The PEAK coalition has stated that “Fossil peaker plants in New York City are perhaps the most egregious energy-related example of what environmental injustice means today.” The influence of this position on current New York State environmental policy has led to this issue finding its way into multiple environmental initiatives. However, the presumption of egregious harm is based on selective choice of metrics, poor understanding of air quality health impacts, and ignorance of air quality trends. This page documents my concerns based on my extensive experience with air pollution control theory, implementation, and evaluation over my 45+ year career.
Caveat: There is no question that disadvantaged communities suffer disproportionate environmental impacts but it is important to understand what causes the harms and balance expectations and potential solutions. This page provides my explanation why the concerns about fossil peaker plants are misguided. Moreover, there is no currently available technology that has been proven at the scale necessary that can replace fossil-fired generation in New York City safely, reliably, and affordably. If safety, reliability, and affordability are not prioritized, then it could easily result in an electric system that does not maintain current standards. More importantly, problems associated with them impact disadvantaged communities more than other communities so those concerns must be considered when decisions are made about peaking power plants.
Peaker Power Plant Articles
I have written multiple articles about peaking power plants and alleged health impacts of these facilities in response to opinion pieces, reports, and policy proposals
I believe that the PEAK Coalition report entitled: “Dirty Energy, Big Money” is the reason that environmental justice organizations vilify all New York City peaking power plants. I have 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.
A post describing my comments on the New York State Department of Environmental Conservation (DEC) decision to deny the NRG Astoria Gas Turbine Power Replacement Project Title V Permit Application summarizes issues and implications of premature retirements.
In February 2023 I wrote an article about the risks of the zero-risk philosophy of environmental justice advocates who vilify peaking power plants. However noble the concept of eliminating any risks from any source of pollution, if it is construed to mean that anything that might be contributing to bad health must be prohibited, then society basically cannot function. Peaking power plant issues were discussed as an example of this problem in the article. The over-arching concern in this article is that the Environmental Rights Amendment to the New York constitution will inevitably set a high hurdle for permitting a new facility or keeping an existing source in operation. The amendment states: “Each person shall have a right to clean air and water, and to a healthful environment.” It is likely that a debate about what constitutes clean air will ensue for every permit application.
Air Quality and Health Metrics
The Clean Air Act established the primary metric to protect human health and welfare codified in a scientifically-based regulatory program. The National Ambient Air Quality Standards (NAAQS) “provide public health protection, including protecting the health of ‘sensitive’ populations such as asthmatics, children, and the elderly”. My air pollution meteorology career is based on the presumption that air quality that meets the NAAQS is acceptable.
Over my career air quality has improved markedly. The Environmental Protection Agency keeps track of air quality trends in the country. The following graph shows air pollution concentration averages.
There is no graph available for the Northeastern US but the data show similar decreases.
For the most part New York air quality reflects national and regional trends. According to the EPA nonattainment/maintenance status summary, there are multiple counties In New York that do not attain the NAAQS for ozone and New York County does not meet the coarse particulate matter standard. Note that all of New York State meets the inhalable particulate (PM2.5) NAAQS. All the other pollutants are in attainment.
Despite the fact that there have been significant improvements and New York is mostly in attainment with the NAAQS there is another approach to air quality health impacts that regulators and activists have used to claim more reductions are necessary.
Even though New York City is in attainment for inhalable particulates, this pollutant is used as a rationale for shutting down peaking power plants because of claims that reducing inhalable air quality impacts is beneficial. For example, the New York City Department of Health and Mental Hygiene’s (DOHMH) Air Pollution and the Health of New Yorkers report is often referenced in this regard. The DOHMOH report concludes: “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 inhalable particulate pollution levels in New York City over the period 2005-2007 of 13.9 µg/m3.
In my comments on the Draft Scoping Plan I explained that the following paragraph from Scoping Plan Appendix G: Section II summarizes the fundamental assumption for these health impacts:
Nevertheless, the health impact functions included in COBRA were developed from a specific population exposed to specific levels and compositions of PM2.5, and conditions in NYS have changed since these functions were developed. For example, the health impact function from the Krewski study was based on examining mortality impacts from 500,000 people in 116 U.S. cities between 1980 and 2000. The levels and compositions of PM2.5 have decreased substantially since 2000, as discussed above, with sharp declines in ammonium sulfate, making ammonium nitrate and secondary organic aerosols relatively more important components of PM2.5 However, the synthesis of the research into PM2.5 impacts on public health conducted for EPA’s draft Integrated Science Assessment for Particulate Matter indicates that the literature provides evidence that the health impact functions may be linear with no threshold below which reductions in exposure to PM2.5 provides no benefits. In other words, even though PM2.5 concentrations have been reduced in NYS in the time since the health impact functions were developed, the evidence suggests that the functions can adequately estimate changes in health impacts even at relatively low levels of PM2.5 Similarly, EPA’s draft Integrated Science Assessment finds that the literature is unclear as to whether changes in the composition of secondary PM2.5 species results in differential changes to health impacts. For this reason, this health analysis, along with most other similar benefits analyses, uses the total change in PM2.5 concentrations to evaluate health impacts rather than looking separately at impacts by the different PM2.5 species.
In brief, the Scoping Plan air quality health assessment depends on a linear no-threshold model. Originally used for radiation assessment, it suggests that each time radiation is deposited in the susceptible target there is a probability of tumor initiation. Note, however, that its use in radiation assessment is controversial.
