Climate Act Transition Plan Pitfalls – Other Voices

A couple of recent articles caught my attention as very good summaries of the challenges of the Climate Leadership & Community Protection Act (Climate Act) transition plan to achieve net zero by 2050.  I provide summaries with extensive quotes but I recommend readers take the time to go to the original articles and read the whole thing.

I have been following the Climate Act since it was first proposed. I submitted comments on the Climate Act implementation plan and written over 300 articles about 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 the net-zero transition 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.

Climate Act Background

The Climate Act established a New York “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.”  In brief, that plan is to electrify everything possible and power the electric gride with zero-emissions generating resources by 2040.  The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to write a Draft Scoping Plan.  After a year-long review the Scoping Plan recommendations were finalized at the end of 2022.  In 2023 the Scoping Plan recommendations are supposed to be implemented through regulation and legislation.

The New York official Climate Act webpage describes the Scoping Plan as the “framework for how New York will reduce greenhouse gas emissions and achieve net-zero emissions, increase renewable energy use, and ensure all communities equitably benefit in the clean energy transition”. It has also been aptly described as “a true masterpiece in how to hide what is important under an avalanche of words designed to make people never want to read it”.  Importantly, the basis of the document, the Integration Analysis, does not provide enough detail to determine if the conglomeration of control strategies that they have cobbled together will actually work together as proposed in general, and, in particular, on the arbitrary schedule mandated by the Climate Act.

New York GHG emissions are less than one half of one percent of global emissions and global emissions have been increasing on average by more than one half of one percent per year since 1990.  This does not mean that New York State should not do something, but it certainly eviscerates any claims that we do not have time to fully evaluate what has been recommended in the Scoping Plan framework.

Francis Menton writing at the Manhattan Contrarian and Arnold Wallenstein writing at Utility Dive both argue that there are fundamental flaws in the transition plan that will add costs and reduce reliability.  However, in the land of Albany politics the disconnect between aspirations and reality is not apparent. 

Samar Khurshid writing at the Gotham Gazette wrote a good overview of the current status of the 2023 implementation push entitled Major Climate and Energy Policies Being Decided in Albany State Budget Negotiations.  He quoted Senator Pete Harckham, a Westchester Democrat who chairs the Senate’s Committee on Environmental Conservation, as saying:

“Consumers are eventually going to be paying less on their utility bills, because energy will be less expensive,” he added. “We’ll lower our health care costs and we’ll be creating 130,000 high-paying union jobs. So there are a lot of upsides to this as we go forward.”

The idea that utility bills will go down is so incredibly out of touch that I can only attribute that belief as religious dogma.  The only way someone can believe that is if they do not understand the difference between power and energy.  In brief, you pay for energy so the comparison metric should be energy produced by wind and solar.  It does not matter if wind and solar provide cheaper power than a fossil plant.   Because those resources are intermittent it is necessary to backup them up when the wind is not blowing and the sun is not shining.  When the costs to provide reliable energy are included New York will find, just like every other jurisdiction that has attempted this transition, that the costs are enormous.  Enough from me the rest of the post summarizes the opinions of two others who share my view.

Menton on the Climate Act Transition Plan

Francis Menton is a retired attorney and author of the Manhattan Contrarian blog where over the he has published well over 1000 articles on issues of public policy.  Close to one-third of the posts at Manhattan Contrarian deal with the subject of climate change broadly defined, including such topics as the application of the formal scientific method to what passes for climate “science” in today’s academia, and evaluation of the potential costs and practical difficulties of attempting to replace our current energy systems with intermittent wind and solar electricity generation.  He is a board member and current President of the American Friends of the Global Warming Policy Foundation. 

In his article, New York Goes Full Central Planning For The Electricity Sector, Menton writes that the only option considered in the Climate Act transition is full speed ahead. There hasn’t been a feasibility study or consideration of a demonstration project so there is no clue whether this will work or not.  In his article he reviews a document that supposedly gives more detail as to how New York is going to accomplish the net zero transition.

