In 2022, Micron announced its plans to build the largest semiconductor fabrication facility in the history of the United States. Micron intends to invest up to $100 billion over the next 20-plus years to construct a new chip fab plant in Clay, New York. My most recent article on this project documented my suggestion that the facility consider co-generation to supply the energy needs of the facility based on the energy density of wind and solar resources. I made the same recommendation in a comment on the Draft Scope of Work for the State Environmental Quality Review Act requirement to address the environmental impacts of the facility. This post describes the response to my comment.
I am following developments at Micron because the facility is going to be built within five miles of my home. I also follow the Climate Leadership & Community Protection Act (Climate Act) because of its impacts on New York. The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.
Micron intends to invest approximately $100 billion over the next 20 years to build a leading-edge semiconductor manufacturing campus in the Town of Clay on the approximately 1,400-acre White Pine Commerce Park. Micron intends to acquire the White Pine Commerce Park from the Onondaga County Industrial Development Agency (OCIDA) and construct a campus for four (4) memory fabrication plants (also known as Fabs) on the site. Each Fab, and their related facilities, would take approximately three to five years to construct. Interior fit-out of each Fab would continue after the building is complete, resulting in continuous site activity over approximately 20 years. It is anticipated that the first two (2) Fabs would be complete within approximately 10 years, and the second two (2) Fabs would be complete approximately 10 years thereafter. Skilled trade labor will be employed throughout the 20-year period. Each Fab would occupy approximately 1.2 million square feet (sf) of land and contain approx. 600,000 sf of cleanroom space, 290,000 sf of clean room support space, and 250,000 sf of administrative space. Each set of two fabs would be supported by approx. 360,000 sf of central utility buildings, 200,000 sf of warehouse space, and 200,000 sf of product testing space housed in separate buildings.
In August I prepared an article that described the reaction of Richard Ellenbogen to the massive amount of energy needed by the facility. I correspond with him regularly because he has spent a lot of time evaluating the Climate Act net-zero transition. I recently described his comprehensive presentation on the transition. When I let him know that the original projection for energy use that would be the same as the state of Vermont has been expanded to be the same as Vermont and New Hampshire he responded with the following:
I have been using the Micron facility as an example of how the Climate Act is actually going to increase NY State’s carbon footprint because transmitting all of that energy to the Micron site, as much as is used by the state of Vermont, over long distances was going to result in an amount of lost energy on the wires that could operate 1-3/4 Cornell Universities. One of my readers sent me an update of energy use because now it is projected that the Clay complex will consume 16 billion kilowatt-hours of electricity per year, as much as Vermont and New Hampshire combined, or 16,000 Gigawatt Hours annually (16 Tera-watt hours). That is double the original projections and the idea that this could be supported with renewable generation is laughable. 16,000 GWh is an 11% increase in NY State electric usage just related to the one facility. The line loss will also double to consume the output of about a 100 megawatt fossil fuel plant under continuous operation.
To put the Micron facility’s usage into perspective, in its last full year of operation the 2 Gigawatt Indian Point nuclear plant generated 16.3 Tera-watt hours so the Micron facility will need to be supported by a 2 Gigawatt fossil fuel or nuclear plant on site or 2.1 Gigawatts of generation off site, 5% more. NY State’s policy makes absolutely no sense. To run the Micron facility would require using about 4 GW of the projected 9 GW of offshore wind to support the plant or 16 GW of solar arrays covering 128,000 acres (80 acres per 10 MW) or 200 Square miles. NY State has 7 million acres of farmland so solar arrays to support the Micron facility would use almost 2% of the farmland in the state and would also require an enormous amount of battery storage, the cost of which would greatly exceed the cost of a nuclear plant on site. A combined cycle generating plant on site would be about 75% less than the cost of the nuclear plant. Both the combined cycle gas plant and the nuclear plant on-site offer the option of recovering the waste heat and using it in the plant to make Micron even more energy efficient. With regard to the solar and wind, NY State is having major difficulties getting all of their renewable projects finished because of cost issues and interconnection issues, let alone adding this gigantic lead weight to the Camel’s back.
Draft Scoping Plan Comments
The Onondaga County Office of Economic Development is the lead agency for permitting the project. The agency with the office charged with the program is the Onondaga County Industrial Development Agency (OCIDA) whose mission is to “stimulate economic development, growth, and general prosperity for the people of Onondaga County by using available incentives, rights, and powers in an efficient and cooperative manner.” Needless to say, this massive project is quire a feather in the cap for Onondaga County.
Assigning OCIDA as the lead agency makes sense from the implementation standpoint because governmental agencies have an easier time getting permits. However, there is a disconnect between the agency and Micron. Both Richard Ellenbogen and I submitted comments on the draft scoping plan suggesting that the environmental impact assessment include a co-generation option. I would not be surprised in the least that Micron is not aware of our recommendation.
The OCIDA final response to comments document basically blew off our recommendation. The following represents the entire response. The responses were listed by number: Ellenbogen (24) and Caiazza (25) comments:
Comment 3: Commenters suggest that the Draft Environmental Impact Statement should include an alternative to add a Combined Cycle generating plant on the Micron Property. (24, 25)
Response: See Response to NYSDEC Comment 5.
NYSDEC Comment 5: The DEIS should include a discussion of potential alternatives and mitigation that could reduce energy and fuel demands during construction and the long-term operation of the facility, including renewable energy sources.
Response: The Scope has been revised to indicate that the DEIS will include a summary of other alternatives previously considered but determined not to be feasible, including an alternative that relies exclusively on alternative sources of energy (beyond use of renewable energy for purchased electricity). The DEIS will also assess the proposed use and conservation of energy (including provisions for renewable energy sources). The DEIS will include an evaluation of energy impacts from construction and long-term operation of the facility, along with potential mitigation of those impacts.
Unfortunately, there is no mention of a combined cycle generating plant in the Final Scope of Work. I guess that Micron could include the option for a co-generation plant in the future, but it would certainly affect the permitting schedule. If they do recognize the value, I believe their best approach would be to do the permitting separately. I guess there is still hope.
Discussion
The Micron facility could be a tremendous boon to Central New York. I hope it goes forward but the reality is that New York energy prices are high now and will increase significantly when the Climate Act transition to zero emissions generating resources proceeds. The cogeneration proposal offers the most likely way to keep energy costs low enough so that Micron can compete with global chip manufacturers.
I previously wrote that the development of Micron within the Climate Act framework will be a good test of pragmatic environmentalism. The tradeoff between Climate Act absolutism, i.e., demanding nothing less than zero, with the extra costs associated with that approach versus the need to keep the Micron facility in New York competitive with the global chip market by accepting non-zero emissions is an important substantive issue.
I am not entirely discouraged by the decision not to include co-generation in the Final Scoping Plan for Micron. It is more important to get the permits in place now so that construction can begin on schedule. Adding the co-generation scenario would distract from that goal.
Make no mistake, if Micron comes to the same conclusion as Ellenbogen and I that the advantages of co-generation are so indisputable and proposes such an approach the feces will become entangled with the impeller. The zero emissions ideologues will scream very loudly and invoke every emotional argument they can. The same politicians that are claiming success for getting Micron to commit are, in many cases also Climate Act supporters. There will be tremendous pressure on those politicians demanding zero-emissions generation while at the same time making it clear that nuclear is unacceptable even if it is the only zero-emissions generation that we know will work. What the ideologues cannot do is argue on the basis of the numbers and the science. Reality is not on their side.
In 2022, Micron announced its plans to build the largest semiconductor fabrication facility in the history of the United States. Micron intends to invest up to $100 billion over the next 20-plus years to construct a new chip fab plant in Clay, New York. A recent letter to the Editor of the Syracuse Post-Standard posed the questions: I wonder why the citizens of our state must be the sole providers of electricity to Micron? Shouldn’t Micron at least share in producing electrical power? The author went on to make recommendations that are inconsistent with the energy density of wind and solar that relate to the viability of the venture. This post documents the response I submitted to that letter.
I am following developments at Micron because the facility is going to be built within five miles of my home. I also follow the Climate Leadership & Community Protection Act (Climate Act) because of its impacts on New York. The letter relates to both interests. The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.
Overview
The Climate Act established a New York “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.” In brief, that plan is to electrify everything possible using zero-emissions electricity. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies. That material was used to develop the Draft Scoping Plan. After a year-long review, the Scoping Plan recommendations were finalized at the end of 2022. In 2023 the Scoping Plan recommendations are supposed to be implemented through regulation, PSC orders, and legislation. Environmental permitting is part of these implementation concerns.
Micron Chip Fab Faciliity
The description in the Environmental Assessment Form states:
Micron intends to invest approximately $100 billion over the next 20 years to build a leading-edge semiconductor manufacturing campus in the Town of Clay on the approximately 1,400-acre White Pine Commerce Park. Micron intends to acquire the White Pine Commerce Park from the Onondaga County Industrial Development Agency (OCIDA) and construct a campus for four (4) memory fabrication plants (also known as Fabs) on the site. Each Fab, and their related facilities, would take approximately three to five years to construct. Interior fit-out of each Fab would continue after the building is complete, resulting in continuous site activity over approximately 20 years. It is anticipated that the first two (2) Fabs would be complete within approximately 10 years, and the second two (2) Fabs would be complete approximately 10 years thereafter. Skilled trade labor will be employed throughout the 20-year period. Each Fab would occupy approximately 1.2 million square feet (sf) of land and contain approx. 600,000 sf of cleanroom space, 290,000 sf of clean room support space, and 250,000 sf of administrative space. Each set of two fabs would be supported by approx. 360,000 sf of central utility buildings, 200,000 sf of warehouse space, and 200,000 sf of product testing space housed in separate buildings.
Micron should share in producing power for its chip fab letter
Scott Love from Jamesville, NY sent a letter to the editor proposing several actions for the power needs of the facility.
After reading the article “Leaders: Grid must grow for Micron, others” in the Dec. 3, 2023, Business section of The Post-Standard, I wonder why the citizens of our state must be the sole providers of electricity to Micron? Shouldn’t Micron at least share in producing electrical power? The acreage covered by the Micron facility roofs should be used for producing solar power. In addition, hydro generators should be considered for the almost 40 miles of pipeline to and from Lake Ontario. On-site wind power should also be considered.
If Micron is to be considered a leader to the future of our community, then it is time for them to be forward-thinking in their planning.
There are several points raised that are ripe for comment in this letter. The paper published the following in response:
Scott Love recently suggested that Micron should share the responsibility to provide the electricity necessary for the facility. I agree with the idea but not his suggested approach.
He suggested that the facility use rooftop solar, think about on-site wind power, and consider hydro in the pipeline from Lake Ontario. That won’t work. The energy density of solar and wind is low. Even if the entire Micron footprint of 1,400 acres was covered with solar panels, panels would provide less than 1% of the power needs. Wind requires even more space so would provide less of the energy needed. Lake Ontario is lower than the Micron site so the water must be pumped up to the facility.
I believe a co-generation facility using natural gas or nuclear power is appropriate. For starters, it would eliminate the need for energy storage when the wind is not blowing or sun not shining. On-site generation makes sense because it reduces line loss and waste heat produced can be used for heating and manufacturing processes. Small modular nuclear reactors are not yet commercially available, but the facility could be designed to use that technology in the future. In the meantime, a combined-cycle gas turbine facility could be built. Carbon dioxide could be minimized by using it in on-site greenhouses that convert it to food.
If Micron is going to be a part of our community, it is time for everyone to be forward thinking and pragmatic about how best to make them competitive.
The remainder of this article summarizes the overall issue of Micron energy requirements and specific concerns with the letter.
Micron Energy Use
In August I prepared an article that described the reaction of Richard Ellenbogen to the massive amount of energy needed by the facility. I correspond with him regularly because he has spent a lot of time evaluating the Climate Act net-zero transition. I recently described his comprehensive presentation on the transition. When I let him know that the original projection for energy use that would be the same as the state of Vermont has been expanded to be the same as Vermont and New Hampshire he responded with the following:
I have been using the Micron facility as an example of how the Climate Act is actually going to increase NY State’s carbon footprint because transmitting all of that energy to the Micron site, as much as is used by the state of Vermont, over long distances was going to result in an amount of lost energy on the wires that could operate 1-3/4 Cornell Universities. One of my readers sent me an update of energy use because now it is projected that the Clay complex will consume 16 billion kilowatt-hours of electricity per year, as much as Vermont and New Hampshire combined, or 16,000 Gigawatt Hours annually (16 Tera-watt hours). That is double the original projections and the idea that this could be supported with renewable generation is laughable. 16,000 GWh is an 11% increase in NY State electric usage just related to the one facility. The line loss will also double to consume the output of about a 100 megawatt fossil fuel plant under continuous operation.
To put the Micron facility’s usage into perspective, in its last full year of operation the 2 Gigawatt Indian Point nuclear plant generated 16.3 Tera-watt hours so the Micron facility will need to be supported by a 2 Gigawatt fossil fuel or nuclear plant on site or 2.1 Gigawatts of generation off site, 5% more. NY State’s policy makes absolutely no sense. To run the Micron facility would require using about 4 GW of the projected 9 GW of offshore wind to support the plant or 16 GW of solar arrays covering 128,000 acres (80 acres per 10 MW) or 200 Square miles. NY State has 7 million acres of farmland so solar arrays to support the Micron facility would use almost 2% of the farmland in the state and would also require an enormous amount of battery storage, the cost of which would greatly exceed the cost of a nuclear plant on site. A combined cycle generating plant on site would be about 75% less than the cost of the nuclear plant. Both the combined cycle gas plant and the nuclear plant on-site offer the option of recovering the waste heat and using it in the plant to make Micron even more energy efficient. With regard to the solar and wind, NY State is having major difficulties getting all of their renewable projects finished because of cost issues and interconnection issues, let alone adding this gigantic lead weight to the Camel’s back.
Micron Sustainability
The fact sheet for the proposed plan describes sustainability initiatives planned:
Achieve 100% water reuse, recycling and restoration.
Use 100% renewable electricity at the new facility.
Use green infrastructure and sustainable building attributes for the construction of the new fab to attain Leadership in Energy and Environmental Design (LEED) Gold status.
Mitigate and control greenhouse gas emissions (GHG) for the new facility.
Incorporate energy efficiency measures.
Utilize green hydrogen – hydrogen formed through electrolysis powered by renewable electricity, without GHG emissions – to the extent feasible to displace/replace natural gas and gray hydrogen consumption.
Adopt measures to reduce and avoid waste generation and achieve zero hazardous waste to landfill.
I have been asked whether I think this facility will ever get built out as proposed. While I hope that it works out my skepticism increases in direct proportion to the number of commitments to politically correct narratives. This sustainability fact sheet is worrisome in that regard. The viability of this facility hinges on its ability to provide cost-competitive chips that require an energy intensive process. The Climate Act is going to raise energy prices and affect that metric. Consider those pledges relative to competitive viability.
This chip fab plant will use enormous amounts of water. Last summer it was disclosed that the environmental assessment expected that when the plant is fully fitted out that 40 million gallons of water per day would be needed. This would require a new 54” pipeline from Lake Ontario to the facility. It is not clear how that is consistent with the 100% water reuse, recycling, and restoration pledge unless the presumption that discharging to the Oneida River that ends up in Lake Ontario where it comes back to the plan is the 100% recycling mechanism. For my part I am fine with that.
The 100% renewable electricity pledge is a competitiveness problem, however. Ellenbogen’s response shown above addresses many of the issues. In his recent presentation he pointed out that as part of the commitment NYPA has committed to allocating 140 MW of hydro generation to Micron. The problem with that is that it does not represent new hydro. That is just re-labelling the “zero-emissions” attribute from somebody else to Micron for that power.
I have reservations about the remaining pledges. Ultimately, pledging to meet virtue signaling sustainability goals could increase energy costs which I worry could affect the viability of the facility. I have to believe that behind the scenes Micron and the State are going to have to address the tradeoffs of added costs for these pledges.
