NESE Pipeline Alternatives for National Grid

The Northeast Supply Enhancement (NESE) pipeline is a proposed pipeline to bring natural gas to New York City and Long Island.   I sent Comments submitted 27 March 2020 in a New York Department of Public Service proceeding related to denial of service requests by National Grid in New York City and Long Island which is associated with this project.  This post describes what is going on, the proposal to resolve the issue and my comments on the proceeding.  Be forewarned there is a lot of material to cover so this is a long one.

Purpose

The request for comments is in regard to a requirement to come up with alternatives to provide additional natural gas supply to National Grid’s service territory on Long Island.  In this section I explain what happened to the original plan to fix the problem and events leading up to the current discussion.  On May 15, 2019 the New York State Department of Environmental Conservation (NYSDEC) denied a water-quality permit for the NESE natural gas pipeline that would bring more natural gas to New York City and Long Island.  On May 24, 2019 National Grid imposed a moratorium on new natural gas connections In New York City and Long Island because they could not guarantee enough supply for additional customers based in part because the pipeline was blocked.  In late November 2019 National Grid relented and started doing hookups for new customers following threats from Governor Cuomo to pull their license to operate.  The fact remains that the there is still a problem so National Grid has developed a collaboration for a “safe and reliable energy future”.  I submitted my comments in response to the public outreach program related to this effort.  Once that effort is complete all the feedback will be collected and reviewed, and the National Grid will issue a supplemental report that summarizes and includes public and customer input.  This is supposed to “enable an agreed long-term solution(s) with New York State by June 2020” so that the solution(s) can be in place and in operation by the winter of 2021/2022.

Water Quality Permit Denial

In order to ensure adequate supplies Transcontinental Gas Pipe Line Company (Transco) proposed the Northeast Supply Enhancement Project (NESE).  The permit application project description states:

The NESE Project is a 26-inch diameter pipeline proposed by Transcontinental Gas Pipe Line Company LLC (Transco) that would transport natural gas from Pennsylvania through New Jersey, traveling underwater in the Raritan Bay and Lower New York Bay to approximately three miles offshore of the Rockaway Peninsula in Queens Borough. Approximately 23.5 miles of underwater pipeline will be installed, of which approximately 17.4 miles would be in New York State waters.

The NESE Project would connect to the existing Rockaway Delivery Lateral in Queens and would provide 400,000 dekatherms per day of incremental capacity to National Grid to serve customers in Brooklyn, Queens, and Long Island. According to Transco, the project is intended to support reliability as well as help displace the use of oil.

The NESE Project would be installed a minimum of 4 feet below the sea floor through a combination of jet trenching, clamshell dredging and horizontal directional drilling (HDD). Construction would be phased to avoid potential impacts to marine species. If permits are ultimately issued, compensatory mitigation would be required to offset unavoidable impacts to benthic resources, including shellfish.

On May 15, 2019, the NYSDEC denied the application for the required Clean Water Act Section 401 Water Quality Certification based on their review of the permit and over 14,000 public comments received on behalf of 45,000 individuals. The full decision (PDF) is outlined in a letter by Daniel Whitehead, Director, Division of Environmental Permits, NYSDEC.  I summarize the rationale below.

Because this is an interstate pipeline project the Federal Energy Regulatory Commission (FERC) has to approve the application to build the pipeline.  On March 27, 2017, Transco submitted to FERC an application for a Certificate of Public Convenience and Necessity for construction and operation of the Project. FERC issued a Draft Environmental Impact Statement (DEIS) on March 23, 2018. The NYSDEC submitted comments to FERC regarding the DEIS on May 14, 2018 and FERC issued a Final Environmental Impact Statement (FEIS) for the Project on January 25, 2019. The FEIS outlined some of the numerous environmental impacts FERC anticipated from the construction and operation of the Project. On May 3, 2019, FERC issued Transco a Certificate for the Project subject to certain environmental conditions recommended in the FEIS. According to FERC, these conditions would mitigate many of the environmental impacts associated with the Project.

Even though FERC approved the project Transco still had to get a Water Quality Certificate from New York State.  After the usual iterations between the applicant and the NYSDEC, the application for the Certificate was deemed complete on January 30, 2019.  When the application went out for public comment well over 90 percent of the 14,000 public comments opposed the Department’s issuing a Certificate.  On the basis of their review of the application and public comments, NYSDEC determined that there would be significant water quality impacts.  This includes “significant water quality impacts from the resuspension of sediments and other contaminants, including mercury and copper. In addition, as proposed, the Project would cause impacts to habitats due to the disturbance of shellfish beds and other benthic resources.”

All environmental impacts involve tradeoffs.  If resuspension of sediments were the deciding criterion and prohibited in every instance then no project that disturbed an underwater surface could proceed – no bridges, no docks, nothing.  For that matter fisherman’s dredges that are towed along the bottom could be prohibited.  In a rational world, the fact that all those activities and the construction of a pipeline are short-term would be considered and if the overall long-term benefits to society out-weigh the transient impacts then the permit would be approved.  This instance is complicated by the fact that the sediments are contaminated, so mercury and copper limits could be exceeded.  Again, if this is the criterion, then no work that disturbs sediments in New York harbor should be permitted.  Another unavoidable impact is habitat disturbance and the same trade-offs apply.  However, the State could have required Transco to rehabilitate the disturbed shellfish beds after the pipeline was installed.

This is an example of hypocritical decision making by the Cuomo Administration.  NYSDEC rejected the National Fuel Gas Empire Pipeline application for a new 97-mile pipeline because it would have caused permanent impacts to 2.335 acres of wetlands within the 73.377 wetland acres impacted.  The poster child for Cuomo hypocrisy is the rejection of the Finger Lakes LPG application for an underground storage facility because of “significant adverse impacts on community character” when the only visible infrastructure was a small pond and a building. On the other hand agencies have approved the Cuomo-correct applications for off-shore wind farms which will permanently disturb much more of the seafloor than the NESE pipeline would have temporarily disturbed, approved projects that permanently disturbed wetlands but allowed the developer to create compensating wetlands, and approved wind and solar applications that have significant impacts on community character.  There is absolutely no question in my mind that the professional staff at NYSDEC and the other NYS regulatory agencies, if left to make permitting decisions based on their experience and the facts of the case, would have approved all of the rejected applications. The reason there were rejected was the Cuomo Administration.

National Grid Moratorium

National Grid’s problem is that they have determined that there is not enough current gas supply to serve future customers.  In their report they explained that 85% of the gas used on the coldest days is used for heating.   If they don’t have enough gas available then service to existing customers will be jeopardized and that means heating supplies will be at risk.  In my comments I provided references that conclusively show that cold weather is more impactful on health than hot weather and I have also shown that claims that hot weather is worse are based on a reporting artifact related to different lag times for hot and cold effects.  Therefore, National Grid has the moral responsibility to ensure heating supplies are available and the State should support those efforts.

Gas supply is regulated by the Public Service Commission (PSC) so the projection methodology is comprehensive and well-documented  When a utility company calculates how much supply they have, how much they are using and how much they will need in the future to argue that they need more supply  infrastructure, the first thing PSC staff does is generate their own analysis using the same methodology.  The two sides compare projections to determine if there are differences and reconcile the numbers.  My point is that the assumptions used in these calculations have been developed over the years to ensure adequate and reliable gas supply and they should not get changed at the whim of anyone.

Faced with their analyses that show they don’t have enough gas for future additions and with the rejection of the solution that they had planned to use to resolve the problem National Grid announced that they had to put a moratorium on new supply hookups.

Cuomo’s Response to the Moratorium

In the fantasy world of Cuomo’s New York, numbers, facts, and precedence don’t matter.  It is all about Andy.  Once people could not get the preferred alternative of a natural gas hookup they squawked and the politician saw an opportunity to cater to voters. His response was to have the Public Service Commission order National Grid to provide natural gas hookups.  According to the New York Post “The Public Service Commission said it has the authority based on a section in Public Service Law that says if a gas company is unable to meet the needs of reliable service to customers, the state has the power to step in”.   Following established State practice National Grid calculated how many customers they could handle and cut off any additional customers when the infrastructure proposed to resolve the problem was rejected by the State.  Obviously National Grid was unable to meet the needs of customers solely because the State would not let them,

Furthermore, Cuomo huffed and puffed a threat to revoke the operating license for National Grid if they did not comply.  Now here is where the precedence issue arises.  The Department of Public Service (DPS) and Public Service Commission are supposed to be independent.  In this instance an independent agency could have said “Sorry Governor but your politically driven appeasement of your voting base meant that there may not be enough gas supply available and in order to protect the citizens the prudent choice is to put a moratorium in place.”  The problem is that the DPS no longer independently serves the public interest.   In the summer of 2019 a group of retired Department of Public Service employees submitted a letter that stated “Until the current administration, Governors have generally respected the plain language of the Public Service Law (PSL), which … safeguards the mission of the DPS to serve not political interests but the public interest.” The letter signed by fifteen retired department workers states: “Governor Andrew Cuomo, however, has not done so.”

Like most bully threats there are questions whether Cuomo could have actually revoked National Grid charter to operate.  Nonetheless it was a thinly veiled threat to step in line or he would make doing business miserable.  National Grid is a business and in order to succeed financially they depend on a rate-making process that is entirely co-opted by the Cuomo Administration.  If National Grid steps out of line there is no question that his Administration will hurt them as often and as hard as possible.

National Grid Interim Solution

Not surprisingly National Grid caved and agreed to lift the moratorium for two years.  According to a Utility Dive report:

National Grid has identified new solutions to supply consumer gas needs in downstate New York since announcing the moratorium, company spokesperson Domenick Graziani told Utility Dive in an email. These include a “previously unavailable source of short-term peaking supplies,” which he declined to provide further details on.

The utility also anticipates reductions in demand due to energy efficiency and demand response programs, a new compression project that will provide additional long-term capacity to portions of Long Island and a greater-than-expected number of customers interested in shifting to “non-firm” service — that is, customers who switch to oil or other alternative fuels when asked to by National Grid. These customers are charged differently from residential and other “firm” customers and can be penalized if they don’t make the switch, according to Graziani.

As noted, before, environmental development issues involve tradeoffs and that is also true for energy development.  In this instance the “previously unavailable source of short-term peaking supplies” turned out to be trucked compressed natural gas.  This option requires a facility where the gas is compressed outside of Long Island and loaded into trucks that transport it to a vaporization facility on Long Island where it can be vaporized and added into a pipeline for delivery.  Natural gas can be transported from the production well to the user entirely by underground pipelines.  While there are safety and environmental issues related to that relatively simple approach there is no question that the CNG truck option through New York City is much riskier and that environmental impacts will be greater when additional handling components are added to the transport from well to user.  Elsewhere this “virtual pipeline” is widely condemned so it is not surprising that the National Grid spokesman declined to provide further details.

This is another instance of Cuomo administration hypocrisy: on one hand basking in the limelight as a leader against climate change by prohibiting new fossil fuel infrastructure but on the other hand needlessly risking safety and increasing environmental impacts with a solution only intended for use as a stop gap in emergencies.  Mark my word if there is CNG truck accident it will be anybody’s fault but Cuomo’s.

National Grid Collaboration

At this time National Grid is conducting an outreach program as described below:

For National Grid, serving our 1.9 million natural gas customers across Brooklyn, Queens, Staten Island, Nassau, and Suffolk is both a privilege and a responsibility. New York has seen dynamic economic growth in the Downstate region, expanding residential and non-residential building space, and thousands of oil-to-gas conversions over the last 10 years. These factors have resulted in a substantial increase in the demand for natural gas, placing stress on our existing gas network and threatening National Grid’s ability to meet our customers’ needs when demand is at its peak. This leaves little room for error in the face of unplanned supply interruptions or other contingencies.

As part of the settlement agreement with New York State that lifted the moratorium on new gas connections imposed in May 2019, we are taking numerous measures to ensure we have sufficient supply for the winters of 2019/2020 and 2020/2021, including increasing reliance on compressed natural gas (“CNG”) trucking when needed to meet peak demand.

Beyond the next two winters, however, continued growth in demand for natural gas creates a challenge that must be addressed. There are multiple potential solutions, each with its own considerations regarding safety, reliability, environmental and community impact, and cost. National Grid has prepared and provided to New York State an extensive Long-Term Capacity Report to facilitate constructive dialog in the quest to answer the challenges presented by increasing demand. The purpose of this Summary Report is to distill the content of that full report for the general public so that all may understand the issues involved and the potential solutions to be considered.

We wish this to be a collaborative process and encourage feedback, either through the public meetings hosted by National Grid in March 2020 or by sharing your thoughts via our online survey at www.ngrid.com/longtermsolutions.  This site also provides access to the full report and a link through which you can share feedback directly with the New York State Department of Public Service.

In other words, National Grid is desperately trying to appease the Governor who wants to play to the no fossil fuel infrastructure maniacs he actively courts.  To do that they have come up with this stakeholder process that lays out the problem and offers a number of alternative approaches to the problem.  All the while trying not to favor any of them.

My Submittal

National Grid has developed a slick website that provides information on the long-term solution options.  Also included are links to the reports, schedule of events, ways to submit comments, and transcripts from their meetings.  I will describe the summary report and reproduce some of the comments I submitted in italics.

In the first section of the summary National Grid describes the problem.  In order to define how much natural gas will be used they use the “Design Day” concept.  This is the plan for peak demand conditions as the level of gas delivery needed to serve all of our customers during an extreme cold weather event. In the Downstate NY region Design Day is defined as a 24-hour period that averages 0° Fahrenheit in Central Park. They note that approximately 85% of this Design Day capacity is used to heat homes and businesses—keeping people warm on the coldest of days.

I frankly could only stand listening to the comments made during the public meeting for a brief period but in that time two people complained about the use of 0° Fahrenheit as the design day because temperatures have been warming.  I am frustrated that they spout off numbers without any consideration that they have no responsibility in the event that they are wrong.  Moreover, I am sure that the choice of the design day temperature is proscribed by some PSC order somewhere to prevent gaming the system so it is unlikely that changing the number could be considered.  Nonetheless, I accessed Central Park data to see whether that value is representative to prepare the following comment:

I am a meteorologist so I checked the representativeness of the 0° Fahrenheit in Central Park criterion.  I used the Northeast Regional Climate Center CLIMOD 2 data portal to download Central Park daily minimum, maximum and average temperature data from 1869 to the present.  Over that period the lowest daily average temperature was -5.5° Fahrenheit and there were six other days with daily average temperatures less than or equal to the 0° Fahrenheit design day criteria.  Note also that on December 30 and 31, 1917 there were two days with average temperatures below 0° Fahrenheit in the midst of a seven-day period with daily average temperatures less than 10° Fahrenheit. 

