NOT IN ANY BACK YARD ELIMINATING POWER PLANTS FROM THE

Thomas Storck M.S. Sustainable Environmental Systems Programs for Sustainable Planning and Development Pratt Institute

Demonstration of Professional Competence May 16th, 2016

Advisor: Alec Appelbaum Technical Advisor: Charles Komanoff

ABSTRACT

In 2001, the New York Power Authority (NYPA) installed four 47 MW gas-fired turbines in Port

Morris, , a neighborhood already suffering from some of the worst asthma and poverty rates in the country. In doing so, NYPA cut regulatory corners, exploited loopholes and minimized public participation. These turbines continue to be re-permitted every five years. To challenge NYPA’s claim that these gas plants are environmentally beneficial, environmental justice coalition South Bronx Unite reached out to energy policy-analyst and environmental activist Charles Komanoff for advice on how these four turbines could be replaced with clean energy or other carbon-free solutions. This report describes how the State managed to install power plants in environmental justice communities by undermining the laws put in place to protect people from polluting infrastructure before evaluating the capabilities of selected alternatives to replace NYPA’s turbines, including offshore wind, solar PV and demand-side management.

2

INTRODUCTION

In 2000, New York State officials agreed to install ten gas-fired turbines across four boroughs in

New York City (Parker, 2003). The Bronx was burdened with four units, more than were installed in any other borough, all concentrated in Port Morris, a community already suffering from a disproportionate share of environmental burdens and home to some of the highest asthma rates in the United States

(Parker, 2003; Maantay, 2007). Leading the project was The New York Power Authority (NYPA)1, who met their self-imposed deadline2 by exploiting regulatory loopholes, avoiding adequate environmental review and minimizing public participation, leaving communities feeling offended, undervalued and discriminated against (Sze, 2007). The public was led to believe the turbines would last no more than three years, but local environment justice groups continue to fight for their removal (New York State

Assembly [NYSA], 2001; Mark-Viverito, 2015).

In response to concerns from residents about their neighborhood’s poor air quality exacerbated by these plants, NYPA argues that their gas turbines are the cleanest and most efficient in the City and that their removal would increase citywide pollution by forcing older, dirtier generators to meet electricity demands instead (New York State Department of Environmental Conservation [NYSDEC],

2015).

My research for this report was gathered after South Bronx Unite, an environmental justice coalition of residents, organizations and allies working to protect the future of the South Bronx, reached out to energy policy-analyst and environmental activist Charles Komanoff3 for advice. Their question:

How could these plants be replaced with clean energy or other non-polluting strategies? (Johnson,

1 The New York Power Authority is a state-owned utility and the largest state power organization in the United States (NYPA website). 2 June 1st, 2001 3 Charles Komanoff is the Director of both Komanoff Energy Associates (www.komanoff.net) and the Carbon Tax Center (www.carbontax.org). He has served as an expert witness on issues of energy policy and economics, including Con Edison’s Power Plant expansion in 2000.

3 2016). Under advisement from Mr. Komanoff, I have prepared this report to serve South Bronx Unite and other energy and environmental justice groups in by identifying intervention points and exploring renewable energy and demand-side management strategies for replacing the four turbines in Port Morris, The Bronx.

PORT MORRIS, THE BRONX – SHOULDERING THE BURDEN FOR NEW YORK CITY

Within the poorest congressional district in the country and the southernmost peninsula of the

Bronx lies Port Morris, a minority neighborhood bordered by as many rivers as it is by highways

(Mueller, 2016). Unfortunately for its residents, the areas along the waterfront once used for recreation have since been replaced (and in some cases destroyed) by industry (Walshe, 2015; Johnson, 2016). The warehouses, distribution centers and waste transfer stations that now line the neighborhood’s edge are extremely truck-intensive, accounting for over 15,000 diesel trucks trips a day through local streets

(Crean, 2015; Johnson, 2016). Nearly one-third of New York City’s solid waste is handled in The South

Bronx (Institute, 2002). The City’s waste is no longer shipped away on barges – instead, it gets transferred from large trucks to even larger trucks, burdening the community with pollutants from diesel exhaust, the stench of garbage, and the danger and noise brought by their intrusion into residential areas (Crean, 2015; Johnson, 2016).

