As part of the Department of Public Service Proceeding 15-E-0302 a technical conference was held on December 11 and 12, 2023 entitled Zero Emissions by 2040. The conference focused on characterization of the potential “gap” discussed in the May 14, 2023 Order. The gap is expected because “renewable energy resources may not be capable of meeting the full range of electric system reliability needs that will arise as fossil generation is replaced.” The conference included panel discussions on potential technologies to fill the gap. The topics at the conference directly relate to my concerns associated with the reliability implications of New York’s Climate Leadership & Community Protection Act (Climate Act) so I watched the webinar and will be developing comments for submittal. This article offers my first impression of the disconnect of those who deny the gap and reality.
I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 380 articles about New York’s net-zero transition. The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.
Overview
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) 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 using zero-emissions electricity. 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 develop the Draft Scoping Plan outline of strategies. After a year-long review, the Scoping Plan was finalized at the end of 2022. In 2023 the Scoping Plan recommendations are supposed to be implemented through regulation, PSC orders, and legislation.
Gap Proceeding
In May 2023, the New York Public Service Commission (PSC) initiated a process to “identify technologies that can close the gap between the capabilities of existing renewable energy technologies and future system reliability needs, and more broadly identify the actions needed to pursue attainment of the Zero Emission by 2040 Target” for New York electric generating sources intended to address that need. I discussed that in a post last May. The May 14, 2023 Order included a requirement for a technical conference to focus on characterization of the potential “gap” and technologies that could shrink or fill that gap.
The pathway established by the Clean Energy Standard (CES) Modification Order focuses on options for procuring sufficient renewable energy resources to meet CLCPA requirements. However, several studies indicate that renewable energy resources may not be capable of meeting the full range of electric system reliability needs that will arise as fossil generation is replaced. These studies suggest that there is a gap between the capabilities of existing renewable energy technology and expected future system reliability requirements. The Independent Power Producers of New York, Inc., New York State Building and Construction Trades Council, and New York State AFL-CIO (Petitioners) also raised this issue in a petition filed in this proceeding on August 18, 2021 (Zero Emissions Petition or Petition).
This Order responds to the Petition and initiates a process to identify technologies that can close the gap between the capabilities of existing renewable energy technologies and future system reliability needs, and more broadly identify the actions needed to pursue attainment of the Zero Emission by 2040 Target. As a first step, rather than adopting a new CES tier as requested in the Zero Emissions Petition, this Order seeks input from stakeholders on options for addressing that gap. In particular, the Commission welcomes responses to the questions posed in the body of this Order and directs the Department of Public Service staff (Staff), in consultation with the New York State Energy Research and Development Authority (NYSERDA), to convene a technical conference that addresses the same list of questions.
I will prepare another post on the Zero Emissions by 2040 Conference itself with more details when the webinar recordings are available. This post is only going to address the disconnect between climate activists who deny the gap and reality.
The Gap
There is an important point to keep in mind. The experts who are responsible for reliability on the electric grid plan for the worst-case scenario to minimize outages. I think the fatal flaw in all the “clean and green” energy technologies touted for the future is that they don’t work all the time. Unfortunately, they don’t work when needed most, i.e., the coldest periods when loads are highest.
The gap is caused by the correlation in time and space of renewable resource availability. There is perfect correlation of all solar resources at night when the solar panels all go to zero. Weather systems affect wind and solar resource availability, and the size of those systems means that there is strong correlation between the conditions that cause high and low resource availability. Most large-scale weather systems exceed the size of New York so there are frequent periods when all the in-state wind and solar resources are low across the state. As a result, over-building wind and solar cannot solve the gap.
I have addressed the ramifications of this in the past using the work of Michel at the Trust, yet Verify blog. Most recently he graphed solar and wind electricity generation as a percentage of daily demand for the Belgian electric system. Over the last nine years solar and wind capacity (MW) in Belgium has increased significantly so the maximum daily share of wind and solar has increased. However, the minimum share has not changed much reflecting the correlation of wind and solar across Belgium. When it is calm at one wind turbine most of the other wind turbines have light winds too. It does not matter how many turbines there are if they all go calm at the same time.
New York is larger than Belgium but there is no expectation that there would be a different observation. The New York and Belgium problems are exacerbated because weather systems can be so large that they affect large portions of the continent. As a result, if other electric operating regions adjacent to New York become reliant on wind and solar importing electricity from outside New York will be affected.
