Forecast Verification for the New York Climate Action Council Meeting

On September 4, 2021 I predicted that at the next meeting of New York’s Climate Leadership and Community Protection Act (CLCPA) Climate Action Council the recent flooding in lower New York State would be described as evidence that climate change is a reality and that the actions of the Council will fight these kinds of disasters.  This post notes that for the record the Co-Chair “remarks and reflections” included a slide on the recent flooding.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

Since the spring of 2020 the Climate Action Council has been developing a scoping plan outlining recommendations to implement the CLCPA.  The goal is to make the recommendations by the end of 2021 and have the next state energy plan incorporate their recommendations.  A key component of the process will be the integration analysis prepared by Energy & Environmental Economics (E3) that “combines a detailed accounting model of energy supplies and demands across the entire economy with an optimized capacity expansion model in the electric sector” to develop a mix of energy sources that will meet the CLCPA goals.  The plan will also estimate total societal costs and benefits.  For further background, I have summarized the schedule, implementation components, and provide links to the legislation itself at CLCPA Summary Implementation Requirements.

A common feature in the Climate Action Council meetings has been a “reflection” in the opening remarks by the co-chairs that brags about recent implementation actions and includes an argument that additional implementation is needed to address the latest extreme weather event.  My forecast was correct because the meeting included the following slide describing the recent New York flood events (At 8:25 in the Meeting Recording).

Discussion

The immediate response after the flooding from the usual suspects was that climate change was involved despite the fact that worse precipitation has been observed in the past.  As noted in the last post the mis-perception between climate and weather is so common that I have developed a page that explains the difference between weather and climate and includes articles debunking similar claims. 

In the previous post I concluded that flooding caused by heavy rainfall following a previous storm is much more an example of extreme weather than a climate change driven event.  The need to implement mitigation measures as part of the CLCPA is mis-guided because it diverts resources from improvements to weather forecasting, extreme weather warning communications, and resiliency adaptation measures.  Those improvements could provide tangible benefits even if the climate change alarm proves to be over rated.  On the other hand, expecting any extreme weather benefits from emission mitigation measures by New York State are doomed simply because world-wide emissions continue to increase at a greater pace than New York reductions can ever hope to slow down much less reverse.

The remarks and reflections also noted that the latest report from the Intergovernmental Panel on Climate Change had come out since the last meeting.  The director of the Department of Environmental Conservation, Basil Seggos, described the stark warnings of the report at 7:25 of the video.  Not surprisingly, there was no recognition that the high carbon pathway that gives the catastrophic predictions is based on emissions that are implausibly high because recent International Energy Agency estimates are 30% less than that IPCC scenario.  Furthermore, Dr Judith Curry writes that “The extreme tail risks from global warming, associated with very high emissions and high climate sensitivity, have shrunk and are now regarded as unlikely if not implausible.”  Nonetheless, NY policy makers continue to emphasize projections based on the high emissions and high climate sensitivity scenarios.

Conclusion

The CLCPA implementation process continues to portray any extreme weather event as “proof” of global warming driving climate change.  However, New York agencies ignore the difference between weather and climate.  A climatological average is defined as a 30-year average.  In 1954 three hurricanes and in 1955 two hurricanes hit the Atlantic coast north of South Carolina.  If that were to happen today, the alarmists would be screaming that this is definitive proof of a changing climate.  It happened over 66 years ago and has not happened again through two climatological averaging periods.  That indicates if anything, a tendency for fewer hurricanes.  I conclude that describing the flooding caused by the remnants of hurricane Ida as proof of climate change is an example of not letting a crisis go to waste and not letting the facts get in the way of a good story.

RGGI Secondary Allowance Market in the Fifth Compliance Period

The Regional Greenhouse Gas Initiative is a carbon dioxide control program in the Northeastern United States.  Starting in January 2009 the program is now in its fifth three-year compliance period.  This technical post explains why the ownership of allowances held in this compliance period will be unique and how that may be a problem.

I have been involved in the RGGI program process since its inception.  I blog about the details of the RGGI program because very few seem to want to provide any criticisms of the program. 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

RGGI is a market-based program to reduce greenhouse gas emissions. It is a cooperative effort among the states of Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Rhode Island, Vermont, and Virginia to cap and reduce CO2 emissions from the power sector.  According to a RGGI website:

“The RGGI states issue CO2 allowances which are distributed almost entirely through regional auctions, resulting in proceeds for reinvestment in strategic energy and consumer programs. Programs funded with RGGI investments have spanned a wide range of consumers, providing benefits and improvements to private homes, local businesses, multi-family housing, industrial facilities, community buildings, retail customers, and more.” 

Proponents tout RGGI as a successful program because participating states have “cut carbon pollution from their power plants by more than half, improved public health by cutting dangerous air pollutants like soot and smog, invested more than $3 billion into their energy economies, and created tens of thousands of new job-years”.  Others have pointed out that RGGI was not the driving factor for the observed emission reductions.  My work supports that point and points out that the cost-effectiveness of the investments from this carbon tax reduce CO2 emissions at a cost of $858 per ton which is far greater than the social cost of carbon metric.  In other words, this is not a cost-effective way to reduce CO2 emissions.

I first became involved with emissions trading pollution control programs at the beginning of the Acid Rain program in 1995.  That program introduced a system of allowance trading that uses market-based incentives to reduce pollution.  The Acid Rain Program is considered a success because it delivered greater emissions reductions at a lower cost than expected.  I think the success caused a problem inasmuch as nowadays emissions trading programs of any form are considered the best approach whatever the circumstances.  First and foremost, trading programs for CO2 have fewer control options.  In the Acid Rain Program there were compliance options such as add-on controls at the affected sources and more fuel-switching options than are available to reduce CO2 emissions.  For existing sources the main control approaches are fuel switching and running less.  Also, with respect to RGGI the idea that a “little” tweak to auction the allowances rather than award them based on past operations presumed that RGGI would get similar results.

Rather than awarding allowances to affected sources the RGGI allowances are made available at quarterly auctions.  Anyone who meets the financial requirements is eligible to participate in the auctions.  Affected sources are required to surrender allowances equal to half their annual emissions at the end of the first and second years of the compliance period and then surrender allowances to cover the rest of their emissions in the compliance period at the end of the third year.  When allowances are awarded to affected sources the excess allowances after reconciliation are surplus and affected sources are confident that they can be sold or traded without impacting compliance.  Thus, the allowance bank in these systems is primarily allowances that have been earned because the affected sources developed a control strategy that exceeded the cap requirements.  Selling all the allowances in auctions enables investors with no compliance obligations to play the market.  That is a big and mostly unacknowledged difference.

I believe there is a major gap between the academic theory how emissions trading works and reality.  Academics believe that the affected sources treat allowances as a storable commodity and a profit center.  However, the reality is that affected sources treat allowances as a compliance instrument and very few companies buy and sell allowances for profit.  Moreover, it is the nature of the generation business today to have a very short-sighted business plan.  As a result, I believe that affected sources only purchase allowances on an expected need basis mostly at the auctions, but also from the market.  Note that this approach means that the size of the banked allowance pool at affected sources is small and used for short-term compliance goals.  At this time the bulk of the current allowance bank consists of allowances purchased by investors without compliance obligations.

During the development of the RGGI rules the possibility that entities could cause anti-competitive behavior was discussed.  In response, RGGI has an independent auditor (Potomac Economics) checking to see if that has been observed and evaluating other aspects of the market (reports here).  In the Environmental Protection Agency market-based pollution control programs there is complete transparency and the ownership of all allowances is available.  However, in RGGI only the independent auditor knows the identity of auction bidders and allowance holders.  In the remainder of this post, I explain why the majority of allowances held by investors rather than affected sources in this compliance period will be unique and how that may be a problem.

Secondary Market Report Allowance Holdings

A couple of months after each auction Potomac Economics prepares a report on the secondary market.  The most recent report on the secondary market summarizes the allowance status of the CO2 allowance holdings at the end of the second quarter of 2021:

  • There were 143 million CO2 allowances in circulation.
  • Compliance-oriented entities held approximately 52 million of the allowances in circulation (36 percent).
  • Approximately 61 million of the allowances in circulation (43 percent) are believed to be held for compliance purposes.

The RGGI market monitor, Potomac Economics, only describes three categories for allowance owners.  Figure 1 from their recent report describes the relationship between the three categories they use.

Figure 1: Classifications of Participant Firms in the RGGI Marketplace

The Potomac Economics description of firms participating in the RGGI market states:

  • Compliance-oriented entities are compliance entities that appear to acquire and hold allowances primarily to satisfy their compliance obligations.
  • Investors with Compliance Obligations are firms that have compliance obligations, but which hold a number of allowances that exceeds their estimated compliance obligations by a margin suggesting they also buy for re-sale or some other investment purpose. These firms often transfer significant quantities of allowances to unaffiliated firms.
  • Investors without Compliance Obligations are firms without any compliance obligations.

These three categories form the basis for two overlapping groups.

  • Compliance Entities – All firms with compliance obligations[1], and their affiliates[2]. Combines the first and second of the above categories.
  • Investors – All firms which are assessed to be purchasing primarily for investment rather than compliance purposes. Combines the second and third of the above categories.

[1] Before New Jersey announced on June 17, 2019 that it would participate in RGGI beginning in January 2020, firms owning Budget Sources in New Jersey but not in currently Participating States were not treated as compliance entities. However, since the announcement, such firms are treated as compliance entities in our reports.

[2] Affiliates are firms that: (i) have a parent-subsidiary relationship with a compliance entity, (ii) are subsidiaries of a parent company that has a large interest in a compliance entity, (iii) have substantial control over the operation of a budget source and/or responsibility for acquiring RGGI allowances to satisfy its compliance obligations.

The assessment of whether a compliance entity holds a number of allowances that exceeds its compliance obligations by a margin that suggests they are also buying for re-sale or some other investment purpose is based on: (a) the entity’s forecasted share of the total compliance obligations for the entire RGGI footprint through 2026, (b) the total number of allowances in circulation, and (c) consideration of the pattern of the entity’s allowance transfers to unaffiliated firms versus affiliated firms. Since the designation of a compliance entity as an investor is based on a review of its transactions and holdings, the designation of a particular firm may change over time as more information becomes available. Therefore, some of the quantities in this report may not match previous reports because of changes in the classification of particular firms.

The number of allowances that are believed to be held for compliance purposes includes 100 percent of the allowances held by compliance-oriented entities and a portion of allowances held by other compliance entities (i.e., entities with compliance obligations that are not included in the compliance-oriented category).

The anonymity of the allowance holders raises a couple of issues.  In the first place, the classification of the owners is subjective and has not been independently reviewed so the classifications might not reflect the likely behavior of the owners.  There also is the possibility of another category of allowance holders.  Potomac Economics presumes that the all the allowances are held by investors who would be willing to sell their holdings if the price was right.  However, if there are owners who regard the RGGI allowances as carbon offsets they would not be willing to sell at any price.  Given the opaque ownership information I have no idea whether there could be enough offset holders to affect the market.

Projected Allowance Holdings

In the fifth RGGI compliance period allowance holdings ownership will become an issue.  In order to illustrate possible scenarios, I estimated the allowances that might be held by entities holding them for compliance purposes and investors with no compliance obligations through the end of the compliance period in 2023.  RGGI does not provide a consolidated source for the allowances in circulation data listed in the Potomac Economics reports.  Because I have been unable to replicate the numbers and the discussion of the calculations is so complicated, I have prepared a documentation report if anyone is inclined to find out how the following numbers were derived.

In brief, I used the second quarter 2021 Potomac Economics allowances in circulation and allowances held for compliance purposes combined with the auction for the third quarter 2021 report that provided an update of the allowances in held for compliance purposes.  For the rest of the auctions, I used the estimated adjusted allowance allocations.  The biggest question mark is the number of allowances that are allocated to states but not put in the allowance auctions.  There are CO2 emissions data available for the first two quarters of 2021 and I used those data to project future emissions.

I prepared three scenarios of the status of the number of allowances available to entities with compliance obligations at the end of 2023.  In all the scenarios I assume that all the auctioned allowances are purchased by compliance entities.  The first scenario assumes constant emissions consistent with the first two quarters of 2021 and allowances allocated to auctions are reduced consistent with the ratio of total allowances available to allowances auctioned in 2020.  In that scenario compliance entities will have to purchase 20 million allowances from investors without compliance obligations to meet their compliance requirements in the fifth compliance period.  The second scenario assumes that all the allowances allocated to each year are auctioned off with the same emission assumption.  In that case, the compliance entities will have to purchase 6 million allowances from investors without compliance obligations to meet their compliance requirements.  Of course, projecting future emissions is difficult but important to the results.  The third scenario reduced emissions in 2022 and 2023 by 3%, consistent with the allowance allocation reductions.  In that scenario compliance entities still have to purchase nearly 19 million allowances for investors without compliance obligations to meet their compliance requirements.

Cost Containment Reserve

There are factors that could significantly change the allocation results.  Additional allowances can be added to the auctions.  The RGGI states have established a Cost Containment Reserve (CCR), consisting of a quantity of allowances in addition to the cap which are held in reserve. These are sold if allowance prices exceed predefined price levels, so that the CCR will only trigger if emission reduction costs are higher than projected. The CCR is replenished at the start of each calendar year.  The CCR trigger price is $13.00 in 2021 and will increase by 7% per year thereafter. The size of the CCR is 10% of the regional cap each year.  If the auction price triggers the CCR in 2021 then an additional 11,976,778 allowances will be added.  In 2022 11,617,475 allowances and in 2023 11,268,951 allowances will be added if the CCT trigger price is exceeded.  Of course, if additional states join the program, then the allowance allocations will increase.  Finally, if investors without compliance obligations purchase allowances that makes it that much more difficult for affected sources to purchase allowances needed for compliance.

