Indian Point Closure Update – May 2020

In April 2017 Governor Cuomo announced the closure of the Indian Point Energy Center by April 2021. According to the Governor “the aging 2,000 megawatt nuclear power plant, located 25 miles north of New York City, has presented numerous threats to the safety of over 20 million residents and the environmental health of the area”.  In April 2020 Indian Point 2 was shutdown.  This post updates some of my previous posts on this subject.

This is a follow-up to five previous posts published between January 2017 and March 2018 on Indian Point replacement power.  The first and a subsequent update considered New York State projects that had been permitted to see if there was replacement power in the pipeline that could replace its output.  I also analyzed whether renewables and energy efficiency were a realistic alternative and concluded that approach was unlikely to succeed. I also looked at a proposal from the New York Battery and Energy Storage Technology Consortiums to use energy storage as a potential replacement for Indian Point.  I concluded that would also not likely succeed.  Finally, I reviewed the New York Independent System Operator (NYISO) response to the question about the replacement power needed to replace Indian Point’s output. 

In July 2019, at a press conference announcing the Climate Leadership and Community Protection Act (“Climate Act”) Cuomo said “The environment and climate change are the most critically important policy priorities we face – they literally will determine the future – or the lack thereof.”  Indian Point 2 (1,299 MW nameplate capacity) has an in-service date of August 1973 and Indian Point 3 (1,012 MW nameplate capacity) was placed in service in April 1976.  The 2020 NYISO Gold Book notes that the 2020 summer capability of the two units is 2,067 MW. The owner, Entergy Nuclear Operations Inc., had applied for renewal of the operating licenses in April 2007, seeking an additional 20 years of operation beyond the original expiration dates of 2013 and 2015. The Nuclear Regulatory Commission renewed the operating licenses for the Indian Point nuclear power plant, Unit 2 and Unit 3, on Sept. 17, 2018 so the units would have been able to run until 2033 and 2035, respectively.  However, under the settlement between Entergy and the state of New York announced a settlement under which Entergy closed Unit 2 by April 30, 2020 and will permanently close Unit 3 by April 30, 2021. 

New York Control Area Energy Production

In order to fully grasp the innumeracy of shutting down 2,0067 MW of CO2-emission free generation at the same time the Climate Act legislates that electricity generation in 2040 will not include any fossil-fired power, we need to look at the energy production numbers in New York.  In the following table I have extracted the energy production by fuel type numbers from the NYISO Gold Book and combined that with the operating data from Indian Point 2 and 3.

NYISO Gold Book Figure III-3:  NYCA Energy Production (GWh) by Fuel Type

  2016 2017 2018 2019
Generator Fuel Types Production Production Production Production
Gas 7,787 6,697 7,594 7,273
Oil 136 74 152 104
Gas & Oil 52,450 44,135 47,526 44,068
Coal 1,493 567 692 425
Nuclear 41,638 42,175 43,003 44,788
Pumped Storage 836 795 811 583
Hydro 26,314 29,554 29,045 30,141
Wind 3,943 4,219 3,985 4,454
Other 2,881 2,919 2,729 2,648
Solar 54 47 49 52
Total 137,532 131,183 135,585 134,536
         
Indian Point 2 6,050 8,352 8,001 8,352
Indian Point 3 9,076 6,953 8,334 8,343

While it is clear by the energy production numbers that Indian Point has a significant contribution to the state’s power production the percentages make the point even better.  The two units generated approximately 12% of all the power produced over the last four years.

NYISO Gold Book NYCA Energy Production (%) by Fuel Type

  2016 2017 2018 2019
Generator Fuel Types Production Production Production Production
Gas 5.7% 5.1% 5.6% 5.4%
Oil 0.1% 0.1% 0.1% 0.1%
Gas & Oil 38.1% 33.6% 35.1% 32.8%
Coal 1.1% 0.4% 0.5% 0.3%
Nuclear 30.3% 32.1% 31.7% 33.3%
Pumped Storage 0.6% 0.6% 0.6% 0.4%
Hydro 19.1% 22.5% 21.4% 22.4%
Wind 2.9% 3.2% 2.9% 3.3%
Other 2.1% 2.2% 2.0% 2.0%
Solar 0.0% 0.0% 0.0% 0.0%
         
Indian Point 2 4.4% 6.4% 5.9% 6.2%
Indian Point 3 6.6% 5.3% 6.1% 6.2%

New York Climate Act Energy Production Targets

The Regulatory Impact Statement for the New York Department of Environmental Conservation (DEC) proposed revisions to 6 NYCRR Part 242, “CO2 Budget Trading Program” states the following:

“Finally, the primary objective of the State’s clean energy and energy storage commitments are to combat climate change, reduce air pollution, and ensure a reliable and diverse low carbon energy supply. In January 2019 as part of the State of the State, Governor Cuomo announced the most aggressive clean energy targets in the nation under New York’s Green New Deal – a nation leading clean energy and jobs agenda. This includes a significant increase of the New York’s Clean Energy Standard where the share of the State’s electricity coming from renewable resources will go from 50 percent to 70 percent by 2030. This will be supported by several critical components:

Quadrupling New York’s offshore wind target to 9,000 megawatts by 2035, up from 2,400 megawatts by 2030.

Doubling distributed solar deployment to 6,000 megawatts by 2025, up from 3,000 megawatts by 2023.

Deploying 3,000 megawatts of energy storage.

More than doubling new large-scale land-based wind and solar resources through the Clean Energy Standard.”

Two of the critical components, offshore wind (9,000 MW) and distributed solar deployment (6,000 MW) total 12,933 more MW than Indian Point 2 and 3.  Assuming an offshore wind capacity factor of 42.5% and fixed-tilt PV solar capacity factor of 20%, then the energy produced by these components could total 33,507 GWh for offshore wind and 10,512 GWh for the distributed solar.  While that all sounds good, there are issues.  For starters, given the alleged urgency for implementing emission reductions for the Climate Act, I would think that timing the closedown until after replacement power was at least permitted would have been appropriate.  More importantly, the problem is not as much the power, it is the energy produced that is of concern as shown below.

Future Energy System Implications

Power is the rate work is performed and is described in MW while energy is the amount of work performed measured in MWh.  The Climate Act  includes a provision to outlaw the use of fossil fuels for electric generation by 2040 and another provision to reduce all fossil fuel emissions to 85% of 1990 levels by 2050 despite not having come up with a plan to change the electric system to meet the energy requirements.  I maintain that it is absolutely necessary to use historical wind and solar insolation data to determine the resources available to meet expected load when transportation and heating are electrified.  My particular concern is the inevitable winter peak periods.

In one analysis I found that there were two no wind energy output periods on 3-4 January 2018 during an intense cold snap when electric load is high as shown in the New York Off-Shore Wind Generation Estimate for 9000 MW CLCPA Off-Shore Target table.  I was surprised to see that the wind resource went to zero during a high load period not only when the winds were light on January 3 but also when a deep low pressure developed and the wind speeds exceeded 25 m/s on the very next day.  The wind generation estimate table lists the output from a single 10.2 MW wind turbine, 80 turbines in the Equinor proposed offshore wind facility and for all 9,000 MW of Cuomo’s CLCPA target for off-shore wind.  It is important to note that adding even more wind turbines still does not preclude the need for substantial energy storage.  While all the New York off-shore wind resource may not go to zero simultaneously that resource is going to be highly correlated across the available area so they all will track closely.  Keep in mind that this example winter peak period occurs at the time that solar energy is very much reduced due to length of the day, angle of the sun and potential snow covering panels.

I followed up on that analysis with an attempt to estimate how much energy storage would be required for this example winter peak.  One of the unmentioned difficulties with Li-Ion battery storage is that they can only be operated over a limited range to get them to last ten years, i.e., they must use active thermal management and cycle the battery within a restricted 54% operating range.   As shown in the Combined Energy Storage Capacity and Cost With Storage 54% Limitation table, in order to meet the 2040 no fossil-fuel requirement I estimate that the price of energy storage alone will  be $96.0 billion, and, because they still only have a lifetime of ten years they will have to be replaced in 2050 at an estimated additional cost of $80.4 billion.  The expected cost of the batteries needed for just energy storage is the sum or $176.3 billion.  

One of the critical components mentioned above is to deploy 3,000 megawatts of energy storage.  It is very frustrating that many of the forecasts for energy storage just list the power capacity.  It makes a huge difference when trying to figure out how well the energy storage will be able to handle the peak load forecasts in an all-renewable energy system.  In the absence of that information, I assumed that the 3,000 MW will have four hours of storage or 12,000 MWh.  In the example given above I estimated that much more energy storage capacity and energy would be needed – 40,926 MW with energy potential of 278,519 MWh in 2040 and 30,556 MW of battery storage with 236,667 MWh of energy potential in 2050.  The critical point is that the overview estimates to date apparently only look at annual numbers.  In order to keep the electric power on when society needs it most, winter peak load analyses have to be done. 

That is not all, unfortunately.  In an earlier post on Indian Point I pointed out I originally thought the only energy storage issue was building enough batteries to store the renewable energy for when it is needed. 

Not surprisingly, it turns out that it is more complicated than that.  PG&E recently reported on the results of a battery storage demonstration project that described how their batteries were used on the grid. The project participated in the day ahead energy market which is used to procure the majority of supply to meet that day’s predicted electric load.  The California ISO also has a real-time energy market and the battery system provided services for short-term fluctuations from the day ahead forecast.  In addition to the energy market, batteries can be used for the ancillary services of frequency regulation and spinning reserves.  Finally, the report notes that it takes more energy to charge the batteries than battery discharges.  Also note that the energy storage association has a longer list of battery technology applications.  Until such time that New York proves that renewable energy and energy storage can keep the power on when it is needed most I think we are headed blindly to a bad ending.

Capacity Change Reality

Previously (here and here), I considered New York State projects that had been permitted to see if there was replacement power in the pipeline that could replace its output.  The NYISO Gold Book also documents changes in the changes of capacity of New York generating sources since the announcement of the closure plan.  I extracted data from the Gold Books since 2017 when Cuomo announced the closure of Indian Point to see how the market has reacted to the loss of Indian Point’s carbon-free generation.  I list the 2017 and 2020 summer capacity for each generator fuel type taken directly from the Gold Book.  There are four types of changes listed in these data: deactivations when a unit is retired, additions and uprates when a new unit is added or existing unit is modified to increase capacity, reclassifications when a unit’s fuel type is changed, and ratings changes which occur based on performance testing.   The biggest change over the last three years has been the addition of new combustion turbines totaling 1,868 MW. 

NYISO Gold Book Table II-1a: 2017 to 2020 Summary of Changes in Summer Capacity (MW)

Generator 2017   Additions Reclassi- Ratings 2020
Fuel Types Capacity Deactivations & Uprates fications Changes Capacity
Gas 3,588 -4 1,124 23 -5 4,725
Oil 2,499 -33 0 0 -50 2,416
Gas & Oil 18,529 -274 744 0 231 19,230
Coal 1,011 -291 0 -23 -21 676
Nuclear 5,375 0 0 0 16 5,391
Pumped Storage 1,407 0 0 0 0 1,407
Hydro 4,251 0 0 0 -4 4,247
Wind 1,740 0 0 0 -1 1,739
Other 378 -25 0 0 5 359
Total 38,778 -627 1,868 0 171 40,191

Note that there has been no renewable capacity added over this period.  I believe that is a result of detailed permitting requirements that include environmental and public health impact analyses, studies regarding environmental justice and public safety, and consideration of local laws. In April 2020, NYS passed the Accelerated Renewable Energy Growth and Community Benefit Act (AREGCBA) as part of the 2020-21 state budget.  This legislation is intended to ensure that renewable generation is sited in a “timely and cost-effective manner”.   In any event, in the past 12 months wind projects totaling nearly 1,300 MW have been permitted and will show up on this table once construction is complete. 

Importantly, those who say that the closure of Indian Point won’t increase fossil-fired emissions are mistaken.  Because the fuel costs of existing renewable projects are essentially zero all the output of existing projects is already spoken for and no increased output to respond to Indian Point closure is possible.  Replacement renewable replacement power has to be new sources.  Nuclear and hydro are normally lower cost sources than fossil fuel sources.  As a result, the only source left source left to replace Indian Point’s lost energy are fossil plants.

