Climate Leadership & Community Protection Act Dispatchable Emission Free Resources Feasibility

Updated October 23 2020: Added a reference to a new Carbon Capture and Storage report.

On July 18, 2019 New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act (CLCPA), which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency.  I have summarized the schedule, implementation components, and provide links to the legislation itself at CLCPA Summary Implementation Requirements.  This post summarizes the status of possible technologies that could be used to meet the need for firm dispatch capacity or dispatchable emissions-free capacity.

I am following the implementation of the Climate Act closely because its implementation affects my future as a New Yorker.  New York State is trying to choose between many expensive policy options to meet the CLCPA targets while at the same time attempting to understand which one (or what mix) will be the least expensive and have the fewest negative impacts on the existing system. If they make a good pick then state ratepayers spend the least amount of a lot of money, but if they get it wrong then we will be left with lots of negative outcomes and even higher costs for a long time.  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.


This post addresses the resources necessary to meet the CLCPA target of an emissions-free electric generating sector by 2040.  In order to assess the potential impacts on power system reliability in 2040 when meeting that target, NYISO contracted with ITRON and the Analysis Group to develop estimates of the necessary resources.  On October 8, 2020 Kevin DePugh, Senior Manager for NYISO Reliability Planning, made a presentation to the Executive Committee of the New York State Reliability Council that summarized their work and provides an estimate of the  Generation Capacity resource mix.  I think that the resources projected are mind-boggling:  35,200 MW of onshore wind, 21,063 MW of offshore wind, 10,878 MW of behind-the-meter solar, 29,262 MW of grid connected solar will be needed, energy storage of 15,600 MW, and winter price responsive demand of 3,412 MW.  Even with those projected capacities there is a category called Dispatchable Emissions-Free (DE) resources with a projected capacity need of 32,136.6 MW.

Ultimately, the problem is that no amount of additional renewable energy will provide electricity when the sun isn’t shining and the wind isn’t blowing.  In order to provide electrical energy during those periods the DE resources category was included.  DePugh described the following characteristics of this resource:

      • Large quantities of DE Resource generation are needed in a small number of hours
      • Substantial quantity of DE Resource capacity is needed, but the energy need is minimal
      • DE Resource must be able to come on line quickly, and be flexible enough to meet rapid, steep ramping need
      • On an average day, storage can meet evening peaks, but the DE Resource must generate if storage is depleted and renewable generation is low
      • In the Winter CLCPA scenario, the DE Resource output across the state must increase from 362 MW (1.1% of DE Resource nameplate capacity) to27,434 MW (85.4% of name plate capacity) in six hours of the most stressed day

The Analysis Group (AG) and NYISO have not offered any examples of a resource that meets these characteristics.  In fact, AG goes out of its way to not offer examples: “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”.  In their presentation to the Power Generation Advisory Panel on September 16, 2020 Energy and Environmental Economics (E3) included a slide titled Electricity Supply – Firm Capacity that said: “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”.    I believe the E3 firm, zero emission resource is the same as the NYISO DE resource so these are potential sources of dispatchable, emissions free energy.

This post will address the complementing firm, zero emission resources examples mentioned by E3.

CLCPA Definition of Renewables

There are two relevant specifications in the language of the CLCPA.  The first defines “renewable energy systems” as “systems that generate electricity or thermal energy through use of the following technologies: solar thermal, photovoltaics, on land and offshore wind, hydroelectric, geothermal electric, geothermal ground source heat, tidal energy, wave energy, ocean thermal, and fuel cells which do not utilize a fossil fuel resource in the process of generating electricity.”  The language specifying the 2030 target states that a minimum of seventy percent of the state wide electric generation “shall be generated by renewable energy systems”.

The renewable energy systems definition is a continuing topic at the Climate Action Council meetings.  There are vocal members who insist on a strict interpretation of allowable electric energy resources.  However, the CLCPA also notes that “the commission shall consider and where applicable formulate the program to address impacts of the program on safe and adequate electric service in the state under reasonably foreseeable conditions. The commission may, in designing the program, modify the obligations of jurisdictional load serving entities and/or the targets upon consideration of the factors described in this subdivision.”  It will be interesting to see what happens if the strict interpretation of appropriate technology prevents safe and adequate electric service.

Hydropower and Nuclear Generation

Both hydropower and nuclear generation would be very useful as dispatchable emissions-free firm capacity.  However potential development of either resource in New York is limited.  New York already has extensive hydropower resources and that means there are only limited opportunities for any additional development.  I believe that it I unlikely that New York would consider building new nuclear generation while at the same time the state is shutting down viable existing nuclear generation.