It is important to note that these relationships are not Clean Air Act mandates despite the fact that they are used constantly to justify further emission reductions. Furthermore, their use in air quality assessments is also controversial. The epidemiological data used by the Environmental Protection Agency have never been independently reviewed and another health impact study of all deaths in California between the years 2000 to 2012 (more than 2 million) reported no correlation between PM2.5 and death. Furthermore, I also submitted comments on the Draft Scoping Plan where I showed that the 2018-2020 average PM2.5 concentration was 7.4 µg/m3 which is substantially lower than the DOHMOH goal of 10.9 µg/m3. If the epidemiological linear no-threshold model is correct, then because inhalable particulate levels have come down uniformly across the country then there should be significant observed health benefits across the country and in New York City. DOHMOH has not verified their projections against observations. Until such time that the projected health impacts using this approach are validated with observed data, I will be skeptical of this metric.
Air Quality Impacts of Peaking Power Plants
Even if you accept the inhalable particulate health benefit premise, I don’t think that the arguments made in Dirty Energy, Big Money make a convincing case that the peaking power plants are the primary driver of air quality environmental burdens on neighboring communities. The ultimate problem with this approach is that the argument relies on environmental burdens from ozone and particulate matter air quality impacts. However, ozone is a secondary air pollutant and the vast majority of ambient PM2.5 from power plants is also a secondary pollutant. As a result, there is a lag between the time emissions are released and creation of either ozone or PM2.5. By the time the precursor pollutants convert to ozone or PM2.5 they have moved out of the neighborhood. That means that the peaking power plants do not contribute to the air quality impact problems alleged to occur to the environmental justice communities located near the plants. In fact, because NOx scavenges ozone the peaker plants reduce local ozone if they have any effect at all.
The alleged effects of peaking power plants also is a consideration in the Climate Leadership & Community Protection Act. Chapter 6. Advancing Climate Justice in the Final Scoping Plan states:
Prioritizing emissions reduction in Disadvantaged Communities should help to prevent the formation or co-pollutant emissions despite a reduction in emissions statewide. A broad range of factors may contribute to high concentrations of pollutants in a given location that create a hotspot. The result can be unhealthy air quality, particularly for sensitive populations such as expectant mothers, children, the elderly, people of low socio-economic status, and people with pre-existing medical conditions.
This contention is based on the arguments in Dirty Energy, Big Money. I have seen indications that there are people who believe that GHG emissions themselves have some kind of air quality impact exacerbated in disadvantaged community hot spots. That is simply wrong – there are no health impacts associated with carbon dioxide emissions at current observed ambient levels. Dirty Energy, Big Money and the Scoping Plan arguments are based on co-pollutant emissions (NOx and PM2.5) that allegedly cause impactful hot spots that result in unhealthy air quality. Note that all facilities in New York State have done analyses that prove that any locations with higher concentrations in the vicinity of power plants do not contravene the NAAQS. Trying to make the cap and invest program, that is appropriate for controlling GHG emissions to mitigate global warming, also address a neighborhood air quality problem already covered by other air quality rules is not in the best interests of a successful cap and invest program.
The argument that peaking power plants are a source of egregious harm to disadvantaged communities is based on selective choice of metrics, poor understanding of air quality health impacts, unsubstantiated health impact analysis, and ignorance of air quality trends.
I maintain that the appropriate metric for determining the impact to human health and welfare is the NAAQS process. Using a linear no-threshold model approach is not an appropriate metric for permitting decisions related to peaking power plants. Appeasing activists who demand zero-risks ultimately means that no emissions will be allowed and that will shut down society.
The argument that peaking power plants affect neighborhoods as portrayed is flawed. The air pollutants that are alleged to be the cause of a significant health impacts in disadvantaged communities near peaking plants are the secondary pollutants ozone and PM2.5. Because it takes time for the conversion from precursor pollutants, they are unlikely to affect adjacent neighborhoods simply because they are blown downwind during the conversion phase.
Inhalable particulates (PM2.5) are frequently cited as the primary cause of health impacts but independent studies offer contrary results. Taken to the ultimate level this concern would ban camp fires. When the wind shifts and the smoke blows towards a camper, they got a dose of inhalable particulates. If one person stays in the smoke for days, then there will be a health impact. On the other hand the campers that sit around a campfire and get a dose of smoke several times a year get much less of a health effect. The linear no-threshold approach gets its estimates of health impacts by multiplying low health impacts by many people. In this case if there are a million campers and if the impact is one millionth of the impact to the guy who stayed in the smoke for days, then it is presumed that one out of a million people would get sick the same way.
The biggest flaw in the argument is that activists argue that the health-related impacts are increasing at the same time that PM2.5 concentrations in the atmosphere are decreasing. All the air quality trends are going down. If proponents can show that there have been substantial benefits associated with the observed concentration reductions then I might be more sympathetic to the arguments.
At some point New York State regulators are going to have to step and be the adults in the room. It is entirely proper to consider environmental justice considerations in disadvantaged communities. However, that consideration cannot be the final word on the continued operation of peaking power plants. This overt deference to environmental justice concerns could easily lead to impacts on the reliability, affordability, and safety of the electric grid. If problems ensue the communities that will be impacted the most will be the ones this mis-guided deference is intended to protect.