New York State Reliability Council Draft Scoping Plan Comments

The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050 and the comment period for the Draft Scoping Plan that outlines how to meet that goal recently ended.  Here I describe comments submitted by New York State Reliability Council.  This is another instance in which the experts are not explicitly saying this is nuts but a little bit of reading between the lines indicates that they believe the proposed Climate Act transition will end badly.

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 submitted comments on the Plan and have written extensively on implementation of New York’s response to that 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 tried to quantify the impact of the strategies.  That material was used to write a Draft Scoping Plan that was released for public comment at the end of 2021. The Climate Action Council states that it 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.

New York State Reliability Council

The New York State Reliability Council (NYSRC) is the other organization that has reliability responsibilities in New York.  According to their Draft Scoping Plan comments:

The NYSRC was established to promote and preserve the reliability of the New York State Power System by developing, maintaining and, from time to time, updating the reliability rules (“Reliability Rules”) that govern the NYISO’s operation of the state’s bulk power system. The NYSRC develops Reliability Rules in accordance with standards, criteria and regulations of North American Reliability Corporation (“NERC”), Northeast Power Coordinating Council (“NPCC”), FERC, the Commission, and the Nuclear Regulatory Commission  The NYISO/NYSRC Agreement provides that the NYISO and all entities engaged in transactions on the New York State power system must comply with the Reliability Rules adopted by the NYSRC.  The NYSRC Reliability Rules have been adopted by the New York State’s Public Service Commission under its Public Service Law authority prescribing reliability rules necessary to ensure safe and adequate service.

Installed Reserve Margin

The standard for the required generating capacity relative to the expected load is called the Installed Reserve Margin.  The NYSRC comments on the Draft Scoping Plan defined the standard and talked about the expected changes in what is required now and what is expected in the future:

One of the major responsibilities of the NYSRC is to set the annual Installed Reserve Margin (IRM) for the New York Power System. The IRM is the reserve resource capacity over and above that required to meet peak load and is needed to maintain minimum levels of reliability in New York. This is necessary based on the recognition that the availability of generation resources may be limited by forced outages or loss of fuel supply, including periods with little to no sun or wind. Typical unavailability figures for fossil fueled generation in New York is in the order of ~15% (~85% availability) largely based on forced outage performance.

NYSRC determined that the IRM for the 2022 – 2023 capability year is 19.6% and that IRM was adopted by the New York Public Service Commission for the New York Control Area on March 16, 2022 (Case 07-E-0088).

The table shows the increase in required reserve capacity from 22,577 MW (78.15% IRM) in 2025 to 102,517 MW (205.94% IRM) in 2050. These numbers need to be pondered in perspective. To supply a forecasted peak load of 49,780 MW in 2050, 152,297 MW of capacity will be needed, roughly 3 times the peak load at that time. The corresponding numbers for 2030 are that for a peak load of 29,640 MW, a capacity of 68,244 MW is needed, more than twice as much. Given that the 2020 installed capacity is 44,023 MW, around 22,000 MW of additional capacity must be built in the next 7-8 years.

NYSRC Comments

The NYSRC comments included an illustration of the magnitude of future resource requirements based on the Draft Scoping Plan for Scenario 3, Annex 2.  The following table shows the amount and type of installed capacity required to meet Climate Act goals and meet NYSRC’s resource adequacy reliability criterion of 1-day-in-10-years. The text in red was added to demonstrate the total installed capacity, the peak load, the required reserve capacity and the IRM for the years 2025 through 2050.

The comments describe the ramifications of these results:

The table shows the increase in required reserve capacity from 22,577 MW (78.15% IRM) in 2025 to 102,517 MW (205.94% IRM) in 2050. These numbers need to be pondered in perspective. To supply a forecasted peak load of 49,780 MW in 2050, 152,297 MW of capacity will be needed, roughly 3 times the peak load at that time. The corresponding numbers for 2030 are that for a peak load of 29,640 MW, a capacity of 68,244 MW is needed, more than twice as much. Given that the 2020 installed capacity is 44,023 MW, around 22,000 MW of additional capacity must be built in the next 7-8 years. 

The analysis makes a couple of assumptions:

The table assumes that intermittent generation capacity from wind and solar resources increases from 13,319 MW in 2025 to 96,629 MW in 2050.

The table also assumes that the magnitude of new technology requirements for Zero-Carbon Firm Resource (RNG, green hydrogen or other) increases from 5,489 MW in 2035 to 25,359 MW in 2050. Long-Term Battery Storage or other increases from 1,500 MW in 2025 to 19,212 MW in 2050. None of these technologies presently exist commercially for utility scale application.

It is politically impossible for these experts to explain that not only do these technologies not exist commercially but there are physical limitations that suggest that a commercially viable and affordable resource like this may never be developed.  The reality is that this is not just a stretch, it is a massive leap in technology.

The NYSRC comments go on to explain that there are other implementation factors that complicate the transition that the Draft Scoping Plan cavalierly claims will happen because of political will:

Some of the new renewable resources will be located behind the meter at retail levels (i.e.. solar PV, batteries, and EV charging). This will also require investment in distribution system automation to protect reliability, cyber-security and public safety. The role of the Distribution System Operator will become even more critical in this complex operating environment.

I think that the observation that the logistics of building the infrastructure necessary to meet the Climate Act goals is particularly important:

The amount of new generation that needs to be built to maintain system reliability in a zero-carbon environment is sobering. This change represents an unprecedented increase in capital investment in resource capacity along with a corresponding increase in transmission and distribution capacity. Further, this transition must be managed during a time of high inflation, and supply chain delays, permitting challenges, and high demand for renewable resource equipment, not just in New York, but around the globe.

There is another technical issue.  My comments on the electric system transition pointed out that it is not clear if the Draft Scoping Plan considered ancillary services.  The NYSRC comments explain:

One other aspect that must be kept in mind is that renewables and storage devices work internally with direct current (DC) and must ultimately be interconnected to a grid that works with alternating current (AC). To accomplish this, devices called inverters that transform DC into AC and vice versa are used. These inverter-based resources (IBR) are starting to be used in increasing numbers in the USA and it is becoming clear through actual reliability impact events that more work is still necessary with respect to the reliability of IBRs, and standards need to be adopted for a reliable transition.

I found no mention of this issue in the Draft Scoping Plan spreadsheets of inverter costs.  Finally, it is telling that the NYSRC notes that there will be a learning curve for operating a system based on intermittent and diffuse renewables. 

Furthermore, even if we build all this capacity on time, operating a system largely based on renewable resources is not the same as operating the system of today. The performance and responsiveness of existing generation must be emulated to keep the lights on. We have no experience in operating a bulk power system that we will need to operate by 2030 and beyond.

The fact is that New York’s current stringent reliability rules are based on hard learned experience.  It is incredibly optimistic to think that the system will make the transition without unanticipated issues that result in blackouts.

NYSRC Recommendations

One of the things that I think is most important is a feasibility study.  As a result, I was hearted by the NYSRC recommendation that “the proposed Climate Action Council strategy be reviewed for application in the short-term based upon practical considerations for the period 2025 to 2030”.  The NYSRC comments list the rationale for this review:

Practical considerations affecting the availability, schedule and operability for new interconnections include: interconnection standards; site availability; permitting; resource equipment availability; regulatory approval; large volume of projects in NYISO queue and study process; scalability of long-term battery storage and other technologies; operational control; impact of extreme weather; consideration of a must run reliability need for legacy resources. In addition, the pace of transportation and building electrification, the timing of any natural gas phase-out and their impact on the electric T&D system must also be carefully studied from technical, economic and environmental perspectives. Together, these practical considerations require the development of reliable zero emission resources to be conscientiously sequenced and timed in the near term (through 2030) to ensure broader GHG reductions in all sectors beyond 2030.

It is noted that delaying or changing a CLCPA goal would be preferable to the risk of a wide scale blackout and associated public safety concerns if it should ever appear that the implementation of the CLCPA’s goals may pose a significant risk to electric system reliability, including the potential risk of a system-wide blackout,

In conclusion, there are many unknowns in the transition to CLCPA’s goals. The risks of not reaching a goal in the time required is real. The CAC and all participants in the transition to an emissions free grid need to stay alert to the critical importance of keeping the system functioning within reliability criteria. Each time that an existing unit must retire or stop operating through some regulatory action, there is a need to confirm that reliability criteria will still be met without that unit.

Conclusion

I have written several articles pointing out that the Climate Action Council is not listening to the experts.  The first post (New York Climate Act: Is Anyone Listening to the Experts?) described the NYISO 2021-2030 Comprehensive Reliability Plan (CRP) report (appendices) released late last year.  The difficulties raised in the report are so large that I raised the question whether any leader in New York was listening to this expert opinion.  The second post (New York Climate Act: What the Experts are Saying Now) highlighted results shown in a draft presentation for the 2021-2040 System & Resource Outlook that all but admitted meeting the net-zero goals of the Climate Act are impossible on the mandated schedule.  Finally, I described the “For discussion purposes only” draft of the 2021-2040 System & Resource Outlook report described in the previous article.  This report highlights multiple feasibility concerns that must be addressed to have any hope of this working, shows that implementation on the schedule proposed will be very difficult and highlights the need for implementation planning. 

The NYSRC comments reiterate all the points mad by the NYISO, The organizations responsible for the relatability of the New York electric grid have raised numerous technological issues that must be addressed going forward for the transition.  Unfortunately, the loudest voices on the Climate Action Council have said that anyone saying there are issues related to using renewable resources are misinforming the public and no leaders on the Council have spoken up to reign in those statements.  If Climate Act implementation to net-zero does not address the issues raised then blackouts are inevitable.

The Latest from the Experts on New York’s Climate Act Implementation

This article was first published at Watts Up With That

I have published two previous articles about New York Independent System Operator (NYISO) analyses related to New York’s Climate Leadership and Community Protection Act (Climate Act).  This post describes what I believe is an important new analysis of the future of New York’s electric system.

New York’s Climate Leadership and Community Protection Act (Climate Act) Act establishes a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050.  I have written extensively on implementation of the Climate Act.  Everyone wants to do right by the environment to the extent that efforts will make a positive impact at an affordable level.  My analysis of the Climate Act shows that the ambitions for a zero-emissions economy outstrip available renewable technology such that the transition to an electric system relying on wind and solar will do more harm than good.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

The implementation plan for New York’s Climate Act “Net Zero” target (85% reduction and 15% offset of emissions) by 2050 is underway.  The Climate Action Council has been working to develop plans to implement the Act.  Over the summer of 2021 the New York State Energy Research & Development Authority (NYSERDA) and its consultant Energy + Environmental Economics (E3) prepared an Integration Analysis to “estimate the economy-wide benefits, costs, and GHG emissions reductions associated with pathways that achieve the Climate Act GHG emission limits and carbon neutrality goal”.  Integration Analysis implementation strategies were incorporated into the Draft Scoping Plan when it was released at the end of 2021.  Since the end of the public comment period in early July 2022 the Climate Action Council has been addressing the comments received as part of the development of the Final Scoping Plan that is supposed to provide a guide for the net-zero transition.

