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Environmental Justice campaign to replace New York City peaking power plants

Reposted from Dr. Judith Curry’s Climate Etc.

Posted on April 2, 2021 by curryja | 

by Roger Caiazza

Environmental justice organizations are at present a serious driver of environmental regulation in New York. A brand new report “The Fossil Fuel End Game, A frontline vision to retire New York City’s peaker plants by 2030” illustrates the campaign technique they’re utilizing to shut down peaking power plants in New York City.  Unfortunately their claims are primarily based extra on emotion than reality.


In the spring of 2020 Physicians, Scientists, and Engineers (PSE) for Healthy Energy launched a report Opportunities for Replacing Peaker Plants with Energy Storage in New York State.  The textual content for the New York particular report describes the alleged downside:

Across New York, 49 oil- and gas-fired peaker power plants and peaking models at bigger plants assist meet statewide peak electrical demand.  These embrace each combustion generators designed to ramp rapidly to meet peak demand, and growing older steam generators now used sometimes to meet peak wants. More than a 3rd of New York’s peaker plants burn primarily oil, and three-quarters are over 30 years previous leading to quite a few inefficient plants with excessive charges of greenhouse gasoline and standards pollutant emissions for each unit of electrical energy generated. Some of those plants are in very city areas: ten plants have greater than one million folks dwelling inside three miles. One-third of the plants are situated in areas the state considers to be environmental justice communities, the place weak populations sometimes already expertise excessive ranges of well being and environmental burdens. New York has set vitality storage targets and not too long ago designed peaker plant emission discount targets, offering a chance to replace inefficient, high-emitting peaker plants in weak communities all through the state with vitality storage and photo voltaic.

These findings had been picked up on by the New York City PEAK Coalition.  They launched a report in June 2020 entitled: “Dirty Energy, Big Money”.  Most not too long ago they adopted up with The Fossil Fuel End Game, a frontline imaginative and prescient to retire New York City’s peaking power plants by 2030.  The campaign is succeeding as a result of the New York Senate handed the Pollution Justice Act of 2021 on March 3, 2021 that mandates that the peaking power plants have to be retired in step with these experiences.

This campaign is deeply flawed from the get go.  The premise is fallacious as a result of peaking power plants are usually not inherently dangerous as a result of they supply important assist to the electrical system when wanted most and that would be the focus of this publish. The rationale is inaccurate that these peaking power plants are instantly affecting air high quality in adjoining environmental justice neighborhoods as a result of the well being impacts are claimed from secondary pollution that don’t type earlier than they’re transported away from the neighborhood.  Replacing all of the peaking plants in the time-frame as advised is extraordinarily dangerous as a result of the know-how accessible right this moment isn’t up to the duty.

In this publish I’m going to focus on the rationale for peaking power plants slightly than the holes within the environmental arguments in opposition to them.  For extra info on these features, I refer readers to posts on my weblog.   The first publish on the Peak Coalition report offered info on the first air high quality downside related to these services, the organizations behind the report, the State’s response to date, the underlying problem of environmental justice and addressed the motivation for the evaluation.  The second publish addressed the rationale and feasibility of the proposed plan relative to environmental results, affordability, and reliability.  I additionally mentioned the unique report Opportunities for Replacing Peaker Plants with Energy Storage in New York State doc that offered technical info utilized by the PEAK Coalition.  I  summarized all three of those technical posts in less complicated vogue.  I seemed on the traits of inhalable particulates in New York City relative to the claims of a dire well being risk.  Finally, I not too long ago wrote a publish on the Pollution Justice Act.

New York has carried out guidelines to replace the previous, inefficient and soiled combustion generators which can be an actual downside.  I consider it’s extra acceptable to permit the load-serving entities, mills, and system operators to contemplate alternate options and implement confirmed options which can be cost-effective and improve slightly than threat reliability with new alternate options till these alternate options have been absolutely vetted.

Blackouts and Peaking Power Plants

There is a protracted historical past of blackouts in New York City (NYC).  After a blackout in July 2019 AMNY printed a temporary historical past of blackouts in New York City.  In 1959 and 1961 surges in electrical use prompted blackouts and “The outage spurred changes to better protect the city’s power grid from future blackouts”.  The 1965 blackout was the primary regional blackout and was attributable to a transmission downside in Ontario inflicting a wave of disruptions within the transmission system.  Over 30 million folks and 80,000 sq. miles in Ontario, New York, Connecticut, Massachusetts, New Hampshire, New Jersey, Pennsylvania, Rhode Island, and Vermont had been left with out power for up to 13 hours. As a part of the response to that occasion New York arrange a power pool to handle electrical energy era and transmission. 

