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 (https://pragmaticenvironmentalistofnewyork.blog/) reflects that outlook. The second blog addresses the New York State Reforming the Energy Vision initiative (https://reformingtheenergyvisioninconvenienttruths.wordpress.com). 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.

Niagara Mohawk Rate Case Ignores Opportunity to Pause Climate Act

I recently used New York utility accounts in arrears and service disconnections information in New York Open Data to develop a spreadsheet that lists the residential collection data submitted by New York’s ten largest distribution utility companies. Since then, I have been evaluating the ongoing Niagara Mohawk Power Corporation (NMPC) dba National Grid rate case. In this article I evaluated the NMPC New York Open Data and found that there are grounds to reduce costs in the rate case because the increase in overdue accounts has increased significantly since the Climate Leadership & Community Protection Act (Climate Act) was introduced.

I am convinced that implementation of the New York Climate Act net-zero mandates will do more harm than good if the future electric system 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 500 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.

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 a requirement to make the electric grid zero-emissions 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.” 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. However, the Hochul Administration has never acknowledged that there are safety valve provisions in the Act.

Safety Valve

New York Public Service Law § 66-p (4). “Establishment of a renewable energy program” includes safety valve conditions for affordability and reliability that are being ignored. Section 66-p (4) states: “The commission may temporarily suspend or modify the obligations under such program provided that the commission, after conducting a hearing as provided in section twenty of this chapter, makes a finding that the program impedes the provision of safe and adequate electric service; the program is likely to impair existing obligations and agreements; and/or that there is a significant increase in arrears or service disconnections that the commission determines is related to the program”. The problem is that the Hochul Administration’s Climate Action Council failed to establish specific criteria for these safety valves, set up a system to track the status, or consider the need for a hearing.

Niagara Mohawk Power Corporation dba National Grid Rate Case

The current NMPC rate case will raise typical household rates 20% more for electricity and 27% more for natural gas two years after the new rates start phasing in. There are many Climate Act related initiatives buried in the request. My previous article showed that Climate Act costs made up as much as 38% of the total residential utility customer costs in 2022.

The rate request filing states that the NMPC is focused on three priorities: delivery of “safe, reliable energy service to its more than two million customers”; enabling customers to “affordably meet their energy needs while improving the NMPC’s customer service”; and supporting the goals of the Climate Act. I think those priorities are inconsistent because of all my concerns related to the Climate Act impacts on reliability and affordability. I maintain that there is a safety valve in New York Public Service Law § 66-p (4) that if considered could be used to pause additional Climate Act costs. This post evaluates the number of customers in arrears to determine if there has been a significant increase.

Residential Collection Data

Utilities file a monthly report in the PSC Case 91-M-0744 docket that documents their arrears and service terminations. There is a data set in New York Open Data that provides data that can be used to determine the number of residential customers in arrears. The “Quarterly snapshot of residential collection dataset” contains this information.

This dataset provides a quarterly snapshot of residential bill collection activity for New York State’s ten largest electric and gas distribution utility companies regulated by the Public Service Commission. Included in this dataset are each utility’s total number of residential customers, residential customers with arrears (overdue bills) greater than 60 days, residential final service termination notices issued, residential accounts terminated (service shut off for nonpayment), active residential deferred payment agreements and the number of uncollectible residential accounts. Also included are the corresponding utility sales figures for each metric above, showing the dollar figure represented.

NMPC Residential Customer Summary

Table 1 lists the annual fourth quarter data for the sum of the Quarterly Snapshot NMPC category for the total number of residential customers, residential customers with arrears (overdue bills) greater than 60 days, and the percentage of residential customers with overdue bills relative to the total number of customers. Between 2019 the last year before the Climate Act was implemented and the most recent year there were 202,538 customers with arrears greater than 60 days, and at the end of 2024 there were 234,694 customers in arrears which is an increase of 32,156 or 16% increase. The final termination notices and number of service disconnections (not shown) are not good estimates of the effect of the Climate Act because other mandates have affected the data, e.g., service disconnections were suspended during COVID.

Table 1: Niagara Mohawk Power Corporation dba National Grid Summary Snapshot Fourth Quarter of Residential Collection Data

The Public Safety Law section 66-p (4) criteria for consideration of suspension or modification is a “significant increase in arrears or service disconnections that the commission determines is related to the program”. The standard deviation of the number of customers in arrears from 2010 to 2019 is 12,350. Because the observed difference, 32,156, is greater than two times the standard deviation the increase is statistically “significant”.

Climate Act Costs

The number of people in arrears has been increasing since 2010 and the change since the start of the Climate Act is “significant”. However, it is not clear how much of the change can be ascribed to the Climate Act. On May 12, 2022, the Commission issued an “Order on Implementation of the Climate Leadership and Community Protection Act” for Case 22-M-0149 that directs DPS Staff to present information on Climate Act costs annually. On July 20, 2023, DPS Staff published the first report (Information Report) in compliance with the Commission’s Order. The costs recovered in 2022 by the utilities associated with Climate Act costs were described in the following Information Report tables:

2022 Climate Act Costs as a Function of Sales

There is insufficient information to ascribe the NMPC Climate Act costs associated with the significant increase in arrears observed. However, it is instructive to calculate the percentage of Information Report NMPC Climate Act costs relative to the annual NMPC residential customer sales. Table 2 lists the sum of the annual “Quarterly snapshot of residential collection dataset” residential sales NMPC.

Table 2: NMPC Annual Utility Residential Customer Sales

The Climate Act cost recoveries for NMPC are listed in Information Report Tables 3 and 4 included above. The sum of the 2022 Climate Act costs is $352,237,995. The Climate Act costs are 38% of the 2022 residential customer sales. This indicates that a significant share of increased costs that drove the number of customers in arrears to increase was related to the Climate Act implementation.

Discussion

There are so many issues coming up with the schedule and ambition of the Climate Act that it is obvious that we need to pause implementation and figure out how best to proceed. In addition is now clear that there will be significant cost increases.

My focus has been on the electrical system but don’t forget that there have been and there will be more costs associated with other reducing emissions in other sectors. After the PSC released its first annual informational report on the implementation of the Climate Act, I noted that 2022 the costs already associated with the Climate Act increased the NMPC residential customer monthly electric bills 9.8% or $9.38 per month. I recently described an Empire Center poll that asked questions about the Climate Act. The poll found that only 50% of the respondents willing to pay more than $10 a month for Climate Costs. I do not think there is any question that half of the poll respondents were paying more for Climate Act implementation than they are willing to pay in 2022.

The DPS should formally determine the amount of residential customer sales that are related to the Climate Act and affect the number of customers in arrears as part of future annual informational reports mandated by the “Order on Implementation of the Climate Leadership and Community Protection Act” for Case 22-M-0149.

This initial assessment of the Public Safety Law section 66-p (4) criteria for consideration of suspension or modification of the Climate Act related to overdue customers or customers in arrears meets the criterion for a significant change. The standard deviation of the number of customers in arrears for ten years before the Climate Act was implemented is 12,350. Because the observed difference between the 2019 and the most recent year, 32,156, is greater than two times the standard deviation the increase is statistically “significant”. Admittedly this is not a robust statistic because of the limited data available. The onus to develop a better metric and transparently track it is on the PSC.

Conclusion

An initial assessment of the change in the number of customers in arrears since the start of the Climate Act indicates that there has been a statistically significant change. This should trigger the PSC to conduct a hearing required by New York Public Service Law Section 66-p(4). There has been no acknowledgement of the requirement, much less any recognition that such a hearing is warranted.

Inevitably reality is going to catch up with the political aspirations of the Climate Act. It is very frustrating that there is a mechanism in place to protect New Yorkers, but it has been ignored so far. The time has come for that to change.