The pledge to use green hydrogen formed through electrolysis powered by renewable electricity, without GHG emissions caters directly to the Climate Action Council. This one could have major financial effects. Note that the caveat “to the extent feasible to displace/replace natural gas and gray hydrogen consumption”, is the only instance in their sustainability fact sheet where there is any hint that these aspirational goals may not be feasible.
The pledge to use green infrastructure and sustainable building attributes for the construction of the new fab to attain Leadership in Energy and Environmental Design (LEED) Gold status is pandering s well. As long as these efforts reduce energy consumption this virtue signal will not impact the competitiveness of the facility.
Offering to mitigate and control greenhouse gas emissions (GHG) for the new facility is fine but there are regulations that are going to require than anyway.
Incorporating energy efficiency measures is another pledge. As long as these efforts reduce energy consumption that will reduce costs and is common sense approach to adding to viability.
The final pledge to “adopt measures to reduce and avoid waste generation and achieve zero hazardous waste to landfill” probably makes sense financially and adds viability value.
Documentation for my Letter
Love proposed that the facility use rooftop solar, think about on-site wind power, and consider hydro in the pipeline from Lake Ontario. He does not understand the scale of energy required or the concept of energy density. The energy density of solar and wind is low. Using the aforementioned analysis by Ellenbogen I calculated that even if the entire Micron footprint of 1,400 acres was covered with solar panels, they would provide less than 1% of the power needs because it takes a lot of space to gather energy from the sun. It might be counter intuitive but Ellenbogen and I both found references from federal agencies that said wind facilities require even more space to generate the same amount of energy. Due to space considerations, I could not point out that solar and wind resources at the facility site are unlikely to be particularly strong relative to other sites in New York because the site is in the lake-effect cloud belt and the area is flat. I expect that the facility footprint would likely produce even less of the energy needs than projected using state averages. Another point I could not make is that on-site production would need to provide energy storage to be useful.
The proposal to put hydro in the pipeline from Lake Ontario is laughable. Lake Ontario is lower than the Micron site so the water must be pumped up to the facility. That approach is an example of a perpetual motion machine. Ellenbogen also pointed out that even if it was downhill, do they really think that a 54″ diameter water pipe could put a dent in the energy needed? Micron’s 16.2 TWh will use the equivalent to 60% of all of the Hydro in the state or 26.8 TWh. Micron is supposed to use 10 million gallons per day after recycling with a 54″ pipe. That corresponds to 7000 gallons per minute. The Robert Moses / Lewiston Pumping Station uses 750,000 gallons per second or 45 million gallons per minute. That would be 6500 times as much.
Ellenbogen and I independently decided that co-generation would be the most appropriate on-site energy source. We believe a co-generation facility using natural gas or nuclear power is appropriate. The Ellenbogen presentation proposed allowing Micron Technologies to build a 2 GW combined cycle plant on their property. He points out that with generation on-site, the thermal energy could be used at the plant and the 500 GWh of annual line loss will be eliminated.
There are two choices for generation. Small modular nuclear reactors are not yet commercially available, but the facility could be designed to use that technology in the future. In the meantime, a combined-cycle gas turbine facility could be built. The downside of a natural gas co-generation plant is that it will emit CO2. One of the unresolved Climate Action Council questions is whether such a gas-fired turbine that includes carbon capture and sequestration would be allowed. According to the zealots, there still would be emissions and the law says zero emissions. Ellenbogen suggested using greenhouses to reduce CO2 emissions. Using the CO2 in them to enhance growth captures carbon in the plants and waste heat from turbines to warm them would tick off the locally sourced produce target and I am sure creative accounting comparing local produce to the produce shipped from overseas could claim GHG emission reductions. .
Conclusion
The development of Micron within the Climate Act framework will be a good test of pragmatic environmentalism. The tradeoff between Climate Act absolutism, i.e., demanding nothing less than zero, with the extra costs associated with that approach versus the need to keep the Micron facility in New York competitive with the global chip market is an important substantive issue. However, much of the Climate Act is style over substance. The press releases to date talk a stylish game about being green but the approach to making them look “green” is a simply shuffling attributes from existing sources. Ellenbogen and I believe that we should let them be green in reality with high efficiency generation that lowers energy costs to make them more competitive without faking it. For all the talk of jobs associated with the energy transition if the energy transition makes the Micron facility unable to compete on the world market then there will be an enormous hit on jobs.
Energy density is the reason that on-site wind and solar generation would only be virtue signaling. The area simply cannot generate enough electricity to be meaningful. I have no doubt that environmental activists will be upset that I recommend energy dense natural gas or nuclear cogeneration that could be installed on the footprint. However, if Micron is going to be a part of our community, it is time for everyone to be forward thinking and pragmatic about how best to make them competitive.
On July 14, 2023 the New York Independent System Operator (NYISO) released its quarterly assessment of reliability of the bulk electric system. The analysis found a deficit in reliability margins for the New York City area beginning in summer 2025. As a result, something must be done or there will be unacceptable risks to reliability that could cause power outages. Unfortunately, it is difficult to understand the reasons for this finding because of the complexity of the subject. This post includes a detailed explanation of the report and its implications. If you want a good non-technical summary, then I recommend James Hanley’s post Get Ready for the New York City Blackout of 2025.
I have been following the Climate Leadership & Community Protection Act (Climate Act) since it was first proposed. I submitted comments on the Climate Act implementation plan and have written over 300 articles about New York’s net-zero transition. I have devoted a lot of time to the Climate Act and New York’s energy planning because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good. Unfortunately, trying to explain the risks and issues associated with the transition is difficult because of the complexity of the problems and the fact that expert reports are dense and filled with jargon. The opinions expressed in this article do not reflect the position any of my previous employers or any other company I have been associated with, these comments are mine alone.
Resource Adequacy Assessments
The NYISO is responsible power system reliability and competitive markets for New York. As part of that mission NYISO determines whether generating resources and the transmission system can adequately meet expected load. They describe the resource adequacy analyses as follows:
Resource adequacy is the ability of the electric system to supply the aggregate electrical demand and energy requirements of the firm load at all times, considering scheduled and reasonably expected unscheduled outages of system elements. The NYISO performs resource adequacy assessments on a probabilistic basis to capture the random nature 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). Consistent with the Northeast Power Coordinating Council and New York State Reliability Council criterion, 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 event days per year.
So what does that mean? The first point is that the electric system is very complicated. I summarized my skepticism of the net-zero transition earlier this year in an article that included an overview of the electric system. Incredibly all the fossil, hydro, and nuclear generating stations in the Eastern Interconnection shown below work together. In order to provide electricity, the generating turbines are synchronized to turn at 1800 revolutions per minute. Operators keeps the voltages as constant as possible in the entire area but rely on those turbines to provide inertia as well as voltage control and that can be dispatched as necessary to match load. The NYISO operates the New York State control area within the Interconnection. In addition to the day-to-day operation, they plan for resource adequacy to ensure that the operators have generating resources available so that they can constantly match load.
The NYISO resource adequacy assessments rely on decades of observed characteristics of generating resources, the transmission system, and system load to develop the likelihood of system element outages. If a system has sufficient transmission and generation, then when a problem occurs (say lightning hits a transmission line) the system can respond without an extended outage. The NYISO has a well-established process to identify reliability needs. The analyses consider how the system can react to various combinations of issues based on historical observations of the existing system to determine the loss of load expectation (LOLE). The organizations overseeing New York reliability, the Northeast Power Coordinating Council and New York State Reliability Council, mandate that the New York State bulk power system is planned to meet the LOLE standard that any involuntary firm load disconnection is not more frequent than once in every 10 years, or 0.1 event days per year.
Annotated Executive Summary
This section quotes the Executive Summary in the report and explains the contents. As part of an on-going reliability assessment process the NYISO analyzes any expected changes to the generation and transmission system:
This report sets forth the 2023 Quarter 2 Short-Term Assessment of Reliability (“STAR”) findings for the five-year study period of April 15, 2023, through April 15, 2028, considering forecasts of peak power demand, planned upgrades to the transmission system, and changes to the generation mix over the next five years.
The analysis finds that there are issues associated with peaking power plants in New York City. I have been involved with this problem and these facilities since 2000. This topic has been the subject of multiple articles on this blog and I have summarized my articles as on overview that I can reference when the issue resurfaces. The Executive Summary notes:
This assessment finds a reliability need beginning in summer 2025 within New York City primarily driven by a combination of forecasted increases in peak demand and the assumed unavailability of certain generation in New York City affected by the “Peaker Rule.” In 2019, the New York State Department of Environmental Conservation adopted a regulation to limit nitrogen oxides (NOx) emissions from simple-cycle combustion turbines, referred to as the “Peaker Rule” (https://www.dec.ny.gov/regulations/116131.html)
The Peaker Rule culminated a decade-long process whereby the New York State Department of Environmental Conservation (DEC) instituted a framework to retire or control the “peakers”. The DEC, NYISO, facility owners and Consolidate Edison, the load serving entity for New York City, all worked together to ensure that the retirement would not endanger reliability. This latest analysis suggests that there are still issues to be resolved:
Combustion turbines known as “peakers” typically operate to maintain bulk power system reliability during the most stressful operating conditions, such as periods of peak electricity demand. As of May 1, 2023, 1,027 MW of affected peakers have deactivated or limited their operation. An additional 590 MW of peakers are expected to become unavailable beginning May 1, 2025, all of which are in New York City. With the additional peakers unavailable, the bulk power transmission system will not be able to securely and reliably serve the forecasted demand in New York City (Zone J). Specifically, the New York City zone is deficient by as much as 446 MW for a duration of nine hours on the peak day during expected weather conditions when accounting for forecasted economic growth and policy-driven increases in demand.
The following paragraph explains that the reliability need is expected because the latest projections of generation, load, and transmission availability have changed over time:
The reliability need is based on a deficient transmission security margin that accounts for expected generator availability, transmission limitations, and updated demand forecasts using data published in the 2023 Load & Capacity Data Report (“Gold Book”). The transmission security margin represents the balance between demand for electricity and the power supply available from generation and transmission to serve that demand. This assessment recognizes that there is uncertainty in the demand forecast due to uncertainties in key assumptions including population and economic growth, the proliferation of energy efficiency, the installation of behind-the-meter renewable energy resources, and electric vehicle adoption and charging patterns. These risks are accounted for in the transmission security margin calculations by incorporating the lower and higher bounds as a range of forecasted conditions during expected weather, specified in the Gold Book as the policy scenario forecasts. The lower and higher demand policy scenario forecasts reflect achievement of policy targets through alternative pathways and assume the same weather factors as the baseline demand forecast.
The Gold Book is the standard for electric data in New York. The following figure shows the range of the demand forecasts for New York City. I want to point out one thing. The emphasis is on providing generation for the peak load. This is a significantly more difficult problem than estimating the generation necessary for an average year. There are more short-term constraints that could affect generation and load that can be ignored on average.
I have some experience with the resource modeling projections and cannot over-emphasize the complexity of all the factors incorporated in the models. Unfortunately, there is a lot of uncertainty associated with projecting all those factors. That is why the NYISO is constantly re-evaluating the model inputs and projections. In addition, they are always looking to refine the model itself. Based on their latest estimates:
Under the baseline forecast for coincident summer peak demand, the New York City transmission security margin would be deficient by 306 MW in 2025 for a duration of 7 hours. However, accounting for uncertainties in key demand forecast assumptions, the higher bound of expected demand under baseline weather conditions (95 degrees Fahrenheit) in 2025 results in a deficiency of 446 MW over 9 hours. The deficiency would be significantly greater if New York City experiences a heatwave (98 degrees Fahrenheit) or an extreme heatwave (102 degrees Fahrenheit).
The NYISO is banking on one project to address this problem after 2025.
Overall, the New York City transmission security margin is expected to improve in 2026 if the Champlain Hudson Power Express (CHPE) connection from Hydro Quebec to New York City enters service on schedule in spring 2026, but the margin gradually erodes through time thereafter as expected demand for electricity grows. Beyond 2025, the forecasted reliability margins within New York City may not be sufficient if (i) the CHPE project experiences a significant delay, (ii) additional power plants become unavailable, or (iii) demand significantly exceeds current forecasts. Without the CHPE project in service or other offsetting changes or solutions, the reliability margins continue to be deficient for the ten-year planning horizon. In addition, while CHPE is expected to contribute to reliability in the summer, the facility is not expected to provide any capacity in the winter.
I am uncomfortable that there is this much reliance on a single project to address the problems identified. I discussed the start of construction late last year for the Champlain Hudson Power Express (CHPE) project. It is a 339-mile underground transmission line capable of bringing 1,250 MW from the Province of Quebec to Astoria Queens in New York City. I explained that I was worried about the schedule and costs of the project. The NYISO Resource Adequacy analyses must necessarily rely on the developer’s prediction for completion. Richard Ellenbogen and I share the timeliness concern. Richard noted that the project was proposed in 2011 and the PSC authorized it on 4/18/13. It has been 11.5 years since it was proposed, 9.5 years since it was authorized, and construction started a year after the funding contract was signed. In addition, it has recently come out that landowners on sections of the right-of-way that are on land have just been informed that they will be impacted. The likelihood of additional delays seems high. Given that other renewable projects are being re-evaluated because of price increases due to inflation and increased cost of materials it seems that this project will also have the same problems. Given its importance to New York City reliability, I cannot conceive of any scenario in which the State will not grant any cost overruns requested by the developers. This project is already expensive equating to an estimated increase in customer electric bills of 2.1 – 4.1% (or $2.08 – $4.08 per month for the average residential customer. I am confident that at the end of the day the final costs will be much higher.
The STAR quarterly report did not limit its analysis to just New York City.
In addition to New York City, this assessment also evaluated the transmission security margins for the statewide system as well as Lower Hudson Valley and Long Island localities. For these localities, the planned Bulk Power Transmission Facilities (“BPTF”) through the study period are within applicable reliability criteria based on the baseline summer coincident peak demand forecast with expected weather and with the planned projects meeting their proposed in-service dates. The NYISO assessed the resource adequacy of the overall system and found no resource adequacy reliability needs.
The NYISO is a product of the de-regulated New York electric system. As such they are ardent supporters of “market” solutions. This adds a layer of uncertainty because NYISO must develop some sort of incentive for a developer to provide the necessary resources. If it was an attractive investment, then I would expect that someone would already be developing the necessary resources. In addition, Con Ed must also determine if local transmission upgrades can resolve the problem.
The short-term need observed in 2025 is a Near-Term Reliability Need. As a result, solutions will be solicited, evaluated, and addressed in accordance with the NYISO Short-Term Reliability Process. The need arises within the Con Edison Transmission District; therefore, Con Edison is the Responsible Transmission Owner for developing a regulated solution.(Reference NYISO’s Open Access Transmission Tariff Section 38.3.6)
The report identifies another particular issue that illustrates why regular STAR analyses are required and why this issue is coming up now. Although all the affected parties may know that there will be changes to the system and have reasonable expectations what they will be, the NYISO cannot officially act until certain filings are made.
Central Hudson identified transmission security issues in its transmission district on its non-BPTF system. These are primarily driven by the assumed unavailability of certain generation in its district affected by the Peaker Rule. Given that those generators have not yet provided complete Generator Deactivation Notices to the NYISO, the local non-BPTF criteria violations identified by Central Hudson are being provided for information but were not assessed to identify possible Generator Deactivation Reliability Needs at this time.
The report also describes an upcoming issue that will be considered officially in a subsequent report. The “informational scenario” considers interconnecting large loads: the Micron New York semiconductor manufacturing (530 MW in 2030), the Air Products and Chemicals (Q#1446), and other load changes that increase load another 694 MW.
As an informational scenario, this STAR includes an evaluation of the impact of additional large load interconnection projects primarily in western and central New York. The anticipated increases to the demand forecast due to these large loads in 2025 is 764 MW which results in a corresponding reduction to the available margin, such that in 2025 the statewide system margin is projected to be deficient of 145MW. By 2033, additional large loads increase the demand by 1,224 MW which results in a corresponding deficient margin of 104 MW. If CHPE does not begin operation, the state wide system margin is projected to be deficient for all years 2025 through 2033 when considering the additional large loads. The 2023 Quarter 3 STAR will include these load projects and the associated system margin impacts. The solution to the New York City reliability need identified in this STAR may also address the state wide system margin concern.