When I submit comments to this proceeding, I am going to emphasize the point that we will not know how to design resources to fill the gap until we understand the magnitude, duration, and scale of low wind and solar resource availability conditions across the Eastern Interconnect that provides imported power to New York. I recently looked at the potential to solve this problem using the wind that is “always blowing somewhere”. The ultimate problem is that dedicated resources are needed to supply energy to New York in the worst-case scenario and that would mean dedicated 1,000 mile transmission lines and a large number of wind turbines devoted to that purpose. It is simply not cost-effective. This result leads to the need for the new resources discussed at the Zero Emissions by 2040 Conference.
Disconnected Activists
I copied the chat log from the webinar display during the conference because there was information that I wanted to preserve. For example, Anshul Gupta, NYCP at 11:39 AM on 12/11/2023 asked: “NYCP documented National Fuel Gas’ disinformation campaign that Clarke mentioned in comments on NFG’s long-term gas plan”. He wrote an op-ed for lohud.com The gas industry is trying to sway critical NY climate policy. Here’s why that epitomizes the impression I have that climate activists are disconnected from the reality of the gap.
In the op-ed he claims that scaremongering claims described below are false:
As we get close to finally implementing the CLCPA, New Yorkers are being subject to incessant scaremongering on how their energy reliability and affordability is threatened by the law, particularly by its building decarbonization goals. The grid can’t handle the electric heat pumps’ load, we are told. That our energy bills will skyrocket, that we’ll be forced to spend $20,000 to upgrade our homes, or that fossil gas can be replaced by renewable natural gas and hydrogen.
He describes himself as a “research scientist and a Steering Committee member of the New York Chapters Coalition of the Climate Reality Project, an international organization founded and led by former Vice President Al Gore”. For my part I am pretty comfortable saying that most of what thinks is not true is closer to fact. However, my bigger concern is the suggestion that saying energy reliability and affordability is threatened by the law is scaremongering. The whole reason for the PSC Zero Emissions by 2040 Conference is concerns about reliability. Apparently, he thinks that the PSC is scaremongering.
On the second day 10:30 AM Valdi Weiderpass (Chair Susquehanna Group, Atlantic Chapter, Sierra Club) recommended ‘No Miracles Needed’ by Mark Jacobsen because it says we can transition to renewables without exotic means. Unfortunately the Climate Act is based on the flawed work of Jacobson and Howarth. That wind, water, and solar” analysis ignores correlation issues and claims that no new technology is needed. The fact that experts in the Integration Analysis itself, the New York Independent System Operator (NYISO) in every recent report on resource adequacy, and this proceeding all say “renewable energy resources may not be capable of meeting the full range of electric system reliability needs that will arise as fossil generation is replaced” does not dissuade Weiderpass from his belief in the work of Jacobson.
Wind, Water, and Solar Has Been Refuted
In order to address the flawed wind, water, and solar work I think the following description from a year-old post is appropriate to repeat here. It is not only the agencies responsible for reliability that are saying new technology is needed and wind, water, and solar are insufficient. Supporters of this argument must ignore that Jacobson’s arguments have been refuted.
When the Climate Action Council voted on the Scoping Plan last year the statement of Robert W. Howarth, Ph.D., the David R. Atkinson Professor of Ecology & Environmental Biology at Cornell University exposed the basis of the “no new technology is needed” argument in the Climate Act:
I further wish to acknowledge the incredible role that Prof. Mark Jacobson of Stanford has played in moving the entire world towards a carbon-free future, including New York State. A decade ago, Jacobson, I and others laid out a specific plan for New York (Jacobson et al. 2013). In that peer-reviewed analysis, we demonstrated that our State could rapidly move away from fossil fuels and instead be fueled completely by the power of the wind, the sun, and hydro. We further demonstrated that it could be done completely with technologies available at that time (a decade ago), that it could be cost effective, that it would be hugely beneficial for public health and energy security, and that it would stimulate a large increase in well-paying jobs. I have seen nothing in the past decade that would dissuade me from pushing for the same path forward. The economic arguments have only grown stronger, the climate crisis more severe. The fundamental arguments remain the same.
I believe that this is the fundamental basis for the Climate Act’s aggressive schedule because it suggests there are no implementation issues, only a matter of political will. The Jacobson analysis approach unfortunately is pretty much the same as the Integration Analysis modeling approach for the Scoping Plan. Both modeling efforts project future load requirements, then list a bunch of control strategies, estimate the energy they could produce, and presume everything will work together if we cross our fingers. Neither does feasibility analysis that considers reliability, affordability, or cumulative environmental impacts. Note, however, the Integration Analysis does conclude that a new zero-emissions dispatchable resource is needed.
