On September 9, 2024 the Hochul Administration initiated the development of the State Energy Plan announcing the release of a draft scope of the plan. On November 15 New Yorkers for Clean Power (NYCP) sponsored a related webinar titled “Get Charged Up for the New York Energy Plan”. My first post on this webinar described the response to my question does New York need a Climate Act feasibility analysis. This post addresses the presentation of one of the speakers.
I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act) net-zero mandates will do more harm than good if the electric system transition relies only on wind, solar, and energy storage because of reliability and affordability risks. I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 470 articles about New York’s net-zero transition. The opinions expressed in this article 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.
Takeaway Message – If you don’t have ~15 minutes to read the whole thing
This article describes the presentation by Janet Joseph who was deeply involved in the development of the Scoping Plan. She noted that issues associated with reliability and affordability are real problems that the advocacy community must address. The insurmountable problem with that is reality bats last.
Her presentation and the others in the webinar did not provide solid support for the listeners to address the reliability and affordability problems. In my previous post about this webinar I documented that the claim by Dr. Robert Howarth that no new technology is necessary is contradicted by the agencies and organization responsible for electric system reliability. Janet Joseph’s presentation disparaged those professionals so I expect that will be the essence of advocate comments. Her presentation also argued that the energy plan should align with the Scoping Plan ignoring the fact that there hasn’t been a response to critical comments on that document. Worse, the Hochul Administration has never proven that the list of strategies in the Scoping Plan are feasible.
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% GHG reduction by 2030. Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “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 quantified 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.
Although related, the Energy Plan should not be confused with the Scoping Plan. 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 with a defined planning horizon of 2040. This makes the Climate Act’s 2040 goal of carbon-free electricity particularly relevant. That plan is to rely on wind, solar, and energy storage. In my opinion, the Energy Plan must prove this will work.
Key Takeaways from the Event
The description of the New Yorkers for Clean Power sponsored a webinar titled “Get Charged Up for the New York Energy Plan” stated:
on November 15th. We are electrified by the demonstrated interest and information shared to support New York’s climate goals through the development of an ambitious and equitable State Energy Plan. To recap, our featured speakers were:
- Janet Joseph, Principal, JLJ Sustainability Solutions (Former VP of Strategy and Market Development, NYSERDA
- Dr. Robert Howarth, Member, New York’s Climate Action Council, and David R. Atkinson Professor of Ecology and Environmental Biology at Cornell University
- Christopher Casey, Utility Regulatory Director for New York Climate and Energy, Natural Resources Defense Council (NRDC)
We’re excited to share the recording and slideshow from the event: Here is the recording of the event and check out the Presenters’ slides here.
Key Takeaways from the Event
- Energy Plan is foundational to achieving New York’s climate and energy goals, aligning policies with the CLCPA.
- Engagement from advocates, community members and developers is critical for ensuring equitable and actionable outcomes.
- Challenges like building decarbonization and system reliability require innovative solutions and statutory changes.
This post addresses the presentations of Janet Joseph with respect to my concern that transitioning the New York electric grid to one that relies primarily on wind, solar, and energy storage will adversely affect reliability and affordability.
Janet Joseph Presentation
The introduction for Janet Joseph notes that before her present gig with her own consulting firm she worked at the New York State Energy Research & Development Authority (NYSERDA). In that role she was involved in the development of the Scoping Plan and earlier iterations of the Energy Plan. Her
presentation noted that now that she is on her own, she can say what she “really thinks” about the transition dictated by the Climate Act.
One of my issues with New York’s unilateral net-zero transition is that we are such a small player in this global problem that whatever we do really cannot make a difference. Joseph argued the opposing view that New York’s climate agenda is important. She believes that New York needs to lead the way showing other jurisdictions how decarbonization can be accomplished. “Mother nature’s accounting system is the only one that matters means we have to push for things that can be replicated in other regions”. She did note that political accounting means we must push for policies that provide real co-benefits. There were many things stated during the webinar that I take exception to, and this is one of them. The calculation of co-benefits is largely a values judgement exercise that the Scoping Plan has biased by over-estimating benefits and ignoring disbenefits. I could go on, but this is a minor issue relative to the Energy Plan.
