Climate Ambition Must Confront Energy Realities

Sean Sweeney recently authored an intriguing article entitled “A Bridge to Somewhere? Progressive Democrats’ “Climate Ambition” Must Confront Energy Realities”.   This post addresses an unexpected agreement on some aspects for two individuals from opposite ends of the climate change debate.

Sean Sweeney is director of the International Program for Labor, Climate and Environment at the Murphy Institute at City University of New York, and coordinator of Trade Unions for Energy Democracy. His article published in the New Labor Forum mentions deniers in the first paragraph and states that the 2017 hurricane season was severe enough to “warrant climate change to be declared a national emergency?” At the other end of the spectrum when I look at a papers based on actual data I find that “since 1900 neither observed continental United States landfalling hurricane frequency nor intensity show significant trends, including the devastating 2017 season.” As a result I do not believe that climate change is a national emergency.

Nonetheless we find common ground. I agree with Sweeney that “the more ambitious the targets, the harder it is to answer questions about how they will be reached.”

Sweeney describes two bills introduced in Congress in 2017 that represent progressive Democrats’ climate ambition. A Senate bill introduced in April 2017 by Senators Jeff Merkley, Bernie Sanders, and Ed Markey. It calls on the United States to transition 100 percent off of fossil fuels by 2050. The “100 × 50” Act would impose new federal mandates requiring “zero carbon” vehicles, while barring federal approval of oil and gas pipelines. The House bill, submitted by Tulsi Gabbard on September 7, 2017, along with six other representatives seeks to end fossil-fuel use in the United States as early as 2035—a full fifteen years earlier than the 2050 target date proposed by Sanders and Merkley. Titled “Off Fossil Fuels for a Better Future Act” (OFF Act) would also mandate the United States to transition to 80 percent clean renewable energy by 2027 and 100 percent by 2035.

Both bills mandate moratoria on any new coal, oil, and gas projects (extraction and infrastructure, including power plants, pipelines, and export terminals). Sweeney and I agree that these are ambitious goals. I agree with him when he states “Ambition surely has its place, but committing to a crash diet on the morning of January 1 is one thing, being fifty pounds lighter in time for the July 4th weekend is something else altogether.” I also agree that with him when he notes that “the difference between aspirational targets and actual accomplishments is not always acknowledged by leading green nongovernmental organizations (NGOs).” I believe he is also correct when he notes that “Mandating electricity retailers to source 80 percent of their power from renewables does not answer the question how that power might be produced, integrated into the grid, or who will do the work.” As noted on my other blog, the aspirational plans to reduce New York State emissions certainly signal the virtue of the Governor of New York but it is not at all clear how those plans will be implemented, whether anyone is looking to see if there are unintended consequences between competing components of the plan, and, most importantly in my mind, how much will they cost.

Despite our agreement on this aspect I cannot overstate how much I disagree with his statement that those two climate bills are “informed by the core findings of the scientific community”. These targets are arbitrary, reflect a mis-reported 97% consensus and the idea that a portion of the scientific community funded to the tune of over $2.5 billion dollars in 2016 would come up with any conclusion other than “it is a problem and you need to fund us more” is naïve. I agree with Dr. Judith Curry “we do not know how much humans have contributed to the recent observed warming and there is disagreement among scientists as to whether human-caused emissions of greenhouse gases is the dominant cause of recent warming, relative to natural causes.” As a result I do not support mitigating greenhouse gas emissions.

Finally, Sweeney states that “If either bill became law, it would amount to a declaration of war on fossil-fuel interests, because much of the present-day stock market value of coal, oil, and gas companies is based on their below-the-ground reserves.” While I agree that this would be a declaration of war on fossil-fuel companies, I think it represents a much bigger target. I believe that fossil fuels have been one of the greatest things to happen to mankind. Until there are in-kind, same price replacements for the ubiquitous use of fossil fuel in society this targets the way of life of everyone. There is a massive lack of understanding relative to what keeps the lights on and enables our affluent and mobile lifestyles. Once you understand that cutting CO2 to the levels proposed will be extraordinarily difficult it is clear that it will be expensive and it is going to affect our lifestyle. For example, electrification of the transportation and residential heating sectors will be required. Sponsors of these bills owe it to their constituents to explain just how expensive it will be and what will have to change in our lifestyle.

