Richard Ellenbogen frequently copies me on emails that address various issues associated with New York’s Climate Leadership and Community Protection Act (Climate Act). I asked his permission to present his analysis explaining why New York’s building decarbonization push it is going to fail, just as Germany’s has, and will drive up state GHG emissions and raise utility costs for decades. He has consolidated all of his material on this topic in one document and has included recommendations for an alternative approach.
I have published other articles by Ellenbogen because he truly cares about the environment and the environmental performance record of his business shows that he is walking the walk. Ellenbogen is the President of Allied Converters that manufactures food packaging. His facility is about 55,000 square feet and does a lot of manufacturing with heat to seal the bags, all electrically driven. The facility has solar panels and uses co-generation. He explains:
In 2008, the average energy cost per square foot for a commercial facility in Westchester was $1.80. We were at 16% of that 12 years later and even with the increases, we are at 62% of that 14 years later. That has been done while having a carbon footprint 30% – 40% lower than the utility system. The $1.80 per foot also included commercial office space and our operation is far more energy intensive than an office. We use energy extremely efficiently and as a result, our bills are much lower than everyone else.
Ellenbogen on Building Decarbonization
While it is being proposed with good intentions, NY State’s building decarbonization push is going to fail, just as Germany’s has, and will drive up state GHG emissions and raise utility costs for decades. The analysis to justify that conclusion follows. While there is new material included, a portion is a synopsis of prior emails but as NY State gets closer to committing energy suicide, I felt obligated to put it all in one document. As it is written, the state’s energy plan is going to be the fossil fuel company’s best friend. NY State is adopting a “Chicken Little” approach to energy policy. It is so focused on the acorn of fossil fuels and a belief that the sky is falling that it is ignoring science in the process. As a result, the state will fall victim to the fox of energy failures, high GHG emissions, and incredibly high utility rates that are going to eat NY State citizens and businesses. For those who declare that NY State must exhibit “Climate Leadership”, this policy isn’t that. It is copying a failed policy from Germany. For those not interested in the minutiae of the reasoning, the figure headlines and the final recommendations will give an accurate picture of the problems.
There is a way to get about a 44% GHG reduction in NY State while also having enough generation to support the system without imposing extremely high costs on the state’s residents and businesses. It can be implemented in one-quarter the time of the state’s current plan using a combination of improved fossil fuel plants and renewables, while replacing old gas equipment with newer gas equipment that won’t require an entire rewiring of NY State.
In lieu of doing something that will actually work, the state’s plan will face the following issues:
1 – Cost – Trillions of Dollars
First of all, the cost of the project will not be anywhere near as inexpensive as the $200 billion figure that is being thrown around. Going through all of the figures, it will be at least $600 billion for the electrification portion, before adding storage and renewable generation to the totals. For anyone that doubts that, the cost of a single 400 mile cable from Quebec to NY City has now risen to $6 billion and try to name a single infrastructure project in NY State that has come in on budget. The Champlain Hudson Power Express Cable was projected to cost $2 billion in 2013. That cost is now up to $6 billion, a 232% increase in inflation adjusted dollars. Does anyone seriously believe that the entire state can be rewired for less than 100 times that cost? If you add in storage costs at the present cost of Lithium Ion Batteries, the cost rises to approximately $4 trillion plus the cost of the renewable generation. Even if you could get a 75% reduction in storage costs using a different technology, the total cost will be well over $1.5 trillion and much of that will depend on the usable life of the new storage. At present, battery storage only lasts 10 years. Pumped Storage would likely be much more cost effective but where in NY State can a utility site a large reservoir. Also, based upon Con Ed’s experience with Storm King Mountain between 1960 and 1980, no utility will even try to build a pumped storage facility.
2 – Logistics – Size of Project and Lack of Labor will result in it requiring Over 60 Years – Policy is going to create situations where the mandates cannot be fulfilled
There are 112,000 miles of roads in NY State. Of those, about 22,000 miles are major highways and likely don’t have electric distribution lines on them, leaving about 90,000 miles of distribution lines that were designed and sized for an era where onsite heating was delivered from fossil fuels or wood. The vast majority of the transformers and conductors will not handle a tripling of the electric load during the during the winter. If you eliminate 18,000 miles (20%) for areas upstate that are already using electric heat, that leaves 72,000 miles of distribution network to be rewired. 8,000 of those miles are in NY City where a substantial portion of the infrastructure is buried and the costs will be higher still.
