New York Resource Adequacy Proceeding Comments

Update March 25, 2020: Submittal documents: Caiazza comments Resource Adequacy, Initial Estimate of Energy Storage Required White Paper,Energy Storage White Paper Appendix 1 Solar Irradiance Maps, and Appendix 1 Air Source Heat Pumps

The New York State Public Service Commission (PSC) issued an order commencing a proceeding to examine how to reconcile resource adequacy programs and the State’s renewable energy and environmental emission reduction goals. This post describes the comments I submitted in this proceeding.

Materials and information are available in the Department of Public Services (DPS) resource adequacy matters docket Case 19-E-0530.  .  According to the Order Instituting Proceeding and Soliciting Comments, the inquiry is “necessitated by the Commission’s statutory obligations to ensure the provision of safe and adequate service at just and reasonable rates. Costs to consumers are a primary and ultimate consideration, recognizing that the necessary investments in resources must have sound economics.”

The PSC order solicited comments on the following questions.  Does the New York Independent System Operator (NYISO) have sufficient resource adequacy evaluation mechanisms in place to deal with the State’s ambitious renewable energy and environmental emission reduction goals?  Do the policies and market structure mechanisms insure just and reasonable consumer rates? There were several specific questions about existing products and their value with respect to costs.  Finally, there was a general question about the State’s role with respect to resource adequacy and request for recommendations for what to do next.

I submitted comments because I am not sure that the Climate Leadership and Community Protection Act (CLCPA) can be implemented so that it does not jeopardize safe and adequate energy service at just and reasonable rates. I based the comments on evaluations I did for previous posts on Solar Issues in Upstate New York , CLCPA Solar and Wind Capacity Requirements and CLCPA Energy Storage Requirements.

My filed documents (dated 9/16/2019 as a filing on behalf of an individual) illustrate my concerns with two examples.  I prepared a white paper that provides an initial estimate of the likely energy storage component requirement based on real world data.  It shows that at night when winds are light the energy produced from these sources will have to be supplanted with stored energy if New York shuts down all its fossil generation.  Given the extraordinary cost of battery energy storage I estimate that the batteries alone will cost over $12 billion to replace existing fossil generation and Indian Point after it retires.  The second example describes a potential problem with winter peak loads once the CLCPA is implemented.  Because of the stringency of the law, home heating is going to have to be electrified.  The preferred retrofit option is an air source heat pump.  However, they don’t produce heat when the temperature gets below zero so homeowners will need a backup system and the cheapest alternative is radiant heat which is much more inefficient.  As a result there will be a spike in electrical load that cannot be avoided.

Both examples used data from the NYS Mesonet.  I believe the best way to determine resource adequacy is to base the analysis on historical meteorological information as shown in the examples.  In order to determine the amount of energy storage you have to calculate how much wind and solar power is available and when.  In order to determine the effect of air source heat pumps meteorological data from the winter 2017-2018 peak load period was used.  I recommended that historical meteorological data be used to characterize potential solar and wind energy production to determine the feasibility of the CLCPA emission reduction target that eliminates emissions from electricity production by 2040.

In addition, I believe that the State needs to do a cumulative environmental impact assessment of this regulation.  The problem is that while an individual industrial wind facility or solar facility may not have a significant 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.  For example, if one raptor gets killed by every ten wind turbines that might be acceptable but if we need a thousand wind turbines is one hundred raptors per year acceptable?

My final recommendation is for an independent review of the findings of the feasibility studies.  The CLCPA is the result of political pandering and the likelihood that a feasibility study would be subject to political influence is high.  The only way I can think of to prevent that is to establish an independent group to review the findings.  Membership should deliberately be chosen to represent both “sides” of vested interests in the outcomes.  They may not be able to come agree but their evaluation report can list where they have agreed to disagree and that will be useful for the public.

I think it is obvious that the resource adequacy proceeding must determine if the CLCPA can be implemented such that it does not jeopardize safe and adequate energy service at just and reasonable rates.  If renewable resources and energy storage are inadequate during the winter peak, then safe and adequate energy service could easily be jeopardized.  No jurisdiction has ever successfully reduced greenhouse gas emissions by developing renewable energy resources and managed to keep prices down and I see no reason that New York will be able to reverse that result.  Most importantly, the increase in energy prices will affect those who can least afford the increased costs.

If you are a resident of New York I ask that you submit comments to the DPS resource adequacy matters docket Case 19-E-0530 supporting the request for comprehensive, independent feasibility and cumulative environmental impact assessments.

CLCPA Energy Storage Requirements

Updated 31 August, 2019 in response to comments – changes in italics

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. This is one of a series of posts on the ramifications of the “most aggressive climate law in the United States”. This post lays out an initial guess for the energy storage needed for CLCPA wind and solar resources at levels greater than announced to date.

CLCPA Target Overview

The Citizens Budget Commission developed an overview of the CLCPA targets in Green in Perspective: 6 Facts to Help New Yorkers Understand the Climate Leadership and Community Protection Act. The goals of the law are truly aspirational:

Reduce greenhouse gas (GHG) emissions:

    • Reduce GHG emissions to 60 percent of 1990 emissions levels in 2030;
    • Generate zero GHG emissions from electricity production by 2040; and
    • Ensure GHG emissions are less than 15 percent of 1990 emissions levels in 2050, with offsets to reduce net emissions to zero.
      • GHG offsets means that for every ton emitted into the air one ton is removed via GHG capture of some sort. For example, a company or individual can pay a landowner to leave trees standing that would otherwise be removed or plant additional trees to offset GHG emissions.

Increase renewable electricity:

    • Increase renewable sources to 70 percent by 2030; and

Develop or support:

    • 9 gigawatts (GW) of offshore wind electric generation by 2035;
    • 6 GW of distributed photovoltaic solar generation by 2025; and
    • 3 GW of energy storage capacity by 2030.
    • Conserve 185 trillion British thermal units (TBTUs) of annual end-use energy use by 2025, of which at least 20 percent should be from energy efficiency improvements in disadvantaged communities.
    • The CLCPA also requires between 35 percent and 40 percent of spending on clean energy or efficiency programs be in disadvantaged communities and mandates an air monitoring program in at least four such communities.