I also evaluated hourly meteorological data for two NYS Mesonet stations (Rush and York sites from December 29, 2017 to January 8, 2018.  In that period the temperature did not get above freezing and on January 6, 2018 the average temperature was 0.8° Fahrenheit.  Based on my meteorology background and despite the fact that the most recent date with an average zero degree design day temperature in Central Park was 15 February 1943, I believe the weather conditions that caused a 0.8° Fahrenheit average day near Rochester in 2018 support the continued use of the 0° Fahrenheit in Central Park criterion.  Because 85% of the Design Day capacity is used for heating this design day criterion may not be stringent enough and certainly should not be adjusted upwards.

National Grid discussed historical demand growth and made two projections, a high-demand and a low-demand scenario, to bound their analysis. In the high demand scenario, they assume that 80% of the State energy efficiency targets are achieved and in the low demand scenario they assume that 100% of the targets are achieved.  Based on the projections and factoring in low-carbon solutions they predict that they will need to close a gap of 400 MDth/day between customer demand and available natural gas supply with the existing system.

In contrast to National Grid’s optimistic projection that they will reduce demand growth by over 50% I disagree.  In the first place, New York has already had extensive energy efficiency efforts in place during the time that demand growth increased 2.4%.  As a result, the easiest and most effective, aka low hanging fruit, energy efficiency projects have already been implemented.  Any future reductions will not be as cheap or effective.  Another problem is that natural gas works well for heating and cooking so it is the preferred alternative.  The “no new fossil-fuel infrastructure” argument is fine in theory but when faced with having to choose a poorer alternative I believe there will be plenty of pushback from the majority of the population that wants the advantages of natural gas and is not as motivated as the environmental advocacy folks so vocal in this proceeding. 

 This is particularly true with regards to home heating electrification because the preferred retrofit alternative is air source heat pumps.  My personal experience with this technology has been bad and I think that is a major problem for those who want to electrify heating. The word on the street is more often negative than positive.  In my case I did research to try to understand the problem.  In my 9/16/2019 filed comments on Resource Adequacy Matters, Case 19-E-0530, I included an analysis in an appendix entitled Air Source Heat Pumps that demonstrated the fundamental flaw with this technology.  In short, when the temperature drops below 20° Fahrenheit there simply is not enough energy to be transferred and converted to heat for the technology to work.  In the event of a seven-day cold snap like the one that occurred around New Year’s Day 1918 anyone without supplemental heat would freeze and the increased electrical load needed to provide supplemental electric resistance heating could lead to unprecedented peak loads.  Claims that improved air source heat pumps will solve this problem are unwarranted absent repealing the laws of physics.

 As a result, I do not think that the low demand case in which 80% of the State energy efficiency targets are achieved is likely.  More realistically the low demand will be 50% of the targets and the high demand 80%.  I am confident that 100% of the State energy efficiency targets will not be met.

Another aspect of the National Grid demand reduction plan is to use three low-carbon solutions: renewable natural gas, hydrogen blending and power-to-gas, and geothermal heat pumps.  National Grid claims that “with proper funding and support, we anticipate that these programs can cover 15–35 MDth of the Downstate NY gas supply gap”.

      • Renewable natural gas (RNG) facilities use biomass—such as landfills, wastewater treatment, food waste, and livestock manure— as feedstock for producing gas. National Grid currently has two RNG sites in their Downstate NY region: one on Staten Island and another at Newtown Creek expected to come online in the winter of 2020. They believe there is even more opportunity to expand RNG in their Downstate NY region.
      • Natural gas supplies can be augmented by blending in hydrogen gas produced by splitting water into hydrogen gas and oxygen gas through the process of electrolysis. Hydrogen blends, in the form of town gas, were used in heating for decades, both in the US and other countries. National Grid has proposed a two-year study to assess optimal parameters for incorporating hydrogen in the Downstate NY region.
      • By transferring heat to and from the ground, geothermal heat pumps offer an attractive, low-carbon alternative for providing central heating and cooling. Based on the success of a demonstration project that connected 10 homes with shared-loop ground-source heat pump (GSHP) systems, National Grid is seeking to expand this program to 900 homes over the coming four years.

As shown below I don’t think these projects have much, if any value.  At the Trust Yet Verify blog, the author notes that in Flanders, they have the expression “calculating oneself rich” which means presenting one’s case in a too optimistic way that doesn’t accord with reality.  Had I been aware of that expression when I wrote the comments, I would have used it because it describes these projects well.

Renewable natural gas is produced from anerobic digesters.  The New York State Energy and Research Development Authority (NYSERDA) has an integrated data system that provides operational data on DERs installed in New York including anerobic digesters.  At the current time there are 38 facilities with a rated electrical output of 22,263 kW.  The majority (29) of these digesters are located on dairy farms.  Eight are at waste water treatment plants and one is located at the Saranac brewery.  Only three of these have output greater than 3 MW and the majority are rated between 100 and 500 kW.  It is telling that NYSERDA rates these by electrical output because that indicates that the methane is primarily used to generate electricity. The National Grid report states that the Newtown Creek WWTP will be capable of producing 1.0 MDth/day and that they are “connected to a 1.6 MDth/day plant in Staten Island”.  Presumably during peak natural gas demand periods, the plan could be to divert the methane to the gas system rather than using it for generating electricity.   I believe that this option has limited potential simply because there are not many possible sites where it could be deployed.

 National Grid has proposed a two-year study to assess optimal parameters for incorporating hydrogen in the Downstate NY region.  In other words, this is more of a concept than a proven technology in today’s energy landscape.  Cynic that I am I consider this more wishful thinking than an actual plan.

 Ground source heat pumps work but the implementation logistics of trying to install meaningful amounts even, if the geology was favorable, in the service territory for this proceeding precludes this as a viable contributor to meaningful load reductions.

The meat of the report is the description of ten distinct options for closing the gap of up to 400 MDth/day between natural gas demand and supply over the next 15 years.  National Grid is careful to state that they do not propose a “best” or “most desirable” solution and pragmatically observe that the ultimate approach ultimately will likely be a portfolio including two or more of these options.  As noted earlier they have the responsibility to provide natural gas and the politicians who demand solutions that are driven by an agenda will disavow any culpability if they don’t work.

National Grid proposes ten projects in three categories.  They propose three large-scale infrastructure projects: an offshore liquified natural gas (LNG) deep water port, an LNG import terminal, and the Northeast Supply Enhancement pipeline project.  There are four distributed infrastructure projects: a peak LNG facility, LNG barges, the Clove Lakes Transmission Project, and the Iroquois enhancement compression project.  There are three no-infrastructure projects: incremental energy efficiency, demand response, and electrification.

The summary report concludes with an assessment of the relative attractiveness of the proposed options with respect to each of the evaluation criteria to “help our customers and the general public evaluate the options”.  I reviewed and commented on the scoring but will not include all my comments here.  In brief, I think that by necessity National Grid scored the NESE pipeline lower than they should have to be “Cuomo correct”.  For example, they gave all the large infrastructure projects the same safety score. I disagree because in most things related to safety simpler is better.  Both LNG alternatives are significantly more complicated because they involve storage and regasification components.  Moreover, they both require marine transport which compared to a pipeline has to be less safe.  I suggested that the scores for those projects be dropped relative to the pipeline.

I did include a comment on the environmental scoring because I have a lot of experience with environmental impact analyses and I disagree with the environmental scoring.  Frankly the evaluation criteria in the report in Table 19 don’t help much.  Greenhouse gas (GHG) emissions is one criterion used.  I don’t see how the compression, regasification, and transportation components of the LNG options would not mean higher GHG emissions. All the other GHG emissions intensity values are the same for all three options.  As a long-time air quality meteorologist, I struggle to find air substantive air quality problems with natural gas use as compared to other dispatchable sources of energy but I believe that air pollution emissions from LNG ship transportation are larger than pipeline compressor stations.  I can accept that the potential impact from construction is higher for pipelines but once in place the operation impacts are likely lower.   I assume that environmental risk relates to the ecological impact.  The fact is that there have to be pipelines from the well pads to the ports for the LNG options.  Expanding pipeline capacity to bring the needed natural gas directly to the City is simpler, safer and less prone to problems.  I cannot comment on the potential of any option to support New York’s decarbonization goals because there is no plan to implement those goals, only targets.  The politicians that enacted legislation with the goals made a major mistake putting the cart (the aggressive targets) before the horse (figuring out what was feasible).  In conclusion I would add another cell to the environment scoring bar to the pipeline option because it is significantly better than the other two.

 Two of the distributed infrastructure projects, Clove Lakes Transmission Project and the Iroquois enhancement compression project, are simple upgrades that will provide more capacity.  I see no reason why they should not be included.

The no-infrastructure projects all qualify as “Cuomo correct” virtue signals.  Because I don’t believe that the existing energy efficiency targets will be met, I reject out of hand the idea that even more substantive energy efficiency could be implemented.  Demand response is a favored component of “smart grid” advocates for shaving summer peak demand.  However, that is not a solution here because the expectation is that the load peak will shift to the winter.  I believe that there are significant differences between cooling peak loads and heating peak loads.  Most importantly, there is a hot period diurnal cycle that means that shifting between uses (A/C is not as large a component of total load as heating is to the total load) and times (when the sun is down there is no direct solar heating and cooling load needs drop significantly) is possible.  The question boils down to this: when 85% of your load is heating and the heating load does not vary much how can you shift the load?  I for one would not accept a thermostat that someone else controls for heating my home.  I do not think I would be an exception.

The third no infrastructure project was heating electrification using cold-climate, electric heat pumps.   I think that widespread implementation of cold-climate heat pumps will be a mistake as I noted in my resource adequacy comments. Bottom line is when you it is really cold and you really need heat they don’t work simply because there isn’t enough energy available. In addition, you are just shifting the problem onto the electric side.  Given that electric transmission is more susceptible to interruption than pipelines I think electrification is a less resilient option.

 The only positive that can be said about these no-infrastructure projects is that they are consistent with the Climate Leadership and Community Protection Act (CLCPA) expected infrastructure.  Unfortunately, we are guessing at what the state plans to do because they set targets without figuring out if they could be met much less how they would be met.  Moreover, I don’t think that the implementation timing for these kinds of projects will be consistent with timing for when the gap between demand and supply needs to be reduced.

National Grid points out that “Creating a comprehensive solution requires looking at how different options can work together to solve the gap between demand and supply”. Then they listed three possible approaches.  I was disappointed that they did not include the NESE pipeline large-scale infrastructure and the two distributed infrastructure pipeline projects as an option. I commented:

It did not get much attention in the documentation but the solution to the fact that current pipeline capacity cannot support today’s peak load demand is to truck compressed natural gas from somewhere on the other side of the supply constraint to somewhere on the inside of the supply constraint.  In my evaluation of the difference between pipeline and LNG infrastructure options I argued that the added safety and environmental effects of marine transport relative to pipelines made pipelines a superior choice.  However, the safety and environmental effects of trucks are greater than those of marine transport.  All three solutions rely on incremental Energy Efficiency, Demand Response, and Electrification to reduce demand and remove the need for CNG trucking. As a result, I could never support any of these solutions simply because it is likely that the need for CNG trucking will remain longer.

The first combined option, build out Large-Scale Infrastructure, capable of almost fully meeting projected needs claims that if construction is not completed before 2021/22, incremental Energy Efficiency (EE), Demand Response (DR) and Electrification would be required to reduce demand and meet customer needs. CNG trucking would be discontinued once the infrastructure is completed. Any shortfall in meeting demand reduction targets would lead to restrictions on new customer connections until the infrastructure is completed.  Incremental EE, DR and electrification won’t be implemented in this time frame – no way no how.

The second combined option, combine distributed infrastructure solutions with incremental No-Infrastructure solutions fails because all of them need to be implemented to meet projected gap so it will be necessary to combine one or two of these options with additional demand reductions achieved through EE, DR, and Electrification to fully meet needs. National Grid admits CNG trucking would remain in place unless demand reduction targets are exceeded, and any shortfall in meeting those targets would lead to restrictions on new customer connections.  Given that I think there is no way the demand reductions will be met CNG trucking remains in use for longer.

The final combined option, fully rely on a portfolio of incremental no- Infrastructure solutions, will undoubtedly be the preferred alternative of the energy innumerate and, thus the king of innumeracy Governor Cuomo.  Because it is unlikely that demand reduction targets will be exceeded, CNG trucking will remain in place, and any shortfall in meeting such demand reduction targets will lead to restrictions on new customer connections.  Somehow, someway when this fails to meet the needs, Cuomo will be the first to blame National Grid.

 Conclusion

National Grid states: “Our hope is that by helping our customers understand the possible approaches for addressing these concerns, they will provide feedback to help guide future decision making.”  Let me translate that for anyone unversed on current New York State energy policy.  National Grid is a business and in order to succeed financially they depend on a rate-making process that is entirely co-opted by the Cuomo Administration.  This report and the extensive outreach program, is a necessary part of doing business but it is just window dressing.  The ultimate decision will not be made to balance costs and risks against benefits to customers.  Whatever the facts say about energy reliability, effects on health, safety risks and costs, the final plan will be a politically driven decision made at the highest level of the Administration based on whatever is determined to best garner support from Cuomo’s political base.

This is another instance of Cuomo administration hypocrisy: on one hand basking in the limelight as a leader against climate change by prohibiting new fossil fuel infrastructure but on the other hand needlessly risking safety and increasing environmental impacts with an interim solution only intended for use as a stop gap in emergencies.  There are three pipeline alternatives that should be the clear choice as less risky, safer and minimal environmental impacts.  The other long-term infrastructure alternative solutions include several options that would continue to use more complicated and thus more risky approaches.  The obligatory no-fossil fuel infrastructure options could, in theory, provide enough energy needed to meet the design day criteria but two of the options (electrification and demand response) have never been implemented on the scale necessary and expecting to get even more energy efficiency reductions runs counter to observed results.  The question is whether the Cuomo administration will risk safety and reliability by requiring the use of those risky approaches to cater to people who will pay no price for being wrong.

Of course, the underlying argument that forms the basis of this entire charade is that climate change is an existential threat.  I believe that is a flawed argument.  New York’s politicians constantly claim that their energy policies have scientific support and they typically lean on the popular conception of an overwhelming consensus that the observed warming is necessarily bad.  In reality, most qualified scientists believe humans are causing some warming, but only a minority are very concerned about it.  The catastrophic impacts touted as proof that something needs to be done invariably rely on a future emission projection scenario that is so unlikely that it is inappropriate to use for policy decisions.  Finally, if the problem is global warming then it logically requires a global solution.  The reality is that New York’s possible impact on global warming reduction is too small to measure and would have effects that could not conceivably alter any of the purported catastrophic impacts.

