Keith Schue sent me an email with the following information that I believe would be of interest to readers here. New York State agencies have recently announced several draft documents that are out for public comment. It is confusing. When Keith sent this clarifying information, I asked for permission to send it out as a post and he graciously gave me permission.
Keith Schue is an electrical engineer and technical adviser on energy policy. Keith advocates for nuclear power. He recently co-authored a commentary in the Albany Times Union with climate scientist James Hansen, making a persuasive case for using nuclear in the future.
Overview
The Climate Leadership & Community Protection Act (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 GHG reduction target of 40%. Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and a requirement that all electricity generated be “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” 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. Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation.
Keith describes three related documents and opportunities for public comments in the following sections. I have made some minor edits and added a few links. He describes each document and includes a suggestion for a possible comment.
Draft Blueprint for Consideration of Advanced Nuclear Technology
A number of states throughout the country are encouraging the development of advanced next generation nuclear reactors to meet our growing energy needs, remain economically competitive, significantly reduce greenhouse gas emissions, conserve farmland, and protect nature. During last month’s Future Energy Summit in Syracuse, Governor Hochul announced that New York ought to consider advanced nuclear power, too. However, several misguided “environmental” groups who either don’t understand energy or don’t care about those things have launched a misinformation campaign involving form-letters to the governor and NYSERDA intended to create the appearance that New Yorkers oppose nuclear power. They would rather see the state pursue an unproven, inefficient, ecologically-destructive energy strategy dominated by massive amounts of solar, wind, and batteries.
The due date for comments is Nov 8th. A useful comment would be to say that if New York is serious about addressing climate change, providing ample reliable electricity essential for a growing economy, and protecting the integrity of rural land and nature, then it needs to join the 21st century by investing in dependable, compact carbon-free nuclear power.
Click here to read the draft Blueprint: Read Draft Blueprint
Click here to comment on the draft Blueprint: Comment on Draft Blueprint
Draft Scope of NYS Energy Plan
Although related, this should not be confused with the Climate Action Council’s Scoping Plan for implementation of the CLCPA that was adopted in Dec 2022. Every several years the New York Energy Planning Board is required to update its overall energy plan for the state. The process begins with an initial document that identifies a “scope” of work–meaning the set of things to be evaluated in the plan. That draft “scope” was released last month for public comment with a defined planning horizon of 2040. This makes the CLCPA’s 2040 goal of carbon-free electricity particularly relevant. Unlike the CLCPA’s 70% renewable goal which only applies in 2030, the 2040 goal does not mandate an arbitrary quota of “renewables”. Instead, it simply mandates carbon-free electricity, which can include nuclear power.
The due date for comments is Nov 25th. An important comment would be to say that if New York is serious about achieving carbon-free electricity as electricity demand doubles, it needs to invest in reliable and resilient nuclear power that is made in America, instead of focusing predominantly on wasteful, fragile, intermittent, and ecologically-harmful sources of energy made mostly in China.
Click here to read the draft Scope: Read Draft Scope
Click here to comment on the draft Scope: Comment on Draft Scope
Draft NYPA Renewables Strategic Plan
Historically, the New York Power Authority (NYPA) has been a well-run public entity that has provided NY residents and business with reliable, affordable electricity by building and operating large hydropower plants and various electric infrastructure projects. In the past, NYPA even helped to develop nuclear power. However, the Build Public Renewables Act adopted last year now forces NYPA to try installing solar, wind, and batteries even faster than the private sector is already doing with subsidies. NYPA’s draft plan appears to leverage its good credit to help rescue or expedite about 31 private-sector large-scale solar/wind/battery projects. It would also build about 9 such projects itself.
The due date for comments is around Dec 8th. A useful comment would be to say that achieving carbon-free electricity requires firm reliable power. Therefore, throwing more public money and resources at intermittent generation not only jeopardizes reliability and affordability, but also ensures that NY will remain dependent on fossil fuels. Instead of focusing on solar panels and wind turbines that the private sector can install on its own, NYPA should do what it has historically done best by working on reliable public projects for the common good, like nuclear energy, hydropower, and utility infrastructure.
Click here to read the draft NYPA Renewables Plan: Read Draft NYPA Renewables Plan
Click here to comment on the draft NYPA Renewables Plan and see the schedule of Public Hearings: https://www.nypa.gov/renewables
Conclusion
Keith’s overview is apropos and I agree with him. I am on vacation so publishing someone else’s work is an easy way to keep the hits to the blog coming. All of these documents and issues are of interest to me, and I intend to comment. The bottom line is that if New York really wants to decarbonize, then nuclear must be part of the future energy mix or it will be impossible to achieve the aspirational targets.
Pragmatic Environmentalist of New York 
The only thing more stupid than nixing nuclear power is to use it as DEFR. Let’s examine this…
First, the goal for 2040 in CLCPA states that only “existing” nuclear facilities can be counted as Emission Free. Hence, CLCPA actually does preclude the use of nuclear – by law – since all plants will eventually be replaced with new ones regardless of the law. By killing nuclear with other legislation, CLCPA is defacto eliminating nuclear power as emission free.
Elimination of existing nuclear (like Indian Point) comes from other legislation. Else, why would they do it.
But the most egregious thing about the draft nuclear plan is to treat new (or ANY) nuclear as DEFR. This is clearly an attempt to do 2 things:
(1) Keep those wind and solar subsidies flowing in
(2) Allow the state bureaucrats and government to claim a highly dishonest DEFR victory – pure politics.
It is ridiculous from both technical and economic viewpoints to utilize nuclear as DEFR. From the technical aspect, nuclear wants to run constantly. It is our best contributor to Baseload generation besides maybe hydro. It does not want to be run as a quick dispatch. That is expensive and wasteful.
From the economic viewpoint, treating nuclear as DEFR requires us to build 2 parallel systems: One for Wind and Solar, and another for nuclear. That’s double the infrastructure, and a huge amount of land. If we stopped wasting our money on Wind and Solar, we could invest in nuclear as our baseload kingpin, and not even have to build any more Wind and Solar.
In addition, if we can utilize SMNRs to replace the heat engines in existing/dormant coal/petro/gas plants, we can use the same turbomachinery and distributed transmission systems we now have – saving $Billions.
But of course, there are big investors in Wind and Solar that need to be made happy – at least until they quietly move their investments to nuclear.
Anybody pay attention to what Bill Gates just did?
I am at a loss to understand why the NYS government is so intent on destroying our economy. Are we not already losing enough population and industry as it is?
MD
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My hope is that when it becomes obvious that nuclear DEFR is necessary that the obvious next step is to cut out the wind and solar nonsense and just go nuclear.
As you said it appears that the Hochul Administratin is intent on destroying our economy. The inevitable result will be losses to population and industry
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