Climate Act Comparison of Generating Resources: Integration Analysis Mitigation Scenarios vs. NYISO Resource Outlook

At the October 25, 2022 Climate Action Council meeting Carl Mas compared the New York Independent System Operator (NYISO) 2021-2040 System & Resource Outlook and Integration Analysis generating resource projections for the net-zero transition plan required by New York’s Climate Leadership and Community Protection Act (Climate Act).  I have long advocated for such a comparison but I remain concerned that this is more of an empty gesture than the start of an open and transparent comparison and discussion of the implications of differences in the projections.

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 do more harm than good.  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.


The implementation for the New York’s Climate Act “Net Zero” target (85% reduction and 15% offset of emissions) by 2050 is underway.  The Climate Action Council has been working to develop plans to implement the Climate 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 for public comment.  Since the end of the public comment period in early July 2022 the Climate Action Council has been addressing the comments received as part of the development of the Final Scoping Plan that is supposed to provide a guide for the net-zero transition.

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 only token response was a special speaker’s session for reliability on August 2, 2021 where six speakers discussed  their concerns. Because subsequent analyses have raised issues, I published four more articles on this topic.  The first post (New York Climate Act: Is Anyone Listening to the Experts?) described the NYISO 2021-2030 Comprehensive Reliability Plan (CRP) report (appendices) released late last year and the difficulties raised in the report are large. 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 “For discussion purposes only” draft of the 2021-2040 System & Resource Outlook report described in the previous article and the concerns raised.  Most recently I compared the NYISO Resource Outlook and Draft Scoping Plan Generating Resource Projections  and argued that they needed to be reconciled.  Fortunately, there was a request from the Council for a comparison and at the October 25, 2022 Climate Action Council meeting (presentation and recording) Carl Mas described the differences between the NYISO resource projections and his Integration Analysis projections.

Integration Analysis Update

At 48:20 of the meeting recording Carl Mas presents the comparison of the Resource Outlook and Integration Analysis mitigation scenarios.  The evaluation compared Integration Analysis (IA) mitigation scenario 2, Strategic Use of Low-Carbon Fuels with NYISO Resource Outlook Scenario 2 as shown in the following slide.  Outlook Scenario 2 is “most aligned” with Integration Analysis (IA) scenario 2.  Both analyses used the same load shapes and meet the Climate Act resource targets.  Even though Mas claimed that the results were “well aligned” there are some key model differences.  There are different assumptions, treatments of the electric system components are not the same, and imports are handled differently.  The IA scenario includes load that they think is needed to generate hydrogen needed for the dispatchable emissions-free resource requirement and the NYISO analysis does not. 

The 2030 comparison of results discussion starts at 53:00 of the meeting recording. Mas claims that the results of the two analyses are largely the same.  His standard for agreement is that the directionality is the same and that the results are the same order of magnitude.  In my opinion that is a pretty low bar.  While I agree that the overall agreement is encouraging, I also think that the devil is in the details.  Both analyses agree that Dispatchable Emissions-Free Resources (DEFR) are a necessary component of the zero-emission electric system of the future.  I will address specific differences in the next section.

The 2040 comparison of results discussion starts at 55:35 in the video recording.   Again, Mas claimed that the results are largely the same.  During the question-and-answer session, Robert Howarth asked about the relative capacity to generation differences.  Specifically, the NYISO capacity is greater than IA capacity but the NYISO generation is smaller than the IA generation.  Mas said that they were still trying to figure out the difference but thought that curtailment was a factor.  Because the NYISO analysis uses a more detailed transmission simulation their projections factor in more situations where the transmission system is unable to get the renewable generation where it is needed when it is needed.  As a result, more capacity has to be built to ensure reliability.

Dennis Elsenbeck suggested that Mas and his modeling team work with the NYISO modelers to produce as joint reconciliation statement.  Mas said that they will be engaging with the NYISO in the coming years but did not promise to reconcile all the differences.  I will note some particular issues that I believe need to be reconciled and questions that I would like answered by both modeling teams in an open, transparent, and documented manner.

Comparison of Scenarios

The following table lists the data for the two NYISO Outlook scenarios and Integration Analysis Scenario 2, Strategic Use of Low-Carbon Fuels that I believe were used to produce the graphs.  Per usual Mas has not documented the numbers in the graphical presentations so I am assuming that there have been no changes to the Integration Analysis numbers since the last update.  I have provided the spreadsheet that I used to prepare this table and the input data extracted from the NYISO and Integration Analysis spreadsheet used.  In my last post on this topic, I described each of the resource categories in the table.  I am not going to repeat my description of the differences I noticed but will only address differences in the resource categories discussed at the Council meeting.

Mas thinks that the reason for fossil generation differences between NYISO Outlook Scenario 2 and the Integration Analysis Scenario is because NYISO treats the fossil resources differently.  The Integration Analysis scenario considers the strategic use of low-carbon fuels, but NYISO does not assume that existing power plants will use alternate fuels in 2040.

