Climate Leadership & Community Protection Act 2030 Electric System Target Feasibility

On August 29, 2021 I posted an article, CLCPA Electric System Targets, that discussed the politics behind the 2030 electric system target that requires a minimum of seventy percent of the state wide electric generation to be provided by renewable energy systems.  I argued that because the definition of renewable energy systems excludes nuclear and renewable natural gas (e.g., methane capture from landfills, farm manure digesters, and other organic sources) that meeting that target was impossible.  However, I did not provide evidence for that claim.  This article documents why I believe it is impossible.

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.   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.


The previous article completely documents the target and relevant definitions but here is the simple version.  § 66-p, 1 (b) states that (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”.  The target is defined in § 66-p, 2 (a) as “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”.

Future Electric System Projections

I looked at feasibility of the 2030 target earlier but I had the mistaken impression that nuclear was included as part of the 70% allowable energy sources.  The premise of my impossibility argument is that the current renewable energy sources distribution from the New York State Energy Research and Development Authority (NYSERDA) Patterns and Trends – New York State Energy Profiles: 2003-2017 report is so small that it is unreasonable to expect that it can be raised to 70% in ten years even if nuclear is included.  Table 1 combines data from the NYSERDA patterns and trends document and the New York Independent System Operator (NYISO) Gold Book for the last three years.  In 2020 the CLCPA renewable energy sources contributed only 24% of the electrical energy system generation (Table 1).  This article will look at a couple of refined projections made for the future electric system under the CLCPA.

The first study is the Initial Report on the New York Power Grid Study as described in Appendix E: Zero-Emissions Electric Grid in New York by 2040 Study (“Zero-Emissions Study”).  It is not surprising that this analysis prepared in part by New York Department of Public Service and NYSERDA staff claimed that “there are feasible pathways to meeting the CLCPA targets” because state policy takes it as a given that CLCPA targets are only a matter of political will.  However, upon closer examination using alternate reasonable alternate assumptions the target is unlikely to be achieved.

Table 2 compares the assumptions in the initial scenario of the Zero-Emissions Study with alternative assumptions.  The New York Independent System Operator (NYISO) Gold Book includes estimates of future load in Table I-1b: Summary of NYCA Baseline Annual Energy Forecasts – GWh.  In this table the baseline annual energy forecast is 145,960 GWh but that includes a reduction of behind the meter solar PV 8,013 GWh.  Because the Zero-Emissions Study includes estimates for this parameter it should be added to the annual forecast to make the 2030 expected load 153,973 GWh.  That makes the renewable energy resources percentage of the total smaller.  The Table 2 alternative assumes the same capacity for distributed behind the meter solar, utility-scale solar, and onshore wind but bases the capacity factors on observed data rather than the “NREL Wind Toolkit and National Solar Radiance database”.  Land-based wind capacity factors averaged 25% over the last five years.  Assuming that all the additional wind capacity developed between now and 2030 meets the NREL 34.6% capacity factor and that all the existing wind capacity continues to operate at 25% the more appropriate combined New York capacity factor should be 31.5% thus reducing the expected energy produced.  The latest Gold Book includes data that indicates that grid solar in New York has a capacity factor of 17.6%.  With respect to grid solar in Table 2 that raises the energy produced.  However, the Zero-Emissions Study assumes that distributed solar will have the same capacity factor as utility-scale solar and that is not supportable.  The NYSERDA New York Solar Study lists different capacity factors for three different classes of distributed solar – all lower than the utility-scale value.  For the alternative I conservatively used the highest value of the three.  As a result of all these alternative assumptions the alternate renewable energy resources percentage is 67.1%.

The second analysis was done by Energy and Environmental Economics, Inc. (E3) for NYSERDA in the spring of 2020.  E3 described their analysis in Pathways to Deep Decarbonization in New York State – Final Report [PDF]. E3 used their RESOLVE model to model the electric sector:

Our modeling approach also incorporates detailed electricity sector representation using E3’s RESOLVE model. RESOLVE is used to develop least-cost electricity generation portfolios that achieve New York’s policy goals, including 100% zero-emission electricity, while maintaining reliability.