Indian Point Replacement Power – NYISO Official Conclusion

I just became aware of a report by the New York Independent System Operator (NYISO) entitled Generator Deactivation Assessment, Indian Point Energy Center dated December 13, 2017 that is the official response to the question of replacement power for the retirement of Indian Point. This post compares their conclusions with my guesses in earlier posts.

In January 2017 New York’s Governor Andrew Cuomo announced the closure of Entergy’s Indian Point Energy Center (IPEC) located 25 miles north of New York City by April 2021. Cuomo claims that Indian Point produces 2,000 megawatts of electrical power and that “more than enough replacement power to replace this capacity will be available by 2021”. Since that announcement NYS agencies have been analyzing the potential impacts of the shutdown and the NYISO study summarizes their evaluation of the Entergy deactivation notice for IPEC. Entergy reported that it intends to deactivate the 1,299 MW unit 2 on April 30, 2020 and the 1,012 MW unit 3 on April 30, 2021.

NYISO Conclusions

As required by their rules, NYISO performed an analysis of resource adequacy and, in coordination with New York Transmission Owners, transmission security analyses of the New York Control Area to determine whether shutting down IPEC would cause problems with their standards for reliability and capacity. The conclusion was that subject to the assumptions of the study there would be no violations of their standards so “Entergy has satisfied the applicable requirements under the NYISO’s Generator Deactivation Process to retire the Generators on or after its requested deactivation date”.

NYISO assumed that three major generation facilities currently under construction would be available in the base case for this assessment that impact the findings: Bayonne Energy Center II Uprate (Zone J, 120 MW), CPV Valley Energy Center (Zone G, 678 MW), and Cricket Valley Energy Center (Zone G, 1,020 MW). All three are natural-gas fired combustion turbines. The assessment found that “reliability criteria would be met without Indian Point Energy Center throughout the Study Period under the assumed and forecasted base case system conditions.”

In addition, NYISO performed a scenario assessment to evaluate the reliability of the system without those three generation facilities. That scenario concluded “These scenario results demonstrate that, without the expected new generation facilities currently under construction, additional replacement sources of power would be necessary to maintain reliability following deactivation of IPEC.” They noted that “Resource needs could potentially be met by combinations of solutions including generation, transmission, energy efficiency, and demand response measures” and estimated that generic addition of at least 200 MW by 2023 anywhere in the Lower Hudson Valley would resolve the deficiency through a five-year horizon and that to address the deficiency through 2027, additional resources would range from 400 MW to 600 MW depending on type and location of the resources within the Lower Hudson Valley.

My Analyses

I prepared four previous posts on Indian Point replacement power. The first and a subsequent update considered New York State projects that had been permitted to see if there was replacement power in the pipeline that could replace its output. I also analyzed whether renewables and energy efficiency were a realistic alternative and concluded that approach was unlikely to succeed. Finally, I looked at a proposal from the New York Battery and Energy Storage Technology Consortiums to use energy storage as a potential replacement for Indian Point. I concluded that this would also not likely succeed.

Ultimately my conclusion that CPV Valley Energy Center, Cricket Valley Energy Center and the proposed Champlain Hudson Express transmission project could provide replacement power for IPEC is very similar to the NYISO conclusion that CPV Valley Energy Center, Cricket Valley Energy Center and the Bayonne Energy Center II Uprate project could provide the replacement power. The only difference is that my replacement scenario did not export jobs from New York to New Jersey and including the transmission project that uses hydro power from Quebec would have lower emissions. In either case, Cuomo’s claim that there would be no net increase of emissions due to the closure is flat out wrong.