Discussion

In the background section I explained that the allowance bank in the RGGI cap-and-auction program is different than the allowance bank in traditional cap-and-trade programs.  At this time 54% of the allowances in the bank are held by investors without compliance obligations.  If the CCR is not triggered, at the end of the fifth compliance period it is likely that the affected sources will have to obtain allowances from entities who purchased the allowances as an investment.  This is unprecedented.

During the development of the implementing RGGI regulations the Integrated Planning Model was used to predict how the market would act.  One of the bigger problems with the model results is that the model had perfect foresight.  It knew how many allowances would be needed for its estimates of emissions and projected that affected sources would rationally act in their best interests with that information by, for example, purchasing allowances early to cover shortfalls later in subsequent compliance periods.  However, affected sources don’t know what their future emissions will be and don’t purchase allowances except on a shorter time horizon.  Throw in the vested interests of investors and we cannot possibly expect that the market will behave “perfectly” as predicted in the model.

One other aspect of the modeling that was not addressed was the relationship between compliance entities and investors without compliance obligations.  No market-based pollution control program has ever reached the point where non-compliance investors owned most of the banked allowances.  Table 1 estimates when affected sources that keep allowances in hand to cover emissions will need to go to the investors.  It starts adding allowances and emissions to the current allowance ownership categories but does not include the allowances surrendered to meet 50% compliance obligation at the end of the first and second years.  Using the assumptions of Scenario 1, the margin between emissions and total allowances for compliance obligations category indicates that affected sources will have to rely on non-compliance entities starting in 2022. 

Table 1: Fifth Compliance Period Projected Allowances and Emissions – Scenario 1
  AllowancesAllowances forConstantCompliance
YearQuarterin CirculationCompliance PurposesEmissionsMargin
2021Q2143.061.049.911.1
2021Q3165.976.374.91.4
2021Q4188.699.099.9-1.0
2022Q1210.5120.9124.9-4.0
2022Q2232.5142.9149.9-7.0
2022Q3254.5164.9174.9-10.0
2022Q4276.5186.9199.9-13.1
2023Q1297.8208.2224.9-16.8
2023Q2319.1229.5249.9-20.4
2023Q3340.4250.8274.9-24.1
2023Q4361.7272.1299.9-27.8

I think that the investors without compliance obligations are in for a windfall.  At some point it is inevitable that affected sources are going to have to purchase allowances from these investors. It is naïve to expect that their selling price will be anything less than near the CCR trigger price because those investors don’t have to sell until their price is met but affected sources will have to buy whatever the cost.  This will reduce societal benefits.  For example, consider the Quarter 3 2021 auction. The closing price for 22,911,423 allowances was $9.30. which earned the RGGI states $213,076,234 which will be invested for “reinvestment in strategic energy and consumer programs”.  Compliance Entities purchased 52 percent of the allowances sold so non-compliance entities ended up with 10,997,483 allowances.  At the end of the fifth compliance period if the allowance market price is $14.85, just under the CCR trigger of $14.88, and compliance entities have to purchase allowances for compliance then the profit for the investors would be $61,036,031. None of those funds will go toward strategic energy and consumer programs.

It will be fascinating to see how this plays out.  I expect that allowance prices will increase when this ownership shift occurs but will they increase enough to trigger the CCR and add allowances to the system?  If allowances are added to circulation, it will delay the leverage that investors without compliance obligations have on affected sources who need allowances to operate.  At this time, it appears to be extremely unlikely that the CCR will be triggered in 2021.  Given the large gap in prices it might not even be triggered in 2022 but given that affected sources will have to go to the market to purchase allowances necessary to cover emissions triggering the CCR is more likely.  I frankly will be surprised if the CCR is not triggered in 2023.  If that happens allowance prices will be over $14.88, 11,268,951 allowances will be added to circulation, and, assuming emissions decrease by 3% per year, the allowances available to the affected sources would approximately equal the compliance obligation.

The biggest unknown in all this is future emissions.  The primary CO2 reduction mechanism is fuel switching and the original nine states in RGGI have already switched fuels at many sites.  I have no experience with Virginia’s emissions so there might be a possibility of significant fuel switching and lower emissions.  In New York the retirement of 2000 MW of nuclear generating capacity will surely increase state CO2 emissions.  The important takeaway is that the worst-case situation is if there are insufficient allowances that affected sources will be unable to run.  In theory, when there is a shortage of allowances the prices will go up and trigger additional allowances from the CCR.

Conclusion

This post explains that RGGI is approaching the situation where the majority of allowances will be held by investors rather than affected sources.  Speaking as an investor, I purchased allowances in auction 40 in June 2018 and sold them earlier this year when I needed the money, I would certainly be setting an “ask” price close to the CCR trigger price.  Investors who have held on to them for this long can afford to wait a couple of more years when affected sources will have to purchase allowances.  As long as quarterly emissions exceed the allowances available it is only a matter of time until that occurs.  This is a problem because consumers will end up paying the allowance costs that get incorporated into the electric system bid costs but they will not reap any benefits on the difference between the auction cost and the sales cost.

The opaqueness of the RGGI allowance bank makes it necessary to rely on the market monitor to tell us the categories of the allowance holders.  The expectation for all three categories, compliance entities, investors with compliance obligations and investors without compliance obligations, is that allowances will be sold at the right price.  However, if there are owners who regard the RGGI allowances as carbon offsets they would not be willing to sell at any price.  It is not clear that there are any allowance holders in this category but it is possible.  Another question is whether carbon offset allowance holders would have an impact on RGGI emissions.  In my opinion that is unlikely because the scarcity of allowances would drive up the price and trigger the release of additional allowances. 

Climate Leadership & Community Protection Act 2030 Electric System Target Feasibility

On August 29, 2021 I posted an article, CLCPA Electric System Targets, that discussed the politics behind the 2030 electric system target that requires a minimum of seventy percent of the state wide electric generation to be provided by renewable energy systems.  I argued that because the definition of renewable energy systems excludes nuclear and renewable natural gas (e.g., methane capture from landfills, farm manure digesters, and other organic sources) that meeting that target was impossible.  However, I did not provide evidence for that claim.  This article documents why I believe it is impossible.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

The previous article completely documents the target and relevant definitions but here is the simple version.  § 66-p, 1 (b) states that (b) “renewable energy systems” means systems that “generate electricity or thermal energy through use of the following technologies: solar thermal, photovoltaics, on land and offshore wind, hydroelectric, geothermal electric, geothermal ground source heat, tidal energy, wave energy, ocean thermal, and fuel cells which do not utilize a fossil fuel resource in the process of generating electricity”.  The target is defined in § 66-p, 2 (a) as “a minimum of seventy percent of the state wide electric generation secured by jurisdictional load serving entities to meet the electrical energy requirements of all end-use customers in New York state in two thousand thirty shall be generated by renewable energy systems”.

Future Electric System Projections

I looked at feasibility of the 2030 target earlier but I had the mistaken impression that nuclear was included as part of the 70% allowable energy sources.  The premise of my impossibility argument is that the current renewable energy sources distribution from the New York State Energy Research and Development Authority (NYSERDA) Patterns and Trends – New York State Energy Profiles: 2003-2017 report is so small that it is unreasonable to expect that it can be raised to 70% in ten years even if nuclear is included.  Table 1 combines data from the NYSERDA patterns and trends document and the New York Independent System Operator (NYISO) Gold Book for the last three years.  In 2020 the CLCPA renewable energy sources contributed only 24% of the electrical energy system generation (Table 1).  This article will look at a couple of refined projections made for the future electric system under the CLCPA.

The first study is the Initial Report on the New York Power Grid Study as described in Appendix E: Zero-Emissions Electric Grid in New York by 2040 Study (“Zero-Emissions Study”).  It is not surprising that this analysis prepared in part by New York Department of Public Service and NYSERDA staff claimed that “there are feasible pathways to meeting the CLCPA targets” because state policy takes it as a given that CLCPA targets are only a matter of political will.  However, upon closer examination using alternate reasonable alternate assumptions the target is unlikely to be achieved.

Table 2 compares the assumptions in the initial scenario of the Zero-Emissions Study with alternative assumptions.  The New York Independent System Operator (NYISO) Gold Book includes estimates of future load in Table I-1b: Summary of NYCA Baseline Annual Energy Forecasts – GWh.  In this table the baseline annual energy forecast is 145,960 GWh but that includes a reduction of behind the meter solar PV 8,013 GWh.  Because the Zero-Emissions Study includes estimates for this parameter it should be added to the annual forecast to make the 2030 expected load 153,973 GWh.  That makes the renewable energy resources percentage of the total smaller.  The Table 2 alternative assumes the same capacity for distributed behind the meter solar, utility-scale solar, and onshore wind but bases the capacity factors on observed data rather than the “NREL Wind Toolkit and National Solar Radiance database”.  Land-based wind capacity factors averaged 25% over the last five years.  Assuming that all the additional wind capacity developed between now and 2030 meets the NREL 34.6% capacity factor and that all the existing wind capacity continues to operate at 25% the more appropriate combined New York capacity factor should be 31.5% thus reducing the expected energy produced.  The latest Gold Book includes data that indicates that grid solar in New York has a capacity factor of 17.6%.  With respect to grid solar in Table 2 that raises the energy produced.  However, the Zero-Emissions Study assumes that distributed solar will have the same capacity factor as utility-scale solar and that is not supportable.  The NYSERDA New York Solar Study lists different capacity factors for three different classes of distributed solar – all lower than the utility-scale value.  For the alternative I conservatively used the highest value of the three.  As a result of all these alternative assumptions the alternate renewable energy resources percentage is 67.1%.

The second analysis was done by Energy and Environmental Economics, Inc. (E3) for NYSERDA in the spring of 2020.  E3 described their analysis in Pathways to Deep Decarbonization in New York State – Final Report [PDF]. E3 used their RESOLVE model to model the electric sector:

Our modeling approach also incorporates detailed electricity sector representation using E3’s RESOLVE model. RESOLVE is used to develop least-cost electricity generation portfolios that achieve New York’s policy goals, including 100% zero-emission electricity, while maintaining reliability.

When the report was released, I analyzed the approach and concluded that: “While their models give the veneer of respectability to the projections, the reality is that the inherent over-simplifications of their models under-estimates the difficulties of the transition in New York and gives a false sense of security to their assurances that implementation will succeed”.  Of particular concern relative to the electric system feasibility is how they handled renewable resource availability.  In the following slide they point out that firm capacity is needed to meet a multi-day period of low wind and solar output in the winter.  In my analysis I argued that actual short-term meteorological data must be used to correctly characterize the renewable resource availability for New York in general and in areas downwind of the Great Lakes in particular. This is because the lakes create meso-scale features, most notably lake-effect snow and clouds, that can affect solar resources many miles from the lake shore.  At the time I asked E3 how they calculated renewable resource availability but they never responded.  The key point is that the ultimate estimate of the electric system generating resources necessary to ensure reliable electricity availability at all times must be able to handle this worst-case situation.  It is not clear to me that the projections in their decarbonization pathway address this in their estimates of resources needed.

I extracted the data in Table 3 from their Supplementary Workbook [XLS] dated October 10, 2020.  I estimate that this analysis projects that renewable energy resources will only total 67.6% instead of 70%.  Even so I think their estimate is high.  My biggest concern is that there are no firm, zero-emissions resources listed for 2030 and I think some will be needed to meet the worst-case period they highlight as a concern.  There also are consistency issues relative to the other estimates.  E3 handled imports differently.  That is good because it does give a renewable energy resource estimate for imported hydropower but it causes the total imports to become negative.  I don’t know how battery storage should be handled relative to the CLCPA definitions so I just lumped it into the renewable energy resources category. 

In addition to the problem that both studies did not prove that their renewable energy resources solution adequately addressed the critical reliability problem of a multi-day period of low wind and solar, both studies presume that the projections for future renewable energy resources can be built on a schedule that ensures that they are available in 2030.  The Accelerated Renewable Energy Growth and Community Benefit Act is supposed to expedite renewable energy development but that does not preclude the possibility of litigation on specific projects or other holdups in the permitting process. In the case of offshore wind, I believe that delays are inevitable because the infrastructure to support building the turbines has to be developed first and those developments are also subject to permitting and construction delays.  Finally, there is a real possibility that the availability of the critical minerals and metals needed for these renewable technologies could slow implementation and increase costs. 

Conclusion

In general, the feasibility approach in the analyses described here is to simply estimate future load and then calculate the energy resources necessary to match that load.  There are multiple issues with these analyses.  First, and foremost, the emphasis appears to be on annual comparisons but the critical reliability issue is a multi-day period in the winter when wind and solar resource availability is low but the load requirements for universal electrified heating and transportation are high and must be met to ensure the safety and health of New York residents.  It is not clear that any of the projections adequately addressed this requirement.  In addition, I don’t think that the projections included the necessary resources needed to provide ancillary transmission grid services as I described in a post on one of the studies.  Finally, I am sure that the studies did not incorporate the resources needed to maintain New York State Reliability Council requirements.  Therefore, these projections under-estimate the resources needed to provide reliable electricity.

The Zero-Emissions Study and the E3 decarbonization pathways analysis both can claim that their approaches achieve the goal that the electric system use 70% renewable energy resources in 2030.  Based on this analysis I think their assumptions about renewable resource availability are overly optimistic.  The practical reality is that time constraints on permitting, procurement, construction and development of supporting infrastructure will most likely delay implementation of the ambitious proposed resource development.  Further compounding the viability of the proposed resources are the New York State Reliability Council requirements and the need for ancillary grid transmission services.  When all these factors are considered, I believe that it will be impossible to meet the 2030 target without endangering reliability.