Consequently, South Bronx residents breathe some of the worst air in country. Half of the area’s pre-Kindergarten to 8th grade students attend schools less than two blocks away from a highway or truck route (Institute, 2009). The asthma hospitalization rate for this same age group is three times higher than the citywide average (King, 2015). Based on the findings from Institute (2009), New York

University’s School of Medicine concluded that air pollution reduction policies should be implemented, such as support for public transportation and creating more green space. Flying in the face of these recommendations, City and State governments recently invested over $100 million to build a new

4 operations center for FreshDirect, a major trucking company, on one of the last remaining open spaces on Port Morris’s waterfront (New York State, 2012). The facility is expected to add a thousand more truck trips a day (Johnson, 2016). “Even if all of FreshDirect’s trucks ran on water,” noted Johnson (2016) of South Bronx Unite, the added traffic will cause other vehicles to idle along the highways surrounding the neighborhood, exacerbating the pollution from existing mobile sources.

Port Morris has very little green space, as demonstrated on this year’s annual Earth Day

Environmental Justice Waterfront Bike Tour lead by Mychal Johnson. Pulaski Park, their largest recreational space, is made of concrete, and the waterfront areas surrounded the neighborhood are no longer accessible to the public. The tour eventually brought us to what used to be the East 132nd St pier, where South Bronx Unite’s Danny Chervoni – a local resident for 60 years – recalled how valuable the destination was for the community and how he would go there to swim as a young kid. The pier was destroyed in 1989 when a severed gas line caused a deadly explosion, explained Johnson. People can still manage to reach the water. That afternoon a group of men were out there fishing, but only after slipping through a barbed wire fence now blocking the old pier’s remains. The Hell Gate power plant, which includes two of NYPA’s turbines, is directly adjacent to the pier.

ELECTRICITY SYSTEMS – NEW YORK

Peak Demand

Electricity demand can be categorized as base load or peak load. As described in Fox-Penner

(2014), demand levels fluctuate throughout the day, but base load is the amount that is always needed

– the lowest point on the demand curve. Peak load includes the part that fluctuates between the base load and the highest point of the demand curve (see below). Over the course of a year in New York, peak load may reach its highest point on a very hot day in the summer, or after a series of exceptionally

5 hot and humid days (Fox-Penner, 2014; Audin, 2016). This moment is called peak demand, and determines how much generation capacity will be required for that year.

Peaking Plants

Fox-Penner (2014) describes how power plants that serve the base load are designed to operate continuously at high output and have low incremental costs per unit of electricity. As demand increases, intermediate power plants must be turned on to provide power for consumers, increasing the cost per unit of electricity for consumers. When demand approaches peak levels, the last power plants that may need to be turned on are typically the most expensive and are designed to run no more than a few hundred hours a year. These are known as peaking plants, or “peakers,” and typically use natural gas to run combustion turbines similar to jet engines (Fox-Penner, 2014).

6 Capacity Requirements

The level of installed generation capacity required to maintain reliability4 is determined by peak demand. New York State has a margin of error supply requirement of 18% of projected peak demand, a cushion between the State’s peak demand and total capacity (Parker, 2003; Gold, 2015). Because of the limited capacity of transmission lines from outside its borders, New York City has a separate requirement to generate at least 80% of its peak electric demand within the five boroughs (New York

City Energy Policy Task Force [NYCEPTF], 2004). The maximum capacities of transmission lines feeding into the City are: 3,700 MW via Westchester; 1,000 MW via New Jersey; 300 MW via

(NYCEPTF, 2004). New lines are difficult to site because of population density, high property values and the extended time to receive permit approvals (Sze, 2007). Because its peak demand is higher than what these lines can carry, New York City is considered a load pocket (NYCEPTF, 2004).

