Power Generation Advisory Panel Enabling Strategies Submitted to Climate Action Council

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.  According to a New York State Department of Environmental Conservation (DEC) bulletin dated May 10, 2021, the Advisory Panels to the Climate Action Council have all submitted recommendations for consideration in the Scoping Plan to achieve greenhouse gas (GHG) emissions reductions economy-wide.   My posts describing and commenting on the strategies are all available here. This post addresses the Power Generation Advisory Panel enabling strategy recommendations, including my impressions of the panel presentation itself.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   I briefly summarized the schedule and implementation: CLCPA Summary Implementation Requirements.  I have described the law in general, evaluated its feasibility, estimated costs, described supporting regulationssummarized some of the meetings and complained that its advocates constantly confuse weather and climate in other articles.  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.

Power Generation Emissions

Although the presentations all follow the same format the details differ.  One of the more important components of the presentations is the emissions estimates and they all include a graphic showing historical emissions in 1990, “preliminary draft” emissions for 2018, and their projections for 2030 and 2050.  A constant theme with this panel compared to others is a lack of critical information for stakeholders trying to understand their recommendations.  The ultimate reason for the recommendations is for emission reductions and this presentation does not provide all the numbers whereas most of the presentations included the values for each year.

The 1990 emissions were defined in the Department of Environmental Conservation’s Part 496 regulations but the sectors used in that regulation are not comparable to this advisory panel’s sector.  In the following graph I estimate that the 1990 emissions are 100 million metric tons (MMt) of carbon dioxide equivalent[1] (CO2e) and 2018 preliminary draft emissions are 60 MMt. 

[1] The amount of carbon dioxide by mass that would produce the same global warming impact as the given mass of another greenhouse gas over a specific time frame, as determined by the IPCC, and as provided in Section 496.5 of this Part.

There are two emission reduction targets in the CLCPA: 40% reduction in GHG emissions by 2030 and 85% reduction in GHG emissions by 2050.   The slide provides the percentage reductions so that the emissions can be estimated.  The projected total reductions emission reduction goals for this advisory panel are a 71% reduction from 1990 by 2030 and a reduction of 95% by 2050.  However, the power generation sector has its own goals: 70% renewable energy by 2030 and 100% carbon-free electricity by 2040.  No documentation is provided to substantiate the claim that 70% renewable energy is equivalent a 50% reduction from the 2018 levels.

The power generation sector was the third largest source of greenhouse gas (GHG) emissions in 2018.  Direct combustion emissions accounted for 57% of the total, imported fossil fuel 28%, oil and gas methane leakage 15%.  The inclusion of emissions by imported fossil fuels and leakage is mandated by law, ECL § 75-0101(13). These two categories represent an estimate of what may be referred to as the lifecycle, fuel cycle, or out-of-state upstream emissions associated with in-state energy demand and consumption.  However, these sectors are not included in internationally accepted emission inventory procedures.  I am working on a post that addresses this issue specifically.

 Power Generation Strategies

According to the meeting presentation, the advisory panel proposed fourteen enabling strategies:

1             Growth of Large-Scale Renewable Energy Generation

2             Clean Energy Siting & Community Acceptance

3             Distributed Generation / Distributed Energy Resources

4             Existing Storage Technology

5             Demand Side

6             Reliability for the future grid

7             Access and Affordability for All

8             Workforce Development

9             Market Solutions

10           Technology Solutions

11           Long Duration Storage Technology

12           Energy Delivery & Hosting Capacity

13           Gas Infrastructure, Transmission & Methane Leakage

14           Retirement of Fossil Fuel-Fired Facilities

The recommendations are available in a slide presentation.  I am not going to critique each of these strategies individually because it would take far too long.  Instead, I will comment on a few things with an emphasis on inconsistencies and implementation issues.  Because this panel is most closely related to my background and interest, I posted earlier on the draft recommendations.  I will also compare the proposed strategies to the draft strategies.

In September 2020 I also posted on the membership of this panel.  That post describes how this process was supposed to work.  I also described the background of the panel members.  I noted the members were mostly aligned with the ideological agenda of the Cuomo Administration rather than maintaining an affordable and reliable power generation system.  Sadly, the events of the last six months or so exceeded my expectations.  In order to make power generation recommendations it is necessary to understand how the power system works and how planning affects reliability and affordability.  Many of the members did not want to understand and did not try to understand the technological challenges.  Unfortunately, they were the loudest voices and their naïve insistence on speculative technologies has resulted in some risky enabling initiatives.


One of the good things that this presentation did include were the category definitions.  Each mitigation strategy describes the potential effect of the strategy on GHG reductions by 2030, cost and funding expectations, and ease of implementation in three categories: low, medium and high.  The following tables define what they mean by low, medium and high.  This panel and the Energy Efficiency & Housing panel were the only ones to include these definitions and I note that there are subtle differences between them.  For example, the Power Generation panel defines the low mitigation strategy cost as <$250M total resource cost and most resources required for successful implementation are already on hand.  The other panel uses the same definitions but expresses the value as “equivalent annualized cost”.

