Pragmatic Environmentalist of New York

Climate Leadership and Community Protection Act Environmental Justice Tradeoffs

On January 11, 2021 the Climate Leadership and Community Protection Act (CLCPA) Generation Advisory Panel met as part of the Climate Action Council Scoping Plan development process. During that meeting one discussion considered the health effects of New York City peaking power plants on environmental justice communities. The CLCPA process focus on this problem needs to consider the impacts of the solutions proposed as alternatives.

On July 18, 2019 New York Governor Andrew Cuomo signed the CLCPA which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency. I have written extensively on implementation of the CLCPA closely because its implementation affects my future as a New Yorker. I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulations, listed the scoping plan strategies, summarized some of the meetings and complained that its advocates constantly confuse weather and climate. The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

The January 11, 2021 the Generation Advisory Panel notes document the discussion about New York City peaking power plants. Following the publication of the Physicians, Scientists, and Engineers (PSE) for Healthy Energy report Opportunities for Replacing Peaker Plants with Energy Storage in New York State last summer, these plants became a touchstone for environmental justice issues in New York City. I discussed how the analysis was used in the PEAK Coalition report entitled: “Dirty Energy, Big Money”. In another post provided information on the primary air quality problem associated with these facilities, the Peak Coalition organizations, the State’s response to date, the underlying issue of environmental justice and addressed the motivation for the analysis. A second post addressed the rationale and feasibility of the proposed plan relative to environmental effects, affordability, and reliability. All three reports were also summarized.

Since the Power Generation Advisory Panel meeting, I prepared a post explaining that the Peak Coalition analysis of peaking plants misses the point of peaking plants and their environmental impacts. The claimed air quality health impacts are from ozone and inhalable particulates. Both are secondary pollutants that are not directly emitted by the peaking power plants so do not affect local communities as alleged. On the other hand, the proposed solutions have much greater health impacts than the air quality problems that are present in New York City’s environmental justice communities.

NYC PM2.5

I prepared a post specifically on New York City PM2.5 because the primary public health reference in the PEAK Coalition report was the New York City Department of Health and Mental Hygiene’s (DOHMH) Air Pollution and the Health of New Yorkers report. The PEAK coalition description of air quality public health impacts quotes the conclusion from the DOHMOH report: “Each year, PM2.5 pollution in [New York City] causes more than 3,000 deaths, 2,000 hospital admissions for lung and heart conditions, and approximately 6,000 emergency department visits for asthma in children and adults.” These conclusions are for average air pollution levels in New York City as a whole over the period 2005-2007.

In my analysis I found that the DOHMOH report claimed that:

Even a feasible, modest reduction (10%) in PM2.5 concentrations could prevent more than 300 premature deaths, 200 hospital admissions and 600 emergency department visits. Achieving the PlaNYC goal of “cleanest air of any big city” would result in even more substantial public health benefits.

It is rarely noted by environmental activists that PM2.5 air quality has improved markedly since 1999 mostly because of national reductions in sulfur dioxide and nitrogen oxides emissions. The NYS DEC air quality monitoring system has operated a PM2.5 monitor at the Botanical Garden in New York City since 1999 so I compared the data from that site for the same period as this analysis relative to the most recent data available (Data from Figure 4. Baseline annual average PM2.5 levels in New York City). The Botanical Garden site had an annual average PM2.5 level of 13 µg/m³for the same period as the report’s 13.9 µg/m³ “current conditions” city-wide average (my estimate based on their graph). The important thing to note is that the latest available average (2016-2018) for a comparable three-year average at the Botanical Garden is 8.1 µg/m³which represents a 38% decrease. That is substantially lower than the PlaNYC goal of “cleanest air of any big city” scenario at an estimated city-wide average of 10.9 µg/m³.

Note that in DOHMOH Table 5 the annual health events for the 10% reduction and “cleanest” city scenarios are shown as changes not as the total number of events listed for the current level scenario. My modified table (Modified Table 5. Annual health events attributable to citywide PM2 5 level) converts those estimates to totals so that the numbers are directly comparable. I excluded the confidence interval information because I don’t know how to convert them in this instance. I estimated the health impact improvements due to the observed reductions in PM2.5 as shown in the last three columns in the modified table. I estimate that using the DOHMOH methodology the observed reduction in PM2.5 concentrations prevented nearly 1,300 premature deaths, 800 hospital admissions and 2,400 emergency department visits. It is important to note that New York’s power generation fleet cannot do much more to continue these health improvements simply because the emissions are so low now tht comparable emission reductions are not possible. In any event the peaker units in the city don’t contribute to these secondary pollutant impacts.

Environmental Justice Hypocritical Tradeoffs

The apparent preferred option to fossil-fired power plants is to use energy storage ultimately powered using renewables. Energy storage, wind generation and solar generation technology all require rare earth metals found in terrestrial rocks in infinitesimal amounts which have superb magnetic, catalytic and optical properties needed for these resources. Therein lies an environmental justice problem unless it is addressed in the CLCPA process..

French journalist and documentary filmmaker Guillaume Pitron has been following the global trade in rare earth metals. Unfortunately, mining these materials come with heavy environmental and social costs. Mining generates massive amounts of polluted wastewater, which left untreated, poisons crops and makes people sick. Guillaume documents these issues in his 2018 book “Rare Metals War’. Recently his work was summarized in the article “Toxic secrets behind your mobile phone: Electric cars, wind turbines and solar panels… how our so-called green world depends on the mining of rare metals which is a filthy, amoral industry totally dominated by China”.

Pitron explains that he visited the Weikuang Dam – an artificial lake into which metallic intestines regurgitate torrents of black water from the nearby refineries. He looked ten square kilometres of toxic effluent. He went to a village called Dalahai on another side of the artificial lake. Here, the thousands of inhabitants breathe in the toxic discharge of the reservoir as well as eating produce, such as corn and buckwheat, grown in it. What he found was a real environmental nightmare:

Cancer affects the local population and many villagers have died. The hair of young men barely aged 30 has suddenly turned white. Children grow up without developing any teeth.

One villager, a 54-year-old called Li Xinxia, confided in me despite knowing it’s a dangerous subject. He said: ‘There are a lot of sick people here. Cancer, strokes, high blood pressure… almost all of us are affected. We are in a grave situation. They did some tests and our village was nicknamed “the cancer village”. We know the air we breathe is toxic and that we don’t have that much longer to live.’

The provincial authorities offered villagers compensation to relocate but these farming folk were reluctant to move to high-rise flats in a neighbouring town.

In short, it is a disaster area.

When you consider the immense effort necessary to produce these rare earth metals for batteries I believe it is hypocritical to demand replacement of fossil-fired power plants without considering the environmental impacts of its alternatives. In the case of New York City power plants, the health impacts associated with the power plants are statistical creations whereas the health impacts of rare earth metal extraction are incontrovertible acute impacts. While there still is room for improvement in New York, no children are growing up without developing teeth.

Conclusion

One of the fundamental problems with any Greenhouse Gas emission reduction program is leakage. Pollution leakage refers to the situation where a pollution reduction policy simply moves the pollution around the globe rather than actually reducing it. Similarly, economic leakage is a problem where the increased costs inside the control area leads to business leaving for non-affected areas. There also is an economic leakage effect in electric systems where a carbon policy in one jurisdiction may affect the dispatch order and increase costs to consumers in another jurisdiction. I also submit that environmental impact leakage where efforts to reduce much greater impacts are the result elsewhere.

The CLCPA specifically mandates that emissions inventories for the energy sector include an estimate of what may be referred to as the lifecycle, fuel cycle, or out-of-state upstream emissions associated with in-state energy demand and consumption. However, because the replacement renewable energy resources are dependent upon rare earth metals there is a large environmental problem associated with their deployment. It is hypocritical for the CLCPA to demand lifecycle analyses of one aspect of energy development but not all others. Therefore, the implementation process should demand ethically sourced rare earth metals be used for batteries, wind energy, and solar energy.

My Accelerated Renewable Energy Growth and Community Benefit Act Comments on the Power Grid Study

On January 19, 2021 the New York State Department of Public Service (DPS) submitted the Initial Report on the Power Grid Study (“Power Grid Study”) prepared pursuant to the Accelerated Renewable Energy Growth and Community Benefit Act (AREGCBA). The AREGCBA legislation is intended to ensure that Climate Leadership and Community Protection Act (CLCPA) renewable generation is sited in a timely and cost-effective manner. The primary purpose of the Power Grid Study is to “inform planning for the bulk transmission and local transmission and distribution (T&D) investments that will be necessary to achieve the clean energy mandates established under the CLCPA”. In order to achieve those mandates and maintain the same level of reliability as the existing system, somebody, somewhere has to provide transmission grid ancillary services. Because none of those reports addressed the requirement for those services, I submitted comments to the DPS. This post documents those comments for future reference.

I have written extensively on implementation of the CLCPA closely because its implementation affects my future as a New Yorker. I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulations, listed the scoping plan strategies, summarized some of the meetings and complained that its advocates constantly confuse weather and climate. The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

I do not understand why the transmission grid ancillary services described here have not been addressed. A reliable electric power system is very complex and must operate within narrow parameters while balancing loads and resources and supporting synchronism. New York’s conventional rotating machinery such as oil, nuclear, and gas plants as well as hydro generation provide a lot of synchronous support to the system. This includes reactive power (vars), inertia, regulation of the system frequency and the capability to ramping up and down as the load varies. Wind and solar resources are asynchronous and cannot provide the necessary grid ancillary support.

Some, but not all of the disadvantages of solar and wind energy in this regard can be mitigated through electronic and mechanical means. When these renewable resources only make up a small percentage of the generation on the system, it is not a big deal. The system is strong enough that letting a small percentage of the resources that don’t provide those services to lean on the system. But as the penetration of solar and wind energy increases the system robustness will degrade and reliability will be compromised without costly improvements. A renewable system could be coupled with extensive batteries and other storage devices, large mechanical flywheels and condensers (basically an unpowered motor/generator that can spit out or consume reactive power). These devices could approximate the behaviors of our conventional power system.