Prediction for the New York Climate Action Council’s Next Meeting

In New York’s Climate Leadership and Community Protection Act (CLCPA) the Climate Action Council is required to prepare and approve a scoping plan outlining the recommendations for attaining the statewide greenhouse gas emissions limits in accordance with the schedule of the law.  I predict that at their next meeting the recent flooding in lower New York State will be described as evidence that climate change is a reality and that the actions of the Council will fight these kinds of disasters.  This post explains why the rationale is wrong and the proposed solution hurts rather than helps the flooding problems.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

Since the spring of 2020 the Climate Action Council has been developing a scoping plan outlining recommendations to implement the CLCPA.  The goal is to make the recommendations by the end of 2021 and have the next state energy plan incorporate their recommendations.  A key component of the process will be the integration analysis prepared by Energy & Environmental Economics (E3) that “combines a detailed accounting model of energy supplies and demands across the entire economy with an optimized capacity expansion model in the electric sector” to develop a mix of energy sources that will meet the CLCPA goals.  The plan will also estimate total societal costs and benefits.  For further background, I have summarized the schedule, implementation components, and provide links to the legislation itself at CLCPA Summary Implementation Requirements.

A common feature in the Climate Action Council meetings has been a “reflection” in the opening remarks by the co-chairs that brags about recent implementation actions and includes an argument that additional implementation is needed to address the latest extreme weather event.  Given that history I have no doubt that the next meeting will describe the flooding effects of hurricane Henri and the remnants of hurricane Ida and imply that the CLCPA will reduce if not eliminate those effects in the future.  That claim as well as all the other similar claims in the past is baloney.

New York Flooding

On August 22, 2021 tropical depression Henri made landfall in Rhode Island.  Although it had weakened from a hurricane and skirted New York, it dumped heavy rains from New Jersey to New England.   The region had a wet summer so the ground was already saturated.  As a result, the main impact was flooding.  Hurricane Ida struck the Louisiana coast on August 29, 2021 sixteen years to the day after Hurricane Katrina devastated New Orleans.  Although there was widespread devastation, the levees in New Orleans held and the loss of life was much less in Louisiana.

I followed the forecasts of the remnants of Ida as it slogged north and the east out to sea.  Every forecaster was warning that heavy rains were likely in the New York City area and coupled with already saturated grounds that flooding was likely.  Cliff Mass described the weather as it hit the area and noting that New York’s Central Park had a record of 3.15 inches in an hour.  He explains that hurricane remnants, known as extratropical cyclones, combine strong upward motions with large amounts of tropical moisture.  This combination causes heavy rains and flooding.  Tragically, dozens of people were killed in New York and New Jersey as a result of this flooding.

The immediate response from the usual suspects was that climate change was involved despite the fact that worse precipitation has been observed in the past.  I believe that this will also be the response by the Climate Action Council co-chairs at the next meeting.  This is such a common response that I have developed a page that explains the difference between weather and climate and includes article debunking similar claims.  In this case however, I want to respond differently.  In particular, I want to discuss what the best approach would be to prevent a reoccurrence of the deaths and devastation in New York City.

Discussion

As I mentioned before this was a very well forecasted event with some caveats.  Cliff Mass notes that there were warnings out for heavy precipitation but that there some issues with “intensity and position”. He goes on to argue that a larger number of finer resolution weather prediction ensembles could be used to develop better probabilistic/uncertainty predictions.  I think those models could also be improved by incorporating higher density observations into the models.  All those revisions could improve the forecasts if implemented.

However, the fact is that the forecasts were ignored.  In my opinion, many New York City residents are so divorced from weather impacts (they simply are not outside for long periods that much) that they don’t pay attention to weather forecasts unless it is an extreme event.  Consequently, the idea that a forecast for heavy rain means that they should monitor the weather situation, i.e., check the weather forecast frequently in that situation, is not common practice.  As a result, communication practices have to be changed to ensure that people stay off the roads and get out of low-lying basement apartments when this kind of forecast is made.

The good news vis-à-vis Ida was that the levee resilience measures installed in Louisiana since Katrina worked well enough to prevent a re-occurrence of that disaster.  If there were other levees that failed it is clear that additional strengthening is needed.  The bigger problem there is the extensive damage to the electric system.  Clearly more needs to be done to strengthen the resiliency of the electric transmission and distribution system.

After super storm Sandy In New York City extensive upgrades were made to prevent damage from storm surges.  However, given that the subways still flooded, more still needs to be done to prevent water damage to that system.  Given the extreme amount of rain it probably is not possible to engineer a system to prevent all the many water issues but it certainly is time to update what could be done.  In addition to infrastructure improvements developing an improved warning system would be useful.  For example, during such an event if people knew that the GPS driving direction systems were being updated with flooding information, they could use them to steer clear of problem areas.

All of the aforementioned resiliency measures require investments of time and money.  However, they all can provide benefits to reduce impacts of future storms.  One of the key points to understand about extreme weather and climate change is that climate change impacts are smaller than the effects of natural variability.  As a result, it is ludicrous to expect that extreme weather will stop occurring even if climate change mitigation measures reduce global warming and the alleged effects on extreme weather.  The most likely future scenario for weather is more extreme weather and that means that adapting to the effects of extreme weather is a no regrets approach.

More importantly the fact is that beyond New York and the United States fossil fuel emissions are increasing at a rate that is many times greater than New York’s emissions.  Consequently, even if New York mitigation efforts do reduce emissions there will be no impacts on the world’s weather because of increased emissions elsewhere. 

Conclusion

The next meeting of the Climate Action Council will be on Monday, September 13, 2021 at 2:00 p.m. ET.  The meeting agenda includes a welcome item that I predict will mention the flooding in New York City as a sign that climate change is a reality and we need to fight it. 

In actuality the observed heavy rainfall following a previous storm is much more an example of extreme weather than a climate change driven event.  The need to do something about it as part of the CLCPA is mis-guided because it diverts resources from improvements to weather forecasting, extreme weather warning communications, and resiliency adaptation measures.  Those improvements could provide tangible benefits in any event.  On the other hand, expecting any extreme weather benefits from emission mitigation measures by New York State are doomed simply because world-wide emissions continue to increase at a greater pace than New York reductions can ever hope to slow down much less reverse.

Reliability Challenges in Meeting New York’s Climate Act Requirements

This post was published at Watts Up With That on  September 2, 2021

On July 18, 2019 former New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act “Climate Act”), which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency.  Over the last year recommendations have been developed by panels of politically chosen representatives for consideration for a Scoping Plan to achieve greenhouse gas (GHG) emissions reductions economy-wide.   On August 2, 2021, the New York State Energy Research and Development Authority (NYSERDA) held a Reliability Planning Speaker Session that provides some interesting insights regarding reliability planning for electric systems dominated by renewable energy generation.

Background

Reliability planning in New York is prioritized because there is a long history of blackouts in New York State in general and New York City in particular.  After a blackout in July 2019 AMNY published a brief history of blackouts in New York City.  In every case after blackouts in 1959, 1961 1965, 1977, 2003, and 2012 new requirements for infrastructure and operating rules were implemented to prevent future reoccurrences.  Reliability planning is a constant concern for the electrical system professionals who operate the system and are responsible for keeping the lights on.  With all due respect to the professionals who are trying to develop a reliable system that incorporates large amounts of intermittent and diffuse wind and solar generation, the track record for blackouts indicates that historically not all the problems could be anticipated and that retrospective reliability improvements were the norm.

Over the past year the electric system professionals have looked on the Climate Act transition process and recommendations with increasing concern because it is clear that many of the appointed representatives do not understand the particular reliability requirements of New York.  After a year and many comments, the State finally responded with an overview briefing presentation on those requirements to the people who are supposed to guide the transition plan.  The speaker session (recording here) included presentations from six organizations with varying levels of reliability background, experience, and responsibilities:

  • New York State Reliability Council (NYSRC) – Mayer Sasson, Steve Whitley, & Roger Clayton
  • New York Independent System Operator (NYISO) – Zach Smith
  • Utility Consultation Group – Margaret Janzen (National Grid) and Ryan Hawthorne (Central Hudson)
  • New York State Department of Public Service (DPS) – Tammy Mitchell
  • Vote Solar – Stephan Roundtree
  • New York Department of State Utility Intervention Unit – Erin Hogan

In a post on my blog I did an overview of all the presentations.  The warning in five of the six presentations was similar: it will not be enough to depend on today’s technology to develop a reliable electric system with net-zero emissions.  A “large quantity of installed dispatchable energy resources is needed in a small number of hours” and it “must be able to come on line quickly, and be flexible enough to meet rapid, steep ramping needs”.  That technology does not exist for utility-scale applications.  Unfortunately, in order to cater to the environmental zealots involved in the process a presentation from Vote Solar who claimed “integrating renewables into the grid while maintaining reliability is possible, and in fact cost effective” was included.  That presentation was based on the report, “Why Local Solar for All Costs Less”, that is fatally flawed because it relies on annual estimates of renewable resource availability and does not address worst case conditions.

NYSRC Presentation

The presentation by the New York State Reliability Council succinctly describes the organization, how the New York electric system is operated to maintain reliability and some of the challenges presented when renewable energy sources are increased significantly.  It was so well done I thought it would be of interest to readers here.

New York’s electric system is de-regulated so reliability planning is provided by the New York Independent System Operator, various state agencies and the NYSRC.  The introduction describes the NYSRC and the Installed Reserve Margin (IRM) parameter.  The IRM is defined as the “minimum installed capacity margin above the estimated peak load to meet the Northeast Power Coordinating Council (NPCC) requirement that the probability of shedding load is not greater than one day in ten years”.   Load shedding occurs when the demand for electricity exceeds supply and grid operators have to turn power off for groups of customers in order to prevent the whole system from collapsing.  Note that one of the lessons learned from previous blackouts was that New York City has to maintain a significant amount of in-city generation availability to prevent blackouts.  The NYSRC has specific rules in this regard.

The next slide described how the system is operated reliably. Note that in addition to the short-term operation of the system that longer term planning is also required.  In order to address the one in ten-year criteria of the IRM, planning has to address new generation and transmission resource development that can take ten years to get built.

The slide titled “Operating the future system reliably” explained that as the mix of generation resources changes, planning and operations will also have to change.  A point of emphasis is that “Limited fuel diversity and over dependence on energy limited resources is a risk to reliability”.  In the past New York boasted a truly diverse fueled electric system with significant coal, residual oil, natural gas, hydro and nuclear resources.  There were significant resources available from sources that could store fuel on-site and could operate with more than one fuel.  However, the state has banned the use of coal and residual oil has become so expensive that its use has dropped precipitously.  The conclusion in the slide that additional dispatchable and sustainable energy resources to manage the substantially different system in order to maintain reliability refers, in part, to the New York City requirements for in-city capacity.  Presently, for example, that means facilities must be able to burn oil when natural gas is unavailable. 

The next slide (not shown here) re-emphasizes the importance of the IRM which turns out to be a future challenge when there are significant increases in renewable resources.  This is illustrated in the slide titled “Solar impact on resource adequacy”.  The slide shows the diurnal variation of load vs solar generation also known as the “duck curve”.  Typical discussions of the duck curve focus on the operational challenge resulting from the loss of solar generation at the same time the load is high.  This slide addresses the changes in the reserve requirements with the addition of 26,000 MW of new solar generation in New York.  Because of the enormous variation in available energy from solar, adding that amount of solar generation would raise the reserve requirement to approximately 22,000 MW as compared to the current reserve requirement of 6,600 MW.  It also means that the state can only retire 4,000 MW of current resources.

The Climate Act has an electric system target of zero emissions in 2040.  The Department of Public Service (DPS) and New York State Energy Research & Development Authority (NYSERDA) have made a preliminary estimate of the resources needed to meet that goal as shown below.  The key numbers from this slide are that they expect to need 88,337 MW in 2040 for an expected load of 38,000 MW.  In order to meet that load and with a loss of load expectation no greater than once in ten years the NYSRC estimates that the total reserves will be approximately 50,000 MW.

The presentation observes that the New York reserve margin will have to increase to over 100% relative to the current reserve margin of about 20%.  The estimates of resources needed to meet the Climate Act targets have not incorporated this issue so they under-estimate the resources needed significantly.  In addition, the new technologies have to be zero emissions and meet the characteristics of fossil fuels (dispatchable, fast-ramping, and long duration storage).  The presentation notes that “these resources rely on technologies that do not currently exist for utility-scale applications”.

Conclusions

I recommend reading the session presentation and listening as it gives a good overview of reliability issues facing New York or any other jurisdiction in the transition to net-zero.  One caveat is to not waste your time reading the Vote Solar presentation because it is based on fatally flawed analysis.

There is consensus that the future worst-case situation in New York will be a multi-day winter time wind lull when both wind and solar availabilities are low.  Coupled with increased electricity load in order to reduce emissions from transportation and heating, any analysis of future renewable energy resources that adequately addresses the worst-case renewable energy resource availability shows the required amounts of wind, solar and energy storage will have to be enormous.  Importantly, the NYSRC analysis indicates that in order to ensure reliability the installed reserve margin will have to be added to the total needed to balance anticipated load.  While the focus of the highlighted presentation was New York, I believe that similar problems will become evident at any other jurisdiction that attempts to develop a net zero emissions electricity system. 

The NYSRC conclusion that the state of New York appears to be headed down a transition path which will require reliance on technologies that do currently exist in less than ten years should be a wake-up call.  The ultimate question is whether the proposed transition plan will address the issues raised by the professionals or cater to the naïve dreams of the politically chosen members of the transition program. I fear New York consumers will be lab rats for a politically motivated virtue signaling empty gesture that is going to cost enormous sums of money, and, in the event of a major blackout, cause much more harm than good.

