New York Goes Peak Madness Over Environmental Justice

New York Goes Peak Madness Over Environmental Justice

Roger Caiazza (on the subject of)
Independent Researcher and Publisher,
Pragmatic Environmentalist of New York

 

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[Editor’s Note: New Yorkers have elected the worst rulers; officials committed to peak madness over environmental justice that steals the future of every Empire State citizen.]

One notable feature of New York’s Climate Leadership & Community Protection Act (Climate Act) implementation process has been the emphasis on environmental justice (EJ) for disadvantaged communities.  A dogmatic concern of New York City EJ advocacy organizations is peaking powerplants which are alleged to be a primary air quality problem in disadvantaged communities.  Unfortunately, those generating facilities fulfill a critical reliability service so the New York Independent System Operator (NYISO) has been warning that premature shutdown of the facilities will cause reliability problems.  This post highlights a relevant NYISO filing that concisely summarizes their concerns and recent comments by EJ advocates.  Get your popcorn, it will be interesting to see how this gets resolved.

I have been following the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 350 articles about New York’s net-zero transition.  I have devoted a lot of time to the Climate Act because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Climate Act Background

The Climate Act established a New York “Net Zero” target (85% reduction and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.”  In brief, that plan is to electrify everything possible and power the electric grid with zero-emissions generating resources.

The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to write a Draft Scoping Plan.  After a year-long review the Scoping Plan recommendations were finalized at the end of 2022.  In 2023 the Scoping Plan recommendations are supposed to be implemented through regulation and legislation.

One of the implementation issues to be resolved is the subject of a New York State Public Service Commission (PSC) “Order initiating a process regarding the zero-emissions target” that will “identify innovative technologies to ensure reliability of a zero-emissions electric grid”.  The ultimate problem with wind, solar, and energy storage technologies proposed to replace fossil-fired electric generation is that they do not work all the time.

The Integration Analysis, NYISO, New York State Reliability Council, and the PSC order all recognize that a new technology is needed to support the grid during those periods.  The problem is exacerbated because the periods when wind and solar resources provide the least power are frequently the periods of highest load when peaking power plants are needed to prevent blackouts.

Peaking Power Plants

I set up a page dedicated to this issue.  The following is a top-level summary.

In order to provide electricity to everyone who needs it when they need it the NYISO must balance power availability with the load on the system.  NYISO is responsible not only for the real-time delivery of power but also for reliability planning.  If the load did not vary, then this would be much less difficult but the reality is that load varies diurnally and seasonally.

Most important is meeting demand when loads are highest in the summer and winter because it is necessary to provide electricity to maintain the health and well-being of customers. Ultimately the problem boils down to the fact that there are short periods when so much load is needed that there are generating units dedicated by intent or circumstances to provide power during peak load demand.

About fifty years ago, when Consolidated Edison was responsible for generating power and providing it to their customers, they developed a fleet of around 100 simple cycle combustion turbines at locations within New York City to provide this peaking power.  Those units were cheap but relatively inefficient and had high emission rates.

In a considered process the Department of Environmental Conservation, NYISO, and the owners of the facilities are in a regulation that ensures that the units either meet more stringent NOx emission limits or shutdown if the NYISO and Consolidated Edison do not identify specific reliability issues.  My point is that there is already a process in place to address the units that have always been considered peaking units.

The 2020 PEAK Coalition report entitled: “Dirty Energy, Big Money” is a primary reason that environmental justice organizations vilify all New York City peaking power plants.  I described this work in three posts.  I published a post that 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 to replace these peaking facilities with “renewable and clean energy alternatives” 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.

There are two relevant aspects of the PEAK Coalition report.  That report did not make a distinction between the traditional peaking simple cycle combustion turbines and other power plants that were originally designed for frequent operations.  The fuel costs to burn oil at New York power plants is so expensive that they do not generally operate except in peak load periods.

