Energy Policy

From: Friends of Science Calgary

By: Ken Gregory, P.Eng.

Date: December 21, 2021

The Cost of Net Zero Electrification of the U.S.A.

Executive Summary

Many governments have made promises to reduce greenhouse gas emissions by replacing fossil fuels with solar and wind generated electricity and to electrify the economy. A report by Thomas Tanton estimates a capital cost of US$36.4 trillion for the U.S.A. economy to meet net zero emissions using wind and solar power. This study identifies several errors in the Tanton report and provides new capital cost estimates using 2019 and 2020 hourly electricity generation data rather than using annual average conditions as was done in the Tanton report. This study finds that the battery costs for replacing all current fossil fuel fired electricity with wind and solar generated electricity, using 2020 electricity data, is 109 times that estimated by the Tanton report. The total capital cost of electrification is herein estimated, using 2020 data, at US$433 trillion, or 20 times the U.S.A. 2019 gross domestic product. Overbuilding the solar plus wind capacity by 21% reduces overall costs by 18% by reducing battery storage costs. Allowing fossil fuels with carbon capture and storage to provide 50% of the electricity demand dramatically reduces the total costs from US$433 trillion to US$24 trillion, which is a reduction of 94.6%. Battery storage costs are highly dependent on the year’s weather and the seasonal shape of electricity demand.

Introduction

The U.S.A. government has set a target to reduce greenhouse gas emissions from fossil fuel use and cement manufacturing to net zero economy-wide by no later than 2050. Some believe we could achieved this by replacing most fossil fuel use with non-emitting energy sources and sequestering carbon dioxide (CO2) emissions from the remaining fossil fuel use by carbon capture and storage (CCS).

This article provides an estimate of capital costs to achieve net zero emissions in the U.S.A. based largely on an analysis by Thomas Tanton in his report “Cost of Electrification: A State-by-State Analysis and Results”. [1] Estimating the increased operating costs is beyond the scope of this study. (continue reading)

The Cost of Net Zero Electrification of the U.S.A.

Solar is intermittent. Therefore, solar generation is intermittent. Solar is unreliably available during the day and reliably unavailable at night. Solar conditions vary geographically and seasonally. Therefore, solar generation potential varies geographically and seasonally. Solar generation has been implemented initially in the best locations for solar generation potential. However, expansion of solar generation would require installations in less than ideal locations.

US Energy Information Administration reports a capacity factor of 25% for solar generation. Virtually all solar generation in the US and globally is redundant capacity, in that it cannot replace dispatchable conventional generation in a reliable grid, though it can displace the output of that conventional generation when solar generation operates.

Solar arrays are typically proposed and reported based on the rating plate capacity of the solar generators. However, since the solar collector capacity factors are in the 25% range, their annual potential output is typically a quarter of the annual potential output of a conventional generator of the same rating plate capacity.

Solar generation must be supplied with full capacity backup to replace the solar generator output when the sun is not shining. This backup capacity is currently provided by the conventional generation fleet. This is also true of most rooftop solar installations. Some rooftop solar installations include storage plus excess solar collector capacity to permit them to operate independent of the utility grid.

Solar generation capacity cannot be permitted to increase beyond the capacity of the conventional generation fleet if the grid is to remain reliable. This situation could result from an increase in solar generation capacity or from a decrease in conventional generation capacity, or both.

The full cost of solar generation includes the capital, operating and maintenance costs of the solar array plus the capital and operating costs of the conventional backup generation required when the solar generation is unavailable. The solar industry typically ignores the real cost of conventional backup, so that it can claim that solar generation is cheaper than conventional generation.

As conventional generation is retired, either because of age and condition or because of environmental regulation or Executive Order, its capacity must be replaced by storage capable of storing the rating plate output of the conventional generators for the maximum period of time solar generation might be unavailable, plus additional solar generating capacity sufficient to recharge the storage in the shortest period of time between solar interruptions. In this case, the full cost of solar generation includes the capital, operating and maintenance costs of the solar array plus the capital, operating and maintenance costs of the storage and the extra solar generation capacity required to recharge storage.

Clearly, solar generation is not cheaper than conventional generation when its full costs are considered. Solar generation increases total generation investment in the short term, since it is redundant capacity. It also increases grid investment in the longer term, since it requires both storage capacity to backup the solar generation and additional solar generation capacity to recharge storage. The undepreciated investment in conventional generation retired by environmental regulation or Executive Order also remains as a grid investment, further increasing the cost of the solar generation plus storage which replaced it.

