New York State Environmental Policy – Pragmatic Environmentalist of New York

Draft Scoping Plan Electric Generating Retirement Assumptions

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 longer depending 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)

Table 2: Scenario 2 Summary Fuel Mix Capacity (MW)

Table 3: Scenario 3 Summary Fuel Mix Capacity (MW)

Table 4: Scenario 4: 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.

Re-building Interstate I-81 in Syracuse, NY

The US edition of the Guardian has picked up on the issue of the re-building of Interstate 81 through the city of Syracuse in an article entitled The NY Highway That Racism Built. According to the article it was built through a historically black neighborhood because of racism. I only want to post this article because the reality is that the location of the highway was dictated by geography.

Background

Briefly, New York State wants to replace the highway through Syracuse because it is needs to be replaced. According to the Department of Transportation website:

Interstate 81 (I-81) is important to the Syracuse area. The highway serves as a major commuter route, providing access to jobs, businesses and services in downtown Syracuse and the hospitals and institutions on University Hill. It also serves as a national and international north-south trade route from Tennessee to the Canadian border. This connectivity is essential and influences the livability, economic vitality, and sustainability of the Syracuse metropolitan region.
Portions of I-81, which was built in the 1950s and 1960s, are deteriorating and nearing the end of their useful life. Also, sections of I-81 do not meet current standards and are experiencing high accident rates. This is especially true of the 1.4-mile elevated section, or “viaduct,” near downtown Syracuse. Now is the time to address I-81’s safety concerns and the structural integrity of the viaduct. In order to do this, the New York State Department of Transportation (NYSDOT) and the Federal Highway Administration (FHWA) are following an environmental review process. The purpose of the I-81Viaduct Project is to address the structural deficiencies and non-standard highway features in the I-81 corridor while creating an improved corridor through the City of Syracuse that meets transportation needs and provides the transportation infrastructure to support long-range planning efforts (such as SMTC LRTP, Syracuse Comprehensive Plan, and others).

Discussion

According to the article:

In the 1960s, I-81 plowed through a historically Black neighborhood in Syracuse, displacing hundreds. Organizers’ dream of seeing it torn down may get new life under Biden.
Just south of downtown Syracuse in upstate New York, a stretch of highway has long divided surrounding neighborhoods.
On the east side are large buildings where university students live, well-maintained green spaces, and a wall that blocks the highway from view. On the west side is a predominantly low-income and disinvested Black neighborhood where the pollution from the highway exacerbates many residents’ existing health conditions

I believe that once the decision was made to bring the highway through the city that the location was destined to go through the neighborhood in question simply because of geographical constraints. There is an overview map of the Syracuse region in the introduction to the draft environmental impact statement. Not shown on the map are railroads that parallel most of the route of the interstate through Syracuse.

The Central Study Area map from the draft environmental impact statement shows the north-south route of I-81 through the city. The viaduct that is the cause of so much concern runs between Downtown and Near Eastside south of I-690 which runs east to west. Note that further south the viaduct separates Southside and University Hill.

There is a picture in the article credited to the Onondaga Historical Society that shows the highway being constructed that shows the hills to the south of the city that are a major reason for the location of the highway.

This picture provides the rationale for my argument that the location of the highway was due to geography. The picture looks south with University Hill, the location of Syracuse University, to the east and downtown Syracuse on the valley floor to the west. Check the overview map and you can see that to the north there is a lake that precludes building the highway to the west of downtown Syracuse. The most direct transportation corridor from the north into the downtown originally followed a canal which was followed by a railroad. The highway route replaced them both. Not shown in the picture is a railroad that cuts under the interstate at the end of the viaduct headed south along the hill on the left. The most direct route to the city from the south followed this transportation corridor into the city. In order to connect the two transportation corridors, the most direct route was through the predominately black neighborhood.

Conclusion

I don’t believe that the argument that the highway location was chosen specifically to target a black neighborhood stands up to the geography rationale. This does not detract in any way the very real environmental and health impacts of the residents near the highway. I have not doubt that in today’s political climate that the viaduct through this section of the city will be torn down and replaced by a community grid. The arguments for and against replacement of the viaduct versus the politically correct community grid option boil down to value judgements.

Ultimately the only thing I am sure that will not happen is that the community grid will ignite a renaissance of the city’s fortunes and revitalization of all the neighborhoods near the highway. There are too many other factors at play to believe that the simply changing the highway will solve the problems that advocates for the community grid option claim are due to the highway.

Environmental Justice Risks from Hyper-Local Monitoring are Exaggerated

Note: This post was also published at Watts Up With That

According to Bloomberg Law, Biden’s Hefty Clean Air To-Do List Follows Early Big Promises means that air quality standards have to be revised and must incorporate social justice and climate concerns. Based on what I have seen this push will rely less on science and more on emotion.

The Bloomberg article states:

“Revising clean air rules is a cornerstone of climate and justice policies, two areas that the Biden administration has set as priorities. Clean air experts in areas that carry a disproportionate burden of dirty air say that runaway air pollution remains a chronic problem, reflecting neglect of low-income neighborhoods and communities of color, exacerbated by air monitor disparities.”

“Portable air quality monitors used in the South Bronx and Brooklyn caught particulate matter quantities 20 times higher in some areas than levels reported by state-run monitors, according to new data from a neighborhood-level air monitoring study by the New York City Environmental Justice Alliance, or NYC-EJA. The findings highlight insufficient air monitoring for targeted environmental justice communities, and show why one generalized air policy may not be enough to mitigate pollution for hard-hit areas, said Jalisa Gilmore, research analyst for NYC-EJA. “That’s why we have a little bit more emphasis on hyper local monitoring, and making sure that we actually get the interventions that are most appropriate for the community,” she said.”

The New York City hyper local monitoring program is described in the Community Air Mapping Project for Environmental Justice (CAMP-EJ) findings and recommendations report. In brief:

“Because New York City has only 13 high-performance ambient air monitoring sites, air pollution exposures are poorly characterized at the neighborhood level. To address this data gap, CAMP-EJ utilized dozens of low-cost, portable air quality monitors to measure hyperlocal air quality and characterize air pollution exposures at more refined spatial and temporal scales than is possible using existing City and State data. The results of our air monitoring campaign shed light on the disproportionate public health burdens imposed on environmental justice communities from industrial pollution, trucking, and transportation infrastructure.”

The analysis found that local facilities and expressways are big polluters, traffic congestion fouls the air twice every day, and that hyperlocal measurements show inhalable particulate matter are twenty times higher than state-run monitors. I was not surprised by the first two findings but the claim that hyperlocal measurements were much higher than state-run monitors surprised me.

I have experience running air quality monitoring networks with particulate matter monitors. I found that measuring particulates was always difficult to do correctly and more so with smaller aerodynamic particles like the inhalable or 2.5 micron particles. In the project, “CAMP-EJ participants used the AirBeam2, a low-cost, palm-sized air quality instrument that measures PM2.5, and AirCasting, an open-source environmental data visualization platform that consists of an Android app and online mapping System”.

The going price for an AirBeam 2 is around $250 and the state-run monitors systems use instruments that go for $25,000. The state-run system has a detailed quality assurance plan and includes quality control tests which I doubt were included in the community monitoring program so my first thought is just how accurate are these personal monitors? According to the report: “The AirBeam2’s PM2.5 measurements are “quite accurate” according to a performance evaluation conducted by South Coast Air Quality Management District, which compared the performance of the AirBeam2 to reference monitors.”