Simple Wind and Solar Capacity Model

I believe that CLCPA advocates have not figured out that an electric system that is completely dependent upon renewables will require much more energy storage than commonly assumed. I follow Michel at the Trust, yet Verify blog because he evaluates Belgian “green” technology quantitatively and has given me many insights into potential issues that might also arise in New York. Moreover, like me he prefers using real-world data. In a recent post Michel evaluated the potential effect of increased electricity production from intermittent energy sources in Belgium with a simple solar and wind capacity increase data analysis “model”. He downloaded solar generation, wind generation, and total load data for an entire year. The solar and wind data were summed together for every time period, in his case 15 minutes. Then he projected solar and wind by multiplying the observed sum by different values. The results graphically showed that adding a lot more intermittent wind and solar capacity increases production peaks but does not increase production nearly as much during production valleys. In addition, the results show that as renewable capacity increases more balancing mechanisms will be required.

In a previous post I adapted his methodology to New York State for 2018 with his help and analyzed data from August 2018 which represents the month with the most deficit periods. I believe that the CLCPA claims that renewable energy can completely replace the current fossil fuel load are extraordinary. As such, its proponents have to provide extraordinary evidence that it can work. In this post I look at the required balancing mechanisms for solar and wind to replace existing fossil generation in New York.

In the previous post I estimated how much energy storage may be required by incorporating reasonable assumptions about the future using assumptions about the availability of nuclear, solar, and wind using the Trust, yet Verify simple approach. The biggest future change is the forced shutdown of the Indian Pont nuclear facility in the next several years. In my previous analysis I used “best case” estimates that assumed that solar and wind are available at their rated capacities every hour in my test period. Because those sources are intermittent the amount of time when they are available at full load is not constant. For example, solar availability varies during the day and over the month of August there will be periods when the wind is blowing less than optimal. On the other hand assuming that Indian Point capacity is not available at its rated capability is a reasonable assumption because it usually runs at full load except for maintenance.

The ultimate result in that post estimated the wind and solar capacity from an aggressive CLCPA implementation plan.  In that post and this one I want to estimate the least amount of energy storage needed in the future so I increased renewable additions more than have been announced to date.  I don’t think there will be any significant increase in hydro or the other renewable category sources of methane, refuse, or wood firing and they are not intermittent so I made no changes to those categories. Because New York is shutting down 2,067 MW of nuclear at Indian Point in the next several years I subtracted that amount from every hour. I multiplied the existing onshore wind resource twenty times to estimate future availability. The CLCPA plan currently calls for 9,000 MW of off-shore wind power but I doubled that amount. The CLCPA plan also calls for 6,000 MW of solar PV power but I doubled that amount too. In order to account for daylight I added 6,000 MW to every time period from 0700 to 1955. In order to account for wind intermittency I made some assumptions about availability and scaled the offshore wind resource down when the on shore resource was below half of the observed maximum.

As shown in August 2018 Simple Model Aggressive CLCPA Renewables vs. Fossil Load, there are many periods of surpluses (all the renewables minus the existing fossil resource shown in blue) but there are still periods with deficits even with the best case assumptions about renewable availability. The remainder of this post examines one of the deficit periods in more detail.

Refined Renewable Resource Estimates.

In order to more realistically estimate the potential renewable resources available during one of these periods real world observations need to be included. For this analysis it is assumed that the onshore wind assumption that additional wind would be proportional to existing wind is adequate. However, I did try to modify the offshore wind and the solar components. In order to do that I chose a shorter period and collected meteorological data to get a better estimate of potential solar and off-shore wind capacity. I arbitrarily chose a deficit period on the early morning of August 8, 2018 when winds were light and the sun was either not up or not at full strength to look at the potential magnitude of energy storage required to balance the deficit.

In order to characterize the off-shore wind potential I found a National Oceanic and Atmospheric Administration buoy located 30 NM south of Islip, NY (40°15’3″ N 73°9’52” W) that I used to represent NY offshore wind resource availability. I downloaded hourly NDBC data for 2018 and scanned the data. As noted August 8 had light winds. The weather map for 8 August 2019 shows that there was a large high pressure system dominating the east coast. As a result, I am confident that this buoy characterizes NY offshore wind speeds and thus the resource of NY offshore wind.

This analysis characterizes wind energy as a function of observed wind as follows. I found a wind turbine power output variation curve, developed a straight line equation for the curve and estimated that the output of 18,000 MW of New York offshore wind equals 1714 times the wind speed minus 6000. I assumed that the observed wind speed at the hub height is proportional to the logarithm of the height above ground. For the calculations I assumed a hub height of 85 m and a surface roughness of 0.0003 while the buoy anemometer height is 4 m. The NY offshore wind output capacity in MW was calculated for every hour using this approach.

The solar output is a function of the observed solar irradiation in watts per meter squared. I assumed that 12,000 MW of solar capacity could be added in response to the CLCPA but that will be installed state wide. I downloaded solar insolation maps from the NYS Mesonet archive. I accessed the solar irradiation map in the spatial analysis directory to get solar irradiation maps and as an added bonus the maps also include gridded winds. NYS Mesonet Solar Irradiance Map 8 August 2018 at 1525 UTC is an example of these maps and can be reproduced at this link. In this case there is a lot of variation across the state which makes a state-wide single number estimate of solar irradiation weak but sufficient for this first cut analysis. I estimate that the highest irradiance was 900 W/m2 and the lowest was around 100 W/m2. To do this right one would have to determine where the solar panels might be located to weight the observations. For this hour I guessed 600 W/m2 for the state. I assumed that the 12,000 MW of solar cells produced 12,000 MW when the solar irradiation equals 800 watts per square meter (the PVUSA test condition) and I did not account for any other factors such as the cell temperature or any losses. So my naïve formula for solar output was simply the observed input solar irradiation times 12,000 divided by 800.

The Deficit Example of Simple Model of Intermittent Wind and Solar Generation vs. Fossil Generation and Indian Point Shutdown table lists 5-minute from 0300 to 0955 EDT on August 18, 2018 when the assumed aggressive CLCPA renewable capacity could not replace the existing fossil capacity and loss of the Indian Point nuclear facility.   The first three data columns list the total NYISO state-wide generation load, the NYISO total load, and the fossil generation load. The next four columns list the onshore wind load, CLCPA solar load, and the CLCPE off-shore wind load calculated as described above with the total shown in another column. The next three columns present the meteorological data used. Finally the sum of the onshore wind load, CLCPA solar load, and the CLCPE off-shore wind load minus the existing fossil and the Indian Point capacity of 2,067 MW is listed. In this period all the five-minute periods were negative. The first conclusion is that the post-CLCPA constraint may not be the peak load but instead a night-time low wind period.

Energy Storage Requirements and Costs

I have never seen an analysis that attempted to determine how much storage capacity would be required to meet a real-world generation capacity deficit. Clearly the total capacity has to exceed the observed deficit. In this case I estimate that the total deficit equals the sum of the average of the 12 5-minute deficits each hour or 33,548 MWh. I think that the maximum output of the energy storage has to equal the largest 5-minute deficit or 8,131 MW.