The over-arching problem for electrical energy reliability in New York City is geography.  Most of New York City is on islands so there’s a pure load pocket.  There was one other blackout in 1977 that was restricted to NYC instantly associated to the load pocket.  It was attributable to storms slicing off transmission into the City and in-City era being unable to replace the load.  Without adequate native power, protecting units flip off overloaded strains and transformers to forestall bodily injury to the gear and this led to the outages.  As a results of this blackout, reliability constraints had been carried out to be sure that when storms threaten transmission into the City that adequate in-City era is out there to forestall a re-occurrence.  In 2003 there was one other regional blackout attributable to a pc software program downside.  Grid operators recognized the trigger after which developed procedures to forestall it from occurring once more.  In 2012 tropical storm Sandy prompted large blackouts exacerbated by flood safety weaknesses.  Since then, there have been large investments to strengthen the infrastructure to forestall a reoccurrence. Note that after each blackout the electrical system homeowners and operators have developed methods to forestall a reoccurrence.

The New York State Reliability Council is an impartial entity “whose mission is to promote and preserve the reliability of electric service on the New York State Power System by developing, maintaining, and, from time-to-time, updating the Reliability Rules which shall be complied with by the New York Independent System Operator (“NYISO”) and all entities participating in electrical transmission, ancillary providers, vitality and power transactions on the New York State Power System”.   Among their guidelines that govern reliability are people who deal with the methods developed after these blackouts. It seems that that New York City’s peaking power plants are a part of these methods and are wanted to present further in-City era inside brief durations of time. 

Releasing the report lower than a month for the reason that Texas vitality debacle ought to give pause to the organizers of this campaign to contemplate the ramifications of what occurred there to New York reliability necessities.  While there have been experiences that dozens of deaths are tied to the storm in Texas, consultants say the demise toll is probably going far bigger. Just what number of gained’t be identified for weeks or months.  The blackouts price the state financial system upward of $130 billion in damages and losses, and a few individuals who did have power noticed their payments spike by hundreds of {dollars}. Grid operators say that the scenario may even have been quite a bit worse, with the system minutes away from a months lengthy blackout

Clearly the historical past of blackouts exhibits that they pose an infinite threat that needs to be averted if potential.

Fossil Fuel End Game Report

The report claims to be the “first detailed strategic and policy road map to retire and replace an entire city’s fossil-fuel peaker power plants”. It lays out a community-led technique to replace about half of New York City’s current fleet of polluting peaker plants with a mixture of offshore wind, distributed photo voltaic, vitality effectivity, and battery storage by 2025. They declare that the remaining peaker plants could possibly be reliably and cost-effectively changed with this mixture of assets by 2030.

In order to consider their alternate options, we want to perceive how they assume peaking plants are used. The report factors out that:

“Electricity from peaker plants is the most expensive energy resource in the system as it comes from centrally-located assets that are used infrequently but must be paid for and maintained to allow availability at times of peak demand. Central location, low utilization and the need for technologies that provide flexibility drive the costs of generation way above those from other energy assets.  For this reason, peaker owners charge for the electricity they produce, and more importantly, also charge for the availability of their resources during system peaks. Such availability is paid through the capacity market, designed to ensure that the system has enough capacity to provide energy during the times of highest energy demand. While NYC is not the only region with a capacity market, it has some of the highest capacity prices in the country. When capacity costs are averaged over the hours of operation, peaker electricity in New York City is up to 1,300% more expensive than the average cost of electricity in the rest of the state.”

It is irritating to me that the authors don’t acknowledge the worth of property that present power when it’s wanted most.  It can also be telling that Texas doesn’t have a capability market.  In order to guarantee power is out there each time it’s wanted ratepayers have to cowl the prices for that availability.  In that mild the comparatively low prices of Texas electrical energy don’t seem to be such deal now.

The report goes on:

Another issue that makes peaker vitality dearer than common is operational inefficiency attributable to technological limitations and distribution constraints. For instance, there are prices related to turning on and off sure producing property that lead plant managers to run them at uneconomic instances, driving up client prices and rising native emissions. From a market perspective, peakers are additionally referred to as to run uneconomically to guarantee native reliability. According to the state’s Market Monitor, Potomac Economics, supplemental dedication of NYC’s peakers happens ceaselessly to enhance the quantity of provide accessible in real-time for native load pocket reliability.  Those necessities be sure that there are sufficient assets to meet load in case of an issue such because the lack of the 2 largest Bulk Power System components supporting a specific load pocket, for instance, the lack of a number of central mills due to contingencies within the pure gasoline system. This supplemental dedication tends to undermine market incentives for effectively assembly reliability necessities and sometimes uplifts market costs, that are finally handed on to clients. Some of those prices could possibly be alleviated via market reforms or via deployment of contemporary inverter-based assets like locally-sited battery storage which may present invaluable working reserves in these load pockets. In 2019, NYC accounted for 87 % of the State’s whole reliability dedication.

