NY Climate Act Implementation – IEA Special Report on Clean Energy Innovation

Update July 6, 2020: I looked at the ETP Clean Energy Technology Guide in more detail and found their ratings for anerobic digesters.  I have modified the relevant section.

On July 18, 2019, Governor Cuomo signed into law the Climate Leadership and Community Protection Act (Climate Act). It is among the most ambitious climate laws in the world and requires New York to reduce economy-wide greenhouse gas emissions 40 percent by 2030 and eliminate the use of fossil fuel for electricity production by 2040. New York’s politicians were sure that implementing these goals was simply a matter of political will so they offered no plan how it would be done.  The International Energy Agency (IEA) recently published “Special Report on Clean Energy Innovation” that directly relates to this implementation effort that I believe should be required reading for New York’s Climate Action Council.

I am following the implementation of the CLCPA closely because its implementation affects my future as a New Yorker.  Given the cost impacts for other jurisdictions that have implemented renewable energy resources to meet targets at much less stringent levels I am convinced that the costs in New York will be enormous and my analyses have supported that concern.  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.

On June 24, 2020 Energy plus Environmental Economics (E3) presented results of their emissions reductions pathway analyses to the New York Climate Action Council which gives the first inkling of what the law’s supporters acknowledge will have to be done.  I took issue with the presentation’s claim that “Deep decarbonization in New York is feasible using existing technologies” previously and in this post will highlight key points made in their Special Report on Clean Energy Innovation (“EIA Report”) that are relevant to New York’s Climate Act Implementation.


New York’s Climate Act requires that the Climate Action Council prepare a plan for “net zero emissions in all sectors of the economy” in the following:

§ 75-0107. Statewide greenhouse gas emissions limits.

1. No later than one year after the effective date of this article, 24 the department shall, pursuant to rules and regulations promulgated after at least one public hearing, establish a statewide greenhouse gas emissions limit as a percentage of 1990 emissions, as estimated pursuant to section 75-0105 of this article, as follows:

a. 2030: 60% of 1990 emissions.

b. 2050: 15% of 1990 emissions.

§ 75-0103. New York state climate action council.

11. The council shall on or before two years of the effective date of this article, prepare and approve a scoping plan outlining the recommendations for attaining the statewide greenhouse gas emissions limits in accordance with the schedule established in section 75-0107 of this article, and for the reduction of emissions beyond eighty-five percent, net zero emissions in all sectors of the economy, which shall inform the state energy planning board’s adoption of a state energy plan in accordance with section 6-104 of the energy law. The first state energy plan issued subsequent to completion of the scoping plan required by this section shall incorporate the recommendations of the council.

The E3 presentation echoes the belief of the supporters of the Climate Act that achieving the net zero goal is essentially just a matter of political will.  However, the IEA report suggests that optimism is mis-placed:

“Without a major acceleration in clean energy innovation, net-zero emissions targets will not be achievable. The world has seen a proliferating number of pledges by numerous governments and companies to reach net-zero carbon dioxide (CO2) emissions in the coming decades as part of global efforts to meet long-term sustainability goals, such as the Paris Agreement on climate change. But there is a stark disconnect between these high-profile pledges and the current state of clean energy technology. While the technologies in use today can deliver a large amount of the emissions reductions called for by these goals, they are insufficient on their own to bring the world to net zero while ensuring energy systems remain secure – even with much stronger policies supporting them.”


In order to focus my analysis on a manageable component of the Climate Act implementation plan I am going to address one component of the electric sector de-carbonization pathway.  E3 and I agree that the biggest problem for a de-carbonized electric system is going to be the winter peak when solar resources are low and the potential for a large high-pressure system could mean that wind resources are near zero for several days.  E3 claims the New York winter statewide peak load will be 24 GW in 2020 and in 2050 the peak load will be 35 GW with flex loads and 43 GW without flex loads when the added demands of electrifying transport and heating are added to the system. E3 offered a combination of five options to meet the challenge: large-scale hydro resources, renewable natural gas, synthetic fuels such as hydrogen, Carbon Capture Storage (CCS), and nuclear power.  I will look at these technologies with respect to the IEA report and feasibility in New York to determine if the 2040 de-carbonized electric system goal is realistic.

There are two technologies listed that are mature and have long histories of development: large-scale hydro resources and nuclear power.  However, New York needs additional resources to meet this demand challenge and I believe it is unlikely that either technology can be counted on in New York.  Although nuclear should be considered the fact that the completed nuclear power plant at Shoreham was never operated, the closing of one operational unit at Indian Point in 2020, and the planned closing of the last operational unit at Indian Point in 2021 suggests that new nuclear in New York is extremely unlikely.  I am comfortable saying that there are no significant sources of undeveloped hydro available much less permittable in New York.  There is a potential for Canadian hydro-power that will likely be considered.

The remaining three technologies are still in the “clean energy innovation pipeline” described in the IEA report.  IEA explains:

“Innovation is not the same as invention. After a new idea makes its way from the drawing board to the laboratory and out into the world, there are four key stages in the clean energy innovation pipeline. But this pathway to maturity can be long, and success is not guaranteed:

Prototype: A concept is developed into a design, and then into a prototype for a new device (e.g. a furnace that produces steel with pure hydrogen instead of coal).

Demonstration: The first examples of a new technology are introduced at the size of a full-scale commercial unit (e.g. a system that captures CO2 emissions from cement plants).

Early adoption: At this stage, there is still a cost and performance gap with established technologies, which policy attention must address (e.g. electric and hydrogen-powered cars).

Mature: As deployment progresses, the product moves into the mainstream as a common choice for new purchases (e.g. hydropower turbines).”

