On March 18, 2025 Senator Mattera invited Richard Ellenbogen to Albany to address the NY State Senate Energy & Telecommunications Committee regarding NY State’s energy situation. This article describes the presentation and documents meeting materials and follow up information.
Ellenbogen is the President [BIO] of Allied Converters and frequently copies me on emails that address various issues associated with the New York Climate Leadership and Community Protection Act (Climate Act). I have published other articles by Ellenbogen including a description of his keynote address to the Business Council of New York 2023 Renewable Energy Conference Energy titled: “Energy on Demand as the Life Blood of Business and Entrepreneurship in the State -video here: Why NY State Must Rethink Its Energy Plan and Ten Suggestions to Help Fix the Problems”. He is an engineer who truly cares about the environment and is an early adopter of renewable technologies at both his home and business.
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 reduction target of a 40% GHG reduction by 2030. 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.” 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.
Senate Energy and Telecommunications Committee Meeting
On March 18, 2025 Senator Mattera invited Richard Ellenbogen to Albany to address the NY State Senate Energy & Telecommunications Committee regarding NY State’s energy situation. Senator Parker, the committee chair, was extremely gracious and essentially gave him an unlimited amount of time to describe his thoughts on utility decarbonization using existing technologies. There is a video of the hearing available. Ellenbogen’s presentation starts at 12:40.
Senator Parker has shown signs of pragmatism regarding the implementation of the Climate Act. During the 2023 budget process he co-sponsored a bill to modify the Climate Act to use the 100-year global warming potential (GWP) that the Environmental Protection Agency and the Intergovernmental Panel on Climate Change use instead of the 20-year GWP mandated by the Climate Act. The only reason to use the 20-year GWP is the irrational belief that methane is a significant threat to global climate. New York’s environmental community went ballistic calling the proposed revision an attempt to gut the Climate Act. The proposal was quietly withdrawn in response to the pressure. Frankly, I thought that experience would mean that Ellenbogen’s presentation on the heretical idea that using natural-gas fired combined cycle combustion turbines with carbon capture (that can get a 90% CO2 reduction but not reach zero emissions) would be given short shrift but it wasn’t.
Ellenbogen Presentation
Ellenbogen referred to a handout during his presentation and the full version of the document is available. He also referenced recent comments on utility system decarbonization 15-e-0302 that provide more background information. The remainder of this section describes highlights of the hearing with links to the video for each highlight.
Ellenbogen’s presentation started with a description of his background. As noted in the introduction he has a proven record of reducing GHG emissions, waste reductions, and energy efficiency deployment at both his home and manufacturing facility. He emphasized that his strategies reduced emissions significantly but did not eliminate them entirely so his efforts would not be enough to meet Climate Act mandates.
Ellenbogen made the point that the Climate Act authors placed too much reliance on Academic “Science”. He gave an example describing how the emphasis on methane is misplaced. I agree that the methane obsession in the Climate Act is irrational.
Ellenbogen offered to discuss his concerns about the results of Ignoring science during his summary of the problem. His personal decarbonization experience made him aware of logistical issues so the labor and supply chain that are delaying the Climate Act strategies were no surprise to him. He argues that physics makes the reliance on wind and solar an impossible proposition. He has explained to me that the energy density of wind and solar energy is too low and the resource intermittency too variable to ever support a reliable electric system relying on those resources
Ellenbogen says that one of the huge issues is New York’s existing fossil load. He described the following chart explaining that the first column is the load in 2019. If we were to electrify everything you would get the second column because many of the electric technologies are more efficient. The problem is that without energy storage the system breaks down. The third column shows the energy storage in the NYSERDA report New York’s 6 GW Energy Storage Roadmap: Policy Options for Continued Growth in Energy Storage. Column D lists the state plan for renewables in 2035. The point of the graph is that the projected renewables do not come anywhere near what is needed.
Ellenbogen’s presentation argued that there is a better way that “adheres to reality”. He believes that repowering existing power plants with combined cycle gas turbines gives a carbon reduction of “30 to 40%.” Replacing the old units reduces emissions, decreases reliability risks because the old units are so old that they are more likely to fail, and because the combined cycle plants are more efficient, they would burn less fuel to produce the same amount of electricity.
Note: I will eventually publish a post describing my supplemental emissions analysis of this proposal. For this article note that when I evaluated 2020 emissions and I found that if 45 existing New York fossil-fired units were replaced by state-of-the-art combined cycle natural gas fired combustion turbines, annual emissions would be reduced 16%. My results are lower than the Ellenbogen presentation because I did not account for the improved efficiency and resulting lower fuel use that would reduce emissions more. Ellenbogen’s email description of the analysis provides background information until I do a detailed post on emissions.
Questions
I am not going to address all the questions and issues that were raised during the presentation. The following are some highlights.