The Executive Summary summarizes their approach:
The wholesale electricity markets administered by the NYISO are an important tool to help mitigate these risks. The markets are designed, and continue to evolve and adapt, to send appropriate price signals for new market entry and the retention of resources that assist in maintaining reliability. The potential risks and resource needs identified in the NYISO’s analyses may be resolved by new capacity resources coming into service, construction of additional transmission facilities, and/or increased energy efficiency and integration of demand-side resources. The NYISO is tracking the progression of many projects that may contribute to grid reliability, including numerous offshore wind facilities that have not yet met the inclusion rules for reliability assessments. The NYISO will continue to monitor these resources and other developments to determine whether changing system resources and conditions could impact the reliability of the New York bulk electric grid.
Note that there are three ways the problem identified can be resolved: building new capacity resources, construction of additional transmission facilities, and/or reducing load expectations with increased energy efficiency and integration of demand-side resources. Even if the Hochul Administration came to its senses and decided to facilitate the construction of dependable generating capacity, that is to say, fossil-fired generators, there is no way that any generating resource to support reliability could get built in this timeframe. My rule of thumb for just getting permits in New York City is a minimum of three years. The summer of 2025 is only two years away. Of course, the possibility of any new fossil infrastructure is very unlikely anyway. Designing, permitting, and building additional transmission facilities may not take quite as long but I cannot imagine this solution could be available in two years. There already are great expectations for reducing load so I cannot imagine any scenario that could reduce additional load on the order necessary to meet the identified load shortfall.
The final paragraph in the Executive Summary describes the specific filings that will trigger further STAR revisions.
As generators that are subject to the DEC’s Peaker Rule submit their Generator Deactivation Notices, the NYISO and the responsible Transmission Owners will continue to evaluate in future STARs whether Generator Deactivation Reliability Needs arise from the deactivation of Initiating Generators. (Reference NYISO’s Open Access Transmission Tariff Section 38.1 state that an “Initiating Generator” is “a Generator with a nameplate rating that exceeds 1 MW that submits a Generator Deactivation Notice for purposes of becoming Retire or entering into a Mothball Outage or that has entered into an Installed Capacity (ICAP) Ineligible Forced Outage pursuant to Section 5.18.2.1 of the ISO Services Tariff which action is being evaluated by the ISO in accordance with its Short-Term Reliability Process requirements in this Section 38 of the ISO Open Access Transmission Tariff.
Discussion
The Findings section expands the description of the problem found. Without changes to existing load pattern the summer peak load demand in New York City would be “deficient by 306 MW in 2025 for a duration of 7 hours”. There are uncertainties in the load demand forecasts. Assuming the upper bound of “demand under baseline weather conditions (95 degrees Fahrenheit) in 2025 results in a deficiency of 446 MW over 9 hours.” If the weather is hotter or lasts for an extended period the “deficiency would be significantly greater.” This exemplifies the tradeoffs the NYISO and NYSRC must make when assessing resource adequacy and reliability standards. If the deficiency is “significantly greater” then it will be impossible to manage the load without rolling blackouts.
The NYISO writes: “The deficient margin is primarily due to the increased demand forecasts within New York City combined with the planned unavailability of simple-cycle combustion turbines to comply with the DEC’s Peaker Rule in 2025”. Apparently, it is not politically correct to point out that Hochul Administration’s policy that finalized the shutdown of 2,000 MW of nuclear power and the disapproval of a plan to build a 1,040 MW, eventually reduced to 437 MW, combined cycle facility exacerbated this problem and that if those resources were available there would not be a problem.
As it stands now, I expect that the solution will be an extension of the operating permits for the peaking turbines because there is no other viable solution to maintain reliability.
The NYISO describes the process and explains how it will be resolved in the following figure. They have identified the reliability need. They will ask Consolidated Edison if the problem can be resolved with transmission system revisions in Step 2. At the same time in Step 3, NYISO will solicit market-based solutions from other developers. In the next step NYISO reviews the proposed solutions “to determine if they are viable and sufficient to address the identified need.” The NYISO description of the last step notes:
Timing is an essential component of the NYISO’s evaluation. If proposed solutions are not viable or sufficient to meet the identified reliability need, interim solutions must be in place to keep the grid reliable. One potential outcome could include relying on generators that are subject to the DEC’s Peaker Rule to remain in operation until a permanent solution is in place. The DEC’s Peaker Rule anticipated this scenario when it authorized the NYISO to designate certain units to remain in operation beyond 2025 on an as-needed basis for reliability. Based on findings from its Short-Term Reliability Process, the NYISO may designate certain units, in sufficient quantity, to remain in operation for an additional two years (until May 1, 2027) with the potential of an additional two-year extension (to May 1, 2029) if a permanent solution that is needed to maintain reliability has been selected but is not yet online. The NYISO would only temporarily retain peakers as a last-step approach if it does not expect solutions to be in place when the identified reliability need is expected in 2025.
Reaction
Utility Dive described the report. Their article quotes Zach Smith, vice president of system and resource planning for the NYISO as saying the assessment “reflects the extraordinary challenges of the grid in transition.” It also notes that the report acknowledges “uncertainty” in the demand forecast surrounding assumptions including population and economic growth, the proliferation of energy efficiency, the installation of behind-the-meter renewable energy resources, and EV adoption and charging patterns.
The reaction of parties in New York State was predictable. Marie French writing at Politico solicited comments from the Hochul Administration:
“To be clear: The reliability of our grid is not in question,” Hochul spokesperson Katy Zielinski said in a statement. “We are committed to ensuring New Yorkers have a reliable and affordable power supply — and we can do this while accomplishing our nation-leading climate goals. Governor Hochul remains fully committed to rapidly decreasing emissions and setting an example for how clean energy and reliability can go hand-in-hand.”
French said that Zielinski cited the planned Canadian hydropower line, the Clean Path line and offshore wind projects as ways to bring more renewables into New York City. There is a fundamental issue with these projects because they all rely heavily on distant transmission that is overly vulnerable to outages One of the New York City blackouts occurred because a transmission line into the city went down and in-city generation could not be brought up fast enough to react to the loss of energy supply. There are specific reliability rules in place that mandate a minimum capability of in-city generation when storms threaten transmission lines into the City. I am not sure how this will be addressed in the future. The Canadian hydropower line may not be affected by storms but still could go down unexpectedly for other reasons. The Clean Path project is “is comprised of more than 20 renewable energy generation projects and an approximate 175-mile, underground transmission line. I am guessing that the argument is that an underground line can provide power that is not subject to storm outages so is exempt from the transmission line reliability rule. However, even if they are much less likely to go out, when they do have problems fixing them is much more difficult. Counting on offshore wind as a viable replacement in the City is very risky unless it is coupled with sufficient energy storage to cover the energy needs for an entire heat wave because the meteorological conditions that cause extreme heat are associated with high-pressure systems that also have light winds.
The Peak Coalition has been the primary mover for peaking power plant environmental justice. French mentioned their statement that notes:
PEAK Coalition is gravely concerned with the impact that the reliability deficit estimated in the Short-Term Assessment of Reliability (STAR) report for Q2 of 2023 released by the New York Independent Systems Operator (NYISO) will have on communities that live near power plants. We encourage all stakeholders involved in the energy planning process to take concrete action to prevent delaying the closure of fossil fuel peaker plants in 2025 and beyond. These plants harm the communities that surround them every hour that they operate. PEAK refuses to accept a scenario in which environmental justice communities must suffer further harm to guarantee further profligate summertime energy consumption in commercial buildings and wealthy communities.
I have evaluated the EJ claims. The PEAK coalition has stated that “Fossil peaker plants in New York City are perhaps the most egregious energy-related example of what environmental injustice means today.” The influence of this position on current New York State environmental policy has led to this issue finding its way into multiple environmental initiatives. However, the presumption of egregious harm is based on selective choice of metrics, poor understanding of air quality health impacts, and ignorance of air quality trends.
As noted previously the NYISO is invested in market solutions. French also got a statement from the NYISO that is completely consistent with that approach:
“We’ve identified the reliability need, so we’re confident that’s present for summer 2025,” said NYISO spokesman Kevin Lanahan. “We’re also confident that we can solve the reliability [need]. That’s the nature of our planning process, to identify those issues with enough time to solve the problems so we’re confident we can find the solution and keep the system reliable.”
French also got a statement from Gavin Donohue at the Independent Power Producers:
“The pace of play is not keeping up with pace of promises, and this report makes that clear,” said Independent Power Producers of New York president and CEO Gavin Donohue, who represents the state’s existing nuclear, renewable and predominantly fossil fuel power plants. “This report should draw attention from state officials in shaping realistic public policies. I encourage the NYISO to identify solutions that are market-based so we can set ourselves on the pathway to a cleaner energy future, while maintaining the reliability of our grid at affordable rates.”
The mistake New York has made is not its goal to eventually reduce NOx emissions but its rush to shut down the peakers — and Indian Point — before developing reliable replacement sources of power. Notably, the Department of Environmental Conservation rejected proposals by NRG Energy to update nearly 1,000 megawatts of electricity production in the city to newer, cleaner-burning, and NOx-standard compliant combined-cycle power plants, claiming that NRG “failed to demonstrate the need or justification for the proposed project.”
This “shutdown first, replace later” model was a major cause of rolling blackouts on the West Coast, but New York authorities didn’t bother to learn from California’s experience. Simple common sense would indicate that the wise approach would be to find assured sources of reliable and dispatchable electricity production before taking critical power plants offline. Sadly, common sense was the first victim of New York energy policy. Even more sadly, it won’t be the last.
Conclusion
Despite assurances from Hochul spokesperson Katy Zielinski, the reliability of the New York City grid is in question. The plans rely on resources that are new to New York and that increases uncertainty. Presuming that proposed projects will replace operational facilities on the schedule proposed is very risky.
There is another dynamic here that will be interesting to watch. Peaker power plants are a primary scapegoat for the New York City EJ community. The PEAK Coalition has already gone on record stating that “If NYISO is forced to issue reliability-must-run orders, New Yorkers will know that electric utilities and state governments willingly failed to act to protect communities most impacted by fossil fuel emissions and climate change”. The electric utilities and state government have failed to explain the potential impacts to the disadvantaged communities if fossil-fired peaking units are not replaced with proven technology. The risks to those communities imposed by the presence of such resources are not nearly as large as the risks to those communities from blackouts. Keeping the lights on is the better social choice.
Thanks to Russell Schussler for review and helpful comments. Any technical errors are mine.
To her credit Susan Arbetter, the host of Spectrum News Capital Tonight program, has tried to expose viewers to issues related to the Climate Leadership & Community Protection Act (Climate Act). Recently she interviewed Rich Dewey CEO of the New York Independent System Operator (NYISO) about the recent release of the annual NYISO Power Trends report and its findings relative to Climate Act implementation. Both Arbetter and Dewey have roles to play in the Albany political scene that require them to be diplomatic and politically correct. As a result, the severity of the problems mentioned was not made clear.
I have been following the Climate Act since it was first proposed. I submitted comments on the Climate Act implementation plan and have written over 300 articles about New York’s net-zero transition. I have extensive experience with air pollution control theory, implementation, and evaluation having worked on every cap-and-trade program affecting electric generating facilities in New York including the Acid Rain Program, RGGI, and several Nitrogen Oxide programs since the inception of those programs. I follow and write about the RGGI cap and invest CO2 pollution control program so my background is particularly suited for the New York Cap and Invest proposal to provide compliance certainty for the Climate Act schedule that has unacknowledged risks associated with the Power Trends report. I have devoted a lot of time to the Climate Act because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good. 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.
Climate Act Background
The Climate Act established a New York “Net Zero” target (85% reduction and 15% offset of emissions) by 2050 and an interim 2030 target of a 40% reduction by 2030. The Climate Action Council is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.” In brief, that plan is to electrify everything possible and power the electric grid with zero-emissions generating resources by 2040. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies. That material was used to write a Draft Scoping Plan. After a year-long review the Scoping Plan recommendations were finalized at the end of 2022. In 2023 the Scoping Plan recommendations are supposed to be implemented through regulation and legislation. The New York Cap and Invest (NYCI) initiative is one of those recommendations.
According to the NYCI overview webinar documentation, NYCI will “establish a declining cap on greenhouse gas emissions, limit potential costs to New Yorkers, invest proceeds in programs that drive emission reductions in an equitable manner, and maintain the competitiveness of New York businesses and industries.” There is an unrecognized dynamic between the goals of a declining cap and the need to limit potential costs. One touted feature of NYCI is that the declining cap provides compliance certainty so that the Climate Act targets (e.g., 40% reduction in GHG emissions by 2030) will be met. There is no question that there will be massive costs associated with the transition to zero emissions across the economy, but NYCI is supposed to limit potential costs. If the investments necessary to deploy zero emissions resources are insufficient then the energy system will fail to meet the cap limits. Even if the money is available, it may not be possible to build it fast enough to meet the arbitrary CLCPA schedule. My biggest concern is that the ultimate compliance strategy for the NYCI program is stop using fossil fuels even if replacement energy sources are not available. In that case, that means that compliance certainty will lead to an artificial energy shortage.
Interview with Dewey
Arbetter’s interview with Dewey is a good overview of the issues facing the NYISO. That organization has a mission to “Ensure power system reliability and competitive markets for New York in a clean energy future”. Arbetter explained that “Decarbonizing New York while at the same time ensuring the seamless functioning of the state’s electric grid takes a delicate balance”. The description of the interview states:
If fossil fuels are eliminated before enough renewable energy comes on-line, that balance will be disrupted.
The New York Independent System Operator (NYISO), the state’s nonprofit electric grid operator, in part, oversees that balance. Each year, NYISO publishes a report called Power Trends.
This year, the report warns the state is facing “declining reliability margins.”
While the grid operator is “fully committed” to New York state’s aggressive decarbonization goals under the Climate Leadership and Community Protection Act (CLCPA), NYISO President and CEO Rich Dewey told Capital Tonight that they must consider reliability first.
“Reliability is the top job,” he said. “When you’re managing the power grid, you’ve got to make sure that you’ve always got adequate supply to balance that demand.”
Currently, according to Dewey, there’s a “tremendous” buildout of new supply, which is largely renewable. But hooking up those new plants to the grid – a process call interconnectivity — is taking a lot of time.
Meanwhile, older legacy fossil fuel plants are being shut down. NYISO is responsible for the due diligence and research that go into interconnectivity.
According to Dewey, there are efforts underway to make that process more efficient.
“It’s a gigantic priority for me and for our organization,” Dewey said. “The challenge really arises from the fact that the new solar and wind resources are being built and interconnected at points on the grid where there does not exist already a generating plant.”
During the interview itself Dewey explained that NYISO reliability concerns about the transition to zero-emissions intermittent resources must be coordinated with retirements of existing fossil-fired resources. It is necessary to develop wind and solar and get the power from those resources to where it is needed before the existing resources can be retired or problems will ensue. It is often unrecognized that connecting the new resources to the grid is not a trivial task and Dewey explained they are working on the need for more support in this regard. The transition is also complicated by the fact that the decarbonization strategy for other sectors is electrification which will necessarily increase demand.
Power Trends 2023
The annual Power Trends report describes recent history and trends on the electric system. NYISO has prepared a key takeaways fact sheet in addition to the Power Trends 2023 report itself. The following graphic summarizes the key messages.
I will address each of these takeaways in the rest of this section.
The first takeaway “Public Policies are driving rapid change in the electric system in the state, impacting how electricity is produced, transmitted, and consumed” states the obvious that the Climate Act mandate to completely transform the energy system of the state affects everything in the electric system.