However, the South Coast Air Quality Management District evaluation report I found told a different story. Three sensors were tested against a reference FEM FRIMM PM 2.5 monitoring instrument similar to the one used in the New York State network. According to the concluding discussion:

“Accuracy: Overall, the three AirBeam sensors showed very low accuracy compared to FEM GRIMM at 20 °C and 40% RH, when varying PM2.5 mass concentration from 10 to 50 μg/m3. The AirBeam sensors significantly overestimated the FEM GRIMM readings. According to the method of calculating accuracy, the % accuracy for the sensors were all negative. When PM2.5mass conc. was over 50 μg/m3, Airbeam sensors reached plateau of 315 μg/m3.”

Don’t get me wrong, I have no doubt that the CAMP-EJ main conclusions, local facilities and expressways are big polluters and traffic congestion fouls the air twice every day, are correct. However, the monitors used over-estimated inhalable particulate concentrations considerably, particularly at the higher rates they claimed are hurting local communities. As a result, the numbers that they claim prove the need to act are incorrect.

Climate Leadership and Community Protection Act Cumulative Environmental Impacts

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. It was described as the most ambitious and comprehensive climate and clean energy legislation in the country when Cuomo signed the legislation. However, it is not clear that the cumulative environmental impacts of all the resources needed to meet the 2050 net-zero goal will be less than the purported environmental impacts of the climate change effects of New York emissions in part because the State has not evaluated the impacts of all the resources needed for those goals.

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

Background

I have been doing environmental assessments for over 40 years and really worry about the environmental impacts of the CLCPA because there is no commitment to evaluate the cumulative impacts. The problem is that while an individual industrial wind facility or solar facility may not have a notable environmental impact the cumulative impact of all the facilities necessary to provide enough power to meet the reliability needs of the state could have significant environmental impacts. Because the State has established this goal it should be responsible for this analysis and not the applicants for individual facilities.

On June 24, 2020, DPS announced that they would be accepting comments on the Draft Supplemental Generic Environmental Impact Statement on the proposed Climate Leadership and Community Protection Act. On September 30, 2020 DPS announced that they had accepted the Final Supplemental Generic Environmental Impact Statement on the proposed Climate Leadership and Community Protection Act (“CLCPA SGEIS”). The Executive Summary explains that this is the fifth environmental impact analysis for various iterations of New York’s clean energy programs. The statement explains that the action is “a continuation of previous initiatives analyzed in the Prior SEQRA Analyses, in addition to the increase in resources needed for implementation of the following CLCPA requirements:

- - 70% of electricity from renewable energy by 2030
  - 9,000 MW of offshore wind electricity by 2035
  - 6,000 MW of distributed photovoltaic solar generation by 2025.”

There are two problems however. There are significant differences between 70% of electricity from renewable energy by 2030 and 100% by 2040. The other problem is that their projections for the generation necessary for 2030 are outdated with more recent estimates coming in higher. This post compares the resources modeled in this impact statement and the latest projections.

Comments

I have made the comment that a comprehensive cumulative environmental impact statement is needed for New York’s clean energy programs in a couple of venues including the Resource Adequacy proceeding and Accelerated Renewable Energy Growth and Community Benefit Act proposed regulation. I prepared comments on the Draft Supplemental Generic Environmental Impact Statement for this CLCPA impact statement but ended up not submitting them. This post updates those unsubmitted comments.

In this post I consider the avian impact of the Bluestone Wind Project in Broome County New York to show impacts for a single facility. It will have up to 33 turbines and have a capability of up to 124 MW covering 5,652 acres. The “Cumulative Impacts Assessment” Appendix UU, which is document #752 on the NYSDPS-DMM-Matter Master website case #16-F-0559 in the Article 10 application for the facility. Over the 30-year expected lifetime of the facility the analysis estimates that 85 Bald Eagles and 21 federally protected Eastern Golden Eagles will be killed. The analysis assumes that impacts to bat species at the Facility would be similar to the average bat impacts reported at other wind energy projects in New York (average rate of 6.05 bats/MW/year) so approximately 868 bat deaths per year could be expected at the Facility. However, the facility has committed to a mitigation curtailment that will stop operations during light wind speeds from July 1 to September 30 which they claim will reduce impacts 60% down to 347 bat deaths per year.

The cumulative impact analysis in this report references a Department of Energy site Projected growth of the Wind Industry. They project that from 2020 to 2050, the projected 30-year life of the Facility, on-shore wind development in New York is estimated to increase from 1.75 gigawatts (GW) to 5.61 GW. The next step is to see how that projection for on-shore wind development squares with more recent, NY climate policy specific projections for on-shore wind and the CLCPA SGEIS.

The Estimates of Land-Based Wind Resources table has 16 estimates of on-shore wind resources. In 2019 there were 1,985 MW of installed wind capacity. According to Exhibit 1-2, Summary of Environmental Resource Areas Analyzed in the Prior SEQRA Analyses, onshore wind impacts were last considered in the 2016 SEIS and in the CLCPA SGEIS were “not analyzed further”. As a result, the 2016 impact statement estimates of the land-based wind capacity , 4,000 MW in the base case and 5,905 MW in the high load case, represent the latest CLCPA EIS estimate. In 2020 the New York Independent System Operator (NYISO) estimated land-based wind resources needed to meet the Climate Act 70×30 goal as part of its Congestion Assessment and Resource Integration Studies (CARIS) planning process. They project that 6,476 MW will be needed, 571 MW more than the latest CLCPA EIS estimate, in 2030. Importantly, in order to meet all the electrification needs of the Climate Act in 2050, much more land-based wind will be needed after 2030. On June 24, 2020 Energy plus Environmental Economics (E3) presented results of their emissions reductions pathway analyses to the New York Climate Action Council that included projections of land-based wind in 2030, 4,700 MW, which is less than the latest CLCPA EIS estimate high load case, but in 2050 they projected 9,000 MW in 2050, which is 3,095 MW more than the latest CLCPA EIS estimate high load case.

On June 15, 2020 the Brattle Group presented results from their report New York’s Evolution to a Zero Emission Power System that included five projections of land-based wind. In their base case they project 9,700 MW in 2030 and 23,300 MW in 2040, 3,795 MW and 17,395 MW more than the latest CLCPA EIS estimate high load case respectively. They also included two scenarios with different estimates of feasibility. They noted that the DPS maximum feasible on-shore wind builds were 10,000 MW (4,095 MW greater than the latest CLCPA EIS estimate) and the NYSERDA maximum feasible on-shore wind builds were 8,000 MW (2,095 MW greater than the latest CLCPA EIS estimate). The final scenario claimed used a National Renewable Energy Lab (NREL) technical potential on-shore wind capacity of 26,000 MW which is 20,095 MW greater than the latest CLCPA EIS estimate. The Analysis Group Climate Change Impact Phase II Final Report for NYISO had another estimate for the NREL total technical potential of 35,200 MW which is 29,295 MW greater than the latest CLCPA EIS estimate. That analysis incorporates all the load increases necessary to electrify other sectors to meet the CLCPA goals so I believe that this is the best estimate of the final resource requirement. Because that capacity estimate is so much larger than the latest CLCPA EIS estimate I can only conclude that another environmental impact analysis is needed when the Climate Action Council finalizes its Scoping Plan.