—————————————————————————————————————————————

Roger Caiazza blogs on New York energy and environmental issues at Pragmatic Environmentalist of New York.  He has  written extensively on implementation of the Climate Act because the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   This represents his opinion and not the opinion of any of his previous employers or any other company with which he has been associated.

Climate Leadership & Community Protection Act Electric System Targets

On July 18, 2019 former New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act (CLCPA), which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency.  I have been posting articles about the feasibility of the CLCPA targets and got the following comment in response to my post CLCPA Feasibility Relative to NYSERDA Patterns and Trends: “Please provide a cross reference to the fact that CLCPA includes nuclear power as acceptable form of renewable energy”.  This post provides a more complete discussion than my reply.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

When I started researching this comment request, I was confident that the legislation actually listed nuclear as a renewable energy system.  However, when I researched it, I found out I was wrong.  Subsequently I discussed this with colleagues who are more attuned to New York policy and legislative considerations than I am.  As is usual with any aspect of the CLCPA whenever you start to dig into the details there are complicating nuances.

Climate Change Regulations

There are three implementing regulations for the CLCPA legislation that became effective on January 1, 2020.  Article 75 – Climate Change was added to the New York Environmental Conservation Law. 

§ 66-p. Establishment of a renewable energy program was added to the New York Public Service law.  Finally, § 54-1523. Climate adaptation and mitigation projects was added to the Environmental Protection Act.

For the purposes of this article the relevant regulation is § 66-p. “Establishment of a renewable energy program”.  The pertinent amended language reads:

§ 66-p. Establishment of a renewable energy program.

1. As used in this section:

(a) “jurisdictional load serving entity” means any entity subject to the jurisdiction of the commission that secures energy to serve the electrical energy requirements of end-use customers in New York state;

(b) “renewable energy systems” means systems that generate electricity or thermal energy through use of the following technologies: solar thermal, photovoltaics, on land and offshore wind, hydroelectric, geothermal electric, geothermal ground source heat, tidal energy, wave energy, ocean thermal, and fuel cells which do not utilize a fossil fuel resource in the process of generating electricity.

2. No later than June thirtieth, two thousand twenty-one, the commission shall establish a program to require that:

(a) a minimum of seventy percent of the state wide electric generation secured by jurisdictional load serving entities to meet the electrical energy requirements of all end-use customers in New York state in two thousand thirty shall be generated by renewable energy systems; and

(b) that by the year two thousand forty (collectively, the “targets”) the statewide electrical demand system will be zero emissions. In establishing such program, the commission shall consider and where applicable formulate the program to address impacts of the program on safe and adequate electric service in the state under reasonably foreseeable conditions. The commission may, in designing the program, modify the obligations of jurisdictional load serving entities and/or the targets upon consideration of the factors described in this subdivision.

The renewable energy systems definition clearly excludes nuclear.  My colleagues all agreed that was a deliberate choice.  It also excludes renewable natural gas that is to say methane from landfills and other organic sources.  That also was a deliberate design choice by the “anti-natural gas in any form” zealots who drafted the regulation.

The first electric system target in the public service law mandates 70% renewable energy by 2030.  Clearly the intent was that 70% of the electric energy has to come from the defined renewable energy systems.  Note that the 2040 100% Carbon-free Electricity target is for a different set of energy sources.  Also note that there is a lifeline such that the Public Service Commission can modify the obligations to meet the target if there are issues with “safe and adequate electric service”.

Discussion

 In my conversation with colleagues who are more conversant about environmental policy in New York, I explained that my work suggests that meeting the 2030 target is impossible with 70% solar thermal, photovoltaics, on land and offshore wind, hydroelectric, geothermal electric, geothermal ground source heat, tidal energy, wave energy, ocean thermal, and fuel cells which do not utilize a fossil fuel resource in the process of generating electricity resources. A forthcoming post will delve into the numbers but for the moment trust that assessment.

The first policy question that comes up is the rationale behind the overly ambitious 2030 target.  Ultimately the decision on that target was made by a few key individuals with former Governor Cuomo at the top.  The first possibility is that the authors didn’t understand the magnitude of the effort needed and inadvertently chose an impossible target for the decision makers.  Given the rhetoric that meeting the “climate change challenge is only a matter of political will” it is possible that they actually believe it.  The second possibility is that political optics were the primary rationale despite recognition that the targets were overly ambitious. Given that we are talking about targets that are nine years away, cynics might wonder if this was the case with the presumption that the decision makers would be out of office by then or that the voters would have forgotten who passed the legislation.

The second policy question is what happens when it becomes obvious that the targets cannot be met.  This question arises on several time frames for the 2030 target.  The first time it comes up is in in the current planning phase.  Preliminary modeling of all advisory panel recommendations to the Climate Action Council which includes all sectors of the economy indicates the collective recommendations fail to meet the near- and long-term emission reduction targets.  The integration analysis presumably has to increase the emission reduction strategies until the plan meets the targets and that comes out later this year.  There is a requirement for an on-going assessment of the status of emissions reductions relative to the targets so the question can come up once the strategies are implemented.  Finally, in 2031 we will know for sure whether the 70% target was achieved.

What happens when it does become obvious that the target cannot be met? The 2040 target includes the language that the PSC may “modify the obligations of jurisdictional load serving entities and/or the targets” but it is not clear to me that allows changes for the 2030 target.  The politicians who put the state in this bind could argue that these are just goals but the environmental advocates and renewable energy grifters have already started flatly stating that this is the law and that it must be enforced.  While there are certainly legal constraints on litigation for this, there seem to be many lawyers willing to push the envelope on legal standing when it comes to suing deep pocket fossil fuel companies for alleged impacts of climate change.  As a result, I suspect that failure to meet the targets will result in litigation.

There is another aspect of this that is relevant.  The CLCPA did not incorporate any funding mechanism and it is wildly optimistic to think that the targets can be met without additional funding.  The last legislative session considered the Climate and Community Investment Act (CCIA) that was intended to fund many aspects of the CLCPA.  Once the costs and direct consumer impacts in the CCIA were estimated by some observers (there is yet to be an estimate of costs by the state agencies) there was a groundswell of disapproval, many legislators backed off support, and the legislation did not pass.  Every indication is that next legislative session this bill or something similar will be back.  The environmental community and environmental justice activists are going to be pushing for passage but will have to overcome the obvious problem of costs.

Conclusion

As I will show in a future post, there is no way that New York can expect to meet the 2030 target for 70% of the electric system energy requirements powered by the defined renewable energy systems of the CLCPA.  In my original assessments of feasibility, I had the mistakenly believed that nuclear power could be used to help meet the 2030 target because that was the only way the state could come close but it turns out I was wrong.  Nuclear is an acceptable source for the 2040 zero emissions electric system but cannot be used for the 2030 goal.  It is a sign of the times that there are activists that want to shut down the upstate nuclear units as well and that will make the 2040 target more difficult. This post clarifies the definitions and addresses possible reasons why the legislation was drafted to make that distinction.  I don’t believe there is any rationale for this that puts the authors of the legislation or the politicians that approved the law in a good light: they either knew and didn’t care or didn’t bother to check feasibility.

I am not sure whether there will be consequences for this particular aspect of the abominable CLCPA.  As the implementation requirements are defined and impossibility of meeting this target becomes evident, I don’t see how this can continue to be a blind spot for New Yorkers.  Hopefully the public will catch on soon that the costs for this virtue-signaling action will be significant and that New York’s contribution to global warming is so small that anything we do cannot have a measurable effect on the alleged warming from GHG emissions.  If that does not end the nonsensical implementation, maybe when the legal requirements to mandate use of electric vehicles or ban the use of natural gas for home heating, cooking and hot-water will initiate protests.  Unfortunately, many in industry agree with me that it might take a catastrophic blackout with impacts comparable to the Texas blackout in February 2021 to finally motivate voters to demand the repeal of the CLCPA.

Climate Leadership & Community Protection Act Reliability Planning Speaker Session Follow-Up

Note: When this was written and posted the recording was not available. The Session recording was posted on August 30, 2021

On July 18, 2019 New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act (CLCPA), which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency. Over the last year Advisory Panels to the Climate Action Council have developed and submitted recommendations for consideration in the Scoping Plan to achieve greenhouse gas (GHG) emissions reductions economy-wide.   This is one in a series of articles about this process.

On August 2, 2021, the New York State Energy Research and Development Authority (NYSERDA) held a Reliability Planning Speaker Session to describe New York’s reliability issues to the advisory panels and Climate Action Council.  All the speakers but one made the point that today’s renewable energy technology will not be adequate to mantain current reliability standards and that a “yet to be developed technology” will be needed.  This post addresses the study that was the basis for the claim by Vote Solar that “integrating renewables into the grid while maintaining reliability is possible, and in fact cost effective” is fatally flawed.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

This post is a follow up to an earlier description of the presentations made at the NYSERDA Reliability Planning Speaker Session on August 2, 2021.  The first article was a detailed description of the following presentations:

  • New York State Reliability Council (NYSRC) – Mayer Sasson, Steve Whitley, & Roger Clayton
  • New York Independent System Operator (NYISO) – Zach Smith
  • Utility Consultation Group – Margaret Janzen (National Grid) and Ryan Hawthorne (Central Hudson)
  • New York State Department of Public Service (DPS) – Tammy Mitchell
  • Vote Solar – Stephan Roundtree
  • New York Department of State Utility Intervention Unit – Erin Hogan

The article included background information on the organizations as well as highlights from each presentation.  I also prepared a condensed version that was edited down even further and published at Natural Gas Now.

The advisory panels who are charged with providing recommendations to the Climate Action Council and the Council itself have been working on implementation plans for the last year.  During the development of the advisory panel recommendations, it was obvious that reliability was only receiving token consideration and that many of the panel and council members did not understand the issues and requirements for a reliable energy system.  As a result of many comments, this briefing on the topic of electric system reliability was set up.

In my previous articles I concluded that there was a common warning admonition in most of the presentations: today’s renewable energy technology is insufficient to develop a reliable electric system with net-zero emissions.  The NYSRC notes that “substantial clean energy and dispatchable resources, some with yet to be developed technology, over and above the capacity of all existing fossil resources that will be replaced” needs to be developed.  The NYISO explicitly points out that a “large quantity of installed dispatchable energy resources is needed in a small number of hours” that “must be able to come on line quickly, and be flexible enough to meet rapid, steep ramping needs” but only implicitly points out that these are magical resources that do not exist yet for utility-scale needs.  The utility consultation group explains that “technology development and diversity of clean resources are essential for long term success” but provide no details of the enormity of that task.  Even the DPS makes the point that “evaluating and implementing advanced technologies to enhance the capability of the existing and future transmission and distribution system” is necessary for future reliability.  The Utility Intervention Unit does not provide a comparable warning but does stress the importance of planning and the need to address new technologies.  Obviously relying on as yet unproven technology to transition the electric system on the schedule of the CLCPA is a serious threat to reliability.

There was one exception to this message.  Vote Solar claimed that “integrating renewables into the grid while maintaining reliability is possible, and in fact cost effective”.  In my previous articles I blamed the speaker’s inexperience and lack of background on this flawed argument.   Since then, and thanks to an unnamed colleague, I have found the likely source of his mis-information as described below.

Local Solar Roadmap

Late last year the report, “Why Local Solar for All Costs Less,” described the results of a new distributed energy resources (DER) planning model.  According to a trade press story: the “planning model that includes what most integrated resource plans and solar cost-benefit analyses still leave out — a detailed and long-term view of the distribution system”.  “Developed by industry consultants Vibrant Clean Energy (VCE), the model provides a Local Solar Roadmap rooted in a super-granular and highly mathematical view of grid planning. Power flows and resources on the distribution system are looked at in slices of 5 minutes and 3 square kilometers. The operational variables built into the model are equally detailed, encompassing multiple applications for energy storage, emerging technologies such as hydrogen, and increasing stress on the system due to climate change.”  Given that Vote Solar was one of the sponsoring organizations and the use of common graphics and tables I am sure that this is the basis for the alternative view presented by Vote Solar.

The results are summarized in a slide presentation and there is an overview summary report that provide a general overview of the approach and results.   The executive summary in the report explains that:

The electricity system in the United States (US) is considered to be one of the largest machines ever created.  With the advent of clean and renewable technologies, a widespread evolution is occurring. The renewable technologies are lower cost than fossil thermal generation on a levelized cost basis, but their variability creates new and unique constraints and opportunities for the electricity system of the next several decades.  Superimposed on the changing structure of the electricity system is a damaged climate that will continue to worsen as mankind continues to emit greenhouse gas (GHG) pollution into the atmosphere.

The first problem with the report shows up in the first paragraph of the executive summary: “renewable technologies are lower cost than fossil thermal generation on a levelized cost basis”.  Levelized cost is defined as “a measure of the cost of an energy generation system over the course of its lifetime, which is calculated as the per-unit price at which energy must be generated from a specific energy source in order to break even. The levelized cost of an energy generation system (LCOE) reflects capital and operating and maintenance costs, and it serves as a useful measure for comparing the cost of, say, a solar photovoltaic plant and a natural gas-fired plant.”  The problem is that comparing costs using this measure only incorporates the costs of the facility itself not the cost to provide reliable power when and where it is needed.  Storage, load balancing and grid integration needs to be developed and those costs are necessary to cover for the intermittent and diffuse nature of wind and solar.  Not acknowledging those costs is a common trick of renewable energy advocates when claiming lower costs.

This analysis “proves” that not only are renewable energy sources the best approach but also goes on to claim that it is not necessary to rely on utility-scale wind and solar facilities. Their work supposedly proves that large additions of distributed energy resources (DER) are the best approach for the future.  They describe conventional thinking as follows:

The new, smarter approach is described as follows:

Obviously, renewables are emphasized but their grid of the future has at least ten times more local solar and storage.  The basis of the claim is new and better models.  The summary slide presentation goes on to argue that the new model is needed to because “utility planning models were designed for a century old utility system”. 