 

The Futility of New York Energy Policy

A major theme of this blog is analysis of New York energy policy as it relates to climate change.  I have found that at the conclusion of every such post I am tempted to include an overview of my conclusions of the reality of the policy.  This post is a reference for three fatal flaws in the arguments used to justify those policies.

Background

I am a retired electric utility meteorologist with nearly 40 years experience analyzing the effects of meteorology on electric operations. I believe that gives me a relatively unique background to consider the potential quantitative effects of energy policies based on doing something about climate change.  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.

My biggest concern is that I am convinced that the general public has no idea what is going on with these energy policies and the possible ramifications.  My posts on New York energy policy are here.  I have described the reasons I think catastrophic anthropogenic climate change is unlikely  here and tried to explain to the layman why their direct experience should guide their opinion on global warming here. I have written a series of posts on the feasibility, implications and consequences of New York’s  Climate Leadership and Community Protection Act (CLCPA) which was described as the most ambitious and comprehensive climate and clean energy legislation in the country when it was passed.

The remainder of this post describes three fatal flaws that could be included in the conclusion of all of my posts on the CLCPA.

Fatal Flaws

New York State energy policy is based on the following: “climate change is a reality”, “our future is at stake”, and “That’s why New York State is committed to the most aggressive clean energy and climate agenda in the country”.  The presumption is that the 97% climate consensus that climate change is real means our future is at stake.  However, the consensus that matters is whether 97% of the scientists who have relevant background and experience are very worried about climate change.  A survey of members of the American Meteorological Society (AMS) showed that while two-thirds of those who responded believe humans are causing a majority of recent warming only 30% are very worried about it. Fully 40% of AMS members believe climate change impacts have been primarily beneficial or equally mixed between beneficial and harmful. Only 50% expect the impacts to be entirely or primarily harmful over the next 50 years. These results do not support the basis of massive changes to New York energy policy.

Further support of the rationale for committing to the “most aggressive clean energy and climate agenda in the country” is found in New York’s description of potential effects of climate change. The CLCPA notes that sea levels along New York’s coastlines are approximately one foot higher than they were in 1900.  The New York Department of Environmental Conservation adopted 6 NYCRR  Part 490, Projected sea-level rise projections for five probability categories ranging from low to high.  The problem is that the high-risk category projection of six feet rise by 2100 that garnered attention from the media is more properly labeled as virtually impossible.  In order to project future impacts, modelers have to simulate the climate changes due to greenhouse gas concentrations and project what those concentrations will be based on future emissions estimates. The problem is that the worst-case impacts rely on a future emissions scenario that was not intended to be plausible but it does make for the scary story needed to justify New York’s  “most aggressive” energy agenda.

Ultimately, however, the reality of climate change and future impacts does not matter if the proposed actions have no impact.  New York State started consideration of greenhouse gas reduction programs in 2003 when the discussions of the Regional Greenhouse Gas Initiative.  Since then there have been multipleregulations, rules and other initiatives but the State has never quantified how much of a global warming reduction could be expected as a result of their programs.  In April 2019 I calculated the effect of the CLCPA reduction of total elimination of New York’s 1990 218.1[1] million metric ton greenhouse gas emissions on projected global temperature rise.  I found there would be a reduction, or a “savings,” of approximately 0.0032°C by the year 2050 and 0.0067°C by the year 2100.  To give you an idea of how small this temperature change is consider changes with elevation and latitude.  Generally, temperature decreases three (3) degrees Fahrenheit for every 1,000-foot increase in elevation above sea level.  The projected temperature difference is the same as going down 27 inches.  The general rule is that temperature changes three (3) degrees Fahrenheit for every 300-mile change in latitude at an elevation of sea level.  The projected temperature change is the same as going south two thirds of a mile.

Conclusion

New York’s politicians constantly claim that their energy policies have scientific support and they typically lean on the popular conception of an overwhelming consensus that the observed warming is necessarily bad.  In reality most scientists believe humans are causing some warming, but only a minority are very concerned about it.  The catastrophic impacts touted as proof that something needs to be done invariably rely on a future emission projection scenario that is so unlikely that it is inappropriate to use for policy decisions.  Finally, if the problem is global warming then it logically requires a global solution.  The reality is that New York’s possible impact on global warming is too small to measure and would have effects that could not conceivably alter any of the purported catastrophic impacts.

The Public Service Commission has statutory obligations to ensure the provision of safe and adequate service at just and reasonable rates. Based on my work I believe that it is only a matter of time before it becomes obvious that New York’s virtue signaling energy policies will negatively affect that obligation in the form of higher rates and decreased reliability.  Until such time as the State proves they can provide reliable energy when and where it is needed relying primarily on renewable energy, we cannot even estimate costs.  This reckless endangerment of one of society’s necessities will end badly.

[1] This was the total for 2015 NYS emissions in NYSERDA Greenhouse Gas Inventory 1990-2015. Subsequent editions have lowered the most recent total so this is a conservative value for impacts.

Accelerated Energy Growth and Community Benefit Act: Additional Concerns

In the summer of 2019 Governor Cuomo and the New York State Legislature passed the Climate Leadership and Community Protection Act (CLCPA) which was described as the most ambitious and comprehensive climate and clean energy legislation in the country when Cuomo signed the legislation.  In early April 2020, NYS passed the Accelerated Renewable Energy Growth and Community Benefit Act (AREGCBA) as part of the 2020-21 state budget.  This legislation is intended to ensure that renewable generation is sited in a timely and cost-effective manner.  When this was proposed I posted an essay describing the hypocrisy and over-reach aspects and recently published another post showing why there are significant risks to the electric system.  This post addresses other concerns including logistics, permitting differences with existing regulations, and environmental impact assessments

 Background

I refer you to the previous post’s background description for an overview of the legislation but I will note that the legislation was incorporated into the 2020-21 New York State budget by Governor Cuomo despite the fact that it might have been more appropriate to concentrate on the financial implications of the coronavirus pandemic.   Worse, it included tight deadlines at the time it was approved when it was obvious that the State was pretty much in a holding pattern for an indefinite amount of time.  It would have been far better to postpone this legislation so that it could be properly vetted and a reasonable schedule developed.

In order to introduce my other concerns, I will repeat my description of section 4 from § 2. Legislative findings and statement of purpose.  I copied section 4 of the legislation and inserted my comments in italics.

  1. A public policy purpose would be served and the interests of the people of the state would be advanced by:

(a) expediting the regulatory review for the siting of major renewable energy facilities and transmission infrastructure necessary to meet the CLCPA targets, in recognition of the importance of these facilities and their ability to lower carbon emissions;

Article 10 Law currently requires “environmental and public health impact analyses, studies regarding environmental justice and public safety, and consideration of local laws” but those requirements take time to evaluate.

(b) making available to developers of clean generation resources build-ready sites for the construction and operation of such renewable energy facilities;

In my opinion if the CLCPA and AREGCBA laws had been written such that the plans were developed first it would have been more protective for New Yorkers.  In that approach the State would fulfill all the Article 10 requirements as part of the “build-ready sites” approach.

(c) developing uniform permit standards and conditions that are applicable to classes and categories of renewable energy facilities, that reflect the environmental benefits of such facilities and address common conditions necessary to minimize impacts to the surrounding community and environment;

I have reviewed all the Article 10 solar applications and there is no question that uniform permit standards and common conditions could be addressed by a comprehensive planning approach.

(d) providing for workforce training, especially in disadvantaged communities;

This is a transparent effort to develop support from a political base.

(e) implementing one or more programs to provide benefits to owners of land and communities where renewable energy facilities and transmission infrastructure would be sited;

This is political payola.  It is a bribe given in exchange for accepting any negative consequences of the renewable energy facilities.

(f) incentivizing the re-use or adaptation of sites with existing or abandoned commercial or industrial uses, such as brownfields, landfills, dormant electric generating sites and former commercial or industrial sites, for the development of major renewable energy facilities and to restore and protect the value of taxable land and leverage existing resources; and

This is a noble gesture.  Without question it is a nice idea to re-use or adapt unused sites but the fact is that those sites are small relative to the areal needs of diffuse wind and solar power production.

(g) implementing the state’s policy to protect, conserve and recover endangered and threatened species while establishing additional mechanisms to facilitate the achievement of a net conservation benefit to endangered or threatened species which may be impacted by the construction or operation of major renewable energy facilities.

This is window dressing designed to appear to address environmental issues when in fact it falls far short of environmental protections.  I will discuss this aspect of the legislation below.

Logistical Concerns

The revised permitting process for AREGCBA sets up a new bureaucracy to handle permitting.  The Office of Renewable Energy Siting (ORES) responsibilities will be established in the Department of State and charged with “accepting applications and evaluating, issuing, amending, approving the assignment and/or transfer of siting permits.”  Within one year the Office is supposed to “establish a set of uniform standards and conditions for the siting, design, construction and operation of each type of major renewable energy facility relevant to issues that are common for particular classes and categories of major renewable energy facilities”.  The goal is to “minimize or mitigate potential adverse environmental impacts”.  Also, within one year, ORES will “promulgate rules and regulations with respect to all necessary requirements to implement the siting permit program established in this section and promulgate modifications to such rules and regulations as it deems necessary”.

With all due respect to the authors of this legislation, implementing those requirements within one year is an overly ambitious goal.  In the first place, the Depart of State has limited existing staff for environmental issues.  The Department of Environmental Conservation, Department of Public Service, Department of Agriculture and Markets, and New York State Energy and Research Development Authority do have staff who support renewable energy development project permitting already.  There is language in the legislation stating that ORES can request support and services from those agencies and language addressing personnel transfers.  The relevant staff in those agencies are already working on projects, so what happens to projects already in the Article Ten queue?  I would not be surprised if there are staff within the agencies who support permit applications for a variety of projects not just renewable energy so what happens to other permit applications?  Consequently, if ORES just commandeers staff for this requirement other agency commitments will suffer.

In the second place, developing uniform standards for siting, design, construction, and operation is going to take time to draft, review and present.  Converting those to rules and regulations also will take time to prepare and the staff with the most experience in this regard have permitting obligations.  Importantly, there are New York Administrative Procedure Act requirements for adopting rules that include the opportunity for public involvement and specific schedule obligations.  All these factors suggest that it is unlikely that all this can be completed within one year.  Once the effects of the coronavirus pandemic are factored in, I am comfortable saying this cannot be implemented on the timeframe legislated.

Permitting Differences

New York’s Article Ten process was enacted during the days when regulated utilities proposed all the major electric generating station developments.  In its original form it was very unwieldly, time-consuming and required enormous resources to complete.  When de-regulation came along and the state realized that they would have to deal with non-regulated generating companies they revised the Article 10 process hoping to streamline its onerous provisions.  To some extent the 2011 revisions made improvements but the fact it that permitting still takes a minimum of over three years and often much more.

The Article Ten Environmental Assessment Form describes the Part 1001 requirements that specify what information is needed in applications to allow the Siting Board to make permit application findings and determinations.  The Article Ten application contains sections specifying general application requirements and exhibits concerning overview and public involvement, location of facilities, land use, electric system effects, wind, natural gas and nuclear power facilities, electric system production modeling, alternatives, consistency with energy planning objectives, preliminary design drawings, construction, real property, cost of facilities, public health and safety, pollution control facilities, air pollutant emissions, safety and security, noise and vibration, cultural resources, geology, seismology and soils, terrestrial ecology and wetlands, water resources and aquatic ecology, visual impacts, effects on transportation and communications, socioeconomic effects, environmental justice, site restoration and decommissioning, state and local laws and ordinances, other filings, electric, gas, water, wastewater and telecommunications interconnections, electric and magnetic fields, back-up fuel, and applications to modify or build adjacent to existing facilities.

One of the first things the ORES will have to do is to specify what information is needed for its application process.  There is no question that there are some topics in the Article 10 applications do not need to be included for renewable energy projects but the reality is that the Article 10 applications are not being held up much by addressing those topics.

In order to reduce permitting time, the AREGCBA’s biggest apparent difference is to eliminate the extensive public outreach components of Article 10 permits.  The Public Involvement Program and Scoping Statement components are the first two steps in the Article 10 permit process.  They include timing requirements that mandate eight months before the permit application can be submitted.  As far as I can tell there is nothing equivalent in the AREGCBA.  The public’s first inkling of a project under AREGCBA is not clear by my reading.  Once the application is received the law states the permit cannot be considered complete “without proof of consultation with the municipality or political subdivision where the project is proposed to be located”.  Once it is considered complete then there is a 60-day comment period.  Without some sort of legal requirement, the general public may only find out about a project that affects them when the 60-day comment period starts.

Article 10 applications are reviewed and approved by a siting board made up of seven people including two local community members.  AREGCBA decisions are made by the Executive Director of ORES.  Cynics like me suspect that the new law makes it easier for the Cuomo administration to control the outcome by reducing the number of people needed to approve a project.

Article 10 requires public notification and scoping statements be prepared with plenty of time for the public to get involved.  Both Article 10 and AREGCBA include provisions to give money for intervenors but finding out about a project, figuring out who and what needs to be addressed, hiring someone to do the evaluation and then getting it done in time to make substantive comments all within the 60 day permit period is ambitious at best and more likely impossible.  In fact, it is such an unrealistic schedule that I suspect that it was included to deliberately forestall local resistance to renewable energy projects.

Another major difference between Article 10 and AREGCBA is that there are no provisions in Article 10 to over-ride local ordinances limiting or prohibiting renewable energy developments.  The Cuomo Administration has already modified the Article 10 rules to forestall a township or county passing an ordinance limiting renewable developments during the Article 10 process.  AREGCBA goes much further stating that when making the final permit decision ORES “may elect not to apply, in whole or in part, any local law or ordinance which would otherwise be applicable if it makes a finding that, as applied to the proposed major renewable energy facility, it is unreasonably burdensome in view of the CLCPA targets and the environmental benefits of the proposed major renewable energy facility”.  It is not hard to read between the lines of that statement to see that Cuomo’s law ensures that renewable energy developments are going to be built whatever the locals think. The Article 10 process is so long that affected communities have replaced elected officials that supported projects with those who opposed them.  Clearly the AREGCBA schedule prevents that from happening.

The hubris of politicians never ceases to amaze me.  In order to make the locals happy the law includes what can only be described as a bribe.  The legislation specifies that “The final siting permit shall include a provision requiring the permittee to “provide a host community benefit, which may be a host community benefit as determined by the public service commission pursuant to section eight of the chapter of the laws of two thousand twenty that added this section or such other project as determined by the office or as subsequently agreed to between the applicant and the host community”. Another changes states that “The public service commission shall, within 60 days from the effective date hereof, commence a proceeding to establish a program under which renewable owners would fund a program to provide a discount or credit on the utility bills of the utility’s customers in a renewable host community, or a compensatory or environmental benefit to such customers.”  The affected locals lose their community character, have their housing values reduced and, depending on what the uniform standards are, could have adverse health effects but not to worry here is a community benefit project.