It is concerning to me that an analysis done for NYSERDA on wind power and biodiversity by the New York Natural Heritage Program (NYNHP) and Nature Conservancy found that: “5,430 square kilometers (1.3 million acres) of land in New York that are both suitable for wind power development and avoid areas that are likely to have high biodiversity value. Using an estimate of 3.0 MW/square kilometers, this translates to a megawatt capacity estimate of 16,300 MW (± 9,000 MW) for New York’s terrestrial landscape.” The Analysis Group projection of 35,200 MW exceeds this range and that suggests that wind turbines will have to be sited within areas of high biodiversity value. It is absolutely necessary that there is a commitment to do a cumulative environmental impact statement evaluating the on-shore wind resources needed to meet the CLCPA goals.

Finally, I made estimated some New York Cumulative On-Shore Wind Impacts. I calculated the land needed for development and compared that to agricultural land and high biodiversity land. According to the latest CLCPA EIS, assuming a conservative range of land use requirements from NREL’s 2009 study of 30 to 141 acres per MW, total land use requirements for 4,000 MW of land-based wind under the base case PPA scenario (the latest CLCPA EIS estimate scenario which projects the lowest amount of land-based wind development) may require between 120,000 and 564,000 acres of land. I calculated the totals for all the scenarios included in the previous table. Based on a recent estimate of 8.79 million acres of agricultural lands in NYS, if agriculture lands hosted 100 percent of wind energy development projects, for all the projections between approximately 1.4 percent up to 56.5% percent of agriculture lands would have to be converted to wind energy development. The fraction of suitable land compares the NYSERDA on wind power and biodiversity estimate of suitable land for wind development to the land needed to meet CLCPA requirements. The fraction ranges from a miniscule 0.09 to a scary 3.82. These unrefined estimates are only intended to make the point that a refined analysis is needed. It is unlikely that wind development will take place on agricultural lands but solar energy development is much more likely there. Wind will impact forests along ridge lines.

Circling back to the Bluestone Wind Project analysis that predicted eagle and bat deaths I also calculated the state-wide impacts using their numbers. Annual deaths range from 91 to 804 Bald Eagles, 23 to 199 Eastern Gold Eagles, and 373 to 3,283 bats simply extrapolating their numbers state-wide. Of course, those are crude numbers. The population density of these species has to be mapped against the actual locations of potential wind farms for starters. The actual methodology used to determine deaths also has to be checked and the bat deaths incorporate a mitigation curtailment that limits operations.

Conclusion

I have always maintained that the biggest deficiency in the CLCPA was the lack of a feasibility study. It is not clear to me that the ultimate problem of trying to supply the energy needs of an mostly electrified New York electric system can be solved during a multi-day winter doldrum if the primary sources of electricity are wind and solar The only way this might work will require extraordinary amounts of wind and solar development. When there is an “official” estimate of those resources clearly a cumulative environmental impact analysis for those resources should be completed as soon as possible.

Ideally, preparations for that cumulative analysis should start now to determine a threshold for unacceptable environmental impacts. For example, I am worried about eagles. If you had told me 30 years ago that I would ever see a Bald Eagle from my home I would have been doubtful. Now that has occurred and I am not willing to chance that environmental victory. Because there are a limited number of eagles and their reproduction rates are low, I imagine that wildlife biologists could develop a criterion on the acceptable annual rate of state-wide eagle deaths from wind turbines. There were 426 occupied bald eagle nest sites in New York in 2017. It is obvious that a more detailed projection of wind turbine impacts on this rare resource is needed. The ultimate goal should be to refine the NYSERDA on wind power and biodiversity habitat sensitivity maps for the CLCPA resource development planning and siting process.

Another Example of New York State Environmental Hypocrisy

On July 15, 2020, the Council on Environmental Quality (CEQ) announced its final rule titled “Update to the Regulations Implementing the Procedural Provisions of the National Environmental Policy Act.” On July 16, 2020, New York Department of Environmental Conservation Commissioner Basil Seggos responded with a press release vilifying the changes to the process. This post explains why the Commissioner’s concerns are flatly contradicted by the State’s own actions.

I am a retired electric utility meteorologist with nearly 40-years experience analyzing the effects of meteorology on electric operations and reviewing environmental policies on energy operations. 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.

Statement from NYS DEC Commissioner Basil Seggos on NEPA Rollbacks

First, here is the statement released by Seggos:

It’s no surprise that the President wants to eviscerate the nation’s environmental review law. This has been the most reckless anti-environment, anti-health, and anti-science administration in history. The administration thinks this would be good for the economy but they have it backward. Thorough environmental review actually strengthens local economies and jobs by ensuring the resiliency and durability of our infrastructure. Environmental review also provides important protections for low-income communities and communities of color that have borne the brunt of pollution-the same communities most impacted by the coronavirus and most at risk from climate change.

CEQ NEPA Regulation Revisions

What changed in the rules to draw the ire of Commissioner Seggos? According to the press release, “The modernized regulations will promote more efficient, effective, and timely environmental reviews by all Federal agencies”. The fact sheet states:

For the first time in over 40 years, CEQ has comprehensively updated its National Environmental Policy Act (NEPA) regulations to modernize the Federal environmental review process, which will benefit the environment, economy, and every American. The regulations, which apply to all Federal agencies, have been complex and unnecessarily difficult to understand and navigate. The result has been excessive paperwork, litigation, and delays. Environmental impact statements (EISs) for Federal highway projects have averaged over seven years to complete and some reviews have taken a decade or more.

CEQ’s final rule will modernize the NEPA regulations by simplifying and clarifying the requirements, and incorporating key elements of President Trump’s One Federal Decision policy. The final rule codifies Supreme Court and other case law, updates the regulations to reflect current technologies and agency practices, eliminates obsolete provisions, and improves the format and readability of the regulations. The rule also exempts certain loan guarantee programs from the NEPA process, which will reduce unnecessary burdens on small businesses and family farms. Additionally, the rule will expand public participation and the involvement of tribal governments in the NEPA process. The modernized NEPA regulations will accelerate the environmental review and permitting processes for development of modern, resilient infrastructure, management of our Federal lands and waters, and restoration of our environment.

Accelerated Renewable Energy Growth and Community Benefit Act

In early April 2020, NYS passed the Accelerated Renewable Energy Growth and Community Benefit Act (AREGCBA) as part of the 2020-21 state budget. This legislation is intended to ensure that renewable generation is sited in a timely and cost-effective manner. According to the State’s press release, “New York State public authorities and agencies announced the passage of legislation as part the FY 2020-2021 state budget to dramatically speed up the siting and construction of clean energy projects to combat climate change and help jumpstart the state’s economic recovery from the COVID-19 health crisis”.

In a post describing the AREGCBA, I commented on the legislative finds and statement of purpose of the law. Of particular note, In section 4: “A public policy purpose would be served and the interests of the people of the state would be advanced by: expediting the regulatory review for the siting of major renewable energy facilities and transmission infrastructure necessary to meet the CLCPA targets, in recognition of the importance of these facilities and their ability to lower carbon emissions”. New York has a permitting process in place for electric generating units, Article 10. that requires “environmental and public health impact analyses, studies regarding environmental justice and public safety, and consideration of local laws” but those requirements take time to evaluate and it appears the purpose of this legislation is to over-ride the time needed for those analyses.

