fired combustion turbine that reduces existing impacts substantially should be an acceptable choice because it provides a proven affordable solution and reduces well-known impacts.  The proposed alternative of renewable energy and energy storage is unproven technology at the scale needed, is costly when the cost to provide uninterruptable power is considered, and could very well lead to worse overall environmental impacts especially when the effects of the rare earth metals needed for those resources is included.  The result is there is a high likelihood of problems with affordability, reliability, and environmental impacts due to the implementation of the proposed solution.  If those problems occur then the disadvantaged communities that these advocates want to protect will be disproportionately impacted.  I don’t think that the advocates understand that those impacts could be worse than the problems that they want addressed.

Texas Lessons to Keep the Lights On Dangers

On March 14, 2021 the Syracuse Post Standard published a commentary “To keep the lights on, take these lessons from Texas” by Dr. David Murphy, an associate professor of environmental studies at St. Lawrence University.  Unfortunately, most of what he said is incorrect and what he proposed will guarantee that New York’s lights will go out.

Unsaid in the commentary is that much of what Dr. Murphy proposed is being incorporated into the implementation plans for the Climate Leadership and Community Protection Act (CLCPA).  I have summarized the schedule, implementation components, and provide links to the legislation itself at CLCPA Summary Implementation Requirements.  I have written extensively in long posts on implementation of the CLCPA because I believe that it will negatively affect reliability, affordability and the environment.  I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulations, listed the scoping plan strategies, summarized some of the meetings and complained that its advocates constantly confuse weather and climate.  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.

Dr. Murphy has a Ph.D. in Environmental Science and Master of Science in Environmental Science, State University of New York, College of Environmental Science and Forestry, Syracuse, NY and Bachelor of Arts in Biology, The College of the Holy Cross, Worcester, MA.  He has authored a textbook Renewable Energy in the 21st Century and according to his webpage at St. Lawrence University, he “has also published widely in the popular press.”  Note in particular that “has been featured on a number of episodes of the podcast The Energy Transition Show with Chris Nelder, a popular podcast in energy technology and climate change activist circles.”  Based on this I characterize Dr. Murphy as a professional climate change activist whose career depends on the narrative that climate change is an existential threat.

To keep the lights on, we should take these lessons from Texas

In the following section I will provide my italicized and indented comments on his commentary.  For a detailed overview of the Texas deep freeze I recommend this article by Weather Blogger Chris Martz.  He explains that Arctic cold weather events have occur regularly, the weather conditions associated with these events always include high pressures with very light winds so wind resources will always stop working, and that “to blame weather events that have occurred many times before on man-made climate change is absurd”.

 The tragedy in Texas is viewed by many as another glimpse of our uncertain future, and that brings up the question of whether it is possible to be prepared for scenarios we can’t even imagine in the new, climate-changing world.

In climate change activist circles any unusual weather is due to climate change.  Martz points out that cold waves are an expression of natural atmospheric variability and result in record cold temperature.  This was a record-breaking event.  He goes on to point out that the earth is warming and that the “frequency of cold waves, the number of record low temperatures, and the percent of land area observing unusually cold temperatures have all declined over the last century”.  Nonetheless, the important point is that similar cold snaps occurred in 2011, 1991, 1990, 1989, 1983, 1963, and 1961 and electrical outages occurred in some of those cold snaps.  The real question is whether Texas adequately planned for the past, not whether we can plan for an uncertain future.

The storm wreaked havoc on almost all major power-producing technologies. A nuclear generator supplying electricity to 1 million homes tripped off-line due to the cold weather impacting a pump system. Natural gas supplies for heating homes froze up. And wind turbines froze in place. The more climate changes, the harder it will be to predict, and outages like the one in Texas are all but guaranteed. The Biden administration must develop a resilient power grid where outages impact fewer people for less time. To build a resilient grid, we should focus on redundancy and decentralization.

This was not a climate change problem.  Instead, it was poor planning for a variety of reasons and, in my opinion, something similar is not likely in New York because the New York electric market has different rules and priorities.  However, given that New York’s CLCPA mandates a transition to zero-emissions electric sources the question becomes is this more likely in the future?  I agree with Dr. Murphy when he says we should focus on redundancy to prevent something similar in the future but disagree what counts as valuable redundancy.  I see no value in de-centralization.

Redundancy means that if there is a failure in one part of the system, another can perform that same task, avoiding a large-scale outage or an outage altogether. Slightly more than half of Texas’ electric grid relies on one fuel source — natural gas —and another quarter relies on wind.

Compared to Texas New York currently has a more redundant electric system because there are more options for generating electricity and used to be much more redundant.  In 2019, New York electricity was generated 38% by natural gas, 23% by hydro, 33% by nuclear, 3% by wind and solar and 2% by other sources.  In 2001, New York electricity was generated 16% by coal, 27% by natural gas, 11% by oil, 16% by hydro, 28% by nuclear, 0% by wind and solar and 2% by other sources.  One key aspect of redundancy is the ability to store fuel on-site which is a feature of coal, oil, hydro and nuclear.  All three fuels are used much less than in 2001.  It is also important to be able to transport the fuel different ways which is another feature of coal and oil that has disappeared.  Based on these trends New York electric generation is becoming less redundant and thus more likely to have blackouts.

Microgrids, small grids within a larger system, are another form of redundancy. Microgrids can operate in “island mode” — if the larger grid is collapsing, the microgrid shuts communication and operates alone, keeping lights on. Alaska —with expansive land and isolated populations — has a number of microgrids. The Longhorn State has few.  Decentralizing power production systems also is important. When one reactor at the South Texas Nuclear Power Station went offline due to the cold temperature, power to supply 1 million homes went off-line. This makes entire cities, not just small towns, vulnerable.  We need many microgrids using many energy sources, both large and small — and by small I mean as small as rooftop solar panels and battery storage systems.

 De-centralized microgrids powered by wind and solar are a climate activist talking point but I don’t believe they stand up to scrutiny.  While it is true that a microgrid can operate without being connected to the grid the question is whether the factors that caused the grid to collapse also affect the microgrid.  In the case of extreme weather events, damage to microgrids powered by wind and solar is also likely. 

 The bigger problem is whether a microgrid can provide necessary power when and for as long as it is needed. Murphy neglects to point out that the Alaskan micro-grids are powered by fossil fuels that can be stored on-site.  His vision is for micro-grids powered by wind and solar.  Martz points out that energy demand is highest during both periods of extreme cold and extreme heat and that such weather conditions are associated with high pressure and very light wind speeds, which means, wind turbines will stop working.  Coupled with the fact that New York solar radiation is reduced by day length, cloudy conditions, and snow cover, I am very leery that sufficient renewable energy resources are available to meet the demands of winter peak load.

 In order to meet New York’s climate law goals heating and transportation will have to be electrified.  As a result, even more electricity will be needed.  Because renewable energy is intermittent, energy storage is required. This is a particular problem because demand varies and when the demand is highest it is also needed most.  Murphy’s rooftop solar panels and battery storage system approach may work most of the time but in order to provide reliability during the coldest periods the amount of energy storage needed for one or two days a year may be uneconomic.  This is precisely what happened in Texas.  Ratepayers enjoyed low rates because the electric market did not incorporate a mechanism for generators to pay for measures that would ensure they could provide power during intense cold snaps.  When the record-breaking cold weather occurred, the system could not provide the necessary energy at any cost so the system broke down.

All this requires a paradigm shift in thinking. For the past century, we have built grids that take what energy guru Amory Lovins calls the “hard energy path.” This means building big, centralized generators that produce massive amounts of electricity in a one-way grid system to deliver power to customers.  We need a 21st century version of Lovins’ “soft energy path” that focuses on energy conservation, solar and wind power. These technologies, in contrast to huge nuclear generators, are smaller and more flexible. And, since many more will be needed and spread across the country, they will be much less prone to massive outages like that in Texas.

Climate activists love to disparage the current electrical system with its centralized generating stations but the fact is that they provide affordable and reliable electricity.  There are inherent economies of scale that enable large power plants to provide power for millions cheaply and efficiently.  Moreover, different types of fuels at these power plants truly provide a redundant and flexible power system that can provide reliable electricity when needed.  In contrast wind and solar power which are utterly dependent upon the vagaries of weather cannot be called flexible and certainly are not dependable without additional energy storage and grid support services that markedly increase the cost.  The claim that wind and solar are less prone to massive outages is absurd given that every night with calm winds causes an outage of both of these generating resources. Furthermore, he point out that “many more will be needed and spread across the country” means that wind turbines and solar panels will sprawl across New York with significant  impacts to birds and bats.

The Biden plan calls for a modern grid system, but details are unclear. The Green Act of 2020 introduced in the House doesn’t address grids. If we want to avoid crises, the plan must include redundancy and decentralization. We must encourage more people to produce their own energy.  Investing in local production and ownership of energy systems makes energy systems more resilient and creates jobs.

One climate alarmist cherished belief is that because the wind is always blowing somewhere the solution to local wind calms is a transmission system that can move the power from those locations to calm locations.  There are problems however. 

 The fundamental issue for keeping the lights on is that wind is intermittent.  I found that in New York in 2018 there were 1,982 MW of onshore wind energy nameplate capacity that generated 3,985 GWh of electrical energy for a state-wide annual capacity factor of 24.5%.  The problem is that I also found that over a sixteen-month period there were 25 hours when none of the 24 wind facilities in the state produced any power, that 36% of the time less than 200 MW per hour was produced and that half the time hourly wind output was less than 324 MW.  The worst case is a long duration period with light winds. I found 12 periods when less than 100 MW of the state’s total wind capacity of 1,982 MW was available for 24 hours, 5 periods for 36 hours, and one period of 58 hours. Evaluation of wind energy on continental scales in Australia shows that large high pressure systems can cause light winds over continental scales.  The grid solution to intermittency is fatally flawed.

