NY-Sun Mythical Claims

Led by Governor Andrew Cuomo, New York’s solar ambitions are a key component in his agenda for to ensure “vital progress on the climate” is continued. This is a post on the claims made by New York State for the NY-Sun program. The opinions expressed in this post reflect my personal opinion.


NY-Sun is supposed to make solar affordable for all New Yorkers. According to the NY Sun section on the NYS website Leading on Climate Change and Protecting our Environment:

  • NY-Sun is developing a sustainable, self-sufficient solar industry in the State by incentivizing New Yorkers, businesses, and communities to invest in solar energy.
  • The Governor’s $1 billion NY-Sun program has grown solar power in New York State by nearly 800% since 2011, and has reduced greenhouse gas emissions by nearly 25%.
  • The program aims to add more than 3 gigawatts of installed solar capacity in the State by 2023, enough solar energy to power 400,000 homes.

I will address each of these claims in this post.

Self-Sufficient NY Solar Industry

My interpretation of self-sufficient solar industry is one where solar manufacturing provides New York solar farms with the panels it needs. I think this is a reference to the SolarCity gigafactory in Buffalo, NY. According to a May 2016 CNBC article:

The Queen City is the crown jewel in Gov. Andrew Cuomo’s multibillion-dollar business-development strategy to revitalize economically depressed Upstate New York by turning it into a 21st-century manufacturing powerhouse. His Buffalo Billion (as in dollars invested) project — although the subject of federal and state bid-rigging probes — is highlighted by a 1.2-million-square-foot “gigafactory” that will be run by Elon Musk‘s SolarCity and fabricate up to 10,000 solar panels per day. In late May, New York’s Public Authorities Control Board unanimously approved a $485.5 million grant, part of the total $750 million the state will spend to construct and equip the humongous facility. New York will retain ownership and lease it to SolarCity in a deal negotiated by Albany-based SUNY Polytechnic Institute, the state university known as SUNY Poly.

An update on February 11,2019 from CleanTechnica is titled “The Latest News from the Tesla Gigafactory 2 in Buffalo Isn’t Good”. The lead to the article admits that they are “one of the biggest cheerleaders for Elon Musk and Tesla” but admits that the factory is “a disaster waiting to happen”. I encourage you to read that article but the key point relative to the NY-Sun claim that NY solar development would be self-sufficient is that one of the recently laid off employees claims ““Some weeks we produced enough solar modules for zero homes and probably the best I saw was maybe four homes in a week, so that is alarmingly scary to obviously be a part of a company who doesn’t have any sense of urgency to tackle these issues and get them working correctly”.

Reduced Greenhouse Gas Emissions 25% since 2011

I have previously evaluated New York State CO2 emission reductions and the claim that NY solar power has reduced CO2 emissions by nearly 25% immediately set off my BS detector. The Solar Generation CO2 Reductions table checks this claim. The New York State Energy Research and Development Authority (NYSERDA) Patterns and Trends – New York State Energy Profiles: 2002-2016 document includes a table that provides the generation by fossil-fired sources and solar and another table that lists CO2 emissions but the data only goes through 2016. I downloaded the annual CO2 emissions from the EPA Clean Air Markets Division through 2018 for your information.

Solar generation reduces CO2 by displacing fossil-fired generation. Assuming that solar only displaces fossil-fired generation means that we can calculate the CO2 displacement by multiplying the solar heat input by the fossil-fired CO2 rate in mass per heat input. In 2016 using the EPA data or the NYSERDA data exclusively indicates that solar is only responsible for 0.21% of the observed reduction. That is two orders of magnitude less than the claim that NY-Sun solar power has reduced CO2 emissions by nearly 25%.

On the other hand the total CO2 reduction from 2011 to 2018 is 25% so that may be where the number came from. However, that reduction is mostly due to fossil-fired fuel switching. CO2 from coal is down 93%, residual oil is down 55%, diesel and other oil is down 59% while natural gas is up 10%. It is worthwhile to note that coal and petroleum usage is down so low now that only small further reductions are possible due to fuel switching.

