Climate Act Misinformation: Renewable Energy Reliability Risks

If you read this blog regularly you know that one of my persistent topics addresses the myth that the transition to the net-zero Climate Leadership and Community Protection Act (Climate Act) mandated targets relying on intermittent wind and solar resources has no potential reliability issues.  I have a long list of other potential topics to discuss but given its importance and the recent publication of a relevant blog post, I am going to try again to explain the reliability challenges embedded in the Climate Act implementation plans.   In particular I am going to call your attention to two recent blog posts The Penetration Problem Part I: Wind and Solar – The More You Do the Harder it Gets and The Penetration Problem Part II: Will the Inflation Reduction Act Cause a Blackout?.  This post excerpts some of the key points and explains the context relative to New York’s implementation plans.

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 submitted comments on the Climate Act implementation plan and have written extensively on New York’s net-zero transition because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that this supposed cure will be worse than the disease.  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 Implementation 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 tried to quantify the impact of the strategies.  That material was used to write a Draft Scoping Plan that was released for public comment at the end of 2021. The Climate Action Council states that it 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 concern about misinformation arises from the response to stakeholder comments.  The leadership of the Climate Action Council has overly emphasized responses to comments by the Climate Justice Working Group and certain members of the Council itself.  Because the favored few members were appointed to their positions because of their ideological opinions and not their technological expertise the over-arching legal mandate to provide input to the Scoping Plan that “shall inform the state energy planning board’s adoption of a state energy plan” has suffered.  The Climate Act has always been more about the politics than reality and the politicians who are driving this process naïvely believe that the technology needed is only a matter of political will.  Many of the appointed ideologues also ascribe to that view, and some of the more vocal members of the Council have downplayed reliability as a concern going so far to claim that those concerns are misinformation.  I believe there is no greater example of actual misinformation than the claim that there are no risks to reliability inherent in the net-zero transition plan described in the Draft Scoping Plan.

Reliability Concerns

I have previously written that the Climate Action Council has not confronted reliability issues raised by New York agencies responsible for keeping the lights on.  The first post (New York Climate Act: Is Anyone Listening to the Experts?) described the New York Independent System Operator (NYISO) 2021-2030 Comprehensive Reliability Plan (CRP) report (appendices) released late last year. The second post (New York Climate Act: What the Experts are Saying Now) highlighted results shown in a draft presentation for the 2021-2040 System & Resource Outlook that all but admitted meeting the net-zero goals of the Climate Act are impossible on the mandated schedule.  Recently I wrote about the draft of the 2021-2040 System & Resource Outlook report described in the previous article and the concerns raised.  Another post detailed the differences between the Resource Outlook and the Draft Scoping Plan Integration Analysis and recommended that those differences be reconciled in a public forum.  Most recently, I explained why the response to the reliability concerns to date has been even worse than I imagined possible.

There was never any response to my suggestion early in the process that everyone associated with the Climate Act transition get a briefing to explain how the electric grid works and highlight potential issues associated with the net-zero transition. As an example of potential topics I referred to the renewable energy systems page that I maintain.  The page provides links to posts that I recommend that anyone who is interested in researching the story behind the complexities of the energy system and relying on renewable wind and solar energy read.  All of the relevant articles by the author of the recommended articles are referenced there.

Retired registered Professional Engineer Russell Schussler writes under the pen name Planning Engineer at Judith Curry’s blog Climate Etc He initially wrote under a pseudonym so that his comments would not be taken as representing his employer.  He continues to use it there because he is well known at the website and he believes his ideas should stand on their own merits, not on claims of expertise.  He hasa BSEE is from The Ohio State University and a Masters of Electrical Engineering from University of Southern California. He worked in generation and transmission for over 30 years for different sized utilities, participated and held leadership roles in various research groups and reliability organizations before his retirement.

In the articles listed above I repeatedly tried to explain the risks inherent in the Draft Scoping Plan reliance on intermittent wind and solar.  I believe the Planning Engineer’s expertise and more accessible writing style makes a better case than I have to date so this post describes his concerns.

Wind and Solar – The More You Do the Harder it Gets 

In the first post Schussler explains:

There seems to be a belief that increasing the level of wind and solar projects will make subsequent progress with these resources easier. Nothing could be further from the truth.  Increasing penetration levels of wind and solar is like a Sisyphean task, except that it is worse. The challenge may be better understood as akin to pushing a huge rock which is getting heavier and heavier, up a hill of a steeper and steeper slope while the ground below gets slicker and more unstable. The problems associated with increased penetration swamp any potential benefits that might be achieved through economies of scale. 

