National Grid Is Risking Blackouts and the Lives of Its Customers by Playing Along with New York's Risky Climate Plans
Guest Post by Roger Caiazza of Pragmatic Environmentalist of New York.
The New York Climate Leadership & Community Protection Act (Climate Act) net zero transition has unleashed an avalanche of Public Service Commission (PSC) proceedings. I submitted comments on Case 24-G-0248 Review of the Long-Term Gas System Plan for National Grid because they provide the natural gas I use for heating, cooking hot water, and my backup generator.
There are so many issues coming up with the schedule and ambition of the Climate Act that it is obvious we need to pause implementation and figure out how best to proceed. The National Grid Long-Term Plan (“LT Plan”) is a perfect example of a component that should be paused.
I submitted comments on the LT Plan as a National Grid customer who relies on natural gas to provide affordable, reliable and resilient energy to my home. My comments showed that there is insufficient consideration of the enormous challenge of the Climate Act transition to a zero-emissions energy system in the LT Plan. I also included a technical comment on the incorrect calculation of the societal cost calculation of avoided GHG emissions.
Safety Valve Criteria
It is premature to implement the transition plan outlined in the LT Plan until metrics for affordability and reliability are established. The LT Plan does not acknowledge the safety valve requirements in New York Public Service Law § 66-p (4), “Establishment of a renewable energy program.” It 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”.
As part of the Scoping Plan process, the Climate Action Council should have developed criteria for the Public Service Law affordability and reliability mandates in Public Service Law Section 66-p (4).
That did not happen, so it is incumbent upon the Commission to define “safe and adequate electric service” and “significant increase in arrears or service disconnections” before the LT Plan is implemented. It is irresponsible to begin replacing the existing resilient, reliable, and affordable natural gas system without assurances that New York has a viable zero-emissions electric system transition plan.
Reliability
I am particularly concerned about reliability. I moved to Liverpool, NY in June 1981 and lived through two extended electricity outages: the Labor Day storm of 1998 and an ice storm in April 2003. I have never had a natural gas outage since 1981. As I write this there are still electric over 3,000 customers in Michigan in the dark after an ice storm 17 days ago.
Keeping the heat on in cold weather is a life and death requirement, and natural gas is a resilient resource. During our ice storm I relied on the natural gas-fired furnace, stove, and hot water, using a portable generator to provide power. Because of this concern, I have installed a whole-house generator so I can survive when another ice storm inevitably occurs.
The LT Plan does not mention that the replacement of natural gas with electric systems will be viable only if the electric system is reliable. As noted above, there are electricity deliverability issues associated with extreme weather events that are not present with natural gas delivery.
The biggest unacknowledged reliability risk associated with the glacial pace of agency progress is addressed in Case 15-E-0302 – “Proceeding on Motion of the Commission to Implement a Large-Scale Renewable Program and Clean Energy Standard.”
New York agencies all agree new Dispatchable Emissions-Free Resource (DEFR) technologies are needed to make a solar and wind-reliant electric energy system viable during extended periods of low wind and solar resource availability. Case 15-E-0302 is supposed to address this technology because no such technology is currently available.
I believe the only likely viable DEFR backup technology is nuclear generation despite its shortcomings because it is the only candidate resource that is technologically ready, can be expanded as needed, and does not suffer from limitations of the Second Law of Thermodynamics.
My comments described inherent weather variability planning risks associated with non-nuclear DEFR technology that is problematic as long as New York continues to champion an electric system dependent upon wind and solar resources. It is necessary to determine how much DEFR capacity is needed for wind and solar resource lulls using as long record of weather data as possible.
That has not been done, and there is nothing in place for it yet, but analyses done to date suggest resource capacity equivalent to existing fossil resources will be needed. I used information from my recent post on the assessment of extreme renewable resource lulls to comment on other issues needing to be resolved before the LT Plan is implemented.
Affordability
One advantage of developing comments is that I can use my articles as source material. In this instance, my comments raised affordability issues included in a recently submitted a letter in relation to Public Service Commission (PSC) Proceeding 22-M-0149 “Assessing Implementation of and Compliance with the Requirements and Targets of the Climate Leadership and Community Protection Act.” THese regarded an affordability standard. I described them in this post.
I did some original work for my comments about costs. It was a holy crap moment when I found the projected costs in the LT Plan for three scenarios. The scenarios include a reference case, CEV or “clean energy vision”, and AE or “accelerated electrification.”
The 2030 average monthly increase for National Grid customers in the former Niagara Mohawk service territory ranges from a 50% increase to a 96% increase. The 2030 average monthly increase for National Grid customers in the former Brooklyn Union Gas service territory ranges from a 65% increase to a 148% increase. The 2030 average monthly increase for National Grid customers in the former Key Span service territory on Long Island ranges from a 41% increase to a 90% increase.