Unfortunately, the Climate Action Council has not confronted reliability issues raised by New York agencies responsible for keeping the lights on.  The first post (New York Climate Act: Is Anyone Listening to the Experts?) described the NYISO 2021-2030 Comprehensive Reliability Plan (CRP) report (appendices) released late last year.  The difficulties raised in the report are so large that I raised the question whether any leader in New York was listening to this expert opinion.  The second post (New York Climate Act: What the Experts are Saying Now) highlighted results shown in a draft presentation for the 2021-2040 System & Resource Outlook that all but admitted meeting the net-zero goals of the Climate Act are impossible on the mandated schedule.  This article describes the “For discussion purposes only” draft of the 2021-2040 System & Resource Outlook report described in the previous article.  While there may be minor changes to the document itself, I am comfortable saying that the major findings will not change substantively.

System and Resource Outlook Summary

The Executive Summary makes the point that the Climate Act is driving changes to the generating system, the transmission grid and the demand landscape.  As a result, this “leads to re-thinking how and where electric supply and storage resources evolve, and how to efficiently enable their adoption to achieve energy policy targets”.  The summary goes on to note:

This 2021 – 2040 System & Resource Outlook (the Outlook), conducted by the New York Independent System Operator (NYISO) in collaboration with stakeholders and state agencies, provides a comprehensive overview of potential resource development over the next 20 years in New York and highlights opportunities for transmission investment driven by economics and public policy in New York State. The Outlook together with the NYISO’s 2021-2030 Comprehensive Reliability Plan (CRP) represent the marquee planning reports that provide a full New York power system outlook to stakeholders, developers, and policymakers.

The Outlook examines a wide range of potential future system conditions and enables comparisons between possible pathways to an increasingly greener resource mix. By simulating several different possible future system configurations and forecasting the transmission constraints for each, the NYISO:

  • Projected possible resource mixes that achieve New York’s public policy goals while maintaining grid reliability;
  • Identified regions of New York where renewable or other resources may be unable to generate at their full capability due to transmission constraints;
  • Quantified the extent to which these transmission constraints limit delivery of renewable energy to consumers, and;
  • Identified potential opportunities for transmission investment that may provide economic, policy, and/or operational benefits.

There are many potential paths and combinations of resource and transmission builds to achieving New York’s climate change requirements. As the current power system continues to evolve, evaluating a multitude of expansion scenarios will facilitate identification of common and unique challenges to achieving the electric system mandates New York State has set for 2030 and 2040. A thorough understanding of these challenges will help build a path for investors and policymakers to achieve a greener and reliable future grid efficiently and cost effectively. Through this Outlook several key findings were brought to light:

Four potential futures are evaluated to best understand the challenges ahead. A Baseline Case evaluates a future with little change from today. A Contract Case includes approximately 9,500 MW of renewable capacity procured by the state and evaluates the impact of those projects. Finally, a Policy Case postulates and examines two separate future scenarios that meet New York policy mandates.

Energy planning analyses such as this work normally evaluate different scenarios of the future by comparing them to a business-as-usual scenario.  In this instance the business-as-usual scenario does not include any of New York’s climate initiatives.  On the other hand, Climate Act Draft Scoping Plan analyses were perverted to “prove” the desired conclusion that the benefits were greater than the costs by comparing future scenarios against a reference scenario.  The Integration Analysis used a semantic trick to claim that some de-carbonization costs (such as de-carbonizing transportation costs) necessary to meet Climate Act targets did not have to be included in the comparison scenario because the electric vehicle conversion legislation was already “implemented”.  That approach took legitimate implementation costs out of the projections.  Of course, this also makes comparison of the NYISO work relative to the Draft Scoping Plan problematic.

The second estimate of the future in the Resource Outlook considered only those projects currently under contract:

Through an annual request for proposals, NYSERDA solicits bids from eligible new large-scale renewable resources and procures Renewable Energy Certificates (RECs) and Offshore Renewable Energy Certificates (ORECs) from these facilities. This Outlook included approximately 9,500 MW of new contracted renewable resources, including 4,262 MW of solar, 899 MW of land-based wind, and 4,316 MW of offshore wind. The addition of these resources to the existing system representation provides insights regarding their impact on system performance in the future.

The Outlook report noted the following Key Takeaways for the contracted renewables scenario:

The pace of renewable project development is unprecedented and requires an increase in the pace of transmission development. Every incremental advancement towards policy achievement matters on the path to a greener and reliable grid in the future, not just at the critical deadline years such as 2030 and 2040. In general, resource and transmission expansion take many years from development to deployment.

Coordination of project additions and retirements is essential to maintaining reliability and achieving policy. Coordination of renewable energy additions, commercialization and development of dispatchable technologies, fossil fuel plant operation, and staged fossil fuel plant deactivations over the next 18 years will be essential to facilitate an orderly transition of the grid.

Many more renewable resources have to be developed to meet the overall Climate Act net-zero goal by 2050 and the interim 2040 goal of “zero-emissions” electricity generation.  The NYISO analysis looked at two Policy Case scenarios that meet those targets:

Scenario 1 utilizes industry data and NYISO load forecasts, representing a future with high demand (57,144 MW winter peak and 208,679 GWh energy demand in 2040) and assumes less restrictions in renewable generation buildout options.

Scenario 2 utilizes various assumptions consistent with the Climate Action Council Integration Analysis and represents a future with a moderate peak but a higher overall energy demand (42,301 MW winter peak and 235,731 GWh energy demand in 2040).

Both scenarios project a blend of land-based wind, offshore wind, utility-scale solar, behind-the-meter solar, and energy storage will be needed to meet the CLCPA policy mandates through 2035. There are significant differences between these scenarios and the equivalent Draft Scoping Plan mitigation scenarios.  One of the big differences is the magnitude of a new generating resource called “dispatchable emission-free resources” (DEFRs):

These resources represent a proxy technology that will meet the flexibility and emissions-free energy needs of the future system but are not yet mature technologies that are commercially available (some examples include hydrogen, renewable natural gas, and small modular nuclear reactors). As more wind, solar, and storage plants are added to the grid, dispatchable emission-free resources must be added to the system to meet the minimum statewide and locational resource requirements for serving system demand when intermittent generation is unavailable.

The report warns:

Both scenarios include significant DEFR capacity by 2035, but it is important to note that the lead time necessary for development, permitting, and construction of DEFR power plants will require action much sooner if this timeline is to be achieved.

As part of the analysis the NYISO considered what would be needed if the DEFR capacity is not developed. They found that “The exclusion of DEFRs as a new technology option, while enforcing the retirement of fossil generators via the zero-emission by 2040 policy, exhausts the amount of land-based wind built and results in the replacement of 45 GW of DEFR capacity in Scenario 1 with 30 GW of offshore wind and 40 GW of energy storage.”  They also noted that the alternative did not address ancillary service requirements needed for the transmission system.

The Outlook report noted the following Key Takeaways for the Policy Case Scenarios:

Significant new resource development will be required to achieve CLCPA energy targets. The total installed generation capacity to meet policy objectives within New York is projected to range between 111 GW and 124 GW by 2040. At least 95 GW of this capacity will consist of new generation projects and/or modifications to existing plants. Even with these additions, New York still may not be sufficient to fully meet CLCPA compliance criteria and maintain the reliable electricity supply on which New York consumers rely. The sheer scale of resources needed to satisfy system reliability and policy requirements within the next 20 years is unprecedented.

To achieve an emission-free grid, dispatchable emission-free resources (DEFRs) must be developed and deployed throughout New York. DEFRs that provide sustained on-demand power and system stability will be essential to meeting policy objectives while maintaining a reliable electric grid. While essential to the grid of the future, such DEFR technologies are not commercially viable today. DEFRs will require committed public and private investment in research and development efforts to identify the most efficient and cost-effective technologies with a view towards the development and eventual adoption of commercially viable resources. The development and construction lead times necessary for these technologies may extend beyond policy target dates.

As the energy policies in neighboring regions evolve, New York’s imports and exports of energy could vary significantly due to the resulting changes in neighboring grids. New York is fortunate to have strong interconnections with neighboring regions and has enjoyed reliability and economic benefits from such connections. The availability of energy for interchange is predicted to shift fundamentally as policy achievement progresses. Balancing the need to serve demand reliably while achieving New York’s emission-free target will require continuous monitoring and collaboration with our neighboring states.

The important findings in the report led to the following recommendations:

Future uncertainty is the only thing certain about the electric power industry. From policy advancements to new dispatchable emissions-free resource technology innovation and ultimate development, the system is set to change at a rapid pace. Situational awareness of system changes and continuous assessment are critical to ensure a reliable and lower-emissions grid for New York. The Economic Planning databases and models will be continually updated with new information and the Outlook study will be improved and performed on a biennial basis.

To meet the minimum capacity requirement in 2040, at least 95 GW of new emission-free resources, including approximately 9.5 GW of new renewable resources, will be required to come on-line. Furthermore, to fully achieve the emission-free grid target by 2040, even more resources will likely be needed along with transmission to deliver the clean power to consumers. The scope of the additional renewable resource need is both substantial and unprecedented. Compared to the 2.6 GW capacity entering service in the past five years while New York experienced a net loss of approximately 2.2 GW, the installation rate in the next 20 years must increase significantly to achieve state law climate change requirements. State agencies should consider releasing a more detailed procurement schedule for renewable resources to guide the long-term system planning and provide clarity to the market.

Discussion

I noted earlier that I was comfortable saying that the major findings in this draft report will not change substantively when it is finalized.  I base that mostly on the fact that the NYISO Market Marketing Unit has reviewed the draft.  As part of their market monitoring responsibilities Potomac Electricreviewed the document relative to implications to New York’s de-regulated electric markets.  If you are interested in that particular aspect of electric system planning, I suggest checking out the memo.  For the rest of us, I only note that they state: “The 2021 Outlook is a major improvement to NYISO’s previous planning studies and provides important insights on the potential impacts of state policies on the NYISO system.”