He provides eight reasons why “increasing the penetration levels of renewables will lead to rapidly increasing costs as well as rapidly decreasing reliability”.   I have annotated my New York centric concerns relative to the Draft Scoping Plan to the list of his challenges below.  For further information I refer you to the original article.

Wind and solar do not readily supply essential reliability services. 

The Draft Scoping Plan does not consider these ancillary services in any meaningful way.

Wind and solar are intermittent resources and their availability/output often does not match or support system needs.

The New York Independent System Operator (NYISO) 2021-2040 System & Resource Outlook projected resources necessary to match system needs are significantly different than the resources in the Draft Scoping Plan.  There is no indication of any urgency to resolve those differences.

The success of wind and solar installations is highly location specific.

This is a particular concern for New York solar resources.  New York is not only a high latitude state with weaker winter insolation and shorter days but large portions of the state have high wintertime snowfall and cloudiness due to the Great Lakes.

Wind and solar depend on materials which must be mined and their ability may be limited.

The Draft Scoping Plan calculates life-cycle impacts for anything related to fossil fuels but ignores all life-cycle impacts for “zero” emission wind and solar components.

As wind and solar generation increase penetration it will become more and more challenging for other resources to subsidize their expansion.

The Draft Scoping Plan ignores this issue.

It takes a lot of energy to build wind and solar facilities.

The Draft Scoping Plan ignores this issue.

Wind and solar make the study, control and operation of the power system more complicated and uncertain.

The Draft Scoping Plan ignores this issue.

Widespread deployment of wind and solar would require that power be transmitted across great distances (or you would need an unrealistic and incredible amount of battery storage.) 

Th NYISO resource outlook raises transmission concerns but the Draft Scoping Plan ignores the issue.

Schussler talks about how the challenges might be overcome.  He argues that “it’s hard to imagine that any economies of scale would allow these resources to leap the formidable challenges” and that “it does not appear that significant improvements in economies of scale are to be expected”. He points out that nuclear energy could be a piece of the net-zero transition because none of the challenges apply.  Unfortunately, even though hydro is zero-emissions and works well with the power system, there are “negligible to no potential locations to expand hydro generation”.

He concludes:

It is way too soon to be envisioning a 100% renewable future with significant contributions from current wind and solar capabilities. It is not a good strategy to support current “green” technologies and retire and prohibit conventional generation hoping that a miracle will occur when we need it. Perhaps with the extensive deployment of nuclear power, carbon capture and other technologies we might be able to approach a zero-carbon grid. At best, current wind and solar technologies will play at most a small part in such a plan.

Will the Inflation Reduction Act Cause a Blackout?

The second post could have been renamed “Will the Climate Act cause a blackout” because the issues raised are directly applicable to the New York net-zero transition.  Schussler sums up the challenge:

Replacing conventional synchronous generating resources, which have been the foundation of the power system, with asynchronous intermittent resources will degrade the reliability of the grid and contribute to blackout risk. The power system is the largest, most complicated wonderful machine ever made. At any given time, it must deal with multiple problems and remain stable. No resources are perfect; in a large system you will regularly find numerous problems occurring across the system. Generally, a power system can handle multiple problems and continue to provide reliable service. However, when a system lacks supportive generation sources, it becomes much more likely it will not be able function reliably when problems occur.

I like his description of the cumulative effects of adding renewable resources:

Just as a pile of dry wood and flammable material can be sparked from many potential sources, or a very unhealthy person could succumb to many different threats, a weakened power system is more vulnerable to many conditions than a robust one. In this post I discussed responsibility for the Texas winter blackout. Many things went wrong that day in Texas. But often many things do go wrong – the real problem was that the Texas market did not provide incentives for standby resources.  In Texas there were not enough committed resources to provide for the system load levels and potential contingencies. Texas relied on an energy market designed to favor wind and solar resources and it failed them. However, many analyses of the Texas blackout focused on the proximate conditions (problems of the sort that are common) ignoring or denying the major underlying problem.

Heat Pumps

One of the key Draft Scoping Plan emissions reduction components for buildings is electrification of the heating system using heat pumps.  Schussler describes electric system issues with heat pumps as the number of heat pumps increased.  The argument in favor of heat pumps is that they are more efficient producing heat because they move energy rather than create it.  In his description of the technology, he states that:

Because of their behavior at colder temperatures, heat pumps are not appropriate for all parts of the country. In the north the many hours they would have to run with resistance heat makes them both environmentally irresponsible and too expensive. Natural gas is a better option. 