After that it is not clear how best to divvy up the energy storage requirements. I assumed that the least cost energy storage approach would maximize energy storage duration based on lower costs per MWh in a recently released report from the National Renewable Energy Lab (NREL): “2018 U.S. Utility-Scale Photovoltaics-Plus-Energy Storage System Cost Benchmark”. I reported on my estimates for different duration energy storage costs in a post at What’s Up With That.  In this analysis I included the costs of the battery and did not include developer costs to site, permit and connect the facility to the grid.

In the Estimated Energy Storage Required and Potential Price table I summarize the energy storage needs and my projection for the amount of different duration energy storage needed for the seven hour deficit period with my over-built renewables future scenario. In the first hour of the deficit period the hourly average was 1,140 MW but the peak was 1,390 MW so I project 1,400 MW at 7-hour duration could be used. The next hour had the peak 5-minute deficit of 8,131 MW. In order to meet that and subsequent hours I project 1,300 MW at 6-hour duration, 2,750 MW at 5-hour duration and 2,690 MW at 1-hour duration would cover that peak and most of the subsequent deficits. In order to cover subsequent peaks I added 1,200 MW at 2-hour duration and 620 MW at 1-hour duration. The total MWh stored (37,160) exceeds the observed total deficit (33,548) by 3,612 so there is a lot of room for refining this analysis but that has to be weighed against the fact that no attempt was made to find the worst case period which has to be done at some point.

The total costs are staggering. In order to cover the deficit of energy produced by solar and wind resources at an aggressive level over current on-shore wind and proposed CLCPA solar and wind, $12.5 billion dollars of energy storage will be required to replace existing fossil generation and Indian Point. Nobody in the State has suggested how much energy storage will be required and the 3,000 MW of energy storage capacity by 2030 goal has not included any duration goals. In context 11,260 MW of energy storage capacity is needed according to this analysis and there are large amounts of seven, six and five hour duration energy storage capacity required.  Needless to say, no State estimates have covered the expected costs of their storage goal much less what might ultimately be needed.

Conclusion

In order to determine the cost and feasibility of the CLCPA the State needs to do a similar analysis using real world data and historical load data. The analysis should attempt to site likely renewable energy resources and use the NYS Mesonet data to determine potential resource availability for as long a period as possible. The goal of the analysis would be to determine the energy storage capacity required to meet the CLCPA so that a cost estimate can be prepared.

CLCPA Solar and Wind Capacity Requirements

CLCPA Solar and Wind Capacity Requirements

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. This is one of a series of posts on the ramifications of the “most aggressive climate law in the United States”.  This post addresses the wind and solar capacity necessary to implement the CLCPA by looking at a “best case” scenario.

CLCPA Target Overview

The Citizens Budget Commission developed an overview of the CLCPA targets in Green in Perspective: 6 Facts to Help New Yorkers Understand the Climate Leadership and Community Protection Act. The goals of the law are truly aspirational:

Reduce greenhouse gas (GHG) emissions:

    • Reduce GHG emissions to 60 percent of 1990 emissions levels in 2030;
    • Generate zero GHG emissions from electricity production by 2040; and
    • Ensure GHG emissions are less than 15 percent of 1990 emissions levels in 2050, with offsets to reduce net emissions to zero.
    • GHG offsets means that for every ton emitted into the air one ton is removed via GHG capture of some sort. For example, a company or individual can pay a landowner to leave trees standing that would otherwise be removed or plant additional trees to offset GHG emissions.

Increase renewable electricity:

    • Increase renewable sources to 70 percent by 2030; and

Develop or support:

    • 9 gigawatts (GW) of offshore wind electric generation by 2035;
    • 6 GW of distributed photovoltaic solar generation by 2025; and
    • 3 GW of energy storage capacity by 2030.
    • Conserve 185 trillion British thermal units (TBTUs) of annual end-use energy use by 2025, of which at least 20 percent should be from energy efficiency improvements in disadvantaged communities.
    • The CLCPA also requires between 35 percent and 40 percent of spending on clean energy or efficiency programs be in disadvantaged communities and mandates an air monitoring program in at least four such communities.

Simple Wind and Solar Capacity Model

I follow Michel at the Trust, yet Verify blog because he evaluates Belgian “green” technology quantitatively and has given many insights into potential issues that might also arise in New York. Moreover, like me he prefers working with real-world data. In a recent post Michel evaluated the potential effect of increased electricity production from intermittent energy sources with a simple solar and wind capacity increase data analysis model. He down-loaded solar generation, wind generation, and total load data for an entire year from the ELIA site. The solar and wind data were summed together for every time period, in his case 15 minutes. Then he projected solar and wind resources by multiplying the observed sum by different values.

Please go to the post and review the methodology and results. The results show that additional intermittent wind and solar capacity increases production peaks but does not increase production nearly as much during production valleys. In addition, the results show that as capacity increases more balancing mechanisms will be required. In my opinion the best part of the analysis was that the graphical results clearly showed these impacts.

As you can see in the comments I complimented Michel for the clarity of the analysis and asked if his model could be applied with New York data. He responded that it would be possible and I sent a link to the New York production data. I had intended to process the data for him to input but Michel graciously did the processing himself. (Fortunately for me because I no longer have access to data processing software, apparently I am the only one who wants to be able to use FORTRAN, so I have to brute force process data in a spreadsheet.) His results for 15x wind plus other renewables relative to total load are reproduced here.

Simple Wind and Solar Capacity Model with New York Data

Michel’s results used the historical data available at the New York Independent System Operator (NYISO) real-time fuel mix data dashboard. I will respond to his comments in the original post in more detail here.

Michel correctly determined that I only want to look at wind and “other renewables”.   I agree that the intermittent source results will not be as clear-cut as the Belgian data where wind and solar are registered on their own, showing the pure effect of the intermittent energy sources. The problem trying to estimate the effect of New York solar capacity increases is that solar is buried in “other renewables” which includes methane, refuse, or wood firing. Those other sources are not intermittent so we get mixed signals.

Michel used solar and wind capacity data but could not find corresponding New York capacity data, so he didn’t correct for potentially increasing capacity over the year. Unfortunately the NYISO data base does not provide a nice spreadsheet format capacity report like the ELIA generating facilities link. However, I don’t think there is enough added capacity to make a difference for this analysis. On the other hand Michel found that Belgian wind capacity increased by 500 MW and solar capacity increased by over 400 MW so he had to correct for that or the results would have been flawed.

