From the Pragmatic Environmentalist of New York
In 2022, Micron announced its plans to build the largest semiconductor fabrication facility in the history of the United States. Micron intends to invest up to $100 billion over the next 20-plus years to construct a new chip fab plant in Clay, New York. A recent letter to the Editor of the Syracuse Post-Standard posed the questions: I wonder why the citizens of our state must be the sole providers of electricity to Micron? Shouldn’t Micron at least share in producing electrical power? The author went on to make recommendations that are inconsistent with the energy density of wind and solar that relate to the viability of the venture. This post documents the response I submitted to that letter.
I am following developments at Micron because the facility is going to be built within five miles of my home. I also follow the Climate Leadership & Community Protection Act (Climate Act) because of its impacts on New York. The letter relates to both interests. The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.
Overview
The Climate Act established a New York “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.” In brief, that plan is to electrify everything possible using zero-emissions electricity. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies. That material was used to develop the Draft Scoping Plan. After a year-long review, the Scoping Plan recommendations were finalized at the end of 2022. In 2023 the Scoping Plan recommendations are supposed to be implemented through regulation, PSC orders, and legislation. Environmental permitting is part of these implementation concerns.
Micron Chip Fab Faciliity
The description in the Environmental Assessment Form states:
Micron intends to invest approximately $100 billion over the next 20 years to build a leading-edge semiconductor manufacturing campus in the Town of Clay on the approximately 1,400-acre White Pine Commerce Park. Micron intends to acquire the White Pine Commerce Park from the Onondaga County Industrial Development Agency (OCIDA) and construct a campus for four (4) memory fabrication plants (also known as Fabs) on the site. Each Fab, and their related facilities, would take approximately three to five years to construct. Interior fit-out of each Fab would continue after the building is complete, resulting in continuous site activity over approximately 20 years. It is anticipated that the first two (2) Fabs would be complete within approximately 10 years, and the second two (2) Fabs would be complete approximately 10 years thereafter. Skilled trade labor will be employed throughout the 20-year period. Each Fab would occupy approximately 1.2 million square feet (sf) of land and contain approx. 600,000 sf of cleanroom space, 290,000 sf of clean room support space, and 250,000 sf of administrative space. Each set of two fabs would be supported by approx. 360,000 sf of central utility buildings, 200,000 sf of warehouse space, and 200,000 sf of product testing space housed in separate buildings.
Micron should share in producing power for its chip fab letter
Scott Love from Jamesville, NY sent a letter to the editor proposing several actions for the power needs of the facility.
After reading the article “Leaders: Grid must grow for Micron, others” in the Dec. 3, 2023, Business section of The Post-Standard, I wonder why the citizens of our state must be the sole providers of electricity to Micron? Shouldn’t Micron at least share in producing electrical power? The acreage covered by the Micron facility roofs should be used for producing solar power. In addition, hydro generators should be considered for the almost 40 miles of pipeline to and from Lake Ontario. On-site wind power should also be considered.
If Micron is to be considered a leader to the future of our community, then it is time for them to be forward-thinking in their planning.
There are several points raised that are ripe for comment in this letter. I submitted the following in response:
Scott Love recently suggested that Micron should share the responsibility to provide the electricity necessary for the facility. I agree with the idea but not his suggested approach.
He suggested that the facility use rooftop solar, think about on-site wind power, and consider hydro in the pipeline from Lake Ontario. That won’t work. The energy density of solar and wind is low. Even if the entire Micron footprint of 1,400 acres was covered with solar panels, panels would provide less than 1% of the power needs. Wind requires even more space so would provide less of the energy needed. Lake Ontario is lower than the Micron site so the water must be pumped up to the facility.
I believe a co-generation facility using natural gas or nuclear power is appropriate. For starters, it would eliminate the need for energy storage when the wind is not blowing or sun not shining. On-site generation makes sense because it reduces line loss and waste heat produced can be used for heating and manufacturing processes. Small modular nuclear reactors are not yet commercially available, but the facility could be designed to use that technology in the future. In the meantime, a combined-cycle gas turbine facility could be built. Carbon dioxide could be minimized by using it in on-site greenhouses that convert it to food.
If Micron is going to be a part of our community, it is time for everyone to be forward thinking and pragmatic about how best to make them competitive.
The remainder of this article summarizes the overall issue of Micron energy requirements and specific concerns with the letter.