My particular concern is that so far, the CLCPA process has only considered the energy storage ancillary services needed to keep the system operating when intermittent wind and solar resources are not available. Unfortunately, the reports in the Power Grid Study primarily considered bulk transmission and T&D investments related to capacity needs. As important as those investments are, the other grid support requirements needed so the electric grid can transmit the power from where it is produced to where it is needed are not adequately discussed in the Power Grid Study that is supposed to inform the CLCPA implementation process.

Comments

I am only going to summarize my comments in this post. The comments and a previous post provide more details.

The comments were based on my review of four reports in the Power Grid Study to see if the ancillary transmission grid services necessary to keep the grid operating were considered:

- - - Initial Report on the New York Power Grid Study;
    - Appendix C: Utility Transmission & Distribution Investment Working Group Study;
    - Appendix D: Offshore Wind Integration Study; and
    - Appendix E: Zero-Emissions Electric Grid in New York by 2040 Study.

I checked these reports in two ways. First, I reviewed the approaches and then I searched the documents for specific references to these services.

I extracted the study approaches for the Initial Report and Appendices C, D, and E. In my opinion, there is no indication that any of the approaches included this problem as part of their charge. It also appears that the guidelines established by the PSC in its May 2020 Order that do not include a charge to look at these services.

The other screening methodology I used was a term search of the documents. I searched documents for terms that I believe should be associated with the ancillary services requirement. I used the following search terms: “Synchro”, “Ancillary”, “Frequency”, “Inertia”, “Reactive” and “Vars”.

In the Initial Report I found several cursory references to the ancillary services challenge. Static synchronous series compensators were mentioned because they offer the operating flexibility to avoid congestion in meshed networks and provide an effective solution to congestion that may arise from variable renewable energy. There were two references to the fact that Smart Inverters can provide ride-through capability for frequency and voltage fluctuations that would typically trip the inverters and can regulate the use of ancillary services that may be provided by solar or storage devices. However, the full extent of this challenge was not addressed.

The Utility Transmission & Distribution Investment Working Group Study was the only report that included a section of the report that actually addressed the problem. in a section on potential technology solutions that included “Energy storage for T&D services”. It addressed ancillary services beyond energy storage:

“Energy storage is increasingly being considered for many transmission and distribution (T&D) grid applications to potentially enhance system reliability, support grid flexibility, defer capital projects, and ease the integration of variable renewable generation. Central to the State’s policies and mandates is the need to enhance power system flexibility to effectively manage renewable energy deployment and the associated increase in variability. As power systems begin to integrate higher penetrations of variable, renewable, inverter-based generation in place of conventional fossil-fuel fired synchronous generation, grid-scale energy storage could become an increasingly important device that can help maintain the load-generation balance of the system and provide the flexibility needed on the T&D system. Pumped hydro storage (PHS) and compressed air energy storage (CAES) are long-established bulk energy storage technologies.”

Utility-scale lithium-ion battery storage has expanded dramatically, as decreasing lithium-ion battery costs make this an increasingly cost-effective solution to meet T&D non-wire, reliability, and ancillary service needs. Redox flow batteries, sodium sulfur batteries, thermal energy storage (both latent and sensible heat), and adiabatic compressed air energy storage are all in various stages of demonstration. This information provides a concise overview of a wide variety of existing and emerging energy storage technologies being considered for T&D systems. It describes the main technical characteristics, application considerations, readiness of the technology, and vendor landscape. It also discusses implementation and performance of different energy storage technologies. In this Report, energy storage systems greater than 10 MW and four or more hours of duration, are considered as bulk and transmission and sub- transmission-connected energy storage.

Two of the eight utilities participating in the report included specific projects related to these ancillary services. However, the study did not quantify the risks of adverse inverter-based resource behavior or voltage instability in general and only LIPA included specific projects to address that problem. Clearly, someone has to quantify these risks.

The Offshore Wind Integration Study was primarily focused on the narrow scope of getting offshore wind into the New York grid. Most of the references to these terms were in the context of transmission capacity not transmission support. In connection to the costs, it was mentioned that the cost of each offshore wind project could be impacted by certain specific cost drivers such as required ancillary services.

I reviewed Zero Emissions Study the same way. According to the findings of the report:

“Based on the analysis carried out in the study, New York State should be able to achieve its 70 x 30 and zero-emission generation by 2040 goals under both the Initial Scenario and the High Demand Scenario using a mix of distributed energy, energy efficiency measures, energy storage, planned transmission projects, utility-scale renewables, and zero-emission resources. The most significant difference in these scenarios was the amount of renewable generation added and the scope (transmission capacity increases) of the transmission projects required to manage congestion and reduce costs.”

Note that this summary described transmission capacity increases but did not mention the ancillary support services requirements. I found no references that addressed reactive power (vars), inertia, or regulation of the system frequency, but they did mention the ramping adequacy ancillary service. Given that achieving the CLCPA goals will require these ancillary services and the report did not address the problem the conclusion that New York should be able to achieve the goals is unsupportable.

Conclusion

My particular concern is that other venues of the CLCPA process have also only considered the energy storage ancillary services needed to keep the system operating when intermittent wind and solar resources are not available. The Power Grid Study was concerned about the related issue of transmission capacity and availability to support the renewable energy resources projected. Unfortunately, the other grid support requirements needed so the electric grid can transmit the power from where it is produced to where it is needed are not discussed in sufficient detail to acknowledge the problem in three of the reports included in the Power Grid Study that is supposed to inform the CLCPA implementation process. Instead, all but Appendix C: Utility Transmission & Distribution Investment Working Group Study ignore or dismiss these services.

The future CLCPA electric system that will be dependent upon wind and solar resources has to be coupled with other devices that can approximate the behaviors of our conventional power system in order to get the power where it is needed. This is a significant shortcoming in the CLCPA process that must be addressed. The conclusion from these reports that New York State should be able to achieve the 2040 CLCPA targets is not based on adequate analysis. The transmission grid ancillary services needed for a wind and solar powered electric system issue must be addressed to determine feasibility.

Climate Leadership and Community Protection Act Borrego Solar Rutland Center Solar 1 Project

New York’s Climate Leadership and Community Protection Act (CLCPA) establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency. The subject of this post is the Borrego Solar Rutland Center Solar One 110-megawatt solar facility in the Towns Rutland and Watertown, Jefferson County, New York.

The CLCPA was described as the most ambitious and comprehensive climate and clean energy legislation in the country when Cuomo signed the legislation but there is one massive flaw. The lawmakers who enacted this law presumed that the transition of the state’s energy system could be implemented by political will so did not include feasibility conditions in the targets or schedules. This post is a short description of one aspect of the many implementation problems of this law.

I have summarized the schedule, implementation components, and provide links to the legislation itself at CLCPA Summary Implementation Requirements. I have written extensively in long posts on implementation of the CLCPA because its implementation affects my future as a New Yorker. I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulations, listed the scoping plan strategies, summarized some of the meetings and complained that its advocates constantly confuse weather and climate. 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.

Rutland Center Solar

My problem with this project is not the development itself but the lack of planning associated with the headlong rush to develop renewable energy to support the CLCPA. At the 19 January 2021 Climate Action Council meeting the meeting presentation announced that “New York has made the largest combined renewable energy awards ever by a U.S. State”. New York’s 2020 renewable energy standard solicitation includes 22 new large-scale renewable energy projects shown in the following map. The thing that prompted this post is the location of the 110 MW Rutland Center Solar One project due east of Lake Ontario in the north central part of the state.

Anyone who knows anything about the weather at the eastern end of Lake Ontario knows where I am going with this post. While it is not in the bullseye of the peak lake-effect snow area, the following map shows that it is darn close. I am a meteorologist who has lived in and studied the lake-effect weather region of Central New York. Because Lake Ontario does not freeze over in the winter anytime cold air crosses the relatively warm water clouds form if you are lucky and if you are not lucky it snows. Of course, there are other factors that affect these storms but the key point is that the amount of snow is maximized by the time the upstream air spends over the lake so the eastern end is the optimal location for Lake Ontario lake-effect snow. There is one other aspect and that is orography or elevation also increase snowfall amounts and the Tug Hill Plateau is at the eastern end of the lake squarely under the bullseye.

According to Wikipedia, the town of Rutland, New York has an elevation of 978’ as compared to Lake Ontario at 243’. I could find no information about the solar project to determine exactly where it is supposed to go. As you can see in the snowfall map there is a strong gradient of snowfall from the yellow (120 to 125”) to the pink (>200”). Given the elevation difference of Rutland above the Black River Valley I believe that this solar center is affected by this orographic effect and is in the 150” of average snowfall per year area.

The problem with the lack of feasibility planning in the CLCPA is that they have not addressed the multi-day winter doldrum period when wind and solar are at their lowest expected availability. There is a rush of solar energy projects that no doubt make headlines that New York has made the largest combined renewable energy awards ever by a U.S. State. However, if those solar projects do not provide any power for the worst-case period then it might not be the best investment that New York can make. Of course, the solar availability is even lower if the solar panels are covered by snow and it sure looks like the Rutland Center location is going to have that problem.

In conclusion, the CLCPA implementation process has to start looking at the big picture of how electricity will be produced during the multi-day winter doldrum because that might guide renewable energy investments. If a project cannot provide any support during those periods it may not be appropriate to support.

Climate Leadership and Community Protection Act Transmission Ancillary Services – Somebody Else’s Problem

UPDATE January 24, 2021: After posting this I prepared a comment for the New York Department of Public Service Case 20-E-0197 – Proceeding on Motion of the Commission to Implement Transmission Planning Pursuant to the Accelerated Renewable Energy Growth and Community Benefit Act addressing the Power Grid Study. I provide this update to note that there was a fourth document in the reports discussing offshore wind but that the report also did not address the problem described here.

