Climate Act Draft Scoping Plan Hydrogen Comment

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.  Long-duration, dispatchable, and emission-free resources will be necessary to maintain reliability and meet the objectives of the Climate Act. This article describes my comments on the plans to use hydrogen to fulfill this requirement 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.   This page documents all the comments that I submitted as part of the Climate Leadership and Community Protection Act implementation process. 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.


My comment addresses the use of hydrogen in some form or other as the Draft Scoping Plan placeholder technology for the Zero-Carbon Firm Resource or Dispatchable Emissions-Free Resource (DEFR) generally accepted as a complementary requirement when intermittent resources like wind and solar make up a significant portion of the electric grid resource mix.   Energy storage is required for intermittent resources but the cost for exclusive reliance on batteries is unacceptably high.  These resources are included to maintain reliability when the wind does not blow and the sun does not shine for long periods.  I concluded that the Final Scoping Plan has to do a much better job documenting the use of hydrogen for this resource to be considered credible. 

My comments summarize background information in the Draft Scoping Plan and from the New York Independent System Operator (NYISO).  I describe the Integration Analysis description of the Carbon-Free Electric Supply and the hydrogen costs provided in an Integration Analysis spreadsheet.  I also describe the on-going NYISO update to their System and Resource Outlook that addresses DEFR.  I used Francis Menton’s article, Hydrogen Is Unlikely Ever To Be A Viable Solution To The Energy Storage Conundrum, as the outline for the comments.  Mr. Menton graciously gave me permission to use his material freely, aka plagiarize his language.   

The NYISO Power Trends 2022 report sums up the challenge: “Long-duration, dispatchable, and emission-free resources will be necessary to maintain reliability and meet the objectives of the CLCPA. Resources with this combination of attributes are not commercially available at this time but will be critical to future grid reliability.”  The Draft Scoping plan speculates without sufficient justification that the “zero-carbon firm resource” projections for the future can be met using hydrogen in one form or another.  My concern is that the Plan does not provide enough reliable documentation to support the speculated use of hydrogen as the technology for this critical resource.  The comments describe specific issues that need to be explicitly addressed in the Final Scoping Plan if the Climate Action Council is to make a compelling argument that this technology will keep the lights and heat on when needed most.

The Draft Scoping Plan calls for the use of so-called “green hydrogen” whereby hydrogen is produced by a carbon-free process of electrolysis from water.  The first probem is that the costs for hydrogen produced using this technology are entirely speculative and by any reasonable basis of estimation will be extraordinaly high.  Compared to the cost of production using natural gas natural gas to produce hydrogen, “green” hydrogen will be more than five times more expensive.

I used a Seeking Alpha analysis to estimate the hydrogen needed if it was combusted to make electricity or used to power fuel cells.  For the NYISO and Integration Analysis scenarios I found that between 73 and 155 turbines sized at 288 MW would have to be dedicated for this resource application.  At this time the world’s largest hydrogen fuel cell is only 79 MW so between 266 and 566 fuels cells of that size would be required.

My analysis calculated the generation energy needed for electrolysis to support DEFR projections.  Scoping Plan Scenaro 2 requires 3,342 GWh of energy for DEFR and 12,812 GWh for electrolysis to produce the hydrogen to cover that requirementwhich is about half the projected imported wind total in 2040.  The Draft Scoping Plan emphasizes the use of solar over wind and it appears that the electrolysis requirements are covered by the solar generation projections.  Importantly, the NYISO draft Outlook Study projected DEFR requirements are an order of magnitude higher than the mitigation scenarios.  As a result, the energy needed for the hydrogen to cover that need (130,353 GWh) is more than the projected total solar, land-based wind, and wind import energy  (121,875 GWh) in 2040.  The Climate Action Council must reconcile the differences between these two estimates because of the ramifications on the energy needed for DEFR using green hydrogen.

The difference in projections also exacerbates the problem associated with the critical winter-time wind lull DEFR condition problem.  The mitigation scenarios call for much more solar capacity (43,432 MW) than the combined land-based wind, imported wind, and offshore wind (26,606 MW) capacity.  The Final Scoping Plan must ensure that an adequate amount of hydrogen is stored before the winter because the solar resource is so poor in the winter that it is unlikely that much, if any, replenishment during the winter can be expected.  It is also critically important that the worst-case wind lull is defined correctly because it if is not then there will not be sufficient hydrogen available to cover the DEFR resources and blackouts will occur.  The Climate Action Council must ensure the Final Scoping Plan addresses both of these issues to ensure a reliable electric system when it is needed the most.

There is a clear need for a feasibility analysis for the use of hydrogen as the DEFR.  For example, where will all the combustion turbines, electrolyzers, and fuel cells be located?  I suspect that there will be significant permitting issues with all the resources needed.  The capacity factors for this resource in the Draft Scoping Plan are 2% for all mitigation scenarios so there will be implentation issues.  In the exisitng system the generating sources designed for peaking power for this reliability requirement used the cheapest technology available (simple-cycle gas turbines) and a significant portion of the backup capacity is met by residual oil burning power plants.  Meeting this requirement in the future using the hydrogen DEFR resource will be using the most expensive generating technology available. 

There are numerous technical concerns that were not addressed in the Draft Scoping Plan. It is not clear whether the Draft Scoping Plan addressed the complex and energy intesive process of  compressing and liquifying hydrogen for storage and transport.  That will require large amounts of additional energy which may be additional cost not yet figured into the calculations.   I could not determine if the Draft Scoping Plan proposed to use the existing natural gas network in all or part.  Metal embrittlement caused by exposure to hydrogen will no doubt require major modifications and replacements for the existing infrastructure.  These costs must be clearly identified and  included in the Draft Scoping Plan.


There are members of the Climate Action Council that believe “the word reliability is very intentionally presented as a way of expressing the improper idea that renewable energy will not be reliable.”   The worst-case renewable availability period is expected to occur in the winter because solar resource availability is low because of the season, Great Lakes induced cloudiness, and the potential for snow on solar panels when there is a wind lull reducing that resource availability.  This is the particular period when the zero-carbon firm resource will be needed most.  The problem is exacerbated because those conditions are typically associated with the coldest weather of the year.  When the state’s heating and transportation systems convert to electricity the expectation is that maximum loads will occur during those periods.  These comments describe many implementation issues associated with using hydrogen for the zero-carbon firm resource not the least of which is using mostly solar PV as a dedicated source of the electrolyzer power.  I conclude that a feasibility analysis that address the questions raised is necessary.  Even better would be a demonstration project at large scale to show how a hydrogen-based power system would work and how much it would cost after including all of the extras and current unknowns not just for producing it but also for transporting it and handling it safely. 

I don’t know how much extra our energy would cost if we forcibly got rid of all hydrocarbons and shifted to wind and solar backed up by “green” hydrogen — and neither does anybody else.  An educated guess would be that the all-in cost of energy would get multiplied by something in the range of five to ten.  Yes, that would probably be a big improvement over trying to accomplish the same thing with batteries.  But it would still be an enormous impoverishment of the New Yorkers in the pointless quest to possibly shave a few hundredths of a degree off world average temperatures a hundred years from now.  

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 the Climate Action Council wants 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.

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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