The double-digit rate increases in the NMPC rate case could be pared down substantially if funding for the CLCPA goals was paused until there is a hearing to see if the CLCPA needs to be temporarily suspended or modified per Public Service Law Section 66-p(4). When other reasons to pause are considered, there are reasons to believe that continued Climate Act funding for renewable energy development projects may be better spent on alternative resources.

Niagara Mohawk Residential Utility Sales and Climate Act Recoveries

My previous post combined 2022 residential annual residential customer sales and the cost recoveries for Climate Leadership & Community Protection Act (Climate Act) related initiatives in 2022 to estimate the fraction of sales dedicated to Climate Act initiatives. The fraction of Climate Act costs was as much as 22% of the total residential utility customer costs in 2022. I live in the Niagara Mohawk Power Corporation (NMPC) service territory, so I applied the same methodology for NMPC.

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. However, the Hochul Administration has never fully accounted for the ratepayer impact of the transition apparently because the impacts are so high.

Residential Collection Data

In a recent article I described a source of data that includes the total dollar amount of residential customer sales. The New York Open Data website contains the Quarterly snapshot of residential collection data file. According to the general description: “This dataset provides a quarterly snapshot of residential bill collection activity for New York State’s ten largest electric and gas distribution utility companies regulated by the Public Service Commission. “

Table 1 lists the annual sum of the quarterly residential customer sales for Niagara Mohawk.

Table 1: Annual Residential Customer Sales

Climate Act Cost Recoveries

In July 2023 the Public Service Commission (PSC) released its first annual informational report on the implementation of the Climate Act. In August 2023 I noted that the informational Report explained that Climate Act costs that have been authorized and were in the 2022 residential bills total $1.2 billion. The Report notes that in 2022 the costs already associated with the Climate Act increased the Upstate residential monthly electric bills 9.8% or $9.38 per month for Niagara Mohawk customers.

The Informational Report included a summary of cost recoveries for 2022:

For purposes of estimating the cost recoveries of CLCPA related initiatives in 2022, Staff issued information requests to each of the utilities. Specifically, Staff requested the utilities provide 2022 cost recoveries for: CES (electric only), CEF (electric only), certain VDER (electric only), Electric Vehicle Make Ready Program (electric only), Clean Heat programs (electric only), Integrated Energy Data Resource (electric only), and Utility Energy Efficiency programs (electric and gas).

The cost recovered in 2022 by the utilities associated with these gas and electric programs described above are detailed in the following tables.

Climate Act Costs and Residential Customer Sales

I combined the information from the two sources for NMPC. The total residential sales in 2022 were $917 million. The combined Climate Act costs for NMPC $351 million. The Climate Act cost share of the total sales is 38% using these two data sets.

I have limited experience with these data sets, so I have reservations about the precision of the estimate. The number is probably an upper bound because the total costs should be spread over all the residential customers of the state as well as the commercial and industrial customers. In 2021 residential natural gas and electricity sales were 80% of the total residential, commercial and industrial sales. If the Climate Act costs are apportioned evenly that would reduce the Climate Act percentage of residential bills down to 31%.

Discussion

It is notable that I had to rely on data from 2022 despite the mandate annual status updates that include costs. On April 14, 2025, I published an article describing a letter I sent to Public Service Commission Chairman Rory Christian regarding the requirement for annual informational reports. In March, Michael B. Mager Counsel to Multiple Intervenors sent a letter to Chairman Christian noting that the annual report was late. Soon thereafter Jessica Waldorf, Chief of Staff and Director of Policy Implementation for the Department of Public Service (DPS) posted a response letter. My letter explained that I agreed with the comments submitted by Multiple Intevenors and was disappointed that the DPS response did not commit to a schedule for the next update of the annual informational report. The point is that the data in the Informational Reports are political dynamite. The estimate that the Climate Act costs are responsible for up to 22% of the cost recoveries in 2022 is just the beginning. The Hochul Administration has every reason to delay the release of update informatoin as long as possible because the Climate Act costs are going to be higher.

The estimated fraction of costs attributable to the Climate Act is only for one component of the costs of the Climate Act net-zero transition. These costs don’t include costs to electrify homes, personal transportation, and the hidden costs for things like upgrading electrical service to be able to electrify everything. Also, it does not include societal costs like the need to electrify school buses and pay for less impactful refrigerants used by grocery stores. The list of hidden costs goes on and on.

I recently described an Empire Center poll that asked questions about the Climate Act. The poll found that only 50% of the respondents willing to pay more than $10 a month for Climate Costs. Recall that the Informational Report found that in 2022 the costs already associated with the Climate Act increased the Upstate residential monthly electric bills 9.8% or $9.38 per month for Niagara Mohawk customers. I do not think there is any question that half of the poll respondents are paying more than they are willing to pay.

These data also raise the question of what the point is. 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. Furthermore, New York’s impact on global warming is unmeasurable. Table 2 projects the amount of global warming “savings” for the 1990 and 2022 historical emissions. The calculations are based on a Perplexity AI query “What is the expected change in global warming per ton of CO2 reduced”. If total New York GHG emissions from the baseline in 1990 or the most recent year (2022) available were to go to zero, the projected change in global warming is too small to measure.

Table 2: Potential Warming Savings for Historical Emissions

Conclusion

The costs to implement the Climate Act for NMPC residents were a little less than two fifths of monthly residential sales in 2022. I have no doubt that the costs that will be in the 2023 Informational report will increase that fraction. Sooner or later the public is going to catch wind of these unsustainable costs and I intend to write some letters to the editor using this information. Given that the investments will not meaningfully affect global emissions or global warming I cannot imagine that NMPC ratepayers will be willing to continue this madness. I hope that politicians are starting to question whether they want to be associated with this.

Residential Utility Sales and Climate Act Cost Recovery Implications

This post combines 2022 residential annual residential customer sales and the cost recoveries for Climate Leadership & Community Protection Act (Climate Act) related initiatives in 2022 to estimate the fraction of sales dedicated to Climate Act initiatives. The fraction of Climate Act costs was as much as 22% of the total residential utility customer costs in 2022.

Overview

Residential Collection Data

Table 1 lists the annual sum of the quarterly residential customer sales for the ten utilities in the Quarterly snapshot of residential collection data file. The ten utilities are: Consolidated Edison, Orange & Rockland, Public Service Electric & Gas, Central Hudson, National Grid – LI, National Grid – Upstate, National Grid New York, New York State Electric & Gas, Rochester Electric & Gas, and National Fuel Gas.

Table 1: Annual Residential Customer Sales

Climate Act Cost Recoveries

In July 2023 the Public Service Commission (PSC) released its first annual informational report on the implementation of the Climate Act. In August 2023 I noted that the informational Report explained that Climate Act costs that have been authorized and were in the 2022 residential bills total $1.2 billion. The Report notes that in 2022 the costs already associated with the Climate Act increased the Upstate residential monthly electric bills 7.6% or $7.15 per month for NYSE&G customers; 7.7% or $7.54 for RG&E customers; and 9.8% or $9.38 for Niagara Mohawk customers.

I followed up with another article that documented post hearing comments related to the NYSEG electric rate case 22-E-0317, RGE electric rate case 22-E-0319, the NYSEG gas rate case 22-G-0318, and the RGE gas rate case 22-G-0320 that address Climate Act costs. I concluded that Climate Act costs are a major factor in this extraordinarily large rate case request. This is an issue in this instance and every future rate case for every New York utility is going to have similarly large costs.

The Informational Report included a summary of cost recoveries for 2022:

For purposes of estimating the cost recoveries of CLCPA related initiatives in 2022, Staff issued information requests to each of the utilities. Specifically, Staff requested the utilities provide 2022 cost recoveries for: CES (electric only), CEF (electric only), certain VDER (electric only), Electric Vehicle Make Ready Program (electric only), Clean Heat programs (electric only), Integrated Energy Data Resource (electric only), and Utility Energy Efficiency programs (electric and gas).

