Climate Leadership & Community Protection Act Integration Analysis -Reliability

The initial integration analysis results for the  Climate Leadership and Community Protection Act (Climate Act) were discussed at the October 1, 2014 and October 14, 2021 Climate Action Council meetings. This post documents the reliability discussion.

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.


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 2030 targets: reduce greenhouse gas emissions by 40% relative to the 1990 baseline by 2030 and 70% of the electrical energy is supposed to come from renewable resources. Starting in the fall of 2020 seven advisory panels developed recommended strategies to meet the targets that were presented to the Climate Action Council in the spring of 2021.  Both the Council and the advisory panels are composed of political appointees chosen more for their direct involvement in the CLCPA transition than their expertise in the energy sector so the strategies proposed were more aspirational than practical. 

Developing a plan to transform the energy sector of the State of New York is an enormous challenge so the New York State Energy Research and Development Authority (NYSERDA) and its consultants are providing technical support to translate the recommended strategies into specific policy options in an integration analysis.  An overview of the results of this integration analysis were presented to the Climate Action Council at the two October meetings.  There is a notable lack of documentation available for the analysis so meaningfully reviewing the plan is difficult.

The integration analysis models the complete New York energy sector.  The modeling includes a reference case that projects how the economy and energy sector will evolve out to 2050 in the absence of any Climate Act policies or mandates.  The following slide from the first integration analysis presentation lists the four mitigation scenarios that were developed to compare with the reference case.  The first simply developed energy strategies that implemented the advisory panel recommendations but the results showed that even more stringent policies were needed because the 2030 targets were not met.  The second mitigation scenario meets the 2030 targets by using low-carbon fuels to meet the critical need for dispatchable resources to keep the lights on.  The third scenario placates the members of the Climate Action Council that naively demanded that no combustion is necessary despite the lack of a proven technology that can keep the lights on in the worst-case scenarios.  Because some members of the Climate Action Council are dupes who don’t appreciate the technological hurdles and risks to reliability of the transition to zero-emissions using renewable energy and have no personal accountability for recommending policies that put New York at risk of catastrophic blackouts, there is a fourth mitigation scenario that looks at options for eliminating combustion as much as possible as soon as possible.


This article documents how the integration analysis addresses reliability.  There is a long history of blackouts in New York State in general and New York City in particular that is a primary driver of reliability concerns in the state.  In 1959 and 1961 surges in electrical use caused blackouts and changes were made to the New York City system to better protect the city’s power grid.  The 1965 blackout was the first regional blackout and spurred New York’s investor-owned utilities to setup the New York Power Pool to coordinate the state’s electric grid.  There was another blackout in 1977 that was limited to New York City directly related to the fact that most of New York City is on islands and is a load pocket.  As a result of this blackout, reliability constraints were strengthened to ensure that when storms threaten transmission into the City that sufficient in-City generation is available to prevent a re-occurrence.  In 2003 there was another regional blackout and grid operators developed procedures to prevent it from happening again.  In 2012 tropical storm Sandy caused massive blackouts exacerbated by flood protection weaknesses.  Since then, there have been investments to strengthen the infrastructure to prevent a reoccurrence.  Reliability planning is a constant concern for the electrical system professionals who operate the system and are responsible for keeping the lights on. Because the system is so complex it is very difficult to anticipate all the things that might go wrong.  Despite best efforts, however, the reality is that the primary mode of reliability improvement was in response to observed problems. 

New York Reliability Planning

In response to stakeholder recommendations the New York State Energy Research and Development Authority held a Reliability Planning Speaker Session on August 2, 2021 for the edification of the Climate Action Council (presentation and recording).  This section summarizes points made during that speaker session.

There are two independent organizations responsible for New York reliability: New York State Reliability Council (NYSRC) and New York State Independent Operator (NYISO).  The NYSRC is a Federal Energy Regulatory Council (FERC) approved entity responsible for “the promulgation of reliability standards for New York, which are mandatory requirements for the New York Independent System Operator”.   The Climate Action Council presentation included a slide describing what is needed to operate the electric system reliably.  The takeaway message of the NYSRC to the Climate Action Council was:

With the intermittency of renewables and the electrification of the economy, substantial clean energy and dispatchable resources, some with yet to be developed technology, over and above the capacity of all existing fossil resources that will be replaced, will be required to maintain reliability in the transition to meeting CLCPA requirements.

For clarification, a dispatchable resource is a generator that can increase or decrease its output energy depending on the needs of the electric grid.  The operators who manage the system balance the load and generation on a minute-by-minute basis.  The critical future reliability challenge is how to manage this balancing act when there are large amounts of wind and solar energy resources that cannot be dispatched.

The NYISO Frequently Asked Questions webpage explains how the organization originated. After the Northeast Blackout of 1965, New York’s seven investor-owned utility companies established a predecessor organization, the New York Power Pool (NYPP), to address the reliability problems exposed by the blackout.  In the 1990s New York’s electric system was de-regulated and the Federal Energy Regulatory Commission (FERC) recommended the formation of independent entities to manage energy transmission and the NYISO was established to replace the NYPP. 