The EIA report notes that de-carbonization comes from four main technology approaches. These are the electrification of end-use sectors such as heating and transport; the application of carbon capture, utilization and storage; the use of low-carbon hydrogen and hydrogen-derived fuels; and the use of bioenergy. EIA explains that each of these areas faces challenges in making all parts of the technological application process, what they call the value chain, commercially viable in the sectors where reducing emissions is hardest.  The IEA report uses the technology readiness level (TRL) scale (complete description in Box 3.2 on page 67) to assess where a technology is on its journey from initial idea to market use.  Their evaluation of the TRL for different de-carbonization technologies is summarized in three figures: Figure 3.2 TRL of technologies along the low-carbon electricity value chain, Figure 3.3 TRL of technologies along the CO2 value chain, and Figure 3.4 TRL of technologies along the low-carbon hydrogen value chain.

Figure 3.2 notes that hydropower and nuclear are mature technologies.  While it is straying from my intent to discuss only those technologies proposed for the winter peak, it is interesting that solar PV, solar thermal, wind, and hydrogen from water electrolysis are all listed as an early adoption TRL. 

E3 claims that Carbon Capture Storage (CCS) can be used to address the winter peak.  The EIA report notes that capture, transport and utilization or storage of CO2 emissions as a successful decarbonization strategy hinges on the commercial availability of technologies at each stage of the process as well as on the development and expansion of CO2 transport and storage networks at a sizeable scale (Figure 3.3). In this instance I assume that E3 is referring to CCS combined with natural gas combustion.  According to the EIA report natural gas electricity production coupled with chemical absorption has a demonstration TRL.  The feasibility issue in New York may ultimately be storage because there is no oil production to enhance.  Storage in saline formations has an early adoption TRL but New York refused to allow propane storage because of its impact on community character so I would imagine this could not be permitted either.

E3 claims that “synthetic fuels such as hydrogen” can be used to address the winter peak. I am going to only consider hydrogen synthetic fuel production and that is covered in Figure 3.4.  The EIA report notes:

“The value chain for low-carbon hydrogen is not completely developed at commercial scale today. It comprises many technologies that are necessary to produce, transport, store and consume low-carbon hydrogen, each of them at a different stage of maturity and facing specific technical challenges (Figure 3.4)”. 

The pathway report only mentions the use of hydrogen but not how it would be used for the winter peak.  I assume that E3 proposes to use hydrogen production from electrolysis and that has an early adoption TRL.  In order to have it available for use during the winter peaks it will need to be shipped and stored.  The hydrogen infrastructure for pipelines and tanks are both rated as mature technologies.  If the hydrogen is supposed to be used for heating hydrogen boilers and fuel cells have an early adoption TRL but hydrogen-driven fuel cells only have a large prototype TRL.  If the hydrogen is supposed to be used to generate electricity then high-temperature fuel cells have an early adoption TRL and hydrogen-fired gas turbines have a large prototype TRL.

Updated July 6, 2020: E3 also proposes to use renewable natural gas from anerobic digesters to address the winter peak problem.  I could not find a category in these three figures that I think fits this technology in the EIA report.  The poster version of the technology guide rates biogas from a non-algae feedstock as “Commercial Operation In Relevant Environment – Solution is commercially available, needs evolutionary improvement to stay competitive”. There are questions about the collection and storage infrastructure needed to transport and store it for the winter peak demand as well as how much gas is available relative to the need for the winter peak.  


I believe that this report underscores my belief that the statement “Deep decarbonization in New York is feasible using existing technologies” mis-characterizes the actual situation.  As EIA points out feasibility depends upon making all parts of the technological application process, what they call the value chain, commercially viable.  The fact is that for the technologies proposed to address the winter peak problem, one or more aspects of commercial viability, availability limitations, or public perception make the E3 recommendations risky bets for future reliability and affordability.

I suggest that it would be better for the State to take a measured approach rather than the all-in approach currently envisioned.  The fact is that we don’t know what will work best for New York so it would be better to have a plan that could be adjusted as necessary.  The IEA proposes five innovation principles that I think would be appropriate for New York to incorporate in their Climate Act implementation process. 

For governments aiming to achieve net-zero emissions goals while maintaining energy security, these principles primarily address national policy challenges in the context of global needs, but are relevant to all policy makers and strategists concerned with energy technologies and transitions:

Prioritise, track and adjust. Review the processes for selecting technology portfolios for public support to ensure that they are rigorous, collective, flexible and aligned with local advantages.

Raise public R&D and market-led private innovation. Use a range of tools – from public research and development to market incentives – to expand funding according to the different technologies.

Address all links in the value chain. Look at the bigger picture to ensure that all components of key value chains are advancing evenly towards the next market application and exploiting spillovers.

Build enabling infrastructure. Mobilise private finance to help bridge the “valley of death” by sharing the investment risks of network enhancements and commercial-scale demonstrators.

Work globally for regional success. Co-operate to share best practices, experiences and resources to tackle urgent and global technology challenges, including via existing multilateral platforms.

Author: rogercaiazza

I am a meteorologist (BS and MS degrees), was certified as a consulting meteorologist and have worked in the air quality industry for over 40 years. I author two blogs. Environmental staff in any industry have to be pragmatic balancing risks and benefits and (https://pragmaticenvironmentalistofnewyork.blog/) reflects that outlook. The second blog addresses the New York State Reforming the Energy Vision initiative (https://reformingtheenergyvisioninconvenienttruths.wordpress.com). Any of my comments on the web or posts on my blogs are my opinion only. In no way do they reflect the position of any of my past employers or any company I was associated with.

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