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

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

I am a retired electric utility meteorologist with nearly 40 years-experience analyzing the effects of meteorology on electric operations.  I have been involved with peaking power plants in particular for over 20 years both from a compliance reporting standpoint and also evaluation of impacts and options for these sources.  This background served me well analyzing this issue.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Overview of the New York Pollution Justice Act of 2021

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

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

Background

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

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

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

Statement of Findings

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Implementation

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

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

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

Conclusion

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

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

 

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

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

I have written extensively on implementation of the CLCPA closely because its implementation affects my future as a New Yorker.  I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulations, listed the scoping plan strategies, summarized some of the meetings and complained that its advocates constantly confuse weather and climate.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Texas Energy Debacle

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

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

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

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

Ultimate Problem

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

Climate Change Impact and Resilience Study

According to the report:

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

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

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

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

NY LOLE planning

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

The RNA document explains that:

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

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

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

Climate Change Impact and Resilience Study Loss of Load Occurrences

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

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

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

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

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

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

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

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

Conclusion

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

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

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

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

2020 76West Clean Energy Competition Winners

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

I follow New York energy policy closely because its implementation affects my future as a New Yorker.  I am not sure that the reliability and affordability of the electric system can be maintained under the Cuomo administration.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

76West Clean Energy Competition

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

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

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

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

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

76West Awards

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

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

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

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

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

Funding

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

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

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

Conclusion

Governor Cuomo has said:

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

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

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

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

 

NYISO Climate Change Impact Studies

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

I have two degrees in meteorology, am a retired certified consulting meteorologist accredited by the American Meteorology Society, have over 45 years experience as a practicing meteorologist, and have been working in the electric utility business since 1981.  The contents of this post are based on that background and experience.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

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

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

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

Climate Change

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

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

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

Analysis Group Renewable Resource Approach

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

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

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

According to the final report:

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

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

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

“Heat waves are modeled using the following model adjustments:

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

Cold waves are modeled using the following model adjustments:

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

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

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

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

Winter wind lulls are modeled using the following model adjustments:

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

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

Critique

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

According to the Analysis Group final report

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

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

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

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

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

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

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

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

 Conclusion

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

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

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

Climate Leadership and Community Protection Act Kick-Start the Economy

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

I am following the implementation of the Climate Act closely because its implementation affects my future as a New Yorker.  Given the cost impacts for other jurisdictions that have implemented renewable energy resources to meet targets at much less stringent levels, I am convinced that the costs in New York will be enormous and my analyses have supported that concern.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Problems with a Green Energy Kick-Start

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Conclusion

Tverberg concludes:

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

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

Media Coverage of Clean Energy

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

Background

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

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

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

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

Energy Foundation

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

The following is their vision statement:

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

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

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

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

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

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

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

Conclusion

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

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

NY Climate Act Implementation – Electric Generation De-Carbonization Pathways

On July 18, 2019, Governor Cuomo signed into law the Climate Leadership and Community Protection Act (Climate Act). It is among the most ambitious climate laws in the world and requires New York to reduce economy-wide greenhouse gas emissions 40 percent by 2030 and eliminate the use of fossil fuel for electricity production by 2040. New York’s politicians were sure that implementing these goals was simply a matter of political will so they offered no plan how it would be done.  On June 24, 2020 Energy plus Environmental Economics (E3) presented results of their emissions reductions pathway analyses to the New York Climate Action Council which gives the first inkling of what the law may suggest will be done.  This post analyzes the electric generation analysis approach.

I am following the implementation of the CLCPA closely because its implementation affects my future as a New Yorker.  Given the cost impacts for other jurisdictions that have implemented renewable energy resources to meet targets at much less stringent levels I am convinced that the costs in New York will be enormous and my analyses have supported that concern.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

I did a post on the Pathways to Deep Decarbonization in New York State Presentation  that can be viewed on the video of the webinar.  The Pathways to Deep Decarbonization in New York State – Final Report  itself and two appendices: Appendix A: Methods and Data  and Appendix B: Literature Review of Economy-Wide Deep Decarbonization and Highly Renewable Energy Systems  were included in the meeting materials.  This post addresses electric generation in the final report and Appendix A.

E3 Modeling

The E3 analysis uses models to simulate which combinations of resources can be used to meet the Climate Act goals, how the transmission grid can provide those resources and the renewable capacity needed to maintain reliability.  I will address these three models below.

E3 used their PATHWAYS model to “create strategically designed scenarios for how the State can reach its 2030 and 2050 GHG goals. The model is built using ‘bottom-up’ data for all emissions produced and energy consumed within the State.   It identifies GHG reduction measures from transportation, buildings, industry, electricity, and other sectors, and captures interactions among measures to create a detailed picture of emissions reductions and costs through 2050”.  E3 notes “that as a ‘stock rollover’ model, PATHWAYS considers realistic timing of investments to replace appliances, vehicles, buildings, and other infrastructure. It pays special attention to the dynamics between electricity generation and new loads from transportation and buildings, as well as the role of low-carbon fuels such as advanced biofuels, hydrogen, and synthetic fuels”.

I believe there is a major problem with their “stock rollover” model.  As far as I can tell, it does not consider the readiness of the technology proposed.  The International Energy Agency (IEA) recently published “Special Report on Clean Energy Innovation” that notes:

“Without a major acceleration in clean energy innovation, net-zero emissions targets will not be achievable. The world has seen a proliferating number of pledges by numerous governments and companies to reach net-zero carbon dioxide (CO2) emissions in the coming decades as part of global efforts to meet long-term sustainability goals, such as the Paris Agreement on climate change. But there is a stark disconnect between these high-profile pledges and the current state of clean energy technology. While the technologies in use today can deliver a large amount of the emissions reductions called for by these goals, they are insufficient on their own to bring the world to net zero while ensuring energy systems remain secure – even with much stronger policies supporting them.”

I have shown that E3 ignored these limitations in its assessment of the technology needed to provide electricity when they claimed “Deep decarbonization in New York is feasible using existing technologies”.  That statement mis-characterizes the actual situation.  As IEA points out feasibility depends upon making all parts of the technological application process, what they call the value chain, commercially viable.  The fact is that for the E3 technologies proposed to address the winter peak problem, one or more aspects of commercial viability, availability limitations, or public perception make the E3 recommendations risky bets for future reliability and affordability.

In order to consider effects of the transmission grid on the de-carbonization effort, E3 used their RESOLVE model:

Our modeling approach also incorporates detailed electricity sector representation using E3’s RESOLVE model. RESOLVE is used to develop least-cost electricity generation portfolios that achieve New York’s policy goals, including 100% zero-emission electricity, while maintaining reliability.

For this study, RESOLVE was configured with six zones: two zones representing the upstate and downstate portions of the New York electricity system and four zones representing the external markets that interact with New York.

It is beyond the scope of my analysis to quantitatively determine whether this resolution is sufficient to represent the New York grid relative to the generation portfolios.  Qualitatively, however, the fact that New York City, which has specific transmission load constraints and a requirement for a minimum level of in-city generation, is lumped with Long Island suggests that this is a significant deficiency.

In my comments on the resource adequacy hearing and elsewhere I have argued that actual short-term meteorological data must be used to correctly characterize the renewable resource availability for New York in general and in areas downwind of the Great Lakes in particular. This is because the lakes create meso-scale features, most notably lake-effect snow and clouds, that can affect solar resources many miles from the lake shore. It is important that the solar and wind resources be evaluated based on geographically representative short-term data so that site-specific temporal effects can be included. E3 calculates the “effective load-carrying capability” which they define as the amount of “perfect capacity” that could be replaced or avoided with wind, solar, or storage while providing equivalent system reliability.