On January 19, 2021 the New York State Department of Public Service (DPS) submitted the Initial Report on the Power Grid Study (“Power Grid Study”) prepared pursuant to the Accelerated Renewable Energy Growth and Community Benefit Act (AREGCBA). The AREGCBA legislation is intended to ensure that Climate Leadership and Community Protection Act (CLCPA) renewable generation is sited in a timely and cost-effective manner. In order for an electric energy grid powered primarily by renewable energy resources to maintain the same level of reliability as the existing system, somebody, somewhere has to provide transmission grid ancillary services. However, none of the three reports provided in the documentation address the problem apparently because it is somebody else’s problem.

Background

First let me describe transmission grid ancillary services. A reliable electric power system is very complex and must operate within narrow parameters while balancing loads and resources and supporting synchronism. New York’s conventional rotating machinery such as oil, nuclear, and gas plants as well as hydro generation provide a lot of synchronous support to the system. This includes reactive power (vars), inertia, regulation of the system frequency and the capability to ramping up and down as the load varies. Wind and solar resources are asynchronous and cannot provide these necessary grid ancillary support.

My particular concern is that the CLCPA process has only considered the energy storage ancillary services needed to keep the system operating when intermittent wind and solar resources are not available. Importantly, the other grid support requirements needed so the electric grid can transmit the power from where it is produced to where it is needed are not adequately discussed in two of the reports included in the Power Grid Study that is supposed to inform the CLCPA implementation process.

Discussion

As far as I have been able to see this component of the future electric system has not been addressed by the CLCPA implementation process. I have reviewed two processes to determine if it is being considered. The Power Generation Advisory Panel that is supposed to develop recommendations for the Scoping Plan that will guide implementation of the changes to the electric system needed to meet a goal of zero emissions by 2040. In my review of their strategy recommendations, I found that they did not mention the problem.

The second process and focus of this post is the Power Grid Study. According to the Executive Summary:

“Transmission & Distribution (T&D) infrastructure will play a critical role in meeting the State’s goals by connecting new renewable resources to the grid and transmitting and delivering energy to consumers. Accordingly, the recently enacted Accelerated Renewable Energy Growth and Community Benefit Act directs the Public Service Commission (PSC) to advance the work of identifying T&D upgrades needed to reliably and cost-effectively integrate the required renewable resources, and to establish planning processes to support cost-effective and timely infrastructure development.”

“To meet these directives, the PSC, through the Department of Public Service, initiated a set of system studies, collectively referred to as the Power Grid Study, which is the subject of this Initial Report. The PGS consists of three components, each of which is included in this Report:

- - - - A study conducted by the Joint Utilities1 on local transmission and distribution (LT&D) needs (Utility Study);
      - A study of offshore and onshore bulk-power transmission infrastructure scenarios, and related environmental permitting considerations, to illustrate possible solutions to integrate the mandated 9,000 MW of offshore wind (OSW generation by 2035, sponsored by the New York State Energy Research and Development Authority (NYSERDA) and conducted by DNV-GL, PowerGem, and WSP (OSW Study)
      - A state-wide scenario-based study to analyze transmission, generation, and storage options for achieving 70% renewable generation by 2030 and a zero emissions grid by 2040, sponsored by NYSERDA and conducted by Siemens (Zero Emissions Study).”

Given the importance of the transmission grid ancillary services needed to keep the lights on I assumed that they would be addressed in the Power Grid Study documents. Collectively these documents are huge so instead of reading each one to determine if these services were included, I searched them. I used search terms that I believe should be associated with this requirement. I used the following search terms: “Synchro”, “Ancillary”, “Frequency”, “Inertia”, “Reactive” and “Vars”.

When I used those search terms in the study of offshore and onshore bulk-power transmission infrastructure scenarios, the only relevant references mentioned static synchronous series compensators and smart inverters. Those were passing references to specific kinds of equipment and did not address the scope or magnitude of the services necessary to maintain reliability. I believe this indicates that this study does not adequately address this issue

I also reviewed the Utility Study in the same way and in that report found relevant references. Eight utility companies proposed plans for local transmission and distribution systems to meet the CLCPA requirements and two included projects targeted to address these ancillary services. The Long Island Power Authority (LIPA) identified a “potentially major issue on the transmission system with the significant increase of inverter-based resources (IBR) and concurrent retirement of conventional fossil power plants is the weakness of the system and the potential for adverse IBR behavior due to this weakness, as well as voltage instability.” This is exactly the kind of issue that I believe needs to be addressed. The report does not quantify this risk but explains that it is very likely that “new synchronous resources will be required (or alternatively, existing resources not being retired and run uneconomically) to strengthen the system such that these new IBR as well as the overall power system can operate in a stable manner.” LIPA included a proxy project for at least one synchronous condenser installation on their system. Avangrid proposed Power Flow Control Devices at several locations including three (3) different technologies (Series Reactors, Phase Angle Regulators, and Static Series Synchronous Compensator devices).

In addition, the report raised the issue in a section on potential technology solutions that included “Energy storage for T&D services” that addressed ancillary services beyond energy storage:

“Utility-scale lithium-ion battery storage has expanded dramatically, as decreasing lithium ion battery costs make this an increasingly cost-effective solution to meet T&D non-wire, reliability, and ancillary service needs. Redox flow batteries, sodium sulfur batteries, thermal energy storage (both latent and sensible heat), and adiabatic compressed air energy storage are all in various stages of demonstration. This information provides a concise overview of a wide variety of existing and emerging energy storage technologies being considered for T&D systems. It describes the main technical characteristics, application considerations, readiness of the technology, and vendor landscape. It also discusses implementation and performance of different energy storage technologies. In this Report, energy storage systems greater than 10 MW and four or more hours of duration, are considered as bulk and transmission and sub- transmission-connected energy storage.”

There were also several other general references to the ancillary services problem. However, the study did not quantify the risks of adverse inverter-based resource behavior or voltage instability in general and only LIPA included specific projects to address that problem. Kudos to the Utility Study for identifying the problem butsomeone has to quantify these risks.

I reviewed Zero Emissions Study the same way. According to the findings of the report:

Note that this summary described transmission capacity increases but did not mention the ancillary support services requirements. I found no references that addressed reactive power (vars), inertia, or regulation of the system frequency, but they did mention the ramping adequacy ancillary service. Therefore, the claim that New York State should be able to achieve the targets is not based on adequate analysis.

Conclusion

There were three reports included in the Power Grid Study documentation. The Power Grid Study itself did not address any of the component ancillary services issues. The Utility Transmission & Distribution Investment Working Group Study broached the general problem but only two utilities offered projects to address related components of the problem. The Zero-Emissions Electric Grid in New York by 2040 confidently claimed that New York should be able to achieve its zero-emission by 2040 goal but only mentioned ramping adequacy as a potential issue. As a result, this documentation falls far short of what is necessary to guarantee the reliability of the electric system by 2040. Those unaddressed requirements will lead not only to cost shifting where the total costs of fossil fuel alternatives have to be directly or indirectly subsidized by the public, but also reliability concerns because no electric grid anywhere has resolved these transmission grid ancillary services requirements and successfully maintained a grid that is as reliant on wind and solar resources as the proposed NY grid.

Given the vital importance of transmission ancillary services to maintain a reliable grid how can anyone explain that two out of three reports on the future grid don’t even mention the problem in any detail? I could not help but notice that this situation is the same as the “Somebody Else’s Problem” phenomenon described by Douglas Adams in his novel Life, the Universe and Everything (in The Hitchhiker’s Guide to the Galaxy comedy science fiction series). Adams describes the idea of an “SEP field” as a kind of cloaking device. The character Ford Prefect says: “An SEP is something we can’t see, or don’t see, or our brain doesn’t let us see, because we think that it’s somebody else’s problem. That’s what SEP means. Somebody Else’s Problem. The brain just edits it out, it’s like a blind spot.” The text then explains: “The Somebody Else’s Problem field… relies on people’s natural predisposition not to see anything they don’t want to, weren’t expecting, or can’t explain.” I can only conclude that the authors of these reports didn’t address transmission ancillary services because it was somebody else’s problem.

Climate Leadership and Community Protection Act Power Generation Advisory Panel Strategies Comment

The Climate Leadership and Community Protection Act (CLCPA) became effective on January 1, 2020 and establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency. The law mandated the formation of the Climate Action Council to prepare a scoping plan to outline strategies to meet the targets. This is one of a series of posts describing aspects of that process. This post is my reaction to the Power Generation Advisory Panel’s initial strategies.

I am very concerned about the impacts of the Climate Leadership and Community Protection Act (CLCPA) on energy system reliability and affordability. There are very few advocates for the typical citizen of New York who has very little idea about the implications of the CLCPA on energy costs and personal choices. 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.

Power Generation Strategy Comments

I am disappointed by this panel’s strategies. Arguably the strategies from this panel are the most important because a basic tenet of decarbonization is electrification of everything. If the proposed strategies are not realistic then everything else fails. I have no seen no sign that there is sufficient focus on strategies that address reliability and affordability of a completely transformed electric sector.

In a post on the peaking power plant problem in New York City I included a section on public policy concerns. I have previously described how the precautionary principle is driving the CLCPA based on the work of David Zaruk, an EU risk and science communications specialist, and author of the Risk Monger blog. In a recent post, part of a series on the Western leadership’s response to the COVID-19 crisis, he described the current state of policy leadership that is apropos to this panel. He explains that managing policy has become more about managing public expectations with consultations and citizen panels driving decisions than trying to solve problems. He says now we have “millennial militants preaching purpose from the policy pulpit, listening to a closed group of activists and virtue signaling sustainability ideologues in narrowly restricted consultation channels”. That is exactly what is happening on this panel in particular. Facts and strategic vision were not core competences for the panel members. Instead of what they know, their membership was determined by who they know. The social justice concerns of many, including the most vocal, are more important than affordable and reliable power. The emphasis on the risks of environmental justice impacts from the power generation sector is detracting from the need to develop a scoping plan that ensures affordable and reliable electricity.