I think this is a fundamental problem in the Climate Act.  In their zealous pursuit of zero risk, they are foisting technology upon the citizens of the state that is not appropriate.  Of course, they have an answer: “In all scenarios electric heat pump space heating technologies are predominantly cold climate air source heat pumps (ASHPs) with electric backup and a significant role for ground source heat pumps (GSHPs)”.  I submitted 23 pages of comments on residential heating electrification and I argued that at many locations in the state all air source heat pumps will have insufficient energy to transfer and will require resistance heat backup.  The New York narrative is that they work in the Nordic countries where it is even colder so they should work in New York too.  Proponents neglect to point out that the reason they work there is that the housing units are smaller and much more energy efficient. 

The particular heat pump problem described by Schussler was that as more heat pumps were introduced the peak annual load shifted to the winter because during cold snaps inefficient electric resistance heating kicked in.  As a result, the electric system design requirements have to change and despite warning signs that this could be a problem, the resulting change in peak load requirements affected average energy costs.  He concludes this section noting that “While almost no one wanted to see it coming, once the effects hit, most everyone in the power supply chain wished they had. This was a terrible blow to rural electric cooperatives who had invested big to improve their load factor, only to find they had subsidized a worse winter load factor”.  Importantly, the same thing is coming to New York and someday down the road there will be unintended consequences.

Renewable Resources

Schussler goes on to discuss how the Inflation Reduction Act will enable blackouts by its encouragement of renewable resources. I believe New Yorkers can substitute Climate Act for Inflation Reduction Act to estimate impacts in the state:

The Inflation Reduction Act seeks to decarbonize the grid. In looking at the grid, you should not make one goal a priority but should instead seek to balance competing objectives. See Balance and the Grid for a discussion of how efforts to maximize one objective without due attention to other major goals can result in a worsening condition for all goals. It seems apparent that all the “green” measures in the Inflation Reduction Act were included because independently they all seem capable of reducing carbon. I have not seen any evidence that any consideration was given to system reliability or how these measures might interact to create problems.

Schussler then goes on to explain how the measures encouraged by the inflation Reduction Act, and Climate Act I believe, will lead to generic blackouts in many situations  He provides a specific prediction for the winter peak demand period: that I believe is applicable to New York:

Winter peaks can be extreme, much more so than summer peaks. As temperatures climb in the summer, air conditioners reach a saturation point. The climb in summer peak demand with each additional increase in temperature typically flattens out. In the winter each additional degree drop can increase demand more than the one before. There are a lot of potential sources of resistive heat that increase demand. In severe cold more and more heating elements come into play and the increase in demand rather than flattening can go up exponentially. Peak winter loads tend to hit just before sunrise. The system sees a rapidly rising peak, often described as needle shaped, which drops as the sun comes up and temperatures warm.  Such peaks can easily be 5 to 20% above normal winter peaks in many areas.   Thus, these conditions have the potential to cause more severe concerns than California sees during extreme summer conditions.

The Climate Act encourages and is projecting significant solar development.  Because the peak load is just before sunrise all this solar provides no support for the peak.  All the virtue-signaling homeowners with solar panels that have insufficient or no battery backup will not only be not providing any power but will be putting maximum demand on the grid.  He points out that “The infrastructure needs to supply a home which only puts a demand on the system a few hours a year concurrent with other uses maximum demand is basically the same as the infrastructure need to support a full requirements home.”  It is difficult for an electric rate structure to cover those system costs so either the needed infrastructure improvements are delayed or everyone else ends up subsidizing residential solar panel households.

Schussler also explains that wind resources are a problem too:

The Act encourages wind development. Like solar, wind will push other better suited resources out of the supply pool. Wind is generally slower just before sunrise and winter is not generally peak wind season. In any case wind is intermittent and some of the times during cold weather wind is not available. Some say that wind tends to rise up as temperatures get colder and there are ways to keep turbines from freezing,. Nonetheless, we do see freezing problems and a tendency for wind to be there is not a guarantee. Green resources perform much better in theory than practice. At least at sometimes wind power will not likely be a great asset during winter morning peaks demand conditions.

