Scoping Plan Reliability Feasibility – Scope of the Problem

The Climate Leadership and Community Protection Act (Climate Act) establishes a “Net Zero” target by 2050 and the Draft Scoping Plan defines how to “achieve the State’s bold clean energy and climate agenda”.   However, there hasn’t been a feasibility plan that fully addresses the cost and technology necessary to provide reliable energy in the future all-electric net-zero New York energy system.  This is the first post of a series of posts describing the problem and the Scoping Plan’s failure to provide a proposal that adequately addresses the problem.

I have written extensively on implementation of the Climate Act because I believe the ambitions for a zero-emissions economy outstrip available technology such that it will adversely affect reliability and affordability, risk safety, affect lifestyles, will have worse impacts on the environment than the purported effects of climate change in New York, 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 preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  The Climate Act requires the Climate Action Council to “[e]valuate, using the best available economic models, emission estimation techniques and other scientific methods, the total potential costs and potential economic and non-economic benefits of the plan for reducing greenhouse gases, and make such evaluation publicly available” in the Scoping Plan. 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.  Those recommendations were translated into specific policy options in an integration analysis by the New York State Energy Research and Development Authority (NYSERDA) and its consultants.  The integration analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021. This draft includes results from the integration analysis on the benefits and costs to achieve the Climate Act goals. The public comment period extends through at least the end of April 2022, and will also include a minimum of six public hearings. The Council will consider the feedback received as it continues to discuss and deliberate on the topics in the Draft as it works towards a final Scoping Plan for release by January 1, 2023.

The Climate Action Council claims that the integration analysis was developed to estimate the economy-wide benefits, costs, and GHG emissions reductions associated with pathways that achieve the Climate Act greenhouse gas emission limits and carbon neutrality goal. The integration analysis incorporates and builds from Advisory Panel and Working Group recommendations, as well as inputs and insights from complementary analyses, to model and assess multiple mitigation scenarios. In addition, there is historical/archived information is available through the Support Studies section of the Climate Resources webpage, and can found as part of the Pathways to Deep Decarbonization in New York State – Final Report.

February 2021 Texas Electricity Debacle

A recent article in Texas Monthly describes the deadly blackout that hit Texas in February 2021. Russell Gold’s article “One year after the deadly blackout, officials have done little to prevent the next one—which could be far worse” does an excellent job describing what happened. He explains that as the frigid air behind the winter storm blanketed the state and the electric gird operators started dealing with resulting problems:

Nobody yet knew just how widespread the blackouts would become—that they would spread across almost the entire state, leave an unprecedented 11 million Texans freezing in the dark for as long as three days, and result in as many as seven hundred deaths. But neither could the governor, legislators, and regulators who are supposed to oversee the state’s electric grid claim to be surprised. They had been warned repeatedly, by experts and by previous calamities—including a major blackout in 2011—that the grid was uniquely vulnerable to cold weather. 

The integration analysis recognizes that the future New York electric grid will be more vulnerable to cold weather.  When electricity is universally used for heating, cooking, hot water, and transportation the peak loads will occur in winter.  The analysis also recognizes that solar energy resources will be reduced in the winter if for no other reason the days are shorter and that multi-day wind lulls mean that non-fossil fuel energy resources availability will be an issue. However, the reality is that the integration analysis does not provide enough detail to be considered a cost and technology feasibility study, particularly with regards to how the cold weather wind lull problem will be handled. 

I highly recommend reading Gold’s article for its description of how the blackouts unfolded.  There is a gripping description of how the blackout disaster unfolded for the grid operators and a very good explanation of the issues they faced.

Two days before Mecke was awakened in his office, ERCOT had held an emergency conference call to warn the state’s utilities and rural electric cooperatives that blackouts were likely. ERCOT officials said the grid might have to shed as much as 7,500 megawatts—effectively darkening roughly one of every eight homes in the state. That’s nearly twice as much as the last controlled load shed, in 2011, when rolling blackouts had lasted as long as eight hours, which in turn was four times longer than the previous large-scale blackout, in 2006. 

The worst-case scenario ERCOT had gamed out, what it called “extreme winter,” contemplated a record-setting demand of 67.2 gigawatts. Electricity consumption blew past that mark at 7 p.m. on February 14. Meanwhile, electricity supply continued to dwindle as underinsulated power plants went down, one after another.

For the grid to function properly, the supply of electricity must always match demand; this equilibrium is reflected in the grid’s frequency, which usually remains steady at 60 hertz. Power plants across the state are tuned in to the frequency, and they automatically increase or decrease generation to maintain equilibrium. The grid is like a giant synchronized machine, its components linked across hundreds of miles, from Midland to Houston, from Amarillo to Brownsville. On this night, as demand drastically outpaced supply, the frequency dropped and the vast machine began churning faster. But eventually it couldn’t compensate on its own.

By 1:23 a.m., ERCOT could no longer delay action. An operator in its control room picked up the hotline phone, which was wired to sixteen of the state’s utility companies, and ordered a thousand-megawatt load shed statewide. “You practice for this for years,” Mecke said. “You hope it never happens.” 

In fact, a few hours earlier, he’d run his coworkers through a simulation of a nearly identical load shed. When the time came to carry out the operation for real, there were no hiccups. “It was surprisingly calm,” he said. “It was smooth.” Within seconds, electricity in parts of San Antonio began to blink off. Mecke, hopeful that the grid would stabilize, breathed a sigh of relief. The calm was short-lived.