The NYISO recent full 2020 summer assessment notes that despite a 506 MW decrease of the capacity margin surplus for baseline peak weather conditions, there is margin above the baseline plus needed operating reserves.  However, if extreme weather conditions occur there is no capacity margin surplus and the system may have to rely on emergency operating procedures to provide relief.  The presentation notes that 2,273 MW have been deactivated this year but that 1,177 MW of natural gas fired power has been added.  It appears that the closure of Indian Point 2 should not affect reliability this summer unless there are extraordinary conditions.

Conclusion

Governor Cuomo said “The environment and climate change are the most critically important policy priorities we face – they literally will determine the future – or the lack thereof.”  Nonetheless the hypocritical implementation of his policies suggests that there are other factors driving these initiatives.  The closure of Indian Point was not coordinated with implementation of renewable energy to replace it.  I am positive that this will result in increased CO2 emissions for some part of the more than a decade useful life of these units that has been short-circuited.  In this instance, the alleged environmental impacts of Indian Point were more of a concern than climate change.  On the other hand, there is no requirement for a cumulative environmental impact of all the renewable energy resources needed by the Climate Act.  (By the way, that is a moot point until the State actually comes up with the plan to convert the electric system completely away from fossil fuels.)  Compounding the risk that the environmental impacts of the Climate Act could be worse than the averted climate change impacts is the AREGCBA law that now circumvents the requirements for detailed site-specific requirements for environmental and public health studies now in place.  So, on one hand, environmental risks trump climate change risks but on the other hand climate change risks overrule the obvious need to consider environmental impacts of massive wind, solar, and transmission deployment.

Finally, the State will undoubtedly claim that it will be cheaper to use offshore wind, distributed solar deployment, and doubling new large-scale land-based wind and solar resources through the Clean Energy Standard than building new fossil-fired generation to replace electric energy from Indian Point 2 and 3.  However, the fact is that the renewable resources come with a hidden price tag because of the necessity of including energy storage for the periods when intermittent wind and solar are unavailable and grid services because diffuse wind and solar require transmission support.  Not only are there significant cost financial implications, the fact that no jurisdiction anywhere has successfully implemented an electric system with such a high dependency upon renewables without becoming dependent upon adjoining electric systems for support, should give the State sufficient incentive to re-consider the ambitious schedule for the aspirational targets of the Climate Act until proper feasibility and cumulative environmental impact analyses have been completed.

New York Energy Efficiency Goals

One of the cornerstone presumptions in New York’s energy future plan is that increasing future energy efficiency efforts will play a key role in the transition to a cleaner, greener electric grid.  In the summer of 2019 the Governor Cuomo and the New York State Legislature passed the Climate Leadership and Community Protection Act (CLCPA) which was described as the most ambitious and comprehensive climate and clean energy legislation in the country when Cuomo signed the legislation.  Among the targets of that legislation is: conserve 185 trillion British thermal units (TBTUs) of annual end-use energy use by 2025, of which at least 20 percent should be from energy efficiency improvements in disadvantaged communities.

Energy efficiency is a major component of New York’s energy planning because if less energy is used then less energy will need to be generated. That concept is not debatable and I support energy efficiency efforts, in no small part, because they can be directed at those least able to pay for the inevitable higher prices resulting from government intervention into energy supply.  The question addressed in this post is whether New York’s energy efficiency programs have done well enough that we can expect this to be a substantive component for future energy reduction goals.  This post will look at two New York energy efficiency goals: one made in the past and one a key component for future energy needs.

Energy Data Used to Evaluate the Goals

The New York State Energy Research and Development Authority (NYSERDA) publishes an annual a comprehensive summary of energy statistics and data on energy consumption, supply sources, and price and expenditure information for New York State called Patterns and Trends.  For anyone interested in New York energy information this is a great resource.  One thing that I particularly like is that when you click on a table there is a link to a spreadsheet with all the data.  For space reasons the report does not list all the numbers but the downloadable spreadsheet includes everything.

Unfortunately, during the Cuomo Administration, the annual updates are lagging further and further behind.  In January 2011, the report updated with data through the end of 2009 was published 13 months after the end of that year.  The latest report available, Patterns and Trends – New York State Energy Profiles: 2002-2016,  publication date is January 2019 but it did not get released for another month so it came out 26 months after the end of the year.  Clearly, the 2017 data update will be even later.

2002 Energy Plan Energy Efficiency

The 2002 Energy Plan includes energy resource assessments including Energy Efficiency  that serves as an excellent overview of energy efficiency (EE) assessment for anyone wanting more background information.  This assessment summarizes how New York’s EE programs evolved between 1990 and 2001 during the transition from traditional utility regulation to today’s de-regulated system.  In those 11 years collective energy efficiency expenditures invested “more than $2.9 billion”.   For example, according to Table 4, NYSERDA-Administered System Benefit Charge Energy Efficiency Spending with Projected and Actual Achievements (1998-2006), in this assessment, reductions to annual electric energy production totaled 11,655 (GWh) for an investment $758.7 million.  Statewide achievements between 1990 and 2001 included

      • Cumulative savings of 57,256 GWh of electricity and 1,688 MW of summer peak demand.
      • Cumulative annual savings in 2001 were 7,095 GWh, or about 5.2% of the approximately 137,000 GWh of electricity sales to ultimate consumers during that year.
      • Cumulative summer peak demand reductions in 2001 were 1,688 MW, or about 5.4% of the 30,982 MW peak that occurred during that summer.

The 2002 State Energy Plan provided “policies, strategies, and recommendations to provide New York with fairly priced, clean, and efficient energy resources”.  The Executive Summary includes the following energy efficiency goal: “The State adopts the goal of reducing primary energy use per unit of Gross State Product (GSP) 25% below the 1990 level of energy use, by 2010.”  I will determine whether the State made that historic goal below.

National Grid Natural Gas Supply Energy Efficiency Goals

In response to the New York Department of Public proceeding related to denial of service requests National Grid prepared a summary report to help “enable an agreed long-term solution(s) with New York State by June 2020” so that the solution(s) can be in place and in operation by the winter of 2021/2022.  EE projections and programs play a key part in this plan to ensure adequate natural gas supplies.  In the report,        National Grid discussed historical demand growth and made two projections, a high-demand and a low-demand scenario, to bound their analysis. In the high demand scenario, they assume that 80% of the State energy efficiency targets are achieved and in the low demand scenario they assume that 100% of the targets are achieved.  In order to meet future energy requirements, they also included a no-infrastructure energy efficiency project to “reduce Design Day demand through intensive weatherization measures, such as air-sealing and maximized insulation”.

The State’s 2002 EE goal was normalized relative to the state gross domestic product.  As a result, the result of that test is irrelevant to determining whether we can have confidence in the energy use projections in the National Grid demand growth projections and their no-infrastructure energy efficiency proposal.  What we need to look at is the actual energy use and energy use per customer.

2002 Energy Plan EE Goal Evaluation

The 2002 Energy Plan EE goal is to reduce primary energy use per unit of Gross State Product (GSP) 25% below the 1990 level of energy use, by 2010.  Table 2-5b, New York State Factors Influencing Energy Demand and Expenditures, lists the Gross State Product and Table 3-1b, New York Consumption of Energy by Fuel Type, lists energy use for the State.  The Evaluation of the 2002 State Energy Plan Goal table lists the annual values from the downloaded spreadsheets for each table, calculates energy use per GSP and then lists the % reduction from 1990 for each year since 1990.  In 2010, the reduction in this parameter was 30.1% easily exceeding the 2002 Energy Plan goal of a 25% reduction.

On the face of it this is good news but we also have to ask why did the State meet the goal.  Total energy use actually went up 3.2% since 1990.  However, the State Gross Product went up 47.5% and that increase more than made up for the energy use increase such that the energy use per GSP parameter went down.

A couple of points for context.  Energy use is a function of multiple effects including the weather (extreme heat or cold increases energy use), the economy (when more businesses are making things they use more energy), as well as how efficiently the energy is being used.  As a result, a single year to a single year comparison could be mis-leading.  Clearly, however, the fact that the energy use per GSP exceeds the goal means that the State effectively met that goal.  I think it is also a laudable achievement to increase the GSP that much and keep the energy use since 1990 pretty close to a small increase.  On the other hand, the aggressive New York state-wide goals for the future will need to rely on reductions in energy use not just energy use per GSP.

Confidence in the Future Projected EE Goal

While I am impressed that the State met its 2002 energy efficiency goal, in the context of actual energy reduction I believe that it is more important to reduce total energy use and energy use per customer served.  If those data suggest that EE is working as well as suggested by the State then we can have confidence that meeting future energy use goals will be achieved.  This section describes the data I used and how it was processed to look at that energy use itself.

For this analysis I used data from the following Patterns and Trends appendices that provide electric and gas number of customers and electric and gas sales.

Appendix F-2, New York State Electricity Customers by Sector by Utility

          • Table F-2a. Residential Sector Electricity Customers by Utility
          • Table F-2b. Commercial Sector Electricity Customers by Utility
          • Table F-2c. Industrial Sector Electricity Customers by Utility

Appendix F-3, New York State Electricity Sales by Sector by Utility

          • Table F-3a. Residential Sector Electricity Sales by Utility (GWh)
          • Table F-3b. Commercial Sector Electricity Sales by Utility (GWh)
          • Table F-3c. Industrial Sector Electricity Sales by Utility (GWh)

Appendix F-5, New York State Natural Gas Customers by Sector by Utility

          • Table F-5a. Residential Sector Natural Gas Customers by Utility
          • Table F-5b. Commercial Sector Natural Gas Customers by Utility
          • Table F-5c. Industrial Sector Natural Gas Customers by Utility

Appendix F-6, New York State Natural Gas Sales by Sector by Utility

          • Table F-6a. Residential Sector Natural Gas Sales by Utility (Millions of Cubic Feet)
          • Table F-6b. Commercial Sector Natural Gas Sales by Utility (Millions of Cubic Feet)
          • Table F-6c. Industrial Sector Natural Gas Sales by Utility (Millions of Cubic Feet)

Both sets of data include values for the residential, commercial and industrial sectors.  Note that these data are only available back to 2001.  Although the primary emphasis is on the goal for natural gas usage, I will include both electric and gas information.

The New York State Natural Gas System Customers, Natural Gas Sales, and Natural Gas Use per Customer Data and Trendstable lists the parameters that I think are more appropriate to evaluate the likelihood that energy efficiency can reduce the amount of natural gas that will be needed for the worst case heating requirements.  In 2016 the amount of natural gas used in the residential sector has increased 9.7% since 2002, in the commercial sector the amount used went down 12.8% and in the industrial sector the amount used went down 9.0%.  The amount of natural gas used per customer went up 3.9%, commercial sector was down 21.1% and industrial sector was down 56.6%

I have issues with these data that should be kept in mind.  In the industrial sector note that the number of industrial customers just about doubled from the 2001 to 2006 years.  Looking at the utility data in Table F-5c this was because of an increase at Brooklyn Union Gas.  I suspect this is more a reporting artifact than an actual change in the number of industrial customers.  Fortunately, that seems to be an exception in the data.

Recall that energy use is a function of weather, the economy and how the energy is used among other things that make the year to year variation and the choice of starting and ending points a concern when trying to determine what is actually going on.  In order to try to address this problem I calculated the percentage change of the energy use per customer for different periods.  The Alternate Natural Gas Use Trends Comparison table lists the change between the first eight year averages and the second eight year averages of the sixteen years of data available, the first five year averages and the last five year averages in the period of record, and the last five year averages relative to the proceeding five year averages.