In my opinion low-carbon fuel is the crux of an issue raised by Gavin Donohue.  Donohue argued that the DEFR technologies cannot be evaluated until the Public Service Commission defines what fuels can be used and whether any fuel can be combusted.  There are members of the Council that believe that combustion is outlawed in the Climate Act but the Council has not made a decision about a recommendation.  I agree with Donohue that this should be decided sooner rather than later.

Mas noted that the Integration Analysis used higher capacity factors for wind and solar resources than the NYISO used.  The following table compares the capacity factors for the resources.  I have calculated New York land-based wind capacity factors since 2006 based on NYISO data.  I agree with the NYISO 2019 capacity factor of 25% but the 2020 Integration Analysis capacity factor of 28.6% does not agree with the observed capacity factor of 23.9%.  In fact, it is 19.3% higher than the observed value.  Note that I submitted a comment that argued the land-based wind capacity factors were biased high and recommended that the final scoping plan correct that bias.  There never has been any acknowledgment of that comment or anything related to the Integration Analysis itself at the Climate Action Council meetings.  Dennis Elsenbeck asked if there was data available from existing systems because of the dangers that the data might not confirm the projections.  Based on this, the answer is the data are being ignored and that means how can the Scoping Plan be finalized if there are errors in the Integration Analysis?

There are differences in the renewable resource category projections between the NYISO Outlook and the Integration Analysis scenarios.  In my opinion, the overview discussion of results did not satisfactorily address the significance of these differences and the potential that they could represent feasibility implementation problems.

In the land-based wind (LBW) resource category, the NYISO Outlook scenarios both project 19,087 MW in 2040 but the Integration Analysis projection is only 12,242 MW (>35% different).  That could be related to the unrealistic capacity factors the Integration Analysis used but it may also be related to the relative weighting of land-based and offshore wind.

The NYISO production resource model apparently does not think that offshore wind is a cost-effective option because both scenarios do not increase the projected capacity significantly beyond the Climate Act mandate of 9,000 MW.  On the other hand, the Integration Analysis scenarios nearly double the amount of offshore wind resources projected.   Overall, the NYISO Outlook offshore wind capacity is 40% lower than the average of the Integration Analysis scenarios and generation is 43% lower. 

In the solar resource discussion, Mas explained that the difference between the Integration Analysis and NYISO Outlook Scenario 2 solar implementation transition was that the Champlain Hudson Power Express transmission line implementation was handled differently.  As a result, more solar was added earlier in the Integration Analysis.  The final resource allocation was the same.  However, he did not address the fact that NYISO Outlook Scenario 1 is significantly different than all the other projections.  The capacity is 63% lower and the generation is 71% lower than the averages of the other scenarios. 

The energy storage resource category capacity values are pretty much the same all the scenarios.  However, the numbers used for the generation projections are presented differently so that it is not possible to compare them.  The Mas presentation did not explain the different methodologies.

As noted in the NYISO Outlook report, the Dispatchable Emissions-Free Resource (DEFR) category is a proxy generator type that represents a yet unavailable future technology that would be dispatchable and produces emissions-free energy (e.g., hydrogen, RNG, nuclear, other long-term season storage, etc.).  The DEFR capacity and generation is substantially higher in Resource Outlook Scenario 1 than all the other scenarios.  Even Resource Outlook Scenario 2 is higher than the Integration Analysis scenarios.  In addition, Resource Outlook Scenario 1 capacity factor is 9% whereas the others are all around 2%.  Mas did not address these differences.

On the other hand, there was considerable discussion about DEFR itself.  As mentioned above, Donohue’s question about acceptable future fuel was related to DEFR.  Thomas Falcone also commented on DEFR but I disagree with him.  Paraphrasing he said:

  • “We don’t have to decide right now what they are”
  • “Nobody’s crystal ball is that accurate to predict the future”
  • “The nature of technology is evolution
  • “We don’t have to solve the 2035 DEFR problem based on 2022 technology information”
  • “Don’t rule anything out today”

On one level those are reasonable assertions but there are caveats that I don’t think the Council on a whole understands.  Unless there is a major change in emphasis to accept nuclear as the only scalable proven DEFR, all the options are unproven technologies.  In the first place counting on an untested technology to be available, permitted, and constructed by 2035 is an ambitious challenge.  In addition, the alternatives are pushing the limits of physics.  Long duration storage options must overcome the Second Law of Physics.  The Draft Scoping Plan chose green hydrogen as its candidate resource and in order to prove that it can work a comprehensive feasibility analysis is required.  If the Council were to actually consider doing a feasibility analysis of the affordability, reliability, and permitting acceptability of the DEFR options I believe that we could rule out some of these potential technologies.  That could have major ramifications for the Scoping Plan.

Donna DeCarolis asked about the difference between NYISO Outlook Scenarios 1 and 2.  Mas described Scenario 1 as a “highly unmanaged future”.  Outlook Scenario 2 and all the Integration Analysis mitigation scenarios presume that load can be managed dynamically.  That means that electric vehicle charging could be limited at times so that system load is reduced.  It may also mean that homes and businesses might be required to be on smart meters so that electricity for heating and cooling load can also be reduced as needed.  Mas described NYISO Outlook Scenario 1 as the worst-case benchmark where energy efficiency does not work as expected and heat pumps don’t perform as claimed in very old weather.  My impression is the scenario as using a more realistic estimate of future load in the highest demand periods.