Environmental Concerns

I have been doing environmental assessments for over 40 years and really worry about the environmental impacts of the CLCPA because there is no commitment to evaluate the cumulative impacts.  As far as I can tell the State Administrative Procedure Act (SAPA) and the State Environmental Quality Review Act (SEQRA) requirements for environmental reviews do not apply to it because it is a legislative action. Up to this point Article 10 did at least require extensive “environmental and public health impact analyses, studies regarding environmental justice and public safety, and consideration of local laws” so at least the local impacts were thoroughly evaluated.  The AREGCBA legislation sets up an entirely new permitting process for renewable energy and it is not clear how environmental impacts will be handled in the new system.  It all depends on the uniform standards developed by ORES in the first year.

The problem proponents of renewable energy have with the Article 10 process is that it takes time.  When Article 10 was revised in 2011, the politicians thought that they were going to streamline the complete process down to a few years. The environmental staff people in the agencies and industries agreed at the time that it was still going to take four to five years to complete an application.  As of March 17, 2020, six projects have had their applications approved taking between 3.2 and 4.5 years since the first filing in the process.

Those completion times are from the first formal submittal in the Article 10 regulatory process.  When a developer starts to evaluate a site for a renewable development a lot of work has to be done to assess the local impacts by mapping and evaluating the property.  The plan has to be drafted, reviewed and submitted in order to start the clock. There is no way to speed those preliminary steps up.  The revised AREGCBA permitting requirements may eliminate some of the Article Ten considerations described below but many will remain so I estimate at least nine months and more like twelve months will be needed to develop that information.  For Article Ten projects that means that from the time a developer starts a project you are talking at least 4 to 5 years to have all the necessary permits to start construction.  Apparently AREGCBA hopes to cut that time mostly be reducing the public involvement requirements.  At a time when the State is emphasizing environmental justice concerns it is odd that this regulation ignores public involvement.  Cynics like me suspect that rural EJ communities don’t matter.

I argued in my more recent post on AREGCBA that a feasibility study was necessary to see if the CLCPA targets are realistic and affordable.  It may be possible to argue that on an individual basis industrial wind and solar facilities may not have acceptable unavoidable environmental impacts.  However, the cumulative impact of all the facilities required by the CLCPA to provide enough power to meet the reliability needs of the state could have unacceptable unavoidable environmental impacts. I estimated the resources needed for a load estimate from the Citizen’s Budget Commission with wind and solar output estimates based on meteorological data from January 3-4 2018 and found that New York would have to build 11,395 MW of residential solar, 16,117 MW of utility-scale solar, 18,457 MW of on-shore wind and 16,363 MW of off-shore wind to meet the increased load needed for the CLCPA targets. I made assumptions about sizes of turbines and solar arrays and estimate that those facilities would require over 3,845 on-shore wind turbines and 176 square miles of solar arrays.

The bottom line is that the massive areal extent of the renewable energy resources needed for the CLCPA obviously needs a cumulative environmental impact analysis to determine how the law will affect the environment.  Instead the AREGCBA legislates a plan to implement “the state’s policy to protect, conserve and recover endangered and threatened species while establishing additional mechanisms to facilitate the achievement of a net conservation benefit to endangered or threatened species which may be impacted by the construction or operation of major renewable energy facilities”.

In the long list of Cuomo’s hypocritical environmental policies this may be the topper.  There is no question that there is value for net conservation benefits.  For example, if an acre of a wetland is impacted, then the applicant could restore, create or enhance more wetland acreage nearby for a net environmental benefit.  The Cuomo administration has a consistent record of ignoring the possibility of this approach where it is inconvenient for their rationale to reject an application (e.g., any of the pipeline applications rejected in his tenure).  While this may be appropriate for affected wetlands at renewable facilities the real concern with blanketing the state with wind turbines is the effect on endangered or threatened avian species.  What in the world could be proposed as a net benefit for incidental slaughter of birds and bats at any wind turbine?

It gets even worse.  The AREGCBA states that: “To the extent that environmental impacts are not completely addressed by uniform standards and conditions and site-specific permit conditions proposed by the office, and the office determines that mitigation of such impacts may be achieved by off-site mitigation, the office may require payment of a fee by the applicant to achieve such off-site mitigation.” So where does this money go? The legislation includes an amendment to environmental conservation law establishing the endangered and threatened species mitigation bank fund.  The fund may pay for contracts with not-for-profit corporations, private or public universities, and private contractors for mitigation services and may “enter into contracts with a not-for-profit corporation to administer grants made pursuant to this title, including the approval and payment of vouchers for approved contracts.”  Gee, do you think there is any chance that this will enable Cuomo to fund his environmental base.

Conclusion

I subscribe to Politico’s daily New York Energy newsletter.  In the April 6, 2020 edition the New York League of Conservation Voters sponsored the following message supporting AREGCBA:

“A broad coalition of environmental, clean energy, real estate and labor groups applaud Governor Cuomo, Majority Leader Stewart-Cousins and Speaker Heastie for including critically needed renewable energy siting and transmission reform in the State Budget that will support New York’s ambitious climate goals and economic development across the state! Learn more.

The learn more link includes the statement “The improved siting process for renewable energy projects will help New York to achieve 70 percent renewable electricity by 2030, as required by NY’s 2019 climate law, and maintain New York’s strong environmental and public participation standards.”  It is not clear to me what they read that gave them assurances that public participation will not be endangered by this regulation but the knowledge that there is a pot of money out there for the environmental non-profits sure gives incentive for their rationale to support this law.

I understand the desire to revise the Article 10 process to handle the upcoming surge of renewable energy projects necessary to implement the CLCPA but believe this should have been addressed differently.  New York State’s budget process has never been a template for good governance because decisions are made by very few players and this March would have been an appropriate time to concentrate on the financial implications of the coronavirus pandemic.   Instead, Cuomo jammed this legislation into the budget package making it difficult for the assembly or senate to discuss, much less object, to any needed reforms to Article 10 for renewable energy projects.  It is very disappointing that there is a broad coalition of groups that think this was a good idea.

It remains to be seen how the uniform standards will play out.  Will there be adequate protections for environmental impacts, local community character, property values, and health impacts?  Another aspect is community involvement.  Article 10 had eight months for public involvement before the permit application was submitted.  There is no specification for local community involvement in the legislation.

This legislation includes two mitigation stipulations: community benefits and the endangered species mitigation bank fund.  Cynics like me suspect this more about payola than mitigating impacts.  Ultimately, I cannot see how anyone can support the CLCPA and AREGCBA legislation without a feasibility study and cumulative environmental impact analysis.

Finally, ORES “may elect not to apply, in whole or in part, any local law or ordinance which would otherwise be applicable if it makes a finding that, as applied to the proposed major renewable energy facility, it is unreasonably burdensome in view of the CLCPA targets and the environmental benefits of the proposed major renewable energy facility”.  This provision runs rough shod over home rule provisions of rural Upstate communities.  The rationale for the CLCPA targets is the climate emergency.  Is it too much for the State to quantify how their programs will affect global warming?  It has never been done by New York State.  When I calculated the effect of the CLCPA reduction of 218.1[1] million metric tons on projected global temperature rise I found there would be a reduction, or a “savings,” of approximately 0.0032°C by the year 2050 and 0.0067°C by the year 2100.  You cannot measure and therefore you cannot expect any effect on any of the purported impacts of climate change.  Based on my analyses to date these laws recklessly endanger electric reliability and the environment in the name of virtue-signaling climate “leadership”.

[1] This was the total for 2015 NYS emissions in NYSERDA Greenhouse Gas Inventory 1990-2015. Subsequent editions have lowered the most recent total so this is a conservative value for impacts.

Accelerated Energy Growth and Community Benefit Act: Electric System Concerns

In the summer of 2019 Governor Cuomo and the New York State Legislature passed the Climate Leadership and Community Protection Act (CLCPA) which was described as the most ambitious and comprehensive climate and clean energy legislation in the country when Cuomo signed the legislation.  In early April 2020, NYS passed the Accelerated Renewable Energy Growth and Community Benefit Act (AREGCBA) as part of the 2020-21 state budget.  This legislation is intended to ensure that renewable generation is sited in a timely and cost-effective manner.   It is best described by a knowledgeable friend as “Once again the idiots in Albany have proven they are willing to dive from the high board without looking to see if there is any water in the pool.”  When this was proposed I posted an essay describing the hypocrisy and over-reach aspects.  This post show why there are significant risks to the electric system.  I will follow up with a post addressing the other problems associated with these laws.

Background

The AREGCBA legislation states that the CLCPA targets “shall mean the public policies established in the climate leadership and community protection act enacted in chapter one hundred six of the laws of 2019, including the requirement that a minimum of seventy percent of the statewide electric generation be produced by renewable energy systems by 2030, that by the year 2040 the statewide electrical demand system will generate zero emissions and the procurement of at least nine gigawatts of offshore wind electricity generation by 2035, six gigawatts of photovoltaic solar generation by 2025 and to support three gigawatts of statewide energy storage capacity by 2030”.

Unfortunately, the politicians that passed this law never bothered to figure out how it could be done.  Prudence would have been to do a study to determine what was feasible and then set the targets. Instead, the legislation sets up a Climate Action Council with the charge to prepare and approve a draft scoping plan “outlining the recommendations for attaining the statewide greenhouse gas emissions limits” within two years of the effective date of the legislation.  One year later, the council shall submit the final scoping plan to the governor, the speaker of the assembly and the temporary president of the senate and post such plan on its website.  I have written a series of posts on the feasibility risks, implications and some of the costs of the CLCPA that provides more details on the law.

The Accelerated Renewable Energy Growth and Community Benefit Act is Cuomo’s legislation and the unintended consequences will be his fault.  On February 21, 2020 he announced “he is advancing a 30-day budget amendment to dramatically speed up the permitting and construction of renewable energy projects, combat climate change and grow the state’s green economy. If adopted, the Accelerated Renewable Energy Growth and Community Benefit Act will create a new Office of Renewable Energy Permitting to improve and streamline the process for environmentally responsible and cost-effective siting of large-scale renewable energy projects across New York while delivering significant benefits to local communities.”  New York State’s budget process has never been a template for good governance and this March would have been an appropriate time to concentrate on the financial implications of the coronavirus pandemic.   Instead, Cuomo jammed this legislation into the budget package making it difficult for the assembly or senate to discuss, much less object.

2. Legislative findings and statement of purpose

I have copied section 4 of this chapter of the legislation and inserted my comments in italics.  My over-riding problem with the CLCPA is that there is no plan.  The AREGCBA legislation compounds the problem by removing the evaluation of community impacts constraints.

    1. A public policy purpose would be served and the interests of the people of the state would be advanced by:

(a) expediting the regulatory review for the siting of major renewable energy facilities and transmission infrastructure necessary to meet the CLCPA targets, in recognition of the importance of these facilities and their ability to lower carbon emissions;

Article 10 Law currently requires “environmental and public health impact analyses, studies regarding environmental justice and public safety, and consideration of local laws” but those requirements take time to evaluate and it appears this legislation over-rides the time needed for those analyses.

(b) making available to developers of clean generation resources build-ready sites for the construction and operation of such renewable energy facilities;

In my opinion if the CLCPA and AREGCBA laws had been written such that the plans were developed first it would have been more protective for New Yorkers.  In that approach the State would fulfill all the Article 10 requirements as part of the “build-ready sites” approach.  It is possible that is the intent of this part of the rule but there will be more sites needed then those which are incentivized by section (f) below. 

(c) developing uniform permit standards and conditions that are applicable to classes and categories of renewable energy facilities, that reflect the environmental benefits of such facilities and address common conditions necessary to minimize impacts to the surrounding community and environment;

I have reviewed all the Article 10 solar applications and there is no question that uniform permit standards and common conditions could be addressed by a comprehensive planning approach. 

(d) providing for workforce training, especially in disadvantaged communities;

This is a transparent effort to develop support from a specific voting bloc.

(e) implementing one or more programs to provide benefits to owners of land and communities where renewable energy facilities and transmission infrastructure would be sited;

This is political payola.  It is a bribe given in exchange for accepting any negative consequences of the renewable energy facilities.

(f) incentivizing the re-use or adaptation of sites with existing or abandoned commercial or industrial uses, such as brownfields, landfills, dormant electric generating sites and former commercial or industrial sites, for the development of major renewable energy facilities and to restore and protect the value of taxable land and leverage existing resources; and

This is a noble gesture.  Without question it is a nice idea to re-use or adapt unused sites but the fact is that those sites are small relative to the areal needs of diffuse wind and solar power production required by the CLCPA.

(g) implementing the state’s policy to protect, conserve and recover endangered and threatened species while establishing additional mechanisms to facilitate the achievement of a net conservation benefit to endangered or threatened species which may be impacted by the construction or operation of major renewable energy facilities.

In the long list of Cuomo’s hypocritical environmental policies this may be the topper.  There is no question that there is value for net conservation benefits.  For example, if an acre of a wetland is impacted, then the applicant could restore, create or enhance more wetland acreage nearby for a net environmental benefit.  The Cuomo administration has a consistent record of ignoring the possibility of this approach where it is inconvenient for their rationale to reject an application (e.g., any of the pipeline applications rejected in his tenure).  While this may be appropriate for affected wetlands at renewable facilities the real concern with blanketing the state with wind turbines is the effect on endangered or threatened avian species.  What in the world could be proposed as a net benefit for incidental slaughter of birds and bats at any wind turbine? 

Electric System Concerns

The politicians that enacted CLCPA made a major mistake putting the cart (the aggressive targets) before the horse (figuring out what was feasible).  The draft scoping plan outlining attainment recommendations will not be approved until June 2021 and the final version will not be presented to the Governor, Assembly and Senate for another year.   The crony capitalists, environmental activists, and all the others who stand to gain from this ambitious plan have conned the legislators and Governor into believing that meeting the targets is simply a matter of political will but as I show below that is not the case.