Alternate Natural Gas Use Trends Comparison

Gas Use (Sales per Customer)
Residential Commercial Industrial
2001-2008 0.091 0.83 18.85
2009-2016 0.094 0.77 11.86
% Difference 3.0% -7.8% -37.1%
2001-2005 0.092 0.90 25.93
2012-2016 0.09 0.77 12.27
% Difference 2.8% -14.7% -52.7%
2007-2011 0.091 0.76 10.96
2012-2016 0.095 0.77 12.27
% Difference 3.8% 2.2% 12.0%

Both the commercial and industrial sectors show impressive reductions in use per customer in the first two alternatives.  However, the industrial sector values are skewed by the questionable number of customers data.  It is very concerning that during the period 2007 to 2016, when there was extensive energy efficiency investment, that the energy use per customer in all three sectors went up.

The New York State Electric System Customers, Electricity Sales, and Electricity Use per Customer Data and Trends table lists the same electric system parameters for completeness.  In 2016 the amount of electricity used in the residential sector has increased 15% since 2002, in the commercial sector the amount used went up 27% and in the industrial sector the amount used went down 14.8%.  The amount of electricity used per customer went up 20.9%, commercial sector use per customer went up 22.2% and industrial sector use per customer went up 63.16%.

As was the case with the natural gas numbers there are issues with the number of customers per sector.  For example, the number of  NYSE&G industrial customers went from ~2,700 in 2002 to 16,292 in 2003 and then back down to ~2,700 in 2004.  Something is wrong there.  Niagara Mohawk customers in 2001 and 2002 are also suspiciously different than the rest of the years.  Otherwise there are no suspect year to year variations.

I addressed the suspicious data issue and the variations due to other effects the same way as the natural gas data.   I calculated the percentage change of the energy use per customer for different periods.  The Alternate Electric Use Trends Comparison table lists the change between the first eight year averages and the second eight year averages of the sixteen years of data available, the first five year averages and the last five year averages in the period of record, and the last five year averages relative to the proceeding five year averages.

Alternate Electric Use Trends Comparison

Electric Use (Sales per Customer)
Residential Commercial Industrial
2001-2008 6.706 71.55 1,614.8
2009-2016 7.044 73.40 2,083.5
% Difference 5.0% 2.6% 29.0%
2001-2005 6.524 68.80 1,573.7
2012-2016 7.024 72.97 2,352.6
% Difference 7.7% 6.1% 49.5%
2007-2011 7.065 75.01 1,689.1
2012-2016 7.024 72.97 2,352.6
% Difference -0.6% -2.7% 39.3%

The sales per customer for all three sectors show increases in the first two alternatives.  However, the industrial sector values are skewed by the questionable number of customers data.  The good news is that contrary to the natural gas energy use, both residential and customer electric use per customer decrease which is what we would expect if energy efficiency programs were working well.  The industrial sector numbers show an increase but that is much more likely due to the changing character of industrial use, e.g., fewer customers but larger users.

Conclusion

I do not dispute that the energy efficiency concept that if less energy is used then less energy will need to be generated is a great thing.   In this post I looked at two New York energy efficiency goals: one made in the past and one a key component for future energy needs to see if results to date support this emphasis.

The 2002 Energy Plan included an energy efficiency goal to reduce primary energy use per unit of gross state product 25% below the 1990 level of energy use, by 2010.  I found data for gross state product and energy use, calculated the parameter used in the goal and determined the percentage reductions since 1990.  In 2010, the reduction in this parameter was 30.1% easily exceeding the 2002 Energy Plan goal of a 25% reduction.

However, upon closer examination, I found that the reason the goal was met was because the gross state product increased more than energy use increased.  The gross state product was included in the goal to try to reduce the economy’ effect on energy use.  This underscores the importance of evaluating energy efficiency programs based on actually reducing the amount of energy used.

At this time New York’s energy policy is counting on substantive reductions in energy use as part of the plan to reduce greenhouse gas emissions.  For example, National Grid’s proposed options to address natural gas supply deficiencies in New York City and on Long Island assume that the New York energy efficiency will meet or exceed 80% of the CLCPA targets and that they could get substantive additional reductions from an intense weatherization project.

I calculated the natural gas and electric energy use per customer rates since 2001 to determine if the energy efficiency investments to date have been successful.  The problem is that energy use is not just a factor of energy efficiency but also weather and the economy.  To get around that I conclude the best I can do is compare the averages of the last five years to the proceeding five year.  For electricity the residential and commercial sector energy use declined as we would expect given the energy efficiency investments.  However, natural gas use increased in the residential, commercial and industrial sectors.

This result raises concerns for me vis-à-vis National Grid’s proposed alternative options for supplying natural gas to New York City and Long Island.  I suspect that the State will force National Grid to choose options that rely on energy efficiency rather than ones that require new fossil-fuel infrastructure despite the fact that they will guarantee adequate supplies of natural gas. The fact that energy use per customer has gone up suggests that existing energy efficiency programs are not working as well as assumed and will not guarantee that additional natural gas is available on the coldest days.

NESE Pipeline Alternatives for National Grid

The Northeast Supply Enhancement (NESE) pipeline is a proposed pipeline to bring natural gas to New York City and Long Island.   I sent Comments submitted 27 March 2020 in a New York Department of Public Service proceeding related to denial of service requests by National Grid in New York City and Long Island which is associated with this project.  This post describes what is going on, the proposal to resolve the issue and my comments on the proceeding.  Be forewarned there is a lot of material to cover so this is a long one.

Purpose

The request for comments is in regard to a requirement to come up with alternatives to provide additional natural gas supply to National Grid’s service territory on Long Island.  In this section I explain what happened to the original plan to fix the problem and events leading up to the current discussion.  On May 15, 2019 the New York State Department of Environmental Conservation (NYSDEC) denied a water-quality permit for the NESE natural gas pipeline that would bring more natural gas to New York City and Long Island.  On May 24, 2019 National Grid imposed a moratorium on new natural gas connections In New York City and Long Island because they could not guarantee enough supply for additional customers based in part because the pipeline was blocked.  In late November 2019 National Grid relented and started doing hookups for new customers following threats from Governor Cuomo to pull their license to operate.  The fact remains that the there is still a problem so National Grid has developed a collaboration for a “safe and reliable energy future”.  I submitted my comments in response to the public outreach program related to this effort.  Once that effort is complete all the feedback will be collected and reviewed, and the National Grid will issue a supplemental report that summarizes and includes public and customer input.  This is supposed to “enable an agreed long-term solution(s) with New York State by June 2020” so that the solution(s) can be in place and in operation by the winter of 2021/2022.

Water Quality Permit Denial

In order to ensure adequate supplies Transcontinental Gas Pipe Line Company (Transco) proposed the Northeast Supply Enhancement Project (NESE).  The permit application project description states:

The NESE Project is a 26-inch diameter pipeline proposed by Transcontinental Gas Pipe Line Company LLC (Transco) that would transport natural gas from Pennsylvania through New Jersey, traveling underwater in the Raritan Bay and Lower New York Bay to approximately three miles offshore of the Rockaway Peninsula in Queens Borough. Approximately 23.5 miles of underwater pipeline will be installed, of which approximately 17.4 miles would be in New York State waters.

The NESE Project would connect to the existing Rockaway Delivery Lateral in Queens and would provide 400,000 dekatherms per day of incremental capacity to National Grid to serve customers in Brooklyn, Queens, and Long Island. According to Transco, the project is intended to support reliability as well as help displace the use of oil.

The NESE Project would be installed a minimum of 4 feet below the sea floor through a combination of jet trenching, clamshell dredging and horizontal directional drilling (HDD). Construction would be phased to avoid potential impacts to marine species. If permits are ultimately issued, compensatory mitigation would be required to offset unavoidable impacts to benthic resources, including shellfish.

On May 15, 2019, the NYSDEC denied the application for the required Clean Water Act Section 401 Water Quality Certification based on their review of the permit and over 14,000 public comments received on behalf of 45,000 individuals. The full decision (PDF) is outlined in a letter by Daniel Whitehead, Director, Division of Environmental Permits, NYSDEC.  I summarize the rationale below.

Because this is an interstate pipeline project the Federal Energy Regulatory Commission (FERC) has to approve the application to build the pipeline.  On March 27, 2017, Transco submitted to FERC an application for a Certificate of Public Convenience and Necessity for construction and operation of the Project. FERC issued a Draft Environmental Impact Statement (DEIS) on March 23, 2018. The NYSDEC submitted comments to FERC regarding the DEIS on May 14, 2018 and FERC issued a Final Environmental Impact Statement (FEIS) for the Project on January 25, 2019. The FEIS outlined some of the numerous environmental impacts FERC anticipated from the construction and operation of the Project. On May 3, 2019, FERC issued Transco a Certificate for the Project subject to certain environmental conditions recommended in the FEIS. According to FERC, these conditions would mitigate many of the environmental impacts associated with the Project.

Even though FERC approved the project Transco still had to get a Water Quality Certificate from New York State.  After the usual iterations between the applicant and the NYSDEC, the application for the Certificate was deemed complete on January 30, 2019.  When the application went out for public comment well over 90 percent of the 14,000 public comments opposed the Department’s issuing a Certificate.  On the basis of their review of the application and public comments, NYSDEC determined that there would be significant water quality impacts.  This includes “significant water quality impacts from the resuspension of sediments and other contaminants, including mercury and copper. In addition, as proposed, the Project would cause impacts to habitats due to the disturbance of shellfish beds and other benthic resources.”

All environmental impacts involve tradeoffs.  If resuspension of sediments were the deciding criterion and prohibited in every instance then no project that disturbed an underwater surface could proceed – no bridges, no docks, nothing.  For that matter fisherman’s dredges that are towed along the bottom could be prohibited.  In a rational world, the fact that all those activities and the construction of a pipeline are short-term would be considered and if the overall long-term benefits to society out-weigh the transient impacts then the permit would be approved.  This instance is complicated by the fact that the sediments are contaminated, so mercury and copper limits could be exceeded.  Again, if this is the criterion, then no work that disturbs sediments in New York harbor should be permitted.  Another unavoidable impact is habitat disturbance and the same trade-offs apply.  However, the State could have required Transco to rehabilitate the disturbed shellfish beds after the pipeline was installed.

This is an example of hypocritical decision making by the Cuomo Administration.  NYSDEC rejected the National Fuel Gas Empire Pipeline application for a new 97-mile pipeline because it would have caused permanent impacts to 2.335 acres of wetlands within the 73.377 wetland acres impacted.  The poster child for Cuomo hypocrisy is the rejection of the Finger Lakes LPG application for an underground storage facility because of “significant adverse impacts on community character” when the only visible infrastructure was a small pond and a building. On the other hand agencies have approved the Cuomo-correct applications for off-shore wind farms which will permanently disturb much more of the seafloor than the NESE pipeline would have temporarily disturbed, approved projects that permanently disturbed wetlands but allowed the developer to create compensating wetlands, and approved wind and solar applications that have significant impacts on community character.  There is absolutely no question in my mind that the professional staff at NYSDEC and the other NYS regulatory agencies, if left to make permitting decisions based on their experience and the facts of the case, would have approved all of the rejected applications. The reason there were rejected was the Cuomo Administration.

National Grid Moratorium

National Grid’s problem is that they have determined that there is not enough current gas supply to serve future customers.  In their report they explained that 85% of the gas used on the coldest days is used for heating.   If they don’t have enough gas available then service to existing customers will be jeopardized and that means heating supplies will be at risk.  In my comments I provided references that conclusively show that cold weather is more impactful on health than hot weather and I have also shown that claims that hot weather is worse are based on a reporting artifact related to different lag times for hot and cold effects.  Therefore, National Grid has the moral responsibility to ensure heating supplies are available and the State should support those efforts.

Gas supply is regulated by the Public Service Commission (PSC) so the projection methodology is comprehensive and well-documented  When a utility company calculates how much supply they have, how much they are using and how much they will need in the future to argue that they need more supply  infrastructure, the first thing PSC staff does is generate their own analysis using the same methodology.  The two sides compare projections to determine if there are differences and reconcile the numbers.  My point is that the assumptions used in these calculations have been developed over the years to ensure adequate and reliable gas supply and they should not get changed at the whim of anyone.

Faced with their analyses that show they don’t have enough gas for future additions and with the rejection of the solution that they had planned to use to resolve the problem National Grid announced that they had to put a moratorium on new supply hookups.