THE PORT MORRIS TURBINES

The turbines in the South Bronx are simple-cycle gas turbines, often characterized as peaking plants. Each is owned and operated by the New York Power Authority and designed to produce up to 47

MW of electricity at ambient temperatures below 100°F, with a net output capability of 44 MW (3 MW are needed for on-site operations) (Parker, 2003). Sites with dual generators have a total capacity of 94

MW with a net output capability of 88 MW. The four units are located on two sites, both along the waterfront in Port Morris. The Hell Gate Plant houses two units and can be found at Locust Avenue between East 132nd and East 134th Streets (Robbins, 2016). A few blocks away on the opposite side of the Randall’s Island Connector overpass, two units form the Harlem River Yard Plant (Robbins, 2016).

4 New York State Reliability Council (2016) defines reliability using the following two terms: 1) Adequacy – “the ability of the electric systems to supply the aggregate electrical demand and energy requirements of their customers at all times, taking into account scheduled and reasonably expected unscheduled outages of system elements” and 2) Security – “the ability of the electric systems to withstand sudden disturbances such as electric short circuits or unanticipated loss of system elements.”

7 They were installed in June 2001, along with six other gas turbines spread across four boroughs

(see right): two units were installed in Sunset

Park, Brooklyn at 23rd Street and 3rd Avenue; one in Williamsburg, Brooklyn at North 1st and

River Streets; two at 42-30 Vernon Boulevard in

Long Island City, ; and one at 143

Edgewater Street in . An eleventh unit was also installed outside of New York City in Brentwood, Long Island (UPROSE, 2001).

THE SITING PROCESS

The following section describes how New York State officials installed gas turbines in New York

City by exploiting loopholes and undermining the laws put in place to protect those affected. The story illustrates how powerful groups are able to not only bend the laws to their convenience, but also invent their own rationality by determining what information is presented as fact.

At the end of summer 2000, the New York State Public Service Commission (PSC)5, the New York

Power Authority (NYPA) and the New York Independent System Operator (NYISO)6 forecasted a 315 MW supply shortfall for summer 2001 (Parker, 2003). Within a month, NYPA purchased 11 simple-cycle gas turbines from General Electric for $510 million dollars (NYCA, 2001). The ten turbines for New York City

5 The New York PSC oversees and regulates all utilities in the State, and is responsible for ensuring an adequate supply of electricity (NYCA, 2001). 6 NYISO controls the energy markets in New York State. They accept bids from power produces on a day-ahead basis and decide which plants turn on and in what order (NYCEPTF, 2004).

8 totaled 440 MW, and NYPA was intent on installing them by June 1st, 2001 (Parker, 2003). The first wave of the California Electricity Crisis had hit only a few months prior, and the State used the fear of

California-style blackouts to justify moving these generators through the siting process as fast as possible (Johnson, 2001). The project was called PowerNow!, appropriate for the speed at which it was completed (Parker, 2003).

State Assembly members were skeptical about NYPA’s intentions. They suspected the

PowerNow! project was primarily motivated to lower electricity prices7, not to meet reliability requirements (NYSA, 2001). At a public hearing in March 2001, NYPA President Eugene Zeltmann responded to these accusation and assured Assembly members that the project is an emergency measure to ensure reliability and that the turbines will only run during on-peak periods: “in October,

November, through… March, April,… these units simply will not run. And they’re not going to run in the evening in the summer times either because that is not what the peak load is” (NYSA, 2001). But the data shows otherwise. During 2015, only 45% of the annual load generated by the four turbines in the

South Bronx was during peak periods8 (Environmental Protection Agency [EPA], 2016). At a public hearing, President Zeltmann admitted that the generators would be bid into the market each day, no matter what the capacity need (NYPA, 2001).

One tactic by which the PowerNow! Project saved time was dodging environmental review.