It is not clear that the members even understand the enormity of the challenge. I used the panel’s email address for public comments last October to suggest a workshop to explain how energy systems work and quantify how much energy is needed and where to provide reliable power to give the panel members a common basis. I even included an overview of the energy system to show why the workshop is needed. There is no sign that anyone on the panel is aware of my comments and there hasn’t been a workshop. I naively believed that that the deep decarbonization workshop would address this need. Unfortunately, the workshop did not provide any discussion of the reliability challenges. Instead, the workshop mostly reinforced the notion that CLCPA targets will be met because of the political will of the State. Long-duration energy storage is the key need and a presentation on that was useful but it did not address the availability or applicability to New York so it is not clear if there is a viable solution to this critical requirement in the timeframe needed. The keynote, hydrogen, and carbon sequestration presentations all sound great superficially but no context relative to New York needs was given and they all have serious technological or implementation issues.

The panel organized itself into four sub-groups: equity, barriers, solutions for the future, and resource mix. They presented ten strategies in the presentation to the Climate Action Council. I address their strategies below.

The equity sub-group presented three strategies. I don’t think these should be stand-alone strategies. Instead, these concerns should be incorporated into strategies for the transition similar to how equity considerations were handled by all the other panels.

The first strategy addressed community Impact suggesting the development of recommendations to identify and proactively address community impacts relating to health concerns, access to renewables and energy efficiency, and siting. Four equity concerns are described:

- - - Reduce disproportionate impacts in overburdened communities (e.g. the operation of high emission power generation facilities result in significant health concerns for neighboring communities)
    - Consider means for increasing access to energy efficiency, solar, and community distributed generation projects to specifically assist disadvantaged communities
    - The siting of renewable projects and their potential impact on local communities both in the short and long term, particularly in rural areas
    - The impacts on communities (e.g. jobs, revenues, etc.) where energy facilities are being retired

The operation of high emission power generation facilities refers to peaking power plants which has become a rallying topic for environmental justice advocates. Its inclusion confirms my suspicions that panel members need to be provided background information because there are some basic misunderstandings. I prepared and submitted a comment to powergenpanel@dps.ny.gov explaining that the presumption that these peaker plants are contributing to local health impacts because of ozone and particulate matter impacts is simply a wrong premise. I described another problem in another comment that explained that there is a mis-understanding which New York City power plants are for peaking purposes and which ones are used for other services.

Considering means to increase energy efficiency, solar, and community distributed generation projects to specifically assist disadvantaged communities is also problematic. This is a power generation strategy so energy efficiency is a different panel’s concern. In my opinion if this is included then this approach for peaking power should have been a stand-alone strategy. The rationale is to provide equity but in order to do that there are technological challenges that have to be addressed. There are so many challenges that it deserves its own focus but the naïve under-estimation of the challenges emphasized the goal itself over the implementation effort needed. The remaining two equity concerns are non-controversial and could have been easily incorporated into other implementation strategies as necessary.

The second strategy is “Access and Affordability for all (Enabling) –Develop recommendations to ensure New Yorkers have access and can afford to participate meaningfully in NYS’s clean energy future”. Inherent in this strategy is the belief that people want to be able to access clean energy presumably by participating in a community project if they cannot install solar panels at home. Forgotten is the fact that ratepayers have had the opportunity to purchase “green” energy for years but that subscription to those offerings has always been low. Overlooked is the fact that if participating means lower prices for participation in specific programs it also means that everyone not participating in those kinds of programs is footing the bill for everyone who does. As long as there are any people with already unacceptable energy burdens this strategy may do more harm than good.

The final strategy from this subgroup is “Workforce Development (Enabling) –Develop recommendations to enable an equitable clean energy workforce”. Again, this clearly is more appropriate as an equity concern in implementing strategies rather than as a stand-alone strategy.

The Barriers sub-group presented two strategies both of which should get higher priority than suggested by the presentation:

- - - Clean Energy Siting
    - Energy Delivery & Hosting Capacity

Because the primary decarbonization strategy is electrification, clean energy siting is a primary consideration. This sub-group listed eight issues to explore:

- - - Optimizing new transmission builds
    - Collocated storage with renewable energy projects
    - Correctly designing clear and transparent price signals for both energy and interconnection costs
    - How to properly track progress and make course corrections as process progresses
    - Provide standardized property tax assessments for renewable projects
    - Encouraging more robust host community and PILOT plans to increase benefits for community members
    - Explore reducing timeframe and restrictions for siting on brownfields and unused industrial land
    - Siting projects closer to end user areas

The first four issues are fundamental implementation issues. Because wind and solar energy is diffuse, transmission has to be developed to get it where it is needed. Because wind and solar energy is intermittent, it is not dispatchable and energy storage is needed to get it when it is needed. New York’s electricity system is de-regulated so the market will dictate whether these resources are developed. The ambitious schedule of the CLCPA targets means that tracking progress is a fundamental requirement to achieve those targets. I agree with them all. The remaining four issues are less important because they address comparatively minor implementation concerns.

Energy delivery and hosting capacity is another primary consideration. The sub-group listed six issues to consider:

- - - Upgrading aging infrastructure and optimizing the location and operation of new transmission projects, including transmission of off-shore wind, and removing regulatory barriers that make optimization difficult
    - Upgrading the transmission system to be able to host more distributed energy resources
    - Easing interconnections on both the bulk and distribution levels
    - Energy delivery extends beyond transmission to include storage, especially as the saturation of intermittent resources increases
    - How should the economic tradeoff between new transmission, energy curtailment, and energy storage be considered
    - How to properly track progress and make course corrections as needed

All of these are fundamental consideration issues. There is one glaring omission however. Wind and solar energy produce asynchronous generation but the transmission grid is synchronous. The need for ancillary services to provide that support must be included.

Solutions for the future addresses the fact that implementation of the CLCPA targets is pushing the limits of technological capabilities. Unfortunately I believe that is contrary to the presumption of many that meeting the goals is only a matter of political will. Two issues were raised:

- - - Technology and Research Needs
    - Market Solutions –Maximize the market participation of different technologies in a way that adds to system efficiency & send correct price signals to resources over time

The rational for technology and research noted that:

- - - Adoption of new technology to enable CLCPA goals must be integrated with more traditional investments for continued safe and reliable operation of the grid
    - Timeframes for adoption of new technology on the electric grid must be accelerated from the typical timeline of 5+ years from initial commercial product availability to deployment at scale

Unfortunately, reality as expressed as a potential implementation challenge is that “demonstration and validation of technology frequently requires large scale projects in real world use cases that are both costly and require coordination of many entities.” Clearly there is need for a feasibility study to determine what can be counted on from existing technology and what new technology is needed either for feasibility or affordability. Last year the International Energy Agency (IEA) published “Special Report on Clean Energy Innovation” that concludes that innovation is necessary for jurisdictions to fulfill their de-carbonization targets. The Energy Transition Plan Clean Energy Technology Guide summarizes 400 component technologies and identifies their stage of readiness for the market. It should be used in a feasibility study to rate the potential availability of any technology proposed.

The other issue of market solutions should be a big concern. New York’s electricity system is de-regulated so the market is expected to provide the necessary resources. However, uncertainty is a problematic issue with investors. As a result, new technology may require guarantees for market investors to provide the support that market advocates believe will appear.

The resource mix subgroup presented three strategies:

- - - Growth of renewable generation and Energy Efficiency
    - Effectively Transitioning away from Fossil Fuel Energy Generation
    - Deploying Energy Storage and Distributed Energy Resources (DERs)

The rational for the first strategy sums up the basis for my concerns very well:

“The CLCPA requires 70% renewable electricity by 2030 and 100% carbon free electricity by 2040. We anticipate demand growth of 65% to 80%, dependent on the scale and timing of electrification and whether there are clean alternatives for transportation and buildings, such as bioenergy. The level of electrification needed to achieve GHG reduction goals will increase overall electric load and shift the system peak from summer to winter. There remains a large amount of renewables that must be procured and developed to reach the goals and NYS needs to incorporate flexibility and controllability as we electrify these sectors in order to create a more manageable system.”

As noted before, a feasibility study for the technology is needed. A primary prerequisite is an official estimate of the projected loads when other sectors are electrified. However, I have an even more basic feasibility concern. As a party to the Department of Public Services (DPS) resource adequacy matters proceeding, docket Case 19-E-0530, I have submitted comments (described here and here) based on my background as a meteorologist who has lived in and studied the lake-effect weather region of Central New York. Both E3 and the Analysis Group have done studies of the weather conditions that affect solar and wind resource availability in New York. However, to my knowledge (neither consultant has ever responded to my question on this topic), they have not considered the joint frequency distribution of wind and solar or used solar irradiance data from the NYS Mesonet. In my opinion, both parameters have to be considered together and using airport data or models for cloud cover are inadequate. The Mesonet data set is the only way to have information that adequately represents the local variations in cloud cover caused by the Great Lakes. In order to adequately determine the combined availability of wind and solar I recommend using that data set for the renewable resource availability feasibility study.

The second strategy, “Effectively Transitioning away from Fossil Fuel Energy Generation” could be used as the outline for all the strategies of the panel. The rationale states: “As renewable penetration increases, how do we transition away from fossil fuels while maintaining reliability and safety standards?” The normal convention for priority ranking is to put the most important issues first in the presentation. It is discomforting that this is placed ninth of the ten strategies. It brings up the question just what are the priorities of this panel if reliability and safety concerns are ranked so low?

The final strategy from this workgroup was “Deploying Energy Storage and Distributed Energy Resources (DERs)”. In my opinion, there was insufficient emphasis on technological feasibility in the discussion of energy storage in this strategy. As mentioned earlier, a major shortcoming in these strategies is the lack of any mention of the need for transmission ancillary services. There is recognition that long duration storage will be needed but the fact that the few large battery systems currently deployed are being used for ancillary services and not storage is an obvious barrier that has not been included. Another concern I have with this strategy is that the definition of DER has changed to exclude distributed generation using fossil fuels. Has anyone thought to ask the hospitals with DER systems whether they can put up with the limitations of renewable DERS for their obviously critical need for constant electric power? An ice storm that knocks power off for days will quickly over-tax the capabilities of any renewable and energy storage system to keep a hospital running.