Conclusion

Clearly, the only distinction between these two separate actions is what kind of project should get treated differently in the future. The Trump administration wants to “accelerate the environmental review and permitting processes for development of modern, resilient infrastructure, management of our Federal lands and waters, and restoration of our environment”. The Cuomo administration wants to expedite “the regulatory review for the siting of major renewable energy facilities and transmission infrastructure necessary to meet the CLCPA targets”. That choice is a value judgement.

In the summer of 2019 Governor Cuomo and the New York State Legislature passed the Climate Leadership and Community Protection Act (CLCPA) which was described as the most ambitious and comprehensive climate and clean energy legislation in the country when Cuomo signed the legislation. The comprehensive plan to implement the transition to an electric system that does not use any fossil fuels by 2040 has yet to be developed. The massive build-out of solar and wind resources as well as the energy storage needed has not been quantified. Nonetheless, state agencies are preparing environmental impact analyses and the AREGCBA is going to accelerate the siting of renewable energy facilities.

If Commissioner Seggos is truly worried about the environment, health impacts and science as well as protections for low-income communities and communities of color, then he needs to address issues related to the CLCPA build-out. The cumulative life-cycle impacts of New York’s energy transition should be addressed for starters. One recent estimate by Brattle presented at a June 15 NYISO committee meeting indicated that over ten times the existing wind energy capacity of New York might be necessary by 2040. The cumulative environmental impacts of that many wind turbines on birds and bats needs to be addressed. Seggos’ Department of Environmental Conservation (DEC) has been touting a link between peaker power plants and human health but, so far, has ignored potential health impacts of wind turbines.

The DEC has thus far also ignored the sustainability science of renewable energy and energy storage. However, as shown in a recent study, “compared with hydrocarbons, green machines entail, on average, a 10-fold increase in the quantities of materials extracted and processed to produce the same amount of energy”. What are the environmental impacts of the extraction and processing of those materials? More importantly, with regards to “low-income communities and communities of color”, where are those materials going to come from. A recent UN report warns that the raw materials used in electric car batteries, are highly concentrated in a small number of countries. For example, two-thirds of all cobalt production happens in the Democratic Republic of the Congo (DRC). According the UN Children’s Fund, about 20 per cent of cobalt supplied from the DRC comes from artisanal mines, where human rights abuses have been reported, and up to 40,000 children work in extremely dangerous conditions in the mines for meager income.

I believe that a comprehensive cumulative environmental impact analysis of the life-cycle of the renewable energy resources required by the CLCPA is necessary. If Commissioner Seggos were calling for such an analysis, then I would respect his statement on the revised NRPA regulation. However, such is not the case and New York’s current regulatory process clearly shows the hypocrisy of the Cuomo Administration.

Transportation Climate Initiative Polling Results

I have previously posted on the Transportation Climate Initiative and its disconnect with reality. To this point its promoters and stakeholders have labored in obscurity all the while believing that they have a mandate from the public to change the transportation system significantly. Now there is a poll out claiming that the majority of the public supports the plan.

Survey

A new survey from MassINC Polling Group purportedly shows broad support for the Transportation Climate Initiative. According to the press release:

A new set of polls of registered voters across the Northeast and Mid-Atlantic finds broad support for a multi-state policy to cap carbon pollution from transportation and invest in transportation improvements. That policy is currently being developed by the Transportation and Climate Initiative (TCI), a collaboration between 12 states and the District of Columbia.

The research surveyed registered voters in the seven largest states at the TCI table: Connecticut, Maryland, Massachusetts, New Jersey, New York, Pennsylvania, and Virginia. Overall, 66% of voters said they would support the policy, while 23% were opposed. Support ranged from a high of 71% in New York to a low of 60% in Virginia.

“This is a complex policy, and so we took the time to explain the basics of how it would work and how states might use the funds generated by it,” said Steve Koczela, president of The MassINC Polling Group, which conducted the polls with support from the Barr Foundation. “Support was broad, stretching across demographic and party lines and throughout the region.”

Across nearly every demographic group, more voters support than oppose their state joining in the program. Support was highest about younger voters (78%), non-white voters (75%), and lower income voters. Women (69%) were slightly more supportive than men (63%). The partisan gap was smaller than is seen on many issues in the current polarized climate, with Democratic support outpacing Republican support.”

Voters were also asked to rate several potential uses for the funds generated by the proposed program. While majorities supported each item, two rose to the top overall and across the seven states polled: improving public transit and protecting transportation infrastructure from the effects of climate change. Generally, investing the proceeds of the program in existing infrastructure was favored over seeding newer technologies like electric vehicles, targeting communities most effected by pollution, or insulating drivers from higher costs at the pump.

The polls also asked voters about their views of climate change:

- - - - 73% of voters across the region think climate change is probably happening;
        
        Among those, 85% think it is due at least in part to human activity;
        
        66% think climate change will be a serious problem for their state if left unchecked;
        
        57% think the federal government is doing too little to address climate change; and
        
        44% think the same of their own state government.

Voters also understand that transportation is contributing to climate change. When asked to rank six sectors of their state’s economy based on their greenhouse gas emissions, 65% ranked transportation first or second.

Despite all this, only 48% cited addressing climate change as a “major priority” for state government in their state. More (64%) considered improving roads, highways and bridges a major priority, just below health care costs (73%) and jobs and the economy (71%).

The disconnect between voters’ professed concern about climate change and the priority they place on addressing it is consistent with other polling MPG has conducted on climate change. “We’ve seen in other polling on this issue that voters believe in climate change and support policies that would address it, though not always because of the link,” said Koczela. “They may not always rank climate as a top immediate concern, but they do support actions to address it.”

About the Poll

These results are based on a survey of 6,395 registered voters across seven Northeast and Mid-Atlantic states: Connecticut, Maryland, Massachusetts, New Jersey, New York, Pennsylvania, and Virginia. Responses were collected via online survey interviewing November 12-19, 2019. Final survey data was weighted to known and estimated population parameters for each state’s registered voters by age, gender, race, education, geography, and party. Each state was then weighted to its relative proportion of registered voters to create an “Overall” regional average. This project was sponsored by The Barr Foundation.

My Thoughts

Steve Koczela, president of The MassINC Polling Group said “This is a complex policy, and so we took the time to explain the basics of how it would work and how states might use the funds generated by it”. It is mind boggling to me that he never thought to include a question about costs. Obviously if costs are low why wouldn’t everyone be in favor of “improving public transit and protecting transportation infrastructure from the effects of climate change”.

The published plan says that in December 2019 there will be a release of a regional policy proposal in the form of a draft Memorandum of Understanding (MOU), accompanied by modeling results that estimate the energy and emissions implications of different cap levels and investment scenarios, as well as potential costs and benefits of different program design options. When it is released then there can be a poll that determines how much appetite the public has when they know potential costs. Until then any poll is suspect.

I have one other problem with the poll itself. I was unable to find details about the geographic distribution but because the only geographical categories listed were by state, I doubt that there was consideration of urban vs. rural. The fact is that rural respondents are not going to rate improvements to public transit very high because it is of no value to them. On the other hand, the gasoline tax increase needed to fund the TCI will disproportionally disadvantage anyone who has no choice but to use their personal vehicle. For example, the National Household Travel Survey estimated vehicle miles traveled in 2009. In the TCI jurisdictions urban vehicles mile traveled totaled 386.55 million miles, suburban miles traveled were 666.36 million miles, and rural miles traveled 703.38 million miles. Failure to account for that geographic difference makes the poll suspect.