Joseph explained the differences between the Energy Plan and Scoping Plan. Her description of the Energy Plan concerns me. She stated that the energy plan is the original place where NY’s “progressive energy policies and practices originated” due to the energy crisis of the 1970’s. In my opinion one of the major tenets of progressivism is the preference for equity over equality which I believe adds unnecessary risks to electric system planning. Note that the NYCP takeaways include the desire for “equitable and actionable outcomes”. Joseph also said that the Energy Plan is “the vehicle used to push many progressive policies in New York”. Equity “recognizes that each person has different circumstances and allocates the exact resources and opportunities needed to reach an equal outcome”. On the other hand, “equality means each individual or group of people is given the same resources or opportunities”. Translating that difference into electric system planning is a distraction for safe and adequate power for everyone.
Jospeh’s presentation notes that policies like renewable portfolio standards, energy efficiency, solar and storage issues all came from the energy plan. I am disappointed by her remarks related to renewable energy. She stated that “In the 1990’s, get this, we were debating 300 MW of renewable energy” because the opposition at the time said, “it would bring the system down”. She concluded “Same arguments and same barriers in different decades” insinuating the proposed transition is simple. In the first place, the scale of the renewable development is different – in 2030 wind and solar is expected to be over 100 times greater than 300 MW. I think it is irresponsible to demonize the people who are responsible for keeping the lights on by anyone who will suffer no consequences by being wrong. The biggest issue is that we are now debating whether the existing electric system of New York can be converted to one that relies on renewables even though no jurisdiction anywhere has successfully done so. Disparaging New York’s electric experts gives the advocates who listened to the presentation false security and hope.
Joseph noted that while we have a comprehensive climate plan, we still must do the energy plan. This is another point of disagreement. In my opinion, the Scoping Plan is not comprehensive, it is just an outline of strategies that the Integration Analysis claims will comply with the Climate Act mandates. There has never been any responses to critiques raised during the Scoping Plan comment process but, more egregious from my perspective, there has never been a feasibility analysis.
In the presentation she said that there were five things advocates should be looking to be included in the Energy Plan but in her presentation she only described four things.
She said that the first aspect that needs to be included in the Energy Plan is alignment between the scoping plan and the energy plan. Joseph argued that confusion and conflict between the two documents would cause delays, and we do not have time for that. She wants “at a minimum, high level alignment, and ideally all the way down to perfect synergy of these documents”. In my opinion, the presumption made by the presenters that the Scoping Plan is feasible is simply crossing our fingers and hoping. I raised many issues in my Draft Scoping Plan comments that were not addressed by the Climate Action Council and remain unresolved to this day. Therefore, the Energy Plan offers the opportunity to correct the oversights and errors in the Scoping Plan. It is inappropriate to assume alignment of the documents is appropriate. We need to determine feasibility.
The second aspect raised was that the Energy Plan is a medium range plan from 2025 to 2040. Her presentation urged the advocates to not debate how we will achieve the last 20%. Joseph said that her experience has led her to believe we should focus on what we need to do to achieve the next 20% of reductions. I disagree with this concept because it is likely that when the technologies for dispatchable emissions-free resources are selected nuclear power will be the best choice. If that is the case, then renewables are not needed, making the current approach a costly dead end.
The third item she mentioned was that the Energy Plan has its roots in system reliability. She said opponents to the renewables approach will be harping on reliability and affordability. She admitted that those issues are real and that they will resonate politically. Then she said that “the advocacy community must be armed to fight that battle and address the impact on reliability and affordability as best you can.” She went on “System reliability issues will be the primary lenses through which recommendations will be filtered.” Then she gave an example where the Urban Green Council partnered with a utility and a “credible analytical entity” to determine where reliability issues would not be an issue for New York City residential building electrification. This is a common advocacy approach where “results for hire” consultants develop an analysis that supports the pre-conceived conclusions of funding organizations. In my previous post on this webinar I documented that a similar targeted analysis that runs contrary to the findings of all the agencies of responsible for New York electric system reliability is being used to support renewable development. In my opinion, the only way to refute concerns about reliability issues associated with renewables is to cherry pick analyses and ignore reality.
The fourth aspect energy plan she made is particularly concerning. She said that (my transcript):
We have to evolve and expand from a narrow technocratic focus on the engineering requirements that keep the fuel flowing and the lights on to one that considers how our system, our infrastructure, and our practices need to change to increase the resiliency of human beings to survive within the new energy system dynamics and new climate extremes.