The NY Riverkeeper blog claims that the three gas plants are not needed to replace IPEC. That post seizes on the alternative scenario that concludes that: “resource needs could potentially be met by combinations of solutions including generation, transmission, energy efficiency, and demand response measures.” In addition to my criticisms of their preferred alternatives in my previous posts, there is a timing issue. The plan is to deactivate one unit on April 30, 2020 and the other on April 30, 2021. No significant generation facilities can get through the NYS Article Ten permitting process in less than five years so alternative resources would not be available for the proposed shutdown schedule.

New York State Comments on the Clean Power Plan – February 2018

Officials from twelve states including New York submitted a comment labelled as State Environmental and Energy Regulators’ Comment on Advance Notice of Proposed Rulemaking, Docket ID No. EPA-HQ-OAR-2017-0545 on February 26, 2018. The comments, facilitated by the Georgetown Climate Center, were from: California, Connecticut, Massachusetts, Minnesota, New York, North Carolina, Oregon, Pennsylvania, Rhode Island, Vermont, Virginia, and Washington. The letter discusses the need to reduce emissions of the greenhouse gases that cause climate change and this post reviews their rationale for that need.

EPA requested comments on a proposed rulemaking to revise the Obama-era Clean Power Plan which was a regulation to limit CO2 emissions from power plants. From my pragmatic standpoint the ultimate issue is whether the regulation can actually impact the purported effects better than an alternate response.

The comment starts as follows:

We are environmental and energy regulators from a group of 12 states, and we are providing comment on the Environmental Protection Agency’s (EPA) Advance Notice of Proposed Rulemaking on State Guidelines for Greenhouse Gas Emissions from Existing Sources (ANPRM)[1].

We represent states that are already suffering the economic and human consequences of climate change, and that are leaders in working to reduce the emissions that cause it. Extreme weather events in recent years have continued to cause record damages that disrupt state economies and require years for recovery. For example, in 2017 California experienced almost twice as many wildfires burning six times as many acres as the average over the last five years[2], and these fires were among the deadliest in the state’s history, killing a total of 47 people[3]. The National Oceanic and Atmospheric Administration (NOAA) estimates that Hurricane Sandy caused damages of over $70 billion, and projected damages from Hurricane Harvey total $125 billion[4]. With over $300 billion in estimated losses from disaster events in 2017, last year was by far the costliest year for climate and weather related events, and it also tied the record for the number of billion-dollar disaster events in a single year[5]. Our states are working to reduce harmful climate pollution individually and jointly. Minnesota’s GDP grew by 23.1 percent between 2000 and 2014, while its emissions decreased by 3.6 percent[6]. North Carolina’s Renewable Energy and Energy Efficiency Portfolio Standard has resulted in investments of over $10 billion in clean energy technologies[7], created 34,000 clean energy jobs,[8] and reduced CO2 emissions by 14.6 percent between 2004 and 2014[9]. Since the launch of the multi-state Regional Greenhouse Gas Initiative, carbon emissions from power plants in the region have decreased by 40 percent[10]. EPA should act urgently to reduce the risk to American citizens from further climate impacts, and should take into account the methods our states have already proven as effective and affordable in reducing carbon pollution.

My problem with this rationale is that it only lists a series of weather events but does not explain how much of the observed events are the result of climate change and, therefore, could be affected by the control program they support. Ultimately, the alleged effects of human impacts on climate are not creating new weather-related hazards. Climate change could make weather hazards more frequent and more intense but will not prevent them from occurring in the future.

Consider, for example, the statement “projected damages from Hurricane Harvey total $125 billion”. Hurricane Harvey was “A category 4 hurricane (on the Saffir-Simpson Hurricane Wind Scale) before making landfall along the middle Texas coast. The storm then stalled, with its center over or near the Texas coast for four days, dropping historic amounts of rainfall of more than 60 inches over southeastern Texas.” “Harvey was the most significant tropical cyclone rainfall event in United States history, both in scope and peak rainfall amounts, since reliable rainfall records began around the 1880s”. Not surprisingly with this much rain there was catastrophic flooding and the fact that it happened over the major metropolitan area of Houston made it very costly.