According to New York State’s then primary law dealing with electric power plant siting, known as

Article X of the Public Service Law, environmental review is always required when siting a new power plant (Parker, 2003). Generators in excess of 80 MW were pursuant to Article X while those with lower capacity, to SEQRA (Parker, 2003). In the case of NYPA’s units, sites with a single turbine (47 MW) were

7 NYSA (2001), p. 203: “CHAIRMAN BRODSKY: This is about price, and this is about the administration’s attempt to deal with the price issue by using a statewide subsidy to deal with the price spike in New York City”. Because the construction and operating costs of NYPA’s generators are picked up by the State’s ratepayers, the electricity produces can be bid at a lower prices, causing other power producers to lower their costs to remain competitive. 8 May through September, 12:00pm – 6:00pm

9 to be reviewed under SEQRA and sites with dual turbines (94 MW), such as the ones now occupying Port

Morris, would have been subject to Article X, a more rigorous review process (Sze, 2007). NYPA petitioned the Siting Board9, asking to avoid Article X by agreeing to a “legally binding commitment” not to run the units above 79.9 MW (NYSA, 2001). But Parker (2003) points out that when stating their decision, the Siting Board changed the statutory language from “generating capacity” to “net generating capacity”. Since 3 MW out of each turbine’s capacity is used for onsite operations, the commitment agreed to by NYPA actually allows each site to generate up to 85.9 MW, a violation of the law according to Article X. The Siting Board agreed, thus triggering environmental review under SEQRA for all of NYPA’s gas turbines (Parker, 2003).

NYPA was the lead agency for its environmental review process, and four days after the Siting

Board’s Article X waiver, they issued a negative declaration, thus removing the obligation to prepare an environmental impact statement (EIS) (Sze, 2007). To determine whether the turbines would disproportionally affect low-income or minority communities, the State Department of Environmental

Conservation (DEC), the agency responsible for issuing air emissions permits, requested that NYPA prepare an “environmental justice” analysis along with its permit application (Sze, 2007). The environmental consulting firm AKRF prepared an assessment, but NYPA only released it after several

Freedom of Information Act requests and one lawsuit led by New York Lawyers for the Public Interest

(NYLPI) (Silvercup, 2001; Sze, 2007). When released, NYPA (2001) revealed that all of the areas chosen by NYPA had higher poverty rates and proportions of minorities than the citywide average. New York

City averages were 18.9% below the poverty line, 28.8% black and 23.7% Latino. By comparison, The

Harlem River Yard site’s were 51% in poverty, 36.9% black and 64.7% Latino. At Hell Gate, the population was 44.1% in poverty, 48.5% black and 52.3% Latino (NYPA, 2001).

9 The New York State Board on Electric Generation Siting and the Environment, or “Siting Board”, is within the Department of Public Service but includes members from multiple New York State agencies. The Board is responsible for authorizing power plant sitings (NYSA, 2001).

10 Local communities and their allies felt angry, taken advantage of and discriminated against, but the State’s secretive, top-down approach made it difficult for the public to participate in the siting process. Sze (2007) describes the sequence of events as follows: Two days after NYPA issued a negative declaration for the project, on the day before Thanksgiving, the NYS Department of Environmental

Conservation (DEC) issued draft air permits for public review. The DEC eliminated the possibility for activists to support their allies at meetings in other boroughs by scheduling the Bronx, Brooklyn and

Queens public hearings on the same day, at the same time. The Siting Board, at the request of NYPA, shortened the public comment period from twenty-one to ten days. Further compromising the public review process was the decision to set the public comments deadline for December 22nd, 2000, three days before Christmas. Within two weeks, NYPA had slipped through the environmental review process and were issued regulatory air permits (Sze, 2007).

Those communities that did speak out against the project’s fast-tracked approach were accused of being selfish for putting citizens in harm’s way if the plants were not installed by NYPA’s self-imposed deadline: “Every day’s delay will push New York City one day closer to California,” the Power Authority said in a written statement after a coalition of neighborhood and environmental groups represented by

New York Lawyers for the Public Interest (NYLPI) sued the Pataki administration for illegally plowing through siting regulations (Johnson, 2001). When Judge Lawrence Knipel ruled in favor of NYPA,

McKinley (2001) reported that the Authority’s spokesman Michael Petralia called the decision a relief, so that “we can keep the lights on for the people of New York City.” Mayor Rudolph Giuliani responded to the ruling with even more gravity: “People actually die,” he warned opponents of the plants during his weekly radio address. “You have a risk to human life. So we should not allow that.” (McKinley, 2001).