Carbon Capture & Sequestration

There are several general issues with carbon capture & sequestration (CCS) technology for DE resources.  Firstly, the final clause in the renewable energy definition “which do not utilize a fossil fuel resource in the process of generating electricity” could apply to all the technologies rather than just the immediately adjacent technology “fuel cells”.  If that is the correct interpretation then CCS is off the table.

The second general issue is the engineering challenges of the technology itself.  While there already is technology to capture CO2 from gases it is another matter to capture CO2 in the hot and corrosive flue gas of a power plant.  Assuming that you can get over those hurdles then you need to store the collected CO2.  If the facility is near old oil and gas fields the CO2 can be used to enhance the recovery of the oil and gas.  To my knowledge this option is not available for New York so an alternative underground rock storage structure will have to be developed.

The final general issue is implementation in New York.  I will provide some anecdotal evidence for this issue.  In a vivid example of how far things have changed in New York, consider that Governor George Pataki’s Office of Regulatory Reform launched the Advanced Clean Coal Initiative in 2006, which sought to encourage the development of one or more clean coal facilities in New York to reduce New York’s dependence on petroleum.  As part of the initiative, the New York Power Authority (NYPA) issued a request for proposal for up to 600 MW electric generating capacity from a coal plant that would significantly reduce emissions and be built with the ability to capture and sequester carbon dioxide emissions.  Four companies submitted bids and my former employer NRG Energy was given a conditional award.  One of the incentives of the initiative was a purchase power agreement with NYPA and when the state figured out the costs necessary to support the project the whole thing was cancelled as too expensive.  In 2020 with the benefit of hindsight we see that was the right decision. As a result of the technology that New York banned (high volume fracking), the low price of natural gas made all of New York’s coal-fired power plants uneconomic.  The additional cost of the CCS would have made this project even more uneconomic.

Although I was not directly involved in my NRG’s carbon capture & sequestration (CCS) proposal, I learned that there were implementation problems with any carbon capture and sequestration project from colleagues who were involved.  New York regulators have a recent history opposing pipelines because of the potential for leaks and contamination.  I believe that the pipeline transport and pumping process would spark the same irrational reaction as fracking produced.  The NRG project had difficulty finding locations where it could be sequestrated in western New York.  Another problem the project faced was that there was no precedence for liability protection if the sequestered CO2 leaked.  Who would get sued, the state, operator, or land-owner?

In conclusion, the fact that despite a lot of effort there are only a few CCS projects suggests that the technology is still an issue.  Coupled with New York limitations this may not be a viable DE resources alternative.

Update (10/23/2020): On October 22, 2020 the Energy Futures Initiative (EFI) and Stanford University released “An Action Plan for Carbon Capture and Storage in California: Opportunities, Challenges, and Solutions,” a report providing policymakers with options for near-term actions to deploy carbon capture and storage (CCS) to meet the state’s climate goals.  According to the press release there are some key takeaways from the report:

      • California’s economy would see rapid near-term emissions reduction benefits from CCS;
      • The state has a strong foundation for supporting CCS projects, and the study has identified 76 facilities suitable for carbon capture;
      • California’s geology makes it well suited for safe, permanent CO2 storage; and
      • California could prioritize CCS projects that have demonstrable local air quality benefits and local job opportunities in line with the state’s climate and equity goals

A few comments. I have not studied this report but it may disprove my assertion that the technology is still an issue.  However, in order to use this technology for the CLCPA, New York would have to do a similar study to identify suitable sites for carbon capture and areas with suitable geology for storage.  However, the CLCPA electric power target in 2040 mandates zero emissions and this technology does not eliminate GHG emissions only reduces them significantly.  Unfortunately, this is still not a viable technology.


In my summary description of the October 8, 2020 Climate Action Council meeting I noted that there is a controversy related to the use of bioenergy and renewable natural gas (RNG).  In this instance I assume that bioenergy refers both to the use of bio-mass as a fuel and methane from biological processes the so called RNG. Similar to the CCS option the interpretation of the CLCPA language could exclude these resources as an option because they are not explicitly included.  For example, opponents of RNG claim that because it is not listed then it is not a renewable energy source.   If that is the correct interpretation then RNG and other forms of bioenergy are off the table.

Renewable natural gas is pipeline quality natural gas derived from renewable energy resources. According to a July 2019 report by the consulting firm MJ Bradley and Associates entitled “Renewable Natural Gas: Potential Supply and Benefits” the most common sources of RNG today include landfills, animal manure, and wastewater treatment plants and additional sources include food waste, agricultural waste, and woody biomass.

In the DE resources context, the advantage of RNG and other forms of bioenergy is that they can be used with existing infrastructure to generate electricity as a dispatchable resource.  Because the sources are renewable, the presumption is that this resource is carbon-neutral.  If the RNG is stored then it will be available during the periods of low wind and solar energy output.  Another advantage is that using the methane generated from the sources listed helps reduce the waste streams.