The values in this analysis were developed using E3’s reliability model, RECAP. The model assesses generation resource adequacy for a power system based on loss-of-load probability analysis but is inherently flawed for this application because it does not consider the observed renewable resource availability which can only be quantified by a detailed look at historical meteorological data such as I have proposed.

Electricity Demands

E3 correctly notes that it will be challenging to meet increased electricity demand due to electrification of vehicles and buildings while at the same time reducing, and eventually eliminating, GHG emissions while maintaining system reliability.  E3 predicts that electricity demand may increase by 65% to 80% depending on the “scale and timing of electrification”.  The electricity requirements depend upon how much of a role bio-fuels and synthetic fuels can play in replacing fossil fuels.  This analysis suffers from the lack of consideration of technical readiness for those technologies.  The IEA report lists very few bio-fuel and synthetic fuel technologies that have reached sizeable deployment and have all designs and underlying components at high technological readiness levels.

Peak Demands

The report explains that the transformation will “change the timing and magnitude of consumers’ electricity demands and create a “winter peaking” system in New York, owing to new demands from electric space heating”.  They go on to claim “Flexibility in electric vehicle charging patterns and building loads can significantly reduce peak demands and the need for new electric generating capacity. Flexible loads can serve a similar role to battery storage, shifting demand to times of high renewables output.”

“Figure 17 illustrates this evolution of the system peak—and the impacts of electric load flexibility over time”.  Because I think winter load is the greater future concern, I will discuss winter instead of summer information.  Figure 17 Annual summer and winter peak electricity demands shows how the peak electricity demand is expected to change.  I was unable to find the corresponding data for the annual summer and winter peak electricity demands portion shown in the figure but I estimate from the figure that the winter statewide peak load will be 24 GW in 2020 and in 2050 the peak load will be 35 GW with flex loads and 43 GW without flex loads.

The bottom portion of Figure 17 Average hourly loads by month is confusing at first glance.  It shows the average hourly load as it varies by each month.  E3 used their models to generate load shapes and develop their claim that there is 8 GW of peak load shaving available in 2050.  There is insufficient information to critique that claim but I am struck by the appearance of the 2020 and 2050 hourly load shapes.  In 2020 heating is a small component of load but in 2050 it will be much larger.  Consequently, I expect that the components of the load shape will change so I would expect some kind of change in the shape.  Instead it appears that the load is just larger and there is no change in the shape.  Importantly it is not clear why the load can be shaved.  Where do you shift the heating component that makes up the sharp increase early in the morning?  If you heat your home at 3:00 AM it will be cold by 7:00 AM during the peak.  Moreover, note that there does not appear to be as much flex load available at the peak later in the day that is roughly the same magnitude.  Consequently, I am not convinced of their arguments that 8 GW of load can be shaved off the winter peak.

Resource Portfolios

E3 claims that New York State has “access to diverse in-state renewable energy resources and zero-emissions technology options, as well as access to adjoining states, provinces, and regional transmission systems which offer additional options for zero-emissions energy supply”.  The E3 analysis used their RECAP model to determine “the new resources required to reliably meet electricity demand in buildings, transportation, and industry with 100% zero-emissions electricity for the upstate and downstate regions of New York”.

Although E3 claims that their analysis models the reliability contributions of intermittent and limited-duration resources, the fact that they did not use a comprehensive and more representative meteorological data set as input makes that claim weak in my opinion.  The worst-case reliability problem in the no-fossil-fuel future is very likely to be the worst-case wind and solar resource availability period not the peak load.  Unfortunately, it is possible that the winter conditions that create future peak loads may also exacerbate renewable resource availability so the two conditions may overlap.  I don’t think anyone has adequately addressed this issue yet.

E3 claims: Our analysis finds that New York can reliably meet growing electricity loads with 100% zero-emissions electricity by relying on a diverse mix of resources, including:

          • Onshore and offshore wind
          • Large-scale and distributed solar
          • In-state hydro and existing and new hydro imports from Quebec
          • Existing nuclear capacity
          • Existing and new combined cycles (CC) and combustion turbines (CT) utilizing zero-emissions biogas
          • New natural gas-fired combined cycles with carbon capture and sequestration (CC-CCS)

Eventually I will try to quantify the resources of each of these resources so that I can compare their projections with others.  The lack of data in this regard makes that task daunting.  I do want to make one observation.  Figure 18, Projected Installed Capacity (top) and Annual Electricity Generation (bottom), shows huge increases in bioenergy installed capacity in both scenarios.  However, note that the annual generation for those categories is small.  I cannot imagine a business case for developing that kind of capacity for such limited output so I believe it is likely that bioenergy will have to be heavily subsidized to make it available as they propose.

Transmission

E3 explains:

New investments in transmission will be needed to enable the delivery of 100% zero-emission electricity, including:

          • Local transmission upgrades to integrate new renewable resources
          • Additional transmission to deliver renewable resources from other regions, especially Quebec, into New York
          • Bulk transmission capacity from upstate New York to downstate load centers

Although New York has started the process of adding bulk transmission capacity it is not clear how much more will be needed.  I have yet to see anyone explain if any of the off-shore wind will be considered in-city generation for reliability purposes.  The DPS White Paper on CES procurements to implement the Climate Act includes a proposal for a Tier 4 procurement to encourage will directly extend financial support for renewable energy delivered into the New York City control zone but that discussion did not address in-city generation requirements.

 Firm Capacity

E3 explains that “Firm capacity is the amount of energy available for power production which can be guaranteed to be available at a given time. As the share of variable resources like wind and solar grows substantially, firm capacity resources will be needed to ensure year-round reliability, especially during periods of low renewables output.”

Firm capacity allows the system to have adequate resources available during prolonged periods of low renewable energy output. I agree with the E3 description that “The State’s need for firm resources would be most pronounced during winter periods of high demand for electrified heating and transportation and lower wind and solar output”.  E3 says that the hourly loads in their analysis are based on six years of historical weather 2007-2012.  I asked E3 what monitoring locations were used but never heard back.  I believe these data are from the National Weather Service climatological sites.  If that is the case they are not representative of the whole of New York and that NYS Mesonet data available from every county in the State should be used instead.

Conclusion

The first proposal to meet the Climate Act targets that was presented to the Climate Action Council can only be considered an overview.  The E3 analysis does not impress me.  While their models give the veneer of respectability to the projections, the reality is that the inherent over-simplifications of their models under-estimates the difficulties of the transition in New York and gives a false sense of security to their assurances that implementation will succeed.

Despite the limitations, the analysis does make important points.  I agree with their conclusion that the transition will “change the timing and magnitude of consumers’ electricity demands and create a “winter peaking” system in New York, owing to new demands from electric space heating”.  They point out that a multi-day period of low renewable energy availability will be a particular problem in the winter and state that: “Firm capacity is the amount of energy available for power production which can be guaranteed to be available at a given time. As the share of variable resources like wind and solar grows substantially, firm capacity resources will be needed to ensure year-round reliability, especially during periods of low renewables output.”

After their presentation to the Climate Action Council, members asked E3 about the use of renewable natural gas as one of the firm capacity resources.  Apparently, some believe that renewable natural gas is not a renewable energy resource according to the Climate Act.  Be that as it may, I suspect that E3 has found that without sufficient firm capacity resources the only alternative to maintain reliability will be extraordinary amounts of energy storage.  Energy storage is very expensive and E3 might have included renewable natural gas energy to limit energy storage use to keep the costs down.