The comment letter states “Extreme weather events in recent years have continued to cause record damages that disrupt state economies and require years for recovery” and uses the very large damage estimate as an example. Not addressed was whether climate change affected the rainfall and thus the damage.

In the first place, using damage estimates is a weak argument for climate change affecting Harvey. If the storm had not stalled over Houston there would have been much less to damage and the costs would have been lower. A recent paper makes the point that “Growth in coastal population and regional wealth are the overwhelming drivers of observed increases in hurricane-related damage”. The paper also shows that there has been no significant change since 1900 in hurricanes that land in the United States for frequency or intensity. So the real argument that the state comments should have made is that Hurricane Harvey itself was affected by climate change.

There are a couple of analyses that do claim that Harvey rainfall was affected by climate change. A team of scientists from World Weather Attribution claimed that human-caused climate change made the record rainfall that fell over Houston during Hurricane Harvey roughly “three times more likely and 15 percent more intense”. Another paper suggests that the annual chance of at least 500 mm (20”) of rain over Texas like that seen from Hurricane Harvey would increase from about 1% between 1981-2000 to 18% by the end of the 21st Century and concludes that the risk from a Harvey event has already increase six-fold in 2017 (a 6% chance of occurrence yearly) versus that from just a couple decades ago.

Both of these analyses use output from dynamical weather forecast models to project the effect of climate change. The theory is that a warmer atmosphere can hold more moisture so rainfall rates would be more intense. Landsea references a study that explains “Theory suggests that the amount of rainfall in the tropical latitudes would go up about 4% per deg F sea surface temperature (7% per deg C). Climate models forced by assuming continued emissions of greenhouse gases suggest around 2-2.5 deg F (1-1.5 deg C) warming by the year 2100, or about 10% more tropical rainfall. Landsea then notes:

Scaling the results from both theory as well as climate model projections suggest, then, that roughly 3% of hurricane rainfall today can be reasonably attributed to manmade global warming. This value is a rather tiny contribution. Thus only about 2” (50 mm) of Hurricane Harvey’s peak amount of 60” (1525 mm) can be linked to manmade global warming.

Landsea goes on to explain why he does not consider the other results reliable. I prefer to use all the results to provide a range of potential outcomes

So even if the State comments had properly considered the real effect of climate change on extreme weather events instead of the inappropriate total cost of a storm, there are a legitimate range of potential outcomes – (15% more intense to 3% more intense). These comments do not provide an appropriate rationale why they believe controls are necessary because they did not provide a science-based argument. Instead they have relied on emotion-based claims of damages without attributing them to climate change impacts.

The Landsea paper lists lessons to be learned from Harvey’s catastrophic flooding that summarize the important points that should be recognized that is written so well I want to include it here:

  1. Hurricanes (and Tropical Storms) have been associated for millenniums with extreme rainfall and freshwater flooding. There is nothing that one can do to prevent these storms from occurring, hitting land, and impacting people;
  2. Massive flooding and catastrophic impact from tropical storms and hurricanes occurs when the system moves slowly over a major city. This is precisely what happened because of Harvey as a tropical storm over Texas;
  3. Flooding is made worse when extreme rainfall occurs over impervious land (such as roads and buildings) and the rain cannot soak in. Land use decisions should better consider allowing building (or rebuilding) in flood prone areas;
  4. Studies should be made to see if evacuating people in advance of extreme flooding rain is feasible. (Currently, only evacuations from hurricanes are primarily issued from possible storm surge – salt-water – flooding. However, because the skill of in day-to-day rainfall amounts and locations continues to improve, it might be feasible to call for limited evacuations in the most vulnerable locations.);
  5. Linking hurricane rainfall to global warming today (and even decades from now) based upon such a tiny contribution is misleading. Moreover, such a fixation can delay steps that can be taken now to better mitigate the effects of extreme flooding from hurricanes. See the following sites for more action today that can be taken: the Federal Emergency Management Agency (FEMA), the Insurance Institute for Business and Home Safety (IIBHS), the Environmental Protection Agency (EPA), and academia (University of Colorado, University of Pennsylvania, and University of Iowa).