On the other hand, there are vocal members of the Climate Action Council that are adamantly opposed to its use.  The basis for this opposition is the methane obsession of Dr. Robert Howarth in which he claims that due to the higher global warming potential of methane and his estimates of fugitive emissions, no additional sources of methane should be encouraged.

As I said this is controversial.  A major issue is that if the programs that use RNG are no longer considered good state policy there are many on-going projects and programs that are no longer viable.  For the companies that have invested in the technology to use RNG expecting to profit from its value as a renewable energy source those investments will be lost.  Unless, of course, their reductions are considered “renewable” by other jurisdictions.  Perhaps the project will end up selling the credits they earned elsewhere so New York gets no benefits.


One superficially attractive approach to the need for storable energy is to use electrolysis to produce hydrogen when there is surplus wind and solar electric production.  It also appears attractive because when the hydrogen is burned it generates no pollutants, only water. On the other hand, hydrogen is an element that does not exist in nature and that is the first of many complicating issues.   While the theory is fine in practice there are many problems with using hydrogen.

One study by Bossel, Eliasson, and Taylor gives a good overview of those problems.  The study notes that, “like any other product, hydrogen must be packaged, transported, stored, and transferred to bring it from production to final use”.  They found that heating value per volume is less than a third of methane.  That means that more energy is needed to package it in more complicated tanks than what is used for oil and gas.  In order to transport hydrogen by pipeline a new system would be needed because of “diffusion losses, brittleness of materials and seals, incompatibility of pump lubrication with hydrogen and other technical issues”.  Storage is an issue which is the consequence of the low energy density of hydrogen and the weight of the pressure vessels.  Before it can be used it has to be transferred from storage and that requires energy to empty the pressurized hydrogen container for use.  Bossel, Eliasson, and Taylor conclude that:

We have to accept that hydrogen is the lightest element and its physical properties do not suit the requirements of the energy market.  The production, packaging, storage, transfer and delivery of the gas are so energy consuming that other solutions must be considered.  Mankind cannot afford to waste energy for uncertain benefits; the market economy will always seek practical solutions and, as energy becomes more expensive, select the most energy-efficient.  Judged by this criterion, the elemental “Hydrogen Economy” can never become a reality.

One other aspect of hydrogen needs to be considered.  When hydrogen is mentioned as a fuel source the first impression of many people is the picture of the Hindenburg dirigible’s hydrogen exploding.   It is an odorless, colorless gas.  Because hydrogen is an element it is difficult to store and prone to leak.  I am not confident that the public will accept widespread use of an undetectable explosive gas that is leak prone.


One of the case studies for the NYISO analysis of the resources needed to meet the 2040 emissions-free electric power generation target includes a category called Dispatchable Emissions-Free (DE) resources with a projected capacity need of 32,136.6 MW.  The E3 pathways analysis for the CLCPA Climate Action Council notes that “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”.  This analysis looked at the potential of those firm, zero emission resources to meet the 32,136.6 MW capacity projected need.

The prospects are not good to meet the 2040 target.  Despite the critical need for these resources to maintain reliability, the technological readiness issues of the options, New York siting constraints for the alternatives, and practical capability of the resources suggest that this may be an insurmountable hurdle.  Moreover, some of the more vocal Climate Action Council members have an ideological interpretation of the CLCPA law that places further constraints on potential resources.  From what I have heard at the CLCPA implementation meetings so far, I don’t think the enormity of this problem, much less the need for pragmatic interpretation of the law, is recognized.

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.

5 thoughts on “Climate Leadership & Community Protection Act Dispatchable Emission Free Resources Feasibility”

  1. Hello. Really enjoyed reading this. I have a question.

    This is all premised on the appearance of a dispatchable, clean electricity generation mechanism before 2040. If such a thing does appear, why is there a need for all the wind and solar? If it doesn’t appear, is all this wind and solar a good thing to be doing?


    1. That is a brilliant observation. The dispatchable, clean electricity generation mechanism (aka magical solution) could then run all the time and earn enough money to be viable without subsidies which surely will be required if they only operate for the short periods predicted. Thanks. I will give you credit when I work this point into a future post!


      1. I have thought about it a bit more. I suppose the magic solution could be expensive to operate so it’s use needs to be minimised.

        Also, I guess for something like hydrogen you need to generate electricity to make it and you constantly lose power as you go from your original source to hydrogen to stored hydrogen and back to electricity. I am way out of my depth here, so I am probably wrong.


  2. Hello.

    I thought this might interest you.

    It is one person’s picture of what the UK may require in terms of wind and solar to be carbon neutral. The UK has greater population density than New York State (to my surprise). It is written by a renewables optimist, but it is (I think) a serious broad brush attempt to understand the scope of (some aspects) of the problem.

    Hope you enjoy it.


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