Another way to address this requirement is to encourage energy efficiency.  There is no question that this helps reduce load and, if the energy efficiency upgrades are consistent with the Nordic country requirements, then the amount of resistance heating necessary can be reduced.  Schussler points out some unintended consequences:

The Act encourages efficiency. This could help to reduce load and thereby make severe outages less likely. But the real problem with peak demand is the difference in demand during the extreme peak period and other more normal high load periods. If efficiency reduces load, you will likely see a reduction in generating resources to serve the load at all high load levels. The risk from peak conditions is more attributable to the delta between the winter peak demand and more common high load levels.  This is because regular loads drive generation additions more than extreme conditions. I don’t know that efficiency measures work better during the most extreme winter temperatures than it does at normal winter cold temperatures (probably less so), therefore its mitigating impact may be small to none. Also, there are those who might argue that consistent with Jevon’s Paradox efficiency efforts lead to increased energy consumption. The basic mechanism, behind this counterintuitive theorem, is illustrated by mechanisms observed such as   individual consumers with more efficient homes choosing to heat more rooms or increase comfort because you get more for your money in an efficient home.

On my long list of analyses that I would like to do is to compare the New York State Energy Research & Development Authority energy efficiency targets and goals with the actual observed improvements.  I have no reason to believe that they have ever come close to meeting their targets, in part, because of some the aforementioned issues.  As a result, I have no reason to believe that New York will achieve the levels of energy efficiency necessary to meaningfully, much less eliminate, the effect of resistance heaters affecting the peak load.

Schussler summarizes this section:

The chart below shows the US typical resource generation by major energy source. Imagine how this chart will look as fossil fuel is phased out. Hydro only makes up about 6% of the mix and expansion there is limited. Nuclear could replace these resources but it is not great for ramping up and down to follow needle peaks. If wind and solar step up to replace fossil fuels this leave us vulnerable to energy shortages during winter peaks just before daybreak. Battery capability would need to be huge, expansive and probably would not be procured in advance of demonstrated needs.

Recall that New York’s residential heating electrification magical solution is cold climate air source heat pumps that allegedly extract energy for home heating on the coldest days.  New York’s answer to the resource requirements quandary is another magical solution: dispatchable emissions-free resources.  This is a resource that has all the electric grid capabilities of a fossil-fired power plant without the emissions.  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 uses “green hydrogen” as its placeholder for this resource and I addressed issues with that pipe dream in my comments on the Draft Scoping Plan.

Specific Blackout Prediction

Schussler lists the following set of conditions that he believes are inevitable in many areas including New York:

  • Very cold pre-dawn extreme temperatures
  • Backup quick start fossil fuel combustion turbines have been largely driven out of the resource mix,
  • Nuclear, hydro and battery resources are tapped out
  • Solar is absent from the distribution side and not available on the generation side
  • Wind may or may not be blowing
  • Heat pumps are operating maxed out in resistance mode, along with other resistive heating to drive system load to extreme heights
  • As with every power system there will be a few problems on the system
  • System will be forced to deliberately shed a lot of load or may go unstable and suffer crippling blackouts

Schussler emphasized this diurnal set of conditions.  I maintain that the ultimate problem with a net-zero energy system is that increased electrification will markedly raise loads during weather conditions that cause peak loads but also can have low wind and solar resource availability over extended periods.  I recently described a paper, Getting to 100%: Six strategies for the challenging last 10%, describes approaches for providing power during peak conditions that are not included in his analysis.  I believe that an extended period of low wind resources in the winter will exacerbate these conditions and tap out all the energy stored in batteries. 

Although New York is surrounded by other sources of electricity and most of the jurisdictions have not committed to either the renewable development targets or aggressive schedule of the Climate Act, there is a particular New York problem.  New York City is a load pocket and has specific reliability mandates that I believe will be violated in the scenario outlined.  That constraint exacerbates all the conditions.  The result will be another catastrophic New York City blackout.


Schussler offers some suggestions to avoid this worst-case outcome.  Unfortunately, New York’s Climate Act mandates and policy actions are working against every one of his suggestions.  I believe that the Climate Action Council naïvely believes that there isn’t a potential reliability issue and has resisted requests to confront the rationales for the differences between the Integration Analysis and the NYISO resource outlook.  An open and comprehensive resolution of those differences should be done before the Scoping Plan is finalized but I have seen no indications that will be done.

To paraphrase Schussler: “The Climate Act is promoting a system with less stability, robustness and reliability”.  I cling to the hope that somebody will step up and be responsible enough to address the reliability concerns described so well by Mr. Schussler.  Unfortunately, I am not optimistic because the Hochul Administration has to this point refused to even address the claims of Climate Action Council members that argue that anyone suggesting there are reliability threats in an electric system that relies on renewable energy is misinformation.  That claim is just wrong and is the real misinformation.

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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