The cost recovered in 2022 by the utilities associated with these gas and electric programs described above are detailed in the following tables.

Climate Act Costs and Residential Customer Sales

I combined the information from the two sources. The total residential sales in 2022 were $5,867 billion. The Climate Act costs for the gas (excluding Corning) and electric utilities were $1,289 billion. The Climate Act cost share of the total sales is 22% using these two data sets.

I have limited experience with these data sets, so I have reservations about the precision of the estimate. The 22% number is probably an upper bound because the total costs should be spread over all the residential customers of the state as well as the commercial and industrial customers. In 2021 residential natural gas and electricity sales were 80% of the total residential, commercial and industrial sales. If the Climate Act costs are apportioned evenly that would reduce the Climate Act percentage of residential bills down to 18%. I understand that municipal utilities are not treated the same so that affects the percentage estimate too.

Discussion

The estimated fraction of costs attributable to the Climate Act in only for one component of the costs of the Climate Act net-zero transition. These costs don’t include costs to electrify homes, personal transportation, and the hidden costs for things like upgrading electrical service to be able to electrify everything. Also it does not include societal costs like the need to electrify school buses and pay for less impactful refrigerants used by grocery stores. The list of hidden costs goes on and on.

I recently described an Empire Center poll that asked questions about the Climate Act. I noted that one third of the respondents are not willing to pay anything on their monthly energy bill for cleaner energy. Another 28% are only willing to pay up to $20 a month for cleaner energy while another 20% would pay up to $40 a month. Nineteen percent are willing to pay up to $200 a month but only 3% are willing to pay more than $200 per month. Given all the necessary costs I believe that $200 per month is not nearly enough for the transition.

Table 2: Potential Warming Savings for Historical Emissions

Conclusion

The costs to implement the Climate Act were about one fifth of the monthly bills in 2022. I have no doubt that the costs that will be in the 2023 Informational report will increase that fraction. Sooner or later the public is going to catch wind of these unsustainable costs. Given that the investments will not meaningfully affect global emissions or global warming I cannot imagine that the voters will be willing to continue this madness. The reckoning cannot come soon enough.

New York Residential Utility Accounts in Arrears

Thanks to Tim Knauss I found information on New York utility accounts in arrears and service disconnections on New York Open Data. These data enabled me to develop a spreadsheet that lists the residential collection data submitted by New York’s ten largest distribution utility companies and enabled me to prepare the data summary shown here.

This information is particularly relevant to the Climate Leadership & Community Protection Act (Climate Act) because there is a safety valve provision that enables the Public Service Commission to “temporarily suspend or modify the obligations” of the Climate Act if, among other things, implementation causes a “significant increase in arrears or service disconnections” related to the program. Before looking at the results please think about what you think is a reasonable percentage of customers in arrears, that is to say those who have not paid their bills for 60 days or more.

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. However, in the rush to meet Climate Act mandates fundamental consumer protections are being ignored.

Safety Valve

New York Public Service Law § 66-p (4) “Establishment of a renewable energy program” includes feasibility safety valve conditions for affordability and reliability that have not been addressed in the Hochul Administration implementation of the Climate Act. Section 66-p (4) states: “The commission may temporarily suspend or modify the obligations under such program provided that the commission, after conducting a hearing as provided in section twenty of this chapter, makes a finding that the program impedes the provision of safe and adequate electric service; the program is likely to impair existing obligations and agreements; and/or that there is a significant increase in arrears or service disconnections that the commission determines is related to the program”.

For the most part this provision of the Public Safey Law has been ignored. In my opinion it is incumbent upon the Hochul Administration to define specific criteria for each provision and establish a tracking system established to determine if suspension or modification of CLCPA obligations is appropriate. Until I found the Quarterly snapshot of residential collection data submitted I was unaware that the arrears and service disconnection data were available.

Residential Collection Data

New York State agencies love web-based dashboards because I think that they can be used to control the message. Consider the Climate Act Data Dashboard. There are options to look at the data for categories showing progress to date, but the data downloads are no more than the numbers shown in the splashy home pages. Not surprisingly there is nothing related to the safety valve conditions in Section 66-p (4).

There is an alternative source of data. New York Open Data was established to “promote transparency, improve government performance, and enhance citizen engagement”. It is a massive database that provides useful information if you can penetrate the clumsy interface to find what you want. Even then the data are just files of numbers with marginal documentation and typically require processing to get anything useful.

In a recent article on the National Grid rate case Tim Knauss mentioned that “More than 210,000 Upstate households are at least 60 days late paying National Grid, owing more than $323 million combined.” When I contacted him about the source of that information he graciously explained that the utilities file a monthly report in the PSC Case 91-M-0744 docket that details their arrears and service terminations. Unfortunately, for an overview of the status those submittals are not that useful.

I decided to check New York Open Data for these data. Nothing was obvious but when I figured out how to do a search and used some of the descriptive terms in the 91-M-0744 documents if found the Quarterly snapshot of residential collection data file. According to their general description:

This dataset provides a quarterly snapshot of residential bill collection activity for New York State’s ten largest electric and gas distribution utility companies regulated by the Public Service Commission. Included in this dataset are each utility’s total number of residential customers, residential customers with arrears (overdue bills) greater than 60 days, residential final service termination notices issued, residential accounts terminated (service shut off for nonpayment), active residential deferred payment agreements and the number of uncollectible residential accounts. Also included are the corresponding utility sales figures for each metric above, showing the dollar figure represented.

The following Data Dictionary table lists the specific parameters available by utility for each quarter starting with the first quarter of 2010. Processing this kind of data set is something I have been doing for years so I was quickly able to get a data summary together. I doubt that many members of the public have that skill set so it is transparently available in name only.

New York Residential Customer Summary

Table 1 lists the annual fourth quarter sum of all ten utilities data for the total number of residential customers, residential customers with arrears (overdue bills) greater than 60 days, residential final service termination notices issued, residential accounts terminated (service shut off for nonpayment), and active residential deferred payment agreements. Of note is that the percentage of residential customers with overdue bills has been between 13.6% and 14.2% the last three years.

Table 1: Annual Summary of Number of Customers and Bill Paying Status

New York Residential Customer Sales Summary

Table 2 lists the annual fourth quarter sum of all ten utilities data for the total sales by residential customers, residential customers with arrears (overdue bills) greater than 60 days, residential final service termination notices issued, residential accounts terminated (service shut off for nonpayment), and active residential deferred payment agreements. The highlight of this table is that the total amount of money that has accumulated since the utilities started this program is $1.86 billion which is more than the utilities collect annually.

Table 2: Annual Summary of Number of Customers and Bill Paying Status

Observations Discussion

Now that you have seen the results, how did your idea of a reasonable percentage of customers in arrears compare to the observed 13.7% at the end of 2024. I think anything over 10% is problematic. In my opinion the observed data indicate a utility system that is currently too expensive.

The number of people in arrears has been increasing since 2010. The number of termination notices issued varies quite a bit, undoubtedly in response to programs to prevent shutoffs. Fortunately, the actual number of shutoffs is relatively small because that should be a last resort. Unfortunately, the cost of these benefits must fall to an increasingly smaller fraction of the rest of the customers.

The sales figures are extraordinary. New York residential customers are paying $1.81 billion a year for utility service. The total amount of money that has accumulated by accounts in arrears since the utilities started reporting these data is $1.86 billion. I don’t think that the accumulated value accurately reflects the magnitude of the problem. Last year the sales associated with accounts that were sent final termination notices was $378 million or 20.9% of the total revenues. Surely that reflects the fact that many residential customers are having trouble paying their bills.

Significance

My primary incentive to analyze these data was to compare them to the Public Safety Law section 66-p (4) criteria for a “significant increase in arrears or service disconnections that the commission determines is related to the program”. There is no breakout of Climate Act costs that contribute to those attributes. We can only estimate whether the NY Open “Quarterly snapshot of residential collection” total data shows a significant increase.