Michel notes that the result is quite different from the Belgian data. In the first place New York is bigger. The ELIA link notes that total capacity in Belgium is 15,660 MW. The NYISO data are buried in Table III-3a Capability by Zone and Type in their annual Load and Capacity Data Report. In the summer the total capacity in New York was 39,245 MW in 2019. Secondly, peak loads are different. New York State production is highest in summer and lower in winter, just the opposite as Belgium. He correctly infers that air conditioning drives the peak load to the summer.

He correctly assumed that there is less solar capacity relative to wind in New York because solar capacity is so small that it does not have its own category. In the NYISO capability table there are only 31.5 MW of solar capacity. The ELIA solar-PV generation data link notes that “Elia has updated the register of total installed solar capacity in Belgium. As a result, the installed solar capacity increases with 416.27 MW” well over ten times as much as NY. However, the link also states that the monitored solar PV capacity is 3,369.05 MW. I assume that this refers to distributed solar PV capacity and also suggests the New York would be well served to start monitoring this capacity as well. The NYISO claims that there are 1,862 MW of solar PV nameplate capacity behind the meter.

Michel observes that consumption is higher in New York than Belgium and the share of intermittent energy smaller. As a result, the point where surpluses and shortages cancel out (without taking the losses into account) will be higher (somewhat higher than 25.5x, versus 8.5x for Belgium).

New York Simple Wind and Solar Capacity Model for August 2018

Michel’s model results indicate that August 2018 has many shortages so I looked at August 2018 data myself using a spreadsheet. My primary concern is the effect of the CLCPA on future capacity keeping in mind that the target is to eliminate fossil fuel use so I compared solar and wind only to fossil load, i.e., the output from the generators listed as fossil in Table III-3a: Capability by Zone and Type. Using the same data as Michel but only using renewables to replace fossil load gives a similar result. Note in the table August 2018 Simple Model 26 x New York Wind + Other Renewables vs. fossil load that surpluses are blue and deficits are red. There are more surpluses simply because fossil load is less than total load. Note that even if the wind and other renewable categories are increased 26 times the current rate existing fossil cannot be replaced without a lot of shortages.

I believe that the CLCPA claims that renewable energy can completely replace the current fossil fuel load are extraordinary. As such, its proponents have to provide extraordinary evidence that it can work. I have tried to modify the data to incorporate reasonable assumptions about the future using “best case” assumptions about the availability of solar and wind. These are “best case” estimates because I assumed that solar and wind are available at their rated capacities every hour in my test period. Because those sources are intermittent the amount of time when they are available at full load is not constant. For example, solar availability varies during the day and over the month of August there will be periods when the wind is blowing less than optimal. On the other hand assuming that Indian Point capacity is not available at its rated capability is a reasonable assumption because it usually runs at full load except for maintenance.

I don’t think there will be any significant increase in hydro or the other renewable category sources of methane, refuse, or wood firing and they are not intermittent so I made no changes to those categories. Incredibly New York is shutting down 2,067 MW of nuclear at Indian Point in the next several years because public perception of nuclear is a more important consideration than the existential threat of climate change. I subtracted that amount from every hour. The CLCPA plan currently calls for 9,000 MW of off-shore wind power so I added that amount to every hour. The CLCPA plan also calls for 6,000 MW of solar PV power. In order to account for daylight I added 6,000 MW to every time period from 0700 to 1955. The results in August 2018 Simple Model CLCPA Renewables vs. fossil load show the same thing: adding solar and wind capacity significantly adds to surplus loads but does not reduce the deficits nearly as much even if it were available at the full capacity every hour.

I tried to estimate capacity from an even more aggressive implementation plan (doubling the offshore wind and solar additions to 18,000 MW and 12,000 MW respectively). However, doing that would show positive numbers unless there is a correction for off shore wind intermittency if I simply added another 9,000 MW of wind to every hour. In order to account for wind intermittency I scaled the offshore wind resource down when the on shore resource reached half of the observed maximum. I scaled the resource proportional to the observed decrease in the 99th to the 70th percentile on-shore resource to the 50th. For example, when the on shore wind resource was at the 50th percentile I estimated that the off-shore wind resource was proportional to the 99th divided by the maximum observed onshore wind resource. I made similar corrections for even lower levels and I believe this is conservative. Again, as shown in August 2018 Simple Model Aggressive CLCPA Renewables vs. Fossil Load, the surplus increases by adding solar and wind capacity at full capacity but we still will have to deal with significant deficits.

My takeaway point is that even with unrealistic assumptions about the “best case” availability of solar and wind capacity, there are periods with significant deficits. In order to prove the extraordinary claim that solar and wind can replace existing fossil the State of New York, a similar type of analysis using actual data to estimate realistic energy production must be done. That is the only way to provide the extraordinary proof showing just how much energy storage will be required to prevent deficits. I will take a preliminary look at the energy storage ramifications of this in a future post.

 

Pragmatic Take on the Climate and Community Protection Act

I blog on pragmatic environmentalism because I am convinced that it is necessary to balance environmental impacts and public policy. This means that evidence-based environmental risks and benefits (both environmental and otherwise) of issues need to be considered. I have developed a set of principles that under lie my concerns. New York’s Climate and Community Protection Act exemplifies the opposite of a pragmatic approach to the problem of climate change. This post references my pragmatic environmentalist principles to explain my concerns.

In the 2019-2020 regular legislative sessions the New York State (NYS) legislature is debating the Climate and Community Protection Act (CCPA). The fundamental problem with this legislation is that it calls for a statewide greenhouse gas emissions limit of 0% of 1990 emissions in 2050.

One of my biggest problems with the CCPA is that the legislation sets its goal before it requires a scoping plan explaining how this will be done and how much it will cost. In almost all environmental issues there are two sides. Pragmatic environmentalism is all about balancing the risks and benefits of the two sides of the issue. In order to do that you have to show your work before you implement the policy and clearly this is not the case with the CCPA.

The rationale for the CCPA trots out many extreme weather events attributed to climate change. These brief sound bite descriptions only tell one side of the story. As a result they frequently are misleading, are not nuanced, or flat out wrong. The level of effort necessary to respond to them is large. As Alberto Brandolini put it: “The amount of energy necessary to refute BS is an order of magnitude bigger than to produce it.” In addition, the more extreme a climate or weather record is, the greater the contribution of natural variability, which is known as the Cliff Mass Golden Rule of Climate Extremes.

Ultimately advocates for this legislation ignore economic realities. Roger Pielke, Jr says the “iron law” simply states that while people are often willing to pay some price for achieving environmental objectives, that willingness has its limits.  There is no question in my mind that this legislation will test that willingness. Furthermore, Gresham’s Law of Green Energy observes that “bad money drives out the good.” The green energy subsidies necessary to implement the CCPA transfer wealth and do not create wealth. The subsidies or “bad” money take money out of the system that was “good” inasmuch as it was being used productively. Subsidized renewable resources will drive out competitive generators, lead to higher electric prices, and reduce economic growth.