I worry about the costs of the CLCPA because jurisdictions that are attempting similar GHG reductions have seen higher costs. Renewable energy supporters claim solar and wind are cheaper than conventional power plants but that is only the cost of the facility.  The problem is the cost of the generator does not include the cost to get the power to where it is needed when it is needed.  I evaluated one example of Cuomo’s renewable energy promises: freeing the state fairgrounds of fossil fuels.  One advocate claimed “solar is doable” and that “the 9 million kilowatt hours the fair used in 2018-2019 could be supplied by a 45-acre solar array and that would cost about $12 million to build”.  In my post I calculated what would be needed to provide all the electric power needed during the ten days the fair is open.  In my cheapest scenario I estimate that the solar array has to be at least twice as large, a wind farm with ten 2.5 MW wind turbines has to be added to reduce energy storage requirements and that you would still need an energy storage array totaling 43 MWh.  I have not evaluated the costs of solar and wind but have looked into the costs of Li-Ion batteries for energy storage.  Using National Renewable Energy Laboratory information, I estimate that the cost of just battery backup would be $17 million.  Assuming that a wind farm is a comparable cost to the 45-acre solar array and doubling the size of the array, the crude cost is $53 million.  Of course, with no detailed plan we have no idea of the cost of the CLCPA.

But it not just a question of cost but also of feasibility.  The State needs to show how many wind turbines, solar panels and energy storage systems will be needed when we most need power.  The only way to do that is to determine the availability of wind and solar based on historical meteorological data.  Done properly the study should look at hourly solar insolation, snow cover, and wind speed meteorological records across the state.  The other component is expected load.  In order to meet all the CLCPA targets the heating and transportation sectors will have to be electrified and that means that the future load peak will be in the winter.  The over-riding feasibility problem is what resources will be needed to cover a winter peak when solar resources are low.  I estimated the resources needed for a load estimate from the Citizen’s Budget Commission with wind and solar output estimates based on meteorological data from January 3-4 2018 and found that New York would have to build 11,395 MW of residential solar, 16,117 MW of utility-scale solar, 18,457 MW of on-shore wind and 16,363 MW of off-shore wind to meet the increased load needed for the CLCPA targets.  For the example winter peak period I showed that the light winds at night would require 150,000 MWh of energy storage and using National Renewable Energy Lab information showed that energy storage alone could cost $176 billion by 2050.

There is another feasibility problem.  Wind and solar are diffuse and chaotically intermittent.  Because they are diffuse the transmission system is needed but because they are so intermittent the transmission system has to be modified.  Conventional fossil-fuel fired, nuclear, and hydro units generate relatively stable power.  Wind and solar units provide variable power generation so resources also have to be developed to handle grid balancing services.  No major electric system has even come close to the targets in the CLCPA but transmission problems have shown up where renewable energy input is about half of the total such as South Australia.  Battery storage such as LI-ion batteries can provide these services in theory but no where has any system near the size of New York demonstrated the practicality of such a system.  Again, because there is no plan, we have no idea of the added costs of this necessary component of the future CLCPA electric energy system.

Even if a study shows it is feasible what about resiliency?  Coal is no longer burned to generate electricity in New York and residual oil is discouraged but both fuels could be stored on-site making them more resilient sources of power.  I recently showed that a 9” snowstorm blocked all the power output from a solar facility for four days.  When the CLCPA target of 6 GW of solar PV is implemented and we have a similar snowstorm to the March 12-14 superstorm that covered the state with 10” of snow, how can the electrical needs be met with no solar generation.  Even worse, what happens when an ice storm takes the power out to a city when residents completely depend on electric heat?  The ultimate resiliency question is how can New York City possibly meet its requirements for in-city generation using diffuse renewables.  Failure to meet those specifications raises the possibility of a New York City blackout.

There also are worrying issues with the environmental aspects.  In order to do justice to those topics I am going to follow up with another post.

Conclusion

The New York electric system is part of one of the largest and most effective machines in the world.  It produces affordable reliable electricity when and where it is needed.  However, the popular conception of the grid is that for all of its complexity and acknowledged past success it is outdated.  Enter the “Smart Grid” to solve all the problems.  According to SmartGrid.gov, “the Smart Grid will consist of controls, computers, automation, and new technologies and equipment working together, but in this case, these technologies will work with the electrical grid to respond digitally to our quickly changing electric demand.“  They also say that “The Smart Grid represents an unprecedented opportunity to move the energy industry into a new era of reliability, availability, and efficiency that will contribute to our economic and environmental health.”  I believe that the underlying impetus is “environmental health”.  The only way to integrate renewable technology is the smart grid and everyone knows that we need renewables to save the planet.

New York State energy policy is on board with the Smart Grid and it has been sold to the gullible and innumerate as a simple, cheaper solution.  Cynics like me say if it is so good then the market should choose it as the preferred alternative.  Instead we get laws like CLCPA with its ambitious targets and the AREGCBA with its rushed incentives to build renewable technology.  As I have shown there is no New York plan to implement this technology and serious technological issues to address.  All we are left with are hollow promises and vague reassurances from the politicians.  Until we have a plan that includes costs and environmental impacts these laws should be put on hold if not repealed altogether.  The problem with the idiots in Albany diving from the high board without looking to see if there is any water in the pool is that they will take the reliable and affordable electric system crashing down with them.

Another Solar Power Issue in Upstate New York

I have calculated how much solar and wind power might be available based on meteorological data for several scenarios.  I discovered another complication that I had not previously included in my analyses that is the subject of this post.  In particular, the effect of snow cover on solar output.

Background

I have analyzed the potential solar generation output that can be expected from facilities in New York based on incoming solar radiation.  In comments that I submitted on the New York Department of Public Services resource adequacy proceeding I prepared a white paper that provides an initial estimate of the likely energy storage component requirement based on historical meteorological data and developed an example of potential problems with air source heat pumps.  Based on that work, my primary concern is that New York State has not done a feasibility study to determine whether the solar and wind resources in the winter are sufficient to provide enough power when the heating sector is electrified.

Obviously if solar panels are covered with snow the generation output will be reduced but I had never quantified the impact.  The New York State Energy and Research Development Authority (NYSERDA) has an integrated data system that provides operational data on Distributed Energy Resources installed in New York.  During the research for a  previous post on this system I downloaded solar output data for the Howland Solar project in Sandy Creek, NY for the winter of 2020 and found data that could be used to estimate the effect of snow cover.

The following graph shows solar output data for the Howland Solar project in Sandy Creek, NY for the winter of 2020.  This site is located east of Lake Ontario in the heart of its lake-effect snow belt.

The thing that caught my eye were four periods when the daily average electricity generated was zero. In this analysis I will focus on the period near December 23. As shown in the next graph data from 16 December through 22 December indicate there was zero solar generation on five consecutive days.

The NYS mesonet has a monitoring station located close to this solar facility at Belleville. The following 7-day meteogram for this site shows that there was a snowstorm during this period. Note that the time scale in these graphs is for UTC time so they differ from the local time by five hours.

Although it is hard to see, the gold trace in the upper left graph is solar insolation. That graph also lists temperature which was below freezing throughout the period. The dark green line in the lower left graph is cumulative precipitation. On the graph it starts between 16/23 and 17/23 but because of the UTC times the onset was much closer to the start of December 17. Note that at the time when the total precipitation increased the most that the sonic wind speed and gusts (black and blue) in the upper right graph also peaked and that the wind direction was WNW as shown in the lower right graph. Those conditions are the classic signature of a lake-effect snow event.

The Buffalo National Weather Service office archives lake-effect snowfall maps for all big events. The map for this period confirms that this was a lake-effect event. The solar facility and the mesonet station are located just north of Pulaski at the eastern end of Lake Ontario squarely in the area that got at least 7″ of snowfall.

The Problem

The following temperature and solar radiation meteogram graph for 20 December shows the solar radiation more clearly than in the seven day. I have not found a better daily solar insolation curve to date. There is no indication (squiggles on the curve) of any variation of intensity other than diurnal sun angle. There could not have been a single cloud that day. The key point is that the temperature struggled to get up to 10 degrees F that day so there would have been high energy demand for heating at the same time .

So how much electric generation did the Howland solar installation provide to the grid that day? There were two hours of 1 kW, two hours of 4kW and two hours of 6 kW for a daily total output of 22 kWh. I checked my usage for that period and I used a total of 766 kWh for a daily average just under the total output of this facility. Importantly I do not use electricity for heating, cooking or hot water.

 Conclusion

Clearly, it is not enough to just look at meteorological conditions to determine the potential worst case for solar power generation output.  Intuitively it is obvious that snow will cover solar panels and the output will be reduced.  This post demonstrates that for a 7” snowfall one solar facility output went to zero for four consecutive days.  I expect that any solar facility with a similar panel configuration located inside the seven-inch contour of the lake effect snow summary map would be similarly affected.

Weather maps for December 17-19 2019 show one typical winter storm scenario for New York.  On 17 December the first snow falls when a storm system goes up the coast.  When this happens snowfall is widespread but higher closer to the coast. 

On 18 December the storm system heads off to the north and east and as it does it draws colder air down from the north.  Oftentimes like in this period, lake effect snow bands develop with smaller areal extent but more snowfall. 

Finally, the cold air settles in behind the storm and lake-effect event, albeit not shown well in the 19 December map.

The future energy system ramification of this is important.  As shown here snow cover can eliminate solar generation output.  It is important to consider what will happen when there is a really big snowstorm that blankets New York with 7” of snow, followed by a lake-effect event that covers the usual lake effect areas with even more, and ends with a really cold day caused by a high pressure system.  Now you are talking about no solar output and reduced wind output at the same time electric loads will be high due to heating electrification.  The data shown here suggest that the no solar output situation can last for days. 

Until such time that New York State shows that they have a plan to address this worst-case situation I believe we could end up with people freezing to death in the dark.

New York Distributed Energy Resources Information

Distributed energy resources (DER) are technologies that generate or manage the demand of electricity at different points of the grid, such as at homes and businesses, instead of exclusively at power plants.  The New York State Energy and Research Development Authority (NYSERDA) has an integrated data system that provides operational data on DERs installed in New York. According to NYSERDA “DERs can play a critical role in supporting Governor Andrew M. Cuomo’s Climate Leadership and Community Protection Act (CLCPA). The CLCPA codifies Governor Cuomo’s nation-leading goals.”   This post looks at the data available from NYSERDA.

Background

NYSERDA has developed dashboards like their DER integrated data system on various energy and environmental topics.  The main purpose, I think, is to publicize the results of their programs.  While the idea to have a location where anyone can track information is understandable my experience with these systems is that these overview systems can also lead to misunderstandings and unintended uses for the data.  As we shall see this is the case for this dashboard.

The NYSERDA website provides an overview of the DER resource.  NYSERDA alleges that they “allow owners to reduce their facilities’ carbon footprints, rein in energy costs, and improve utility grid power-outage resiliency”.  My intention was to use their data to check on these claimed benefits but it is not clear how useful the information presented is for this purpose.  First here is what is available.

The Solar data provided includes performance data for 508 larger commercial and industrial solar installations. According to NYSERDA:

“DER Solar panels, which are made up of photovoltaic (PV) cells, convert sunlight into electricity without creating noise, air, or water pollution. Solar can be connected directly to the grid or connected behind the customer’s meter within the building. Either way, utilities offer compensation for electricity generated by solar but not used on-site.”

The website lists 418 Energy Storage projects but provides no summary performance data information.. According to NYSERDA:

“On-site energy storage, including batteries, allows facility owners to lower their costs by storing cheaper energy for use when electricity costs are high. This includes storing electricity purchased during periods of low demand to use during peak hours, or similarly storing energy generated by solar panels during the day for use later. They can also be used to shift the building’s demand, thereby allowing for savings on utility demand charges. Depending on how they are interconnected, energy storage systems can be used during grid outages to provide some resiliency to the building.”

The summary of resources describes Hybrid Systems but offers no information on such systems in New York.  According to NYSERDA:

“Hybrid DER projects have two or more energy technologies installed at a site, working in synergy to provide more benefits than two separate projects. For example, solar projects combined with energy storage technologies can save excess energy generated from the solar panels during the middle of the day, which can be used in the late afternoon and evening.”

The website lists 208 Combined Heat and Power projects.  According to NYSERDA:

“Combined heat and power (CHP), or cogeneration, simultaneously generates thermal and electrical energy from a single fuel source. By recycling valuable heat from the combustion process, CHP can result in greater overall efficiencies than centralized power generation, transmission and distribution. The recovered thermal energy from on-site CHP systems may be used for industrial processes, space heating, domestic hot water, or cooling through an absorption chiller. CHP is considered a viable and economical use of distributed generation (DG) when installed at or near the point of use.  At the start of 2017, 4,395 commercial, industrial, healthcare, multi-family residential, and other energy use-intensive facilities in the United States had operational CHP systems, representing a combined electric generation capacity of 82,600 MW. 631 of these systems, totaling 5,500 MW, were in New York State.”

“Combined heat and power” is the current label for “co-generation”.  Cogeneration has a bad reputation.  The Public Utility Regulatory Policies Act of 1978 (PURPA) was intended to encourage:

      • The conservation of electric energy,
      • Increased efficiency in the use of facilities and resources by electric utilities,
      • Equitable retail rates for electric consumers,
      • Expeditious development of hydroelectric potential at existing small dams, and
      • Conservation of natural gas while ensuring that rates to natural gas consumers are equitable

One of the ways PURPA tried to accomplish its goals was through the establishment of a new class of generating facilities which would receive special rate and regulatory treatment. Generating facilities in this group are known as qualifying facilities (QFs), and fall into two categories: qualifying small power production facilities and qualifying cogeneration facilities.

In 1981 New York regulators tried to enact energy policy that went beyond PURPA in the well-intended, but disastrous, legislation known as the “six-cent law,” that required utilities to purchase power from unregulated co-generators for a minimum of six cents when more often than not, the utility-owned generation made power at less than half that cost.  The legislation estimated that the avoided cost of generation would be worth six cents but when the actual costs were much lower the feeding frenzy in the market overwhelmed the regulatory process and caused massive losses for the regulated utilities that were passed on to the consumers.  The high mandated price prices coupled with “the ingenuity of new entrepreneurs who stormed into the market were enough to create a massive problem of excess capacity”.  In 1992, New York amended its Public Service Law to eliminate the mandatory six-cent rate.  There is no wonder that the co-generation label is avoided at all costs by New York regulatory agencies.

The website lists 38 Anaerobic Digester projects.  According to NYSERDA:

“When organic materials such as manure, agricultural waste, food waste, and other wastes breakdown in the absence of oxygen—a process called anaerobic digestion—they produce an energy-rich gas called anaerobic digester gas (ADG) or biogas. Anaerobic digestion processes can reduce methane emissions from organic wastes in addition to producing renewable energy from ADG. Facilities with ADG systems can reduce their energy costs and emissions by generating and using electricity onsite or produce vehicle fuel from what would otherwise be waste.”

