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Citizens Guide to the Climate Act

Originally Published December 14, 2021 and Updated April 9, 2022

Update April 22, 2022: I gave verbal comments on the Draft Scoping Plan at the April 26, 2022 Draft Scoping Plan Public Hearing in Syracuse.

New York’s Climate Leadership and Community Protection Act (Climate Act) a legal mandate for New York State greenhouse gas emissions to meet the lofty net-zero by 2050 goal. It is very likely that implementation of the technology necessary to meet that goal will adversely affect energy sector affordability and risk current reliability standards.  Unfortunately, most New Yorkers are unaware of it and only a handful understand the implications.  While the Climate Act has been a frequent subject for articles on this website, many of those articles are overly technical for the general public.  In order to address the need for a concise resource of the potential impacts of the Climate Act I have developed the Citizens Guide to the Climate Act.

Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies.  I have written extensively on implementation of New York’s response to that risk because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that it will adversely affect reliability, impact affordability, risk safety, affect lifestyles, and will have worse impacts on the environment than the purported effects of climate change in New York.  New York’s Greenhouse Gas (GHG) emissions are less than one half one percent of global emissions and since 1990 global GHG emissions have increased by more than one half a percent per year.  Moreover, the reductions cannot measurably affect global warming when implemented.   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.

Background

The Climate Act became effective on January 1, 2020.  It mandates that the Climate Action Council prepare the Scoping Plan that outlines how to meet its targets. Starting in the fall of 2020 seven advisory panels developed recommended strategies to meet the targets that were presented to the Climate Action Council in the spring of 2021.  Those recommendations were translated into specific policy options in an integration analysis by the New York State Energy Research and Development Authority (NYSERDA) and its consultants.  An overview of the results of this integration analysis were presented to the Climate Action Council at two October meetings and has since been updated.  That analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021.  Comments can be submitted until June 10, 2022.

The Citizen Guide is intended to provide an introduction to the Climate Act and potential ramifications.  A one-page summary has been prepared that can be printed out.  There is an annotated summary reproduced below that includes links to more detailed information on particular topics.  The Guide is a work in progress so feedback is encouraged.

Annotated Citizens Guide to the Climate Act

The Climate Act is an ambitious attempt to reduce New York State greenhouse gas emissions to meet the currently fashionable net-zero by 2050 goal.  The implementation plan boils down to electrify everything and rely on wind and solar to provide the electricity needed.  In order to reach the aspirational goals changes to personal choice are needed, significant risks to reliability are likely, substantial energy costs increases will occur, but there will be no measurable effect on global warming itself and significant environmental impacts from the massive wind and solar deployments.  The bottom line is that we don’t have the technology today to meet the ambitions of the Climate Act and maintain current reliability standards and affordability.  Until we do, we should reconsider the targets and schedule of the law.

Climate Act

The actual name of the Climate Act is the Climate Leadership and Community Protection Act. It was signed on July 18, 2019 and establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency.  The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  Starting in the fall of 2020 seven advisory panels developed recommended policies to meet the targets that were presented to the Climate Action Council in the spring of 2021.  Their strategies were converted into specific strategies by the New York State Energy Research & Development Authority over the summer of 2021.  The integration analysis implementation strategies was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021.  Comments can be submitted until June 10, 2022.

Implementation Strategy Risks and Effects

In order to meet the net-zero goal of the Climate Act, risky emission reduction strategies from all sectors will be required and personal choices limited. All residences will have to be completely electrified despite the risks to safety in the event of an ice storm.  In the transportation sector electric vehicles will be required and zoning changes to discourage the use of personal vehicles implemented. 

Reliability Risks

The New York electric gird is a complex system that has evolved over many years.  It is highly reliable using proven hardware and procedures.  Relying on unprecedented levels of wind and solar that are not proven on the scale necessary and energy storage system technology to account for intermittent wind and solar that has not been tested for the proposed use is an ill-conceived plan that will likely end in a reliability crisis.

Costs and Benefits

The Climate Act did not determine the greenhouse gas emission targets based on a feasibility analysis. The scoping plan claims that “The cost of inaction exceeds the cost of action by more than $90 billion”.   That statement is inaccurate and misleading.  The claimed benefits are all societal and do not directly offset consumer costs. The plan claims $235 billion societal benefits for avoided greenhouse gas emissions, but I estimate those benefits should only be $60 billion.  The Scoping Plan gets the higher benefit by counting benefits multiple times.  If I lost 10 pounds five years ago, I cannot say I lost 50 pounds but that is what the plan says.

The cost estimates are poorly documented but I have figured out that the costs of action used for the claim misleadingly exclude the costs in the transportation investments category needed to make the necessary reductions. The semantic justification is that the program is already implemented.  Adding $700 billion for that and using the correct avoided cost of carbon means that costs are at least $760 billion more than the benefits.

Effect on Global Warming

When the Climate Act eliminates New York’s greenhouse gas emissions the effect on global warming will not be measurable.  The expected impact on global warming is only 0.001°C by the year 2100.  More importantly, New York emissions are less than one half of one percent of total global emissions while global emissions have been increasing on average by more than one half of one percent per year.  Consequently, anything we do will be displaced in a year by countries in the developing world building their energy systems with reliable and affordable fossil fuels.  To deny those countries the benefits of plentiful electricity is immoral.

Zero-Emissions Environmental Impacts

The Climate Act only accounts for fossil fuel life-cycle costs and environmental impacts while ignoring the life-cycle impacts of wind, solar, and energy storage technologies.  These “zero-emissions” resources may not have emissions when generating electricity but the volume of materials needed to access dilute wind and solar energy and the rare earth elements necessary for those technologies certainly have environmental impacts when mined and processed.  The large number of wind turbines and solar panels will also create massive amounts of waste when they are retired.  Furthermore, the cumulative environmental impacts of thousands of wind turbines and square miles of solar panels has not been compared to the environmental impacts of current fossil fuel technology.  Finally, it is unreasonable to expect that there will be any changes to environmental impacts due to climate change because the New York effect on global warming is too small to measure.

What You Can Do

On December 30, 2021, the Climate Action Council released the Draft Scoping Plan for public comment. The public comment period extends through July 1, 2022, and includes ten public hearings. The Council will consider the feedback received.  I strongly encourage readers to provide comments and contact your legislators to tell them you don’t favor any legislation that implements GHG reduction mandates.  I have listed all the comments here that I have submitted if you need a template for your own comments.

References

The official New York State Climate Act webpage describes New York State climate news and developments.  Links to articles on the Climate Act at the Pragmatic Environmentalist of New York website, implementation overviews, background technology references and background information are provided in the references.

Conclusion

My colleagues in industry and I all agree on a few things.  We believe that most New Yorkers are unaware of the potential impacts of the Climate Act.  We are convinced that the costs will be eye-watering.  We don’t think that technology is available to maintain current reliability standards and replace fossil fuel sources of energy.  The goal of the Citizens Guide is to educate New Yorkers on the law, the costs, and the risks.  Any feedback on this attempt to responds to that goal is encouraged at nypragmaticenvironmentalist@gmail.com.

More Reliability Concerns that Need to be Considered by the Climate Action Council

The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050.  I have previously noted that there are members of the Climate Action Council who deny the challenge of the electric grid transition from existing sources to one dependent upon wind and solar resources.  This article describes a couple of recent articles that highlight transition issues.

Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies.  I submitted comments on the Plan and have written extensively on implementation of New York’s response to that risk because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that this supposed cure will be worse than the disease.  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.

Climate Act Background

The Climate Act establishes a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council.  Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that tried to quantify the impact of the strategies.  That material was used to write a Draft Scoping Plan that was released for public comment at the end of 2021. The Climate Action Council states that it will revise the Draft Scoping Plan based on comments and other expert input in 2022 with the goal to finalize the Scoping Plan by the end of the year.

In my comments on the Draft Scoping Plan I noted that the Plan and the Climate Action Council have downplayed the reliability risks of the Climate Act transition to renewables.  Equally troubling there are vocal members of the Climate Action Council that deny the existence of any implementation issues associated with a renewable energy resource dependent electric system.  At the May 26, 2022 Climate Action Council meeting, Paul Shepson Dean, School of Marine and Atmospheric Sciences at Stony Brook University claimed that the conversion cannot be unreliable at 23:39 of the recording.  Robert Howarth, Professor, Ecology and Environmental Biology at Cornell (starting at 32:52 of the recording) said: “Clearly one can run a 100% renewable grid with reliability”.   In this article, I describe a couple of recent articles that highlight some of the issues associated with this conversion that the academics overlook.

Renewable Energy Systems

I have prepared a page that documents the work of various authors that describe the complexities of the energy system and problems associated with over-reliance on intermittent wind and solar generating resources.  One of the resources is a series of posts at Climate Etc by Planning Engineer who posts under the pseudonym because he wanted to frankly share his personal views and not have them tied directly to his current employer.  Recently he posted an article entitled Will California “learn” to avoid Peak Rolling Blackouts? that provides a good overview of upcoming reliability issues.

The article presents a graph that shows recorded peaks and the projected 2022 value that caused issues earlier in September.  Then he explains that:

The most basic planning criteria is that a system should be able to survive the loss of the largest generating resource and the most critical transmission element during a peak load with no loss of load and no severe voltage declines or undamped system oscillations. Looking at the variability in load levels here, no particular challenges to planners are apparent. If “green” resources were capable of replacing traditional resources with minor adjustments, we would not see the problems we are seeing.

He goes on to explain why there was a problem.

Why is California challenged now and why might it continue to see challenges in the future?  Primarily because the focus on green energy is increasing the percentage of “green” intermittent resources. “Green” resources are not as dependable as traditional rotating machinery nor do they support the system as well. It is likely that these resources have been credited with more ability to provide capacity than is warranted, and when the rubber meets the road, they don’t perform as “expected”. Intermittent resources cause problems on both the generation side and the load side. Intermittent solar on the residential side serves to reduce load as seen by the Cal ISO. When solar is not performing well available load which is not displaced by solar on the residential side increases concurrent with solar reduction on the supply side.

If California were more honest about the capabilities of “green” intermittent resources planning would be enhanced. However, being honest about the capabilities of “green” resources would have consequences that some would find unacceptable. There has been a big push to make “green” options appear much more economic and capable than they are so that they will be more competitive. Subsidization of “green” resources by traditional uses occurs in many ways. In addition to crediting “green” resources above their dependable capability, others subsidies include directing costs associated with such additions to others. Being honest makes the “green” dream a much harder sell. Assuming that “green” resources work well saves other investment in the grid. This subterfuge tends to limit the cost increase that should be imposed by these resources, but does so at the cost of reliability. This tradeoff takes a while to see as we have built the electric grids to have very high levels of reliability at the bulk level. In the short term it looks like you are getting a cleaner, equally reliable system at a moderate cost increase. But as penetration levels increase, cost get higher and reliability gets much worse.

He points out that California policy makers are responsible for resource investment, resource allocations and how and when grid improvements are made to enhance reliability. Earlier in September there were reliability issues and extreme weather was blamed.  Obviously, the planning failed to account for weather but proper reliability planning has to account for the effects of extreme weather.  Planning Engineer points out that if “there truly was something unusual about the weather as driven by climate change, shouldn’t this have been anticipated by those responsible?” 

He concludes:

Ideally the power system represents the best balance between economics, reliability and public responsibility. California has reached a balance skewed by false expectations that “green” resources cannot meet. Creating a balance that looks at the true costs and reliability impacts of green resources should benefit electric users in California.

Ramping Up Renewables Can’t Provide Enough Heat Energy in Winter

Gail Tverberg writing at Our Finite World explains that one of the unappreciated benefits of fossil fuels is their ability to store energy that can be used to provide heat in the winter.  She notes that:

In some ways, the lack of availability of fuels for winter is a canary in the coal mine regarding future energy shortages. People have been concerned about oil shortages, but winter fuel shortages are, in many ways, just as bad. They can result in people “freezing in the dark.”