The second takeaway address’s reliability margins which are shrinking because fossil-fired generators are retiring at a faster pace than new renewable supply is entering service. What are they talking about? The Installed Reserve Margin (IRM) is “the minimum level of capacity, beyond the forecasted peak demand, which utilities and other energy providers must procure to serve consumers”. Power Trends notes “The IRM for the 2023-2024 capability year is 20.0% of the forecasted New York Control Area peak load, an increase from 19.6% last year. Based on a projected summer 2023 peak demand of 32,048 MW and the IRM, the total installed capacity requirement for the upcoming summer capability period is 38,458 MW”.
There is a significant underlying issue with this metric. In order to determine resource adequacy for the IRM, NYISO has a process that has been developed and refined over decades. Over the years this work has determined just how much extra power capacity is necessary to cover the unexpected loss of operating capacity at any one time. Importantly, a fundamental presumption based on observations in the NYISO analyses is that conventional generating resources operate independently. One of the biggest issues with a generating system dependent upon wind and solar resources is that there is a very high correlation between wind and solar output across the state. At night every solar resource provides zero energy. The primary cause for low wind energy output is a high-pressure system which is typically larger than New York. That means that the output for all the wind facilities in New York are highly correlated now and even when offshore wind comes on line this will continue. NYISO and the New York State Reliability Council are just coming to grips with this problem and how future resource adequacy analyses will have to be modified to refine the IRM standard. Finally, note that this problem is exacerbated by the fact that the hottest and coldest periods in New York associated with the highest electrical loads correlate very well with high pressure systems with light winds. In the winter when the solar resource is low because days are shorter and irradiance lower this problem is even more difficult.
The reliability margin takeaway discussion also raises implementation schedule concerns: “The potential for delays in construction of new supply and transmission, higher than forecasted demand, and extreme weather could threaten reliability and resilience of the grid.” This is one of my primary concerns with NYCI. Even if the technologies needed actually work, they might not be deployed fast enough to meet the NYCI cap limits.
The next takeaway addresses the issue of interconnection. It notes that “The NYISO’s interconnection process balances developer needs with grid reliability”. There is a lot of pressure on the NYISO to approve facility interconnection requests by those who will bear no responsibility if the rush to approve creates unanticipated issues. This is complicated. A reliable electric power system is very complex and must operate within narrow parameters while balancing loads and resources and supporting synchronism. New York’s conventional rotating machinery such as oil, nuclear, and gas plants as well as hydro generation provide a lot of synchronous support to the system. This includes reactive power (vars), inertia, regulation of the system frequency and the capability to ramping up and down as the load varies. Wind and solar resources are asynchronous and cannot provide this necessary grid ancillary support. The New York State Reliability Council (NYSRC) has proposed a new reliability rule for large asynchronous resources that is necessary but will likely add unavoidable delays to the interconnection process.
The Climate Action Council has the responsibility to develop the Scoping Plan to implement the Climate Act. Unfortunately, the members were chosen more for ideology than technical expertise and one of the primary ideological beliefs of many on the Council was that existing technology is sufficient for the transformation of the electric sector. The next takeaway argues otherwise: “To achieve the mandates of the CLCPA, new emission-free supply with the necessary reliability services will be needed to replace the capabilities of today’s generation.” Note that this position is supported by the Integration Analysis, the NYSRC, and even the Public Service Commission (PSC) that recently convened a proceeding to address this particular issue. The Council’s misunderstanding of this requirement could have serious consequences.
This new resource is an instance where the NYISO must placate the supporters of the Climate Act by downplaying the difficulty of developing this resource. The Power Trend takeaway states: “Such new supply is not yet available on a commercial scale” but they have not publicly come out bluntly and said how difficult this might be. In my draft scoping plan comments I argued there is a real concern because any resource that is emission-free and provides necessary reliability services must overcome the Second Law of Thermodynamics. Any energy storage system must lose energy as it is stored and then again as it comes out of storage. This limits the viability of every storage system touted for this resource.
The final takeaway addresses the wholesale electricity market. The NYISO is a creation of the deregulated electric system and its market. It is not surprising that the NYISO touts their critical role in the transition in this regard. However, in my opinion, the market adds a layer of complexity. It is not enough to just determine what resources are necessary to keep the lights on but it is also necessary to develop a market incentive to provide that resource. What happens if the PSC proceeding recommends an emissions free resource that provides the grid support needed but nobody wants to risk the money for a resource that is needed for a limited period during critical demand peaks?
Peaking Power Plants
There were other press reports describing Power Trends. Reuters emphasized the “balanced and carefully planned transition” theme. New York Focus chose to point out that the report indicates that “Air-polluting “peaker” plants were a top priority for closure in New York’s green transition. But the state isn’t building clean energy fast enough to replace them on time.” Arbetter also raised the “peaker” power plant issue. Dewey said there are “dirty” units that reside in “underprivileged communities” and Arbetter said they cause “lots of pollution and environmental racism”.
This is a complicated problem that has become embroiled in emotional arguments. There are some old power plants that are only used to provide power during the highest load demand periods. They are old, relatively dirty, and many are located in low- and middle-income disadvantaged communities in New York City so have become the poster child of disproportionate impacts on over-burdened communities. No politically correct organization dares raise any objections to the argument that this is a problem. On the other hand, I not only have subject matter expertise but also have no voice. I have shown that the alleged peaker power plant problems are based on selective choice of metrics, poor understanding of air quality health impacts, and ignorance of air quality trends. In other words they are not as much of a problem as environmental advocates claim.
This is a particular problem for the NYISO. The new resource that must be developed is needed for this particular problem. These are the facilities that Dewey wants to be kept available in New York City until a viable alternative is provided. Someone with a voice is going to have to come out and say that until we have alternatives that will work, have lower risks to the communities where they reside, and are affordable, some peaker power plants may have to remain available. Whether or not they ever point out that the arguments used to vilify the facilities don’t hold water is another matter.
Conclusion
I agree completely with the following. The New York Focus article quotes C. Lindsay Anderson, an energy specialist at Cornell University’s school of engineering, who said it’s hard to avoid such gaps in an energy transition with so many moving parts.
“Everything has to move sort of in sync to make the plan work,” Anderson said. “Taking [peakers] offline is an important signal that we’re making progress. But with many other pieces of the plan having been delayed, it’s not surprising that we may need to delay this a little bit to let the other pieces catch up.”
The necessity to toe the line of political correctness in the Capital District prevented Dewey from explicitly connecting some of the Power Trends takeaways and the Climate Act implementation process. For example, the concern about timing and suggestions that delays are inevitable directly impacts the NYCI emission caps. The caps are based on the arbitrary Climate Act deadlines that were not chosen based on any kind of a feasibility analysis. To my knowledge, NYISO has not been asked to provide their best estimate of the timing of the wind and solar resources necessary to displace the existing resources required to meet the Climate Act mandates. Their resource adequacy modeling and other work is the only credible way to determine if the schedule is reasonable and would likely show the current schedule is not viable. Because GHG emissions are primarily associated with energy use meeting the unrealistic NYCI emission caps means the only compliance strategy is to create an artificial energy shortage.
New York GHG emissions are less than one half of one percent of global emissions and global emissions have been increasing on average by more than one half of one percent per year since 1990. While this may not be a reason to not do something about climate change, it certainly suggests that adjustments to the arbitrary Climate Act schedule are justified. The Power Trends report certainly implies that adjustments to the schedules appear to be necessary.
The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emission reductions to do “something” about climate change. I have been submitting comments as I complete them on the Draft Scoping Plan that outlines strategies for the energy transition. This article describes a comment on the Plan I submitted describing my problem with the assumptions used for retiring renewable energy generating assets.
Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies. I have written extensively on implementation of New York’s response to climate change risk because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that it will adversely affect reliability, impact affordability, risk safety, affect lifestyles, and will have worse impacts on the environment than the purported effects of climate change in New York. New York’s Greenhouse Gas (GHG) emissions are less than one half one percent of global emissions and since 1990 global GHG emissions have increased by more than one half a percent per year. Moreover, the reductions cannot measurably affect global warming when implemented. The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.
Climate Act Background
The Climate Act establishes a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”. They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council. Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies. That material was used to write Draft Scoping Plan that was released for public comment at the end of 2021. The Climate Action Council will revise the Draft Scoping Plan based on comments and other expert input in 2022 with the goal to finalize the Scoping Plan by the end of the year.
Integration Analysis Lifetime Assumptions
I prepared an annotated version of the Draft Scoping Plan description of the “Carbon-Free Electric Supply” in Appendix G Section. This section describes the Integration Analysis projected future electric supply system. More detail is provided in the spreadsheet IA-Tech-Supplement-Annex-1-Input-Assumptions tab named “Retirement” that “contains expected lifetime assumptions by resource category”. The table listing the lifetimes is shown below.
Table Notes:
* Resources with “indefinite” lifetimes are assumed to remain online throughout the study period.
** The license expiration of upstate nuclear units is determined as part of scenario definitions.
***Select units in NYISO zones J and K that are expected to retire as a result of the DEC NOx emissions rule are assumed offline by the start of 2025, based on the 2021 Gold Book.
Units that hit their 60 year lifetime threshold by 2025 but that have not yet announced retirement plans are kept online through model year 2025, due to the time it takes to complete retirement studies.
The 60-year retirement threshold is not enforced in downstate NY until 2035, to ensure local reliability is maintained in the near term. This analysis enforced LCRs in each capacity zone but did not study more detailed local reliability issues.
The reason I prepared a comment is that the lifetime assumptions for hydro, wind, solar, and storage are listed as indefinite. While that may be true for hydro it is an inappropriate assumption for wind, solar and energy storage. As far as I can tell that assumption was used to project future costs.
Other Wind, Solar, and Energy Storage Expected Lifetimes
My comments included the results of a quick literature search for wind, solar, and energy storage technologies expected operating lifetimes.
According to TWI: A good quality, modern wind turbine will generally last for 20 years, although this can be extended to 25 years or longerdepending on environmental factors and the correct maintenance procedures being followed. However, the maintenance costs will increase as the structure ages. The Electricity Markets & Policy group at Berkeley Lab claims: “Our interest was in better understanding how expectations for useful life have changed over time, as the wind industry has matured. We find that most wind project developers, sponsors and long-term owners have increased project-life assumptions, from a typical term of ~20 years in the early 2000s to ~25 years by the mid-2010s and ~30 years more recently. Current assumptions range from 25 to 40 years, with most respondents citing 30 years”. However, there is a difference between design life and actual lifetimes. Energy Follower explains that “There is very little data on modern turbines reaching their life expectancy so it is largely unknown how long they will be operable. Modern wind turbines have over 8,000 parts (broken down into three major components) and blades as long as 262 feet, the same length as the wingspan of an Airbus. With higher efficiency modern turbines due to additional electronic components and a more powerful and massive design, there is a higher chance of something going wrong with more potential points of failure and overall added stress and load on the structure.”
There is less information available for utility-scale photovoltaic systems. The Electricity Markets & Policy group at Berkeley Lab claims: “Solar project developers, sponsors, long-term owners, and consultants have increased project-life assumptions over time, from an average of ~21.5 years in 2007 to ~32.5 years in 2019. Current assumptions range from 25 years to more than 35 years depending on the organization; 17 out of 19 organizations from which data were obtained use 30 years or more.” It is not clear to me why these expectations are so high when it known that photovoltaic cells degrade over time. The National Renewable Energy Lab concluded:
A history of degradation rates using field tests reported in the literature during the last 40 years has been summarized. Nearly 2000 degradation rates, measured on individual modules or entire systems, have been assembled from the literature and show a mean degradation rate of 0·8%/year and a median value of 0·5%/year. The majority, 78% of all data, reported a degradation rate of <1% per year.
There is even less information available for utility-scale energy storage systems. Another National Renewable Energy Lab analysis did an example scenario:
An example scenario was simulated wherein an integrated battery-PV system was controlled in self-consumption mode, attempting to minimize energy exchanged with the grid. For this application, battery lifetimes ranging from 7-10 years may be expected. 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.
I found one other reference that claimed that listed different types of chemical battery lifetimes between 5 and 15 years.
Integration Analysis Implications
I searched the Draft Scoping Plan for the term “retirement” and could not find any documentation for the rationale used to assume that wind, solar, and energy storage have indefinite lifetimes. My comments recommended that the Final Scoping Plan incorporate documentation explain the retirement rationale because as I show below there are implications for the cost projections.
My annotated version of the Draft Scoping Plan section “Carbon-Free Electric Supply” in Appendix G Section I that starts at page 42. The only annotation addition is an extracted copy of the actual data in the figures that list capacity (MW) and generation (GWh) in that section that are based on data in the IA-Tech Supplement Annex 2 Emissions Key Drivers spreadsheet.
The following tables list the capacities for the Integration Analysis fuel mix categories for the Reference Case (Table 1), Scenario 2: Strategic Use of Low-Carbon Fuels (Table 2), Scenario 3: Accelerated Transition Away from Combustion (Table 3), and Scenario 4: Beyond 85% Reduction.
Table 1: Reference Case Summary Fuel Mix Capacity (MW)
The Integration Analysis spreadsheet states that “Resources with ‘indefinite’ lifetimes are assumed to remain online throughout the study period.” I assume that means that the 2020 wind capacity of 1.917 MW in 2020 is not replaced in the total capacity in 2040, 20 years later. Table 5 shows that assumption under-estimates the resource builds in the wind, solar, and energy storage resource categories significantly. If those resource builds are not included then the costs are underestimated too.
Table 5: Additional Capacity Installed for replacement at expected lifetime
Using an indefinite retirement date for these resources underestimates the total builds needed for 2050. For land-based wind between 3,814 MW and 4,600 MW are not included and for offshore wind between 6,200 and 6,600 MW are not included. The amount of solar not included ranges between 22,639 MW and 19,983 MW. Finally, for battery storage between 10,713 MW and 12,207 MW of additional resources will be need to be developed to meet the 2050 projected value.
Another way to look at the exclusion of these resources is that land-based wind development costs could be up to 45% higher than the projections that don’t include reasonable retirement dates because that much more of the resource needs to be developed. Off-shore wind costs could be up to 38% higher, solar costs could be up to 35% higher, and battery storage could be up to 64% higher than projections that exclude reasonable retirement dates.
My comments included questions for the Climate Action Council. Why shouldn’t reasonable retirement dates be included in the Final Scoping Plan. What would the revised costs be if retirements were included? The operational characteristics of battery storage affect expected lifetimes. What did the Integration Analysis assume for thermal management and discharge characteristics? Were those factors included in the estimates of the projected capacity resources?
Conclusion
I prepared this comment because I could not believe that the Integration Analysis authors would apparently ignore all the information that indicates that the lifetimes of wind, solar and battery storage are much less than other generating resources. It appears to me that not including reasonable retirement dates is an egregious attempt to reduce the published costs of wind, solar, and battery storage. The result is that units are assumed to remain online throughout the study period and no costs for replacements between now and 2050 are included. However. that is a poor assumption because it is totally unreasonable to expect that, for example, the existing land-based resources will still be in operation in 2050.
The simplest way to look at the effective result of excluding these resources is that much more of the resource needs to be developed so costs are necessarily higher. For land-based wind development costs could be up to 45% higher than the projections because that much more of the resource needs to be developed. Off-shore wind costs could be up to 38% higher, solar costs could be up to 35% higher, and battery storage could be up to 64% higher than projections that exclude reasonable retirement dates.
New York’s Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050 and has included specific renewable energy deployment targets. On December 17, 2021 the New York State Energy Research and Development Authority (NYSERDA) and New York State Department of Public Service Staff (DPS Staff) released “New York’s 10 GW Distributed Solar Roadmap: Policy Options for Continued Growth in Distributed Solar” that proposes a pathway to achieve a goal of 10 GW of distributed solar deployment by 2030. This post addresses the solar policy options related to agricultural protection and land use in that document and what is actually happening to agricultural land as a result of New York’s poor planning.
I have written extensively on implementation of the Climate Act because I believe the ambitions for a zero-emissions economy outstrip available renewable technology such that it will adversely affect reliability and affordability, risk safety, affect lifestyles, will have worse impacts on the environment than the purported effects of climate change in New York, and cannot measurably affect global warming when implemented. The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.
