Zero Emissions Comments Provide Solutions to PSC - Executive Summary

IPPNY has partnered with the New York State AFL-CIO and the New York State Building and Construction Trades Council in submitting a petition to the Public Service Commission (PSC or Commission) asking for the PSC to fulfill its obligation under the Climate Leadership and Community Protection Act (CLCPA) by designating technologies that will qualify as zero emission sources. In addition, the coalition asked that a program be set up to identify and develop at least 1 gigawatt (GW) of these technologies, the first milestone toward what the New York Independent System Operator (NYISO) states needs to be on the system by 2040 to maintain system reliability. This past June, the PSC granted both of IPPNY’s requests for opening a comment period to determine what resources should qualify as zero emissions, as well as setting up a timeline to hold a technical conference.

This executive summary encapsulates key points in the comments submitted by IPPNY (which include an affidavit by Sargent and Lundy) and Labor regarding zero emissions sources and answering questions posed by the PSC. In drafting comments to answer these questions, IPPNY has provided solutions that have been shown to work, while leaving the door open to new technological advancements.

IPPNY worked closely with Sargent and Lundy, who opined in the affidavit on the feasibility of various technologies. Sargent and Lundy is a leading engineering firm with over 100 years of experience in the power and energy field. Over the firm’s history, it has worked with more than 500 power generating companies. This expertise includes designing and overseeing the construction of projects for all types of generation, including nuclear, hydrogen, energy storage, carbon capture and sequestration (CCS), and renewable natural gas (RNG).

In addition to promoting the development of these technologies, this program under our petition would create quality job opportunities and include progressive labor provisions. These requirements would further promote future private sector investments while creating thousands of employment and training opportunities for New Yorkers. IPPNY worked closely with Labor in ensuring that our messages were aligned on our respective comments. We both recognize the importance of a trained workforce to meeting the CLCPA goals.

IPPNY defined zero emissions to cast a broad net, as “an electrical demand system that delivers net zero greenhouse gas (GHG) emission equivalent electricity.” Net zero is defined as “cutting [GHG] emissions to as close to zero as possible, with any remaining emissions re-absorbed from the atmosphere, by oceans and forests for instance.” This definition does not include renewable energy systems, given that the PSC already has established programs for those resources. We also urged the Commission to rule that a technology that produces emissions that are de minimis, or minimal, in the context of the total emissions reduced by the technology, qualifies as a zero emission source for purposes of meeting the CLCPA’s target of a zero emissions system by 2040. This definition falls into line with other jurisdictions’ definitions.

The coalition took an “all of the above” approach toward determining the necessary resources for a clean energy transition when submitting the comments. Below are examples of potential resource options that have been proven successful and should be considered as zero emission sources. Each technological option is expanded upon within the full comment document.

• Existing and New Nuclear: Nuclear generation made up 21% of energy generated in New York during 2022, while emitting no GHG. The low marginal cost and simple operation technology makes existing nuclear a great baseload resource. Additionally, modifications are possible to existing nuclear plants to make them operate flexibly. New small nuclear reactors are being developed which have more flexible operation than traditional generators and, when coupled together, could enhance this ability. The New York State Climate Action Council’s Scoping Plan (Scoping Plan) indicates that the State should evaluate the role of existing and advanced nuclear facilities prior to the scheduled conclusion of the Zero Emissions Credit program in 2029 and also needs to recognize the time required to relicense these facilities and to refuel them. Lastly, nuclear can be used to create pink hydrogen, discussed below, which can be stored to deal with future peak loads.
• Green and Pink Hydrogen: The Scoping Plan noted that green and pink hydrogen technologies have seen significant advancements and offer new opportunities in difficult to electrify sectors. Both are produced without the emission of GHG. Designating green and pink hydrogen as zero emission sources will allow New York to leverage significant funding and other incentives provided by Congress as New York seeks to become the Northeast Regional Clean Hydrogen Hub in partnership with six northeast states.
• RNG: RNG is a gas collected from sources that already produce and release bio-derived methane, which eliminates already occurring methane emissions in the atmosphere. This feature is important because methane’s climate impact is significantly greater than carbon dioxide’s. The benefits of RNG have been recognized in governmental programs, such as the EPA’s Landfill Methane Outreach Program and its AgSTAR Program, which work with various industries to avoid methane emissions by supporting biogas energy projects. Furthermore, the Scoping Plan acknowledged that RNG may be considered to “decarbonize the gas system as it transitions.”
• CCS: This technology can be used to capture and permanently store carbon from fossil fuel generating facilities. Natural gas generators that utilize CCS can remove 95 – 98% of carbon emissions. The EPA has proposed that “CCS with a 90 percent capture rate has been adequately demonstrated and is technically feasible based on the demonstration of technology at existing coal-fired steam generating units and industrial sources in addition to combustion turbines.” Further, to date, an incredible amount of carbon has been stored globally, and this option has the opportunity for expansion in New York.
• Alternative Options: Green Ammonia, Demand Response, Distributed Energy Resources, Virtual Power Plants, Long Duration Storage, etc.

Many of the current peaking plants in New York are currently in Disadvantaged Communities and will be replaced by these zero emission sources. Additionally, these zero emissions facilities require roughly the same size workforce, creating employment opportunities.

IPPNY urges the PSC to act expeditiously in considering the comments received and determine what qualifies as a zero emission source. We further encourage the PSC to work closely with the New York State Department of Environmental Conservation, the NYISO, and the New York State Reliability Council before issuing its order.

The NYISO has published that a large amount of these resources is necessary by 2040. According to the NYISO’s latest report, more than 111 GW of total installed capacity will be needed by 2040. Of that 111 GW, 95 GW must be new generation. Further, 27 – 45 GW of the 95 GW of the new generation must be emissions free resources. For reference, 1 GW is enough to power roughly 750,000 homes, illustrating the mountain New York must climb to achieve its climate goals.  A failure to meet this threshold on the system could result in requiring the importation of energy from neighboring jurisdictions, which likely was produced using fossil fuels.

IPPNY’s Members will be poised to invest in these solutions once they are identified and cost recovery mechanisms are determined. If the resource gap outline by the NYISO is to be filled, the initial GW is the first step. With the help of the Labor organizations, these proven technologies can begin increasing the reliability of the New York grid as the State transitions into a cleaner energy future.