Although E3 claims to bring “clear, unbiased analysis to the critical issues facing the energy industry today” I don’t think that is possible to be unbiased and work for the New York Climate Action Council.  New York’s Climate Act is predicated upon the belief that decarbonization is only a matter of political will.  Unfortunately, that belief is inconsistent with the firm capacity challenge for the winter peak.  It will be interesting to see how the Council deals with inconvenient issues that challenge the notion that this transition is not pushing the envelope of electric system reliability.

New York Peaking Power Plants and Environmental Justice Summary

New York State energy and environmental policy is more about optics than facts.  Nowhere is this more apparent than the recent spate of opinion pieces, reports, and even policy proposals related to peaking power plants.  I evaluated the basis of these items in a series of three posts but because they are very technical I have elected to summarize this issue in this post.

I think this is an important because the vilification of peaking power plants is getting all sorts of undeserved attention.  Although the peaking plants are alleged to be a primary driver of the environmental burden in neighboring environmental justice communities that is unlikely to be the case.  Combine that with the enormous costs of energy storage and the difficulty siting enough renewables within the city to replace these plants that means that a clean energy “solution” is likely not in the best interests of society, particularly in the admittedly over-burdened environmental justice communities.

This post is a summary of three detailed technical posts.  The PEAK Coalition recently released a report entitled: “Dirty Energy, Big Money”.  My first post provided information on the primary air quality problem associated with these facilities, the organizations behind the report, the State’s response to date, the underlying issue of environmental justice and addressed the motivation for the analysis.  My second post addressed the rationale and feasibility of the proposed plan relative to environmental effects, affordability, and reliability.  Finally, I discussed the  Physicians, Scientists, and Engineers (PSE) for Healthy Energy report Opportunities for Replacing Peaker Plants with Energy Storage in New York State that provided technical information used by the PEAK Coalition.

I am a retired electric utility meteorologist with nearly 40 years-experience analyzing the effects of meteorology on electric operations.  I have been involved with the peaking power plants in particular for over 20 years both from a compliance reporting standpoint and also evaluation of impacts and options for these sources.  This background served me well preparing this post.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

The Problem

There are two drivers for peaking power plant issues.  In order to provide electricity to everyone who needs it when they need it, the New York Independent System Operator (NYISO) has to balance power availability with the load on the system.  NYISO is responsible not only for the real-time deliver of power but also for reliability planning.  If the load did not vary this would be much less difficult, but the reality is that load varies diurnally and seasonally.  Most important is meeting demand when loads are highest in the summer and winter when it is necessary to provide electricity to maintain the health and well-being of customers. Ultimately the problem boils down to the fact that there are short periods when so much load is needed that there are units dedicated by intent or circumstances to provide just that load during the year.  This is expensive and inefficient but is, in my opinion, a problem with no easy solution.

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

The reports both suggested that the payments for the peaking power were unreasonable.  The PEAK Coalition believes that these plants “receive exorbitant payments from utilities and other energy service providers just for the plants to exist”.  This is not my area of expertise but based on the turnover of ownership and other factors, I don’t believe that they are the profit centers the PEAK Coalition believes they are.  Importantly, the units do run when power is needed most so there is a reason for them to exist.

The Analysis

I found that the basis for the technical aspects of the PEAK Coalition report is work by Physicians, Scientists, and Engineers (PSE) for Healthy Energy.  PSE evaluated Federal data peaking power plants across the country based on fuel type, capacity, technology and how much they ran.  This is a blunt approach that cannot address any of the nuances that have resulted in some units running for short times.  In New York for example, there are simple cycle turbines in New York City that were built specifically to provide peaking power.  There also are some large oil-fired units that run little because their fuel costs are so high.  Off the top of my head I also note that there are units that burn oil and run only when needed due to natural gas supply constraints, but there certainly could be other reasons some units run so little.  As a result the simplistic proposal for replacement is only valid for some of the facilities at best.

In order to prove the need for a clean energy alternative, PSE combined the peaking power plant data with ambient air quality data to show that the peaking plants often run at the same time that there are National Ambient Air Quality Standard exceedances.  That is a well-known fact.  PSE also developed a “cumulative vulnerability index that integrates data on health burdens (asthma, heart attacks, premature birth rates); environmental burdens (ozone, particulate matter, toxics, traffic proximity, lead paint, and hazardous facilities); and demographic indicators (low-income, minority, linguistically isolated, and non-high school-educated populations)”.  All of these data were combined to make the claim that these plants need to be replaced.

However, I don’t think that the PSE approach made a convincing case that the peaking power plants are a primary driver of environmental burdens on neighboring communities.  Their vulnerability index lists other factors but makes no attempt to attribute impacts to each factor.  The ultimate problem with this approach is that the peak unit justification relies on environmental burdens from ozone and particulate matter air quality impacts.  However, ozone is a secondary air pollutant and the vast majority of ambient PM2.5 from power plants is also a secondary pollutant.  As a result, there is enough of a lag between the time emissions are released and creation of either ozone or PM2.5 that the impact is felt far away from the adjacent communities.  That means that the accused peaking power plants do not create the air quality impact problems alleged to occur to the environmental justice communities located near the plants.  In fact, because NOx scavenges ozone, the peaker plants reduce local ozone if they have any effect at all.

The Solution

Dirty Energy, Big Money states “Experts have found—and real-world examples have proven—that battery storage and renewable generation may be less expensive to develop and manage than the rarely used but heavily polluting fossil fuel power plants, while also meeting or exceeding the same performance standards”.  This statement is just plain wrong as I showed in detail.  As soon as energy storage is added to the renewable “solution” the projected costs rise exponentially and there are no real-world examples supporting this as a proven policy approach.  Moreover, the difficulties and cost of siting enough renewable energy within New York City to meet the in-city generation requirements also suggest enormous costs.

New York’s irrational war on natural gas continues in this vilification of peaking power plants.  I do not dispute that there is a New York City peaker problem where old, inefficient combustion turbines designed to provide peak power are being used to provide critically needed power when needed most. In order to force their replacement the New York State Department of Environmental Conservation (DEC_promulgated new  limits for the simple cycle turbines such that they will be required to install controls or shut down. They should be replaced and probably should have been replaced long ago so the question is why hasn’t this happened.

In my opinion the continued operation of the old simple cycle turbines in New York City is the result of New York’s de-regulated market place.  I am absolutely sure that in a regulated environment the responsible utility would have made a case to the Department of Public Service that replacement with cleaner, more efficient generation was needed, the Department would have agreed  and after it was approved the utility would have built the replacements units and been guaranteed a reasonable return on their investment.  However, in the de-regulated market there wasn’t a strong enough financial incentive to replace the old units.  Before I retired in 2010, I worked on two separate permit applications for new, efficient, and cleaner replacement power for one set of the old combustion turbines.  In both instances the permits were approved but the replacements were never built, apparently because the company decided that the business case was not strong enough to warrant the investment.

According to the plans submitted to comply with DEC’s peaking power plant rule only one company is planning to build replacement peaking power. I fear that in today’s political climate that the proposed re-powering of Gowanus will not be permitted because it is new fossil fuel infrastructure.  However, it is fundamentally different inasmuch as the proposed plant is on a barge.  If New York’s aspirational climate agenda works out  then it won’t be needed and it can simply be moved away to another location to serve as a bridge source of energy elsewhere.  However, I am unconvinced that the clean energy alternatives proposed will work, much less be affordable.  Therefore, this proposed project is invaluable insurance for reliability and affordability.