These elements are outdoors my space of experience however it’s my understanding that many of those points are legacies from the swap from a regulated, vertically built-in utility to New York’s de-regulated market.  Consolidated Edison designed the era, transmission, and distribution system once they had been answerable for all three features of the system.  When the market was de-regulated possession of those property was not essentially chosen to guarantee operational effectivity.  Anecdotally I’ve heard from colleagues that it’s not clear how these models are dispatched so I think not less than a few of these criticisms have benefit.

The report acknowledges that “peakers play an important role in supporting reliable electric service for New Yorkers” and factors out that a few of them additionally “produce steam that feeds the city’s “district heating” system, offering warmth and cooling to many buildings in Manhattan”.  However, the report presents no suggestions how the steam system would get replaced with their really useful know-how.

The evaluation evaluates historic knowledge to develop a alternative plan: “More specifically, the peaker fleet was analyzed on a unit-by-unit, hourly basis using historic generation profiles as reported to the EPA for the years 2017, 2018 and 2019”.  Therein lies the an issue.  They argue that over these three years the total capability of the fleet of peakers in New York City has not been required to meet peaking wants in NYC however as a result of New York’s reliability guidelines are primarily based on lack of load expectation over ten years their timeframe is just too brief.

They additionally argue that “In 2018, the year with the most challenging peak, only 4,790 MW out of 6,200 MW (or about 77% of total peaking capacity) was ever used simultaneously. Moreover, more than half of the peaker fleet is rarely used simultaneously, in fact, this only happened during 44 hours of the year (0.5% of the time) and in very short event durations.”  They additionally analyze working traits. “An analysis of the peaker starts and run duration showed that many of the peakers run for relatively short durations that could be served by energy storage at competitive costs”.  As talked about earlier than, the brief length of their analysis interval makes these findings weak.  The short-comings of the NYC transmission and distribution system additionally have an effect on peaker operations and additional cut back the credibility of those findings.

The marketing consultant who did the work, Strategen, “used a 90th percentile approach on duration to determine the replacement needs of NYC fossil assets while taking in consideration five factors that would otherwise overestimate the reliability value of peakers in a traditional “longest peaker runtime” method. These embrace 1) peaker unit dispatch versus accessible zone stage capability, 2) peaker unit dispatch versus plant stage capability, 3) peaker unit dispatch for localized non-peaking wants, 3) inconsistent ranges of peaker output throughout longer-runtimes, and 5) unit operational constraints.” There is not any query in my thoughts that this method underneath estimates the worst case.  For heaven’s sakes they’re saying don’t fear about what occurs ten % of the time on the identical time they’re addressing peaking models that run lower than 5% of the time.

“Assuming a 90-percentile approach on unit duration to account for system characteristics and its reliability needs”, Stategen decided that “28 units with 765 MW of installed capacity have maximum durations of four hours or less, making them attractive candidates for replacement with storage even in a 1-to-1 basis”.  The proposed answer is alternative with vitality storage that has a cap on how lengthy power might be offered so it’s much less versatile, doesn’t contemplate that vitality storage discharge capacities are usually not 100%, and overlooks life expectancy of batteries two or thrice much less in contrast to a fossil generator.  There are 52 different peaking generators that ran for longer durations which solely exacerbates the constraints.  Finally, they suggest to replace 9 giant steam models, accounting for 3,882 MW or 64% of the overall fleet capability. These models “have maximum dispatch durations that go from 80 to 1,500 hours but are also the perfect example of over-dispatch driven by technology constraints”.  Those services definitely wouldn’t be purpose-built for his or her current function however they supply dispatchable, in-city power from small foot print services and may produce agency dispatchable power for very lengthy durations. 

Clean Energy Vision

According to the report’s overview: “The report lays out a plan for New York City focused on local, distributed solutions. This decentralized approach creates a more resilient power system than the current grid, which depends on centralized fossil-fuel power plants.”  The “Clean Energy Vision for New York City” is determined by 4 assets: offshore wind, group and residential photo voltaic, vitality effectivity and vitality storage.  I’ll deal with every beneath.