I appreciate the inclusion of these definitions.  However, I don’t think some of the category definitions for the enabling initiatives are correct.  In particular, Initiative #1, Growth of Large-Scale Renewable Energy Generation states that the cost and funding considerations are $, <$250 million total resource cost for NYSERDA’s existing Tier 1, Tier 4, and offshore wind programs.  The only way those estimates can be correct is if they are referring only to the process for growing large-scale renewable generation.

The New York State Energy Research & Development Authority (NYSERDA) offshore wind website notes that the State’s five currently planned offshore wind projects total 4,300 MW.   The US Energy Information Administration (EIA) regularly assesses the levelized costs of all power sources, and only a year ago calculated that the cost of offshore wind was $115.04/MWh.  EIA claims a capacity factor of 45% which means that the 4,300 MW will generate 16,950,600 MWh.  Using the EIA levelized cost of electricity, see below, with that amount of generation yields $1.9 billion for the 4,300 MW of offshore wind.  Something else to keep in mind is that this projection does not include costs on the wholesale market, capacity market, or impacts on balancing and ancillary service markets which all add to the cost.  The biggest concern is providing power when the wind is not blowing.  It is hard to imagine how the authors of this slide managed to estimate that these costs would be less than $250 million unless they were only talking the process.  Then the question becomes where the heck do these costs show up in the recommendations.


In general, the greatest threat to grid reliability is the transition away from fossil-fired power plants that provide dispatchable electricity whenever needed to intermittent and diffuse generation from wind and solar.  Donn Dears book “The Looming Energy Crisis” provides a detailed description of potential problems associated with this transition.  In this post I am only going to address two CLCPA aspects.

The final recommendations to the Climate Action Council at least emphasized the need to maintain reliability.  Incredibly, the first presentation from the Climate Action Council on the advisory panels did not mention reliability.  There are extensive electric system reliability requirements in place and despite numerous requests, no presentation on New York’s requirements was provided to this panel. 

Moreover, enabling initiative #6, reliability for the future grid, misses the point.  As shown in the following description the cost and ease of implementation refer to the process for maintaining reliability, not the difficulty of making the changes needed to make the system reliable.  For example, in August 2019 there was a blackout in England.  Initially triggered by a lightning strike followed by “Two almost simultaneous unexpected power losses” from an offshore wind farm and a gas-fired power plant resulted in a “cumulative level of power loss greater than the level required to be secured by the Security Standards” and the blackout ensued.  My point is that as the system transitions to renewables I expect this kind of trial and error de-bugging of the system reliant on intermittent renewable energy.  For example, the North Park Solar proposal calls for a facility with up to 450 MW of solar panels covering 2500 acres.  What happens on a partly cloudy day when the incident solar radiation varies wildly?  Could that trigger an unexpected power loss? 

A reliable electric power system is very complex and must operate within narrow parameters while balancing loads and resources and supporting synchronism. New York’s conventional rotating machinery such as oil, nuclear, and gas plants as well as hydro generation provide a lot of synchronous support to the system. This includes reactive power (vars), inertia, regulation of the system frequency and the capability to ramping up and down as the load varies. Wind and solar resources are asynchronous and cannot provide these necessary grid ancillary support services.  Earlier this year I wrote that no one seemed to want to take the responsibility to figure out was is needed to provide that support. 

Enabling initiative #9, Market solutions, is the only place in the recommendations where ancillary services is mentioned.  Similar to the problem for the reliability initiative, this recommendation discusses the market mechanisms rather than the problem itself.  The responsibility for the initiative is on the New York Independent System Operator (NYISO).  The barriers to success note that this “Will require several forward-looking market designs and the implementation of each design must be structured in a way that sends the correct price signal at the appropriate time”.  This panel unloads all the responsibilities onto the NYISO. Not only do they have to anticipate all the potential issues in an unprecedented system reliant on asynchronous generation but also have to create a market mechanism to get market participants to invest in that technology.  This is another trial-and-error exercise where the rate-payers of the state are lab rats.


I have always maintained that the fundamental flaw of the CLCPA is that it assumed it was only a matter of political will to completely transform the existing electrical system to one dependent upon renewable energy.  Clearly, it would be appropriate to define affordability and reliability metrics then do a comprehensive analysis to determine if the transition would threaten those metrics.  The following tables list the ease of implementation descriptions for all 14 enabling strategies.