The expected service life of solar PV collectors is 20-25 years. This compares with the 40-year depreciation period for utility generation assets. This shorter service life expectancy increases the cost of ownership of the solar array.

By: PragerU

Wind is intermittent. Therefore, wind generation is intermittent. Wind is unreliably available around the clock. Wind conditions vary geographically and seasonally. Therefore, wind generation potential varies geographically and seasonally. Wind generation has been implemented initially in the best locations for wind generation potential. However, expansion of wind generation would require installations in less than ideal locations.

US Energy Information Administration uses a capacity factor of 40% for new onshore wind generation. The International Energy Agency uses a capacity factor of 50% for offshore wind generation. Virtually all wind generation in the US and globally is redundant capacity, in that it cannot replace dispatchable conventional generation in a reliable grid, though it can displace the output of that conventional generation when wind generation operates.
 
Wind farms are typically proposed and reported based on the rating plate capacity of the wind generators. However, since the wind turbine capacity factors are in the 40-50% range, their annual potential output is typically half, or less, of the annual potential output of a conventional generator of the same rating plate capacity.

Wind generation must be supplied with full capacity backup to replace the wind generator output when the wind is not blowing, or is blowing at too high a velocity for the turbines to operate. This backup capacity is currently provided by the conventional generation fleet.

Wind generation capacity cannot be permitted to increase beyond the capacity of the conventional generation fleet if the grid is to remain reliable. This situation could result from an increase in wind generation or from a decrease in conventional generation capacity, or both.

The full cost of wind generation includes the capital, operating and maintenance costs of the wind farm plus the capital and operating costs of the conventional backup generation required when the wind generation is inoperable. The wind generation industry typically ignores the real cost of conventional backup, so that it can claim that wind generation is cheaper than conventional generation.

As conventional generation is retired, either because of age and condition or because of environmental regulation or Executive Order, its capacity must be replaced by storage capable of storing the rating plate output of the conventional generators for the maximum period of time wind generation might be unavailable, plus additional wind generating capacity sufficient to recharge the storage in the shortest period of time between wind interruptions. In this case, the full cost of wind generation includes the capital, operating and maintenance costs of the wind farm plus the capital, operating and maintenance costs of the storage and the extra wind generation capacity required to recharge storage.

Clearly, wind generation is not cheaper than conventional generation when its full costs are considered. Wind generation increases total generation investment in the short term, since it is redundant capacity. It also increases grid investment in the longer term, since it requires both storage capacity to backup the wind generation and additional wind generation capacity to recharge storage. The undepreciated investment in conventional generation retired by environmental regulation or Executive Order also remains as a grid investment, further increasing the cost of the wind generation plus storage which replaced it.

The expected life of wind turbines is 20-25 years. This compares to the 40-year depreciation period typical for conventional generation, increasing the annual ownership costs of the wind farm.

Dominion Energy has proposed Coastal Virginia Offshore Wind (CVOW), the first large offshore wind project in the United States. CVOW would be a 2.6 GW wind farm consisting of 176 15 MW wind turbines, 3 offshore electric substations, underwater and onshore power delivery cables, a collector station and an interconnection to the existing Dominion grid.

The estimated cost of the project is $10 billion, or approximately $57 million per wind turbine. The 15 MW Siemens Gamesa wind turbines are the largest commercially available wind turbines and will be mounted 800 feet above mean sea level, approximately 27 miles offshore of Hampton, VA.

The International Energy Agency (IEA) estimates the annual capacity factor of offshore wind turbines at 50%. I will use this estimate, since there is no commercial experience with these new wind turbines and no experience with offshore wind turbines in the Norfolk, VA area. At this capacity factor, the actual average annual capacity of the CVOW wind farm would be approximately 1.3 GW, fluctuating over a range from 0 – 2.6 GW. The output of the CVOW wind farm, as proposed, is non-dispatchable. Therefore, it would require either conventional generation backup or massive electricity storage capacity.

The daily average power generated by the CVOW wind farm would be approximately 31 GWh (1.3 * 24). Therefore, storage capacity of approximately 31 GWh would be required to replace wind farm output for each low/no wind day. Replacing wind farm output over a 10-day wind drought similar to that experienced in the UK and Western Europe in the Fall of 2021 would require long-duration storage of more than 300 GWh. Such long-duration storage is not currently commercially available and there is no schedule for its commercial availability.