 New York’s worst case wind energy deficit was 58 hours long when wind output was less than 100MW meaning that in order to replace the total onshore wind capacity 1,800 MW has to be generated elsewhere and transmitted to New York.  In order to be absolutely positive that amount of power is available, dedicated renewable resources someplace where the winds are guaranteed to not also be calm are required.  In other words, both the wind turbines and the transmission capacity necessary cannot be used for anything else.  I expect that would be uneconomic.   Alternatively, energy storage could be developed but the problem is there is no long-duration energy storage technology currently available that can be deployed in the necessary quantities.

 It is not clear to me how wind and solar resources can be considered redundant.  Putting all our energy production into two limited types of intermittent resources seems anything but redundant and given their susceptibility to weather impacts it certainly is not a resilient option..

Clean energy jobs account for roughly 40% of energy sector jobs in the U.S., and according to a Brookings Institution report, they are also better paying than most jobs across the country.

While I am not sure that I reviewed the Brookings Institution report referenced, I suspect that the Brookings report Advancing Inclusion through Clean Energy Jobs has the same biases are present in all their work.  I believe the appropriate jobs metric limits clean energy jobs to those that would not exist in the absence of clean energy initiatives.  However, the Brookings definition of clean energy jobs encompasses jobs that go well beyond the work necessary for a clean energy economy.  For example, in the environmental management sector they include hazardous materials removal workers, refuse and recyclable material collectors, and septic tank servicers and sewer pipe cleaners.  Consequently, they are taking credit for “clean energy” jobs that would exist anyway which makes the claim that 40% of the jobs in the energy sector are in clean energy exaggerated.

By encouraging individuals and local communities to produce their own energy, we will also increase energy democracy, so that not just the downtown, wealthy areas remain with power while the poorer neighborhoods experience outages, such as what happened in Texas. We can’t predict the future, and outages will continue to occur, we can only hope to minimize their impact, and focusing on a resilient future is the only path to do so.

The presumption that individuals have the desire and means to produce their own energy is a great theory but in practice I suspect most people have a greater desire for affordable and reliable electricity. Until it is demonstrated that investing in the capability to provide reliable power as proposed when I need it is cheaper than current costs, I suspect that I am not the only skeptic of the economics of this approach.  As to viability my roof line runs north-south so I do not have the optimal setup for solar panels and I live in the cloud and snow belt downwind of Lake Ontario so solar is not dependable in the winter.

 Energy democracy is a slogan long on emotion but short on content.  I don’t understand what is meant by energy democracy or the basis of the argument so I cannot respond.

 The Texas lesson should be that they did not develop an electric market that rewarded development of infrastructure to withstand cold temperatures that have been observed in the past.  My concern is that while community energy approach may work most of the time there will be times, likely when the power is needed the most, that it won’t work.  Any resources diverted to this aspirational, feel-good approach reduce what is available to a solution that provides power all the time. 

 The other Texas warning should be the pitfalls of an over-dependence upon wind energy.  The coldest air of the winter and the highest demand occurs when cold air moves in behind a cold front.  This Arctic air is associated with a cold core high pressure system pushing the front.  Those high pressure systems have very little wind.  Martz nailed it when he said “When it comes to a life and death situation, what would you do? Use fossil fuels to keep warm and survive, or freeze yourself to death once wind power fails in order to save the planet?”


Dr. Murphy concludes that “We can’t predict the future, and outages will continue to occur, we can only hope to minimize their impact, and focusing on a resilient future is the only path to do so.”  The real cause of the Texas energy debacle was to fail to address obvious impacts associated with observed cold weather outbreaks in the winter.  Our first priority should be to plan for the future based on what has happened in the past because if we cannot do that then there is no way we can plan for future changes.

His recommendation is to build a resilient grid which focuses on redundancy and decentralization.  A redundant electric system exceeds what is normally needed and necessary for as wide a range of conditions as possible.  It is unclear how solar energy that is only available half the time, is reduced when it is cloudy, and can go to zero when panels are covered with snow can be considered redundant.  His suggested approach relies on energy conservation, solar and wind power and that might work most of the time.  Unfortunately, an electric system that fails to provide power when it is needed most is a recipe for catastrophe, just like Texas.

Energy conservation is a no regrets approach but it is naïve to expect that energy loads won’t continue to peak and grow when the weather is very cold or very hot, especially when New York’s CLCPA mandates heating electrification.  When the electric system transitions to solar and wind power, the critical weather period will be a multi-day wind lull in the winter because both wind and solar energy availability is very low.   In order to provide power during those periods for Murphy’s de-centralized large energy sources and rooftop solar panels, the energy storage systems necessary for them to be independent of the centralized system will have to be large.  I expect that installing large batteries for short periods of the year will be uneconomic.  Advocates for this approach have to prove otherwise.

Like it or not New York is rushing ahead to incorporate the themes in Dr. Murphy’s commentary in the implementation plans for the CLCPA.  It cannot be over-emphasized that these concepts have not been implemented anywhere on the scale necessary to transition the New York electric grid.  Moreover, initial attempts in other jurisdictions have shown that costs have gone up and reliability has gone down.  The real lessons of the Texas energy debacle should be caution is needed, that reliance on intermittent resources is risky, and that failure will have catastrophic impacts.


New York Pollution Justice Act of 2021 – What Were They Thinking?

Just when I think New York politicians cannot do anything more stupid something comes out that proves me wrong.  On March 3, 2021 the New York State Senate passed the New York Pollution Justice Act of 2021.  According to this law power plants that only run during peak periods are ripping off consumers, causing health impacts, and can be replaced with renewable energy systems.  The premise is wrong, the rationale is incorrect, and the solution is risky.  Coming so close to the Texas energy debacle any rational politician might think it would be inappropriate to try to dictate energy policy but the New York Senate majority thinks otherwise.

I am a retired electric utility meteorologist with nearly 40 years-experience analyzing the effects of meteorology on electric operations.  I have been involved with peaking power plants in particular for over 20 years both from a compliance reporting standpoint and also evaluation of impacts and options for these sources.  This background served me well analyzing this issue.  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.

Overview of the New York Pollution Justice Act of 2021

The law affects a power plant that is located within one mile of an environmental justice community and is a “Replaceable peaker plant” defined as a major electric generating facility as defined in paragraph b of subdivision one of section 19-0312  that burns coal, oil, diesel or natural gas and was operational and generated electricity less than fifteen percent of the year during at least two years between two thousand ten through two thousand  nineteen.  Such plants must be replaced by the construction and operation of a renewable energy system, battery or energy storage, or transmission and distribution infrastructure that enables the provision of the equivalent maximum annual power output achieved by the replaceable peaker.

The owner or operator of a replaceable peaker plant has to include a mandatory replacement and compliance plan with an application to renew an operating permit.  That plan has to include a proposed strategy to “replace the plant with renewable energy systems or battery storage or a combination thereof”.  A timetable for implementation of the proposed replacement strategy is required that “shall not exceed five years from the date of renewal of the operating permit and that shall ensure that the renewable energy systems and battery storage are fully operational, and the operations of the peaker plant can be completely replaced, on or before five years from the date of renewal of the operating permit”


The genesis of this law is the Physicians, Scientists, and Engineers (PSE) for Healthy Energy report Opportunities for Replacing Peaker Plants with Energy Storage in New York State.  The text for the New York specific report describes the alleged problem:

“Across New York, 49 oil- and gas-fired peaker power plants and peaking units at larger plants help meet statewide peak electric demand.  These include both combustion turbines designed to ramp quickly to meet peak demand, and aging steam turbines now used infrequently to meet peak needs. More than a third of New York’s peaker plants burn primarily oil, and three-quarters are over 30 years old resulting in numerous inefficient plants with high rates of greenhouse gas and criteria pollutant emissions for every unit of electricity generated. Some of these plants are in very urban areas: ten plants have more than a million people living within three miles. One-third of the plants are located in areas the state considers to be environmental justice communities, where vulnerable populations typically already experience high levels of health and environmental burdens. New York has set energy storage targets and recently designed peaker plant emission reduction targets, providing an opportunity to replace inefficient, high-emitting peaker plants in vulnerable communities throughout the state with energy storage and solar.”

These findings were picked up on by the New York City PEAK Coalition.  They released a report in the spring of 2020 entitled: “Dirty Energy, Big Money”.  Last year I wrote three posts on this topic.   The first post provided information on the primary air quality problem associated with these facilities, the organizations behind the report, the State’s response to date, the underlying issue of environmental justice and addressed the motivation for the analysis.  The second post addressed the rationale and feasibility of the proposed plan relative to environmental effects, affordability, and reliability.  Finally, I discussed the Opportunities for Replacing Peaker Plants with Energy Storage in New York State document that provided technical information used by the PEAK Coalition.  I  summarized all three of the technical posts in simpler fashion.  Finally note that I looked at the trends of inhalable particulates in New York City relative to the claims of a dire health threat.

Statement of Findings

In this post I will address the points made in § 19-1301, Statement of findings in the text of the Pollution Justice Law.  I will list the text and follow that with italicized and indented comments.

  1. Electric generating units that generally operate during periods of peak electricity demand are known as peaker plants. Many peaker plants in the state are older fossil fuel-fired units that emit greenhouse gases and a variety of other harmful air pollutants including sulfur oxides, nitrogen oxides, particulates and mercury.

In order to identify peaking power plants PSE evaluated data from power plants across the country based on fuel type, capacity, technology and how much they ran.  This is a blunt approach that cannot address any of the nuances that have resulted in some units running for short times.  These units are typically vilified as old, inefficient, and high emitters but the PSE classification includes newer efficient units with low emission rates. There are simple cycle turbines in New York City that were built specifically to provide peaking power which have been the focus of regulatory efforts that are old, inefficient and high emitters but last year the Department of Environmental Conservation promulgated regulations to phase them out.  Large oil-fired units that run little because their fuel costs are so high are also included and the proposed legal remedy is not a cost-effective replacement for those units.

 The pollutants listed are misleading.  Greenhouse gases are emitted but there is a law specifically designed to address them.  No New York power plants burn coal so only natural gas and oil are burned and that means that mercury is not emitted at detectable levels.  There are stringent sulfur in fuel limits for oil across the state but particularly in New York City, so sulfur oxides emissions are low.  Particulate emissions from oil-firing are also low.  Natural gas emissions of particulates and sulfur oxides are essentially zero.  In my opinion then, the emissions of those pollutants are non-issues.  The New York metropolitan area is in non-attainment for ozone so the real pollutant of concern is nitrogen oxides because it is a precursor to ozone. 