It is inconceivable that those costs, when combined with similar increases in electric costs, will not result in a significant increase in arrears or service disconnections exceeding the Public Service Law Section 66-p (4) safety valve. It is long overdue for National Grid and the PSC to acknowledge these costs to ratepayers and for the PSC recognize that its mission to ensure “affordable, safe, secure, and reliable access” to electric and gas services is incompatible with the Climate Act mandates.
The DEFR requirement and weather variability risk described in the previous section also have affordability implications. Until a DEFR strategy is proposed, we have no idea how much this will all cost, so any claims the Climate Act will be “affordable” are incomplete.
Because any DEFR backup resource will be used so little and will be so expensive, there will be inevitable tradeoff considerations for the rarely used backup resource. The result will be pressure to minimize the costs associated with DEFR backup capacity, which will increase the probability of a catastrophic blackout. If natural gas has been shut off, the blackout effects will be exacerbated.
Societal Cost Test (“SCT”)
I also included a technical comment on the incorrect calculation of the societal cost calculation of avoided GHG emissions.
I believe the SCT methodology over-estimates the benefits of the societal impacts of greenhouse gas emissions. As far as I can tell, the National Grid Long-Term Gas System Plan report calculates the societal benefits based on avoided emissions. I believe the reference to “avoided” emissions means that the emission reductions for the different scenarios are accumulated out to a specific date.
I also evaluated the latest NYS GJG emissions inventoryand found that the New York State total GHG emissions from the buildings and industry sectors were 84.5 million metric tons in 2021. In that year the NYSERDA Patterns and Trends report showed that National Grid sold roughly half the natural gas in New York.
Based on that I assume National Grid emitted 42.2 million metric tons in 2021. Table 8-8: GHG Emissions Reductions by Scenario and Operating Company in the LT Report lists emissions ranging from 223.8 to 1,239 million metric tons which far exceeds the observed 2021 emissions.
Calculations of avoided emissions benefits consider reductions over some time frame. It is inappropriate to claim the benefits of an annual reduction of a ton of greenhouse gas over any lifetime or to compare it with lifetime avoided emissions. The value of a GHG emission reduction is based on all the damage predicted to occur from the year that the ton of carbon is reduced out to 2300. The correct societal benefit can be no more than the current GHG emissions times the social cost of carbon.
Clearly, using cumulative values for this parameter is incorrect because it counts those values over and over. That is equivalent to me saying I lost 25 pounds because I lost 5 pounds five years ago and kept it off. I contacted social cost of carbon expert Dr. Richard Tol about my interpretation of the use of lifetime savings and he confirmed “The SCC should not be compared to life-time savings or life-time costs (unless the project life is one year).”
Conclusion
National Grid has developed a long-term plan to replace natural gas with electricity. The projected costs are enormous, and the benefits are overstated. The plan does not acknowledge that this is a safe and viable approach only if the future electric system is reliable.
The feasibility of a reliable electric system that relies on wind and solar has not been proven. The Scoping Plan zero emissions electric system needs a new resource, we don’t know how much of that resource is needed, what it will be, or how much it will cost.
I concluded that it is imprudent for the Commission and National Grid to continue this long-term plan to eliminate natural gas until the affordability and reliability mandates in Public Service Law Section 66-p (4) are defined and evaluated.
I have no doubts the mandated evaluation will find the Climate Act impedes the provision of safe and adequate electric service. It will cause a significant increase in arrears or service disconnections and result in suspension or modification of the Climate Act mandates, including the long-term shutdown of the natural gas system.
It is, therefore, irresponsible to begin the replacement of the existing resilient, reliable, and affordable natural gas system until New York has a viable zero-emissions electric system available. The LT Plan should acknowledge this prerequisite to implementation.
Conclusion
The Scoping Plan zero emissions electric system needs a new resource, we don’t know how much of that resource is needed, what it will be, or how much it will cost, and whatever we do eventually, it won’t be enough. People will die in a catastrophic blackout.
It is imprudent for the Commission and National Grid to continue this long-term plan to eliminate natural gas until the affordability and reliability mandates in Public Service Law Section 66-p (4) are defined and evaluated.
#NaturalGas #Caiazza #Climate #NewYork #ClimateAct #EnergySecurity #Blackouts #ZeroEmissions
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 500 articles about New York’s net-zero transition.
Absolute delight to read Roger’s well written and logical case against the implementation of a transition plan that takes from reliable, affordable and resilient to intermittent, unaffordable and dangerous. No gas and no DEFR is a lethal combination.
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