The article goes on to describe eight issues involved with winter energy use.  She points out that “batteries are suitable for fine-tuning the precise time during a 24-hour period solar electricity is used” but they cannot be scaled up to store solar energy from summer to winter.  There is no long duration energy storage resource available.

The article addresses hydro and wind energy resources in this context.  She argues that “ramping up hydro is not a solution to our problem of inadequate energy for heat in winter” and that “wind energy is not greatly better than hydro and solar, in terms of variability and poor timing of supply”.

She also lists five specific reasons that “when wind and solar are added to the grid, the challenges and costs become increasingly great”.  All of these concerns are concerning by themselves and the combination of problems directly contradicts the Climate Act narrative that there are no serious challenges to reliability.  Two deserve attention.  The inherent variability of wind and solar generation creates power transients and those fluctuations need to be addressed.  The problem is that the magnitude of this problem is new and it is likely that learning how to address it is difficult to anticipate so corrections will be reactions to problems.  Supporters of the Climate Act transition seem to think that existing wind, solar and energy storage resources only need to be scaled up to the quantity needed.  What they miss is that the more resources built the less those resources will be used.  Tverberg points out that low-capacity factors hurts energy return on investment payback.  All of these issues should be considered but have not been addressed in the Scoping Plan.

Tverberg also point that the word “sustainable” has created unrealistic expectations with respect to intermittent wind and solar electricity.  She illustrates this issue as follows:

A person in the wind turbine repair industry once told me, “Wind turbines run on a steady supply of replacement parts.” Individual parts may be made to last 20-years, or even longer, but there are so many parts that some are likely to need replacement long before that time. An article in Windpower Engineering says, “Turbine gearboxes are typically given a design life of 20 years, but few make it past the 10-year mark.”

She notes that “energy modeling has led to unrealistic expectations for wind and solar”.  This is evident in the Integration Analysis projections.  It should be obvious that the Scoping Plan projections for future generating resources have to be reconciled with the work of the New York Independent System Operator but, so far, no plan has been announced to do that.

Finally, Tverberg argues that current pricing plans that enable the growth of wind and solar electricity have consequences.  They are displacing existing dispatchable resources such that those resources are no longer viable.  The result is “pushing a number of areas in the world toward a “freezing-in-the-dark” problem”.  She concludes: “The world is a very long way from producing enough wind and solar to solve its energy problems, especially its need for heat in winter.”

Conclusion

I cannot improve on Planning Engineer’s conclusion.  Substitute New York for California and his conclusion sums up the issue that the Climate Action Council should address in the Scoping Plan:

Will California learn to avoid peak rolling blackouts?  If reliability were a primary concern, this situation shouldn’t bubble up again in a few years. California should be able to properly credit the ability of its power resources and match them to projected weather ensuring adequate power. If other priorities prevent responsible steps to ensure reliability, then those priorities, not the weather, should claim responsibility for the consequences. If California wants to continue as they have, they should be honest and make statements such as the following:

This is the end of affordable, reliable electric service as we understood it for most of the last 50 years. We are choosing to go with “green “technology to deal with the climate crisis. Keeping past reliability levels will raise your costs tremendously. As we try to put on limit on costs this will decrease your reliability. At times the power will not be there. We’ve all got help each other out.

New York Independent System Operator Draft Scoping Plan Comments

The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050.  The comment period for the Draft Scoping Plan that outlines how to meet that goal recently ended.  Here I describe comments submitted by the New York State Independent System Operator (NYISO). 

Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies.  I submitted comments on the Plan and have written extensively on implementation of New York’s response to that risk because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that this supposed cure will be worse than the disease.  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.

Climate Act Background

The Climate Act establishes a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council.  Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that tried to quantify the impact of the strategies.  That material was used to write a Draft Scoping Plan that was released for public comment at the end of 2021. The Climate Action Council states that it will revise the Draft Scoping Plan based on comments and other expert input in 2022 with the goal to finalize the Scoping Plan by the end of the year.

New York State Independent System Operator

The predecessor organization to the  NYISO was created after the Northeast Blackout of 1965.  New York’s seven investor-owned utility companies established the New York Power Pool (NYPP), to address the reliability problems exposed by the blackout.  In the 1990s New York’s electric system was de-regulated and the Federal Energy Regulatory Commission (FERC) recommended the formation of independent entities to manage energy transmission and generation and the NYISO was established to replace the NYPP.  Because the change to the wholesale electricity market is the reason for their existence, the NYISO unquestioningly supports market driven responses to any problem.  This is evident in their Draft Scoping Plan comments.

The NYISO manages the electric system.  They have to balance the instantaneous supply of electricity between the generators and customers across the state in the de-regulated electricity market.   They manage the supply of power and maintain the frequency across the state and with their connections to other operating systems.  In addition, the NYISO has to plan for future changes to the system.  At this time the biggest factor for change is the Climate Act so their comments are important to understand.

Comments on Draft Scoping Plan Recommendations

The NYISO comments included comments on four aspects of future power generation strategies:

  • Fossil Generator Retirements Must Be Coordinated with Replacement Resources,
  • Accelerate Growth of Renewable Generation and Other Resources,
  • Storage Provides Value and Must Work in Concert with Generation, and
  • Interconnection Process Improvements

    The NYISO comments emphasized that the drive to retire fossil-fired generating units has to be coordinated with replacements. They explained (their emphasis added) that:

    A sufficient fleet of new generation resources that satisfy the CLCPA, with the appropriate reliability attributes, must be available before the existing, traditional generators retire voluntarily or are forced out of service. An essential step to facilitate the orderly transition from traditional generators to emission-free electricity is promulgation of environmental regulations with defined milestones and ample lead time for new resource development. For example, firm regulatory milestones that define emission limits to be achieved on specified dates and compliance plan obligations that require generators to describe their approach to compliance give the NYISO planning processes essential information to consider and share with stakeholders.

    NYISO is very concerned that Administration policy appears to build as many renewables as possible and shut down as much fossil infrastructure at the same time without a strategic plan.  The comments stated:

    Proposing environmental regulations with defined milestones to facilitate the CLCPA mandates would help protect electric system reliability by allowing the existing reliability processes to more accurately review and evaluate reliability needs. The Draft Scoping Plan provides that the DEC should assess regulatory options to reduce emissions from fossil generators to the maximum extent practicable to achieve the requirements of the CLCPA while maintaining electric system reliability. The DEC should examine all potential regulatory options, including new regulations and/or permit requirements or amendment of current regulations and/or permitting requirements, to determine the most efficient, effective, and enforceable format to achieve the determined emissions reduction targets and the CLCPA requirements. The process should include effective mechanisms for input and comments from stakeholders prior to a formal proposal under the State Administrative Procedures Act, similar to the process used in promulgating the DEC “Peaker Rule,” 6 NYCRR Subpart 227-3

    The NYISO strongly encourages the DEC and other state agencies to pursue new or amended regulations to implement emissions reductions in an orderly, predictable manner. The process should include effective mechanisms for input and comments from stakeholders prior to a formal proposal. This exact approach proved effective when the DEC developed the Peaker Rule in 2018-2019.

    NYISO commented on the pace of accelerated growth of renewable generation and other resources necessary to meet the timeline and targets of the Climate Act. 

    New resources will be necessary to serve load and provide reliability services in place of the generators that will retire. The Draft Scoping Plan contemplates accelerating the growth of large-scale renewable generation, offshore wind generation, distributed generation, and distributed energy resources. This growth is envisioned, in part, through recommendations that the state accelerate adoption of innovative technologies and programs that increase hosting capacity such as flexible interconnection, hybrid systems, and coupling resources with energy storage or controlled load.

    NYISO makes the point that even the Draft Scoping Plan recognizes that wind, solar, and energy storage are inadequate to meet the requirements of a zero emissions electric system in 2040.

    The Draft Scoping Plan also correctly observes that dispatchable and emissions-free resources, with operating characteristics similar to fossil generators, will be equally, if not more important, to protect consumers from electric service interruptions. It states:

    “The current system is heavily dependent on existing fossil fueled resources to maintain reliability. To ensure reliability and that generation is available when needed, dual fuel capability currently provides oil back up during periods of high gas and electric demand. To replace these units, dispatchable and emissions-free resources will be needed to balance the system and must be significant in capacity, be able to come on-line quickly, and be flexible enough to meet rapid, steep ramping needs. The importance of developing large amounts of dispatchable generation is echoed in the Power Grid Study, Pathways Study, and NYISO Grid-in Transition and Climate Change Study.”

    There is an additional complication that is often overlooked outside of the industry.  NYISO not only has to figure out how the infrastructure has to be changed to meet the Climate Act requirements they also have to design market mechanisms that will induce the development of the required infrastructure.

    The NYISO supports the State’s consideration of how the wholesale markets can work in conjunction with financial incentives, e.g., Clean Dispatch Credits (“CDC”) or a renewable energy credit (“REC”)-like product, to increase the number of new flexible resources interconnecting to the electric grid. Such salable attributes could encourage new technologies that run on storable fuels, as opposed to wind or solar energy. Incentives could also encourage storage resources to possess the capability to charge from the grid, regardless of whether they are coupled with generation or load resources. The option, or technical capability, to charge from the wholesale electric grid improves provision of reliability services by increasing the overall ability of resources to inject or withdraw energy from the grid and lowers overall prices for consumers when the storage resource charges at a lower cost.

    The NYISO commented that storage provides value and must work in concert with generation.  Their comments stated:

    The Draft Scoping Plan observes that a portfolio of energy storage technologies will be needed to support balancing the intermittency of energy production as more weather-dependent renewable energy generation connects to the grid. Existing and newer, long-duration, storage will be needed to maintain reliability as the state approaches 2040. This suite of storage technologies, however, will be needed well before 2040 to reach the State’s energy policy goals.

    The comments also provide an explanation why storage requirements are complicated.

    While storage is a critical part of the future resource fleet, it is only capable of being part of the solution. The electric system will require electricity production to reliably meet demand across a wide range of conditions, every day of the year. Battery storage resources can help to fill in short term reductions in renewable resources output, but extended periods of low- or zero-renewable resource output will rapidly deplete the short duration storage capabilities of existing battery technologies. The resource fleet must include generators that operate on storable fuels in addition to renewable resources and batteries. At times, renewable resource production may be insufficient to serve other load and to provide the charging capability needed for the large levels of storage expected to enter the system.  These circumstances could extend the periods when storage resources are unable to supply energy to serve load. A successful transition requires replacing the reliability contributions of the existing fleet of generation as their performance capabilities will be no less essential in a future grid than they are today.

    The concerns about market mechanisms for energy storage devices are also included in the comments:

    The NYISO seeks the lowest production costs for consumers. To allow the markets to seek the lowest production cost, all technologies that can support the system needs must be able to participate. The NYISO regularly reviews market rules to accommodate participation of new and emerging resources, such as energy storage resources through market participation. When the capabilities of a particular technology require changes to existing market rules, the NYISO has evolved its markets and its Tariffs to accommodate participation along the lines of the Draft Scoping Plan description of expanding wholesale market eligibility participation rules for new policy resources. For example, in 2020, the NYISO implemented a participation model for energy storage resources (“ESRs”) and, in 2021, the NYISO expanded the participation model to accommodate co-located resources consisting of a combination of storage and other generating technologies, such as wind or solar. The NYISO integrated ESRs as supply resources in both instances, not as providers of transmission service.  Although ESRs, like other resources, can be dispatched to prevent an overload of a transmission facility, they do not change the thermal capability of a transmission facility and, therefore, do not change the ratings of transmission facilities. Like other types of suppliers, ESRs can provide dispatchable services to help mitigate transmission constraints and can serve load to meet local reliability needs and defer infrastructure investments.