Conclusion

The claims that peaking power plants are dangers to neighboring environmental justice communities are based on emotion.  In the evaluation I did of the PSE analysis and the PEAK Coalition report, I found that the alleged impacts of the existing peaking power plants over-estimates impact on local communities relative to other sources.  The existing simple cycle peaking turbines in New York City are old, inefficient and much dirtier than a new facility and clearly should be replaced.  However, they reliably produce affordable power when needed most.  In order to maintain that affordability and reliability I think it is best to rely on a proven solution such as the proposed Gowanus re-powering project.  The solar plus energy storage approach advocated by PSE and the PEAK Coalition will likely increase costs significantly if it works.  I cannot over-emphasize the fact that it may not work because solar and energy storage is not a proven technology on the scale necessary to provide New York City’s peaking power requirements.  Sadly in the rush to prove politically correct credentials this unproven technology may be chosen despite the risks to power reliability.

PSE Healthy Energy: New York State Peaker Power Plants

Update June 30, 2020:  I wrote a layman’s summary on this issue here.

Physicians, Scientists, and Engineers (PSE) for Healthy Energy is a multidisciplinary, nonprofit research institute that studies the way energy production and use impact public health and the environment. One of their recent programs is the Energy Storage Peaker Plant Replacement Project.  That work formed much of the technical basis for the PEAK Coalition report entitled: “Dirty Energy, Big Money”.  I have prepared two posts on that document (here and here).  This post addresses the PSE report Opportunities for Replacing Peaker Plants with Energy Storage in New York State.

I am a retired electric utility meteorologist with nearly 40 years-experience analyzing the effects of meteorology on electric operations.  I have been involved with New York peaking power plants in particular for over 20 years from a compliance reporting and operations standpoint and also evaluated impacts and options for this kind of source.  This background served me well preparing this post.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Energy Storage Peaker Plant Replacement Project

PSE defines the alleged problem in the introduction to this project as follows:

The United States relies on more than 1,000 natural gas- and oil-fired peaker power plants across the country to meet infrequent peaks in electricity demand. These peaker plants tend to be more expensive and inefficient to run for every megawatt-hour generated than baseload natural gas plants and emit higher rates of carbon dioxide and health-harming criteria air pollutants. Peaker plants are also typically disproportionately located in disadvantaged communities, where vulnerable populations already experience high levels of health and environmental burdens.

The text for the New York specific report describes the problem similarly:

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

Their proposed solution:

Renewable energy and energy storage systems are beginning to emerge as competitive replacements for this fossil fuel infrastructure. Simultaneously, numerous states across the country are designing incentives and targets to support energy storage deployment. Together, these developments provide a unique opportunity to use energy storage to strategically displace some of the most polluting peaker power plants on the grid.

In the Energy Storage Peaker Plant Replacement Project PSE did a screening analysis across nine states that identified peaker power plants that “may be prime candidates for replacement based on operational and grid characteristics, and whose replacement may yield the greatest health, environment and equity co-benefits”.  They claim that their approach “aligns state efforts to adopt energy storage with environmental and societal goals”.

The following section is the summary of the report.  Based on my review of the New York State-specific results I believe further study is needed to actually determine if all the peaker units identified can actually be considered candidates for replacement with energy storage and solar.  I also worry that the PSE analysis is mis-leading inasmuch as it does not address the fact that peaker plants fulfill niche operational backup roles that vary widely across the country.  I am familiar with New York State peaker plants and will show why that is important in New York.

PSE Summary

“The majority of New York’s peaker plants are located in densely urban areas in New York City and Manhattan, a region that is in non-attainment for federal ozone standards. These include old, inefficient  and oil-burning units near populations that experience high cumulative environmental health and socioeconomic burdens.  The state’s new emission reduction standards for nitrogen oxides, along with its energy storage deployment goals, provide a clear opportunity to target inefficient and polluting facilities for replacement with cleaner alternatives, particularly in urban areas. In the attached table, we provide operational, environmental and demographic data for New York peakers and nearby populations. Indicators such as nearby population, emission rates, heat rate (a measure of efifciency), operation on poor air quality days, capacity factor, typical run hours, and location in an environmental justice community or in an import-constrained load zones downstate can help inform whether a given plant might be a good target for replacement with storage, solar+storage, demand response, or other clean energy alternatives. These data should be accompanied by engagement with accompanied by engagement with affected communities to determine replacement priorities and strategies.”

The New York report has four sections: New York State Policy and Regulatory Environment, New York State Peaker Plants, Nearby Populations, and Emissions and the Environment.  I will address those sections in the following.

New York State Policy and Regulatory Environment

There isn’t much to comment on in this section.  The PSE report only describes New York’s climate initiatives.  Although the summary notes that New York has new emission reduction standards for nitrogen oxides, it does not highlight the fact that the regulation was specifically intended to address emissions from the old, inefficient simple cycle combustion turbines in New York City.  I described New York’s specific initiatives in my background post on the PEAK Coalition Dirty Energy, Big Money report.

New York State Peaker Plants

This analysis and report were intended to provide background information to support “clean energy alternatives” for peaker plants.  A primary component of that information is identification of peaker plants.  The technical documentation describes peaker power plants and the selection criteria used in their screening analysis.  PSE states “The phrase peaker plant commonly refers to fossil fuel-burning power generation used to meet peak demand on the electric grid, but the term itself does not have a precise definition”.  Actually, for EPA reporting purposes there is an exact, regulatory definition.  40 CFR Part 75  §72.2, states that a combustion unit is a peaking unit if it has an average annual capacity factor of 10.0 percent or less over the past three years and an annual capacity factor of 20.0 percent or less in each of those three years.

PSE chose to select peaking power plants based on the following criteria: fuel type: oil & natural gas; Capacity: ≥ 5 MW; capacity factor: ≤15% (3-yr. avg.); unit technology type: simple cycle combustion turbine, steam turbine & internal combustion; application: entire peaker plants & peaking units at larger plants; and status: existing and proposed units.  Relative to the peaking power plants subject to EPA reporting requirements, the biggest difference is that the PSE criteria selects small units between 5 and 15 MW that are so small that their emissions and impacts are generally considered insignificant.  Those facilities do not report continuous emissions monitoring data that the units >15 MW do.

Briefly, PSE collected data from EPA and EIA then screened it with their criteria to identify peaking units.  They calculated operational and emissions data.  Then they compared operational data with ambient monitoring data and found periods when the peaking units operated during periods of high ambient levels.  This is a straight-forward number crunching exercise and I have no comments on the methodology.

The technical and policy documentation for the Energy Storage peaker plant replacement project includes a section titled “Grid requirements: transmission constraints and capacity needs” that includes a discussion of New York.  For the most part PSE relied on the New York Independent System Operator analyses of the peaker plants. They note that the impacts of removing capacity is highly location dependent quoting NYISO reports: “lower amounts of capacity removal are likely to result in reliability issues at specific transmission locations” and that NYISO did not “attempt to assess a comprehensive set of potential scenarios that might arise from specific unit retirements”.  Despite the fact that NYISO cannot make specific recommendations PSE goes ahead and makes recommendations for five plants in New York City and five plants on Long Island that are “replacement opportunities” in PSE Peaker Documentation Table 5.3.

