Citizens Guide to the Climate Act Reliability Page

The Climate Act emissions reduction strategy is to electrify everything and use zero-emissions electricity sources. That will require unprecedented levels of wind and solar energy and supporting technologies that have not been tested at utility scale.  The New York electric system has evolved over many years and became more resilient when changes were made in response to blackouts in the region and in New York City.  The schedule and reliance on untested amounts of intermittent sources of energy make it likely that some unforeseen circumstances will cause blackouts with impacts comparable to Superstorm Sandy.

Importance of Reliability

There is a long history of blackouts in New York State in general and New York City in particular that is a primary driver of reliability concerns in the state.  After a blackout in July 2019 AMNY published a brief history of blackouts in New York City.  In 1959 and 1961 surges in electrical use caused blackouts and “The outage spurred changes to better protect the city’s power grid from future blackouts”.  The 1965 blackout was the first regional blackout and was caused by a transmission problem in Ontario causing a wave of disruptions in the transmission system.  Over 30 million people and 80,000 square miles in Ontario, New York, Connecticut, Massachusetts, New Hampshire, New Jersey, Pennsylvania, Rhode Island, and Vermont were left without power for up to 13 hours.   There was another blackout in 1977 that was limited to New York City directly related to the fact that most of New York City is on islands and is a load pocket.  It was caused by storms cutting off transmission into the New York City and in-City generation was unable to replace the load without disruptions.  Without sufficient local power, protective devices turn off overloaded lines and transformers to prevent physical damage to the equipment and this led to the outages.  As a result of this blackout, reliability constraints were strengthened to ensure that when storms threaten transmission into the City that sufficient in-City generation is available to prevent a re-occurrence.  In 2003 there was another regional blackout caused by a computer software problem.  Grid operators identified the cause and then developed procedures to prevent it from happening again.  In 2012 tropical storm Sandy caused massive blackouts exacerbated by flood protection weaknesses.  Since then, there have been investments to strengthen the infrastructure to prevent a reoccurrence.  Reliability planning is a constant concern for the electrical system professionals who operate the system and are responsible for keeping the lights on.

New York Reliability Planning

There are two independent organizations responsible for New York reliability: New York State Reliability Council (NYSRC) and New York State Independent Operator (NYISO).  The NYSRC is a Federal Energy Regulatory Council (FERC) approved entity responsible for “the promulgation of reliability standards for New York, which are mandatory requirements for the New York Independent System Operator”.   The Climate Action Council presentation included a slide describing what is needed to operate the electric system reliably.  The takeaway message of the NYSRC to the Climate Action Council was:

With the intermittency of renewables and the electrification of the economy, substantial clean energy and dispatchable resources, some with yet to be developed technology, over and above the capacity of all existing fossil resources that will be replaced, will be required to maintain reliability in the transition to meeting CLCPA requirements.

The NYISO system planning process has added a new component to address the Climate Act.  They evaluate a longer planning horizon than was included previously.  The 2021-2040 System & Resource Outlook can be downloaded from NYISO and a datasheet summary of key takeaways of the Outlook report is also available.   The following figure shows four key findings.

The Dispatchable Emissions-Free Resource finding is particularly important.   The Scoping Plan projects that between 14.6 GW and 20.7 GW of this resource will be needed in the future and assumed that hydrogen resources would fulfill that need.  However, hydrogen has never been used as proposed. There is no technology that is zero-emissions, able to come on line quickly and flexible enough to meet rapid and steep ramping needs.  NYISO noted that  “while there is not an immediate reliability need, changes in the economy, new generation technology, extreme weather and policy drivers are creating challenges for the future grid that may require actions to avoid interruptions in electric service.” The Scoping Plan doesn’t even address those concerns.  Before the regulations implementing the Scoping Plan framework are promulgated, feasibility must be considered or we run the risk of those challenges causing a catastrophic blackout.

Black Swan Events

The reliability concerns related to the integration analysis proposals to this point only addressed normal weather variability effects. There is another major catastrophic potential problem.  What happens to the electric system when unprecedented extreme weather cripples the relatively fragile renewable generating and transmission system?  These statistical outliers are described as a “black swan event”.

A Black Swan event is an event in human history that was unprecedented and unexpected at the point in time it occurred. However, after evaluating the surrounding context, domain experts (and in some cases even laymen) can usually conclude: “it was bound to happen”. Even though some parameters may differ (such as the event’s time, location, or specific type), it is likely that similar incidences have had similar effects in the past.

I worry about two potential black swan events.  The integration analyses project that 20 GW of offshore wind resources will be necessary.  Assuming that New York builds the latest generation offshore wind turbine that equates to over 1,600 turbines.  Given that one of the reasons we are told we must address climate change is that hurricanes will be more intense and more frequent in the future and that there have been historical storms strong enough to damage those turbines, storms strong enough to knock this resource off line for an extended period of time are inevitable.  The second inevitable black swan event is an ice storm.  The January 1998 North American ice storm caused massive damage to trees and electrical infrastructure in northern New York leading to widespread long-term power outages. The impacts of these storms will be magnified when the New York energy system is electrified as much as possible and most of the power comes from wind and solar.