Whatever the supporters say about costs the fact is that they will be significant. This legislation is presented as necessary but does not does not consider that in order to implement the initiatives tradeoffs are required simply because the resources available are finite. We can do almost anything we want, but we can’t do everything. Building resiliency to historical weather extremes seems to me to be a much better expenditure of resources.

 The economics issues are particularly relevant because of the ambitious goal. One of my principles states that: as the pollution control efficiency increases the control cost per ton reduced increases exponentially. This is particularly true for electrical system fossil emissions reductions. In New York the electrical generating plants reduced CO2 emissions 27% by switching from coal and oil to natural gas at essentially no cost because natural gas was cheaper than coal. Replacing natural gas generation to renewables is going to cost more because natural gas is cheaper. (If natural gas was not cheaper then no renewable subsidies would be necessary). Because the renewables are diffuse the transmission grid must be maintained but renewables do not support the grid so at some point that support must be added to the cost of displacing fossil fuels. Because renewables are intermittent at some point energy storage has to be added to the cost further adding to the cost of every incremental displacement. The final displacement to complete elimination of fossil fuel necessarily must expand the need for storage and grid support for the peak periods which are inherently the most difficult.

The final relevant principle is Ridley’s Paradox: Economic damage from man-made ‘climate change’ is illusory whereas damage from man-made ‘policies’ to fight the said change is real. Advocates for climate change action insinuate that all the extreme weather listed in the CCPA cause economic damage but are noticeably short on documenting how much the legislation will affect that weather. No one has ever claimed that hurricanes will not exist when we reduce CO2 emissions so the reality is that climate change might tweak a storm a little stronger. How much does that incremental change influence cost impacts and how much can we affect that change? In the absence of quantitative estimates this economic damage is an illusion. On the other hand, when we, for example, use food for fuel (ethanol subsidies) and drive up energy costs there are real tangible impacts to those least able to pay.

In conclusion my opinion on the legislation is uniformly negative because it has no plan and violates so may pragmatic environmental principles.

NYS Climate Leadership and Community Protection Act Effect on Global Warming

Update: 1 September 2019: Title changed and reference to signed legislation added

In the 2019-2020 regular sessions the New York State (NYS) legislature is debating the Climate and Community Protection Act (CCPA). 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.  This post calculates how much this legislation will reduce global warming.

The legislation definitions include “Greenhouse gas” means carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, sulfur hexafluoride, and any other substance emitted into the air that may be reasonably anticipated to cause or contribute to anthropogenic climate change.

The emission reduction goals are listed below

  • 75-0107. Statewide greenhouse gas emissions limits.
    1. No later than one year after the effective date of this article, the department shall, pursuant to rules and regulations promulgated after at least one public hearing, establish a statewide greenhouse gas emissions limit as a percentage of 1990 emissions, as estimated pursuant to section 75-0105 of this article, as follows:
          1. 2020: 85% of 1990 emissions.
          2. 2025: 65% of 1990 emissions.
          3. 2030: 50% of 1990 emissions.
          4. 2035: 35% of 1990 emissions.
          5. 2040: 20% of 1990 emissions.
          6. 2045: 10% of 1990 emissions.
          7. 2050: 0% of 1990 emissions.

In the absence of any official quantitative estimate of the impact on global warming from CCPA or any other New York State initiative related to climate change I did my own calculation. I simply adapted data for this emission reduction from the calculations in Analysis of US and State-By-State Carbon Dioxide Emissions and Potential “Savings” In Future Global Temperature and Global Sea Level Rise. This analysis of U.S. and state by state carbon dioxide 2010 emissions relative to global emissions quantifies the relative numbers and the potential “savings” in future global temperature and global sea level rise.   These estimates are based on the MAGICC: Model for the Assessment of Greenhouse-gas Induced Climate Change) so they represent projected changes based on the Intergovernmental Panel on Climate Change estimates. All I did in my calculation was to pro-rate the United States impacts by the ratio of New York emissions divided by United States emissions to determine the effects of a complete cessation of all CO2 emissions in New York State in 1990 proposed in the CCPA plan.

The first step is to quantify NY emissions. The New York State Energy Research and Development Authority 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. In 1990 the NY total was 218.1 million metric tons. The New York impacts were calculated by the ratio of the NY emissions reductions to the US reductions in the report. For example, the NY % of global total emissions equals the % of US global total (17.88%) times the CCPA reduction emissions goal (218.1) divided by the US emissions (5631.3). The CCPA Potential “Savings” in Future Global Temperature Table lists the results.

These calculations show current growth rate in CO2 emissions from other countries of the world will quickly subsume New York total emissions much less any reductions in New York CO2 emissions. According to data from the U.S. Energy Information Administration (EIA) and based on trends in CO2 these emission reductions will be subsumed by global emissions growth in 99 days. Furthermore, using assumptions based on the Intergovernmental Panel on Climate Change (IPCC) Assessment Reports we can estimate the actual impact to global warming for CCPA. The ultimate impact of the CCPA 100% reduction of 218.1 million metric tons on projected global temperature rise would be a reduction, or a “savings,” of approximately 0.0032°C by the year 2050 and 0.0067°C by the year 2100.

These small numbers have to be put in context. First consider temperature measuring guidance. The National Oceanic & Atmospheric Administration’s Requirements and Standards for NWS Climate Observations states that: “The observer will round the entered data to whole units Fahrenheit”. The nearest whole degree Fahrenheit (0.55°C) is over one hundred seventy times greater than the projected change in temperature in 2050.

Although this change is too small to measure I am sure some will argue that there will nonetheless be some effect on the purported impacts. However if these numbers are put into perspective of temperatures we routinely feel then that argument seems hollow. For example, in Syracuse NY the record high temperature is 102°F and the record low temperature is -26°F so the difference is 128 °F which is over 27,000 times greater than the predicted change in temperature in 2050. The annual seasonal difference ranges from the highest daily average of 71.6°F to the lowest daily average of 23.2°F, or a difference of 48.4°F which is over 10,000 times greater than the predicted change in temperature in 2050. The average difference between the average daily high and average daily low temperature is 10.4°F or nearly 4,000 times greater than the predicted change in temperature in 2050. Clearly the projected temperature change is so much less than what we routinely encounter there will be no personal effect.

