Climate Leadership & Community Protection Act Feasibility Relative to NYSERDA Patterns and Trends

I recently published an article describing how the New York State Energy Research and Development Authority (NYSERDA) Patterns and Trends – New York State Energy Profiles: 2003-2017  (“Patterns and Trends”) comprehensive summary of energy statistics and data could be used to assess where the state stands now relative to Climate Leadership and Community Protection Act (CLCPA).  I looked at data up to 2017 to assess the status of two targets: 70 percent of electricity from renewable sources by 2030 and 100 percent carbon-free electricity by 2040. Because the data in the report is three years old, I stated that it was difficult to assess feasibility using historical energy use data.  This article addresses feasibility by projecting energy use requirements.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed are not feasible with present technology, will adversely affect affordability and reliability, that wind and solar deployment will have worse impacts on the environment than the purported effects of climate change, and, at the end of the day, meeting the targets 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.


For anyone interested in New York energy information the Patterns and Trends documents are a great resource.  One thing that I particularly like is that when you click on a table there is a link to a spreadsheet with all the data.  For space reasons the report does not list all the numbers but the underlying spreadsheet includes everything.  Unfortunately, during the Cuomo Administration, the annual updates are lagging further and further behind.  In January 2011, the report updated with data through the end of 2009 was published 13 months after the end of the year.  The latest report available, Patterns and Trends – New York State Energy Profiles: 2003-2017  (“Patterns and Trends”) publication date was March 202,1 38 months after the end of 2017.. 

In the previous article I explained that Patterns and Trends data showed that in 2017 30% of the electricity generated in the state came from fossil fuels and that nuclear provided 32%.   In 2017, hydro provided 18%, municipal solid waste, biomass and geothermal provided  2%, solar had yet to show any significant generation and wind provided 3%.  The CLCPA defines renewable energy sources as wind, solar, biomass, geothermal, hydro and nuclear so recent trends in those sources are important to detemine feasibility of the 2030 goal.

New York Historical Energy Source Calculations

Figure 1 lists the percentage trend of the sources of electric generation in New York State (NYS) from 2001 to 2022.  This section describes the methology and assumptions used to develop those data. 

In order to determine the feasibility of the 70% renewable by 2030 target these data list four source categories: fossil fuels, imports, nuclear and all the other categories lumped together as CLCPA renewables.  I broke out nuclear to show the impact of the retirement of Indian Point nuclear station.  The CLCPA renewables categories includes biomass and municipal waste generation that I think may not be acceptable as CLCPA renewable at the end of the day but for now they are included.

The data from 2001 to 2017 is directly from Patterns and Trends.  The data from 2018 to 2020 comes from a variety of sources.  The total electric load used the baseline annual energy forecast from New York Independent System Operator (NYISO) Gold Book 2021 Table I-1b: Summary of NYCA Baseline Annual Energy Forecasts – GWh.  The projected category values are set up to equal these load projections.  The fossil category data are based on heat input data from EPA Clean Air Markets Division reported emissions data.  I included a 1.05 multiplier adjustment to account for difference between historical EPA and NYISO Btu data.  The NYISO Gold Book observed data for the nuclear, wind, and other generation sources was used.  Hydro used the maximum value of the last ten years from Patterns and Trends.  Utility scale solar was assumed to increase linearly to 5 TBtu by 2020.  Imports were calculated as the sum of the maximum observed value over the last ten years from Patterns and Trends plus whatever energy was needed to balance the total electric load and sum of all other categories.  In other words, it was assumed that imports made up the differences in total component loads to total energy forecast load.