Three gigawatts power 400,000 homes

According to the US Energy Information Administration, in 2017, the average annual electricity consumption for a U.S. residential utility customer was 10,399 kilowatthours (kWh). At that rate, 400,000 homes would require 4,160 GWh of energy. Three gigawatts of solar operating 24 -7 would produce 26,280 GWh. The capacity factor is the ratio of the actual to the maximum possible generation and in this example it would have to be 15.8% to power 400,000 average homes.

The NYSERDA New York Solar Study in includes a table of Projected New York capacity factors. The highest values listed are 14.96% for MW-scale systems in Downstate NY. I calculated the number of average homes for three gigawatts of solar using their capacity factors. If all the homes were powered by residential scale systems in Upstate only 316,654 homes would be powered by 3 gigawatts. If all the homes were powered by utility scale systems downstate 378,076 homes would be powered by 3 gigawatts. NY Sun is funding all four types of installations across the state so the best number would be somewhere in between.

Myth Scorecard

NY-Sun is developing a sustainable, self-sufficient solar industry in the State by incentivizing New Yorkers, businesses, and communities to invest in solar energy.

Depending on your definition of sustainable, self-sufficient there may be some validity to this claim but if the claim is taking credit for the Tesla Gigafactory 2 in Buffalo it appears very unlikely that this facility will provide much if any support for New York solar installations.

The Governor’s $1 billion NY-Sun program has grown solar power in New York State by nearly 800% since 2011, and has reduced greenhouse gas emissions by nearly 25%.

There is no way to salvage this statement. It implies that solar power growth has led to CO2 reductions in New York and that is simply not true.

The program aims to add more than 3 gigawatts of installed solar capacity in the State by 2023, enough solar energy to power 400,000 homes.

If the NY-Sun uses a different value for the energy needed by an average home then 400,000 may be legitimate. However, if you use the US EIA value then the capacity factor used by NY-Sun is higher than acceptable.

German Compendium for a Sensible Energy Policy

The German Energiewende or energy transition is a plan to move away from fossil fuels and nuclear to a low carbon energy supply. Advocates of New York’s Reforming the Energy Vision (REV) often point to this as a model for the New York transition. However, a recent paper, Vernunftkraft, Bundesinitiative für vernünftige Energiepolitik or Compendium for a Sensible Energy Policy, produced by a group of German energy experts, engineers and technicians, eviscerates those claims for its success. Their full study is available to be downloaded in PDF here.

I am a numbers and history guy. If you can produce numbers or show examples where a policy has worked elsewhere then I can determine whether I can support that policy. My fundamental problem with REV is that I have not seen where any jurisdiction has been able to move away from fossil fuels without markedly increasing costs. Furthermore, there are very few places where the amount of renewable energy proposed in REV has been implemented so it is not clear to me whether that much renewable energy can actually be implemented without threatening the reliability of the grid.

I believe that the Compendium for a Sensible Energy Policy should be a cautionary tale for New York. The review produced by this group is intended to inform public debate to try to bring a reconsideration of Germany’s energy policy. Most of the discussion topics in the introduction of the Compendium are directly applicable to New York and REV. It is troubling that rather than learning from the results of the German experience we seem to be headed down the same path.

Introduction from the Compendium for a Sensible Energy Policy

’But where should the electricity come from’ is usually the immediate question to someone who takes a critical position on the expansion of wind and solar power plants. Our problem description in section 1. focuses on this simple question. It shows that wind and solar energy, which seem to promise a quick fix, are not simple alternatives to fossil fuels. Indeed, they are not even part of the answer; as their deployment becomes widespread, they become a problem in themselves and make it even more important to find sensible solutions.

It is often claimed that all that is needed is a sufficiently large and sufficiently widely distributed network of wind farms (’the wind is always blowing somewhere…’); ‘smart grids’ and grid-scale energy storage will then compensate for the intermittency of the power supplied. Section 2. On the technological aspects shows that these hopes are unrealistic.

