New York Siting Board Garnet Solar Project Application Decision

Last year I was contacted by one of the organizers of Conquest Against Industrial Solar and since then I have been following the Article 10 application of the Garnet Energy Center.  On October 27,2022 the New York State Board on Electric Generation Siting and the Environment (Siting Board) “granted approval to Garnet Energy Center, LLC to build and operate a 200-megawatt (MW) solar farm in the Town of Conquest, Cayuga County, with 20 MWs of battery storage capacity, one of the largest approved to date”.  While I am terribly disappointed with the approval from the standpoint of the local impacts to most of the residents of Conquest there are larger ramifications.  I describe two problems with this approval: the impact on local agriculture across the state and the failure of the Hochul Administration to protect local agricultural communities.

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 but actions like this 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.

Solar Siting Issues

I have written enough articles on solar siting issues that I have setup a page that summarizes them all.  I became aware of the particular issues of utility-scale solar development on agriculture after I had a couple of people contact my blog describing issues that they had and suggested that I look into the issue.  The problems that they raised are real, the solutions are available, but in the rush to develop as many renewable resources as quickly as possible the State of New York has dropped the ball on responsible utility-scale solar development.  Given the massive amount of projected utility-scale solar generation capacity required to meet Climate Act goals the rush to develop solar projects could easily lead to the permanent loss of significant amounts of prime farmland that will hurt farming communities and endanger Climate Act strategies to sequester carbon in soil. 

Solar developers are quick to point out that a landowner gets revenue when a solar project is developed.  However, when land is taken out of production it will reduce farm jobs and the economic activity may be improved during construction but once the facility is operational there are very few economic benefits to essential local businesses.  Furthermore, taking the land out of production may make other farmers who have been renting that land to make their operations viable will not be able

to support investments made in facilities, livestock, or equipment.  

Press Release Announcement

The press release announcing the siting decision describes the project:

The project will consist of commercial-scale solar arrays, access roads, buried electric collection lines, a collection substation, and electrical interconnection facilities. Additional facilities would include a 345-kV switchyard which will be transferred to New York Power Authority to own, maintain, and operate. The project will be located on land leased from owners of private property. The project will include a 20 MW energy storage system which will charge exclusively off the solar array.

The press release goes on to say:

The project area is about 2,289 vacant acres, and the project footprint is about 900 acres. The solar farm is expected to begin commercial operation in 2023. Through land agreements, the project developer says it supports the agricultural economy by infusing revenue into family farms and diversifying their income.

The focus of this article will be on these statements.  In the first place the 2,298 “vacant” acres include a “total of approximately 1,234.2 acres of NYSORPS classified Agricultural Land (Code 100)”.  Clearly agricultural land is not vacant.  I hope that was a typo, but if not, it is a sad testament to the disconnect between the Hochul Administration and the agricultural community. 

The bigger issue is the claim that the project supports the agricultural economy.  The New York State Department of Agriculture & Markets (AGM) testimony concluded that the project will have “significant and adverse disproportionate agricultural impact upon the local farming community”.  This article will explain why the best interests of the state as exemplified by the AGM testimony have been cast aside in the unplanned rush to build renewables as part of the transition of the economy to net-zero.

NextEra Response to Testimony

On March 10, 2022 Michael Saviola of the New York State Department of Agriculture & Markets (AGM) submitted prepared testimony on the Garnet Energy Center application.  On April 12, 2022 NextEra Energy Resources responded to the comments in Garnet Rebuttal Panel Testimony.  In the following I am going to discuss two issues where the Siting Board chose the developer’s rationale over the AGM.

The two issues are addressed in the Panel response to Saviola on page 124 at line 6 of their rebuttal testimony. Question: “Please address the direct testimony of AGM staff’s witness Mr. Michael Saviola.”  The answer:

Mr. Saviola states that AGM “discourages the conversion of farmland to a non-agricultural use” (AGM staff Testimony, p. 6, ll. 4–5). With respect to utility-scale renewable energy projects, Mr. Saviola states that “[t]he 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” (AGM staff Testimony, p. 7, l. 21–p. 8, l. 2).

On page 125 line 3 the rebuttal testimony poses the question: “Does siting the Project on Prime Farmland soils amount to a permanent conversion of agricultural soils to a non-agricultural use, as Mr. Saviola argues (AGM staff Testimony, p. 8, ll. 18–20)?  The response states:

No. Although agricultural land within the LOD will not be available for farming during the life of the Project, the soils will be suitable for agricultural use after the Project is decommissioned.

Saviola’s testimony explained the AGM concern:

Due to increasing NYS energy goals encouraging renewable energy development, we see no reason facilities will not be upgraded and re-leased to maintain the growing or static renewable energy demand, in this case, 35 years from energization. The Department further asserts that as long as NYS incentives for the development of renewable energy exists, the complete decommissioning of solar electric energy generation, and full resumption to agricultural use is not likely to occur.

The developer’s response to this claimed it was speculation on the part of Saviola and reveals their development rationale and the shortcomings of current State policy.  On Page 127 line 4 the rebuttal testimony states: “In our view, however, it is equally speculative that State incentives will remain constant, that no participating landowners will elect to resume agricultural activities within the Project Area, and that all participating landowners will agree to release their land for solar generation at that time.”  Parsing out “State incentives will remain constant”, it is obvious that the developer believes that without state incentives aka subsidies they would not consider redeveloping the site.  It seems to me that they admit that solar development in the future will still depend on subsidies.  The decision to return to farming or leasing to farmers is primarily driven by money.  While I have no personal animosity towards landowners that offer their land for solar development, the fact is that the NYS solar incentives provide more than enough money to outbid the value and risks of farming so it is an easy choice for land owners.  However, if nearby farmers were renting land used for solar, there is no hope that they can compete with the state money.  AGM developed guidelines so that solar development would not reward a favored few at the expense of the entire agricultural community.  They are saying you have to keep most of the Prime Farmland available for farming purposes.  The Siting Board and Climate Action Council have failed to support the AGM opinion that “the facility will result in or contribute to a significant and adverse disproportionate agricultural impact upon the local farming community”.

NextEra arguments hinge on the definition of permanent.  It points out that on page 126 line 15 that:

As the Siting Board has previously explained, although agricultural lands will be converted to non-agricultural use during the life of the Project, decommissioning and post-decommissioning restoration measures “result in minimal permanent impacts to agricultural resources.”

In my opinion the implicit concern of AGM is that even during the life of this project the loss of Prime Farmland is to be avoided.  Even if the project area is restored the avoided minimal permanent impacts likely are limited to the farmland itself.  It is unlikely that the failed family farms who depended on renting that property and the local businesses that went out of business when all the affected farms stopped farming will startup when the solar leases end and the land becomes available to farm again.  While solar developers want to be able to install panels on land that requires less work to maximize their profits, clearly it is in the best interest of the State to encourage responsible solar development that avoids installation of solar panels on Prime Farmland and directs it towards land with less value. 

On page 124 line 19 the rebuttal testimony gets to the crux of the problem:

Article 10, the State Energy Plan, the CLCPA and the recently enacted Accelerated Renewable Energy Growth and Community Benefit Act (“Accelerated Renewables Act”) do not specify any agricultural standards that must be satisfied, nor do they attempt to usurp the rights of private landowners to voluntarily decide if they wish to grow food on all their land or use a portion of it to allow the generation of renewable electricity in order to support their farm operations.

This is all completely true and is the license which out-of-state developers are using to usurp the AGM’s attempts to protect to protect the state’s most productive farmland.  It is evidence of the Administration and Climate Action Council’s failure to act in the best interests of the state’s agricultural community.  The State has a responsible solar siting  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. Clearly there should have been a moratorium on utility-scale solar development permit approvals until those policies are put in place and I submitted a comment on the Draft Scoping Plan that made that suggestion.  Without responsible solar siting guidelines, the solar developers can thumb their noses at the AGM and the agricultural community they are trying to protect. 

On page 128 line 1 of the rebuttal testimony responds to the question “Does the Project minimize permanent conversion of Prime Farmland soils to the maximum extent practicable in accordance with AGM’s 10% goal (AGM staff Testimony at p. 12, l. 22 – p. 13, l. 3)?”.  The answer:

Yes. The Project’s LOD encompasses approximately 1,054 acres. As a result of the Applicant’s Update to the Application (January 2022), approximately 185 acres of solar arrays have already been eliminated from the Project layout (see App. Ex. 4 Update at 1). This reduction of arrays resulted in an overall reduction of Prime Farmland within the LOD by approximately 37 acres and reduced permanent impacts to Prime Farmland by approximately 2 acres. Approximately 492.2 acres of land within the LOD is classified as Prime Farmland. However, only approximately 12.6 acres (approximately 2.6% of Prime Farmland within the LOD) will be permanently impacted by the installation of Project Components (id.). The rest of the land will be restored and maintained in compliance with the AGM Guidelines to the maximum extent practicable. This permanent impact is well within AGM’s 10% goal.

The Garnet application Updated Exhibit 4. Land Use describes the project area impacts to agricultural land:

The Project Area was evaluated to determine impacts to Agricultural Land, including mapped Agricultural Districts, as part of the Project. A total of approximately 1,234.2 acres of NYSORPS classified Agricultural Land (Code 100) is mapped within the Project Area. The Project will have a fenced-in area of approximately 901.6 acres. Although the Project is sited entirely within mapped Agricultural Districts, the fenced area will only occupy 0.3 percent of all lands designated as mapped Agricultural Districts within Cayuga County and 5.0 percent of all lands designated as Agricultural Districts within the Town of Conquest. Finally, of the 1,054.1 acres of LOD, only 464.7 acres will occur on land classified as Prime Farmland which is only 6.5 percent of all Prime Farmland within the Town of Conquest, and 0.25 percent of all Prime Farmland within Cayuga County.

When I look at the numbers, I get a different result.  The total project area is 2288.7 acres, 464.7 acres of prime farmland will be on Prime Farmland and that works out to 20% of the project.  That is double the AGM guidelines that led to the conclusion that the project will have “significant and adverse disproportionate agricultural impact upon the local farming community”.  The percentages of prime farmland in the town and county are only listed to give the appearance that this is not a big deal but there are not standards for those parameters. 

There was another paragraph responding to this question:

In addition, no statutory or regulatory support is cited for AGM’s proposed 10% or less Prime Farmland soil conversion “goal” that “the production of food is more essential than the generation of [renewable] electricity,” or that soil classifications 1-4 should be avoided, even if it means interfering with the development of a renewable facility contracted to sell renewable energy credits to NYSERDA. The Certificate Conditions conserve and protect agricultural lands; it is the responsibility of AGM, and not private solar developers, to encourage the development of farming. That charge cannot be used to thwart the renewable energy goals of the State.

I was shocked at the tone of this rebuttal to Saviola’s testimony.  In this example we have out-of-state developers lecturing state agencies on policy.  Of course, their only concern is throwing up as many solar panels as possible as soon as possible before the Administration figures out that there are negative consequences to irresponsible solar development that should be considered and not ignored.  Sadly, the lack of a planning by the Climate Action Council has resulted in no regulatory guidelines so developers are free to thumb their noses at the agencies. 

Finally, there is no more tone-deaf response to the AGM arguments than on page 127 line 8: “New York State is combatting the devasting impacts of climate change now”.  This pathetic attempt to appeal to emotions demands a response.  Given that New York’s total annual GHG emissions are less than the annual increase in global emissions averaged since 1990 the likelihood that the climate change value of this solar project is greater than the “significant and adverse disproportionate agricultural impact upon the local farming community” is vanishingly small.

Conclusion

New York State has stacked the deck against home rule and the consequence is going to be a disaster for communities dependent upon local agriculture when vast swaths of Prime Farmland are converted to solar panels over the life of the project.  I am terribly disappointed with the Garnet Energy Center project approval because I believe it will have local consequences that will out-weigh any climate change benefits due to the solar development.  Unfortunately, it is just a symptom of a much larger disease.

Since I started tracking solar development project approvals a total of five applications have been approved for a total of 1,120 MW.  The total project areas cover 14,812 acres and the project footprints total 5,728 acres.  Despite the best efforts of AGM staff to prevent the loss of Prime Farmland the area unavailable for farming in these projects totals 3,920 acres or 26% of the combined project areas.  This is bad enough but all three Draft Scoping Plan mitigation scenarios call for over 40,000 MW of solar development.  Unless the Climate Action Council institutes responsible solar siting guidelines similar to the policy option roadmap for the proposed 10 GW of distributed solar development there will be significant and irreplaceable loss of Prime Farmland and damage to farming communities across the state.

The Garnet Energy Center project approval is an example of the State’s net-zero transition unfolding disaster.  As NextEra states “Article 10, the State Energy Plan, the CLCPA and the recently enacted Accelerated Renewable Energy Growth and Community Benefit Act do not specify any agricultural standards that must be satisfied” so developers are free to use as much Prime Farmland as they want.  In addition, there are no solar capability standards so developers are free to install fixed panel racking systems that cost less but do not meet the capacity expectations of the Draft Scoping Plan.  The state has not updated its cumulative environmental impact assessment for the larger renewable energy capacities in the mitigation scenarios so the consequences of the necessary level of development are unknown.  Finally, the State has not released actual cost estimates of their proposed control strategies. To sum up, current state policy does not protect Prime Farmland, unless guidelines are promulgated even more solar capacity will be required causing even more undefined cumulative environmental impacts, and there is no estimate how much this will all cost.  What could possibly go wrong?

Replacing Peaking Power Plants with Battery Energy Storage Systems

In the last couple of years environmental advocates have vilified peaking power plants in their endless quest for zero risk to Environmental Justice (EJ) communities.  There is no benign way to generate and distribute electricity so every option has drawbacks.  I do not believe that the advocates understand that replacing a fossil-fired peaking power plant with their preference for “clean” energy and battery energy storage has risks that are potentially worse.

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.  This requires a pragmatic approach.  The purpose of this blog is to describe the environmental tradeoffs associated with energy production and use in New York.  I am motivated to write this article because I have been intimately involved with New York’s peaking power plants for a couple of decades.  I believe the State’s policy appeasement of the environmental advocacy organizations is ill-founded and dangerous.  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.

Peaking Power Plants

Peaking power plants are used to balance generation and load.  I recently described a paper that explains that electric load varies substantially: “Variations in demand profiles and the existence of demand peaks are caused by variation in weather, end-use technology stock, and, ultimately, consumer preferences and behavior”.  Developing an electric system that reliably provides power for these demand peaks has always been part of the planning process for electric power systems.  While on the face of it, for example as described in Wikipedia, the use of peaking power plants seems to be simple the reality is much different. 

In 2020 the PEAK Coalition released a report entitled: “Dirty Energy, Big Money” that vilified peaking power plants in New York City.  The PEAK coalition’s goal is to “come together to end the long-standing pollution burden from power plants on the city’s most climate-vulnerable people”.  They claim their efforts are the first comprehensive effort in the US to reduce the negative and racially disproportionate health impacts of a city’s peaker plants by replacing them with renewable energy and storage solutions.

At the time I evaluated the technical analysis for the PEAK Coalition report by Physicians, Scientists, and Engineers (PSE) for Healthy Energy. I described my evaluation in three detailed technical posts.  The first post provided information on the primary air quality problem associated with these facilities, the organizations behind the report, the State’s response to date, the underlying issue of environmental justice and addressed the motivation for the analysis.  The second post addressed the rationale and feasibility of the Coalition’s proposed plan relative to environmental effects, affordability, and reliability.  Finally, I discussed the  Physicians, Scientists, and Engineers (PSE) for Healthy Energy report Opportunities for Replacing Peaker Plants with Energy Storage in New York State that provided technical information used by the PEAK Coalition.  Because those were technically oriented and long, I also prepared a simpler summary post that addressed all my concerns.