The National Renewable Energy Laboratory (NREL) estimates the current cost of 4-hour battery storage at $350/kwh. This cost is projected to drop to an average of $150/kWh by 2050. Since long-duration storage capable of a 10-day operating cycle is not commercially available and its future cost is unknown, I will use the current cost of 4-hour storage to estimate the cost of making the output of the CVOW wind farm dispatchable. The approximate 300 GWh long-duration storage requirement is equal to 300,000,000 kWh, at a storage system cost of $350/kWh, or a total cost of approximately $105 billion, or approximately 10 times the cost of the wind farm.

Storage is a passive component of the overall wind energy system. Storage must be charged with surplus electricity generated by the wind farm or elsewhere in the Dominion grid; and, it must also be recharged after each use. While this could be accomplished today using the Dominion grid’s conventional generation capacity reserve margin, charging and recharging in a renewable plus storage grid would require additional renewable generating capacity beyond the capacity required to serve the contemporaneous demand of the grid. The additional renewable generating capacity required to charge and recharge storage would be determined by the number of days allowed for charging and especially recharging storage.

“A goal without a plan is just a wish.”, Antoine de St. Exupery

The Biden Administration has announced several goals to be achieved regarding climate change, culminating in Net Zero GHG emissions by 2050 in the US. However, the Administration has not publicly introduced plans to achieve these goals, though the elements of such plans must be in existence.

Certain elements of such plans have begun to become obvious over the past 15 months. The Administration has taken numerous actions to hamper the exploration for and production of oil and natural gas to starve the market for these commodities, including delaying or canceling lease sales and “slow walking” operating permits on existing leases. The Administration has also encouraged the financial markets to deny financing to new fossil fuel projects. The Administration is also preparing new environmental regulations intended to make oil and gas production, transmission and distribution more difficult and expensive.

These actions have resulted in an approximate doubling of fossil fuel prices. The intent of these actions and the resulting increases is to make fossil fuel use less attractive and thus make electric end-use more attractive to consumers and businesses. The most obvious manifestation of this intent is the promotion of electric vehicles of all types, including purchase incentives and federal support for the installation of EV fueling infrastructure. The Administration has actually recommended that people buy EVs to avoid increasing gasoline prices. The recent ban on imports of Russian oil will likely further increase gasoline prices, which have already doubled under the Administration.

The Administration is also actively promoting renewable electricity generation and providing continuing incentives for the construction of wind and solar generation. However, wind and solar generation represent redundant generating capacity, since they require full conventional generation backup in the absence of electric energy storage sufficient to power the grid during periods of low/no wind and solar generation. The conventional backup requirement, combined with dispatch preferences for renewables when available, increases the cost of utility electricity while disincentivizing the operation of the conventional backup generation, which operates at progressively lower capacity factors and thus higher cost per unit of power generated.

Interestingly, the proliferation of renewable generation is increasing electricity costs and thus increasing the cost of the electricity required to recharge the batteries in the EVs being promoted to avoid rising gasoline costs.

Perhaps the most interesting outcome of these Administration actions and the resulting price increases and electric grid reliability issues is the “Blame Game”, in which the Administration denies any responsibility for the results of its actions and points the “finger of blame” at the oil and gas industries and the electric utility industry.

The Administration is joined in pointing the “finger of blame” at the electric utility industry by the developers of renewable generation projects, who assert that the utilities should be responsible for extending transmission lines to their projects and also for providing sufficient electricity storage to meet grid demand during periods of low/no wind and solar generation. That position allows the renewable developers to brag about their low generating costs while blaming the utilities for the increased utility rates resulting from these transmission and storage investments.

From: McKinsey Sustainability

By: Rory Clune, Laura Corb, Will Glazener, Kimberly Henderson, Dickon Pinner, and Daan Walter

Date: May 5, 2022

Navigating America’s net-zero frontier: A guide for business leaders

With the United States’ announcement of targets to halve US greenhouse-gas (GHG) emissions by 2030 and reach net-zero emissions by 2050, the world’s largest economy (and second-largest emitter) has joined some 130 nations in its intention to act on climate change.1 Some 400 large US-based companies have also committed to net-zero targets of their own, many of which have set ambitious emissions reductions targets for 2030 or sooner.2 In our experience, few have yet turned those pledges into detailed plans for adjusting their business models to thrive in a net-zero economy.