Another way to give you an idea of how small this temperature change consider changes with elevation and latitude. Generally, temperature decreases three (3) degrees Fahrenheit for every 1,000 foot increase in elevation above sea level. The projected temperature difference is the same as going down 27 inches. The general rule is that temperature changes three (3) degrees Fahrenheit for every 300 mile change in latitude at an elevation of sea level. The projected temperature change is the same as going south two thirds of a mile.

Conclusion

I do not think that there is any question why the State has not provided a quantitative estimate of the impact on global warming from CCPA or any other New York State initiative related to climate change. Clearly we can expect no discernable impact. The calculated values provided in this post are based on the “consensus” estimates of the Intergovernmental Panel on Climate Change which I personally believe over-estimate the impact of temperature changes caused by greenhouse gas emissions but do represent the justification for the CCPA. As shown here claiming any observable impacts for the projected small change in temperature due to these emissions reductions is a stretch at best.

NYS Climate and Community Protection Act Rationale

In the 2019-2020 regular sessions the New York State (NYS) legislature is debating the Climate and Community Protection Act (CCPA). This post addresses the claims of increasing severity and frequency of events attributed to climate change in the CCPA rationale.

The bill states:

Climate change is adversely affecting economic well-being, public health, natural resources, and the environment of New York. The adverse impacts of climate change include:

      • an increase in the severity and frequency of extreme weather events, such as storms, flooding, and heat waves, which can cause direct injury or death, property damage, and ecological damage (e.g., through the release of hazardous substances into the environment);
      • rising sea levels, which exacerbate damage from storm surges and flooding, contribute to coastal erosion and saltwater intrusion, and inundate low-lying areas, leading to the displacement of or damage to coastal habitat, property, and infrastructure;
      • a decline in freshwater and saltwater fish populations;
      • increased average temperatures, which increase the demand for air conditioning and refrigeration among residents and businesses;
      • exacerbation of air pollution; and
      • an increase in the incidences of infectious diseases, asthma attacks, heart attacks, and other negative health outcomes.

This rationale is similar to most calls for action. Invariably there is a listing of weather events, claims of increasing severity and frequency, notes that extreme weather causes damages and, finally, insinuations that the proposed action will reduce damage.

When I first started this blog I developed a list of pragmatic environmentalist principles that describe my beliefs. This post illustrates my first principle that there are two sides to environmental issues and my latest principle that arguments about the issue are usually based on how each side interprets conflicting data. In this case the focus on one interpretation obscures the possibility that direct action would likely be a more effective policy alternative than the indirect policy proposed to control greenhouse gas emissions in hopes that will affect one of the drivers of the rationale examples.

Extreme Weather Events

The CCPA claims that climate change is adversely affecting New York now and cites storms, flooding, heat waves and rising sea-levels. If the CCPA were correct then all the occurrence of all these events should be increasing in frequency and intensity. In fact, the data on these extreme weather events are all easily available, and clearly show that there are no increases in any category other than normal fluctuations, and certainly nothing that can be attributed to human influences. Here is a link to a definitive document prepared by Francis Menton compiling evidence in all these categories and others. Judith Curry recently prepared a Special Report on Hurricanes and Climate Change that assesses the current status of hurricanes and climate.

The NY CCPA rationale for extreme weather events echoes the constant barrage of popular media accounts that attribute any unusual weather to climate change but in every instance there are data that indicate otherwise.

Decline in freshwater and saltwater fish populations

One example of the claim that declining fish populations are due to warming seas is the recent paper Impacts of historical warming on marine fisheries production. It states that “temperature-dependent population models to measure the influence of warming on the productivity of 235 populations of 124 species in 38 ecoregions. Some populations responded significantly positively (n = 9 populations) and others responded significantly negatively (n = 19 populations) to warming, with the direction and magnitude of the response explained by ecoregion, taxonomy, life history, and exploitation history. Hindcasts indicate that the maximum sustainable yield of the evaluated populations decreased by 4.1% from 1930 to 2010, with five ecoregions experiencing losses of 15 to 35%.” This description of the study seemingly supports CCPA rationale. It states that the study “looked at the impact of rising ocean temperatures on 124 marine species representing about one-third of the global catch from 1930 to 2010. It found that the “maximum sustainable yield,” or the amount of fish that could be caught each year without jeopardizing future harvests, dropped by 4.1 percent over this period as a result of climate change.”

Actually the study did not say anything nearly as alarming. It looked at 235 populations and found that warming had a positive influence on 9 populations, no influence on 207 populations and a negative influence on 19. Reality is that the 4.1% decrease in maximum sustainable yield only could be attributed to 19 of 235 populations. There is no question that decreasing fish stocks is a serious environmental problem. However the problem is over-whelmingly due to over-fishing “Increased human demand for fish and subsidies for fishing fleets have resulted in too many boats chasing too few fish”.

The NY CCPA rationale does not address the root cause of the decline in fish populations so it is unlikely that the legislation will have any effect on fish populations.

Increased average temperatures

I agree that average temperatures are increasing but I do want to point out that even this relatively uncontroversial statement is complicated. For example, consider the points made about the United States average temperature trend in this video. It shows that if you calculate the trend using the raw data the trend is cooling but recent adjustments have shifted it to warming.

The primary concern for increased temperature is heat waves and the National Weather Service NYC office determined the trend of decadal heat waves that clearly showed an increase in the length of heat waves since 1880. However, I believe that it can be argued that the urban heat island mentioned in the report is a primary driver of the Central Park trend. Trying to determine how much of the temperature and heat wave trend is caused by the greenhouse gas effect (the target of CCPA) compared to land use change and natural variation is a non-trivial task completely ignored by simply claiming that average temperatures are increasing.

Exacerbation of air pollution

The only air pollutant regulated by the Environmental Protection Agency that can possibly be exacerbated by warmer temperatures is ozone. Ozone is a secondary air pollutant created by a complex photo-chemical reaction from nitrogen oxides and volatile organic compounds and that reaction is temperature dependent. However regarding ozone levels, the relative effect of temperature compared to emission rates is small as shown by the fact that New York State ozone concentrations have been decreasing even though temperatures are increasing.

Increased incidences of diseases

The CCPA rationale claims climate change can increase the incidences of infectious diseases, asthma attacks, heart attacks, and other negative health outcomes. According to the World Health Organization report on climate change and infectious diseases it is well known that climatic conditions affect epidemic diseases. That report goes on to state that “Malaria is of great public health concern, and seems likely to be the vector-borne disease most sensitive to long-term climate change”. However, it also is well known that during the construction of the Erie Canal canal fever was a concern, particularly during construction across the Montezuma Marsh.   In fact there were malaria problems even further north in Ontario when the Rideau Canal was built. This article explains that malaria can be controlled by “reducing the numbers of malaria parasites to a point low enough to break the infection cycle.”