I concluded that the claims that peaking power plants are dangers to neighboring environmental justice communities are based on emotion.  In the evaluation I did of the PSE analysis and the PEAK Coalition report, I found that the alleged impacts of the existing peaking power plants over-estimates impact on local communities relative to other sources.   The primary air quality health impacts claimed are associated with ozone and inhalable particulates that are secondary pollutants.  While some inhalable particulates are emitted directly, most of the particulates and all of the ozone form after they are emitted and transported away from the disadvantaged communities peaking power plant closure is supposed to protect. 

In my previous work I discussed feasibility challenges associated with the solar plus energy storage “solution” advocated by PSE and the PEAK Coalition.  I believe that it will markedly increase costs significantly and it may not even work because solar and energy storage is not a proven technology on the scale necessary to provide New York City’s peaking power requirements.  Until such time that the state’s organizations responsible for reliability confirm that those technologies are adequate it simply is not safe to rely on them.  This post is going to address another pragmatic tradeoff – the relative potential environmental and health impacts of the so-called “zero-emissions” solar plus energy storage alternative.

New York Peaking Power Plant Environmental Policy

In order to address the peak load power requirements, New York utilities have relied on two types of generating resources: purpose-built units and existing but aging and inefficient units.  The primary peaking power plant issue is in New York City where generating units are necessarily close to residential neighborhoods.  Around 1970 Consolidated Edison of New York installed about 100 simple cycle combustion turbines to provide peaking power and also maintain reliability in specific regions of New York City and Long Island – known as load pockets. Load pockets represent transmission-constrained geographic areas where energy needs in that area can only be served by local generators, due to the inability to import energy over the transmission system during certain high-demand conditions.  These units were cheap but not particularly efficient or clean.  After de-regulation they were sold to several generating companies who considered replacement with efficient modern and clean units but despite the fact that permits to build replacements were approved no one ever built one.  I believe this occurred because the developers did not think that they could recover the costs of building the replacements.  I think that reflects the difficulty financing a facility that only operates infrequently.

However, the continued operation of the purpose built inefficient and dirty peaking turbines is coming  to an end due to the New York Department of Environmental Conservation’s (DEC) “Peaker Rule”.  The rule sets new limits on nitrogen oxides emissions from simple-cycle combustion turbines in a phased implementation from 2023 to 2025 that effectively forces them to install controls or be retired.  Importantly, the rule included an electric system reliability subpart that ensured that the units would not retire until replacement power was available as determined by the “New York Independent System Operator (NYISO), the local transmission/distribution owner, or the New York State Public Service Commission”.  This rule sets a good precedent for how electric generating units should be retired due to environmental policy.

The other source of peaking generation is older units that are no longer efficient enough to compete for normal operations.  New York State has quite a few large steam boilers that were designed to burn residual oil.  Over time the cost differential between oil and gas has shifted such that residual oil is rarely a cost-effective fuel to burn.  Consequently, those steam boilers run very little and survive primarily to provide peaking power support. In addition, New York City has specific reliability requirements for in-city generation that mean that despite their low operating times those large steam boilers are paid for their ability to provide that service.  The reliability requirements also mean that any replacement options for these facilities also have to be located in New York City.

At this time DEC is proposing guidance changes to the permitting process that will address the eventual retirement of these units to meet Climate Act mandates.  It is worrisome that the lessons learned from the successful Peaker Rule don’t appear to be incorporated.  Moreover, DEC is modifying its regulations for public participation in the Uniform Procedures Act apparently to appease the environmental advocates.  I am convinced that the common theme in any public comments will be shut down the boilers and replace them with clean energy and battery energy storage without acknowledging the issues described in the next section.

Advocacy Replacement Proposal Issues

The crux of the problem is that  environmental advocacy organizations and the PSE Opportunities for Replacing Peaker Plants with Energy Storage in New York State propose similar solutions for the purpose built turbines as the steam boilers.  In 2019 the Department of Public Service released a report that studied the potential replacement of peaking units with energy storage that was adopted as proof that energy storage technology could be used for all the peaking power plants even though that report was concerned primarily with the peaking turbines.  The PSE report did not differentiate between small peaking turbines and much larger steam boilers.  In addition to the local air quality impact concerns, the Climate Leadership and Community Protection Act includes a mandate to make the electric grid zero-emissions by 2040.  As a result, environmental advocacy groups are lobbying hard to shut down any remaining units, including the steam boilers, that operate infrequently enough to be classified as peaking units.  Their plan is to phase out fossil fuel peaker power plants and replace them with clean renewables and battery energy storage system (BESS) technologies. 

I believe PSE has misled the advocacy groups that their control alternative is a viable option for large boilers.  There are two problems with large boiler replacement.  The first is the size of the boilers.  The following table lists the remaining New York City steam electric boiler units.  They are all old and some run under 5% of the time.  Next year the majority of the operating (Title V) permits for the boilers will expire. In New York City, the smallest boiler is 146 MW, there is a total of 2,095 MW of boilers that operated less than 5% of the time in 2021 a total of 3,555 MW of boilers whose operating permits expire next year, and total of 3,887 MW of steam boiler capacity in New York City.  The cost of replacing that amount of capability will be very high at a time of increasing energy costs.

New York City Steam-Electric Boilers

The second boiler replacement problem is the space necessary for a battery array that can provide the energy equivalent to any of the electric-steam boilers still operating in New York City.  I was unable to find spatial requirements on the web so I base my estimates on the Elkhorn Battery facility at Moss Landing in California.  Elkhorn Battery consists of a total of 256 Tesla Megapacks, the total energy capacity is 730 MWh, and power output is up to 182.5 MW, As shown in the following view there are 132 cubical structures that apparently hold two Megapacks each.  I estimate that one third (in the 4 by 11 configuration) of the Megapacks are rated at 60.8 MW and produce 243 MWh cover an area of 240 by 280 feet which works out to around 1.5 acres.

Google Maps view of the Elkhorn Battery array at Moss Landing, California

Using that estimate of spatial requirements I estimated the New York City acreage necessary to replace steam electric boilers with the clean energy and battery storage option.  Replacing the smallest boiler would require 3.6 acres. Replacing the 2,095 MW of boilers that operated less than 5% of the time in 2021 would require 52 acres.  Replacing the total of 3,555 MW of boilers whose operating permits expire next year would require 88 acres.  Finally, replacing all the steam boiler capacity in New York City would require 95.9 acres.  Space in New York City is at a premium so the area needed may not be available.

One other point is that these spatial estimates are based on power (MW) capabilities.  At this time battery energy storage systems only provide energy for four hours.  Because peak load requirements can be greater than four hours and these steam boilers can run throughout a load peak, the number of batteries necessary to provide that energy is significantly greater than shown here.  I believe that when the full energy requirements necessary to replace the steam boilers is calculated it will be determined that there is insufficient room available in New York City to provide equivalent capabilities.

Energy Storage System Environmental Risks

In addition to logistical implementation issues, there are environmental tradeoffs and safety risks.  The Tesla Megapack lithium-ion batteries are similar to the ones in electric vehicles.  Michael Mills explains that there is no such thing as a “zero-emissions” vehicle.  He points out that you don’t eliminate emissions you export them.  This also applies to BESS components but I am not going to discuss this hypocrisy anymore in this post.

Instead, I am going to focus on the potential risks of BESS thermal runaway fires and explosions.  Paul Christensen, Professor of Pure and Applied Electrochemistry at Newcastle University in the United Kingdom gave a presentation at PV magazine’s Insight Australia event in 2021 that describes the risks.  He is one of the world’s leading experts on battery fires and safety and said global uptake of lithium-ion battery technology has “outstripped” our knowledge of the risks.  I recommend the entire presentation as a good overview of this issue.

His primary concern about battery fires is described in the presentation.  Once a battery is abused the chemistry can become unstable.  If it does that generates gases and heat, the heat creates more gases and the potential exists for a thermal runaway reaction.  The following slide illustrates the relationship. 

Christensen explains that:

In thermal runaway and prior to ignition, lithium- ion batteries produce a white vapour which consists of: hydrogen (ca. 30-50%), carbon monoxide, carbon dioxide, hydrogen fluoride, hydrogen chloride, hydrogen cyanide, small droplets of the organic solvents, ethane, methane and other hydrocarbons, sulphur dioxide and nitrogen oxides, i.e. a vapour cloud.

He explains that thermal runaway runaways should be prevented by safety systems, but he points out that fires and explosions are still occurring on land, sea, and in the air.  His presentation included the following slide that lists Lithium Ion Battery Energy Storage System (LiBESS) events.  The acronym VCE stands for vapor cloud explosion on the list.  Also note that since the presentation, the Moss Landing facility had another fire incident on September 20, 2022 that shut down traffic and resulted in a shelter in place advisory.

Christensen explained that the Korean government is leading the world in LiBESS developments and the presentation included a description of a translation of the official South Korean government report on LiBESS fires:

It is likely that these safety flaws are not unique to battery systems and BESS made in Korea. It is more likely that the large amount of BESS installed in Korea has made the flaws evident earlier. These flaws are also likely to exist in BESS and battery systems that were not made by Korean manufacturers.

BESS safety can only be fully assessed on the system level. A safe battery cell is the foundation for a safe BESS, but not a guarantee. The historical strong focus on cell safety only has led to avoidable slips in the technical risk management of BESS projects as a whole. Therefore, the safety assessment of the BESS should cover all hazards, not just the electrochemical related hazards.

The LG Chem report on SK incidents blames:

  1. Inadequate design of the electrical protection system
  2. Inadequate control of the operating environment within system enclosures
  3. Careless installation practices that degraded system integrity
  4. Inadequate ESS system control and protection

Failures could only be reproduced with multiple stresses, e.g.: High humidity + Common Mode Voltage (CMV) aka Common Mode Noise.

Christensen describes the characteristics of the thermal runaway plume and then he shows frightening examples of tests of vapor cloud fires and explosions.  The intensity of the fires and the toxic gases mean that fire fighters cannot put the fires out safely.  They just have to let them burn themselves out and hope that the fires don’t destroy anything other than the batteries and their enclosures. 

Discussion

The peaking power plant issue is a poster child example of the dangers of environmental advocacy organizations misplaced focus on one issue.  Disparaging ugly peaking power plants in neighborhoods makes for a great sound bite rallying call to stir up action.  However, the argument that those facilities are the root cause of significant health issues rings hollow because the primary air quality effects are from secondary pollutants that form after the emitted pollution has been transported away from the neighborhood.  Moreover, my bet if an air quality monitoring attribution analysis was done in the so-called “asthma alley” that advocates mention in their press releases, is that fossil-fired power plants would not be the dominant component.

Nonetheless, the Hochul Administration is pushing for closure of power plants in New York City.  According to the LS Power website:

On October 17, 2019, the PSC granted a Certificate of Public Convenience and Necessity (CPCN) for LS Power’s proposed 316-megawatt battery energy storage project at the Ravenswood Generating Station in Long Island City. Additionally, the Ravenswood storage project was accepted in the New York Independent System Operator (NYISO) 2019 interconnection facility study process, and is therefore well positioned to be able to meet a 2022 in-service requirement.

A trade press article about the Ravenswood renewable redevelopment plans states:

Energy asset developer Rise Light & Power will redevelop its 2,480MW Ravenswood Generating Station – New York City’s biggest power plant – as a new renewable energy hub including on-site energy storage.

The 27-acre site in Queens will be turned into a hub integrating various clean energy sources, although the press release is not clear on when the fossil fuel units will be retired nor exactly what renewable capacity will be built on-site.

It does make clear that large-scale battery energy storage will be deployed directly on the facility site, which currently powers 20% of New York City’s needs.

The redevelopment will repurpose existing infrastructure to connect thousands of megawatts of offshore wind and onshore wind, solar, and other clean energy resources from Upstate New York to the City’s grid, a press release said. Ravenswood’s river water intake system will also be repurposed to provide zero-emission thermal energy to nearby communities.

LS Power is proposing a 316 MW BESS on a 27-acre site in New York City.  According to my estimates that requires 7.8 acres for equivalent battery energy storage.  I could not find any details of the proposed plan but they necessarily must pack the batteries closer together than the battery array at the Elkhorn Battery in Moss Landing, CA.  Given that facility has had two fires since it began operating a little over a year ago and the Christensen presentation shows how dangerous those fires can be, my impression that is not such a good idea.  Dr. Christensen’s remark that he is “astounded and appalled that if there is no appreciation of the safety issues involved” certainly should prompt an extensive safety review before this facility is permitted and constructed.

Conclusion

I conclude that until you have a viable alternative, and I submit that the renewable energy battery storage option is not viable, then it is premature to shut down the existing fossil fired peaking generation in New York City and the state.  Not only will the closures have minimal effect on health impacts but closure could affect reliability.  Given the impacts of New York City blackouts I don’t believe any threats to current reliability standards should be accepted.

Furthermore, the proposed alternative of renewable energy and energy storage systems has to overcome space constraint issues and is not proven technology.  When a leading expert on batteries says “Everybody has to be educated how to use these batteries safely”, I think the best course of action is to follow his advice.  It is not appropriate to make the residents of the disadvantage communities near a BESS become unwilling lab rats to test whether a technology that can generate toxic gases, fires, and explosions is appropriate in an urban setting. 

Another unrecognized constraint by the environmental advocacy organizations is the financing model for a necessary resource that only operates a few times a year.  Purpose-built peaking generation resources to this point have relied on the cheapest resource available such as simple-cycle combustion turbines.  While an argument may be made that some renewable generation resources are competitive with simple cycle turbines the requirement in New York City is for a dedicated resource capable of providing peaking power on demand.  That means that the renewable resources, the transmission to get that power to New York City, and the BESS to provide that power have to be dedicated to this requirement.  I believe those costs will be several multiples greater than any fossil-fired alternative so financing and operation costs will be a problem. 

Of course, the environmental advocate argument is that it is necessary to address climate change.  Paraphrasing Tom Shepstone, my ultimate concern is “It is profound climate misinformation to suppose global warming is such a threat that any action, no matter how risky, is somehow preferable to a fossil fuel alternative without those risks”.

Climate Act Emissions in Graphical Context

This post was updated on 10/24/22 to replace the second graph included and include data to 2019

The Climate Leadership and Community Protection Act (Climate Act) establishes a “Net Zero” target by 2050. The Draft Scoping Plan defines how to “achieve the State’s bold clean energy and climate agenda” and claims that there are significant direct and indirect benefits if New York’s greenhouse gas emissions (GHG) are reduced to net-zero but there is no mention of New York’s emissions relative to the rest of the world.  I explained that any claim of benefits is illusory because in the context of global impacts New York’s contribution is miniscule.  This short post puts the numbers into a couple of graphs.

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 Climate Act implementation plan and have written extensively on New York’s net-zero transition because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that this supposed cure will be worse than the disease.  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 and Global GHG Emissions

The purpose of this post is to illustrate how New York GHG relate to global emission increases.  I found CO2 and GHG emissions data for the world’s countries and consolidated the data in a spreadsheet earlier this year.  I downloaded the data again for this post and found data out to 2019.  The following graph shows global and CO2 emissions for the world and New York plotted on the same graph.  New York emissions are essentially zero.