Mayor Giuliani’s statements imply that there were no alternatives to ensuring reliability besides building these plants and that there was no doubt New York City was facing an otherwise inevitable crisis. But because NYPA removed their obligation to complete an environmental impact statement,

11 they were not required to prove the estimated 315 MW supply shortfall (Sze, 2007). Opponents of the project, community members and elected officials alike, cited evidence that the State’s numbers did not add up (NYSA, 2001). One reason: the State ignored the value of peak demand reduction in ensuring reliability. By January 2001, the Public Service Commission had increased funding for the System

Benefits Charge (SBC), a program offer monetary incentives for energy efficiency, from $78.1 million to

$150 million (SBC, 2014). The New York State Energy Research and Development Authority (NYSERDA) projected these incentives would reduce the State’s peak demand by 250 – 300 MW by summer 2001

(NYSA, 2001). When asked at a public hearing why the demand reduction projections were not included in their capacity assessment, PSC Director Howard Tarler explained that demand side management projects are unreliable because they depend largely on consumer behavior. Unsatisfied, State

Assemblyman Richard Brodsky, then Chairman of the Committee on Environmental Conservation, responded, “I could understand you don’t want to put the full 250 or 300 in. I cannot understand zero.”

(NYSA, 2001).

The State’s assessment of available generation capacity was questioned as well. Ashok Gupta, energy analyst for the Natural Resources Defense Council, conducted a detailed analysis challenging the

315 MW shortfall and found 527 MW10 of available capacity not included in PSC’s estimates (Parker,

2003). The PSC and NYPA produced no equivalent analysis (Parker, 2003). Although previous power plant siting laws had stricter needs requirements, Article X required no analysis of need for increased megawatts as long as new generators contribute to competition (Sze, 2007).

Mayor Giuliani’s dismissal of the consequences of air pollution and greenhouse gas emissions highlights a much deeper issue surrounding energy policy – that of the unequal attention given to spectacular and unspectacular time. As far as the public was told, this project was necessary to avoid an

10 The additional capacity came from the following facilities: Astoria (170 MW), increased capacity of existing sources (157 MW), a Key Span site (40 MW), Linden Cogeneration (70 MW), ConEd Unit 10 (60 MW) and an increased capacity of ConEd Gowanus (30 MW) (Parker, 2003).

12 otherwise inevitable catastrophic event that could cost New York State millions or billions or dollars and possibly human lives (Sze, 2007). But the death and destruction related to climate change is framed in much longer terms, with much more complex causal relationships, that it typically goes unnoticed, untreated or misunderstood. Similarly, though on a smaller scale, victims of localized air pollution also suffer from this misunderstanding of long-term and cumulative damage (Nixon, 2011).

ENERGY POLICY TODAY

Despite attempts to minimize debate, environmental justice groups such as Communities United for Responsible Energy (CURE), Organization of Waterfront Neighborhoods (OWN) and UPROSE managed to insert themselves into the process and were able to spark a public debate about energy justice (Sze, 2007). In June 2001, the Brooklyn Appellate Court ruled in favor of community groups’ appeal of Judge Knipel’s ruling and ordered NYPA to complete an environmental impact study, and one

11 that included an analysis of the plants’ PM2.5 output (UPROSE, 2001).

Although the plants are still in operation, as Sze (2007) points out, the efforts by environmental groups had significant influence on energy policy and contributed to public skepticism about new power plant construction. Some of the groups leading the fight against NYPA’s plants in 2000 and 2001 were appointed in 2003 to Mayor Bloomberg’s Energy Task Force, including CURE, Gail Suchman of NYLPI and

Ashok Gupta of NRDC (NYCEPTF, 2004). The task force was formed after another blackout – the northeast in August 2003 – but this time those involved were able to insert into the report strategies of energy conservation and green building design (Sze, 2007). According to CURE, it was the first “public recognition that there is no hysterical energy crisis” (Sze, 2007).