The website lists 41 Fuel Cells projects.  According to NYSERDA:

“Fuel cells use an electrochemical process to convert a fuel’s energy to electricity without combustion. Fuel cell uses include portable power generation, stationary power generation, and power for transportation.”

Performance Data

NYSERDA tracks real-world performance data for over 1200 projects so I thought that I could use their information to project how these resources have operated to date.  When I accessed the website on March 8, 2020 the total performance to date claim was 6,260 GWh of electricity have been produced.  The data can be accessed for individual facilities or combined in a portfolio.  I downloaded the performance data for portfolios composed of all the anerobic digesters, combined heat and power, fuel cell, and solar resources to get capacity factors, electric efficiency, and thermal efficiency.  The NYSERDA Distributed Energy Resources Performance Data table lists the performance data by these resources.  I found the first inconsistency in the data at this point.  The GWh sum of the individual resources is 5,258 GWh.

I contacted NYSERDA about this issue and did get a response.  According to staff, the DER data website ignores “unreliable” data which doesn’t meet quality control algorithms.   In this instance I would expect that the total performance data would exclude unreliable data so that the dashboard total would be less than the total of the individual sources.  So either NYSERDA or I misunderstood the other party.

 Characteristics Data

The NYSERDA Distributed Energy Resources Characteristics Data Summary table lists data for the different types of resources.  It lists the number of facilities for different sizes, the largest rated electric capacity within each type, the total capacity, and the number of facilities in the performance data and the characteristics data.  As was the case with the performance data there was another inconsistency because the summary totals and the sum of the individual projects do not match.

In response to my question about this discrepancy NYSERDA responded that “The differences in counts (number of “facilities” not exactly matching number of “reporting entities”) could occur if a given site has two different systems on different electric services and thus different data collection/data reporting meters (one site, two data streams)”.   This is an example of an unintended application for the dashboard.  As an overview it is fine but if someone else has specific questions about a certain type or resource they will get as confused as I did.

There are 38 anerobic digesters in both the performance and characteristics data.  The majority (29) of these digesters are located on dairy farms.  Eight are at waste water treatment plants and one is located at the Saranac brewery.  Note that the “system” rated electric generation is inconsistent with the “project” rated electric generation.  I used the system values.  Only three of these are greater than 3 MW and the majority are rated between 100 and 500 kW. As a result, they should be viewed as replacing the power they need from the grid rather than a potential source of significant supplemental dispatchable power.

Combined heat and power distributed energy resources include the highest electric capacity unit at 37.5 MW.  The NYSERDA performance data says that there are 208 facilities but when I totaled the characteristic data, I only came up with 206.  There are 158 facilities under 0.5 MW, 19 between 0.5 and 1 MW and 29 greater than 1 MW.  These facilities have advantages for the system in that they are dispatchable, they are generally bigger than most other resources, and they provide over 200 MW of capacity.  I think there is another huge advantage in that they are truly resilient.  If they are using natural gas then their supply is underground and cannot be blown away by high winds.  The problem is that they are fossil-fired so it is not clear how much of a contribution they can make in the CLCPA 2040 electric generation world when no electricity is supposed to be fossil-fired.

Energy storage systems resources did not include any performance data.  Energy storage is a critical component for the CLCPA 2040 goal because there are times when the wind does not blow at night so there will be no renewable energy generation.  I estimated that the amount of energy storage needed for a light-wind fifteen-hour period from January 3, 2018 at 1600 until January 4, 2018 at 0600 would total 134,545 MWh.  The storage projects listed in here total 63.3 MW and have a storage capacity of 123.6 MWh.  In addition, note that there were two projects where the storage capacity in kWh was less than the storage in kW, i.e., the data are wrong.  According to NYSERDA there are 418 energy storage projects but 75 projects don’t have any discharge capacity levels listed so my table only lists 343 projects.  Again, that means the data are incomplete or wrong.  Most of the projects are small.  In fact, there were 306 projects that were smaller than 25 kW.  Another 30 are smaller than 1 MW which means that there were only seven projects greater than 1 MW.  I doubt that energy storage below 1 MW will have value for the grid energy storage deficit reduction I predict will be needed.

Fuel cells are toys in my opinion.  The data characteristic data has a total of 36 facilities and the performance data summary claims 41.  Thirty-two facilities are less than 0.5 MW.  Distributed energy resource purports to make the grid smarter by spreading the generation out but these facilities are so small that they will likely only provide power for the facility served.  Very little generation could be provided to support the grid itself.

Solar PV is the largest distributed energy resource.  The data characteristic data has a total of 485 facilities and the performance data summary claims 508.  There is a total rated electrical capacity of 732 MW and the largest facility is 14.9 MW.  Also note that there are 226 facilities that are rated for over one MW.  Unfortunately, the solar PV resource is intermittent and diffuse.  In order to support the grid you need energy storage and transmission to get the power from where it is produced to where it is needed.

Conclusions

I conclude that the NYSERDA integrated data system is an interesting source of distributed energy resource data and it can be used to determine how well the State’s programs are doing.  At this time there is just over one GW of DER rated capacity in this system provided by over 1200 facilities.  It is not clear to me whether the results presented are a cause for optimism or pessimism.  On one hand there are quite a few projects but on the other the output is not all that impressive.

NYSERDA could use this information to do an analysis to determine just how effective these resources would be relative to the Climate Leadership and Community Protection Act targets.  For example, one question could b:  if anerobic digesters were installed at all the municipal waste water plants how much power could be generated?  Of course, it is more complicated because there are likely space constraints the preclude installation.  The follow up question then becomes were the eight waste water treatment plant systems installed all that could be installed?  I have argued that a study to determine the availability of wind and solar based on meteorological data is necessary and believe this shows that a study of other resource availability would also be appropriate.

Encouraging COVID-19 Information for New York

Doctors have warned that air pollution increases the risks of dying from COVID-19.  This post compares air pollution levels in Italy with the highest European COV-19 mortality with New York State where the largest number of COVID-19 cases have occurred in the US.  I am sure the general impression is that New York City air quality is so bad that, if this relationship is true, that similar mortality rates are inevitable but I will show that is not the case.

Background

In an interview Dr. Sucharit Bhakdi, a German microbiology specialist, explains that the reason for the apparent global different mortality rates for COVID-19 may be because of different local situations.  He points out Northern Italy and China both have air pollution problems as well as high mortality rates.  Consistent with others he suggests that the lungs of individuals in those areas have been chronically injured over decades and this influences the mortality rates.

I compared Italian data with New York data that I had on hand.  Italian air quality data are available at the European Environment Agency Italy air pollution country fact sheet website.  Air quality data from New York’s monitoring network are available at the New York State Department of Environmental Conservation air quality monitoring website, in their annual reports, and there is an Environmental Protection Agency website that also has the data.  Particulate Matter 2.5 (PM2.5 measures particles that are generally 2.5 micrometers or smaller), Particulate 10 (PM10 measures particles that are generally 10 micrometers or smaller), nitrogen dioxide (NO2) and ozone are measured in both jurisdictions.  Unfortunately. the readily available summary data for PM10 and ozone data are not directly comparable because the air quality standards are different.  New York has only a few monitors for NO2.   The pollutant of most concern for health impacts is PM 2.5 because these particles are small enough to get inhaled into the lung.  There are seven monitoring sites within New York State with directly comparable PM2.5 data and that have reported data since 1999.  The only issue is that those data are not readily available so I have manually extracted these data from annual reports over the years.

Comparison

The Comparison of Italian Average and Selected New York State Air Monitors Annual Average Air Quality Data table includes Italian and New York PM2.5 annual average measurements that are encouraging.  Italian data are downloadable in three categories: Traffic which represents the highest expected levels, suburban/urban background which I assume represents ambient conditions for most people, and rural background which should represent atmospheric concentrations without Italian impacts.  The New York data are listed for the Botanical Garden station in New York City, three Upstate cities, a monitoring location on Long Island that is downwind of New York City and two rural background stations.

The Italian traffic impacts site had a PM2.5 annual average of 18.3 µg/m3, the suburban/urban background was 17.2 µg/m3and the rural background was 16.1 µg/m3.  The good news is that the monitoring location with the highest observed annual PM2.5 concentrations was at the Botanical Garden monitor in New York City was 8.0 µg/m3 which was less than half the rural Italian average background.  Note that in the most recent year there were a total of 23 PM2.5 air monitors operating in New York City.  In 2018 the Botanical Garden monitor had an annual average greater than or equal to all but four of the monitors.  The highest annual average was 10.4 µg/m3 still well under the Italian rural background.  The important thing to note is that all of New York PM2.5 annual averages are smaller than the lowest Italian traffic and suburban/urban background sites since 1999 and the rural background site averages since 2002.  There is no question that New York State air quality is substantively better than Italy for PM2.5.

I also list the nitrogen dioxide data.  New York NO2 air quality levels are only marginally better than Italy.   It is instructive to compare the two pollutants.  NO2 primarily gets in the air from the burning of fuel. NO2 forms from emissions from cars, trucks and buses, power plants, and off-road equipment.  Most small particles form in the atmosphere as a result of complex reactions of chemicals such as sulfur dioxide and nitrogen oxides, which are pollutants emitted from power plants, industries and automobiles.  I suspect the difference between New York and Italian air quality reflects the success of the EPA and New York State air pollution control efforts since 1990.  Since 1999 New York power plant sulfur dioxide emissions are down 99% and nitrogen oxides emissions are down 92%.  Coupled with concurrent reductions from industrial sources this has been a primary factor for the PM2.5 reductions.  I guess that Italian sources have not reduced their emissions as much.  On the other hand, New York continues to struggle with the ozone ambient air quality standards in part because nitrogen oxides emissions from the transportation sector have not come down nearly as much.  This would explain why the Italian and New York NO2 data don’t differ as much.

Conclusion

I think there is a general perception that New York City air quality is poor.  The fact is that while there are still some overall New York issues, the pollution levels have improved significantly.  The good news is that if the hypothesis that the COVID-19 mortality rate is related to chronic air pollution levels and that PM2.5 is a good surrogate for that pollution, then these data suggest that factor will not have as much of an effect in New York State in general and New York City either.  The PM2.5 concentrations are significantly lower than either Italy and, I would presume, China too.

Hornsdale Power Reserve Considerations

At the Trust, yet verify blog, Michel has written a couple of posts about the Hornsdale Power Reserve.  I had intended to do a post on this energy storage facility for a while and commented that I was planning to do a post but hadn’t gotten around to it.  When I said would not have to produce a post Michel said his was only one way to look at it and there are other possible views.  After reading the second post I decided to make a point about this system as it relates to New York State energy policy.

Background

According to the Hornsdale Power Reserve website “At 100MW/129MWh, the Hornsdale Power Reserve is the largest lithium-ion battery in the world, and provides network security services to South Australian electricity consumers in concert with the South Australian Government and the Australian Energy Market Operator (AEMO).  The Hornsdale Power Reserve is a facility comprising of a 100MW/129MWh Tesla Powerpack system located approximately 15km north of Jamestown in South Australia.”

In the first post Michel addressed the claim made by renewable energy advocates that batteries can replace natural gas for peaking and gap filling.  The advocates point to Hornsdale profits as proof of this claim.  However, he showed that the facility was making most of its money providing Frequency Control Ancillary Services.  There is great value to the electric grid having a way to quickly address variations in grid frequency and this system does that well.  However, peaking requirements are different and there is no sign that this small a system can provide much value for that need.

In the second post he responded to a heated discussion on a reblog of the first post on the blog “Utopia, you are standing in it!“  An advocate for renewable energy claimed that battery systems like Hornsdale can compensate for intermittency problems.  In this particular case, the intermittency from break downs at fossil-fired power plants was the cited example.  Michel concluded that “A power plant with a capacity of 1,480 to 2,200 MW breaking down is by no means a “minor” event and if a battery system with a capacity of 55 MW / 80 MWh (or even a 100 MW / 129 MWh in case of the Hornsdale Power Reserve) is able to compensate for such an event, then it most probably wasn’t a “break down””.

In this post I want to look at the use of energy storage batteries for short-term fluctuations of renewable energy resources at an example solar facility.  On March 17, 2020 North Park Energy submitted their Public Involvement Program Plan as the first step of the New York State electric generation permitting process.  Their proposed Declaration Energy Center Project in Seneca County is proposed to have a generating capacity of 450 MW covering a project area of ~4,400 acres of land of which ~ 2,500 to 3,000 acres will be used for the solar energy center.

Analysis

In this post I want to show that there is another aspect of the intermittency problem. To date I have focused on intermittency energy storage when wind and solar resources are low and must be replaced.  In particular, those times when the wind does not blow at night.  The problem I want to address here is short-term intermittency when solar is affected by variable clouds.

In order to determine how solar electric generation could vary over short periods I used short-term meteorological data from the NYS Mesonet meteorological system. The NYS mesonet is a network of 126 weather observing sites across New York State.  The official website of the Mesonet includes a tab for live data that brings up station information for the 126 operating individual sites that shows that available data include wind direction and speed, temperature at two levels, relative humidity, precipitation, pressure, solar radiation, snow depth, and camera images. For this analysis I obtained 5-minute archived meteorological data for the Rush and York Mesonet stations near Caledonia, NY.  I previously used these data to evaluate the output from a proposed 180 MW solar facility nearby but will assume that these data also represent conditions that could be expected at the Declaration Solar 450 MW project.

I analyzed the five-minute solar insolation (watts per meter squared) to determine how the electric generation output from photovoltaic solar panels would vary.  I only looked at five-minute periods when the solar insolation was greater than zero for a fifteen-day period (12 July through July 26 2017). The Summary Solar Insolation Statistics for Rush and York page lists statistics for different parameters in three tables.  I list the standard descriptive statistics for both stations in the first table.  There are over 2,700 five-minute periods when there was solar insolation greater than zero in this period.  The average insolation was around 300 watts per meter squared and the maximum insolation was just over 1,000.

In order to assess solar variability effects, I calculated the absolute difference between successive observations.  In the second table I list the summary statistics.  While the average difference is around 50 watts per meter squared the standard deviations are 1.7 times greater suggesting that there is a lot of variability.  Importantly, the maximum difference between successive periods is 702 watts per meter squared at Rush and 675 at York.  The maximum solar output difference divided by the maximum solar radiation represents the maximum variability.  Any solar facility near Rush could generate up to a change of 68.9% of the maximum output in successive five-minute periods and at York the maximum change would be 62.4%.  The last table shows the frequency distribution of the five-minute absolute difference percentage change.  Note that 1% of the time solar generation output varies 40% or more.