The NYISO manages the electric system.  They operate the control center mentioned in the previous slide that balances the instantaneous supply of electricity between the generators and customers across the state in the de-regulated electricity market.   In addition, the NYISO has to plan for future changes to the system and the biggest factor for change is the Climate Act.  Their recent Power Trends 2021: New York’s Clean Energy Grid of the Future report describes how hourly demand patterns fluctuate diurnally and seasonally today and how they expect it will change in the future.  One 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 problem is that no such zero-emissions resource has been deployed at the scale necessary to keep the lights on in New York.

In addition to these organizations, the New York State Department of Public Service (DPS) has oversight of utility reliability planning.  This covers traditional transmission & distribution investment planning and the utilities’ obligation to “reliably serve forecasted customer loads”.  There is a nuance to this that is not universally understood.  This process is used to ensure adequate transmission and distribution capability to serve customers but the production of the electricity itself is not included.  Instead, the wholesale market overseen by the NYISO provides the power.  This nuance is usually neglected in the projections of future resources.  If the market signals are not correct then New York could find itself without sufficient generating resources.  Their summary of reliability considerations makes many of the same points addressed in the NYSRC and NYISO as shown in the following slide.

Integration Analysis

All three organizations conclude that dispatchable resources are a critical future necessity.  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 the requirement for a zero-emissions dispatchable resource.  In the integration analysis scenarios, the zero-carbon firm capacity resource is provided by 15 to 23 GW of hydrogen resources to meet multi-day reliability needs.

However, there is no mention in the presentation just how risky a proposition it is to rely on hydrogen resources.  I documented the technological readiness of hydrogen for transport, storage, production and generation from the International Energy Agency (IEA) “Special Report on Clean Energy Innovation” report.  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 rated as “First of a Kind Commercial – Commercial demonstration, full scale deployment in final form” in technological readiness.  The next category of technical readiness is described as “Commercial Operation in Relevant Environment – Solution is commercially available, needs evolutionary improvement to stay competitive” so the likely generation technologies would need have to be successfully employed in a relevant commercial operation to get to the same level.  There is one production technology that is rated at that readiness level.  In order for the production and generation technologies to be considered a stable technology with predictable growth there have to be evolutionary improvements to stay competitive and even then, would need further integration efforts.  Furthermore, I only evaluated 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.

Reliability Risks

The integration analysis short-changes reliability.  The Initial Results presentation includes the word reliability six times but never addresses the fact that the proposed critical firm dispatchable resource has not been employed on the scale needed to keep New York lights on. Overlooking the importance of reliability ignores experiences elsewhere where renewable resource integration issues led to blackouts. There was a short blackout in Great Britain associated with a very short-term spike in resources.  California is having trouble dealing with the diurnal variation of renewable resources that have resulted in rolling blackouts.  Finally, Texas had a catastrophic blackout because they didn’t provide a strong enough market signal for resources needed for an extreme cold event accompanied with calm winds.

Great Britain

In August 2019, there was an unusual set of circumstances in Great Britain that led to a short blackout for 1.1 million customers.  According to the interim report summary describing the incident:

Prior to 4:52pm on Friday 9th August 2019, Great Britain’s electricity system was operating as normal. There was some heavy rain and lightning, it was windy and warm – it was not unusual weather for this time of year. Overall, demand for the day was forecast to be similar to what was experienced on the previous Friday. Around 30% of the generation was from wind, 30% from gas and 20% from Nuclear and 10% from interconnectors.

At 4:52pm there was a lightning strike on a transmission circuit (the Eaton Socon – Wymondley Main). The protection systems operated and cleared the lightning in under 0.1 seconds. The line then returned to normal operation after c. 20 seconds. There was some loss of small embedded generation which was connected to the distribution system (c. 500MW) due to the lightning strike. All of this is normal and expected for a lightning strike on a transmission line.

However, immediately following the lightning strike and within seconds of each other:

          • Hornsea off-shore windfarm reduced its energy supply to the grid
          • Little Barford gas power station reduced its energy supply to the grid

The total generation lost from these two transmission connected generators was 1,378MW. This unexpected loss of generation meant that the frequency fell very quickly and went outside the normal range of 50.5Hz – 49.5Hz.

The ESO was keeping 1,000MW of automatic “backup” power at that time – this level is what is required under the regulatory approved Security and Quality of Supply Standards (SQSS) and is designed to cover the loss of the single biggest generator to the grid.