When I did the utility project with Con Ed back in 2010 where we demonstrated that we could reduce transmission loads and line losses using reactive power correction on the local distribution system, I added power monitoring devices to four transformers. On hot days during the summer, three of the four transformers where the project was executed were operating at or near their capacity on a hot summer day. If heat pumps are added to the system, the winter time load on a cold day will be substantially higher than the summer time load on a hot day. That is not my speculation. The NYISO has determined that NY State will need an additional 25 Gigawatts of generation to support heat pumps in NY State. during the winter. Winter peaks are expected to exceed summer peaks starting in the early 2030’s.
As a result, a substantial portion of that 90,000 miles will need to be rewired to support onsite electrification. Using an existing project in California as a reference, PG&E has been required to bury 10,000 miles of high voltage transmission lines in the fire prone areas. In 2022, they replaced 71 miles of cable. By 2025, they expect to increase that to a rate of 1200 miles per year. That doesn’t include replacing transformers or services to people’s homes which would be required to electrify onsite heating. Even larger conductors will have to be added in rural areas of NY State where they expect to interconnect large solar arrays so that the projects don’t keep getting canceled because of interconnection costs. While replacing overhead lines would take less time than burying them, replacing old equipment with higher capacity equipment for the larger heating loads and the additional time needed to increase the service sizes into people’s homes would about offset the time difference.
At 1200 miles per year, rewiring 72,000 miles of distribution lines in NY state will take 60 years to upgrade. They have been burying larger electric and gas services in New Rochelle to support the extra 9,000 units of housing that they are building here and the roads have been like a slalom course for about 4 years to fix about 10 miles of services so the 60 years is not an unrealistic estimate. NY City may take even longer to rewire and that is 40% of the state’s population. What is going to happen to the people that cannot replace their gas equipment in areas where the service has not been upgraded to support the higher electric loads imposed on the system by NY State policy ?
3 – Bad Science Is Driving Initiatives – Results Will be Far worse than Estimated and It will add Enormous Costs On the Backs of the State’s Citizens
I have read extensively about the PAF (Population Attributable Fraction) technique that was used as the analytical tool to do the analysis for the recent paper about gas stoves and childhood asthma. A slide from an upcoming PowerPoint that I will be presenting is below. The caption at the bottom of the slide was copied from the introduction of a paper discussing PAF by people that developed an improvement to PAF. However, the improved version needs very specific data directed at the variables involved, and not 30 – 40 year old data that was not asking the necessary questions from a time when the focus on health issues was very different. Every PAF study with multiple variables warns of bias in the study and questionable results, whether it is from sugar intake and type 2 diabetes to comorbidities and Covid. Asthma falls into the multiple variable category. Risk factors can include tree pollen, second hand smoke, proximity to large emission sources such as factories or power plants, pet dander, vehicle exhaust, nutrition, and yes, even gas stoves, among others. But unless all of the data on the other variables was collected in the survey, PAF will return garbage, even in the updated format proposed by the authors of the PAF improvement. Thus, the conclusions of the gas stove report have no validity.
Another issue never explained by the authors of the gas stove study is why the top ten states for cases of asthma in the US are all 80% electric stoves and the top eight states for childhood asthma are 80% electric stoves. If gas stoves were that large of a factor, at least one of the five states that is primarily gas stoves would appear higher on those lists. The conclusions of the study could possibly be correct, but no one could be sure because the study was so poorly conceived, conducted, and analyzed. It certainly should not be used as the basis for a public policy affecting 19.5 million people that is going to add an additional $72 billion in costs onto the backs of the state’s utility customers. Results that will be at least 95% – 98% as effective can be obtained at a fraction of that cost using other techniques.
4 – Existing Transmission and Distribution System Will Not Support Installation of Large scale Renewable Generation – Too Many Resources are Being Wasted on Projects that will Yield No Environmental Benefits. Not Enough is being spent On Grid Infrastructure to support renewables and vehicle electrification.