Missing Points

I have mentioned previously that the major missing point in these strategies is that ancillary services are not mentioned. Someone, somewhere has to address the frequency control and reactive power needs of the grid. Obviously, that has to be included in the strategies. It goes beyond simply adding it to a strategy because it is not clear how those services can be incorporated into the market signal to provide them. For example, there are advocates for a carbon price on electricity generation. In this approach any generator that emits CO2 will have to include a carbon price in their bid which serves to provide the non-emitting generators with more revenue. However, solar and wind generators are not paying the full cost to get the power from the generator to consumers when and where it is needed. Because solar and wind are intermittent, as renewables become a larger share of electric production energy storage now provided by traditional generating sources will be needed but there is no carbon price revenue stream for that resource. Because solar and wind are diffuse, transmission resources are needed but solar and wind do not directly provide grid services like traditional electric generating stations. Energy storage systems could provide that support but they are not subsidized by the increased cost to emitting generators. When the carbon pricing proposal simply increases the cost of the energy generated, I think that approach will lead to cost shifting where the total costs of fossil fuel alternatives have to be directly or indirectly subsidized by the public. This result is not in the best interests of low-income ratepayers.

Funding and affordability considerations received short shrift from this panel. In light of the fact that the New York Independent System Operator has proposed a carbon pricing initiative for the electric sector it would seem that a strategy to address that approach or something else should be included. There is another aspect of affordability that should also be addressed. The Department of Environmental Conservation recently released its guidance on the value of carbon. Because the electric sector has documented control costs, this panel should include a strategy to determine if the marginal abatement cost approach should be used for recommendations to the Climate Action Council.

Conclusion

This was the only panel that included specific strategies to address environmental justice concerns. All the other panels incorporated those concerns within their strategies and it would have been appropriate to do the same here. It appears that the idealogues on this panel are more concerned about those concerns than affordability and reliability. In my opinion those should be the primary concerns of this panel because those factors will impact the disadvantaged people of New York the most.

Because of the importance of power generation to the electrification needed to reduce GHG emissions in all sectors, this panel should focus its attention on the challenges of a transition to an electric system that is dependent upon wind and solar resources. I recommend that strategies include a feasibility study of technology needed for the transition, a resource availability study and a cumulative environmental impact analysis. Until this feasibility studies are complete any strategies are simply guessing and the absence of a cumulative environmental impact assessment could mean that the impacts from the cure are worse than impacts from the disease.

Climate Leadership and Community Protection Act Energy Efficiency and Housing Advisory Panel Strategy Comments

The Climate Leadership and Community Protection Act (CLCPA) became effective on January 1, 2020 and establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency. The law mandated the formation of the Climate Action Council to prepare a scoping plan to outline strategies to meet the targets. This is one of a series of posts describing aspects of that process. This post is my reaction to the Energy Efficiency and Housing Advisory Panel’s initial strategies.

General Comments

I believe that the primary consideration of any implementation strategy should be affordability and reliability for the energy system of New York. Energy use is largely inelastic so increased energy costs are hidden regressive taxes. Our society needs dependable energy so current reliability standards must be maintained. In general, each strategy must address potential costs and who would pay, whether there are co-benefits that would offset costs, any impacts on energy reliability, the feasibility of the proposed action, and the GHG reduction potential.

I believe that the CLCPA implementation strategies should consider cumulative environmental impacts of the renewable energy development proposed. As far as I can tell the only related environmental impact analysis was the Department of Public Service (DPS) Final Generic Environmental Impact Statement and the Final Supplemental Environmental Impact Statement for CASE 14-M-0101 – Reforming the Energy Vision and six other cases. The supplemental impact statement evaluated the potential environmental impacts of the Clean Energy Standard mandating that 50% of all electricity consumed in New York by 2030 be supplied by renewable resources. Of course, the CLCPA upped the ante and now 60% of all electricity of all electricity must be supplied by renewable resources by 2030. The important point is that the amounts and types of new renewable generation that may be needed to meet the CLCPA goals are much larger than anything evaluated by the State to date. The supplemental impact statement evaluated a base case large scale renewable on-shore wind increment of approximately 29,000 GWh (9,508 MW) and a high-end case of approximately 40,000 GWh (14,504 MW) of large-scale on-shore wind energy would be necessary to meet the goal. The Analysis Group “Climate Change Impact Phase II – An Assessment of Climate Change Impacts on Power System Reliability in New York State” draft final report released in October 2020 projected that New York would have to develop all of the projected National Renewable Energy Lab’s technical potential on-shore wind capability of 35,200 MW – three times what has been evaluated. Similarly, no one has evaluated the environmental impact of the latest estimates of utility-scale solar and off-shore wind.

I have a general concern about the CLCPA mandates for investments. It is entirely appropriate that there should be an emphasis on environmental and social justice but I have concerns about the State’s approach. Given that all other jurisdictions that have attempted to reduce GHG emissions have increased the cost of energy, it is likely that will be the case in New York too. I think strategies have to consider cost-effectiveness to reduce the regressive impact on those who can least afford those increased costs, regardless of location, who are living in energy poverty or already have a disproportionate energy burden. This means that strategies that do not reduce costs or have low GHG reduction potential should be ranked very low for future consideration.

Comments on Proposed Strategies

The Energy Efficiency and Housing Advisory Panel had 16 strategies in five scoping categories.

The first scope was titled as “Mandates that require energy efficiency improvements and on-site emissions in building and appliance with dates as market signal” and included two strategies:

- - Expand State energy & building codes (with date signals) to drive the transition to electrification & building efficiency and
  - Modify State Appliance Standards (for example, ban fossil fuel appliances sales and installations). Consider building performance standards for large buildings to meet 2050 and interim targets with a focus on onsite emissions.

I don’t think the public is going to be willing to make the sacrifices called for in these strategies. It would be best for all concerned to get out there with publicity now to gauge acceptability. There are all sorts of issues. For starters, how will house trailers be considered. For the rural poor this is often all they can afford and it is simply not possible to improve energy efficiency much. There also is an implementation issue associated with housing sector date-certain efficiency standards. What happens to someone trying to sell an old house after the certain date. Presumably, they will be on the hook to spend whatever is needed to get up to the efficiency standard to be able to sell and that means losing a big chunk of equity in their home or the house is priced out of the market and they cannot sell the house.

Three strategies were listed in the “Financing and incentives for building efficiency and electrification at scale” scope:

- - - Inducing market/behavioral change (e.g., taxes, registration fees, carbon levies) that incentivize market providers (owners, developers, lenders etc.) and residents to reduce emissions and transition to electrification;
    - Shift lenders to quantify energy efficiency in single/multifamily/commercial (e.g. underwriting to savings); and
    - Financial incentives for owners, developers and residents (e.g. cash incentives, pay as you save, low-interest financing, more agile of existing programs to get to 2050 and interim targets, etc.), with emphasis on low and middle income owners.

The biggest hurdle for these strategies is cost. In many instances the capital cost of the electric option is more expensive than the fossil fuel option. Moreover, I see absolutely no reason to expect that the cost of electricity will go down because that has not been the case in any jurisdiction that has attempted to meet GHG reduction targets. I also have reservations about taxes, registration fees or carbon levies and the proposed emphasis on disadvantaged communities. In the first place the requirement for targeted investment benefits may have the perverse effect of increasing the overall cost of energy because those investments may not be the most cost-effective approaches to reducing CO2 emissions. If that is the case then anyone who is not a direct beneficiary of financial incentive benefits is going to be hurt. The Climate Action Council needs to track energy poverty or energy burden and the effect of these policies on those who can least afford additional energy costs so that no one (whether or not they are in a dis-advantaged community) is literally left out in the cold.

The third scope was called “Training and education of building decarbonization to improve behavior and operations for health and comfort and build workforce (enabling strategy)”. Three strategies were included:

- - - Workforce development to provide skilled professionals to design, build, operate, & enforce decarbonized building stock;
    - Education -owners, developers, design professionals and other stakeholders: resources on capital planning, all-electric buildings, electrification-ready, etc. Mandatory energy performance disclosures and building consumption data (public facing); certified product declarations for materials/equipment; and
    - Education-residents/businesses: performance, economics., environmental quality, operation and maintenance for low-carbon technologies.

Clearly, we need to train professionals to design, build, and operate the decarbonized building stock but what is the meaning of enforce decarbonized building stock? When proposing building decarbonization strategies you have to prove that decarbonization will be affordable, maintain current levels of reliability, not lead to unintended environmental consequences that exceed the alleged impacts of climate change in New York, and actually have some sort of quantifiable effect on climate change.

The “Technology innovation and demonstration to drive better performance, reduce costs, and increase customer confidence” scope had four strategies:

- - Research and development to improve cost/performance of solutions for all-electric buildings (e.g., cold climate heat pumps, geothermal, etc.);
  - Research, development, and demonstration for hard-to-electrify buildings (e.g., on district steam, steam-heated, hydronic distribution) and advance scalable solutions and potential cost reductions (e.g., community geothermal, industrialized fabric/modular, virtual tools);
  - De-risking demonstrations to help critical customer groups who may lack access to resources and information (e.g., coops/condos); and
  - Approaches to reducing embodied carbon (e.g., new tech to reduce GHG emissions from materials/construction/transportation).

The American Council for an Energy-Efficient Economy published a paper that raises issues with air source heat pumps: Field Assessment of Cold Climate Air Source Heat Pumps. The 2016 report describes a Center for Energy and Environment field study in Minnesota where cold climate air source heat pumps (ccASHPs ) were directly compared to propane and heating oil furnaces. The study found these systems have the greatest potential for adoption in cold-climate regions where natural gas is not available for space heating; ccASHPs can offset the use of more expensive delivered fuels, and for homes with electric resistance heat, can result in a significant reduction in electrical use; that it is feasible for a utility energy efficiency program to receive credit for the energy savings achieved from ccASHPs through the reduction in fuel oil and propane; and that during periods of very cold temperatures when ccASHPS do not have adequate capacity to meet heating load, a furnace or electric resistant heat can be used as backup. These conclusions are not compatible with the CLCPA targets.