More importantly, what about the Climate Action Council?  Unfortunately, as I pointed out before the Climate Action Council has not confronted reliability issues raised by New York agencies responsible for keeping the lights on.  In a series of meetings over the next couple of months the Council will have to address the Draft Scoping Plan comments made by the NYISO and the New York State Reliability Council that raised reliability concerns.  I hope. without any supporting evidence, that the Integration Analysis team is working with the NYISO planning staff to reconcile the differences between this analysis and theirs.

In the meantime, there are vocal members of the Climate Action Council that deny the existence of any implementation issues associated with a renewable energy resource dependent electric system.  At the May 26, 2022 Climate Action Council meeting Council members described their impressions of comments made at the public hearings.  I have prepared an overview summary of all the comments made during the Update on Public Hearings and Comments agenda item and wrote an article highlighting relevant comments.  In this regard, Paul Shepson Dean, School of Marine and Atmospheric Sciences at Stony Brook University talked about mis-representation at 23:39 of the recording:

Mis-representation I see as on-going.  One of you mentioned the word reliability.  I think the word reliability is very intentionally presented as a way of expressing the improper idea that renewable energy will not be reliable.  I don’t accept that will be the case.  In fact, it cannot be the case for the CLCPA that installation of renewable energy, the conversion to renewable energy, will be unreliable.  It cannot be.

Robert Howarth, Professor, Ecology and Environmental Biology at Cornell (starting at 32:52 of the recording) picked up on that theme.  He said that fear and confusion is based on mis-information but we have information to counter that and help ease the fears.  He stated that he thought reliability is one of those issues: “Clearly one can run a 100% renewable grid with reliability”.   Obviously, these views are at odds with this report.

There is one other point.  In addition to the reliability concerns of the net-zero transition I am very concerned about affordability.  The Draft Scoping Plan has avoided any mention of ratepayer impacts to date.  The NYISO projection methodology has that information because it is inherent in the models. It is a shame that it is not being reported.

Conclusion

This is an important report for New York but I also believe that there are ramifications for other net zero transition programs.  These findings must be reconciled with the Draft Scoping Plan projections for the future generating system.  The leadership of the Climate Action has repeatedly punted the responsibility for a feasibility study down the road as somebody else’s problem. This report highlights multiple feasibility concerns that must be addressed to have any hope of this working.  I believe that it shows that implementation on the schedule proposed will prove impossible.  The report also highlights the need for implementation planning.  Currently there is no plan for siting renewable resources where they are needed for the future system and this shows that it must be done.

With respect to other net-zero transition programs I think the discussion and implications of the dispatchable emissions-free resource are of interest.  The analysis shows that in order to minimize the storage and renewable over-build requirements this resource could be a better choice.   However, the report notes that DEFRs such as hydrogen, renewable natural gas, and small modular nuclear reactors are not commercially viable today. “DEFRs will require committed public and private investment in research and development efforts to identify the most efficient and cost-effective technologies with a view towards the development and eventual adoption of commercially viable resources.”  There is that nasty planning and feasibility is necessary component again.

NYISO Offshore Wind Profile Development

The implementation plan for New York’s Climate Leadership and Community Protection Act (Climate Act) “Net Zero” target (85% reduction and 15% offset of emissions) by 2050 is underway.  I think the biggest problem confronting any net-zero transition effort is matching variable wind and solar generation with load at all times.  This post describes an effort by the New York Independent System Operator (NYISO) to address that problem for offshore wind resources.  It is a great start but needs to be expanded for other sources of renewable generation and for as long a period as possible.

I have written extensively on implementation of the Climate Act.  Everyone wants to do right by the environment to the extent that efforts will make a positive impact at an affordable cost.  Based on my analysis of the Climate Act I don’t think that will be the case as proposed.  I believe that the ambitions for a zero-emissions economy outstrip available renewable technology such that the transition to an electric system relying on wind and solar will do more harm than good.  I am a retired meteorologist who started working for Niagara Mohawk in 1981 and have continued to work in the New York electric generating industry continuously since then.  Over that time, I have been involved in many energy planning activities that included meteorological components. The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Climate Act Background

The Climate Act established the Climate Action Council who 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 meet the goals.  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 analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021 and will be finalized in 2022. 

Renewable Resource Adequacy

I called the renewable resource adequacy problem the ultimate problem for the Climate Act as early as September 2020.  On August 2, 2021, the New York State Energy Research and Development Authority (NYSERDA) held a Reliability Planning Speaker Session to describe New York’s reliability issues to the advisory panels and Climate Action Council.  All the speakers but one made the point that today’s renewable energy technology will not be adequate to maintain current reliability standards and that a “yet to be developed technology” will be needed.  A recent article by David Wojick at PA Pundits International titled Unreliability Makes Solar Power Impossibly Expensive does a great job describing how renewable resource availability affects reliability.  I adapted his work to New York to analyze the impact on the Draft Scoping Plan.

There are serious problems when extreme weather affects the grid.  The Federal Energy Regulatory Commission (FERC) and the North American Electric Reliability Corporation (NERC) report on the February 2021 cold weather outages in Texas and the South Central United States described the event, the impacts and made recommendations.  According to the report this event was the fourth cold-weather event in the last ten years to affect bulk electric system reliability.  Cold weather caused problems that required rolling blackouts to avoid system instability and even worse problems for the electric grid.  Given that the weather conditions that caused these problems occurred recently I am taken aback that resources were not devoted to preventing re-occurrence.  Among the many recommendations two are relevant: “improving near-term load forecasts for extreme weather conditions” and additional study of “potential effects of low-frequency events on generators in the Western and Eastern Interconnections”.

In order to address this renewable resource variability problem, it is necessary to determine the worst-case meteorological conditions affecting wind and solar availability.   As long as the NYISO and other agencies responsible for electric system reliability understand the worst-case renewable availability conditions they can plan to prevent low availability impacts.  I submitted comments on the Draft Scoping Plan’s treatment of wind and solar resource availability and concluded that it was inadequate in this regard. I recommended that the State undertake a more comprehensive analysis of wind and solar availability to serve as input for future reliability planning.  I have also been trying to get the NYISO and New York State Reliability Council to consider the recommendations I made for a comprehensive availability analysis.  So far, I have not had any success getting a response.

Offshore Wind Power Profile Study

Despite my personal lack of success I was encouraged that the NYISO started a project in July to address offshore wind profile development.  In particular, they plan to develop wind power estimates for the New York offshore wind development areas that will estimate resource availability for a 20-year period.  I am going to highlight some of the slides in the presentation by DNV describing their work for the NYISO ICAP/MIWG/PRLWG Meeting on September 07, 2022.  Note that all the slides are copyrighted to either NYISO or DNV and are labeled as draft for discussion purposes only.  I am including a couple of slides to show what should be done on a more comprehensive basis for the Final Scoping Plan.

In my opinion, the critical consideration is the frequency, duration, and severity of periods when wind and solar resources are in “droughts” or low resource availability.  I described several recent applicable papers in my comments describing analyses to estimate the frequency and duration of periods with those conditions.  In order to provide a robust estimate of the wind and solar availability during worst case conditions I believe it is necessary to analyze as long a time period of historical meteorological data as possible. Fortunately, meteorological reanalysis descriptive data generated by modern weather forecast models but using observed data from decades ago is available for this application. This is exactly what DNV is proposing to do.

The DNV project description slide explains that they will use the historical data to generate detailed wind maps using a weather forecast model.  This output is combined with their model that projects wind energy output as a function of wind speed.  They are going to model wind energy production for seven potential development areas off Long Island and New Jersey.

The weather model slide describes their approach.  They are going to use a forecast model that takes historical data and calculates wind speed and direction on an hourly basis.  The inputs for their modeling include not only the observed meteorological data but also surface characteristics and surface temperatures.  Note that the model inputs extend far beyond the offshore wind study area.

The presentation also includes slides on wind power modeling, wind turbine power curve output, and describes their validation analyses.  They also described four different aspects that cause reductions in power output in their analysis.  At some point I should compare their assumptions with those used in the Draft Scoping Plan.  In order to minimize wake effects DNV is proposing 1 nautical mile spacing which seems higher than I have noticed elsewhere.

Discussion

I think that this analysis is a great start.  I only have one concern relative to the scope of work.  As far as I could tell the meteorological input data is available back to 1980.  However, this project only goes back to 2000.  I think it would be better to evaluate the 1980 to 2000 data specifically looking for wind droughts.  I know there was a huge ozone episode in August 1988 that had to include very light winds.  I have no idea how that period compares to “normal” but we won’t know because this analysis does not cover that period. 

This analysis is entirely appropriate for the offshore wind resource.  However, it does not address the onshore wind and solar resources.  The same type of analysis has to be done for those resources covering not only the entire state but also the area where New York could expect to import power.   Ideally, the ERA5 global reanalysis data base that goes back to 1950 should be used in the analysis to find the worst-case conditions.  It is not necessary to determine the renewable power output over the entire period and region.  Once the worst cases are identified then a power output model can be applied to those periods to determine how the electric system can be setup to avoid bulk electric supply disruptions. 

It is my professional opinion that until this comprehensive renewable energy resource evaluation is completed that New York State will unnecessarily risk catastrophic blackouts.  Because the worst-case resource availability is associated with the coldest or hottest periods, the loads are highest and the need to prevent blackouts most acute.

Working with New York Farmers to Ensure Climate Resiliency for the Future

There is a consistent disconnect between reality and the State’s consideration of climate change incorporated in the Climate Leadership and Community Protection Act (Climate Act).  Nowhere is this more obvious than in the op-ed by NYS Department of Environmental Conservation Commissioner Basil Seggos and NYS Department of Agriculture and Markets Commissioner Richard Ball published in the Auburn Citizen on August 30.

New York’s Climate Leadership and Community Protection Act (Climate Act) Act establishes a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050.  I have written extensively on implementation of the Climate Act.  Everyone wants to do right by the environment to the extent that efforts will make a positive impact at an affordable level.  My analysis of the Climate Act shows that the ambitions for a zero-emissions economy outstrip available renewable technology such that the transition to an electric system relying on wind and solar will do more harm than good.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

New York Permitting Requirements

New York’s Article Ten process defines the permitting requirements for all large-scale electric generating new construction or expansion.  It includes extensive and time-consuming public notification and public participation requirements.  The 2011 revisions to the Article Ten law were intended to speed things up but were largely ineffective in that regard.  In early April 2020, NYS passed the Accelerated Renewable Energy Growth and Community Benefit Act (AREGCBA) as part of the 2020-21 state budget.  The legislation was intended to ensure that renewable generation is sited in a timely and cost-effective manner.   Unfortunately, the result has been an unchecked land rush of solar development in the state with no limitations on the conversion of prime farmlands to utility-scale solar development. 

