Pragmatic Environmentalist of New York Summary Update November 4, 2024 – November 17, 2024
Four articles all document planning problems associated with NY's net-zero transition
This is my fortnightly summary update of recent posts at Pragmatic Environmentalist of New York. I have been writing about the pragmatic balance of the risks and benefits of environmental initiatives in New York since 2017 with a recent emphasis on New York’s Climate Leadership & Community Protection Act (Climate Act). A pdf copy of the following information and previous summaries are also available. The opinions expressed in these articles do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.
DPS Definitions for Establishment of a Renewable Energy Program
I believe that the biggest shortcoming of the Hochul Administration’s implementation of the Climate Act is the lack of a plan, and four articles addressed that concern. The first points out that a plan for the Climate Act would include things like fundamental definitions. Amazingly while there is a mandate that all electricity must be generated by “zero-emissions” resources by 2040, “zero emissions” hasn’t been defined until now. On November 4, 2024, the Department of Public Service (DPS) staff finally proposed this definition.
The Staff Proposal definition states: The Commission’s interpretation of this term will lay the foundation for decisions about planning, investments, and more in the run-up to 2040.” This is an admission that there is no foundation for the current planning process. Some of the aspects of the definition are more important than others. My post concentrated on the question whether non-greenhouse gas emissions were also required to be zero. Practically speaking the issue was related to the use of hydrogen which is the recommended zero-emissions fuel technology for hard to convert sectors and the place holder for the new Dispatchable Emissions-Free Resource (DEFR) that the Integration Analysis argues is necessary. Everyone agrees that compliant hydrogen should not be produced with fossil fuels, but the question was whether the hydrogen had to be used in fuel cells so that the only emission was water or whether it could be burned to produce energy. I am sure that the ideologues are having fits over the proposed definition:
Staff recommends that the Commission interpret “zero emissions” to refer to greenhouse gases only and not to emissions of other air pollutants.
In my opinion the support cited for this interpretation was strong and I think that it is a pragmatic approach. It will be hard enough and expensive enough to produce hydrogen for the uses proposed without adding to the challenge by insisting that it be used in fuel cells. I expect that the ideological environmentalist organizations will disagree, vehemently.
I noted that the they have finally provided a fundamental definition. The law mandated that a program be established by 6/30/2021 to meet the targets. The fact that the terms crucial to the development of an implementation plan were defined 28 months after the program was supposed to be established epitomizes the lack of planning throughout the Hochul Administration’s implementation of the Climate Act.
DPS Reviewing Progress Towards Achieving the 2040 Target
My article on the DPS staff proposal concerning definitions for key terms was described above. The DPS Staff Proposal also included a section titled “Reviewing Progress Towards Achieving the 2040 Target” that is the subject of this post. The Introduction of the Staff Proposal explains:
Staff also recommends that the Commission direct Staff to develop a review process consistent with the provisions of PSL §66-p that tracks progress toward the power sector energy transition targets.
I agree with the sentiment of the recommendation because a key aspect of an implementation plan is a schedule with clearly defined targets. However, the Staff Proposal does not acknowledge my fundamental concern that there is no comprehensive plan for implementation. The Scoping Plan is an outline of strategies that NYSERDA’s Integration Analysis claims will reduce emissions consistent with the Climate Act mandates but there never has been a feasibility analysis of the strategies.
DPS Staff “believes that it is timely to interpret provisions of PSL §66-p that authorize the Commission to consider impacts of the zero emissions by 2040 target on safe, reliable, and affordable electric service in the state.” Unfortunately, the Staff Proposal addresses the timeliness of the wind, solar, and energy storage deployment but just assumes that an electric system reliant on wind, solar, and energy storage will somehow work.
The Staff Proposal admits that “Pursuing the 2040 target will require the deployment of novel technologies and their integration into a changing grid”. Transitioning a fully functional electric system to something that depends on undefined novel technologies is enormously risky. The presumption of the Climate Act authors was that no new technologies would be required is contradicted by the Staff Proposal and seven analyses that all have noted that a new category of generating resources called Dispatchable Emissions-Free Resources (DEFR) is necessary to keep the lights on during periods of extended low wind and solar resource availability. For your information, I have summarized the analyses in the Scoping Plan, NYISO 2023-2042 System & Resource Outlook, New York Department of Public Service (DPS) Proceeding 15-E-0302 Technical Conference, New York Independent System Operator (NYISO) Power Trends 2024, NYISO 2023-2042 System & Resource Outlook, Richard Ellenbogen, Cornell Biology and Environmental Engineering, and Nuclear New York.
The Hochul Administration’s current approach is based on Scoping Plan projections for wind, solar, and energy storage with an as-yet undefined and novel technology. No jurisdiction anywhere has successfully developed an electric system that is as dependent on wind and solar as the current Hochul plan. In no small part, that is because of the difficulty associated with extended periods of low wind and solar resource availability. Consequently, I think it would be appropriate to fund a demonstration project to prove that it can be done or, at the very minimum, complete a comprehensive feasibility analysis to ensure that an appropriate technology is available before addressing the timeliness of tracking progress toward the power sector energy transition targets.