In January 2022 electric utility Con Edison issued “An Integrated View of Our Energy System through 2050.”  He writes:

Let me start with a few thoughts on the Con Edison Report. It is lots of verbiage and plenty of charts and graphs. And it is more or less exactly what you would expect if you think for say, one minute, about what position Con Edison might take. As a deeply regulated entity, they are completely required to affirm the directives and applaud the wisdom of their government overlords. But more than that, they are clearly salivating over the prospect of getting to make billions of dollars of new investments, all of which will earn a guaranteed, regulated rate of return for their investors — and if we are really, really lucky, the end result will be that we get the exact same electricity for much higher cost. If we aren’t so lucky, we will get much less reliable electricity for the much higher cost. The cost factor is played down throughout the Report, and we never get any meaningful quantification.

But all the verbiage and charts and graphs mainly have the purpose of obscuring the fact that Con Ed does not take responsibility for making sure that there is enough electricity availability to supply customer demand on the grid. That’s somebody else’s job.

To set the tone, here is a quote from page 1:

[W]e are committed to being the next-generation, clean energy company that our customers deserve and expect. We will play a critical role in delivering on the ambitious climate and clean energy goals set by New York State and New York City, including reaching net-zero greenhouse gas (GHG) emissions by 2050. In addition, the need for safe, reliable, and secure energy infrastructure remains paramount.

OK, where in there did you say that you take responsibility for there being enough electricity to meet demand?

Cost barely gets mentioned in the introductory section. It finally turns up in the last paragraph.

Here’s how they spin it:

We recognize this transition to a net-zero GHG emissions energy system will require significant investment. We seek to make investments that achieve the goals of this transition as cost- effectively as possible, which necessitates growing our electric system while maintaining our gas and steam systems to achieve clean energy goals.

In other words, whoo-boy is there a lot of money for us to make here!

He goes on to discuss that Con Ed does not take responsibility to build the things necessary they only offer support for “interconnection” and “balance.”  Then he addresses energy storage and note that Con Ed does not make the proper delineation between power and energy.

And how about the trillions of dollars worth of energy storage that will be needed when the sun doesn’t shine and the wind doesn’t blow? See if you can decode this word salad:

“We have developed plans to build the necessary electric transmission and distribution infrastructure by 2050 to . . . [d]evelop and facilitate up to 12.6 GW of energy storage through direct utility investments and customer programs at customer and utility scales.”

Where even to start? “12.6 GW” of storage? They don’t even know the correct units to discuss this issue. If these are four-hour duration lithium ion batteries (unspecified, but what else could they be talking about?), that will give you 50.4 GWh of storage — enough to cover New York State for a couple of hours at most of low sun and wind. Competent calculations indicate a storage requirement of more like 20 to 30 days of storage to deal with the seasonality of the sun and wind. So this is at best a small fraction of one percent of what will be needed to back up the solar/wind grid of the future.

But what does Con Ed care? They’re not actually saying here that they are taking responsibility for making the new system work, let alone even providing the batteries themselves. They’re only saying that they have “developed plans” to “facilitate” the storage, which could occur either through “utility investments” or “customer programs.” In other words, I guess, hey sucker, use your electric car battery to power the house when the grid goes down.

Arnold Wallenstein on the Climate Act Transition Plan

Arnold R. Wallenstein is a Boston-based attorney who represents independent power producers in New York and other states and is the principal member of the Wallenstein explains in New York’s plan for transforming its electricity generation will reduce reliability at extreme cost that there are obstacles to meeting the ambitious schedule of the Climate Act net-zero transition.  He explains why he thinks the transition plan is doomed to failure:

The Climate Action Council projects current electric load in New York to triple by 2040 due to the electrification of transportation and 100% building electrification. By 2040, when all electricity generation must be zero emissions, NYISO, the independent New York grid operator, states that at least 95 GW of new generation must be developed to make up for generation plant retirements and increased electrical demand. This goal is unrealistic and unachievable because the state only added 12.9 GW over the last 23 years, and it is highly unlikely that 95 GW of new generation capacity will be added in 17 years due to state permitting and grid interconnection delays.

The Climate Action Council’s final Scoping Plan also reveals that New York will need 15 GW to 45 GW of new “zero emission dispatchable electric generation” by 2040 to meet increased electric demand and maintain electric system reliability. This is emission-free electric generation that can be dispatched, i.e., turned on, by NYISO at night or stormy conditions when there is no solar radiation or during calm wind conditions. But the Scoping Plan also admits that this 15 GW – 45 GW target “cannot be currently met” with existing technologies.