The trend results indicate that the year-to-year trend in GHG emissions was positive 21 of 26 years and for CO2 emissions was positive 24 of 30 years.  In order to show this information graphically I calculated the rolling 3-year average change in emissions by year.  The following graph shows that rate of change in emissions has been consistently higher than New York emissions since 1990.

Conclusion

By any measure New York’s complete elimination of GHG emissions is so small that there will not be any effect on the state’s climate and global climate change impacts to New York.  I previously showed that although New York’s economy would be ranked ninth relative to other countries, New York’s emissions are only 0.45% of global emissions which ranks 35th.  This post graphically shows New York emissions are negligible compared to global emissions.  The change to global warming from eliminating New York GHG emissions is only 0.01°C by the year 2100 which is too small to be measured much less have an effect on any of the purported damages of greenhouse gas emissions.  Finally, this post shows global emissions have increased more than New York’s total share of global emissions consistently since 1990.  In other words, whatever New York does to reduce emissions will be supplanted by global emissions increases in a year.

The only possible conclusion is that the Climate Act emissions reduction program is nothing more than virtue-signaling.  Given the likely significant costs, risks to reliability, and other impacts to New York society, I think that the schedule and ambition of the Climate Act targets needs to be re-assessed for such an empty gesture.

Updates to Pragmatic Environmentalist Pages

This is a second summary of updates I made 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 and I also have highlighted a few recent articles that don’t fit my needs on those pages.

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 added links to three articles on the Renewable Energy Feasibility page including two videos. Michael Mills Prager University video “How much energy will the world need?” explains that oil, natural gas, and coal provide 84% of the world’s energy today despite great expenditures to wean the world off fossil fuels over several decades.  He points out that the materials needed to develop wind and solar require massive amounts of mining to produce which in turn requires major increases in energy use.  Dr. John Robson Climate Discussion Nexus video “American Energy for Grownups” describes how the Biden Administration’s goal of phasing out fossil fuels has increased the difference between supply and demand such that costs have increased dramatically.  In addition, Robson explains that due to environmental regulations and climate regulatory expectations has led to a lack of infrastructure investments.  He points out that the existential threat of climate change claims are overblown and that the actual effects of greenhouse gas emissions on climate change are vastly out-weighed by the benefits of plentiful and affordable energy provided by fossil fuel use.  Most recently, Francis Menton sums it all up showing that society cannot develop “green” energy using only green energy. 

I added a link to the Electric Heating page that describes a proposed Department of Energy rulemaking on energy conservation standards for residential furnaces.  Robert Bradley describes this proposal seeks to “regulate/prohibit gas furnaces on a pure physical efficiency standard, demoting up-front cost considerations, as well as back-end reliability issues (such as when the power goes out).”  He describes comments submitted by free market advocacy groups that argues that “A fair-field, no-favor competitive market for home and business heating—a let the market decide policy—is the obvious choice in place of one-size government policy from Washington, DC.”  I added the link because the article eviscerates the climate impact rationale for the revised standards and provides links to other articles about the decarbonization efforts to eliminate the use of natural gas in homes.

As soon as Hurricane Ian hit the Florida coast the usual suspects came out and claimed links to global warming.  Chris Martz did a great job reviewing the claims made and examined the claims to see if they held up to close examination.  He found common themes and rated them for accuracy.

Hurricane Ian tied with several others as the 5th most intense to strike the Contiguous United States since records began in 1851.  This was rated true but debatable because the measurement methodology has changed over time and that could affect the ratings.

Storms like Hurricane Ian are becoming more likely because of human-caused climate change. Martz provided detailed information and many examples that shows that this is a false claim.

Globally, we are observing stronger tropical cyclones; a greater proportion of hurricanes are reaching major hurricane status.  Martz provided detailed information and many examples that shows that this is a false claim.

Rapid intensification (RI) events (30-knot increase in 24-hours) are becoming increasingly common because warmth from rising sea surface temperatures (SSTs) is diffusing into deeper layers, increasing the fuel, or ocean heat content (OHC) for hurricanes.  Martz explained that the information necessary to calculate these events is only available for a limited time and showed that it proves this is a false claim.

The size of storm surge has increased due to both sea level rise (SLR) and increasing tropical cyclone size.  Martz argued that there is missing context from this claim.  “Sea-level rise could certainly prove to be a major issue for coastal communities during the next couple of centuries assuming rates either remain constant or accelerate. However, that’s an entirely separate issue from the size of a hurricane’s storm surge, and with current scientific understanding, discernable trends in magnitude remain to be seen.”

Climate change upped rainfall amounts in Hurricane Ian by at least 10%. For every 1°C rise in ocean surface temperatures, the amount of water evaporating into the atmosphere increases by 7% which exacerbates flooding from extreme rainfall.  Martz explains that “Oversimplifying a complex issue leads to erroneous results and flawed reasoning” and shows that the claim is false.

Paul Homewood did an article that reminds us just how destructive mining for lithium needed for electric vehicles is to the environment.  He references an article that describes how water quality, wildlife populations, and crops are all adversely affected by lithium mining.  He concludes with a question that bothers me too: “It is one of the great mysteries why the green movement in general is not actively campaigning against this”.

Other Posts of Note

Jo Nova described French President Macron response to the Yellow Vest protests a couple of years ago. His government chose 150 people who spent nine months learning climate science to figure out what the other 65 million French citizens would have chosen had they been there. Naturally, they were marinated and baked in approved ClimateThink, and no dissenting scientists or citizens were invited.  The result was predictable:

After this intense love in, they came up with a list of policies as big as a phone book, the government picked the ones they were probably going to do anyway, and flicked the ones they weren’t and then proclaimed the citizens had spoken! In theory there was supposed to be a Referendum option at the end, but this, well, nevermind, became just another round of votes in Parliament.

I mention this because it is similar to New York’s Climate Action Plan response to comments.  In New York the 22-member Climate Action Council (plus one added to appease the labor constituency of Hochul’s demographics) and the 13-member Climate Justice Working Group decide which stakeholder comments get addressed out of the 35,000 comments submitted.  As far as I can tell there never has been any intention to address any issues raised that are inconsistent with the narrative.

Two articles make me pessimistic about the future.  Don Ritter led the National Environmental Policy Institute after leaving Congress. His commentary The Real “Existential Threat” To People and Planet argued persuasively that green policies that promote green energy and suppress fossil fuels are doing more harm than good.  I believed that once there was an unmistakable link between the green policies and a bad outcome that there would be an acknowledgement and similar policies would be off the table elsewhere.  Michael Schellenberger’s interview with Will Cain discuss the war on fertilizer (at 7:55 of the video) and the response to the Sri Lanka agriculture disaster.  They agree that agencies advocating the ban on fertilizer just blew off the problems and have moved on to advocate implementation elsewhere.  I believe that when the inevitable blackout occurs in New York all the Climate Act advocates will blame someone else and double down on their policies that caused it.

Climate Act Cost of Inaction Misinformation

I have argued repeatedly that claims that reliance on intermittent wind and solar resources to meet the net-zero Climate Leadership and Community Protection Act (Climate Act) mandated targets have no potential reliability issues is simply incorrect.  My other big concern is affordability and this article addresses the supposed cost benefits of the Climate Act.  In particular, a recent segment by Spectrum News report Nick Reisman addressed the costs of the Climate Act that included an argument that the cost of inaction is far greater than the cost of action.  I believe that is also simply incorrect.

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 Climate Act implementation plan and have written extensively on New York’s net-zero transition because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that this supposed cure will be worse than the disease.  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 Implementation 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. Following a six month public comment period, 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.

I have written multiple articles (summarized here) documenting my belief that the Climate Action Council has not confronted reliability issues raised by New York agencies responsible for keeping the lights on.   Because those agencies have raised substantive issue based on the work of their subject matter experts I believe that the members of the Council that have downplayed reliability as a concern and have claimed that those concerns are misinformation  are the ones guilty of misinformation.  This post addresses the public’s perception of the claim that the costs of inaction are greater than the costs of action.

Can clean energy changes avoid dinging New Yorkers’ wallets?

The Nick Reisman story addressed the costs of the Climate Act and included a discussion of costs.  I think the genesis of the presentation was Children’s Environmental Health Day where advocates gathered at the State Capitol to urge the Climate Action Council to release a strong Climate Action Plan.  Reisman interviewed a local politician to explain the rationale for the request:

Elected officials and climate advocates are pushing for an aggressive plan to address global warming and reduce pollution. New Lebanon Supervisor Tistrya Houghtling says her community is especially vulnerable to extreme weather.   A school bus garage is vulnerable to flooding and farmers are hurt by fluctuations in weather and temperature.  “Between the drought and the flooding, and kind of what I call our bipolar weather where it goes back and forth so quickly, a lot of our farmers are struggling with their crops and other things,” she said.

For once there appears to be recognition that there is a difference between weather and climate because Houghtling correctly says that weather is causing the problems.  Nonetheless the implication is that a strong Climate Action Plan could affect these weather events.  No New York State regulatory policy related to climate change has ever quantified the potential effect of the regulation on global warming itself.  The reason is simple.  I have calculated the  expected impact on global warming as only 0.01°C by the year 2100 if New York’s greenhouse gas (GHG)  emissions are eliminated. That change is simply too small to be measured much less have a meaningful effect on any New York weather event. 

The interview goes on: “But at the same time, she does not want the changes to hit the wallets of her neighbors, especially lower income people who may struggle to pay to upgrade their homes with an electric car charging or a new heat pump.”  Reisman provides some background on the requirements:

In the coming years, New York plans to phase out gas-powered cars for electric vehicles. Buildings and homes will be electrified. The transition will mean a major change for how homes and businesses are powered, requiring major infrastructure upgrades along the way.

Of course, these actions will cost money and it is not clear just how much.  The news report notes:

Republicans, including Senate Minority Leader Robert Ortt, are skeptical utility ratepayers won’t take the brunt of the costs.  “What is the cost of these policies? Can we do these things?” Ortt said at a news conference recently.

New Yorkers have already been contending with high gas prices and an expected increase in home heating bills this winter.  “It’s not going to be at the pump so much that it’s going to be in their mailbox,” he said. “It’s going to be their utility bills. And it’s going to be the cost to heat their homes.”

The final interview is the reason I prepared this post.  In rebuttal to Ortt:

New Paltz Mayor Tim Rogers says the cost of inaction on climate is far greater.  “If we don’t make these investments,” he said, “if we don’t make these conversions, we will be paying many trillions more in costs for our communities.”

There are egregious mistakes in Rogers’ quote.  As noted previously, the presumption that implementation of the Climate Act reductions will actually have any effect on the observed weather and associated impacts is wrong simply because any New York emission reductions are simply too small to affect global warming.  In addition, New York GHG emissions have to be considered relative to global emissions.  I found that New York emissions are less than one half of one percent of global emissions.  On average, global emissions have been increasing by more than one half of one per cent per year for many years.  Therefore, any effect New York could possibly have on global warming will be offset by global emission increases in a year.

Draft Scoping Plan Cost and Benefits Claims

There is another egregious mistake in Rogers’ quote, namely the implication that reducing New York emissions prevent trillions in costs.  The Draft Scoping Plan estimates of potential benefits are much lower.  In order to bolster the claim that the costs of inaction are greater than the costs of action the Draft Scoping Plan conjures up as many speculative benefits as possible.   Figure 46 in the Draft Scoping Plan lists the net present value of benefits from 2020 to 2050 and the largest estimate is $420 billion or less than one half a trillion dollars. 

There is another problem.   I think the cost-benefit analysis is flawed and said so in my comments.  Because I have seen no indication in recent Climate Action Council meetings of any suggestion that stakeholder comments questioned the Draft Scoping Plan cost benefits claims I think it appropriate to summarize those comments.

The first problem is the lack of detailed cost documentation in the Draft Scoping Plan.  In my opinion the lack of detailed cost information in the Plan and the lack of response to questions about them is politically motivated because the costs will be eye watering.  Moreover, I maintain that the cost information provided is misleading.  In my comments on the Draft Scoping Plan I showed that in order to further the narrative that there is value to the Climate Act’s costs the reported numbers are carefully presented to give the impression that the cost of inaction is greater than the cost of action.  I documented a trick used to deceive the public that benefits out-weigh costs by excluding legitimate Climate Act costs.  For example, the analysis did not include the costs of the 2035 zero-emission vehicle mandate as part of the modeling comparison case because the “program was already implemented”.  That decreased the costs of compliance.  In addition, the Plan incorrectly interprets guidance to inflate the societal benefits of avoided emissions. That increases the alleged benefits.  When those errors are corrected the costs are greater than the benefits.

There is another issue with the benefit claims.  James Hanley from the Empire Center submitted written testimony to the Climate Action Council that addressed the cost and benefits of the Climate Act.  Although the messaging is that the benefits surpass the costs, Hanley commented that:

But what is obfuscated in this message is that all the costs fall on New Yorkers, while they receive only a portion of the benefits. Avoided economic costs due to reduced greenhouse gas emissions estimated at $260 billion are global benefits, although the plan fails to specify this important detail. This becomes clear only to those who are aware that the $260 billion estimate is based on the Department of Environmental Conservation’s social cost of carbon, which in accordance with the CLCPA is explicitly a global benefit. This is not clearly specified in the Scoping Plan, leaving the unwary reader with the mistaken impression that the benefit to New York outweighs the cost to New York.           

He goes on to explain that a careful analysis of the Draft Scoping Plan shows that the costs are greater than the benefits:

Nor does the Integration Analysis prepared by Energy+Environmental Economics make any attempt to disaggregate that $260 billion global benefit to discern what share accrues to the people who will be paying for it. But New York contributes approximately four-tenths of one percent of global greenhouse gas emissions. If we assume the state receives roughly the same share of the benefit, New York’s share of that benefit is only $1.4 billion. If we generously multiply that by 10 (assuming for the state what is likely a highly disproportionate share of the benefit), the benefit to New York would be $10.4 billion. If we subtract the $260 billion from the claimed $420 to $430 billion in benefits, then add back in that assumed benefit of $10.4 billion, we get a total net benefit to New York of $170.4-180.4 billion.  Against a cost of $280 – $340 billion, this means there is no net benefit to New Yorkers, but a net loss of $100-170 billion. Simply put, by the state’s own analysis the cost to New York outweighs the benefit to New York.

Conclusion

Despite the far-reaching impacts of the Climate Act, I remain convinced that most New Yorkers are unaware of what is coming.  In that context Spectrum News is to be congratulated for addressing this topic.  Unfortunately, like the majority of other news stories on this topic it accepts the basic talking points of both sides of the story without any investigation.  Advocates for action rely on talking points and typically respond to criticism by dismissing it as “misinformation”.

Investigation into the statements by both politicians would show their comments are real misinformation.  Houghtling implied that the Climate Act can reduce the potential risks to her jurisdiction but the State has never quantified those impacts or admitted that New York’s emissions relative to global emission increases negates anything we can do.  Rogers’ claim “if we don’t make these conversions, we will be paying many trillions more in costs for our communities” is not supported by the Draft Scoping Plan that projects benefits on the order of half a trillion over the period 2020-2050. Finally, careful review of the claimed benefits show that there are methodological issues and, importantly, that most of the benefits will accrue outside of New York. The costs will be real but the benefits are imaginary.

The news story interviewed politicians who supported a strong Climate Action Plan.  They don’t understand or don’t want to understand the enormous costs associated with the net-zero transition implementation.  To their defense the Hochul Administration has not provided sufficient information for anyone to find out what the state expects those costs to be.  Shouldn’t the fact that the Administration has refused to provide specific cost information for the proposed control strategies for a program that will radically transform the entire energy system of the state be the real story?