Discussion

The primary purpose of the op-ed was to congratulate Greenfield Farms in Skaneateles, NY for being “the recipient of this year’s prestigious New York Leopold Conservation Award for its extraordinary environmental protection efforts, uses healthy soil practices that enhance water quality and strengthen carbon sequestration”.  That is a great achievement and I believe it should be a keystone component of the state’s efforts for a resilient agricultural economy.

The op-ed also describes New York State’s innovative Climate Resilient Farming Program.  This program “assists farmers who proactively tackle climate concerns by providing cost-shared grants to incentivize transformative management practices that reduce greenhouse gas emissions, draw down carbon dioxide from the atmosphere, and increase carbon storage in soils and woody plants.”  Those are laudable efforts, are necessary for Climate Act implementation, and I support them. 

However, the op-ed goes off the rails when it continues: “At the same time, it helps protect at-risk agricultural land across the State.”  I have written multiple articles about solar siting with respect to agriculture in New York.  Based on that work I believe that the biggest risk to agricultural land in New York State is the lack of a responsible solar siting framework for the massive utility-scale solar projects needed to meet the Climate Act targets.  There is a policy option roadmap for the proposed 10 GW of distributed solar development.  However, there is not an equivalent set of policies for utility-scale solar development.  

On July 25, 2022 a press release from Governor Hochul announced siting approval of New York’s largest solar facility to date.  The release said that the “New York State Office of Renewable Energy Siting has issued a siting permit to Hecate Energy Cider Solar LLC, to develop, design, construct, operate, maintain, and decommission a 500-megawatt solar facility in the Towns of Oakfield and Elba, Genesee County.“  In the press release Commissioner Basil Seggos was quoted as saying:

DEC applauds Governor Hochul’s ongoing prioritization of renewable energy development to support our state’s necessary transition away from fossil fuels. As more solar projects continue to be approved and come online, we are closer to achieving the goals and requirements set in the Climate Leadership and Community Protection Act. This will continue to provide renewable energy benefits here in Genesee County and throughout the state.

In my article on this approval, I noted that according to the exhibit titled “Farmland Classification Mapping” that lists landcover class data.:

According to NLCD data, the dominant landcover class in the Project Site is active agriculture, followed by forestland. Agricultural lands in the Project Site are comprised of active agricultural land (both row crops and mowed/maintained hayfields) and there are numerous family and commercial farms and farm structures in the Project Site. Row crops comprise approximately 68% (3,143 acres) of the Project Site, and less than 1% (23 acres) of the total Project Site is maintained hayfields. Additionally, there is approximately 3.5% (161 acres) of the Project Site where the dominant land cover is grasslands or pasturelands.

Relative to agricultural soils, the Project Site includes approximately 41% (1,912 acres) of land classified as Prime Farmland, 27% (1,252 acres) as Prime Farmland if Drained, 19% (891 acres) as Farmland of Statewide Importance, and 13% (596 acres) as Not Prime Farmland (Natural Cooperative Soil Survey 2020).

The prime farmland and prime farmland if drained categories total 2,143 acres well in excess of 1,400-acre Greenfield Farms.

I believe best practices for solar development should meet the Department of Agriculture and Markets target for prime farmland conversion.  In particular, “The Department’s goal is for projects to limit the conversion of agricultural areas within the Project Areas, to no more than 10% of soils classified by the Department’s NYS Agricultural Land Classification mineral soil groups 1-4, generally Prime Farmland soils, which represent the State’s most productive farmland.”   Four recently approved solar projects totaling 920 MW all exceeded that threshold and converted 3,456 acres of the state’s prime farmland to industrial use.  Overall, those projects converted 28% of the prime farmland in the Project Areas.  In addition, none of these projects propose practicing responsible solar siting consistent with the state’s distributed solar development roadmap.  For example, there are no provisions for agricultural practices consistent with the solar panels.

Conclusion

The current projections for utility-scale solar development call for over 43,000 MW in order to meet the requirements for zero-emissions power.  At the current rate of converted prime farmland to capacity development upwards of 161,000 acres of prime farmland could be lost.  Until such time that the state adopts responsible solar siting guidelines for utility-scale development consistent with existing policies for distributed solar, the impacts of solar development will have bigger impacts on agriculture than those purported to occur because of climate change.

Obviously, Commissioner Seggos recent press releases are hypocritical.  Regarding the massive solar project, he states that “Solar farms of this scope produce enough energy to power thousands of homes while also creating well-paying, family-sustaining jobs and breathing new life into our local economies.”  His op-ed states that the Climate Resilient Farming Program “helps protect at-risk agricultural land across the State”.  The fact is that unbridled utility-scale solar development is the major risk to agricultural land in the State and no amount of protection from any virtue signaling state agricultural program is going to stop that.

Updates to Pragmatic Environmentalist Pages

I am going to start summarizing updates I make to the pages I maintain at  Pragmatic Environmentalist of New York and Reforming the Energy Vision Inconvenient Truths.  I have an extensive list of reference materials on my original blog that I occasionally update when I run across an article that is particularly interesting and relevant and this blog also has reference material.  This article describes some recent page updates.

I started blogging in late 2017 on New York’s energy policies because I was convinced that they are going to end as an expensive boondoggle driving electricity prices in particular and energy prices in general significantly higher. Reforming the Energy Vision (REV) was the previous comprehensive energy strategy for New York. I wrote about the inconvenient unpublicized or missing pieces of New York State’s REV policy: implementation plan, costs and impacts. At some point I should probably combine that blog with this one but in the meantime, I will maintain them both.  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.

Updates

I linked two articles to the renewable energy feasibility page.  This very good overview of all the problems associated with green energy was described at the Australian Stop These Things website.  Author Andrew Roman points out six issues ignored by New York State energy policy:

All energy sources have some adverse effects on the environment, including wind and solar:

  • extensive use of scarce minerals supply, largely controlled by China;
  • massive concrete bases and steel towers of wind generators require extensive use of coal in manufacturing;
  • low energy density requires huge amounts of land (some 25 per cent of the US land area if all electricity was to be generated by solar panels);
  • wind turbines kill birds and bats;
  • both solar panels and wind turbines create huge amounts of un-recyclable waste
  • China dominates solar panel and wind turbine manufacturing by burning a lot of coal.

The article goes on to document these issues.

The second renewable feasibility article by Francis Menton made the point that the easiest Net-Zero goal is to eliminate emissions in the electric generation sector.  However, he points out that not only has no jurisdiction successfully made the transition but also argues that it will be never be achieved.  He notes that wind and solar development is entirely dependent upon government subsidies.  All other energy transitions have been based on organic consumer demand not on government mandates.  His article describes the current situation in Europe where net=zero energy transition policies have created a situation where they don’t have dispatchable, emissions-free generating resources available for extended periods of low wind and solar resource availability causing affordability and reliability issues.  He concludes:

So, if you have a chance to make a bet, you’ll be extremely safe betting against Net Zero generation of electricity any time during your life. Nuclear is the only way it could potentially be done, and that’s blocked by regulatory obstruction more or less everywhere.

Chris Denton from New York’s Southern Tier wrote a great article describing a reasonable development policy for industrial solar that I linked to my solar issues page.  He points out that it is reasonable to have a policy framework in place before we “advance the production of electric energy by means of industrial free-standing solar collectors”.  He argues that developing industrial solar facilities diverts land from an existing use (e.g., habitat or agriculture) it follows that “how much and where we divert the sun’s rays ought be very carefully measured and studied before allowing any further industrial development of solar electric generation.”  He points out that there are plenty of locations that do not impact agriculture and sequestration so those should a priority.  He concludes:

The damage caused by our refusal to recognize these impacts can destroy our environment as effectively as any other unexamined industrial or commercial project. It is that very blindness to incremental, unplanned action that has led to the very global warming which we are now trying to unwind.  We should not make the same mistake in the cure as we did in acquiring the disease. We need to take care that in our zeal to protect our environment from unrestricted global warming, we don’t destroy the very plants, animals, land, water, and scenic values which we are trying to protect.

I added a link to this article on offshore wind turbine spacing to the wind issues page.  As turbines become bigger their wakes become bigger and that leads to a reduction of output at any existing turbine that is too close.  “An important new working paper from renewables consultants ArcVera is reporting that the wake effects behind the huge turbinesthat are now coming onstream are going to be much worse than previously thought.”

Other Articles of Interest

There were a couple of other articles that were interesting but inappropriate for my pages. 

Science and religion belong to separate domains. Science is empirical, falsifiable and logical, where later scientists “stand on the shoulders” of the earlier. It constitutes the finest achievement of Western civilization. The Tenth Climate Commandment’s prohibition against debate leads to the death of science, when science is replaced by an ideology that justifies its authority by its order not to question.  This is the same claim which religions have made through the ages. As the Roman poet Horace warns: “vestigia terrent”- the footprints are frightening

    Question for the Climate Action Council

    The implementation plan for New York’s Climate Leadership and Community Protection Act (Climate Act) “Net Zero” target (85% reduction and 15% offset of emissions) by 2050 is being developed.  Here is a question for the Climate Action Council.  How do you expect to avoid the affordability and reliability issues evident in Europe occurring as their net-zero policies are implemented?

    I have written extensively on implementation of the Climate Act and submitted extensive comments on the Draft Scoping Plan.  Everyone wants to do right by the environment to the extent that efforts will make a positive impact at an affordable cost.  Based on my analysis of the Climate Act I don’t think that will be the case.  I believe that the ambitions for a zero-emissions economy outstrip available renewable technology such that the transition to an electric system relying on wind and solar will do more harm than good.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

    Climate Act Background

    The Climate Act established the Climate Action Council who 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 meet the goals.  Those strategies were used to develop the Integration Analysis prepared by New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies.  That analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021 and will be finalized in 2022.  The Climate Action Council has set up three subgroups to consider alternative fuels, economy-wide strategies to fund the transition, and gas system transition.  While I do not deny that these are worthwhile topics, I am disappointed that reliability, feasibility, and affordability are not being explicitly considered.  This is of particular concern given the energy affordability and reliability crises underway in Europe.

    Great Britain Affordability

    Net Zero Watch publishes a newsletter that describes climate and decarbonization policies, what they cost, whether they are delivering and what their real impact is on the environment.  Based in Great Britain they are following the affordability impacts of current net-zero energy policy.  The latest reports from their newsletter are disturbing.

