The following is a contributed article by Arnold R. Wallenstein, a Boston-based attorney who represents independent power producers in New York and other states and is the principal member of The Energy Law Group.
The New York Department of Environmental Conservation (DEC) on Oct. 27 denied required Clean Air Act permits for two proposed state-of-the-art natural-gas-fired power plants (Danskammer and Astoria) on the basis that they would emit "greenhouse gases”, i.e., carbon dioxide, and would not contribute to the reduction of fossil-powered generation in New York, both in violation of the state's Climate Leadership and Community Protection Act passed in 2019. The DEC also stated that the plants simply would not be needed by 2030 because of the state's commitment to using renewable energy sources, particularly solar and wind, causing new fossil-fired generation to be unnecessary.
Dancing in the dark?
Activists are doing victory dances now, but in future years, they may be dancing in the cold and dark if New York continues to ban dispatchable generation that can be activated on-command during extended low solar and low wind periods, especially during certain peak load periods in the winter.
Why this devastating result from what seems like an appropriate response to climate change? New York state has legislated that electricity generation in the state emit zero carbon by 2040. But this zero carbon emission goal can't be accomplished only with solar, wind and batteries. Studies prepared for New York's grid operator, NYISO, indicate that reliance solely on solar, wind and some battery storage may cause New York to run short of the electricity it needs to power homes and its economy on or before the statutory 2040 zero emission/fossil fuel generation shut down date, euphemistically called the “resource gap.”
Studies done for NYISO also show that the size of the New York electrical load may triple by 2040 to 150,000 MW due to electrification of automobiles and conversion of buildings to electric heat. NYISO's prognosticators also predict about 32,000 MW of "dispatchable" power — power that can be generated on command and not solar and wind — will be needed in 2040, almost equivalent to New York's current 38 GW of grid generating capacity. NYISO estimates that about 10% of generation needs in 2040 will have to be met by dispatchable emission-free resources.
During certain peak periods in 2040, studies done for NYISO show that zero emission dispatchable resources other than solar and wind would be needed to provide 59% of energy demand in New York even after massive renewable energy investments in the state. But you can't generate these tens of thousands of megawatts of electricity from solar or wind resources when it is dark, cloudy or during an extended storm, and wind turbines can't be ordered to spin when there is low or no wind.
So what happens when the grid operator calls for more power in 2040 and solar and wind can't generate and battery storage is exhausted? New York will experience brownouts and blackouts at the coldest and darkest times of the day or night. The state will have to import power from neighboring states or Canada — undoubtedly at very high prices — that's even if New York's neighbors have any power to spare, because they will also likely be experiencing higher electrical demand and lower renewable generation at the same time.
How can New York illuminate a way forward?
What should the state do to avoid this impending energy cliff? It will take decades of realistic planning, regulation and public investment to build an electric generation system that is primarily powered by renewable energy. But the state must also permit and mandate that the energy industry also build enough "dispatchable" zero carbon emission generation — approximately 32,000 MW — that can be tapped when the sun doesn't shine and the wind doesn't blow and the limited battery storage is exhausted.
Nuclear power is a good fit for zero emission dispatchable power, but most, if not all, nuclear plants in New York will probably be retired by 2040. Hydropower is renewable, but there is no significant new hydropower generation that could be built in New York. Natural gas-fired facilities are dispatchable and very clean and efficient, but the state has ordered their shut down by 2040 and refuses to permit any new natural-gas fired plants, whether they are peaker or baseload combined cycle plants.
Green hydrogen to the rescue
The only viable answer at this time to fill the electric reliability hole that New York policymakers are digging is the conversion of existing and new state of the art natural gas-fired generation plants to use "green hydrogen" whereby electrolysis of water, driven by renewable energy, is used to break up the H2O molecules of water into H2 and O. Since there is no carbon in hydrogen, it is the best candidate for a fuel that can run in dispatchable power generation facilities and help achieve the state's goal of zero carbon emissions from power generation.
The renewable energy used to power electrolysis could come from wind energy resources operating at night and other off-peak periods when their power is not needed and their prices are very low, keeping hydrogen production costs low.
The green hydrogen can be stored, trucked or piped to converted natural gas-fired power plants which can be turned on to generate on command when solar and wind facilities are down due to weather, darkness or low wind conditions.
Some natural gas-fueled generation facilities in New York have already started test burns using hydrogen. Eventually, these clean and highly efficient state of the art natural gas facilities may be able to use green hydrogen as their primary fuel source. The NY DEC decisions on the proposed Astoria and Danskammer plants deemed use of hydrogen as a fuel as uncertain and speculative, but in fact private industry in New York is rising to the challenge of converting their natural gas-fired generation facilities to use hydrogen as a fuel source.
The New York DEC air permit regulators are shortsighted. Even the DEC’s sister agency, NYSERDA, has a clean hydrogen program. The U.S. Department of Energy has an "Earthshot" program to incentivize the widespread use of green hydrogen as a fuel in dispatchable power plants. The Commonwealth of Massachusetts also realizes that zero emission dispatchable fuels such as green hydrogen will be necessary to overcome the intermittencies of weather dependent solar and wind generation. In addition, the Infrastructure Investment and Jobs Act legislation signed by President Biden on Nov. 15 contains provisions to greatly increase the use of hydrogen as a dispatchable carbon free fuel and authorizes $9.5 billion to incentivize hydrogen’s use, including creating four clean hydrogen centers.
New York regulators and policymakers should take note and let entrepreneurs and private industry take the risks and make the investments necessary to achieve greenhouse gas reductions while building the new energy infrastructure that is sufficiently reliable and diversified to power the state's economy, homes and businesses when renewable energy sources and storage are simply unable to generate sufficient power.
Slamming the door on new state of the art natural gas plants that can initially use natural gas and thereafter be converted to green hydrogen, as well as existing natural gas fired plants that already burn natural gas and can later be converted to green hydrogen, is a short sighted gesture to an anti-fossil fuel political base for short term political gain.
New York politicians and regulators need to realize that maintaining a steady, reliable supply of electricity is an important goal that should have equal priority with climate change goals.
New York should permit and not regulate out of existence dispatchable, generation resources which will be needed to keep the lights on and the economy running in the state. Through the use of green hydrogen in zero emission dispatchable power plants that formerly burned natural gas, New York can lead the way in establishing a practical, achievable, carbon-free electric generation system to power tomorrow's totally electrified society and economy.