Climate Act Misinformation: Renewable Energy Reliability Risks

If you read this blog regularly you know that one of my persistent topics addresses the myth that the transition to the net-zero Climate Leadership and Community Protection Act (Climate Act) mandated targets relying on intermittent wind and solar resources has no potential reliability issues.  I have a long list of other potential topics to discuss but given its importance and the recent publication of a relevant blog post, I am going to try again to explain the reliability challenges embedded in the Climate Act implementation plans.   In particular I am going to call your attention to two recent blog posts The Penetration Problem Part I: Wind and Solar – The More You Do the Harder it Gets and The Penetration Problem Part II: Will the Inflation Reduction Act Cause a Blackout?.  This post excerpts some of the key points and explains the context relative to New York’s implementation plans.

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 Climate Act implementation plan and have written extensively on New York’s net-zero transition because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that this supposed cure will be worse than the disease.  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 Implementation 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.

My concern about misinformation arises from the response to stakeholder comments.  The leadership of the Climate Action Council has overly emphasized responses to comments by the Climate Justice Working Group and certain members of the Council itself.  Because the favored few members were appointed to their positions because of their ideological opinions and not their technological expertise the over-arching legal mandate to provide input to the Scoping Plan that “shall inform the state energy planning board’s adoption of a state energy plan” has suffered.  The Climate Act has always been more about the politics than reality and the politicians who are driving this process naïvely believe that the technology needed is only a matter of political will.  Many of the appointed ideologues also ascribe to that view, and some of the more vocal members of the Council have downplayed reliability as a concern going so far to claim that those concerns are misinformation.  I believe there is no greater example of actual misinformation than the claim that there are no risks to reliability inherent in the net-zero transition plan described in the Draft Scoping Plan.

Reliability Concerns

I have previously written that 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 New York Independent System Operator (NYISO) 2021-2030 Comprehensive Reliability Plan (CRP) report (appendices) released late last year. 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.  Recently I wrote about the draft of the 2021-2040 System & Resource Outlook report described in the previous article and the concerns raised.  Another post detailed the differences between the Resource Outlook and the Draft Scoping Plan Integration Analysis and recommended that those differences be reconciled in a public forum.  Most recently, I explained why the response to the reliability concerns to date has been even worse than I imagined possible.

There was never any response to my suggestion early in the process that everyone associated with the Climate Act transition get a briefing to explain how the electric grid works and highlight potential issues associated with the net-zero transition. As an example of potential topics I referred to the renewable energy systems page that I maintain.  The page provides links to posts that I recommend that anyone who is interested in researching the story behind the complexities of the energy system and relying on renewable wind and solar energy read.  All of the relevant articles by the author of the recommended articles are referenced there.

Retired registered Professional Engineer Russell Schussler writes under the pen name Planning Engineer at Judith Curry’s blog Climate Etc He initially wrote under a pseudonym so that his comments would not be taken as representing his employer.  He continues to use it there because he is well known at the website and he believes his ideas should stand on their own merits, not on claims of expertise.  He hasa BSEE is from The Ohio State University and a Masters of Electrical Engineering from University of Southern California. He worked in generation and transmission for over 30 years for different sized utilities, participated and held leadership roles in various research groups and reliability organizations before his retirement.

In the articles listed above I repeatedly tried to explain the risks inherent in the Draft Scoping Plan reliance on intermittent wind and solar.  I believe the Planning Engineer’s expertise and more accessible writing style makes a better case than I have to date so this post describes his concerns.

Wind and Solar – The More You Do the Harder it Gets 

In the first post Schussler explains:

There seems to be a belief that increasing the level of wind and solar projects will make subsequent progress with these resources easier. Nothing could be further from the truth.  Increasing penetration levels of wind and solar is like a Sisyphean task, except that it is worse. The challenge may be better understood as akin to pushing a huge rock which is getting heavier and heavier, up a hill of a steeper and steeper slope while the ground below gets slicker and more unstable. The problems associated with increased penetration swamp any potential benefits that might be achieved through economies of scale. 

He provides eight reasons why “increasing the penetration levels of renewables will lead to rapidly increasing costs as well as rapidly decreasing reliability”.   I have annotated my New York centric concerns relative to the Draft Scoping Plan to the list of his challenges below.  For further information I refer you to the original article.

Wind and solar do not readily supply essential reliability services. 

The Draft Scoping Plan does not consider these ancillary services in any meaningful way.

Wind and solar are intermittent resources and their availability/output often does not match or support system needs.

The New York Independent System Operator (NYISO) 2021-2040 System & Resource Outlook projected resources necessary to match system needs are significantly different than the resources in the Draft Scoping Plan.  There is no indication of any urgency to resolve those differences.

The success of wind and solar installations is highly location specific.

This is a particular concern for New York solar resources.  New York is not only a high latitude state with weaker winter insolation and shorter days but large portions of the state have high wintertime snowfall and cloudiness due to the Great Lakes.

Wind and solar depend on materials which must be mined and their ability may be limited.

The Draft Scoping Plan calculates life-cycle impacts for anything related to fossil fuels but ignores all life-cycle impacts for “zero” emission wind and solar components.

As wind and solar generation increase penetration it will become more and more challenging for other resources to subsidize their expansion.

The Draft Scoping Plan ignores this issue.

It takes a lot of energy to build wind and solar facilities.

The Draft Scoping Plan ignores this issue.

Wind and solar make the study, control and operation of the power system more complicated and uncertain.

The Draft Scoping Plan ignores this issue.

Widespread deployment of wind and solar would require that power be transmitted across great distances (or you would need an unrealistic and incredible amount of battery storage.) 

Th NYISO resource outlook raises transmission concerns but the Draft Scoping Plan ignores the issue.

Schussler talks about how the challenges might be overcome.  He argues that “it’s hard to imagine that any economies of scale would allow these resources to leap the formidable challenges” and that “it does not appear that significant improvements in economies of scale are to be expected”. He points out that nuclear energy could be a piece of the net-zero transition because none of the challenges apply.  Unfortunately, even though hydro is zero-emissions and works well with the power system, there are “negligible to no potential locations to expand hydro generation”.

He concludes:

It is way too soon to be envisioning a 100% renewable future with significant contributions from current wind and solar capabilities. It is not a good strategy to support current “green” technologies and retire and prohibit conventional generation hoping that a miracle will occur when we need it. Perhaps with the extensive deployment of nuclear power, carbon capture and other technologies we might be able to approach a zero-carbon grid. At best, current wind and solar technologies will play at most a small part in such a plan.

Will the Inflation Reduction Act Cause a Blackout?

The second post could have been renamed “Will the Climate Act cause a blackout” because the issues raised are directly applicable to the New York net-zero transition.  Schussler sums up the challenge:

Replacing conventional synchronous generating resources, which have been the foundation of the power system, with asynchronous intermittent resources will degrade the reliability of the grid and contribute to blackout risk. The power system is the largest, most complicated wonderful machine ever made. At any given time, it must deal with multiple problems and remain stable. No resources are perfect; in a large system you will regularly find numerous problems occurring across the system. Generally, a power system can handle multiple problems and continue to provide reliable service. However, when a system lacks supportive generation sources, it becomes much more likely it will not be able function reliably when problems occur.

I like his description of the cumulative effects of adding renewable resources:

Just as a pile of dry wood and flammable material can be sparked from many potential sources, or a very unhealthy person could succumb to many different threats, a weakened power system is more vulnerable to many conditions than a robust one. In this post I discussed responsibility for the Texas winter blackout. Many things went wrong that day in Texas. But often many things do go wrong – the real problem was that the Texas market did not provide incentives for standby resources.  In Texas there were not enough committed resources to provide for the system load levels and potential contingencies. Texas relied on an energy market designed to favor wind and solar resources and it failed them. However, many analyses of the Texas blackout focused on the proximate conditions (problems of the sort that are common) ignoring or denying the major underlying problem.

Heat Pumps

One of the key Draft Scoping Plan emissions reduction components for buildings is electrification of the heating system using heat pumps.  Schussler describes electric system issues with heat pumps as the number of heat pumps increased.  The argument in favor of heat pumps is that they are more efficient producing heat because they move energy rather than create it.  In his description of the technology, he states that:

Because of their behavior at colder temperatures, heat pumps are not appropriate for all parts of the country. In the north the many hours they would have to run with resistance heat makes them both environmentally irresponsible and too expensive. Natural gas is a better option. 

I think this is a fundamental problem in the Climate Act.  In their zealous pursuit of zero risk, they are foisting technology upon the citizens of the state that is not appropriate.  Of course, they have an answer: “In all scenarios electric heat pump space heating technologies are predominantly cold climate air source heat pumps (ASHPs) with electric backup and a significant role for ground source heat pumps (GSHPs)”.  I submitted 23 pages of comments on residential heating electrification and I argued that at many locations in the state all air source heat pumps will have insufficient energy to transfer and will require resistance heat backup.  The New York narrative is that they work in the Nordic countries where it is even colder so they should work in New York too.  Proponents neglect to point out that the reason they work there is that the housing units are smaller and much more energy efficient. 

The particular heat pump problem described by Schussler was that as more heat pumps were introduced the peak annual load shifted to the winter because during cold snaps inefficient electric resistance heating kicked in.  As a result, the electric system design requirements have to change and despite warning signs that this could be a problem, the resulting change in peak load requirements affected average energy costs.  He concludes this section noting that “While almost no one wanted to see it coming, once the effects hit, most everyone in the power supply chain wished they had. This was a terrible blow to rural electric cooperatives who had invested big to improve their load factor, only to find they had subsidized a worse winter load factor”.  Importantly, the same thing is coming to New York and someday down the road there will be unintended consequences.

Renewable Resources

Schussler goes on to discuss how the Inflation Reduction Act will enable blackouts by its encouragement of renewable resources. I believe New Yorkers can substitute Climate Act for Inflation Reduction Act to estimate impacts in the state:

The Inflation Reduction Act seeks to decarbonize the grid. In looking at the grid, you should not make one goal a priority but should instead seek to balance competing objectives. See Balance and the Grid for a discussion of how efforts to maximize one objective without due attention to other major goals can result in a worsening condition for all goals. It seems apparent that all the “green” measures in the Inflation Reduction Act were included because independently they all seem capable of reducing carbon. I have not seen any evidence that any consideration was given to system reliability or how these measures might interact to create problems.

Schussler then goes on to explain how the measures encouraged by the inflation Reduction Act, and Climate Act I believe, will lead to generic blackouts in many situations  He provides a specific prediction for the winter peak demand period: that I believe is applicable to New York:

Winter peaks can be extreme, much more so than summer peaks. As temperatures climb in the summer, air conditioners reach a saturation point. The climb in summer peak demand with each additional increase in temperature typically flattens out. In the winter each additional degree drop can increase demand more than the one before. There are a lot of potential sources of resistive heat that increase demand. In severe cold more and more heating elements come into play and the increase in demand rather than flattening can go up exponentially. Peak winter loads tend to hit just before sunrise. The system sees a rapidly rising peak, often described as needle shaped, which drops as the sun comes up and temperatures warm.  Such peaks can easily be 5 to 20% above normal winter peaks in many areas.   Thus, these conditions have the potential to cause more severe concerns than California sees during extreme summer conditions.

The Climate Act encourages and is projecting significant solar development.  Because the peak load is just before sunrise all this solar provides no support for the peak.  All the virtue-signaling homeowners with solar panels that have insufficient or no battery backup will not only be not providing any power but will be putting maximum demand on the grid.  He points out that “The infrastructure needs to supply a home which only puts a demand on the system a few hours a year concurrent with other uses maximum demand is basically the same as the infrastructure need to support a full requirements home.”  It is difficult for an electric rate structure to cover those system costs so either the needed infrastructure improvements are delayed or everyone else ends up subsidizing residential solar panel households.

Schussler also explains that wind resources are a problem too:

The Act encourages wind development. Like solar, wind will push other better suited resources out of the supply pool. Wind is generally slower just before sunrise and winter is not generally peak wind season. In any case wind is intermittent and some of the times during cold weather wind is not available. Some say that wind tends to rise up as temperatures get colder and there are ways to keep turbines from freezing,. Nonetheless, we do see freezing problems and a tendency for wind to be there is not a guarantee. Green resources perform much better in theory than practice. At least at sometimes wind power will not likely be a great asset during winter morning peaks demand conditions.

Another way to address this requirement is to encourage energy efficiency.  There is no question that this helps reduce load and, if the energy efficiency upgrades are consistent with the Nordic country requirements, then the amount of resistance heating necessary can be reduced.  Schussler points out some unintended consequences:

The Act encourages efficiency. This could help to reduce load and thereby make severe outages less likely. But the real problem with peak demand is the difference in demand during the extreme peak period and other more normal high load periods. If efficiency reduces load, you will likely see a reduction in generating resources to serve the load at all high load levels. The risk from peak conditions is more attributable to the delta between the winter peak demand and more common high load levels.  This is because regular loads drive generation additions more than extreme conditions. I don’t know that efficiency measures work better during the most extreme winter temperatures than it does at normal winter cold temperatures (probably less so), therefore its mitigating impact may be small to none. Also, there are those who might argue that consistent with Jevon’s Paradox efficiency efforts lead to increased energy consumption. The basic mechanism, behind this counterintuitive theorem, is illustrated by mechanisms observed such as   individual consumers with more efficient homes choosing to heat more rooms or increase comfort because you get more for your money in an efficient home.

On my long list of analyses that I would like to do is to compare the New York State Energy Research & Development Authority energy efficiency targets and goals with the actual observed improvements.  I have no reason to believe that they have ever come close to meeting their targets, in part, because of some the aforementioned issues.  As a result, I have no reason to believe that New York will achieve the levels of energy efficiency necessary to meaningfully, much less eliminate, the effect of resistance heaters affecting the peak load.

Schussler summarizes this section:

The chart below shows the US typical resource generation by major energy source. Imagine how this chart will look as fossil fuel is phased out. Hydro only makes up about 6% of the mix and expansion there is limited. Nuclear could replace these resources but it is not great for ramping up and down to follow needle peaks. If wind and solar step up to replace fossil fuels this leave us vulnerable to energy shortages during winter peaks just before daybreak. Battery capability would need to be huge, expansive and probably would not be procured in advance of demonstrated needs.

Recall that New York’s residential heating electrification magical solution is cold climate air source heat pumps that allegedly extract energy for home heating on the coldest days.  New York’s answer to the resource requirements quandary is another magical solution: dispatchable emissions-free resources.  This is a resource that has all the electric grid capabilities of a fossil-fired power plant without the emissions.  The NYISO Power Trends 2022 report sums up the challenge: “Long-duration, dispatchable, and emission-free resources will be necessary to maintain reliability and meet the objectives of the CLCPA. Resources with this combination of attributes are not commercially available at this time but will be critical to future grid reliability.” The Draft Scoping Plan uses “green hydrogen” as its placeholder for this resource and I addressed issues with that pipe dream in my comments on the Draft Scoping Plan.