  1. A substantial number of peaker plants are located in or adjacent to environmental justice communities in the city of New York and Long Island that already bear disproportionate pollution burdens due to a history of siting pollution sources in those communities. More than one million New Yorkers live within one mile of a peaker plant.

Potential environmental justice areas, based on DEC Commissioner Policy 29 on Environmental Justice and Permitting (CP-29), are U.S. Census block groups of 250 to 500 households each that, in the Census, had populations that met or exceeded at least one of the following statistical thresholds:

          1. At least 51.1% of the population in an urban area reported themselves to be members of minority groups; or
          2. At least 33.8% of the population in a rural area reported themselves to be members of minority groups; or
          3. At least 23.59% of the population in an urban or rural area had household incomes below the federal poverty level.

I closed out my career working at the NRG Oswego Harbor Power plant. It turns out that the neighborhood surrounding the plant is a potential environmental justice area. This plant has two 850 MW oil-fired boilers and because the cost of oil is usually higher than natural gas the unit does not run much.  Therefore, because this is a peaking power plant and in an environmental justice neighborhood, I believe the law applies to the plant.

  1. Pollutants from peaker plants contribute to significant public health problems. According to the New York city department of health and mental hygiene’s air pollution and the health of New Yorkers report: “each year, PM2.5 pollution in (New York City) causes more than 3,000 deaths, 2,000 hospital admissions for lung and heart conditions, and approximately 6,000 emergency department visits for asthma in children and adults.” According to the report, each year exposures to ozone concentrations above background levels cause an estimated “400 premature deaths, 850 hospitalizations for asthma and 4,500 emergency department visits for asthma.”

 The claim that there are significant public health problems is based on the New York City Department of Health and Mental Hygiene’s (DOHMH) Air Pollution and the Health of New Yorkers report.  Based on their results the report notes that: “Even a feasible, modest reduction (10%) in PM2.5 concentrations could prevent more than 300 premature deaths, 200 hospital admissions and 600 emergency department visits”.  In my analysis of New York City inhalable particulates, I found that between the time of this study and the most recent comparable three-year period the PM2.5 concentrations decreased 38%.  In order to convince me that the PM2.5 health impacts claimed by MOHDOH and this law are correct I need to see confirmation with observed data showing health improvements on the order of the claimed health impacts.

  1. Peaker plants often operate during summer months when air pollution levels are highest and their emissions add to existing pollution burdens in environmental justice communities and contribute to adverse health effects in those communities from air pollution.

There is a well-established peaking power plant problem.  In the first place, in order to provide electricity to everyone who needs it when they need it the New York Independent System Operator (NYISO) has to balance power availability with the load on the system.  NYISO is responsible not only for the real-time deliver of power but also for reliability planning.  If the load did not vary this would be much less difficult but the reality is that load varies diurnally and seasonally.  Most important is meeting demand when loads are highest in the summer and winter when it is necessary to provide electricity to maintain the health and well-being of customers. Ultimately the problem boils down to the fact that there are short periods when so much load is needed that there are units dedicated by intent or circumstances to provide just that load during the year. 

 The second driver for this issue is that the hot and humid conditions that cause the high energy use in the summer peak are also the conditions conducive to ozone formation and higher levels of PM2.5.  New York State has been working on the issue of emissions and air quality on high electric demand days specifically since at least 2006.  While there is an undeniable link between high energy demand and the high emissions that create peak ozone levels there also should be an over-riding requirement to keep the power on when it is needed most.

 The argument made here is that these peaking plants are dis-proportionally dis-advantaging the neighboring environmental justice communities.  However, the health impacts that they cite are from inhalable particulates and ozone.  Both of the these are secondary pollutants not directly emitted by power plants.  It takes time for inhalable particulates and ozone to be created by emissions from the plants and in that time the pollution has been transported away from neighboring communities.  It is simply incorrect to ascribe health impacts from these pollutants to neighborhood power plants.  Finally, claiming neighborhood impacts at Oswego is absurd because the pollutants are emitted from stacks that are 700 feet high.  It is virtually impossible for any pollutants to reach the ground in the adjacent neighborhood.

  1. The owners and operators of peaker plants have received billions of dollars in capacity payments from ratepayers over the last decade to subsidize operation of their plants, even though the plants primarily operate during peak load periods.

One of the reasons that there were blackouts in Texas during a period of peak load was that Texas does not pay for capacity.  Simply put, the politicians in Texas decided that subsidizing power plants to run when you need them most was not necessary.  New York Senators apparently agree that a power plant that makes money by providing blackout protection for consumers is such a bad thing that they are willing to risk it in New York. However, the fact that these units are paid to only operate during peak load periods is an insurance feature not a flaw.

  1. Fossil fuel-burning peaker plants can be replaced with renewable energy systems that will eliminate or significantly reduce air pollution impacts to environmental justice communities from peaker plant operations.

Renewable advocates rarely acknowledge that there are inherent advantages to fossil fuels.  At the top of the list is the fact that fossil-fired power plants can be dispatched when needed.  The Oswego power plant burns oil that is stored on-site and can operate throughout any peak load period.  Many of the other plants targeted by this legislation also store oil on-site for precisely the same reason.  In order to replace these units with renewable energy it is not enough to just build wind turbines and solar panels but enough storage has to be provided for at least a couple of days of operation.

 The 2030 Climate Leadership and Community Protection Act (CLCPA) energy storage target is 3000 MW.  Conspicuous by its absence is how many hours are associated with that figure but my guess is they are talking about 4 hours so the total is 12,000 MWh.  In order to replace just the Oswego power plant’s capability to run for say 36 hours with renewable and storage would take over half the 2030 power storage capacity goal but over five times as much energy would be needed.  In order to replace the Oswego’s peaking capability energy storage and renewable power has to be dedicated to that purpose.  It does not make economic sense to invest in that much renewable power and energy storage only to be used less than 10% of the time.

 NYISO’s reliability planning process determines if there are sufficient resources when the probability of an unplanned disconnection of firm load (loss of load expectation, or “LOLE”) is equal to or less than the standard of once in every 10 years or 0.1 events per year.”  In Texas there were seven cold snaps similar to the one that caused the outages in the last 60 years so the probability is 0.13 events per year.  The peaking power plants targeted by this legislation are part of the solution to LOLE reliability planning.  It is not clear to me what combination of solar, wind, and energy storages would be required to meet replace the peaking power plants in a multi-day winter wind lull but I am sure that the numbers would be extraordinary.  Presumably at some time the CLCPA implementation process will address this but at this time no one knows.

  1. Replacement of fossil fuel-burning peaker plants with renewable energy systems is in the public interest, will save millions of dollars in environmental and human health-related damages, will promote environmental justice and will assist in meeting the greenhouse gas emission reduction and energy storage goals of the climate leadership and community protection act.

The public interest is affordable and reliable electricity.  State agencies have not identified the renewable resources necessary to replace all fossil-fired generation by 2040 and meet current reliability standards so it is presumptuous of the New York Senate to presume that their mandated solution is possible in the time frame in this law.  The millions of dollars in damages claims is not substantiated and given that the emissions from units that run so little are small it is unlikely.  The purported effect on environmental justice communities is based on air quality impacts from inhalable particulates and ozone that are not direct impacts on those communities.  It is unclear why another law is needed to assist in meeting the CLCPA and logic suggests that it is likely that a better choice to let the CLCPA play out than to add a complicating factor.


Besides the facts that the premise is wrong, the rationale is incorrect, and the solution is risky, there are a couple of implementation concerns.  Peaking power plants are a critical resource during peak load periods.  However, definition 8 in § 19-1303 says “’Replace’ or ‘replacement’ means the construction and operation of by the construction and operation of a renewable energy system, battery or energy storage, or transmission and distribution infrastructure that enables the provision of the equivalent maximum annual power output achieved by the replaceable peaker”.  Power output is the capacity in MW and the peak load need is the energy in MWh.  The critical parameter for peak load is energy output.  This language directly benefits renewable developers who cannot provide dispatchable energy but it puts New York at risk of a blackout similar to Texas because renewables may not be available to provide all the energy needed during peak loads whatever their maximum annual power output is.

I am also concerned about the language requiring a replaceable peaker plant owner or operator to include a proposed strategy to “replace the plant with renewable energy systems or battery storage or a combination thereof” in an operating permit.  Developing such a strategy requires a major investment in time and money that could well be beyond the capabilities of an owner or operator.  My suspicion is that in such a case the independent power producer will simply surrender the permit and walk away from the state.

The bill authors have not identified the affected units nor has any study been done that shows proposed replacement solutions can keep the system reliable.  I could find no list of units to be affected by this bill. It only seems decent that the authors should identify the units, provide notice to the affected generators and host communities. What about the real property tax implications?  The existing fossil generating stations pay taxes but replacement renewables won’t by located in the same communities nor will they pay taxes at a rate equivalent to fossil plant.


This is deeply flawed legislation.  The premise is wrong because peaking power plants are not inherently bad because they provide critical support to the electric system when needed most.  The rationale that these peaking power plants are directly affecting air quality in adjacent environmental justice neighborhoods is incorrect because the health impacts are claimed from secondary pollutants that do not form before they are transported away from the neighborhood.  Replacing all the peaking plants covered by this law in the time frame mandated is extremely risky because the technology available today is not up to the task as shown in the Power Generation Advisory Panel emphasis on research and development.

Given that there was a power outage disaster in Texas less than a month ago I am extremely disappointed that the New York Senate as taken it upon themselves to dictate energy policy to the electric sector.  Although the complete story of what happened in Texas is unknown at this time, it is clear that extremely cold weather caused a major peak load event.  Past New York energy policy has emphasized the need for diverse set of dispatchable resources to prevent reliability problems in these situations.  This legislation risks reliability in its mandate for resources that are not diverse and technology that have not been tested at the scale needed.


