Biased NGOs Such as the PEAK Coalition Attract Political Attention But Know NOTHING About Energy Security

Guest Post by Roger Caiazza of Pragmatic Environmentalist of New York.

In my post about the implications of the Moss Landing Battery Plant fire, I discussed the implications of the fire on the proposal by the PEAK Coalition to the shutdown of New York City peaking power plants. I also quoted comments made at their webinar entitled “Replacing NYC’s Peaker Plants with Clean Alternatives: Progress, Barriers, and Pathways Forward”. The subject of this post is one of the comments made at the webinar that illustrates the gulf between the emotion-driven ideologues who make are responsible for these proposals and reality.

Overview

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.

I have prepared a summary of this issue that explains why 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. The page documents my concerns based on my background in air pollution control theory, implementation, and evaluation over my 45+ year career as an air pollution meteorologist and extensive personal experience with peaking power plants and their role during high energy demand days.

Reality Disconnect

The Peak Coalition webinar entitled “Replacing NYC’s Peaker Plants with Clean Alternatives: Progress, Barriers, and Pathways Forward” included a presentation by Megan Carr, Skadden Fellow – Environmental Justice Program, New York Lawyers for the Public Interest. She talked about regulatory barriers for battery storage. She claimed the current grid is not reliable:

When we talk about reliability concerns, we also have to remember that our current grid is not reliable. Having over 70% of our downstate energy generated by fossil fuels that we’re buying on a volatile global market that’s subject to price spikes is not actually reliable. When we’re talking about uncertain economics, the cost of peak electricity in New York City is 1300% higher than the average cost of other electricity in the state. Those are not reasonable economics. That means there are over 600,000 New Yorkers paying over 6% of their annual income in energy payments. That is untenable. Most importantly as Sebastian and Victor already touched on, it is unacceptable because it requires that some of our communities are sacrificed and regularly exposed to harmful air quality which has devastating health effects.

Her interpretation of reliability is absurd. It is what you would expect from an environmental justice lawyer who received her master’s degree in childhood education from Canisius College, and her B.A. from Kenyon College. There certainly is a link between keeping the lights on and being able to afford to turn on the lights. However, connecting fuel costs to reliability shows just how weak advocate arguments concerning reliability really are.

Wind, solar, and energy storage advocates like the New Yorkers for Clean Power who want to “rapidly shift to an equitable clean energy economy” acknowledge that reliability is a real issue.

At a webinar titled “Get Charged Up for the New York Energy Plan” Janet Joseph is a former employee at the New York State Energy Research & Development Authority (NYSERDA) who managed work associated with the Climate Act Scoping Plan.

She correctly recognized that reliability and affordability are real issues for the proposed wind and solar reliant electric grid and must be addressed. She said that “the advocacy community must be armed to fight that battle and address the impact on reliability and affordability as best you can.”

Reliability Reality

The Peak Coalition does not acknowledge the reliability challenges of the electric grid, which I think is because they do not understand the system. More importantly they dismiss the enormous reliability risks of an electric grid relying on weather-dependent generators backed up by energy storage resources. I talked about my fears of such a system in this post and later I refined my concerns noting that it boils down to “correlated intermittency”.

Wind and solar are inherently intermittent – the sun does not shine at night and the wind does not always blow. That intermittency is correlated. All the solar in New York is unavailable at night. It turns out that wind resources across New York also are usually high or low at the same time.

There are exceptions but there is a high incidence of similar behavior. That matters for electric resource planning. Today electric resource planning relies on decades of performance experience with hydro, nuclear, and fossil plants that do not correlate, there is no reason to expect that all the nuclear plants will be offline at the same time.

The variation in weather that affects wind and solar resource availability will require changes to electric resource planning. It will be necessary to develop weather dependent probabilistic energy production estimates.

The unresolved problem is what return period probability is acceptable. If the resource planning process does not provide sufficient backup resources to provide capacity for a future peak load period that occurs when wind and solar resources are low, then blackouts are inevitable. Two factors exacerbate the challenge of this problem:

1. The periods of highest load are associated with the hottest and coldest times of the year and frequently correspond to the periods of lowest wind resource availability.

2. The decarbonization strategy is to electrify everything possible so peak loads will be larger and the impacts of a peak load blackout during the coldest and hottest periods will be greater.

The New York Independent System Operator 2024 Reliability Needs Assessment identified reliability risks. Risks have also been identified by the North American Electric Reliability Corporation.

Both have expressed concerns that extreme weather events, rapid demand growth, and systemic vulnerabilities pose risks for supply shortfalls and grid reliability. In a rational world these reliability issues would be at the forefront of New York energy policy and a complete feasibility analysis would be completed before the state proceeds with a wind, solar, and energy storage grid. Sadly, New York is not rational.