Paraphrasing Dr. Landsea, the fixation on reducing greenhouse gas emissions in the Obama-era Clean Power Plan is delaying actions that could and should be done today to mitigate the inevitable catastrophic hurricane damages. The comment letter by these states continues this inappropriate fixation. Moreover, the comments do not provide any indication how much their preferred control options would impact global warming in general or the alleged impacts listed in particular.

[1] 82 Fed. Reg. 61,507 (Dec. 28, 2017).

[2] “Incident Information,” California Department of Forestry and Fire Protection,

[3] California Department of Forestry and Fire Protection, Large Fires 2017: 300 Acres and Greater,

[4] Billion-Dollar Weather and Climate Disasters,” NOAA,

[5] Id.,

[6] Devashree Saha & Mark Muro, The Brookings Institution, Growth, Carbon, and Trump: State progress and drift on economic growth and emissions ‘decoupling’ (December 8, 2016), Fig. 3.

[7] RTI International, Economic Impact Analysis of Clean Energy Development in North Carolina – 2017 Update (Oct. 2017),

[8] U.S. Climate Alliance, 2017 Annual Report, 219/USCA_Climate_Report-V2A-Online-RGB.PDF.

[9] North Carolina Utilities Commission, Annual Report Regarding Renewable Energy and Energy Efficiency Portfolio Standard in North Carolina Required Pursuant to G.S. 62-133.8(J) (October 1, 2017),

[10] “RGGI Emissions Fell Again in 2016,” Acadia Center (March 10, 2017),

Reality Slap to the REV Microgrid Concept

I believe that the Reforming the Energy Vision (REV) call for microgrids will result in the unintended consequence of encouraging the development of natural gas fired combined heat and power units. The most compelling reason is because that approach does not need to include storage in order to provide 24-7 power and any storage component will make that option much more expensive. However that reality does not comport with the dreams of those who believe a no-fossil future is necessary. This brings us to an ideal situation to see how this will be reconciled in New York State.

The ideal candidate for conversion to a combined heat and power unit is an office complex that has a power plant for steam heat and uses grid electricity. The Empire State Plaza in Albany NY is just such a complex. The New York Power Authority (NYPA) has proposed the Empire State Plaza Microgrid and Combined Heat and Power Plant to replace the existing system. However, their rationale ran aground against the idealism of local community members and environmentalists from across the state who assailed NYPA’s plan to replace aging steam turbines in the low-income, predominantly African-American Sheridan Hollow community with two new combined heat and power turbines to provide electricity and steam.

On February 5, 2018 NYPA caved to this pressure and announced that they will do additional studies of the proposed Empire State Plaza Microgrid and Combined Heat and Power Plant project in Albany in order to better evaluate renewable energy options for the project. The press release claimed that:

“This will allow a more comprehensive review of possible alternative energy sources that may be feasible to explore as part of the Sheridan Avenue project to improve reliability, resiliency and energy efficiency at the plaza. The project partners, the New York State Office of General Services and NYPA, will take this time to enlist ongoing engagement and input from members of the public, including local community members, energy experts and advocacy organizations and will incorporate community benefits into the project’s go-forward plan.”

According to slide 8 in the NYPA presentation on the Empire State Plaza CHP and Microgrid Project Overview the Plaza consumes 111,000,000 kWh per year and uses 1,003,084 klbs of steam per year. NYPA proposed two Taurus 70 combustion turbines that will produce more than enough electricity and steam heat to fulfill those needs. The key to the greater efficiency of a combined heat and power facility is that you use the waste heat, in this case to produce steam for heating. The proposed application is ideal because the CHP output can use the existing electrical and steam infrastructure thus saving costs.