    The electric grid has been described as the world’s largest machine because the generators and users are all connected. The NYISO comments address interconnection process improvements:

    To support development of new generation resources, the Draft Scoping Plan recommends that the state speed up the pace of processing interconnection applications and emphasize the need for right-sizing human resources at utilities to mitigate delays in application processing. Interconnection rules that support grid reliability, along with siting and other regulatory processes that facilitate timely review and consideration of projects, are necessary to effectively respond to the rapid growth of projects being developed in response to the state’s clean energy policies. The NYISO is committed to continue working with stakeholders to assess how its processes can be enhanced to better manage the increasing volume of resources while still providing the critical reliability analysis needed.

    An underlying premise of the NYISO comments is the insinuation that there are significant logistical issues associated with schedule.  The comments describe changes to the process for connecting new generating sources to the grid:

    The NYISO’s generation interconnection study process identifies potential adverse reliability impacts associated with new resources interconnecting to FERC jurisdictional distribution and transmission. The process, which requires significant coordination among the NYISO, facility developers, and affected transmission owners, identifies necessary system upgrades and their estimated costs to protect electric system reliability. This allows investors to make more informed investment decisions. To facilitate the dramatically increasing number of interconnection requests, the NYISO has been working with stakeholders to implement improvements to the interconnection study process. NYISO completed a comprehensive redesign of the interconnection study process in 2019. The redesign offers greater flexibility and expedited study options to developers seeking the necessary information to interconnect to the grid. The enhancements have proven effective in accelerating the interconnection study process.

    The numbers for new projects are notable:

    The improvements were applied for the first time to the Class Year 2019, the largest in the NYISO’s history, with 66 projects representing 7,254 MW of capacity, and helped the NYISO to bring the Class Year process to closure in record time. Since 2019, the number of new interconnection requests has continued to increase, reaching 197 requests per year and 387 projects with ongoing interconnection studies at the end of 2021.

    Nonetheless, more changes are needed:

    The NYISO continues to review and improve its interconnection process, including a current initiative under discussion with stakeholders regarding improved coordination between the various interconnection processes. In addition, the NYISO anticipates significant additional interconnection process changes will be required in later 2022 and 2023 prompted by FERC’s Notice of Proposed Rulemaking regarding Improvements to Generator Interconnection Procedures and Agreements (Docket No. RM22-14-000). Given the volume of interconnection requests it is imperative to further streamline interconnection processes.

    My primary concern is generation but of course the NYISO has to also worry about transmission and distribution strategies for the use of diffuse renewable resources.  The NYISO comments described their concerns:

    The Draft Scoping Plan recommends that the state expand electricity transmission and distribution systems to support energy delivery, and, building on the Power Grid Study, continue research, development, and demonstration (“RD&D”) and rapid deployment of advanced grid technology. The transmission-focused efforts should strive to alleviate transmission system bottlenecks to allow for better deliverability of renewable energy throughout the state and unbottle constrained resources to allow more hydro and/or wind imports and the ability to reduce system congestion. In addition, the Draft Scoping Plan encourages optimized utilization of existing transmission capacity and rights of way by utilities to accelerate investments in their local systems. These actions will facilitate renewables development and enhance the electrification of transportation and grow safety and resiliency.

    The rest of the comments described the planning processes used.  I mentioned the NYISO’s unwavering support of market mechanisms to solve any electric system issue.  There are descriptions how public policy requirements are addressed with public planning.  Similarly, they address economic issues associated with transmission constraints. 

    Relative to the Climate Act the most important planning process is related to reliability.  There is a good summary of the process that they use.

    NYISO reliability planning processes evaluate reliability needs that are arising due to a shifting resource mix, as higher-emitting, controllable fossil generators deactivate and new renewable, intermittent generation, and other clean energy supply resources enter service. The NYISO’s reliability processes form a baseline system that identifies transmission and resources expected to enter into service, and transmission that is needed to maintain reliability. Additional transmission infrastructure needed for public policy requirements, like the CLCPA, build on these reliability analyses and solutions.

    The NYISO comments seems to be satisfied that the Draft Scoping Plan adequately addresses the NYISO reliability planning process:

    The Draft Scoping Plan recommends that the State conduct established biennial evaluations to assess the state of bulk power system reliability in consultation with the NYISO and the New York State Reliability Council. The NYISO supports this recommendation and agrees that ongoing evaluations and transmission system reliability planning are critical to maintaining an energy secure and sustainable system for New York. The NYISO has established processes that should be used to support the Draft Scoping Plan recommendation. The NYISO’s reliability planning processes identify reliability risks and, if found, include actions such as solicitations of transmission and resource solutions needed to maintain reliable electric service. These processes are designed to provide the baseline reliable system on which to build the grid of the future, integrating renewable resources and storage to attain the requirements of state climate change laws. The frequency and structure of these planning studies allow the NYISO and stakeholders to regularly review study assumptions and scenarios based on up-to-date operational experience. Review of the State’s power system performance in conformance with established operations requirements will be critically important throughout the clean energy transition.

    The reference for this commitment (footnote 37) is:

    Draft Scoping Plan at p. 171 (“Continual Evaluation: The State should conduct established biennial evaluations to assess the state of bulk power system reliability in consultation with the federally designated electric bulk system operator (NYISO) and the State and federally jurisdictional entity the New York State Reliability Council. These evaluations should ascertain if any program adjustments are needed to ensure continued safe and adequate electric service. They should be informed by the review of the State’s power system performance in conformance with established operations requirements and by relevant studies including the NYISO’s Reliability Needs Assessment”). 

    There are two issues related to this continual evaluation requirement.  First and foremost, I believe that this evaluation should be a prerequisite for any implementation regulations. Once the Scoping Plan is complete it is the guideline for the New York’s energy planning but regulations have to be developed to implement the changes.  It is inappropriate to start implementing rules if the organization responsible for reliability has reservations about continued safe and adequate electric service. Secondly, I am not privy to the discussions between the NYISO and the Administration and neither are most members of the Climate Action Council.  To this point no one on the Council has spoken up to reign in the loudest ideological voices who believe the reductions have to be instituted no matter what, that the intent of the Climate Act is to ban all combustion sources, and that there are no reliability issues related to an electric system that depends upon renewable energy.

    The NYISO resource adequacy comments are at odds with the vocal ideologues.  The comments emphasize that all options have to be considered at this time:

    The Draft Scoping Plan recommends that the State and the NYISO examine all resource adequacy options and continue to improve compensation for resource adequacy contributions. It specifically calls for the state to continue working with the NYISO “on market enhancements that facilitate the resource transition, support investment, minimize costs to consumers, eliminate buyer- side mitigation (BSM) for Climate Act resources, and meet reliability.” The NYISO is continuously evaluating the accuracy and robustness of its underlying resource adequacy models, reliability metrics and probabilistic tools, and updating them to incorporate changing characteristics of the power system and resource fleet. The NYISO welcomes the opportunity to continue working on these efforts with the state and to build on the recent success of the comprehensive mitigation reform effort.

    The only concession made by the Climate Action Council to the reliability concerns of the state’s experts and organizations who are responsible for keeping the lights on was a listening session last summer.  The NYISO comments summarize the issues:

    The combination of solar, wind, and today’s battery storage technologies are not sufficient on their own to provide the services necessary to support reliability on the power grid. The resource adequacy challenge becomes attracting and retaining sufficient resources, including flexible resources, to maintain reliable service. The NYISO-administered energy and ancillary service markets alone do not provide enough revenue to attract sufficient investment to maintain adequate resources for system reliability. Thus, capacity markets provide and will need to continue to provide an additional revenue stream to support adequate investment to maintain the required levels of resource adequacy. As the fleet transforms and new challenges emerge, ongoing efforts will be needed to ensure that together the energy, ancillary service, and capacity market designs continue to support adequate investment.

    The final comment I want to mention discusses the markets that are critical to achieving the Climate Act.  It is only possible to fully comprehend the magnitude of the challenge of a zero-emissions electric system if you understand the markets described.  I have seen no indication that the majority of the Council members have that knowledge.

    The NYISO supports reliability primarily through three complementary markets: energy, ancillary services, and capacity. Wholesale electricity markets have successfully delivered efficiency gains on the grid and cleaner energy production, making them an effective platform for reflecting public policy and technological influences efficiently and reliably. In these markets, energy, regulation, and operating reserves are simultaneously procured to meet demand while respecting transmission limits. The NYISO has a proven record of enabling the entry of new technologies into the state’s competitive wholesale electricity markets consistent with state public policy objectives. The NYISO-administered wholesale energy markets are critical to successfully fulfilling the mission and goals of reliability and economic efficiency while also shifting investment risk from ratepayers to asset owners and serving as an effective platform for achieving New York State environmental objectives. As such, the NYISO is actively engaging stakeholders and policymakers in developing plans to meet the future challenges expected to arise from a grid characterized with high levels of energy supply from intermittent renewable and Distributed Energy Resources (“DER”).

    Conclusion

    It is telling that the NYISO comments had to emphasize the point that it is not good policy for the state to force fossil generator retirements until appropriate replacement generating resources are available.  Unfortunately, state agencies are promulgating policies that are not consistent with this obvious point.  The NYISO comments state the obvious point that an enormous quantity of renewable resources is going to have to be developed and point out that energy storage will be needed.  The comments also point out that dispatchable and emissions-free resources will be needed to balance the system.  Unfortunately, the comments do not explain the difficulty and challenge of developing this new resource and the risk of relying on this technology for a future electric system.

    Never forget that the Climate Act is all about politics. It is evident that there are reliability concern disconnects between the public face of the Administration, the Climate Action Council scoping plan development, and the NYISO.  In order to address the problems raised by the NYISO the Administration is going to have to burst the bubbles of one or more of the pet positions of some of the Climate Act’s fervent supporters and their organizations.  The alternative is putting the state’s residents at unacceptable reliability risks.

    Initial Impression of Climate Action Council Response to Public Comments on Transportation

    The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050.  The comment period for the Draft Scoping Plan that outlines how to meet that goal recently ended.  The last two meetings of the Climate Action Council have offered some insights into the plans to address those comments.  I am not encouraged by what I have seen so far.

    Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies.  I submitted comments on the Plan and have written extensively on implementation of New York’s response to that risk because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that this supposed cure will be worse than the disease.  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.

    Climate Act Background

    The Climate Act establishes a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council.  Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that tried to quantify the impact of the strategies.  That material was used to write a Draft Scoping Plan that was released for public comment at the end of 2021. Since the close of the public comment period in early July staff has been updating the Integration Analyses and working through the comments to provide the Council with summaries for their review.

    In this article, I will describe the response to the Transportation sector comments relative to the comments I submitted on this sector.  I submitted two comments on electric vehicles.  I noted that the Integration Analysis is making assumptions about future zero-emissions transportation implementation strategies without providing adequate referenced documentation.  The other comment addressed electric vehicle costs.  I also submitted a comment on high-speed intercity passenger rail transportation that is relevant to the September 13, 2022 Climate Action Council Presentation that will be the focus of this article.

    Transportation Comments Response

    The discussion of Transportation Summary Themes at the September 13, 2022 Climate Action Council meeting included “Several commenters suggested investments in rail infrastructure, to connect cities and move freight”. 

    The staff recommendations stated that few changes in response to public comments were needed.  Relative to the railroad theme they noted that: “Emphasize that improving intercity passenger rail service, including High Speed Intercity Passenger Rail transportation, and strengthening the freight rail system is an important component of New York State’s economic future and environmental sustainability.”

    I submitted a comment on high-speed intercity passenger rail transportation that is ignored in this response.  The Federal Railroad Administration (FRA), in cooperation with the New York State Department of Transportation (NYSDOT) completed the Empire Corridor Environmental Impact Statement (EIS) in 2014 to “evaluate proposed system improvements to intercity passenger rail services along the 463-mile Empire Corridor, connecting Pennsylvania (Penn) Station in New York City with Niagara Falls Station in Niagara Falls, New York.” This is the primary reference for Draft Scoping Plan Scenario 4 high speed intercity passenger rail transportation upgrades.