While I am certainly no expert on New York City reliability requirements I believe that there are ramifications not considered by PSE.  The NYISO Gold Book Data for Table 5.3 Replacement Opportunities table provides additional data for the PSE opportunities.  First note that PSE did not identify peaking units that operate at facilities with other units.  There is a combustion turbine at Northport and Arthur Kill that operates with the capacity factor listed.  PSE apparently does not understand that the primary purpose of those units is for black starts, that is to say when they provide power necessary to start the steam turbine units when there is no off-site power available.  In theory battery storage could be used for that but because of reliability considerations the battery would have to always be kept with enough energy to start the plant for the very rare occasion when there is a blackout.  There is no way that could be cost-effective.  My table also lists the fuel burned and it is instructive that all but one of the units listed can burn kerosene or number 2 fuel oil.  There are specific requirements for minimum oil burning when there is a possibility that the gas supply could be cut off.  Because this is not the standard peaking power plant replacement scenario, I am not sure whether battery storage would be cost-effective for this requirement.

Advocates for “clean energy alternatives” point out that New York has a law that requires that no electricity will be generated by fossil fuels in 2040.  Until such time that the State has a plan to meet that goal that explains how reliability and affordability can be maintained, then I will continue to believe that meeting that aspirational goal is more than simply a matter of political will.  For example, the Gowanus power plant has a nameplate capacity of around 540 MW. For all the Article Ten solar energy applications currently in the queue 5.4 acres per MW was the lowest spatial requirement.  That means that solar panels totaling at least 4.6 square miles will be needed to replace this source of in-city generation. While that may be possible, there are a host of logistical issues starting with the need to provide the power where it is needed when it is needed.  New York City is a load pocket relative to the rest of the grid but there are numerous smaller load pockets within the city.

Nearby Populations

The report notes that “Ten of the New York peaker plants each have more than a million people living within a three-mile radius. The most urban plants tend to also be in relatively low-income, minority communities, due to both the location of some facilities in low-income, environmentally overburdened communities of color.”  In my background post on the PEAK Coalition Dirty Energy, Big Money report I described the environmental justice concept of dis-proportionate impacts.  I do not know how to deal with dis-proportionate impacts when the location of some facilities impact rich communities at the same time they impact low-income communities.

PSE developed a “cumulative vulnerability index that integrates data on health burdens (asthma, heart attacks, premature birth rates); environmental burdens (ozone, particulate matter, toxics, traffic proximity, lead paint, and hazardous facilities); and demographic indicators (low-income, minority, linguistically isolated, and non-high school-educated populations)”.  It is vital to determine the effect of the peaker power plants relative to all the other impacts on the admittedly over-burdened environmental justice communities.

Emissions and the Environment – Air Quality Impacts

In order to determine the relative impact of peak power plants we have to consider their air quality impacts.  In order to be permitted to operate, all power plants have to evaluate the potential impacts of their emissions relative to the National Ambient Air Quality Standards (NAAQS).  There are two types of standards.  Primary standards provide public health protection, including protecting the health of “sensitive” populations such as asthmatics, children, and the elderly. Secondary standards provide public welfare protection, including protection against decreased visibility and damage to animals, crops, vegetation, and buildings.  Air quality models combine information about the emissions, operating characteristics, and meteorological conditions to estimate the ambient concentrations from the power plants and those estimates are compared to the NAAQS.  If the contribution from the facility directly causes an exceedance of any NAAQS limit then the plant cannot operate until changes are made to reduce the impact.  If nothing can be done to reduce the impacts lower than the limits then it cannot be permitted to operate.

The air quality modeling used to permit a power plant to operate considers pollutants like sulfur dioxide and nitrogen dioxide that are directly emitted by the plant.  Power plants also emit pollutants that are precursors to other pollutants that form in secondary reactions.  Modeling secondary pollutants is more complicated and ascribing the impacts of particular facilities on air quality is more difficult.  Permit conditions for secondary pollutants such as ozone and inhalable particulate matter can also limit emissions of the precursor pollutants.

In my opinion the most difficult air quality issue today is ozone attainment because the emission source characteristics and meteorological conditions are not only complex and difficult to understand but also because making the reductions necessary are costly and impactful.   Ground-level ozone is created by chemical reactions between oxides of nitrogen (NOx) and volatile organic compounds (VOC). Those pollutants are emitted by cars, power plants, industrial boilers, refineries, chemical plants, natural sources and other man-made sources and when they chemically react in the presence of sunlight, they create ozone.  Ozone is most likely to reach unhealthy levels on hot sunny days in urban environments but because NOx and VOC as well as ozone can be transported long distances by wind, rural areas are affected and urban areas are affected by sources far upwind.

It has been observed that when widespread transportation restrictions are implemented (e.g. during the Atlanta Olympics) that there is a marked improvement in ozone levels.  However, the fact is that there is little societal desire to maintain the draconian restrictions of automobile use that produce those improvements.  For peaking power plants, the problem is that the conditions most conducive to create ozone are also the hot and muggy conditions that increase electricity demand for cooling, so the peak load of electric generation produces the most emissions at the worst time.  However, in order to provide the power necessary to keep the lights on when people really want and need it, the existing power grid has peaking facilities.  In my second post on the PEAK coalition report I described the process used to determine if these units are needed and why I think they have not been replaced yet.

Recall that PSE developed a cumulative vulnerability index that integrates data on environmental burdens including ozone and particulate matter.   The point of this entire discussion is that ozone is a secondary air pollutant and the vast majority of ambient PM2.5 from power plants is also a secondary pollutant.  In other words, there is a lag between the time of relevant emissions and creation of either ozone or PM2.5.  As a result, the accused peaking power plants do not create the air quality impact problems alleged to occur to the environmental justice communities near the peaking power plants.  In fact, because NOx scavenges ozone the peaker plants reduce local ozone if they have any effect at all.

Conclusion

The PSE report notes that “These data should be accompanied by engagement with accompanied by engagement with affected communities to determine replacement priorities and strategies.”  I do not want anyone to misunderstand that I am not arguing that something should not be done about New York City’s simple cycle combustion turbine peaking power plants.  They are old, inefficient and relatively dirty.  However, in order to do the right thing, we need to understand all the background information.  The PSE analyses and the PEAK Coalition vilification of fossil-fired power plants only tells one side of the story and, inasmuch as most of the alleged environmental impacts are based on ozone and PM2.5 impacts, they misleadingly imply much more of an environmental benefit to the affected communities than will actually occur if the existing power plants are replaced by the latest generation of natural-gas fired power plants.

As noted in my post on the feasibility of the “clean energy alternative”, I have reservations about that proposed solution.  Even though the cost for developing renewable energy resources is allegedly cheaper than the cost of equivalent fossil-fired energy resources, the cost to ensure that electricity is available when and where it is needed for the two resources are not even close.  Because renewable energy is intermittent energy storage is required and my feasibility post demonstrated those costs are immense and would have to drop by an order of magnitude to make the solar+storage option comparable in cost.

Post Script

The PSE report Opportunities for Replacing Peaker Plants with Energy Storage in New York State includes a table that lists all the power plants in New York State that meet their screening criteria defining a peak plant.  The title of the report suggests that this list contains facilities that could be replaced by energy storage.  However, it includes steam turbine units that burn residual oil.  Because those units burn an expensive fuel, they don’t run much but because their operating costs are relatively low, they can be kept available for the rare occasions when they are needed. I was working at one of the named Upstate plants, Oswego, when the 2003 Northeast blackout occurred.  When the transmission system lost power, three nuclear units nine miles east of the plant had to shut down.  In order to bring the system back on-line, both of Oswego’s 850 MW units were turned on, ran for a combined 231 hours and generated 71,684 MWh.  I cannot think of any scenario where it would be in the best interest of New York to build enough energy storage to replace the Oswego power plant for this type of incident.

PEAK Coalition Dirty Energy, Big Money: Rationale and Feasibility

Update June 30, 2020:  I wrote a layman’s summary on this issue here.