Climate Leadership and Community Protection Act – NYISO Resilience Study and the Texas Energy Debacle: New York Worst Case

I recently wrote that the energy debacle that occurred in Texas is unlikely in New York today because of market and system differences but if the Climate Leadership and Community Protection Act (CLCPA) is implemented incorrectly something similar is inevitable.  Last fall the Analysis Group completed their Climate Change Impact and Resilience Study (“Resilience Study”) for the New York Independent System Operator (NYISO).    The study evaluated different resource scenarios that meet the 2040 CLCPA zero-emissions mandate for various weather and load scenarios.  The findings do not portend well for New York’s energy future and raise important questions for New York’s planning.  In this first post discussing the Resilience Study findings relative to the Texas Energy Debacle I will compare New York’s future reliability problem relative to the Texas weather that caused their problems.  This is a long detailed post but will provide background for future posts on other aspects of this issue.

I have written extensively on implementation of the CLCPA closely because its implementation affects my future as a New Yorker.  I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulations, listed the scoping plan strategies, summarized some of the meetings and complained that its advocates constantly confuse weather and climate.  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.

Texas Energy Debacle

In brief, the ultimate cause of the blackouts and resulting problems in Texas was due to poor planning.  The weather in Texas during the storm was extreme but not unprecedented.  Similar cold snaps occurred in 2011, 1991, 1990, 1989, 1983, 1963, and 1961 and there were electrical outages in 2011.   Because there is no apparent trend in low daily maximum temperatures (see Tony Heller’s graph), climate change is not a factor.  This was a weather event.

Clearly the Texas electricity market failed to provide adequate resiliency for these conditions.  I agree with Becky Klein, former commissioner and chairman of the Public Utility Commission of Texas who writes that the questions that need to be considered now are:

      • Are we prepared to pay more for electricity and water to ensure higher levels of reliability?
      • And if so, how much more?
      • How can we be better prepared for “outlier” events, regardless of their probability?
      • Would it make sense to require state-wide scenario planning that includes coordinated drills that test both our operational and communication capabilities across multiple entities?

As New York transitions its electric system to one dependent upon renewables all of these questions need to be addressed.  Fortunately, the NYISO Climate Change Impact and Resilience Study lays the foundation to start to address those questions in New York.

Ultimate Problem

I have described what I believe is the ultimate problem previously.  Both E3 in their presentation to the Power Generation Advisory Panel on September 16 and the Analysis Group  in their September 10, 2020  presentation to NYISO explained that in order to meet the CLCPA emissions reduction goals that a resource category that provides firm, dispatchable and zero-emissions generation is needed.  E3 gives examples such as “such as bioenergy, synthesized fuels such as hydrogen, hydropower, carbon capture and sequestration, and nuclear generation” but the Analysis Group avoids being specific.  The  International Energy Agency (IEA) recently published “Special Report on Clean Energy Innovation” that classified the technology readiness level of the technologies that could possibly be both dispatchable without GHG emissions.  The bottom line is that none of the E3 examples of firm, dispatchable and zero-emissions technologies are close to being ready for adoption except nuclear and hydro which I believe are unlikely to provide any meaningful support for New York.

Climate Change Impact and Resilience Study

According to the report:

“In 2020, NYISO contracted with Analysis Group (AG) to complete this Climate Change Phase II Study (“Phase II Study”). The Phase II Study is designed to review the potential impacts on power system reliability of the (1) the electricity demand projections for 2040 developed in the preceding Climate Change Phase I Study, and (2) potential impacts on system load and resource availability associated with the impact of climate change on the power system in New York (“climate disruptions”).The climate disruptions considered include items that could potentially occur or intensify with a changing climate and that affect power system reliability, such as more frequent and severe storms, extended extreme temperature events (e.g., heat waves and cold snaps), and other meteorological events (e.g., wind lulls, droughts, and ice storms).”

As the Texas experience shows, it is necessary to address potential impacts of extreme weather on power system reliability.  However, in my opinion, there is a significant weakness in the Analysis Group’s team because it does not include a meteorologist.  If one was on the team this language probably would have been modified to make the point that natural variability in weather events such as extended extreme temperature events (e.g., heat waves and cold snaps), and other meteorological events (e.g., wind lulls, droughts, and ice storms) currently is much larger than any climate change induced variations.  As a result, I refer to this report as the Resilience Study rather than the Climate Study.  The report continually refers to climate disruptions which in reality are actually extreme weather events but that does not detract from the value of the analysis itself.

I refer you to the report for a detailed description of the Analysis Group modeling approach summarized in their Figure ES-1.  As input they used two long-term hourly zonal-level load forecasts that reflect state policy goals and climate effects developed by ITRON.  The Analysis Group energy balance model analyzed two load scenarios: a reference case and the CLCPA case that includes the expected increases in load due to heating and transportation electrification.  Four sets of generating system resources were considered.  The Resilience Study estimated what they thought would be needed to meet the load requirements and they also include the NYISO Grid in Transition estimates.  A reference scenario and an expected resource scenario for both were evaluated.  They considered weather disruptions including heat waves, cold snaps, wind lulls, wind storm disruptions, ice storms, and droughts.  The result was a set of 72 analyses projecting the amount of each type of energy resource needed and the potential for resource inadequacy for a 30-day evaluation period.

Last October, soon after the Climate Change Phase II study came out, I prepared a post evaluating whether it adequately addressed the weather disruptions.  Unfortunately, I don’t think it does.  The evaluation period was too short and importantly they did not evaluate extreme wind and solar availability over the same periods.  I also believe that monitoring data from a network with more spatial resolution must be done to adequately represent the effect of lake-effect clouds and precipitation.  Nonetheless the analysis represents a good start addressing the problem of extreme weather.

NY LOLE planning

According to the 2020 NYISO Reliability Needs Assessment: “The New York system is deemed to have sufficient resources if the probability of an unplanned disconnection of firm load (loss of load expectation, or “LOLE”) is equal to or less than the standard of once in every 10 years or 0.1 events per year.”  The reliability planning process starts with the Reliability Needs Assessment (RNA) followed by the Comprehensive Reliability Plan.  I will only discuss the RNA here.  It evaluates “the reliability of the New York bulk electric grid through 2030, considering forecasts of peak power demand, planned upgrades to the transmission system, and changes to the generation mix over the next ten years.”  A base case “includes projected impacts driven by limitations on generator emissions”.  Different scenarios “include an in-depth look at certain policy goals from the CLCPA” and “reliability risks associated with the cumulative impact of environmental laws and regulations”.

The RNA document explains that:

“Resource adequacy is the ability of the electric system to supply the aggregate electrical demand and energy requirements of the customers at all times, taking into account scheduled and reasonably expected unscheduled outages of system elements. Resource adequacy considers the transmission systems, generation resources, and other capacity resources, such as demand response. The NYISO performs resource adequacy assessments on a probabilistic basis to capture the random natures of system element outages. If a system has sufficient transmission and generation, the probability of an unplanned disconnection of firm load is equal to or less than the system’s standard, which is expressed as a loss of load expectation (LOLE).  The New York State bulk power system is planned to meet an LOLE that, at any given point in time, is less than or equal to an involuntary firm load disconnection that is not more frequent than once in every 10 years, or 0.1 events per year. This requirement forms the basis of New York’s Installed Reserve Margin (IRM) requirement and is analyzed on a statewide basis.”

“If Reliability Needs are identified, various amounts and locations of compensatory MW required for the NYCA to satisfy those needs are determined to translate the criteria violations to understandable quantities. Compensatory MW amounts are determined by adding generic capacity resources to NYISO zones to effectively satisfy the needs. The compensatory MW amounts and locations are based on a review of binding transmission constraints and zonal LOLE determinations in an iterative process to determine various combinations that will result in reliability criteria being met. These additions are used to estimate the amount of resources generally needed to satisfy Reliability Needs. The compensatory MW additions are not intended to represent specific proposed solutions. Resource needs could potentially be met by other combinations of resources in other areas including generation, transmission and demand response measures.”

The relevant question after the Texas energy debacle is whether this planning process adequately protects New Yorkers from a similar blackout.

Climate Change Impact and Resilience Study Loss of Load Occurrences

The Resilience Study includes a generic resource intended to “identify the attributes of any additional resources that may be needed to avoid or reduce Loss of Load Occurrences (LOLO).  This is similar to the NYISO Loss of Load Event but does not imply a specific frequency of occurrence like the LOLO.  The Analysis Group labels these resources as dispatchable and emissions‐free resources (“DE Resources”).  They “cover any circumstances where the resource sets are insufficient to meet identified demand, and to evaluate what attributes such a resource must have to help meet reliability needs”.  These are the resources described in the Ultimate Problem section above.

The Resilience Study identified LOLO periods in 26 of the 72 scenarios evaluated.  Overall, there were 414 hours with a loss of load identified totaling 331,065 MWh.  Fourteen periods were associated with extreme weather events such as hurricanes, wind storms or icing while the other twelve were associated with a scarcity of renewable wind and hydro resources.  Note that there was no specific scenario for a solar energy lull analogous to the wind energy lulls evaluated.

The extreme weather events are outliers.  Over the 14 periods, 323 hours totaling 258,504 MWh were identified as having loss of load.  Recall that Becky Klein wrote that one of the questions that need to be considered now is “How can we be better prepared for “outlier” events, regardless of their probability?”  The key question is probability of occurrence for these events and a logical first step would be to determine how often these events happen.  It is also important to determine what could be done to reduce impacts.  Recall that the NYISO RNA process determines the various amounts and locations of compensatory MW required to reduce the probability of these events.  It is not clear to me that any amount of additional resources could mitigate these impacts.  Preparation for the outliers would probably focus on hardening infrastructure which is beyond the scope of this article.

On the other hand, the scarce renewable energy resources scenarios can be addressed by specifying compensatory MW requirements.  For the twelve periods identified there were 91 hours totaling 72,561 MWh.  Nine of the periods were associated with periods of calm winds and three with droughts.  I agree with E3 who has highlighted the critical period of concern to be a multi-day winter period of light winds.