Senator Parker had questions about methane. Ellenbogen responded that the emphasis on methane reductions is misleading because recent analysis shows that anthropogenic activities are not the primary source of methane in the atmosphere. Consequently, reducing natural gas in New York is not going to significantly affect potential global warming.
There was a cost discussion. Ellenbogen did not respond to the issues raised during the presentation because he needed to review recent information. He did respond to the questions in a follow-up letter that referenced a Central Hudson response to a rate case question about the costs of the Climate Act. It has been my experience that every issue I have looked at is more complicated than it appears at first glance. Such is the case with the Central Hudson $4.269 trillion cost estimate based on the Scoping Plan. Suffice to say here that there is a lot of uncertainty associated with that figure. I have addressed some of the affordability problems recently but will explain the issues associated with the Scoping Plan cost estimates some other time.
I want to discuss is the comment by Parker that the state will not be repealing the Climate Act. He asked Ellenbogen what we can do to make it successful. Ellenbogen responded that we need to broaden the terms to overcome physics reality. He explained that the energy density of wind and solar is insufficient for what is needed. Intermittency is another issue because it needs over-building and storage. Ellenbogen’s recommendation is for a non-zero alternative because it is energy-dense and dispatchable. There still are significant reductions but reliability risks are eliminated.
Parker said he would need to see the difference between the various options described. We know existing emissions levels but he also wants to see the improvements due to more efficient combined cycle units and the improvements if carbon capture is added to that. The analysis of mine described earlier was prepared to directly respond to these questions.
When Ellenbogen was asked for recommendations going forward, he said “We have to be realistic” because the reality is that physics and math limit what can be done for the transition. That leads to his recommendation to pursue combined cycle combustion turbines with carbon capture until other proven zero-emissions technologies like nuclear can be deployed.
Parker re-iterated his request for emission numbers and noted that the timeline may have to shift to accommodate numbers and physics. He admitted that we are not on track for a variety of reasons. More importantly he also said that at the end of the day NY is not going to solve the climate crisis but we can still provide leadership.
Discussion
Ellenbogen’s recommendation is a pragmatic solution that I support. Unfortunately, there was no one at this hearing who was aware of the recent history of re-powering proposals for combined cycle natural gas plants and relevant nuances of the Climate Act that make this approach a tough sell.
For example, at one point Senator Parker stated that if there are companies out there that want to submit proposals for combined cycle plants, they should submit proposals. The problem is that three repowering project applications have all been rejected or withdrawn since the Climate Act passed. The Danskhammer Energy Center proposed a replacement gas-fired combined-cycle combustion turbine but DEC denied the permit stating that “The proposed project would be inconsistent with or would interfere with the statewide greenhouse gas emissions limits established in the Climate Act.” Although not a combined cycle proposal, NRG Energy proposed replacing their old units with modern units but the DEC decision letter claimed that “the Project would be inconsistent with or would interfere with the attainment of the Statewide greenhouse gas (GHG) emission limits established in Article 75 of the Environmental Conservation Law (ECL)”. A subsidiary of Eastern Generation LLC proposed to repower their old turbines at Gowanus and Narrows with modern simple cycle turbines. As far as I could tell everyone at this hearing understood the benefits of replacing old with new and trying to avoid stranding the investments. This development was for barge mounted turbines. Once it was clear that they could be replaced with something consistent with the Climate Act they could have been moved elsewhere but the company withdrew their application because of DEC’s position on consistency with the Climate Act.
There also is a problem with the recommendation to capture the carbon. My reading of the Climate Law is that it prohibits the use of carbon capture and sequestration for an electric generating unit. The references to sequestration in the law are associated with the definition of “Greenhouse gas emission offset projects” that includes the following project: carbon capture and sequestration. Section 75-0109 “Promulgation of regulations to achieve statewide greenhouse gas emissions reductions (4. a.)” states that “The department may establish an alternative compliance mechanism to be used by sources subject to greenhouse gas emissions limits to achieve net zero emissions.” However, carbon capture and sequestration at electric units is expressly prohibited in § 75-0109, (4,f) “Sources in the electric generation sector shall not be eligible to participate in such mechanism.”
Conclusion
I was very encouraged by the meeting. Senator Parker’s admission that there are implementation issues and course corrections are necessary is refreshing because most of his colleagues have not shown any departure from the orthodoxy. At one point during the meeting Senator Mattera and Senator Parker agreed on the need to be more flexible which Richard Ellenbogen notes is the equivalent of seeing a Unicorn. All this suggests that there might be support for a course correction of the Climate Act.
Nonetheless, I want to point out that at the end of the meeting Ellenbogen left a gift for Albany – a wand in a glass case with a note saying in case of a blackout break glass. A magical solution still may be the last hope.
Pragmatic Environmentalist of New York 