Howarth appeals to the authority of peer-reviewed science to provide credibility to the Jacobson analysis. However, science is a continuous process where hypotheses are constantly challenged and confirmed. In this instance Howarth neglects to mention the analyses that discredit the Jacobson work.
The Jacobson analysis cited was a continuation of previous work. For example, in a widely publicized November 2009 Scientific American article, Mark Jacobson and Mark Delucchi, suggested all electrical generation and ground transportation internationally could be supplied by wind, water and solar resources as early as 2030. However, other contemporary projections were less optimistic. Two examples: the 2015 MIT Energy and Climate Outlook has low carbon sources worldwide as only 25% of primary energy by 2050, and renewables only 16% and the International Energy Agency’s two-degree scenario has renewables, including biomass, as less than 50%.
Howarth’s statement cites a specific plan for New York (Jacobson et al. 2013) that he and Jacobson laid out a decade ago. He says that “In that peer- reviewed analysis, we demonstrated that our State could rapidly move away from fossil fuels and instead be fueled completely by the power of the wind, the sun, and hydro.” Table 2 from that report follows. This analysis includes power from exotic resources such as waves, geothermal, tidal turbines, and concentrated solar power but no energy storage. It is significantly different than the projections in the Integration Analysis and the New York Independent System Operator (NYISO) 2021-2040 System & Resource Outlook that exclude all the exotic renewable generating capacity, contain significant amounts of energy storage, and include a new dispatchable, emissions-free resource for a set of resources that they think is necessary to provide sufficient electrical power for the future. In my opinion, any analysis that suggests that concentrated solar power is a viable source of energy in New York is simply not credible because that resource would never work in New York. It is too cloudy to operate enough to cover costs and the environmental impacts would be too great. Furthermore, Jacobson and Howarth claim that end-use power demand can be decreased by 37%. I question whether we can electrify all other energy uses and decrease end-use power demand.
There was a formal rebuttal paper to this analysis. The rebuttal paper argued that:
The feasibility analysis performed by Jacobson et al. (2013) is incomplete and scientifically questionable from both the technical and economic perspectives, and it implicitly assumes, without sufficient justification, that social criterion would not produce even larger feasibility barriers.
Jacobson et al. responded to that rebuttal claiming that “The main limitations are social and political, not technical or economic.” Given the significant differences between that analysis and the most recent projections by the organization responsible for keeping the lights on, I agree with the rebuttal conclusion cited above. I do not believe that the 2013 analysis includes a defensible feasibility analysis.
Using Jacobson as the basis for the Climate Act transition has an even larger credibility problem. Unmentioned by Dr. Howarth is that in a 2015 article for a different iteration of the wind, water, and solar roadmap Clack et al, 2017 discredited the Jacobson approach:
In this paper, we evaluate that study and find significant shortcomings in the analysis. In particular, we point out that this work used invalid modeling tools, contained modeling errors, and made implausible and inadequately supported assumptions. Policy makers should treat with caution any visions of a rapid, reliable, and low-cost transition to entire energy systems that relies almost exclusively on wind, solar, and hydroelectric power.
In the scientific process, when issues with your work are noted, the proper response is to provide more evidence supporting your modeling tools, explain why the claimed errors are not errors, and defend your assumptions. Instead, Jacobson filed a lawsuit, demanding $10 million in damages, against the peer-reviewed scientific journal Proceedings of the National Academy of Sciences and the authors for their study showing that Jacobson made improper assumptions in order to make his claims that he (and by extension Howarth) had demonstrated U.S. energy could be provided exclusively by renewable energy, primarily wind, water, and solar. In my opinion this is an appalling attack on free speech and scientific inquiry but want to emphasize that the bad actions by Jacobson in no way should be attributed to Howarth.
In February 2018, following a hearing at which PNAS argued for the case to be dismissed, Jacobson dropped the suit. The defendants then filed, based on the anti-SLAPP — for “Strategic Lawsuit Against Public Participation” — statute in Washington, DC, for Jacobson to pay their legal fees. In September 2022, he was ordered to pay the defendants’ legal fees based on a statute “designed to provide for early dismissal of meritless lawsuits filed against people for the exercise of First Amendment rights.”