In this case defining significance will entail many value judgements. For example, what is a “significant” increase in arrears? Before the Climate Act was passed in 2019 there were 1,046,219 customers with arrears greater than 60 days, and at the end of 2024 there were 1,383,480 customers in arrears which is a 32.4% increase. The percentage increase for the percentage of customers in arrears was 31.3%. In my opinion that is a significant increase.

There is a limited amount of data to use for a statistical evaluation of significance. Nonetheless, we can use the data we have. In simplistic terms, if a change exceeds two times the standard deviation of the observed data, we can hypothesize that it is significantly different.

Table 3 is a subset of Table 1 that lists the annual fourth quarter sum of all ten utilities data for the total number of residential customers, residential customers with arrears (overdue bills) greater than 60 days, and the percentage of residential customers with overdue bills relative to the total number of customers. Between 2019 the last year before the CLCPA was implemented and 2024, there were 1.046,219 customers with arrears greater than 60 days, and at the end of 2024 there were 1,383,480 customers in arrears which is an increase of 337,261 or 32.4% increase. The percentage increase for the percentage of customers in arrears was 31.3%.

The standard deviation of the number of customers in arrears from 2010 to 2019 is 39,175 and the percent in arrears standard deviation is 0.6%. The observed increases are greater than two times the observed standard deviations. Keep in mind that a standard deviation based on ten observations is anything but robust so this indicative but not conclusive that there is a “significant” increase in arrears.

Table 3: Annual Customers in Arrears

There are other aspects of the calculation of significance for Public Service Law Section 66-p(4). Other value judgements for significance include the following. What costs are related to the Climate Act? Should the costs include programs implemented before the Climate Act but that are necessary to achieve the Climate Act goals. Should the evaluation consider the effect of programs designed to lower costs, programs that give residents an active payment plan and prevent service disconnections that all affect the totals? Should “significance” be defined relative to the value of the emission reductions for the programs in absolute terms or relative to global emissions?

All these have been valid questions since the Climate Act was passed in 2019. The Climate Action Council should have addressed this but dropped the ball. Given that there are so many issues coming up with the schedule and ambition of the Climate Act that it is obvious that we need to pause implementation and figure out how best to proceed. Defining the safety valve criteria and developing a tracking system for a transparent status report should be part of the implementation reassessment.

Conclusion

This analysis found a useful source of residential customer data. The New York Open Data was established to “promote transparency, improve government performance, and enhance citizen engagement”. Unfortunately, accessing the data file is not straightforward unless you have experience with this kind of data.

The observed differences between the number of residential customers in arrears before the Climate Act was enacted and the end of 2024 are greater than two times the standard deviations. It can be argued that this means the increase is “significant”. Therefore, it would be appropriate for the Public Service Commission to conduct a hearing to determine if it would be appropriate to temporarily suspend or modify the obligations of the Climate Act per Public Safety Law Section 66-p(4).

I think this should be resolved quickly. Given that there are so many issues coming up with the schedule and ambition of the Climate Act it is obvious that we need to pause implementation and figure out how best to proceed. Clearly defining the safety valve criteria and developing a tracking system for a transparent status report should be part of the implementation reassessment.

Roger Pielke Jr on Climate Variability

Roger Pielke, Jr. described the underappreciated importance of climate variability in a recent post. It is increasingly obvious that there are so many issues coming up with the New York Climate Leadership & Community Protection Act (Climate Act) net zero transition that we need to pause implementation and figure out how best to proceed. Pielke’s article raises another example.

I am convinced that implementation of the Climate Act net-zero mandates will do more harm than good because the proposed green energy programs are crimes against physics. 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. I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 500 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.

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. However, in the rush to meet Climate Act mandates fundamental concepts and concerns are being ignored.

Climate Variability

One of the frustrating characteristics of climate advocates is the constant attribution of any unusual weather to climate change. I have noted that a climatological average is normally based on a 30-year averaging period and explained that climate change could be defined as the difference. As is the case with all aspects of climate change issues, there is more nuance and detail than obvious at first glance.

Roger Pielke, Jr. provides nuance and detail to the question “what is climate change.”

One of the most pervasive misunderstandings of climate — even among some who publish on climate — is the belief that any long-term trend in a measured climate variable indicates a change in climate, as defined by the Intergovernmental Panel on Climate Change (IPCC}. In practice, “long-term” is often defined to be only a few decades worth of observations. Some trends in observational data are not an indication of a change in climate, and others are — telling the difference is not easy when it comes to extreme weather events.

He explains that the first issue is that climate data like any observation set of natural phenomena fluctuates naturally. A post at Climate Etc. explains:

According to the IPCC, “climate variability refers to variations in the mean state and other statistics (such as standard deviations, the occurrence of extremes, etc.) of the climate on all spatial and temporal scales beyond that of individual weather events. Variability may be due to natural internal processes within the climate system (internal variability), or to variations in natural or anthropogenic external forcing (external variability).”

Pielke explains why this should be considered when estimating climate change effects:

The IPCC AR6 explains that the detection of a change in climate requires some certainty that the trend is not simply due to climate variability: “An identified change is detected in observations if its likelihood of occurrence by chance due to internal variability alone is determined to be small, for example, <10%.”

Quantifying internal variability with respect to any climate metric is challenging, typically with multiple valid interpretations possible. Superimposed upon the challenge is the fact that internal variability itself has been influenced by human factors, notably the emission of greenhouse gases.

Pielke notes that a common simplifying assumption is that the observed weather would not change were it not for “human influence”. The problem is that it is too frequently applied to short observational records to claim climate change impacts. Pielke notes that this is flawed because:

The current climate varies on timescales both greater and less than 30 years. The IPCC AR6 defines climate variability:

“Deviations of climate variables from a given mean state (including the occurrence of extremes, etc.) at all spatial and temporal scales beyond that of individual weather events. Variability may be intrinsic, due to fluctuations of processes internal to the climate system (internal variability), or extrinsic, due to variations in natural or anthropogenic external forcing (forced variability).”

Pielke’s post goes on to address the question “How near or far into the past does one need to go to adequately characterize a ‘current climate’?” to use as the baseline for a climate change comparison. He uses flood data for various periods to show how easy it is to find a “convincing” trend showing larger floods over time since 1897 consistent with the hypothesis that increased greenhouse gases are causing the increase based on the data used. However, when data prior to 1897 Hirsch (2011) explain that:

. . . we get a very different and more complex picture. . . Now we would say that although there has been some increase in flood magnitudes over time, the pattern is no longer very consistent with a hypothesis that this is driven by greenhouse gas increases in the atmosphere. The high values in the 19th Century are inconsistent with this hypothesis. In fact, one could put forward the argument that there are two populations of annual floods at this location. One is the population that spanned the years of about 1900 to 1941, and the other population existed before 1900 and after 1942. Without the benefit of the longer record, we could easily conclude that the data were highly supportive of a greenhouse-gas driven trend in flood magnitudes, but with it we find ourselves having to entertain other highly plausible hypotheses about an abruptly shifting population, with shifts that take place at time scales of many decades. The data do not negate the possibility that greenhouse forcing is a significant factor here, but they make it much more difficult to argue that these data provide a clear demonstration of the effect of enhanced greenhouse gas forcing on flood magnitudes.

Pielke goes on to describe how this issue affects the US government’s approach to flood policy. He notes that a common application of flood risk fails to account for this problem. This challenge has been long recognized by flood experts. Leslie Bond described this 20 years ago:

In the statistical estimation of a flood peak of a specific recurrence interval requires that all of the recorded peak flows be accurate and that the record be stable over the period of the record and the period for which the estimate is to be applied. That is, if there is a 50-year record of stream flow from 1931 through 1980, and you want a current estimate of the 1% flood to be valid for 30 years, the hydrology, the meteorology and the hydraulics must be stable from 1930 through 2034. In fact, we do not have sufficient historic rainfall data to be sure that the meteorology is stable, and few watersheds in the world are not changing as a result of urbanization, deforestation, agriculture, grazing or other causes.