    The Office of Gas and Electricity Markets (OFGEM), supporting the Gas and Electricity Markets Authority, is the government regulator for the electricity and downstream natural gas markets in Great Britain.  The energy price cap is a backstop protection from the government for people who default onto their supplier’s basic energy tariff. Ofgem calculates the cap level that suppliers must apply to these tariffs. 

    According to the Independent, August 27, 2022, the “United Kingdom faces ‘catastrophe’ after energy bills soar 80% amid warning price cap could hit £7,000”.  The article notes that:

    Regulator Ofgem has revealed that the price cap, which is supposed to protect consumers from unfair energy bill increases, will rise to £3,549 per year for an average household – more than three times last winter’s level. That is expected to leave some 8.9 million households in fuel poverty, charity bosses have said, with a “real risk” that children will go hungry as Britain’s poorest see almost half of their income taken up by gas and electricity.

    There also were articles describing the impacts beyond the obvious energy poverty ratepayer effects.  The energy caps apply only to consumers but not, for example, health care providers.  It has been reported that:

    The chief executive of Care England said providers faced a staggering 683 per cent increase in energy costs during the past 12 months, with bills expected to rise again early next year. For gas and electricity, the costs were £660 per bed, per year, this time last year; this week, care providers have to pay an astonishing £5,166.

    The Daily Telegraph writes that this is not just a problem for low-income people.  In an interview with the Telegraph, Nadhim Zahawi said that “support cannot be confined to families on benefits and added that gas prices could remain punishingly high for two years.”  He went on to say: “If you are a senior nurse or a senior teacher on £45,000 a year, you’re having your energy bills go up by 80 per cent and will probably rise even higher in the new year – it’s really hard”.

    An editorial in the Wall Street Journal brings home the impacts of these high prices.  It notes that the latest price increases bring the average household’s annual bill to £3,549 and that the median household income is £31,400.  That means that for half of the households if their average annual budget for central heating, cooking, and keeping the lights on is equal to the average that the percentage of income spent on energy is over 11%.  New York has an energy poverty target of only 6% so if the adverse affordability effects of New York net-zero implementation are anyway similar then we can expect a major increase in the number of households in energy poverty.

    German Reliability

    Writing at No Tricks Zone, P. Gosselin translates an article from Die kalte Sonne.  He explains that Germany’s massive, subsidized expansion of electricity generation from renewable sources has squeezed conventional generation units out of the market. Two experts warn of growing grid instability.

    Quo Vadis, Grid Stability?

    The conclusion of the two is very alarming. Here, too, not a word about “storage facilities galore. Here, reality clashes with the wishful thinking of some green energy protagonists who think there is enough storage and that all that needs to be done is to change the “mindset,” as Patrick Graichen put it.

    The continued expansion of highly volatile renewable energy sources and the further displacement of more conventional generation units from the market are making the power grid increasingly sensitive to weather-related fluctuations. Unusual weather phenomena such as dark doldrums pose significant challenges to the security and stability of supply to the power grid. The largely intermittent output of solar and wind farms does not correlate with fluctuations in electricity demand.

    The excess supply of renewable energy should be buffered during periods of low electricity demand, and the stored capacity should be injected back into the grid during periods of high electricity demand when fewer renewable sources are available. However, large battery energy storage systems, which have been promisingly announced, are still not on the horizon due to their low capacity and maturity, as well as their exorbitantly high cost of deployment.”

    At this point, at the latest, some people’s ears should be ringing:

    As long as economic energy storage systems are not established, even proponents of the current direction of Germany’s energy transition will have to admit that reliable conventional power plants will be needed for a long time to come.”

    This article is also an urgent reading recommendation for politicians and experts who like to be interviewed.

    The authors also conclude:

    The importance of nuclear power plants for security of supply in base-load operation and their and their ability to operate the grid in parallel with renewable renewable energies have been demonstrated. The nuclear power plants appear to be well suited for the energy made to achieve the future goal of carbon-free power generation. However, the Atomic Energy Act foresees an early end to nuclear power generation by the end of 2022.”

    So without nuclear power in Germany, grid stability problems are a future certainty.

    Conclusion

    At the August 23, 2022 Climate Action Council meeting some of the comments were discussed.  Among the 35,000 comments submitted were around 900 with attachments including “some still being reviewed and summarized”.  There was no mention of a couple of points I raised in comments about specific Climate Act mandates including one for the Climate Action Council  to consider results from other jurisdictions and another for the New York Public Service Law  § 66-p. “Establishment of a renewable energy program” safety valve conditions for affordability and reliability.  In order to address both mandates the Climate Action Council should respond to the question: How do you expect to avoid the affordability and reliability issues evident in Europe occurring as their net-zero policies are implemented?

    I don’t think there is any way to avoid the issues seen in Europe.  So, I have to wonder whether the Climate Action Council is willfully or naively ignoring the energy crisis as it unfolds.  In any case failure to account for the issues will ensure that New York goes over the same cliff.

    Initial Forecast Verification for August 23, 2022 Climate Action Council Meeting

    The implementation plan for New York’s Climate Leadership and Community Protection Act (Climate Act) “Net Zero” target (85% reduction and 15% offset of emissions) by 2050 is underway.  Prior to the August 23 the Climate Action Council meeting I posted a prediction for the “Public Comments Summary and Proposed Process for Integration” agenda topic.  This post is a forecast verification based on the meeting presentation slides.  I will update this more when the video for the meeting is posted.

    I have written extensively on implementation of the Climate Act and submitted extensive comments on the Draft Scoping Plan.  Everyone wants to do right by the environment to the extent that efforts will make a positive impact at an affordable cost.  Based on my analysis of the Climate Act I don’t think that will be the case.  I believe that the ambitions for a zero-emissions economy outstrip available renewable technology such that the transition to an electric system relying on wind and solar will do more harm than good.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

    Climate Act Background

    The Climate Act established the Climate Action Council who 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 meet the goals.  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 analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021 and will be finalized in 2022.  The Climate Action Council has set up three subgroups to consider alternative fuels, economy-wide strategies to fund the transition, and gas system transition.  While I do not deny that these are worthwhile topics, I am disappointed that reliability, feasibility, and affordability are not being explicitly considered.

    Climate Action Council Meeting August 23, 2022

    The agenda and meeting information are available in the 2022 Climate Action Council Meetings section of the Climate Act Materials and Meetings website.  In the previous post, I predicted that the agenda item discussing public comments would make the number of posts a point of emphasis, will undoubtedly count the comments in favor and make a big deal that the majority of the comments support the Draft Scoping Plan approach.  The number of posts was a point of emphasis in the following slide but the slides did not provide a scorecard of comments in favor relative to the comments opposed.  So I was only half right.

    The slides summarized the feedback received.  There were cost impact concerns as shown in the following.  It will be interesting to see if the Council responds to the issues raised or just decides that they need to do more advertising to convince people that these issues are not real.

    Capacity, reliability, and security of the electric grid issues were raised.  I have often written about those issues so will be very interested to see how the council handles them,

    The presentation also described comments made about “Jobs and the New York economy”, “Alternative fuels”, “Scoping Plan goals, timeline and process”, “Renewable energy technologies”, “Climate justice and equity”, “Perceived ban on wood burning”, “Economy-wide strategies”, and Sector-specific feedback”.  Frankly, the commenters who supported the Draft Scoping Plan descriptions of these topics are naïve in my opinion and just parroted the talking points of special interest groups.  Many valid concerns were raised on these topics.

    While the descriptions are mostly unbiased, I also got the impression that comments contrary to the narrative were not taken seriously and will be dismissed.  This is most evident in the following slide with the description climate change denial.  Denial in this context is a pejorative term equating anyone who does not accept the climate change science narrative of the Climate Act and Draft Scoping Plan as the same as those that do not accept the Holocaust.  Drawing a similarity to a scientific theory with the documented horrors of the holocaust is an insult and inappropriate in the presentation.  Also consider that one of the descriptions highlights the argument that some said New York’s climate goals would be insignificant if other jurisdictions do not take similar actions.  My concern is what happens to this point now?  Will the Final Scoping Plan provide a calculation showing the impact of New York’s climate goals relative to other jurisdictions or will the response just be blown off?

    The remaining descriptions of the comments addressed the 28,500 email campaign categories.  Forty five organizations developed a form letter and had their members submit a form letter using their template.  All of these letters represent special interest of one form or other.  The campaigns were separated into nine categories: gas transition, climate & environmental justice, multi-topic, green hydrogen, agriculture & forestry, wood burning, nuclear energy, waste incineration, and legislation.  I will break down the numbers below but if you wonder what the special interest campaigners were exercised about then I refer you to these summaries.

    The slides did list the approximate number of commenters in each of the campaigns. I have summarized the interesting totals below.  For example consider the 13,300 gas transition comments that expressed support about doing something about climate change but basically said they were not willing to give up natural gas.  There was an email campaign (~ 500 submissions) in the multi-topic category that similarly expressed support for climate change action but said that it “Must strike the right balance between protecting our planet and safeguarding our economy”.  I think that could be taken to mean that they are not willing to take hits to the economy they think are inherent in the Climate Act.  There was similar support with conditional concerns with the agriculture and forestry commenters.  Amazingly to me, if all those comments can be categorized as we don’t support the current content of the Draft Scoping Plan, then half the comments were against.  I fully expected that a clear majority of comments would support the Draft Scoping Plan transition plan for the Climate Act so predicted that would be highlighted.  That was not the clearcut case and could be the reason that no scorecard was presented.

    It is notable that no email campaign addressed the electric vehicle mandate.  It is not surprising because all the car companies have signed on to do electric vehicles and the government support for electric vehicle purchases means they can raise prices commiserate with those subsidies.  I am convinced however, that most people Upstate have no intention of switching to an electric car as their primary mode of transportation and were simply unaware of the opportunity to comment.  I imagine if there was some organization that asked people to submit a comment against the requirement to lose the ability to purchase an internal combustion engine by 2035 that the submittals against that component would be overwhelming.

    When I described my predictions, I outlined what I thought should be done if the Council really wants to integrate public comments and predicted that it would not be included.  I said the comments have to be provided in a searchable database for the Council and public as soon as possible.  The comments have to be categorized into specific topics for the Council with a summary of the issues raised with an emphasis on substantive issues.  The proposed process for integrating the comments slide makes no mention of a database.  The staff will summarize themes which is equivalent to categorizing the comments.  The slide says that staff will continue developing actionable recommendations which I guess relates to my substantive issues.  However, the slide presentation to the Council did not highlight issues that must be addressed.  Maybe that occurred during the discussion but that review will have to wait until the video recording is available and I have to review it.

