Climate Leadership & Community Protection Act Integration Analysis: New Findings

At the October 1, 2021 meeting of New York’s Climate Leadership and Community Protection Act (CLCPA) Climate Action Council  Carl Mas from the New York State Energy Research & Development Authority (NYSERDA) described findings from the integration analysis.  These findings underscore the difficulties faced to meet the CLCPA targets.

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 Climate Action Council is responsible for submitting the Scoping Plan that will outline a plan to implement strategies to meet the ambitious targets of the CLCPA.  Of particular interest are the targets to reduce greenhouse gas emissions by 40% relative to the 1990 baseline and supply 70% or the electrical energy come from renewable resources by 2030 and by 2040 provide all electricity from zero-emissions sources.  Meeting these targets will require a transition of the entire New York energy system.

Last spring advisory panels submitted their recommendations to the Climate Action Council for strategies in seven sectors to meet the targets.  The Council and the advisory panels are composed of political appointees chosen more for their advocacy and politics than their expertise in the energy sector.  In order to address the lack of expertise and assemble a comprehensive strategy New York State Energy Research and Development Authority (NYSERDA) and their consultants are providing technical support by developing an integration analysis.

The integration analysis has developed a reference case and four scenarios that include specific strategies, emission estimates, and costs for Climate Action Council comment and discussion:

      • Reference Case
        • Currently implemented policies
      • Scenario 1: Advisory Panel Recommendations
        • Aggregate impacts of recommendations from Advisory Panels
        • Scenarios that meet or exceed GHG emission limits, achieve carbon neutrality by midcentury
      • Scenario 2: Strategic Use of Low-Carbon Fuels
        • Includes the use of bioenergy derived from biogenic waste, agriculture & forest residues, and limited purpose grown biomass, as well as green hydrogen, for difficult to electrify applications
      • Scenario 3: Accelerated Transition Away from Combustion
        • Low-to-no bioenergy and hydrogen combustion; Accelerated electrification of buildings and transportation
      • Scenario 4: Beyond 85% Reduction
        • Accelerated electrification limited low-carbon fuels; Additional VMT reductions; Additional innovation in methane abatement; Avoids direct air capture of CO2

According to the presentation in order to meet the targets, there are foundational themes across the scenarios based on findings from Advisory Panels and supporting analysis:

      • Zero emission power sector by 2040
      • Enhancement and expansion of transit & vehicle miles traveled reduction
      • More rapid and widespread end-use electrification & efficiency
      • Higher methane mitigation in agriculture and waste
      • End-use electric load flexibility reflective of high customer engagement and advanced techs

The schedule for the remainder of the year is ambitious.  The integration analysis will be incorporated into the draft scoping plan by the end of October and in November the Climate Action Council will discuss the strategies and provide feedback on the draft scoping plan.  The plan is to finalize scoping plan by the end of the year and next year put it out for public comment.

New Findings

I extracted the bullet points describing the new findings of the integration analysis from the October 1, 2021 Climate Action Council meeting presentation.  My reaction to these findings is shown in italics below.

  • Achievement of emissions reductions to meet state law requires action in all sectors, especially considering New York State’s novel emissions accounting

Novel emissions reporting refers to the emphasis on greenhouse gases other than CO2, particularly, methane and nitrous oxides.  Novel is another way of saying no other jurisdiction in the world has prepared an inventory of emissions with such an overt and flawed emphasis on natural gas.

      • Every sector will see high levels of transformation over the next decade and beyond, requiring critical investments in New York’s economy
  • Energy efficiency and end-use electrification will be essential parts of any Pathway that hits NYS Emissions Limits
      • In all scenarios modeled, zero emission vehicles and heat pumps become the majority of new purchases by the late 2020s, and fossil-emitting cars and appliances are no longer sold after 2035
      • 1 -2 million efficient homes electrified with heat pumps by 2030
          • In 2017 there were 7,302,710 occupied housing units in NYS
          • 2% or 820,554 used electricity for space heating
          • The fraction of heat pumps used is unknown but has to be small
          • To reach 1.5 million heat pump homes requires about 200,000 conversions per year
      • Approximately 3 million zero-emission vehicles (predominantly battery electric) by 2030
          • 1 million vehicle registrations on file in 2018 so 2030 is 27% EV
          • On 9/2/2021 there were 81,858 ZEVs on the road in NY, 0.9%
          • Over the last 12 months 2.15% of the new vehicles registered were electric vehicles and the greatest month was 4.36%
  • Unprecedented rate of adoption of novel and potentially disruptive technologies and measures

Disruptive technologies “significantly alter the way consumers, industries, or businesses operate”.  “To be considered disruptive, technology must be easily accessed by a majority of the population. Revolutionary inventions are often not disruptive because they’re too expensive for the common consumer. In many cases, it’s not until the technology is refined enough to become affordable that it’s considered disruptive to the market. A disruptive technology is one that enters the mainstream and changes the way most people think or behave.

Disadvantages of disruptive technologies:

          • “New technology is typically untested and unrefined during its early stages and development can continue for years.”
          • “Nearly all innovations go through a period of problem-solving.”
          • “It can take time for a disruptive technology to find its place in the marketplace.”

It is incredibly risky to be counting on novel and disruptive technologies to meet the CLCPA targets.

