The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050. This article describes the comments I submitted to the Climate Action Council describing the differences between the projections for future electricity generation by the New York Independent System Operator (NYISO) and those in the Draft Scoping Plan.
Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies. I have written extensively on implementation of New York’s response to that risk because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that it will adversely affect reliability, impact affordability, risk safety, affect lifestyles, and will have worse impacts on the environment than the purported effects of climate change in New York. New York’s Greenhouse Gas (GHG) emissions are less than one half one percent of global emissions and since 1990 global GHG emissions have increased by more than one half a percent per year. Moreover, the reductions 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.
Climate Act Background
The Climate Act establishes a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”. They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council. Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies. That material was used to write Draft Scoping Plan that was released for public comment at the end of 2021. The Climate Action Council will revise the Draft Scoping Plan based on comments and other expert input in 2022 with the goal to finalize the Scoping Plan by the end of the year.
The key point is that the Scoping Plan “shall inform the state energy planning board’s adoption of a state energy plan” but the Climate Action Council membership is generally lacking the background, experience, and education to decide technical matters such as the fuel mix of the future generating system. Thomas Sowell said “It is hard to imagine a more stupid or more dangerous way of making decisions than by putting those decisions in the hands of people who pay no price for being wrong”. Therefore, my comments explained why I believe the differences between the Draft Scoping Plan and the NYISO have to be addressed in a public forum.
Summary
The New York Independent System Operator (NYISO) is currently (June 6, 2022) updating its System and Resource Outlook. The last Outlook Study Status presentation (April 26, 2022) noted that the draft report will be issued in June 2022. One of the supporting documents for this study is the Capacity Expansion Zonal Results Analysis spreadsheet. The projected new generating resources in the preliminary modeling results are different than the capacity additions in the Draft Scoping Plan Integration Analysis. The projection for future generation capacity and energy for the baseline case with a forecast for Climate Act is shown in the following table.
The Draft Scoping Plan Appendix G: Integration Analysis Technical Supplement “summarizes, reports, and documents the findings, results, and methodology of the Integration Analysis developed to support the Climate Action Council in its development of the Draft Scoping Plan pursuant to the Climate Act”. For this analysis I relied on data in the Appendix G: Annex 2: Key Drivers and Outputs spreadsheet. The following two tables list the installed capacity and annual generation for the three mitigation scenarios in the Draft Scoping Plan.
The capacity (MW) and generation (GWh) for the NYISO outlook study baseline with CLCPA case forecast scenario and integration analysis mitigation scenarios were combined in a spreadsheet and a table that is too large to include in this article. The point of my comment was that although the total generation capacity is pretty close between the analyses, the Climate Action Council and the NYISO have to reconcile four significant differences in the projections. The NYISO analysis projects dispatchable emissions-free resources capacity on the order twice as much as the three Integration Analysis mitigation scenarios. The NYISO analysis projects land-based wind capacity development about three times larger than the three Integration Analysis mitigation scenarios. The NYISO analysis projects off-shore wind capacity about 50% less than the three Integration Analysis mitigation scenarios. The NYISO analysis projects that solar will provide about one tenth the projected capacity of the three Integration Analysis mitigation scenarios.
Conclusion
The NYISO presentation notes that their study should be finalized this summer: “July 2022: Seek Board of Directors review and approval”. I believe that it is important that when the NYISO report and projections are finalized the differences between the Integration Analysis and this report are reconciled.
At one of this year’s Climate Action Council meetings, I believe the idea of workshops to consider specific issues as suggested. I think this would be an ideal candidate topic for just such a meeting. In the first place there is a clear need to determine which analysis should be the primary driver for the ultimate energy plan. In addition, this workshop could also include sessions to address other reliability issues.
Pragmatic Environmentalist of New York 