Discussion

The solar variability analysis provides an overview of the data for one example period.  The archive for the Mesonet includes daily meteograms or graphs of different weather parameter which provides an overall description of the day.  The reports for the July 18, 2017 solar radiation example are available at these links: Rush and York but I have also provided  the Rush and York 18 July 2017 meteograms  which combines the two. (Note that the hours listed are UTC times so you need to subtract five hours to get to Eastern Daylight Time.)  During the proceeding night temperatures dropped enough that in the morning there was very high humidity and possibly fog with light winds so I don’t think there were clouds.  Once the sun came out the temperature rose quickly but note the variability throughout the day.

The Solar Variation in Five-Minute Meteorological Data at the Rush and York NYS Mesonet Stations table lists all the meteorological data available from the Mesonet five-minute data archive and the calculated absolute solar insolation difference between five-minute periods.  This table highlights cells where the difference between successive 5-minute periods is greater than half the maximum observed solar radiation in the Insolation % of Max Delta column.  Note that during this 8-hour period that value was exceeded seven times at Rush and six times at York.

The Solar Electric Output Variation in Five-Minute Meteorological Data at the Rush and York NYS Mesonet Stations table lists estimated power output based on two testing conditions used to rate the output of solar photovoltaic modules for a more limited period than the previous table.  Although there is a temperature factor that should be included to increase accuracy, I am only going to consider the effect of insolation.  In this instance ambient temperatures were close to the testing temperature of 20 deg C so it probably is not much or a factor.  The first test condition is Photovoltaics for Utility Scale Applications (PV-USA) and that determines maximum output when the insolation equals 1,000 watts per square meter.  The second condition is normal operating cell temperature (NOCT) which rates maximum output when the insolation equals 800 watts per square meter.  The Declaration Energy Center Project is proposed to have a generating capacity of 450 MW.  My naïve formula for solar output was simply the observed input solar insolation times solar PV capacity (450 MW) divided by the test condition insolation.

Using Rush meteorological conditions, the largest 5-minute change occurs from 1245 to 1250 EDT when the output changes 66% or 301 MW using PV-USA or 376 MW using NOCT.  It might be more of problem for the York data at 1325 EDT when the output went down 59% but then back in the next five-minute period 52%.  That is a PV-USA load swing of 287 MW and 256 MW or a NOCT load swing of 359 MW and 320 MW.

That is concerning enough but the fact is that the partly cloudy weather on July 18, 2017 commonly covers a large area and it would not surprise me in the least that most of New York was in these conditions.  As of March 17, 2020 there are 36 solar facilities totaling 5,759 MW and another four solar plus storage facilities totaling 740 MW currently in the New York State active permitting queue.  Let’s say that half of the solar-only facilities were in the same weather pattern.  In that case I expect that the solar output would be jumping around by hundreds of MW every five minutes and in the worst case by a couple of thousand MW.  This would be large short-term variability for the grid to handle and remember that I showed earlier that 1% of the time solar generation output varies 40% or more between five-minute periods.

The obvious solution is to require solar facilities to have an energy storage battery that could buffer the output from the solar panels to the grid.  Instead of tying the solar facility directly to the grid the output would go to a battery that should be able to provide power with less fluctuations.

Conclusion

This post adds another caveat to the claims of renewable energy advocates. The all-renewable electric grid has to rely on energy storage.  At first glance energy storage only appears necessary to provide power when renewable resources are not available for hours or days.  However, the requirements are more complicated and nuanced than that.

In previous posts at the Trust, yet verify blog, it was shown that energy storage systems such as the Hornsdale Power Reserve cannot provide peaking support or compensate for intermittency problems at larger power plants unless they are much larger.  On the other hand, Hornsdale is making money providing Frequency Control Ancillary Services.

In my previous energy storage work I considered energy storage with respect to renewable energy resources to determine costs.  In order to rely on renewable energy, stored energy has to be provided at night when the wind is not blowing.  This article shows that in addition to the longer-term storage problem, there is a short-term renewable output fluctuation problem that we may have to rely on battery energy storage to resolve.

There is no question that energy storage systems like the Hornsdale Power Reserve can provide value to the electric grid.  However, we have shown that increased renewable resources will cause multiple problems that have to be resolved.  On one hand, it is clear that much larger battery systems will be needed for the more obvious requirements but it is not clear to me that those systems could also be used to simultaneously resolve the other problems described.   I suspect that batteries operated to provide Frequency Control Ancillary Services or to address the five-minute fluctuations issue have to be operated differently because in both instances they have to react to increases and decreases in power.  Therefore, the batteries would not be charged to the maximum level.  On the other hand, if the primary purpose is energy storage then you need to keep them charged as much as possible.

Renewable advocates are fond of saying that wind and solar development costs are cheaper than fossil-fired alternatives.  However, when you start adding the costs to make those intermittent sources available as needed that argument fails because of the energy storage issues described here.

 

Cuomo’s Promise to Free the New York State Fairgrounds of Fossil Fuels

On March 11, 2020 Glenn Coin at the Syracuse Post Standard posted a paywalled article at syracuse.com entitled Governor Cuomo’s big promise to free the state fairgrounds of fossil fuels: What’s the status?  This post addresses the prospects for a fossil-free State Fair.

Background

I am a retired electric utility meteorologist with nearly 40 years-experience analyzing the effects of meteorology on electric operations.  I have also spent a lot of time evaluating electric load and generation variability.  That background served me well preparing this post.  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.

Mr. Coin did a good job describing the problems involved, but he did not critically evaluate what he was told by the energy experts he interviewed.  On the basis of his interviews he concluded “While building enough solar panels to provide the fair’s electricity would be straightforward and effective, heating the fairgrounds’ vast buildings all year would be much harder and could involve wholesale renovations to heating and hot water systems”.  This post will concentrate on the claim that providing electricity from renewable resources would be “straightforward and effective”.

Coin quoted Chris Carrick, energy program manager for the Central New York Regional Planning and Development Board as saying that “solar is doable”. Carrick, who has overseen solar installations in Central New York, said “the 9 million kilowatt hours the fair used in 2018-2019 could be supplied by a 45-acre solar array and that would cost about $12 million to build”.  Coin pointed out that there would be a problem if the fair installed its own solar power because the electrical use isn’t constant throughout the year. Using monthly data provided by the Fair Data he found that it uses about a third of its annual electricity during the months of August and September.

Coin also interviewed a professor and renewable energy expert at SUNY College of Environmental Science and Forestry, Dr. Neal Abrams. “The fair uses a lot of power, but only for a small amount of time,” Abrams, “Installing solar and/or wind exclusively for the fair doesn’t make sense, but if it is part of a larger state- or utility-owned project, it could.”  Abrams said it might make more sense for the fair to tap into community based solar projects. If the state wanted wind power at the fair, he said, there’s no reason to build new turbines when wind farms are already in place in in Madison county and Tug Hill.

For the purposes of this post I am going to calculate what renewable resources would be required to meet the Governor’s proposal.  In my opinion the claim should stand on its own with new renewable resources.  What the fair does not need can be used elsewhere but it should not rely on existing sources or projects in development designated for other purposes.  Otherwise Governor Cuomo could already have said the State Fair gets all its electric power from renewables instead of a promise for the future.

In order to properly calculate the requirements to make New York State Fair electricity fossil-free detailed historical load information is needed.  I don’t have that information so I am going to have to explain what I am assuming about load and why I am assuming it.  Ultimately, I hope to show readers the difficulties glossed over by the renewable energy proponents that Mr. Coin interviewed.  If you don’t want to wade through the numbers then skip the analysis section and cut to the chase.

Analysis

I am going to focus on Chris Carrick’s claim that “solar is doable”. He said “the 9 million kilowatt hours the fair used in 2018-2019 could be supplied by a 45-acre solar array and that would cost about $12 million to build”.  I will show solar is not so doable or cheap unless you use his simplistic approach.

One of the difficulties explaining technical information is the need for background information.  Another problem is there is little room for the details and, frankly, no public appetite for the boring minutiae needed to check numbers so it is understandable why that information was not included in the article.  I don’t have any space restrictions and will try to keep readers awake long enough in this explanation section so that you understand my calculations and conclusions.

A primary problem with solar energy is that it is intermittent.  Obviously at night there can be no solar energy generated and when it is cloudy the amount produced is lower than on a clear day.  The capacity factor (the actual amount of energy produced divided by the maximum possible amount of energy produced) is a measure of the availability of any electric generation source.  I will use that parameter in this analysis to calculate how much energy can be produced for a solar farm of a given size over a given time.

I chose to use performance information from a local solar installation to evaluate the claim that solar is doable and would cost about $12 million.  I used the Onondaga County Oak Orchard Waste Water Treatment Plant (OOWWTP) which has data in the New York State Energy & Research Development Authority Distributed Energy Resources system.  The first data reported from this installation is dated 31 August 2018.  The facility was developed by Tesla Energy Operations, Inc. with a rated electric generation capacity of 2,523 kW.  Even though this is about ten miles away from the Fair I chose the site because it is relatively new, is at the same elevation as the state fair so there should be no problem with orographic cloud so cloudiness should be relatively similar, and because there wasn’t anything with data available really close to the fair grounds.

According to Coin’s article the fair used 9 million kilowatt hours in 2018-2019.  I will assume that is an annual number.   In 2019 OOWWTP generated 2,363,640 kW of electricity for a capacity factor of 10.7%.  In other words, it produced 937 kWh for each kW of capacity.  In order to produce 9 million kWh the facility would have to have a capacity of 9,607 kW.  The article did not give a capacity but did state that a 45-acre solar farm could provide the electrical energy needed. Assuming 66 square feet generates 1kW of solar energy 9,607 kW would require 14.6 acres of solar panels.  Another way to calculate the space needed from OOWWTP is by estimating the area of the solar array from a satellite view.  I estimate that the OOWWTP array itself covers 7.54 acres and scaling that by the kW capacity produces an area of 28.7 acres.  My annual estimate appears to be significantly different that the Carrick’s quoted 45 acres of panels so I assume he did not use the annual number to estimate the size of the needed solar farm.

Even though I cannot reasonably say that my estimates of the annual solar electric generation reasonably match the article’s estimate it does not matter much because using annual numbers is wrong.  I will show below that the time period used to estimate the necessary resources matters a lot.

The article notes that “The fair uses about a third of its annual electricity during the months of August and September”.  The annual number is 9 million kWh so for those two months 3 million kWh is needed.  The good news is that 2019 monthly capacity factors ranged between 2.14% and 19.44% and the higher numbers are in the summer.  The Monthly Solar Output Onondaga County Oak Orchard WWTP table lists all the monthly values.  I calculated that the capacity factor for the two months would be 14.13%.  In August and September 2019 OOWWTP generated 521,976 kWh of electricity.  Therefore, it produced 207 kWh for each kW of capacity.  In order to produce 3 million kWh the facility would have to have a capacity of 14,500 kW.  Based on the data for these two months the solar facility would have 1.5 times larger capacity than one sized based on annual data.  Assuming 66 square feet generates 1kW of solar energy 14,500 kW would require 22.0 acres of solar panels and scaling the size of the OOWWTP array would be 43.3 acres.  That is pretty close to Carrick’s 45 acres so let’s assume he used the monthly numbers to estimate the necessary resources.

Of course, most of the power is used during the 13-day run of the fair itself.  In order to estimate the daily requirements, I arbitrarily assume that the power used during the State Fair days is ten times the power used on the other 49 days in August and September.  I calculate that the average power used on a State Fair day is 167,598 kWh.  The Daily 2019 State Fair Electric Energy (kWh) Needed and Production Equivalent to Oak Orchard WWTP Solar System table lists the data used to calculate the average State Fair day electric energy need and the daily output and daily capacity factor from the OOWWTP.  Using the same methodology to determine how much electric energy could be generated for each 1 kW of capacity the table lists the capacity needed for each day of the 2019 Fair season.  There probably are daily difference sin energy use as a function of the attendance but I did not try to estimate that effect.  Nonetheless, we can see that even on the day with largest capacity factor (8/25/2019) the capacity needed for one state fair day doubles the monthly estimate and that a facility with a capacity of 30,415 kW would be needed. Importantly note that the day to day variation of the capacity factor.  On the worst day you would need to over 171,000 kW of capacity using these assumptions about daily load at the State Fair and that would require a solar facility nearly 12 times larger than one based on the monthly numbers.  I assume that would be an overestimate because on the day with the lowest solar capacity problem also was the lowest attendance day so probably was not only cloudy but raining.

Renewable proponents rarely acknowledge the time period problem shown here because it makes their cost estimate of the renewable resource worse.  There is an even bigger problem that is rarely mentioned.  The all renewable resource plan should also account for energy storage needed when winds are calm at night.  The Hourly State Fair Electric Energy (kW) Requirements and Estimated Deficit table lists estimated hourly loads and potential solar and wind hourly output.  In order to estimate the hourly load, I made assumptions about the hourly load in the State Fair Hours Weight column.  I assumed that hours 19 through 22 would be maximum load and that hour 02 through 06 would be 15% of the maximum.  The column lists the hourly assumed load as a percentage of the maximum load for all the hours.  I used that information and the assumed 167,598 kWh of a State Fair day value to calculate the hourly loads shown.

The table also lists the hourly renewable energy outputs which can be combined with the hourly load estimate to determine the margin between the two.  Remember that the Governor wants to make State Fair electricity all renewable so at the end of the day the cumulative margin should be positive.  In this analysis I estimated how much wind and solar would be available on the best solar capacity factor day.  I estimated that a solar facility (capacity of 30,415 kW) based on the previous daily requirement analysis combined would be needed and combined that with the OOWWTP output data for August 25, 2019 to predict solar generation.  I utilized the same approach to calculate the capacity that would be needed for a wind farm to power the same average daily load.  II used the capacity factor from all the onshore wind farms during the State Fair and calculated that 23,423 kW of wind capacity would be needed to provide 1,675,978 kWh.  Hourly wind data downloaded from the NYISO real-time dashboard were used to calculate the hourly capacity factors needed to estimate hourly availability of wind on August 25, 2019.

The analysis shows that there are five hours when the combined solar and wind energy resources are insufficient to power the State Fair.  The Governor’s promise to use only renewable resources should include energy storage costs for those five hours when winds are light at night. A recently released report from the National Renewable Energy Lab (NREL): “2018 U.S. Utility-Scale Photovoltaics-Plus-Energy Storage System Cost Benchmark” provides information that can be used to estimate the costs of the energy storage option.  I explained how information from that report could be modified to estimate costs for any configuration in another posted essay.  In the Calculated Cost Breakdown $ per kWh Parameters for a U.S. Li-ion Standalone Storage System table I show how to estimate the costs for a solar-only system ($30.5 million) and a combined solar and wind system ($9 million) to meet the shortfalls for this example State Fair day.