For example, consider scenario 13 which considers CLCPA conditions during a state-wide wind lull in the winter with the set of resources chosen to handle the CLCPA target of zero emissions.   Over the 30 day analysis period the Resilience Study estimates that 9,043,988 MWh will be generated by 35,200 MW of land-based wind, 5,288,985 MWH will be generated by 21,063 MW of offshore wind, 503,859 MWh will be generated by 10,878 MW of behind-the-meter solar, 1,951,742 MWh will be generated by 39,262 MW of utility-scale grid solar, 2,027,789 MWh will be generated by 4,486 MW of hydro pondage and run of the river hydro, 2,422,224 MWh will be generated by 4,364 MW of nuclear, 2,023,200 MWh will be imported, 98,672 MWh will be generated by 1,170 MW of pumped storage, 800,462 MWh will be provided by 15,600 MW of battery energy storage over 189 hours, demand response will displace 3,412 MW and 566,429 MWh over 276 hours, and the 32,317 MW of the DE resource will generate 3,653,404 MWh over 278 hours.  Over the 30 days 28,380754 MWh will be generated but even these resources will be unable to prevent LOLO totaling 13 hours and 14,404 MWh.

I believe it would be more appropriate for future analyses to consider shorter time periods in greater detail.  In this case consider the seven-day period from hour 192 to hour 360.  This is the critical period where the most DE resources are required and when the hours with load loss occurred.  I think that the uncolored area under the load curve around hour 264 represents the load loss period.  Note that battery storage was used up early in the critical period.  In order to fully replace all the DE resources MWh would take an extraordinary amount of additional energy storage.  Clearly the big problem is a lack of land-based and offshore wind.  In the winter, solar is just not going to be able to cover the loss of wind across the state.  Furthermore, it is not clear to me that the solar energy output reflects snow cover impacts.  It appears that no amount of over-building of wind and solar coupled with battery energy storage is going to be able to solve this renewable resource problem.

The Resilience Study analysis reinforces the fact that the multi-day winter wind lull is a critical period for reliability. In my comments on the resource adequacy hearing and elsewhere I have argued that actual short-term meteorological data from the NYS Mesonet system must be used to correctly characterize the renewable resource availability for New York in general and in areas downwind of the Great Lakes in particular. This type of evaluation is necessary to completely characterize the resource availability during the multi-day winter wind lull.  I believe that using those data in conjunction with a meteorological evaluation of the weather systems that cause these conditions could also develop a frequency of occurrence distribution that could be used to extend the Loss of Load Occurrence estimates to Loss of Load Expectation projections.

Independent System Operator – New England (ISO-NE) recently had an analysis done, Analysis of Stochastic Dataset for ISO-NE, that purports to provide frequency of occurrence information.  I am not comfortable that they have actually done what they thought they did.  In their analysis they used a statistical re-sampling technique that I am not sure adequately considers serial correlation and the relationships between wind and solar resource availability.  In their February 20, 2020 presentation to the ISO-NE Planning Advisory Committee, Wind and Power Time Series Modeling of ISO-NE Wind Plants, Methodology and Analysis of Results, they describe a wind mapping system that generates high-resolution mesoscale wind maps.  The report notes that “wind generation is very likely to be high during the peak load hour” and goes on to say that “this appears to be due to passing cold fronts associated with strong low-pressure systems that drive wind speeds across New England”.  In the February 2020 presentation there is a table with wind turbine power curve basics that shows a cutoff speed for low wind speeds and high wind speeds.  I am very sure that the Analysis Group cutoffs were different than the ones used in this study because there is a difference in wind output for wind storms.  While another good start I believe that this analysis also comes up short adequately characterizing the lowest renewable energy resource availability period.


The Analysis Group writes: “The variability of meteorological conditions that govern the output from wind and solar resources presents a fundamental challenge to relying on those resources to meet electricity demand.”  I agree completely.

In Texas there were seven cold snaps similar to the one that caused the outages in the last 60 years so the frequency of occurrence is 8 divided by 60 or 0.13 events per year.  New York’s LOLE standard is 0.1 events per year so the NYISO planning process is supposed to address this kind of event.  The relevant question for New York is how often do we expect a multi-day winter wind lull.  My answer to that is every year but the intensity varies.  For example, from 2/14/21:2300 until 2/15/21:1600 there were 15 of 17 hours when the wind output was less than 10% of the nameplate capacity and all of New York’s on-shore wind turbines produced a total of 765 MWh for a capacity factor of 2.6%.  This period wasn’t as intense as the Resilience Study conditions and I did not determine the duration of the wind lull but it was just a random choice.  We won’t know how often and how intense these periods are until an analysis specifically designed to evaluate New York’s renewable resource potential is completed using fine-resolution meteorological monitoring data.

As to whether New York’s reliability planning process adequately protects New Yorkers I must reserve judgement.  NYISO has the responsibility for this protection but can only guess at what the CLCPA process will propose as its resource mix.  Until that time, they cannot do the evaluation work necessary to determine future reliability so it is unfair to pass judgement.  I will note however that the Analysis Group and NYISO have identified serious challenges that must be overcome to make a reliable system that meets the CLCPA mandates.

In my opinion, those challenges will prove to be impossible to meet without a marked degradation of reliability.  Future posts will explain why I believe that to be the case.

2020 76West Clean Energy Competition Winners

Governor Cuomo announced this year’s winners of the 2020 76West Clean Energy Competition on October 19, 2020.  This post discusses the competition, its record, and this year’s awards.

I follow New York energy policy closely because its implementation affects my future as a New Yorker.  I am not sure that the reliability and affordability of the electric system can be maintained under the Cuomo administration.  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.

76West Clean Energy Competition

Before I explain what this program is really about here is the 76West website description:

“76West is an unparalleled competition focused on growing entrepreneurs and attracting resources from the U.S. and around the world to build clean energy businesses and jobs in New York State’s Southern Tier region. Administered by NYSERDA, the 76West Competition  was launched in 2016 as a $20 million four-year initiative to grow the clean energy ecosystem in the Southern Tier with funds from the Regional Greenhouse Gas Initiative and the Clean Energy Fund. Due to its significant positive impact for the region, the competition is being funded this year by Empire State Development through the Southern Tier Soaring Upstate Revitalization Initiative. The Competition supports technological and other innovation initiatives to meet New York State’s climate and decarbonization goals. “

The first question is why is there a focus on New York State’s Southern Tier region.  The Southern Tier spans eight counties along central New York’s southern border with Pennsylvania.  In 2015 the New York Department of Environmental Conservation (DEC) finalized an environmental impact statement that effectively banned hydro-fracking in New York State based on the Department of Health’s public health recommendation that the activity should not proceed in the state.  In January 2020, Cuomo announced legislation in the fiscal year 2021 executive budget to make the ban permanent and that legislation was passed later in the year.  Cuomo’s announcement notes that:

“In the wake of the ban, the clean energy ecosystem in the Southern Tier has grown rapidly over the last five years, fueled by a variety of programs and resources. New companies have sprouted in the Southern Tier with innovations in a wide variety of clean energy sectors, supporting over 4,100 jobs as of 2017. Examples of this industry density include the success of 76West Clean Energy Competition, new business like Imperium3, Sungeel, and Micatu locating in the ST, and the most recent spotlight on the region’s clean energy expertise with the 2019 Nobel Prize in Chemistry awarded to Binghamton University’s Stan Whittingham. These efforts have been bolstered by Southern Tier Soaring, the URI-winning strategic plan developed by the Southern Tier Regional Economic Development Council.”

There you have it.  The eight counties in the Southern Tier were the counties adjacent to Pennsylvania where hydrofracking was proposed before the ban.  The progressive meme is that we don’t need fossil fuels for jobs because the clean energy economy will provide jobs.  So, this program is a bone thrown out to the Southern Tier to make up for the economic benefits lost by the fracking ban.

76West Awards

Not surprisingly the awards are described in multiple places.  You can “Sign in to review information on competitors, judges and mentors, view videos and more on the 76West Competition Platform”.  There is a competition results page for each year’s winners.  I have also summarized the winners in the 76West Competition Winner Summary   According to the website description: “76West is designed to help clean energy technology startups develop in the region, get early users for their technologies, as well as further develop the community of clean tech innovators, industry experts, educators, and investors.”

Since 2016 the state has awarded five $1,000,000 prizes, seven $500,000 prizes, and sixteen $250,000 76West competition prizes for a total of $12,5000,000.  If I had the time to research this more, I would address all the winning entries but in this post I will just describe the winners in the latest year and the first year of the competition.

In 2020, Montreal based TermoAI won the $1,000,000 prize for “Optimizing and automating industrial combustion with patent-pending artificial intelligence to reduce greenhouse gas emissions and increase energy efficiency.”  While this is needed for the future system it is nothing new.  I recall companies offering similar services to Niagara Mohawk when I worked there 20 odd years ago albeit the sales pitch then was that it would reduce nitrogen oxides emissions and decrease fuel costs by improving efficiencies.  AGreatE, Inc. won a $500,000 prize for “Making renewable energy affordable and accessible by producing artificial intelligence-enabled battery-based energy storage systems.”  Energy storage is a critical need for the future energy system.  COI Energy Services, Inc. won a $500,000 prize for “Improving building energy performance and grid optimization with software-as-a-service solutions.”    Optimizing energy efficiency is another aspect of the future energy system that is needed.  Combplex won a $500,000 prize for “Creating a farming ecosystem that sequesters more greenhouse gases by eliminating pests that threaten the health of honeybee hives.”  Their web page states: “Our mission is simple. Help beekeepers, help farmers, and help pollinators to create a more resilient farming ecosystem. Not clear how this relates to clean energy.

In 2016 Micatu won a $1,00,000 prize for “optical sensor for highly accurate real-time grid monitoring.  Their web site includes a picture of their new work headquarters in Horseheads, NY so I imagine that their award facilitated that move.   Charge CCCV won a $500,000 prize for energy storage batteries with longer lifetimes to reduce costs.   They are an “intellectual property company” and “By state mandate, the company is located in designated space at Binghamton University.”  West76 awarded $250,000 prizes to Besstech for “Silicon-based electrodes to make energy storage batteries cheaper, fast-charging and more environmentally friendly”; ChromaNanoTech for “Dye which blocks invisible radiation in windows to reduce air conditioning loads”; Concertio for “Software that reduces the energy consumption of data centers”; and Global Thermostat “Captured carbon dioxide and purifies it for industrial manufacturers”  but appears to be more oriented to carbon capture technologies.  Besstech is an electrode design and engineering venture based in Albany, New York. ChromaNanoTech was founded in 2014 at the Binghamton University incubator so this prize does help the Southern Tier.  Concertio headquarters are in Manhattan but on their about page there are two references to Cornell which is located in Ithaca within the Southern Tier.  Global thermostat is also headquartered in Manhattan.