New York State energy and environmental policy is more about optics than results.  Nowhere is this more apparent than the recent spate of opinion pieces, reports, and even policy proposals related to peaking power plants.  In May 2020, the PEAK Coalition released a report entitled: “Dirty Energy, Big Money”.  The focus of the study is the “peaker” power plants that operate when energy demand in New York City spikes above normal levels.  Because I have been involved with this issue and these plants for over 20 years, I want to review the report.

This is my second post on this topic.  The first post provided information on the primary air quality problem associated with these facilities, the organizations behind the report, the State’s response to date, the underlying issue of environmental justice and address the motivation for the analysis.  This post addresses the rationale and feasibility of the proposed plan relative to environmental effects, affordability, and reliability.

I am a retired electric utility meteorologist with nearly 40 years-experience analyzing the effects of meteorology on electric operations.  I have been involved with the peaking power plants in particular for over 20 years both from a compliance reporting standpoint and also evaluation of impacts and options for these sources.  This background served me well preparing this post.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

The Physicians, Scientists, and Engineers (PSE) for Healthy Energy is a multidisciplinary, nonprofit research institute that studies the way energy production and use impact public health and the environment. Their report Opportunities for Replacing Peaker Plants with Energy Storage in New York State formed much of the technical basis for this PEAK Coalition analysis.   I discuss that report here.

The full title of Dirty Energy, Big Money includes: “How Private Companies Make Billions from Polluting Fossil Fuel Peaker Plants in New York City’s Environmental Justice Communities—and How to Create a Cleaner, More Just Alternative Public Health Impacts”.  The table of contents includes sections on public health impacts, New York’s reliability process and payments, clean energy alternatives and the benefits of the PEAK Coalition proposed alternative.  I will address each of these topics.

The report has a table of Peaker Power Plants Operating in New York City which is based on a Physicians, Scientists, and Engineers for Healthy Energy report: Opportunities for Replacing Peaker Plants with Energy Storage in New York State.  The peaking units included in that report cover not only small combustion turbines with nameplate capacities down to 16 MW but also steam turbine boilers such as Ravenswood ST03 with a nameplate capacity of 1,027 MW.  The problem with using that overview analysis in this instance is that the impacts and alternatives for such widely different power plants are completely different.   Unfortunately, the report does not address the differences and suffers as a result.

Public Health Impacts

The PEAK coalition description of air quality public health impacts claims that “When New York’s gas-fired peaker plants are operating, they can account for over one-third of New York’s daily power plant NOx emissions,” but the citation is from a press release so I could not track down the basis for that claim.  This is one example of the problem resulting from the broad definition of peaker plants that considers both steam turbine boilers and combustion turbines.  Because steam turbine boilers have relatively tall stacks and hot plumes there are very few direct impacts on local neighborhoods from their emissions simply because there is no opportunity for the plume to reach the ground so close.  The press release is apparently referring to the older simple cycle combustion turbines that either have to retire or install controls by May 1, 2023.  More importantly, the discussion of health impacts focuses on PM2.5 (particulate matter with a diameter of 2.5 microns or less that is small enough to be inhaled deep into the lung) and ozone.  Neither of those pollutants is associated with local impacts from natural gas and oil-fired power plants because they are primarily a result of secondary pollutant effects meaning that they result from reactions with other directly emitted pollutants.  Those reactions take time and by the time they occur the air mass has moved away from the local neighborhoods.

The primary public health reference was the New York City Department of Health and Mental Hygiene’s (DOHMH) Air Pollution and the Health of New Yorkers report.  The PEAK Coalition quotes the conclusion from that report: “each year, PM2.5 pollution in [New York City] causes more than 3,000 deaths, 2,000 hospital admissions for lung and heart conditions, and approximately 6,000 emergency department visits for asthma in children and adults.”  Each year they claim exposures to ozone concentrations above background levels cause an estimated “400 premature deaths, 850 hospitalizations for asthma and 4,500 emergency department visits for asthma.”  What is not made clear is that these conclusions are for total air pollution in NYC and are based on air quality conditions from 2005-2007.

The DOHMOH report describes PM2.5 and its sources:

Fine Particles (PM2.5) are small, airborne particles with a diameter of 2.5 micrometers or less. Major sources of PM2.5 include on-road vehicles (trucks, buses and cars); fossil fuel combustion for generating electric power and heating residential and commercial buildings; off-road vehicles (such as construction equipment); and commercial cooking (U.S. Environmental Protection Agency, National Emissions Inventory). Fine particles can also become airborne from mechanical processes such as construction or demolition, industrial metal fabrication, or when traffic or wind stirs up road dust.

An article entitled Fine Particulate Matter Constituents Associated with Cardiovascular Hospitalizations and Mortality in New York City by Ito et al., 2011 concludes that “Local combustion sources, including traffic and residual oil burning, may play a year round role in the associations between air pollution and cardiovascular disease outcomes, but transported aerosols may explain the seasonal variation in associations shown by PM2.5 mass”.  Residual oil burning at the PEAK coalition peaker power plants is a backup fuel source used when there is a scarcity of natural gas or there are transmission constraint requirements that require a minimum oil burn.  Because of the fuel use characteristics, the tall stacks, and the conversion time between SO2 emissions and sulfate aerosols it is unlikely that these power plants have neighborhood impacts.  It is more likely that traffic sources are a larger contributor to EJ communities near the power plants.

There is one more aspect of the DOHMOH PM2.5 report that needs to be addressed.  The report specified four scenarios for comparisons (DOHMOH Figure 4) and calculated health events that it attributed to citywide PM2.5 (DOHMOH Table 5).  Based on their results the report notes that:

Even a feasible, modest reduction (10%) in PM2.5 concentrations could prevent more than 300 premature deaths, 200 hospital admissions and 600 emergency department visits. Achieving the PlaNYC goal of “cleanest air of any big city” would result in even more substantial public health benefits.

It is important to note how the air quality has improved since the time of this analysis.  The NYS DEC air quality monitoring system has operated a PM2.5 monitor at the Botanical Garden in New York city since 1999 so I compared the data from that site for the same period as this analysis relative to today (Data from Figure 4. Baseline annual average PM2.5 levels in New York City). The Botanical Garden site had an annual average PM2.5 level of 13 ug/m3 for the same period as the report’s 13.9 ug/m3 “current conditions” city-wide average (my estimate based on their graph).  The important thing to note is that the latest available average (2016-2018) for a comparable three-year average at the Botanical Garden is 8.1 ug/m3 which represents a 38% decrease which is substantially lower than the PlaNYC goal of “cleanest air of any big city”.

The DOHMOH analysis used a linear no-threshold health impact analysis.  As a result, it is possible to estimate the air quality health effects of the observed decrease in PM2.5 using their model (Modified Table 5. Annual health events attributable to citywide PM2 5 level).  Note that in DOHMOH Table 5 the annual health events for the 10% reduction and “cleanest” city scenarios are shown as changes not as the total number of events listed for the current levels.  My modified table converts those estimates to totals so that the numbers are directly comparable.  I excluded the confidence interval information because I don’t know how it would be modified.  I tested the linear hypothesis by scaling the “current level” scenario number of events to the proportion of the PM 2.5 concentrations for the “current level” and the other two scenarios.  My estimated health impacts were all within 1% which demonstrates that is all the DOHMOH analysis did.  Therefore, I could estimate the health impact improvements due to the observed reductions in PM2.5 as shown in my modified table.

I do not believe that the linear no-threshold air quality health impact model is correct.  I could be convinced, however, if the DOHMOH could demonstrate that the observed health impacts improved as predicted by the model.  Until such time as someone validates the performance of this kind of model I recommend caution in these results.