The authors claim that “These models play a critical role in developing integrated resources plans and setting electric rates, however current models are missing fundamental data” and that one of the missing pieces is “high resolution climate and weather data”.  It is not clear to me whether they don’t know or choose to ignore that current utility planning relies on multiple models.  The reliability presentations described models used to explicitly address reliability issues that incorporate historical weather data.  In the past it was not necessary to consider short-term (less than one hour) weather variations because the generating facilities did not fluctuate as much as wind and solar.  However, the work that NYSRC and NYISO are doing now does consider those fluctuations and uses shorted term data.

The complaint that transmission and distribution costs are “rarely considered or simply an afterthought” may be true elsewhere but New York’s current reliability planning process does consider them.  I also consider the claim that “they don’t account for total system costs and benefits” disingenuous for anyone that invokes the levelized cost basis to “prove” that wind and solar are cheaper than traditional generating facilities.  The point of all these arguments is that a new and better model is needed.

WIS:dom®-P

The overview summary report describes the new model that “proves” their claims:

The present study demonstrates, quantifies and evaluates the potential value that distributed energy resources (DERs) could provide to the electricity system, while considering as many facets of their inclusion into a sophisticated grid modeling tool. The Weather-Informed energy Systems: for design, operations and markets planning (WIS:dom®-P) optimization software tool is utilized for the present study. A detailed technical document of the WIS:dom®-P software can be found online. The modeling software is a combined capacity expansion and production cost model that allows for simultaneous 3-kilometer, 5-minute dispatch and power flow along with multi-decade resource selection. It includes detailed representations of fossil generation, variable resources, storage, transmission and DERs. It also contains policies, mandates, and localized data, as well as engineering parameters and constraints of the electricity system and its components. Some novel features include highly granular weather inputs over the whole US, climate change-induced changes to energy infrastructure, land use and siting constraints, dynamic transmission line ratings, electrification and novel fuel production endogenously, and detailed storage dispatch algorithms.

WIS:dom®-P is described as a “state of the art, fully combined capacity expansion and production cost model , developed to process vast volumes of data”.  It simultaneously “co-optimizes for: “(1) Capacity expansion requirements (generation, storage, transmission, and demand side resources); and (2) Dispatch requirements (production costs, power flow, reserves, ramping and reliability)”. 

The model documentation is a great example of intimidation by equation and jargon.  In order to run the model, the user defines 25 parameters ranging from “amortized capital and fixed costs for generation technologies” to “the fuel cost per unit of primary energy for generation technologies”.  Each parameter covers a range of options that vary by location.  Considering the fact that the model can cover the contiguous United States parameter definition is a daunting task.  The model optimizes a further 21 internal variables.  These are not variables in the elementary sense representing a single value.  Instead, they are multi-dimensional representations of the, for example, “installed capacity of generation technologies” and “electricity demand” covering an area up to the size of the continuous United States.  Each of the 46 parameters gets its own symbol as exemplified by the internal variable list below:

The mathematical formulation of the objective function is:

Don’t worry I am not going to dissect the formulation.  I just want to make the point that the authors of the program are very likely on a different level of mathematical understanding than the sponsors of the solar advocacy groups who wanted this analysis.  Frankly they are on a different level than me, an old retired guy who might have been able to dissect this 50 years ago but who has long since forgotten much of the mathematics behind this optimization methodology.  However, I understand enough to question whether this approach adequately addresses the issues that the NYSRC, NYISO and DPS have analyzed in their work.

Ultimate Problem

The question for the reader is why the WIS:dom®-P approach provides a different answer than the other organizations that presented at the reliability speaker session.  I believe that the reason is that all the others are addressing resource planning for the worst-case situation when load peaks.  In the past, reliability planning focused on the resources needed for peak summer loads when energy use increases above normal load to provide extra load for air conditioning.  The New York energy planners all recognize that when the CLCPA requires electrification of heating and transportation that the peak load will shift to the winter.  This leads to the bigger problem that the availability of solar and wind resources during the winter peak also has to be considered when it is expected to be much lower than in the summer.   I agree with the conclusion that the future worst-case will be a multi-day wind lull in the winter when solar energy availability is low and wind is also low but I am uncomfortable that analyses done to date adequately consider renewable resource availability during those periods.

I was unable to conclusively determine how worst-case meteorological conditions were addressed in the WIS:dom®-P approach.  The documentation states “The model was initialized and aligned with historical data from 2018 and then the simulations evolved the electricity system across the contiguous United States (CONUS) from 2020 through 2050 in 5-year investment periods”.  Elsewhere it states “Typically, seven calendar years are also simulated after a pathway solution is found. Future simulations will also include 175 years of 50-km, hourly data to determine the robustness of solutions”.   It also notes that the supply and demand balance equation set includes: “the weather-driven (wind, solar, and hydro) resource potential, charge/discharge cycles of storage and demand flexibility, and changes in demand requirements throughout the entire simulation period” among other things that suggests that the model incorporates meteorological effects on resources.  The formulation of the reserve margin (eq. 1.14.3) suggests that the calculations are on an annual basis:

The advantage of Eq. (1.14.3) is that it incorporates numerous years of weather data in a reduced form that is mathematically tractable. Some disadvantages persist. First, the minimum years (time step by time step) can jump around across the dataset. Secondly, the weather and demand are decoupled from each other. Finally, to understand the dynamics of conventional generation, storage and DSM, the original weather year time step data are used, which could underestimate their performance. Overall, however, it does provide a robust evaluation of the VRE contribution to planning reserve margins over a wide range of possible conditions.

This leads me to believe that the fatal flaw in the WIS:dom®-P approach is that the optimization occurs on an annual basis.  In order to ensure that adequate electricity is available when needed the most during the winter wind lull, the optimization balancing has to address the specific requirements of that period.  Unless the renewable resource availability constraints are addressed for the energy storage estimates during the worst-case period, the true magnitude of the resources needed to keep lights on during those conditions remains unknown.  Everyone else recognized this constraint and consequently raised a common concern about current renewable technology.

Conclusion

In the previous posts I wondered if the Climate Action Council will address the issues raised by the professionals or cater to the naïve dreams of the politically chosen members of the Power Generation Advisory Panel.  This analysis shows that the basis for their dreams of a “smarter” planning solution are dangerous because the supporting analysis does not address the worst case.  If electric planning does not address those worst-case conditions, then the inevitable result will be a Texas style blackout that will have enormous costs and result in people freezing to death.  The severe winter weather in Texas caused at least 151 deaths, property damage of $18 billion, economic damages of $86 billion to $129 billion, and $50 billion for electricity over normal prices during the storm.  This is comparable to the costs of superstorm Sandy.  However, the costs for one are preventable but the costs for a storm like Sandy are not.

Climate Leadership & Community Protection Act Reliability Planning Speaker Session

Note: When this was written and posted the recording was not available. The Session recording was posted on August 30, 2021

On July 18, 2019 New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act (CLCPA), which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency. Over the last year Advisory Panels to the Climate Action Council have developed and submitted recommendations for consideration in the Scoping Plan to achieve greenhouse gas (GHG) emissions reductions economy-wide.   On August 2, 2021, the New York State Energy Research and Development Authority (NYSERDA) held a Reliability Planning Speaker Session to describe New York’s reliability issues to the advisory panels and Climate Action Council.  If reliability is a key condition for CLCPA implementation then the briefing summarized here should have been held a year earlier.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   I briefly summarized the schedule and implementation: CLCPA Summary Implementation Requirements.  My posts describing and commenting on the strategies are available here. I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulationssummarized some of the meetings and complained that its advocates constantly confuse weather and climate in other articles.  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

There is a long history of blackouts in New York State in general and New York City in particular that is a primary driver of reliability concerns in the state.  After a blackout in July 2019 AMNY published a brief history of blackouts in New York City.  In 1959 and 1961 surges in electrical use caused blackouts and “The outage spurred changes to better protect the city’s power grid from future blackouts”.  The 1965 blackout was the first regional blackout and was caused by a transmission problem in Ontario causing a wave of disruptions in the transmission system.  Over 30 million people and 80,000 square miles in Ontario, New York, Connecticut, Massachusetts, New Hampshire, New Jersey, Pennsylvania, Rhode Island, and Vermont were left without power for up to 13 hours.   There was another blackout in 1977 that was limited to New York City directly related to the fact that most of the City is on islands and is a load pocket.  It was caused by storms cutting off transmission into the City and in-City generation was unable to replace the load without disruptions.  Without sufficient local power, protective devices turn off overloaded lines and transformers to prevent physical damage to the equipment and this led to the outages.  As a result of this blackout, reliability constraints were strengthened to ensure that when storms threaten transmission into the City that sufficient in-City generation is available to prevent a re-occurrence.  In 2003 there was another regional blackout caused by a computer software problem.  Grid operators identified the cause and then developed procedures to prevent it from happening again.  In 2012 tropical storm Sandy caused massive blackouts exacerbated by flood protection weaknesses.  Since then, there have been investments to strengthen the infrastructure to prevent a reoccurrence.  Reliability planning is a constant concern for the electrical system professionals who operate the system and are responsible for keeping the lights on.

The members of the Climate Action Council and the advisory panels who are charged with providing recommendations to meet the CLCPA targets were chosen because of their political connections not their energy system expertise.  During the development of the advisory panel recommendations, it was obvious that reliability was only receiving token consideration and that many of the panel and council members did not understand the issues and requirements for a reliable energy system.  As a result, I was one of many commenters who suggested that a briefing on the topic of electric system reliability would be appropriate.  Obviously, this presentation should have been held early in the process but later is better than never. 

Note:  At one point I found the August 2, 2021 speaker session presentation on a NY website but it not available at this time nor is the recording of the presentation available.  My downloaded copy of the presentation is available here.  I recommend reading the session presentation as it gives a good overview of reliability issues facing New York in the transition to net-zero.

The session included presentations from six organizations with varying levels of reliability background, experience, and responsibilities:

  • New York State Reliability Council – Mayer Sasson, Steve Whitley, & Roger Clayton
  • New York Independent System Operator (NYISO) – Zach Smith
  • Utility Consultation Group – Margaret Janzen (National Grid) and Ryan Hawthorne (Central Hudson)
  • New York State Department of Public Service – Tammy Mitchell
  • Vote Solar – Stephan Roundtree
  • New York Department of State Utility Intervention Unit – Erin Hogan

I will address each organization and their comments below.

Reliability Council

The New York State Reliability Council (NYSRC) is a Federal Energy Regulatory Council (FERC) approved entity responsible for “the promulgation of reliability standards for New York, which are mandatory requirements for the New York Independent System Operator”.   The presentation explains that one of the primary concerns of the NYSRC is the Installed Reserve Margin (IRM) which is the “minimum installed capacity margin above the estimated peak load to meet the Northeast Power Coordinating Council (NPCC) requirement that the probability of shedding load is not greater than one day in ten years”.   In order to determine that value the NYSRC conducts a “complex probabilistic analysis of generation and transmission resources, and demand response”.  Their presentation went on to describe in the following slide all the responsibilities of the operators who keep the system operating reliably.

The presentation explained that as the percentage of renewable resources increases operating the system must change and the planning for those changes must evolve.  It summed up this section as follows: “Limited fuel diversity and over dependence on energy limited resources is a risk to reliability”.

In the last section of the NYSRC presentation results from some planning work already done were presented.  Using an example of solar resource impact on resource adequacy it was shown that the “addition of 26,000 MW of new solar generation raises the reserve requirement to ≈22,000 MW & allows the retirement of only 4,000 MW of current resources” (my emphasis added).  The presentation went on to show that the addition of all the projected renewable energy resources needed to eliminate the use of fossil fuels in 2040 results in a reserve requirement of ≈50,000 MW in order to meet the CLCPA 2040 goals and the NYSRC Resource Adequacy IRM Reliability Criterion.  The current reserve requirement is around 6,000 MW.  It is important for readers to realize that this means that 50 GW of renewable capacity have to be developed in addition to the 12 GW of onshore wind, 10 GW of offshore wind, 17 GW of utility-scale solar, 6 GW of behind the meter solar, and 15 GW of energy storage projected in the NYS DPS/NYSERDA “Initial Report on the New York Power Grid Study” annual installed capacity supply mix for 2040 because that study did not address the IRM requirement.

The takeaway message of the NYSRC to the Climate Action Council was:

With the intermittency of renewables and the electrification of the economy, substantial clean energy and dispatchable resources, some with yet to be developed technology, over and above the capacity of all existing fossil resources that will be replaced, will be required to maintain reliability in the transition to meeting CLCPA requirements.

New York Independent System Operator

The NYISO Frequently Asked Questions webpage explains how the organization originated. After the Northeast Blackout of 1965, New York’s seven investor-owned utility companies established a predecessor organization, the New York Power Pool (NYPP), to address the reliability problems exposed by the blackout.  In the 1990s New York’s electric system was de-regulated and the Federal Energy Regulatory Commission (FERC) recommended the formation of independent entities to manage energy transmission and the NYISO was established to replace the NYPP.  Because the change to the wholesale electricity market is the reason for their existence, the NYISO unquestioningly supports market driven responses to any problem.

The NYISO manages the electric system.  They have to balance the instantaneous supply of electricity between the generators and customers across the state in the de-regulated electricity market.   They manage the supply of power and maintain the frequency across the state and with their connections to other operating systems.  In addition, the NYISO has to plan for future changes to the system.  At this time the biggest factor for change is the CLCPA. 

Unfortunately, in my opinion, the NYISO is not as independent as it should be.  In a recent post I explained how the Cuomo Administration has co-opted the NYISO to the point that their recommendations are couched in terms that do not adequately convey the enormity of the technical issues associated with this transition.  Moreover, their faith in market solutions de-values the risks of developing those solutions in the face of the fact this has never been done before.