Finally, I think there is a corollary to the concept that you can prove anything with statistics. In particular, you can prove anything with a survey poll. The Barr Foundation sponsored this poll. Their website states:

“Climate change is real. It is happening. It is accelerating. All over the world, people are experiencing its effects. And these are becoming more devastating every year—a trend that can be checked only through dramatic, global effort.”

I believe they got what they paid for.

New York City Energy Storage Peaking Turbine Replacement

The biggest air quality issue in New York State is compliance with the National Ambient Air Quality Standard for Ozone. In order to meet that limit the New York State of Department of Environmental Conservation (DEC) proposed regulations earlier this year to lower allowable nitrogen oxide (NO_x) emissions from simple cycle and regenerative combustion turbines during the ozone season. The problem is that these turbines are needed to keep the lights on during periods when needed most so replacement is not very simple as I explained in an earlier post.

This post describes the State’s evaluation of the politically correct alternative, energy storage, to provide the power generated by these turbines. This post addresses the report findings for turbines that could be directly replaced by energy storage. I want to emphasize that the following represents my opinion and not the opinion of any of my previous employers or any other company with which I have been associated. I have been following the operational implications of these turbines and their effect on ozone for over 20 years.

Background

The evaluation of using energy storage to replace these peaking units is part of the New York State Energy Storage Roadmap announced by Governor Cuomo in June 2018. As part of that effort the Department of Public Service (DPS) established an Energy Storage Deployment Program. On July 1, 2019, Energy Storage Deployment Program Report – Unit by Unit Peaker Study was submitted to the docket for Case 18‐E‐0130 – In the Matter of Energy Storage Deployment Program. DPS staff, working with New York State Energy Research and Development Authority (NYSERDA), Long Island Power Authority (LIPA), New York Independent System Operator (NYISO), NY Department of Environmental Conservation (DEC), Con Edison, and consulting firm Energy and Environmental Economics, Inc. (E3) prepared the report. The DPS December 12, 2018 Order Establishing Energy Storage Goal and Deployment Policy directed them to develop a unit‐by‐unit operational and emission profile study and methodology to determine which downstate peaking power plant generating units are potential candidates for repowering or replacement. My previous post describes these peaking turbines and more detail on the rationale for replacement so I will not repeat that material here.

The December 2018 DPS Energy Storage Goal and Deployment Policy specified what was to be included in the analysis. It was to “include a series of reliability and operational assessment studies looking at the equivalent level of ‘clean resources’ that could provide the same level of reliability as the existing peaker units. Hybridization and repowering with energy storage, as well as replacement with stand-alone energy storage, should be explicitly examined, according to the Roadmap.”

According to the description in Energy Storage Deployment Program Report – Unit by Unit Peaker Study:

The analysis relies on historical 2013 hourly operational and emissions data for the approximately 4,500 MW of affected peaking units across the state (almost entirely concentrated in New York City, Long Island, and the Lower Hudson Valley) to examine the technical feasibility of energy storage or energy storage paired with solar providing equivalent historical generation of the peaking units. Peaker operational and emissions data from 2013 was chosen because this reflects the peak NYISO demand year, and the correspondingly high levels of peaker operation which occurred in July 2013. This served as a proxy for representing peak‐level system operations, although theoretical peak system operations may impose incremental needs beyond those of 2013. The study did not consider system changes after 2013 that may impact how conventional peaking units and energy storage resources operate in the future, such as retirements of existing units, changes in the overall levels and patterns of demand, new transmission solutions, and/or the addition of more intermittent, renewable energy.

Analysis

I am not a fan of the approach used in this analysis because I think it gives some mis-leading unit specific information. In the first place they considered all turbines as candidates not understanding that the primary purpose of some turbines is not to provide power during high load demand periods. They wasted effort considering the Jamestown Public Utilities turbine in Western New York that runs on the order of half the time. Peaking turbines are defined as units with an “average annual capacity factor of 10.0 percent or less over the past three years”. In addition there are turbines at steam boiler facilities that are necessary for “black start” situations when there is a blackout and the power necessary to start up the boiler is unavailable from the grid. Because that is a very rare instance the units are also run to provide power for peak power periods. In my opinion it would not be cost effective to dedicate energy storage for this application. You could not use it for peak loads because you never know when the grid power won’t be available. In conclusion the report considered units that should not have been included.

According to Table A-1 in the report, there are 3,780 MW of peaking turbines in New York. The report concludes that “Overall, at least 275 MW of peaking units, or around six percent of the total rated capacity of the fleet, are found to be potential candidates for replacement with 6‐hour energy storage sized to the maximum 2013 output of each peaking unit.” That means that a 6-hr energy storage system would be able to replace 7% of the existing peaking turbine capacity. The report goes on to say that “This number increases to over 500 MW when using 8‐hour duration storage”, but that only increases the replacement of existing capacity to 13%.

I don’t disagree with their conclusion that “Energy storage or a combination of energy storage and solar can contribute towards meeting NOx limits for a large number of units”. However there is a long way between “can contribute” and “will actually be an option used”. This is a preliminary scoping study. It notes that the “minimum size storage required to meet the NOx requirements can vary between units of the same facility” but does not recognize that the variation between sister units at a facility does not mean that one unit is more of a candidate than another. The reality is that affected sources will adopt a facility‐wide strategy to meet the NOx limits and those strategies were not examined in this report.

There are other issues as noted in the Conclusion and Recommendations for Further Study. They note that “A more detailed analysis will be needed to understand the reliability impacts of specific unit replacements, especially as loads and resources change with greater electrification of transport and buildings and higher penetrations of renewables.” Many of these peaking units are in load pockets and changes in the load will drive whether energy storage is viable.

Costs

The report states that “A more detailed and thorough benefit‐cost analysis would need to be performed to understand the true economic viability of the replacement and/or hybridization options presented in this analysis.” Therein lies the biggest issue of energy storage – the cost. For those of us outside of Albany who care about costs a recently released report from the National Renewable Energy Lab (NREL): “2018 U.S. Utility-Scale Photovoltaics-Plus-Energy Storage System Cost Benchmark” provides information that can be used to estimate the costs of the energy storage option.

The NREL study lists costs for durations up to four-hours but the DPS report also includes six-hour and eight-hour durations. Table 3 in the NREL document, Detailed Cost Breakdown for a 60-MW U.S. Li-ion Standalone Storage System with Durations of 0.5–4 Hours, provides the information necessary to extend their projections to those different durations. I fit a linear regression model to describe the relationship between the specific costs and energy storage duration from the NREL table. I use Statgraphics Centurion software from StatPoint Technologies, Inc. to do my statistical analyses because it enables the user to choose the best relationship from 27 different linear regression equations. In this evaluation, in every instance, the reciprocal-X model (Y = a + b/X) statistic was the best choice and every regression had an R-squared coefficient great than 99.9% which indicates a strong relationship and suggests that these estimates are good enough for this analysis.

The NREL analysis includes all the costs for a greenfield energy storage project so I calculated values of retrofit potential costs that exclude the land acquisition costs. I estimate the installed cost for energy to be $343/kWh for an eight-hour battery system, $355/kWh for a six-hour battery system, and $380/kWh for a four-hour battery system.