There are three easy to implement strategies: Reliability for the future grid, Workforce Development, and Gas Infrastructure, Transmission & Methane Leakage. These strategies are supposed to have been implemented many times and/or can build off an existing NYS program, rely on Proven and widely available technology, and the key stakeholders are strong supporters, there were no strong opponents.  However, recall that the reliability strategy was more about the mechanics of assessing reliability than actually addressing the problem.  It is ludicrous for this panel to claim reliability for a wind and solar dependent electric generation system will be “easy”.

Most of the strategies had a medium ease of implementation defined as: strategy is new to New York State but has been successfully implemented in other comparable states/countries, proven technology with known GHG impact, but still small-scale, and key stakeholders are neutral, or balanced mix of supporters and opponents.  I think the biases of the panel members and their lack of technical backgrounds impact these ease of implementation estimates.  Consider the medium label for existing storage technology.  Despite all the fawning reports over Tesla’s utility-scale batteries, the press and this panel has not picked up on how they are being used.  The Australian Hornsdale Power Reserve battery system is making money for the operators and saving consumers money by providing frequency control ancillary support services.  It is not being used to provide meaningful energy storage for the system.  As a result I argue that claiming that utility-scale energy storage has been successfully implemented is dubious at best.

There are three initiatives that even this panel had to conclude would be hard to implement: long duration storage technology, energy delivery & hosting capacity, and retirement of fossil fuel-fired facilities.  I believe that both existing and long duration energy storage technologies should be difficult.  A recent article by Kevin Kilty “Why is Energy so Difficult to Store? Why is Stored Energy so Difficult to Use?” described the generic problems with energy storage systems. He concluded that “It took money spent over a century to learn the systems engineering currently built into the grid. It will take a lot of money to duplicate all this for a completely re-imagined grid in a decade.”  Long-duration storage is necessary so depending upon a technology that does not even exist in a pilot project is an incredible risk.

Energy delivery & hosting capacity refers to “planning and implementation processes to facilitate necessary energy delivery options for the renewable energy buildout”.  Like all the other strategies by this panel it is presumed that there are no technical challenges to accomplish this.  In fact, this reads like a wish list for the renewable energy developers on the panel. 

Retirement of fossil fuel-fired facilities engendered a non-consensus recommendation with majority support: “temporary moratorium on new or repowered fossil fuel-fired facilities until the full recommendation is adopted”.  The strategy description is to develop a plan and implement regulations to phase out fossil fuel-fired baseload and peaking generation resources as quickly as practicable while retaining system reliability by prioritizing efforts to lower emissions of co-pollutants in disadvantaged and environmental justice communities.   The current cause célèbre amongst environmental justice activists are power plants in disadvantaged communities because they just have to be causing health problems due to ozone and inhalable particulates.  The problem is that those are both secondary pollutants and form long after the precursor pollutants are emitted so any health effects are not due to neighborhood power plants.  The mitigating solution to this non-problem: “The recommendations from the Power Generation Advisory Panel focus on enabling strategies to assist in the transition away from fossil fuels. These include strategies to more rapidly deploy renewable technologies, including flexible resources, addressing barriers to renewables deployment, transmission and distribution upgrades, developing and deploying technology innovations, encouraging effective market structures, and ensuring a just and equitable transition.”  As near as I can interpret this, there is absolutely no inkling that there might be technological and physical barriers that could preclude any of these enabling strategies.


The panel covers affordability with its own enabling initiative.  I find it rich that the panel presumes that Federal Relief Funds should be used first.  The problem is that similar efforts elsewhere have markedly increased costs.  According to Germany’s Enegiewende program, the share of renewables in electricity generation should reach 45 percent by 2030 and 100% by half century.  The costs have sky rocketed and now German electricity prices are three times higher than France.  The Global Warming Policy Foundation has analyzed the cost of Great Britain’s net-zero programs concluding that astronomical cost burden risks are becoming a “toxic issue” for the government. If CLCPA proponents could point to a single jurisdiction with high renewable energy use that did not experience a marked increase in costs, then I would not believe this is an insurmountable problem.


Two things about this advisory panel.  It is arguably the most import panel because achieving CLCPA will only be possible if zero-emission electric power is available.  It was inarguably the worst run panel by far.  John Rhodes “leadership“ was abysmal and by the time he retired the damage had been done.  A leader would have steered discussions to achievable solutions that could maintain current levels of reliability and affordability.  What happened is that the loudest voices in the room drove the recommendations and discussions. As David Zaruk, who writes at the Risk Monger blog, explains those voices are: “millennial militants preaching purpose from the policy pulpit, listening to a closed group of activists and virtue signaling sustainability ideologues in narrowly restricted consultation channels”.  Rather than trying to understand the technological challenges these idealogues made recommendations for processes that would enable what they believe only requires political will.  “It is hard to imagine a more stupid or more dangerous way of making decisions than by putting those decisions in the hands of people who pay no price for being wrong.”– Thomas Sowell

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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