The argument for asthma attacks and climate change is that it increases water and air pollution. One study claims that there is an increase in heat-induced heart attack risk in recent years. But they go on to note that “Individuals with diabetes or hyperlipidaemia were particularly at risk over the latter period. The researchers suspect that this is partly a result of global warming, but that it is also a consequence of an increase in risk factors such as diabetes and hyperlipidaemia, which have made the population more susceptible to heat.”

All these examples are similar and the rationale that reducing greenhouse gases will have an effect is flawed.   For malaria the effect of long-term climate change can be mitigated much better by directly breaking the infection cycle than indirectly reduce mosquitos by trying to control temperatures. Directly mitigating air and water pollution is more effective than trying to reduce it by controlling temperature. Finally, directly reducing other heart attack risk factors is likely more effective than indirectly reducing temperature.

Science

Advocates for this legislation and other similar programs in New York State claim that they are all for the science. So am I. There is no question that global temperatures have been warming since the end of the Little Ice Age in the early 1800’s. There also is no question that increased levels of carbon dioxide and other greenhouse gases reduce out-going long-wave radiation and that warming results. Because human activities have added to those gases there is no question in my mind that at least some of the observed warming is very likely due to mankind. The question is how much of the observed warming is due to greenhouse gases relative to other human factors and the natural causes that have driven all previous climatic change. That makes all the difference.

Despite the constant barrage of popular media accounts that simply state that climate change is real and caused by mankind, reality is much more complex and it is not clear that mitigating greenhouse gases will necessarily affect climate change. We do not understand the natural causes of climate variation responsible for historic climate change. If we did understand them then we would be able to predict the weather for the next season, for example how much snow and how much cold. Clearly we don’t.

More importantly, for societal policy there is a trade-off. I tried to show that if we are concerned about the issues in the CCPA rationale that are ascribed to climate change that directly addressing them will likely be more effective than trying to control the climate. Moreover, the Ridley’s Paradox should also be considered: Economic damage from man-made ‘climate change’ is illusory whereas damage from man-made ‘policies’ to fight the said change is real.

Air Source Heat Pumps In New York

New York’s proposed Community and Climate Protection Act has a goal for “the state of New York to reduce greenhouse gas emissions from all anthropogenic sources 100% over 1990 levels by the year 2050, with an incremental target of at least a 50 percent reduction in climate pollution by the year 2030”. In order to reach that ambitious CO2 reduction goal all sources of CO2 emissions have to be reduced. One energy sector with relatively large emissions is residential home heating and the clean energy alternative for home heating is electric heat pumps. In this post I explain why I think that air source heat pump deployment in New York coupled with the simultaneous goal to eliminate greenhouse gas emissions is fatally flawed based on a case study for conversions near Caledonia, NY.

Background

How Stuff Works explains that “heat pumps use a small amount of energy to move heat from one location to another”. Air conditioners cool our homes by removing heat from the air inside and moving outside. An air-source heat pump acts like an air conditioner in the summer and in the winter works in reverse moving heat from the outside air into the home to warm it. Obviously this kind of heat pump eliminates the need to have two separate systems and advocates tout its energy savings too. According to the Department of Energy (DOE):

An air-source heat pump can provide efficient heating and cooling for your home. When properly installed, an air-source heat pump can deliver one-and-a-half to three times more heat energy to a home than the electrical energy it consumes. This is possible because a heat pump moves heat rather than converting it from a fuel like combustion heating systems do.

Air-source heat pumps have been used for many years in nearly all parts of the United States, but until recently they have not been used in areas that experienced extended periods of subfreezing temperatures. However, in recent years, air-source heat pump technology has advanced so that it now offers a legitimate space heating alternative in colder regions.

For example, when entire units are replaced in the Northeast and Mid-Atlantic regions, the Northeast Energy Efficiency Partnerships (NEEP) found that the annual savings when using an air-source heat pump are around 3,000 kWh (or $459) when compared to electric resistance heaters, and 6,200 kWh (or $948) when compared to oil systems. When displacing oil (i.e., the oil system remains, but operates less frequently), the average annual savings are near 3,000 kWh (or about $300).

Reading this statement gives the impression that this technology is a “no regrets” solution for replacing oil heating CO2 emissions because it saves money for home heating. However, there is a critical caveat for New York State. Air-source heat pumps only work when they move heat and when it is really cold (below zero degrees Fahrenheit) there is no heat in the air to move.

The American Council for an Energy-Efficient Economy published a paper that illustrates this issue with air source heat pumps: Field Assessment of Cold Climate Air Source Heat Pumps (ccASHP) (https://aceee.org/files/proceedings/2016/data/papers/1_700.pdf). The report describes a Center for Energy and Environment field study in Minnesota where cold climate air source heat pumps were directly compared to propane and heating oil furnaces. The report notes that “During periods of very cold temperatures when ccASHPs do not have adequate capacity to meet heating load, a furnace or electric resistant heat can be used as backup.” Figure 2 (ASHP Supplemental Energy Use) from that document graphically shows the problem. In this field study homes were instrumented to measure the heat pump and furnace backup usage. Backup furnace usage was relatively low and the heat pump provided most of the heat until about 20 deg. F. For anything lower, heat pump use went down and the furnace backup went up. Below zero the air source heat pumps did not provide heat and furnace backup provided all the heat.

I believe that there are two problems with the plan to deploy air source heat pumps. I suspect but will not try to evaluate that because a fossil fired furnace or electric resistant heat must be used as backup in a typical New York State winter the cost savings from a more efficient heat pump are offset by the need to maintain a second heating system. The other problem is what might happen to peak electrical loads if electric resistant heat is the preferred backup system. The analyses that I have reviewed point out that converting a natural gas system to an electric heat pump system increases operating costs because natural gas is so low. Propane or fuel oil conversions save money so would be the first to convert because of the higher costs of propane and fuel oil. However, I am not sure that homeowners who convert would want to maintain an oil or propane furnace simply because of the storage system requirement. Consequently, I believe radiant electric heat will be the preferred option for air source heat pump conversions. If residential home heating is electrified significantly electric load will increase and I wonder what could happen to load when the efficient heat pump is replaced with radiant electric heat when the temperatures get really cold.

Procedure

I hypothesize that the combination of widespread air source heat pump deployment and increased reliance on wind and solar renewable energy will create unacceptable reliability issues during peak winter load periods. I evaluated energy usage for one week before and one week after the 2017-2018 peak winter day (January 5, 2018). I had previously analyzed data near Caledonia, NY and will use that for this analysis.