The table NYC Energy Storage Peaker Replacement Summary lists data from the DPS study and calculated values. Table E1 in the DPS report lists the total nameplate capacity (MW) of peaking units that can potentially be fully replaced with storage to meet the 2025 NOx limits at 100% sizing to each unit’s 2013 peak generation. Note that I did not include the upstate turbine included in the DPS report in this analysis because it is not a peaking turbine. There are 36 MW of peaking unit capacity in New York City and Long Island that can be replaced with four hours of storage, 229 MW that can be replaced with six hours of storage, and 463 MW with eight hours of storage for a total of 728 MW. This is 18% of the 2013 peak load in New York City and on Long Island. Table A estimates the replacement cost estimate using the NREL report numbers and shows that replacing 18% of the load with Li-ion battery storage would cost $1.8 billion.

The cost per ton removed further demonstrates the staggering cost implications. I could not figure out which particular units were candidates for replacement because my analysis of Table B-1 did not result in the same number of units in each category. As a result I could not calculate the unit-specific cost per ton removed. Instead I just used the total emissions from all the sources the report’s Table 3: Peaking Units 2013 Operational Data. Table B shows the costs if all the emissions from all the peaking units came only from the 728 MW that can be replaced by energy storage. The cost to remove a ton of NOx is over $900,000 per ton and cost to remove a ton of CO2 is over $1,000 per ton. In order to put those numbers in perspective consider that the social cost of carbon (the alleged societal cost per ton of CO2 emitted) is currently around $50 by the Obama administration method and less than $5 by the Trump administration.

Conclusion

The report concludes “Overall, the findings suggest that there is an opportunity to consider replacing or hybridizing a substantial portion of the peaking units subject to DEC’s proposed NOx rule with a fleet of storage resources paired with solar. Such an outcome would potentially deliver significant environmental benefits, advance the state’s carbon reduction and clean energy goals, as well as benefit historically disadvantaged populations and communities such as environmental justice areas in line with the goals of the Climate Leadership and Community Protection Act.” However these results show that the cost of energy storage replacement is at least an order of magnitude greater than the cost of carbon’s impacts so this opportunity is not a cost-effective way to advance the state’s carbon reduction and clean energy goals.

New York Peaking Turbines

On February 28, 2019 the New York State of Department of Environmental Conservation (DEC) proposed regulations to lower allowable nitrogen oxide (NO_x) emissions from simple cycle and regenerative combustion turbines during the ozone season. On the face of it this should be a relatively simple air quality issue but it is complicated by Governor Cuomo’s clean energy agenda. I am motivated to write this post on air quality regulation and energy policy because the majority of what has been said so far about this regulation fails to discuss the complexities of the issue and misses the point of the regulations.

This post describes an open regulatory issue and I want to emphasize that the following represents my opinion and not the opinion of any of my previous employers or any other company with which I have been associated. Ozone pollution is currently New York State’s most difficult air quality issue and I have been following the particular aspect of these turbines and their effect on ozone for over 20 years. I will try to show in this post the background of the problem and how this regulation is embroiled in energy policy implications that are complicating the issue considerably.

Background

The proposed regulation covers simple cycle and regenerative combustion turbines but I am going to focus on just simple cycle turbines in New York City which make up the majority of the turbines in question. In the early 70’s Consolidated Edison was an integrated utility and responsible for generating and distributing electricity to New York City. Their generation planners developed a fleet of baseload, intermediate and peaking generating plants to provide power for the expected demand. (If you are unfamiliar with this concept I recommend the Generation Planning 101 section at this link).

Keep in mind that New York City requires massive amounts of power and there are geographical limitations as to how much can be imported in so the whole metropolitan area is a load pocket. Moreover there were areas in the City that had their own load issues, i.e. they are in load pockets within the City-wide load pocket. In order to provide peaking power for the City and those areas Con Ed developed four combustion turbine facilities that use simple cycle turbines: Astoria (558 MW current nameplate capacity), Gowanus (640 MW), Narrows (352 MW) and Ravenswood (375.3 MW). According to the NYISO “Gold Book” in 2017 the net energy generated from all four facilities was 212.2 GWh with an overall capacity factor of 1.3% as shown in New York City Simple Cycle Peaking Turbines Summary.

New York City Simple Cycle Peaking Turbines Summary

	Number of	Name Plate	2017 Net Energy	Capacity
Facilities	Turbines	(MW)	GWh	Factor
Astoria	12	558.0	103.2	2.1%
Gowanus	32	640.0	31.9	0.6%
Narrows	16	352.0	56.6	1.8%
Ravenswood	10	375.3	20.5	0.6%
Total	70	1,925.3	212.2	1.3%

The units at these facilities are known as peaking turbines for a reason. They only run when power is really needed. For New York City this is primarily during the summer when load peaks due to air conditioning load. When Consolidated Edison was responsible for electric system reliability they had a fuel and generating mix that addressed peak load using these relatively cheap to install and operate turbines. Simple cycle turbines are basically jet engines hooked up to an electrical generator. In order for these sources to be profitable they have to recover all their operating and maintenance costs for the year during those peak periods. Part of the reason costs go up so much when energy demand is high is because of this effect.

While appropriate at the time they are ready for replacement. The turbines at these four facilities are approaching 50 years old, they are inefficient inasmuch as they burn more fuel than a new turbine to produce the same amount as power, and they are dirty, that is to say their emission rates are much higher than a modern turbine.

However, New York State de-regulated the electric sector at the turn of the century. As part of that process, Consolidated Edison sold most of their generating facilities and, in order to encourage competition, the in-city fossil generation assets were sold to three different companies. In the simpler time before de-regulation, DEC would have promulgated a phase-out rule and Consolidated Edison would have proposed replacement power generating facilities and received cost recovery from the NYS Department of Public Service in a rate case because of the obvious need. Today’s owners have no such assurances. Instead they have to rely on the market to recover their investment costs. As a result energy policy is a major concern.

Ozone Air Quality Issue

As noted previously, ozone is New York State’s most difficult are quality problem. Despite years of progress ozone stubbornly fluctuates around the current National Ambient Air Quality Standard (NAAQS) limit that protects human health. It is important to keep in mind that the limit has changed over time so there has been progress but reaching the current limit has proven difficult. Ground-level ozone is not directly emitted into the atmosphere. Instead it is created in a complex photo-chemical reaction (it needs sunlight) from oxides of nitrogen (NOX) and volatile organic compounds (VOC). It is difficult to control in New York City because there are two pollutants, the reaction that creates ozone takes time so wind transport is an issue and transport in the complicated wind regimes along the Atlantic and Long Island Sound coastlines is difficult to simulate.

Ozone reaches unhealthy levels on hot sunny days and therein lies the rub. On hot sunny days people want air conditioning and as a result those are the days of peak load. That means that the peaking turbines usually run on those days most conducive to ozone formation. On those days reductions at all sources of NOX and VOC have been considered to control ozone. Because NOX is emitted from all combustion sources and VOCs are emitted from most things that have an odor there are all kinds of sources that affect ozone concentrations. Peaking turbines are one of the last large sources and I believe need to be controlled. As a side note however, I don’t think that when they are controlled that ozone compliance will be attained but it is progress and their time has come.