It is difficult to make supportable projections but I did want to illustrate the effect of retiring the Indian Point nuclear station so I did project energy use in the best case in 2021 and 2022.  The total electric load used the baseline annual energy forecast from New York Independent System Operator (NYISO) Gold Book 2021 Table I-1b: Summary of NYCA Baseline Annual Energy Forecasts – GWh.  For fossil use I took the 2020 data minus the annual reductions necessary to get to zero in 2040 by straight extrapolation.  Hydro used the maximum value of the last ten years from Patterns and Trends.  The nuclear electric production was set to the average of the last five years of all nuclear facilities less Indian Point.  Eliminating the load from Indian Point units 2 and 3 removes 15,774 GWh of CLCPA renewable energy from the NYS electric system.  I assumed that waste, land-fill gas and wood are assumed to stay constant at 26 Tbtu, the rounded maximum value in last ten years.  With regards to other renewables note that distributed solar is included in the NYISO total load projections.  For utility-scale solar and wind I used Energy Information Administration Table 54.  Electric Power Projections by Electricity Market Module Region for two New York State regions to estimate the total renewable capacity (GW) additions.  I assumed future utility-scale development will be 50-50 solar and wind with a combined capacity factor of 23% to estimate total energy produced in GWh.  I used Patterns and Trends data to develop a conversion factor based on recent data to estimate TBtu.  As an aside note that for some reason this conversion factor has been changing the last five years contrary to all other sectors.  Finally I believe that the EIA projections for future capacity development are wildly optimistic – 1640 MW are supposed to come on line in 2021.

Current New York Energy Sources

Figure 1 lists the percentage trend of the sources of electric generation in New York State (NYS) from 2001 to 2022.  In 2001, nuclear provided 28% of the energy and other CLCPA renewable sources another 16% for a total of 44%.  Fossil fuels provided over half the energy and imported energy made up the remaining 5%.  In 2020, nuclear provided 30%, down from the high of 32%, other CLCPA renewable sources provided 24% for a total of 54% of CLCPA renewable energy, fossil was down to 32%, and imports up to 15%.  I project that in 2022, the retirement of Indian Point will reduce nuclear down to 21% and that other CLCPA renewable sources will increase to 30% for a total of 51% of CLCPA renewable energy.  The assumption that fossil fuel use will decrease reduces its share to 29% but increases imports to 20%. 

Eight years after the projections in Figure 1, nuclear and the Climate Act renewable energy category are supposed to provide 70% of the energy to produce electricity.  Those categories only comprise 51% in 2022 in my projection.  Estimating the future growth of those categories is difficult but one key factor should be noted.  Despite the supposed urgency of reducing fossil fuel emissions, the Cuomo Administration shut down Indian Point nuclear station which generated 165 TBtu of energy or about 12% of the total energy of the state.  In order to replace that energy four times as much wind capacity as currently exists has to be developed.  Until such time as the renewable resources to replace the lost nuclear are developed, fossil fueled energy or imported energy has to pick up the necessary load.  In this projection it was assumed that imported energy picked up the load but it is likely that fossil will replace much of the load because of transmission constraints to New York City and Long Island.

There is another aspect to imported electricity that I cannot address.  The CLCPA requires that out-of-state resource renewable attributes be defined so that there is no leakage, that is to say the emissions just move out of state and are not reduced.  Unfortunately, I cannot find any information on the attributes of out of state electricity so I cannot comment on how this will affect meeting the target.

CLCPA 70 percent of electricity from renewable sources by 2030 Feasibility

Now that the status has been established we can look towards 2030.  I changed my methodology to use GWhr instead of TBu to compare different sources.  I based my projections on the feasibility of meeting the 2030 load requirements for wind and solar on the following assumptions.  I assumed that the electricity provided by imports, hydro, geothermal, biomass and municipal waste generation all equal the average of the Patterns and Trends data for 2015 to 2017.  Nuclear generation was also set at the 2015 to 2017 average less Indian Point nuclear station energy.  I calculated the annual reductions needed to meet the 2040 zero fossil fuel emissions target and used the 2030 value.  Using those assumptions that means that wind and solar generation have to meet the difference between the sum of those categories and the total load projected by NYISO or 37,256 GWhr.

There are two CLCPA targets for renewable development.  In 2025 the target is 6,000 MW of solar and by 2035 there is a target for 9,000 MW of off-shore wind.  The NYISO Gold Book projections for total load assume that all of the 2025 solar goal is behind the meter so their load forecasts incoporate the target.  For utility solar by 2030 I assumed three scenarios for solar deployment up to 6,000 MW.  For 2030 offshore wind I assumed three scenarios: all 9,000 MW in 2030, only the current 4,300 MW under development and a third scenario midway between those two.  For on-shore wind I assumed total capacity would be 1,.5, 2, and 2.5 times the current capacity.  This gives a low, medium and high range of potential wind and solar deployment.