In this sampling of the 2016 and 2020 awards for the 76West competition “focused on growing entrepreneurs and attracting resources from the U.S. and around the world to build clean energy businesses and jobs in New York State’s Southern Tier region” I am not necessarily seeing that focus.  The four awards in 2020 went to three companies outside the Southern Tier in Montreal, Canada, Carlsbad, CA, and Tampa, FL.  Perhaps their proposals promised that offices would be established in the Southern Tier.  Combplex is based in the Southern Tier but trying to make a connection to the admirable goal of helping honey bees as a clean energy effort is more than a little stretch.  In 2016 Micatu won the biggest prize and has established its headquarters in the Southern Tier and their technology is needed for the grid of the future.  ChromaNanoTech is also based in the Southern Tier.  The other three 2016 winners have no obvious direct connection with the Southern Tier.


NYSERDA is responsible for the initiatives to be supported by Regional Greenhouse Gas Initiative (RGGI) auction proceeds. The RGGI Operating Plan is “designed to strategically invest across disciplines, economy wide, in a way that supports comprehensive strategies that best advance the CO2 emission reductions goals of the State”.  RGGI is ostensibly a GHG emission reduction program but emission reductions since the inception of the program are primarily due to the hydrofracking technology that New York banned than the program itself.  I have shown that the cheaper price of natural gas due to hydrofracking made natural gas a cheaper alternative than coal and oil, the only reductions due to RGGI are those from the investment of its proceeds.  At some point, however, further reductions in CO2 emissions will need to come from these kinds of investments.

The last time I reviewed the NYSERDA RGGI investments I found that none of the NYSERDA investments of RGGI auction proceeds meet the social cost of carbon criterion of a cost-effective control strategy.   I believe that New York will propose to use the Obama era social cost of carbon value which is $50 in 2019.  The Consolidated Summary of Expected Cumulative Annualized Program Benefits through 31 December 2018 table summarizes the benefits and costs. It shows that for a total of $558 million invested that the total claimed GHG savings are 1,203,781 tons for a cost benefit of $463.54 per ton reduced, almost ten times higher than the social cost of carbon.

According to the 2020 RGGI Operating Plan Amendment numbers shown in the 76West Financial Awards and NYSERDA RGGI Funding Summary, RGGI is the primary source of funding for the 76West program.  Clearly, the 76West competition does not emphasize strategies that best advance CO2 emissions reductions goals of the State.  That suggests that this competition is one of the reasons why the RGGI investments are not producing socially cost of carbon effective reductions.


Governor Cuomo has said:

“New York has made unprecedented progress in reducing its carbon footprint, while making great strides in transforming the economy into one that is cleaner, greener, stronger and more sustainable than ever before,” Governor Cuomo said “The Regional Greenhouse Gas Initiative has been an incredible success in reducing emissions throughout New York and the Northeast, while supporting thousands of jobs and billions of dollars of investments in green development projects.”

As noted above.  I have shown that the cheaper price of natural gas due to hydrofracking was the primary cause of the “unprecedented progress” in reducing New York’s carbon footprint.  Furthermore, RGGI investments have not been effective tools to reduce emissions.  These facts directly contradict Cuomo’s claims.

According to the NYSERDA October 19, 2020 press notice announcing the winners of the 76West clean energy business competition “Winning companies will spur clean energy innovation in support of Governor Cuomo’s nation-leading climate and clean energy agenda”.  Even this cursory check of the winners of the competition illustrates that the winning projects will do little to achieve the climate emission reduction goals which are the primary drive of the clean energy agenda.  If one were to try to estimate the actual CO2 reductions that might result from these winning programs relative to the awards, I am sure the cost per ton reduced would be much higher than the general numbers that I extracted previously.

The poster child for well-intentioned work but without any obvious connection to clean energy is the Combplex award for technology to track honey bee disease.  According to the Wall Street Journal, New York faces a $59 billion revenue shortfall.  In this time of clear financial crisis and the purported existential climate crisis, if funding intended to make the transition to clean energy is diverted to anything other than clear clean energy projects, then it would seem that decision makers are short changing their clean energy posturing for political gain.


NYISO Climate Change Impact Studies

The New York Independent System Operator (NYISO) manages New York’s power grid and wholesale electric markets.   That responsibility not only includes the day-to-day management but also extends to long-term planning.  As part of the latter charge NYISO commissioned two studies of climate change impacts on power system reliability in New York.  While the studies provide valuable information, I think further work is needed before we can be assured that solar and wind resources will be sufficient to meet load requirements.

I have two degrees in meteorology, am a retired certified consulting meteorologist accredited by the American Meteorology Society, have over 45 years experience as a practicing meteorologist, and have been working in the electric utility business since 1981.  The contents of this post are based on that background and experience.  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.


In order to assess the potential impacts on power system reliability in 2040 associated with system changes due to climate change and policies to mitigate its effects, NYISO contracted with ITRON and the Analysis Group. In today’s New York it is necessary to address the political presumption that the effects of climate change are being felt today so a primary goal was to address that concern.  New York’s Climate Leadership and Community Protection Act (CLCPA) has targets for decreasing greenhouse gas emissions, increasing renewable electricity production, improving energy efficiency and an aggressive schedule as I have documented in CLCPA Summary Implementation Requirements.  Both studies also addressed the effects of this climate policy on the future electric system.

Itron developed long-term energy, peak, and hourly load projections that address the potential effect of climate change and the CLCPA. According to an Itron blog post that report identified “historical weather trends across more than 20 weather stations in New York State”. That information was used to drive system and planning area load models. They noted that “complicating factors include continued growth in behind-the-meter solar generation, increasing proliferation of electric vehicles and state policy to address climate change through electrification”.  The final report included two long-term hourly zonal-level load forecasts that reflect state policy goals and climate effects.

In the second phase the Analysis Group used the Itron load forecasts to evaluate system impacts and develop a climate resiliency plan.  According to the Executive Summary in the draft Climate Change Phase II Study, the “Phase II Study is designed to review the potential impacts on power system reliability of the (1) the electricity demand projections for 2040 developed in the preceding Climate Change Phase I Study, and (2) potential impacts on system load and resource availability associated with the impact of climate change on the power system in New York (“climate disruptions”). The NYISO Electric System Planning Working Group meeting on September 10, 2020 included a presentation by the Analysis Group that gives a good overview.

Climate Change

The original intent of these projects was to consider the effects of climate change on the electric system.  Iton claims that their forecasts “reflect the potential continuation of such weather trends during the next 30 years” corresponding to the implementation period of the CLCPA 2050 target.  Analysis Group considers potential impacts of “climate disruptions” on the electric system.  However, I think their projections actually represent something else.

Contrary to popular opinion, teasing out the effect of climate change presumed to be inextricably linked to GHG concentrations from natural climatic variation is a controversial topic in the meteorological community. The Analysis Group climate disruptions “include items that could potentially occur or intensify with a changing climate and that affect power system reliability, such as more frequent and severe storms, extended extreme temperature events (e.g., heat waves and cold snaps), and other meteorological events (e.g., wind lulls, droughts, and ice storms).”  Invariably in my experience a purported climate signal is, in reality, just a weather extreme.  All these “climate disruptions” fit that bill.

Bottom line is that while both studies provide valuable information the projections represent extreme weather more as a result of natural variability than any climate effect due to global warming.  The key point is that these weather impacts have to be considered to adequately represent future load.  The fact that I consider the climate change signal small compared to natural weather variability is irrelevant for the results.

Analysis Group Renewable Resource Approach

While I applaud the results provided by the Analysis Group, I don’t think it should represent the final word on the effect of weather on wind and solar resource availability.  I will explain my problems with what they did and offer my suggestion for what is needed below.

The Analysis Group estimated what electric generating resources will be necessary to meet the projected loads predicted by Itron. The primary goal was to estimate the generating and transmission infrastructure necessary to meet the CLCPA 2040 target to eliminate the use of fossil fuels for electricity generation.  Importantly, the emphasis was on the viability of a resource mix to meet this target and they repeatedly point out that their estimate is just one of many possible pathways to the goal.  Their electric system modeling is described in a recent presentation.

The draft report explains that there are three core elements to the modeling approach.  The first element is the load forecasts from the Phase I study.  The second element is the development of resource sets for two scenarios representing the climate change impacts and inputs from another NYISO study on the grid in transition.  The starting point for the resource allocations was earlier NYISO work based on New York’s announced procurement goals.  “This resource set alone is insufficient to meet demand; thus, the analysis adds renewable generating capacity, storage capacity, transmission capability, and Dispatchable Emission-free (DE) resource capacity in quantities sufficient to meet the seasonal peak demand.”  My primary interest is the third core element: “Climate Disruption Scenarios”.

According to the final report:

 “These climate disruptions are used to define seasonal ‘cases’, which are run through the energy balance model to identify any reliability risks associated with operations under those conditions. The results of the model identify the magnitude, frequency and duration of any periods where available generation was potentially insufficient to meet load over the duration of the seasonal modeling period, or where significant storage or DE resource output is needed to supplement renewable generation.”

The report developed these extreme-weather or physical disruption events to simulate conditions that “increase demand and/or reduce or eliminate the availability of renewable resources and transmission infrastructure.”  Table 12 Description of Physical Disruption Modeling Events from the draft Phase II study lists ten types of events that could physically disrupt the electric energy generation system in 2040 when it is strongly dependent upon wind and solar resources.  I will focus on the treatment of meteorological inputs on solar and wind output for these events below.