According to slide 5 in the NYPA presentation Project Overview Slide 5, NYPA considered and rejected:

  • Solar Photovoltaic
  • Solar Thermal
  • Geothermal
  • Wind Power

Let’s review the feasibility of these alternative energy sources. As noted above my main rationale for using natural gas CHP is that you eliminate the need for storage. In their project overview this issue was not addressed because they noted fatal flaws without it. The more comprehensive review proposed in the press release must address that issue or be compromised.

NYPA noted that there is not enough roof space or appropriate acreage in Albany and that the option does not provide heat for solar photovoltaic as issues. At the simplest level if we assume 0.75 kWH per day per square yard of solar photovoltaic, then you would need 84 acres of space for enough PV cells so I have to agree with the NYPA space argument. Furthermore that is the minimum level needed because PV output varies over the year. In order to do the calculation correctly you would need to match the PV output with the actual daily and seasonal load curves. In any event you would still need to provide energy for heating and that requirement is exacerbated by the fact that the fact that when you need the heat the most the solar energy is lowest.

With regards to solar thermal, NYPA noted that the technology cannot generate steam, space is an issue and it does not provide electricity. If your only requirement is hot water then solar thermal may have value but in this case I agree with NYPA. To use solar thermal for heating you would have to replace the existing heating system, you need the solar thermal collectors contiguous to the facility so space is an even bigger constraint, and the peak need for energy is in winter when the solar energy available is lowest. The final nail in the coffin is that this option does not provide electricity.

Geothermal has two flaws. In the first place it cannot generate steam heat so that means that the existing heating system cannot be used. Secondly, it does not produce electricity.

NYPA noted that wind power is hard to site in urban areas, has safety issues in urban areas, and noted that the area does not have enough wind potential for the project. In addition they could have noted that wind does not produce steam so the heating system would have to be changed.

The press release course of action notes:

NYPA will engage community stakeholders, energy experts, and community advocacy organizations to examine renewable options including large scale net metering for solar and wind inputs. The Authority will further assess the feasibility of incorporating any renewable energy options as part of a proposed locally-sourced mini-power grid. The grid will be connected to the statewide grid, and also be able to operate independently, to power the Governor Nelson A. Rockefeller Empire State Plaza in Albany. The goal for the proposed project is to be able to supply 90 percent of the power for the 98-acre downtown Albany complex and be able to save the Plaza an estimated $2.7 million in annual energy costs.

In my opinion, this will be difficult to justify and meet the criteria listed. The ultimate problem is that renewable energy is intermittent and diffuse. Any meaningful renewable energy component to this project will have to include storage to address intermittency or it is simply a virtue signaling symbolic gesture. As noted by NYPA and confirmed in my simple estimates, renewable energy’s Achilles Heel of diffusivity means that in order to include any substantive wind or solar it will have to be collected beyond the Empire State Plaza boundary. When that happens the goal of being able to operate independently is contradicted because the existing grid will be used to transmit the power.

Judith Enck, the former EPA regional administrator for the Obama administration claims “If the state of New York is serious about climate change, it has to stop investing in fossil fuels.” While for this particular project I concede that it is technologically feasible to use renewable energy I don’t see how it could be implemented without substantially higher costs to address intermittency with storage and without contradicting the basic tenet that it will be able to operate independently. NYPA is a New York agency controlled by the Governor. It will be interesting to see how the short-comings of renewable energy are reconciled with the reality of the electrical and heating needs of the Empire State Plaza.

Cuomo State of the State 2018 Climate Agenda “Really?”

Governor Cuomo unveiled a comprehensive agenda to combat climate change by reducing greenhouse gas emissions and growing the clean energy economy in the 2018 State of the State on January 3, 2018. My reaction to one aspect of this reminded me of the VW Sign then Drive Event – “Really?” commercials. In the commercial a kid rows a gutter ball and says “Really?”, a lady gets no responses to a party and says “Really?”, and so on. The 20th proposal of the 2018 State of the State: a comprehensive agenda to combat climate change by reducing greenhouse gas emissions and growing the clean energy economy made me think the same thing. In particular is this little gem to undertake “revisions to strengthen RGGI by grouping together and thereby covering peaking units that collectively exceed RGGI’s capacity threshold of 25 megawatts”.