Another major issue, and one that is severely impacting the installation of renewables is the fact that the state’s utility system is wired backwards for what policy makers are trying to do with it. The utility system was wired to have large sources of generation distributing energy outward from a few locations. Now, the state is trying to site large generation sources in remote locations where the infrastructure won’t support it. As a result, renewable generation installers are faced with long transmission line runs to interconnect into the system, making the projects non-cost effective. The projects are being cancelled and as a result, NY State is falling well behind in their installation schedule that was already insufficient to fulfill the state’s requirements.
This is also apparent with regard to the 9 GW of offshore wind. There is a major concern about the availability of space to run the cables to interconnect the energy to where it is needed. One possibility is running the cables across Long Island in an environment where every infrastructure project is faced with lawsuits. As a result, even if they can build the 9 GW of Atlantic Wind, they may only be able to interconnect about 6 GW to where it is needed. That is clearly shown in another slide from the upcoming PowerPoint documenting a critical page in a NY State Power Grid report, below. Transferring renewable generation installation projects to NYPA may increase the rate of installation slightly but the node analyses will still have to be done that takes five years at present and the transmission lines will still have to be installed so the price will not be reduced.
5 – Air Source Heat Pumps On a System Not Fully Supported By Renewable Generation Will Not Reduce GHG. There are not Enough Drillers to install Ground Source Heat Pumps, which actually work, in any time frame that will yield significant results.
As is clearly documented in the slide below, putting electric onsite heating into buildings that are not fully supported by renewables just shifts the load to existing generating plants. In Germany, heat pump installation, primarily air source, exceeds gas combustion installation. However, despite installing massive amounts of renewable generation, while their household carbon emissions have declined by 28% since 1999, their utility system carbon emissions only declined by 3.4%. While they closed nuclear plants, they actually installed more Gigawatt hours of renewables. They should have seen a large GHG decrease, but heat pumps running on a system that uses fossil fuel generation add marginal additional load to the fossil fuel plants with higher emissions than an efficient gas boiler/furnace.
Germany is playing “Whack-A-Mole” with its building emissions and NY State is about to do the same thing. They beat down the emissions in one place and they pop up somewhere else. That chart was copied from a Yale publication “Can Germany revive its stalled energy transition?” published in about 2018. Based upon events 4 years later, the answer has been a resounding “NO” Even prior to the war in Ukraine, Germany was reopening coal plants. After the war started and they lost their gas supply, they opened even more coal plants and there were news articles about people across Europe stealing firewood, cutting down trees, and burning anything that they could find to stay warm. That will be the future of NY State with the proposed policies. Germany has been exceedingly lucky this year with a relatively warm winter, however they recently signed an agreement with Qatar to import 20 million metric tons of Liquid Natural Gas over the next ten years.
As the chart shown below from a Cornell Geothermal report clearly show, all additional load added to the system is supported by fossil fuel generation. Blue and Brown lines were added after to explain the difference between the upstate and downstate generation sources which in 2019 were within 5% of each other. However, in terms of zero emissions sources, they were worlds apart. The downstate system is almost entirely supplied by fossil fuels.
6 – Battery Storage is being added to the System Prematurely. The batteries will wear out at least 50 years before the state has enough renewable generation to charge them. As a result, they will be charged with fossil fuel generation with a 15% – 20% higher carbon footprint than the actual generation.
As all marginal generation in NY State is provided by fossil fuel generation, all new battery systems that are added will increase fossil fuel generation by a minimum of 15% related to that stored energy as 15% of the battery’s energy is lost in the Charge/Discharge cycle. The batteries will need to be replaced after about 10 years, well before the system will be supported by renewable generation. This is great news for Elon Musk, but not that good for the taxpayers and utility customers in NY State. The following slide was also borrowed from the same report.
7 – An Energy “Shell Game” is Being Used to Make the New Micron Technology Facility Appear Greener than it Actually Will Be under CLCPA rules. However, it could be made far “Greener” in reality by siting a combined cycle generating plant next to the Micron Facility. Nuclear generation would be better still, but that would take far longer to build and would have much higher upfront costs.