Micron Energy Use
In August I prepared an article that described the reaction of Richard Ellenbogen to the massive amount of energy needed by the facility. I correspond with him regularly because he has spent a lot of time evaluating the Climate Act net-zero transition. I recently described his comprehensive presentation on the transition. When I let him know that the original projection for energy use that would be the same as the state of Vermont has been expanded to be the same as Vermont and New Hampshire he responded with the following:
I have been using the Micron facility as an example of how the Climate Act is actually going to increase NY State’s carbon footprint because transmitting all of that energy to the Micron site, as much as is used by the state of Vermont, over long distances was going to result in an amount of lost energy on the wires that could operate 1-3/4 Cornell Universities. One of my readers sent me an update of energy use because now it is projected that the Clay complex will consume 16 billion kilowatt-hours of electricity per year, as much as Vermont and New Hampshire combined, or 16,000 Gigawatt Hours annually (16 Tera-watt hours). That is double the original projections and the idea that this could be supported with renewable generation is laughable. 16,000 GWh is an 11% increase in NY State electric usage just related to the one facility. The line loss will also double to consume the output of about a 100 megawatt fossil fuel plant under continuous operation.
To put the Micron facility’s usage into perspective, in its last full year of operation the 2 Gigawatt Indian Point nuclear plant generated 16.3 Tera-watt hours so the Micron facility will need to be supported by a 2 Gigawatt fossil fuel or nuclear plant on site or 2.1 Gigawatts of generation off site, 5% more. NY State’s policy makes absolutely no sense. To run the Micron facility would require using about 4 GW of the projected 9 GW of offshore wind to support the plant or 16 GW of solar arrays covering 128,000 acres (80 acres per 10 MW) or 200 Square miles. NY State has 7 million acres of farmland so solar arrays to support the Micron facility would use almost 2% of the farmland in the state and would also require an enormous amount of battery storage, the cost of which would greatly exceed the cost of a nuclear plant on site. A combined cycle generating plant on site would be about 75% less than the cost of the nuclear plant. Both the combined cycle gas plant and the nuclear plant on-site offer the option of recovering the waste heat and using it in the plant to make Micron even more energy efficient. With regard to the solar and wind, NY State is having major difficulties getting all of their renewable projects finished because of cost issues and interconnection issues, let alone adding this gigantic lead weight to the Camel’s back.
Micron Sustainability
The fact sheet for the proposed plan describes sustainability initiatives planned:
- Achieve 100% water reuse, recycling and restoration.
- Use 100% renewable electricity at the new facility.
- Use green infrastructure and sustainable building attributes for the construction of the new fab to attain Leadership in Energy and Environmental Design (LEED) Gold status.
- Mitigate and control greenhouse gas emissions (GHG) for the new facility.
- Incorporate energy efficiency measures.
- Utilize green hydrogen – hydrogen formed through electrolysis powered by renewable electricity, without GHG emissions – to the extent feasible to displace/replace natural gas and gray hydrogen consumption.
- Adopt measures to reduce and avoid waste generation and achieve zero hazardous waste to landfill.
I have been asked whether I think this facility will ever get built out as proposed. While I hope that it works out my skepticism increases in direct proportion to the number of commitments to politically correct narratives. This sustainability fact sheet is worrisome in that regard. The viability of this facility hinges on its ability to provide cost-competitive chips that require an energy intensive process. The Climate Act is going to raise energy prices and affect that metric. Consider those pledges relative to competitive viability.
This chip fab plant will use enormous amounts of water. Last summer it was disclosed that the environmental assessment expected that when the plant is fully fitted out that 40 million gallons of water per day would be needed. This would require a new 54” pipeline from Lake Ontario to the facility. It is not clear how that is consistent with the 100% water reuse, recycling, and restoration pledge unless the presumption that discharging to the Oneida River that ends up in Lake Ontario where it comes back to the plan is the 100% recycling mechanism. For my part I am fine with that.
The 100% renewable electricity pledge is a competitiveness problem, however. Ellenbogen’s response shown above addresses many of the issues. In his recent presentation he pointed out that as part of the commitment NYPA has committed to allocating 140 MW of hydro generation to Micron. The problem with that is that it does not represent new hydro. That is just re-labelling the “zero-emissions” attribute from somebody else to Micron for that power.
I have reservations about the remaining pledges. Ultimately, pledging to meet virtue signaling sustainability goals could increase energy costs which I worry could affect the viability of the facility. I have to believe that behind the scenes Micron and the State are going to have to address the tradeoffs of added costs for these pledges.
The pledge to use green hydrogen formed through electrolysis powered by renewable electricity, without GHG emissions caters directly to the Climate Action Council. This one could have major financial effects. Note that the caveat “to the extent feasible to displace/replace natural gas and gray hydrogen consumption”, is the only instance in their sustainability fact sheet where there is any hint that these aspirational goals may not be feasible.