A widespread view is that if a measure is designed to protect the climate or the environment, then we should see no sacrifice or technical challenge involved in putting it in place as too great. In fact, however, this attitude is based on false premises, as section 3. on the ecological aspects of the renewable energy question shows. Instead of delivering the promised protection of the climate, current energy policy is causing a biodiversity disaster. The protection of nature and wildlife is suffering, and populations of endangered wild animals have been decimated. These sacrifices are all the more tragic because they are completely pointless. There are easier, and much less painful ways to reduce carbon dioxide emissions.

The energy transition is a ‘blessing for rural regions’, claimed the former head of the German Chancellery, Peter Altmaier, a few years ago. Poorer regions would be given a new boost through their involvement in renewable energy production. There were also high expectations that Germany would take the lead in developing many of the new technologies and would benefit from a ‘green jobs’ boom. Section 4. on the economic aspects measures these expectations against reality. It reveals that renewables are being given perverse economic incentives, giving rise to undesirable developments that pose considerable risks to economic growth and prosperity in Germany.

The social effects and the losses in health and quality of life that the expansion of ‘green electricity’ facilities will have, are hardly noticeable in the large cities. Dramas are taking place in the countryside that remain hidden from the Energiewende enthusiasts, most of whom live in the cities. Our section 5. on social and health aspects examines these negative impacts.

A great deal needs to change in energy policy. We therefore conclude this paper with a list of demands, addressed to the future German Federal Government – whoever they may be.

The list of demands in the conclusion:

  • The idea of meeting our country’s energy needs with wind power and solar energy has proven to be an illusion. At present, around 29,000 wind turbines and 1.6 million photovoltaic systems together account for just 3.1 % of our energy requirements. Although their share of electricity is higher, their direct and systemic costs are gigantic.
  • The cardinal problems – weather-dependence and low energy density – are unsolved or unsolvable. The idea often put forward by the government that expanding the areas covered in renewable systems will reduce natural volatility contradicts mathematical laws and has also been clearly refuted empirically.
  • To compensate for the lack of reliability of wind and sun and to be able to actually replace conventional power generation, gigantic amounts of electricity storage would be required. The replacement of controllable power generation with a fluctuating power supply is impossible without storage and unaffordable with it.
  • As a result of the rapid expansion of ‘renewable energies’, electricity prices have risen steadily and further cost increases are inevitable. Germany as a desirable location for business is suffering. The social imbalance is getting worse and worse. There is a locational disadvantage for the manufacturing industry. At the same time, the redistribution from ‘bottom’ to ‘top’ is continuously increasing.
  • The present energy policy does not serve the alleged climate protection. CO2 emissions are rising instead of falling. The ‘dirty secret’ of producing ‘green electricity’ is not a transitional phenomenon, but a systemic one. Through emissions trading, a (global) tax and open-technology research funding, the target of CO2 reduction could be achieved much more cost-effectively. Instead of’ climate protection’, the incentive system of the EEG induces environmental crime, sows discord and causes unprecedented landscape damage and destruction of nature.


NYS Energy Efficiency Fatal Flaw

In Governor Cuomo’s 2018 state of the state address he announced a plan to create new energy efficiency targets and appliance standards and on Earth Day new energy efficiency targets were announced. This is all part of the effort needed to meet the Reforming the Energy Vision (REV) 80 by 50 goal. The study New Efficiency New York describes the new efficiency target, the “utility-leveraged action” to drive energy efficiency, market enabling actions and other aspects of the program. This post addresses one aspect of the program that I consider a fatal flaw: widespread implementation of air-source heat pumps at the same time the state is pushing renewable energy, particularly solar.

Air-Source Heat Pumps

In order to meet the REV reduction goal carbon dioxide emissions from the home heating sector need to be reduced by replacing oil and natural gas furnaces with electricity. Heat pumps are the recommended choice for home heating electrification in no small part because they can be used for both heating and cooling. According to the Department of Energy (DOE):

An air-source heat pump can provide efficient heating and cooling for your home. When properly installed, an air-source heat pump can deliver one-and-a-half to three times more heat energy to a home than the electrical energy it consumes. This is possible because a heat pump moves heat rather than converting it from a fuel like combustion heating systems do.