The DOHMOH report also describes ozone:

Ozone is not emitted directly from fuel combustion; it is produced by chemical reactions involving nitrogen oxides (NOx)—a mixture including nitric oxide (NO) and nitrogen dioxide (NO2)—volatile organic compounds and sunlight. O3 concentrations typically peak in the afternoon and are highest in the summer, when daylight hours are long and temperatures are high. Although NOx emissions from vehicles contribute to higher ozone in urban areas, in city locations where fresh NOx emissions are concentrated, NO reacts with, and removes, ozone from the atmosphere in a reaction known as ozone “scavenging.” As a result, concentrations in urban areas with an abundance of NOx from traffic sources tend to have somewhat lower concentrations of ozone than more suburban locations downwind from the city center.

For the purposes of this evaluation of localized neighborhood impacts from the peaker plants note two things.  Because ozone is a secondary pollutant the emissions from the peaker plants do not create ozone that affects neighbors.  The reason the DEC put controls on the peaking turbines last year was because of their impact on ozone levels downwind in Connecticut.  Moreover, as the DOHMOH report explains if there is any effect of these power plants on the neighborhoods it would be a reduction in ozone because of “scavenging”.

New York’s Reliability Process and Payments

The description of New York’s energy reliability process provides a good overview and appropriately stresses the importance of reliable energy to prevent blackouts and brownouts.  It describes the process which determines the energy mandates, procurement process and specifies energy needed for peak energy demand.  Despite apparently understanding the process and the importance of having power available for peak demands, the capacity market is vilified as unwarranted “big money”.  The de-regulated market needs a mechanism to pay the power plant owners for their services.  If the load did not vary diurnally, seasonally, and was not subject to high energy demands, payments would be simple.

However, because it is not simple, the market mechanism includes both payments for electricity provided but also for capacity.  The report states “This means that all peaker plants in New York City collect millions of dollars every year just to be “on standby” to produce very little energy —sometimes for only a few days each year.”  That is true but it neglects the obvious point that if they were not available for those few days each year there would not be enough energy and brownouts and blackouts would be the result.

I do not dispute that there is a New York City peaker problem where old, inefficient combustion turbines are being used to provide critically needed power when needed most. In order to force their replacement the New York State Department of Environmental Conservation promulgated new  limits for the simple cycle turbines such that they will be required to install controls or shut down. The compliance date for that regulation is May 2023 and the state may grant a two-year compliance extension to peaker plants deemed a “reliability resource by the NYISO or transmission owner”.

In my opinion the New York City peaker problem is the result of New York’s de-regulated market place.  I am absolutely sure that in a regulated environment the responsible utility would have made a case to the Department of Public Service that replacement with more efficient generation was needed and after it was approved the utility would have been guaranteed a reasonable return on their investment.  However, in the de-regulated market there wasn’t a strong enough signal to replace the old units.  Before I retired in 2010, I worked on two separate permit applications for new efficient and cleaner replacement power for one set of the old combustion turbines.  In both instances the permits were approved but the replacements were never built, apparently because the company decided that the business case was not strong enough to warrant the investment.

The PEAK Coalition apparently believes that there are problems with payments for the existing generators.  I have neither the background or time to evaluate those claims in detail so I cannot comment on them.  The fact that there has been a lot of turnover in ownership for New York’s peaking units suggests that no one is making great profits under the existing system.  Moreover, it should be kept in mind that in the de-regulated market, generation owners have no obligation to serve.  If they cannot make money they will just shut down.

Clean Energy Alternatives

This report proposes replacing peaker plants with “renewable and clean energy alternatives”.  It states:

However, solar and wind power alone cannot replace peaker plants, because the power they produce cannot be dispatched on command, and they have limitations on when they generate energy (e.g., solar photovoltaic (PV) systems can only generate optimal energy amounts on sunny days). For this reason, wind and solar energy systems are known as variable renewable energy sources. Combining battery storage technologies with renewables can address this limitation. Replacing peaker plants with batteries has now become a viable and profitable solution, due to the rapidly declining cost of energy storage systems.  Ideally, the batteries replacing peaker plants would be charged with local, renewable energy resources.

The motivation for the PSE peaker project that provides the technical basis of this report appears to support the use of batteries as a clean energy alternative to fossil-fired power plants.  By motivation I mean the likely source of funding for their analysis.  As a result, it is no surprise that batteries are touted as the solution.  Unfortunately, the PEAK coalition report fails to temper the enthusiasm of the battery “solution”.  Statements such as “Experts have found—and real-world examples have proven—that battery storage and renewable generation may be less expensive to develop and manage than the rarely used but heavily polluting fossil fuel power plants, while also meeting or exceeding the same performance standards” are suspect at best.

For example, I will consider options to build new generation to replace the energy produced at the Astoria Gas Turbine, Gowanus Generating Station, and Narrows Generating Station peaking plants on a typical high-load day – June 18, 2018.  All three plants operate simple-cycle combustion turbines that can burn natural gas or kerosene. All three facilities are on the order of 50 years old and, in my opinion, should be replaced.

The peak hourly load in this example was 752 MW so I used US Energy Information Administration (EIA) construction cost data for electric generators installed in 2017 information to estimate costs.  The report provides $/kW estimates for different technologies, locations and configurations.  I estimated the cost of a new combined cycle power plant similar to the one proposed to re-power Gowanus and Narrows and what was proposed for the two permit applications for re-powering the Astoria gas turbine facility.  According to EIA the average construction cost ($/kilowatt of installed nameplate capacity) of a combined cycle unit was $829 so a replacement facility would cost $674 million.  The average construction cost ($/kilowatt of installed nameplate capacity) of a utility-scale solar PV facility using crystalline silicon, axis-based tracking panels is $2,135 so a replacement facility would cost $1,606 million or nearly twice as much.   The average construction cost ($/kilowatt of installed nameplate capacity) of a land-based wind turbine facility (plant size 200-500 MW) is $1,526 so a replacement facility would cost $1,148 million.  It is often said that renewable energy is cheaper than fossil-fired energy but these numbers from 2017 clearly are refute that presumption.

The bigger problem, and one that should always be kept in mind that even if the cost of a solar and wind are equal to or a little less than the cost of a new fossil-fired plant, renewable energy is not dispatchable.  In this example I will only address the storage needed to handle the output for the existing peaking turbines but because renewable energy is diffuse transmission lines are needed.  Fossil-fired units provide grid support services but solar and wind generators do not.  Those support services are not considered in this example.

My interpretation of the PSE proposed alternative and the PEAK Coalition plan is to rely on energy storage to replace the output of the existing combustion turbines.  The Calculated Cost Breakdown for a U.S. Li-ion Standalone Storage System for June 18 2018 Example Peak provides the information necessary to estimate the energy storage batteries necessary to replace the turbines as well as the estimated battery requirements.  I simply estimated battery configurations needed by picking a capacity to cover the minimum needed for as long a period as possible and then repeated the process until the storage capacity met the observed load.  For example, at Astoria there were six hours of load and a battery with 280 MW capacity operating for six hours combined with a battery with 200 MW operating for one hour could completely cover the generation at that facility.  This simplistic approach also does not include energy losses due to charging and discharging.

I relied on two National Renewable Energy Lab (NREL) reports to estimate the costs of energy storage: “2018 U.S. Utility-Scale Photovoltaics-Plus-Energy Storage System Cost Benchmark” and “Life Prediction Model for Grid-Connected Li-ion Battery Energy Storage System”.  I estimated the parameters used by NREL to project costs so that I could calculate the cost of any battery configuration.  Keep in mind that I did not try to optimize battery resources in any way so these should be considered first-cut estimates.  I estimate that $1,797 million of Li-Ion batteries would be required to replace the power assuming that the battery capacity equals the observed generation.