11 Fine particulate matter with a diameter smaller than 2.5 microns. PM2.5 is small enough to travel into respiratory tracts and reach the lungs and can worsen medical conditions such as asthma and heart disease (New York Power Authority [NYPA], 2002).

13 Energy policy in New York looks remarkably different in 2016 than it did fifteen years prior. At the state level, Governor Andrew Cuomo’s new Clean Energy Standard will establish a mandate of 50% clean electricity in New York by 2030 (New York State [NYS], 2016). His current energy plan, Reforming the Energy Vision (REV), focuses primarily on increasing renewables, minimizing fossil fuel dependency, reducing peak demand and protecting the health and welfare of New Yorkers (NYS, 2016). Mayor Bill de

Blasio’s goals focus on less dependency on fossil fuels as well. His 2015 update to Mayor Bloomberg’s greenhouse gas emission reduction plan set a target of 80%12 by 2050 (Mayor’s Office, 2015). That same year, the Mayor announced his plan to power all municipal buildings, most of which are now served by

NYPA, with 100% renewable electricity (Office of the Mayor, 2016).

ALTERNATIVES

The following section is an assessment of a select few renewable energy and demand side management strategies and each’s ability to replace the megawatts (MW) and megawatt-hours (MWh) now provided by the four turbines in the Bronx. NYPA’s power plants are value in two ways: 1) the electricity they generate and 2) their contribution to a reliable supply system.

The amount of electricity provided can be expressed as megawatt-hours (MWh), and equals the gross load minus the load needed for on-site operations. The combined annual electricity production from the four turbines has been fairly consistent across the four most recent years13, averaging about

100,000 MWh, or 100 gigawatt-hours (GWh) per year (EPA, 2016). Their contribution to a reliable electricity system can be expressed in terms of their capacity. Together, they provide 160 MW14 that is available if we need it. My assessment of alternatives will use these values – 160 MW and 100 GWh – as targets for their replacement.

12 Reduced from 2005 levels. 13 2012 - 2015 14 Each site is capped at 79.9 MW (Parker, 2003)

14 Before going into these calculations, it’s important to understand two concepts: capacity factor and capacity value. Capacity factor means what a resource is actually producing versus its potential production according to its capacity (Komanoff, 2016a). Capacity value is important when considering variable resources like wind and solar. Unlike a gas turbine, the wind and the sun cannot be turned on when needed, so an equal amount of capacity of one of these variable resources does contribute equally to the State’s reliability requirements (New York Independent System Operator [NYISO], 2010).

Capacity value then can be used as a conversion factor.

Offshore Wind

On March 16, 2016 the Department of Interior (DOI) announced that the Bureau of Ocean

Energy Management (BOEM) has designated for offshore wind development a 127 square mile area off

Long Island, 13 miles from the City of Long Beach (Bureau of Ocean Energy Management [BOEM], 2016).

The DOI broke the news following an announcement that the Obama administration had decided not to allow oil or gas drilling off the mid- and south Atlantic coast (U.S., 2016). The designated area is based on a proposal in 2011 from the New York Power Authority to build a 700 MW wind farm in the same area using 194 turbines, each with a potential to generate 3.6 MW (BOEM 2016). “New York has tremendous offshore wind potential,” according to Secretary of the Interior Sally Jewell (BOEM, 2016).

By some estimates, an offshore wind farm this size could provide electricity for up to 300,000 homes

(Schlossberg, 2016).

According to NYISO (2010), the capacity value of an offshore wind farm in New York is between

0.2 and 0.3, meaning 1 MW of wind capacity has been treated in power-system planning as providing the same peak-reliability increment as only 0.2-0.3 MW of existing fossil fuel capacity. However, it is possible that advances in both turbine technology and power-system optimization will allow the NYISO to increase its capacity value to wind resources (Komanoff, 2016b). Nevertheless, the value from NYISO

15 (2010) suggests that a 700 MW offshore wind farm would allow 140-210 MW to be removed.

