Climate Leadership and Community Protection Act Ultimate Problem

In the summer of 2019 Governor Cuomo and the New York State Legislature passed the Climate Leadership and Community Protection Act (CLCPA) which was described as the most ambitious and comprehensive climate and clean energy legislation in the country when Cuomo signed the legislation.  This post documents the resource adequacy problem that I believe should be a primary consideration for the 2040 electric system which is supposed to be fossil-free.

I am a retired electric utility meteorologist with nearly 40-years-experience analyzing the effects of meteorology on electric operations. I believe that gives me a relatively unique background to consider the potential quantitative effects of energy policies based on doing something about climate change. From this context I have published a series of posts on the feasibility, implications and consequences of the CLCPA.   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. 

My biggest concern with the CLCPA is that I am convinced that the general public has no idea what is going on with these energy policies and the possible ramifications.  Moreover, I do not believe that the CLCPA implementation process includes sufficient provisions for the general public to find out what this law will mean to them until it is too late to prevent the inevitable higher costs of energy.  I am also very concerned that the people who are responsible for implementing the CLCPA have insufficient background to understand the implications of the resource adequacy problem described here.

The Adequacy Problem

I believe that in order for the CLCPA to be successful it must not only provide the environmental benefits planned but must also not mean a reduction of electric system reliability particularly because when heating and transportation are electrified reliability will be a life and death requirement.  There are two aspects of the problem that must be addressed: future load and renewable energy availability during peak load periods. 

It is generally acknowledged that the future load peak will occur in the winter.  Because both heating and transportation must be electrified to meet the reduction targets in those sectors there will be a load peak shift from the summer to winter primarily because it takes more energy to heat than cool.  When the needs of the transportation sector are included it seems unlikely that energy efficiency will be able to prevent an increase from current levels. 

The CLCPA plans to replace fossil generation with wind and solar energy.  At Albany New York’s latitude day length is over six hours less at the winter solstice than the summer solstice and the sun angle is lower so the strength of the sunlight is less in winter too.  Moreover, clouds are lower and more frequent.  Include the fact that solar panels could be covered with snow and all that means that in the worst-case solar energy’s contribution to the power needed could essentially be zero.  Wind can also become calm during the winter albeit there is not the same seasonal difference as with solar.

Therefore, in order to maintain reliability, we need resources that can replace the loss of intermittent wind and solar energy while at the same time it is likely that loads will increase.  There has to be an alternative resource that can be dispatched to provide power to meet the load required to keep the lights on.  Every member of the Climate Action Council, advisory panels and working groups should understand that this problem exists and the ramifications of this issue on the energy strategies they propose.  Recent presentations raised this issue but I am not sure those members realized the gravity of their remarks.


In their presentation to the Power Generation Advisory Panel on September 16, 2020 E3 included a slide titled Electricity Supply – Firm Capacity.  Consistent with the above the slide states: “The need for dispatchable resources is most pronounced during winter periods of high demand for electrified heating and transportation and lower wind and solar output.  The slide goes on to say: “As the share of intermittent resources like wind and solar grows substantially, some studies suggest that complementing with firm, zero emission resources, such as bioenergy, synthesized fuels such as hydrogen, hydropower, carbon capture and sequestration, and nuclear generation could provide a

number of benefits.  Of particular interest is the graph of electric load and renewable generation because it shows that this problem may extend over multiple days.

Analysis Group

On September 10, 2020 the Analysis Group presented a discussion of draft recent observations as part of the New York Independent System Operator (NYISO) Climate Change Phase II Study.  That discussion included a slide titled “Attributes of Generic Resource Required for Grid Reliability”.  In their analysis they included a generic resource they called the Dispatchable & Emissions-Free Resource, or “DE Resource”.  The DE Resources are “included to maintain reliability during the highest load hours of each modeling period” and they “provide the majority of energy on the peak winter hour during the CLCPA load scenario”.  They state “The DE Resources are included to maintain reliability during the highest load hours of each modeling period. DE Resources provide the majority of energy on the peak winter hour during the CLCPA load scenario.”

Their projected nameplate capacity by resource type graphic (below) is interesting.  The DE resources category makes up 19% (32,137 MW) of the total capacity for their projected CLCPA load scenario.  The Analysis Group includes the “DE Resource” their model to achieve reliable solutions” but includes the following caveats: “AG does not presume to know what resource or what fuel will fill this gap twenty years hence” and “the purpose of modeling it is to understand the attributes of the resource need”.


As a party to the Department of Public Services (DPS) resource adequacy matters proceeding, docket Case 19-E-0530, I have submitted comments (described here and here) based on my background as a meteorologist who has lived in and studied the lake-effect weather region of Central New York.  Both E3 and the Analysis Group have done studies of the weather conditions that affect solar and wind resource availability in New York.  However, to my knowledge (neither consultant has ever responded to my question on this topic), they have not used solar irradiance data from the NYS Mesonet. In my opinion, using airport data or models for cloud cover are inadequate and the Mesonet data set is the only way to have information that adequately represents the local variations in cloud cover caused by the Great Lakes.  in order to adequately determine the solar resources available when assessing future reliability needs, I strongly recommend that the NYS Mesonet data set be used.

E3 and the Analysis Group both have a future resource category, E3 (firm capacity) and Analysis Group (DE Resources), that needs to be dispatchable and cannot have GHG emissions.  E3 gives some examples but the Analysis Group avoids being specific.  The  International Energy Agency (IEA) recently published “Special Report on Clean Energy Innovation” that classified the technology readiness level of the technologies that could possibly be both dispatchable without GHG emissions.  The bottom line is that there is nothing close to being ready for adoption that fulfills those requirements. 


If “then a miracle occurs” is replaced with “19% DE resources” then implementation of the CLCPA is well characterized by the following cartoon:

The problem is that we need resources that can replace the loss of intermittent wind and solar energy when it is needed the most during the winter when heating is necessary.  E3 and the Analysis Group both have a future resource category, E3 (firm capacity) and Analysis Group (DE Resources), that fulfills the need to be dispatchable without GHG emissions during those periods.  Importantly, the Analysis Group DE resources category makes up 19% (32,137 MW) of their projected total capacity so this is not a small number.

The task for those charged with implementing the goals of the CLCPA is to propose resources that will meet this need.  E3 gives some examples but the Analysis Group avoids being specific.  The  International Energy Agency (IEA) recently published “Special Report on Clean Energy Innovation” that classified the technology readiness level of technologies that could be dispatchable without GHG emissions.  In an earlier post I found that some of these technologies were not ready for wide-spread implementation.  I think it is incumbent upon the advisory groups to only make recommendations for technologies with technology readiness levels that indicate proven success.  Given the immaturity of the examples suggested by E3 it would be appropriate for the New York State Energy Research & Development Authority to be charged with research and development to increase the availability of options.   

Most troubling to me is that there are indications that some advisory group members are trying to limit options for some kinds of firm capacity/DE resources technology.  In particular, there have been complaints about excluding renewable natural gas (for example from anerobic digesters) because it is not explicitly listed as a renewable energy option.   Given the critical need for this resource and the limited number of proven options, I think that is risky.

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 ( reflects that outlook. The second blog addresses the New York State Reforming the Energy Vision initiative ( 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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