    One final point about the presentation.  The initial slide mentioned that 900 comments included attachments and that some of those are still being reviewed and summarized.  The only way to provide substantive comments is by using attachments.  There was no mention of comments submitted by the New York Independent System Operator (NYISO) or New York State Reliability Council.  The staff summary of those comments should be highlighted to the Council members and the fact that no slide highlighted their comments suggests to me that haven’t been reviewed yet.

    At some point I should discuss the section of the presentation that described continuing Integration Analysis work.  It is a problem for me that this work has been going on apparently absent comment input.  I think the NYISO comments would be directly relevant to the Integration Analysis work but there was no suggestion of that.  The presentation claimed that benefits out-weighed the costs but I submitted comments that directly contradicted that.  I described the games played to be able to conclude that “The cost of inaction exceeds the cost of action “.   The reality is that the benefits are imaginary but the costs are real and the Integration Analysis that provides the basis of the Draft Scoping Plan consistently over-states benefits and under-estimates the costs.  Shouldn’t the Council know that there were comments on that specific topic or will my comments be ignored because there was only one comment that said that?

    Conclusion

    There is no indication that any comment that is not consistent with the Draft Scoping Plan narrative will be incorporated into the Final Scoping Plan.  Given the schedule and the approach outlined at the meeting, I doubt that the Council will ever hear about those comments, much less discuss why they should be ignored.

    The Climate Action Council has to make a case that a net-zero electric system will work and to date they have totally ignored that analysis.  Francis Menton recently summarized the issues with such a transition and concluded that it will never work.  I have little faith that the current administration is going to address the issues he raises.  I only hope that the folks who are foisting this travesty on the state will be in some way held accountable when the plan fails.

    Prediction for August 23, 2022 Climate Action Council Meeting

    I am on the road and don’t have the ambition to develop a long post so this will be a short one.  The implementation plan for New York’s Climate Leadership and Community Protection Act (Climate Act) “Net Zero” target (85% reduction and 15% offset of emissions) by 2050 is underway.  On August 23 the Climate Action Council meeting agenda includes an item for “Public Comments Summary and Proposed Process for Integration”.  This post provides my prediction for that item.

    I have written extensively on implementation of the Climate Act.  Everyone wants to do right by the environment to the extent that efforts will make a positive impact at an affordable cost.  Based on my analysis of the Climate Act I don’t think that will be the case.  I believe that the ambitions for a zero-emissions economy outstrip available renewable technology such that the transition to an electric system relying on wind and solar will do more harm than good.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

    Climate Act Background

    The Climate Act established the Climate Action Council who 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 meet the goals.  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 analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021 and will be finalized in 2022.  The Climate Action Council has set up three subgroups to consider alternative fuels, economy-wide strategies to fund the transition, and gas system transition.  While I do not deny that these are worthwhile topics, I am disappointed that reliability, feasibility, and affordability are not being explicitly considered.

    Climate Action Council Meeting August 23, 2022

    The agenda and meeting information are available in the 2022 Climate Action Council Meetings section of the Climate Act Materials and Meetings website.  At some point a recording for the meeting will be posted on the site.  I will eventually do a post to see if my forecast for what I think will happen verifies.

    The agenda for the meeting includes the following items:

    • Welcome
    • Consideration of July 11, 2022, Minutes
    • Subgroup Progress Reports
    • Integration Analysis Updates
    • Public Comments Summary and Proposed Process for Integration
    • Proposed Process for CJWG Feedback Integration
    • Proposed Process for Disadvantaged Communities Barriers & Opportunities Report Integration
    • Next Steps

    Most of these discussions will be perfunctory.  The subgroup progress reports will give vague updates of the work to date.  The primary issue with these topics is that there is no way to reconcile different opinions so I doubt that they will add value to the process.  It is intriguing that work on the Integration Analysis has been going on.  It will be interesting to see what topics were addressed. 

    Given that I submitted 27 comments totaling 356 pages I am particularly interested in the process for handling Draft Scoping Plan comments.  In previous meetings Agency staff has talked about the volume of comments.  I predict that the summary agenda item will make that a point of emphasis, will undoubtedly count the comments in favor and make a big deal that the majority of the comments support the Draft Scoping Plan approach.  Of course, this ignores the fact that most people in the state are unaware of any of the details of the plan and did not submit comments.

    If the Council really wants to integrate public comments, then the process should include the following.  The comments have to be provided in a searchable database for the Council and public as soon as possible.  The comments have to be categorized into specific topics for the Council with a summary of the issues raised.  It is unreasonable to expect that the Council and the public should have to figure out the substantive issues on their own. Instead I predict that the comments will be available in a list, perhaps consolidated somewhat for the obvious form letters.  It might be searchable but that will be the extent of the accessibility concession.

    I have become so cynical of the process that I believe the last two environmental justice topics will just be treated as window dressing.  Any overlap with Administration priorities this election year will be highlighted and any inconsistencies will be ignored.

    Conclusion

    If the State really was planning to integrate public comments, then the process would have been on-going.  As issues were raised in the comments those that were impactful should have been passed on to the Council.  With only a couple of months left before the Final Scoping Plan has to be drafted there simply is not time to understand all the comments much less for meaningful integration of them.

    I hope I am wrong but I am not holding my breath that the plan for integrating comments will actually address substantive comments.  I expect that my comments will be acknowledged but I doubt that they will be considered.

    Climate Act Avoided Cost of Gas Working Group

    There is an immense amount of work that needs to be done to implement New York’s Climate Leadership and Community Protection Act (Climate Act) “Net Zero” target (85% reduction and 15% offset of emissions) by 2050.  It is very difficult to grasp all the different ways that this transition is going to affect all New Yorkers.  Despite the lack of a reliability and affordability feasibility analysis an army of government bureaucrats are developing transition plans to change our energy choices assuming that everything will work out.  This article talks about just one of those efforts.

    I have written extensively on implementation of the Climate Act.  Everyone wants to do right by the environment to the extent that efforts will make a positive impact at an affordable dollar cost.  Based on my analysis of the Climate Act I don’t think that will be the case.  I believe that the ambitions for a zero-emissions economy outstrip available renewable technology such that the transition to an electric system relying on wind and solar will do more harm than good.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

    Climate Act Background

    The Climate Act established the Climate Action Council who 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 meet the goals.  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 analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021 and will be finalized in 2022.  At the same time this process is underway various state agencies are already implementing regulations for the transition.  The problem is that the Scoping Plan is just a guide and does not include a reliability feasibility analysis or any affordability specifics about the costs for the transition.  Couple that with the fact that many New Yorkers are unaware of the Climate Act much less its implications suggest to me that this that public blowback will be immense when the realization of what is required becomes obvious.

    Gas Planning Procedures

    In order to explain what is going on I will provide background information for this example.  The New York State Department of Public Service (DPS) Case 20-G-0131 – Proceeding on Motion of the Commission in Regard to Gas Planning Procedures “seeks to establish planning and operational practices that best support customer needs and emissions objectives while minimizing infrastructure investments and ensuring the continuation of reliable, safe, and adequate service to existing customers.”  The Background for the order instituting the proceeding follows with my explanations:

    Gas utilities in several regions of New York State have recently claimed supply constraints that may prevent them from accepting applications for new firm service. LDCs have invoked moratoria on new service connections in some locations, leading in some cases to customer hardships. In resolving the moratorium invoked by KEDNY and KEDLI, the Commission-adopted settlement requires those LDCs to develop a “Long-Term Capacity Report” to address the long-term capacity constraints affecting their operations.

    This refers to gas utility load distribution company (LDC) issues.  A footnote to this section explains that:

    On January 17, 2019, Consolidated Edison Company of New York, Inc. (Con Edison) notified the Commission of a moratorium on new firm gas service in most of Westchester county, commencing March 15, 2019. Beginning November 2018, The Brooklyn Union Gas Company d/b/a National Grid NY (KEDNY), serving Brooklyn and parts of Queens, and KeySpan Gas East Corporation d/b/a National Grid (KEDLI) (collectively, National Grid) began informing large applicants for new service that National Grid would be unable to provide firm service unless a pending supply project was approved. As of May 15, 2019, National Grid stated that it would not fulfill applications for new firm service connections, or requests for additional firm load from existing customers on Long Island, including Queens and Brooklyn. Based on a settlement adopted and approved by the Commission, National Grid ended its moratorium as of November 26, 2019. Case 19-G-0678, Proceeding on Motion of the Commission to investigate Denials of Service by National Grid, Order Adopting and Approving Settlement (issued November 26, 2019); Case 19-G-0678, supra, Confirming Order (issued December 12, 2019). Additionally, New York State Electric and Gas Corporation (NYSEG) has declared a moratorium on new gas customer attachments in the Town of Lansing, in Tompkins County in February 2015.

    In other words, there have been examples where people who want to hook up to natural gas have not been allowed to get service.  This is the crux of the gas transition problem.  The net-zero transition to natural gas alternatives means that at some point the choice to use natural gas will no longer be an option.  The Background goes on:

    These circumstances demonstrate that conventional gas planning and operational practices adopted by natural gas utilities have not kept pace with recent developments and demands on energy systems.  Gas utilities need to learn from recent experience and adopt improved planning and operational practices that enable them to meet current customer needs and expectations in a transparent and equitable way while minimizing infrastructure investments and maintaining safe and reliable service. Additionally, planning must be conducted in a manner consistent with the recently enacted Climate Leadership and Community Protection Act (CLCPA).

    Implicit in this is that customer choice will have to be limited.  I do not believe that many New Yorkers understand that this transition is coming at them.  The Background notes:

    Moratoria can create adverse customer impacts, as they prevent at least some applicants from receiving firm gas service. Some types of development projects can utilize viable alternatives to firm gas service, if they are practically available. Others, however, may have more difficulty without firm gas service. Additionally, reliance on alternatives can have emission impacts. Reduced emissions impacts may result where the alternative to gas is efficient use of clean electricity, while increased emission impacts may result where the alternative to gas is oil or propane.

    If viable alternatives were available, and by that, I mean affordable above all, then applicants would be choosing them willingly.  I published a post describing the comments on the Draft Scoping Plan submitted by a small manufacturer in Rochester who replacing equipment that is powered by natural gas now would cost over a million dollars and said that his company could not afford that conversion.  I will quote one last paragraph from the Background:

    Given these potential impacts, the public interest demands that gas utilities provide information to and communicate with customers in a way that promotes effective customer planning, reduces confusion, and avoids inequities or the appearance of inequities. Similarly, the public interest demands that gas utilities provide information to and communicate with the Department, with other government entities and agencies, and with stakeholders, so as to promote effective planning and best consideration of alternatives, thus benefiting costs, emissions, and economic development.