Considering that the four turbines in Port Morris exceeded a combined gross load of 140 MW for almost

300 hours over the course of 2015, it may appear that this wind project alone may not be enough to replace all four plants (EPA, 2016).

According to Long Island (2016), a 350 MW offshore wind farm operating at 40% its capacity would generate 1,226,000 MWh per year. It follows, then, that a 700 MW farm with the same capacity factor would generate about 2,452,000 MWh per year – twenty-five times more than the four turbines combined.

The low capacity of offshore wind power can be partially attributed to the difficulty to predict wind speeds. Also, NYPA’s turbines tend to operate more frequently during peak hours (EPA, 2016).

While offshore wind is better than onshore for peak power replacement, simulations from NYISO (2010) suggest that wind farms are more productive during winter and at night. In New York City, winter peaks are projected to decrease over the next ten years, and summer peaks projected to increase, so a more peak-coincident resource may be better suited to replace NYPA’s gas turbines (Gold, 2015).

Solar PV

Solar power is also a variable resource, but more coincident with peak demand than wind.

According to Perez (2008), at the current level of solar integration in the downstate New York area, solar photovoltaics (PV) oriented southwest and tilted 30° can achieve a 70% capacity value. Using these configurations, it would take about 230 MW of installed solar PV to match the contribution to reliability from the four turbines in the Bronx.

To calculate out how many megawatts of solar photovoltaics (PVs) would be needed to match the annual net load from the Bronx peakers15, I used hourly capacity factor data from a report prepared

15 100 GWh

16 for the New York City Economic Development Corporation (NYCEDC) by Bright Power (2009). Because of variations in solar radiation throughout the day and year, installed solar PV’s capacity factor varies as well. Using month averages for each one-hour interval, I calculated that producing 100 GWh of electricity would require approximately 70 MW of installed solar capacity (Bright Power, 2009; EPA,

2016). That’s about twice as much as the City’s current installed capacity as of October 2015 (New York

City [NYC], 2015). Solar output peaks around noon, while the hour interval with the highest generation from the turbines is between 5:00 and 6:00PM (Bright, 2009; United, 2016).

Using the same assumptions as NYC (2015), I calculated that approximately 8,750,000 square feet of usable roof area would be needed to install 70 MW of solar PV in New York City (NYC, 2015).

Such capacity could be achieve by utilizing all the possible roof space east of Halleck St and south of

Ryawa Ave in Hunts Point, along the waterfront from Stony Point to Tiffany St but southeast of the train tracks and Leggett Ave, along the entire Bronx Kill waterfront south of 132nd St, and on Rikers Island

(NYC, 2015) (see below).

17 While 70 MW of solar would be enough to replace the megawatt-hours from the four turbines, it would likely not be enough to replace their reliability. In fact, the more wind and solar power are integrated into the grid, the more we may need to rely of gas-fired turbines to cope with their intermittency (Wesoff, 2011). Unfortunately, storage on such a large scale may not be feasible for decades (Fox-Penner, 2014). Gas turbines can be fired up and down quickly, making them valuable to pick up the slack when the wind stops blowing or the sun stops shining (Wesoff, 2011). This could cause a net increase in output from the remaining six turbines, most of which are in low-income and minority communities (NYPA, 2001).

Renewable energy can eliminate greenhouse gas emissions by forcing fossil fuel plants to run at lower capacity, thus making the plants less profitable their energy more expensive for consumers

(World, 2016). If fossil fuel plants have to remain online, consumers still have to pay that capacity cost

(ClimateWire, 2013). While it’s important for clean energy to be cheaper than high-carbon energy, there should be mechanisms in place to avoid higher prices for our most energy-burden consumers. Lower- income communities might not have the means to choose between energy sources, but incentives could be put into place to make renewable energy a more viable option for those who otherwise can’t afford it.