The rationale in the agenda is that:

RGGI only covers power plants with a capacity of 25 megawatts or greater, leaving out many smaller but highly-polluting, high demand “peaking” units, which operate intermittently during periods of high electricity demand. These polluting units are often located close to population centers that come online to meet peak electricity demand on excessively hot or cold days, and disproportionately impact low-income and minority communities that already face a multitude of environmental burdens.

I never really thought too much about the CO2 emissions from the peakers because after all they don’t run much and they are small although admittedly relatively inefficient. So I looked into it. Table 1 New York State CO2 Emissions by Control Program lists operating data and CO2 emissions. Of course you run into a problem immediately inasmuch as about two thirds of the peakers don’t even report CO2. Nevertheless I managed to come up with an estimate. I downloaded all the Environmental Protection Agency Air Markets Program New York unit annual emissions for all reporting programs from 2009 to 2016. I categorized the units by RGGI program; Other Program, 5-month reporting; and Other Program 12-month reporting. In 2016 the RGGI unit CO2 total was 31,194,515 tons and the peaker units already included in RGGI CO2 total was 245,987 tons.

In order to estimate CO2 emissions from the units that don’t report I assumed that the CO2 rate per operating time would be the same for peakers that report and those that don’t to calculate a conversion for the 5 month units. I multiplied that conversion factor by the reported operating times and assumed that it should be pro-rated across the entire year by multiplying by 12/5. Using those assumptions the total CO2 peaker emissions increase 215,000 tons to 460,987 tons or about 1.4% of the total emissions.

One of my biggest problems with the New York State clean energy programs is the apparent lack of an end game. I think the primary rationale for this is the environmental justice angle that the peaking units “disproportionately” impact low-income and minority communities. So it looks like the goal is to shut these units down.

Peak load days correspond to highest emissions days but the problem is that the peaking turbines needed to provide the peak load are old, inefficient and relatively high emitting. Consequently there is an extra kick of NOx pollution which as a precursor to ozone creates problems meeting the ozone ambient air quality standard. That is a real problem but conflating that with CO2 “pollution” is silly at best.

The State has never explicitly produced a game plan to replace the turbines in question. For example, consider July 20, 2015 which is the highest emissions day that year. The total gross load from all electric generating units in New York on that date was 303,967 MWh. Units covered by the RGGI program generated 297,350 MWh or 97.8% of the load. There already are combustion turbines covered by RGGI and they accounted for 19,960 MWH or 6.6% of the load. The non-RGGI combustion turbines targeted by the agenda only accounted for 2.1% of the load but that was still 6,369 MWh. The problem is that all of the combustion turbine generation was dispatched when it was needed, where it was needed in the New York City transmission system, and was not subject to weather. It is a non-trivial exercise for the Governor’s renewable energy program to replace that generation with those constraints.

I suppose proponents for including these units in RGGI could think that the revenues resulting from the sale of the RGGI allowances necessary to run could be invested to replace the peaking turbines. But 215,000 allowances at even $5 per ton is only $1,075,000. If those funds were allocated to the Clean Energy Fund then you could expect 3,575 MWh reduction based on calculations derived from my estimate of the NY RGGI operating plan. On the face of it that is pretty close to the 6,369 MWh number above but the gob smacking issue is that the 6,369 MWh is for one day and the 3,575 MWh is for a year!

NY RGGI Stakeholder Meeting February 2018

UPDATE: The stakeholder meeting was held on 2/13/2018 and I never received a response to my request for a webinar and the meeting did not include remote access.  Ironically, I understand one of the topics of conversation was an initiative to control CO2 emissions from the transportation sector. 

On January 25, 2018 several New York State (NYS) agencies announced a stakeholder meeting for NYS interests in the RGGI proceeding. These agencies should be leading by example but this announcement demonstrates to me their actual lack of commitment to their espoused goal.