The current 6 gigawatt (GW) NY-Sun distributed solar program target is nearly achieved, with more than 93 percent of the target either completed or at an advanced stage of development.1 As called upon by New York State Governor Kathy Hochul during Climate Week 2021, the New York State Energy Research and Development Authority (NYSERDA) and New York State Department of Public Service Staff (DPS Staff) have analyzed the current distributed solar market in New York State and found that costs and NYSERDA-provided incentives have declined over time, while a thriving solar market has created approximately 12,000 jobs in New York. Together, these facts demonstrate the success of the NY-Sun program in transforming New York’s distributed solar industry. Additionally, NYSERDA directed further analysis of future revenues, costs, and market support mechanisms needed for distributed solar development beyond the 6 GW target.
Informed by this analysis, NYSERDA and DPS Staff developed this Distributed Solar Roadmap (Roadmap) to propose a pathway to achieve 10 GW of distributed solar deployment by 2030. With the current 6 GW by 2025 goal nearly achieved, the Roadmap explores various options for setting incentive levels to achieve the expanded NY-Sun goal of an incremental 4 GW (Incremental 4 GW Target). These options include various procurement structures, pricing models, and funding mechanisms
The press release bragging about the new framework to achieve at least 10 GW of distributed solar by 2030 included the following statement by Rory M. Christian, CEO of the Department of Public Service:
“I would like to thank Governor Hochul for her ardent support, encouraging the development of and access to solar energy in New York State. The roadmap that has been developed provides New York with the tools it needs to accelerate the transition to a clean-energy economy and meet our critically important climate goals.”
Since the NY-Sun initiative was launched, NYSERDA has worked closely with local governments, agricultural communities, other state agencies, and a wide range of stakeholders to ensure that projects are developed and sited in a manner that fully considers land use and are advanced in close collaboration with local stakeholders and agricultural communities. NYSERDA will extend its ongoing technical assistance for all municipalities in the state to assist localities in aligning solar development with local priorities. In addition, projects sited in New York State Department of Agriculture and Markets’ designated Agricultural Districts must follow Guidelines for Agricultural Mitigation for Solar Energy Projects and will be subject to an additional review process with the NYSDAM, as well as with local agricultural boards. Those projects that exceed 30 acres of impact to prime agricultural soils will be subject to mitigation fees.
Agricultural Protection and Land Use
This section lists the contents of Section III.a.4 Agricultural Protection and Land Use. In my opinion, if the policy is employed as they claim, then it should offer protection to prime farmland and local farming communities from distributed solar project development.
Farmland protection and the maintenance of a vibrant agricultural economy are important State policy goals. New York State recognizes the importance of collaboration between the agriculture and clean energy sectors as a critical part of the State’s overall decarbonization strategy. NYSERDA works in close coordination with the Department of Agriculture and Markets (NYSAGM) and other stakeholders to responsibly support the development of renewable energy projects. In the 2019 NY-Sun Expansion Petition, NYSERDA described the interaction of distributed solar with agriculture in New York:
“The majority of projects in [the Upstate C/I] market sector are expected to be ground-mounted arrays ranging between 5 MW and 7.5 MW in size, which occupy approximately 20 – 25 acres of land, typically on rural properties that are leased or sold to the solar developer by the landowner. Notably, this includes properties that are currently used, or could potentially be used for, agricultural production. While NYSERDA expects that the total agricultural acreage utilized for distributed solar projects will remain modest as compared to total farmland in New York State, through its implementation efforts, NYSERDA will act to ensure that negative impacts to farmland and the State’s agricultural economy are avoided and minimized, and where they are unavoidable, mitigated. NYSERDA, working with partner agencies and stakeholders, has already taken multiple actions along these lines and will pursue additional actions under an expanded NY-Sun program.” (This section is from the NY-Sun Petition, p. 21.)
In the subsequent two years, NYSERDA and NYSAGM have continued to work in partnership to put in place requirements for solar projects to minimize impact to farming and agricultural soils. (These requirements include, inter alia: complying with New York State Agriculture and Markets Law; submitting appropriate notices to NYSAGM and local Agricultural and Farmland Protection boards; executing a copy of the Guidelines for Solar Energy Projects – Construction Mitigation for Agricultural Lands document published by NYSAGM; and making a Mitigation Fund payment or committing to other mitigation measures where impacted agricultural soils exceed 30 acres.) These requirements have already demonstrated their effectiveness: In 2021 to date, all 50 distributed solar projects subject to these requirements, totaling 1,037 acres of affected area, have committed to avoiding and minimizing impacts to prime soils in consideration of the solar layout. For 48 of these projects, all unaffected portions of the farms hosting the solar projects, a total of 3,385 acres, will remain in agricultural production. Many of the farmers hosting projects on a portion of their land report that the steady lease revenue from the solar projects has enabled them to continue farming on most of their property despite challenging agricultural economic pressures.
This Roadmap foresees the existing requirements being extended to distributed solar projects developed through the Incremental 4 GW Target. The State’s Agricultural Technical Working Group (A-TWG), an independent advisory body convened by NYSERDA early in 2021, will continue to serve as the primary forum for stakeholder and interagency collaboration on policies and practices pertaining to distributed solar and agriculture. Guidance provided by the A-TWG and the New York State Farmland Protection Working Group will continue to inform agricultural preservation and mitigation requirements and practices going forward. NYSERDA also continues to provide and expand resources to landowners and local governments through the New York State Solar Guidebook and direct technical assistance.
Utility-Scale Solar Reality
Assuming that these numbers are correct, then I applaud the efforts of NYSERDA and NYSAGM. There is a major problem however. The majority of these distributed solar projects are “expected to be ground-mounted arrays ranging between 5 MW and 7.5 MW in size, which occupy approximately 20 – 25 acres of land”. The reality is that a large fraction of the projected solar generation capacity will be utility-scale solar facilities that are much larger and have bigger impacts than the developers admit.
That are both being developed by NextEra Energy Resources. According to NextEra, Trelina will have 80 MW of solar capacity located on 418 acres within a 1,067-acre project area. Garnet is a 200-megawatt solar project with 20 megawatts of energy storage with a project area of 2,288 acres and facility area (area within in project fence line) of 1,054 acres. Both projects have Article Ten applications and Michael Saviola, an Associate Environmental Analyst with the New York State Department of Agriculture & Markets (“Department”) submitted testimony describing the nature and extent of potential impacts of the projects on agricultural land.
Saviola’s prepared testimony responded to the question whether the projects had been “sited to avoid and/or minimize impacts to land uses within the Study Area and Project Area to the maximum extent practicable”. For Trelina his testimony noted that “the Department finds the Applications proposed siting is not consistent with the Department’s siting policy because it will occur on more that 10% of active farmland classified as Prime Farmland”. It goes on to explain that “the Department estimates that greater than 68% of the of the limits of disturbance includes the conversion of farmland classified as Prime Farmland Soil”. While the application claims that solar panels will cover 325 acres, the testimony shows that “areas located outside of fenced areas will likely become fallow or orphaned as a result of screening requirements and setbacks” and this “will eliminate crop production on much more than 325 acres of agriculture lands for a minimum of 30 years -worth of crop yields from some of the most productive farmland soils in the State”. The application claims that there will be temporary impact to agricultural land and farming, but the testimony argues that “a 30-year loss of the production of crops, livestock and livestock products constitutes a permanent conversion to a nonagricultural use.” Finally, even though a decommissioning plan has been prepared, the testimony states: “there is virtually no reasonable assurance that the project will be decommissioned and that the full resumption back to agricultural use will be reestablished.”
Saviola’s testimony for Garnet was very similar. The conclusion is the same: “the Department finds the Applications proposed siting is not consistent with the Department’s siting policy”. In this instance almost 30% of the project will be on active farmland classified as Prime Farmland. His testimony explains that “the Application update states that the project will occupy nearly 1,000 acres of land to generate up to 200 MW of electricity, however, areas located outside of fenced areas will likely become fallow or orphaned as a result of screening requirements and setbacks”. Nearly three times as much land will lose crop production on “agricultural lands for a minimum of 30 years-worth of crop yields from some of the most productive farmland soils in the State”. The same points about temporary claimed impacts and decommissioning assurances were made. His testimony concludes: “It is the Department’s opinion that the facility will result in or contribute to a significant and adverse disproportionate agricultural impact upon the local farming community. They have not avoided, offset or minimized agricultural impacts to the maximum extent practicable using verifiable measures”.
Despite the recommendations of the Department, on November 30, 2021 the New York State Board on Electric Generation Siting and the Environment granted approval to Trelina Solar Energy Center to build and operate the 80-megawatt solar farm. According to a state press release, the Siting Board’s decision “follows a detailed review and robust public participation process to ensure that the solar farm meets or exceeds all siting requirements”. Clearly, the fact that the Department of Agriculture and Markets finding that the project was not consistent with their siting policy belies that claim.
The Garnet Energy Center Article Ten public comment period is open until May 1, 2022. While Saviola’s testimony is similar for both cases it is not identical. The Department requested information from NextEra and documented the responses. In general, NextEra’s response to questions simply repeated statements in the already submitted materials. The testimony notes that in response to a question about agricultural co-utilization: “The Applicant indicates that they have not considered incorporating agricultural co-utilization as part of the Project. They indicate that there is not sufficient space for co-utilization.” Saviola goes on to say he does not agree with this response: “There is ample space inside the fence for agricultural activities such as sheep grazing, apiary incorporation and pollinator species, and small-scale grass hay production, nor have they demonstrated any reduced impacts to agriculture from the increased density of the panels. The Applicant should work with hosting farmers to explore dual-use, or agrivotalic projects.”
NY-Sun Disconnect from Reality
As quoted earlier the State’s press release about the release of the framework was all praise. It claimed that NYSERDA has worked closely with local governments, agricultural communities, other state agencies, and a wide range of stakeholders to ensure that projects are developed and sited in a manner that fully considers land use and are advanced in close collaboration with local stakeholders and agricultural communities. In the future, they state that “projects sited in New York State Department of Agriculture and Markets’ designated Agricultural Districts must follow Guidelines for Agricultural Mitigation for Solar Energy Projects and will be subject to an additional review process with the NYSDAM, as well as with local agricultural boards.” The problem is that those initiatives only address distributed-solar projects.
Table 1 lists projected future New York State solar generating capacity for the Reference Case, Scenario 1 that represents recommendations by the Advisory Panels and Scenarios 2-4 that represent Integration Analysis mitigation scenarios. The mitigation scenarios were constructed so that the Climate Act targets could be achieved. Unfortunately, the Draft Scoping Plan does not document how much of the solar capacity is expected to come from distributed solar projects and how much from utility-scale projects. Assuming half is utility-scale solar that means we can expect 32.3 GW of industrial solar installations in Scenario 2. Two utility-scale projects are discussed in this article and they have average 5.26 MW per acre of fenced area covered with panels. Using that estimate, Scenario 2 utility-scale solar project solar panels will cover 170,000 acres or 266 square miles in 2050. The Department testimony explains that considering only the fenced area impacts underestimates the amount of land that actually be lost to most agricultural uses. The reality is that the impacts for utility-scale solar project will dwarf the land taken up by distributed solar projects (much of which is sited on buildings) in NY-Sun and there are no equivalent farmland protections for massive utility-scale projects under development.
I submitted comments on March 17 to the Garnet Energy Center Article Ten application docket contending that the project should follow responsible solar siting guidelines. In my post describing the comment submittal I argued that responsible siting guidelines based on the American Farmland Trust report, the state’s policies for distributed solar described above in the 10GW Solar Roadmap and the New York State Energy Research & Development Authority’s Agricultural Technical Working Group analyses will likely eventually be used to form the basis of a state-wide policy for utility-scale solar development. Without those policies in place, it is inappropriate to allow projects like the Garnet project to proceed. Obviously, the fact that the Department of Ag & Markets testified that “the facility will result in or contribute to a significant and adverse disproportionate agricultural impact upon the local farming community” demonstrates that the project is inconsistent with the NY-Sun’s commitment to responsible solar development.
Given the magnitude of the potential impacts to prime farmland I also submitted a comment to the Climate Action Council recommending that they impose a moratorium on the development of utility-scale solar projects until permitting requirements have been established for responsible solar siting and protection of prime farmlands. I said that even though the Department of Agriculture and Markets has policies on solar energy projects, the Article Ten Trelina Solar Project was approved despite the fact that it did not adhere to that policy. I argued that, at a minimum, all utility-scale projects should adhere to those policies. A moratorium would not only protect communities and farmland but it would also help meet Climate Act goals. Using the Draft Scoping Plan solar projections and land use estimates for solar projects in the Article Ten queue in 2020 suggest that the smallest Scoping Plan scenario solar equipment area covered will be 266 square miles. Moreover, there are Climate Act considerations. The law has a “net-zero” target by 2050 that requires 15% sequestration. One of the strategies to meet that target is soil carbon management. Taking productive farmland out of production hinders that goal.
Conclusion
New York’s 10 GW Distributed Solar Roadmap: Policy Options for Continued Growth in Distributed Solar document outlines a policy approach for responsible distributed solar siting. I have no argument with their approach or their results. However, there is a major problem. The majority of these distributed solar projects are “expected to be ground-mounted arrays ranging between 5 MW and 7.5 MW in size, which occupy approximately 20 – 25 acres of land”. There are no similar guidelines in place for the larger utility-scale projects. Even though the Draft Scoping Plan does not specify how much projected solar generation capacity will be distributed as opposed to utility-scale, it is clear that massive amounts of land will be required for utility-scale development.
In December 2021 the State announced that NY-Sun projects are developed and sited in a manner that fully considers land use and are advanced in close collaboration with local stakeholders and agricultural communities. However, in the same month the Trelina Solar Project was approved despite the fact that the Department of Ag & Markets testified that “the proposed siting is not consistent with the Department’s siting policy because it will occur on more that 10% of active farmland classified as Prime Farmland”. There are numerous initiatives underway to ensure that the solar developments necessary to meet the Climate Act goals are sited in a responsible fashion. However, projects that inconsistent with those guidelines are being developed and will remove “agricultural lands for a minimum of 30 years-worth of crop yields from some of the most productive farmland soils in the State”. It is time for a moratorium on these developments until that guidance is in place.
My primary concern with this project is how it relates to the Climate Leadership and Community Protection Act. In particular, I believe that the massive resouces that have to be devoted to diffuse and intermittent renewable energy development will have worse impacts on the environment than the purported effects of climate change in New York. 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.
Trelina Energy Center
There is another utility-scale solar project being developed near the Garnet project. Late last year the New York State Board on Electric Generation Siting and the Environment (Siting Board) granted approval to build and operate the Trelina Solar Project, an 80 megawatt (MW) solar farm in the Town of Waterloo, Seneca County that is being developed by NextEra Energy Resources, the same company that is developing the Garnet Energy Center. I published an article about the approval process and noted that despite the fact that the New York Department of Agriculture and Markets (Ag & Markets) testimony clearly demonstrated that the project did not meet the Department’s siting policies the project was approved.
As part of the regulatory analysis of the project Michael Saviola, an Associate Environmental Analyst with Ag & Markets submitted prepared testimony on the Trelina Solar Project application. His testimony made a compelling case against the project. In response to the question “What Department policies are subject to the proceeding”, he responded (Line 20, page 6):
As previously mentioned, The Department discourages the conversion of farmland to a non-agricultural use. However, to support the New York State’s CLCPA initiatives, the Department has developed a siting policy supportive of solar development efforts on agricultural lands if (his emphasis added) the proposed projects are properly sited on lands other than the State’s most productive farmland. The Department’s goal is for projects to limit the conversion of agricultural areas within the Project Areas, to no more than 10% of soils classified by the Department’s NYS Agricultural Land Classification mineral soil groups 1-4, generally Prime Farmland soils, which represent the State’s most productive farmland. Soils classified with the soil groups 5-10 are identified as having soil limitations. The only responsible position the Department can take to stay true to the 7 AML Article 25-AA §300 and to support the NYS CLCPA renewable energy initiative is to ensure the preservation of agricultural areas involving soils classified as soil groups 1-9 for the production for food and fiber, as well as not object to proposed development on lesser productive soils, i.e. agriculture lands comprised on classified mineral soil groups 5-10.