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

The strategies proposed by this Advisory Panel are appropriate but the details should make it clear that a similar study in New York on the latest air source heat pumps is required. That should be coupled with an assessment of the renewable energy resources. It is not clear to me that it is possible to meet the multi-day winter doldrum period while relying on wind and solar. Analysis of the data shows that no amount of over-building solves this problem. Extraordinary amounts of storage are needed. In order to determine just how much of energy storage will be required much better estimates of the load expected for electrifying homes and transportation are needed.

The final scope “Resilience and climate adaptation strategies for all-electric building, hazard mitigation planning and building retrofits” had four strategies.

- - Supporting/coordinating improved resiliency solutions for all-electric building & resilient spaces for vulnerable pops.;
  - Grid and transmission resilience and independence;
  - Electrification paired with supplemental heating sources;
  - Improving building stock to withstand the impacts of climate change.

Resiliency is a buzz word employed to suggest that these policies will be improvements to systems so that they can better recover from difficult events. What are the resiliency solutions for all-electric buildings when there is an ice storm? According to Wikipedia (https://en.wikipedia.org/wiki/January_1998_North_American_ice_storm): “The North American Ice Storm of 1998 (also known as Great Ice Storm of 1998) was a massive combination of five smaller successive ice storms in January 1998 that struck a relatively narrow swath of land from eastern Ontario to southern Quebec, New Brunswick and Nova Scotia in Canada, and bordering areas from northern New York to central Maine in the United States. It caused massive damage to trees and electrical infrastructure all over the area, leading to widespread long-term power outages. Millions were left in the dark for periods varying from days to several weeks, and in some instances, months. The only way those people survived is because they had alternatives to electricity. When electricity is the only option available then what?

Conclusion

I maintain that the fundamental problem with the CLCPA is the lack of a feasibility study. It is not clear to me that the ultimate problem of trying to supply the energy needs of a mostly electrified New York electric energy system will work during a multi-day winter doldrum if the primary sources of electricity are wind and solar. The only way this might work will require extraordinary amounts of energy storage, wind, and solar development. When there is an “official” estimate of those resources clearly a cumulative environmental impact analysis for those resources should be completed as soon as possible.

From what I have heard the consensus opinion on the advisory panels is that air source heat pumps are an unqualified solution to residential heating. The Minnesota field study suggests otherwise. It would be appropriate for the panel to include a strategy for New York to replicate that study to prove that this solution will work here. In addition, a strategy to assess the potential impacts to society when the inevitable next severe ice storm occurs should be included.

Climate Leadership and Community Protection Act CLCPA Agriculture and Forestry Advisory Panel Strategies Comments

The Climate Leadership and Community Protection Act (CLCPA) became effective on January 1, 2020 and establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency. The law mandated the formation of the Climate Action Council to prepare a scoping plan to outline strategies to meet the targets. This is one of a series of posts describing aspects of that process. This post is my reaction to the Agriculture and Forestry Advisory Panel’s initial strategies.

Background

I have described the implementation requirements in a stand-alone document. In brief, The CLCPA mandates that a scoping plan outlining the recommendations for attaining the statewide greenhouse gas emissions shall be prepared and approved by December 31, 2021. The Climate Action Council and seven advisory panels, transportation, energy intensive and trade-exposed industries, land-use and local government, energy efficiency and housing, power generation, waste, and agriculture and forestry consisting of political appointees and supported by agency staff are charged with this responsibility. Since the formation of the panels in the middle of 2020 they have been holding meetings and preparing strategies. Each advisory panel is expected to “Identify a range of emissions reductions, consistent with analysis and in consultation with the Climate Action Council, for the sector which contributes to meeting the statewide emission limits.” They have been asked to present a list of recommendations for emissions reducing policies, programs or actions, for consideration by the Climate Action Council for inclusion in the Scoping Plan and to seek public input to inform the development of recommendations to the Council for consideration. This post describes the comments that I plan to submit as part of that public process.

General Comments

There are major potential land use and environmental impact ramifications of the CLCPA on agriculture and forest lands. I believe it is necessary to do a cumulative environmental impact assessment of the Scoping Plan’s projections for wind and solar development and I strongly recommend that this panel work with the land use panel to take the lead in developing a strategy to evaluate those impacts.

At the end of September 2020 the Department of Public Service released the Final Supplemental Generic Environmental Impact Statement on the proposed Climate Leadership and Community Protection Act (“CLCPA SGEIS”). Unfortunately, that analysis only evaluated the 70% reduction by 2030 target and did not even use the latest estimates for the wind and solar developments for that target. Based on the projections by E3 in their presentation to the Power Generation Advisory Panel on September 16, 2020 and the Analysis Group September 10, 2020 presentation of draft recent observations as part of the New York Independent System Operator (NYISO) Climate Change Phase II Study significantly more wind and solar will be required than was analyzed in the CLCPA SGEIS process. Because the capacity estimates from these analyses and others are so much larger than the latest CLCPA SGEIS estimate I believe that another environmental impact analysis is needed when the Climate Action Council finalizes its Scoping Plan.

I extrapolated results from several projects to estimate the potential cumulative impacts for the extraordinary buildout of wind generation projected by the Analysis Group – 35,200 MW compared to 5,905 MW in the last DPS impact statement that evaluated wind energy cumulative impacts. If all the wind projects are built on agricultural land, then between 12% and 56% of the agricultural lands will be covered with wind turbines. Of course, it is more likely that wind turbines will be sited on ridge lines but that will affect forest land use. Nonetheless that study also projected 39,262 MW of utility scale solar that will have to go somewhere. It is not just land use that will be affected. The environmental impacts of this much wind generation could cause the deaths of between 91 and 804 bald eagles a year.

I recommend that the Agriculture and Forestry Advisory Panel develop a strategy that includes preparations for the cumulative analysis of the Scoping Plan recommended wind and solar development. That process should start soon and determine a threshold for unacceptable environmental impacts. For example, I am worried about eagles. If you had told me 30 years ago that I would ever see a Bald Eagle from my home I would have been doubtful. Now that has occurred and I am not willing to risk that environmental victory for the CLCPA goals. Because there are a limited number of eagles and their reproduction rates are low, I imagine that wildlife biologists could develop a criterion on the acceptable annual rate of state-wide eagle deaths from wind turbines. There were 426 occupied bald eagle nest sites in New York in 2017. It is obvious that a more detailed projection of wind turbine impacts on this rare resource is needed. The ultimate goal should be to refine the NYSERDA wind power and biodiversity habitat sensitivity maps for the CLCPA resource development planning and siting process.

Comments on Proposed Strategies

The Agriculture and Forestry advisory panel presented 12 strategies in six categories. It is particularly relevant that the cumulative environmental impacts of all the large-scale renewable energy projects on land use be addressed by this panel.

There were two strategies in the livestock/dairy management category: alternative manure management and precision feed management. It is not clear to me why these strategies to reduce methane from manure are included because § 75-0109, (2) (b) states “Include legally enforceable emissions limits, performance standards, or measures or other requirements to control emissions from greenhouse gas emission sources, with the exception of agricultural emissions from livestock.” What is the point of alternative manure management if livestock emissions are exempt? At the very least accounting for livestock emissions is going to be complicated. If there are no enforceable emissions limits then should the emissions be included in the inventories?

It appears to me that the strategies in the soil health and nutrient management, nutrient (fertilizer) management and soil carbon sequestration, and agroforestry, silvopasture, alley cropping, and riparian forest buffers, categories are consistent with § 75-0103 (13) (d) “Measures to achieve long-term carbon sequestration and/or promote best management practices in land use, agriculture and forestry”.

I agree that the land conversions category strategies of agricultural protection and access and no net loss of forestland are important and should be included. However, the CLCPA electric sector targets are going to require enormous amounts of solar and wind energy development. This factor has to be addressed and it was over-looked in the mitigation strategy slides. The Agriculture and Forestry and Power Generation Advisory Panels must determine how much agricultural land and forests will be taken out of production for solar and wind development sprawl

There were four forestry strategies: urban forestry, statewide afforestation/reforestation efforts, improved forest management, and increase manufacture and use of harvested wood products, and a strategy to support opportunities to substitute fossil fuels in the bioeconomy category. I have one overall observation for these strategies. I believe that the increased costs of energy induced by the CLCPA and the desire to backup electric heating is going to put a lot of pressure on forests as more people turn to wood-fired heating. The mitigation strategy slides did not mention this issue and I think this Advisory Panel should address it.

Conclusion

I maintain that the fundamental problem with the CLCPA is the lack of a feasibility study. It is not clear to me that the ultimate problem of trying to supply the energy needs of a mostly electrified New York electric energy system will work during a multi-day winter doldrum if the primary sources of electricity are wind and solar. The only way this might work will require extraordinary amounts of wind and solar development. When there is an “official” estimate of those resources clearly a cumulative environmental impact analysis for those resources should be completed as soon as possible. This panel and the land use panel are in the best position to develop a strategy to address this problem.

Climate Leadership and Community Protection Act Con Ed Peaking Power Plant Solution

On January 11, 2021 the Climate Leadership and Community Protection Act Power (CLCPA) Generation Advisory Panel met as part of the Climate Action Council Scoping Plan development process. The meeting tested a consensus building process to address the “problem” of peaking power plants. I recently published a post on that issue. It has come to my attention that Consolidated Edison recently submitted a petition to the New York Department of Public Service (DPS) proposing a solution to the peaking power plant problem. This post describes that solution relative to the CLCPA.