Cuomo’s Response to the Moratorium

In the fantasy world of Cuomo’s New York, numbers, facts, and precedence don’t matter.  It is all about Andy.  Once people could not get the preferred alternative of a natural gas hookup they squawked and the politician saw an opportunity to cater to voters. His response was to have the Public Service Commission order National Grid to provide natural gas hookups.  According to the New York Post “The Public Service Commission said it has the authority based on a section in Public Service Law that says if a gas company is unable to meet the needs of reliable service to customers, the state has the power to step in”.   Following established State practice National Grid calculated how many customers they could handle and cut off any additional customers when the infrastructure proposed to resolve the problem was rejected by the State.  Obviously National Grid was unable to meet the needs of customers solely because the State would not let them,

Furthermore, Cuomo huffed and puffed a threat to revoke the operating license for National Grid if they did not comply.  Now here is where the precedence issue arises.  The Department of Public Service (DPS) and Public Service Commission are supposed to be independent.  In this instance an independent agency could have said “Sorry Governor but your politically driven appeasement of your voting base meant that there may not be enough gas supply available and in order to protect the citizens the prudent choice is to put a moratorium in place.”  The problem is that the DPS no longer independently serves the public interest.   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.”

Like most bully threats there are questions whether Cuomo could have actually revoked National Grid charter to operate.  Nonetheless it was a thinly veiled threat to step in line or he would make doing business miserable.  National Grid is a business and in order to succeed financially they depend on a rate-making process that is entirely co-opted by the Cuomo Administration.  If National Grid steps out of line there is no question that his Administration will hurt them as often and as hard as possible.

National Grid Interim Solution

Not surprisingly National Grid caved and agreed to lift the moratorium for two years.  According to a Utility Dive report:

National Grid has identified new solutions to supply consumer gas needs in downstate New York since announcing the moratorium, company spokesperson Domenick Graziani told Utility Dive in an email. These include a “previously unavailable source of short-term peaking supplies,” which he declined to provide further details on.

The utility also anticipates reductions in demand due to energy efficiency and demand response programs, a new compression project that will provide additional long-term capacity to portions of Long Island and a greater-than-expected number of customers interested in shifting to “non-firm” service — that is, customers who switch to oil or other alternative fuels when asked to by National Grid. These customers are charged differently from residential and other “firm” customers and can be penalized if they don’t make the switch, according to Graziani.

As noted, before, environmental development issues involve tradeoffs and that is also true for energy development.  In this instance the “previously unavailable source of short-term peaking supplies” turned out to be trucked compressed natural gas.  This option requires a facility where the gas is compressed outside of Long Island and loaded into trucks that transport it to a vaporization facility on Long Island where it can be vaporized and added into a pipeline for delivery.  Natural gas can be transported from the production well to the user entirely by underground pipelines.  While there are safety and environmental issues related to that relatively simple approach there is no question that the CNG truck option through New York City is much riskier and that environmental impacts will be greater when additional handling components are added to the transport from well to user.  Elsewhere this “virtual pipeline” is widely condemned so it is not surprising that the National Grid spokesman declined to provide further details.

This is another instance of Cuomo administration hypocrisy: on one hand basking in the limelight as a leader against climate change by prohibiting new fossil fuel infrastructure but on the other hand needlessly risking safety and increasing environmental impacts with a solution only intended for use as a stop gap in emergencies.  Mark my word if there is CNG truck accident it will be anybody’s fault but Cuomo’s.

National Grid Collaboration

At this time National Grid is conducting an outreach program as described below:

For National Grid, serving our 1.9 million natural gas customers across Brooklyn, Queens, Staten Island, Nassau, and Suffolk is both a privilege and a responsibility. New York has seen dynamic economic growth in the Downstate region, expanding residential and non-residential building space, and thousands of oil-to-gas conversions over the last 10 years. These factors have resulted in a substantial increase in the demand for natural gas, placing stress on our existing gas network and threatening National Grid’s ability to meet our customers’ needs when demand is at its peak. This leaves little room for error in the face of unplanned supply interruptions or other contingencies.

As part of the settlement agreement with New York State that lifted the moratorium on new gas connections imposed in May 2019, we are taking numerous measures to ensure we have sufficient supply for the winters of 2019/2020 and 2020/2021, including increasing reliance on compressed natural gas (“CNG”) trucking when needed to meet peak demand.

Beyond the next two winters, however, continued growth in demand for natural gas creates a challenge that must be addressed. There are multiple potential solutions, each with its own considerations regarding safety, reliability, environmental and community impact, and cost. National Grid has prepared and provided to New York State an extensive Long-Term Capacity Report to facilitate constructive dialog in the quest to answer the challenges presented by increasing demand. The purpose of this Summary Report is to distill the content of that full report for the general public so that all may understand the issues involved and the potential solutions to be considered.

We wish this to be a collaborative process and encourage feedback, either through the public meetings hosted by National Grid in March 2020 or by sharing your thoughts via our online survey at www.ngrid.com/longtermsolutions.  This site also provides access to the full report and a link through which you can share feedback directly with the New York State Department of Public Service.

In other words, National Grid is desperately trying to appease the Governor who wants to play to the no fossil fuel infrastructure maniacs he actively courts.  To do that they have come up with this stakeholder process that lays out the problem and offers a number of alternative approaches to the problem.  All the while trying not to favor any of them.

My Submittal

National Grid has developed a slick website that provides information on the long-term solution options.  Also included are links to the reports, schedule of events, ways to submit comments, and transcripts from their meetings.  I will describe the summary report and reproduce some of the comments I submitted in italics.

In the first section of the summary National Grid describes the problem.  In order to define how much natural gas will be used they use the “Design Day” concept.  This is the plan for peak demand conditions as the level of gas delivery needed to serve all of our customers during an extreme cold weather event. In the Downstate NY region Design Day is defined as a 24-hour period that averages 0° Fahrenheit in Central Park. They note that approximately 85% of this Design Day capacity is used to heat homes and businesses—keeping people warm on the coldest of days.

I frankly could only stand listening to the comments made during the public meeting for a brief period but in that time two people complained about the use of 0° Fahrenheit as the design day because temperatures have been warming.  I am frustrated that they spout off numbers without any consideration that they have no responsibility in the event that they are wrong.  Moreover, I am sure that the choice of the design day temperature is proscribed by some PSC order somewhere to prevent gaming the system so it is unlikely that changing the number could be considered.  Nonetheless, I accessed Central Park data to see whether that value is representative to prepare the following comment:

I am a meteorologist so I checked the representativeness of the 0° Fahrenheit in Central Park criterion.  I used the Northeast Regional Climate Center CLIMOD 2 data portal to download Central Park daily minimum, maximum and average temperature data from 1869 to the present.  Over that period the lowest daily average temperature was -5.5° Fahrenheit and there were six other days with daily average temperatures less than or equal to the 0° Fahrenheit design day criteria.  Note also that on December 30 and 31, 1917 there were two days with average temperatures below 0° Fahrenheit in the midst of a seven-day period with daily average temperatures less than 10° Fahrenheit. 

I also evaluated hourly meteorological data for two NYS Mesonet stations (Rush and York sites from December 29, 2017 to January 8, 2018.  In that period the temperature did not get above freezing and on January 6, 2018 the average temperature was 0.8° Fahrenheit.  Based on my meteorology background and despite the fact that the most recent date with an average zero degree design day temperature in Central Park was 15 February 1943, I believe the weather conditions that caused a 0.8° Fahrenheit average day near Rochester in 2018 support the continued use of the 0° Fahrenheit in Central Park criterion.  Because 85% of the Design Day capacity is used for heating this design day criterion may not be stringent enough and certainly should not be adjusted upwards.

National Grid discussed historical demand growth and made two projections, a high-demand and a low-demand scenario, to bound their analysis. In the high demand scenario, they assume that 80% of the State energy efficiency targets are achieved and in the low demand scenario they assume that 100% of the targets are achieved.  Based on the projections and factoring in low-carbon solutions they predict that they will need to close a gap of 400 MDth/day between customer demand and available natural gas supply with the existing system.

In contrast to National Grid’s optimistic projection that they will reduce demand growth by over 50% I disagree.  In the first place, New York has already had extensive energy efficiency efforts in place during the time that demand growth increased 2.4%.  As a result, the easiest and most effective, aka low hanging fruit, energy efficiency projects have already been implemented.  Any future reductions will not be as cheap or effective.  Another problem is that natural gas works well for heating and cooking so it is the preferred alternative.  The “no new fossil-fuel infrastructure” argument is fine in theory but when faced with having to choose a poorer alternative I believe there will be plenty of pushback from the majority of the population that wants the advantages of natural gas and is not as motivated as the environmental advocacy folks so vocal in this proceeding. 

 This is particularly true with regards to home heating electrification because the preferred retrofit alternative is air source heat pumps.  My personal experience with this technology has been bad and I think that is a major problem for those who want to electrify heating. The word on the street is more often negative than positive.  In my case I did research to try to understand the problem.  In my 9/16/2019 filed comments on Resource Adequacy Matters, Case 19-E-0530, I included an analysis in an appendix entitled Air Source Heat Pumps that demonstrated the fundamental flaw with this technology.  In short, when the temperature drops below 20° Fahrenheit there simply is not enough energy to be transferred and converted to heat for the technology to work.  In the event of a seven-day cold snap like the one that occurred around New Year’s Day 1918 anyone without supplemental heat would freeze and the increased electrical load needed to provide supplemental electric resistance heating could lead to unprecedented peak loads.  Claims that improved air source heat pumps will solve this problem are unwarranted absent repealing the laws of physics.

 As a result, I do not think that the low demand case in which 80% of the State energy efficiency targets are achieved is likely.  More realistically the low demand will be 50% of the targets and the high demand 80%.  I am confident that 100% of the State energy efficiency targets will not be met.

Another aspect of the National Grid demand reduction plan is to use three low-carbon solutions: renewable natural gas, hydrogen blending and power-to-gas, and geothermal heat pumps.  National Grid claims that “with proper funding and support, we anticipate that these programs can cover 15–35 MDth of the Downstate NY gas supply gap”.

      • Renewable natural gas (RNG) facilities use biomass—such as landfills, wastewater treatment, food waste, and livestock manure— as feedstock for producing gas. National Grid currently has two RNG sites in their Downstate NY region: one on Staten Island and another at Newtown Creek expected to come online in the winter of 2020. They believe there is even more opportunity to expand RNG in their Downstate NY region.
      • Natural gas supplies can be augmented by blending in hydrogen gas produced by splitting water into hydrogen gas and oxygen gas through the process of electrolysis. Hydrogen blends, in the form of town gas, were used in heating for decades, both in the US and other countries. National Grid has proposed a two-year study to assess optimal parameters for incorporating hydrogen in the Downstate NY region.
      • By transferring heat to and from the ground, geothermal heat pumps offer an attractive, low-carbon alternative for providing central heating and cooling. Based on the success of a demonstration project that connected 10 homes with shared-loop ground-source heat pump (GSHP) systems, National Grid is seeking to expand this program to 900 homes over the coming four years.

As shown below I don’t think these projects have much, if any value.  At the Trust Yet Verify blog, the author notes that in Flanders, they have the expression “calculating oneself rich” which means presenting one’s case in a too optimistic way that doesn’t accord with reality.  Had I been aware of that expression when I wrote the comments, I would have used it because it describes these projects well.

Renewable natural gas is produced from anerobic digesters.  The New York State Energy and Research Development Authority (NYSERDA) has an integrated data system that provides operational data on DERs installed in New York including anerobic digesters.  At the current time there are 38 facilities with a rated electrical output of 22,263 kW.  The majority (29) of these digesters are located on dairy farms.  Eight are at waste water treatment plants and one is located at the Saranac brewery.  Only three of these have output greater than 3 MW and the majority are rated between 100 and 500 kW.  It is telling that NYSERDA rates these by electrical output because that indicates that the methane is primarily used to generate electricity. The National Grid report states that the Newtown Creek WWTP will be capable of producing 1.0 MDth/day and that they are “connected to a 1.6 MDth/day plant in Staten Island”.  Presumably during peak natural gas demand periods, the plan could be to divert the methane to the gas system rather than using it for generating electricity.   I believe that this option has limited potential simply because there are not many possible sites where it could be deployed.

