PSE’s Flawed Analysis: “Replacing” Indian Point
Although claiming to analyze the “replacement” of electricity from Indian Point, PSE’s brief goes no further than its title suggests, which is to evaluate the potential for “offsetting” watts or watt-hours from Indian Point with electricity from other sources. The brief does not fully consider the function that Indian Point performs within the downstate electric grid. Instead, it redefines the task of replacement, saying that success is achieved if additional recent or projected gains in local renewable energy and energy efficiency equal the nameplate capacity of Indian Point at peak times; and if additional recent or projected gains in renewables and efficiency exist statewide to equal the total annual generation of Indian Point. This approach is flawed for several reasons: It inappropriately counts existing renewable and energy efficiency gains that were displacing fossil fuels; it does not adequately consider the real-time impacts of intermittency; and it dismisses physical constraints of transmission and deployment at scale.
Reallocation of Existing Renewables and Efficiency
In its brief, PSE inappropriately credits renewable energy and efficiency measures deployed three years prior to the closure of IP2 toward replacement of Indian Point. Whether installed recently or years ago, existing renewables provide electricity to the grid when they can and reduce the need for generation from fossil fuel power plants. If those existing renewables are subsequently reallocated to the displacement of nuclear power, they can no longer displace fossil fuels and more fossil fuels will be burned—precisely what occurred in New York last year. Likewise, existing gains in energy efficiency have already been absorbed into the broader energy system, reducing demand and avoiding generation from fossil fuel power plants. If those efficiency gains are later credited with the replacement of nuclear power, previously avoided generation from fossil fuels will occur. The brief makes this mistake in its analysis of both local capacity and statewide generation. PSE’s discussion of “compensatory megawatts”, identified in an Indian Point deactivation assessment by the New York Independent System Operation (NYISO), is also misleading. In that assessment, NYISO found that electricity from three new gas plants (CPV, CVE, and Bayonne Uprate) would not be needed for reliability until 2023 only because excess capacity is available from previously existing power plants in the region. Utilizing “excess capacity” means burning more fossil fuels.
PSE vaguely acknowledges that fossil-fuel power plants may need to run more due to Indian Point’s closure. However, it excuses this, saying “…a portion of the plant’s generation might temporarily be replaced with gas generation rather than renewables. A short-term demand for gas generation could likely be met by existing plants, however, without the need to build new gas infrastructure.” This latter point is rendered moot by the fact that giant new gas power plants explicitly built to replace Indian Point are already operating. Moreover, the brief fails to define “temporary” or quantify the impacts of additional gas-fired generation on carbon emissions or air quality within affected communities. From the standpoint of Environmental Justice, of particular concern is the ramping up of older facilities within the NYC metropolitan area.
Gains in renewables and efficiency prior to the closure of IP2 were not held in a lockbox waiting to replace nuclear power. They had been put to good use, reducing fossil fuels consumption, particularly gas. When IP2 closed, those good uses were forfeited, causing more gas to be burned.
PSE’s brief acknowledges the intermittency of renewables, but does not seriously consider the real-world challenges created by it. This results in an apples-to-oranges comparison of dissimilar energy sources. In analyzing local capacity, PSE multiplies the nameplate capacity of existing and projected solar projects by winter and summer capacity factors to calculate what it describes as winter and summer peaking capacities, which it then applies to Indian Point replacement. However, this is not the same as available power. The amount of power that an intermittent source can produce ranges anywhere from zero up to its rated nameplate capacity, depending on particular conditions at any given time. In its assessment, PSE also recites various CLCPA targets for the deployment of solar and offshore wind. But the capacities of intermittent sources are not necessarily additive, nor can they be considered “replacement” for baseload generation. Similar extraneous calculations are performed for efficiency. The very nature of intermittency means that electricity may not be available when it is needed, including during peak periods.
These problems are also seen in PSE’s discussion of annual generation. To claim that one source of electricity “replaces” another, the alternative must reliably provide the same amount of electricity at the same times (and to the same places) as the source being eliminated, thus satisfying the same real-time load demands. For this reason, the total amount of electricity generated annually by wind and solar across New York is of little relevance in determining whether nuclear power can be removed from the downstate grid without burning more fossil fuels. The brief asserts that statewide renewable resources can replace Indian Point’s non-peak generation, but this is not necessarily so. Whether intermittent sources are local or statewide, their ability to replace nuclear power depends on when they are generating electricity, and how much they are generating at any given time, in addition to transmission constraints. Treating all watt-hours equally—regardless of when or where they are generated and when or where they are needed—ignores the dynamics of grid operation. Nevertheless, this is what PSE does by summing annual watt-hours of renewable energy and efficiency as “replacement” for Indian Point.