It turns out that assumption is wrong because the second NREL report abstract notes that “The lifetime of these batteries will vary depending on their thermal environment and how they are charged and discharged. Optimal utilization of a battery over its lifetime requires characterization of its performance degradation under different storage and cycling conditions.”   The report concludes: “Without active thermal management, 7 years lifetime is possible provided the battery is cycled within a restricted 47% DOD operating range. With active thermal management, 10 years lifetime is possible provided the battery is cycled within a restricted 54% operating range.”  Because of the high cost of the batteries I assume that it would be best to extend the lifetime as much as possible.  When the 54% operating range constraint is added, more batteries are required and cost to replace the power produced by these three peaking plants on June 18, 2018 would be $3,651 million.  One other thing needs to be pointed out. If we assume that the life expectancy of the combustion turbines, solar arrays and wind turbines is 30 years that means that the battery storage for the renewable power would have to be replaced twice over the lifetime of the facilities.

Furthermore, the energy storage estimates in this example have no real-world counter parts.  According to the Hornsdale Power Reserve website “At 100MW/129MWh, the Hornsdale Power Reserve is the largest lithium-ion battery in the world, and provides network security services to South Australian electricity consumers in concert with the South Australian Government and the Australian Energy Market Operator (AEMO)”.  According to the PEAK coalition report “In October 2019, the New York Public Service Commission (PSC) approved the development of a 316-MW, 8-hour-duration battery at the Ravenswood Generating Station in Long Island City”.

Dirty Energy, Big Money states “Experts have found—and real-world examples have proven—that battery storage and renewable generation may be less expensive to develop and manage than the rarely used but heavily polluting fossil fuel power plants, while also meeting or exceeding the same performance standards”.  This statement is just plain wrong.  As soon as energy storage is added to the renewable “solution” the projected costs rise exponentially and there are no real-world examples for policy decisions.

Benefits of the PEAK Coalition Proposed Alternative

The report claims that “Replacing peaker plants with renewable energy and battery storage, if done right, brings a host of benefits in addition to efficient, clean, dispatchable electricity.”  The report does not explain how a “done right” replacement with renewable energy and battery storage could be accomplished.  For example, there is no apparent recognition that the NYISO currently requires that at least 80% of New York City’s electric generating capacity needs be met through in‐City generation. My impression is that the presumption is that the PEAK Coalition believes that solar can be used in the city.  However, I think the space requirements make that unlikely.  For ten Article Ten solar energy applications currently in the queue, 5.4 acres per MW was the lowest spatial requirement.  For my example of 752 MW of peaking power, 602 MW would have to be produced in the city and at 5.4 acres per MW that means that there would have to be five square miles of solar panels.  I am sure that there are no open areas that size so the panels will have to be installed on buildings.  That would add to the costs substantially.

The lack of any kind of plan is not the only issue with proposed alternative.  The benefits listed are as superficial and innumerate.  Consider the discussion on resiliency per: “A transition toward renewable energy and energy storage technologies can provide energy resiliency, backup power, and other benefits at the local level”.  I do not consider an energy system resilient when it is unavailable half the time like solar or is subject to the vagaries of weather like the wind.  The current emphasis is on the summer peak but New York’s aspirational climate targets will require electrification of heating a necessity which means the winter peak will become much more of an issue.  As a result, the worst-case load situation may not be the annual peak peak but could be a combination of high load and low renewable energy inputs.  That is not the sign of a resilient system.  It gets worse when the report states “Resiliency planning is particularly important for critical facilities throughout the five boroughs, including hospitals, evacuation centers, cooling centers, and food distributions hubs” and gives an example of a solar array on a school that serves as an evacuation center during emergencies.  If the facility is critical then redundant energy supplies not based on intermittent renewables are needed.  If there is an ice storm and the power lines go down then what?  The obvious, but politically incorrect solution, is to have a natural gas fired turbine generate the power needed by the micro-grid.

Another benefit claimed is reduced air pollution and resulting health improvements.  The report states “Using renewable energy to charge batteries eliminates greenhouse gas emissions. Statewide, it is estimated that adding 1,500 MW of energy storage would avoid one million tons of CO2 emissions”.  In order to get the one million ton reduction the addition of 1,500 MW would have to displace the large steam boilers PSE includes in their peaker category.  Those are not candidates for battery storage replacement.   The report claims: “With over 1.2 million New Yorkers living within a one-mile radius of a fossil fuel peaker plant, the reduction of air pollutants from peaker plants would have a significant impact on the health and quality of life of people living in the five boroughs of New York City”.  As previously explained in this post, that claim is very unlikely to be true.

Another benefit claimed would address the energy burden on under-resourced communities.  The report explains that energy poverty is a serious issue in New York City and goes on to claim that a significant portion of utility bills is directly related to payments for the “outdated fossil fuel peaker plants”.  I do not understand how environmental and social justice organizations can support the idea that the renewable and energy storage transition will lead to lower costs when every jurisdiction that has tried to implement those resources has seen marked increases in prices.  I am convinced that New York’s climate aspirations will result in much higher prices and the communities that these organizations purport to serve will be impacted the most.

The final benefit claimed is that the proposed transition will mean that “Instead of capacity payments going to private hedge funds or equity firms that own fossil fuel peaker plants, billions of dollars in ratepayer funds could instead be used to invest locally in publicly-owned and community-owned, distributed renewable and battery storage alternatives in New York City.”  The numbers shown in this report suggest that the transition will be far more expensive that investing in a natural-gas fired combined cycle power plant.  According to EIA the power plant that could provide the energy produced by three old peaking power facilities on June 18, 2018 would cost $674 million and would last at least 30 years.  If in-city solar were built it would cost $1,606 million and could also last 30 years.  The fatal flaw in the economic argument is the need for energy storage.  I estimate that, based on NREL estimates, energy storage would cost $3,651 but would only last ten years.  It is very unlikely that energy storage can come down significantly from the $10.953 million 30-year cost.

Policies to Advance the Transition

I only have one comment on this section.  The report notes that “New York City, strict fire safety rules make it very challenging to install energy storage batteries in most buildings, though there are clear guidelines for siting these batteries outdoors.”  There is a reason for those strict fire safety rules, namely that if the batteries are operated improperly, they can catch fire.  The health impacts of the toxic pollutants emitted during a battery fire are a real concern that cannot be overlooked.

 Conclusion

I will conclude this post by addressing one paragraph:

“Fossil peaker plants in New York City are perhaps the most egregious energy-related example of what environmental injustice means today. Throughout one of the most diverse and technologically developed cities in the world, numerous polluting oil and gas peaker plants in the City are sited in low income communities and communities of color. These environmental justice communities continue to bear the brunt of the harmful impacts from dirty energy and industrial infrastructure that pose significant public health and environmental hazards. At the same time, private companies receive billions of dollars to keep this polluting infrastructure in place.”

As shown here, the evidence presented for the egregious environmental injustice claim is more rhetoric than fact.  There is no benign way to make electricity but affordable and reliable electricity is a necessity for public safety, health and welfare.  Today’s question is whether New York City can risk reliability on unproven technology at the scale needed for its needs and can afford the costs needed to make intermittent and diffuse renewable energy available when and where it is needed.  I do not dispute that there is a problem with peaker power plants in New York City but this study over-estimates the effects of the existing plants and under-estimates the difficulty replacing them with anything other than fossil fuels.