Climate Leadership & Community Protection Act Technology Aspirations

Recent presentations (Benefits and Costs Presentation and Initial Results Presentation on the integration analysis strategies to meet the  Climate Leadership and Community Protection Act (Climate Act) targets are providing insight into the technology required to meet the Climate Act targets.  Last year the International Energy Agency (IEA) published “Special Report on Clean Energy Innovation” that analyzes the current state of clean energy technology.  I did an evaluation of the report results relative to the Climate Act at that time.  The integration analysis states that “firm capacity is provided by hydrogen resources to meet multi-day reliability needs, ranging from 15 to 23 GW”.  This article reviews the IEA technological readiness of hydrogen resources.

I have written extensively on implementation of the CLCPA because I believe the ambitions for a zero-emissions economy outstrip available technology such that it 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.

Clean Energy Innovation Background

The IEA “Special Report on Clean Energy Innovation” report concludes that innovation is necessary for jurisdictions and companies to fulfill their de-carbonization targets and lists the current status of many potential technologies.  The IEA website describing this report explains why innovation is necessary and the magnitude of the effort needed to decarbonize and the innovation necessary to make it work.  The Energy Transition Plan Clean Energy Technology Guide is a useful summary of around 400 component technologies and identifies their stage of readiness for the market. It includes an interactive section where you can choose a sector, various filters and get a summary of the readiness of different technologies.  There also is a poster that you can download to see similar information.  IEA uses the technology readiness level (TRL) scale to assess where a technology is on its journey from initial idea to market use that I used to assess the status of some the necessary technology needed for Climate Act implementation.

Climate Act Background

Implementation for the Climate Act implementation began soon after the law became effective in January 2020.  The law established the Climate Action Council whose charge was to develop a scoping plan to meet the targets.  The Council was supported by seven advisory panels who between late summer 2020 and spring 2021 developed strategies for the required emission reductions.  Last summer they were turned into specific policies by the New York State Energy Research & Development Authority (NYSERDA) and its consultant by using an economy-wide energy model that quantifies emissions and costs. The results from the integration analysis are being incorporated into the draft scoping plan so that the scoping plan can be finalized by the Climate Action Council by the end of the year.  Next year the public and other stakeholders will get to comment on the scoping plan.

In recent Climate Action Council meetings (October 1, 2021 and October 14, 2021), the initial results of the integration analysis were presented.  The integration analysis compares the model output for a reference case that estimates emissions and costs assuming no Climate Act policies with four scenarios that incorporate different emission reduction strategies.  The results presentation described specific recommended strategies and provided the first inkling of the costs and alleged benefits.  I am convinced that most New Yorkers have no idea what is included in the state’s plan to do “something” about climate change.

Renewable Resource Reliability Concern

One of the problems with the politicized structure of the Climate Action Council is that very few of the people appointed to develop recommendations for the scoping plan have the background and experience to understand the enormity of the technological challenges to the energy system transition away from fossil fuels.  They have been lulled into a false sense of security by the renewable energy grifters on the panels and fear of retribution if concerns are raised from the entities charged with maintaining a reliable electric system, I believe there are real risks of catastrophic system-wide blackouts.  If you look there are hints that the transition path is not without peril.

On October 25, 2021 the New York Independent System Operator (NYISO) released the draft 2021-2030 Comprehensive Reliability Plan that is part of the New York reliability planning process.  While this report only runs out to 2030 the report also includes a section on the reliability and resiliency challenges further out:

Looking ahead to 2040, the policy for an emissions-free electricity supply will require the development of new technology. Substantial zero-emission dispatchable resources will be required to fully replace fossil generation.

The new technology is some form of zero-emission dispatchable generating.  Electric system grid operators have to balance load and generating resources on a minute-by-minute basis.  It is always a challenge but as long as the operators have generating resources that they can dispatch (that is to say increase or decrease generation on demand) to match the load then the fact that large blackouts are very rare proves that they are doing a good job. 

The existing system has enough dispatchable resource availability to balance the system at this time but the Comprehensive Reliability Plan describes one of the problems, albeit in technical terms, that the grid in transition will have to address:

Most renewable generators will be connected to the grid asynchronously through power electronic devices (i.e., inverter-based resources). The ability of inverter-based resources to function properly often depends on the strength of the grid at or near the interconnection of the resources. Grid strength is a commonly used term to describe how the system responds to system changes (e.g., changes in load, and equipment switching). In a “strong” system, the voltage and angle are relatively insensitive to changes in current injection from the inverter-based resource. Inverter-based resources connecting to a portion of the system rich in synchronous generation that is electrically close or relatively large are likely connecting to a strong portion of the system. Inverter-based resources connected to a “weak” portion of the grid may be subject to instability, adverse control interactions, and other issues.

A full explanation of the electric grid is beyond the scope of this article but if you want more information here is a summary.  In brief, this paragraph’s concern about synchronicity is related to the fact that all generators connected are synchronized.  “Synchronous” generators create electricity by spinning a magnet in a coil of wire.  The strength of the system in the description basically refers to the spinning inertia of all the generators producing power.  As long as there are a lot of them then the system is “strong”.  Wind and solar generators produce electricity for the grid through an inverter so are asynchronous and do not provide any ancillary support services for the grid.  As more and more wind and solar are added this disadvantage increases and at some point, there will not be enough inertia among other things to keep the grid stable.  Importantly, no one knows at what point the grid will become so unstable that safety mechanisms trip out a “weak” region to prevent problems elsewhere.

In addition to the ancillary support concerns renewable energy is intermittent.  One New York Independent System Operator (NYISO) analysis projected future winter energy production by resource type and found that the worst-case future resource concern will be a winter-time wind lull.  During those periods solar resources are low because days are short and the sun is at a low angle, and wind resources can be less than 25% of the wind capacity for seven days at a time.  Consequently, there is a need for a large quantity of installed dispatchable energy resources needed for a small number of hours.  They must be able to come on line quickly and be flexible enough to meet rapid and steep ramping needs.

