3.0
ENERGY PLANNING
3.1 Consistency with Energy Planning and Public Interest
3.1.1 Regulatory Applicability
In the Article X process, among the key findings that the Siting Board must make are whether or not the Project complies with state and local laws and whether or not environmental impacts have been adequately mitigated and public health and safety protected. The bulk of the Project’s Application will address these requirements. The Application will also support two additional necessary findings: that the Project was selected pursuant to an approved procurement process; and that the Project is in the public interest.
The Article X statute and the Siting Board regulations require that TGE demonstrate that the Project is reasonably consistent with the policies and long-range energy planning objectives and strategies contained in the most recent New York State Energy Plan or that the Project has been “selected pursuant to an approved procurement process.” PSL168.2(a) and 16 NYCRR 1001.5. The Article X statute also requires a demonstration that the Project is “in the public interest.” PSL168.2(e).
3.1.2 Long-range
Energy Planning and Objectives
The New York State Energy Planning Board releases and
periodically updates the New York State Energy Plan (SEP) in order to provide
strategic direction and policy guidance for energy-related decisions to be made
in the public and private sectors. The
most recent version of the SEP was published in November 1998.
The objective of the plan is to provide the policy framework to assist
state agencies and other energy-related organizations in making energy decisions
that will contribute to a growing economy in a sustainable and environmentally
sound manner.
The SEP indicates that siting of major electric facilities
under Article X may be premised on a determination that the proposed facilities
would promote or contribute to a competitive market for wholesale or retail
provision of electricity. The 1998
SEP promotes competition as a long-range energy planning objective and strategy.
As long as there are sufficient supplies of energy and a sufficient
number of disparate owners, customers should receive not only affordable prices,
but also price stability. Conversely,
when these conditions are not met, neither affordability nor price stability are
likely.
3.1.3 Approved
Procurement Process
On the basis of the 1998 SEP, certain applicants under Article X have petitioned the Public Service Commission for determinations that their market-based independent generation proposals satisfy the requirement of an approved procurement process. On August 18, 1999, the Public Service Commission ruled, based on petitions by Ramapo Energy Limited Partnership and Sithe Energies (dockets 99-E-0084 and 99E-0089) that plants proposed to operate in the competitive electricity supply market will have been selected through an approved procurement process because wholesale electricity competition is reasonably consistent with the 1998 State Energy Plan. The PSC further ruled that future projects would not need to petition the PSC for rulings on a project-by-project basis, but rather left it up to each case-specific Siting Board to make a determination as to whether a particular project will operate in the competitive marketplace, and therefore be a project selected pursuant to an approved procurement process.
3.1.4 Construction and Operation in the Public Interest
One of the findings that the Siting Board must make
prior to issuing a Certificate is that “the construction and operation of the
facility is in the public interest, considering the environmental impacts of the
facility” and the required evaluation of alternatives.
PSL168.2(e). Thus, the finding as to whether a project is in the public
interest includes the necessary evaluation of the impacts of a specific
facility’s construction and operation. It
is also based on the premise that the proposed Project would promote or
contribute to a competitive market for wholesale or retail provision of
electricity. TGE will explain in
the Application why operation of the Project will be in the public interest.
A preliminary explanation is included here.
The proposed Project will be a merchant facility without recourse to ratepayer funds. It will compete with other independent energy producers to supply power through the NYISO to the wholesale electric power marketplace and/or enter into bilateral agreements with electric customers. Competition with other wholesale electricity suppliers allows the competitive retail market to reflect these cost savings to their customer base, including industrial, commercial, institutional and residential users.
From the perspective of air emissions and environmental protection, the proposed Project will be among the cleanest in the world. Gas-fired combined-cycle plants are efficient, modern and reliable. Dispersion of the air pollutant emissions is such that impacts at residential points (open spaces, streets, buildings) are minimal. The Application will include a thorough, cumulative air quality study to support this claim. Furthermore, operation of the newer, modern power plants inevitably displaces operation of less efficient plants because electricity must be supplied instantaneously in order to meet demand, and cannot effectively be stored. For every unit of electric energy produced by the Project, a less efficient – and, in all likelihood, more polluting – unit of electric energy will no longer be produced elsewhere within the New York power grid. To support this claim, TGE will present the results of a detailed system production cost analysis. This analysis will assume the operation of all the Article X plants which have filed applications that have been deemed compliant before TGE’s Application is filed. The analysis will also include the New York Power Authority’s in-City peaking turbines (built during 2001). Thus, TGE will only present its incremental benefit assuming that proposed generation, removal proceeding through the licensing process, is constructed. Potentially, the benefit could be greater if some of the proposed Projects are not constructed.
It must be noted, however, that demonstration of compliance with air quality standards will not rely on this premise of displacement of older generation. The cumulative studies to be presented in the forthcoming Application will analyze new power plants as well as nearby emission sources.
3.2 No Action Alternative
TGE will examine the “no action” alternative. Included in this analysis will be the possible future development of the parcel, its compatibility with local land use and zoning, and environmental implications. The no action alternative will also be viewed from a public policy perspective, as well as from the point-of-view of TGE’s goals.
3.3 Cooling Technology Alternatives
Three cooling technologies are potentially feasible
for facilities such as the proposed Project: 1) a once-through cooling system;
2) a closed loop evaporative cooling system; and 3) an air-cooled condenser (dry
system). The Project has proposed
air cooling. The three systems are
described below.