Specific Blackout Prediction

Schussler lists the following set of conditions that he believes are inevitable in many areas including New York:

  • Very cold pre-dawn extreme temperatures
  • Backup quick start fossil fuel combustion turbines have been largely driven out of the resource mix,
  • Nuclear, hydro and battery resources are tapped out
  • Solar is absent from the distribution side and not available on the generation side
  • Wind may or may not be blowing
  • Heat pumps are operating maxed out in resistance mode, along with other resistive heating to drive system load to extreme heights
  • As with every power system there will be a few problems on the system
  • System will be forced to deliberately shed a lot of load or may go unstable and suffer crippling blackouts

Schussler emphasized this diurnal set of conditions.  I maintain that the ultimate problem with a net-zero energy system is that increased electrification will markedly raise loads during weather conditions that cause peak loads but also can have low wind and solar resource availability over extended periods.  I recently described a paper, Getting to 100%: Six strategies for the challenging last 10%, describes approaches for providing power during peak conditions that are not included in his analysis.  I believe that an extended period of low wind resources in the winter will exacerbate these conditions and tap out all the energy stored in batteries. 

Although New York is surrounded by other sources of electricity and most of the jurisdictions have not committed to either the renewable development targets or aggressive schedule of the Climate Act, there is a particular New York problem.  New York City is a load pocket and has specific reliability mandates that I believe will be violated in the scenario outlined.  That constraint exacerbates all the conditions.  The result will be another catastrophic New York City blackout.

Conclusion

Schussler offers some suggestions to avoid this worst-case outcome.  Unfortunately, New York’s Climate Act mandates and policy actions are working against every one of his suggestions.  I believe that the Climate Action Council naïvely believes that there isn’t a potential reliability issue and has resisted requests to confront the rationales for the differences between the Integration Analysis and the NYISO resource outlook.  An open and comprehensive resolution of those differences should be done before the Scoping Plan is finalized but I have seen no indications that will be done.

To paraphrase Schussler: “The Climate Act is promoting a system with less stability, robustness and reliability”.  I cling to the hope that somebody will step up and be responsible enough to address the reliability concerns described so well by Mr. Schussler.  Unfortunately, I am not optimistic because the Hochul Administration has to this point refused to even address the claims of Climate Action Council members that argue that anyone suggesting there are reliability threats in an electric system that relies on renewable energy is misinformation.  That claim is just wrong and is the real misinformation.

Climate Action Council Question: Thruway EV Infrastructure

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 process to develop the implementation plan is well underway.  Unfortunately, Governor Kathy Hochul’s administration does not appear to be focused on reliability and affordability issues and is instead placating the ideologues on the Climate Justice Working Group (CJWG) and particular members of the Climate Action Council.  This post illustrates the problem by looking at one particular question about the electric vehicle (EV) charging infrastructure at the redeveloped New York State Thruway service centers that was brought up at the September 29, 2022 Council meeting (presentation and recording).

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 Climate Act implementation plan and have written extensively on New York’s net-zero transition because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that this supposed cure will be worse than the disease.  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.

I recently described my concerns about the Climate Action Council response to stakeholder comments.  In brief, there is no indication that any comment that raised issues inconsistent with the narrative will be addressed.  Most concerning to me is that there is no apparent realization that it is inappropriate to not reconcile the differences between the Integration Analysis generating resource projections with the estimates made by the New York Independent System Operator (NYISO) in their 2021-2040 System & Resource Outlook report.  Another concern is that the leadership of the Council has paid so much attention to questions and issues raised by some of the more vocal but energy illiterate members of the Council that substantive issues will not be addressed.  Throughout the Council’s Scoping Plan development process, the leadership has allowed those members to go off on tangents to address their particular personal agendas rather than keeping the meetings focused on the overall objective to “inform the state energy planning board’s adoption of a state energy plan”. 

Thruway Electric Vehicle Charging

In my article on the September 29, 2022 Climate Action Council meeting I gave an example of one of the frivolous questions from the Council.  At 22:28 of the meeting recording Peter Iwanowicz asked about the New York State Thruway Service Area Redesign and Redevelopment Project that is presently underway.  He asked if anyone in the administration could give the Council an idea what’s going on with respect to fast charging at the Thruway rest stops stating: “I was personally blown away at driving into one of the newly reopened ones to see no electric vehicle charging there”.  He went on to say that “it’s pretty shocking to me, one as a member of the Council but two as an EV driver not to see chargers in the newly reopened station charging”.  In this case the response was “Let us get back to you”.  I noted that I would address this in more detail in a future post.

The New York State Thruway is a toll road that runs just under 500 miles from New York City north to Albany, west to Syracuse and Buffalo then on to the Pennsylvania line near Erie, PA.   The New York State Thruway Service Area Redesign and Redevelopment Project explains that there is an effort underway to redevelop 27 service areas along the toll road.  It took very little effort to find an answer to the Iwanowicz question.  The website’s Frequently Asked Questions explains that they are working on it:

Additionally, under direct guidance and consultation with the New York Power Authority (NYPA), Empire plans to implement a passenger vehicle electric charging program at all Service Areas to further New York’s goals of reducing emissions and expanding electric vehicle infrastructure across the State.

While they are “working on it” is the simple answer, the real concern of the Climate Action Council should be on the expectations for electric vehicle charging.  As has been the case for every component of the transition plan that I have researched the answers are more complicated and uncertain than implied in the Draft Scoping Plan.  When the electric car mandate came out, I posted an article that was republished at Watts Up With That.  One of the comments on the republished article caught my eye.  Steven Pfeiffer stated:

I’m sure that the New York State officials have carefully taken into account the impact of EV’s on the electrical grid in NY. /SARC

Where it could get interesting is the peak demand with fast chargers, because a lot of them will be needed even with many people charging at low levels overnight or at work.

Let’s say a typical “Quick Mart” has 16 gas pumps. Each gas pump now has a fractional HP pump, maybe a load of 500 Watts per pump. So maybe 8 kW total peak demand.

Replace those (or add) today’s “fast” chargers, say 16 of those at a nominal 250 kW (that may be on the low end, Tesla’s may be 350 kW).

16 x 250 = 4,000 kW or 4 MW of connected load. So suddenly every suburban or rural Quick Mart has an electric load (design peak demand) equal to a paper mill, auto assembly plant, or a medium size college campus.

And if I’m doing my math correctly, a 250 kW charger (with 15% loss) adds a net of about 3.5 kWh per minute to the EV battery, so it will be adding about 12-14 miles range per minute of actual charge time.

Compare that to my sedan, where I can add over 300 miles of range in about two minutes of actual full time, or 150 miles per minute.

Either electric or gas cars will have similar time requirements to pull in, park, initiate the process with a payment method, etc. So the actual “fill time” is what is important.

Most EV proponents assume the in the future, new batteries and chargers will be developed that will make EV charging “as convenient” as filling the tank of an IC engine vehicle.

If that ever becomes reality then the impact on the grid will be monumental – based on simple calculations, the supercharger load will be about 4 megawatts per charger – that is 4 MW for ONE charger supplying ONE car, to be able to match the miles added per unit of time attainable with a conventional IC engine car.

In the following section I am going to adapt his analysis (spreadsheet) for an example service center. Note, I did not double check his assumptions.  I used the New York program to develop electric vehicle infrastructure, Evolve NY electric chargers for more information.  I presume this NYPA program will be combined for the service center implementation of passenger vehicle charging stations.  The description of these charging stations states that charging speeds range between 150-350kW. 

Warners Service Center Electric Vehicle Charging

Google Maps satellite view of NYS Thruway Warners Service Center

I arbitrarily chose to look at the closest service center to my home primarily because the re-development has not started there yet.  There are ten automotive fuel pumps and one truck pump.  I counted the parking spots in the automotive lot and found that there were 154 parking spaces: 6 handicapped, 97 spaces in the interior and 51 spaces on the edge where I presume it would be possible to install an electric charger.

Steven Pfeiffer’s example considered 16 gas pumps but Warners only has 10. Each gas pump has a fractional HP pump, with “maybe a load of 500 Watts per pump”. Warners has a peak load 5 kW.  The common comparison metric for load is a typical household which is 1 kWh/day with a peak load of 100kW.  In this case the peak load at the service center is equivalent to 5% of a typical household.

Pfeiffer’s example compared those gas pumps to a “fast” charger with a charging rate of 250 kW.  That works out to a peak load of 2,500 kW which is equivalent to the peak load of 25 households.  Note, however, that the Evolve NY chargers include 350 kW chargers.  That works out to a peak load of 3,500 kW and that is equivalent to the peak load of 35 households.

Travelers don’t really care about the electricity requirements.  Their main concern is how long it takes to fuel up.  For this analysis assume that an internal combustion engine (ICE) automobile gets 25 miles to the gallon, has a 12-gallon tank (so it has a 300-mile range), and that a motorist would fill up when the tank is 1/6 full so that 10 gallons would be pumped.  If the gas pump fills at 5 gallons per minute, then pumping takes 2 minutes and 250 miles are added to the range.

Pfeiffer notes that if he is doing his math correctly: “a 250-kW charger (with 15% loss) adds a net of about 3.5 kWh per minute to the EV battery, so it will be adding about 12-14 miles range per minute of actual charge time.”  Assuming that the charger adds 13 miles of range per minute of charging time it will take 19.2 minutes to get the same mileage with the 250-kW charger.  I assumed that all the values were proportional for the 350-kW charger and found that it will take 13.7 minutes to get 250 miles of additional range.

Cars will have similar time requirements to pull in, park, initiate the process with a payment method and do everything else necessary to fuel.  I assume that those requirements add three minutes to the car fill up.  Using these assumptions an ICE automobile can get filled up in five minutes, an EV can get charged in 22 minutes with a 250-kW charger and 17 minutes with a 350-kW charger.

I maintain that the question about the availability of charging systems at the Thruway service center was inappropriate because it is so limited.  I believe it would be more appropriate for the Climate Action Council to be discussing bigger picture expectations.  In this instance it would be more appropriate to discuss whether the EV plan for the Thruway service center redevelopments should be to provide equivalent re-fueling capabilities such that the same level of service is available in the future.  The existing Warners service center has ten pumps and can fuel 600 vehicles per hour.  In order to match that hourly rate, the service center would need 44 250-kW chargers or 33 350-kW chargers.

In order to provide that level of service the peak load will increase.  For the 250-kW chargers the peak load is 11,115 kW which is equivalent to 111 households.  For the 350-kW chargers the peak load is 11,550 kW which is equivalent to 116 households.  At this point complicating questions about the electric distribution service availability come up.  At a minimum, additional transformers will be needed.  Many of these service centers are in rural areas and additional upgrades may be required for the power supply.  The Council should know whether those complications are considered in the Draft Scoping Plan.

Pfeiffer points out that “Most EV proponents assume the in the future, new batteries and chargers will be developed that will make EV charging “as convenient” as filling the tank of an IC engine vehicle.”  He explains that “If that ever becomes reality then the impact on the grid will be monumental – based on simple calculations, the supercharger load will be about 4 megawatts per charger – that is 4 MW for one charger supplying one car, to be able to match the miles added per unit of time attainable with a conventional IC engine car”.  In this example that would increase the peak load at the service center to 40,000 kW which is equivalent to 400 households.  At that level I would expect that a new substation might be required.

In addition to the power constraints, installation of EV charging stations needs to consider site constraints.  Recall that there are 154 parking spaces: 6 handicapped, 97 spaces in the interior and 51 spaces on the edges.  Here is another appropriate overview discussion for the Council.  There is a tradeoff between parking available for people who need to attend to personal needs (restaurants and bathrooms) and for chargers.  At some point in the future placing EV chargers in the current fueling area will be possible but that transition has to be planned.  The ultimate question is how long and whether New York intends to provide fossil fuels to out-of-state visitors and grandfathered vehicles owned by residents.

Google Maps Satellite View of NYS Thruway Warners Service Center Parking Area

On a practical level I assume that that the preferred location for chargers would be on the edges.  Depending on the fast charger type between 33 and 44 chargers provide equivalent service and there are 51 spaces on the exterior.  The first practical question is whether additional parking spots are needed to respond to the loss of spots to chargers.  I imagine there will also be installation issues for the electric power and infrastructure needed for the charging points.  Another issue is whether there should be provision for charging services for vehicles towing trailers.

The bigger challenge is New York winters.  One issue is that the charging efficiency and the vehicle range are both reduced in cold weather.  The current re-fueling capabilities are not seasonally dependent.  Should there be additional chargers added because more people will need to stop to charge and it will take charging longer in the winter?  The bigger issue in my opinion is snow.  While it is more practical to put the charging stations on the edges of the parking lot that is also the only place that snow removed from the lot can initially go.  Parking lot designs that do not take into account snow removal can cause safety issues and certainly affect the time necessary to clean up after snow storms.

Discussion

On the list of issues confronting the state’s energy transition this particular question is pretty low on the priority list.  We have already seen the leadership of the Council claim that there is too little time to reconcile the electric grid projections made by the NYISO with the Integration Analysis.  Nevertheless, a Council member thinks that it is appropriate to cut into the precious little time available for the Council to consider the entirety of the energy transition with his personally biased question.  More importantly this is just an example of a recurring theme throughout the Scoping Plan process.  Any question from the CJWG and certain members of the Council gets a response no matter how removed from the issue at hand. 

I highlighted this particular question because it illustrates my bigger concern.  The Climate Action Council should be focused on big picture items that affect not only the net-zero transition but also the public’s use of energy.  Instead, the leadership has allowed the membership to go off on tangents like this.  In this example, the relatively trivial issue is what can be expected at the Thruway service areas and over-arching questions arose.  What does the Council recommend for future planning: minimizing resources required which increases public inconvenience or the opposite?  How does the Draft Scoping Plan address these tradeoffs?  What is the expectation for resources like this during the transition?  Unfortunately, those big picture items are not getting addressed while Staff tries to track down answers to questions like this.

There are many over-arching net-zero transition issues that the membership of the Council seems OK ignoring as the Scoping Plan development process unfolds.  I am particularly concerned that the Draft Scoping Plan only provides aggregated costs relative to societal benefits and there are significant unresolved differences between the generation resource projections for the net-zero transition between the Integration Analysis and the NYISO Resource Outlook.  It is not clear that the aspirational technology deployments proposed in the Draft Scoping Plan are feasible with respect to affordability and reliability.  I believe the Council should define their expectations for those two aspects.  What does affordable mean; how should it be tracked as the transition unfolds to protect the low- and middle-income citizens who are least able to afford regressive energy cost increases; and what does the Scoping Plan project will happen in this regard?  Reliability is a bigger concern because it directly affects public safety.  Does the Council believe that current reliability standards must be maintained in the future?  How will that be enforced?  In particular, if the organizations responsible for reliability believe the current reliability standards are threatened what is the plan?

Conclusion

I have shown that even a trivial question about New York State Thruway service centers raises more important general issues that should be the focus of the Climate Action Council.  Not so long ago, affordability and reliability were the paramount concerns for the New York energy system.  At that time the idea that the existing system would be dismantled without proven technology in place would be dismissed out of hand.  It was generally accepted that, for example, natural gas could be used a bridge fuel until the aspirational dispatchable emission-free resources could be tested at the scale needed, perform like a natural gas fired generating unit, and provide power at a similar cost, was generally accepted as a rational approach. The analogy for the current approach is that proponents including some members of the Climate Action Council want to jump out of a perfectly good airplane without a parachute because they assume that the concept of a parachute will be developed, proven technically and economically feasible, and then delivered in time to provide a soft landing.  The risks of the current approach are not even being discussed by the Council as they fritter away time dealing with politically expedient Integration Analysis updates and personal agenda items of the membership.  I am not optimistic about the future.