    What this means is that the DPS and gas utilities in the state are grappling with a tradeoff between providing safe and reliable natural gas to existing and new customers at the same time the Climate Act net-zero transition calls for the natural gas system to be shut down or transitioned to use something other than natural gas.  A presentation at a recent meeting of the Avoided Cost of Gas Working Group offers some insight into the practical considerations that Albany bureaucrats are starting to deal with and are completely unknown to most natural gas consumers despite the public interest in this topic.

    Avoided Cost Working Group First Meeting

    On July 6, 2022 the Avoided Cost Working Group (ACWG) met for the first time.  The presentation described the purpose of the group in the following slide.  The Benefit Cost Analysis Framework Order required Department of Public Service staff to develop a white paper on benefit cost analysis.  That process did not address gas industry issues.  This workgroup is supposed to provide the Commission with a report describing recommended calculations and specific elements for each LDC, which will then be issued for comment from stakeholders.

    The BCA white paper included the following list of benefit and costs components to be included in the framework.  The workgroup will be adjusting the calculations for the gas industry but there are no plans for changes to the list.

    The first meeting discussed the plan to address four main topics.  They want to determine the avoided bulk system costs for the gas commodity, the costs necessary to meet peak loads and pipeline capacity costs.  Another topic is avoided distribution costs for the high, medium, and low-pressure components of the pipeline system.  There has been much discussion about the use of renewable natural gas and they want to determine what qualifies for that label.  The final topic is the subject of leaks in the system.  As monitoring technology has improved more leaks have been found and this has been a point of contention on the Climate Action Council.

    Avoided Cost Working Group Second Meeting

    The second meeting of the ACWG on August 4 included two presentations.  The first presentation from the DPS staff discussed the typical non-pipelines alternatives process.  This is another of the Climate Act magical solutions where an existing fossil-fuel service can supposedly be replaced by an alternative that will not affect reliability or affordability.  National Grid provides a summary of the approach:

    Non-Pipeline Alternatives (NPA) is the inclusive term for any targeted investment or activity that is intended to defer, reduce, or remove the need to construct or upgrade components of a natural gas system, or “pipeline investment.”

    These NPA investments are required to be cost-effective compared to the infrastructure investment and are required to meet the specified gas system need.  An NPA can include any action, strategy, program, or technology that meets this definition and these requirements.

    Some technologies and methodologies that can be applicable as an NPA investment include demand-side measures, such as demand response, sewer heat recovery, advanced controls strategies, new business models, energy efficiency or electrification. Additional technologies may be feasible as a demand-side NPA. NPA projects can include these and other investments individually or in combination that meets the specified need. A benefit-cost analysis (BCA) will be used to determine the cost-effectiveness of the NPA project.

    In my opinion there are a lot of assumptions and biases that can skew the NPA study to prove whatever the utility wants and, in order to survive and make their earnings targets, that will be what the PSC wants.  The Administration’s response to public input leans to whatever constituency the Administration wants to please rather than what is best for the majority or the strength of adverse comments.

    The DPS presentation outlined the process for a NPA study, reviewed the list of benefit and costs components and presented a list applicable to the natural gas system.  I don’t think there is anything particularly controversial or, frankly, of interest to the general public.

    The second presentation by staff from New York State Energy Research & Development (NYSERDA) and their consultant Energy + Environmental Economics (E3)  described the work done to date in the Integration Analysis and Draft Scoping Plan.  They gave an overview of the Avoided Cost of Gas (ACG) framework developed by E3 for NYSERDA and DPS in 2020,  provided insights into other “Future of Gas” projects E3 has contributed to since 2020 , and presented key similarities and differences with the ACG framework.

    The following slide is an overview of the approach.  E3 has set up a model that quantifies avoided costs that will be used to eventually justify the transition of New York’s natural gas system to net-zero consistent with the Climate Act.  At this time the framework has only focused on business-as-usual and has not been used to examine the impacts of the Climate Act.  It quantifies the following avoided costs:

    • Upstream supply costs
    • Leakage rates and other losses
    • “Peak gas” value
    • Local avoided infrastructure costs
    • Avoided GHGs (methane and CO2)

    The presentation describes the ACG framework approach.  The following slide explains what the avoided costs results tell us.  The costs include installation, program and fuel costs.  The benefits include avoided utility costs and the alleged benefits of avoided greenhouse gas emissions.  Noticeably absent, in my opinion, is consideration of added costs to customers.  For example, the aforementioned small manufacturer in Rochester uses natural gas because it is the best alternative for his processes.  Any alternative is going to add costs not included.  In my case, I value natural gas because it is extremely reliable.  In the 41 years I have lived in my home there never has been a natural gas outage.  There were two long duration electric blackouts including one due to an ice storm that we survived because I can provide electricity to my furnace and keep the house warm.  This approach ignores these impacts and benefits.

    The presentation goes on to discuss cost shift analyses in the next slide that will “help understand longer term ratepayer impacts”.  At this point transition complications start to become evident.  If the utility avoided costs lead to bill savings, then no cost shift occurs.  The slide explains that if customer bill savings are higher than avoided utility costs, a cost shift is likely to occur.  In that case the first adopters make out by saving money but the ‘remaining’ ratepayers have to cover more system costs and will see their costs rise.  It may be that avoided utility costs could be higher than customer bill savings so an “inverse cost shift” is likely to occur where ‘remaining’ ratepayers see bill decreases.  However, the slide concludes that “With more customers switching to electrification, there is risk of significant cost shift” because “embedded costs will need to be collected from a smaller customer base”.

    The next slide explains what the consultants want you to know about the avoided cost results.  The avoided costs outputs show the monetized utility costs plus the carbon costs.  They claim that significant non-monetized utility value may result from NPA projects but the examples shown are pretty weak in my opinion.   They also claim that additional environmental value may also result, beyond what is captured by the social cost of carbon metric all the while ignoring that those costs are buried in the New York version of the social cost of carbon metric.  Finally, they note that the avoided cost framework does not consider potential cost avoidance related to embedded system costs of existing infrastructure.

    Of particular interest is the example given.  After a long description of the values of the BCA approach for non-pipeline alternatives the thumb on the scale is evident.  Even though the example NPA found a negative benefit cost ratio the utility went ahead and did it anyway!  The BCA approach includes many value judgements despite its quantitative output.  At the end of the day the State and the utility made more value judgements to justify going ahead to implement an alternative to adding natural gas infrastructure.  The cited the following reasons.  They claim that it will increase local reliability but that does not consider the fact that the natural gas system is much more reliable than the electric system.  Going ahead may be consistent with Climate Act goals but that criterion suggests that all this is window dressing.  The third rationale is that it “Supports Joint Proposal goal of no net increase in gas utilization”.  I believe this is a specific component in the utility’s rate case settlement.  If true it is incontrovertible proof that New York utilities are forced to meet specific Administration goals to get rate case approval.  The final rationale is that it “supports local environmental advocacy”.  This is blatant acknowledgement that political appeasement of a preferred political constituency is a consideration in development considerations and that any pretense that the methodology that is supposed to be used is just a sham.

    The next slide describes the inter-relationships of cost shift impacts.  I want to emphasize the two final points on the slide.  There is a possibility that a “’feedback loop” may develop that could drive gas costs higher.  In my opinion that kind of feedback is to be expected.  It is telling that they admit that customer impacts may be inequitable without a transition strategy and that it will disproportionally affect those unable to switch away from gas (renters and low-income customers).  So much for the environmental justice advocacy component of the Climate Act.

    The presentation goes on to argue that a structured transition could help to mitigate these impacts.  E3 presented results of an analysis for a similar transition program in Massachusetts.  I am not going to discuss these results in this post.  The bottom line is that they believe that the better approach going forward is to target customer transitions rather than just transitioning natural gas customer use as their appliances age out. 

    The following slide discusses the factors that affect the feasibility of the transition conversion away from natural gas.  I think this is important particularly because this kind of discussion is not included in the Draft Scoping Plan.  First there is a concession that the transition to “targeted electrification or networked geothermal hinges on several factors”.  Because the natural gas system is inter-connected there are limitations on which segments that can be removed “without adversely affecting the safety, reliability or other operational parameters of the system”.  Not surprisingly the consultant analysis keeps the customer satisfied by claiming that cost savings are achievable.  However, the slide mentions two caveats relative to customer choice.  If voluntary conversions are proposed “all consumers served by part of the gas system would need to accede to losing gas service”. The caveat is that the scale of the project drives the likelihood that there will be holdouts: “It may be possible to find 5 customers who are all willing to switch, 500 is likely a different matter.” The other alternative is to force customers to switch.  In that case: “Barring widespread shifts in consumer preferences, the nature of LDCs’ obligation to serve existing customers may need to change, with implications for customer choice.”  The second main point is that this feasibility analysis notes that there will likely be additional costs of decommissioning not captured in the analysis.

    The slide also includes a highlighted section that asks the question “What do you need to “believe” in order for gas system conversions or cost avoidance to be achieved?”  In order for this this to be feasible then the conditions described above have to be met.  The other aspect is that “High levels of upfront planning and high levels of constructability & workforce availability” are needed.  A study from Palo Alto Utilities also notes there will likely be workforce issues related to decommissioning work.  That is a career with a built-in end date so training people for a short career might be a problem.  Given that all of these conditions have to be met to achieve the goal I am skeptical that it will be successful.

    Finally, the presentation described an alternative approach to the avoided cost framework.  The Climate Act transition is a mandated large-scale customer transition described in a “Future of Gas” framework.  The avoided cost of gas framework appears to me to be better suited for smaller scale transition components.  Like it or not New York is stuck with a larger scale transition.  The alternate framework evaluates long-term revenue requirement implications for such a transition, considers geographical constraints, considers long-term implications of large-scale customer transitions and can evaluate long-term cost shifts in the absence of regulatory measures.  The presentation concludes that ca ombination of these two approaches may be useful.