 National Grid has proposed a two-year study to assess optimal parameters for incorporating hydrogen in the Downstate NY region.  In other words, this is more of a concept than a proven technology in today’s energy landscape.  Cynic that I am I consider this more wishful thinking than an actual plan.

 Ground source heat pumps work but the implementation logistics of trying to install meaningful amounts even, if the geology was favorable, in the service territory for this proceeding precludes this as a viable contributor to meaningful load reductions.

The meat of the report is the description of ten distinct options for closing the gap of up to 400 MDth/day between natural gas demand and supply over the next 15 years.  National Grid is careful to state that they do not propose a “best” or “most desirable” solution and pragmatically observe that the ultimate approach ultimately will likely be a portfolio including two or more of these options.  As noted earlier they have the responsibility to provide natural gas and the politicians who demand solutions that are driven by an agenda will disavow any culpability if they don’t work.

National Grid proposes ten projects in three categories.  They propose three large-scale infrastructure projects: an offshore liquified natural gas (LNG) deep water port, an LNG import terminal, and the Northeast Supply Enhancement pipeline project.  There are four distributed infrastructure projects: a peak LNG facility, LNG barges, the Clove Lakes Transmission Project, and the Iroquois enhancement compression project.  There are three no-infrastructure projects: incremental energy efficiency, demand response, and electrification.

The summary report concludes with an assessment of the relative attractiveness of the proposed options with respect to each of the evaluation criteria to “help our customers and the general public evaluate the options”.  I reviewed and commented on the scoring but will not include all my comments here.  In brief, I think that by necessity National Grid scored the NESE pipeline lower than they should have to be “Cuomo correct”.  For example, they gave all the large infrastructure projects the same safety score. I disagree because in most things related to safety simpler is better.  Both LNG alternatives are significantly more complicated because they involve storage and regasification components.  Moreover, they both require marine transport which compared to a pipeline has to be less safe.  I suggested that the scores for those projects be dropped relative to the pipeline.

I did include a comment on the environmental scoring because I have a lot of experience with environmental impact analyses and I disagree with the environmental scoring.  Frankly the evaluation criteria in the report in Table 19 don’t help much.  Greenhouse gas (GHG) emissions is one criterion used.  I don’t see how the compression, regasification, and transportation components of the LNG options would not mean higher GHG emissions. All the other GHG emissions intensity values are the same for all three options.  As a long-time air quality meteorologist, I struggle to find air substantive air quality problems with natural gas use as compared to other dispatchable sources of energy but I believe that air pollution emissions from LNG ship transportation are larger than pipeline compressor stations.  I can accept that the potential impact from construction is higher for pipelines but once in place the operation impacts are likely lower.   I assume that environmental risk relates to the ecological impact.  The fact is that there have to be pipelines from the well pads to the ports for the LNG options.  Expanding pipeline capacity to bring the needed natural gas directly to the City is simpler, safer and less prone to problems.  I cannot comment on the potential of any option to support New York’s decarbonization goals because there is no plan to implement those goals, only targets.  The politicians that enacted legislation with the goals made a major mistake putting the cart (the aggressive targets) before the horse (figuring out what was feasible).  In conclusion I would add another cell to the environment scoring bar to the pipeline option because it is significantly better than the other two.

 Two of the distributed infrastructure projects, Clove Lakes Transmission Project and the Iroquois enhancement compression project, are simple upgrades that will provide more capacity.  I see no reason why they should not be included.

The no-infrastructure projects all qualify as “Cuomo correct” virtue signals.  Because I don’t believe that the existing energy efficiency targets will be met, I reject out of hand the idea that even more substantive energy efficiency could be implemented.  Demand response is a favored component of “smart grid” advocates for shaving summer peak demand.  However, that is not a solution here because the expectation is that the load peak will shift to the winter.  I believe that there are significant differences between cooling peak loads and heating peak loads.  Most importantly, there is a hot period diurnal cycle that means that shifting between uses (A/C is not as large a component of total load as heating is to the total load) and times (when the sun is down there is no direct solar heating and cooling load needs drop significantly) is possible.  The question boils down to this: when 85% of your load is heating and the heating load does not vary much how can you shift the load?  I for one would not accept a thermostat that someone else controls for heating my home.  I do not think I would be an exception.

The third no infrastructure project was heating electrification using cold-climate, electric heat pumps.   I think that widespread implementation of cold-climate heat pumps will be a mistake as I noted in my resource adequacy comments. Bottom line is when you it is really cold and you really need heat they don’t work simply because there isn’t enough energy available. In addition, you are just shifting the problem onto the electric side.  Given that electric transmission is more susceptible to interruption than pipelines I think electrification is a less resilient option.

 The only positive that can be said about these no-infrastructure projects is that they are consistent with the Climate Leadership and Community Protection Act (CLCPA) expected infrastructure.  Unfortunately, we are guessing at what the state plans to do because they set targets without figuring out if they could be met much less how they would be met.  Moreover, I don’t think that the implementation timing for these kinds of projects will be consistent with timing for when the gap between demand and supply needs to be reduced.

National Grid points out that “Creating a comprehensive solution requires looking at how different options can work together to solve the gap between demand and supply”. Then they listed three possible approaches.  I was disappointed that they did not include the NESE pipeline large-scale infrastructure and the two distributed infrastructure pipeline projects as an option. I commented:

It did not get much attention in the documentation but the solution to the fact that current pipeline capacity cannot support today’s peak load demand is to truck compressed natural gas from somewhere on the other side of the supply constraint to somewhere on the inside of the supply constraint.  In my evaluation of the difference between pipeline and LNG infrastructure options I argued that the added safety and environmental effects of marine transport relative to pipelines made pipelines a superior choice.  However, the safety and environmental effects of trucks are greater than those of marine transport.  All three solutions rely on incremental Energy Efficiency, Demand Response, and Electrification to reduce demand and remove the need for CNG trucking. As a result, I could never support any of these solutions simply because it is likely that the need for CNG trucking will remain longer.

The first combined option, build out Large-Scale Infrastructure, capable of almost fully meeting projected needs claims that if construction is not completed before 2021/22, incremental Energy Efficiency (EE), Demand Response (DR) and Electrification would be required to reduce demand and meet customer needs. CNG trucking would be discontinued once the infrastructure is completed. Any shortfall in meeting demand reduction targets would lead to restrictions on new customer connections until the infrastructure is completed.  Incremental EE, DR and electrification won’t be implemented in this time frame – no way no how.

The second combined option, combine distributed infrastructure solutions with incremental No-Infrastructure solutions fails because all of them need to be implemented to meet projected gap so it will be necessary to combine one or two of these options with additional demand reductions achieved through EE, DR, and Electrification to fully meet needs. National Grid admits CNG trucking would remain in place unless demand reduction targets are exceeded, and any shortfall in meeting those targets would lead to restrictions on new customer connections.  Given that I think there is no way the demand reductions will be met CNG trucking remains in use for longer.

The final combined option, fully rely on a portfolio of incremental no- Infrastructure solutions, will undoubtedly be the preferred alternative of the energy innumerate and, thus the king of innumeracy Governor Cuomo.  Because it is unlikely that demand reduction targets will be exceeded, CNG trucking will remain in place, and any shortfall in meeting such demand reduction targets will lead to restrictions on new customer connections.  Somehow, someway when this fails to meet the needs, Cuomo will be the first to blame National Grid.

 Conclusion

National Grid states: “Our hope is that by helping our customers understand the possible approaches for addressing these concerns, they will provide feedback to help guide future decision making.”  Let me translate that for anyone unversed on current New York State energy policy.  National Grid is a business and in order to succeed financially they depend on a rate-making process that is entirely co-opted by the Cuomo Administration.  This report and the extensive outreach program, is a necessary part of doing business but it is just window dressing.  The ultimate decision will not be made to balance costs and risks against benefits to customers.  Whatever the facts say about energy reliability, effects on health, safety risks and costs, the final plan will be a politically driven decision made at the highest level of the Administration based on whatever is determined to best garner support from Cuomo’s political base.

This is another instance of Cuomo administration hypocrisy: on one hand basking in the limelight as a leader against climate change by prohibiting new fossil fuel infrastructure but on the other hand needlessly risking safety and increasing environmental impacts with an interim solution only intended for use as a stop gap in emergencies.  There are three pipeline alternatives that should be the clear choice as less risky, safer and minimal environmental impacts.  The other long-term infrastructure alternative solutions include several options that would continue to use more complicated and thus more risky approaches.  The obligatory no-fossil fuel infrastructure options could, in theory, provide enough energy needed to meet the design day criteria but two of the options (electrification and demand response) have never been implemented on the scale necessary and expecting to get even more energy efficiency reductions runs counter to observed results.  The question is whether the Cuomo administration will risk safety and reliability by requiring the use of those risky approaches to cater to people who will pay no price for being wrong.

Of course, the underlying argument that forms the basis of this entire charade is that climate change is an existential threat.  I believe that is a flawed argument.  New York’s politicians constantly claim that their energy policies have scientific support and they typically lean on the popular conception of an overwhelming consensus that the observed warming is necessarily bad.  In reality, most qualified scientists believe humans are causing some warming, but only a minority are very concerned about it.  The catastrophic impacts touted as proof that something needs to be done invariably rely on a future emission projection scenario that is so unlikely that it is inappropriate to use for policy decisions.  Finally, if the problem is global warming then it logically requires a global solution.  The reality is that New York’s possible impact on global warming reduction is too small to measure and would have effects that could not conceivably alter any of the purported catastrophic impacts.

 

The Futility of New York Energy Policy

A major theme of this blog is analysis of New York energy policy as it relates to climate change.  I have found that at the conclusion of every such post I am tempted to include an overview of my conclusions of the reality of the policy.  This post is a reference for three fatal flaws in the arguments used to justify those policies.

Background

I am a retired electric utility meteorologist with nearly 40 years experience analyzing the effects of meteorology on electric operations. I believe that gives me a relatively unique background to consider the potential quantitative effects of energy policies based on doing something about climate change.  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.

My biggest concern is that I am convinced that the general public has no idea what is going on with these energy policies and the possible ramifications.  My posts on New York energy policy are here.  I have described the reasons I think catastrophic anthropogenic climate change is unlikely  here and tried to explain to the layman why their direct experience should guide their opinion on global warming here. I have written a series of posts on the feasibility, implications and consequences of New York’s  Climate Leadership and Community Protection Act (CLCPA) which was described as the most ambitious and comprehensive climate and clean energy legislation in the country when it was passed.

The remainder of this post describes three fatal flaws that could be included in the conclusion of all of my posts on the CLCPA.

Fatal Flaws

New York State energy policy is based on the following: “climate change is a reality”, “our future is at stake”, and “That’s why New York State is committed to the most aggressive clean energy and climate agenda in the country”.  The presumption is that the 97% climate consensus that climate change is real means our future is at stake.  However, the consensus that matters is whether 97% of the scientists who have relevant background and experience are very worried about climate change.  A survey of members of the American Meteorological Society (AMS) showed that while two-thirds of those who responded believe humans are causing a majority of recent warming only 30% are very worried about it. Fully 40% of AMS members believe climate change impacts have been primarily beneficial or equally mixed between beneficial and harmful. Only 50% expect the impacts to be entirely or primarily harmful over the next 50 years. These results do not support the basis of massive changes to New York energy policy.

Further support of the rationale for committing to the “most aggressive clean energy and climate agenda in the country” is found in New York’s description of potential effects of climate change. The CLCPA notes that sea levels along New York’s coastlines are approximately one foot higher than they were in 1900.  The New York Department of Environmental Conservation adopted 6 NYCRR  Part 490, Projected sea-level rise projections for five probability categories ranging from low to high.  The problem is that the high-risk category projection of six feet rise by 2100 that garnered attention from the media is more properly labeled as virtually impossible.  In order to project future impacts, modelers have to simulate the climate changes due to greenhouse gas concentrations and project what those concentrations will be based on future emissions estimates. The problem is that the worst-case impacts rely on a future emissions scenario that was not intended to be plausible but it does make for the scary story needed to justify New York’s  “most aggressive” energy agenda.