Climate Action Council Response to Comments Is Worse Than I Thought


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.  I have not posted recently on the Climate Action Council response to Draft Scoping Plan comments because I have been on vacation and have not bothered to follow the most recent meetings.  Based on what I observed at the September 29 meeting (presentation and recording), there appears to be no consideration of any comments that are inconsistent with the Hochul administration transition narrative.

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 Climate Act implementation plan and have written extensively on New York’s net-zero transition because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that this supposed cure will be worse than the disease.  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.

Last May I posted an article describing the composition, responsibilities and consideration requirement mandates in the Climate Act related to the Climate Action Council.  Based on the activities of the Council from the start of 2022 I believe that the Climate Action Council is going through the motions of addressing public comments.  If the public comments were truly going to be considered then I think it would have been appropriate to make comment distillation an on-going process from the get go.  At the time I also said I didn’t see why the comments had not been posted to the website.  It would be relatively easy to just provide a list of comments as they were received and there is no reason why they couldn’t also list the comments in some broad categories.  As I write this on October 9, 2022 three months after the close of the comment period the comments have not been posted to https://climate.ny.gov/ as promised last May.  This post highlights further indications of the gameplan from the September 29, 2022 Climate Action Council meeting.

Reliability

I have spent enough time educating myself about the operations of the electric grid over the last 40 years that I am well aware of reliability challenges for the New York electric system.  More importantly, I know people who are subject matter experts and they all share my concerns that the Integration Analysis and the Draft Scoping Plan have not adequately addressed the feasibility of the transition in the mitigation scenarios.  On the other hand, some of the more vocal members of the Council have downplayed reliability as a concern and have gone so far to claim that those concerns are misinformation

I have previously written that 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 New York Independent System Operator (NYISO) 2021-2030 Comprehensive Reliability Plan (CRP) report (appendices) released late last year and the difficulties raised in the report are large. 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.  Recently I wrote about the “For discussion purposes only” draft of the 2021-2040 System & Resource Outlook report described in the previous article and the concerns raised.  Most recently, I detailed the differences between the Resource Outlook and the Draft Scoping Plan Integration Analysis and recommended that those differences be reconciled in a public forum.

At the September 29 Climate Action Council meeting Gavin Donohue asked about dispatchable emissions-free resources (DEFR) at 1:05:25 of the meeting recording.  DEFR refers to a generating resource that can provide power as needed to keep the lights on.  It is a critical component but there is no commercially available resource that meets the specifications.  The main point of my articles described in the previous paragraph is that the organizations responsible for electric system reliability have raised questions that have not been addressed including DEFR viability.  Donohue apparently agrees with me and asked about the risks of not specifying exactly how DEFR will be used in the transition and how that could affect costs.  The response by the lead modeler, Carl Mas, was that they did look at it at the end of last year and found that the costs would change.  He acknowledged that it has not been resolved whether the hydrogen would be used in combustion turbines or in fuel cells and that should be resolved.  Donohue pressed him that it needs to be resolved as part of the process.  Mas said that it was a previous sensitivity from last year and it is “good to bring it back up”.

Later in the same meeting Dennis Elsenbeck pointed out (2:58:40 of the meeting recording)  that the NYISO Resource Outlook raised issues that haven’t been addressed in the Draft Scoping Plan.  He asked how do we reconcile what the subject matter experts are saying versus what’s in the scoping document.  He also asked if that is a conversation that we need to have during this process or are we beyond that?  The Climate Action Council Executive Director, Sarah Osgood, said “it would be interesting to hear from other council members and said she didn’t know if the modeling analyses were comparable. She said that “at this late stage” it might be difficult to compare the analyses and wasn’t sure whether it would be worthwhile. 

Carl Mas said they could determine whether there is enough time to do at least a little side by side analysis of some of the key issues.  At this point he said there is uncertainty as to, for example, imports vary between the analyses.  He noted that the NYISO did adopt one of the Integration Analysis load scenarios in their analysis.  He said the Integration Analysis team worked very hard to ensure that there was “at least some commonality between the scenarios”.  He did admit that not all aspects were similar but suggested that they might be able to find some time to evaluate differences between scenarios and the projections. 

Elsenbeck pointed out that stakeholders outside of the Hochul Administration see the NYISO reports and “the first thing that comes to mind is my resiliency is going to go to hell”.  He said the Council could just not look the other way.  Mas responded that there is agreement that by 2040 there is a need for firm dispatchable resources but ignored the implications of the state’s reliability depending on an unproven resource.  Then he went on to claim that it is critical to work with the NYISO.  Elsenbeck then pointed out that the Council is going to be voting on a Final Scoping Plan that has not been fully vetted with the NYISO.

In my opinion, these conversations are very troubling.  At no time during his presentation or his questions did the Integration Analysis lead modeler mention any issues raised in the stakeholder comments.  Were it not for the fact that my comments and the comments submitted by the NYISO and New York State Reliability Council did raise substantive issues I would have to believe that all the stakeholder comments agree that the unelected bureaucrats who have no reliability responsibilities have produced a perfect transition plan that can guide the future New York energy system. 

Sarah Osgood’s response to the Elsenbeck question is especially troubling.  The Executive Director of the Climate Action Council didn’t know if the generation resource modeling analyses critical to the success of the transition plan were comparable to the analyses by the NYISO.  She said that “at this late stage” it might be difficult to compare the analyses and wasn’t sure whether it would be worthwhile.  This demonstrates an astounding lack of awareness by the Climate Action Council leadership that has frittered away months without addressing this issue.  Now they claim they cannot reconcile the results because it is too late.  You can bet the ranch that when this implodes that the NYISO will be blamed for not speaking up. 

Integration Analysis

Carl Mas gave an update on the Integration Analysis at 24:25 of the meeting recording.  Ostensibly the updates address the impact of the Inflation Reduction Act (IRA) as well as analyses that look at a high fuel price sensitivity and a high technology cost sensitivity.  In order to prove the benefits are greater than the costs the focus is on the net benefits metric especially as it relates to their societal cost benefit test. 

The following slide summarizes the IRA integration analysis update.  The modeling addresses two key aspects: what IRA funds may be available that could come to New York to offset costs and to translate that into how it “layers into our net benefit or overall analysis”.  I interpret that to mean that because of the emphasis on net benefits that means that the analysis assumes that IRA funds directly offset New York costs so the net benefits increase. 

The modeling updates purportedly will also consider the ramifications of IRA funding on adoption technologies.  For example, the IRA might fund more electric vehicle subsidies so that the adoption rate will increase.  One of my criticisms of the Draft Scoping Plan is that there are enormous presumptions that the public will acquiesce to, for example, purchase more expensive and less suitable electric vehicles simply because the Climate Act says they have to.  Any increase in adoption levels because there is more money available increase this type of speculation level further.

While I have not listened to every minute of every meeting, I am pretty sure that Carl Mas has not suggested that there were any relevant stakeholder comments on the Integration Analysis that need to be addressed.  I provided extensive comments on the Integration Analysis costbenefit analysis and recommended that the Integration Analysis provide the costs, benefits, and expected emission reductions for every control measure proposed.  There are three possibilities why those comments have not been raised: the comment reviewers never provided any relevant comments to the modelers, the comments were received and have been ignored, or that they won’t be mentioned until the end so the response will be there is insufficient time to address them.  All three excuses are unacceptable given the responsibilities of the Climate Action Council that are mandated in the Climate Act.

Implementation

Based on comments from the leadership of the Climate Action Council their perception of the Scoping Plan is that it is just an outline of how the future energy system will transition to meet the net-zero targets.  I have heard repeated suggestions that particular implementation issues didn’t need to be addressed as part of this process because there will be an opportunity for stakeholder input when regulations are proposed that implement the changes needed.  The announcement that New York is going to implement a 100% zero-emission vehicle mandate by 2035 raises the question whether that is an appropriate approach.

At 12:29 of the meeting recording Jared Snyder announced that on the morning of this meeting that Governor Hochul announced that the Department of Environmental Conservation “will adopt the Advanced Clean Car rule by the end of the year.  That rule will require all sales of light-duty cars and trucks to be zero emissions by 2035 which means that all vehicles have to be either battery electric of fuel cell powered.  He said “that rule implements legislation that Governor Hochul signed a year ago in September 2021 that required 100% sales of electric vehicles by 2035”.  He also said that “it implements a recommendation of the Draft Scoping Plan to adopt the advanced clear cars rulemaking”.   

This portends what I predict will be the future for the regulatory process.  In this instance there is a law in place that mandates going forward whatever the cost, whatever the impacts, and whatever the feasibility.  What I think will happen is that when other regulations are proposed the rationale will be “it was a recommendation in the Scoping Plan so it has to be done” whatever the cost, impacts, or feasibility.  The fact that the Scoping Plan did not address the cost, impacts, or feasibility is immaterial to this line of reasoning and will be conveniently forgotten in the response to comments.

Response to Questions

The focus of the Hochul Administration response to comments has been on the concerns of the Climate Justice Working Group (CJWG) and particular members of the Climate Action Council.  For example, at 22:28 of the meeting recording Peter Iwanowicz asked about the New York State Thruway Service Area Redesign and Redevelopment Project that is presently underway.  He asked if anyone in the administration could give the Council an idea what’s going on with respect to fast charging at the Thruway rest stops stating: “I was personally blown away at driving into one of the newly reopened ones to see no electric vehicle charging there”.  He went on to say that “it’s pretty shocking to me, one as a member of the Council but two as an EV driver not to see chargers in the newly reopened station charging”. 

On the list of issues confronting the state’s energy transition this is pretty low on the priority list.  We have already seen the leadership of the Council claim that there is too little time to reconcile the electric grid projections made by the NYISO with the Integration Analysis.  Nevertheless, a Council member thinks that it is appropriate to cut into the precious little time available for the Council to consider the entirety of the energy transition with his personally biased question.  More importantly this is just an example of a recurring theme throughout the Scoping Plan process.  Any question from the CJWG and certain members of the Council gets a response no matter how removed from the issue at hand. 

In this case the response was “Let us get back to you”.  Left unsaid is we don’t have that information at our finger tips because we are trying to consider the entirety of the energy system.  The ultimate response may suggest that this is indicative of a bigger problem but I bet that the Administration answer will not raise that type of issue.  I will address this in more detail in a future post but a quick read of the summary of the New York State Thruway Service Area Redesign and Redevelopment Project shows that the Frequently Asked Questions explains that they are working on it:

Additionally, under direct guidance and consultation with the New York Power Authority (NYPA), Empire plans to implement a passenger vehicle electric charging program at all Service Areas to further New York’s goals of reducing emissions and expanding electric vehicle infrastructure across the State.

Conclusion

From what I have seen at the recent Climate Action Council meetings the promise to consider public stakeholder comments on the Draft Scoping Plan is being ignored.  There is no indication that the Hochul Administration intends to reconcile the differences in the generating resource projections in the Integration Analysis and any of the NYISO reports or the risks involved in depending upon a resource that is not currently available.  It is scary that the leadership of the Climate Action Council does not even appear to comprehend that addressing those issues would be appropriate and even if they can be convinced now, they will plead that there is insufficient time.  Furthermore, it is not clear to me that the Administration even intends to tell Council members that there any comments that question any of the fundamental assertions in the Draft Scoping Plan.

It is clear that the Hochul Administration’s primary goal in the Integration Analysis is political posturing – in particular to “prove’ that the benefits are greater than the costs.  It is also clear that the leadership of the Council is catering to particular members of the Climate Action Council that represent the interests of political supporters.  Given that Council legal mandate is to prepare a plan “achieve the State’s bold clean energy and climate agenda” the focus should be on that instead.

The legal mandate for the Scoping Plan is that it “shall inform the state energy planning board’s adoption of a state energy plan”.  The Climate Action Council membership is generally lacking the background, experience, and education to inform technical matters such as the fuel mix of the future generating system. Thomas Sowell said “It is hard to imagine a more stupid or more dangerous way of making decisions than by putting those decisions in the hands of people who pay no price for being wrong”.  To ignore the analyses of the subject matter experts who are responsible for reliability is insane.

As noted in this article I have written multiple articles about the differences in generating resource projections and dependency upon the magical dispatchable emissions-free resource.  When I submitted my draft scoping plan comments that explained why I believe the differences between the Draft Scoping Plan and the NYISO analyses have to be addressed in a public forum I thought it inconceivable that the response to comments would ignore the state’s experts.  At no time did I believe that the response to comments would meaningfully address my personal comments but ignoring the state’s experts is why I believe the response to comments is going to be worse than I thought possible.

Comparison of NYISO Resource Outlook and Draft Scoping Plan Generating Resource Projections

The final version of the important New York Independent System Operator (NYISO) 2021-2040 System & Resource Outlook that addresses New York’s Climate Leadership and Community Protection Act (Climate Act) was released on September 22, 2022.  This post compares the projections for resources needed to meet the Climate Act targets in this report and the Draft Scoping Plan. 

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 Climate Act implementation plan and have written extensively on New York’s net-zero transition because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that this supposed cure 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 for the 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 Climate 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.

I have previously written that 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 and the difficulties raised in the report are large. 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.  Recently I wrote about the “For discussion purposes only” draft of the 2021-2040 System & Resource Outlook report described in the previous article and the concerns raised.  It is amazing to me that these issues continue to be ignored.

Description of Resource Outlook and Draft Scoping Plan Mitigation Scenarios

This section compares two alternate approaches to meeting the Climate Act net-zero transition requirements. 

The NYISO Resource Outlook report includes two scenarios that “reflect full achievement of the Climate Act targets”. 

Outlook 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.

Outlook 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).

The Resource Outlook describes the scenarios:

In both Policy Case scenarios, a significant amount of land-based wind capacity was built by 2040. The model selected land-based wind due to its assumed capital cost, energy output, and capacity ratings. In both scenarios, land-based wind capacity builds to the assumed capacity build limits imposed (~16 GW).

In both scenarios, a significant amount of capacity from renewable generation and dispatchable emission free resources (DEFRs) is projected by 2040, with the most installation forecasted in the last five years, to help offset the projected fossil-fueled generation retirements. Dispatchable emission free resources are a proxy generator type assumed for generation expansion in the Policy Case to represent a yet unavailable future technology that would be dispatchable and produces emissions-free energy (e.g., hydrogen, RNG, nuclear, other long-term season storage, etc.). As noted above, all existing fossil-fueled generation (~26 GW) was modeled as retired by 2040 due to the CLCPA requirement of a zero emissions grid by 2040. In addition, in Scenario 2 the age-based retirement assumption captured the retirement of 12 GW, nearly half the fossil fleet. The models expanded to approximately 111 GW of total capacity for Scenario 1 and 124 GW of total capacity for Scenario 2, inclusive of NYCA generators, BTM-PV, and qualifying imports from Hydro Québec. This level of total installed capacity would be needed in 2040 to satisfy the state policy, energy, and resource adequacy constraints for Scenario 1 and Scenario 2, respectively. Of this total, approximately 85 GW to 100 GW represent generation expansion for Scenario 1 and Scenario 2, respectively, beyond the 9.5 GW planned through state contracts.25 For comparison, the Contract Case has approximately 51 GW of total installed capacity by 2040.

In general, resources take years from development to deployment. By year 2030, roughly seven years from the publication of this report, an estimated 20 GW of additional renewable generation needs to be in-service to support the energy policy target of 100% zero-emission generation by 2040. For reference, 12.9 GW of new generation has been developed since wholesale electricity markets began more than 20 years ago in 1999. Over the past five years, 2.6 GW of renewable and fossil-fueled generators came on-line while 4.8 GW of generation deactivated26. This Outlook demonstrates the need for an unprecedented pace of project deployment, which will require significant labor and materials available for New York over a long period of time.