Climate Act Implications

I have long-standing concerns about wind and solar resource availability. The issues described by Pielke related to long-term weather observations are relevant to that problem. It is obvious that we need to know the worst-case scenario for low wind and solar resource availability to determine how much long-term storage and/or some magical dispatchable emissions-free resource is needed to provide sufficient energy during resource droughts. His references to floods are apropos because I believe we need to develop a probabilistic resource drought parameter equivalent to the 100-year flood.

I have always believed that we should use as long a period of data as possible to determine that parameter. These results complicate wind and solar-depending electrical system planning because it means even using the longest period of data may specify requirements incorrectly. Also note that we apparently must worry about not just storage but also whatever weather conditions that cause extreme inertial frequency fluctuations that can lead to blackouts like in Spain.

My ultimate concern is that electrical planners currently base their reliability projections based on decades of experience with power plant outages that are uncorrelated. They have a good handle on the failure probabilities and how much installed reserve capacity is needed as backup. In the future the reliability requirements for wind and solar resource availability will be driven by weather that is fickler than plant shutdown variability. In addition, this variability correlates over large areas so many of the wind and solar resources will behave the same.

In my opinion, the likelihood of exceeding the planning parameters is much greater for a weather dependent electric system than today’s grid. When everybody and everything possible is electrified, and the resource drought planning criteria are exceeded, the results will be catastrophic.

Conclusion

Pielke concludes:

A main reason why the IPCC has not achieved detection of trends in most measures of extreme weather events, and does not expect to this century, is the magnitude of expected trends — based on model projections — in the context of documented variability.

This does not mean that humans are not influencing the climate system or extreme events, or that such influences are not important. It certainly does not mean that we should forget about mitigation and adaptation policies.

What it does mean is that the climate is more variable than many appreciate. A quest to identify trends and ascribe causality to them should not obscure the fact that whatever role humans play in altering the climate, society needs to be robust to a much wider range of possibilities than we’ve observed.

Weather-dependent resources add reliability risks. There has been insufficient consideration of this risk and Pielke’s work indicates that there will be a wider range of possibilities than what we can estimate using available data. This is another reason that we need to pause the Climate Act implementation process. It appears that if you want to decarbonize safely then nuclear power is the way to go because it removes these risks.

New York Creatively Hides the Costs of the Climate Act

On April 23, 2025 Governor Hochul announced that State University of New York (SUNY) Oneonta will be the first school in the SUNY system to purchase Tier 1 Renewable Energy Certificates (REC) from the New York State Energy Research and Development Authority’s (NYSERDA) voluntary sales program. This post interprets the meaning of this announcement.

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. At the same time, the Hochul Administration has delayed reporting mandates in the Climate Act that must document costs and progress. New Yorkers do not know where we stand,

Renewable Energy Credits

According to the Governor’s April 23, 2025 press release, SUNY Oneonta will be the first school in the SUNY system to purchase Tier 1 REC. The press release notes that the REC purchase will enable SUNY Oneonta to “claim 1,000 MWhs of new, local renewable energy in 2025” which will provide “enough locally-sourced clean energy to fully power four, 200-bed residence halls on the SUNY Oneonta campus.”

Renewable Energy Credits (REC) are defined:

A REC is a certificate, created by a tracking system, such as the New York Generation Attribute Tracking System (NYGATS), that represents the attributes of one megawatt hour of electricity generated from a renewable source like solar or wind. These RECs, or certificates, are needed to substantiate environmental claims related to energy use, such as for compliance with a State-mandated renewable compliance program, or for “voluntary” claims such as a climate action pledge.

REC are purchased by a range of entities “to comply with state mandates and to voluntarily support renewable energy development.” The buyers include utilities who are obligated to purchase them, government entities like New York City with commitments to use 100% renewable energy, and private organizations who “voluntarily purchase RECs to meet internal sustainability targets, claim environmental benefits, and demonstrate climate leadership.”

SUNY Oneonta

I imagine that the rationale for the purchase is the sustainability core value in the SUNY Oneonta mission statement. This core value declares that sustainability means “stewarding resources to foster a just community in ecological balance.” This phrase is nothing more than trendy moral posturing that checks the box so that SUNY Oneonta can claim the high ground for environmental protection.

The mission statement is accompanied by this:

Together with the mission, these values now guide SUNY Oneonta’s pursuit of a clear vision:

to become the exemplar residential community, providing relevant educational experiences in and outside of the classroom.

SUNY Oneonta will challenge the status quo, test assumptions, and ask difficult questions about relevancy and impact. The university must understand the needs of today’s learners and tomorrow’s. Our campus and all of the opportunities it can offer should revolve around students and evolve with them. As they trust us to guide them to their goals, we entrust them with the future and the hope of a more just, humane and happier world.

I received my B.S. in meteorology in 1974 at SUNY Oneonta, went on to get a M.S. in meteorology, and started my air pollution meteorologist career in 1976. Half a century of experience has taught me that stewarding resources must include pragmatic tradeoffs between ambition, risks, benefits, and costs. The REC program is part of New York’s Climate Leadership and Community Protection Act (Climate Act).

That law epitomizes dogmatic policy driven by emotion and not reason. There is no consideration of any tradeoffs. The status quo in New York is that there is an existential climate crisis that can be solved by eliminating the use of fossil fuels. Somehow, I doubt that SUNY Oneonta has any interest in challenging that paradigm, testing the assumptions that a net-zero transition is possible, or considering the difficult tradeoffs that are inherent in the proposed transition away from fossil fuels.

Furthermore, 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. New York cannot solve global warming by itself and the third-world economies that are developing abundant, economical energy using fossil generation to improve their lives. The tradeoff between equitable distribution of energy resources relative to speculative climate change benefits is something that SUNY Oneonta students should consider for the goal of a “more just, humane and happier world.”

Another Shell Game

A shell game is defined as “A fraud or deception perpetrated by shifting conspicuous things to hide something else.” In my opinion the Scoping plan employed shell game tactics to claim that the Climate Act “costs of inaction are more than the costs of action”. The Administration knows how much the Climate Act will cost and is surely aware that public support for green energy initiatives to combat climate change dissipates quickly if the costs are substantial. I believe that affordability is the fundamental reason that the release of required reports on the implementation of the Climate Act have been delayed.

From that perspective the State University voluntary purchase of REC from NYSERDA looks suspicious. If all the SUNY institutions follow suit and purchase REC there will be a dependable funding steam for more NYSERDA renewable development. On the other hand, the primary goal of SUNY is education and not the societal goal of emission reduction, so I do not favor colleges squandering money on support of renewable energy development. I conclude that this is simply an inter-agency transfer of funds prompted by a decision to obscure costs and postpone the inevitable political reckoning when the extraordinary transition costs can no longer be hidden.

Fully Powering Nonsense

The press release continues the charade that renewable energy can “fully power” anything. The fact is that Hochul’s Administration has not shown that the technology necessary to resolve renewable intermittency is available, much less affordable. Without that backup technology, four, 200-bed residence halls on campus will only have electricity when the wind is blowing or the sun is shining. This is an example of selective use of metrics and descriptions that falsely gives the impression that the changeover to green energy is simple.

Conclusion

Renewable Energy Credits exist to subsidize green energy development. As a compliance tool they have value. However, one of the stated values of REC voluntary purchases is that they can be used to “demonstrate climate leadership”. That epitomizes virtue-signaling which I believe has little value as part of the education of SUNY Oneonta students.

Ultimately the SUNY Oneonta purchase of REC has another goal. It hides the cost to consumers by transferring money from one state account to another. A college education is expensive enough today without foisting students and parents with hidden costs that do not provide tangible benefit to their education.