Ultimately, however, the reality of climate change and future impacts does not matter if the proposed actions have no impact.  New York State started consideration of greenhouse gas reduction programs in 2003 when the discussions of the Regional Greenhouse Gas Initiative.  Since then there have been multipleregulations, rules and other initiatives but the State has never quantified how much of a global warming reduction could be expected as a result of their programs.  In April 2019 I calculated the effect of the CLCPA reduction of total elimination of New York’s 1990 218.1[1] million metric ton greenhouse gas emissions on projected global temperature rise.  I found there would be a reduction, or a “savings,” of approximately 0.0032°C by the year 2050 and 0.0067°C by the year 2100.  To give you an idea of how small this temperature change is consider changes with elevation and latitude.  Generally, temperature decreases three (3) degrees Fahrenheit for every 1,000-foot increase in elevation above sea level.  The projected temperature difference is the same as going down 27 inches.  The general rule is that temperature changes three (3) degrees Fahrenheit for every 300-mile change in latitude at an elevation of sea level.  The projected temperature change is the same as going south two thirds of a mile.

Conclusion

New York’s politicians constantly claim that their energy policies have scientific support and they typically lean on the popular conception of an overwhelming consensus that the observed warming is necessarily bad.  In reality most scientists believe humans are causing some warming, but only a minority are very concerned about it.  The catastrophic impacts touted as proof that something needs to be done invariably rely on a future emission projection scenario that is so unlikely that it is inappropriate to use for policy decisions.  Finally, if the problem is global warming then it logically requires a global solution.  The reality is that New York’s possible impact on global warming is too small to measure and would have effects that could not conceivably alter any of the purported catastrophic impacts.

The Public Service Commission has statutory obligations to ensure the provision of safe and adequate service at just and reasonable rates. Based on my work I believe that it is only a matter of time before it becomes obvious that New York’s virtue signaling energy policies will negatively affect that obligation in the form of higher rates and decreased reliability.  Until such time as the State proves they can provide reliable energy when and where it is needed relying primarily on renewable energy, we cannot even estimate costs.  This reckless endangerment of one of society’s necessities will end badly.

[1] This was the total for 2015 NYS emissions in NYSERDA Greenhouse Gas Inventory 1990-2015. Subsequent editions have lowered the most recent total so this is a conservative value for impacts.

Accelerated Energy Growth and Community Benefit Act: Additional Concerns

In the summer of 2019 Governor Cuomo and the New York State Legislature passed the Climate Leadership and Community Protection Act (CLCPA) which was described as the most ambitious and comprehensive climate and clean energy legislation in the country when Cuomo signed the legislation.  In early April 2020, NYS passed the Accelerated Renewable Energy Growth and Community Benefit Act (AREGCBA) as part of the 2020-21 state budget.  This legislation is intended to ensure that renewable generation is sited in a timely and cost-effective manner.  When this was proposed I posted an essay describing the hypocrisy and over-reach aspects and recently published another post showing why there are significant risks to the electric system.  This post addresses other concerns including logistics, permitting differences with existing regulations, and environmental impact assessments

 Background

I refer you to the previous post’s background description for an overview of the legislation but I will note that the legislation was incorporated into the 2020-21 New York State budget by Governor Cuomo despite the fact that it might have been more appropriate to concentrate on the financial implications of the coronavirus pandemic.   Worse, it included tight deadlines at the time it was approved when it was obvious that the State was pretty much in a holding pattern for an indefinite amount of time.  It would have been far better to postpone this legislation so that it could be properly vetted and a reasonable schedule developed.

In order to introduce my other concerns, I will repeat my description of section 4 from § 2. Legislative findings and statement of purpose.  I copied section 4 of the legislation and inserted my comments in italics.

  1. A public policy purpose would be served and the interests of the people of the state would be advanced by:

(a) expediting the regulatory review for the siting of major renewable energy facilities and transmission infrastructure necessary to meet the CLCPA targets, in recognition of the importance of these facilities and their ability to lower carbon emissions;

Article 10 Law currently requires “environmental and public health impact analyses, studies regarding environmental justice and public safety, and consideration of local laws” but those requirements take time to evaluate.

(b) making available to developers of clean generation resources build-ready sites for the construction and operation of such renewable energy facilities;

In my opinion if the CLCPA and AREGCBA laws had been written such that the plans were developed first it would have been more protective for New Yorkers.  In that approach the State would fulfill all the Article 10 requirements as part of the “build-ready sites” approach.

(c) developing uniform permit standards and conditions that are applicable to classes and categories of renewable energy facilities, that reflect the environmental benefits of such facilities and address common conditions necessary to minimize impacts to the surrounding community and environment;

I have reviewed all the Article 10 solar applications and there is no question that uniform permit standards and common conditions could be addressed by a comprehensive planning approach.

(d) providing for workforce training, especially in disadvantaged communities;

This is a transparent effort to develop support from a political base.

(e) implementing one or more programs to provide benefits to owners of land and communities where renewable energy facilities and transmission infrastructure would be sited;

This is political payola.  It is a bribe given in exchange for accepting any negative consequences of the renewable energy facilities.

(f) incentivizing the re-use or adaptation of sites with existing or abandoned commercial or industrial uses, such as brownfields, landfills, dormant electric generating sites and former commercial or industrial sites, for the development of major renewable energy facilities and to restore and protect the value of taxable land and leverage existing resources; and

This is a noble gesture.  Without question it is a nice idea to re-use or adapt unused sites but the fact is that those sites are small relative to the areal needs of diffuse wind and solar power production.

(g) implementing the state’s policy to protect, conserve and recover endangered and threatened species while establishing additional mechanisms to facilitate the achievement of a net conservation benefit to endangered or threatened species which may be impacted by the construction or operation of major renewable energy facilities.

This is window dressing designed to appear to address environmental issues when in fact it falls far short of environmental protections.  I will discuss this aspect of the legislation below.

Logistical Concerns

The revised permitting process for AREGCBA sets up a new bureaucracy to handle permitting.  The Office of Renewable Energy Siting (ORES) responsibilities will be established in the Department of State and charged with “accepting applications and evaluating, issuing, amending, approving the assignment and/or transfer of siting permits.”  Within one year the Office is supposed to “establish a set of uniform standards and conditions for the siting, design, construction and operation of each type of major renewable energy facility relevant to issues that are common for particular classes and categories of major renewable energy facilities”.  The goal is to “minimize or mitigate potential adverse environmental impacts”.  Also, within one year, ORES will “promulgate rules and regulations with respect to all necessary requirements to implement the siting permit program established in this section and promulgate modifications to such rules and regulations as it deems necessary”.

With all due respect to the authors of this legislation, implementing those requirements within one year is an overly ambitious goal.  In the first place, the Depart of State has limited existing staff for environmental issues.  The Department of Environmental Conservation, Department of Public Service, Department of Agriculture and Markets, and New York State Energy and Research Development Authority do have staff who support renewable energy development project permitting already.  There is language in the legislation stating that ORES can request support and services from those agencies and language addressing personnel transfers.  The relevant staff in those agencies are already working on projects, so what happens to projects already in the Article Ten queue?  I would not be surprised if there are staff within the agencies who support permit applications for a variety of projects not just renewable energy so what happens to other permit applications?  Consequently, if ORES just commandeers staff for this requirement other agency commitments will suffer.

In the second place, developing uniform standards for siting, design, construction, and operation is going to take time to draft, review and present.  Converting those to rules and regulations also will take time to prepare and the staff with the most experience in this regard have permitting obligations.  Importantly, there are New York Administrative Procedure Act requirements for adopting rules that include the opportunity for public involvement and specific schedule obligations.  All these factors suggest that it is unlikely that all this can be completed within one year.  Once the effects of the coronavirus pandemic are factored in, I am comfortable saying this cannot be implemented on the timeframe legislated.

Permitting Differences

New York’s Article Ten process was enacted during the days when regulated utilities proposed all the major electric generating station developments.  In its original form it was very unwieldly, time-consuming and required enormous resources to complete.  When de-regulation came along and the state realized that they would have to deal with non-regulated generating companies they revised the Article 10 process hoping to streamline its onerous provisions.  To some extent the 2011 revisions made improvements but the fact it that permitting still takes a minimum of over three years and often much more.

The Article Ten Environmental Assessment Form describes the Part 1001 requirements that specify what information is needed in applications to allow the Siting Board to make permit application findings and determinations.  The Article Ten application contains sections specifying general application requirements and exhibits concerning overview and public involvement, location of facilities, land use, electric system effects, wind, natural gas and nuclear power facilities, electric system production modeling, alternatives, consistency with energy planning objectives, preliminary design drawings, construction, real property, cost of facilities, public health and safety, pollution control facilities, air pollutant emissions, safety and security, noise and vibration, cultural resources, geology, seismology and soils, terrestrial ecology and wetlands, water resources and aquatic ecology, visual impacts, effects on transportation and communications, socioeconomic effects, environmental justice, site restoration and decommissioning, state and local laws and ordinances, other filings, electric, gas, water, wastewater and telecommunications interconnections, electric and magnetic fields, back-up fuel, and applications to modify or build adjacent to existing facilities.

One of the first things the ORES will have to do is to specify what information is needed for its application process.  There is no question that there are some topics in the Article 10 applications do not need to be included for renewable energy projects but the reality is that the Article 10 applications are not being held up much by addressing those topics.

In order to reduce permitting time, the AREGCBA’s biggest apparent difference is to eliminate the extensive public outreach components of Article 10 permits.  The Public Involvement Program and Scoping Statement components are the first two steps in the Article 10 permit process.  They include timing requirements that mandate eight months before the permit application can be submitted.  As far as I can tell there is nothing equivalent in the AREGCBA.  The public’s first inkling of a project under AREGCBA is not clear by my reading.  Once the application is received the law states the permit cannot be considered complete “without proof of consultation with the municipality or political subdivision where the project is proposed to be located”.  Once it is considered complete then there is a 60-day comment period.  Without some sort of legal requirement, the general public may only find out about a project that affects them when the 60-day comment period starts.

Article 10 applications are reviewed and approved by a siting board made up of seven people including two local community members.  AREGCBA decisions are made by the Executive Director of ORES.  Cynics like me suspect that the new law makes it easier for the Cuomo administration to control the outcome by reducing the number of people needed to approve a project.

Article 10 requires public notification and scoping statements be prepared with plenty of time for the public to get involved.  Both Article 10 and AREGCBA include provisions to give money for intervenors but finding out about a project, figuring out who and what needs to be addressed, hiring someone to do the evaluation and then getting it done in time to make substantive comments all within the 60 day permit period is ambitious at best and more likely impossible.  In fact, it is such an unrealistic schedule that I suspect that it was included to deliberately forestall local resistance to renewable energy projects.

Another major difference between Article 10 and AREGCBA is that there are no provisions in Article 10 to over-ride local ordinances limiting or prohibiting renewable energy developments.  The Cuomo Administration has already modified the Article 10 rules to forestall a township or county passing an ordinance limiting renewable developments during the Article 10 process.  AREGCBA goes much further stating that when making the final permit decision ORES “may elect not to apply, in whole or in part, any local law or ordinance which would otherwise be applicable if it makes a finding that, as applied to the proposed major renewable energy facility, it is unreasonably burdensome in view of the CLCPA targets and the environmental benefits of the proposed major renewable energy facility”.  It is not hard to read between the lines of that statement to see that Cuomo’s law ensures that renewable energy developments are going to be built whatever the locals think. The Article 10 process is so long that affected communities have replaced elected officials that supported projects with those who opposed them.  Clearly the AREGCBA schedule prevents that from happening.