    I evaluated the transportation sector vehicle miles traveled difference between Scenarios 2 and 3 compared to Scenario 4 due to rail passenger improvements.  Note that this basically proposed the development of a dedicated high-speed rail corridor between Buffalo and Albany.  The Draft Scoping Plan claims that “Incremental reductions from enhanced in-state rail aligning with 125 MPH alternative detailed in Empire Corridor Tier 1 Draft EIS” will provide a reduction of 200 million light duty vehicle miles at a per unit cost of $6 per mile or $1.2 billion.  I estimated that the only valid cost for the difference between the rail alternatives is $8.4 billion and that it would only provide a vehicle mile reduction of 64.7 million miles. 

    Discussion

    There are multiple issues associated with the presentation response to comments.  At the previous meeting the State acknowledged that they had not worked their way through the comments submitted as attachments.  My comment was submitted as an attachment so it is possible that it has not even been reviewed yet.  In my opinion, the only way to make detailed comments is through an attachment so I think many of the substantive comments may not have been evaluated yet.

    It is not clear whether this presentation was only meant to be an overview of the comments received.  Alternatively, it could represent the entirety of the discussion of the comments for each of the sectors (Transportation, Agriculture and Forestry, Land Use, Local Government, and Waste) discussed. My specific comment was not mentioned and it is not clear if this was because they have not reviewed it yet or whether it was inconvenient for them to respond.  If this is supposed to be the final word on the comments for each of these sectors then it is clear that the stakeholder public comment process is just window dressing and that no meaningful revisions will be incorporated.

    At one point the Council promised to provide all the comments for public review.  Of course, the odds that the comments will be provided in format that enables it to be evaluated easily is another thing.  I believe all the comments should be available by topic in a searchable formatted document.

    I believe my specific comment has to be addressed on two levels.  On the first level, I identified a problem with their numbers.  Shouldn’t they have to respond to that error?  While it might not rise to the level where an explicit Climate Action Council decision is needed, I do think the Council has to decide what level of high-speed intercity passenger rail transportation improvements they are recommending. The response to this topic at this meeting “Emphasize that improving intercity passenger rail service, including High Speed Intercity Passenger Rail transportation, and strengthening the freight rail system is an important component of New York State’s economic future and environmental sustainability” is just a bunch of words devoid of meaningful comment.

    I also noticed a bias in the comment descriptions.  For example, “Generally, there was strong support for electrification policies in the draft plan” compared to “Some commenters expressed concern over the costs of electrification, particularly in rural communities and for larger vehicles” inappropriately indicates the rates the level of support based on numbers.  The value of a comment is the quality of the argument not the number of people who submitted the argument.  The statement “Several detailed comments supported the development of renewable and/or low-carbon fuels, while many commenters expressed opposition, describing such fuels as a ‘false solution’ “ is particularly problematic because it suggests that no matter how strong the technical argument, if enough ideologues using slogans oppose it that the Council is going to side with the slogans. 

    Conclusion

    I am not surprised that my comments were ignored.  However I am terrified that the Council may ignore the comments submitted by the New York Independent System Operator and the New York State Reliability Council.  There was no mention of any need to reconcile the Integration Analysis with the recent NYISO 2021-2040 System & Resource Outlook report.  The projections are significantly different and the citizens of New York deserve to have them reconciled clearly and transparently.  It is entirely inappropriate for the state to be committed to go down a transformational energy policy path based on the work of unelected bureaucrats who are not responsible for keeping the lights on without incorporating the input of the state’s experts who are responsible.

    New York State Reliability Council Draft Scoping Plan Comments

    The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050 and the comment period for the Draft Scoping Plan that outlines how to meet that goal recently ended.  Here I describe comments submitted by New York State Reliability Council.  This is another instance in which the experts are not explicitly saying this is nuts but a little bit of reading between the lines indicates that they believe the proposed Climate Act transition will end badly.

    Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies.  I submitted comments on the Plan and have written extensively on implementation of New York’s response to that risk because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that it will adversely affect reliability, impact affordability, risk safety, affect lifestyles, and will have worse impacts on the environment than the purported effects of climate change in New York.  New York’s Greenhouse Gas (GHG) emissions are less than one half one percent of global emissions and since 1990 global GHG emissions have increased by more than one half a percent per year.  Moreover, the reductions cannot measurably affect global warming when implemented.   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.

    Climate Act Background

    The Climate Act establishes a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council.  Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that tried to quantify the impact of the strategies.  That material was used to write a Draft Scoping Plan that was released for public comment at the end of 2021. The Climate Action Council states that it will revise the Draft Scoping Plan based on comments and other expert input in 2022 with the goal to finalize the Scoping Plan by the end of the year.

    New York State Reliability Council

    The New York State Reliability Council (NYSRC) is the other organization that has reliability responsibilities in New York.  According to their Draft Scoping Plan comments:

    The NYSRC was established to promote and preserve the reliability of the New York State Power System by developing, maintaining and, from time to time, updating the reliability rules (“Reliability Rules”) that govern the NYISO’s operation of the state’s bulk power system. The NYSRC develops Reliability Rules in accordance with standards, criteria and regulations of North American Reliability Corporation (“NERC”), Northeast Power Coordinating Council (“NPCC”), FERC, the Commission, and the Nuclear Regulatory Commission  The NYISO/NYSRC Agreement provides that the NYISO and all entities engaged in transactions on the New York State power system must comply with the Reliability Rules adopted by the NYSRC.  The NYSRC Reliability Rules have been adopted by the New York State’s Public Service Commission under its Public Service Law authority prescribing reliability rules necessary to ensure safe and adequate service.

    Installed Reserve Margin

    The standard for the required generating capacity relative to the expected load is called the Installed Reserve Margin.  The NYSRC comments on the Draft Scoping Plan defined the standard and talked about the expected changes in what is required now and what is expected in the future:

    One of the major responsibilities of the NYSRC is to set the annual Installed Reserve Margin (IRM) for the New York Power System. The IRM is the reserve resource capacity over and above that required to meet peak load and is needed to maintain minimum levels of reliability in New York. This is necessary based on the recognition that the availability of generation resources may be limited by forced outages or loss of fuel supply, including periods with little to no sun or wind. Typical unavailability figures for fossil fueled generation in New York is in the order of ~15% (~85% availability) largely based on forced outage performance.

    NYSRC determined that the IRM for the 2022 – 2023 capability year is 19.6% and that IRM was adopted by the New York Public Service Commission for the New York Control Area on March 16, 2022 (Case 07-E-0088).

    The table shows the increase in required reserve capacity from 22,577 MW (78.15% IRM) in 2025 to 102,517 MW (205.94% IRM) in 2050. These numbers need to be pondered in perspective. To supply a forecasted peak load of 49,780 MW in 2050, 152,297 MW of capacity will be needed, roughly 3 times the peak load at that time. The corresponding numbers for 2030 are that for a peak load of 29,640 MW, a capacity of 68,244 MW is needed, more than twice as much. Given that the 2020 installed capacity is 44,023 MW, around 22,000 MW of additional capacity must be built in the next 7-8 years.

    NYSRC Comments

    The NYSRC comments included an illustration of the magnitude of future resource requirements based on the Draft Scoping Plan for Scenario 3, Annex 2.  The following table shows the amount and type of installed capacity required to meet Climate Act goals and meet NYSRC’s resource adequacy reliability criterion of 1-day-in-10-years. The text in red was added to demonstrate the total installed capacity, the peak load, the required reserve capacity and the IRM for the years 2025 through 2050.

    The comments describe the ramifications of these results:

    The table shows the increase in required reserve capacity from 22,577 MW (78.15% IRM) in 2025 to 102,517 MW (205.94% IRM) in 2050. These numbers need to be pondered in perspective. To supply a forecasted peak load of 49,780 MW in 2050, 152,297 MW of capacity will be needed, roughly 3 times the peak load at that time. The corresponding numbers for 2030 are that for a peak load of 29,640 MW, a capacity of 68,244 MW is needed, more than twice as much. Given that the 2020 installed capacity is 44,023 MW, around 22,000 MW of additional capacity must be built in the next 7-8 years. 

    The analysis makes a couple of assumptions:

    The table assumes that intermittent generation capacity from wind and solar resources increases from 13,319 MW in 2025 to 96,629 MW in 2050.

    The table also assumes that the magnitude of new technology requirements for Zero-Carbon Firm Resource (RNG, green hydrogen or other) increases from 5,489 MW in 2035 to 25,359 MW in 2050. Long-Term Battery Storage or other increases from 1,500 MW in 2025 to 19,212 MW in 2050. None of these technologies presently exist commercially for utility scale application.

    It is politically impossible for these experts to explain that not only do these technologies not exist commercially but there are physical limitations that suggest that a commercially viable and affordable resource like this may never be developed.  The reality is that this is not just a stretch, it is a massive leap in technology.

    The NYSRC comments go on to explain that there are other implementation factors that complicate the transition that the Draft Scoping Plan cavalierly claims will happen because of political will:

    Some of the new renewable resources will be located behind the meter at retail levels (i.e.. solar PV, batteries, and EV charging). This will also require investment in distribution system automation to protect reliability, cyber-security and public safety. The role of the Distribution System Operator will become even more critical in this complex operating environment.

    I think that the observation that the logistics of building the infrastructure necessary to meet the Climate Act goals is particularly important:

    The amount of new generation that needs to be built to maintain system reliability in a zero-carbon environment is sobering. This change represents an unprecedented increase in capital investment in resource capacity along with a corresponding increase in transmission and distribution capacity. Further, this transition must be managed during a time of high inflation, and supply chain delays, permitting challenges, and high demand for renewable resource equipment, not just in New York, but around the globe.

    There is another technical issue.  My comments on the electric system transition pointed out that it is not clear if the Draft Scoping Plan considered ancillary services.  The NYSRC comments explain:

    One other aspect that must be kept in mind is that renewables and storage devices work internally with direct current (DC) and must ultimately be interconnected to a grid that works with alternating current (AC). To accomplish this, devices called inverters that transform DC into AC and vice versa are used. These inverter-based resources (IBR) are starting to be used in increasing numbers in the USA and it is becoming clear through actual reliability impact events that more work is still necessary with respect to the reliability of IBRs, and standards need to be adopted for a reliable transition.

    I found no mention of this issue in the Draft Scoping Plan spreadsheets of inverter costs.  Finally, it is telling that the NYSRC notes that there will be a learning curve for operating a system based on intermittent and diffuse renewables. 

    Furthermore, even if we build all this capacity on time, operating a system largely based on renewable resources is not the same as operating the system of today. The performance and responsiveness of existing generation must be emulated to keep the lights on. We have no experience in operating a bulk power system that we will need to operate by 2030 and beyond.

    The fact is that New York’s current stringent reliability rules are based on hard learned experience.  It is incredibly optimistic to think that the system will make the transition without unanticipated issues that result in blackouts.

    NYSRC Recommendations

    One of the things that I think is most important is a feasibility study.  As a result, I was hearted by the NYSRC recommendation that “the proposed Climate Action Council strategy be reviewed for application in the short-term based upon practical considerations for the period 2025 to 2030”.  The NYSRC comments list the rationale for this review:

    Practical considerations affecting the availability, schedule and operability for new interconnections include: interconnection standards; site availability; permitting; resource equipment availability; regulatory approval; large volume of projects in NYISO queue and study process; scalability of long-term battery storage and other technologies; operational control; impact of extreme weather; consideration of a must run reliability need for legacy resources. In addition, the pace of transportation and building electrification, the timing of any natural gas phase-out and their impact on the electric T&D system must also be carefully studied from technical, economic and environmental perspectives. Together, these practical considerations require the development of reliable zero emission resources to be conscientiously sequenced and timed in the near term (through 2030) to ensure broader GHG reductions in all sectors beyond 2030.