The frequency should have risen after the load shed, but instead it kept falling. It was “nerve-racking,” said Mecke. 

At 1:47 a.m., the hotline phone rang again. Everyone in the CPS control center stopped what they were doing. ERCOT needed another thousand megawatts cut. Because of coronavirus precautions, CPS executives weren’t in the control room. Rudy Garza, the chief customer officer, tracked the frequency’s dangerous decline on his phone, texting back and forth with industry friends and former coworkers from across the state. “We were scared,” he said.

CenterPoint Energy, a utility in Houston, runs a control room similar to that of CPS. Eric Easton, CenterPoint’s vice president of real-time operations, was hastening to execute the second round of blackouts when the hotline phone rang for the third time, at 1:51 a.m. ERCOT ordered another three thousand megawatts—more than the first two combined. “Calls started coming in so fast that they were overlapping,” said Easton. “When are we going to stop shedding load?” he wondered.

But the situation was only growing more dire. At the precise time of the third call, the frequency reached a critical threshold: 59.4 hertz. The Texas grid, which has been around in some form since World War II, had only once in its history fallen this low. Automated turbines across the state began spinning even faster to produce more electricity, but when the frequency dips below 59.4 hertz, the turbines reach speeds and pressures that can cause catastrophic damage to them, requiring that they be repaired or replaced. This scenario was unlikely because, to prevent it, the grid automatically triggers a nine-minute countdown when it strikes 59.4 hertz. If the frequency did not rise in time, power plants would shut down and the grid would begin turning itself off completely. This would leave all 26 million Texans who relied on the ERCOT grid without power for weeks or months. 

A few more minutes ticked by. The frequency kept falling, touching 59.302 hertz, yet another alarming precipice. At 59.3 hertz, human operators are taken out of the equation: they are too slow to make the urgent adjustments that are needed to stabilize the grid. The system is programmed to automatically start blacking out as many areas as are necessary to balance power supply and demand. But in this scenario, that fail-safe may not have worked because so many areas had already been manually cut off. “We were on the very edge,” said Easton. 

In a last-ditch effort to prevent the grid’s collapse, ERCOT placed a fourth hotline call, at 1:55 a.m., and ordered another 3,500 megawatts. All across Texas, grid operators were moving as quickly as they could, blacking out more and more neighborhoods, but they were running out of options. As the countdown approached zero, the frequency suddenly shot back up. The immediate crisis was over—the last-second load shed had worked—but for most of the following day, the grid remained dangerously unstable. 

It is hard to fathom the devastation a total shutdown would have wreaked. Bill Magness, then the CEO of ERCOT, would explain as much to the Texas Senate ten days later. Magness is a lawyer with a buzz cut and ramrod-straight posture who spent time in the nineties and aughts as a practicing Buddhist. “What my team and the folks at the utilities in Texas would be doing is an exercise called ‘black start,’ ” he said. A black start would have required carefully rebooting a few power plants at a time and using them to jump-start others, thereby restoring the grid piece by piece. It’s not a matter of flipping switches. The steps required for a black start are numerous, complex, and delicate. No one knows how long that process would take, because no one has ever needed to do it. Magness said it would have been weeks at least. 


Gold also gives his opinion why it happened and how to fix it.  I am not familiar enough with the Texas electric energy system to support or dispute his arguments.  In this instance it does not matter.  For whatever reason the Texas electric system did not have enough generating resources available to meet the peak load requirements when Texans needed it most.  If New York’s implementation plan for net-zero leads to a similar situation where there isn’t enough energy available the result will be the same: massive costs and deaths due to a lack of heat.

I have called the renewable resource adequacy problem the ultimate problem for the Climate Act as early as September 2020.  On August 2, 2021, the New York State Energy Research and Development Authority (NYSERDA) held a Reliability Planning Speaker Session to describe New York’s reliability issues to the advisory panels and Climate Action Council.  All the speakers but one made the point that today’s renewable energy technology will not be adequate to maintain current reliability standards and that a “yet to be developed technology” will be needed.  It is my understanding that the New York Independent System Operator and the New York State Reliability Council have reliability planning responsibilities.  How can the Climate Action Council propose a Scoping Plan without reconciliation with those entities? 

According to a Gothamist summary of the Climate Act: “Seggos, the DEC commissioner, said the draft plan is meant to generate a framework and solicit input on how the state can meet its climate goals, not provide a policy-by-policy cost estimate.”  With all due respect to the commissioner, I believe it is inappropriate to rely on a “framework” to claim that renewable energy resources can provide adequate and reliable electric service affordably.


At the September 13, 2021 meeting of the Climate Action Council a requirement to consider carbon reduction measures in other jurisdictions was discussed.  The fact is that the situation in Europe this winter is a harbinger of things to come in New York.  The Draft Scoping Plan considers control measures in isolation and ignores the ramifications observed elsewhere for the measures.  The Draft Scoping Plan’s strategies to decarbonize the economy are a classic example of the ancient political strategy of “winging it”. Sadly, the Climate Action Council is basing the future of New York’s electricity grid on a plan that relies, to a very great extent, on a collective crossing of fingers.  If this problem is not resolved then the impacts observed in the Texas blackouts disaster of February 2021 will be the inevitable outcome.  In subsequent posts I will explain why this is the case and offer some suggestions for addressing the problem.

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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