The biggest single weather factor on load is temperature.  Heat waves and cold snaps are the primary cause of peak loads.  In this analysis the meteorological conditions for these temperature extremes were adjusted as follows:

“Heat waves are modeled using the following model adjustments:

        • Load ‐ High temp 90° F or above for seven days, with daily zonal load increase of between 0 percent and percent 18.7 percent
        • Wind Generation ‐ 20 percent decrease for seven days
        • Solar Generation ‐ use solar profile from hottest day in Y2006 for seven days
        • Transmission ‐ five percent decrease for seven days

Cold waves are modeled using the following model adjustments:

        • Load ‐ Low temp of 0° F or below for seven days, with daily zonal load increase of between 2.3 percent and percent 25.6 percent.
        • Solar Generation ‐ Use solar profile from coldest day in Y2006 for seven days”

Three wind “lulls” physical disruption events were evaluated: just Upstate, just Off-shore and state-wide.  To evaluate potential variability, Analysis Group evaluated historical National Renewable Energy Laboratory (NREL) daily wind data from 2007 to 2012 to estimate the wind generation output.  Three sites representing upstate and offshore production were used: Niagara, Plattsburgh, and the offshore Empire Wind Zone.  The analysis found 19 wind lulls in the summer and only three in the winter.  In order to evaluate the effects on loads they adjusted the high load periods developed in Phase I as follows:

“Summer wind lulls are modeled using the following model adjustments:

          • Wind Generation ‐ 15 percent Average Capacity Factor in all Zones for 12 days
          • Wind Lull overlaps the 12‐day period with highest load

Winter wind lulls are modeled using the following model adjustments:

          • Wind Generation ‐ 25 percent Average Capacity Factor in all Zones for seven days
          • Wind Lull overlaps the seven‐day period with highest load”

I am not going to spend much time commenting on the remaining five disruptions considered.  The analysis considered four storm events: hurricane/coastal wind storm, severe wind storm upstate, severe wind storm offshore, and an icing event.  In all the cases they simply made assumptions about how the load, wind and solar resources would be affected and times for recovery.  The final disruption was a drought and that was assumed to reduce hydro output 50% for 30 days.


My primary concern as a meteorologist is the availability of renewable energy resources.  The question is just how much wind and solar energy is potentially available every hour.

According to the Analysis Group final report

“The generation profile, in terms of hourly capacity factors, assumed for the solar units are based on 2006 data from the NREL Solar Power database using 62 simulated solar farm sites across New York State. Two Zones did not have solar farm data. For Zone D BTM solar, a simple average of bordering Zones F and E was used. For Zone K utility solar, the BTM solar data from Zone K was uprated by the average ratio of utility to BTM solar NYCA‐wide.  The hourly capacity factors assumed for the wind units are based on 2009 data at simulated 100 meter turbine height from the NREL’s Wind Toolkit Database, using 721 weather sites in NY. A summary of renewable resource capacity factors by season is listed in Table 6. As shown, solar capacity factors are higher on average in the summer modeling period than in the winter, and wind capacity factors are higher on average in the winter than in the summer.”

The NREL Solar Power database consists of one year (2006) of 5-minute solar power and hourly day-ahead forecasts for approximately 6,000 simulated PV plants including 62 in New York.  NREL generated the 5-minute data set using the Sub-Hour Irradiance Algorithm that produces global horizontal irradiance (GHI) values.  The sub-hour algorithm produces “coherent sub-hour datasets that span distances ranging from 10 km to 4,000 km”. The algorithm “generates synthetic GHI values at an interval of one minute, for a specific location, using SUNY/Clean Power Research, satellite-derived, hourly irradiance values for the nearest grid cell to that location and grid cells within 40 km”.   Combining satellite cloud data and a probability distribution it estimates one of five cloud classifications which are used to generate the solar irradiance value.

In my comments on the resource adequacy hearing and elsewhere I have argued that actual short-term meteorological data must be used to correctly characterize the renewable resource availability for New York in general and in areas downwind of the Great Lakes in particular. This is because the lakes create meso-scale features, most notably lake-effect precipitation and clouds, that can affect solar resources many miles from the lake shore. It is important that the solar resources be evaluated based on geographically representative short-term data and I do not believe that the NREL approach adequately addresses this concern.

On the other hand, their approach for wind data is acceptable.  They have more stations included and wind speed fields are generally well connected as opposed to discontinuous lake-effect clouds.  As a result, the data used are adequately representative.  However, there is a problem with the Analysis Group physical disruptions analysis.  They only looked at light wind disruption of wind energy output.  Because wind turbines have a high wind speed cutoff there could also be reductions if the winds are too fast.

Finally, there is a major flaw in the approach.  Analysis Group makes assumptions about the effects on wind and solar output for each physical disruption on its own.  In reality a study that considers the joint distribution of wind and solar energy impacts from weather events is needed.  This isn’t even possible using the NREL data sets they used because they are for different years.

I did my own analyses of the renewable resource availability for two short periods using observed data for summer peak energy storage requirements and winter peak energy storage requirements. My guesses for the generating resources were extremely crude but I think the approach should be the next step check on the feasibility of renewable resource dependency.  In particular, I used historical meteorological data and estimated wind and solar output relative to observed load for the same time periods.

When I started my analysis, I expected that the winter observed peak load would occur during very cold weather associated with a slowly moving high pressure system that originated in the cold northern plains large enough to cover the entire northeastern US.  The resulting multi-day period of clear skies, light winds, and inherent cold temperatures would result in very high energy demand for heating at the same time the wind resource was weak.  In my example high load period in early January 2018 conditions were very different.  Weather maps for this period show (January 2018 Weather Maps) a relatively small high-pressure system in the central US on January 2 that moved east ahead of a storm system on January 3.  The high pressure was strong enough over the New York offshore wind region that winds were less than 3.5 m/s for five hours on January 3.  However, the storm system moved eastward and re-developed into a strong storm just off the coast on January 4 with an eleven-hour period of greater than 25 m/s wind speed 13 hours after the light wind period ended.  By January 5 the storm had raced northeast to the Canadian Maritimes but was pumping cold air back across New York State.

This period shows why actual data must be analyzed in more detail by New York State to determine whether the CLCPA requirements endanger fuel and energy security.  The actual solar irradiance irrespective of cloudiness was low in this period because it was near the winter solstice.  I assumed that the wind turbine low speed cutoff was 3.5 m/s and the high speed cutoff was 25 m/s.  If the assumptions I used for no wind power due to light winds and strong winds are correct then there will be 16 hours of no wind power in a 29-hour period during the coldest extended duration cold weather event that the Analysis Group identified after analyzing 25 years of data.  Furthermore, this period also overlaps fourth worst 3-day cold snap.


The Itron Phase I and Analysis Group Phase II climate change studies provide valuable results and address my worries about the meteorological impacts on renewable energy resources.  However, I don’t think they go far enough to answer my fundamental concern that wind and solar energy might not be sufficient to power the state during the winter peak.

In my comments on the resource adequacy hearing and elsewhere I have argued that actual short-term meteorological data must be used to correctly characterize the renewable resource availability for New York in general and in areas downwind of the Great Lakes in particular. This is because the lakes create meso-scale features, most notably lake-effect snow and clouds, that can affect solar resources many miles from the lake shore.  In my opinion as a meteorologist living downwind of Lake Ontario, I don’t think the output from any cloud modeling approach has enough resolution to adequately simulate lake-effect clouds.  Therefore, the solar and wind resources should be evaluated using geographically representative short-term data so that site-specific temporal effects can be included.

I strongly recommend that meteorological data available from the NYS Mesonet meteorological system be used to determine the availability of wind and solar energy over as long a period as is available. The NYS Mesonet is a network of 126 weather observing sites across New York State so it can provide representative data for this kind of analysis.  If historical meteorological data are used to estimate solar and wind output against the observed load, suitably adjusted for climate and climate policy, then it will be a much better test than using the assumptions made by the Analysis Group to estimate how the meteorology might affect renewable output.

Climate Leadership and Community Protection Act Kick-Start the Economy

On July 18, 2019, Governor Cuomo signed into law the Climate Leadership and Community Protection Act (CLCPA).  It is among the most ambitious climate laws in the world and requires New York to reduce economy-wide greenhouse gas emissions 40 percent by 2030 and no less than 85 percent by 2050 from 1990 levels. This post looks at claims that using the green energy projects needed to meet the CLCPA goals will get the economy moving after the COVID pandemic.

I am following the implementation of the Climate Act closely because its implementation affects my future as a New Yorker.  Given the cost impacts for other jurisdictions that have implemented renewable energy resources to meet targets at much less stringent levels, I am convinced that the costs in New York will be enormous and my analyses have supported that concern.  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.

Problems with a Green Energy Kick-Start

Advocates for the CLCPA claim that we should use clean energy projects to get the economy moving again.  For example, at the August 24, 2020 Climate Action Council meeting Co-Chair Doreen Harris said this summer’s large-scale renewable project solicitations will kick-start the economy.  In this post I evaluate Gail Tverberg’s post “Why a Great Reset Based on Green Energy Isn’t Possible” at her blog Our Finite World with respect to those claims.

Ms. Tverberg gives ten reasons why re-starting the economy after the Covid pandemic is not simply like resetting your computer.  She explains some of the misunderstandings that “lead people to believe that the world economy can move to a Green Energy future”.  I encourage readers to read her post. Despite her emphasis on the world’s economy there are important lessons for New York.

Her first point is that the “The economy isn’t really like a computer that can be switched on and off; it is more comparable to a human body that is dead, once it is switched off.”  Ms. Tverberg argues that the economy and energy system are inextricably interconnected.  She explains that the economy is only able to “grow” because of energy consumption.  As resources change businesses change.  A key point is that as energy sources are taken away systems like the economy fail quickly.  While in this instance the economic collapse was not because of energy input it still cannot simply be turned back on.

Tverberg’s blog originally explored how oil limits affect the economy but, in my opinion, oil is only a surrogate for energy.  In the “Getting Started” section on her blog she explains how limits to minerals and energy sources should be incorporated into economic modeling.  This is related to her second point “Economic growth has a definite pattern to it, rather than simply increasing without limit”.  Of particular interest to New York is that one of the economic limits ignored by economic modelers is “an energy supply that becomes excessively expensive to produce”.  We are still waiting for an estimate for the cost of the CLCPA but experience elsewhere does not bode well.