Spain and Portugal Blackout – Another Reason to Pause the Climate Act

I am very frustrated with the New York Climate Leadership & Community Protection Act (Climate Act) net zero transition because the reality is that there are so many issues coming up with the schedule and ambition of the Climate Act that it is obvious that we need to pause implementation and figure out how best to proceed. This article explains that the ramifications of the recent blackout in Spain and Portugal need to be considered to ensure that the cause of the blackout is not a feature of all renewable-energy dependent electric systems.

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 target of a 100% zero-emissions electric system 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.” 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.

In 2023 the New York Independent System Operator (NYISO) reports that solar capacity was 254 MW for utility scale facilities and 5,172 MW for behind-the-meter solar capacity. NYISO data shows that the utility-scale capacity factor was only 16.6%. The Scoping Plan Strategic Use of Low-Carbon Fuels scenario projects that 40,860 MW of total solar capacity will be needed to meet the 2040 zero-emissions target. The report projects that solar will be 30% of the total capacity of New York.

Spain and Portugal Blackout – April 29,2025

Earlier this week there was a massive blackout that started in Spain. According to Reuters:

At around 12:30 p.m. (1030 GMT), electricity generation in Spain dropped rapidly from around 27 gigawatts to just over 12 GW. The 15 GW loss was equivalent to 10% of Spain’s total installed capacity.

The sudden drop in grid load destabilized electricity flows, which require an extremely stable frequency of 50 Hertz to maintain supply. This, in turn caused a break in the Spanish and French electricity interconnection that goes through the Pyrenees mountains, resulting in the total collapse of the Spanish power system.

Spain exports electricity to Portugal, so the collapse of power in Spain quickly spread throughout the Iberian Peninsula. Some areas in France also suffered brief outages on Monday.

The blackout in Spain is projected to cost 2-4 billion euros. It is imperative to figure out what caused it. Currently there hasn’t been any definitive explanation. Nonetheless, there are reasons tp believe that it could have been caused by Spain’s reliance on wind and solar.

Potential Causes Related to Wind and Solar

Net Zero Watch described a potential problem:.

Grid analysts have suggested a high likelihood that the extent of yesterday’s blackout in Iberia was a result of the Spanish grid operating almost entirely on renewables at the time. The stability of power grids depends on so-called ‘inertia’, a resistance to rapid change that is an inherent feature of large spinning turbines, such as gas-fired power stations, but not of wind and solar farms. Too much renewables capacity on a grid can therefore mean inadequate inertia. As a result, in grids dominated by wind and solar, faults can propagate almost instantaneously across grids, leading to blackouts.

In a recent Net Zero Watch paper, entitled Blackout Risk in the Great Britan Grid, energy system analyst Kathyn Porter pointed out that the Great Britain electricity system is becoming increasingly unstable. “Large fluctuations in grid frequency – the first sign of problems – are becoming much more common”. This has not been observed in New York, yet.

Richard Ellenbogen sent an email with more information. He explained:

While the exact cause of the blackout is uncertain, both Spain and Portugal have become heavily reliant on renewables. The power loss was caused by the sudden disappearance of 15 GW of generation for five seconds. To understand the scale of the problem, the five nuclear power plants in Spain have a combined installed capacity of 7.4 GW.

There is a reliability criterion in New York that boils down to keeping enough generation capacity online and available to that if the largest source of power trips offline that the spare capacity can replace it easily. If we have to worry about all the solar going offline this quickly there is a huge challenge to resolve. Ellenbogen explained that a few minutes before the blackout, 60% of Spain’s energy was coming from solar. He also quoted an article by Robert Bryce:

The best explanation of grid inertia and its importance was published in 2016 by University of Queensland professor Simon Bartlett. In a paper written for the Energy Policy Institute of Australia, “The ‘Pressure Cooker’ Effect of Intermittent Renewable Generation on Power Systems,” Bartlett declared that the “practical upper limit for renewables is around 40% of total electricity generated.” He continued, “The scale-up of intermittent renewables not only diminishes the robustness of a particular power system but can also magnify the short and long-term risk of investing in non-renewable generation assets and the power grid itself.”

Ellenbogen also provided a link that provides an explanation about utility frequency issues for anyone that wants to read further.

Discussion

Ellenbogen closed his email with the thought that “with all of the investment that has been made in their renewable infrastructure, will we see a realistic report from the Spanish utility? An article in Reuters by Ron Bousso titled “Don’t blame renewables for Spain’s power outage” supports Ellenbogen’s concern that advocates for renewables are too invested in them to admit their proposed use may be irretrievably flawed. The article opens:

While it may be tempting to blame the unprecedented power outage that hit the Iberian peninsula this week on the rapid growth of wind and solar power in Spain, reliance on renewables is not to blame. Rather, the issue appears to be the management of renewables in the modern grid.

I love this. We don’t know what happened, but he claims it could not have been the renewables. This was followed by the description of what occurred that I quoted earlier. The next section noted that the “cause of the initial drop that led to the catastrophic cascade of events is unclear, though a collapse in Spain’s solar power system was certainly involved.” At least he admits that the solar power system was “certainly involved”. Bousso notes:

One possible contributor is the lack of so-called ‘grid inertia’ as a result of the relatively small share of nuclear and fossil fuel generation in Spain’s power mix.

Inverter-based wind and solar power, which generated just under 70% of Spain’s total electricity at the critical moment on Monday, does not involve physical rotation and therefore inertia could not compensate for the sudden loss of power.

What grid management of renewables in the modern grid is possible? His short-term solution? “An obvious short-term solution to avoid a repeat of the blackout would be to maintain a higher baseload of rotating power generation.” The current generation payment system that gives solar and wind power preferential treatment means that wholesale changes to the payment system would have to be implemented. Furthermore, if we must keep enough rotating power generation on-line to cover the sudden loss of all wind and solar due, then it begs the question why we just don’t use those resources and skip the charade of green energy.

His long-term solution is batteries:

Over the long term, however, power systems will need to invest heavily in battery capacity to store electricity as well as technologies for synchronising the grid that are critical to maintaining the 50 Hz frequency. In theory, this should be doable, as battery costs have declined sharply in recent years and are being deployed at scale around the world.

There is a critical caveat that is glossed over when he says “this should be doable”. One of the poorly understood aspects of inverter-based resources like wind and solar is the energy management systems in the inverters. It is beyond my experience to explain but the experts that I have talked to about this note that distinguishing between a problem with the equipment that requires a shutdown to protect the equipment and a grid problem that requires the system to stay on and support the system is no easy task. It gets worse when you consider that there are behind-the-meter resources like residential solar that cannot be expected to have sophisticated energy management systems. The other aspect is the cost:

But all this would still require heavy investment. While spending on new solar capacity reached around $500 billion last year, investment in grids was only at around $400 billion, becoming bottlenecks for the energy transition, according to the International Energy Agency.

Professor Simon Bartlett declared that the “practical upper limit for renewables is around 40% of total electricity generated. The New York Scoping Plan projects that in 2040 solar capacity will be 40,860 MW, onshore wind 13,096 MW, and offshore wind 13,484 MW so the renewable total is 67,440 MW. The question is whether the Scoping Plan analysis capped the amount of wind and solar output at any one time at 40%. I doubt it but this is a nuance that cannot be answered by looking at the impenetrable Scoping Plan documentation. Clearly this is another reason to pause implementation because now we know that this can be a billion-dollar risk and we don’t know how the Scoping Plan or for that matter the NYISO analyses addressed it.