The integration analysis prepared to support the development of the scoping plan that will modify New York’s energy system to meet the targets of the Climate Act includes a “zero-carbon firm resource” to fulfill that requirement.  The integration analysis projects that between 14.6 GW and 20.7 GW of this resource will be needed in the future.  The integration analysis states that “firm capacity is provided by hydrogen resources to meet multi-day reliability needs, ranging from 15 to 23 GW”

IEA Hydrogen Resources Readiness

This section describes the readiness of hydrogen resources for this firm capacity resource.  The integration analysis lacks detailed documentation.  The only reference to the plan to use hydrogen resources is that it will be the source of the firm capacity to meet reliability needs.  As a result, it is necessary to make some guesses about the technologies that could be used.

The first issue is the readiness of the hydrogen resources as described in the  Energy Transition Plan Clean Energy Technology Guide.  I extracted the hydrogen resources from that guide into a table, Hydrogen Technology Readiness Level.  The IEA Guide groups technology into four categories: production, storage, transport, and generation and estimates readiness level on an 11-category scale.

There are fourteen production technologies listed.  I assume that the only CLCPA acceptable technology is electrolysis using excess electricity produced by wind and solar generating resources.  There are four electrolysis technologies: seawater electrolysis, solid oxide electrolyser cell, polymer electrolyte membrane, and alkaline.  Given that off-shore wind is supposed to account for 17-20 GW of capacity in the future integration analysis scenarios seawater electrolysis might be an option but it is only at the “Concept Needs Validation – Solution needs to be prototyped and applied” readiness level.  The solid oxide electrolyser cell is at the “Pre-Commercial Demonstration – Solution working in expected conditions” readiness level.  Hydrogen production using the polymer electrolyte membrane technology is rated at the “First of a Kind Commercial – Commercial demonstration, full scale deployment in final form” readiness level.  The alkaline electrolysis production technology is the highest rated technology described as “Commercial Operation in Relevant Environment – Solution is commercially available, needs evolutionary improvement to stay competitive”.  Note, however, that before this technology can be considered a stable technology with predictable growth that it needs evolutionary improvement to stay competitive and even then, would need to further integration efforts.

There are three storage technologies listed: depleted oil & gas field, aquifer, salt cavern storage, and storage tanks.  The depleted oil & gas field, aquifer and salt cavern storage technologies are only available where there is an appropriate geological formation so there are limitations on availability.  The remaining technology option, tank storage is rated “Proof of Stability Reached – Predictable growth” which means that the technology can be relied on for hydrogen storage.

There are four transport technologies listed: hydrogen blending in natural gas network, liquid hydrogen tanker, liquid organic-hydrogen carrier tanker, and pipeline.  I assume that the liquid hydrogen tanker and liquid organic-hydrogen carrier tanker technologies will not be used.  I have heard suggestions that hydrogen blending in natural gas network could be used because it would reduce the infrastructure development requirements.  However, its technical readiness level is “Pre-Commercial Demonstration – Solution working in expected conditions” which is a long way from a dependable technology.  Fortunately, pipelines are rated “Proof of Stability Reached – Predictable growth” so they can be used albeit they would require a new pipeline network.

There are eight generation technologies listed.  I assume that only the high-temperature fuel cell, hybrid fuel cell-gas turbine system, and hydrogen gas-fired turbine technologies would be considered.  Both the high-temperature fuel cell technology and hydrogen gas-fired turbine are rated as “First of a Kind Commercial – Commercial demonstration, full scale deployment in final form”.   The hybrid fuel cell-gas turbine system is rated “Full Prototype at Scale – Prototype prove at scale in conditions to be deployed”. 

Hydrogen is used as a raw material in the petrochemical industry so storage in tanks and transport in dedicated pipelines are mature technologies that New York can count on as part of the “firm capacity hydrogen resource”.  However, the production and generation technologies are not as mature.  The two higher rated generation technologies are not as ready as the highest rated production technology and would have to be successfully employed in a relevant commercial operation to get to the same level.  All the technologies cannot be considered a stable technology with predictable growth until there are evolutionary improvements to stay competitive and even then, would need further integration efforts. 


The International Energy Agency report “Special Report on Clean Energy Innovation” concludes that innovation is necessary for jurisdictions and companies to fulfill their de-carbonization targets.  The report explains:

“Without a major acceleration in clean energy innovation, net-zero emissions targets will not be achievable. The world has seen a proliferating number of pledges by numerous governments and companies to reach net-zero carbon dioxide (CO2) emissions in the coming decades as part of global efforts to meet long-term sustainability goals, such as the Paris Agreement on climate change. But there is a stark disconnect between these high-profile pledges and the current state of clean energy technology. While the technologies in use today can deliver a large amount of the emissions reductions called for by these goals, they are insufficient on their own to bring the world to net zero while ensuring energy systems remain secure – even with much stronger policies supporting them”.

The integration analysis states that hydrogen resources will provide the reliability resource support necessary to keep the lights on, but offer no documentation why this technology should be trusted.  Based on the IEA technology assessment I do not believe that hydrogen resources or any other technology is available at this time that is zero-emissions, able to come on line quickly and flexible enough to meet rapid and steep ramping requirements.  Until clean energy innovation has produced technologies that are proven to work as needed with those characteristics it is premature to chase the aspirational goal of net-zero emissions without risking our current reliability standards.  Furthermore, I have only discussed technological feasibility and not costs or environmental impacts.  There are plenty of concerns related to the hydrogen economy overlooked in the integration analysis that must be addressed in the scoping plan.

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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