When the report was released, I analyzed the approach and concluded that: “While their models give the veneer of respectability to the projections, the reality is that the inherent over-simplifications of their models under-estimates the difficulties of the transition in New York and gives a false sense of security to their assurances that implementation will succeed”.  Of particular concern relative to the electric system feasibility is how they handled renewable resource availability.  In the following slide they point out that firm capacity is needed to meet a multi-day period of low wind and solar output in the winter.  In my analysis I argued that actual short-term meteorological data must be used to correctly characterize the renewable resource availability for New York in general and in areas downwind of the Great Lakes in particular. This is because the lakes create meso-scale features, most notably lake-effect snow and clouds, that can affect solar resources many miles from the lake shore.  At the time I asked E3 how they calculated renewable resource availability but they never responded.  The key point is that the ultimate estimate of the electric system generating resources necessary to ensure reliable electricity availability at all times must be able to handle this worst-case situation.  It is not clear to me that the projections in their decarbonization pathway address this in their estimates of resources needed.

I extracted the data in Table 3 from their Supplementary Workbook [XLS] dated October 10, 2020.  I estimate that this analysis projects that renewable energy resources will only total 67.6% instead of 70%.  Even so I think their estimate is high.  My biggest concern is that there are no firm, zero-emissions resources listed for 2030 and I think some will be needed to meet the worst-case period they highlight as a concern.  There also are consistency issues relative to the other estimates.  E3 handled imports differently.  That is good because it does give a renewable energy resource estimate for imported hydropower but it causes the total imports to become negative.  I don’t know how battery storage should be handled relative to the CLCPA definitions so I just lumped it into the renewable energy resources category. 

In addition to the problem that both studies did not prove that their renewable energy resources solution adequately addressed the critical reliability problem of a multi-day period of low wind and solar, both studies presume that the projections for future renewable energy resources can be built on a schedule that ensures that they are available in 2030.  The Accelerated Renewable Energy Growth and Community Benefit Act is supposed to expedite renewable energy development but that does not preclude the possibility of litigation on specific projects or other holdups in the permitting process. In the case of offshore wind, I believe that delays are inevitable because the infrastructure to support building the turbines has to be developed first and those developments are also subject to permitting and construction delays.  Finally, there is a real possibility that the availability of the critical minerals and metals needed for these renewable technologies could slow implementation and increase costs. 


In general, the feasibility approach in the analyses described here is to simply estimate future load and then calculate the energy resources necessary to match that load.  There are multiple issues with these analyses.  First, and foremost, the emphasis appears to be on annual comparisons but the critical reliability issue is a multi-day period in the winter when wind and solar resource availability is low but the load requirements for universal electrified heating and transportation are high and must be met to ensure the safety and health of New York residents.  It is not clear that any of the projections adequately addressed this requirement.  In addition, I don’t think that the projections included the necessary resources needed to provide ancillary transmission grid services as I described in a post on one of the studies.  Finally, I am sure that the studies did not incorporate the resources needed to maintain New York State Reliability Council requirements.  Therefore, these projections under-estimate the resources needed to provide reliable electricity.

The Zero-Emissions Study and the E3 decarbonization pathways analysis both can claim that their approaches achieve the goal that the electric system use 70% renewable energy resources in 2030.  Based on this analysis I think their assumptions about renewable resource availability are overly optimistic.  The practical reality is that time constraints on permitting, procurement, construction and development of supporting infrastructure will most likely delay implementation of the ambitious proposed resource development.  Further compounding the viability of the proposed resources are the New York State Reliability Council requirements and the need for ancillary grid transmission services.  When all these factors are considered, I believe that it will be impossible to meet the 2030 target without endangering reliability.

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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