By Justin Gundlach
Due to damage from Hurricane Irma, the lights are out in much of southern Florida—an inconvenience to many and fatal to some. Meanwhile, in Texas, power still has not been restored everywhere in the aftermath of Hurricane Harvey. As the Wall Street Journal headline says of both states, “Power Outage Pushes Limits.” Utilities and utility commissions in those states and others must learn the lesson these storms have to teach. It is one that New York City and the State’s Public Service Commission (PSC) learned following Hurricane Sandy: as the climate changes, electricity grids designed to deal with historical weather and temperature patterns will become less resilient and, consequently, less reliable.
The Sabin Center for Climate Change Law led the effort to guide New York to this lesson by intervening in a proceeding before the New York PSC after Sandy had wreaked havoc on downstate electricity distribution grids. Consolidated Edison, the utility company responsible for New York City’s grid, had conducted a narrowly focused assessment of its vulnerabilities to climate risks, and as part of its rate request, sought funding for routine triennial operations, maintenance, and investment, and for certain measures to protect against the next Sandy-like event. The Sabin Center argued that ConEd’s assessment was inadequate and proposed to the PSC that electricity ratepayers’ money should also be allocated to (1) a thorough Climate Change Vulnerability Assessment of ConEd’s facilities, and (2) efforts to adapt the grid to the circumstances revealed by the vulnerability assessment’s findings. The PSC endorsed this proposal—not only for ConEd but for utilities statewide. After some delay, ConEd’s thorough vulnerability assessment is underway, and is slated for completion in late 2019.
In a rational world, New York’s experience of flooding amid Superstorm Sandy, complete with an exploding substation and long power outage, would have prompted other state commissions to call on their utilities to examine whether they would be able to keep the lights on amid storms—and other weather events, like heat waves—amplified by climate change. But few have done so (California is a notable exception). Indeed, in May 2016, Florida Power & Light’s (FPL) parent company rejected shareholder calls for an assessment of FPL’s vulnerabilities to sea level rise and related hazards, such as larger storm surges. Consequently, while FPL has buried power lines and replaced many of its wooden utility poles with concrete ones, it remains exposed to unexamined climate-driven hazards. In this, it is not unusual. Few utilities—in Florida, Texas, or elsewhere—have examined their vulnerabilities to climate-driven hazards, much less taken steps to reduce those vulnerabilities. Of course, blindness to vulnerabilities only lasts until dire events, such as Hurricanes Harvey and Irma, reveal them, too late to mitigate the damage.
Few utilities have examined their vulnerabilities to climate-driven hazards, much less taken steps to reduce those vulnerabilities.
Climate change adaptation planning for the electric grid is not uncharted territory. The U.S. Department of Energy has published guides on how to go about the task generally and in relation to sea level rise in particular, as well as a report on electricity grid vulnerabilities and countermeasures in different regions of the country. California’s Public Utility Commission built on those DOE reports in its state-specific guidance to its utilities. And several utilities in and beyond New York and California have conducted climate change vulnerability assessments, albeit of varying scope and depth.
Conceptually, the task is simple: identify gaps between the existing grid’s capabilities and the future environment, and take steps to fill them. It starts by using the best available science to identify probable hazards to grid facilities, such as sea level rise, changing levels of ambient temperature and humidity, changes to precipitation and other features of the hydrologic cycle, and, where appropriate, increasingly frequent and severe coastal storms or wildfires. Practically speaking, this often means partnering with a nearby university to develop down-scaled projections of future climate scenarios for the region.
Next, it requires comparing the parameters generated by those projections to existing design standards and locational choices. For instance, whereas New York City experienced temperatures above 90°F for 14 days each year (on average) from 1971 to 2000, it is projected to experience two to three times as many by the 2050s. During the 2012 ConEd rate case, it was shown that ConEd’s design criteria did not envision such temperature extremes and would have to be revised.
Finally, adapting the grid to address identified vulnerabilities means investing in countermeasures to future hazards. In New York, ConEd has created multiple layers of flood protections (both physical and operational), ensured that communications networks will operate despite the strains that come with big storms, and modified its design ratings and operational standards for hot weather.
The contentious politics of climate change and sizeable expenses involved in assessing and addressing climate-related vulnerabilities have thus far kept many utilities and utility commissions from taking the prudent steps described above. In the case of FPL, its parent company stated its opposition to shareholders’ proposal of annual reports on vulnerabilities to sea level rise in this way: “a proposal that asks the company to speculate on a single aspect of global climate change nearly a century into the future would be a waste of time and money.” But this language also hints at how storms like Harvey and Irma can provide a compelling basis for arguing that this quiescence is dangerous.
Simply put, the nature of this month’s historically unprecedented storms makes clear that vulnerability assessments are not speculation (climate change makes coastal storms more powerful, storm surges bigger, and rainfall more intense), and conducting them can save money, not waste it. Armed with simple questions about what levels of heat and flooding electricity facilities can handle, advocates can push utility commissions to imitate the New York PSC’s prudence. The legal basis is straightforward: all public utility commissions have a duty to advance the reliability of the systems they regulate, and Harvey and Irma have yet again demonstrated that extreme weather events are a great threat to reliability.
This post was originally published on the Sabin Center’s Climate Law Blog.