Air-source heat pumps have been used for many years in nearly all parts of the United States, but until recently they have not been used in areas that experienced extended periods of subfreezing temperatures. However, in recent years, air-source heat pump technology has advanced so that it now offers a legitimate space heating alternative in colder regions.

Note that there are two types of heat pumps: air source and ground source. Both extract heat from outside the building to warm the inside. Air-source heat pumps extract it from the atmosphere where the efficiency is affected by air temperature but it is relatively easy to duct the pump to the source. On the other hand ground-source heat pumps use stable ground temperature so are uniformly more efficient. The tradeoff is that developing the ground system is much more complicated. As a result, an air-source heat pump can be retrofitted into an existing structure much more easily than a ground-source heat pump.

The reason that heating electrification is included in the energy efficiency policy is related to peak loads. Section 7.2 of New Efficiency New York is entitled “Support Heat Pump Adoption to Decarbonize Heating and Cooling”. The rationale for advocating heat pumps is based on the observation that the value of energy efficiency is higher when it reduces demand during a utility system’s peak load hours. The report notes that a Lawrence Berkeley National Laboratory study of the time-varying value of electric efficiency concluded “that of five common measures modeled, residential central air conditioning in summer-peaking systems has the most significant added value”.

Peak Loads

Peak loads are a problem that are a primary driver of political agenda of REV. Electricity demand varies with time. In the middle of the night the residential use drops when people sleep but it peaks in the later afternoon when everyone is awake and using electricity. The electrical grid uses power from different sources at different rates to cover this normal variation. The peak problem is that when there is abnormally warm and cold weather energy use increases a lot. The existing system is designed to provide power for these abnormal periods but that requires the use of additional facilities that only run during peak load periods. The problem is that those additional sources are expensive so prices peak too. The theory is that if the peak load could be shaved then you would not need those expensive sources and the prices would be reduced.

The New York Independent System Operator (NYISO) provides peak load data for New York State (NYS) for the hour in the summer and winter when electricity usage was highest. The following data are for coincident peak demand which refers to simultaneous load peaks between different sectors. For example, residential and commercial heating will peak at the same time during cold weather. There are two significant electric load peaks during the year: summer when air conditioning use is highest and winter when heating demand is highest (Figure 1: NYISO Gold Book Actual and Project Coincident Peak Demand Generation. Over the last 20 years (1998-2017) the summer peak averaged 6,760 MW larger than the winter peak. Figure 1 also includes forecasts from the 2008 Gold Book and 2018 Gold Book. The discontinuity between 2017 and 2018 represents the changeover between the two forecasts.

The Table NYISO Gold Book Coincident Summer Peak and Winter Peak Average Demand by Zone – MWaverages load data for three periods: the last five years, a five year period 20 years ago and 2026 to 2030 at the first target date of REV. NYISO divides the state up into 11 load zones. Note that there is tremendous variation across the zones. Three downstate zones I, J and K accounted for 55% of the summer load and 48% of the winter zone in the most recent five years. Note that in zones D and E winter load is greater than summer load. I have been unable to track down older data but I believe that in the past that was the situation for more zones.

Fatal Flaw

The latest state-wide report on NYS load, NYISO Power Trends 2018, states that:

Distributed energy resources — such as rooftop solar — are transforming historical patterns of consumption, and affecting consumer reliance on electricity provided by the bulk power system. For instance, energy usage from New York’s bulk power system is expected to decline over the next decade at a rate of 0.14% per year. Peak demand — a critical element to reliable system planning that establishes the total amount of capacity that must be procured to meet reliability standards — is projected to decline at a pace of 0.13% per year, through 2028.

However, nowhere in that document is there any mention of the plan to electrify residential home heating as a necessary component of the REV carbon reduction goal. To date all the NYS plans discuss summer peak demand reduction and have ignored the potential for an increase in winter demand.

I believe that overlooking the impact of electrifying the residential and commercial winter heating could be a fatal flaw. The Department of Energy claims that the preferred air source heat pump technology is a legitimate alternative and the Northeast Energy Efficiency Partnerships, an organization whose overview goal is “Assisting the Northeast/ Mid-Atlantic Region in reducing total carbon emissions 80% by 2050”, notes that the more efficient heat pumps provide cost savings. Unfortunately air-source heat pumps only work when they move heat and when it is cold enough there is no heat in the air to move.