Conclusion

In the coming months the green energy apologists will be saying that it is unfair to blame renewables for Spain’s power outage. My first observation is that it would be incredibly insulting to the public to say that renewables were not the original cause of the problem. The question is whether an electric system can be designed and operated to address this problem. I have the utmost respect for electric system planners and their ability to design the system to address known problems. However, given the complexity of the electric generating and transmission system I do not think that they can anticipate every potential problem that could cause a blackout. Another important consideration is whether the proposed New York electric system has incorporated features that would preclude the observed problem from happening here when we become as dependent upon inverter-based resources.

This is another reason to pause the Climate Act implementation. We simply don’t know if the proposed zero-emissions system that relies so much on wind and solar will work. If New York decides that the future electric system must be zero-emissions and it turns out that no more than 40% of the power at any time can come from wind and solar, then the only viable approach is nuclear power. Nuclear replace can replace renewables, eliminate the need for a massive backup resource to address this problem, and provide an electric system that we know can maintain current standards of reliability. Therefore, it would be prudent to pause renewable development until this issue is resolved because nuclear generation may be the only viable path to zero emissions.

Wind Energy Reasons to Pause

I am very frustrated with the New York Climate Leadership & Community Protection Act (Climate Act) net zero transition because the reality is that there are so many issues coming up with the schedule and ambition of the Climate Act that it is obvious that we need to pause implementation and figure out how best to proceed. This article describes reasons to pause implementation associated with wind energy deployment.

Overview

The Scoping Plan Strategic Use of Low-Carbon Fuels scenario projects that 13,096 MW of onshore wind and 13,484 MW of offshore wind will be needed for the electric system to be “zero emissions” in 2040. If the onshore wind turbines are like the Alle-Catt 340 MW project that has 117 turbines, then each turbine will be 2.9 MW and 4,516 turbines will be needed. If the offshore wind turbines are similar to the Empire Wind project that proposes 15 MW turbines then 899 offshore turbines will be needed.

This post describes problems with wind energy in recent articles.

Wind Curtailment

Parker Gallant keeps track of wind energy production in Ontario and the problem of what to do with excess wind energy when the production from Ontario exceeds the load. The current strategy is to dump the excess power into Quebec, New York, and Michigan at a low price which has short-term consumer benefits to those jurisdictions. However, Gallant has documented that through 4/20/25 dumping the excess wind and solar energy has cost Ontario taxpayers and ratepayers $64 million. On April 21 the total bill was another $12,3 million. On April 26, the total for the month had reached $101 million which is about $20 per Ontario household.

He explains what happened on April 21:

Even though our Peak Hour was a little bit higher reaching 16,250 MW at Hour 20 we still didn’t need what the IWT and solar were generating so IESO were selling it for deep discounts to our neighbours as the average HOEP (hourly Ontario energy price) was a piddly $17.80/MWh (1.8 cents/kwh). IESO had forecast those IWT would generate 88,811 MW (75.5% of capacity) but only accepted 81,846 MW meaning they curtailed 7,000 MW which we paid for. Solar generation was small (not much sun) and generated only 1,326 MW! IESO’s intertie data indicates they sold 89,574 MW to our neighbours which means we Ontario ratepayers and taxpayers ate $12.3 million of their respective costs along with a few dollars for the other exported power which probably was baseload nuclear and hydro!

This is another reason to pause the implementation because in 2040 when there are over 5400 wind turbines running, we will have the same problem. I must believe that the problem will get worse for Ontario because they at least got paid something but, in the future, when our turbines are producing too much we will not be a market so they will just have to eat the curtailment costs. When our neighbors install their turbines, then we will have to eat our costs too. How is this supposed to work for New York ratepayers?

European Experience

Tallbloke’s Talkshop poses the renewables question whether “endless subsidies for a so-called ‘energy transition’ are affordable for those forced to cover the costs, especially when the things being subsidised are creating daily problems for electricity supply and grid stability due to the erratic nature of the technology? He describes an article in the Europe section of an OilPrice.com opinion piece that addresses the question.

Certainly, there are plenty of industries that rely on state subsidies, but how many of these, it’s worth asking, rely on these subsidies for their very survival?

The answer is inconvenient for the transition lobby. These are the only industries that literally cannot survive without massive and consistent state financial support. And that essentially makes them unviable in a natural market environment.

For recent proof, look no further than Europe. There is no anti-transition government in Europe. There is no Trump or anything like him at the helm of any European country. And yet it was in Europe that the chief executive of Danish Ørsted insisted that the government step up their financial support for the offshore wind industry to ensure its survival.

As reported by the Financial Times, which spoke to Rasmus Erbroe, “European capitals to commit to consistent annual support for the industry in order to meet offshore wind targets and help reverse rising costs.”

“If you want to deliver on energy security, energy independence, affordability for Europe for the coming decades and meet the targets, then we need to make this change,” the executive said, quite likely believing every word that came out of his mouth was the holy truth. In fact, there is nothing affordable about an energy that cannot absorb its own costs and turn in a profit without government guarantees of that profit.

Surely the question whether wind energy can ever turn a profit without government guarantees of that profit is a valid question that needs to be addressed before New York squanders more money on this technology.

Wake Physics

I described the Scoping Plan projections for wind energy earlier in this article. Those are underestimates because the projections for the expected annual output are too optimistic. In other words, if reasonable estimates were used then even more wind turbines would be needed. Pierre Gosselin describes another nuance that could affect the number of turbines needed. Klimanachrichten explains that wakes from upwind turbines reduces the output of downwind turbines. He notes:

The expansion of offshore wind energy in the North Sea is a central component of the European energy transition. However, two of the biggest players in the industry are now warning of negative effects: Ørsted and Equinor have jointly calculated that the planned 1.5 gigawatt wind farm ‘Outer Dowsing’ could cause significant so-called wake losses. These are yield losses that occur when the wind is weakened by upstream wind farms, causing downstream turbines to produce less electricity.

This might be included in the Scoping Plan, but the documentation is so poor that it is impossible to know. If I had to bet then I would bet the ranch that this nuance is not included.

Ultimate Problem

Regular readers of this blog are undoubtedly tired of me constantly whining about the insurmountable challenges associated with extended periods of extended periods of light winds. Chris Morrison describes notes that in the first quarter of 2025 “low levels of renewable generation and high demand drove gas-fired power production to its highest level since 2021”. He continues:

But this gas rescue act came at a large cost since Britain’s increasingly unstable electricity supply, which provides some of the highest prices in the world, showed wild cost swings in windless days in January. On at least two freezing winter days, wind production was more-or-less zero. Not untypical winter weather conditions also saw the sun fail to shine for a number of consecutive days. Some periods saw the wholesale peak-time electricity price top £160 per megawatt hour ((MWh). On January 8th, when winter high pressure stopped the wind blowing across the UK, the wholesale price soared to £300 MWh, while the sophisticated clearing price needed to balance the non-storable supply with instant demand soared to £2,900 MWh.

Rafe Champion agrees with my concern. He recently wrote:

The wind and solar system is vulnerable to wind droughts. It is not entirely fanciful to plan a book titled How Wind Droughts Almost Destroyed Civilisation based on these articles: The late discovery of wind droughts, We have to talk about wind droughts, and The “wind drought trap.”

The Scoping Plan analyses were not sophisticated enough to incorporate these costs into their projections. So this massive problem was downplayed by the Climate Action Council.

Killing Eagles

I recently received an email about a seminar addressing bird kills associated with wind turbines. Proponents argue that wind turbines kill only “a fraction as many as are killed by house cats, buildings, or even the fossil fuel operations that wind farms replace.” Of course, when asked about raptor kills there is no response. David Wojick continues his great coverage of the impacts of wind turbines on eagles with a post about eagle kill offset rules. He explains the problem:

Every operating wind power facility has a US Fish and Wildlife Service (FWS) permit to kill eagles on an ongoing basis and many do kill eagles. Each permit depends on eagle-kill offset rules which appear to be false. If so then the killing is illegal, a violation of the Bald and Golden Eagle Protection Act.

The eagle kill offset rules are not protecting eagles. This is another unacknowledged issue in the Scoping Plan.