A once-through cooling system uses water as the heat sink for the plant’s cooling system. A once-through cooling system typically uses approximately 0.5 billion gallons per day. Existing once-through cooling systems in New York draw water from adjacent tidal areas (such as the East River, Arthur Kill, or Hudson River), and then conduct heat exchange between the withdrawn water and the plant’s steam surface condenser, thereby cooling steam back to water. The warmer water is then discharged to the original water source.
A closed loop wet evaporative cooling system uses
water as a heat transfer medium between the steam surface condenser and the
final heat sink -- ambient air. It
is primarily a closed system designed to reuse water to the extent feasible.
Warm water from the condensers is conveyed to a cooling tower, mixed with
ambient air, and cooled through evaporation.
Cooled water returns from the tower and passes again through the steam
surface condensers. In a forced
draft tower, air is moved through the cooling tower by fans.
The tower requires a constant supply of water to make up for cooling
tower evaporation and “blow down” losses.
Using an air-cooled condenser (ACC), also commonly known as
dry cooling, would rely only on ambient air as a direct steamcycle heat
sink without the use of an intermediary heat transfer medium.
Steam turbine exhaust passes through a series of finned tubes while air
is blown over the outer tube surface. Condensate
is discharged from the aircooled condenser and returned to the Project
HRSGs after heat is transferred from the turbine steam exhaust directly to the
air.
The Application will include an analysis that shows why TGE
is proposing an air-cooled system, giving qualitative consideration to:
· land requirements;
· visibility and aesthetics;
· water demand and consumptive water losses;
· incremental water discharge to the sewer and/or into the environment;
· water treatment requirements and quality;
· aquatic biology;
· thermal impacts;
· potential for noise generation;
· public health;
· fogging and icing; and
· the overall efficiency of the system, including its power requirements and associated emissions.
3.4 Power Block
The Application will contain an assessment of the
reliability and feasibility of TGE’s preferred sources of power –
Siemens-Westinghouse 501F turbines and related power block.
Historic performance or reliability data for each of the selected major
generating components will be provided, as will data on the reliability of the
entire selected power block in tandem. Any
alternatives that TGE is considering for the power block will also be analyzed
qualitatively in the Application.
3.5 Fuel Selection
3.5.1 Primary Fuel
Natural gas is the cleanest burning fossil fuel. Natural gas combined cycle turbines offer unparalleled efficiency, and are also very competitive in the long term.
Natural gas supply can be curtailed during severe cold weather. Using a backup fuel can relieve the stress on the natural gas system during such conditions. Backup fuel use will also ensure that while residences, schools, hospitals and firm sales customers are given first-order priority for gas supply, the Project’s ability to operate is unimpeded. For this reason, the use of a backup fuel is an important reliability issue. TGE proposes using such a fuel.
3.5.2 Backup
Fuel
The standard backup fuel being proposed in the current
generation of power plants in the urban northeastern United States is a
petroleum distillate similar to transportation-grade diesel.
Like transportation diesel, it has a 0.05% sulfur content.
One alternative available to TGE is to pursue a backup fuel with less
than a 0.05% sulfur content. Fuels
with ten times less sulfur (0.005% sulfur, or 50 ppm) currently exist in Europe
and other parts of the world, such as Japan, but are not cost-effective and
therefore not currently available in the United States.
The introduction of such a fuel cannot feasibly be mandated in a short
time frame. EPA is presently
reconsidering its policy of mandating such fuels by 2004.
The Project's proposed use of the backup fuel with the lowest available sulfur content may help increase demand for such fuel and thus facilitate its supply for a broader market. Furthermore, the short-term emissions from the Project would be lower with a cleaner-burning fuel oil. For these two reasons, TGE will evaluate both types of backup fuel – the currently available 0.05% sulfur oil and the as yet unavailable 0.005% sulfur oil. In the Application, TGE will also evaluate using firm natural gas. The analysis will include Project technology and viability, reliability, air quality, water use, and surface water protection.
3.6 Peaking Capability
The proposed Project is suited to operate as a baseload unit, but can also be designed with additional peaking capacity above its base output. The two primary types of peaking technologies are additional combustion in the HRSG, also known as duct firing, and methods that increase the mass of air flow through the compressor, hence drawing more fuel and generating additional electricity. This can be achieved by injecting steam or water into the combustion chamber or cooling inlet air. Having some type of peaking capability could provide a valuable benefit during periods of peak electricity or steam demand because it would avoid the need to pursue that peaking capacity at another site, which could be a new development site, with its own set of land use and environmental impacts. Because New York City did not have a sufficient number of plants with peaking capability, an aggressive program of in-City peaking generation was undertaken in spring and summer 2001, with certain environmental, aesthetic, and land use impacts. Whatever peaking technology is selected, if any, would typically be used for brief, intermittent periods. In the Application, TGE will present its alternatives analysis with respect to different peaking technologies. The analysis will be divided into project technology/reliability, air quality and water use.
3.7 Air Pollution Control Alternatives
The Clean Air Act requires alternatives analyses for air pollution control technologies. This comprehensive alternatives analysis will be included as part of the NYSDEC air quality permitting process that is conducted in coordination with the Article X process.