Advocacy Reliability

In the absence of anything rational to address the impact on reliability and affordability the supporters of the Climate Act are left with argument that volatile global markets affect fossil fuel prices so much that it is not affordable. I see no way that has anything to do with reliability.

The volatile fuel prices affecting electric affordability argument came up at last month’s New York Assembly Committee on Energy hearing addressing NYSERDA’s revenues and expenditures effectiveness.

Jessica Waldorf, Chief of Staff & Director of Policy Implementation, New York State Department of Public Service said that there are reasons “to build renewable energy resources in New York that are not just related to emissions.” She gave two reasons: energy security and price volatility. Waldorf’s explanation of energy security mentioned “localizing energy production here”. She went on to state:

The other thing I would say about energy security is price volatility. Customers are beholden to the winds of the fossil fuel industry and the up and down markets that we see from fossil fuels. Localizing our energy production and renewables allows us for price stability. That is definitely a benefit of building resources here.

In a post describing this testimony I noted that at first glance, the price volatility argument is persuasive because we have all experienced the impact of increased fuel costs in recent memory. However, in the last two months the European electric market has shown what happens when an electric system becomes overly dependent upon wind and solar:

From November 2 to November 8 and from December 10 to December 13, Germany’s electricity supply from renewable energies collapsed as a typical winter weather situation with a lull in the wind and minimal solar irradiation led to supply shortages, high electricity imports and skyrocketing electricity prices.

The electric transmission connections to other countries raised prices elsewhere when German wind and solar failed to provide sufficient energy. Prof. Fritz Vahrenholt says they went up so much in Norway that the energy minister “wants to cut the power cable to Denmark and renegotiate the electricity contracts with Germany.”

Swedish Energy Minister Ebba Busch stated: “It is difficult for an industrial economy to rely on the benevolence of the weather gods for its prosperity.” He went on to respond directly to Habeck’s green policy: “No political will is strong enough to override the laws of physics – not even Mr. Habeck’s.”

There is no question that the same thing will happen in New York. Note that the technologies proposed as backup for extended periods of low wind and solar resource availability are expected to operate even less than the peaking power plants have operated historically.

Those resources will have to be paid very high rates during those hours to be economically viable. High spot prices is one of the problems identified by the Peak Coalition to vilify peaking power plants. The price volatility argument that Megan Carr claims causes reliability issues will be a more pronounced feature of the system she advocates.

It is also notable that responsible New York agencies all agree that new Dispatchable Emissions-Free Resource technologies are needed to make a solar and wind-reliant electric energy system work reliably during extended periods of low wind and solar resource availability. No one knows what those technologies are.

Greenhouse Gas Initiative Operating Plan Advisory Stakeholder meeting held on December 5, 2024 NYSERDA Staff mentioned that they were working with the Department of Public Service to start a five-year plan to address DEFR. The NYSERDA projections for renewable energy and the New York Independent System Operator (NYISO) projections do not anticipate deployment of DEFR starting before 2035.

However, those analyses also assume that existing generators in New York City do not retire as the Peak Coalition recommends.

Comments submitted by NYISO on the DPS zero emissions proceeding warned:

Electric system reliability margins are already close to minimum reliability requirements in certain areas across New York and are tightening. If these margins are totally depleted, the reliability of the grid would be at an unacceptable risk and power outages could disrupt normal life or negatively impact public health, welfare, and safety.

I believe the most likely reason New York City reliability will degrade would be implementation of Peak Coalition recommendations.

Conclusion

I have never been impressed with the technical background and experience of the ideologues who represent the Peak Coalition. This is exemplified by baseless claims that “We also have to remember that our current grid is not reliable” and “Having over 70% of our downstate energy generated by fossil fuels that we’re buying on a volatile global market that’s subject to price spikes is not actually reliable.”

If the system was not reliable then blackouts would be common. They are not. Fuel prices affect affordability but there is no link to reliability. That biased organizations like this catch the attention of politicians and affect New York policy is a sad commentary on New York energy policy.

#Caiazza #Climate #PeakCoalition #Reliability #ClimateAct #NewYork

Roger Caiazza blogs on New York energy and environmental issues at Pragmatic Environmentalist of New York.  This post represents his opinion alone and not the opinion of his previous employers or any other company with which he has been associated. Roger has followed the Climate Leadership & Community Protection Act (Climate Act) since it was first proposed, submitted comments on the Climate Act implementation plan, and has written over 490 articles about New York’s net-zero transition.