My Comments on Draft Blueprint for Consideration of Advanced Nuclear Technologies
On September 4-5, 2024, the Hochul Administration hosted a Future Energy Summit. After the Summit the State released the draft Advanced Nuclear Technologies Blueprint (Draft Blueprint). This post describes my response to comments request that explained why I supported the comments presented on behalf of Nuclear New York, New York Energy and Climate Advocates, and Mothers for Nuclear (“NNY comments”).
The Future Energy Summit kicked off the release of the Draft Blueprint. I believe that the Hochul Administration is attempting to gauge public opinion on the nuclear option with the release of this draft The response to the draft Advanced Nuclear Technologies Blueprint will ultimately decide how the Administration proceeds. Supporters of the wind, solar, and energy storage approach in the Scoping Plan have mobilized to oppose nuclear options.
The announcement requesting comments for the Draft Blueprint said that they wanted to “solicit industry feedback”. The NNY comments did a great job addressing the specific questions raised in the Draft Blueprints so I merely endorsed them. Their comments make a persuasive case for the use of advanced nuclear energy in New York’s future. They clearly document why nuclear has advantages over the proposed wind, solar, and energy storage approach espoused in the Climate Leadership & Community Protection Act Scoping Plan. The NNY technical comments strengthen the quality of the Draft Blueprint.
Proponents for the Scoping Plan approach using wind, solar, and energy storage must address the DEFR challenge mentioned above. The NNY comments argue that all but one of the options for DEFR have technological readiness issues and that advanced nuclear power is the only option that does not. There is an admitted commercial readiness issue, but their comments made persuasive arguments how those challenges can be overcome concluding that advanced nuclear should be used as the backbone of a decarbonized grid rather than limiting its use to just DEFR backup.
My comments concentrated on the unacknowledged challenges associated with weather variability risks associated with planning for the DEFR resources necessary for extended periods of minimal wind and solar resource availability. The first challenge is calculating the resources needed which requires analysis of meteorological data to estimate resource availability and expected loads. I believe the State has not done a comprehensive enough analysis because they haven’t used the longest period of data available, and they have not included adjacent regional transmission operator areas. The second challenge is intractable. The resulting analysis will develop a probabilistic estimate of the resources needed analogous to the one in a hundred-year flooding parameter. The problem is that just like we see flood exceeding the one in hundred year probability, it is inevitable that the weather conditions that caused the worst-case resource drought planning scenario will be exceeded.
Today’s resource planning process must meet a one-in-ten-year loss of load reliability criteria. This period is acceptable because observations of existing generating resources over many years show that unplanned outages do not happen at the same time. They have a good idea of how many facilities can run into problems and go offline at the same time. As a result, planning based on ten-year periods has provided reliable electric energy. However, wind and solar resources are affected by weather systems that make many wind and solar go offline at the same time. I think this means that when the planning criteria are exceeded it will be a bigger problem than with today’s system. Strengthening the planning criteria will reduce the probability of exceeding the planning criteria but the fact that eventually any weather-standard will be exceeded means that someday the resources will be unable to meet the expected load. When everything is electrified to meet the Climate Act mandates, the result will be catastrophic. This risk goes away if nuclear resources are used as the backbone of the future electric system because they are not affected by weather.
Summing up, the State agencies responsible for a reliable energy system agree that a wind, solar, and energy storage system needs DEFR, the most likely viable candidate for DEFR is nuclear power, the economics suggest nuclear resources should be used as much as possible, using nuclear eliminates the need for the massive wind , solar and energy shortage development proposed, and using nuclear as the backbone of the grid eliminates the reliability risk of reliance on weather-dependent resources. I believe a feasibility analysis will confirm these findings. If I am wrong, then we can continue down that path. In the meantime, we should stop the deployment of wind, solar, and energy storage because it is likely a dead-end approach that I believe will do more harm than good.
Renewable Transition Raw Materials Challenge This article was also published at Watts Up With That.
Simon P. Michaux published two articles in Bulletin 416 Special Issue of the Geological Survey of Finland that raises another important feasibility aspect of the Climate Act Transition. It is a long technical post, so I am not going to provide details here. If you are interested in the numbers associated with elements of the transition it is a wonderful, well-documented resource.
In brief, Michaux estimated how much energy would be required to replace fossil fuels, the technologies that could be used as replacements, and the metals required to build the replacement technologies in the first article. The second article goes on determine metal resource availability and mining output necessary for the development. The takeaway message is this analysis of the metals required to transition away from fossil fuels compared to the capacity to mine those metals suggests that available metals are “manifestly inadequate for meeting projected demand”. If the raw materials necessary for the transition are unavailable, then the proposed approach makes no sense.
My conclusion to this article is also an appropriate conclusion for this update. The current Climate Act implementation plan relies on wind and solar generation. No jurisdiction anywhere has successfully developed an electric system that relies on wind and solar generation. Consequently, let me say again, it is obviously necessary to fund a demonstration project to prove that the Scoping Act wind, solar, and energy storage approach can be done or, at the very minimum, complete a comprehensive feasibility analysis outlining how issues raised here and elsewhere can be addressed without affecting the mandate for reliable and affordable electric energy before proceeding.