The overall Project Area is 1,067 acres and “only approximately 44.4 percent will be used for Project Components within a fenced area of approximately 418 acres to generate 79.5 to 80 MW of renewable energy”. Note, however, that the testimony notes that “The Department’s goal is for projects to limit the conversion of agricultural areas within the Project Areas, to no more than 10% of soils classified by the Department’s NYS Agricultural Land Classification mineral soil groups 1-4, generally Prime Farmland soils, which represent the State’s most productive farmland.” The testimony also notes that “The Department estimates that greater than 68% of the of the limits of disturbance includes the conversion of farmland classified as Prime Farmland Soil”.
The application argues that the project only disturbs 4.9% of all the prime farmland in the Town of Waterloo and presumably would argue that means they meet the intent of the Department policy. The problem with that is there is no master plan for development and no assurances that other more responsibly sited facilities could not be constructed in the Town of Waterloo that would raise the town total over the 10% goal of the Department. The Ag and Markets testimony also argues against the claims that only 10.05 acres will be permanently disturbed. The testimony explains that 474.1 acres will be permanently disturbed because “as long as NYS incentives for the development of renewable energy exists, the complete decommissioning of solar electric energy generation, and full resumption to agricultural use is not likely to occur”.
I concluded that the press release describing the Siting Board’s decision statement that the process “follows a detailed review and robust public participation process to ensure that the solar farm meets or exceeds all siting requirements” is demonstrably false.
Ag & Market Solar Energy Project Policies
On March 10, 2022 Michael Saviola submitted prepared testimony on the Garnet Energy Center application. As before his responsibility was “to determine if the Project as proposed follows the Department’s Guidelines for Agricultural Mitigation for Solar Energy Projects.” This section provides some background on Ag & Market/Department policies. He notes that the Department of Ag and Markets does not have an opinion on the need for utility-scale solar generation but (Page 6, line 3):
The Department discourages the conversion of farmland to a non-agricultural use. This effort is in accordance with Section 4 of Article 14 of the 2018 New York State Constitution, which provides for the conservation of agricultural lands, as well as NYS Agriculture and Markets Law (AML), Article 25-AA, §300, which more specifically states:
“It is, therefore, the declared policy of the state to conserve, protect and encourage the development and improvement of its agricultural land for production of food and other agricultural products. It is also the declared policy of the state to conserve and protect agricultural lands as valued natural and ecological resources which provide needed open spaces for clean air sheds, as well as for aesthetic purposes.”.
After acknowledging that the Department is aware of the Climate Act and supports the general initiative, the testimony goes on to state that these projects are permanent installations (Page 6, line 20):
The Department will continue to discourage the conversion of agriculture land to a non-agricultural use. Prior to large-scale solar development, the Department has not been associated with PSL 22 Article 10 cases that constitute large, long-term conversion of agricultural lands to non-agricultural uses. Commercial wind generating facilities generally allow for farming activity to continue once the project is in-service. In comparison, the solar industry arguably eliminates the ability to perform normal viable agricultural operations within, and potentially immediately surrounding the facility. This constitutes a long-term conversion to a non-agricultural use. Due to increasing NYS energy goals encouraging renewable energy development, we see no reason facilities will not be upgraded and re-leased to maintain the growing or static renewable energy demand, in this case, 35 years from energization. The Department further asserts that as long as NYS incentives for the development of renewable energy exists, the complete decommissioning of solar electric energy generation, and full resumption to agricultural use is not likely to occur.
In response to the question “What Department policies are subject to the proceeding”, he responded (Line 17, page 7):
As previously mentioned, The Department discourages the conversion of farmland to a non-agricultural use. However, to support the New York State’s CLCPA initiatives, the Department has developed a siting policy supportive of solar development efforts on agricultural lands if (his emphasis added) the proposed projects are properly sited on lands other than the State’s most productive farmland. The Department’s goal is for projects to limit the conversion of agricultural areas within the Project Areas, to no more than 10% of soils classified by the Department’s NYS Agricultural Land Classification mineral soil groups 1-4, generally Prime Farmland soils, which represent the State’s most productive farmland. Soils classified with the soil groups 5-10 are identified as having soil limitations. The only responsible position the Department can take to stay true to the 7 AML Article 25-AA §300 and to support the NYS CLCPA renewable energy initiative is to ensure the preservation of agricultural areas involving soils classified as soil groups 1-9 for the production for food and fiber, as well as not object to proposed development on lesser productive soils, i.e. agriculture lands comprised on classified mineral soil groups 5-10. Additionally, the Department requires the Applicant to follow Department Guidelines for constructing solar facilities in agricultural lands. Draft Certificate Condition 47 and 95 identifies the Applicant’s agreement to comply with Department’s Guidelines entitled Solar Energy Projects – Construction Mitigation for Agricultural Lands (Revision 10/18/2019), specifying construction mitigation techniques intended to protect and restore agricultural soil resources. Furthermore, the Applicant has agreed to consult with the Department for any potential deviation from the Guidelines to develop applicable construction and restoration alternatives.
In response to the question: What are the primary agricultural impacts associated with the construction of a commercial solar energy generation facility on agricultural lands the testimony states: (Line 16, page 8)
The construction of a commercial solar energy generation facility within agricultural land constitutes a long-term impact and permanent conversion of farmland to an industrial (non-agricultural) use. The development of solar arrays and ancillary facilities (including panels, panel racking, transformer/inverter equipment pads, access roads, security fencing, substations, energy storage options, operation and maintenance facilities, planted visual screening areas, etc.) makes it infeasible to continue farming on viable agricultural land within the Project area. Furthermore, the location of project-related infrastructure- panel spacing and alignment in agricultural fields create obstacles that the farm operator will have to avoid during numerous types of agricultural equipment operations; including, but not limited to, cultivation, seeding, nutrient recycling, weed management, harvest, etc. The difficultly created by the obstacles forces the farm operator to abandon use of the field.
Impacts to agricultural lands remaining outside of the security fencing also has a high likelihood to become abandoned and/or orphaned. More specifically, these generally narrow areas outside the fenced facility are created by development limitations (municipal setbacks, buffers, etc.) and limit the conduct of mechanized farming. The scenarios cited above create narrow strips of land that although may be available to some agricultural producers are unattractive for most commercial farm operators, as they are inefficient to harvest crops due to the limitations of acreage and maneuverability for modern mechanized farming equipment. These “indirect” impacts often result in the loss of additional farmland which, in turn, result in a decrease in mechanized farming efficiency leading to a reduction in the production of crops, livestock and livestock products necessary for food production and security.
On page 10 line 8, the testimony asks the question How does the siting of commercial solar project-related infrastructure impact agricultural operations?
There are several potential impacts. Farms demand a certain acreage to meet their business, long-term staffing, and environmental objectives and to remain viable. If leased land is abruptly lost to another use, such as a solar installation, the farm will grow and market less produce, grains, forages, and livestock products; may have to downsize and lay-off employees; and could be challenged to have adequate acreage for proper manure nutrient recycling. Such changes may force the farm to close. As in other sectors, farmers seek improvements to management and efficiency to remain competitive and viable. Larger, more efficient tillage, planting, crop management, and harvesting equipment is one example of how farmers have adapted to remain viable and more productive. Often, this equipment can include two pieces of harvesting or tillage equipment pulled by a single tractor. As the size of the farming equipment has increased over the years, the turning radius for the equipment has also increased. The location of access roads and other project-related infrastructure in an agricultural field creates an obstacle which the farm operator has to avoid during field planting and harvesting operations. Placement of project-related infrastructure in agricultural fields can result in a loss of productive acreage as well as a decrease in field operation efficiency or viability with the larger planting and harvesting equipment because of the increased turning radii required. Depending on the location of project-related infrastructure, primarily solar arrays and access roads, the loss of acreage available to farming, and the loss of farming efficiency or farm viability can be significant and, in some cases, devastating to farms and for food production.
Garnet Energy Center
The Garnet Energy Center is a proposed 200-megawatt solar project with 20 megawatts of energy storage located in the town of Conquest in Cayuga County, N.Y. NextEra Energy Resources is also developing this project. According to the July 2021 Proposed Array Layout the project area is 2,288 acres and the facility area (area within in project fence line) is 1,054 acres. The fenced area encloses the solar arrays, inverters, energy storage modules and the project substation.
On Page 12, line 18 of Saviola’s testimony he addresses the question “Does the facility layout follow the Department’s Solar Guidelines and does it align with the Department’s siting policy?”
In general, access roads should follow field edges and the solar arrays should not be sited in a manner in which agricultural areas become orphaned as described in my testimony above. Additionally, the Department finds the Applications proposed siting is not consistent with the Department’s siting policy because it will occur on almost 30% of active farmland classified as Prime Farmland (Generally, Mineral Soil Groups 1-4) within the proposed project. The Application update states that the project will occupy nearly 1,000 acres of land to generate up to 200 MW of electricity, however, areas located outside of fenced areas will likely become fallow or orphaned as a result of screening requirements and setbacks. This will eliminate crop production on nearly 1,000 acres of agricultural lands for a minimum of 30 years-worth of crop yields from some of the most productive farmland soils in the State. While the Applicant describes the impact to agricultural land and farming, in general, as temporary, a 30-year loss of the production of crops, livestock and livestock products constitutes a long-term conversion to a nonagricultural use and a long-term loss of food production. Although a decommissioning plan has been prepared, there is virtually no reasonable assurance that the project will be decommissioned and that the full resumption back to agricultural use will be reestablished.
As if this is not enough the testimony goes on to respond negatively to NextEra’s response to questions. For example, “True long-term impacts include the approximate 30 plus year loss in the production of crops, livestock and livestock products as a result of project-related components being constructed inside the fence. Nearly 1,000 acres of farmland will be taken out of production.” (Page 14 line 5). On Page 15, line 18 agricultural co-utilization is discussed: “The Applicant indicates that they have not considered incorporating agricultural co-utilization as part of the Project. They indicate that there is not sufficient space for co-utilization.” And goes on to say he does not agree with this response: “There is ample space inside the fence for agricultural activities such as sheep grazing, apiary incorporation and pollinator species, and small-scale grass hay production, nor have they demonstrated any reduced impacts to agriculture from the increased density of the panels. The Applicant should work with hosting farmers to explore dual-use, or agrivotalic projects. Similarly, the response to questions about subsurface drainage systems was eviscerated.
On page 19, line 18 comes this: “It is the Department’s opinion that the facility will result in or contribute to a significant and adverse disproportionate agricultural impact upon the local farming community. They have not avoided, offset or minimized agricultural impacts to the maximum extent practicable using verifiable measures”.
Responsible Solar Energy Siting
There are other efforts that define what is needed to site utility-scale solar projects to minimize impacts. In December 2021 New Yorkers for Clean Power (NYCP) and Alliance for Clean Energy NY (ACENY) co-hosted a workshop “What’s the Deal with Renewable Energy & Agriculture?” that discussed the compatibility of renewable energy and agriculture in New York State and all the speakers advocated responsible solar development that minimizes the loss of prime farmland. Three other examples follow.
The Saviola testimony describes a document on responsible siting of utility-scale solar development:
The American Farmland Trust published a study in February 2022 on smart solar siting on farmland in New York State. This study was completed with input from, and collaboration with, advisory members from government and non-governmental organizations, solar industry advocates, not-for profit land trusts, solar developers, and academia. The study was conducted to develop smart solar strategies to meet climate goals while supporting its agricultural economy and future food security. The report reveals trends that show that good quality farmland has been a first-choice site for solar development. As in with this proceeding here. The lowest hanging fruit. The study strongly recommends against siting solar infrastructure on prime farmland or farmlands comprised of Mineral Soil Groups 1-4 and to site infrastructure on marginal lands. The Study also indicates that farmers are interested in agrivotalics. The Study concludes by stating that the choices we make today about where and how solar projects, particularly large-scale facilities, are sited on active farmland will make a difference to rural economies and influence our ability to farm and grow food in New York to feed ourselves and reap environmental benefits now and into the future.
Farmland protection and the maintenance of a vibrant agricultural economy are important State policy goals. New York State recognizes the importance of collaboration between the agriculture and clean energy sectors as a critical part of the State’s overall decarbonization strategy. NYSERDA works in close coordination with the Department of Agriculture and Markets (NYSAGM) and other stakeholders to responsibly support the development of renewable energy projects. In the 2019 NY-Sun Expansion Petition, NYSERDA described the interaction of distributed solar with agriculture in New York:
“The majority of projects in [the Upstate C/I] market sector are expected to be ground-mounted arrays ranging between 5 MW and 7.5 MW in size, which occupy approximately 20 – 25 acres of land, typically on rural properties that are leased or sold to the solar developer by the landowner. Notably, this includes properties that are currently used, or could potentially be used for, agricultural production. While NYSERDA expects that the total agricultural acreage utilized for distributed solar projects will remain modest as compared to total farmland in New York State, through its implementation efforts, NYSERDA will act to ensure that negative impacts to farmland and the State’s agricultural economy are avoided and minimized, and where they are unavoidable, mitigated. NYSERDA, working with partner agencies and stakeholders, has already taken multiple actions along these lines and will pursue additional actions under an expanded NY-Sun program.” (This section is from the NY-Sun Petition, p. 21.)”
In the subsequent two years, NYSERDA and NYSAGM have continued to work in partnership to put in place requirements for solar projects to minimize impact to farming and agricultural soils. (These requirements include, inter alia: complying with New York State Agriculture and Markets Law; submitting appropriate notices to NYSAGM and local Agricultural and Farmland Protection boards; executing a copy of the Guidelines for Solar Energy Projects – Construction Mitigation for Agricultural Lands document published by NYSAGM; and making a Mitigation Fund payment or committing to other mitigation measures where impacted agricultural soils exceed 30 acres.) These requirements have already demonstrated their effectiveness: In 2021 to date, all 50 distributed solar projects subject to these requirements, totaling 1,037 acres of affected area, have committed to avoiding and minimizing impacts to prime soils in consideration of the solar layout. For 48 of these projects, all unaffected portions of the farms hosting the solar projects, a total of 3,385 acres, will remain in agricultural production. Many of the farmers hosting projects on a portion of their land report that the steady lease revenue from the solar projects has enabled them to continue farming on most of their property despite challenging agricultural economic pressures.
Finally, the New York State Energy Research & Development Authority Agricultural Technical Working Group is working on a “Smart Solar Siting“ scorecard to encourage responsible siting of renewables on agricultural land. The scorecard lists five area to avoid:
Avoid prime agricultural soils
Farmland in active cultivation
Forested land
Wetlands
Grass lands
Conclusion
In my opinion, the American Farmland Trust report, the state’s policies for distributed solar and the Agricultural Technical Working Group analyses will eventually be used to form the basis of a state-wide policy for responsible siting of utility-scale solar development. In the meantime, it is inappropriate to allow projects like the Garnet project to proceed.
The Garnet Energy Center permit decision will be a litmus test to see if the State is going to protect farming communities. I believe that the testimony clearly demonstrates that the proposed project is inappropriate because “the facility will result in or contribute to a significant and adverse disproportionate agricultural impact upon the local farming community”. Ag and Markets testimony for the Trelina project was similarly negative but that got approved. At a minimum the project approval should be delayed until guidelines for responsible utility-scale solar development are available and I submitted comments to the docket to that effect. If the Siting Board ignores the Ag and Markets testimony and the clear need to wait for guidelines, then it will be clear that the State is not going to protect farming communities.
In early September 2021 I wrote an article, “Reliability Challenges in Meeting New York’s Climate Act Requirements”, that described a presentation made by the New York State Reliability Council (NYSRC) to the New York Climate Action Council. In this post I describe a recent paper that analyzes synoptic-scale extreme reductions in wind and solar power energy resources that I think raises an important reliability question: when New York relies on fragile intermittent wind and solar energy resources is the current New York reliability goal to prevent a loss of load event due to resource adequacy of no more than once per ten years still appropriate.
I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented. The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.