    Discussion

    I have always maintained that a fundamental flaw in the Draft Scoping Plan is that it is just a guide and does not include a reliability feasibility analysis or any affordability estimate of the costs for the transition.  The point of this article is that the extraordinary effort necessary for New York State to transition to net-zero is underway without that information.  Despite the recognized need that providing public information is appropriate, there are many activities going on that are necessary for the transition but are proceeding without significant public oversight.  In the first place there are so many components to the transition that no individual or outside organization can follow them all.  Notice and documentation of the activities are buried in the DPS DMM: Matter Master that is not user-friendly even to professionals who follow these actions.  Even if someone manages to find out about an activity and tracks down the description of the activity, trying to decipher what is in the jargon-filled reports is a challenge.  They may be able to claim that there is publicly available information but reality is different.

    This article described the transition activities of one aspect of the net-zero transition.  In order to meet the net-zero transition targets major changes to the natural gas distribution system are needed.  The Avoided Cost Working Group is trying to force fit the natural gas transition analysis into the same framework as was used for the electric system benefit cost analysis.  The NYSERDA consultants have suggested that it may be necessary to also include another approach and it remains to be seen whether that will be considered.  I get the impression the emphasis is on getting it done rather than taking the time to get it right.

    Most importantly, it is clear that there are feasibility issues to the natural gas net-zero transition.  The Scoping Plan is only intended to provide a framework for the transition but what if that framework isn’t feasible?  With regards to the natural gas transition, the Draft Scoping Plan insinuated that the transition would occur as the appliances aged out.  In other words, at some date owners would not be able to replace their broken appliances with a natural gas-fired option.  However, it appears that the ACWG is considering options to transition certain segments of the network and is grappling with how to deal with the practical issues associated with that approach.  I doubt very much that this will be the only situation where the Scoping Plan implied implementation approach does not past muster as a viable methodology.

    I am also troubled by the overt manipulation of the analytical techniques to make them consistent with the Climate Act narrative.  The framework analysis depends on a model that is large, includes many value judgements, and has so many variables that it can provide any answer that the Climate Action Council wants.  For example, I believe that the modeling approach ignores the benefits of natural gas options and does not include the costs to replace it with other less reliable and affordable options which makes the transition conversion more beneficial than it actually will be.  This bias is also evident in the application of the benefit cost analysis methodology.   An example is given where the NPA calculation did not project that the benefits would out-weigh the costs.  Nonetheless the utility went ahead and chose that option anyway.  At some point the public has to ask what is the point of all this if you modify the rules to get the answer you want anyway.

    Conclusion

    The background for the DPS order for this effort states that “public interest demands that gas utilities provide information to and communicate with customers in a way that promotes effective customer planning, reduces confusion, and avoids inequities or the appearance of inequities”.  There is no way that is happening at this time and all indications that it will not occur until it is too late for meaningful public input and the possibility of changing anything significant.

    The Administration is controlling the implementation approach for the Climate Act’s net-zero transition.  A fundamental assumption in the Climate Act is that this transition is only a matter of political will and there are people involved in this process that actually believe that is the case.  This approach over-simplifies the problem and the solution.  The lack of a detailed reliability and affordability feasibility analysis kicks the problem down the road.  State agencies are rushing ahead to implement plans and regulations for the transition without taking into account this risk.  Moreover, the analyses and processes for the implementation are biased and even if the results suggest that implementation now is premature, decisions are being made consistent with the narrative and not reality.  I cannot believe that this won’t end badly.

    Follow Up to RFF Inflation Reduction Act Retail Electric Rate Cost Analysis

    This is a follow up to my article published at Watts Up With That Resources for the Future: Retail Electricity Rates Under the Inflation Reduction Act of 2022  and re-published here.  The article addressed the  Resources for the Future (RFF) Issues Brief titled Retail Electricity Rates Under the Inflation Reduction Act of 2022 claim that the legislation, will “save typical American households up to $220 per year over the next decade and substantially reduce electricity price volatility.”  I got a comment here that raised two flaws in my arguments.  I used data from the United States Energy Information Administration (EIA) Electricity Data Browser for Texas to test the hypothesis that increased renewable energy resources would lower electricity costs.  This article addresses the flaws raised.

    The comment that exposed my flawed argument was provided by Dr. Michael Giberson, associate professor of practice in the Area of Energy, Economics, and Law with the Rawls College of Business at Texas Tech University.  He commented that:

    When I follow your directions for your chart using the EIA data you describe, I get a very different picture. Avg residential power prices in Texas peak in mid 2008, then fall for several years before coming up more recently. Your chart is showing something other than what you describe.

    Further, inflation adjusted power prices have been falling over the 2001-2022 period. Using CPI data with January 2022 = 100, average real price in early 2001 was about 12.5 cents then jumped up to 18.5 cents in mid 2008 before falling back to about 12.5 cents in 2022.

    I hypothesized that if I used the United States Energy Information Administration (EIA) Electricity Data Browser  tool I could find data that showed that prices would go up in states where renewable energy development has increased the fraction of renewable energy generated and I used Texas an example.   I downloaded the monthly total net generation (GWh) and the net generation from just renewable resources so I could calculate the percentage of renewable generation energy.  Then I downloaded the average monthly residential average price of electricity. 

    I went back and reviewed my work and have to apologize to everyone because I mistakenly used the wrong monthly residential cost data.  Dr. Giberson used the correct data as shown below.  The Texas data do not illustrate any relationship between the percentage of monthly renewable energy generated per month (left axis) and the monthly residential electric price (right axis).  What it does show is that the observed variability of the monthly prices is large in Texas. 

    Importantly, this result invalidates my hypothesis that these two parameters could be used to show that when the Texas electric system added more renewable energy the costs went up.  Obviously, these data do not confirm that hypothesis.  Upon further review in order to pick out a trend in the cost data I should have adjusted for inflation as Dr. Giberson suggested.  The variation in the data before the renewable energy production kicked in also suggests that picking out a trend is more complicated than I thought it would be. 

    An alternative hypothesis is that this is an issue with just the Texas data so I did the same thing with California data.  The results shown below are significantly different than Texas.  There is less cost variability and the increase after 2005 is not as pronounced.   It does appear that costs go up and renewable penetration goes up but I did not adjust for inflation to test that theory.

    The axes in the Texas and California charts are different so inter-comparison is difficult.  When combined the results are messy but there are a couple of interesting things.  Texas residential electric costs are significantly lower (89% in 2021) and the spread has increased over time.  However, during the years 2005 to 2009 the Texas energy costs were less than 20% lower apparently because something happened to the Texas market in that time.  Dr. Giberson notes that the inflation adjusted real price in early 2001 was about 12.5 cents then jumped up to 18.5 cents in mid-2008 before falling back to about 12.5 cents in 2022. The other interesting point is that as the percentage of renewable generation increases the spread between the monthly values increases which I think reflects seasonal variations in resource availability.

    I also extracted data for the United States as a whole. Note that US residential electric costs increased at the same time Texas rates increased after 2005.  The same volatility increase as additional renewable power is added is apparent.  It is notable that historically there has been a clear annual cycle of costs peaking in the summer and troughing out in the winter.  With regards to the RFF cost projection, I don’t think there is much evidence that increasing renewable penetration has increased cost but the annual cycle appears to be becoming less pronounced.  Of course, trying to analyze a trend when there was a pandemic is likely to end up with massive uncertainty.

    As noted, there is one aspect that is consistent for all the renewable penetration data.  As the percentage of renewable energy production increases the volatility of the monthly production increases.  Wind resources are generally higher when there is a greater contrast in air masses in the spring and fall.  Obviously solar resources are lower in the winter when days are shorter.  I believe that there is an important outcome of that finding.  The RFF brief claims that adding more renewable resources will “substantially reduce electricity price volatility”.  I believe that the argument is that the price of fossil fuels is subject to many extraneous factors that affect price but those factors are smaller for renewable resources.  I think these data suggest that the inherent variability in a weather-dependent source of power generation could increase electric price volatility as the system becomes more dependent upon those resources. 

    The following figure lists cost data for Texas. California, and the country as a whole.  What interests me are the outliers.  For example, in March 2014 the monthly residential price of electricity in California was 15.86 cents.  It dropped to 10.12 cents in April then rebounded to 16.46 cents in May.  Subsequent outliers are all either in October or April for the next five years.  This might represent increased wind availability but it is not clear why it is not as pronounced before or after this period if that is the case.

    More important are the high outliers.  In California, the monthly price was 15.17 cents in June 2005, jumped to 16.65 cents in July, and then dropped to 14.89 cents in August.  In Texas, the monthly price was 11.4 cents in January 2021, jumped to 12.74 cents in February, and then went down to 11.5 cents in March.  The Texas blackout was the cause for the energy price spike in February 2021 but I don’t know of any specific problem in California in July 2005.  I suspect that these events will become more common as renewable penetration increases but the data do not show that yet.

    Conclusion

    Obviously, I need to double check my data analyses before publishing.  I found that using the correct data leads to an analysis that is consistent with every other aspect of the net-zero transition that I have looked at.  Everything is more complicated than it appears at first glance and any conclusions drawn are more uncertain.  Any claims about conclusive evidence should be regarded cynically.

    The RFF Retail Electricity Rates Under the Inflation Reduction Act of 2022 issues brief claims that the legislation, will “save typical American households up to $220 per year over the next decade and substantially reduce electricity price volatility.”  My original conclusion was that the Texas cost and renewable generation data showed that it was unlikely that there would be cost savings due to increased renewable energy but I used incorrect data.  Using the correct data, I could argue that the Texas results did not show a decrease which is contrary to the RFF projection, but it is also reasonable to argue that were it not for the renewable generation that costs would have increased more than they did.  At first glance and without adjusting for inflation, California data suggested that increased penetration of renewable resources increases costs but there are clear uncertainties that make this a tenuous conclusion.

    Despite the problems with my analysis, I remain convinced that the RFF projection is unlikely. The models used for this kind of analysis do not do future changes to the electric system well. For example in the comments on my original post, Rud Istvan explained why wind renewables cannot reduce electricity prices.  He showed that EIA LCOE estimates do not accurately project future costs for renewable energy development because they don’t include the costs to make the energy generated available when and where it is needed.  Francis Menton recently made a persuasive argument that all projections for future electric systems overbuild the wind and solar resources resulting in higher costs.  Worse, you still need a backup dispatchable resource and someone also has to provide ancillary services to maintain the grid’s ability to move power around.  I believe that the modeling down by RFF and others does not adequately take those factors into account and if it did it would not show reduced costs.

    One final point about the data.  There is a real trend in the renewable energy generation data that needs to be watched in the future.  All the data show that as the percentage of renewable energy production increases the volatility of the monthly production increases.  The RFF brief claims that adding more renewable resources will “substantially reduce electricity price volatility”.   While there is no apparent impact in retail costs due to this observed volatility in these data, I suspect that will change in the future.