The pledge to use green infrastructure and sustainable building attributes for the construction of the new fab to attain Leadership in Energy and Environmental Design (LEED) Gold status is pandering s well. As long as these efforts reduce energy consumption this virtue signal will not impact the competitiveness of the facility.
Offering to mitigate and control greenhouse gas emissions (GHG) for the new facility is fine but there are regulations that are going to require than anyway.
Incorporating energy efficiency measures is another pledge. As long as these efforts reduce energy consumption that will reduce costs and is common sense approach to adding to viability.
The final pledge to “adopt measures to reduce and avoid waste generation and achieve zero hazardous waste to landfill” probably makes sense financially and adds viability value.
Documentation for my Letter
Love proposed that the facility use rooftop solar, think about on-site wind power, and consider hydro in the pipeline from Lake Ontario. He does not understand the scale of energy required or the concept of energy density. The energy density of solar and wind is low. Using the aforementioned analysis by Ellenbogen I calculated that even if the entire Micron footprint of 1,400 acres was covered with solar panels, they would provide less than 1% of the power needs because it takes a lot of space to gather energy from the sun. It might be counter intuitive but Ellenbogen and I both found references from federal agencies that said wind facilities require even more space to generate the same amount of energy. Due to space considerations, I could not point out that solar and wind resources at the facility site are unlikely to be particularly strong relative to other sites in New York because the site is in the lake-effect cloud belt and the area is flat. I expect that the facility footprint would likely produce even less of the energy needs than projected using state averages. Another point I could not make is that on-site production would need to provide energy storage to be useful.
The proposal to put hydro in the pipeline from Lake Ontario is laughable. Lake Ontario is lower than the Micron site so the water must be pumped up to the facility. That approach is an example of a perpetual motion machine. Ellenbogen also pointed out that even if it was downhill, do they really think that a 54″ diameter water pipe could put a dent in the energy needed? Micron’s 16.2 TWh will use the equivalent to 60% of all of the Hydro in the state or 26.8 TWh. Micron is supposed to use 10 million gallons per day after recycling with a 54″ pipe. That corresponds to 7000 gallons per minute. The Robert Moses / Lewiston Pumping Station uses 750,000 gallons per second or 45 million gallons per minute. That would be 6500 times as much.
Ellenbogen and I independently decided that co-generation would be the most appropriate on-site energy source. We believe a co-generation facility using natural gas or nuclear power is appropriate. The Ellenbogen presentation proposed allowing Micron Technologies to build a 2 GW combined cycle plant on their property. He points out that with generation on-site, the thermal energy could be used at the plant and the 500 GWh of annual line loss will be eliminated.
There are two choices for generation. Small modular nuclear reactors are not yet commercially available, but the facility could be designed to use that technology in the future. In the meantime, a combined-cycle gas turbine facility could be built. The downside of a natural gas co-generation plant is that it will emit CO2. One of the unresolved Climate Action Council questions is whether such a gas-fired turbine that includes carbon capture and sequestration would be allowed. According to the zealots, there still would be emissions and the law says zero emissions. Ellenbogen suggested using greenhouses to reduce CO2 emissions. Using the CO2 in them to enhance growth captures carbon in the plants and waste heat from turbines to warm them would tick off the locally sourced produce target and I am sure creative accounting comparing local produce to the produce shipped from overseas could claim GHG emission reductions. .
Conclusion
The development of Micron within the Climate Act framework will be a good test of pragmatic environmentalism. The tradeoff between Climate Act absolutism, i.e., demanding nothing less than zero, with the extra costs associated with that approach versus the need to keep the Micron facility in New York competitive with the global chip market is an important substantive issue. However, much of the Climate Act is style over substance. The press releases to date talk a stylish game about being green but the approach to making them look “green” is a simply shuffling attributes from existing sources. Ellenbogen and I believe that we should let them be green in reality with high efficiency generation that lowers energy costs to make them more competitive without faking it. For all the talk of jobs associated with the energy transition if the energy transition makes the Micron facility unable to compete on the world market then there will be an enormous hit on jobs.
Energy density is the reason that on-site wind and solar generation would only be virtue signaling. The area simply cannot generate enough electricity to be meaningful. I have no doubt that environmental activists will be upset that I recommend energy dense natural gas or nuclear cogeneration that could be installed on the footprint. However, if Micron is going to be a part of our community, it is time for everyone to be forward thinking and pragmatic about how best to make them competitive.
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