    It is noted that delaying or changing a CLCPA goal would be preferable to the risk of a wide scale blackout and associated public safety concerns if it should ever appear that the implementation of the CLCPA’s goals may pose a significant risk to electric system reliability, including the potential risk of a system-wide blackout,

    In conclusion, there are many unknowns in the transition to CLCPA’s goals. The risks of not reaching a goal in the time required is real. The CAC and all participants in the transition to an emissions free grid need to stay alert to the critical importance of keeping the system functioning within reliability criteria. Each time that an existing unit must retire or stop operating through some regulatory action, there is a need to confirm that reliability criteria will still be met without that unit.

    Conclusion

    I have written several articles pointing out that the Climate Action Council is not listening to the experts.  The first post (New York Climate Act: Is Anyone Listening to the Experts?) described the NYISO 2021-2030 Comprehensive Reliability Plan (CRP) report (appendices) released late last year.  The difficulties raised in the report are so large that I raised the question whether any leader in New York was listening to this expert opinion.  The second post (New York Climate Act: What the Experts are Saying Now) highlighted results shown in a draft presentation for the 2021-2040 System & Resource Outlook that all but admitted meeting the net-zero goals of the Climate Act are impossible on the mandated schedule.  Finally, I described the “For discussion purposes only” draft of the 2021-2040 System & Resource Outlook report described in the previous article.  This report highlights multiple feasibility concerns that must be addressed to have any hope of this working, shows that implementation on the schedule proposed will be very difficult and highlights the need for implementation planning. 

    The NYSRC comments reiterate all the points mad by the NYISO, The organizations responsible for the relatability of the New York electric grid have raised numerous technological issues that must be addressed going forward for the transition.  Unfortunately, the loudest voices on the Climate Action Council have said that anyone saying there are issues related to using renewable resources are misinforming the public and no leaders on the Council have spoken up to reign in those statements.  If Climate Act implementation to net-zero does not address the issues raised then blackouts are inevitable.

    The Latest from the Experts on New York’s Climate Act Implementation

    This article was first published at Watts Up With That

    I have published two previous articles about New York Independent System Operator (NYISO) analyses related to New York’s Climate Leadership and Community Protection Act (Climate Act).  This post describes what I believe is an important new analysis of the future of New York’s electric system.

    New York’s Climate Leadership and Community Protection Act (Climate Act) Act establishes a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050.  I have written extensively on implementation of the Climate Act.  Everyone wants to do right by the environment to the extent that efforts will make a positive impact at an affordable level.  My analysis of the Climate Act shows that the ambitions for a zero-emissions economy outstrip available renewable technology such that the transition to an electric system relying on wind and solar will do more harm than good.  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.

    Background

    The implementation plan for New York’s Climate Act “Net Zero” target (85% reduction and 15% offset of emissions) by 2050 is underway.  The Climate Action Council has been working to develop plans to implement the Act.  Over the summer of 2021 the New York State Energy Research & Development Authority (NYSERDA) and its consultant Energy + Environmental Economics (E3) prepared an Integration Analysis to “estimate the economy-wide benefits, costs, and GHG emissions reductions associated with pathways that achieve the Climate Act GHG emission limits and carbon neutrality goal”.  Integration Analysis implementation strategies were incorporated into the Draft Scoping Plan when it was released at the end of 2021.  Since the end of the public comment period in early July 2022 the Climate Action Council has been addressing the comments received as part of the development of the Final Scoping Plan that is supposed to provide a guide for the net-zero transition.

    Unfortunately, the Climate Action Council has not confronted reliability issues raised by New York agencies responsible for keeping the lights on.  The first post (New York Climate Act: Is Anyone Listening to the Experts?) described the NYISO 2021-2030 Comprehensive Reliability Plan (CRP) report (appendices) released late last year.  The difficulties raised in the report are so large that I raised the question whether any leader in New York was listening to this expert opinion.  The second post (New York Climate Act: What the Experts are Saying Now) highlighted results shown in a draft presentation for the 2021-2040 System & Resource Outlook that all but admitted meeting the net-zero goals of the Climate Act are impossible on the mandated schedule.  This article describes the “For discussion purposes only” draft of the 2021-2040 System & Resource Outlook report described in the previous article.  While there may be minor changes to the document itself, I am comfortable saying that the major findings will not change substantively.

    System and Resource Outlook Summary

    The Executive Summary makes the point that the Climate Act is driving changes to the generating system, the transmission grid and the demand landscape.  As a result, this “leads to re-thinking how and where electric supply and storage resources evolve, and how to efficiently enable their adoption to achieve energy policy targets”.  The summary goes on to note:

    This 2021 – 2040 System & Resource Outlook (the Outlook), conducted by the New York Independent System Operator (NYISO) in collaboration with stakeholders and state agencies, provides a comprehensive overview of potential resource development over the next 20 years in New York and highlights opportunities for transmission investment driven by economics and public policy in New York State. The Outlook together with the NYISO’s 2021-2030 Comprehensive Reliability Plan (CRP) represent the marquee planning reports that provide a full New York power system outlook to stakeholders, developers, and policymakers.

    The Outlook examines a wide range of potential future system conditions and enables comparisons between possible pathways to an increasingly greener resource mix. By simulating several different possible future system configurations and forecasting the transmission constraints for each, the NYISO:

    • Projected possible resource mixes that achieve New York’s public policy goals while maintaining grid reliability;
    • Identified regions of New York where renewable or other resources may be unable to generate at their full capability due to transmission constraints;
    • Quantified the extent to which these transmission constraints limit delivery of renewable energy to consumers, and;
    • Identified potential opportunities for transmission investment that may provide economic, policy, and/or operational benefits.

    There are many potential paths and combinations of resource and transmission builds to achieving New York’s climate change requirements. As the current power system continues to evolve, evaluating a multitude of expansion scenarios will facilitate identification of common and unique challenges to achieving the electric system mandates New York State has set for 2030 and 2040. A thorough understanding of these challenges will help build a path for investors and policymakers to achieve a greener and reliable future grid efficiently and cost effectively. Through this Outlook several key findings were brought to light:

    Four potential futures are evaluated to best understand the challenges ahead. A Baseline Case evaluates a future with little change from today. A Contract Case includes approximately 9,500 MW of renewable capacity procured by the state and evaluates the impact of those projects. Finally, a Policy Case postulates and examines two separate future scenarios that meet New York policy mandates.

    Energy planning analyses such as this work normally evaluate different scenarios of the future by comparing them to a business-as-usual scenario.  In this instance the business-as-usual scenario does not include any of New York’s climate initiatives.  On the other hand, Climate Act Draft Scoping Plan analyses were perverted to “prove” the desired conclusion that the benefits were greater than the costs by comparing future scenarios against a reference scenario.  The Integration Analysis used a semantic trick to claim that some de-carbonization costs (such as de-carbonizing transportation costs) necessary to meet Climate Act targets did not have to be included in the comparison scenario because the electric vehicle conversion legislation was already “implemented”.  That approach took legitimate implementation costs out of the projections.  Of course, this also makes comparison of the NYISO work relative to the Draft Scoping Plan problematic.

    The second estimate of the future in the Resource Outlook considered only those projects currently under contract:

    Through an annual request for proposals, NYSERDA solicits bids from eligible new large-scale renewable resources and procures Renewable Energy Certificates (RECs) and Offshore Renewable Energy Certificates (ORECs) from these facilities. This Outlook included approximately 9,500 MW of new contracted renewable resources, including 4,262 MW of solar, 899 MW of land-based wind, and 4,316 MW of offshore wind. The addition of these resources to the existing system representation provides insights regarding their impact on system performance in the future.

    The Outlook report noted the following Key Takeaways for the contracted renewables scenario:

    The pace of renewable project development is unprecedented and requires an increase in the pace of transmission development. Every incremental advancement towards policy achievement matters on the path to a greener and reliable grid in the future, not just at the critical deadline years such as 2030 and 2040. In general, resource and transmission expansion take many years from development to deployment.

    Coordination of project additions and retirements is essential to maintaining reliability and achieving policy. Coordination of renewable energy additions, commercialization and development of dispatchable technologies, fossil fuel plant operation, and staged fossil fuel plant deactivations over the next 18 years will be essential to facilitate an orderly transition of the grid.

    Many more renewable resources have to be developed to meet the overall Climate Act net-zero goal by 2050 and the interim 2040 goal of “zero-emissions” electricity generation.  The NYISO analysis looked at two Policy Case scenarios that meet those targets:

    Scenario 1 utilizes industry data and NYISO load forecasts, representing a future with high demand (57,144 MW winter peak and 208,679 GWh energy demand in 2040) and assumes less restrictions in renewable generation buildout options.

    Scenario 2 utilizes various assumptions consistent with the Climate Action Council Integration Analysis and represents a future with a moderate peak but a higher overall energy demand (42,301 MW winter peak and 235,731 GWh energy demand in 2040).

    Both scenarios project a blend of land-based wind, offshore wind, utility-scale solar, behind-the-meter solar, and energy storage will be needed to meet the CLCPA policy mandates through 2035. There are significant differences between these scenarios and the equivalent Draft Scoping Plan mitigation scenarios.  One of the big differences is the magnitude of a new generating resource called “dispatchable emission-free resources” (DEFRs):

    These resources represent a proxy technology that will meet the flexibility and emissions-free energy needs of the future system but are not yet mature technologies that are commercially available (some examples include hydrogen, renewable natural gas, and small modular nuclear reactors). As more wind, solar, and storage plants are added to the grid, dispatchable emission-free resources must be added to the system to meet the minimum statewide and locational resource requirements for serving system demand when intermittent generation is unavailable.

    The report warns:

    Both scenarios include significant DEFR capacity by 2035, but it is important to note that the lead time necessary for development, permitting, and construction of DEFR power plants will require action much sooner if this timeline is to be achieved.

    As part of the analysis the NYISO considered what would be needed if the DEFR capacity is not developed. They found that “The exclusion of DEFRs as a new technology option, while enforcing the retirement of fossil generators via the zero-emission by 2040 policy, exhausts the amount of land-based wind built and results in the replacement of 45 GW of DEFR capacity in Scenario 1 with 30 GW of offshore wind and 40 GW of energy storage.”  They also noted that the alternative did not address ancillary service requirements needed for the transmission system.

    The Outlook report noted the following Key Takeaways for the Policy Case Scenarios:

    Significant new resource development will be required to achieve CLCPA energy targets. The total installed generation capacity to meet policy objectives within New York is projected to range between 111 GW and 124 GW by 2040. At least 95 GW of this capacity will consist of new generation projects and/or modifications to existing plants. Even with these additions, New York still may not be sufficient to fully meet CLCPA compliance criteria and maintain the reliable electricity supply on which New York consumers rely. The sheer scale of resources needed to satisfy system reliability and policy requirements within the next 20 years is unprecedented.

    To achieve an emission-free grid, dispatchable emission-free resources (DEFRs) must be developed and deployed throughout New York. DEFRs that provide sustained on-demand power and system stability will be essential to meeting policy objectives while maintaining a reliable electric grid. While essential to the grid of the future, such DEFR technologies are not commercially viable today. DEFRs will require committed public and private investment in research and development efforts to identify the most efficient and cost-effective technologies with a view towards the development and eventual adoption of commercially viable resources. The development and construction lead times necessary for these technologies may extend beyond policy target dates.

    As the energy policies in neighboring regions evolve, New York’s imports and exports of energy could vary significantly due to the resulting changes in neighboring grids. New York is fortunate to have strong interconnections with neighboring regions and has enjoyed reliability and economic benefits from such connections. The availability of energy for interchange is predicted to shift fundamentally as policy achievement progresses. Balancing the need to serve demand reliably while achieving New York’s emission-free target will require continuous monitoring and collaboration with our neighboring states.