Despite the truth that there hasn’t been any offshore wind growth thus far, the imaginative and prescient counts on this useful resource and expects that it may be developed quicker than proposed.  New York State has a purpose to develop 9 GW of offshore wind by 2035.  I’ve not seen whether or not this useful resource will probably be thought of “in-city”.  If not and I’d argue that it isn’t, then it is a non-starter.  Because the State has solely authorized 4 tasks and wishes to develop infrastructure to assist constructing these tasks, I think that growth will take longer than proposed.

The report acknowledges that there are inherent difficulties siting photo voltaic in NYC: “New York City is afflicted with many of the canonical challenges that inhibit rooftop solar development including challenging local regulation, shared rooftop space, a significant population that rents, and aging buildings and electrical infrastructure”.   Because they declare there’s lots of worth in having it, they blithely assume that the obstacles might be overcome and assume that 5.4 GW of photo voltaic might be developed in NYC.

The evaluation depends on vitality effectivity to markedly cut back vitality use so as to cut back the vitality wanted throughout peak durations.  There is a complicating issue that I don’t assume they deal with.  New York’s local weather laws mandates electrification of every little thing to meet its 2050 zero-emissions purpose.  As a end result, heating and transportation may have to be electrified and all analysts agree that signifies that the annual peak load will shift from the summer season when photo voltaic can present significant power to winter when it can not. 

The largest downside I’ve is with their evaluation of vitality storage.  They used a linear vitality dispatch mannequin to decide how a lot storage is required to replace peaker plant era for his or her plan.  In their methodology “Energy storage was modeled to provide energy arbitrage services, that is, storing clean energy when it is produced but not used, and discharging it into the grid at times of need.”   Aside from the sensible matter that the amount of vitality storage requires vital house which could possibly be a difficulty within the crowded metropolis there are different considerations.  They solely used a single yr for the evaluation and there’s no suggestion that discharge capability limits had been thought of.  The evaluation doesn’t acknowledge that so as to replace fossil peakers two sorts of vitality storage are wanted.  Longer-duration storage wants to cowl, for instance, night time time for photo voltaic assets.  That seems to be the storage addressed.  However, fossil-fired combustion generators used for peaking function at fastened masses however photo voltaic assets, for instance fluctuate if it’s a partly cloudy day.  Therefore, vitality assets are wanted for this short-term variation.  But that’s not all.  Fossil models additionally present ancillary providers comparable to frequency management.  The level is that they didn’t calculate how a lot vitality storage has to be allotted for these different providers.

There is one other flaw on this method.  They seemed on the traits of vitality load and the way peaking models offered that vitality and proposed an answer primarily based on off-shore wind and photo voltaic assets assuming that these assets could be accessible.  I’ve argued that one of many largest shortcomings in New York’s implementation course of is that haven’t but performed an analysis of the provision of wind and photo voltaic on the identical time over a protracted interval.  To date the first planning downside has all the time been the height load however it’s conceivable that the larger downside for a future grid reliant upon wind and photo voltaic will probably be low coincidental useful resource availability.  However, as a result of the height masses are related to the coldest and hottest climate and people durations are related to excessive strain system with mild winds, it’s seemingly that low renewable useful resource availability will probably be worst when it’s wanted most.  In any occasion, the Strategen evaluation didn’t contemplate useful resource availability in any respect.


Even although there are different shortcomings within the evaluation, this publish is just too lengthy so I’ll wrap it up.  At this time, environmental justice group are conducting a well-orchestrated effort to replace peaking power plants in New York City.  New York vitality and environmental coverage initiatives are catering to these organizations and the New York Senate has even handed a legislation codifying the method proposed.   I think that this method will turn into evident on the nationwide stage quickly.

There are many inherent benefits to fossil-fired power plants.   In the New York City context, they supply dependable power when wanted from comparatively small footprints and are a key element to the reliability requirements developed from arduous expertise.  Unfortunately, the arguments to replace them are primarily based extra on emotion than reality and appear to be pushed by the urge to remove one over hyped threat whereas ignoring the unintended penalties of their options which can create different dangers that would trigger larger issues.  

In my opinion, it’s notably troubling that the issue of peaking power plants has already being addressed.  Last summer season New York promulgated guidelines to replace the previous, inefficient and soiled combustion generators which can be an actual downside.  This examine and others develop the definition of peaking power plants to different models that can not be changed simply.  I believe that the organizations behind this report are unwilling to settle for any perceived dangers from new environment friendly and clear fossil producing plants partially primarily based on the naïve perception that renewable options are solely a matter of political will.  Given that political coverage choices performed a hand within the current Texas vitality debacle, I believe that may be a harmful path to take.


Roger Caiazza blogs on New York vitality and environmental points at Pragmatic Environmentalist of New York.  This represents his opinion and never the opinion of any of his earlier employers or another firm with which he has been related.

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