The notice stated:

On February 13, 2018, the Department of Environmental Conservation (DEC), New York State Energy Research and Development Authority (NYSERDA), and Department of Public Service (DPS) will host a New York State stakeholder meeting to follow the Regional Greenhouse Gas Initiative (RGGI) regional stakeholder webinar scheduled for January 26th, and to discuss next steps related to the conclusion of the 2016 RGGI Program review. The meeting in Albany will build upon the regional meetings held to date and provides an opportunity to discuss New York specific topics related to the RGGI model rule implementation in New York. This includes forthcoming proposed revisions to DEC’s regulation implementing RGGI in New York, 6 NYCRR Part 242, CO2 Budget Trading Program.

My problem is the following:

This meeting will be in-person only to better facilitate dialogue as New York kicks off it’s stakeholder process. Additional meeting dates, including webinar opportunities may be made available to interested parties that cannot attend this meeting.

In my opinion, New York has set aggressive emission reduction targets more as a slogan and support for Governor Cuomo’s political ambitions than a rational action. At the top of the list of support for that statement is the decision to eliminate 10% of the state’s total electrical energy and 17% of the carbon free electrical energy by closing Indian Point. The fact of the matter is that in order to meet the Reforming the Energy Vision goal of an 80% reduction of GHG emissions by 2050 it will take enormous effort, require NYS citizens all to make sacrifices and accept some inconveniences. See for example this article on tradeoffs. State agencies should be leading by example. That the agencies would prefer to require attendees to increase their carbon footprint to attend a meeting solely “to better facilitate dialogue” is inconsistent with that reality. As Glenn Reynolds said: “I’ll believe global warming is a crisis when the people telling me it’s a crisis start acting like it’s a crisis.”

I submitted a comment to the contact address that included that point on January 27, 2018 and asked for remote access. If the agencies respond to that request I will update this post.

News from NY Office of Climate Change

The New York State Department of Environmental Conservation (DEC) Office of Climate Change publishes a regular email that lists the latest climate news. The latest edition shows that news has to be consistent with their preconceived notions of global warming. In this edition they use information to prove their case for climate change problems at the same time as they claim similar information cannot be used to not suggest climate change is not a problem. Talk about trying to have their cake and not eating it too.

Before proceeding a disclaimer. Before retirement from the electric generating industry, I was actively analyzing air quality regulations that could affect company operations. The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

There are two articles that show the inability of the Office of Climate Change to really understand that there are two sides to the issue of climate change. The lead article is a picture of extensive ice at Niagara Falls with the following caption: “Extreme cold at the end of 2017 has frozen all but the moving water at Niagara Falls. Recent research suggests that a warming arctic may be contributing to cold snaps like this one in the Northeastern U.S. as a result of a weakened polar vortex.”

Also included, under a title “Science” is a quote from A Response for People Using Record Cold U.S. Weather to Refute Climate Change, published December 28, 2017 on

“Weekly or daily weather patterns tell you nothing about longer-term climate change (and that goes for the warm days too). Climate is defined as the statistical properties of the atmosphere: averages, extremes, frequency of occurrence, deviations from normal, and so forth. The clothes that you have on today do not describe what you have in your closet but rather how you dressed for today’s weather. In reality, your closest is likely packed with coats, swimsuits, t-shirts, rain boots, and gloves. In other words, what’s in your closet is a representation of ‘climate.’”

I agree completely that weekly or daily weather patterns are no indicator of longer-term climate change. If it is not immediately obvious the “recent research” analysis about the cold weather is trying to make an argument about weather patterns as an indicator of longer-term climate change. I am sorry but you cannot have it both ways.

If the Office of Climate Change deigns to correct this that might also want to mention to the Governor that he consistently is guilty of the same thing. He consistently refers to Superstorm Sandy as devastation related to climate change and has mentioned the November 2014 Buffalo lake effect snowstorm as further proof. Both were caused by short-term weather patterns. In order to prove otherwise historical weather patterns would have to be evaluated to determine if there was a change over time. In my opinion running a climate model to claim causation is dubious at best.