In this light it is not surprising that the NYISO presentation emphasized their recent Power Trends 2021: New York’s Clean Energy Grid of the Future report that describes current and emerging trends transforming the grid and electricity markets.  The report describes how hourly demand patterns fluctuate diurnally and seasonally today.  It goes on to explain that the CLCPA de-carbonization efforts will change the magnitude and demand plans in the future, most notably the peak load will occur in the winter instead of the summer.  One NYISO analysis projected future winter energy production by resource type.

The important reliability finding of the NYISO work is that the worst-case future resource concern will be a winter-time wind lull.  During those periods solar resources are low because days are short and the sun is at a low angle, and wind resources can be less than 25% of the wind capacity for seven days at a time.  Consequently, there is a need for a large quantity of installed dispatchable energy resources needed for a small number of hours.  They must be able to come on line quickly and be flexible enough to meet rapid and steep ramping needs. The report does not come out and emphasize the important point that there is no current utility-scale resource that meets those criteria.

Utility Consultation Group

This is “A consortium of New York’s gas and electric utilities, focused on providing expertise and perspective to the Climate Action Council and its advisory panels”.  Given that most of these utilities are dependent upon rate case decisions made by representative hand picked by the Cuomo Administration there is an obvious reluctance to take a strong contrary position.  Given that Cuomo has threatened to revoke a utility operating license over a disagreement in gas supply, I have no doubt that there is real concern that a difference of a fraction of percentage point in any rate case  increases could easily make a difference in the stock price colors any statements by this organization.

The consortium fully supports the CLCPA goals even while noting that “customers will continue to value reliability, resiliency, and safety of the energy system during and after decarbonization”.  There is the hint that technology development is necessary which may make this a bit difficult and a plea that cost effective solution are necessary.  Finally, there is the obligatory shout out that environmental and economic justice need to be considered.

The presentation claims that the “Transition to a clean energy future is feasible, but must be orderly, responsible and cost effective”.  Heaven forbid that they suggest the transition is anything but feasible but where in the world is there proof that it is possible much less responsible and cost effective?  Given their situation they cannot say this is unlikely to work but it is disappointing that they did not respond with more concern about the potential difficulties.

New York State Department of Public Service (DPS)

DPS has oversight of utility reliability planning.  This covers traditional transmission & distribution investment planning and the utilities’ obligation to “reliably serve forecasted customer loads”.  There is a nuance to this that is not universally understood.  This process is used to ensure adequate transmission and distribution capability to serve customers but the production of the electricity itself is not included.  Instead, the wholesale market overseen by the NYISO provides the power.  Note that the power producers have no similar obligation to generate electricity.  The market is supposed to provide that incentive.  I believe there is a common misconception that somehow if things don’t work out that the generators are covered by some sort of obligation to serve but that is not true in the same sense as the T&D utilities.

The presentation explained that DPS constantly evaluates on a real time and forward-looking basis electric system reliability based on a multitude of factors and impacts including customer demands, planned and unplanned outages, weather, regulatory requirements, interconnection requests, and state policy.  It was noted that staff works with utilities on these matters but that the PSC has regulatory authority and responsibility to ensure reliability is maintained.  The presentation does not explicit make the distinction between T&D reliability planning and planning for generation.  Instead, it was explained that DPS staff participates actively in the NYISO planning process, NYSRC committees, and the NPCC board who do have the generation responsibilities.

In response to the CLCPA and Accelerated Renewable Growth Act, the Public Service Commission (PSC) issued orders directing the Utilities to undertake a study and to propose a planning and investment framework for local transmission and distribution investments driven by CLCPA.  The Utilities filed the study and their proposals for CLCPA investment criteria on November 2, 2020.  At the same time, the PSC and NYSERDA undertook two other studies.  One identified “possible grid interconnection points and offshore transmission configurations and assessed onshore bulk transmission needs to reliably integrate 9,000 MW of offshore wind generation”.  The second study identified “bulk transmission upgrades potentially necessary to support the State’s path to a 100% decarbonization of the electricity sector by 2040”.  The Power Grid Study filed on January 19, 2021 combines all three studies.

The presentation implicitly suggests that this work addresses all the problems.  It is important to note that their summary of reliability considerations makes many of the same points addressed in the NYSRC and NYISO as shown in the following slide.

Vote Solar

The purpose of this reliability presentation was to present the concerns of the organizations and professionals who are responsible for maintaining electric reliability.  In a blatant example of the political machinations that underly the CLCPA and implementation of the law, Stephan Roundtree, Jr., Northeast Director of Vote Solar  presented his take on reliability.  Mr. Roundtree holds a B.A. in History from Boston College, a J.D. from Northeastern School of Law, and a Master’s in Environmental Policy from Vermont Law School.  My point is that in addition to the fact that he is a crony capitalist representing an organization dependent upon the largesse of subsidies from laws like this, he has no apparent relevant utility-scale power system experience. 

Unfortunately, not only does he have no experience he is a member of the Power Generation Advisory Panel.  As such his presentation mirrors the reliability mis-understandings of many of the members of that panel.  Those mis-understandings are precisely the reason that many asked for this presentation.  In my opinion the reliability presentation is a year late in its attempt to provide the background information necessary for the panel to adequately do their job.  A reliability presentation should have been given to the Council and the Power Generation panel at the start of the process.  Admittedly it is not clear that the political appointees would have tried to understand the reliability difficulties described by those responsible organizations and people responsible for keeping the lights on.  As far as I can tell their politically valuable vested interests preclude listening to inconvenient facts much less trying to reconcile them with their pre-conceived notions.

Roundtree’s first slide lays down the gauntlet: “Not a question of whether we can or should shift the grid to be 100% renewable and maintain reliability; it’s the law”.  As someone with no reliability responsibilities that is easy for him to say.  Sadly, because the virtue-signaling politicians that wrote the law did not include a feasibility requirement before implementation of the “best in the nation” emission reduction targets it is the law.  However, if the scoping plan honestly describes the technical difficulties and costs, I cannot see how they can describe implementation of the law as feasible or affordable.  The big question is then what?

Roundtree describes three key takeaways: 

  1. Reliability is paramount, particularly for vulnerable communities in climate crisis;
  2. Integrating renewables into the grid while maintaining reliability is possible, and in fact cost effective;
  3. Aggressive adoption of a renewables-based grid is arguably the only lawful path to decarb and equity mandates

He accepts that reliability is “paramount” as the first takeaway.   He notes that “Lack of electricity service during extreme weather events impacts disadvantaged community members first and worst” and that “Interruption of electricity, combined with lack of wealth & resources, can lead to deepening poverty, housing insecurity, illness, and death”.  I agree with what he says.  However, I am sure he does not understand that the greatest threat to electric system reliability is ill-considered implementation of renewable resources in the manner he proposes.

In his introduction the second takeaway states that “Integrating renewables into the grid while maintaining reliability is possible, and in fact cost effective”.  In the presentation the second takeaway morphed into “Repowering or perpetuating fossil generation is not necessary for reliability”.  That was a majority position of the Power Generation panel but there was a minority opinion arguing that it is too soon to say whether that is possible.  As proof of the feasibility of a renewable power grid he argues that “Centralized fossil-based grids are proving to be unreliable in our changing climate and cannot withstand increasingly frequent extreme weather events” and cites the Texas energy debacle last February.  I don’t believe the 2021 Texas energy debacle was caused by renewable resources but it does foreshadow the difficulty replacing them when the wind isn’t blowing at night.  The lesson to be learned is that Texas energy policy prioritized and subsidized unreliable energy sources (wind and solar) at the expense of reliable ones (natural gas, coal and nuclear) for decades but did not incorporate market mechanisms to ensure that the system could operate under market conditions that had occurred in the past. 

He goes on to say that “modernizing the grid by adding demand flexibility, efficiency, and distributed energy resources including rooftop solar and storage but also EVs and microgrids is the solution we need to meet reliability needs of tomorrow” and that “renewables pair cost effectively with local grid modernizing infrastructure like storage and microgrid tech don’t have to pay the huge external cost of fossil”.  These claims are articles of faith amongst environmental advocates perpetuated by the grifters selling renewable solutions. 

The proof offered is a Rocky Mountain Institute analysis.  I reviewed their work and found that they selectively choose how they want to treat resources.  There are hopeful assumptions for distributed resources and battery energy storage that have no track record in utility-scale applications (hundreds of MW of capacity).  There is no consideration of life-cycle resources needed for all the batteries, solar panels and wind turbines. Finally, while the treatment of the technological components necessary to provide the resources are overly optimistic in my opinion, their treatment of costs is much worse.  Both current costs and expected cost expectations in the future are more aspirational than rational.  Roundtree also cites an advocate analysis that is contradicted by the NYISO analyses. Frankly I believe that Roundtree’s experience and background are ill-suited for him to realize that his cited proof is anything but evidence that his approach can work to keep the lights in New York City on during the worst conditions.

In the introduction his final takeaway was another veiled threat that “aggressive adoption of a renewables-based grid is arguably the only lawful path”.  This also morphed into “Local generation & storage promotes equity” in the presentation.  Again, his claims are articles of faith.  “Fossil pollution causes vast public health challenges which largely aren’t included in reliability vs transition discussion” is always highlighted as a religious tract but the fact that air pollution reductions from fossil pollution have led to large improvements in air quality while the purported health impacts haven’t also improve sis never addressed.  The true believers also claim that “Building renewables, batteries, and microgrids in high load disadvantaged communities results in improved public health and better preparedness / functionality during grid stresses and shocks”.  The first claim that green energy leads to better public health ignores the environmental and health impacts of the mining of rare earth minerals used in batteries and wind turbines.  The proposed solution will not eliminate environmental and health impacts it will just move them and, arguably, make them worse elsewhere.   The claim that renewables and batteries will improve functionality during grid stresses is unproven on the utility-scale.  The final rationale for this takeaway states that: “Prioritizing state investment in disadvantaged community local grid infrastructure is a pathway to meet CLCPA investment equity mandate” is probably true but should not be a prime reliability concern.

New York Department of State Utility Intervention Unit

The Division of Consumer Protection’s Utility Intervention Unit (UIU) is supposed to act on behalf of the ratepayer.  They represent “the interests of New York consumers before federal, state and local administrative and regulatory agencies engaged in the regulation of energy, water and telecommunication services”.  According to their about webpage:

The UIU participates in the deliberations of the Public Service Commission (PSC), the New York Independent System Operator (NYISO) and the Federal Energy Regulatory Commission (FERC), as well as utility and energy-related interagency working groups, task forces and committees. The UIU analyzes filings, submits testimony and briefs, engages in settlement discussions and participates in evidentiary hearings in PSC and FERC regulatory proceedings and participates in NYISO governance.

Their presentation starts off with an interesting quote by Peter Fox Penner, Institute for Sustainable Energy: “In a nutshell our challenge is to steer clear of the technical and institutional pathway that together yield poor service, expensive power, or a failure to decarbonize quickly.”  I agree that is the key challenge but question whether all of these goals are possible.  Of course, that it is possible to have affordable, reliable and emissions-free electricity is the fundamental basis of the CLCPA so no state agency can question the orthodoxy of it.  Nonetheless including this quote suggests that the agency representing consumer interests is aware of the problem.

The presentation goes on to show three graphic representations: the electric system of the past, the present, and what is supposed to happen in the future.  Then there is a slide that makes the important point that the one constant in all three cases is that load and generation must balance. Then considerations of changes in load over time are discussed.  In 2021 the question is “how are the decisions now going to impact prices in the future and adoption of electrification?”.  In 2025 the status must be evaluated to see if programs have reached their targets and where they stand.  In 2030 we have to ask if we reached the renewable goal.   In 2035 the question is “Are there any new technologies or improvements to existing technologies?”   In 2040, the question is whether the electric system has weaned itself off fossil fuels.  There are strengths, weaknesses, opportunities and threats every step of the way.  In their conclusion the importance of planning was stressed.  I suspect that the UIU is as uncomfortable as I am that the CLCPA does not include a feasibility mandate.

Conclusion

The warning in most of the presentations was similar: it will not be enough to depend on today’s technology to develop a reliable electric system with net-zero emissions.  The NYSRC notes that “substantial clean energy and dispatchable resources, some with yet to be developed technology, over and above the capacity of all existing fossil resources that will be replaced” needs to be developed.  The NYISO explicitly points out that a “large quantity of installed dispatchable energy resources is needed in a small number of hours” that “must be able to come on line quickly, and be flexible enough to meet rapid, steep ramping needs” but only implicitly points out that these are magical resources that do not exist yet for utility-scale needs.  The utility consultation group explains that “technology development and diversity of clean resources are essential for long term success” but provide no details of the enormity of that task.  Even the DPS makes the point that “evaluating and implementing advanced technologies to enhance the capability of the existing and future transmission and distribution system” is necessary for future reliability.  The Utility Intervention Unit does not provide a comparable warning but does stress the importance of planning and the need to address new technologies.   None of these organizations was in a position to state the obvious that relying on as yet unproven technology to transition the electric system on the schedule of the CLCPA is a serious threat to reliability.

As further proof that the CLCPA is at its root simply political showmanship and virtue signaling, the technical session on reliability allowed an organization with a vested interest in today’s inadequate renewable technology to be included.  Giving Vote Solar a chance to present the message that “integrating renewables into the grid while maintaining reliability is possible, and in fact cost effective” proves that the whole thing is politically motivated because the presenter had neither the background or experience to understand the dangers and the requirements to maintain reliability.  Moreover, the speaker has no relevant responsibility but the organizations and professionals who are responsible for keeping the lights on all made the point that as the need for sufficient levels of new clean energy resources increases during the grid transformation “some of these resources rely on technologies that do not currently exist for utility scale application.” 