Her post addresses the world’s economy but her third issue “Commodity prices behave differently at different stages of the economic cycle. During the second half of the economic cycle, it becomes difficult to keep commodity prices high enough for producers”, should be a direct warning for New York.  In particular, we are waiting for the Climate Action Council to develop their scoping plan that will include an energy plan for New York.  We can only guess at how many wind turbines, solar panels, and energy storage systems will be needed when heating and transportation are electrified.  Given that energy storage is expensive, one cost minimization approach is to over-build wind and solar to minimize the periods when a lot of energy storage is needed.  The peak demand periods occur rarely but they are also the most impactful – think the coldest and hottest periods.  However, if you over-build, the electricity commodity price will be very low most of the time when solar and wind output is greater than the load needed.  Tverberg explains that too low oil prices make it more difficult for oil producers to survive and this will also be a likely problem for New York’s energy producers.

Her next point specifically addresses coal and oil prices.  She is concerned that the low prices since mid-2008 seem to be leading to both peak crude oil and peak coal.  In both cases she claims that investments in new oil wells and unprofitable coal mines are not occurring.  Consequently, there will be less energy available for the economy.

Tverberg believes that economic “modelers missed the fact that fossil fuel extraction would disappear because of low prices, leaving nearly all reserves and other resources in the ground”.   Importantly she points out that these “modelers instead assumed that renewables would always be an extension of a fossil fuel-powered system”.  The following quote is directly applicable to New York’s CLCPA:

“Thus, modelers looking at Energy Return on Energy Invested (EROI) for wind and for solar assumed that they would always be used inside of a fossil fuel powered system that could provide heavily subsidized balancing for their intermittent output. They made calculations as if intermittent electricity is equivalent to electricity that can be controlled to provide electricity when it is needed. Their calculations seemed to suggest that making wind and solar would be useful. The thing that was overlooked was that this was only possible within a system where other fuels would provide balancing at a very low cost.”

The CLCPA assumes that political will is sufficient to over-come this problem but no one has shown how they plan to do it.

Tverberg makes the same point that I have been making that her concerns apply to other aspects of the economy: “The same issue of low demand leading to low prices affects commodities of all kinds. As a result, many of the future resources that modelers count on, and that companies depend upon as the basis for borrowing, are unlikely to really be available.”  If New York continues down this path, then our only hope is that jurisdictions outside of New York won’t, so that future resources will be available elsewhere.

 The following two issues addressed by Tverberg reveal fundamental flaws in the CLCPA.  First, she notes that “On a stand-alone basis, intermittent renewables have very limited usefulness. Their true value is close to zero.”  Recall that the CLCPA plans to replace almost all fossil fuels with intermittent renewables.  I am sure she would agree with me that the CLCPA will likely end badly.

 I could not agree more with the second applicable issue: “The true cost of wind and solar has been hidden from everyone, using subsidies whose total cost is hard to determine.”  A common trope is that wind and solar are cheaper but those comparisons always include the cost of construction and exclude the costs to make the intermittent and diffuse renewable power available when and where it is needed.  When those costs are included wind and solar are far more expensive.  If subsidies are needed to make intermittent renewable viable then how can New York afford to maintain the subsidies indefinitely?  She notes that the “ability to subsidize a high cost, unreliable electricity system is disappearing.”

 Tverberg points out that “Wind, solar, and hydroelectric today only comprise a little under 10% of the world’s energy supply” so we have a long way to go to reach a “green” energy system.   According to the New York Independent System Operator wind, solar and hydroelectric in New York totaled 25.8% of New York’s energy supply mostly because New York is in the unique geographical position to get 22.4% from hydro primarily at Niagara Falls and the St. Lawrence River.  In my opinion the hydro capability for New York is tapped out so future renewables will have to come from wind and solar.  Additionally, she makes the point that None of these three energy types is suited to producing food. Oil is currently used for tilling fields, making herbicides and pesticides, and transporting refrigerated crops to market.”

 I also agree strongly with Tverberg’s final consideration: “Few people understand how important energy supply is for giving humans control over other species and pathogens.”  She ends that section withWe are dealing with COVID-19 now. Today’s hospitals are only possible thanks to a modern mix of energy supply. Drugs are very often made using oil. Personal protective equipment is made in factories around the world and shipped to where it is used, generally using oil for transport.”


Tverberg concludes:

“We do indeed appear to be headed for a Great Reset. There is little chance that Green Energy can play more than a small role, however. Leaders are often confused because of the erroneous modeling that has been done. Given that the world’s oil and coal supply seem to be declining in the near term, the chance that fossil fuel production will ever rise as high as assumptions made in the IPCC reports seems very slim.”

I conclude that two of the concerns raised in her article are fundamental flaws in the CLCPA. She explains that intermittent renewables have a true value close to zero and that the total cost of the subsidies needed to support wind and solar are hidden and hard to determine.  The CLCPA mandates reliance on intermittent renewables which will inevitably eventually cause problems.  I also believe that those flaws undermine the concept that the technologies will kickstart the economy.  That can only appear to work until the subsidy money runs out.  At a time when there isn’t enough money for basic services throwing money away on intermittent renewables is sheer folly.

Media Coverage of Clean Energy

I had other plans for today but I have to post on this topic.  I came across two separate articles that stated that the costs of renewables are cheaper than power from existing alternatives which reminded me that I have to do a post on that topic.  However, the thing that prompted this post was buried at the bottom of the Christian Science Monitor article Power pivot: What happens in states where wind dethrones King Coal?


In particular at the bottom of article was the statement: “This story was produced with support from an Energy Foundation grant to cover the environment.”  That link leads to a June 29, 2018 page that notes that “the Energy Foundation has given a grant to support the Monitor’s distinctive approach to climate change coverage”.  It goes on to say:

The Monitor believes the solution to climate change doesn’t come from speaking more loudly or citing even more peer-reviewed science, but from recognizing why people come to climate change from such vastly different perspectives – and meeting them where they are. Changing minds to find paths forward starts with a deep commitment to humanity and respect, not from frustrated finger-pointing.

That perspective has drawn the attention of some philanthropists interested in supporting media outlets bringing light to this divisive topic. The Monitor’s science desk is the proud recipient of a special grant from the Energy Foundation, a philanthropic organization dedicated to “serving the public interest by helping to build a strong, clean energy economy.” You can read more about the Energy Foundation here. These funds are specifically to bolster the Monitor’s approach to coverage of climate, energy, and the environment during the coming year.

Presumably, the grant was extended to continue support since it has longer than a year since this description appeared and the August 21, 2020 publication of Power pivot: What happens in states where wind dethrones King Coal?

Energy Foundation

I had never heard of the Energy Foundation.  Their mission statement makes their motivation clear: “Our mission is to secure a clean and equitable energy future to tackle the climate crisis.”

The following is their vision statement:

We envision a healthy, safe, equitable economy powered by clean energy. We believe a thriving clean energy economy can create sustainable opportunities, spur innovation, and protect our climate—for today and future generations.

Energy Foundation supports education and analysis to promote non-partisan policy solutions that advance renewable energy and energy efficiency while opening doors to greater innovation and productivity—growing the economy with dramatically less pollution. For nearly 30 years, Energy Foundation has supported grantees to help educate policymakers and the general public about the benefits of a clean energy economy. Our grantees include business, health, environmental, labor, equity, community, faith, and consumer groups, as well as policy experts, think tanks, universities, and more.

We are a complex, multi-site, multicultural nonprofit organization with big plans for the future. Under the leadership of our CEO, Energy Foundation has embarked on a major strategy refresh, a prioritized commitment to Diversity, Equity and Inclusion (DEI), and rapid geographic expansion.

Our comprehensive approach advances energy efficiency and renewable energy in the power, transportation, and buildings sectors. Our programs focus on developing innovative policies and campaigns to help propel clean energy development in these sectors. The Venues team is a cross-disciplinary team of policy, communications, and campaign experts dedicated to advancing strong state and regional climate and clean energy policies. The Policy team works to deliver strategy and network support services to our issue-focused grantees and funding partners. And the Strategic Communications team develops powerful narrative and communications strategies designed to build support for our work regionally and nationwide.

Energy Foundation’s founding office is in San Francisco, CA, with regional offices in Raleigh, NC; Chicago, IL; Washington, DC; and Las Vegas, NV.

Energy Foundation funds do not support legislative lobbying or electoral activities.

The Energy Foundation is not a small organization courageously fighting the noble cause against “Big Oil”.  Their 2017 IRS Form 990 claims total revenues in 2016 of $118.9 million and $110.2 million in 2017; total expenses of $113.6 million in 2016 and $114.1 million in 2017; and net assets of $62.4 million at the close of 2017.  The Form 990 is worth a read if only to see the large number of organizations that receive grants to “promote education and analysis” to support a clean energy future.  I was surprised to see universities among the grantees –           three California state universities received on the order of $2 million alone.  Missing from their web page is any description of who funds the Energy Foundation itself.


I wrote this post because this particular quote caught my eye: “We’ve reached a point where it is now cheaper to build and operate a wind farm or solar plant than it is to operate a coal plant,” says Joe Daniel, senior energy analyst at the Union of Concerned Scientists in Washington. “And that trend is going to continue.”  I see that often and get exasperated every time I see it because, like most people, I don’t care what it costs to build a power plant.  The only thing I care about is how much it costs me to get electricity when and where I need it.  When those considerations are added to the costs of any renewable source of electricity the price sky rockets.

I have long thought that any journalist that does not caveat such a statement either lacks understanding in general or does not understand the energy system well enough.  After finding out that there is a foundation that provides funding to news organizations I have to add a less flattering reason for not providing the full explanation.  The Christian Science Monitor has a motivated reason to continue to receive funding from an organization dedicated to “serving the public interest by helping to build a strong, clean energy economy.”  In that light even the possibility that a “clean energy economy” may have flaws and that overall it may not be in the best public interest is not going to be incorporated in any reporting.