The New Micron Technology Facility in Clay, NY will eventually use more energy than the state of Vermont. NY State and NYPA have said that they will provide 140 Megawatts of NY Hydro to the plant. For lack of a better word, that policy is a farce. All of the NY State Hydro has been allocated for years. If they allocate it to the Micron Facility, those customers that are currently using it will then effectively be using fossil fuels. They want Micron to use all renewable energy. From Where? A solar array that could generate enough energy to support that facility would occupy 100 square miles. They want Micron the buy Carbon Credits. From whom? NY State’s two largest neighbors to the south and west, Pennsylvania and Ohio, average 1.5% renewable energy. If NY State has to import energy from either of those states to support the Micron facility, it will all be from fossil fuel generation, gas or coal fired, at a lower efficiency than a combined cycle generator. The import of energy from long distances to the Micron Site will increase transmission line losses by approximately 350 Gigawatts compared with a generator on-site. The new rules are going to make the Micron facility less energy efficient, more polluting, and also increase Micron’s operational costs while imposing environmental costs on the state. Forcing Micron to buy Carbon Credits does nothing to help the environment. It literally papers over the problem while raising Micron’s costs and doing nothing tangible to reduce greenhouse gas emissions.
8 – Renewable Generation Installation Rates are Insufficient to Support NY State’s Plan
Even prior to many of the recent cancellations of renewable generation projects, NY State was not going to have enough renewable generation installed for about 60 years. Prior to the cancellations, NY State was going to be at least 120,000 Gigawatt hours short of what it would need to support the system on all renewables by 2035 as is shown in the slide below. With onsite fossil fuel combustion about to be banned in new building and replacement equipment banned after 2035, while EV’s are mandated for all sales after 2035, the system load is going to grow far more rapidly than the expansion of renewable generation resulting in an energy shortfall. Beyond the transmission issues facing the Atlantic Wind projects mentioned earlier, the Jones Act is going to slow the rate of installation for offshore wind by limiting the number of jack ships that will be available. While NY State is short on land, money, and grid capacity, the one thing that NY State has in abundance is lawyers so that any renewable project will be faced with years of NIMBY lawsuits and the resulting delays.
Just because California tried it that doesn’t mean that NY State should. California has a Mediterranean climate and is 20 degrees warmer in the winter so the orange and gray “energy blocks” in the fossil fuel column A on the chart below are much smaller. If NY State had the same climate as California, it would eliminate a need for about 150,000 Gigawatt hours of renewable generation on the future system. Keep in mind that California is having difficulty keeping the lights on without the albatross of onsite heating around their neck.
Four columns on the chart above are labeled A,B,C,D and are referred to in the conclusion.
“A” is the Existing Fossil Fuel Consumption in NY State. “B” is the Electric Load if all of that was converted to electric technologies on a fully GHG free generation system. “C” is 6 GW of 1000 hour storage as mentioned in the NY State Energy Storage report. Current cost using Lithium-Ion batteries, $3.4 Trillion. NY State is betting on technologies that don’t exist commercially yet and at present, have shorter lifespans than the 10 years of Lithium-Ion. “D” was the projected renewable installation for 2035 estimated in 2019 using figures provided by NY State. With solar projects being canceled, in 2023 that is an overly optimistic estimate.
Even if all of the existing fossil fuel generation remained static and no fossil fuel plants are closed, the additional load being mandated is going to outstrip the rate of renewable installation. As NY State is not allowed to build any new fossil fuel generation, one of two things will happen as a result of the energy shortfalls shown in the slide above. NY State citizens will be without lights and heat, or NY State will have to import large amounts of fossil fuel generation from out of state, just as California has had to do. When the neighboring states don’t have it available, NY State will have to impose rolling blackouts just as California now does, only the blackouts will occur on the coldest days of winter which will be far more deadly than the hot days during the California summer.
If Climate Change is truly the existential crisis that the authors of the CLCPA claim it to be, and if the recent UN report about the need to halve atmospheric carbon within 10 years is true, then NY State’s 60 – 70 year plan that is going to increase carbon emissions for at least the first 30 years needs some rethinking.
Keep in mind that NY States total GHG emissions are 350 million metric tons annually. Worldwide GHG emissions increased in 2021 by 2 billion metric tons, 40% of that from increased coal combustion in China, India, Germany, Japan, and other countries. So, the increase in worldwide GHG emissions in 2021 was six times NY State’s total annual emissions.