On July 18, 2019 New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act, which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency. I have written extensively on implementation of the CLCPA closely because its implementation affects my future as a New Yorker. I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulations, listed the scoping plan strategies, summarized some of the meetings and complained that its advocates constantly confuse weather and climate. The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

As described in my previous post, peaking power plants are used to ensure that there is sufficient electricity at the time it is needed most. The problem is that the hot, humid periods that create the need for the most power also are conducive to the formation of ozone. In order to meet this reliability requirement ~ 100 simple cycle turbines were built in New York City in the early 1970’s that were cheap and functional but, compared to today’s standards, emitted higher levels of nitrogen oxides that are a precursor to ozone. In 2020 the Department of Environmental Conservation promulgated a new regulation that will result in the retirement of these simple-cycle combustion turbines presently used exclusively for peaking power uses in order to address ozone nonattainment.

On December 30, 2020 Consolidated Edison (Con Ed) submitted a petition for “approval to recover costs of certain transmission reliability and clean energy projects” as part of DPS Case 19-E-0065 as part of their currently effective rate plan. They propose three transmission reliability and clean energy projects that will address reliability issues associated with DEC’s new regulation affecting these peaking units.

Concerns

The biggest CLCPA Power Generation Advisory Panel problem with the Con Ed solution is that it only addresses the simple-cycle combustion turbines used for peaking services. The environmental justice community and some members on the Advisory Panel use a more expansive definition of peaking power plants including generating units that are not covered by this proposal. In the Physicians, Scientists, and Engineers (PSE) for Healthy Energy report Opportunities for Replacing Peaker Plants with Energy Storage in New York State peaking power plants are defined based on the following criteria: fuel type: oil & natural gas; Capacity: ≥ 5 MW; capacity factor: ≤15% (3-yr. avg.); unit technology type: simple cycle combustion turbine, steam turbine & internal combustion; application: entire peaker plants & peaking units at larger plants; and status: existing and proposed units. This definition of peaking units includes boilers used for electric power, boilers used for steam, and recently built combined cycle combustion turbines as well as the 100 or so peaking turbines that industry considers peaking units. The Peak Coalition definition includes units that do not necessarily exist solely to address peak load problems but also have other uses.

In October 2020, The New York Power Authority (NYPA) and the PEAK Coalition “unveiled an agreement to assess how NYPA can transition its natural gas fired ‘peaker’ plants, six located in New York City and one on Long Island with a total capacity of 461 megawatts, to utilize clean energy technologies, such as battery storage and low to zero carbon emission resources and technologies, while continuing to meet the unique electricity reliability and resiliency requirements of New York City”. As far as I can tell, the Con Ed transmission projects will not address the NYPA combined cycle combustion turbines. Also note that the Con Ed Petition specifically dismissed the clean energy technologies in the NYPA agreement:

“The Company also evaluated whether non-wires solutions, load reductions and/or load transfers, renewable resource or energy storage deployment within the Transmission Load Area (TLA), local transmission additions, or a combination of these solutions, could address both the local reliability need and the constraints. The Company determined that only the Transmission Reliability and Clean Energy (TRACE) projects would both solve the local system reliability needs and alleviate transmission system constraints to enable the State to achieve its clean energy goals. Specifically, physical space limitations within the TLAs challenge or virtually foreclose the addition of utility scale photovoltaic (“PV”) and large-scale energy storage systems there. And, as described below, storage within the TLA can only partially address reliability needs because the TLA deficiencies, which extend over 10 to 14-hour periods often over consecutive days, exceed the capability of storage technologies to respond.”

It may be that the physical space limitations may differ near the NYPA turbines but we are dealing with New York City which is notorious for limited space.

There is another aspect that I know exists but don’t have sufficient knowledge to address in this context. The power still has to come from somewhere. There are specific requirements for in-city generation that were developed to address previous blackouts in New York City. I am not sure how those requirements will be satisfied within the constraints of the CLCPA.

The Con Ed petition claims that their projects are necessary to “facilitate achievement of the State’s clean energy goals as defined in the CLCPA” by enabling retirement of the peaking power plants and solving the associated reliability needs without the addition of any new fossil-fired power plants. Note however that the proposed cost of these projects is $780 million and only provides delivery of the power not replacement power production.

Conclusion

I agree with the Con Ed petition’s claim that the three transmission projects are “multi-value, ‘no regrets’ solutions”. Not only do they “provide critical reliability contributions that require their construction to meet established reliability design criteria, but also put in place the necessary foundation to achieve the CLCPA’s goals.” Unfortunately, the public will never know the comparative cost of this CLCPA-consistent solution relative to an alternative solution that used fossil fuels. As a result there will be a hidden CLCPA cost.

The bigger problem is the ramifications relative to the environmental justice advocates and their allies on the Power Generation advisory panel. In the first place, even though Con Ed’s solution checks all the CLCPA technology boxes it only addresses the facilities that have generally been considered “peakers”, not the facilities that the Peak Coalition considers “peakers”. Secondly, Con Ed considered and discarded as technically inappropriate, the alternatives that the Peak Coalition is advocating for the NYPA peaking turbines. Those turbines provide peaking services but they also are clean and efficient. It boils down to whether the environmental justice advocates can accept minimal risks from those facilities or will only be satisfied if there is zero risk from their pre-conceived notion of the problem. I am not comfortable that they understand the trade-offs of different risks from different options.

Climate Leadership and Community Protection Act Energy-Intensive and Trade-Exposed Industries Advisory Panel Strategies Comments

The Climate Leadership and Community Protection Act (CLCPA) became effective on January 1, 2020 and establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency. The law mandated the formation of the Climate Action Council to prepare a scoping plan to outline strategies to meet the targets. This is one of a series of posts describing aspects of that process. This post is my reaction to the Energy-Intensive and Trade-Exposed Industries Advisory Panel’s initial strategies.

Background

Comments

I am not sure what to make of this panel’s charge. Industrial sectors within EITE panel scope include manufacturing, mining, and construction and only total ~7% of State emissions. The types of companies included in these sectors are vastly different so will likely require many different technologies to reduce emissions. They also compete not only with similar companies within New York but also with companies outside the state and country. Energy costs for any company in New York will surely increase as the decarbonization of the energy industry ratchets down emissions, they are being asked to also decrease their emissions with immature and potentially infeasible technologies, and they have to compete with companies unfettered by those constraints. The panel has a Sisyphean task trying to offer any viable strategy.

The Panel has proposed 12 strategies in six topics.

The first scope topic is “Provide financial incentives and technical assistance for the decarbonization of the EITE sectors”. It proposes four strategies:

- - Provide technical assistance to help identify economically viable decarbonization pathways and to provide comprehensive energy management planning;
  - Provide financial incentives for decarbonization projects;
  - Refer economic assistance recipients to resources that will result in lower-emitting projects; and
  - Leverage low-cost hydropower to provide support for industry

Clearly if the State wants reductions from this sector it will need to provide assistance but there is no guarantee that there are solutions available for the challenge. The backup is payments to try to reduce costs. It is not clear where this money is going to come from given that every other strategy from every other panel also needs funding.

The panel proposes a strategy to “Create incentives for business to capitalize on low-carbon economy opportunities” that will create preferential standards for the public procurement of low-carbon building materials. If a preferential standard is needed to drive the use of low-carbon building materials it means that alternative is more expensive. That makes it a hidden tax of the program and another instance of increased costs that someone will have to pay.

The third scope topic “Identify and support technological innovations to enable deep industrial decarbonization” proposes four strategies:

- - Develop a comprehensive Innovation Roadmap to address knowledge gaps and to guide key priorities for deep decarbonization investment in the areas of carbon-tech, low-carbon fuels, and carbon removal;
  - R&D funding for early stage decarbonization technologies;
  - Demonstration pilot funding for high impact solutions in coordination with private market; and
  - Identify potential for innovation clusters to leverage supply chains and infrastructure for novel solutions

These are all necessary strategies. However, it is not clear how the panel will integrate them into recommendations for the Climate Action Council. At some point the Council will need to recommend specific plans to achieve specific reductions to meet the CLCPA targets and these strategies only can offer the hope that someday, something will be available to meet some unspecified reduction.

There is the obligatory strategy for workforce development training that will provide workforce development on existing and new innovative emission reduction technologies that affect EITE industries. This presumes that there actually be solutions that reduce emissions that keep New York manufacturing, mining, and construction competitive.

There is a strategy to “Increase the available data on industrial GHG emissions to help prioritize efforts and monitor progress” which would require additional industrial facilities to report their GHG emissions. This should be limited only to companies that actually produce GHG emissions. Any company that runs a generator should only be required to provide fuel use information.

The final strategy is to “provide economic incentives to grow the green economy” by leveraging “the State’s climate policies to develop an in-state supply chain of green economy companies by engaging in business development discussions and offering incentives through programs such as NYSTAR, NY Ventures and Excelsior Tax Credits”. Again, this means more and more competing for funds from as yet unidentified sources.

Conclusion

As part of a CLCPA mandate to evaluate the impact to energy-intensive and trade-exposed industries, this panel has gone through the motions attempting to address concerns that are likely irreconcilable. In today’s global economy New York’s industrial sector has to compete not only within this country but everywhere else too. The inevitable extra costs of energy will make production more expensive and less competitive. The requirements to make GHG reductions in their industrial processes reduces competitiveness further.

Climate Leadership and Community Protection Act Power Generation Advisory Panel Peaking Power Plants

On July 18, 2019 New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act (CLCPA), which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency. I have written extensively on implementation of the CLCPA closely because its implementation affects my future as a New Yorker. I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulations, listed the scoping plan strategies, summarized some of the meetings and complained that its advocates constantly confuse weather and climate. The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

Last summer I wrote that New York State energy and environmental policy is more about optics than facts as exemplified by opinion pieces, reports, and even policy proposals related to peaking power plants in New York City. The perception that they have significant local impacts and have no use in the future has now invaded the CLCPA implementation process.

The optics post summarized three detailed technical posts all related to the PEAK Coalition report entitled: “Dirty Energy, Big Money”. The first post provided information on the primary air quality problem associated with these facilities, the organizations behind the report, the State’s response to date, the underlying issue of environmental justice and addressed the motivation for the analysis. The second post addressed the rationale and feasibility of the proposed plan relative to environmental effects, affordability, and reliability. Finally, I discussed the Physicians, Scientists, and Engineers (PSE) for Healthy Energy report Opportunities for Replacing Peaker Plants with Energy Storage in New York State that provided technical information used by the PEAK Coalition.