Offshore wind capacity buildout remains near the 9 GW policy objective through 2040 for both scenarios. This outcome results primarily from the assumed high capital cost of offshore wind technology in the model, which was the highest cost renewable technology available. Additionally, considering the declining marginal capacity reliability value curves assumed, offshore wind at the levels modeled is an inefficient resource to meet peak capacity needs and Locational Capacity Requirements because the capacity contribution of intermittent renewable resources declines as more are added to the system.

Overall, results for Scenario 2 showed a higher level of renewable buildout than Scenario 1, most notably in utility-scale solar capacity, and had a different projection of the capacity expansion throughout the study period as compared to Scenario 1 for all generator types. The main factors for these differences are the assumptions for load forecasts and differences in generator types eligible for capacity expansion as well as the maximum allowable capacity builds by technology type modeled between the two scenarios. One major difference in Scenario 2 is that a reduced land-based wind capacity limit was used, which changed the projection of capacity builds for all types. Notably, the projections for offshore wind were higher earlier in the model horizon (e.g., 2030) in Scenario 2 as compared to Scenario 1 to help achieve the 70 x 30 target.

Two primary drivers are attributable to increased renewable resources in capacity expansion: (1) high operating cost of dispatchable generators, and (2) low capital costs for renewable generators. High fuel (e.g., natural gas prices, clean DEFR fuel prices) and/or high CO2 emissions prices result in significant decrease in fossil generation and subsequent increase in renewable generation earlier than otherwise projected. Low capital costs for renewable generators result in capacity builds much earlier than otherwise projected, and often an increase in the total amount of capacity built.

In terms of the zonal location for capacity buildouts determined by the capacity expansion model, limitations were imposed on the zonal level as to which generator type(s) could build in each zone. For instance, land-based wind was eligible for expansion in upstate regions (Zones A-G), utility-scale solar was eligible for expansion in upstate regions and Long Island (Zones A-G and Zone K), and offshore wind was eligible for expansion in New York City and Long Island (Zones J and K). Dispatchable emission free resource (DEFR) technologies and battery storage were included as generation resource options in all NYCA zones.

The Draft Scoping Plan includes a reference case and four mitigation scenarios.  The first mitigation scenario only includes the initial recommendations of the Climate Act Advisory Panels but it did not meet the targets.  The three remaining mitigation scenarios meet or exceed GHG emission limits and achieve carbon neutrality by 2050.  They all include:

  • Zero emission power sector by 2040
  • Enhancement and expansion of transit & vehicle miles traveled (VMT) reduction
  • More rapid and widespread end-use electrification & efficiency
  • Higher methane mitigation in agriculture and waste
  • End-use electric load flexibility reflective of high customer engagement and advanced technologies

The three mitigation scenarios that meet the Climate Act targets address concerns raised by the Climate Action Council membership:

Draft Scoping Plan Scenario 2: Strategic Use of Low-Carbon Fuels: Includes the use of bioenergy derived from biogenic waste, agriculture & forest residues, and limited purpose grown biomass, as well as green hydrogen, for difficult to electrify applications

Draft Scoping Plan Scenario 3: Accelerated Transition Away from Combustion: Includes Low-to-no bioenergy and hydrogen combustion and accelerated electrification of buildings and transportation

Draft Scoping Plan Scenario 4: Beyond 85% Reduction:  Accelerated electrification + limited low-carbon fuels: This scenario adds additional VMT reductions; additional innovation in methane abatement; and avoids direct air capture of CO2

I prepared Draft Scoping Plan comments on these mitigation scenarios that includes descriptions and a comparison of the differences between them based on Appendix G of the Draft Scoping Plan.  Unfortunately, the documentation is so poor that it does not explain the rationale for the generation sector differences described in the next section.

Comparison of Scenarios

The following table provides an overview of the capacity (MW) and energy generated (GWhr) generating resources in the five scenarios described above.  Because it is difficult to read the table I have also provided a spreadsheet with the table and the input data extracted from the NYISO and Integration Analysis spreadsheets.  I will compare each of the resource categories in the following from 2019 up to 2040 when the state’s electric grid is supposed to be zero-emissions.

The first resource category is nuclear.  There is no significant difference in the capacity and power generated between the scenarios.  They all reflect the irrational shutdown of over 2,000 MW at the Indian Point Nuclear Station and continued operation of the remaining nuclear facilities to 2040.  Despite the fact that nuclear is the only dispatchable emissions-free generating resource that can be scaled up neither analysis believes that additional nuclear power generation could be part of New York’s future.

There are interesting differences between the scenarios in the fossil generation resource category.  Resource Outlook Scenario 1 reduces fossil capacity 19% from 2019 to 2030, keeps it the same in 2035, and then goes to zero in 2040.  Resource Outlook Scenario 2 reduces fossil capacity 33% from 2019 to 2030, reduces it another 9% by 2035, and then goes to zero in 2040.  Note that the energy produced is the same for both scenarios in 2030 but in 2025 Scenario 1 is reduced 8% more. So even though there is more fossil capacity in 2035 in Scenario 1 it is used less.  This is problematic for me because it means that the production resource model is treating the fossil resources differently between the scenarios.  It is not clear what would cause this difference.

The Integration Analysis scenario fossil projections raise similar concerns.  Scenario 2, Accelerated Transition from Combustion, capacity and generation is higher in 2030 compared to the other two scenarios but then does show a marked decrease in 2035.  If it is accelerated, why is it higher in 2030?  Integration Analysis Scenarios 2 and 4 are comparable to Resource Outlook Scenario 1 and Integration Analysis Scenario 3 is comparable to Resource Outlook Scenario 2.  I assume that this reflects similar assumptions by the analysts at NYISO and NYSERDA.

All the Hydro category scenarios show an increase in capacity between 2019 and 2030.  I assume that a large part of that is due to the Clean Path New York (CPNY) and Champlain Hudson Power Express projects. 

The remaining categories are the key parts of the transition.

The land-based wind (LBW) resource category is the first where there are significant differences between the Resource Outlook and the Integration Analysis scenarios.  Resource Outlook Scenario 1 increases LBW capacity 3.1 times whereas Scenario 2 only doubles the amount in 2030.  Integration Analysis Scenario 2 also doubles capacity by 2030, Scenario 3 goes up 2.7 times, and Scenario 4 goes up 2.4 times.  The differences between scenarios disappear by 2035 but the Resource Outlook projects land-based wind capacity will be 53% higher than the mitigation scenarios in the Integration analysis with 42% more generation.

The NYISO production resource model apparently does not think that offshore wind is a cost-effective option because both scenarios do not increase the projected capacity significantly beyond the Climate Act mandate of 9,000 MW.  On the other hand, the Integration Analysis scenarios nearly double the amount of offshore wind resources projected.   Overall, the Resource Outlook offshore wind capacity is 40% lower than the average of the Integration Analysis scenarios and generation is 43% lower. 

For the solar resource there is a significant difference between Resource Outlook Scenario 1 and all the other scenarios.  The capacity is 63% lower and the generation is 71% lower than the averages of the other scenarios.  In 2040 the capacity factor for the projected resource capacity and expected generation is a reasonable 15% for Resource Outlook Scenario 1 whereas Resource Outlook Scenario 2 is 17% but 21% for the Integration Analysis scenarios.  In my opinion I question why there is a difference for the Resource outlook scenarios. I don’t think that the Integration Analysis expectation that the solar capacity factor can bas high as 21% in 2040 is reasonable for New York’s latitude and snowfalls.

The energy storage resource category capacity values are pretty much the same all the scenarios.  However, the generation projections are presented differently so that it is not possible to compare them.

As noted in the Resource Outlook, the Dispatchable Emissions-Free Resource (DEFR) category is a proxy generator type that represents a yet unavailable future technology that would be dispatchable and produces emissions-free energy (e.g., hydrogen, RNG, nuclear, other long-term season storage, etc.).  The DEFR capacity and generation is substantially higher in Resource Outlook Scenario 1 and all the other scenarios.  Even Resource Outlook Scenario 2 is higher than the Integration Analysis scenarios.  In addition, Resource Outlook Scenario 1 capacity factor is 9% whereas the others are all around 2%.

Getting to 100%: Six strategies for the challenging last 10%

My most recent post described a recent paper, Getting to 100%: Six strategies for the challenging last 10%, that provides a concise evaluation of six zero-emissions technologies.  It is instructive to consider these strategies in the context of these projections.  The authors from the National Renewable Energy Laboratory provided the following summary of the challenge:

Meeting the last increment of demand always poses challenges, irrespective of whether the resources used to meet it are carbon free.  The challenges primarily stem from the infrequent utilization of assets deployed to meet high demand periods, which require very high revenue during those periods to recover capital costs.  Achieving 100% carbon-free electricity obviates the use of traditional fossil-fuel-based generation technologies, by themselves, to serve the last increment of demand—which we refer to as the ‘‘last 10%.’’

The Getting to 100% paper describes six strategies that are summarized in the following table.  Note that the strategies are compared to an ideal solution.  Ideally, the solution for peak loads would have low capital expenses and low operating expense, low resource constraints, be technologically mature, have low environmental impacts, and work well with other resources.  Needless to say, no technology comes close to meeting those ideal conditions.  The authors note that: “Although existing studies generally highlight the same fundamental causes associated with the last 10% problem, there is a lack of consensus on the preferred strategies for meeting this challenge. This is not surprising, given the diversity of possible solutions and the speculative nature of their costs, given their early stage of development.”

The Getting to 100% paper described strategies for the last 10% challenge which for this resource refers to increasing the use of wind, solar, and storage to cover what I call the ultimate problem.  Both the Resource Outlook and the Integration Analysis models predict that the primary resource for this challenge will be seasonal storage using DEFR.  Although there are mentions of the other strategies the emphasis is on the dispatchable emissions-free resource.  The proxy technology in the Integration Analysis is hydrogen although the production and use options are not specified. 

There are other options for seasonal storage.  The report notes:

This group of technologies is not well defined, but it could include batteries with very low-cost electrolytes capable of longer-than-diurnal durations. Because of the requirement for very low-cost energy storage, most seasonal storage pathways focus on hydrogen, ammonia, and other hydrogen-derived fuels stored in geologic formations.

Ultimately the Getting to 100% paper evaluates hydrogen used either in a combustion turbine or a fuel cell for electricity production.  In the New York implementation plan the dispatchable emissions-free resource (DEFR) place holder is hydrogen produced using wind and solar.  There are members of the Climate Action Council that insist that the hydrogen has to be used in a fuel cell rather than a combustion turbine because combustion causes emissions.

The Draft Scoping Plan calls for the use of so-called “green hydrogen” whereby hydrogen is produced by a carbon-free process of electrolysis from water. The Draft does not include a feasibility analysis of the production and use of hydrogen in some form as the placeholder technology for DEFR.  The Resource Outlook does not specify a specific technology but emphasizes the risks of depending upon an unproven technology: “Both scenarios include significant DEFR capacity by 2035, but it is important to note that the lead time necessary for commercialization, development, permitting, and construction of DEFR power plants will require action much sooner if this timeline is to be achieved.”

I submitted a Draft Scoping Plan comment specifically addressing this presumption.  I do not believe that the Integration Analysis correctly accounted for the energy needed to produce the hydrogen needed for the DEFR requirement. I think that there will be siting issues for all the fuel cells, electrolyzers, pipelines, and hydrogen storage facilities.  .  In the exisitng system the generating sources assigned for peaking power for this reliability requirement used the cheapest technology available (simple-cycle gas turbines).  Meeting this requirement in the future using the hydrogen DEFR resource will be using the most expensive generating technology available.  The capacity factors for this resource in the Draft Scoping Plan are 2% for all mitigation scenarios so it will be difficult to cover these costs for the short periods needed.  I guarantee the usual suspects will complain about profiteering when the costs spike during these periods.

In addition, the Getting to 100%: Six strategies for the challenging last 10% report notes that “current high-cost electrolyzers need to operate almost continuously to recover their capital expense”.  The Draft Scoping Plan plans to use intermittent wind and solar that preclude any continuous processes.  That issue has been completely ignored in the Draft Scoping Plan. 

Recall that there are members of the Climate Action Council that insist that hydrogen used for electric generation has to be used in fuel cells.  The Getting to 100% paper addresses fuel cells:

Fuel cells have diverse applications, but their use for bulk power generation is currently limited. Given the range and scale of applications especially for transportation, substantial capital cost reductions for fuel cells are possible. With low capital costs for combustion turbines and future potential cost reductions for fuel cells, the economic case for hydrogen mainly hinges on lowering the cost of electrolytic hydrogen.

According to Table 1 in the Getting to 100% paper, it really is a stretch to say that there are any positive aspects for using hydrogen.  For hydrogen used in combustion turbines the report claims low capital expenses (apparently referring only to the combustion turbine but not including the generation of the hydrogen itself), medium operating expenses and resource constraints, and concerns about hydrogen storage and transport as well as competition for using hydrogen in other sectors.  For hydrogen used in fuel cells there is a potential for low capital expenses, high operating expenses, low resource constraints (apparently referring only to the fuel cell and not assuming that the hydrogen is generated with wind and solar resources), low technological maturity, and the same other considerations as hydrogen used in combustion turbines.

Discussion

This analysis found significant differences between the projections for land-based wind, offshore wind, energy storage and dispatchable emissions-free resources in the Resource Outlook and the Integration Analysis.  I think that those differences should be discussed in an open forum.  Most importantly to New York citizens the costs associated with the different options have to be made available from the NYISO and Climate Action Council.  I am pretty sure costs account for the differences in the NYISO scenarios but without that information we cannot be sure.  Most importantly, the feasibility of a dispatchable emissions-free resource has to be addressed and the projected DEFR utilization difference between Resource Outlook Scenario 1 and all the other scenarios reconciled.  I also believe that both organizations have to address the economic viability challenge of DEFR stemming from the infrequent utilization of those assets deployed to meet high demand periods, which require very high revenue during those periods to recover capital costs. 

Moreover, the forum should also address implementation concerns raised by the New York State Reliability Council in their Draft Scoping Plan comments.  They made the point that the new resources required are enormous and also raised other concerns:

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.

One final point about the modeling analyses.  The programs are proprietary and the documentation is sparse so it is not possible to fully understand the results.  For example, the Integration Analysis Accelerated Transition Away from Combustion scenario has higher fossil generation projections in intermediate years than the other scenarios.  Untangling the reason for that would be a challenge.  I believe that the models can create projection differences as much by input tweaks as by the projection algorithms.  Because the models are so complicated and include so many input parameters the modelers have to be careful to limit changes between scenarios that could affect the outcomes.

Conclusion

I have repeatedly made the point that the differences between the NYISO projected resources and the Integration Analysis projections need to be reconciled.  This post attempted to explicitly list those differences.  Unfortunately, this concern does not seem to be shared by the Climate Action Council and the Hochul Administration.  It is only a matter of time until the ramifications of this abrogation of responsibility affects reliability and affordability of the state’s electric grid.

The other unresolved issue is the feasibility of any dispatchable emissions-free resource.  It is staggering that the State is pushing ahead without an independent analysis of the options available for this critical resource.  As it stands it will not end well.

Getting to 100%: Six strategiesfor the challenging last 10%

A recent paper, Getting to 100%: Six strategies for the challenging last 10%, provides a concise summary of six technologies that could be used for the Climate Leadership and Community Protection Act (Climate Act) legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050.  I continue to be amazed that the parties responsible for Climate Act implementation continue to ignore the risks associated with these aspirational technologies so this article summarizes this useful paper.

