New York Climate Act: What the Experts are Saying Now  

On February 6, 2022 an article of mine was posted: New York Climate Act: Is Anyone Listening to the Experts?  This post shows that the experts are saying now that there is a major problem with New York’s plan for a “zero-emissions” electric grid by 2040. Unfortunately, the message is buried in a technical analysis product and expressed in jargon so the warning will likely be ignored.


New York’s Climate Leadership and Community Protection Act was passed in 2019 and became effective on 1/1/2020. The Climate Action Council has been working since then to develop plans to implement the Act.  Over the summer of 2021 the New York State Energy Research & Development Authority (NYSERDA) and its consultant Energy + Environmental Economics (E3) prepared an Integration Analysis to “estimate the economy-wide benefits, costs, and GHG emissions reductions associated with pathways that achieve the Climate Act GHG emission limits and carbon neutrality goal”.  Integration Analysis implementation strategies were incorporated into the Draft Scoping Plan when it was released at the end of 2021. 

My last post here described the New York Independent System Operator’s (NYISO) 2021-2030 Comprehensive Reliability Plan (CRP) report (appendices) released late last year.  The difficulties raised in the report are so large that I raised the question whether any leader in New York listening to this expert opinion.  This post highlights results shown in a draft presentation that all but admits meeting the net-zero goals of the Climate Act are impossible on the mandated schedule.

Ultimate ProblemI have discussed the ultimate problem before so will only sum up here.  In their presentation to the Power Generation Advisory Panel on September 16, 2020 E3 included the following figure. The problem is that there are significant periods when winds are so low that wind generation output is negligible and, especially in the winter, solar output is also low: “The need for dispatchable resources is most pronounced during winter periods of high demand for electrified heating and transportation and lower wind and solar output”.  The presentation notes: “As the share of intermittent resources like wind and solar grows substantially, some studies suggest that complementing with firm, zero emission resources, such as bioenergy, synthesized fuels such as hydrogen, hydropower, carbon capture and sequestration, and nuclear generation could provide a number of benefits”.   New York has substantial existing hydro resources but cannot be expected to develop much more.  Nuclear is the obvious choice going forward but New York policies shut down 2,000 MW of nuclear capacity in the last couple of years so that is unlikely for the net-zero plan.  The ultimate problem is what Dispatchable Emission Free Resource (DEFR) will be used to supply electricity during multi-day winter wind lulls.  In the CRP NYISO stated:

“While there are hundreds of projects in the NYISO interconnection queue, there are none that would be capable of providing dispatchable emission-free resources that could perform on a multi-day period to maintain bulk power system reliability. Such resources are not yet widely commercially available.”

NYISO Analysis

A bit of background about the NYISO.  It is the Regional Transmission Organization/Independent System Operator for New York State.  Independent System Operators (ISO) grew out of the orders that enabled de-regulation of the electric system.  The concept of an Independent System Operator was one way for existing tight power pools to satisfy the requirement of providing non-discriminatory access to transmission. The Federal Energy Regulatory Commission encouraged the voluntary formation of Regional Transmission Organizations (RTO) to administer the transmission grid on a regional basis throughout North America (including Canada).

The NYISO Electric System Planning Working Group (ESPWG) is the stakeholder group that provides Market Participant input on the NYISO’s comprehensive planning processes. On March 24, 2022 the NYISO Economic Planning Department made a presentation to the EPSWG on their System & Resource Outlook Update.  The presentation itself is a draft – “for discussion purposes only” so the specific numbers are not finalized.  The point of referencing this analysis is to show what the experts are saying now about the critical dispatchable emissions-free resource needed for the net-zero electric system transition.  The purpose of the System & Resource Outlook analysis is to project what electric generating resources will be needed to maintain a reliable electric system in the future.  The Economic Planning Department is collaborating with EPSWG and the presentation was to designed to solicit EPSWG and stakeholder input.

This type of capacity expansion modeling analysis develops a reference case that represents what is expected to happen to the system without any changes to “business as usual”.  Then the analysis develops “Policy” case simulations and the model calculates an optimized projection of what capacity is needed as the Climate Act policy is implemented. The presentation described 27 different policy case scenarios that covered a wide range of different possible outlooks for the future.  For example, they included two different low load projections for the future that, not surprisingly, were predicted to need much less future generation capacity.  Scenarios to consider increased imports from Canada, different cost projections for wind and solar capacity, changes in nuclear retirements, and lower hydro output were also included.  In addition, there were six scenarios that considered different future projections for DEFR were included. 