All the “backup power” and tools the ESO normally uses and had available to manage the frequency were used (this included 472MW of battery storage). However, the scale of generation loss meant that the frequency fell to a level (48.8Hz) where secondary backup systems were required to disconnect some demand (the Low Frequency Demand Disconnection scheme) and these automatically kicked in to recover the frequency and ensure the safety and integrity of the network

This system automatically disconnected customers on the distribution network in a controlled way and in line with parameters pre-set by the Distribution Network Operators. In this instance c. 5% of GB’s electricity demand was turned off (c. 1GW) to protect the other 95%. This has not happened in over a decade and is an extremely rare event. This resulted in approximately 1.1m customers being without power for a period.

The disconnection of demand along with the actions of the ESO Control Room to dispatch additional generation returned the system to a normal stable state by 5:06pm. The DNOs then commenced reconnecting customers and supply was returned to all customers by 5:37pm.

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.  This report notes that “Substantial zero-emission dispatchable resources will be required to fully replace fossil generation”.  It goes on to explain that the grid in transition will have to address the following problem:

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.

I believe this concern is related to the blackout in Great Britain described above.  There is no indication in the integration analysis documentation that they have addressed this requirement.


In August 2020 as many as 2 million Californians experienced one-hour blackouts as the state triggered rolling power outages.  The California Independent System Operator (CAISO) root cause analysis of the outages found that:

      • The climate change-induced extreme heat storm across the western United States resulted in the demand for electricity exceeding the existing electricity resource planning targets. The existing resource planning processes are not designed to fully address an extreme heat storm like the one experienced in mid-August.
      • In transitioning to a reliable, clean and affordable resource mix, resource planning targets have not kept pace to lead to sufficient resources that can be relied upon to meet demand in the early evening hours. This makes balancing demand and supply more challenging. These challenges were amplified by the extreme heat storm.
      • Some practices in the day-ahead energy market exacerbated the supply challenges under highly stressed conditions.

In a nutshell the CAISO did not plan well enough.  Although CAISO is supposed to be independent, they very likely operate under intense political scrutiny and pressure like the New York Independent System Operator.  The first reason uses the excuse that climate change contributed is, in my opinion, weak because heat storms are not a new type of weather and every analysis of supposed climate change induced events that I have evaluated turned out to be weather and not climate.  If their analysis had correctly accounted for past observed events and had included a tweak of increased temperature for climate change, then their resource planning should have been able to address the heat storm.   In addition, electrical load is a factor not only of weather extremes but also changes in electrical use.  I suspect that the effect of additional load is greater than the effect of climate change. 

The second reason probably is the fundamental cause.  I suspect that political pressure forced it to be listed second.  In the context of New York’s Climate Act push to use renewables the key point is that “resource planning targets have not kept pace to lead to sufficient resources that can be relied upon to meet demand in the early evening hours”.  The Climate Act integration analysis is not refined enough to provide any assurance that their proposed resource mix will prevent this kind of problem.  If New York resource planning does not account for all the variables associated with the transition to zero-emissions generation, then the same problems observed in California will happen in New York.


Severe winter weather in Texas in February 2021 caused at least 151 deaths, property damage of $18 billion, and higher costs of $50 billion for electricity over normal prices during the storm.  I do not believe that the 2021 Texas energy debacle was caused by the lack of wind and solar resources but the fact is that they were not available when needed most.  The situation does foreshadow the difficulty providing reliable electricity in a system that depends on renewables when the wind isn’t blowing at night.  The primary cause for the blackouts was a lack of planning manifested by an electric market that only pays for the energy produced.  As a result, there was no incentive to develop the capacity needed for rare extreme conditions so when it was needed it simply was not there.  Both Federal and Texas policy prioritized and subsidized unreliable energy sources (wind and solar) at the expense of reliable ones (natural gas, coal and nuclear) for decades and this was a contributing factor.  The problem that New York has to address to avoid a similar problem is that the coldest air of the winter and the highest demand occurs when Arctic air moves in behind a cold front.  This frigid air is associated with a cold core high pressure system pushing the front.  Those high-pressure systems have very little wind and, in the winter, there is little solar energy available in the best case and none when panels are covered with snow.

The importance of this issue has been highlighted by the Analysis Group Climate Change Impact and Resilience Study and similar work by E3 for the Climate Action Council implementation process.  Both have found that a winter-time wind lull is the critical planning criterion and both note that a resource category that provides firm, dispatchable and zero-emissions generation is needed when wind and solar resources are low or non-existent.  In my opinion no one has done an adequate job evaluating historical weather data to determine the likely worst-case scenario for low renewable resource availability and I have recommended a technique that would provide an assessment of the frequency, duration, and intensity of those renewable resource droughts.  Until that or something similar is done then the assessments are not adequate and a blackout similar to the Texas event is inevitable.


Despite numerous appeals for an increased emphasis the Climate Act process is short-changing reliability concerns.  The Climate Act mandated advisory panels provided aspirational recommendations and the integration analysis has converted them into policy options.  So far, the Climate Action Council has not stepped up and asked if the proposed policy options are technologically feasible for maintaining current reliability levels, much less whether the costs and environmental impacts are acceptable.

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 available at this time 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. 

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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