Consequences of Intermittency
As more wind and solar are deployed, intermittency becomes increasingly difficult and costly to overcome. Storage can help, but understanding its practical limitations is important. The largest battery in the world is California’s 1200 Megawatt-hour (MWh) Moss Landing project. This corresponds to only about a half-hour of the energy that Indian Point delivered reliably 24 hours a day prior to the loss of IP2. Notably, Ravenswood Development has proposed a 316 MW battery with eight hours of storage in Queens, NY. However, this constitutes merely 15% of Indian Point’s deliverable power, and if configured to match its power output, only about 80 minutes’ worth of Indian Point’s energy. These facilities do not come close to replacing the important function served by Indian Point in delivering reliable, baseload electricity. Any real-world system must account for a wide range of operating conditions, which makes determining the amount of storage needed to achieve reliability for different levels of renewable penetration a complex statistical analysis. Although the title of PSE’s brief claims to evaluate the potential for storage to make up for the loss of Indian Point, the brief does not do this. It merely says that “hourly grid modeling will be necessary.” Rather than analyzing storage needs and limitations, the brief restates battery capacity goals of the CLCPA in watts, which is a measure of deliverable power, not storable energy.
Advances in technology have allowed batteries, sometimes coupled with renewables, to become a viable alternative to “peaker” plants that run only for limited amounts of time during periods of peak load. However, this has little impact on baseload demand. Where large amounts of intermittent sources are deployed, as in California, dispatchable gas combustion is needed to serve customers when wind and sunshine are not available. This “partnering” creates a dependency on gas that thwarts the goal of carbon-free electricity. It also leads to inefficient gas-fired generation—typically resulting in frequent startup and shutdown which degrades performance, the use of simple-cycle plants that respond quickly but consume more gas per watt-hour, or running plants in “hot standby” (meaning that fuel is burned even when not making electricity). Operating a network this way may help to prop up arbitrary renewable energy targets, but it undermines the fundamental goal of greenhouse gas reduction. Another consequence of adding significant wind and solar to the grid is the production of electricity when it is not needed. If excess energy cannot be used or stored, it must be curtailed (“dumped”), resulting in even lower effective capacity factors, systemwide inefficiency, and increased cost of building and maintaining underutilized resources.
The difficulties of matching supply with demand grow exponentially as intermittent sources comprise larger and larger portions of total generation. However, PSE neglects this, suggesting that current efforts are also applicable to the retirement of other nuclear plants in New York. Retaining “firm” carbon-free capacity, which nuclear power provides, is essential to any real-world plan to ensure reliability while meeting climate goals.
Transmission Constraints and Energy Density
Contrary to common belief, there would be very little “local” about a grid dominated by intermittent renewables. Robust and flexible paths must exist for electricity to flow, potentially very long distances, from wherever electricity happens to be generated to wherever it is needed. Power lines and transformers cannot move in response to dynamically changing pathways, so this requires the large-scale expansion of transmission infrastructure. This is not fully appreciated in PSE’s brief. The brief highlights new transmission capacity coming online in 2023 as if such improvements can be devoted to Indian Point’s replacement without regard to other needs for congestion relief (which had been an issue prior to IP2’s closure), or to further transmission improvements required to replace downstate fossil fuels. The brief also improperly sums the capacity of transmission projects connected in series. Constraints that impact electricity transmission within local distribution networks elsewhere cannot be ignored either. For example, the brief predicts significant amounts of new renewable generation statewide between 2020 and 2025. However, it is not valid to credit electricity produced from rooftop solar panels in Buffalo (which in all likelihood does not leave Buffalo), along with every other incremental production of renewable electricity throughout New York, against electricity produced by Indian Point to serve the downstate metropolitan area. The same applies to efficiency. Installing LED lighting upstate does not reduce the demand for electricity in New York City or the need for transmission capacity to delivery that electricity from sources outside the region.
The very low energy density of intermittent renewables will also make achieving New York’s energy goals extremely difficult, a reality understated by PSE. Even with offshore wind, unless New York imports much of the electricity it consumes, tremendous amounts of wind and solar will still have to be deployed throughout the state in an extremely short amount of time. This in turn will require the very rapid siting, permitting, and construction of intermittent resources over large areas, along with associated transmission and storage infrastructure—all of which have environmental impacts that must be considered. Even in politically progressive states and western Europe where renewable energy is generally supported, the tolerance level for such expansion diminishes as renewables and related infrastructure consume an increasingly large amount of the landscape, and as the cost of implementation puts an ever-growing burden on ratepayers. Prudent consideration of these factors would dictate preserving energy dense, carbon-free assets that already exist, rather than eliminating them.