In my opinion Jacobson’s attempted lawsuit was because his work could not stand on its own. Therefore, it is unsettling that it is claimed to be the basis of the Climate Act. Howarth’s statement explicitly lays out his position for the Jacobson analysis:
We further demonstrated that it could be done completely with technologies available at that time (a decade ago), that it could be cost effective, that it would be hugely beneficial for public health and energy security, and that it would stimulate a large increase in well-paying jobs.
Unfortunately, Howarth’s technology demonstration is not supportable. Nonetheless, it forms the basis for the Climate Act schedule and zero-emission electric system by 2040 mandate. The Climate Action Council has embraced it despite the conflicting projections in the Integration Analysis and the NYISO Resource Outlook that reject it. This PSC proceeding is the final reason to disregard the claim that existing technology is sufficient for the transition.
Discussion
I have asked myself many times why climate advocates ignore anything that does not fit their narrative that climate change is an existential threat and the energy transition away from fossil fuels will be painless, save money, and solve the threat of climate change. Francis Menton recently addressed this in a post entitled Climate Advocacy: Incompetence or Intentional Fraud? He describes an article about the electricity system on one of Spain’s Canary Islands, El Hierro, that claims “it ran its electricity system entirely on wind and water power for 28 consecutive days.” Menton has advocated for a real-world test of the claims that an electric grid can be run solely on today’s renewable energy systems. He explains that this system is the closest thing we have to such a field study: “The El Hierro system has wind turbines and energy storage from a pumped hydro system with nameplate capacity seemingly well in excess of peak electricity usage on the island.” It turns out that it is not working out:
And yet, despite having such a rare near-perfect site for a large pumped hydro storage facility, the El Hierro system does not have nearly the energy storage needed to provide full-time electricity from the wind/storage system. It would need to multiply its storage capacity by at least an order of magnitude to come close to 100% electricity from this system. Meanwhile, most of its electricity comes from a backup diesel generator.
Menton addresses the disconnect of advocates in his conclusion:
So, is the piece mere incompetence, or intentional fraud? Several factors would seem to give strong support to the inference of intentional fraud — failure to mention the diesel backup at all; failure to mention the number of hours in each recent year where the diesel backup had to be called into activity to keep the lights on, and whether that number of hours was trending up or down; failure even to consider how much energy storage would be needed to enable the system to operate full time without the diesel backup, and whether there are any plans to provide that amount of storage or at what cost. Is it possible that someone could write a piece on this subject without even being aware of these issues? You be the judge!
I think the comments by Gupta and Weiderpass should be judged similarly. Is it possible that any climate activist who is so involved in an advocacy organization would not be aware of the reliability and affordability issues. I will be generous and say there is a third possibility. If they remain in their insular world where anything contrary to their beliefs is labeled as disinformation, then they may not know any better.
The question is what would it take for them to change their minds? Given that the belief that no new technology is only possible if you don’t read the Integration Analysis details, you believe that the NYISO is a shill for fossil fuel interests, so their reports are biased, and think that the PSC does not understand the electric system. Instead, they believe in a couple of academics. I have long thought that when the problems described by NYISO cause a blackout that the activists would get it. Now I think the climate advocacy bubble will blame something else and the true believers will continue to deny reality.
Conclusion
It is disappointing that those who claim to support the “science” and denigrate anything inconsistent have it exactly wrong. The Climate Act dependency on the work of Jacobson and Howarth is flawed and the experts who are responsible for the electric system have it right. There is no question that technology that is not commercially available is needed unless New York comes to its senses and embraces nuclear power. Anyone who argues we can transition to renewables without exotic means is wrong and is distracting from the real issues at hand.
There is an important ramification of the Scoping Plan’s implicit endorsement of the no new technology paradigm. Because all the technology was assumed to be available, the Climate Act implementation schedule is overly optimistic. The risks of forging ahead to meet the “zero emissions” by 2040 goal without knowing the potential costs of technology that is not commercially available and even whether some of the technologies will work as assumed is assumed are extraordinarily high.
Climate activists constantly urge action without delay because of the climate crisis. Those arguments never address the impact of New York GHG emissions on global warming. 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. As a result, the elimination of New York emissions will be replaced by increases elsewhere in less than a year. Weighing the risks to reliability and affordability against the negligible risks on climate change posed by New York emissions clearly destroys the myth that urgent action is required. That is not to say that New York should not do something, but it clearly argues that we have time to make sure that the actions taken do not do more harm than good.
Pragmatic Environmentalist of New York 