    The important findings in the report led to the following recommendations:

    Future uncertainty is the only thing certain about the electric power industry. From policy advancements to new dispatchable emissions-free resource technology innovation and ultimate development, the system is set to change at a rapid pace. Situational awareness of system changes and continuous assessment are critical to ensure a reliable and lower-emissions grid for New York. The Economic Planning databases and models will be continually updated with new information and the Outlook study will be improved and performed on a biennial basis.

    To meet the minimum capacity requirement in 2040, at least 95 GW of new emission-free resources, including approximately 9.5 GW of new renewable resources, will be required to come on-line. Furthermore, to fully achieve the emission-free grid target by 2040, even more resources will likely be needed along with transmission to deliver the clean power to consumers. The scope of the additional renewable resource need is both substantial and unprecedented. Compared to the 2.6 GW capacity entering service in the past five years while New York experienced a net loss of approximately 2.2 GW, the installation rate in the next 20 years must increase significantly to achieve state law climate change requirements. State agencies should consider releasing a more detailed procurement schedule for renewable resources to guide the long-term system planning and provide clarity to the market.

    Discussion

    I noted earlier that I was comfortable saying that the major findings in this draft report will not change substantively when it is finalized.  I base that mostly on the fact that the NYISO Market Marketing Unit has reviewed the draft.  As part of their market monitoring responsibilities Potomac Electricreviewed the document relative to implications to New York’s de-regulated electric markets.  If you are interested in that particular aspect of electric system planning, I suggest checking out the memo.  For the rest of us, I only note that they state: “The 2021 Outlook is a major improvement to NYISO’s previous planning studies and provides important insights on the potential impacts of state policies on the NYISO system.”

    More importantly, what about the Climate Action Council?  Unfortunately, as I pointed out before the Climate Action Council has not confronted reliability issues raised by New York agencies responsible for keeping the lights on.  In a series of meetings over the next couple of months the Council will have to address the Draft Scoping Plan comments made by the NYISO and the New York State Reliability Council that raised reliability concerns.  I hope. without any supporting evidence, that the Integration Analysis team is working with the NYISO planning staff to reconcile the differences between this analysis and theirs.

    In the meantime, there are vocal members of the Climate Action Council that deny the existence of any implementation issues associated with a renewable energy resource dependent electric system.  At the May 26, 2022 Climate Action Council meeting Council members described their impressions of comments made at the public hearings.  I have prepared an overview summary of all the comments made during the Update on Public Hearings and Comments agenda item and wrote an article highlighting relevant comments.  In this regard, Paul Shepson Dean, School of Marine and Atmospheric Sciences at Stony Brook University talked about mis-representation at 23:39 of the recording:

    Mis-representation I see as on-going.  One of you mentioned the word reliability.  I think the word reliability is very intentionally presented as a way of expressing the improper idea that renewable energy will not be reliable.  I don’t accept that will be the case.  In fact, it cannot be the case for the CLCPA that installation of renewable energy, the conversion to renewable energy, will be unreliable.  It cannot be.

    Robert Howarth, Professor, Ecology and Environmental Biology at Cornell (starting at 32:52 of the recording) picked up on that theme.  He said that fear and confusion is based on mis-information but we have information to counter that and help ease the fears.  He stated that he thought reliability is one of those issues: “Clearly one can run a 100% renewable grid with reliability”.   Obviously, these views are at odds with this report.

    There is one other point.  In addition to the reliability concerns of the net-zero transition I am very concerned about affordability.  The Draft Scoping Plan has avoided any mention of ratepayer impacts to date.  The NYISO projection methodology has that information because it is inherent in the models. It is a shame that it is not being reported.

    Conclusion

    This is an important report for New York but I also believe that there are ramifications for other net zero transition programs.  These findings must be reconciled with the Draft Scoping Plan projections for the future generating system.  The leadership of the Climate Action has repeatedly punted the responsibility for a feasibility study down the road as somebody else’s problem. This report highlights multiple feasibility concerns that must be addressed to have any hope of this working.  I believe that it shows that implementation on the schedule proposed will prove impossible.  The report also highlights the need for implementation planning.  Currently there is no plan for siting renewable resources where they are needed for the future system and this shows that it must be done.

    With respect to other net-zero transition programs I think the discussion and implications of the dispatchable emissions-free resource are of interest.  The analysis shows that in order to minimize the storage and renewable over-build requirements this resource could be a better choice.   However, the report notes that DEFRs such as hydrogen, renewable natural gas, and small modular nuclear reactors are not commercially viable today. “DEFRs will require committed public and private investment in research and development efforts to identify the most efficient and cost-effective technologies with a view towards the development and eventual adoption of commercially viable resources.”  There is that nasty planning and feasibility is necessary component again.

    NYISO Offshore Wind Profile Development

    The implementation plan for New York’s Climate Leadership and Community Protection Act (Climate Act) “Net Zero” target (85% reduction and 15% offset of emissions) by 2050 is underway.  I think the biggest problem confronting any net-zero transition effort is matching variable wind and solar generation with load at all times.  This post describes an effort by the New York Independent System Operator (NYISO) to address that problem for offshore wind resources.  It is a great start but needs to be expanded for other sources of renewable generation and for as long a period as possible.

    I have written extensively on implementation of the Climate Act.  Everyone wants to do right by the environment to the extent that efforts will make a positive impact at an affordable cost.  Based on my analysis of the Climate Act I don’t think that will be the case as proposed.  I believe that the ambitions for a zero-emissions economy outstrip available renewable technology such that the transition to an electric system relying on wind and solar will do more harm than good.  I am a retired meteorologist who started working for Niagara Mohawk in 1981 and have continued to work in the New York electric generating industry continuously since then.  Over that time, I have been involved in many energy planning activities that included meteorological components. 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.

    Climate Act Background

    The Climate Act established the Climate Action Council who is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  They were assisted by Advisory Panels who developed and presented strategies to meet the goals.  Those strategies were used to develop the Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies.  That analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021 and will be finalized in 2022. 

    Renewable Resource Adequacy

    I called the renewable resource adequacy problem the ultimate problem for the Climate Act as early as September 2020.  On August 2, 2021, the New York State Energy Research and Development Authority (NYSERDA) held a Reliability Planning Speaker Session to describe New York’s reliability issues to the advisory panels and Climate Action Council.  All the speakers but one made the point that today’s renewable energy technology will not be adequate to maintain current reliability standards and that a “yet to be developed technology” will be needed.  A recent article by David Wojick at PA Pundits International titled Unreliability Makes Solar Power Impossibly Expensive does a great job describing how renewable resource availability affects reliability.  I adapted his work to New York to analyze the impact on the Draft Scoping Plan.

    There are serious problems when extreme weather affects the grid.  The Federal Energy Regulatory Commission (FERC) and the North American Electric Reliability Corporation (NERC) report on the February 2021 cold weather outages in Texas and the South Central United States described the event, the impacts and made recommendations.  According to the report this event was the fourth cold-weather event in the last ten years to affect bulk electric system reliability.  Cold weather caused problems that required rolling blackouts to avoid system instability and even worse problems for the electric grid.  Given that the weather conditions that caused these problems occurred recently I am taken aback that resources were not devoted to preventing re-occurrence.  Among the many recommendations two are relevant: “improving near-term load forecasts for extreme weather conditions” and additional study of “potential effects of low-frequency events on generators in the Western and Eastern Interconnections”.

    In order to address this renewable resource variability problem, it is necessary to determine the worst-case meteorological conditions affecting wind and solar availability.   As long as the NYISO and other agencies responsible for electric system reliability understand the worst-case renewable availability conditions they can plan to prevent low availability impacts.  I submitted comments on the Draft Scoping Plan’s treatment of wind and solar resource availability and concluded that it was inadequate in this regard. I recommended that the State undertake a more comprehensive analysis of wind and solar availability to serve as input for future reliability planning.  I have also been trying to get the NYISO and New York State Reliability Council to consider the recommendations I made for a comprehensive availability analysis.  So far, I have not had any success getting a response.

    Offshore Wind Power Profile Study

    Despite my personal lack of success I was encouraged that the NYISO started a project in July to address offshore wind profile development.  In particular, they plan to develop wind power estimates for the New York offshore wind development areas that will estimate resource availability for a 20-year period.  I am going to highlight some of the slides in the presentation by DNV describing their work for the NYISO ICAP/MIWG/PRLWG Meeting on September 07, 2022.  Note that all the slides are copyrighted to either NYISO or DNV and are labeled as draft for discussion purposes only.  I am including a couple of slides to show what should be done on a more comprehensive basis for the Final Scoping Plan.

    In my opinion, the critical consideration is the frequency, duration, and severity of periods when wind and solar resources are in “droughts” or low resource availability.  I described several recent applicable papers in my comments describing analyses to estimate the frequency and duration of periods with those conditions.  In order to provide a robust estimate of the wind and solar availability during worst case conditions I believe it is necessary to analyze as long a time period of historical meteorological data as possible. Fortunately, meteorological reanalysis descriptive data generated by modern weather forecast models but using observed data from decades ago is available for this application. This is exactly what DNV is proposing to do.

    The DNV project description slide explains that they will use the historical data to generate detailed wind maps using a weather forecast model.  This output is combined with their model that projects wind energy output as a function of wind speed.  They are going to model wind energy production for seven potential development areas off Long Island and New Jersey.

    The weather model slide describes their approach.  They are going to use a forecast model that takes historical data and calculates wind speed and direction on an hourly basis.  The inputs for their modeling include not only the observed meteorological data but also surface characteristics and surface temperatures.  Note that the model inputs extend far beyond the offshore wind study area.

    The presentation also includes slides on wind power modeling, wind turbine power curve output, and describes their validation analyses.  They also described four different aspects that cause reductions in power output in their analysis.  At some point I should compare their assumptions with those used in the Draft Scoping Plan.  In order to minimize wake effects DNV is proposing 1 nautical mile spacing which seems higher than I have noticed elsewhere.

    Discussion

    I think that this analysis is a great start.  I only have one concern relative to the scope of work.  As far as I could tell the meteorological input data is available back to 1980.  However, this project only goes back to 2000.  I think it would be better to evaluate the 1980 to 2000 data specifically looking for wind droughts.  I know there was a huge ozone episode in August 1988 that had to include very light winds.  I have no idea how that period compares to “normal” but we won’t know because this analysis does not cover that period. 

    This analysis is entirely appropriate for the offshore wind resource.  However, it does not address the onshore wind and solar resources.  The same type of analysis has to be done for those resources covering not only the entire state but also the area where New York could expect to import power.   Ideally, the ERA5 global reanalysis data base that goes back to 1950 should be used in the analysis to find the worst-case conditions.  It is not necessary to determine the renewable power output over the entire period and region.  Once the worst cases are identified then a power output model can be applied to those periods to determine how the electric system can be setup to avoid bulk electric supply disruptions. 

    It is my professional opinion that until this comprehensive renewable energy resource evaluation is completed that New York State will unnecessarily risk catastrophic blackouts.  Because the worst-case resource availability is associated with the coldest or hottest periods, the loads are highest and the need to prevent blackouts most acute.

    Working with New York Farmers to Ensure Climate Resiliency for the Future

    There is a consistent disconnect between reality and the State’s consideration of climate change incorporated in the Climate Leadership and Community Protection Act (Climate Act).  Nowhere is this more obvious than in the op-ed by NYS Department of Environmental Conservation Commissioner Basil Seggos and NYS Department of Agriculture and Markets Commissioner Richard Ball published in the Auburn Citizen on August 30.