  • Consumer decision-making plays a large role, especially important for the purchase of new passenger vehicles and heating systems for homes and businesses through the next decade

The climate act implementation echo chamber has not addressed what will happen when there is an extended outage following an ice storm.  Many folks have a contingency plan for that kind of an event but see no reasonable alternatives when everything is electrified.

  • Substantially reduce vehicle miles traveled while increasing transportation access
    • Expansion of transit service structured around community needs
    • Smart growth inclusive of equitable transit-oriented development
    • Transportation demand management

I do not believe that the majority of New Yorkers are aware that the CLCPA will mandate these limitations on personal mobility.  The climate act implementation echo chamber has not explained how this will not have massive impacts to rural areas and the rural poor.

  • Wind, water, and sunlight power the majority of New York’s economy in 2050 in all Pathways
    • Even with aggressively managed load, electric consumption doubles and peak nearly doubles by 2050, and NYS becomes a winter peaking system by 2035.

Although the presentation mentions that the reliability standards are included in the scenarios it is not clear to me that is the case because there is so little documentation available.  Furthermore, I think it is likely that there will be new reliability rules that certainly have not been included.

  • Offshore wind on the order of 20 GW, solar on the order of 60 GW, and 4-and 8-hour battery storage on the order of 20 GW by 2050

These are extraordinary numbers.  The largest integrated solar-powered battery will be at the Florida Power & Light Manatee Solar Energy Center rated at 409 MW, 900 MWh.  Note that the energy storage facility only provides two hours of storage so over 100 equivalent facilities will have to be built.

  • Firm, zero-emission resources, such as green hydrogen or long-duration storage, will play an important role to ensure a reliable electricity system beyond 2040

Long-duration storage does not exist today and green hydrogen has not been deployed at utility scale.  Moreover, as the hydrogen is produced it will have to be stored and transported to where it will be used which is no easy feat.

  • Low-carbon fuels such as bioenergy or hydrogen may play a critical role in helping to decarbonize sectors that are challenging to electrify
    • By 2030, initial market adoption of green hydrogen in the following applications: medium and heavy-duty vehicles, high-temperature industrial (sic).

For a technology not yet commercially available expecting any significant market adoption in this time frame is a stretch.

  • Additional promising end-use applications include district heating and non-road transportation such as aviation and rail.

In theory these fuels might work for these applications but the technology has not been proven.

  • Required transition to low-GWP refrigerants and enhanced refrigerant management by 2050

If these refrigerants and enhanced management were cost-effective,then they would be used now.

  • Large-scale carbon sequestration opportunities include lands and forests and negative emissions technologies
    • Protecting and growing New York’s forests is required for carbon neutrality

I get the impression but have not confirmed that one of the control strategies is to convert home heating with wood to electric.  The concept that people do that because they cannot afford alternatives and the probable increase in costs associated with this law suggests that more rather than less people will want to heat with wood.  It is not clear to me how the State would regulate a land owner’s use of wood for home heating.

  • Negative emissions technologies (e.g., direct air capture of CO2) may be required if the State cannot exceed 85% direct emissions reductions

This is an absurd statement because it presumes that the New York contribution to the total greenhouse gas levels in the atmosphere can be measured to the point where direct air capture could have an effect.  

  • Strategic land-use planning will be essential to balance needs
  • Necessary methane emissions mitigation in waste and agriculture will require transformative solutions
    • Diversion of organic waste, capture of fugitive methane emissions are key in waste sector

Easy to say but extremely difficult to implement in practice.

  • Alternative manure management and animal feeding practices are key in agriculture

If these practices were cost-effective farmers would be doing them today.  Apparently they are not using them so who pays for farmers to use them?

 Additional innovation will be required in areas such as carbon sequestration solutions, long-duration storage, flexible electric loads, low-GWP refrigerants, and animal feeding, in concert with Federal action (e.g. Earthshots)

Requiring “additional innovation” to ensure that the lights are on, homes are kept warm and people will be able to charge their mandated electric vehicles is extraordinarily risky.  If the risks associated with the effects of climate change that could be changed by New York emissions were compared to the risks of this policy causing a blackout, then I have no doubts that the integration analysis strategies would be rejected out of hand.

 For what it is worth, the Earthshot example refers to the Department of Energy’s “Energy Earthshots” that will “accelerate breakthroughs of more abundant, affordable, and reliable clean energy solutions within the decade”.  Even if they accomplish a breakthrough the CLCPA schedule is too aggressive to take advantage of it.

  • Largest three remaining sources of emissions in 2050: Landfills, aviation, and animal feeding

No comment.


Of particular concern is that the integration analysis acknowledges that disruptive technologies will be required to meet the CLCPA targets.  I explain that these technologies are typically untested and unrefined during early stages and development can continue for years.  These innovations go through a period of problem-solving.  Given that the electric system has a long history of revisions following blackouts to address reliability problems as they arose it is unrealistic to expect that similar problems will not arise in the future. 

In order to meet the CLCPA legal schedule there has been insufficient time to prepare the documentation necessary for stakeholders to evaluate the proposed strategies.  However, given the absolute need to try to avoid catastrophic problems the integration analysis scenarios have to be fully documented.  Climate Action Council meetings have included multiple member statements arguing that the law requires some of the more unrealistic proposals incorporated into the strategies.  The ultimate question for the Climate Act is what happens when stakeholders expose the reliability risks of those strategies.  Will the Hochul administration cave to the special interests or listen to those responsible for keeping the lights on.

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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