This aspirational baloney is difficult to interpret. The interpretation and weighting of the proposed energy plan effects on “new energy system dynamics” and “new climate extremes” makes all the difference in the interpretation of her comments. When advocates ignore the difference between weather and climate to ascribe every extreme weather event to climate change then the concept that everything needs to change to deal with the supposed existential threat is necessary. She could be arguing that the Energy Plan must address this effect. On the other hand, the reference to “new energy system dynamics” could be a tacit acknowledgement that relying on weather-dependent resources is an inherently less reliable approach. I believe that relying on weather-dependent resources will inevitably mean that someday electricity will not be available when needed most. She goes but does not clarify this distinction in my opinion:
“In short we need more focus not on just system reliability in this energy plan but resiliency. We cannot be afraid to talk about what happens when the lights go out and how people remain safe in that event. We will have storms, we will have downed power lines, and the lights will go out. We need to think through this. It is not just a New York issue. This is a certainly a global issue. We will have extreme weather that will affect the totality of our infrastructure.
This is bigger than an emergency preparedness plan. Our future energy and related infrastructure policies and practices need to be shaped with these considerations in mind. Here too, I sat in too many conversations over the years where people are debating – That shouldn’t be in an energy plan – it should be in an adaptation plan. “That’s not a climate plan – it should be in a resiliency plan”. It doesn’t matter where it is folks. We have to start thinking through the weather extremes that we will be faced with, this rapidly changing energy system and how it affects people. We need more focus on resiliency.
She then threw out some ideas to “make it real”. She suggested both heating and cooling capabilities should be mandated for landlords in our future climate. She recommended more “community resiliency facilities with backup power”. She also suggested that home designs should include “climate-safe zones” and maybe “requirements for solar and storage on every new home and subsidies for those who can’t afford it”. She recommended weatherization to increase passive survivability in the event of a power outage. She admitted that we have “GW of solar that is “not going to help us from a resiliency standpoint” and concluded that we need to determine what to do to improve upon this.
She concluded that:
I think that we have made tremendous progress in New York State in the Climate Scoping Plan developing really comprehensive GHG mitigation strategies. I am proud to have participated in that activity. But I don’t think we really have moved the needle on policies and practices that would develop a more resilient system at the central community and local level. Just to be clear
I am not in the camp of those people who think every change we are making to reduce GHG emissions and increase renewables is going to take the system down. I am in the camp that we have to think through this and make sure we are building in resiliency all the way down to the local level. So I am hopeful that this energy plan will pick up on those hard resiliency discussions in a very meaningful and substantive way. These are hard conversations but we have to start having them.
The interpretation of which factors affecting resiliency she is concerned about is important. She has enough experience and background to know that the new energy system dynamics have real risks. I have no doubt that she sincerely believes that “new climate extremes” is a real thing. If she believe that the primary resiliency driver is more extreme weather, her suggestions boil down to whether the emphasis should be on mitigation or adaptation. On the other hand, she could be admitting that the new energy system dynamics are a real concern that could be addressed by accepting less reliability and just dealing with blackouts better. That is not outside the realm of possibility because I have read climate advocates who have argued that it is appropriate. However, that response is antithetical to New York electric resource planning doctrine and I think most electric users in the state would not accept more frequent and longer blackouts as an acceptable risk for reducing GHG emissions.
Conclusion
It was interesting that Janet Joseph recognized that reliability and affordability are real. Then she said that “the advocacy community must be armed to fight that battle and address the impact on reliability and affordability as best you can.” The insurmountable problem with that is reality bats last. I have three related concerns about presentations at this webinar.
The presentations gives Climate Act proponents false confidence that the proposed transition to an electric system that relies on wind, solar, and energy storage has few risks. In my previous post about this webinar I documented that the claim by Dr. Robert Howarth that no new technology is necessary is contradicted by the agencies and organization responsible for electric system reliability. Janet Joseph’s presentation disparaged those professionals inappropriately in my opinion.
Joseph’s remarks also argued that the upcoming Energy Plan must align with the Climate Act’s Scoping Plan. I do not think that the Scoping Plan proved that its proposed strategies would maintain system reliability standards or that it would be affordable. In her leadership role on the Energy Efficiency and Housing Advisory Panel she never responded to related comments and questions on the Draft Scoping Plan. That lack of acknowledgement of criticism was true of all the critical comments made. As a result, I think the Scoping Plan is flawed and must not be used as the template for the Energy Plan.
Finally, I disagree with the Joseph’s support for progressive equity concepts relative to the electric system. That approach would require treating the availability and affordability of electricity differently to certain constituencies. That is anathema to me because I think there will be serious unintended consequences.
Pragmatic Environmentalist of New York 