Finally, note that problems with a similar transition are already being noted elsewhere.  In August 2020, California grid operators had to impose rolling electric blackouts to maintain grid reliability standards.  The basic problem was that power demand peaks as people turn on their air conditioning in the late afternoon just as the solar power supplies cut off as the sun goes down.  So little power was available the California grid operator had to reduce load to prevent an uncontrolled, much wider scale blackout in the event of a problem at an operating power plant.  The scale of that problem pales compared to the scale of the situation when the CLCPA requirements to electrify heating and transportation increase winter load and the elimination of fossil generation increases the dependency upon wind and solar electricity generation.  In the winter at New York’s latitude the days are short and the solar panels could be covered by snow.  When there is a prolonged cold snap accompanied by light winds both renewable resources will be unavailable and the only question is for how long.  With respect to reliability, planning for this worst-case availability scenario has to develop a system that can prevent a future New York blackout that could result in people freezing to death in the dark unable to flee. 

The ultimate question is whether the Climate Action Council will address the issues raised by the professionals or cater to the naïve dreams of the politically chosen members of the Power Generation Advisory Panel. Absent changes to the law itself I fear New York consumers will be lab rats for a politically motivated virtue signaling empty gesture that is going to cost enormous sums of money, and, in the event of a major blackout, cause much more harm than good.

Post Script: This text was drafted before Governor Cuomo resigned over sexual harassment allegations.  In my opinion his actions towards his accusers were the worst kind of bullying.  They are also symptomatic of his Administration’s micro-managing treatment of any dissent from any individual or organization in the state.  I am sure that there are many technical professionals in the staff of many state agencies involved in the CLCPA implementation that know that you cannot have an affordable, reliable, and emissions-free electric system but have no way to speak out with those reservations lest they jeopardize their careers.  They same can be said of organizations trying to provide value for their shareholders.  Hopefully, the new administration will at least consider the reliability risks brought up by the NYSRC, NYISO, Utility Consultation Group, DPS and Utility Intervention Unit.

Energy Storage Best Practices from New England

This article was published at Watts Up With That.

According to their website, the “Clean Energy States Alliance (CESA) is the leading US coalition of state energy organizations working together to advance the rapid expansion of clean energy technologies and bring the benefits of clean energy to all”.  On August 5, 2021, they released “Energy Storage Policy Best Practices from New England: Ten Lessons from Six States” that “explores energy storage policy best practices and lessons learned from the New England states.”  This post gives an overview of the report.

The report “aims to inform state policymakers and regulators seeking to expand energy storage markets”.  I will address the following ten recommendations that “each state should consider as it charts its own course”:

  1. Identify benefits of energy storage that are not priced or monetizable in existing markets; recognize and accommodate the multi-use nature of energy storage resources.
  2. Establish a monetary value for each storage benefit and use those values when calculating cost effectiveness and setting incentive rates. Estimated value is better than no value at all.
  3. Create incentives to support storage operations that further state policy goals. Incentivize storage use, not just storage deployment.
  4. Set ambitious clean energy and/or emissions reduction goals and explicitly include energy storage as an eligible technology. Define how storage is expected to be deployed and operated to help meet the goals.
  5. Incorporate energy storage into existing clean energy and efficiency programs.
  6. Incorporate equity considerations into energy storage program design from the start, not as an afterthought.  This should include significant incentive adders for qualifying participants.
  7. Support a wide variety of storage ownership, application, and business models.
  8. Anticipate and proactively address needed regulatory changes.
  9. Replicate and improve on successful programs implemented in other states.
  10. Fund demonstration projects when needed, but do not rely on grants alone to build a market.

After Superstorm Sandy struck New York City the importance of resilient power became evident to the green energy policy makers and the idea that battery storage could help was broached.  The report states that their efforts began “with the idea that advanced battery storage—especially when combined with rooftop solar and other energy resources—could provide clean, resilient backup power, allowing critical facilities such as emergency shelters and health clinics to ride through future grid outages.”   A frequently used example of the viability of distributed systems is a hospital in Princeton, NJ that remained on-line despite widespread grid outages due to Sandy.  Unfortunately, proponents of these distributed energy approach who cite this as proof of the viability of the concept don’t mention that the hospital had a natural gas fired backup system.  The presumption that coupling battery storage with renewable resources will work as well is untested in practice.

The report goes on to note that energy storage can be used to provide other energy services: “demand management, frequency regulation, grid infrastructure investment deferral, renewables integration, and load shifting.”  The report claims that: “As the list of possible storage applications expanded, state storage policy would need to become more sophisticated, and state utility commissions would need to review many regulations that had been written prior to the widespread availability of advanced battery storage, which now needed to be revised to accommodate this new technology”.  The ten recommendations address these points.

The first recommendation is to “Identify benefits of energy storage that are not priced or monetizable in existing markets and recognize and accommodate the multi-use nature of energy storage resources”.  The example benefit given is behind-the-meter (BTM) resilient power that is the ability to support critical facilities and infrastructure during an electric grid outage.  As proof they note that that is “widely recognized as having value—otherwise, there would not be a thriving market for backup generators.”  The claim is that “Battery storage, when properly configured, can provide resilient power, and this is one of the storage applications that customers value most highly.”  Therefore, they recommend that the states figure out some way to monetize this benefit.  However, in my case while I chose to install a generator because resilient power is important to me, I wanted the system to be able to handle the multi-day outages I have experienced due to a wind storm and an ice storm.  In both cases there is no way I could have installed enough rooftop solar and storage to provide power throughout those days-long outages.  Resilient power needs are for the worst case, not just most of the times the power goes out.  The worst case is a long duration extreme hot or cold weather situation and energy storage is a poor choice for those scenarios.

In this recommendation, the report states that “Advanced energy storage can provide a wide variety of energy services, and storage owners frequently need to “stack” multiple services (each representing a revenue stream or cost savings opportunity) in order to make storage investments economic.”  It includes a highlighted section that discusses a “multi-use” resource.  While it recognizes that the different services are “not necessarily” available at the same time, it goes on in Table 1 to list the ratepayer individual savings for six beneficial services then sums for the total.  Clearly, this is not appropriate.

The second recommendation is to “Establish a monetary value for each storage benefit and use those values when calculating cost effectiveness and setting incentive rates. Estimated value is better than no value at all”.  The paper lists values for seven non-energy benefits of distributed storage in Massachusetts.

The first claimed benefit is Avoided Power Outages – “Battery storage helps avoid outages, and all of the costs that come with outages for families, businesses, generation and distribution companies”.  I agree that outages have costs for families and businesses and battery storage that can reduce or eliminate them clearly has value.  However, the only way I can think that outages would affect generation companies is if there is a power plant outage and energy storage is used during the outage but the existing system has enough spare capacity to handle that concern.  I cannot think how energy storage would reduce costs for a distribution company.

The second value is Higher Property Values – “Installing battery storage in buildings increases property values for storage measure participants by: 1. Increasing leasable space; 2. Increasing thermal comfort; 3. increasing marketability of leasable space, and 4. reducing energy costs”.  My understanding is that energy storage systems need space so it is unclear how they would increase leasable space.  The other three benefits also seem to be stretch the concept of “value”.

Next is Avoided Fines – “Increasing battery storage will result in fewer power outages and fewer

potential fines for utilities”.  I have no clue how energy storage can provide this benefit.  Utilities get fined when they don’t plan for enough resiliency in their system to prevent extreme weather impacts on their transmission and distribution systems.  Energy storage cannot prevent power outages caused by damages to the wires.

The fourth value is Avoided Collections and Terminations – “More battery storage reduces the need for costly new power plants, thereby lowering ratepayer bills, and making it easier for ratepayers to consistently pay their bills on time. This reduces the need for utilities to initiate collections and terminations.”  The ability of battery storage to reduce the need for new power plants is an article of faith amongst the advocates of this technology.  However, the claims are long on rhetoric and short on quantitative analysis.  If an old power plant has to be replaced it would take one heck of a lot of energy storage to provide the output of any natural gas fired turbine.   Until I see their numbers then I will continue to believe that the costs of sufficient energy storage coupled with renewable resources would be far more than the costs of a new turbine.

The fifth value is Avoided Safety-Related Emergency Calls – “Increasing battery storage results in fewer power outages, which reduces the risk of emergencies and the need for utilities to make safety-related emergency calls”.  In theory if a customer has a need for uninterrupted power a personal battery storage system could reduce emergency calls.  However, you are back to the issue of energy storage capacity versus outage time.  If I have the need for uninterrupted power, I want it available for long durations.  In order to provide that with energy storage I have to purchase so much capacity for such a rare event that it cannot be cost effective relative to a generator.

The sixth value in the document is Job Creation – “More battery storage benefits society at large by creating jobs in manufacturing, research and development, engineering, and installation”.  I have my doubts about this claim but don’t want to do the research necessary to refute this.

The last value in this recommendation is Less Land Used for Power Plants – “More battery storage reduces the need for peaker plants, which are more land-intensive than storage installations—benefiting society by allowing more land to be used for other purposes.”  This is only true at the facility itself.  However, the grand plan is to combine energy storage with power generated from wind and solar power.  Ignoring the vast land use requirements for enough coupled energy storage and diffuse renewable generation is an egregious oversight as shown in the following picture from the report.

The third recommendation is to “Create incentives to support storage operations that further state policy goals. Incentivize storage use, not just storage deployment.”  The report states that because

“clean energy incentives generally support broader policy goals such as energy sector decarbonization, electrification, sustainability, modernization, efficiency, resilience, and reliability” that the “energy storage incentive program should not be about ‘storage for storage’s sake,’ but should be designed to support specific policy goals”.  The report notes that battery storage can “provide several different services depending on how it is used” so it suggests that “a state energy storage program must actively link the use of battery systems to applications that support specific policy objectives. However, it does not recognize that battery systems that support one policy objective cannot necessarily support all other policy objectives.  For example, batteries used for energy storage when intermittent renewables are not available need to be kept charged at their maximum capacity but batteries for frequency regulation and to smooth intermittent fluctuations in supply are kept at an intermediate capacity so that they supply power and draw power as needed.  Consequently, I believe the report underestimates the amount of energy storage needed.

Furthermore, there is another example of the disconnect between energy storage by itself and energy storage coupled with renewable energy to solve intermittency.  Figure 4A, Misaligned Financial Signals claims that a California energy storage program to reduce emissions was set up incorrectly because “battery owners frequently discharged their batteries during low emissions periods, rather than charging when emissions were low and discharging when they were high”.  Honestly, I don’t think the author understands emissions control programs or diurnal peak loads.  Time of day emissions matters for conventional air pollution but does not matter for GHG emissions because GHG contribute only to a global long-term alleged problem.  Diurnally, California renewable energy primarily comes from solar which peaks during the middle of the day.  Figure 4A shows the batteries being charged during the day and then discharging later in the day causing the emissions to go to zero.  Diurnal peak loads are usually in the late afternoon so even though there are emissions in the middle of the day the program eliminated emissions during the peak period – it worked precisely as it was supposed to if the goal of the program is to reduce nitrogen oxides for ozone attainment.  The “solution” shown in Figure 4B is simply switching the charging source to wind because if it is charging in the night, it certainly is not coming from solar. 

The fourth recommendation is “Set ambitious clean energy and/or emissions reduction goals and explicitly include energy storage as an eligible technology. Define how storage is expected to be deployed and operated to help meet the goals.”  Regulators take ambitious goals as an article of faith believing that somehow the goals can be met because previous air pollution control programs have always met their goals.  The concept that feasibility should be considered is not an element of many regulators and no politician’s thought process.

The next recommendation is “Incorporate energy storage into existing clean energy and efficiency programs.”  I think this is pretty obvious so no comment.

The sixth recommendation is “Incorporate equity considerations into energy storage program design from the start, not as an afterthought.  This should include significant incentive adders for qualifying participants.”  The rationale for this is:

Low-income and underserved communities spend proportionally more of their income on energy costs than other segments of the population. They are also more likely to suffer from energy related environmental and health burdens; and they are hit hardest by natural disasters and the accompanying grid outages and have fewer resources with which to recover. In short, they are most in need of the cost savings, resilience, and health benefits energy storage can offer.

This is another example of limited thinking.  While I do not dispute the underserved communities are disproportionally impacted by environmental impacts and extreme weather events the presumption that cost savings will accrue from clean energy are not supported by the experience of any jurisdiction that has tried it.  Furthermore, if society not only subsidizes clean energy but also attempts to provide it to those who cannot afford existing energy then it only increases the costs to everyone else.  Most importantly, those who may be just able to afford energy bills now but will not be able to afford them in future net-zero energy systems will be impacted by this recommendation.

The recommendation listed in the introduction as “Anticipate and proactively address needed regulatory changes” apparently morphed into the seventh recommendation in the report “Pay attention to regulatory friction points” during the documentation preparation process.  The point of the recommendation is that there may be unintended consequences when new energy storage policies are adopted.  The analogy used is regulatory whack-a-mole where the states will have to “spend several years fixing problems one at a time as they pop up” after they implement a new rule.  In my opinion this should be addressed as part of the feasibility study that most advocates don’t think is necessary.  However, the presumption that all the problems associated with converting an energy system using dispatchable energy sources that has taken decades to evolve to one utterly dependent upon intermittent energy sources in a decade or two can be anticipated is wishful thinking.  Anyone in a net-zero jurisdiction will be a guinea pig for this experiment.

The eighth recommendation is “Support a wide variety of storage ownership, application, and business models”.  The rationale is that energy storage can “integrate renewables and make regional grids more efficient, reduce transmission congestion, defer distribution grid investments, make variable generators dispatchable”. It is also claimed that it can “flatten demand peaks, balance microgrids, make critical infrastructure resilient, and provide ancillary services”.  Not noted is that these applications are mostly theory and, especially in a de-regulated market, developing business models that work for both society and the grifters selling energy storage as the solution to anything and everything will be a challenge.

