Draft Scoping Plan Electric System Comments

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.  In response to the request for comments on the Draft Scoping Plan I submitted 26 comments on specific issues primarily related to subjects raised at this blog before the end of the comment period on July 1.  This article sums up the comments I submitted related to the electric system.

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 electric system  comments addressed a few Draft Scoping Plan electric system issues. This is one of the topics that I did not address all the things that I thought needed to be raised.  I just ran out of time.

I believe that the ultimate problem is that the Climate Act presumed that converting the electric grid from its current reliance on fossil fuels to provide reliable electricity when needed most was just a matter of political will.  However, the New York Independent System Operator (NYISO) Power Trends 2022 report notes: “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 projects that the long-duration, dispatchable, and emission-free resource capacity requirement is about the same as the current fossil-fired generating capacity.  This is an enormous challenge and the cavalier way it is addressed in the Draft does not inspire confidence that the Integration Analysis electric system projections are viable.

Capacity Costs

I estimated the costs for the projected generating capacity described in the Draft Scoping Plan Integration Analysis.  I used the following sources of data to calculate the capital costs for the generating capacity (MW) additions projected in the Draft Scoping Plan.  The Integration Analysis lists projected installed capacity values for 2020 and for the Reference Case and Scenarios 1-4 for 2040 in the IA-Tech-Supplement-Annex-2-Key-Drivers-Outputs spreadsheet.  My primary source for cost information was U.S. Energy Information Administration (EIA)  Cost and Performance Characteristics of New Generating Technologies, Annual Energy Outlook 2022.   EIA does not provide costs for hydrogen electrolyzers so I used data in the “Hydrogen” tab in the IA-Tech-Supplement-Annex-1-Input-Assumptions spreadsheet for electrolyzers, infrastructure, and transportation.  The input data, calculations and results are included in the attached Caiazza Electric System Comment Spreadsheet

Although my estimate of the overnight cost to develop the resources needed to transition to a zero-emissions electric system in 2040 are generally consistent with the Appendix G Figure 48 net present value of system expenditures, there are differences.  I estimate that the Reference Case capital costs are only $82.5 billion and that the mitigation scenarios range from $220 billion to $400 billion. That difference is undoubtedly due to what resources are in the Draft Scoping Plan Reference Case that I excluded because they are not business-as-usual. 

I compared the capital costs (2020 $/kW) in the IA-Tech-Supplement-Annex-1-Input-Assumptions spreadsheet Resource Costs tabs against the EIA Table 1: Cost of new central station electricity generating technologies.  Table A-3 in Addendum 1 shows that with the exception of the capital costs for large hydro and a gas-fired combined cycle unit in Upstate New York all the other technology costs are lower and, in some cases, much lower in the Integration Analysis.  Table 1 lists the percentage difference between Integration Analysis (IA) and comparable Energy Information Administration (EIA) estimates for New York City and Long Island (NYCW) and Upstate New York (NYUP).  If my comparison interpretation is correct then these differences are outrageous.  The capital costs for offshore wind are half of the EIA costs.  While there may be some interpretation of the battery energy storage cost that can explain why EIA costs are five times higher, I don’t think there is any interpretation issue with the hydrogen fuel cell technology that is five times higher in New York City and four times higher Upstate.  The Climate Action Council must explain why the Draft Scoping Plan numbers are so high for these technologies.

Table 1: Percentage Difference Between Integrated Analysis Base Capital Costs and EIA  Cost and Performance Characteristics of New Generating Technologies, Annual Energy Outlook 2022 Costs

The Draft Scoping Plan does not provide sufficient documentation to reconcile all the differences.  My estimates only include the capital costs for the projected generating resources and do not include transmission ancillary services that must be included for a true estimate of the total costs to go to zero-emissions generation.  In order to fully predict the costs of the Scoping Plan, the Climate Action Council should insist that the authors of the Integration Analysis provide more detailed explanations.

Reference Case Misdirection

The Integration Analysis that provides the numbers used in the Draft Scoping Plan misleads readers with its definition of the Reference Case.  Policy modeling like this compares projections for future mitigation scenarios against a business-as-usual case future projection.   The definition used in the Integration Analysis “includes a business-as-usual forecast plus implemented policies”.  The Climate Act mandates “9 gigawatts (GW) of offshore wind electric generation by 2035”.  I believe it is unacceptable to include those resources in the Reference Case. In my benefits are greater than costs comment I showed that the after correcting for other improperly categorized sectors from this mis-leading approach projects net-zero transition costs are between $295 billion and $316 greater than the benefits but the cost numbers in these comments show that the costs are increased to between $363 and $372 greater than the benefits.  The Climate Action Council should insist that the Final Scoping Plan describe all the control measures, provide the assumptions used for the strategies, the expected costs and expected emission reduction for each measure for the Reference Case, the Advisory Panel scenario and the three mitigation scenarios.  Then the public would be able to decide for themselves which costs associated with “already implemented” programs are appropriate. 

Retirement Sleight of Hand 

In a different comment I showed that the Integration Analysis incorrectly assumed that no wind, solar, and energy storage projects would reach their end of useful life and thus not have to be replaced between before 2050. In this comment I quantified costs associated with that approach.  I showed that in 2040 incorporating retirements would increase costs by at least 6%.  However, costs jump considerably when costs to 2050 are considered.  For example, my projected cost for Scenario 4 in 2040 is $399,530 million but the cost to replace all the equipment that ages out between 2020 and 2050 is $304,428 million.  I also showed that the biomass and wind capacity factors are biased high.  The observed statewide average wind capacity is trending down since 2015 and that effect is not addressed in the Draft Scoping Plan.  The Climate Action Council should ensure that the Final Scoping Plan addresses these issues


The ultimate goal of the Scoping Plan is to inform the Energy Plan that is supposed to outline how New York state policy will guide future energy use.  Unfortunately, the Scoping Plan is just a list of policies that are projected to reduce emissions consistent with the Climate Act mandates.  There is no proof-of-concept feasibility analysis that shows how those policies will work together to provide reliable electricity to power the energy needs of the state.  The costs are hidden in a black box that only provides limited information. 

It will be fascinating to see how the Council responds to the requests for more information.  I hope that the Council will insist that the final iteration of the Integration Analysis will be compatible with the projections and analysis performed by the NYISO and others.  Failure to do so will not end well.

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 (https://pragmaticenvironmentalistofnewyork.blog/) reflects that outlook. The second blog addresses the New York State Reforming the Energy Vision initiative (https://reformingtheenergyvisioninconvenienttruths.wordpress.com). 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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