The hubris of politicians never ceases to amaze me.  In order to make the locals happy the law includes what can only be described as a bribe.  The legislation specifies that “The final siting permit shall include a provision requiring the permittee to “provide a host community benefit, which may be a host community benefit as determined by the public service commission pursuant to section eight of the chapter of the laws of two thousand twenty that added this section or such other project as determined by the office or as subsequently agreed to between the applicant and the host community”. Another changes states that “The public service commission shall, within 60 days from the effective date hereof, commence a proceeding to establish a program under which renewable owners would fund a program to provide a discount or credit on the utility bills of the utility’s customers in a renewable host community, or a compensatory or environmental benefit to such customers.”  The affected locals lose their community character, have their housing values reduced and, depending on what the uniform standards are, could have adverse health effects but not to worry here is a community benefit project.

Environmental Concerns

I have been doing environmental assessments for over 40 years and really worry about the environmental impacts of the CLCPA because there is no commitment to evaluate the cumulative impacts.  As far as I can tell the State Administrative Procedure Act (SAPA) and the State Environmental Quality Review Act (SEQRA) requirements for environmental reviews do not apply to it because it is a legislative action. Up to this point Article 10 did at least require extensive “environmental and public health impact analyses, studies regarding environmental justice and public safety, and consideration of local laws” so at least the local impacts were thoroughly evaluated.  The AREGCBA legislation sets up an entirely new permitting process for renewable energy and it is not clear how environmental impacts will be handled in the new system.  It all depends on the uniform standards developed by ORES in the first year.

The problem proponents of renewable energy have with the Article 10 process is that it takes time.  When Article 10 was revised in 2011, the politicians thought that they were going to streamline the complete process down to a few years. The environmental staff people in the agencies and industries agreed at the time that it was still going to take four to five years to complete an application.  As of March 17, 2020, six projects have had their applications approved taking between 3.2 and 4.5 years since the first filing in the process.

Those completion times are from the first formal submittal in the Article 10 regulatory process.  When a developer starts to evaluate a site for a renewable development a lot of work has to be done to assess the local impacts by mapping and evaluating the property.  The plan has to be drafted, reviewed and submitted in order to start the clock. There is no way to speed those preliminary steps up.  The revised AREGCBA permitting requirements may eliminate some of the Article Ten considerations described below but many will remain so I estimate at least nine months and more like twelve months will be needed to develop that information.  For Article Ten projects that means that from the time a developer starts a project you are talking at least 4 to 5 years to have all the necessary permits to start construction.  Apparently AREGCBA hopes to cut that time mostly be reducing the public involvement requirements.  At a time when the State is emphasizing environmental justice concerns it is odd that this regulation ignores public involvement.  Cynics like me suspect that rural EJ communities don’t matter.

I argued in my more recent post on AREGCBA that a feasibility study was necessary to see if the CLCPA targets are realistic and affordable.  It may be possible to argue that on an individual basis industrial wind and solar facilities may not have acceptable unavoidable environmental impacts.  However, the cumulative impact of all the facilities required by the CLCPA to provide enough power to meet the reliability needs of the state could have unacceptable unavoidable environmental impacts. I estimated the resources needed for a load estimate from the Citizen’s Budget Commission with wind and solar output estimates based on meteorological data from January 3-4 2018 and found that New York would have to build 11,395 MW of residential solar, 16,117 MW of utility-scale solar, 18,457 MW of on-shore wind and 16,363 MW of off-shore wind to meet the increased load needed for the CLCPA targets. I made assumptions about sizes of turbines and solar arrays and estimate that those facilities would require over 3,845 on-shore wind turbines and 176 square miles of solar arrays.

The bottom line is that the massive areal extent of the renewable energy resources needed for the CLCPA obviously needs a cumulative environmental impact analysis to determine how the law will affect the environment.  Instead the AREGCBA legislates a plan to implement “the state’s policy to protect, conserve and recover endangered and threatened species while establishing additional mechanisms to facilitate the achievement of a net conservation benefit to endangered or threatened species which may be impacted by the construction or operation of major renewable energy facilities”.

In the long list of Cuomo’s hypocritical environmental policies this may be the topper.  There is no question that there is value for net conservation benefits.  For example, if an acre of a wetland is impacted, then the applicant could restore, create or enhance more wetland acreage nearby for a net environmental benefit.  The Cuomo administration has a consistent record of ignoring the possibility of this approach where it is inconvenient for their rationale to reject an application (e.g., any of the pipeline applications rejected in his tenure).  While this may be appropriate for affected wetlands at renewable facilities the real concern with blanketing the state with wind turbines is the effect on endangered or threatened avian species.  What in the world could be proposed as a net benefit for incidental slaughter of birds and bats at any wind turbine?

It gets even worse.  The AREGCBA states that: “To the extent that environmental impacts are not completely addressed by uniform standards and conditions and site-specific permit conditions proposed by the office, and the office determines that mitigation of such impacts may be achieved by off-site mitigation, the office may require payment of a fee by the applicant to achieve such off-site mitigation.” So where does this money go? The legislation includes an amendment to environmental conservation law establishing the endangered and threatened species mitigation bank fund.  The fund may pay for contracts with not-for-profit corporations, private or public universities, and private contractors for mitigation services and may “enter into contracts with a not-for-profit corporation to administer grants made pursuant to this title, including the approval and payment of vouchers for approved contracts.”  Gee, do you think there is any chance that this will enable Cuomo to fund his environmental base.

Conclusion

I subscribe to Politico’s daily New York Energy newsletter.  In the April 6, 2020 edition the New York League of Conservation Voters sponsored the following message supporting AREGCBA:

“A broad coalition of environmental, clean energy, real estate and labor groups applaud Governor Cuomo, Majority Leader Stewart-Cousins and Speaker Heastie for including critically needed renewable energy siting and transmission reform in the State Budget that will support New York’s ambitious climate goals and economic development across the state! Learn more.

The learn more link includes the statement “The improved siting process for renewable energy projects will help New York to achieve 70 percent renewable electricity by 2030, as required by NY’s 2019 climate law, and maintain New York’s strong environmental and public participation standards.”  It is not clear to me what they read that gave them assurances that public participation will not be endangered by this regulation but the knowledge that there is a pot of money out there for the environmental non-profits sure gives incentive for their rationale to support this law.

I understand the desire to revise the Article 10 process to handle the upcoming surge of renewable energy projects necessary to implement the CLCPA but believe this should have been addressed differently.  New York State’s budget process has never been a template for good governance because decisions are made by very few players and this March would have been an appropriate time to concentrate on the financial implications of the coronavirus pandemic.   Instead, Cuomo jammed this legislation into the budget package making it difficult for the assembly or senate to discuss, much less object, to any needed reforms to Article 10 for renewable energy projects.  It is very disappointing that there is a broad coalition of groups that think this was a good idea.

It remains to be seen how the uniform standards will play out.  Will there be adequate protections for environmental impacts, local community character, property values, and health impacts?  Another aspect is community involvement.  Article 10 had eight months for public involvement before the permit application was submitted.  There is no specification for local community involvement in the legislation.

This legislation includes two mitigation stipulations: community benefits and the endangered species mitigation bank fund.  Cynics like me suspect this more about payola than mitigating impacts.  Ultimately, I cannot see how anyone can support the CLCPA and AREGCBA legislation without a feasibility study and cumulative environmental impact analysis.

Finally, ORES “may elect not to apply, in whole or in part, any local law or ordinance which would otherwise be applicable if it makes a finding that, as applied to the proposed major renewable energy facility, it is unreasonably burdensome in view of the CLCPA targets and the environmental benefits of the proposed major renewable energy facility”.  This provision runs rough shod over home rule provisions of rural Upstate communities.  The rationale for the CLCPA targets is the climate emergency.  Is it too much for the State to quantify how their programs will affect global warming?  It has never been done by New York State.  When I calculated the effect of the CLCPA reduction of 218.1[1] million metric tons on projected global temperature rise I found there would be a reduction, or a “savings,” of approximately 0.0032°C by the year 2050 and 0.0067°C by the year 2100.  You cannot measure and therefore you cannot expect any effect on any of the purported impacts of climate change.  Based on my analyses to date these laws recklessly endanger electric reliability and the environment in the name of virtue-signaling climate “leadership”.

[1] This was the total for 2015 NYS emissions in NYSERDA Greenhouse Gas Inventory 1990-2015. Subsequent editions have lowered the most recent total so this is a conservative value for impacts.

Accelerated Energy Growth and Community Benefit Act: Electric System Concerns

In the summer of 2019 Governor Cuomo and the New York State Legislature passed the Climate Leadership and Community Protection Act (CLCPA) which was described as the most ambitious and comprehensive climate and clean energy legislation in the country when Cuomo signed the legislation.  In early April 2020, NYS passed the Accelerated Renewable Energy Growth and Community Benefit Act (AREGCBA) as part of the 2020-21 state budget.  This legislation is intended to ensure that renewable generation is sited in a timely and cost-effective manner.   It is best described by a knowledgeable friend as “Once again the idiots in Albany have proven they are willing to dive from the high board without looking to see if there is any water in the pool.”  When this was proposed I posted an essay describing the hypocrisy and over-reach aspects.  This post show why there are significant risks to the electric system.  I will follow up with a post addressing the other problems associated with these laws.

Background

The AREGCBA legislation states that the CLCPA targets “shall mean the public policies established in the climate leadership and community protection act enacted in chapter one hundred six of the laws of 2019, including the requirement that a minimum of seventy percent of the statewide electric generation be produced by renewable energy systems by 2030, that by the year 2040 the statewide electrical demand system will generate zero emissions and the procurement of at least nine gigawatts of offshore wind electricity generation by 2035, six gigawatts of photovoltaic solar generation by 2025 and to support three gigawatts of statewide energy storage capacity by 2030”.

Unfortunately, the politicians that passed this law never bothered to figure out how it could be done.  Prudence would have been to do a study to determine what was feasible and then set the targets. Instead, the legislation sets up a Climate Action Council with the charge to prepare and approve a draft scoping plan “outlining the recommendations for attaining the statewide greenhouse gas emissions limits” within two years of the effective date of the legislation.  One year later, the council shall submit the final scoping plan to the governor, the speaker of the assembly and the temporary president of the senate and post such plan on its website.  I have written a series of posts on the feasibility risks, implications and some of the costs of the CLCPA that provides more details on the law.

The Accelerated Renewable Energy Growth and Community Benefit Act is Cuomo’s legislation and the unintended consequences will be his fault.  On February 21, 2020 he announced “he is advancing a 30-day budget amendment to dramatically speed up the permitting and construction of renewable energy projects, combat climate change and grow the state’s green economy. If adopted, the Accelerated Renewable Energy Growth and Community Benefit Act will create a new Office of Renewable Energy Permitting to improve and streamline the process for environmentally responsible and cost-effective siting of large-scale renewable energy projects across New York while delivering significant benefits to local communities.”  New York State’s budget process has never been a template for good governance and this March would have been an appropriate time to concentrate on the financial implications of the coronavirus pandemic.   Instead, Cuomo jammed this legislation into the budget package making it difficult for the assembly or senate to discuss, much less object.

2. Legislative findings and statement of purpose

I have copied section 4 of this chapter of the legislation and inserted my comments in italics.  My over-riding problem with the CLCPA is that there is no plan.  The AREGCBA legislation compounds the problem by removing the evaluation of community impacts constraints.

    1. A public policy purpose would be served and the interests of the people of the state would be advanced by:

(a) expediting the regulatory review for the siting of major renewable energy facilities and transmission infrastructure necessary to meet the CLCPA targets, in recognition of the importance of these facilities and their ability to lower carbon emissions;

Article 10 Law currently requires “environmental and public health impact analyses, studies regarding environmental justice and public safety, and consideration of local laws” but those requirements take time to evaluate and it appears this legislation over-rides the time needed for those analyses.

(b) making available to developers of clean generation resources build-ready sites for the construction and operation of such renewable energy facilities;

In my opinion if the CLCPA and AREGCBA laws had been written such that the plans were developed first it would have been more protective for New Yorkers.  In that approach the State would fulfill all the Article 10 requirements as part of the “build-ready sites” approach.  It is possible that is the intent of this part of the rule but there will be more sites needed then those which are incentivized by section (f) below. 

(c) developing uniform permit standards and conditions that are applicable to classes and categories of renewable energy facilities, that reflect the environmental benefits of such facilities and address common conditions necessary to minimize impacts to the surrounding community and environment;

I have reviewed all the Article 10 solar applications and there is no question that uniform permit standards and common conditions could be addressed by a comprehensive planning approach. 