The American Council for an Energy-Efficient Economy published a paper that documents the problem: Field Assessment of Cold Climate Air Source Heat Pumps (ccASHP) (https://aceee.org/files/proceedings/2016/data/papers/1_700.pdf). The report describes a Center for Energy and Environment field study in Minnesota where cold climate air source heat pumps were directly compared to propane and heating oil furnaces. The report notes 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.” For example, the figure Energy use versus outdoor air temperature method from ASHP Site 2 shows that as temperature decreases the energy use for an air-source heat pump goes up. Below 20 deg. F the efficiency of the air-source heat pump decreases to the point where the system cuts back and a backup system is needed. Below zero the air-source heat pump does not operate well enough to use.

The unanswered question is how these initiatives will be reconciled. Although air source heat pumps are more efficient, widespread implementation will exacerbate the winter peak load. If distributed rooftop solar is supposed to provide a significant portion of that load what happens when it snows for 66 straight hours and there is record cold? When the temperatures are that cold then home heating has to use something other than an air source heat pump. The fact is that either home owners will have to maintain their original furnace or invest in a radiant electric heating system. The economics of maintaining two furnaces does not seem likely to lead to widespread adoption. However a radiant heating system is far less efficient so the peak in electric use that cannot be covered by solar renewable energy will be exacerbated.

Several related issues have to be addressed. As more and more renewable energy is brought on to the system less and less energy is produced by fossil-fired generating facilities. The first issue is how much load will be required for the winter peak when the recommended alternative for heating electrification, air source heat pumps, must be supplanted with much less efficient radiant heating. Secondly, where is this energy going to come from? Depending upon rooftop solar for residential heating in the Upstate NY winter is clearly not viable so what is the renewable solution? Absent a magical solution the system is going to have to depend upon fossil-fired facilities to prevent people from freezing to death. However, widespread implementation of rooftop solar and other renewable energy alternatives has to negatively affect the economic viability of existing or new fossil-fired facilities. The final issue is to determine what will be necessary to incentivize the backup power needed when the subsidized energy from rooftop solar is unequal to the task of keeping the heat on. The potential fatal flaw is that identifying and reconciling all these issues takes time and it may not be possible to prevent a severe reliability problem before it occurs.

NYSERDA 2018 Renewable Energy Awards – Inconvenient Facts

On March 9, 2018 Governor Cuomo announced the “single largest commitment to renewable energy by a state in U.S. history at $1.4 billion, which will advance 26 large-scale renewable energy projects across New York.”   This sounds great in a news release but when you look at the numbers in more detail there are some inconvenient facts.

Per usual the details are sparse but there is a summary that says the New York State Energy and Research Development Authority (NYSERDA) request for renewable energy standard bids resulted in 26 agreements to develop 1,383 MW of new, clean energy capacity throughout New York State. The total funding committed through the request for proposals is approximately $1.4 billion, and the weighted average price for these contracts was $21.71 for each Tier 1 Renewable Energy Credit. The successful proposals include a hydroelectric project, three wind projects (including one with energy storage), and several solar projects. They also claim 1.6 million metric tons of reductions from these projects.

The NYSERDA Greenhouse Gas Inventory 1990-2014 contains an inventory of historical greenhouse gas emission data from 1990-2014 for New York State’s energy and non-energy sectors. According to this, New York State Greenhouse Gas (GHG) emissions were 235.8 million metric tons in the baseline year of 1990 for the REV goal so the 80% reduction is 188.7 million metric tons and 2050 emissions will only total 47.2 million metric tons if the goal is met. In 2014 total GHG emissions were 217.7 million metric tons so the reduction so far from 1990 is 18.1 million metric tons or only 10% of the 2050 goal.