“Dirty Energy, Big Money” only defined a peaking unit as one that operates infrequently so the EJ advocates consider these relatively large steam boiler units peakers.  The second point is that I found that the presumption of egregious harm from all the peaking facilities is based on selective choice of metrics, poor understanding of air quality health impacts,  and ignorance of air quality trends.  This is not as dire a problem as it is portrayed.

Peaking Power Plant Shutdowns

Environmental justice advocates believe that it is a problem.  Marie French recently wrote a Politico article that noted that “Shutting the units down is a top priority for environmental justice groups in the city”.  The article quoted Daniel Chu, the energy planner for the NYC Environmental Justice Alliance: “We think it’s unacceptable that for the sake of reliability, we would have to sacrifice communities for two more years or potentially even longer just to ensure that we don’t have blackouts or brownouts”.  He went on to say: “We don’t want blackouts or brownouts, but we also don’t want continued pollution.”

Raya Salter who is the founder of Energy Justice Law & Policy Center and is a member of the Climate Action Council never misses an opportunity to emphasize her belief that these facilities are a root cause of air quality health impacts in New York City disadvantaged communities.

In a recent Equity and Climate Justice Roundtable session, she argued that the New York Cap-and-Invest program should make shutting down the peaking units a priority.  She believes that equity is only achieved when fossil plant emissions are zero saying that “Anything less than shutting down power plants is a distraction from the goals of the Climate Act”.  However, she also says getting to zero mush be done “in a way that prioritizes emissions and co-pollutant reductions in front line communities and does not disproportionately burden disadvantaged communities”.

The disconnect between those goals will have to addressed in another post.  You cannot have your cake and eat it too.  In this post I will consider the unconditional demand for shutdowns relative to the concerns of NYISO.

NYISO Reliability Concerns

Last month NYISO released its quarterly assessment of reliability of the bulk electric system which found  a deficit in reliability margins for the New York City area beginning in summer 2025.  I explained that report found that without changes to existing load pattern the summer peak load demand in New York City would be “deficient by 306 MW in 2025 for a duration of 7 hours”.  It is possible, due to uncertain load demand forecasts, that the deficiency could be “446 MW over 9 hours.”  They found that: “The deficient margin is primarily due to the increased demand forecasts within New York City combined with the planned unavailability of simple-cycle combustion turbines to comply with the DEC’s Peaker Rule in 2025”.

On August 25, 2023 NYISO submitted comments on a petition filed by Alliance for Clean Energy New York, Inc. seeking modification to Clean Energy Standard Tier 1 Renewable Energy Certificate purchase and sale agreements as part of Case 15-E-0302 – Proceeding on Motion of the Commission to Implement a Large-Scale Renewable Program and a Clean Energy Standard.  The submittal includes a succinct description of the replacement power problem.

In the introduction to the comments, the letter states:

The NYISO is committed to operating an electric system that provides reliable service 24 hours a day, 365 days a year, and to planning a reliable system for the future grid. The Climate Action Council’s Scoping Plan accurately notes, “[w]hile transitioning away from fossil fuel use, maintaining reliable access to power, whether through centralized or distributed energy sources, is crucial for maintaining good public health in our energy-dependent society.”  The NYISO takes no position on the issue of whether, and if so how, REC Agreements should be modified as requested in the Petition and related dockets. The NYISO offers these comments to highlight the importance of developing and deploying generation resources that comply with the CLCPA requirements in a manner that is rationally coordinated with the retirement of existing fossil resources so that system reliability is not jeopardized.

The following is the letter’s comments section (without footnote references):

New Yorkers have long enjoyed reliable electric service and will expect the same level of service to continue. Reliable electric generation supports every aspect of New Yorkers’ daily lives and is vital to the state’s economy. Economic development within the state is driving the interconnection of large loads to the grid and increasing the demand for electricity. As transportation and building heat turn to the electric grid to drive the required economy-wide greenhouse gas emission reductions, people will become even more dependent on reliable electric service for their health, welfare, and safety. Reliable electric service is critical today and will become more critical to everyone’s daily life and general well-being as other sectors of the economy electrify.