    New York’s Climate Leadership and Community Protection Act (Climate Act) Act establishes a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050.  I have written extensively on implementation of the Climate Act.  Everyone wants to do right by the environment to the extent that efforts will make a positive impact at an affordable level.  My analysis of the Climate Act shows that the ambitions for a zero-emissions economy outstrip available renewable technology such that the transition to an electric system relying on wind and solar will do more harm than good.  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.

    New York Permitting Requirements

    New York’s Article Ten process defines the permitting requirements for all large-scale electric generating new construction or expansion.  It includes extensive and time-consuming public notification and public participation requirements.  The 2011 revisions to the Article Ten law were intended to speed things up but were largely ineffective in that regard.  In early April 2020, NYS passed the Accelerated Renewable Energy Growth and Community Benefit Act (AREGCBA) as part of the 2020-21 state budget.  The legislation was intended to ensure that renewable generation is sited in a timely and cost-effective manner.   Unfortunately, the result has been an unchecked land rush of solar development in the state with no limitations on the conversion of prime farmlands to utility-scale solar development. 

    Discussion

    The primary purpose of the op-ed was to congratulate Greenfield Farms in Skaneateles, NY for being “the recipient of this year’s prestigious New York Leopold Conservation Award for its extraordinary environmental protection efforts, uses healthy soil practices that enhance water quality and strengthen carbon sequestration”.  That is a great achievement and I believe it should be a keystone component of the state’s efforts for a resilient agricultural economy.

    The op-ed also describes New York State’s innovative Climate Resilient Farming Program.  This program “assists farmers who proactively tackle climate concerns by providing cost-shared grants to incentivize transformative management practices that reduce greenhouse gas emissions, draw down carbon dioxide from the atmosphere, and increase carbon storage in soils and woody plants.”  Those are laudable efforts, are necessary for Climate Act implementation, and I support them. 

    However, the op-ed goes off the rails when it continues: “At the same time, it helps protect at-risk agricultural land across the State.”  I have written multiple articles about solar siting with respect to agriculture in New York.  Based on that work I believe that the biggest risk to agricultural land in New York State is the lack of a responsible solar siting framework for the massive utility-scale solar projects needed to meet the Climate Act targets.  There is a policy option roadmap for the proposed 10 GW of distributed solar development.  However, there is not an equivalent set of policies for utility-scale solar development.  

    On July 25, 2022 a press release from Governor Hochul announced siting approval of New York’s largest solar facility to date.  The release said that the “New York State Office of Renewable Energy Siting has issued a siting permit to Hecate Energy Cider Solar LLC, to develop, design, construct, operate, maintain, and decommission a 500-megawatt solar facility in the Towns of Oakfield and Elba, Genesee County.“  In the press release Commissioner Basil Seggos was quoted as saying:

    DEC applauds Governor Hochul’s ongoing prioritization of renewable energy development to support our state’s necessary transition away from fossil fuels. As more solar projects continue to be approved and come online, we are closer to achieving the goals and requirements set in the Climate Leadership and Community Protection Act. This will continue to provide renewable energy benefits here in Genesee County and throughout the state.

    In my article on this approval, I noted that according to the exhibit titled “Farmland Classification Mapping” that lists landcover class data.:

    According to NLCD data, the dominant landcover class in the Project Site is active agriculture, followed by forestland. Agricultural lands in the Project Site are comprised of active agricultural land (both row crops and mowed/maintained hayfields) and there are numerous family and commercial farms and farm structures in the Project Site. Row crops comprise approximately 68% (3,143 acres) of the Project Site, and less than 1% (23 acres) of the total Project Site is maintained hayfields. Additionally, there is approximately 3.5% (161 acres) of the Project Site where the dominant land cover is grasslands or pasturelands.

    Relative to agricultural soils, the Project Site includes approximately 41% (1,912 acres) of land classified as Prime Farmland, 27% (1,252 acres) as Prime Farmland if Drained, 19% (891 acres) as Farmland of Statewide Importance, and 13% (596 acres) as Not Prime Farmland (Natural Cooperative Soil Survey 2020).

    The prime farmland and prime farmland if drained categories total 2,143 acres well in excess of 1,400-acre Greenfield Farms.

    I believe best practices for solar development should meet the Department of Agriculture and Markets target for prime farmland conversion.  In particular, “The Department’s goal is for projects to limit the conversion of agricultural areas within the Project Areas, to no more than 10% of soils classified by the Department’s NYS Agricultural Land Classification mineral soil groups 1-4, generally Prime Farmland soils, which represent the State’s most productive farmland.”   Four recently approved solar projects totaling 920 MW all exceeded that threshold and converted 3,456 acres of the state’s prime farmland to industrial use.  Overall, those projects converted 28% of the prime farmland in the Project Areas.  In addition, none of these projects propose practicing responsible solar siting consistent with the state’s distributed solar development roadmap.  For example, there are no provisions for agricultural practices consistent with the solar panels.

    Conclusion

    The current projections for utility-scale solar development call for over 43,000 MW in order to meet the requirements for zero-emissions power.  At the current rate of converted prime farmland to capacity development upwards of 161,000 acres of prime farmland could be lost.  Until such time that the state adopts responsible solar siting guidelines for utility-scale development consistent with existing policies for distributed solar, the impacts of solar development will have bigger impacts on agriculture than those purported to occur because of climate change.

    Obviously, Commissioner Seggos recent press releases are hypocritical.  Regarding the massive solar project, he states that “Solar farms of this scope produce enough energy to power thousands of homes while also creating well-paying, family-sustaining jobs and breathing new life into our local economies.”  His op-ed states that the Climate Resilient Farming Program “helps protect at-risk agricultural land across the State”.  The fact is that unbridled utility-scale solar development is the major risk to agricultural land in the State and no amount of protection from any virtue signaling state agricultural program is going to stop that.

    Updates to Pragmatic Environmentalist Pages

    I am going to start summarizing updates I make to the pages I maintain at  Pragmatic Environmentalist of New York and Reforming the Energy Vision Inconvenient Truths.  I have an extensive list of reference materials on my original blog that I occasionally update when I run across an article that is particularly interesting and relevant and this blog also has reference material.  This article describes some recent page updates.

    I started blogging in late 2017 on New York’s energy policies because I was convinced that they are going to end as an expensive boondoggle driving electricity prices in particular and energy prices in general significantly higher. Reforming the Energy Vision (REV) was the previous comprehensive energy strategy for New York. I wrote about the inconvenient unpublicized or missing pieces of New York State’s REV policy: implementation plan, costs and impacts. At some point I should probably combine that blog with this one but in the meantime, I will maintain them both.  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.

    Updates

    I linked two articles to the renewable energy feasibility page.  This very good overview of all the problems associated with green energy was described at the Australian Stop These Things website.  Author Andrew Roman points out six issues ignored by New York State energy policy:

    All energy sources have some adverse effects on the environment, including wind and solar:

    • extensive use of scarce minerals supply, largely controlled by China;
    • massive concrete bases and steel towers of wind generators require extensive use of coal in manufacturing;
    • low energy density requires huge amounts of land (some 25 per cent of the US land area if all electricity was to be generated by solar panels);
    • wind turbines kill birds and bats;
    • both solar panels and wind turbines create huge amounts of un-recyclable waste
    • China dominates solar panel and wind turbine manufacturing by burning a lot of coal.

    The article goes on to document these issues.

    The second renewable feasibility article by Francis Menton made the point that the easiest Net-Zero goal is to eliminate emissions in the electric generation sector.  However, he points out that not only has no jurisdiction successfully made the transition but also argues that it will be never be achieved.  He notes that wind and solar development is entirely dependent upon government subsidies.  All other energy transitions have been based on organic consumer demand not on government mandates.  His article describes the current situation in Europe where net=zero energy transition policies have created a situation where they don’t have dispatchable, emissions-free generating resources available for extended periods of low wind and solar resource availability causing affordability and reliability issues.  He concludes:

    So, if you have a chance to make a bet, you’ll be extremely safe betting against Net Zero generation of electricity any time during your life. Nuclear is the only way it could potentially be done, and that’s blocked by regulatory obstruction more or less everywhere.

    Chris Denton from New York’s Southern Tier wrote a great article describing a reasonable development policy for industrial solar that I linked to my solar issues page.  He points out that it is reasonable to have a policy framework in place before we “advance the production of electric energy by means of industrial free-standing solar collectors”.  He argues that developing industrial solar facilities diverts land from an existing use (e.g., habitat or agriculture) it follows that “how much and where we divert the sun’s rays ought be very carefully measured and studied before allowing any further industrial development of solar electric generation.”  He points out that there are plenty of locations that do not impact agriculture and sequestration so those should a priority.  He concludes:

    The damage caused by our refusal to recognize these impacts can destroy our environment as effectively as any other unexamined industrial or commercial project. It is that very blindness to incremental, unplanned action that has led to the very global warming which we are now trying to unwind.  We should not make the same mistake in the cure as we did in acquiring the disease. We need to take care that in our zeal to protect our environment from unrestricted global warming, we don’t destroy the very plants, animals, land, water, and scenic values which we are trying to protect.

    I added a link to this article on offshore wind turbine spacing to the wind issues page.  As turbines become bigger their wakes become bigger and that leads to a reduction of output at any existing turbine that is too close.  “An important new working paper from renewables consultants ArcVera is reporting that the wake effects behind the huge turbinesthat are now coming onstream are going to be much worse than previously thought.”

    Other Articles of Interest

    There were a couple of other articles that were interesting but inappropriate for my pages. 

    Science and religion belong to separate domains. Science is empirical, falsifiable and logical, where later scientists “stand on the shoulders” of the earlier. It constitutes the finest achievement of Western civilization. The Tenth Climate Commandment’s prohibition against debate leads to the death of science, when science is replaced by an ideology that justifies its authority by its order not to question.  This is the same claim which religions have made through the ages. As the Roman poet Horace warns: “vestigia terrent”- the footprints are frightening

      Question for the Climate Action Council

      The implementation plan for New York’s Climate Leadership and Community Protection Act (Climate Act) “Net Zero” target (85% reduction and 15% offset of emissions) by 2050 is being developed.  Here is a question for the Climate Action Council.  How do you expect to avoid the affordability and reliability issues evident in Europe occurring as their net-zero policies are implemented?

      I have written extensively on implementation of the Climate Act and submitted extensive comments on the Draft Scoping Plan.  Everyone wants to do right by the environment to the extent that efforts will make a positive impact at an affordable cost.  Based on my analysis of the Climate Act I don’t think that will be the case.  I believe that the ambitions for a zero-emissions economy outstrip available renewable technology such that the transition to an electric system relying on wind and solar will do more harm than good.  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.

      Climate Act Background

      The Climate Act established the Climate Action Council who is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  They were assisted by Advisory Panels who developed and presented strategies to meet the goals.  Those strategies were used to develop the Integration Analysis prepared by New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies.  That analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021 and will be finalized in 2022.  The Climate Action Council has set up three subgroups to consider alternative fuels, economy-wide strategies to fund the transition, and gas system transition.  While I do not deny that these are worthwhile topics, I am disappointed that reliability, feasibility, and affordability are not being explicitly considered.  This is of particular concern given the energy affordability and reliability crises underway in Europe.

      Great Britain Affordability

      Net Zero Watch publishes a newsletter that describes climate and decarbonization policies, what they cost, whether they are delivering and what their real impact is on the environment.  Based in Great Britain they are following the affordability impacts of current net-zero energy policy.  The latest reports from their newsletter are disturbing.

      The Office of Gas and Electricity Markets (OFGEM), supporting the Gas and Electricity Markets Authority, is the government regulator for the electricity and downstream natural gas markets in Great Britain.  The energy price cap is a backstop protection from the government for people who default onto their supplier’s basic energy tariff. Ofgem calculates the cap level that suppliers must apply to these tariffs. 