This dire prediction is confirmed by NYISO, which has issued reports stating that the New York grid may experience as much as a 10% deficiency, and possibly more,  in generation capacity by 2040, and will require 32 GW of new zero-emission dispatchable generation by 2040 — which would almost double the current New York grid’s 37 GW generation capacity. NYISO also warns that such zero-emission dispatchable generation technologies “are not commercially available.” Electricity shortages will occur if these new emission-free generation plants do not materialize in time as hoped for by the state. Hope is not an action plan to solve electric reliability deficits. 

Electric power deficiency is already starting to occur. A report just issued on April 14 by NYISO points out that New York City and the Lower Hudson Valley may have electric reliability problems and generation shortages starting in 2025 due to generation plant retirements caused by the New York Department of Environmental Conservation shutdown of NOx producing peaker plants and if there are extreme weather events, worsening through 2032, where there may a 600 MW generation deficiency in New York City and environs.

The Climate Action Council’s climate plan — if fully implemented by the state as is currently being debated in the legislature — risks placing New York in an electricity shortage that could result in blackouts and brownouts. The New York grid operator pointed out that if existing gas-fired electric generation is shut before new resources come on line, there is a risk that NYISO will not be able to provide a reliable electric system. 

NYISO also said fossil fuel generators — natural gas and oil-fired — will be needed to maintain reliability until non-emitting dispatchable resources can effectively replace the fossil-fired generation plants to provide grid reliability as a back up to intermittent, weather-dependent renewable energy resources. NYISO also predicts than in 2040 when fossil-fueled generators are shut down by state’s climate law, zero-emissions dispatchable generation, which doesn’t yet exist, will still be required to supply 10% or more of New York’s electricity, depending on how many megawatts of new renewable and “dispatchable” emission-free generation is actually operational by 2040. 

These warnings of future electric deficiencies are echoed by the New York State Electric Reliability Council and the North American Electric Reliability Corp., the entities tasked with monitoring electric reliability in New York as well as the U.S.

Blackouts during cold winter months can cost lives. When Texas experienced an unprecedented freeze in 2021 between 246 (direct) and 700 (indirect) people died because of power outages. Similarly, many people died in Buffalo’s Christmas 2022 blizzard. That cannot be allowed to happen in New York because of a poorly designed climate plan.

If that wasn’t enough, the cost to implement New York’s climate plan may be stratospheric: authoritative commentators, including the Empire Center for Public Policy, have suggested New York taxpayers and ratepayers will pay $340 billion to $500 billion to transition the New York electric system to primarily relying on solar and wind power supplemented by battery storage.

But no overall cost analysis was provided by the State’s Climate Action Council.

Gavin Donohue, CEO of the Independent Power Producers of New York, refused to vote for the climate plan, and said it would take pure “magic” to make the plan work.

And how much will this costly plan contribute to reduction of greenhouse gases: only 0.4% of global GHG emissions according to recent commentators.

A reliable supply of electricity that can be generated at all times during cold nights and low wind conditions is absolutely essential to our modern economy and our standard of living. The state’s climate plan’s proposed radical changes to the New York electricity generation sector should not be fully implemented by the state until it can guarantee that there will be adequate generation at all times. This means keeping in service some natural gas-fired generation which can quickly ramp up when solar and wind plants are not operating. NYISO warns that with even with increased renewable energy generation by 2040, “at least 17,000 MW of existing fossil generation must be retained to reliably serve forecasted demand.”


The difference between these articles that clearly are based in reality and Harckham’s statement that  “Consumers are eventually going to be paying less on their utility bills, because energy will be less expensive” could not be starker.  The innumeracy of anyone who thinks that intermittent wind and solar power can ever be cheaper is astounding because the numbers are so straight-forward.  It must be that they simply don’t want to hear anything that runs contrary to their cherished narrative.  At what point will they concede the risks of this insane policy.

Both authors echo my concerns about the lack of adequate feasibility planning to maintain current reliability standards and the absence of a complete accounting of the costs.  This blog is dedicated to the idea that environmental regulation should concentrate on tradeoffs and consideration of all the impacts.  Both authors argue that this pragmatic approach is not a characteristic of the Climate Act transition.  I agree with Wallenstein that “the New York Climate Action Council’s climate plan, if carried out as intended, will probably not be able to supply New York state with a reliable supply of electricity. And it will cost New York taxpayers and utility customers (i.e., everyone) hundreds of billions of dollars to create a less reliable electric system than New York now enjoys.”

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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