The ninth recommendation is “Replicate and improve on successful programs implemented in other states”.  Obviously, there is no sense reinventing the wheel so this makes sense.  However, “success” has to be defined well because it can be in the eye of the beholder.

The last recommendation is to “Fund demonstration projects when needed, but do not rely on grants alone to build a market”.  As I read this document, I became more and more convinced that the author had limited electric energy system experience.  He claims that “there is little need to demonstrate another utility-scale lithium-ion battery providing peak demand reduction and frequency regulation services when numerous such projects already exist in the region”.  The report is illustrated with pictures and descriptions of five energy storage facilities with the largest having an 8 MWh duration and totaling 22.4 MWh.  The average daily load in New England is 260,120 MWh so those facilities are inconsequential.  I don’t think there is any question that in these micro grid applications that batteries can provide peak demand reduction and frequency regulation services.  I question whether the author understands that the issue is a matter of scale and it is not at all clear that peak demand reduction and frequency regulation is feasible when non-dispatchable resource penetration is significant.  Ultimately it is obvious that ratepayers cannot provide grants for all the energy storage projects needed to try to support the utility grid. 

Conclusion

The report concludes that “With falling battery prices, increasing adoption of state clean energy and decarbonization goals, and forward-looking utilities (and ratepayers), many states have a strong foundation for success”. The report is supposed to offer “some suggestions to policymakers for building on that foundation”.

I am unconvinced that this report provides any value.  The report was not proofed well because wording of the ten recommendations in each chapter do not match the description of the ten recommendations in the introductory text.  I was prompted to write this article by the following quote from the introduction: “In Vermont, for example, Green Mountain Power’s residential battery program has placed battery systems in more than 3,000 homes; the utility dispatches this aggregated, distributed energy storage resource to reduce peak demand, saving ratepayers millions of dollars.”   The report notes that the “Stafford Hill solar farm includes 7,700 solar panels capable of producing 2.5 megawatts (MW) of electricity, enough to power 2,000 homes. Therefore 3,000 homes are powered by 3.75 MW.  I would love to see the math that produces millions of dollars of savings from shaving peaks by 3.75 MW.  I just don’t think this is credible and indicates a lack of knowledge about electric systems by the author.

I believe there is a fundamental oversight not mentioning that stacking energy storage applications is problematic.  A single energy storage system cannot supply all the different resources suggested (e.g., by summing the benefits of each resource in Table 1) in this report.  There is another fundamental issue with the report because it considers energy storage by itself.  Batteries are supposed to solve non-dispatchable renewable energy issues.  Claiming that energy storage improves resilience when the coupled energy input is fragile and intermittent is at best a stretch.  Finally note that there was very little in the way of caveats and cautions with respect to this unproven, at utility scale and using renewables, technology.  As a result, policy makers will not get a full appreciation of the challenge of this transition.

Climate Leadership & Community Protection Act Feasibility Relative to NYSERDA Patterns and Trends

I recently published an article describing how the New York State Energy Research and Development Authority (NYSERDA) Patterns and Trends – New York State Energy Profiles: 2003-2017  (“Patterns and Trends”) comprehensive summary of energy statistics and data could be used to assess where the state stands now relative to Climate Leadership and Community Protection Act (CLCPA).  I looked at data up to 2017 to assess the status of two targets: 70 percent of electricity from renewable sources by 2030 and 100 percent carbon-free electricity by 2040. Because the data in the report is three years old, I stated that it was difficult to assess feasibility using historical energy use data.  This article addresses feasibility by projecting energy use requirements.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed are not feasible with present technology, will adversely affect affordability and reliability, that wind and solar deployment will have worse impacts on the environment than the purported effects of climate change, and, at the end of the day, meeting the targets cannot measurably affect global warming when implemented.   The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

For anyone interested in New York energy information the Patterns and Trends documents are a great resource.  One thing that I particularly like is that when you click on a table there is a link to a spreadsheet with all the data.  For space reasons the report does not list all the numbers but the underlying spreadsheet includes everything.  Unfortunately, during the Cuomo Administration, the annual updates are lagging further and further behind.  In January 2011, the report updated with data through the end of 2009 was published 13 months after the end of the year.  The latest report available, Patterns and Trends – New York State Energy Profiles: 2003-2017  (“Patterns and Trends”) publication date was March 202,1 38 months after the end of 2017.. 

In the previous article I explained that Patterns and Trends data showed that in 2017 30% of the electricity generated in the state came from fossil fuels and that nuclear provided 32%.   In 2017, hydro provided 18%, municipal solid waste, biomass and geothermal provided  2%, solar had yet to show any significant generation and wind provided 3%.  The CLCPA defines renewable energy sources as wind, solar, biomass, geothermal, hydro and nuclear so recent trends in those sources are important to detemine feasibility of the 2030 goal.

New York Historical Energy Source Calculations

Figure 1 lists the percentage trend of the sources of electric generation in New York State (NYS) from 2001 to 2022.  This section describes the methology and assumptions used to develop those data. 

In order to determine the feasibility of the 70% renewable by 2030 target these data list four source categories: fossil fuels, imports, nuclear and all the other categories lumped together as CLCPA renewables.  I broke out nuclear to show the impact of the retirement of Indian Point nuclear station.  The CLCPA renewables categories includes biomass and municipal waste generation that I think may not be acceptable as CLCPA renewable at the end of the day but for now they are included.

The data from 2001 to 2017 is directly from Patterns and Trends.  The data from 2018 to 2020 comes from a variety of sources.  The total electric load used the baseline annual energy forecast from New York Independent System Operator (NYISO) Gold Book 2021 Table I-1b: Summary of NYCA Baseline Annual Energy Forecasts – GWh.  The projected category values are set up to equal these load projections.  The fossil category data are based on heat input data from EPA Clean Air Markets Division reported emissions data.  I included a 1.05 multiplier adjustment to account for difference between historical EPA and NYISO Btu data.  The NYISO Gold Book observed data for the nuclear, wind, and other generation sources was used.  Hydro used the maximum value of the last ten years from Patterns and Trends.  Utility scale solar was assumed to increase linearly to 5 TBtu by 2020.  Imports were calculated as the sum of the maximum observed value over the last ten years from Patterns and Trends plus whatever energy was needed to balance the total electric load and sum of all other categories.  In other words, it was assumed that imports made up the differences in total component loads to total energy forecast load.

It is difficult to make supportable projections but I did want to illustrate the effect of retiring the Indian Point nuclear station so I did project energy use in the best case in 2021 and 2022.  The total electric load used the baseline annual energy forecast from New York Independent System Operator (NYISO) Gold Book 2021 Table I-1b: Summary of NYCA Baseline Annual Energy Forecasts – GWh.  For fossil use I took the 2020 data minus the annual reductions necessary to get to zero in 2040 by straight extrapolation.  Hydro used the maximum value of the last ten years from Patterns and Trends.  The nuclear electric production was set to the average of the last five years of all nuclear facilities less Indian Point.  Eliminating the load from Indian Point units 2 and 3 removes 15,774 GWh of CLCPA renewable energy from the NYS electric system.  I assumed that waste, land-fill gas and wood are assumed to stay constant at 26 Tbtu, the rounded maximum value in last ten years.  With regards to other renewables note that distributed solar is included in the NYISO total load projections.  For utility-scale solar and wind I used Energy Information Administration Table 54.  Electric Power Projections by Electricity Market Module Region for two New York State regions to estimate the total renewable capacity (GW) additions.  I assumed future utility-scale development will be 50-50 solar and wind with a combined capacity factor of 23% to estimate total energy produced in GWh.  I used Patterns and Trends data to develop a conversion factor based on recent data to estimate TBtu.  As an aside note that for some reason this conversion factor has been changing the last five years contrary to all other sectors.  Finally I believe that the EIA projections for future capacity development are wildly optimistic – 1640 MW are supposed to come on line in 2021.

Current New York Energy Sources

Figure 1 lists the percentage trend of the sources of electric generation in New York State (NYS) from 2001 to 2022.  In 2001, nuclear provided 28% of the energy and other CLCPA renewable sources another 16% for a total of 44%.  Fossil fuels provided over half the energy and imported energy made up the remaining 5%.  In 2020, nuclear provided 30%, down from the high of 32%, other CLCPA renewable sources provided 24% for a total of 54% of CLCPA renewable energy, fossil was down to 32%, and imports up to 15%.  I project that in 2022, the retirement of Indian Point will reduce nuclear down to 21% and that other CLCPA renewable sources will increase to 30% for a total of 51% of CLCPA renewable energy.  The assumption that fossil fuel use will decrease reduces its share to 29% but increases imports to 20%. 

Eight years after the projections in Figure 1, nuclear and the Climate Act renewable energy category are supposed to provide 70% of the energy to produce electricity.  Those categories only comprise 51% in 2022 in my projection.  Estimating the future growth of those categories is difficult but one key factor should be noted.  Despite the supposed urgency of reducing fossil fuel emissions, the Cuomo Administration shut down Indian Point nuclear station which generated 165 TBtu of energy or about 12% of the total energy of the state.  In order to replace that energy four times as much wind capacity as currently exists has to be developed.  Until such time as the renewable resources to replace the lost nuclear are developed, fossil fueled energy or imported energy has to pick up the necessary load.  In this projection it was assumed that imported energy picked up the load but it is likely that fossil will replace much of the load because of transmission constraints to New York City and Long Island.

There is another aspect to imported electricity that I cannot address.  The CLCPA requires that out-of-state resource renewable attributes be defined so that there is no leakage, that is to say the emissions just move out of state and are not reduced.  Unfortunately, I cannot find any information on the attributes of out of state electricity so I cannot comment on how this will affect meeting the target.

CLCPA 70 percent of electricity from renewable sources by 2030 Feasibility

Now that the status has been established we can look towards 2030.  I changed my methodology to use GWhr instead of TBu to compare different sources.  I based my projections on the feasibility of meeting the 2030 load requirements for wind and solar on the following assumptions.  I assumed that the electricity provided by imports, hydro, geothermal, biomass and municipal waste generation all equal the average of the Patterns and Trends data for 2015 to 2017.  Nuclear generation was also set at the 2015 to 2017 average less Indian Point nuclear station energy.  I calculated the annual reductions needed to meet the 2040 zero fossil fuel emissions target and used the 2030 value.  Using those assumptions that means that wind and solar generation have to meet the difference between the sum of those categories and the total load projected by NYISO or 37,256 GWhr.

There are two CLCPA targets for renewable development.  In 2025 the target is 6,000 MW of solar and by 2035 there is a target for 9,000 MW of off-shore wind.  The NYISO Gold Book projections for total load assume that all of the 2025 solar goal is behind the meter so their load forecasts incoporate the target.  For utility solar by 2030 I assumed three scenarios for solar deployment up to 6,000 MW.  For 2030 offshore wind I assumed three scenarios: all 9,000 MW in 2030, only the current 4,300 MW under development and a third scenario midway between those two.  For on-shore wind I assumed total capacity would be 1,.5, 2, and 2.5 times the current capacity.  This gives a low, medium and high range of potential wind and solar deployment.

Table 1 lists the capacity (MW), capacity factors, and projected energy (GWhr) from all the scenarios and four total scenario projections.  Scenario 1 uses the low end estimates for all sources and has a deficit of 11,736 GWhr.  Scenario 2 uses the mid-point estimates for all sources and has a 1,735 GWhr surplus.  If al the estimates are at the high end in Scenario 3 there is a surplus of 15,205 GWhr.  My personal best guess (Scenario 4) is mid point for utility solar and on-shore wind but the low estimate for off-shore wind because the entire infrastructure to develop off-shore wind has to be built first.  That scenario has a deficit of 6,500 GWhr.

I believe that a major problem with meeting the target is that permitting and construction will slow the deployment of solar and on-shore wind.  I reviewed wind and solar project applications for New York’s Article 10 permitting process to get an idea of the magnitude of development for the bracketing scenarios .  Based on the solar applications between 19,000 and 56,000 acres and between 6 and 18 million solar panels will be needed for the solar scenarios.  The wind applications suggest that between 15 and 25 projects with 60 turbines at each site and that between 900 and 1,500 3.3 MW turbines will be needed for the on-shore wind scenarios.  The off-shore wind project information is too scanty at this point to develop similar information.  This many projects with such extensive scopes inevitably fail to meet schedules.

Conclusion

While the results shown suggest that meeting the 2030 target can be met in two out of four scenarios there is a big issue with the approach used.  Replacing fossil and Indian Point annual energy output with intermittent wind and solar energy outut is not a one for one energy substitution.  While a wind turbine can provide a certain amount of energy during a year, it is not dispatchable.  Because the total annual load is based on the sum of varying loads over hours, days and seasons, much more intermittent wind and solar capacity is needed to replace the dispatchable capacity that produced historical energy and maintain a reliable system that provides electricity whenever and wherever it is needed.  The real test of feasibility is to determine the amount of solar and wind necessary to meet the worst case situation – a wintertime wind lull when both wind and solar generate minimal levels of power.  Therefore do not believe any claims for feasibility that are based only on annual energy output.

I want to re-iterate the point that these data do illustrate one hypocritical aspect of the CLCPA and New York energy policy.  The CLCPA includes nuclear generation in the definition of acceptable “renewable” sources of electricity.  The CLCPA is supposed to protect New Yorkers from the existential threat of climate change but New York energy policy retired nearly 2,000 MW of acceptable renewable power when Indian Point was retired.  If the threat of climate change is so pressing how can that be justified?  The replacement of the annual power produced by Indian Point will consume all of the off-shore wind currently under development so at a minimum it makes meeting the CLCPA targets that much more difficult.