Draft Scoping Plan Comments on Reliability

A primary concern in my comments was reliability and in particular the notion that the energy transition must proceed no matter what because the law says so.  However, New York Public Service Law  § 66-p. “Establishment of a renewable energy program” includes a safety valve condition:  “(4) 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”.  Unfortunately, the Climate Action Council got bogged down in details of specific technologies and did not define the criteria for safe and adequate electric service, impairing existing obligations, and increase in arrears or service disconnections for Climate Act implementation.  In 2023 the Department of Environmental Conservation is supposed to promulgate enabling regulations for the Scoping Plan net-zero transition plan.  It is critical that those regulations are evaluated against these conditions, implemented only if the conditions are met, and then tracked during implementation to see if they are being maintained.

Further Reading

The Basics of Electrical Distribution System Reliability

Cold and Dark? New York’s Risky Energy Future

Electricity Emergency

Reliability Problems Elsewhere

Pragamatic Environmentalist of New York Reliability Posts

Other Reliability Concerns

Climate Action Council Reliability Planning Speaker Session

In response to stakeholder recommendations the New York State Energy Research and Development Authority held a Reliability Planning Speaker Session on August 2, 2021 for the edification of the Climate Action Council (presentation and recording).   For clarification a dispatchable resource is a generator that can increase or decrease its output energy depending on the needs of the electric grid.  The operators who manage the system balance the load and generation on a minute-by-minute basis.  The critical reliability challenge is how to manage this balancing act when there are large amounts of wind and solar energy resources that cannot be dispatched.

The NYISO Frequently Asked Questions webpage explains how the organization originated. After the Northeast Blackout of 1965, New York’s seven investor-owned utility companies established a predecessor organization, the New York Power Pool (NYPP), to address the reliability problems exposed by the blackout.  In the 1990s New York’s electric system was de-regulated and the Federal Energy Regulatory Commission (FERC) recommended the formation of independent entities to manage energy transmission and the NYISO was established to replace the NYPP. 

The NYISO manages the electric system.  They operate the control center mentioned in the previous slide that balances the instantaneous supply of electricity between the generators and customers across the state in the de-regulated electricity market.    In addition, the NYISO has to plan for future changes to the system and the biggest factor for change is the Climate Act.  Their recent Power Trends 2021: New York’s Clean Energy Grid of the Future report describes how hourly demand patterns fluctuate diurnally and seasonally today and how they expect it will change in the future.  One NYISO analysis projected future winter energy production by resource type and found that the worst-case future resource concern will be a winter-time wind lull.  During those periods solar resources are low because days are short and the sun is at a low angle, and wind resources can be less than 25% of the wind capacity for seven days at a time.  Consequently, there is a need for a large quantity of installed dispatchable energy resources needed for a small number of hours.  They must be able to come on line quickly and be flexible enough to meet rapid and steep ramping needs. The problem is that no such zero-emissions resource has been deployed at the scale necessary to keep the lights on in New York.

In addition to these organizations, the New York State Department of Public Service (DPS)has oversight of utility reliability planning.  This covers traditional transmission & distribution investment planning and the utilities’ obligation to “reliably serve forecasted customer loads”.  There is a nuance to this that is not universally understood.  This process is used to ensure adequate transmission and distribution capability to serve customers but the production of the electricity itself is not included.  Instead, the wholesale market overseen by the NYISO provides the power.  This nuance is usually neglected in the projections of future resources.  If the market signals are not correct then New York could find itself without sufficient generating resources.  Their summary of reliability considerations makes many of the same points addressed in the NYSRC and NYISO as shown in the following slide.

Catastrophic Strategy

The ultimate problem for the Climate Act is that the general strategy is to electrify everything primarily using wind and solar means that a winter-time wind lull creates an energy resource challenge. Despite red flag warnings that the integration analysis has not adequately addressed the problem of simply providing enough electricity during those periods,  the Climate Action Council has not acknowledged the limitations of the integration analysis. 

In particular there is a significant reliability risk because a zero-emissions energy resource that can quickly ramp up or down upon demand is needed when the primary electric resources are from wind and solar.  In a presentation describing the 2021 -2030 Comprehensive Reliability Plan, one of the key points made is that “Dispatchable resources that are emissions-free, and on the scale needed, are not yet available or currently in the NYISO interconnection Queue”.  The integration analysis proposed technology for this resource is hydrogen but they offer no documentation why this technology should be trusted.  Based on my evaluation of available technologies,  I do not believe that hydrogen resources or any other technology is available at this time that is zero-emissions, able to come on line quickly and flexible enough to meet rapid and steep ramping requirements.

Severe winter weather in Texas in February 2021 caused at least 151 deaths, property damage of $18 billion, and higher costs of $50 billion for electricity over normal prices during the storm.  The ultimate cause for much of the impacts is that the Texas energy system could not produce enough electricity when it was needed most.  While the Texas system did not fail entirely because of a lack of wind and solar, the key point is that wind and solar were very low during the storm.  In order to prevent a similar problem in New York the system has to be designed to produce sufficient, reliable energy during similar conditions.  As noted above this does not seem to be the case and as a result, an energy debacle like Texas is inevitable.