New York regulators’ first steps to broaden the path to a zero-emissions future have drawn limited response from stakeholders.

The New York Public Service Commission received only five comments on its May 18 order to begin filling the power generation gaps likely to arise in the transition away from fossil fuels. It is part of Case 15-E-0302, the PSC’s implementation of a large-scale renewable energy program and a clean energy standard.

The issue is potentially contentious, as the order states that favored renewable technologies such as solar and wind may not provide enough power and that more controversial alternatives such as hydrogen, nuclear and biofuel may be needed.

But the issue is increasingly pressing: Less than two months after the PSC order, NYISO reported that the nation’s largest city could face a reliability margin deficit of up to 446 MW as soon as summer 2025 because of a wave of mandated fossil generation retirements and the slow pace of replacement power coming online. (See NYC to Fall 446 MW Short for 2025, NYISO Reports.)

Meanwhile, leaders are pushing to electrify the state to the greatest extent possible as they carry out the landmark Climate Leadership and Community Protection Act of 2019. But many renewable generation projects have been delayed or canceled, and the new generators that do come online are intermittent.

To start the process of addressing this, the PSC in its May 18 order asked stakeholders to address a series of questions, including:

• • how to define “zero emissions”;
  • whether advanced nuclear power, long-duration storage, green hydrogen, renewable natural gas (RNG), carbon capture and sequestration, virtual power plants, distributed energy resources and demand response resources can be considered zero-emissions sources;
  • what other resources should be considered;
  • whether efforts to achieve zero emissions by the 2040 target should focus solely on resource adequacy or include a broader set of technologies that could be integrated into the transmission and distribution systems;
  • whether lifecycle emissions should be considered when characterizing energy resources;
  • how RNG should be considered, given the limited feedstocks in the state; and
  • what re-examination and possible revision to the tiers of the Clean Energy Standard might be needed.

Some of these would seem to be red flags for environmental advocates and others who have pushed for climate mitigation measures in New York. But the only responses were from industry groups pitching their solutions, as well as from four members of the state Senate’s Republican minority pressing their existing agenda of an all-of-the-above approach to the energy transition. This includes splitting atoms and burning various combustible matter, two solutions that are opposed by many in the environmental movement.

Minority Report

Republican Sens. Mario Mattera, Tom O’Mara and Mark Walczyk, all members of the Energy and Telecommunications Committee, and Senate Minority Leader Robert Ortt said the state needs an all-hands-on-deck approach as it decarbonizes, because it will need nearly 100 GW of new generation by 2040.

They pointed out that solar’s capacity factor is only about 14% in New York. Onshore wind is much higher, but still only 20 to 26%.

“Hydrogen, nuclear, renewable natural gas, bioenergy and sewer heat recovery provide more reliable sources of energy than wind and solar, as they would not be intermittent,” they wrote. “To be clear, New York state cannot meet the mandates in the CLCPA by solely focusing on wind and solar energy generation.”

The senators urged the PSC to consider as zero-emissions all types of hydrogen — regardless of how it was generated. Non-green hydrogen generation is another target of environmental advocates.

Making Gas

Berq RNG and Strategic Project Management submitted mostly identical comments with the American Biogas Council, urging the PSC to give greater consideration to the biogas sector as a means of achieving its goals.

They said New York does not use the full statewide potential of its waste-to-energy biogenic resources, such as landfills and manure lagoons.

Industry data show 191 active biogas systems in the state, they said, but indicate there is enough renewable methane available to power more than 500 systems. Buildout of these facilities is also a significant opportunity to divert organic waste from landfills and to reduce emissions of methane, they said.

They urged that “zero emissions” be defined to recognize any molecule and any system for converting it to energy that can deliver a lifecycle carbon emission profile of zero or below.

Water Flow

The Low Impact Hydropower Institute urged that when totaling up lifecycle emissions, a leveled impact assessment be used, taking into account the project lifespan.

For example, it said, building a hydropower facility generates a high upfront emission impact, but its impact may be less when considered over its very long lifespan.

It noted that old and new energy resources alike, including hydropower, have exacerbated environmental justice concerns, but the process laid out by New York will begin to address that. It suggested New York look to Massachusetts, where regulations try to recognize not just renewable energy but also, in the case of hydropower, resources that reinvest in their natural surroundings in an accountable, annual and transparent manner that meets specific outcome requirements.

LIHI offered itself as a resource, saying its criteria have “helped facilitate healthy river flows, vibrant aquatic communities, and accessible recreational opportunities across the state and region.”

Pumped Hydro

Serium Energy Storage, which is pursuing development of closed-loop underground hydroelectric energy storage, pointed out what others have flagged: the need for large amounts of long-duration storage to maintain reliability in New York when the sun is not shining and the wind is not blowing.

Closed-loop pumped hydro is the perfect fit for several reasons, Serium said: It is a proven and mature technology; it has a more-than-100-year history in New York; it is compatible with carbon-reduction and environmental stewardship; and it does not face the limits that batteries do.

Serium said the major drawbacks of surface pumped hydro, including environmental impacts, are not an issue with the underground systems it proposes. The company asked the PSC to add hydroelectric storage to its “zero emissions” list, and to begin procurement soon, given its long timeframe for approval.