Background
In my reliability challenge article, I explained that there is consensus that the future worst-case situation in New York will be a multi-day winter time wind lull when both wind and solar availabilities are low. Coupled with increased electricity load in order to reduce emissions from transportation and heating, any analysis of future renewable energy resources that adequately addresses the worst-case renewable energy resource availability shows the required amounts of wind, solar and energy storage will have to be enormous. Importantly, the NYSRC analysis indicates that in order to ensure reliability the installed reserve margin will have to be increase substantially above current levels to satisfy anticipated load and the intermittent nature of wind and solar resources. The NYSRC presentation concludes that the state of New York appears to be headed down a transition path which will require reliance on technologies that do not currently exist in less than ten years.
Wind and Solar Droughts
Dr. Patrick Brown’s blog post describes his recent paper co-authored with David J. Farnham and Ken Caldeira entitled “Meteorology and climatology of historical weekly wind and solar power resource droughts over western North America in ERA5” (Brown et al., 2021). His post explains that as wind and solar become more indispensable for providing electricity it is important that we understand the intensity, frequency, and duration of droughts of their availability. In Brown et al., 2021 they use a meteorological database that covers 71 years from 1950 to 2020. They compared estimated weekly solar and wind availability against cooling and heating degree days as a proxy for electrical load over that entire period.
The following plot of the weekly values is of special interest. The plot explanation states:
All weekly values from 1950 to 2020 (average over the western North America domain, Fig. 1) for power supplied by wind and solar resources (x and y axes respectively) and a proxy for power demanded via cooling degree days (color of dots). The mean seasonal cycle in wind and solar power is shown by the black loop (52 black dots for each week of the year). Drought weeks are indicated with black edge colors with wind droughts represented as circles, solar droughts represented as squares and compound wind and solar droughts represented as diamonds.
Of particular concern is the lower left quadrant which represents weeks where both wind and solar resources are lower than the annual mean of long-term availability. Note that this quadrant is “mostly astronomical autumn. The mean wind & solar power given a wind + solar drought label shows that during a drought you can only expect around 40% of the solar resource and 65% of the wind resource.
There is an animation showing the degree to which there is persistence in time. In the video each week is sequentially plotted since 1979 over a plot of the seasonal cycle. As you watch the video keep in mind that you are watching the seasonal progression of plots. While the majority of weeks with both wind and solar droughts are in autumn there are periods at the start of each year that appear to me to be among the most intense. That is consistent with New York analyses that define the ultimate problem
that must be resolved to ensure reliability: firm capacity is needed to meet a multi-day period of low solar and wind resource availability during the winter.
In their presentation to the Power Generation Advisory Panel on September 16, 2020 E3 included a slide titled Electricity Supply – Firm Capacity that states: “The need for dispatchable resources is most pronounced during winter periods of high demand for electrified heating and transportation and lower wind and solar output”. The slide goes on to say: “As the share of intermittent resources like wind and solar grows substantially, some studies suggest that complementing with firm, zero emission resources, such as bioenergy, synthesized fuels such as hydrogen, hydropower, carbon capture and sequestration, and nuclear generation could provide a number of benefits. Of particular interest is the graph of electric load and renewable generation because it shows that this problem may extend over multiple days.
Because wind and solar are naturally intermittent the amount of energy storage needed to balance output must be determined. The Brown et al., 2021 technique can also be used to identify periods that should be evaluated in more detail to determine the intensity of the droughts so that energy storage requirements can be determined. This is important not only for grid planning but also for distributed energy resources (DER). In theory DER can “generate smaller amounts of clean electricity closer to end-users, to increase energy efficiency, reduce carbon pollution, improve grid resiliency, and potentially curtail the need for costly transmission investments”. However, unless they incorporate sufficient energy storage these resources won’t work when the system is stressed the most, so they may not be the panacea that advocates claim.
To this point, reliability planning has been primarily focused on an electric system powered by conventional dispatchable generating resources. In that context resource obtainability is not particularly concerned with long-term availability of the resource because the resources are not intermittent. That changes when the system becomes dependent upon wind and solar because there are short-term and long-term availability concerns. It is in this context that the results from Brown et al., 2021 climatology becomes important and raises the question whether planning based on a ten-year metric is still appropriate in the future. Using this approach, we can determine the frequency and duration of the expected worst case over ten years consistent with current IRM planning. However, because we can consider a longer period, we can also consider the frequency and duration of droughts over the whole 70 years and get expected worst cases over other time periods. If there is a marked difference over say the 30-year time period, it may be appropriate to expand the IRM planning period in order to prevent the probability of shedding load due to more severe drought.
Black Swan Events
To this point in this article, I have only addressed normal weather variability effects. During the preparation of this post, I came to believe that there is another reliability concern related to renewable resource adequacy that has to be addressed. What happens to the electric system when unprecedented extreme weather cripples the relatively fragile renewable generating and transmission system? These statistical outliers are described as a “black swan event”.
A Black Swan event is an event in human history that was unprecedented and unexpected at the point in time it occurred. However, after evaluating the surrounding context, domain experts (and in some cases even laymen) can usually conclude: “it was bound to happen”. Even though some parameters may differ (such as the event’s time, location, or specific type), it is likely that similar incidences have had similar effects in the past.
In this context the conclusion that “it was bound to happen” has to be discussed. At an Our Energy Policy (OEP) panel discussion on New York State’s emerging offshore wind market, someone asked an off-shore wind industry expert whether wind turbines in New York would be able to withstand aCategory 5 storm. Clint Plummer the head of market strategies and new projects for Ørsted, the world’s largest owner, developer, and operator of offshore wind responded: “wind turbines are designed to withstand a Category 3 hurricane, and they have built into their permit applications an insurance fund that can pay for repairs in cases of catastrophic loss from a storm more severe”. He said “a Category 5 hurricane has a return period in excess of 100 years, while the design life of a wind farm is 30-35 years, so wind turbines are not designed to withstand a Category 5 storm because they are not expected to experience one”. “Anything less than that up to a certain speed is just a really good day for producing a lot of wind power,” he said.
In the October 1, 2021 Climate Action Council meeting presentation Carl Mas described the initial results of the integration analysis that will be used to develop the plan to implement changes to New York’s energy system to meet the CLCPA targets. Four scenarios have been developed with different renewable resource, load reduction and sequestration strategies. The new findings indicate that 20 GW of offshore wind resources will be necessary. Assuming that New York builds the latest generation offshore wind turbine, e.g. the GE Haliade-X 12 MW turbine, that equates to over 1,600 turbines with 220 m or 722 foot rotors.
However, hurricanes likely exceeding the threshold described by Ørsted expert Plummer have occurred in the area New York plans to build its offshore wind facilities. In 1635 the “Great Colonial” Hurricane hit New York and New England and the “Great Storm of 1693” devastated Long Island. There were other hurricanes that made landfall in the Tri-State area – 1788 (left the Battery in ruins), 1821, 1893 (the second hurricane that year, different from the one that hit Halifax, Nova Scotia), 1944 (“Great Atlantic” hurricane), 1954 (Carol), and 1991 (Bob). The 1938 “Long Island Express” made landfall in Long Island as a Category 3 hurricane with sustained winds of 125 mph and wind gusts up to 150 mph bringing waves surging to 35 feet. Given that part of the rationale for the CLCPA is that extreme weather events such as hurricanes are becoming more frequent and severe there should be no question that a contingency plan is necessary for the time that a hurricane inevitably affects, if not destroys, the New York offshore wind resource. Moreover, should that not be a part of the reliability planning process?
Unfortunately, that is not the only extreme weather event that can have extreme consequences on a more fragile wind and solar electricity network. I am particularly worried about ice storms. On a local level it is not clear how the public will be able to survive a multi-day power outage caused by an ice storm when the CLCPA mandates electric heat and electric vehicles but the bigger reliability concern is that fact that ice storms can take out transmission lines. For example, consider, the January 1998 North American ice storm:
The North American Ice Storm of 1998 (also known as Great Ice Storm of 1998) was a massive combination of five smaller successive ice storms in January 1998 that struck a relatively narrow swath of land from eastern Ontario to southern Quebec, New Brunswick and Nova Scotia in Canada, and bordering areas from northern New York to central Maine in the United States. It caused massive damage to trees and electrical infrastructure all over the area, leading to widespread long-term power outages. Millions were left in the dark for periods varying from days to several weeks, and in some instances, months. It led to 34 fatalities, a shutdown of activities in large cities like Montreal and Ottawa, and an unprecedented effort in reconstruction of the power grid. The ice storm led to the largest deployment of Canadian military personnel since the Korean War, with over 16,000 Canadian Forces personnel deployed, 12,000 in Quebec and 4,000 in Ontario at the height of the crisis.
New York Governor Kathy Hochul recently announced “two major green energy infrastructure projects to power New York City with wind, solar and hydropower projects from upstate New York and Canada”. The press release claims that the combined project will deliver 18 million megawatt-hours of upstate and Canadian renewable energy per year. Clean Power New York plans on over 20 wind and solar generation projects – all located in New York State – and a new 174-mile, underground transmission line. Champlain Hudson Power Express is a 338-mile underground power line from Quebec hydroelectric facilities to New York City. The problem is that not all the associated infrastructure in these projects is underground and immune from ice storms.
The requirements for New York reliability planning will have to change for a future grid that relies on intermittent and diffuse wind and solar. Current planning for the electric system is based on decades-long experience with a system powered primarily by sources that are dispatchable and includes sources that have on-site storage. The potential for lack of source availability over days, weeks, and even months is not a serious concern today because the New York system has been diverse, redundant, and resilient to the vagaries of weather.
The CLCPA requirement for a zero-emissions electric system that relies on wind and solar energy resources changes the reliability planning requirements. Previous analysis has highlighted the need to address multi-day wind lulls in the winter as a particular problem. Brown et al., 2021 have developed a technique that can be used to determine the climatological frequency and duration of those periods of low wind and solar resource availability that clearly should be included in New York reliability planning. Their analysis technique can also be used to identify the worst-case periods of wind and solar droughts so that more detailed resource availability analyses can estimate how much energy storage is needed not only for the electric grid but also the distributed energy resources proposed for the CLCPA. This analysis is needed to prevent the kind of Texas February 2021 disaster from happening in New York.
The existing New York system has evolved over years of trial-and-error experience to the point where it is relatively resilient to extreme weather events. While there have been exceptions, the possibility of widespread, weeks-long outages is extremely low. However, because wind and solar resources are more fragile to wind and ice crippling damage than existing generating sources, the likelihood of the conditions that cause that level of damage should be determined. Brown et al., 2021 can determine the occurrence of events over a 71-year period. If, for example, their analysis suggests that the return period of a crippling event is one in thirty years, then should New York reliability planning incorporate a longer time horizon for its planning?
At this time, the off-shore wind strategy calls for 20 GW of development. The ramifications of a Category 4 or greater hurricane destroying or significantly damaging those facilities should be at least be considered. Repairing them will take months if not years and the ramifications if insufficient resources are available are immense. If nothing else the statements claiming that the future wind and solar dependent electric system will be more resilient should be toned down.
On July 18, 2019 New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act (CLCPA), which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency. The Ney York Independent System Operator (NYISO) is the “organization responsible for managing New York’s electric grid and its competitive wholesale electric marketplace”. This post addresses the relationship between the CLCPA and NYISO.
The NYISO Frequently Asked Questions webpage explains how the organization originated. After the Northeast Blackout of 1965, New York’s seven investor-owned utility companies established the New York Power Pool (NYPP) to address the reliability problems exposed by the blackout. The NYPP “balanced electricity supply and demand, maintained transmission voltage, monitored system contingencies, managed operating reserves, and dispatched generation”. In the 1990s New York’s electric system was de-regulated and the Federal Energy Regulatory Commission (FERC) recommended the formation of independent entities to manage energy transmission. “At the same time, the New York State Public Service Commission (PSC) established retail electric competition to allow customers to choose their electric supplier. The PSC supported the formation of competitive wholesale markets as the basis of retail choice, and approved restructuring plans by which utilities divested most of their power plants to competitive generation companies.” In 1999, the NYISO was established to replace the NYPP.
The NYISO manages the electric system. They have to balance the instantaneous supply of electricity between the generators and customers across the state. In the de-regulated market electricity is supplied by multiple types of agreements between the suppliers and the NYISO. Some of the power is contracted by purchase power agreement contracts, some by day-ahead auctions, and the rest by real-time auctions that cover any additional power needed. They manage the supply of power and maintain the frequency across the state and with their connections to other operating systems. In addition, the NYISO has to plan for future changes to the system. At this time the biggest factor for change is the CLCPA.
There are a few other relevant aspects in the NYISO description:
The NYISO is a not-for-profit, independent company unaffiliated with any state or federal agency or energy company. The NYISO is led by an independent Board of Directors. The NYISO’s federally-approved tariffs contain strict requirements for our Board of Directors and all employees to have no financial relationship with any of the companies that participate in our wholesale energy markets. The NYISO is dedicated to transparency in how we operate, the information we provide, and our role as an impartial system operator, planner, and broker of New York’s wholesale electricity markets.
The NYISO is accountable to both federal and state regulatory bodies and maintains compliance with nearly 1,000 reliability requirements. The NYISO’s independent Board of Directors collaborates with our stakeholders via a robust shared-governance process that facilitates input from interested stakeholders. The establishment of the NYISO created a system of shared governance that provides all market participants — from utility companies to electric generators — a voice in the operation and evolution of the marketplace.
Under the NYISO’s transparent, inclusive process, representatives from market participants have voting power to exercise responsibilities such as preparing the NYISO’s annual budget, reviewing and recommending candidates for Board vacancies, developing and adopting technical guidelines for operation of the bulk power system, and market design and system planning. NYISO stakeholders share responsibility with the NYISO Board to approve proposed changes to the NYISO’s governing documents, including its federally approved tariffs.
The NYISO’s description of their process and the very name suggest that they are independent of New York politics but that is not the case with the current administration. In the following I will explain why I think that the NYISO is pulling its punches vis-à-vis the feasibility of the CLCPA.
NYISO and the Cuomo Administration
I am not an admirer of Governor Cuomo because my impression is that his administration has always been about his best interests. Whenever any organization has disagreed with Cuomo’s energy agenda the response has been bluster and threats. For example, when National Grid’s plan for natural gas supply in New York City contradicted Cuomo’s agenda, he threatened to revoke the operating license for National Grid if they did not comply with his plans. Another example, is NRG Energy’s Dunkirk power plant which was deemed uneconomic and scheduled for closure. For some political reason, Cuomo announced an agreement to repower the plant with natural gas. In a de-regulated market making a grant to one facility to continue operations is sure to upset competitors and a lawsuit was filed. In addition, certain rules have to be followed that include fee requirements and NRG decided to not pursue re-powering. Cuomo’s response was to seek a PSC probe of the business decision.
This overt insistence on toeing the administration’s political agenda extends to all the agencies under his thumb. The Department of Public Service (DPS) and Public Service Commission are supposed to be independent however this is not the case. In the summer of 2019 a group of retired Department of Public Service employees submitted a letter that stated “Until the current administration, Governors have generally respected the plain language of the Public Service Law (PSL), which … safeguards the mission of the DPS to serve not political interests but the public interest.” The letter signed by fifteen retired department workers states: “Governor Andrew Cuomo, however, has not done so.”
Unfortunately, the NYISO is not immune to the Governor’s tactics. In a filing to the Public Service Commission, the NYISO noted that in order to meet Cuomo’s Clean Energy Standard, a predecessor regulation to the CLCPA, New York would have to install over 1,000 new miles of bulk transmission lines at great cost and effort which exposed one of the short-comings of the Governor’s clean energy agenda. In response, Cuomo’s energy czar, Richard Kauffman, accused NYISO Director Brad Jones and his NYISO report as “misleading, incomplete, and grossly inaccurate…revealing an alarming lack of developed analysis into the imperative to address climate change…” Kauffman’s letter accused Jones of protecting fossil fuel generators and said that he was “dismayed by [Jones’] public comments.