Table 1 lists the capacity (MW), capacity factors, and projected energy (GWhr) from all the scenarios and four total scenario projections.  Scenario 1 uses the low end estimates for all sources and has a deficit of 11,736 GWhr.  Scenario 2 uses the mid-point estimates for all sources and has a 1,735 GWhr surplus.  If al the estimates are at the high end in Scenario 3 there is a surplus of 15,205 GWhr.  My personal best guess (Scenario 4) is mid point for utility solar and on-shore wind but the low estimate for off-shore wind because the entire infrastructure to develop off-shore wind has to be built first.  That scenario has a deficit of 6,500 GWhr.

I believe that a major problem with meeting the target is that permitting and construction will slow the deployment of solar and on-shore wind.  I reviewed wind and solar project applications for New York’s Article 10 permitting process to get an idea of the magnitude of development for the bracketing scenarios .  Based on the solar applications between 19,000 and 56,000 acres and between 6 and 18 million solar panels will be needed for the solar scenarios.  The wind applications suggest that between 15 and 25 projects with 60 turbines at each site and that between 900 and 1,500 3.3 MW turbines will be needed for the on-shore wind scenarios.  The off-shore wind project information is too scanty at this point to develop similar information.  This many projects with such extensive scopes inevitably fail to meet schedules.


While the results shown suggest that meeting the 2030 target can be met in two out of four scenarios there is a big issue with the approach used.  Replacing fossil and Indian Point annual energy output with intermittent wind and solar energy outut is not a one for one energy substitution.  While a wind turbine can provide a certain amount of energy during a year, it is not dispatchable.  Because the total annual load is based on the sum of varying loads over hours, days and seasons, much more intermittent wind and solar capacity is needed to replace the dispatchable capacity that produced historical energy and maintain a reliable system that provides electricity whenever and wherever it is needed.  The real test of feasibility is to determine the amount of solar and wind necessary to meet the worst case situation – a wintertime wind lull when both wind and solar generate minimal levels of power.  Therefore do not believe any claims for feasibility that are based only on annual energy output.

I want to re-iterate the point that these data do illustrate one hypocritical aspect of the CLCPA and New York energy policy.  The CLCPA includes nuclear generation in the definition of acceptable “renewable” sources of electricity.  The CLCPA is supposed to protect New Yorkers from the existential threat of climate change but New York energy policy retired nearly 2,000 MW of acceptable renewable power when Indian Point was retired.  If the threat of climate change is so pressing how can that be justified?  The replacement of the annual power produced by Indian Point will consume all of the off-shore wind currently under development so at a minimum it makes meeting the CLCPA targets that much more difficult.

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.

9 thoughts on “Climate Leadership & Community Protection Act Feasibility Relative to NYSERDA Patterns and Trends”

  1. Please provide a cross reference to the fact that CLCPA includes nuclear power as acceptable form of renewable energy.


    1. When I started researching this request, I was confident that the legislation actually listed nuclear as a renewable energy system. Turns out I was wrong.

      On page 12 of the legislation draft renewable energy systems are defined (see below) and nuclear is not listed as a system. However, in the very next paragraph the 70% of electricity must be met by renewable energy systems by 2030 target is listed. The projections in this analysis for 2030 were fossil 18%; imports 17%; hydro 19%; other 2%; combined wind and solar 26%, and nuclear 19%. Even with nuclear counting as a renewable resource I believe that getting wind up to 26% is unlikely. I am confident that the 2030 target cannot be met unless nuclear can be used to “meet the electrical energy requirements of all end-use customers in New York state in two thousand thirty” even though it is not explicitly defined as a “renewable energy system”.

      I will do some more research and follow up with a post addressing this issue.

      § 4. The public service law is amended by adding a new section 66-p to read as follows:
      § 66-p. Establishment of a renewable energy program.
      1. As used in this section:

      (a) “jurisdictional load serving entity” means any entity subject to the jurisdiction of the commission that secures energy to serve the electrical energy requirements of end-use customers in New York state;

      (b) “renewable energy systems” means 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.

      2. No later than June thirtieth, two thousand twenty-one, the commission shall establish a program to require that:

      (a) a minimum of seventy percent of the state wide electric generation secured by jurisdictional load serving entities to meet the electrical energy requirements of all end-use customers in New York state in two thousand thirty shall be generated by renewable energy systems; and

      (b) that by the year two thousand forty (collectively, the “targets”) the statewide electrical demand system will be zero emissions. In establishing such program, 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.

      Thank you for the question.


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