In this post last week, I took note that New York’s electric grid system operator, NYISO, has recently issued some clear, if muted, warnings of the impossibility of the energy transition mandated by the state’s 2019 Climate Leadership and Community Protection Act (CLCPA). In a November 2023 Report, NYISO stated (deeply buried at page 52) that “DEFRs are needed to balance intermittent supply with demand,” and those DEFRs must be “significant in capacity.” DEFRs are the elusive and not-yet-invented “dispatchable emissions-free resources.” At a conference the following month, NYISO’s VP for System Integration Planning, Zachary Smith, reiterated the need for these DEFRs in large amounts. Smith presented charts quantifying the capacity of DEFRs needed for New York to “balance” its prospective intermittent wind/solar supply as something in the range of 30+ GW. 30 GW is close to the peak electricity demand for the entire state, and is approximately equivalent to the existing capacity of New York’s fleet of natural gas plants, all of which are mandated to be closed by 2040.

So what is the answer to the great DEFR conundrum? New York’s Public Service Commission, operating from its usual playbook, has initiated a proceeding, under the name Proceeding 15-E-0302, to uncover the answer. My New York co-blogger Roger Caiazza calls this the “DEFR Proceeding,” although I don’t find the PSC using that name. Everybody gets to submit their brilliant thoughts and ideas. So far there seem to be well over 22,000 items entered in the docket — more than any human being can ever read.

In just the past few days, some big comments from important players have floated in. On Monday (June 17), a comment appeared on this DEFR docket co-signed by two environmental NGOs, Earth Justice and the Sierra Club. These are two of the very biggest, best funded, and most vociferous advocates of the urgent necessity of an immediate energy transition away from fossil fuels. With their hundreds of millions of dollars of annual revenue and scores of staffers, surely these guys must have found the answer to the DEFR conundrum.

In fact, incredibly, they have no clue. The basic approach in their Comment is to pooh-pooh the entire idea that large amounts of DEFRs may be needed, on the sole ground that there may be some (unspecified) flaws in the modeling used by NYISO. Their preferred solution is to turn off everybody’s electricity via a central switch when generation drops. Back to the Stone Age!

Here is their topic sentence:

Commenters are concerned that NYISO’s presentation at the December technical conference overstates the need for dispatchable, emissions-free resources (“DEFRs”) and downplays the value of taking steps in the near term to minimize this gap.

OK then, if perhaps NYISO has “overstated” the need for these DEFRs, then what is your alternative calculation of the amount of such resources that will be needed, and what are the assumptions that go into that calculation? They don’t provide any of that, not even a rough estimate or guess of any kind. Instead, they seek to discourage and stop any development whatsoever of these DEFRs:

Rushing to deploy expensive and untested DEFRs risks committing New York to flawed technologies, as it is unclear at the present time which technologies will emerge as commercially scalable and cost effective, much less which ones of the often talked about DEFRs would actually be emissions free.

So if there is to be no development or deployment of DEFRs in the next several years — during which New York is scheduled to close its natural gas plants and electrify both building heat and large numbers of automobiles — then what do you propose as the way to provide the electricity? Basically, all they would allow is “storage, wind and solar.”:

Rather than picking DEFR technologies to subsidize that may end up being sub-optimal, the DPS should focus on accelerating the build out of storage, solar, and wind, along with other existing methods to minimize the DEFR gap.

If “storage” is to be the back-up of intermittent wind and solar, how much will you need, and how much will that cost, and will the storage technology be capable of holding charge as long as will be needed? The only answer provided to these questions is a touching hope for some magical results from a tiny and barely-initiated federal program:

Deployment of new long duration storage to fill any gap may also become a viable avenue for filling whatever gap remains. In fact, just this April the US Department of Energy disbursed $15 million to advance projects seeking to “enable a long-duration capable (10+ hours) energy storage technology. . . .

As readers here know, 10 hours of storage is not enough to get through even one long calm winter night. The real storage need to back up wind and solar for an entire year is more like 1000 hours.

So it looks like we’ll be resorting to those “other existing methods” for balancing supply and demand to potentially fill the DEFR “gap.” What are those? It turns out that that phrase refers to some combination of hoping for imports from neighboring states (don’t they use coal?) and doing away with the idea that you can have electricity when you want it:

Some of these existing methods include but are not limited to improving inter-regional coordination, expanding import capability with inter-regional transmission, expanding intra-regional transmission, increasing energy efficiency and mandatory demand response, and incorporating flexibility of large loads if possible.

“Mandatory demand response” is Maoist-speak for turning off your electricity from central headquarters when the wind isn’t blowing.

Interestingly, about half of this Comment is then devoted to the issue of potentially developing hydrogen infrastructure as the means to back up a wind/solar system. Given that these guys are against investigating any other DEFRs, you might think they would be fans of hydrogen. But you would be wrong. In fact, from this Comment you will learn that they echo the Manhattan Contrarian on the many problems of hydrogen:

[P]ipelines constructed specifically to transport hydrogen do not exist in New York. [E]xisting gas pipelines in New York cannot safely transport more than de minimis concentrations of hydrogen, and creating a new pipeline distribution system for hydrogen would incur enormous costs. Leakage of hydrogen is a serious concern. Due to its small molecular size, hydrogen is prone to leakage rates on the order of 1.3-2.8 times greater than methane. . . . Increasing the mileage of pipelines in New York capable of transporting hydrogen also presents significant cost challenges. . . . [H]ydrogen embrittles steel and cast iron pipelines, necessitating a costly replacement of existing pipeline infrastructure to accommodate hydrogen. . . . [E]ven if existing natural gas pipelines could be easily repurposed to transport higher percentages of hydrogen, the amount of energy flowing through the pipelines would be drastically reduced. . . . [S]toring hydrogen presents both cost and feasibility hurdles.

And on and on from there. No known means of generating reliable electricity meets their standards of environmental purity. Although they will only say it in the Orwellian terminology of “demand response,” these guys are clearly advocating for the end to the idea of electricity whenever you want it.

Mr. Caiazza has many more detailed thoughts on this Comment at his website here.

Bottom line: nobody has the answer to how to keep the lights on after the natural gas plants are closed. For now, we continue to careen toward the disaster.