In this political climate it is not surprising that rather than standing up to the bully, the “independent” NYISO caved, Jones left, and was replaced by Rich Dewey. Now the NYISO reports carefully word every document so as to not invoke the wrath of Cuomo’s bullies.
NYISO Raison D’être
There is another aspect of the NYISO’s operations that colors their responses. It is not surprising that the NYISO completely endorses the idea that wholesale electricity markets have the ability to solve any problems because that is the reason for their existence. Unfortunately, I think some of their faith in market mechanisms is unwarranted.
I am not an expert on market design but I fear we are heading towards an energy crisis. In a regulated market the Public Service Commission (PSC) tells the vertically integrated electric utilities to meet a specific mandate, the utilities develop a response, the PSC oversees their responses relative to reliability and affordability, and the necessary infrastructure gets built. In New York’s de-regulated market, planners at the NYISO and various state agencies do the planning and then the NYISO and PSC develop “innovative market rules necessary to meet the objectives of the CLCPA” that they hope will engender market participants to build the necessary infrastructure.
In addition, the problem may occur because the NYISO identifies a problem that the politicians who are running New York energy policy decide to ignore. Of course, when it occurs the blame will be place on the NYISO. In this regard Donn Dears book “The Looming Energy Crisis” provides a detailed description of potential problems that are a challenge to overcome and might require imposition of politically unpopular policies. In the current political environment these issues are more likely than not.
Finally, I want to give an example where the market did not produce the obvious environmental solution. New York State energy and environmental policy is more about optics than facts. Nowhere is this more apparent than the recent spate of opinion pieces, reports, and even policy proposals related to peaking power plants. In brief there are old simple cycle turbines in New York City that were built to provide reliable power during peak load periods. However, there are old, inefficient and much dirtier than today’s technology. In my opinion the continued operation of the old simple cycle turbines in New York City is the result of New York’s de-regulated market place. I am absolutely sure that in a regulated environment the responsible utility would have made a case to the Department of Public Service that replacement with cleaner, more efficient generation was needed, the Department would have agreed, and, after it was approved, the utility would have been guaranteed a reasonable return on their investment so the turbines would have been replaced. However, in the de-regulated market there wasn’t a strong enough financial incentive to replace the old units. Before I retired in 2010, I worked on two separate permit applications for new, efficient, and cleaner replacement power for one set of the old combustion turbines. In both instances the permits were approved but the replacements were never built, apparently because the company decided that the business case was not strong enough to warrant the investment. The fact is that sometimes the market signals are too weak to provide the desired result.
Conclusion
The point of this post is to document the importance of the NYISO but to also point out that their policies and recommendations are necessarily colored by their belief that markets are a viable solution to the challenges of the CLCPA energy transition and by the political climate of New York. The NYISO has done a good job analyzing the challenges of the energy transition. Unfortunately, many members of the CLCPA advisory panels and the Climate Action Council don’t understand, don’t want to understand, or choose to ignore the warnings in those analyses. In my opinion, there are enough technical challenges in the transition that maintaining reliability will be a problem but the added challenge of designing some market mechanism to get the market to provide the resources necessary all but assures that reliability will become an issue.
Finally, I sympathize with the NYISO position. All their work not only has to fully explain the problems they identify but the wording has to pass a political optics text. This means that all their reports have to toe the existential threat of climate change narrative without any suggestion that the potential risks to reliability, affordability, and environmental impacts of the proposed solutions far out-weigh the alleged impacts of climate change. It is similar to the symbiotic relationship between the Egyptian plover and crocodile. NYISO is performing a service to the state but you never know if the Cuomo crocodile is going to snap.
Truthout is a nonprofit news organization dedicated to providing independent reporting and commentary on a diverse range of social justice issues. According to the about description “Truthout works to spark action by revealing systemic injustice and providing a platform for progressive and transformative ideas, through in-depth investigative reporting and critical analysis. With a powerful, independent voice, we will spur transformations in consciousness and inspire both policy change and direct action.” If the article Fossil Fuel Phase Out Must Begin Where the Industry Has Hurt People the Most is any indicator, however, their platform is based on emotion and not facts. The alleged problems with peaking power plants and neighborhood power plant impacts on local health are exaggerated and nearly fact free. The proposed solution is untested and likely to make the lives that they want to improve worse.
I am a retired air pollution meteorologist with over 40 years-experience analyzing the effects of meteorology on electric operations. While doing consulting work for the Environmental Protection Agency I evaluated air quality model performance and later worked at a utility company where I was responsible for ambient monitoring networks in the vicinity of power plants and evaluating their air quality impacts. I have been involved with peaking power plants in particular for over 20 years both from a compliance reporting standpoint and also evaluation of impacts and options for those sources. This background served me well preparing this post. The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.
Background
The article is prefaced with a note that “this story is part of Covering Climate Now, a global journalism collaboration strengthening coverage of the climate story”. The author is Leanna First-Arai. “a freelance journalist who covers environmental and climate (in)justice. Her work has appeared in Undark, Sierra Magazine, Yes! Magazine, Outside Magazine, on New England Public Radio and elsewhere”.
The Fossil Fuel Phase Out Must Begin Where the Industry Has Hurt People the Most article describes the claims made in the recently released Fossil Fuel End Game report that I described here. The basic premise is that New York City peaking power plants only operate a limited days per year, they are usually old and dirty plants located in disadvantaged communities, and they received around $5 billion to keep running in the last decade. Therefore, they should be the first fossil plants to be replaced by clean energy.
I have been following this peaking power plant initiative for about a year and summarized my work here. This article is the latest iteration of advocacy releases based on the Physicians, Scientists, and Engineers (PSE) for Healthy Energy report Opportunities for Replacing Peaker Plants with Energy Storage in New York State. I discussed the PSE report last year and the PEAK Coalition report entitled: “Dirty Energy, Big Money” in two detailed technical posts. The first post provided information on the primary air quality problem associated with these facilities, the organizations behind the report, the State’s response to date, the underlying issue of environmental justice and addressed the motivation for the analysis. The second post addressed the rationale and feasibility of the proposed plan relative to environmental effects, affordability, and reliability.
Oswego Harbor Power Plant
In order to show that this article is based on emotion and not facts consider the description and allegation related to the Oswego Harbor Power Plant. In this section I have annotated (indented and italicized) my comments after each sentence from the relevant paragraph in the article.
Residents living within a one-mile radius of the Oswego Harbor Power Plant, one of only a handful of such plants left in Upstate New York, are ranked in the 99th percentile for incidence of heart attacks, based on an analysis of New York State Health Department data by the nonprofit research institute Physicians, Scientists and Engineers for Healthy Energy (PSE).
The insinuation here is that the residents within one-mile of the power plant have a high rate of heart attacks because of the power plant.
The 73-year-old plant only went online six times in 2018 (the most recent year for which data are available).
There is a description of the plant in a US Army Corps of Engineers harbor infrastructure report that explains that there are two 850 MW units in operation and in service since 1975 – 46 years not 73. The older units have been retired since before the turn of the century. The units burn residual oil that is stored on-site. At the time of their construction residual oil was cheaper than coal and for many years residual oil was cheaper than natural gas so the units ran a lot in the late 1980’s. The fuel price differential no longer supports the use of residual oil. However, in times of great need the facility can generate 1,700 MW of dispatchable power without regard to weather-caused outages.
The EPA Clean Air Markets Program Database provides data for the most recent quarter within 45 days so more recent data are available than claimed. Table 1 lists annual data through 2020. The important point in the context of this discussion is that emissions from the plant are minimal which is not surprising because of the short operating times.
Table 1: Oswego Harbor Power Annual Emissions and Operations Data
Unit ID
Year
Operating Time
Gross Load
SO2
NOx
CO2
(Hours)
(MW-h)
(tons)
(tons)
(tons)
5
2016
92
18,071
44
24
17,309
6
2016
146
23,212
63
24
23,659
5
2017
92
19,132
45
25
17,426
6
2017
141
22,678
56
23
20,811
5
2018
186
26,025
68
32
25,075
6
2018
165
26,600
65
24
23,976
5
2019
95
15,394
37
19
14,225
6
2019
240
23,600
58
25
22,407
5
2020
249
26,736
69
34
26,760
6
2020
125
23,906
62
25
21,024
But if residents suspect hazier-than-usual skies, no federal air quality data exists to help make sense of the short-lived plume of pollution, as the closest Environmental Protection Agency monitors are 40 and 70 miles away, respectively, in Syracuse and Rochester.
The insinuation that the DEC, EPA and owner of the plant know nothing about the plume of pollution is completely baseless. The author clearly knows nothing about air quality regulations, air quality meteorology, or the Oswego Harbor plant. The New York Department of Environmental Conservation (DEC) is responsible for maintaining air quality that meets the National Ambient Air Quality Standard limits under the guidance of EPA. They do that by monitoring near emission sources and modeling facility emissions to estimate air quality impacts.
At this time there are no DEC air monitoring stations closer than Rochester and Syracuse. EPA does not monitor air quality in New York. However, that does not mean that there never was any air quality monitoring closer to the plant. I know because I as responsible for submitting the data from the network around the Oswego plant. After several years of not measuring any exceedances from the power plant DEC and EPA agreed that it was no longer necessary to run the monitoring network and it was retired by 1990. At one time most, if not all power plants, had monitoring networks but one of two things happened. If, like at Oswego, no measurements indicating problems were found then the networks were retired. If problems were found then the emission limits were changed for the facility until the monitoring found that there were no problems. Also note that these data were used to verify that the air quality models used to predict ambient levels near the plants were correct. Under contract to EPA, I did that verification work using those data sets and later also compared the Oswego Harbor plant modeled impacts to observations. That work proved that the models correctly characterize nearby air quality.
It is not surprising that the modeling never showed anything approaching an exceedance of the National Ambient Air Quality Standards or that the highest observed monitored concentrations were accompanied with the smell of chocolate from the Nestles plant that was located in the opposite direction. The stacks at Oswego are 700’ high and the plume rise from the hot gases pushes the plume higher. As a result, the pollution plume is nowhere near the ground within a mile of the plant.
The insinuated claim that the Oswego Harbor Power Plant is somehow associated with local high incidents of heart attacks is unsubstantiated. The article states that the plant only ran six times in 2018 and the data show it only ran 352 hours so it was online for less than three days at a time. Present operations are about 1% of the operating times and rates as in 1988 when the monitoring network that showed the plant did not adversely affect air quality. If I had to guess why there is a high rate of heart attacks my money would be on the fact that Oswego is in the lake-effect snow belt and when it snows, it snows a lot. Snow removal is a notorious cause of heart attacks.
Peaking Power Plant Replacements
The author and the advocates quoted in the article are unaware of the fundamental problem with the PSE report Opportunities for Replacing Peaker Plants with Energy Storage in New York State. PSE defined peaking power plants by their current time of operation not by their design capabilities. The Oswego Harbor Power Plant is the best example of this problem. The plant was designed to provide base load power when it was thought that residual oil would continue to be a cost-effective fuel. The two 850 MW units operated well when that was true but with today’s fuel costs it only offers support to system as backup capacity. There are three nuclear plants within ten miles of the facility and if there is a problem with those units then the power plant can step in to replace their output. For example, in the 2004 blackout Nuclear Regulatory Commission operating rules required the nuclear units to go offline and the Oswego Harbor Power Plant was called on to support the system until the nuclear units were allowed to go back online. The units also come online when loads are very high and all power generation is needed. There are other power plants in New York that operate much less than they were designed to operate that fulfill similar reliability needs.
The PSE report claims that all of the plants that they claim are peakers can be replaced by renewable energy and storage. The problem with that is that their definition is based solely on operating times and does not consider the capabilities of the peaking units. The New York electric system has more stringent rules than Texas. In the wake of the blackouts last February, Texas is wrestling with how to prevent similar problems in the future by asking should power generators be required to guarantee that they can provide a certain amount of electricity? New York’s response to this issue includes capacity payments to Oswego Harbor Power for 1700 MW of power six times a year. This resource is dedicated to that need and can provide that capability because the capital investments necessary have already been paid, even though the fuel is relatively expensive it provides concentrated energy capable of 1700 MW, and the costs to maintain that much power capability are relatively low.
The first problem with the PSE report claims that the steam turbine units like Oswego that provide peak capacity support can be replaced by renewable energy and storage is that the capital cost to develop enough energy storage to replace all those units has to be paid for a rarely used resource. A major reason that New York’s capacity payments are as low as they are is because the resources needed to meet New York’s requirements has paid off those costs. Replacing those facilities with anything will be much more expensive. The second problem is that the renewable and energy storage approach proposed has never been implemented at the scale needed for New York’s electric resource requirements. Replacing a system that has worked for decades with unproven technology could very well lead to reliability issues as the system is de-bugged.
Conclusion
All these analyses vilify peaking power plants oblivious to their value to the grid. The PSE study estimated that they received around $5 billion in the last decade but only ran less than 5% of the time. The New York electrical system pays for these units to provide capacity and ancillary services so that the electric system can reliably provide power when it is needed most. The Texas energy system does not have a similar policy in place. While Texas average prices are lower than New York prices their system is vulnerable to blackouts when peaking power is unavailable. Simply put, New York peaking power plants are an insurance policy to prevent Texas-style blackouts. The February 2021 Texas blackouts caused dozens of deaths and tens of billions of dollars in damages. The New York peaking power plant insurance policy looks like a good deal to me.
Another big driver in the vilification of peaking power plants is the claim that they adversely affect air quality in neighboring disadvantaged communities. However, I don’t think that the PSE approach made a convincing case that the peaking power plants are a primary driver of environmental burdens on neighboring communities. My primary objection to this claim is that the health effects attributed to peaking power plants are based on air quality impacts from ozone and particulate matter. However, ozone is a secondary air pollutant and the vast majority of ambient PM2.5 from power plants is also a secondary pollutant. As a result, there is enough of a lag between the time emissions are released and creation of either ozone or PM2.5, that the impact is away from the adjoining neighborhoods. That means that the accused peaking power plants do not create the air quality impact problems alleged to occur to the environmental justice communities located near the plants. In fact, because NOx scavenges ozone the peaker plants reduce local ozone if they have any effect at all.
The claims that peaking power plants are dangers to neighboring environmental justice communities are based on emotion. The existing simple cycle peaking turbines in New York City are old, inefficient and much dirtier than a new facility and clearly should be replaced. However, they reliably produce affordable power when needed most. Importantly regulations are now in place that ensure that they are retired or that their pollution control equipment is upgraded on a schedule that guarantees in-kind replacement of capacity and ancillary services. In order to maintain existing levels of affordability and reliability I think it is best to rely on a proven solution using fossil fuels. The solar plus energy storage approach advocated by PSE and the PEAK Coalition will likely increase costs significantly if it works. I cannot over-emphasize the fact that it may not work because wind, solar, and energy storage is not a proven technology on the scale necessary to provide New York City’s peaking power requirements. Sadly, in the rush to prove politically correct credentials this unproven technology may be chosen despite the risks to power reliability. It is the height of hubris that the New York legislature has pending bills to over-ride the reliability planning process and existing environmental regulations without including a feasibility study to define the wind, solar and energy storage resources needed, the technological readiness of those resources at the scale needed and the costs of that approach.
Finally, I do not disagree with the premise that disproportionate environmental risks to disadvantaged communities need to be addressed. However, that goal has limits. First, and foremost, it simply is not good policy to expect the removal of all environmental impacts. For example, a replacement state-of-the-art natural gas fired combustion turbine that reduces existing impacts substantially should be an acceptable choice because it provides a proven affordable solution and reduces well-known impacts. The proposed alternative of renewable energy and energy storage is unproven technology at the scale needed, is costly when the cost to provide uninterruptable power is considered, and could very well lead to worse overall environmental impacts especially when the effects of the rare earth metals needed for those resources is included. The result is there is a high likelihood of problems with affordability, reliability, and environmental impacts due to the implementation of the proposed solution. If those problems occur then the disadvantaged communities that these advocates want to protect will be disproportionately impacted. I don’t think that the advocates understand that those impacts could be worse than the problems that they want addressed.