Reliable, dispatchable electric generation is in jeopardy as generation retires faster than new resources become operational. Electric system margins have decreased to unprecedentedly low levels. In fact, the NYISO’s Short-Term Assessment of Reliability for 2023 Quarter 2 concluded that the New York City locality is deficient by as much as 446 MW for a duration of nine hours on the peak summer day under expected weather conditions, after accounting for forecasted economic growth and policy-driven increases in demand for electricity. The deficiency would be significantly greater if New York City experiences a heatwave or an extreme heatwave. The narrowing margins and the identified deficiency in New York City demonstrate that the addition of new resources is timely and critical.

NYISO’s ability to facilitate a reliable electric system, including delivery to consumers, requires that the introduction of new resources be coordinated with and occur prior to the orderly retirement of any existing generators. This order of operations is critical for maintaining reliability after such retirements. Electric system reliability margins are already close to minimum reliability requirements in certain areas across New York and continue to tighten, as discussed above. If these margins are totally depleted, the reliability of the grid would be at risk and power outages could disrupt normal life or negatively impact public health, welfare, and safety.

The figures below demonstrate the trend of shrinking reliability margins. Figure 1 shows how resource retirements are beginning to outpace resource additions, notably over the last three years. Figure 2 depicts how this trend is leading to tighter reliability margins in the coming years. While the state’s bulk electric system meets current reliability requirements, risks to reliability and system resilience remain. One key factor driving this risk continues to be resource retirements outpacing additions.

A sufficient fleet of new generation resources that satisfy the CLCPA must be available before more of the existing, traditional generators retire voluntarily or are forced out of service. New generation resources are required now to serve consumers’ needs and to maintain electric system reliability as load increases and existing generators retire. Large-scale renewable energy

generation, offshore wind generation, storage, and distributed energy resources are needed to satisfy CLCPA mandates and to support electric system reliability. Renewable energy generation must still increase substantially to achieve the CLCPA’s 70 percent by 2030 renewable energy requirement and then increase further between 2030 and 2040. This transition will facilitate new renewable resources entering service in the near term, fossil generation will operate less and less prior to retiring, but remain available for when it is needed to serve load and maintain system reliability.

Conclusion

Two opposing viewpoints must be reconciled to resolve the direction of Climate Act implementation.  On one hand, there are ideologues who have so far been setting Climate Act policy.  Despite their lack of energy system qualifications, they argue that the Climate Act mandates require zero emissions.  On the other side NYISO says that introduction of new resources to get to zero emissions must be coordinated with and occur prior to the orderly retirement of any existing generators. Failure to acknowledge this requirement will risk and power outages that could disrupt normal life or negatively impact public health, welfare, and safety.

I believe that those who believe that the Climate Act law has no implementation restrictions are wrong.  There are reliability and affordability safety valve provisions in New York Public Service Law  § 66-p(4). “Establishment of a renewable energy program”.   §66-p (4) states: “The commission may temporarily suspend or modify the obligations under such program provided that the commission, after conducting a hearing as provided in section twenty of this chapter, makes a finding that the program impedes the provision of safe and adequate electric service; the program is likely to impair existing obligations and agreements; and/or that there is a significant increase in arrears or service disconnections that the commission determines is related to the program”.

I have never seen anyone else suggesting that this is a possibility so it is likely that I am wrong.  In any event, is the Hochul Administration so invested in appeasing the EJ constituency that they are willing to risk causing a blackout or out of control energy costs?  In my opinion if the pragmatic approach to put the implementation on hold until the costs are known and reliability risks are minimized, the ideologues will have a meltdown and call for Hochul’s head.  There is no sign whatsoever that they will accept any compromises or delays to their demands.  As noted in the introduction, get out the popcorn watching this unfold is going to be fascinating.

Roger Caiazza blogs on New York energy and environmental issues at Pragmatic Environmentalist of New York.  This represents his opinion and not the opinion of any of his previous employers or any other company with which he has been associated.

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