In response to a request from the EPSWG three DEFR build types were addressed:

  • High Capital, Low Operating (HcLo)
  • Medium Capital, Medium Operating (McMo)
  • Low Capital, High Operating (LcHo)

As has been the case for all the other analyses to date, these build types are only proxies for what could happen if a DEFR were to be developed with the identified characteristics. The authors chose three cost and operational profiles to show what kinds of DEFR would be built.  These build types were included so that the capacity expansion model can provide solutions to load requirements and build resources if they are economic to build using the assumed characteristics.

What the Experts are Saying

The following two slides from the presentation are the focus of my claim that the experts are warning there are problems with the New York transition to net-zero.  The first slide describes one of the policy case scenarios in the analysis described above.  I have highlighted one of the caveats: Significant uncertainty related to cost / availability of DEFR technologies, as well as regulatory definition of “zero-emissions” compliant technologies.

Figure 1: NYISO System & Resource Outlook Update Dispatchable Emission Free Resource (DEFR) Scenario Description in March 24, 2022 Presentation to EPSWG.

The following DEFR capacity expansion scenarios slide describes the assumptions used for five different scenarios.  I have highlighted the note: Assumption included in the scenarios are not an endorsement or estimate of the validity of the values modified. Some scenarios do not represent realistic system performance but are helpful in identifying directional impacts and sensitivity to key variables.

Figure 2: NYISO System & Resource Outlook Update Dispatchable Emission Free Resource (DEFR) Scenario Description in March 24, 2022 Presentation to EPSWG.

Experts from the NYISO, the organization primarily responsible for keeping the lights on, said there is “Significant uncertainty related to cost / availability of DEFR technologies, as well as regulatory definition of “zero-emissions” compliant technologies” and that “Some scenarios do not represent realistic system performance but are helpful in identifying directional impacts and sensitivity to key variables”.  For people familiar with the jargon and the electric system these are red flags.  Let me unpack the statements for everyone else.

Dispatchable emissions free resource technologies do not exist at this time to provide power for the long-duration periods when wind and solar resources are expected to provide minimal generation.  This kind of technical report says “significant uncertainty” because they can’t flatly say “we don’t think this will occur”.  Because they don’t think there is a resource that will be available, they certainly can’t guess a cost.  A scenario that does not represent “realistic system performance” pretty clearly says that we cannot expect the system to perform as needed with the scenario’s resources.  This is as close to telling the Climate Action Council that their “plan” to go to zero emissions by 2040 is not going to happen as it gets without actually explicitly saying that.  In a perfect world an “independent” organization would just tell it like it is, but this is the state of New York so politics color everything including the future of the electric system.

Furthermore, during the presentation discussion the point was made that the capacity projected numbers indicate an enormous amount of generation is needed. That result was described as just “stunning”.  Someone asked whether anyone on the Council is looking at what this means.  These experts are clearly worried about the enormous resources that have to be built to meet to transition the New York electric grid to a net-zero.  That concern is above and beyond my concern about DEFRs.

There is one other aspect of the first statement that needs to be addressed.   The reference to the “regulatory definition of ‘zero-emissions’ compliant technologies” is included because the Climate Action Council has not defined what is meant by “zero-emissions”.  Several of the most vocal members of the Council believe that zero-emissions means no combustion and are determined to impose that restriction.  All of the New York analyses that have tried to project what types of generation and how much from each type will be needed for the future net-zero electric system have included combustion generation using hydrogen or renewable natural gas.  The leaders of the Council have not had the courage to tell the members who have no reliability responsibilities and little relevant expertise “Sorry, even if we combust those arguably zero-emission fuels, there still are great risks to a feasible system that is reliable.  If we don’t use them the feasibility risks are so high that the system will be unreliable”.


The NYISO capacity expansion modeling has been forced to be consistent with the Draft Scoping Plan by using DEFR technology and building enormous amounts of generating capacity.  The capacity resource modeling is based on what is needed to keep the lights on rather than whether dispatchable emissions-free resources that provide those resources will actually be available.  The authors of the report essentially say that they don’t think DEFR technologies will be available but I don’t think the message is blunt enough to force the Climate Action Council to respond.

Not so long ago the idea that natural gas could be used a bridge fuel until these aspirational dispatchable emission-free resources could be tested at the scale needed, perform like a natural gas fired generating unit, and provide power at a similar cost, was generally accepted as a rational approach. The analogy for skipping the need for a bridge fuel is that proponents want to jump out of a perfectly good airplane without a parachute because they assume that the concept of a parachute will be developed, proven technically and economically feasible, and then delivered in time to provide a soft landing.  That cannot end well and this won’t either.


Roger Caiazza blogs on New York energy and environmental issues at Pragmatic Environmentalist of New York.  More details on the Climate Leadership & Community Protection Act are available here. This represents his opinion and not the opinion of any of his previous employers or any other company with which he has been associated.

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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