Mas offered several key takeaways.  He said he was “really pleased about amount of similarity” but as shown he did not address potentially significant differences.  He admitted that there are some things we can learn but did not make any suggestions how those lessons could be incorporated into the Scoping Plan.  He also promised that they will be engaging with NYISO in the coming years.  I will comment on that remark in the discussion below.


The Climate Act has prompted a massive revamping of New York’s energy system.  The Scoping Plan that is supposed to inform the future Energy Plan depends on an Integration Analysis that has not documented its control strategies and costs.  The overall plan depends upon electrification of everything but the Integration Analysis generation resource projections have not been reconciled with the projections prepared by the NYISO who is responsible for operating and planning for a reliable electric grid.  I fear that this short discussion is all that the Climate Action Council will consider before the Scoping Plan is finalized.

Dennis Elsenbeck suggested a joint reconciliation statement to address differences.  He suggested it would allow the Council to compare differences in the perceptions of the modelers.  In my opinion, such a statement should be the ultimate product of a process where the discussions between the NYISO and Integration Analysis modelers are open and the opportunity for stakeholder input is included.  The forum could address issues raised about the Integration Analysis but ignored in the response to comments.

One missing component in the response to comments thus far has been any mention of Integration Analysis technical issues raised by stakeholder comments.  I mentioned a couple of examples above but I am particularly concerned about one aspect of all this modeling.  It is not clear to me how the worst-case renewable energy resource is treated.  At some point any projection for future generating resources has to account for the fact that there are prolonged periods of light winds during the winter so there are limits to how much energy will be available from wind and solar resources.  I submitted an unacknowledged comment explaining that I do not think that the Integration Analysis treatment of this condition is adequate. I am not familiar with the NYISO methodology for the worst case but I think it does a better job than the Integration Analysis.  I believe this should be a primary topic for a reconciliation process.

Both modeling approaches are designed to force the system to meet the 70% zero-emissions generation by 2030 mandate.  That metric is based on generation not capacity.  As a result, DEFR is not needed until later because existing fossil generation can fill in where needed.  That also means that it would be inappropriate to retire fossil capacity prematurely just because it is not used much.  Peaking generation plants provide dedicated energy where and when it is needed.  They cannot be replaced until DEFR provides equivalent energy at the location within the system where it is needed from resources that are dedicated to that service.  That is significant feasibility hurdle so far ignored by the Council.

There was another implementation issue mentioned but not really addressed.  The difference in some generating resources depends on whether imports include fossil generation.  Anyone who mentioned this said that the Climate Act clearly precludes fossil imports.  Based on many years of tracking power plant emissions I believe that no one knows how that could be tracked on a real-time basis so that the NYISO system operators can dispatch and meet the criterion.  More importantly, is that requirement so important that the dispatcher is supposed to start rolling blackouts instead of accepting imported fossil-fired power?

I had a thought when Mas said that they will be engaging with the NYISO in the coming years.   At what point does Mas shut down his New York State Energy Research & Development Authority modeling empire and the State put its trust in the existing reliability planning process by the organizations responsible for electric system reliability. The NYISO process has worked for years and should be the standard going forward.  Having two sets of modeling results is confusing and the NYISO process has checks and balances on its modeling that are not included in the Mas modeling analyses.

I have one overriding question.  What are the expected costs?  Both analyses incorporate cost estimates to choose the least-expensive solution but neither one has provided any detailed numbers.  That would be a prime consideration for the differences discussion.  For example, offshore wind is minimized in the NYISO modeling which I suspect is because their cost estimates are much higher than the Integration Analysis that projects over 50% more offshore wind capacity in 2040.  Without more information we won’t know and cannot decide which is the more appropriate approach.


In response to Climate Action Council member requests the October 25, 2022 Council meeting finally offered a token comparison of the difference between the generating resources projected by the Integration Analysis and the latest NYISO analysis.  The presentation was covered in three slides and lasted about 20 minutes with questions. I have long advocated for such a comparison but I remain concerned that this is more of an empty gesture than the start of an open and transparent comparison and discussion of the implications of differences in the projections.

I cannot over-emphasize that reconciliation makes a difference.  Just because Carl Mas said that there is “close agreement” between the scenarios does not mean that there are no implications.  For example, NYISO and I agree that current land-based wind capacity is under 25% but the Integration Analysis uses a factor that is 19% higher than observed.  Therefore, at a minimum, the Integration Analysis land-based wind capacity projected is 19% lower than necessary to meet the generation requirement.  The Council has not responded to any of my technical comments and questions that showed in every instance the Integration Analysis over-estimated benefits and under-estimated costs.  Add that to the fact that the Scoping Plan does not include a feasibility analysis of the affordability, reliability, and permitting acceptability of the propose implementation strategies leads me to conclude that the Scoping Plan process could easily lead to negative consequences far greater than any climate change effects attributable to New York GHG emissions. 

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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