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 Climate Act implementation plan and have written extensively on New York’s net-zero transition because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that this supposed cure will be worse than the disease.  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.

I have previously written that 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.  Recently I wrote about the “For discussion purposes only” draft of the 2021-2040 System & Resource Outlook report described in the previous article. 

Challenges of a Zero-Emissions Electric Grid

It is generally recognized that as increasing amounts of intermittent wind and solar energy are added to the electric grid, unique issues arise as grid operators balance generation and load.  I maintain that the ultimate problem with a net-zero energy system is that increased electrification will markedly raise loads during weather conditions that cause peak loads but also can have low wind and solar resource availability.  A recent paper, Getting to 100%: Six strategies for the challenging last 10% (“Getting to 100% report”), describes approaches for providing power during peak conditions.  It describes the general peaking problem, how wind and solar will exacerbate the problem, and what the authors think is necessary to solve the future problem.

The authors from the National Renewable Energy Laboratory provided the following summary:

Meeting the last increment of demand always poses challenges, irrespective of whether the resources used to meet it are carbon free.  The challenges primarily stem from the infrequent utilization of assets deployed to meet high demand periods, which require very high revenue during those periods to recover capital costs.  Achieving 100% carbon-free electricity obviates the use of traditional fossil-fuel-based generation technologies, by themselves, to serve the last increment of demand—which we refer to as the ‘‘last 10%.’’ Here, we survey strategies for overcoming this last 10% challenge, including extending traditional carbon-free energy sources (e.g., wind and solar, other renewable energy, and nuclear), replacing fossil fuels with carbon-free fuels for combustion (e.g., hydrogen- and biomass-based fuels), developing carbon capture and carbon dioxide removal technologies, and deploying multiday demand-side resources. We qualitatively compare economic factors associated with the low-utilization condition and discuss unique challenges of each option to inform the complex assessments needed to identify a portfolio that could achieve carbon free electricity. Although many electricity systems are a long way from requiring these last 10% technologies, research and careful consideration are needed soon for the options to be available when electricity systems approach 90% carbon-free electricity.

The Getting to 100% paper describes six strategies that are summarized in the following table.  Note that the strategies are compared to an ideal solution.  Ideally, the solution for peak loads would have low capital expenses and low operating expense, low resource constraints, be technologically mature, have low environmental impacts, and work well with other resources.  Needless to say, no technology comes close to meeting those ideal conditions.  The authors note that: “Although existing studies generally highlight the same fundamental causes associated with the last 10% problem, there is a lack of consensus on the preferred strategies for meeting this challenge. This is not surprising, given the diversity of possible solutions and the speculative nature of their costs, given their early stage of development.”

Although I think the Getting to 100% paper is useful, I want to point out a few issues with it.  It is hardly unexpected that authors from the National Renewable Energy Laboratory appear to over-estimate the maturity and economics of wind and solar technologies.  Also note that in New York, the implementation plan calls for offshore wind capacity to be at least one third to over one half of the projected wind capacity but the report claimed that wind economic factors were low, capital costs low, operational expenses low and that wind has high technological maturity.  All true perhaps for land-based wind but certainly not true for off-shore wind. 

My biggest concern is that the analysis does not consider the ‘‘inverter challenge’’ as a major constraint.  Another report, “The challenges of achieving a 100% renewable electricity system in the United States”, explains that in the existing electrical system synchronous generators provide six services shown in the following table that provide system stability.  Wind and solar resources are asynchronous generators that do not provide those services.  Somebody has to provide them so this analysis that concentrates only on the levelized cost of energy that ignores those services under-estimates the cost and technological challenges to provide electricity to consumers.

The Getting to 100% paper explains that the biggest problem is making sure there is sufficient available capacity during all periods, even if that capacity is seldom used.  This problem is not new and exists in the existing system.  The paper notes:

The increase in costs associated with approaching 100% carbon-free electricity is a special case of the more general problem of meeting peak demand, which has always been part of the planning process for electric power systems. Variations in demand profiles and the existence of demand peaks are caused by variation in weather, end-use technology stock, and, ultimately, consumer preferences and behavior.

The Getting to 100% paper explains that there are differences between daily load and daily renewable energy (RE) generation over the year.  The following figure shows the seasonal patterns in the daily imbalance (daily load minus daily RE generation) for hypothetical high RE systems where about 90% of annual load is met by wind, solar, and other RE generation technologies for New York State. As noted previously the fundamental problem is that when the loads are the highest in the summer and winter, RE generation can be low.  In the spring and fall the RE resources are generally high but loads are low.   As the share of RE increases,” these aspects are increasingly accentuated”.  The paper makes the point that:

Eventually, with high enough VRE shares, the addition of new VRE capacity would offer very little benefit in reducing peaks in net load, while causing additional oversupply conditions where unusable VRE needs to be curtailed. The low capital utilization problem of meeting demand is exacerbated in high VRE systems. These issues shape the characteristics of a last 10% solution.

In the following I will address each strategy.

Variable renewable energy, transmission, and diurnal storage

This approach is “technologically conservative, as it relies only on technologies currently being deployed at gigawatt (GW) scale”. The seasonal mismatch problem is addressed by overbuilding wind and solar resources as well as adding more transmission capacity.  Diurnal storage is deployed to fill hourly supply gaps and excess wind and solar is curtailed during high-resource periods.  The authors claim: “Increasing oversupply during high-resource times decreases the amount of storage necessary to supply low-resource times.”  The authors admit that wind and solar “curtailment in such systems can reach 35%–50%”.  There is an associated problem.  As more wind and solar resources are added to minimize storage requirements, those additional resources markedly increase curtailment rates for all those resources.  

In order to address those issues, the authors claim that new developments could “make this approach more competitive” In particular: “Higher-capacity-factor system designs (low-windspeed and/or high-hub-height wind turbines; tracking PV arrays with high inverter-loading ratios preferentially increase output during low-resource periods, increasing VRE dispatchability”.  My impression however, is that those are tweaks and do not eliminate all issues.  The authors mention hybrid systems, “including concentrating solar power with thermal energy storage”, but neglect to mention that the Crescent Dunes Solar Energy Project that used this technology failed.  They also claim that “Increased long-distance transmission deployment (over distances larger than the extent of weather systems decreases curtailment, cost, and storage needs by exploiting the declining spatial correlation of VRE availability with increasing distance”.  Advocates of this approach never discuss just what distances are needed for it to work and just how it would work in practice.

According to Table 1 in the Getting to 100% paper, on the positive side the economic factors are relatively low cost and technological material is high.  The resource constraints are listed as medium but I think that is optimistic given the volume of these resources required.  Frequent claims of the low costs of wind and solar generation ignore the fact that the real cost that matters is the delivered cost.  When the costs to keep the lights on when the wind is not blowing at night are considered the low cost claims are wrong.

Other renewable energy

The study claims that “geothermal, hydropower, and biomass are renewable energy resources that do not rely on variable solar and wind resources and have higher capacity credit”. While the report claims that these resources can play an important role in a net-zero-emissions power system the fact is geothermal and hydro resources depend on certain physical site constraints so there is not a lot of potential availability in New York.  The main problem with biomass is that there are limits on how much could be produced and it is not enough to be a major contributor to the overall energy needs.  In New York there are members of the Climate Action Council that believe that zero-emissions means no combustion so there is an ideological constraint as well.

According to Table 1 in the Getting to 100% paper, on the positive side the technological material is high and some of the economic factors are favorable.  However, all the options have high resource constraints that limit the applicability of these options.

Nuclear and fossil with carbon capture

The study notes that “Nuclear and fossil with carbon capture and storage (CCS) are widely cited as potentially important resources in a decarbonized electricity system”.  There is no question that nuclear is the only emissions-free dispatchable resource that could be deployed in sufficient quantities to provide all needed baseload power.  The report notes that: ”The existing nuclear fleet comprises reactor designs with large nameplate capacities and designed to operate near their maximum output potential”, and that “Advanced nuclear reactor designs are typically smaller in scale and more flexible” .  Consequently, nuclear might be viable for the last 10% problem.  Alas New York, for example, on one hand worries about an existential threat of climate change but shuts down 2,000 MW of zero-emissions nuclear generation which suggests that this option is off the table.

The report notes that “Fossil CCS plants have yet to be deployed at scale, but some studies find significant deployment potential, including from retrofits of existing fossil fuel-fired Plants”.   The report sums up the pragmatic dilemma associated with this option:

Fossil CCS has a capture rate of less than 100%; therefore, some emission offsets are needed for fully net carbon-free electricity unless technology advancements, such as through oxy-combustion, can enable zero or near-zero emissions.  he role of fossil CCS could be impacted by how strictly the ‘‘100%’’ requirement is interpreted with respect to any remaining emissions that are not captured and emissions from upstream fuel extraction, including methane leakage.

There is another issue associated with CCS.  A fossil plant capturing CO2 has a derate of about one third because of the energy needed to run the equipment required to capture and compress the CO2 so that it can be transported and sequestered underground.  Finally, in order to safely store the CO2 particular geologic formations are required which limits where these facilities can be located.

According to Table 1 in the Getting to 100% paper, advanced nuclear has high capital expenses and moderate operating expenses; medium resource constraints, medium technological maturity, and security, supply chain, regulatory and cost uncertainties.  Fossil CCS has high capital expenses, medium operating expenses, medium resource constraints, low technological constraints, and issues with upstream emissions, CO2 transport and sequestration.

Seasonal storage

Seasonal storage refers to the use of electricity to produce a storable fuel that can be used for generation over extended periods of time later:

This group of technologies is not well defined, but it could include batteries with very low-cost electrolytes capable of longer-than-diurnal durations. Because of the requirement for very low-cost energy storage, most seasonal storage pathways focus on hydrogen, ammonia, and other hydrogen-derived fuels stored in geologic formations.

Hydrogen produced using electricity to split water (i.e., electrolytic hydrogen) is a form of storage because the energy it carries can be converted back to electricity.  Electrolytic hydrogen technology has been used at an industrial scale since the early 20th century. Although currently higher cost than hydrogen from natural gas reforming, electrolytic hydrogen production costs can be reduced if low- cost electricity, such as zero-cost otherwise-curtailed renewable energy, is used.

In the New York implementation plan the dispatchable emissions-free resource (DEFR) place holder is hydrogen produced using wind and solar.  In addition to the irrational ideological prohibition against combustion sources there are technological issues for New York.  The report notes that “current high-cost electrolyzers need to operate almost continuously to recover their capital expense” and that “Storage and transport costs would add to the delivered cost of hydrogen”. 

The New York ideologues plan is to use hydrogen in fuel cells, but the report notes:

Fuel cells have diverse applications, but their use for bulk power generation is currently limited. Given the range and scale of applications especially for transportation, substantial capital cost reductions for fuel cells are possible. With low capital costs for combustion turbines and future potential cost reductions for fuel cells, the economic case for hydrogen mainly hinges on lowering the cost of electrolytic hydrogen.

According to Table 1 in the Getting to 100% paper, it really is a stretch to say that there are any positive aspects for using hydrogen with combustion turbines or in fuel cells.  For hydrogen used in combustion turbines the report claims low capital expenses (apparently referring only to the combustion turbine but not including the generation of the hydrogen itself), medium operating expenses and resource constraints, and concerns about hydrogen storage and transport as well as competition for using hydrogen in other sectors.  For hydrogen used in fuel cells there is a potential for low capital expenses, high operating expenses, low resource constraints (apparently referring only to the fuel cell and not assuming that the hydrogen is generated with wind and solar resources), low technological maturity, and the same other considerations as hydrogen used in combustion turbines.

Carbon dioxide removal

The report describes carbon dioxide removal (CDR) strategies which are “dedicated efforts to reduce atmospheric CO2 levels.  In theory this can offset emissions from carbon-emitting power generation so that fossil-fired units can operate to fulfill the last 10% requirement. This is too far fetched to be credible in my opinion.

According to Table 1 in the Getting to 100% paper, there are no positive aspects of this technology except that there are low resource constraints for direct air capture and storage. 

Demand-side resources

Net-zero advocates are enamored with “smart planning” approaches that reduce load which reduces generating resource requirements.  The report notes that “Demand-side resources, also referred to as demand response or demand flexibility, have unique properties compared with the supply-side solutions”.  The report explains:

To a limited extent, they are already relied upon for grid planning and operations today. By reducing electricity consumption during times of system stress, these resources help avoid capital expenditures associated with new peaking capacity.  Through flexible scheduling or interruption of electricity consumption, they can also reduce operating costs or be used for important grid reliability services.

While there are indisputable advantages, I think that advocates lose track of the limitations.  There are demand-side programs in place today but the applications are limited.  Today’s programs limit reduction requests to rare instances of limited duration primarily to shave peak loads primarily by large industrial or commercial users. The problem is that applying demand-side options as a last 10% strategy for decarbonization “requires them to be reliably available over extended multi-day periods”. This means that they cannot be used for residential heating and cooling loads and electric vehicle charging. Moreover, the report notes that “Large-scale commercial or industrial customers can provide multi-day response, but extended interruptions would negatively impact these capital-intensive (non-power) applications”.  As a result, I don’t think this approach will provide adequate reductions when needed the most.

According to Table 1 in the Getting to 100% paper there are low capital expenses but there are uncertain opportunity costs.  The paper claims that resource constraints are uncertain and that the technological maturity is medium.  There are concerns about communications, control equipment and reliability.

Discussion

An Inside Clean Energy article on the paper offers a summary from the climate advocacy side.  Of note is a plug for the 100% renewable option:

A growing segment of energy researchers say that the electricity system can run on 100 percent renewable energy, which would mean renewables and energy storage would provide the last 10 percent. This approach sees no good reason to build new nuclear plants or to use carbon capture systems on fossil fuel plants, citing high costs and a variety of other concerns.

The author admits that the myth of low-cost solar and wind resources does not take into account the resources needed for reliability during periods of peak demand:

At the same time, a sizable group of energy researchers maintain that nuclear and carbon capture are essential parts of getting to carbon-free electricity. This side has doubts about the ability of renewable sources to meet all needs, citing concerns about the availability of land and the intermittent nature of wind and solar. They note that wind and solar are not a low-cost option when taking into account the amounts of storage and power line capacity needed to make those resources reliable for meeting peak demand.

I find the author’s conclusion naïve:

Within all of this is something encouraging: Researchers and energy companies have figured out how to start the transition to 100 percent carbon-free electricity and they have a pretty good idea of what the in-between steps will look like. Now, they are beginning to dig deep on how this journey to a carbon-free grid may end.

Academic researchers are not accountable for reliability and have found a cash cow for funding.  No one is funding them to make a responsible estimate of future resources that does not fit the alarmist narrative.  In a de-regulated world energy companies are also not responsible for reliability and are toeing the line of the net-zero narrative.  New York’s organizations responsible for reliability are not as optimistic (here and here). New York’s Draft Scoping Plan presumes that the State can transition to net-zero without addressing reliability and affordability feasibility but the reality is that even this report suggests that substantive issues have to be addressed.

Conclusion

I think this is a biased report that is too optimistic for future projections.  Nonetheless, it does offer a concise summary of potential approaches to address the last 10% problem that is my ultimate concern.  With respect to New York’s implementation plans, if the concerns of the National Renewable Energy Laboratory staff are ignored in the Final Scoping Plan, then New York will surely have a catastrophic blackout with consequences far beyond any impacts that can be attributed to climate change.