Demand-Side Management

Considering their size, the South Bronx turbines are much more valuable in terms of their reliability than they are in the energy they provide. Over the last four years16 they have averaged a capacity factor of 7%. Considering the challenges of ensuring reliability with offshore wind and solar PV, it may be more effective to utilize strategies that focus on reducing peak demand. Con Edison and the

New York State Research and Development Authority (NYSERDA) have a program to do just that –

16 2012 - 2015

18 replacing power plants with demand reduction (Audin, 2016). Inspired by the possible closing of the

Indian Point Energy Center, a 2,000 MW nuclear power plant, Con Edison and NYSERDA started the

Demand Management Program (DMP) in July 2014, which enhances incentives for Con Edison customers who install energy efficiency technologies (Demand, 2016). Eligible projects and their increased incentives are listed below:

The program’s target is to achieve a 125 MW reduction in peak demand by June 1st, 2016

( [ConEd], 2016). Coned (2016) shows that approved energy efficiency and demand reduction projects had already exceeded the 125 MW target by 10 MW. About 110 MW had been committed for $134 million in incentives and 17 MW achieved for $17 million. About $13 million have been approved for an expected 8.4 MW reduction from combined heat and power projects. Con Edison and NYSERDA anticipate that these numbers will drop from some projects dropping out of the program, but part of the reason projects may drop out is because they may not have time to fully implement them before June 1st (ConEd, 2016). At this rate of return on investment, it’s quite possible that a 2-year extension of the DMP alone could be enough to eliminate the need for all four Bronx turbines. According to Audin (2016), member of the Association of Energy Engineers’ (AEE) Hall of Fame, 1993 International

Energy Manager of the Year and president of Energywiz, Inc., “the most powerful, immediate, and

19 probably cost-effective way to cut peak demand at this time is to extend the [DMP]… Extending that deadline for another 2 years (or more) would help greatly toward the development of large projects for cutting end user demand.”

But reducing peak demand by 160 MW by extending these incentives may not account for the megawatt-hours provided by these turbines. Demand-response commitments have a high capacity value potential, depending on the duration and number of calls17, but energy use reduction is limited to periods of peak demand (New York Independent System Operator [NYISO], 2012). Thermal energy storage, which utilizes cheaper baseload power at night to make ice to cool buildings during the day, is effective at reducing peak demand but may actually increase the total amount of electricity required

(Komanoff, 2016b). Efficient lighting, however, is effective at reducing both MW and MWh. In fact, the analysis by Hinge et al. (2012) found that a 160 MW peak electric demand reduction could be achieved if all the easily accommodating New York City office space18 were retrofitted with comprehensive, advanced daylighting controls. The analysis also found that this level of peak demand reduction would account for 340 GWh of electricity savings.

17 According to NYISO (2012), 1,800 MW of demand-response penetration can reach a capacity value of nearly 100% if the number of calls reaches 30 days a year at a length of 10 hours each. 18 114 million square feet (Hinge et al., 2012).

20 CONCLUSION

This report evaluates only a few alternatives for ensuring electricity reliability, but those selected offer a wide range of strengths – from offshore wind, which is much more powerful than it is reliable, to thermal energy storage, which can provide reliable peak reduction precisely when needed but may not help to reduce energy usage. Depending on what may be needed most (MW or MWh) or what programs are already in place versus what can be expanded or implemented, this assessment is meant to provide critical tools to be used towards recommending a plan for replacing the four gas turbines in the South Bronx. The methods I used can also be applied to other fossil fuel plants.

While synthesizing my findings, I was reminded of Bent Flyvbjerg’s essay Bringing Power to

Planning Research is which he writes, “Power has a clear tendency to dominate rationality in the dynamic and overlapping relationship between the two. Paraphrasing Pascal, one could say that power has a rationality that rationality does not know.” (Flyvbjerg, 2012). I have made an attempt with this paper to explore the relationship between power and rationality, and to show that while each can lead to the other, those who have power have to ability to invent their own rationality. I hope these findings can help close that gap.

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