Creating an effective business plan for the net-zero transition won’t be easy, for uncertainty surrounds the pace and scale at which this transition will progress in America and in other countries. That uncertainty has been compounded by the conflict in Ukraine, which has increased the world’s attention to energy security, creating both tailwinds and headwinds for the energy transition. In light of this uncertainty, US companies may wish to assess the business risks and opportunities and the socioeconomic impacts associated with the transition. We believe the companies that understand these factors can better position themselves for long-term success and positive impact. Those that delay action may miss out on growth prospects that should arise as institutions in America and elsewhere strive to eliminate GHG emissions in pursuit of national and corporate targets.

This article is intended as a guide to America’s net-zero transition. It examines four topics critical for business leaders as they shape strategies for this defining decade. First, we describe America’s starting point and trace a pathway that we modeled for achieving federal net-zero targets. Next, based on this pathway, we identify five areas in which climate solutions could offer enormous potential for both emissions abatement and economic growth through 2025: renewable power, electrification, operational efficiency, clean fuels, and carbon capture. We then examine several macro trends that business leaders should anticipate. Finally, we suggest how executives might define their company’s approach to the transition. Even if the transition plays out differently from what our scenario envisions, it appears that a time of climate-focused innovation, investment, and change has arrived—and that leaders would do well to prepare for it. (continue reading)

Navigating America’s net-zero frontier: A guide for business leaders

Definition of uncertain (Merriam-Webster)

1a : not known beyond doubt : dubious an uncertain claim
b : not having certain knowledge : doubtful remains uncertain about her plans
c : not clearly identified or defined a fire of uncertain origin
2 : not constant : variable, fitful an uncertain breeze
3 : indefinite, indeterminate the time of departure is uncertain
4 : not certain to occur : problematical his success was uncertain
5 : not reliable : untrustworthy an uncertain ally

We live with uncertainty and make the best decisions we can based on the uncertain information available. Weather and climate are not constant, nor is our knowledge regarding what they are and what they will be in the future. Many factors regarding climate are not known beyond doubt, such as climate sensitivity and feedback. Many weather and climate events are problematical and their timing indefinite, including ENSO (El Niño-Southern Oscillation) events, PDO (Pacific decadal oscillation) and AMO (Atlantic Multidecadal Oscillation) shifts, tropical cyclone timing, frequency and intensity, tornadoes, droughts and floods. The origin of wildfires is frequently unidentified. Forecasts of future weather and climate events are not reliable. The existence of multiple but differing near-surface temperature records, sea level rise measurements and climate model projections are all examples of uncertainty regarding climate and climate change.

The uncertainty regarding weather and climate leads to uncertainty regarding the performance of systems dependent on weather, such as wind and solar electric generation. History provides some basis for estimating typical wind velocities and solar insolation levels in specific locations. However, sufficient uncertainty remains to require the inclusion of some redundant generating and storage capacity to deal with events beyond previous experience. The recent “wind drought” and extended period of below normal solar insolation which affected the UK and Western Europe are examples of such events. Daily variations in wind speed and solar insolation are reasonably predictable, but the accuracy of the predictions declines over longer periods.

The goals of electrifying all energy end uses and supplying all of them with a renewable electric generation and storage infrastructure add additional uncertainty regarding the pace of the transition and the relative efficiencies of the fossil and electric end uses. There are also end uses, such as the production of iron and steel and the calcining of cement, for which there are currently no non-fossil alternatives and for which the potential availability of alternatives is unknown.

The uncertainties regarding weather and its impact on the operation of weather-dependent electric generating systems greatly complicate the design and operation of a renewable plus storage electric grid. The frequency and duration of low/no wind and solar events affect the design capacity of the generation system, the relative design capacity of wind and solar generation in the system, and the capacity and discharge rates of the storage.

The mix of these system components would vary considerably from region to region within the US and around the globe as a function of wind and solar availability. The design of the storage systems will be heavily dependent upon the mix of wind and solar and upon the likely frequency and duration of low/no wind and solar events.