Because of the above fact, it is apparent that the rate of Climate Change is not in the purview of NY State policy makers. As resources are limited, instead of wasting money on building electrification that will yield no holistic improvements in GHG emissions, resources should be used to harden infrastructure against the inevitable negative effects of Climate Change, whether that is on grid infrastructure or flood mitigation. The most expensive and severe impacts of Sandy were on the underground infrastructure of NY City and along the Hudson River. Venice type barriers might be considered for under the Verrazano and the Triborough Bridges, however that will never happen if the state wastes $600 billion on an electrification plan with no positive upside.
A Better Plan –
The following, if executed properly could result in the energy chart, below, where the right hand column actually can supply NY State’s energy needs at a fraction of the cost of the current plan while also reducing fossil fuel energy use and the associated GHG emissions by 44%. However, people will have to allow techniques that don’t meet the current standard of ideological purity in NY State.
By eliminating the push to electrify buildings, the energy savings and carbon reductions will actually be greater than what the CLCPA will yield in practice. This alternative plan will need far less labor and storage resources. Existing resources can be allocated to grid infrastructure to support renewable installation and vehicle electrification. Vehicle electrification is the fastest way to improve GHG emissions. Eliminating storage requirements will reduce battery demand and costs, making EV’s cheaper.
All is not Doom and Gloom
What can be done to reduce GHG emissions considering the state’s lack of financial resources and the lack of sufficient renewable generation for at least seven decades? The following is a list of ten ideas that can be implemented relatively quickly that will help to rapidly lower GHG without breaking the piggy bank while also slowing or reversing the increase in utility bills
- Do not electrify buildings that run on natural gas – while it will reduce GHG at the building, it will increase it as much at the generating plants while forcing residents and the utilities to incur enormous rewiring costs. There will be no reduction in current fossil fuel energy, Column A in the New York Fossil Fuel Energy Load figure. Also, the gas stove analysis that was done recently was mathematically flawed and should not be used to set public policy.
- Focus heat pump efforts on locations that use oil heat or that use radiant electric heat. Those locations will see a significant reduction of GHG and heat pumps will reduce grid load when compared to radiant electric heat.
- Focus resources on expanding grid infrastructure. This will reduce the cost of installing solar in Upstate locations and reduce the number of system cancellations allowing the state to increase the proposed renewable generating resources, Column D in the New York Fossil Fuel Energy Load figure.
- Increasing grid infrastructure will also help with the installation of chargers for the electric vehicle wave that is about to arrive, with or without the state mandate.
- Do not install large amounts of battery storage until there is sufficient renewable generation to support the storage. It will increase current fossil fuel energy (Column A in the New York Fossil Fuel Energy Load figure) while incurring an enormous capital outlay and starving other projects of funding. They will also decay well before sufficient renewable generation is installed.
- Replace older generating plants with higher efficiency combined cycle natural gas generating plants. The state will need the energy to support the EV’s and the newer plants are far more efficient. It will lower Column A, reduce gas usage and put downward pressure on the commodity price.
- Place an emphasis on hydrogen injection into natural gas combustion plants. It will decrease gas usage and increase combustion temperatures which reduces NOx emissions and lowers current fossil fuel energy, Column A. It will greatly lower GHG emissions related to those generating plants
- Focus available natural gas resources on combined heat and power systems. It will reduce the utility bills for the system owners while also reducing requirements for grid infrastructure. Allow multiple building to form micro-grids to utilize the thermal output and increase the generation capacity. It will greatly reduce Column A
- Allow Micron Technolgies to build a combined cycle plant the size of Cricket Valley Energy Center on their property. The Micron facility will use more energy than the state of Vermont. Instead of letting them be “green” on paper by buying carbon credits, let them be green in reality with high efficiency generation and have lower energy costs to make them more competitive and able to recoup the $5 billion rebate without faking it. That will eliminate the increase in column a related to the facility.
- Figure out how the utilities can interconnect the 9 GW of offshore wind because at the moment, no one is certain how to do it. There is limited space for underwater cables. Without that, energy curtailments will occur and impede the increase of column d, unless they use the alternative idea which is to run transmission lines across Long Island.