      According to the Independent, August 27, 2022, the “United Kingdom faces ‘catastrophe’ after energy bills soar 80% amid warning price cap could hit £7,000”.  The article notes that:

      Regulator Ofgem has revealed that the price cap, which is supposed to protect consumers from unfair energy bill increases, will rise to £3,549 per year for an average household – more than three times last winter’s level. That is expected to leave some 8.9 million households in fuel poverty, charity bosses have said, with a “real risk” that children will go hungry as Britain’s poorest see almost half of their income taken up by gas and electricity.

      There also were articles describing the impacts beyond the obvious energy poverty ratepayer effects.  The energy caps apply only to consumers but not, for example, health care providers.  It has been reported that:

      The chief executive of Care England said providers faced a staggering 683 per cent increase in energy costs during the past 12 months, with bills expected to rise again early next year. For gas and electricity, the costs were £660 per bed, per year, this time last year; this week, care providers have to pay an astonishing £5,166.

      The Daily Telegraph writes that this is not just a problem for low-income people.  In an interview with the Telegraph, Nadhim Zahawi said that “support cannot be confined to families on benefits and added that gas prices could remain punishingly high for two years.”  He went on to say: “If you are a senior nurse or a senior teacher on £45,000 a year, you’re having your energy bills go up by 80 per cent and will probably rise even higher in the new year – it’s really hard”.

      An editorial in the Wall Street Journal brings home the impacts of these high prices.  It notes that the latest price increases bring the average household’s annual bill to £3,549 and that the median household income is £31,400.  That means that for half of the households if their average annual budget for central heating, cooking, and keeping the lights on is equal to the average that the percentage of income spent on energy is over 11%.  New York has an energy poverty target of only 6% so if the adverse affordability effects of New York net-zero implementation are anyway similar then we can expect a major increase in the number of households in energy poverty.

      German Reliability

      Writing at No Tricks Zone, P. Gosselin translates an article from Die kalte Sonne.  He explains that Germany’s massive, subsidized expansion of electricity generation from renewable sources has squeezed conventional generation units out of the market. Two experts warn of growing grid instability.

      Quo Vadis, Grid Stability?

      The conclusion of the two is very alarming. Here, too, not a word about “storage facilities galore. Here, reality clashes with the wishful thinking of some green energy protagonists who think there is enough storage and that all that needs to be done is to change the “mindset,” as Patrick Graichen put it.

      The continued expansion of highly volatile renewable energy sources and the further displacement of more conventional generation units from the market are making the power grid increasingly sensitive to weather-related fluctuations. Unusual weather phenomena such as dark doldrums pose significant challenges to the security and stability of supply to the power grid. The largely intermittent output of solar and wind farms does not correlate with fluctuations in electricity demand.

      The excess supply of renewable energy should be buffered during periods of low electricity demand, and the stored capacity should be injected back into the grid during periods of high electricity demand when fewer renewable sources are available. However, large battery energy storage systems, which have been promisingly announced, are still not on the horizon due to their low capacity and maturity, as well as their exorbitantly high cost of deployment.”

      At this point, at the latest, some people’s ears should be ringing:

      As long as economic energy storage systems are not established, even proponents of the current direction of Germany’s energy transition will have to admit that reliable conventional power plants will be needed for a long time to come.”

      This article is also an urgent reading recommendation for politicians and experts who like to be interviewed.

      The authors also conclude:

      The importance of nuclear power plants for security of supply in base-load operation and their and their ability to operate the grid in parallel with renewable renewable energies have been demonstrated. The nuclear power plants appear to be well suited for the energy made to achieve the future goal of carbon-free power generation. However, the Atomic Energy Act foresees an early end to nuclear power generation by the end of 2022.”

      So without nuclear power in Germany, grid stability problems are a future certainty.

      Conclusion

      At the August 23, 2022 Climate Action Council meeting some of the comments were discussed.  Among the 35,000 comments submitted were around 900 with attachments including “some still being reviewed and summarized”.  There was no mention of a couple of points I raised in comments about specific Climate Act mandates including one for the Climate Action Council  to consider results from other jurisdictions and another for the New York Public Service Law  § 66-p. “Establishment of a renewable energy program” safety valve conditions for affordability and reliability.  In order to address both mandates the Climate Action Council should respond to the question: How do you expect to avoid the affordability and reliability issues evident in Europe occurring as their net-zero policies are implemented?

      I don’t think there is any way to avoid the issues seen in Europe.  So, I have to wonder whether the Climate Action Council is willfully or naively ignoring the energy crisis as it unfolds.  In any case failure to account for the issues will ensure that New York goes over the same cliff.

      Initial Forecast Verification for August 23, 2022 Climate Action Council Meeting

      The implementation plan for New York’s Climate Leadership and Community Protection Act (Climate Act) “Net Zero” target (85% reduction and 15% offset of emissions) by 2050 is underway.  Prior to the August 23 the Climate Action Council meeting I posted a prediction for the “Public Comments Summary and Proposed Process for Integration” agenda topic.  This post is a forecast verification based on the meeting presentation slides.  I will update this more when the video for the meeting is posted.

      I have written extensively on implementation of the Climate Act and submitted extensive comments on the Draft Scoping Plan.  Everyone wants to do right by the environment to the extent that efforts will make a positive impact at an affordable cost.  Based on my analysis of the Climate Act I don’t think that will be the case.  I believe that the ambitions for a zero-emissions economy outstrip available renewable technology such that the transition to an electric system relying on wind and solar will do more harm than good.  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.

      Climate Act Background

      The Climate Act established the Climate Action Council who is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  They were assisted by Advisory Panels who developed and presented strategies to meet the goals.  Those strategies were used to develop the Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies.  That analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021 and will be finalized in 2022.  The Climate Action Council has set up three subgroups to consider alternative fuels, economy-wide strategies to fund the transition, and gas system transition.  While I do not deny that these are worthwhile topics, I am disappointed that reliability, feasibility, and affordability are not being explicitly considered.

      Climate Action Council Meeting August 23, 2022

      The agenda and meeting information are available in the 2022 Climate Action Council Meetings section of the Climate Act Materials and Meetings website.  In the previous post, I predicted that the agenda item discussing public comments would make the number of posts a point of emphasis, will undoubtedly count the comments in favor and make a big deal that the majority of the comments support the Draft Scoping Plan approach.  The number of posts was a point of emphasis in the following slide but the slides did not provide a scorecard of comments in favor relative to the comments opposed.  So I was only half right.

      The slides summarized the feedback received.  There were cost impact concerns as shown in the following.  It will be interesting to see if the Council responds to the issues raised or just decides that they need to do more advertising to convince people that these issues are not real.

      Capacity, reliability, and security of the electric grid issues were raised.  I have often written about those issues so will be very interested to see how the council handles them,

      The presentation also described comments made about “Jobs and the New York economy”, “Alternative fuels”, “Scoping Plan goals, timeline and process”, “Renewable energy technologies”, “Climate justice and equity”, “Perceived ban on wood burning”, “Economy-wide strategies”, and Sector-specific feedback”.  Frankly, the commenters who supported the Draft Scoping Plan descriptions of these topics are naïve in my opinion and just parroted the talking points of special interest groups.  Many valid concerns were raised on these topics.

      While the descriptions are mostly unbiased, I also got the impression that comments contrary to the narrative were not taken seriously and will be dismissed.  This is most evident in the following slide with the description climate change denial.  Denial in this context is a pejorative term equating anyone who does not accept the climate change science narrative of the Climate Act and Draft Scoping Plan as the same as those that do not accept the Holocaust.  Drawing a similarity to a scientific theory with the documented horrors of the holocaust is an insult and inappropriate in the presentation.  Also consider that one of the descriptions highlights the argument that some said New York’s climate goals would be insignificant if other jurisdictions do not take similar actions.  My concern is what happens to this point now?  Will the Final Scoping Plan provide a calculation showing the impact of New York’s climate goals relative to other jurisdictions or will the response just be blown off?

      The remaining descriptions of the comments addressed the 28,500 email campaign categories.  Forty five organizations developed a form letter and had their members submit a form letter using their template.  All of these letters represent special interest of one form or other.  The campaigns were separated into nine categories: gas transition, climate & environmental justice, multi-topic, green hydrogen, agriculture & forestry, wood burning, nuclear energy, waste incineration, and legislation.  I will break down the numbers below but if you wonder what the special interest campaigners were exercised about then I refer you to these summaries.

      The slides did list the approximate number of commenters in each of the campaigns. I have summarized the interesting totals below.  For example consider the 13,300 gas transition comments that expressed support about doing something about climate change but basically said they were not willing to give up natural gas.  There was an email campaign (~ 500 submissions) in the multi-topic category that similarly expressed support for climate change action but said that it “Must strike the right balance between protecting our planet and safeguarding our economy”.  I think that could be taken to mean that they are not willing to take hits to the economy they think are inherent in the Climate Act.  There was similar support with conditional concerns with the agriculture and forestry commenters.  Amazingly to me, if all those comments can be categorized as we don’t support the current content of the Draft Scoping Plan, then half the comments were against.  I fully expected that a clear majority of comments would support the Draft Scoping Plan transition plan for the Climate Act so predicted that would be highlighted.  That was not the clearcut case and could be the reason that no scorecard was presented.

      It is notable that no email campaign addressed the electric vehicle mandate.  It is not surprising because all the car companies have signed on to do electric vehicles and the government support for electric vehicle purchases means they can raise prices commiserate with those subsidies.  I am convinced however, that most people Upstate have no intention of switching to an electric car as their primary mode of transportation and were simply unaware of the opportunity to comment.  I imagine if there was some organization that asked people to submit a comment against the requirement to lose the ability to purchase an internal combustion engine by 2035 that the submittals against that component would be overwhelming.

      When I described my predictions, I outlined what I thought should be done if the Council really wants to integrate public comments and predicted that it would not be included.  I said the comments have to be provided in a searchable database for the Council and public as soon as possible.  The comments have to be categorized into specific topics for the Council with a summary of the issues raised with an emphasis on substantive issues.  The proposed process for integrating the comments slide makes no mention of a database.  The staff will summarize themes which is equivalent to categorizing the comments.  The slide says that staff will continue developing actionable recommendations which I guess relates to my substantive issues.  However, the slide presentation to the Council did not highlight issues that must be addressed.  Maybe that occurred during the discussion but that review will have to wait until the video recording is available and I have to review it.

      One final point about the presentation.  The initial slide mentioned that 900 comments included attachments and that some of those are still being reviewed and summarized.  The only way to provide substantive comments is by using attachments.  There was no mention of comments submitted by the New York Independent System Operator (NYISO) or New York State Reliability Council.  The staff summary of those comments should be highlighted to the Council members and the fact that no slide highlighted their comments suggests to me that haven’t been reviewed yet.

      At some point I should discuss the section of the presentation that described continuing Integration Analysis work.  It is a problem for me that this work has been going on apparently absent comment input.  I think the NYISO comments would be directly relevant to the Integration Analysis work but there was no suggestion of that.  The presentation claimed that benefits out-weighed the costs but I submitted comments that directly contradicted that.  I described the games played to be able to conclude that “The cost of inaction exceeds the cost of action “.   The reality is that the benefits are imaginary but the costs are real and the Integration Analysis that provides the basis of the Draft Scoping Plan consistently over-states benefits and under-estimates the costs.  Shouldn’t the Council know that there were comments on that specific topic or will my comments be ignored because there was only one comment that said that?

      Conclusion

      There is no indication that any comment that is not consistent with the Draft Scoping Plan narrative will be incorporated into the Final Scoping Plan.  Given the schedule and the approach outlined at the meeting, I doubt that the Council will ever hear about those comments, much less discuss why they should be ignored.

      The Climate Action Council has to make a case that a net-zero electric system will work and to date they have totally ignored that analysis.  Francis Menton recently summarized the issues with such a transition and concluded that it will never work.  I have little faith that the current administration is going to address the issues he raises.  I only hope that the folks who are foisting this travesty on the state will be in some way held accountable when the plan fails.