In brief, peaking power plants are used to ensure that there is sufficient electricity at the time it is needed most. The problem is that the hot, humid periods that create the need for the most power also are conducive to the formation of ozone. In order to meet this reliability requirement ~ 100 simple cycle turbines were built in New York City in the early 1970’s that were cheap and functional but, compared to today’s standards, emitted a lot of nitrogen oxides that are a precursor to ozone. The Peak Coalition report claims that peaking units operate when energy load spikes, are mostly old, and have high costs. However, they expand the definition of peaking units to just about every facility in the City including units that are new, have low emission rates, and have lower costs than claimed. Environmental Justice advocates claim that the expanded definition peaking power plants are dangers to neighboring environmental justice communities. However, my analyses found that the alleged impacts of the existing peaking power plants over-estimate impact on local communities relative to other sources.

There is a category of existing simple cycle peaking turbines in New York City that are old, inefficient and much dirtier than a new facility and clearly should be replaced. However, they reliably produce affordable power when needed most. PSE and the PEAK Coalition advocate a solar plus energy storage approach and that has become the preferred approach of the majority of the Power Generation Advisory Panel members. It is not clear, however, if that is a viable option.

Peaking Power Plant Status

By definition, for EPA reporting purposes 40 CFR Part 75 §72.2, a combustion unit is a peaking unit if it has an average annual capacity factor of 10.0 percent or less over the past three years and an annual capacity factor of 20.0 percent or less in each of those three years. As noted previously the utility industry considers the combustion turbines built expressly for peak periods as the New York City peaking plants. PSE chose to select peaking power plants based on the following criteria: fuel type: oil & natural gas; Capacity: ≥ 5 MW; capacity factor: ≤15% (3-yr. avg.); unit technology type: simple cycle combustion turbine, steam turbine & internal combustion; application: entire peaker plants & peaking units at larger plants; and status: existing and proposed units.

There is another nuance to the peaking units story. Because the primary concern with the combustion turbines that run so little is ozone attainment, they only are required to report data during the Ozone Season (May 1 to September 30). The NYC Peaking Unit Annual Ozone Season Load graph shows the trend of the simple cycle combustion turbine peaking unit and the Peak Coalition peaking unit ozone season load. Since 2001, the simple cycle turbines load trend is down and in 2020 the ozone season total energy produced was only 8,155 MWh compared to a peak over this period of 897,939 MWh in 2005. On the other hand, the Peak Coalition peaking units have only been trending down since 2017. Over that short a period the effects of weather may be the primary driver of any load changes.

The New York City Ozone Season Trends table categorizes the units as simple cycle turbines (the industry “peakers”), all the other turbines, boilers that provide electricity and steam boilers that provide steam. In the last 20 years a number of combined cycle combustion turbines that are more efficient than the simple cycle turbines and the boilers. In 2020, that category provided the most energy of any of the units considered displacing most of the simple cycle turbine output and a big chunk of the boilers producing electricity. As shown in the table, in 2020 the “peakers” only generated 8,155 MWh and emitted 6,927 tons of CO2 and 28 tons of NOx. The combined cycle turbines produced 3,968,562 MWh, 1,772,752 tons of CO2 and 103 tons of NOx and the boilers produced 2,172,185 MWh in 2020, 1,654,514 tons of CO2 and 752 tons of NOx in the 2020 Ozone Season.

Alternatives

I don’t think that many of the members of the power generation advisory panel really understand the electric system. Although the simple cycle turbine peaking units have run less and less, completely eliminating them is still a significant undertaking. Nonetheless, last year the Department of Environmental Conservation promulgated a new regulation that will shut them down on a schedule based on complete assurance that equally reliable options are available. In order to eliminate the units in the Peak Coalition report is a much more difficult problem. Unfortunately, to the ill-informed it is a simply a matter of political will.

The apparent preferred option is to use energy storage ultimately powered using renewables. In December 2020, 74 Power Global and Con Edison announced the signing of a seven-year dispatch rights agreement for the development of a 100-megawatt battery storage project, the East River Energy Storage System, in Astoria, Queens. The NRG Astoria Gas Turbine facility presently consists of 24 16MW simple cycle turbines is also located at the same location. The East River Energy Storage System is rated to provide 4 hours at 100 MW capacity or 400 MWh. On the other hand, those 24 16MW turbines can run all day if the need arises to produce 9,216 MWh or 23 times more energy.

Unfortunately, that is not the end of the bad news for energy storage. Last year I estimated the energy storage requirements of the CLCPA based on a NREL report Life Prediction Model for Grid-Connected Li-ion Battery Energy Storage System that describes an analysis of the life expectancy of lithium-ion energy storage systems. The abstract of the report notes that “The lifetime of these batteries will vary depending on their thermal environment and how they are charged and discharged. To optimal utilization of a battery over its lifetime requires characterization of its performance degradation under different storage and cycling conditions.” The report concludes: “Without active thermal management, 7 years lifetime is possible provided the battery is cycled within a restricted 47% DOD operating range. With active thermal management, 10 years lifetime is possible provided the battery is cycled within a restricted 54% operating range.” If you use the 54% limit the 400 MWh of energy goes down to 216 MWh and the existing turbines can produce over 42 times as much energy in a day.

The mantra of the environmental justice advocates on the power generation advisory panel is that “smart planning” and renewables will be sufficient to replace fossil generation peaking plants. In the absence of what is exactly meant by “smart planning” I assume that it will be similar to the New York Power Authority agreement to “assess how NYPA can transition its natural gas fired ‘peaker’ plants, six located in New York City and one on Long Island with a total capacity of 461 megawatts, to utilize clean energy technologies, such as battery storage and low to zero carbon emission resources and technologies, while continuing to meet the unique electricity reliability and resiliency requirements of New York City.” Beyond the press release however, is a major technological challenge that if done wrong will threaten reliability.

Moreover, the costs for this technology seem to be an afterthought. The Energy Information Administration says the average utility scale battery system runs around $1.5 million per MWh of storage capacity. That works out to $600 million for the East River Energy Storage System. NYC currently peaks at around 13,000 MW– just to keep the city running. I get the impression that one aspect of “smart” planning is to shave peaks but the CLCPA targets will require electrification across all sectors. I don’t think that any peak shaving programs can do much to reduce the current summer peak and the peak will certainly shift to the winter when peak shaving and shifting of heating is unrealistic. Assuming the same peak level and that the daily total peak above the baseline requires 104,000 MWhr, that means that 481 East River Energy Storage Systems operating at the NREL 54% limit would be needed to cover the peak at a cost of $289 billion. Throw in the fact that the life expectancy is ten years and I submit this unaffordable.

NYC Solar

Even if you have enough energy storage, the mandates of the CLCPA require the use of solar and wind resources to provide that energy. There are specific in-city generation requirements for New York City that have been implemented to ensure there is no repeat of blackouts that were caused by issues with the transmission and generation system. It is not clear to me how this will be handled within the CLCPA construct but there is a clear need for in-city generation. Clearly massive wind turbines are a non-starter within NYC so that leaves solar. The problem is that a 1 MW solar PV power plant will require between 2.5 acres and 4 acres if all the space needed for accessories are required. Assuming that panels generate five times their capacity a day 43.2 MW of solar panels can generate the 216 MWh of energy available from the East River Energy Storage System and that means a solar array of between 108 and 173 acres. To get the 104,000 MWh needed for the entire NYC peak between 10 and 16 square miles of solar panels will be needed.

Public Policy Concerns

I have previously described how the precautionary principle is driving the CLCPA based on the work of David Zaruk, an EU risk and science communications specialist, and author of the Risk Monger blog. In a recent post, part of a series on the Western leadership’s response to the COVID-19 crisis, he described the current state of policy leadership that is apropos to this discussion:

“The world of governance has evolved in the last two decades, redefining its tools and responsibilities to focus more on administration and being functionary (and less on leadership and being visionary). I have written on how this evolution towards policy-making based on more public engagement, participation and consultation has actually led to a decline in dialogue and empowerment. What is even more disturbing is how this nanny state approach, where our authorities promise a population they will be kept 100% safe in a zero-risk biosphere, has created a docilian population completely unable and unprepared to protect themselves.”

His explanation that managing policy has become more about managing public expectations with consultations and citizen panels driving decisions describes the Advisory Panels to the Climate Action Council. He says now we have “millennial militants preaching purpose from the policy pulpit, listening to a closed group of activists and virtue signaling sustainability ideologues in narrowly restricted consultation channels”. That is exactly what is happening on this panel in particular. Facts and strategic vision were not core competences for the panel members. Instead of what they know, their membership was determined by who they know. The social justice concerns of many, including the most vocal, are more important than affordable and reliable power. The focus on the risks of environmental justice impacts from these power plants while ignoring the ramifications if peaking power is not reliably available when it is needed most does not consider that a blackout will most likely impact environmental justice communities the most.

Conclusion

There are significant implementation issues trying to meet the CLCPA mandates in New York City. Energy storage at the scale needed for any meaningful support to the NYC peak load problem has never been attempted. The in-city generation requirements have to be reconciled with what could actually be available from solar within the City. All indications are that the costs will be enormous. Importantly, I have only described the over-arching issues. I am sure that there are many more details to be

reconciled to make this viable and there are as yet unaddressed feasibility issues.

I have previously shown that the Peak Coalition analysis of peaking plants misses the point of peaking plants and their environmental impacts. The primary air quality health impacts are from ozone and inhalable particulates. Both are secondary pollutants that are not directly emitted by the peaking power plants so do not affect local communities as alleged. While nothing detracts from the need to retire the old, inefficient simple cycle turbines, replacing all the facilities targeted by the Peak Coalition is a mis-placed effort until replacement technologies that can maintain current levels of affordability and reliability are commercially available. At this time that is simply not the case.