I believe that one of the weaknesses of the REV process is that there isn’t clear, concise summary with a roadmap to meet the ambitious goal. In order to meet the 80% target NYS emission reductions will have to average over 4.7 million metric tons per year until 2050. If renewable energy standard bids were the only mechanism for achieving reductions, this year’s awards only gets a third of the annual reduction needed and we have to do this for 32 more years. However, the implementation plan combines both reductions in emissions and reductions in loads so this is not a correct comparison.

The New York State Department of Public Service Staff’s White Paper on the Clean Energy Standard did project what renewable energy was needed to meet the interim Reforming the Energy Vision and State Energy Plan goal of 50% renewable energy by 2030. According to the white paper:

To achieve the SEP 50 by 30 goal Staff has initially determined that in order for this goal to be met, slightly more than 33,700 GWh of incremental renewable generation must be added to the State’s fuel mix. Staff arrived at this calculation by determining projected 2030 load statewide. Staff adjusted the projected load growth for expected energy efficiency gains. We then noted that in 2014 the State had approximately 26% renewable energy in its power generation mix, net of exports, or 41,300 GWh of renewable energy. We then calculated that the CES program will be required to add an additional 33,700 GWh of renewable energy to meet the 50% by 2030 mandate.

Note that this white paper defines the needed renewable generation in output with units of GWh. That number is calculated by summing the hourly power produced by a generating facility over a year. After digging around for a while I found that the Frequently Asked Questions link for the 2017 Renewable Energy Standard Results notes that “Once operational, the 26 projects awarded in this RES solicitation are expected to generate more than 3.2 million MWhs annually.” Note that this converts to 3,200 GWh.

Here’s the first inconvenient fact: The “single largest commitment to renewable energy by a state in U.S. history at $1.4 billion” gets less than ten percent of the renewable energy needed by 2030 for the interim 30 by 50 goal. Simple extrapolation means that another $10 billion will be needed for the 2030 renewable energy goal.

Another inconvenient problem is the timing. According to the Frequently Asked Questions link, the target commercial operations date for these projects is 2022. In order to meet the 33,700 GWh projection the annual rate of project developments will have to be greater than the 2018 award level.

There is another inconvenient issue: permitting. Of the 26 projects, eight are large enough (>25 MW) to fall under the NYS Article Ten permitting process. This is an onerous and time-consuming process and it is interesting how many projects fall just short of the threshold capacity limit. Of the eight that have to go through that process, the Article Ten Projects Under Review link indicates that only one has submitted its application and another two have submitted scoping statements. As a result, I believe those three facilities could have their permits within a year or two. Frankly I would be shocked if any of the other five applicants could get through these permitting requirements in less than three years which only leaves a single year for construction.

In addition to the timing issue I have a particular concern relative to the implicit message sent when an award is announced for any project before it is permitted. There is a chance under the Article Ten permitting program that a project could be rejected due to local concerns and home rules. However, in this instance, the Cuomo Administration picks the judges and jury for that decision so it seems that the decision is pre-ordained in favor of the developer.

Moreover, deliberately sizing the project to skirt the Article Ten rules means that 18 local jurisdictions will have to address them and there maybe local issues that have to be addressed. For example, the Middletown recordonline web site describes the surprise of local officials about four projects. Of the four projects, two developers have contacted the town where the facility will be built but have not started the permit application process, one has not started work with the local agency, and the fourth has not even contacted the town. This could affect the viability of any project because, for example, one project does not fit the requirements of the proposed solar law the town is considering. The draft solar law allows for projects of up to 20 acres, generating 2 megawatts of power. The proposed project wants to use 95 acres to generate almost 25 megawatts of power. I think this puts undue and unfair pressure on the towns to approve permitting as quickly as possible because the Cuomo Administration has “approved” these projects.

In conclusion there are inconvenient facts related to this announcement:

  • The investment of over $1 billion covers only ten percent of the 2030 interim goal;
  • The size of the award is smaller than the annual amount necessary to meet the 2030 interim goal;
  • The schedule for this award is ambitious relative to permitting requirements;
  • In addition this timing issue will make subsequent investments successively more difficult to be permitted and constructed in time for the 2030 target deadline; and
  • The announcement of the awards to unpermitted projects puts undue pressure on the affected jurisdictions.