Ellenbogen Conclusion
Ellenbogen Follow Up
The next day Ellenbogen followed up with another email with this warning.
In a speech to the British Parliament in 1948, Winston Churchill said, ‘Those who do not learn history are doomed to repeat it”.
As a conclusion to my email of yesterday, March 28, the following should serve as a warning to those proposing the current NY State Energy plan and expensive projects that are going to raise utility rates but do little for the environment.
The statement above by Churchill not only applies to NY State following Germany’s failed energy program. It also applies to something that happened just across Lake Ontario, much closer to home.
In 2009, Ontario, Canada passed the Green Energy Act. Ontario has a similar population distribution to NY State with large population centers to the south and more rural areas to the north. Hardships were incurred by the more rural areas in the building of renewable generation and sending the energy to the wealthier, more densely populated southern areas. In reading some articles on the subject, it was portrayed as a class war. The act might have survived that issue, except energy costs skyrocketed along with the perceived injustices and the combination led to the repeal of the Act after only 10 years. The Green Energy Act from 2009 is available here and an article documenting the repeal is here.
As I documented above, the state’s energy policies are going to cost trillions of dollars with far fewer carbon emission reductions than could otherwise be obtained at a far lower cost. Hundreds of square miles of solar arrays and wind farms are going to have to be built in rural areas that are already exhibiting a substantial resistance to the projects. The 2019 repeal of the act gave municipalities the right to control what energy projects could be built within their borders, just the opposite of NY State’s proposed legislation.
The quest for the perfect will be anything but and the inevitable voter rebellion that is going to occur in the not-too-distant future is going to leave the state with massive debt, extremely high utility costs, and little to no GHG reduction to show for it. In the interim, a decade will have passed where functional, inexpensive programs could be implemented that will actually reduce GHG in the real world, as opposed to the current program that only might work in Mark Zuckerberg’s fantasy Metaverse. It certainly hasn’t worked in any cold climate on Earth where it has been tried.
Utility customers are already feeling enormous amounts of pain. I have been receiving emails of late from politicians excoriating Con Ed for raising rates, however most of the increase is needed to comply with the mandates of the CLCPA. The increases are due to terrible policy and not utility rate gouging. As a clear example of how upside down this policy is, it actually has me defending Con Ed after they said some rather nasty things about me in a tariff hearing 12 years ago. I have a long memory and no love for Con Ed but this energy policy is going to end up turning the state’s utilities into piñatas through no fault of their own.
The utility rate increases are going to be far worse going forward as the costs documented in my email of yesterday are not figments of my imagination. The plan will not be sustainable. The state can’t borrow its way out of trillions of dollars of costs in an effort to subsidize utility rate payers to ease the pain that will be caused by this.
Beyond the actual costs, there is going to be a huge opportunity cost in terms of lost time imposed by the CLCPA that prevents working solutions from being executed, along with a souring of popular attitudes towards any future programs to reduce GHG.
In their overreach for an unrealistic fantasy, they are going to achieve nothing. Unfortunately, as bad as that is, that situation will be the best-case scenario. The worst-case scenario will be that they continue to push forward, ignoring utility customers pain, still achieving no GHG reductions, while creating energy shortages that result in loss of life.
The current energy policy has no long-term positive outcomes.
Caiazza Concluded Remarks
I could quibble with a few numbers and my take is slightly different for a few aspects but I am in complete agreement that this cannot possibly work. The biggest flaw in the Hochul Administration’s net-zero transition plan is the lack of a feasibility analysis. In 2018 I wrote the following.
We’re choosing between as yet undefined but surely expensive options trying to understand which one (or what mix) will be the least expensive. Unfortunately we don’t know but we need to start now because we’ve been told that we have to make reductions by 2030. If we make a good pick then we’ll spend the least amount of a lot of money and will be left with the fewest negative outcomes, but if we get it wrong, we will be left with many more negative outcomes and even higher costs for a long time.
Since then, the only thing I would change is that it is not just about the money, the possibility of catastrophic reliability outcomes must be considered because present wind, solar, and energy storage technology must be coupled with other ill-defined and speculative resources in order to work reliably. Clearly the first step and priority should be a feasibility analysis before anymore time and money is spent on this.
Pragmatic Environmentalist of New York 