Electric Sector Energy Policy

If this were only an air quality issue the New York State Department of Environmental Conservation (DEC) would have simply promulgated a rule that requires phase out over time a long time ago. Unfortunately, there are energy policy ramifications, because while they are dirty, they also are necessary to provide power during peak periods. DEC wants to keep the lights on so they have not proposed such a rule until this time. During the development of the regulation the primary concern was how to develop a regulation that would give time for replacement power to be developed.

According to de-regulated utility theory the market will respond to needs when the price is right. In this case, that will be when developers believe the market supports permitting and building replacement power plants. I am not an economist or power plant developer but it is my opinion that you asking a lot of the market to provide an incentive to an investor to commit to developing a power plant anywhere, but (as we shall see) in New York that is doubly true. So what is the peaker market situation in New York? As mentioned before three companies currently own the four primary peaker turbine facilities in New York. One has not done anything. As far as I can tell that simply may because their facility has more site constraints than the other two companies. The other two companies have replacement plans.

According to the NYISO Gold Book, NRG Energy first proposed to re-power its Astoria Gas Turbine facility in the 2009 Gold Book and there is a project proposed in the most recent edition. Their plan is to build “fast-response, high efficiency combined cycle” turbines to replace the existing facility. New York has excruciating permitting requirements for power plants which are a major hurdle for development. The fact that NRG has a permitted project is a big plus. Again, I am no economist or power plant developer, but it appears to me that NRG thought they could make money when they were doing the permitting but has not yet decided to commence construction so they are not sure they can make money re-powering its turbines. Only time will tell whether that economic decision will change when this regulation is implemented.

Eastern Power Generation owns the Gowanus and Narrows turbine facilities. They have proposed to re-power Gowanus and retire Narrows at the formal start of their permitting process so they are navigating the process. In addition to emission reductions, their proposal will reduce the peak amount of power that can be generated. Given that their permitting program is proceeding they must believe they can make money once the facility is built.

To recap, DEC has proposed a regulation to phase out older peaking turbines because of their high emissions that affect ozone concentrations. The phase out is complicated by the need to insure peaking power is available but two owners have expressed interest in developing replacement power plants to meet that need. So on the face of it all looks good. If only it were this simple.

New York State Announcement

The only official announcement of this rule was from the New York State Energy Research and Development Authority (NYSERDA).

Governor Andrew M. Cuomo today announced that the New York State Department of Environmental Conservation released proposed regulations to improve air quality and protect public health with new, stringent requirements on peak-use power plants. The proposal will substantially reduce emissions from the “peaking” power plants operating on the hottest days with the most air pollution. These dirty, inefficient plants, are also major sources of carbon pollution. Transitioning away from them is a critical component of achieving Governor Cuomo’s nation-leading Green New Deal. These regulations will help to reduce greenhouse gas emissions 40 percent by 2030 and shift to 100% clean electricity by 2040.

“Climate change is a frightening reality, and while the federal administration buries its head in the sand, New York is taking action to protect our environment and the health of our residents,” Governor Cuomo said. “These proposed regulations are a critical step toward getting older, dirty power plants off the grid in the state’s most vulnerable areas, and demonstrates New York’s leadership in developing a clean energy economy and healthier communities for generations to come.”

There are several odd things about this announcement. Firstly, it did not come from the agency responsible for the rule. I am not sure why DEC would not have made it. The press release correctly notes that it will substantially reduce emissions from peaking power plants. However it states that these units are “also major source of carbon pollution”. Then it goes on to state that this is a critical component for the greenhouse gas emissions goals. The comment about “getting older, dirty power plants off the grid in the state’s most vulnerable areas” is an apparent sop to the environmental justice community. The bottom line is that we have gone from an air quality issue complicated by de-regulation to a “critical” component of Governor Cuomo’s Green New Deal and all the political pandering that entails. I address these points relative to the real world below.

Cuomo’s announcement says that these sources are a major source of carbon pollution. The four peaking turbine facilities I am focusing on in this post emitted 79,385 tons of CO2 in 2017. Other RGGI affected sources in New York emitted 26,064,607 tons of CO2 in 2017. I do not agree that 0.32% of the electric sector emissions is significant. The claim that these turbines are a major source of carbon pollution is absurd.

Cuomo also claims that this is a critical component of the needed reductions for his goals. The NYSERDA Greenhouse Gas Inventory 1990-2015 contains an inventory of historical greenhouse gas emission data from 1990-2015 for New York State’s energy and non-energy sectors. It shows that in 2015 the electric sector was responsible for 16.3% of the state’s emissions. The percentage of these peaking turbines to total electric sector emissions is only 0.043%. One of the Cuomo goals is to reduce total NYS emissions 80% from 1990 levels. In 1990 CO2 emissions in New York State totaled 185,719,081 tons so the goal will be to get down to 37,143,816 tons. In 2015, CO2 emissions were 164,726,801 tons so the State “only” has to reduce another 127,582,985 tons. If the state is to meet the 2050 goal, then reductions of 3,645,228 tons per year are necessary. In other words the peaking turbines “critical” component (79,385 tons) is 2.2% of the reduction needed for one year which is, again, absurd.

My concern is with the energy policy implications. The announcement also quotes Cuomo as saying “These proposed regulations are a critical step toward getting older, dirty power plants off the grid in the state’s most vulnerable areas”. While these plants are indisputably old and dirty the energy policy question is whether they can be replaced by markedly cleaner fossil. Cuomo was badgered into “committing” to no new natural gas plants in May 2018. In February 2018 the Administration forced the New York Power Authority to do additional studies of the proposed Empire State Plaza Microgrid and Combined Heat and Power Plant project in Albany because the power plant was going to be powered by natural gas in response to local pressure to not use natural gas. I am not sure what the Administration position is on natural gas units for his Green New Deal. Additionally note that the New York City Council Climate Mobilization Act proposed regulation requires the city to complete a study over the next two years on the feasibility of closing all 24 oil- and gas-burning power plants in city limits and replacing them with renewables and batteries. Ultimately the question is whether the environmental agenda for absolutely no more natural gas infrastructure will derail the proposals for new power plants.

The air quality issue is whether these climate related energy agenda policies will affect the schedule for the replacement of these power plants. One last time, I am no economist or power plant development investor but it seems to me that these are not policies that encourage the proposed re-powering projects. On the other hand I have done enough energy research to determine that replacing dispatchable peaking power with renewables and enough energy storage to guarantee power is available for the peak needs given New York City constraints is a technological reach and a money pit. I fear that the politicians are going to delay what I believe what will ultimately be determined as necessary re-powering projects.

Conclusion

While many stories I have read about the proposed regulation to retire these peaking turbines as a component of Cuomo’s clean energy initiatives that is not the case. The New York City peaking turbines need to be replaced as part of the process of ozone attainment. They are dirty and inefficient but most of all they are approaching 50 years old and may fail when needed most. Proposals have been made to replace existing units with modern, efficient and markedly cleaner units. Unfortunately the energy innumerate claim that they can be replaced with renewables but the reality is that that is a technological stretch. The real story is that Cuomo’s energy initiatives will likely delay replacing these units or putting the City at risk of another black out banking on an untried and technologically challenging renewable and storage plan.

NY Green Deal: Offshore Wind

This is one of a series of posts on Governor Andrew M. Cuomo’s New York State Green New Deal. As part of his 2019 Justice Agenda he included a “nation-leading clean energy and jobs agenda that will put the state on a path to carbon neutrality across all sectors of New York’s economy”.