 I used two sources of data. Electric load data for New York State are available from the New York State Independent System Operator and meteorological data are available from the NYS Mesonet meteorological system. The NYS mesonet is a network of 126 weather observing sites across New York State. The official website of the Mesonet includes a tab for live data that brings up station information for the 125 operating individual sites that shows that available data include wind direction and speed, temperature at two levels, relative humidity, precipitation, pressure, solar radiation, snow depth, and camera images. I obtained hourly and 5-minute archived meteorological data for two sites near Caledonia, NY where a 180 MW solar farm has been proposed.

The Winter 2017-2018 load peak occurred during an intense cold snap. From December 29 to January 8 the temperature did not get above freezing and there were four days with below freezing temperatures as shown in the table of Daily temperature and load statistics. Note that the highest load did not occur on the coldest day. This was because the coldest day was a Saturday when business loads are lower. Also note that the New Year’s holiday occurred during this period which also reduced the load. The graph of load, temperature and wind speed for winter peak 2017-2018 shows how hourly load varies with temperature over the 15 day peak period.

In order to estimate how much renewable energy would be available during these conditions I converted to solar insolation and wind speed into power generated in MW using example utility-scale facilities. For solar power I used the 180 MW Horseshoe Solar Farm estimated output because it is near the NYS mesonet stations. In my analysis of Solar Issues in Upstate New York using that facility I assumed that 180 MW of power would be generated when the solar insolation equaled 600 watts per square meter and power output the rest of the time would be proportional so observed solar insolation. I believe that is a conservative assumption but would welcome comment.

There aren’t any wind farms nearby. So I estimated power output for a 100 MW wind farm. I found a reference that stated “Wind turbines start operating at wind speeds of 4 to 5 metres per second and reach maximum power output at around 15 metres/second”. I assumed that below 9 mi/hr wind output was zero and that power output was proportional to the wind speed difference between 9 mi/hr and 33 mi/hr consistent with that reference. The NYS mesonet measures wind at 10m and I assumed that the wind farm hub height was 90m. I modified observe wind speed using the wind profile power law with a coefficient of 1/7 to account for the relationship between wind speed and height.

I used Field Assessment of Cold Climate Air Source Heat Pumps Figure 2 (ASHP Supplemental Energy Use) to estimate the amount of power needed when an individual home convert to an air source heat pump and uses radiant electric heat when the heat pump becomes ineffective (assumed to be 15 deg F). I crudely digitized the lines in Figure 2 and calculated the best fit lines for ASHP Consumption and Furnace Backup Consumption. I converted the energy use to electrical energy by converting Btu to watts by dividing the Btu energy use by 3.41. The Energy Use for Residential Home Heating Electrification Table Table illustrates my concern that residential home heating conversion to air source heat pumps has the unintended consequence that when it gets below 15 deg F and consumers really need to heat their homes that the rate of energy use increases over six times per five degree drop in temperature.

Case Study

The purpose of this analysis is to determine if there are problems if the 100% renewable solar and wind target is coupled with widespread implementation of residential home heating with air source heat pumps. The Housing Units by Space Heating Fuel Table lists the number of occupied housing units for two counties near Caledonia. The Field Assessment of Cold Climate Air Source Heat Pumps report states that liquefied propane (LP gas) and fuel oil or kerosene space heating are the most likely sectors to convert to heat pumps because of fuel cost savings. There are 18,244 housing units that burn those two fuels. I calculated the electricity required for 10%, 15% and 25% conversions for 18,244 housing units.

The figure entitled Residential Home Heating ASHP Conversion and Renewable Power Case Study shows the relationship between home heat electrical load and meteorological conditions affecting renewable wind and solar power. Colder days in Upstate New York often occur on clear, windless nights. When the sun rises the temperature increases quickly. Although cloudless skies maximize solar power the sun is low in the sky and the days are short so the power output is low. Of course the cold weather increases the need for home heating energy.

The Cumulative Renewable Charging and Discharging Margins graph attempts to estimate energy storage requirements. Clearly the only way that solar and wind can be expected to cover winter peak loads is by incorporating energy storage. During this windless case study energy storage needs to discharge to cover the residential home heating power requirement as shown in blue. During the day solar power recharges the energy storage as shown in red. In this case study the maximum storage needed was 372 MW-hr on hour 82. It turns out that renewable excess power charged to the system before this case study was sufficient to cover that requirement.

Conclusion

This case study illustrates my concern that wide-spread implementation of air source heat pumps coupled with increased use of renewables will be difficult. In this analysis the meteorological conditions on New Year’s Eve 2018 show that the proposed Horseshoe solar facility with a nameplate capacity of 180 MW and a wind farm with a nameplate capacity of 100 MW would have been just able to cover the conversion of 2,737 homes to air source heat pumps. However, energy storage capable of at least 372 MW-hr has to be available somewhere. There already are 47,000 homes using electricity and another 15,000 homes that are supposed to be cost-effective candidates for conversion just in two local counties. Most importantly, this is just one component of residential electricity load which is one component of total load.

The Horseshoe Solar Farm – Public Involvement Program claims that the facility will provide enough electricity to meet the average annual consumption of 33,000 or 50,000 households, based on average annual household electric consumption of 10.8 MWh for the U.S. and 7.2 MWh for New York State, respectively. I bet that these household electric consumption averages do not reflect an electrically heated home in cold regions. If I guess that the average consumption for this 15 day period is a decent number for the heating season and assume a 90 day heating season that more than doubles the electric consumption for a New York State household. In other words there is no way Horseshoe Solar Farm is going to provide enough electricity for 50,000 homes using air source heat pumps.

Even though this is a crude “back of the envelope” analysis, the sobering results suggest that the Legislature should do a complete winter peak analysis correctly before codifying reductions that eliminate fossil fueled power plants and require the conversion of residential home heating to meet some arbitrary CO2 reduction goal. According to Patterns and Trends – New York State Energy Profiles: 2002-2016 there are over a million homes currently using fuel oil or kerosene, 500,000 homes using electricity and another 200,000 using propane in New York State.

Based on my analysis I think that even moderate air source heat pump deployment for the residential home heating sector in New York coupled with the simultaneous goal to eliminate greenhouse gas emissions using extensive deployment of wind and solar power is fatally flawed.  I cannot imagine how much wind power, solar power and energy storage would have to be deployed to cover the winter peak, much less the winter peak adding significant electrification of residential home heating, for the entire state because those renewable resources are very weak during winter peak load periods. It is incumbent upon the advocates for the Climate and Community Protection Act to determine what renewable resources will be required and how much they will cost before their legislation is considered by the Legislature.