From: Gatestone Institute

By: Francis Menton

Date: April 25, 2022

A Mostly Wind- and Solar-Powered U.S. Economy Is a Dangerous Fantasy

When President Biden and other advocates of wind and solar generation speak, they appear to believe that the challenge posed is just a matter of currently having too much fossil fuel generation and not enough wind and solar; and therefore, accomplishing the transition to "net zero" will be a simple matter of building sufficient wind and solar facilities and having those facilities replace the current ones that use the fossil fuels.

They are completely wrong about that.

The proposed transition to "net zero" via wind and solar power is not only not easy, but is a total fantasy. It likely cannot occur at all without dramatically undermining our economy, lifestyle and security, and it certainly cannot occur at anything remotely approaching reasonable cost. At some point, the ongoing forced transition... will crash and burn.

[I]t doesn't matter whether you build a million wind turbines and solar panels, or a billion, or a trillion. On a calm night, they will still produce nothing, and will require full back-up from some other source.

If you propose a predominantly wind/solar electricity system, where fossil fuel back-up is banned, you must, repeat must, address the question of energy storage. Without fossil fuel back-up, and with nuclear and hydro constrained, storage is the only remaining option. How much will be needed? How much will it cost? How long will the energy need to remain in storage before it is used?(continue reading)

A Mostly Wind- and Solar-Powered U.S. Economy Is a Dangerous Fantasy

By: PragerU

From: Master Resource

By: Robert Bradley Jr.

Date: April 26, 2022

“A Promise Kept: Biden’s War on American Energy”

Some policy statements and summaries are valuable for the historical record. The Republican review below highlighting Biden oil policies relative to gasoline prices is worth studying and memorializing.

Presidential politics and tone are important to the investment health of consumer-driven, taxpayer-neutral energies. Biden campaigned against the very energies the America needs, including those of motorists and other consumers of transportation fuel. Ditto for natural gas. Ditto for coal in the generation of electricity.

It is past time for the oil, gas, and coal industries to wise up and stop trying to appease the radical left. It is past time for Democrats to become the party of the working class. And it is past time for Republicans to become more consistent and forceful against government favors to any energy (ethanol and nuclear included) and any technology (carbon capture and storage) that a business lobby wants. (continue reading)

“A Promise Kept: Biden’s War on American Energy”

By: PragerU

The wind and solar generation systems installed in the US have been installed in the most favorable locations available, for obvious reasons. However, as wind and solar generation are expanded toward a renewable plus storage generation infrastructure and electric demand increases as the result of electrification of transportation, residential, commercial and industrial appliances and equipment, wind and solar installations will have to be extended into less favorable locations.

US EIA Electric Power Monthly reports the annual average capacity factor of US wind installations as 35.3%, with capacity factors ranging from 28.2% - 41.1% seasonally. The annual average solar photovoltaic capacity factor is reported as 24.2%, with capacity factors ranging from 14.9% – 33.3% seasonally. These capacity factors would be expected to decrease somewhat as installations expanded into less favorable locations. However, capacity factors for offshore wind installations are expected to be somewhat higher than for onshore wind, in the range from 40-50%.

Solar installations in the northern tier of the US would be expected to have lower capacity factors during the Winter as the result of the lower sun angle and snow accumulations on the collector surfaces. Wind turbines operating in colder climates would require heating of the blades to avoid snow and ice accumulations, which would impose parasitic power consumption on the turbine generating capacity.

However, the greatest expected impact on renewable generation capacity factors would likely be the need to overbuild generation to have excess capacity available to recharge storage when storage replaces fossil generation as grid support when renewable generation fluctuates and during periods of low/no wind and solar availability. Significant renewable generation capacity would be in surplus during periods of good wind and solar availability when storage is fully charged.

The analysis of the need for storage is somewhat simpler for solar than for wind. On a clear day, solar collectors might generate at rated capacity for as long as 8 hours. However, they will predictably generate no electricity for the remaining 16 hours of the day. Therefore, any loads they serve would have to be served from surplus wind availability or from storage. Some solar generators are installing 4-hour storage to serve the daily peak in the late afternoon, after the solar system stops generating. However, that storage capacity must be recharged from excess capacity during the 8-hour solar generating day.

Wind generation is less predictable throughout the day and its fluctuations and interruptions must be met from storage, which must also be recharged from excess capacity during the day.