Not surprisingly there are no details other than the announcement, no mention of potential costs, and no explanation how all this will affect any of the many impacts that he claims are caused by climate change. There is a proposal to provide the plan to make New York carbon neutral and I will blog on those plans as they become available. In the meantime this post discusses the language used to describe the plan to make New York the national hub for offshore wind and deploy 9,000 megawatts by 2035 as part of the New York Green New Deal.

In the following sections I list the text from the announcement and my indented and italiczed comments follow.

New York is leading the nation on offshore wind, which, as an emerging clean energy industry in the U.S., has tremendous potential for both the energy sector and economic development in the state. Called for by Governor Cuomo and released in 2018, New York’s Offshore Wind Master Plan is the most comprehensive offshore wind strategy in the country and has charted the course for this energy resource to play a significant role in achieving a carbon-free electricity grid. In November 2018, New York issued its first major offshore wind solicitation for at least 800 megawatts, which will set the stage for large-scale development of this important resource and the economic advantages that come with it.

Although the course has been charted, aside from issuing a solicitation there really hasn’t been any implementation progress.

To ensure New York State is the focal point for offshore wind development and this growing industry, Governor Cuomo is proposing nearly quadrupling the State’s target for offshore wind deployment from 2,400 megawatts by 2030 to 9,000 megawatts by 2035, the most aggressive offshore wind goal in U.S. history.

The more relevant number is MWh or megawatt hour which is the measure of energy. New York State energy announcements usually report new facilities in MW or megawatts or power capacity. I believe this is mis-leading because a cursory comparison of this announcement’s 2,400 MW is close to Indian Point’s 2,311 MW capacity. However because wind energy is intermittent, the 2400 MW will only produce 8,977,000 MWh using National Renewable Energy Laboratory’s (NREL) 42.7 capacity factor while Indian Point produced 15,305,000 MWh.

I used the NREL capacity factor to determine the energy produced. According to the NREL’s 2017 Cost of Wind Energy Review, the levelized cost of energy off-shore wind is over two and a half times more expensive ($124 per MWh vs $47 per MWh). For the 6,000 MW of offshore wind mandated the estimated cost would be $4.174 billion.

To complement this bold statement of national and global leadership, Governor Cuomo is directing new actions, as part of the Green New Deal, to accelerate offshore wind progress in three specific areas: port infrastructure, workforce development, and transmission infrastructure.

Ports: Invest $200 million in New York port infrastructure to unlock private supply chain capital and maximize the long-term economic benefits to the state from the regional development of offshore wind. This multi-location investment would represent the nation’s largest infrastructure commitment to offshore wind and would solidify New York’s position as the hub of the burgeoning U.S. offshore wind industry.

Workforce Development: Establish a New York State Advisory Council on Offshore Wind Economic and Workforce Development and invest in an offshore wind training center that will provide New Yorkers with the skills and safety training required to construct this clean energy technology right here in New York.

Transmission: Initiate a first of its kind effort to evaluate and facilitate the development of an offshore transmission grid that can benefit New York ratepayers by driving down offshore wind generation and integration costs.

In order to get the off-shore wind power to market, we have to add $200 million for port upgrades, train workers at some cost, and build an off-shore transmission grid. The NREL estimate of over $4 billion does not cover all the costs of off-shore wind!

The development and adoption of offshore wind is a critical component of the transition to a clean energy economy and presents a major economic opportunity for New Yorkers, including the creation of thousands of high-quality jobs. With these new commitments, the New York will continue to lead in this exciting and developing field.

Denmark has offered to help New York’s offshore wind development. However, in 2016 the Danish government decided to abort the plans to build five offshore wind power farms, which were to stand ready by 2020. At the same time, Denmark is also scraping its green energy tariffs and abandoning some of its climate goals. “Since 2012 when we reached the political agreement, the cost of our renewable policy has increased dramatically,” said Minister for Energy and Climate Lars Christian Lilleholt to Reuters. The real lesson maybe to beware this source of renewable energy.

New York State Environmental Regulatory Hypocrisy

I have admired those skeptics that would not stop until they had open access to the climatic data that was used for the hockey stick calculations. In my own way I try to emulate their tenacity attempting to get policy makers to use the best rationale for decisions. This is a story of a complete failure of an attempt of mine in that regard.

This post reflects my opinion as a private retired citizen. They do not reflect the position of any of my previous employers or any other company I have been associated with, these opinions are mine alone.

The Cross State Air Pollution Rule (CSAPR) is a regional cap-and-trade program that regulates emissions from large fossil fuel-fired electricity generating units (EGUs) that produce electricity for sale and have a nameplate capacity greater than 25 megawatts electrical. The New York State Department of Environmental Conservation (DEC) recently revised their Parts 243, 244, and 245 rules to ensure New York maintains authority to allocate federal CSAPR allowances to regulated in-state generators and the New York State Energy Research and Development Authority (NYSERDA).

CSAPR is a cap and trade program. In this approach a cap is set that limits the total amount that sources can emit. Allowances representing a ton of emissions are distributed equal to the level of the cap. Sources have flexibility to choose how to meet their limits by either reducing their own emissions or purchasing allowances from other sources. Sources measure and report emissions, and must have sufficient allowances to cover their emissions. If they fail to surrender an allowance for each ton of pollution emitted then there are significant automatic penalties. This approach has been very successful so far but as the caps are ratcheted down there are limits to how well it work in the future.

New York State has submitted comments to the Environmental Protection Agency complaining that the CSAPR emission caps in upwind states are insufficient to enable New York to meet the ozone National Ambient Air Quality Standard limits. They claim that those emissions create so much ozone in the State that it is impossible for in-state sources to reduce enough to meet the ozone limits. They have submitted comments that claim that the upwind sources are not running their existing control equipment enough to lower emissions.

This is a component of cap and trade that some claim is a weakness of the approach. If the cost of an allowance is cheaper than the cost to run control equipment to reduce a ton of pollution, then the source will choose to emit rather than run the control equipment. If you want emissions as low as possible then this frustrates lower emissions. Ultimately this is a problem related to the size of the cap. If the cap is too high then allowances are cheap and their costs will be low and this problem will arise.

Earlier this year the DEC proposed changes to their regulations for the cap and trade programs associated with CSAPR. Their process includes a stakeholder meeting where the proposed rule changes are presented and stakeholders get to ask questions. This is followed by a formal release of the proposed rules and a comment period. Comments are submitted and the final rule is promulgated after consideration of the comments.

My particular problem with the DEC revised rules is that it has an allocation methodology that rewards sources that do not run their control equipment to the full extent possible. In CSAPR, EPA allocates each state a fixed number of allowances. The states get to pick how they allocate those allowances to the affected sources. In earlier programs DEC allocated allowances based on operations and the state-wide emission rate that they determined would meet the cap. In that case, a source had an incentive to run their pollution control equipment more because it would generate extra allowances that could be sold beyond those needed for compliance. The recently promulgated rule awards allowances based on recent emissions. In this case a source that does not run its pollution control equipment gets more allowances!

Despite my comments pointing out this problem and simply recommending that they go back to the previous allowance allocation methodology DEC promulgated the rule with the emissions allowance allocation methodology. It seems hypocritical of DEC to demand that upwind states reduce their emissions when their own rules reward sources that do the same thing.