There is another consideration with Li-Ion battery storage systems.  The National Renewable Energy Lab (NREL) report Life Prediction Model for Grid-Connected Li-ion Battery Energy Storage System  notes that in order to maximize battery life the batteries have to be operated such that a limited operating range is used.  In particular the report says that they must use “active thermal management and cycle the battery within a restricted 54% operating range”.  When the operating range limitation is included the battery storage costs increase to $55.7 million for the solar-only system and $16.8 million for the solar and wind system.  Don’t forget that is only for ten years!

 Conclusion aka The Chase

As noted before Chris Carrick claimed “solar is doable”. He said “the 9 million kilowatt hours the fair used in 2018-2019 could be supplied by a 45-acre solar array and that would cost about $12 million to build”.  Using the information available in the article I was not able to reproduce those values exactly so I am not sure what assumptions were used.

I used historical data from a nearby 2,523 kW solar array to compare with Carrick’s numbers.  Using 2019 annual operating capacity in order to produce 9 million kWh the capacity of a solar array would have to be 9,607 kW.  However, the proportion of the size of the local solar array to the size of the array needed is 29 acres which is not particularly close to the size Carrick claimed would be needed.  I assume that even though he mentioned needing 9 million kWh that he did not use that value to calculate the size.

The fair uses about a third of its annual electricity during August and September.  Using the observed operating characteristics of the local array I determined that the size of the array necessary to provide the State Fair with that amount of power would have to be 14,500 kW.  The proportion of that amount of power to the local array indicates that new array would have to be 43 acres so I assume that Carrick sized his array based on the August and September data.

However, in order for renewable resources to provide all the electricity for the State Fair we need to look at the renewable resources and energy use on the ten days when the State Fair is open.  Using the best local data availability and my estimated daily energy usage the solar array necessary to meet the Fair’s needs would have to have a capacity of 30,415 kW, over twice as large as using a monthly estimate to determine needs.  The Daily 2019 State Fair Electric Energy (kWh) Needed and Production Equivalent to Oak Orchard WWTP Solar Systemtable shows that daily variation is high.  On the worst-case day, you would need a solar array of 171,000 kW capacity nearly 12 times larger than one based on a monthly value.

Proponents of renewable energy typically ignore the short-term renewable requirements but there is an even bigger problem.  Any plan to become 100% fossil free needs to account for the fact that energy storage is required at night when the winds are light.  On August 25, 2019 I determined that there were five hours when solar and wind energy resource output would be insufficient to power the fair and that energy storage would be required.  I estimated that 23 MWh of energy storage would be required to balance the deficits observed.  In order to maximize battery life the operating range of Li-Ion batteries is only 54% so that means that batteries capable of providing 43 MWh are needed.

 

I was not able to verify Carrick’s cost estimate of $12 million dollars.  However, using daily data instead of monthly data increases the solar power needed between two and twelve times his estimate so it will be more expensive than he claimed.  In order to minimize energy storage cost, I included output from a 24,423 kW wind farm which I would expect to be on the order of the same cost of the solar array.  Even with the wind farm, the energy storage cost to backup the solar array adds another $16.8 million dollars.  If we assume that the wind and solar resources can last 30 years then that means that the battery cost will be tripled.

 

In conclusion, I expect that the cost of the solar array will be at least doubled if the daily needs of the State Fair are considered, in order to minimize energy storage a wind farm costing about the same as the original solar array has to be included, and energy storage at about the cost of the original solar array will be needed three times over the lifetime of the solar array.  Add them all up and I estimate that the true cost of renewables is at least six times higher than Carrick’s estimate of $12 million.

Mr. Coin concluded “While building enough solar panels to provide the fair’s electricity would be straightforward and effective”.  If costs are no object then it is “doable”, but I challenge the “straightforward and effective” conclusion.  The claim that all that is needed is a 45 acre solar facility is wrong if we are to provide the State Fair with all the electric power needed during the ten days the fair is open.  In the cheapest scenario I estimate that the solar array has to be at least twice as large, a wind farm with ten 2.5 MW wind turbines and an energy storage array totaling 43 MWh would be needed.

I don’t have the time to comment on Mr Coin’s conclusion that “heating the fairgrounds’ vast buildings all year would be much harder and could involve wholesale renovations to heating and hot water systems”.  However, all the problems that I found for the summertime use of electricity at the fairgrounds are compounded in the winter because the solar resource is so much lower.

Finally, there is one last aspect of Cuomo’s, dare I say it, grandstanding.  What about transportation at the State Fair?  With the exception of some of the buses that provide shuttle service, all the transportation servicing the Fair are powered by fossil fuels.  That includes trucks bringing food and material, moving the midway with all the carnival rides and attractions, and all the farmers bringing livestock to exhibit.  Finally even the on-site the trams used to get around are pulled by fossil-fired tractors.

Do not hold your breath waiting for a truly fossil free New York State Fair.

Regulatory Assistance Project Electric Vehicle Roadmap

The Regulatory Assistance Project (RAP) is an” independent, non-partisan, non-governmental organization dedicated to accelerating the transition to a clean, reliable, and efficient energy future”.  This post addresses their “Roadmap for Electric Transportation”.

I have run into RAP policy recommendations before.  Staff are “former utility and environmental regulators, industry executives, system operators, and other policymakers and officials with extensive experience in the power sector”.  After seeing this I wondered who supports their work and could find nothing on their web page.  Mark Krebs looked into RAP and concluded that RAP is effective and well funded but could not find any specifics who funds their work.  He suspects and I agree that “RAP is now being funded by the usual climate fear mongers, such as the Pew Charitable Trust, the Hewlett Foundation, etc.”

The intent of the roadmap is to provide legislators a “complete and useful resource for legislators interested in accelerating electric vehicle deployment”. RAP has developed a policy guide, “as well as a set of model legislative options with annotations noting their implications, a fact sheet and presentation slides”.  In other words, it is a slick lobbying effort.

The roadmap’s introduction prompted me to write this essay.  The introduction states:

“Electrification of the transportation sector (cars, trucks, buses, taxis, ports, etc.) provides an opportunity for states to save citizens money, increase local jobs and business, address national security concerns, improve public health and combat climate change. Real-world experience and studies show that these benefits are achievable, but proactive legislative action and state planning are needed to realize their full magnitude. Without an early and comprehensive approach, potential benefits will be lost.”

In particular, I had to scratch my head how electric vehicles (EV) would provide those benefits.  I address each benefit claim below.

Save Citizens Money

It is a matter of faith that electric vehicles will save consumers money.  The RAP Policy Guide states:

Consumers buy electric vehicles for a variety of reasons, ranging from environmental consciousness to enjoyment of the product. The costs of new EVs are higher than comparable gasoline vehicles, but the cost differential is dropping. EV owners currently save money after purchase because EVs are cheaper to operate and maintain than gasoline vehicles.  Maintenance costs of an EV are lower than for traditional vehicles due to fewer moving parts. Fueling costs are cheaper too; on a national average, it costs less than half as much to travel the same distance in an EV as in a conventional vehicle.

I don’t want to spend a lot of time doing a quantitative analysis of potential cost savings but will make some comments.  There is the obligatory claim that EVs are more expensive now but the costs are coming down and when they do boy oh boy then everyone will want one.  In the meantime, if people would just consider that maintenance and fuel costs are cheaper, then people would buy them.  So, on one hand consumers are supposed to total costs to guide their decision to buy but not all the costs.  What about the batteries?  The life of the battery affects the overall cost of the EV.  There are two factors that affect the life of the battery – calendar life and the number of charging cycles.  Temperature, rate of charge and discharge, depth of discharge, etc. affects the life of the battery.    Consumers like me either buy a new car and drive into the ground or buy used.  In either case I would have battery life anxiety given that a typical Li-ion battery lasts for 300-500 charging-discharging cycles.   One other cost detail is that users have to install a battery charging system.  A 110 volt charging system only costs $500 to $1,000 but takes 18 hours to charge to drive 100 miles.  A 240 volt charging system costs $2,000 to $5,000 and takes 4 hours to charge to drive 100 miles.

Increase Local Jobs and Business

The first contradiction is that the claim electric vehicles require less maintenance also means that there will be fewer maintenance jobs.  In addition, the RAP Policy Guide states “In Minnesota, a study found that installing 150 EV chargers would generate $14.2 million in economic activity, including $4.6 million in labor income”.  The reference for that claim says “The University of Minnesota Extension study indicates that installing just 75 50-kW and 75 150-kW DCFCs in Greater Minnesota would generate $14.2 million in economic activity.  This includes $4.6 million in labor income.  Communities and businesses that host charging stations may also see economic benefits as EV drivers eat or shop while their vehicles charge.”  However, there is no reference for the study to determine if this claim is justified.  The direct cost to construct 75 50-kW and 75 150-kW fast-charging electric vehicle chargers listed is $9.2 million.  Without the original reference to check the assumptions I will assume that each charger equals $9.2 million divided by 150 or $61,333 each.  The report claims that 50 people will be employed at a cost of $3.3 million.  I have no clue how to apportion that because I have no idea how many people would take how long to install a charger but we can add the labor cost to estimate that each charger will cost $83,333.  Somehow the study claims that spending will lead to indirect and induced output of $5 million.

I don’t know what you call grey literature that references grey literature that quotes an unreferenced study but suffice to say it is not peer reviewed science.  All this example and the other points made in the policy guide show is that government spending creates jobs but ignores the broken window fallacy – money spent on EV fast charges, for example, is “money that cannot be spent on food, clothing, health care, or other industries. The stimulus felt in one sector of the economy comes at a direct – but hidden – cost to other sectors”.

Address National Security Concerns

Just when you thought the claims could not get anymore ignorant the national security benefit is described:

In 2017, the United States imported about 19% of the petroleum it consumed. Because transportation accounts for nearly three-fourths of total U.S. petroleum consumption, using more energy-efficient vehicles like hybrid and plug-in electric vehicles can have a direct impact. When EVs plug in, they are mostly powered by a domestic mix of energy sources, including natural gas, coal, nuclear, hydropower, wind and solar. This is in stark contrast to gasoline-fueled vehicles, which depend solely on oil — which is subject to a range of global price and availability risks.

This studiously ignores the changes caused by fracking which have changed the import/export dynamic because in 2018 the US only imported 11% (or 8% less than in 2017) of the petroleum it consumed and I am sure that the 2019 imports will be even lower.  There also is another national security issue – not enough of the rare earth minerals necessary for EV batteries are produced in the US.  It is estimated that there’s about 63 kg of lithium in a 70 kWh Tesla Model S battery pack, which weighs over 1,000 lbs (~453 kg).  When asked if he worries about lithium supply, Tesla CTO JB Straubel once said that he worries more about cobalt, which is used in the cathode of Tesla’s battery cells. The resource is more problematic since the bulk of it overall supply has historically come from the conflict-prone Congo.  Clearly, if you look at the big picture national security concerns will be an issue if we try to electrify transportation compared to where we stand now with petroleum.

Improve Public Health

The fact is that ambient air quality levels have been coming down in the United States for years.  There still are ambient air quality issues and a switch to electric vehicles will help alleviate those health problems.  However, there will be diminished returns for future reductions simply because the concentrations are already so low.  In fact, the marginal improvements in the United States have to be weighed against health impacts elsewhere.

The public health improvements claimed by EV advocates immorally ignore the environmental and health impacts of rare-earth mineral mining elsewhere.  In particular, cobalt is problematic.  Unlike most metals, which are not toxic when they’re pulled from the ground as metal ores, cobalt is “uniquely terrible,” according to Gleb Yushin, chief technical officer and founder of battery materials company Sila Nanotechnologies.  “One of the biggest challenges with cobalt is that it’s located in one country,” he adds. You can literally just dig up the land and find cobalt, so there’s a very strong motivation to dig it up and sell it, and a a result there’s a lot of motivation for unsafe and unethical behaviour.” The Congo is home to ‘artisanal mines’, where cobalt is extracted from the ground by hand, often using child labour, without protective equipment”.

Combat Climate Change

Advocates for greenhouse gas reductions regularly pick and choose which numbers to include and which ones to exclude.  Until the electric grid operates only without fossil fuels, the CO2 emitted from the tailpipe is simply moved to an electric generating unit stack somewhere.  I would love to see a true life-cycle analysis of the 100% renewable energy system vs. the fossil-fueled energy system.  I suspect that the real observable environmental impacts of the renewable system with the enormous areas required to provide power as opposed to the fossil-fueled system of today are greater.

More importantly, transportation greenhouse gas emissions in, for example, New York are such a small fraction of global emissions any reduction will not provide any tangible benefits. In the New York Transportation Analysis of Carbon Dioxide Emissions and Potential “Savings” table I present the effects of completely eliminating the total NY transportation emissions of 73.98 million metric tons of CO2 equivalent in 2016.  The table shows that the transportation emissions are 0.23% of the total global emissions and that we could expect the global temperature in 2010 will only be 0.0023 degrees C if those emissions are eliminated.  These numbers don’t mean much but can be related to the facts that temperatures decrease as you go higher in elevation or temperatures increase as you go further south in latitude.  Specifically, temperature generally decreases three degrees Fahrenheit for every 1,000 foot increase in elevation above sea level and temperature changes three degrees Fahrenheit for every 300 mile change in latitude at an elevation of sea level.  In this instance, completely eliminating New York transportation emissions would be the same as a nine inch change in elevation or two tenths of a mile change in latitude.

Conclusion

There is another aspect of the EV policy that weakens the benefits arguments.  In A reality check on electric cars Bill Lynch and Dr. Jay Lehr crunched some numbers and show that the benefits of electric cars are based on weak numbers.  They also show that the goal of a longer range EV is unlikely simply because the weight of the additional batteries needed offsets the mileage gained.  The bottom line is that the prospects for improved EV performance are not as rosy as proponents suggest.

To summarize, the benefits claimed in this study are all either feel good virtue signals or demonstrably inaccurate.  There could be public health impacts but given current ambient levels of pollution they will be smaller than imagined in the descriptions of this report.  There will be climate change “benefits” but they are only feel-good measures because the impacts could never be measured.  Cost savings projections are based more on expected cost reductions and ignore the additional costs of installing a charging system.  The claims made for local jobs and business cannot be verified and ignore reductions that would necessarily occur in the existing vehicle service job market.  The claims for national security ignore the current status of petroleum imports and exports.  More importantly, they immorally ignore the very real horrific environmental and societal impacts of cobalt mining in the Congo as well as the fact that relying on that country for a critical component necessary for electrifying transportation would substantively increase national security concerns.

The RAP is a front organization for climate fear mongers.  This slick package of lobbying materials is based on shallow and inaccurate claimed benefits.  Sadly, I expect that it will find a ready audience for those convinced that we have to do something and unwilling to check the basis of the arguments.