The increased investment resulting from generation overbuilding and the requirement to provide short and intermediate duration storage to smooth fluctuations in renewable generation output and long-duration storage to support the grid during periods of low/no wind and solar availability will also substantially increase the cost of the renewable plus storage grid. However, these additional costs are unavoidable if the grid is to be stable and reliable and not subject to catastrophic failure. Renewable generation developers have been able to ignore these issues in the mixed renewable and fossil grid, but will be unable to do so going forward.

The electric utility grid requires instantaneous balancing of demand and supply. Historically, most fluctuations on the grid were the result of changes in customer demand. However, as intermittent renewable sources of generation are added to the grid, changes in the output of wind and solar generation sources increase the complexity of grid balancing. A recent report by Elexon regarding grid balancing in the UK illustrates the rapid increase of grid balancing costs as the intermittent renewable fraction of generation increases. The report suggests that this trend will continue as the percentage of intermittent generation on the grid increases.

The principal source of grid balancing generation in the UK is natural gas combined-cycle generators, as it is in the US. Battery storage is currently a minor source, though it is planned to grow considerably. However, it is critical that battery storage growth exceeds the rate of reduction of capacity of the other sources of grid balancing generation, particularly natural gas generation. This is especially important because of the anticipated growth of electric demand resulting from the electrification of transportation, residential, commercial and industrial energy consumption.

As the transition from fossil generation to renewable generation proceeds, the contemporaneous transition from fossil grid balancing to storage grid balancing would increase the renewable generation capacity required to support the grid. Storage would support the grid during periods of low/no wind and solar generation, but would require the availability of renewable generating capacity in excess of the contemporaneous grid demand to recharge the storage batteries so that they are ready for the next requirement for grid balancing.

The excess generating capacity required would be a function of the duration of the grid balancing demand on storage resources and the period over which storage must be recharged. For example, the “wind drought” which affected the UK and parts of Europe in the fall of 2021 lasted for approximately 10 days. In that case, the grid balancing was accomplished with fossil generation in the UK and nuclear-generated electricity imported from France. However, in a renewable plus storage grid, the balancing generation previously provided by fossil generation would have to be replaced by withdrawals from storage. A requirement to replace the electricity drawn from storage in such a 10-day period over the following 10 days would require a doubling of renewable generating capacity, half to serve the contemporaneous demand of the grid and the other half to recharge storage, assuming no further demands on storage for grid balancing over that period.

It has been common in the US grid to maintain a 20% capacity reserve margin relative to peak demand, should one or more generators need to be taken offline for maintenance or repairs. In a renewables plus storage grid, both the renewable generation and the storage system would have to include such a capacity reserve margin. A requirement to function through a 10-day period of low/no wind and solar and to recharge storage over the succeeding 10-day period, with a 20% capacity reserve margin, would require renewable generating capacity approximately 2.4 times peak demand on the grid.

This commentary suggests a reporting format for the renewable plus storage demonstration discussed in the prior two commentaries.

• Renewable Demonstration
• Transparency

This proposed demonstration project has several important objectives:

• Create a unique renewable plus storage service area
• Force design of a standalone capable renewable plus storage grid
• Highlight the critical nature of electricity storage in this grid
• Highlight the evolving status of grid storage technology
• Highlight the sensitivity of this grid to daily and seasonal weather variations
• Document in and out storage losses in real storage systems
• Document inversion system losses in real grid operation
• Demonstrate the advantages of storage at the generation sites
• Establish the real cost of electricity in a renewable plus storage grid
• Document the number and magnitude of grid emergencies
• Document the effects of the transition to electric vehicles on the grid
• Document the effects of the transition to electric appliances and equipment
• Document the effects of the transition to electric industrial processes

The information collected using the form above should be available to the general public on a website designed to provide easily understandable access to information on the performance of the renewable plus storage grid demonstration, since this is the intended future national electric grid. The project should be treated as a learning experience for grid designers and operators, but also for customers served by the grid.

It is regrettable that the demonstration must begin with largely pseudo-storage, rather than physical storage systems. However, it is not possible to design and operate a reliable grid based on renewable generation without storage. The proliferation of renewable generation with conventional generation support has created the impression that renewable generation system design can be simple and inexpensive. However, in a fossil-free generation system, additional renewable generation plus storage must replace the conventional backup currently relied upon for generation when wind and solar generated electricity is not available in sufficient quantities to meet the contemporaneous demand of the electric grid.