(d) providing for workforce training, especially in disadvantaged communities;

This is a transparent effort to develop support from a specific voting bloc.

(e) implementing one or more programs to provide benefits to owners of land and communities where renewable energy facilities and transmission infrastructure would be sited;

This is political payola.  It is a bribe given in exchange for accepting any negative consequences of the renewable energy facilities.

(f) incentivizing the re-use or adaptation of sites with existing or abandoned commercial or industrial uses, such as brownfields, landfills, dormant electric generating sites and former commercial or industrial sites, for the development of major renewable energy facilities and to restore and protect the value of taxable land and leverage existing resources; and

This is a noble gesture.  Without question it is a nice idea to re-use or adapt unused sites but the fact is that those sites are small relative to the areal needs of diffuse wind and solar power production required by the CLCPA.

(g) implementing the state’s policy to protect, conserve and recover endangered and threatened species while establishing additional mechanisms to facilitate the achievement of a net conservation benefit to endangered or threatened species which may be impacted by the construction or operation of major renewable energy facilities.

In the long list of Cuomo’s hypocritical environmental policies this may be the topper.  There is no question that there is value for net conservation benefits.  For example, if an acre of a wetland is impacted, then the applicant could restore, create or enhance more wetland acreage nearby for a net environmental benefit.  The Cuomo administration has a consistent record of ignoring the possibility of this approach where it is inconvenient for their rationale to reject an application (e.g., any of the pipeline applications rejected in his tenure).  While this may be appropriate for affected wetlands at renewable facilities the real concern with blanketing the state with wind turbines is the effect on endangered or threatened avian species.  What in the world could be proposed as a net benefit for incidental slaughter of birds and bats at any wind turbine? 

Electric System Concerns

The politicians that enacted CLCPA made a major mistake putting the cart (the aggressive targets) before the horse (figuring out what was feasible).  The draft scoping plan outlining attainment recommendations will not be approved until June 2021 and the final version will not be presented to the Governor, Assembly and Senate for another year.   The crony capitalists, environmental activists, and all the others who stand to gain from this ambitious plan have conned the legislators and Governor into believing that meeting the targets is simply a matter of political will but as I show below that is not the case.

I worry about the costs of the CLCPA because jurisdictions that are attempting similar GHG reductions have seen higher costs. Renewable energy supporters claim solar and wind are cheaper than conventional power plants but that is only the cost of the facility.  The problem is the cost of the generator does not include the cost to get the power to where it is needed when it is needed.  I evaluated one example of Cuomo’s renewable energy promises: freeing the state fairgrounds of fossil fuels.  One advocate claimed “solar is doable” and that “the 9 million kilowatt hours the fair used in 2018-2019 could be supplied by a 45-acre solar array and that would cost about $12 million to build”.  In my post I calculated what would be needed to provide all the electric power needed during the ten days the fair is open.  In my cheapest scenario I estimate that the solar array has to be at least twice as large, a wind farm with ten 2.5 MW wind turbines has to be added to reduce energy storage requirements and that you would still need an energy storage array totaling 43 MWh.  I have not evaluated the costs of solar and wind but have looked into the costs of Li-Ion batteries for energy storage.  Using National Renewable Energy Laboratory information, I estimate that the cost of just battery backup would be $17 million.  Assuming that a wind farm is a comparable cost to the 45-acre solar array and doubling the size of the array, the crude cost is $53 million.  Of course, with no detailed plan we have no idea of the cost of the CLCPA.

But it not just a question of cost but also of feasibility.  The State needs to show how many wind turbines, solar panels and energy storage systems will be needed when we most need power.  The only way to do that is to determine the availability of wind and solar based on historical meteorological data.  Done properly the study should look at hourly solar insolation, snow cover, and wind speed meteorological records across the state.  The other component is expected load.  In order to meet all the CLCPA targets the heating and transportation sectors will have to be electrified and that means that the future load peak will be in the winter.  The over-riding feasibility problem is what resources will be needed to cover a winter peak when solar resources are low.  I estimated the resources needed for a load estimate from the Citizen’s Budget Commission with wind and solar output estimates based on meteorological data from January 3-4 2018 and found that New York would have to build 11,395 MW of residential solar, 16,117 MW of utility-scale solar, 18,457 MW of on-shore wind and 16,363 MW of off-shore wind to meet the increased load needed for the CLCPA targets.  For the example winter peak period I showed that the light winds at night would require 150,000 MWh of energy storage and using National Renewable Energy Lab information showed that energy storage alone could cost $176 billion by 2050.

There is another feasibility problem.  Wind and solar are diffuse and chaotically intermittent.  Because they are diffuse the transmission system is needed but because they are so intermittent the transmission system has to be modified.  Conventional fossil-fuel fired, nuclear, and hydro units generate relatively stable power.  Wind and solar units provide variable power generation so resources also have to be developed to handle grid balancing services.  No major electric system has even come close to the targets in the CLCPA but transmission problems have shown up where renewable energy input is about half of the total such as South Australia.  Battery storage such as LI-ion batteries can provide these services in theory but no where has any system near the size of New York demonstrated the practicality of such a system.  Again, because there is no plan, we have no idea of the added costs of this necessary component of the future CLCPA electric energy system.

Even if a study shows it is feasible what about resiliency?  Coal is no longer burned to generate electricity in New York and residual oil is discouraged but both fuels could be stored on-site making them more resilient sources of power.  I recently showed that a 9” snowstorm blocked all the power output from a solar facility for four days.  When the CLCPA target of 6 GW of solar PV is implemented and we have a similar snowstorm to the March 12-14 superstorm that covered the state with 10” of snow, how can the electrical needs be met with no solar generation.  Even worse, what happens when an ice storm takes the power out to a city when residents completely depend on electric heat?  The ultimate resiliency question is how can New York City possibly meet its requirements for in-city generation using diffuse renewables.  Failure to meet those specifications raises the possibility of a New York City blackout.

There also are worrying issues with the environmental aspects.  In order to do justice to those topics I am going to follow up with another post.

Conclusion

The New York electric system is part of one of the largest and most effective machines in the world.  It produces affordable reliable electricity when and where it is needed.  However, the popular conception of the grid is that for all of its complexity and acknowledged past success it is outdated.  Enter the “Smart Grid” to solve all the problems.  According to SmartGrid.gov, “the Smart Grid will consist of controls, computers, automation, and new technologies and equipment working together, but in this case, these technologies will work with the electrical grid to respond digitally to our quickly changing electric demand.“  They also say that “The Smart Grid represents an unprecedented opportunity to move the energy industry into a new era of reliability, availability, and efficiency that will contribute to our economic and environmental health.”  I believe that the underlying impetus is “environmental health”.  The only way to integrate renewable technology is the smart grid and everyone knows that we need renewables to save the planet.

New York State energy policy is on board with the Smart Grid and it has been sold to the gullible and innumerate as a simple, cheaper solution.  Cynics like me say if it is so good then the market should choose it as the preferred alternative.  Instead we get laws like CLCPA with its ambitious targets and the AREGCBA with its rushed incentives to build renewable technology.  As I have shown there is no New York plan to implement this technology and serious technological issues to address.  All we are left with are hollow promises and vague reassurances from the politicians.  Until we have a plan that includes costs and environmental impacts these laws should be put on hold if not repealed altogether.  The problem with the idiots in Albany diving from the high board without looking to see if there is any water in the pool is that they will take the reliable and affordable electric system crashing down with them.

Another Solar Power Issue in Upstate New York

I have calculated how much solar and wind power might be available based on meteorological data for several scenarios.  I discovered another complication that I had not previously included in my analyses that is the subject of this post.  In particular, the effect of snow cover on solar output.

Background

I have analyzed the potential solar generation output that can be expected from facilities in New York based on incoming solar radiation.  In comments that I submitted on the New York Department of Public Services resource adequacy proceeding I prepared a white paper that provides an initial estimate of the likely energy storage component requirement based on historical meteorological data and developed an example of potential problems with air source heat pumps.  Based on that work, my primary concern is that New York State has not done a feasibility study to determine whether the solar and wind resources in the winter are sufficient to provide enough power when the heating sector is electrified.

Obviously if solar panels are covered with snow the generation output will be reduced but I had never quantified the impact.  The New York State Energy and Research Development Authority (NYSERDA) has an integrated data system that provides operational data on Distributed Energy Resources installed in New York.  During the research for a  previous post on this system I downloaded solar output data for the Howland Solar project in Sandy Creek, NY for the winter of 2020 and found data that could be used to estimate the effect of snow cover.

The following graph shows solar output data for the Howland Solar project in Sandy Creek, NY for the winter of 2020.  This site is located east of Lake Ontario in the heart of its lake-effect snow belt.

The thing that caught my eye were four periods when the daily average electricity generated was zero. In this analysis I will focus on the period near December 23. As shown in the next graph data from 16 December through 22 December indicate there was zero solar generation on five consecutive days.

The NYS mesonet has a monitoring station located close to this solar facility at Belleville. The following 7-day meteogram for this site shows that there was a snowstorm during this period. Note that the time scale in these graphs is for UTC time so they differ from the local time by five hours.

Although it is hard to see, the gold trace in the upper left graph is solar insolation. That graph also lists temperature which was below freezing throughout the period. The dark green line in the lower left graph is cumulative precipitation. On the graph it starts between 16/23 and 17/23 but because of the UTC times the onset was much closer to the start of December 17. Note that at the time when the total precipitation increased the most that the sonic wind speed and gusts (black and blue) in the upper right graph also peaked and that the wind direction was WNW as shown in the lower right graph. Those conditions are the classic signature of a lake-effect snow event.

The Buffalo National Weather Service office archives lake-effect snowfall maps for all big events. The map for this period confirms that this was a lake-effect event. The solar facility and the mesonet station are located just north of Pulaski at the eastern end of Lake Ontario squarely in the area that got at least 7″ of snowfall.

The Problem

The following temperature and solar radiation meteogram graph for 20 December shows the solar radiation more clearly than in the seven day. I have not found a better daily solar insolation curve to date. There is no indication (squiggles on the curve) of any variation of intensity other than diurnal sun angle. There could not have been a single cloud that day. The key point is that the temperature struggled to get up to 10 degrees F that day so there would have been high energy demand for heating at the same time .

So how much electric generation did the Howland solar installation provide to the grid that day? There were two hours of 1 kW, two hours of 4kW and two hours of 6 kW for a daily total output of 22 kWh. I checked my usage for that period and I used a total of 766 kWh for a daily average just under the total output of this facility. Importantly I do not use electricity for heating, cooking or hot water.

 Conclusion

Clearly, it is not enough to just look at meteorological conditions to determine the potential worst case for solar power generation output.  Intuitively it is obvious that snow will cover solar panels and the output will be reduced.  This post demonstrates that for a 7” snowfall one solar facility output went to zero for four consecutive days.  I expect that any solar facility with a similar panel configuration located inside the seven-inch contour of the lake effect snow summary map would be similarly affected.

Weather maps for December 17-19 2019 show one typical winter storm scenario for New York.  On 17 December the first snow falls when a storm system goes up the coast.  When this happens snowfall is widespread but higher closer to the coast. 

On 18 December the storm system heads off to the north and east and as it does it draws colder air down from the north.  Oftentimes like in this period, lake effect snow bands develop with smaller areal extent but more snowfall. 

Finally, the cold air settles in behind the storm and lake-effect event, albeit not shown well in the 19 December map.

The future energy system ramification of this is important.  As shown here snow cover can eliminate solar generation output.  It is important to consider what will happen when there is a really big snowstorm that blankets New York with 7” of snow, followed by a lake-effect event that covers the usual lake effect areas with even more, and ends with a really cold day caused by a high pressure system.  Now you are talking about no solar output and reduced wind output at the same time electric loads will be high due to heating electrification.  The data shown here suggest that the no solar output situation can last for days. 

Until such time that New York State shows that they have a plan to address this worst-case situation I believe we could end up with people freezing to death in the dark.