GHG Impacts of Astoria Replacement Project and Supplement
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Appendix E Navigant/Guidehouse Study: GHG Impacts of Astoria Replacement Project and Supplement Appendix E.1 Navigant/Guidehouse April 2020 GHG Report GHG Impacts of Astoria Replacement Project Prepared for Astoria Gas Turbine Power LLC Submitted by: Navigant Consulting, Inc. n/k/a Guidehouse (Navigant) 1200 19th Street NW Suite 700 Washington, DC 20036 202.973.2400 navigant.com April 2020 ©2020 Guidehouse Inc. GHG Impacts of Astoria Replacement Project TABLE OF CONTENTS Executive Summary ...................................................................................................... 1 1. Astoria Replacement Project ................................................................................... 3 2. Environmental Regulations Driving Change in New York ..................................... 5 2.1 The CLCPA ................................................................................................................................... 5 2.2 NYSDEC Ozone Season NOx Emission Limits for Simple Cycle and Regenerative Combustion Turbines (6 NYCRR 227-3) ....................................................................................................... 5 3. New York State’s Power System .............................................................................. 7 3.1 History and Overview .................................................................................................................... 7 3.2 Current New York Supply Mix ....................................................................................................... 8 4. New York’s Future Resource Mix ............................................................................. 9 4.1 New York City Retirements ........................................................................................................... 9 4.2 New York City Load Requirements ............................................................................................. 10 4.3 Future Resource Mix Statewide and in New York City ............................................................... 10 5. GHG Reductions from the Astoria Replacement Project ..................................... 14 5.1 Direct Emissions Reductions ...................................................................................................... 14 5.2 Indirect GHG Reductions from the Astoria Replacement Project ............................................... 18 Page i ©2020 Guidehouse Consulting, Inc. GHG Impacts of Astoria Replacement Project DISCLAIMER This report was prepared by Navigant Consulting, Inc., n/k/a Guidehouse Inc. (“Navigant”) for Astoria Gas Turbine Power LLC (“Astoria”). The work presented in this report represents Navigant’s best professional judgment based on the information available at the time this report was prepared. Navigant is not responsible for the reader’s use of, or reliance upon, the report, nor any decisions based on the report. NAVIGANT MAKES NO REPRESENTATIONS OR WARRANTIES, EXPRESSED OR IMPLIED. Readers of the report are advised that they assume all liabilities incurred by them, or third parties, as a result of their reliance on the report, or the data, information, findings and opinions contained in the report. Page ii ©2020 Guidehouse Inc. GHG Impacts of Astoria Replacement Project EXECUTIVE SUMMARY Astoria Gas Turbine Power LLC (“Astoria”) is proposing to modify its previously permitted 1,040 MW project to replace twenty four nearly 50-year-old Pratt & Whitney (“P&W”) combustion turbines and seven recently retired Westinghouse combustion turbines at Astoria with a new, state-of-the-art, H-class simple cycle combustion turbine generator (“CTG”) (the “Astoria Replacement Project” or the “Project”). The need for the Replacement Project is driven by the anticipated impacts of climate change policies and regulatory frameworks that are pushing modernization and decarbonization of the New York Independent System Operator (“NYISO”) and especially the New York City generation fleet. The purpose of this report is to describe the greenhouse gas (“GHG”) emissions impacts of the Astoria Replacement Project and to describe how the Project is consistent with the New York State Climate Leadership and Community Protection Act (“CLCPA”). Based on the GHG reductions that will result from the Project, it is consistent with the attainment of the Article 75 GHG emission limits. The CLCPA requires the New York State Department of Environmental Conservation (“NYSDEC”) to implement regulations, pursuant to the CLCPA and Article 75 of the New York Environmental Conservation Law (“ECL”), that reduce GHG emissions 40% (from 1990 levels) by 2030 and 85% by 2050. It also requires the New York Public Service Commission (“NYPSC”) to implement a program to meet the targets of 70% of electricity to be sourced from renewable generation by 2030 and obtain a statewide zero-emissions electrical system by 2040. While these regulations and programs have not yet been developed by NYSDEC or NYPSC, Section 7(2) of the CLCPA requires all state agencies to consider whether the decision to issue permit(s) is inconsistent with or will interfere with the attainment of the GHG emission limits established in ECL Article 75. This analysis evaluates the impact of the Project on statewide GHG emissions based on full compliance with the CLCPA’s targets and limits.1 The results show that the Project is consistent with the CLCPA and provides significant GHG reduction, while minimizing costs and maximizing benefits to New York via the following mechanisms: • Direct reduction through displacement of older, less efficient generation in New York City. This also includes reduction in GHG emissions due to extraction and transmission of fossil fuels imported into the state. • Indirect reduction by providing required quick start and fast ramping capacity to maintain reliability in New York City. This allows New York to avoid the installation of very large amounts of marginal capacity from energy storage, the cost savings of which can be applied to accelerate procurement of additional renewable resources including significant amounts of offshore wind. Figure 1 shows the annual direct and indirect GHG emissions reductions due to the Project based on (i) comparing emissions from the Project with emissions from replacement generation that would be required without the Project and (ii) additional renewable generation that can be added to the system from cost savings attributable to the Project. The cumulative reductions through 2035 is nearly 5 million tons of GHG. Post-2035, emissions are still reduced by the Project, but the quantity depends on how the system 1 All figures and charts are from Navigant analysis, unless otherwise noted. Page 1 ©2020 Guidehouse Inc. GHG Impacts of Astoria Replacement Project ultimately reaches full decarbonization and whether (and when) the Project starts to generate electricity using hydrogen fuel. Figure 1. GHG Benefits of Astoria Replacement Project Source: Navigant Analysis Building the Project is also consistent with the long-term targets and goals of the CLCPA, which require 70% of electricity statewide to be sourced from renewables by 2030, shifting to zero-carbon emission generation by 2040, as the Project’s CTG technology is already capable of being converted to use zero- emission hydrogen as fuel once it becomes commercially available in sufficient quantities via a commercial delivery system such as the existing natural gas pipeline system. Page 2 ©2020 Guidehouse Inc. GHG Impacts of Astoria Replacement Project 1. ASTORIA REPLACEMENT PROJECT The Astoria Replacement Project is being developed at the approximately 15.7-acre Astoria Gas Turbine Facility (“the Facility”) located at 31-01 20th Ave., Astoria, Queens County, New York, situated within a large 600+ acre complex (referred to as the “Astoria ConEd Complex”) shown in Figure 2. The Facility currently consists of 31 older, dual-fuel (natural gas and ultra-low sulfur kerosene) combustion turbine generators including 24 Pratt & Whitney turbines and seven retired Westinghouse turbines, with a combined nameplate rating of 646 megawatts (“MW”). Astoria is proposing to modify its previously approved project. The Project will replace the 50-year-old P&W and previously retired Westinghouse CTGs at the Facility with a new, state-of-the-art, dual fuel, simple cycle combustion turbine generator unit. The proposed replacement unit (General Electric 7HA.03 or equivalent) has a nominal generator output of approximately 437 MW. All of the existing units, with the exception of one P&W Twin Pac (consisting of two combustion turbines and a single generator), will be permanently shut down once the new unit has completed its shakedown period. The two remaining P&W turbines will remain operational to make the site black-start capable until replaced by an approximately 24 MWe battery energy storage system (“BESS”). Page 3 ©2020 Guidehouse Inc. GHG Impacts of Astoria Replacement Project Figure 2. Astoria Replacement Project Site Location Source: AECOM Page 4 ©2020 Guidehouse Inc. GHG Impacts of Astoria Replacement Project 2. ENVIRONMENTAL REGULATIONS DRIVING CHANGE IN NEW YORK Environmental regulations and policies are causing significant shifts in the resource and generation mix in New York. The GHG emission reduction requirements and renewable targets and decarbonization goals laid out in the CLCPA provide the framework for procuring future electric generators and drive the long- term shift away from thermal resources towards zero-emission energy