Accountability for Wind Farms in France

There was an encouraging article. A court in France took action when an eagle was killed:

The recent shutdown of the Bernagues wind farm in Hérault, France, marks a long-overdue reckoning with the lethal impacts of wind energy on wildlife—particularly raptors like the golden eagle. On April 9, 2025, a French court ordered the entire site to cease operations for one year following the confirmed death of a golden eagle, a protected species, that collided with one of the farm’s turbine blades in January 2023. The decision also slapped Energie Renouvelable du Languedoc (ERL), the farm’s operator, with a €200,000 fine, half of which was suspended, and imposed an additional €40,000 fine on the company’s director.

I don’t think that it is very likely that a New York judge would take such an action. Nor do I expect that the Department of Environmental Conservation to step up until it has become obvious that 5,000 wind turbines could destroy the comeback of the Bald Eagle in New York State and by then it would probably be too late.

Breaking the Law in the US

Unfortunately in the United States the Federal government has been charging ahead with offshore wind development and it is not clear that they are following the law.

The Save the Right Whales Coalition has joined legal challenges to the Bureau of Ocean Energy Management’s (BOEM) approval of the Vineyard Wind 1 project and ten other offshore wind facilities. In a newly filed amicus brief, SRWC argues that BOEM broke federal law by rewriting statutory language, bypassing public rulemaking, and using compensation to justify harm — all to advance offshore wind at any cost.

Despite the offshore wind advocates arguments that the massive development of offshore wind will not affect the endangered Right Whale, I believe that it will. There are just too many potential impacts that will accumulate and overwhelm the few whales left.

Conclusion

Evidence continues to mount that issues associated with every component of the Climate Act transition plan are so great that a pause to re-assess the plan is necessary. New York Public Service Law § 66-p (4). “Establishment of a renewable energy program” includes safety valve conditions for affordability and reliability that are directly related to wind energy deployment. The failure of the Hochul Administration to establish criteria for those safety vales and provide public tracking of the status must be corrected before implementation proceeds.

NY State Senate Energy and Telecommunications Committee Air Quality Considerations

In March 2025 Senator Mattera invited Richard Ellenbogen to Albany to address the NY State Senate Energy & Telecommunications Committee regarding NY State’s energy situation relative to the Climate Leadership & Community Protection Act (Climate Act). I was impressed that the meeting showed that the Committee agreed with Ellenbogen that there are implementation issues and course corrections are necessary. I previously described the emissions analysis I did for the Committee. This post describes the air quality aspects of New York power plant emissions.

Overview

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, gave Ellenbogen time to describe his thoughts on the Climate Act transition, describe his proposal to use of existing technology that will not get to zero but will maintain system reliability, and answer questions. There is a video of the hearing available and a previous post includes links to specific discussions within the video.

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 significant carbon reductions. 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.

During the discussions at the meeting, Chairman Parker said a couple of times that he wanted to get specific numbers for potential emission reductions. I described the detailed description of the emissions analysis I provided to the Committee in another post. The last thing I want to address is air quality associated with New York electric generating units.

Context

The detailed analysis that I submitted to the Committee included this section on context. I joined Niagara Mohawk Power Corporation (NMPC) in 1981 and one of my responsibilities until I retired in 2010 was accounting and reporting air pollution emissions. I think it is important to understand that there have been massive reductions in electric generating unit emissions in New York since the time I joined the utility industry. The earliest records I have date back to 1984. At the time NMPC owned and operated oil-fired facilities in Albany and Oswego and coal-fired plants in Dunkirk and Tonawanda. In 1984 those facilities emitted 136,684 tons of sulfur dioxide (SO2), 37,221 tons of nitrogen oxides (NOx), and 12,530,220 tons of carbon dioxide. In 1995, according to the Environmental Protection Agency all the fossil fueled power plants in New York emitted 239,183 tons of sulfur dioxide, 120,138 tons of nitrogen oxides, and 54,000,913 tons of carbon dioxide. In 2024 all the fossil fueled power plants in New York emitted 698 tons of sulfur dioxide, 7,757 tons of nitrogen oxides, and 31,201,251 tons of carbon dioxide. The following table (NY Emissions Analysis.xls “NYS” tab) lists the annual values from 1980 until 2024.

New York Electric Generating Unit Annual Emissions from EPA Clean Air Markets Division

Air Quality Trends

There have been recent reports that noted that the American Lung Association (ALA) reported that dangerous air pollution is affecting more Americans than last year. Behind the headlines is the fact that the data they used included “exceptional (e.g., wildfires) and natural events (e.g., stratospheric intrusions)” that are the reason air quality worsened. Not mentioning the fact that the deteriorating air quality has very little to do with humans would not help their agenda and fund raising so that information isn’t included in the news stories. In this context, however, it leads the general public to believe that this indicates a trend towards worse air quality.

The National Ambient Air Quality Standards (NAAQS) establish air quality levels that are protective of public health and welfare with an adequate margin for safety, including protecting the health of ‘sensitive’ populations such as asthmatics, children, and the elderly”. From a regulatory standpoint, there is nothing that local jurisdictions can do to reduce exceptional and natural events. Consequently, the high air quality associated with those events is not counted against the attainment designation relative to the NAAQS. The air quality was worse last year in many places but in the absence of exceptional and natural events the air quality is getting better. I also believe that while there are extreme weather events that cause things like wildfires, that climate change is not exacerbating extreme weather to any observable degree.

Without those events the observed emission reductions have been accompanied by improvements in air quality. SO2 levels have decreased dramatically, with a 98% reduction in annual average levels from 2009 to 2017. I found that nitrogen dioxide one-hour ambient levels decreased 63%. There also have been decreases in particulate matter.

For the most part New York air quality reflects national and regional trends. According to the EPA nonattainment/maintenance status summary, there are multiple counties In New York that do not attain the current NAAQS for ozone and New York County does not meet the coarse particulate matter standard. Note that all of New York State meets the inhalable particulate (PM_2.5) NAAQS. All the other pollutants are in attainment. Finally, note that over the years the NAAQS limits have become more stringent.

Despite the fact that there have been significant improvements and New York is mostly in attainment with the NAAQS there is another approach to air quality health impacts that regulators and activists have used to claim more reductions are necessary. They claim that levels of pollution lower than the NAAQS have health impacts based on simplistic epidemiological extrapolations that assume there are no health impact thresholds.

For example, even though New York City is in attainment for inhalable particulates, this pollutant is used as a rationale for shutting down peaking power plants because of claims that reducing inhalable air quality impacts is beneficial. The New York City Department of Health and Mental Hygiene’s (DOHMH) 2011 Air Pollution and the Health of New Yorkers report is often referenced in this regard. The DOHMOH report concludes: “Each year, PM_2.5pollution in [New York City] causes more than 3,000 deaths, 2,000 hospital admissions for lung and heart conditions, and approximately 6,000 emergency department visits for asthma in children and adults.” These conclusions are for average air inhalable particulate pollution levels in New York City over the period 2005-2007 of 13.9 µg/m³.

I submitted comments on the Draft Scoping Plan where I showed that the New York City 2018-2020 average PM_2.5concentration was 7.4 µg/m³ which is substantially lower than the DOHMOH goal of 10.9 µg/m³. If the epidemiological linear no-threshold model is correct, then because inhalable particulate levels have come down In New York City there should be significant observed health benefits since the 2011. However, DOHMH has not verified their projections against observations. Until such time that the projected health impacts using this approach are validated with observed data, I will be skeptical of this metric. The fact that asthma and other health impacts have not improved at the same rate as the air quality improvements suggests that other factors are driving those outcomes. In my opinion, there should be a commitment to determining the more likely causes rather than wasting money on reducing already low power plant emissions.

Current Air Quality Conditions

During the Energy & Telecommunications Committee hearing on March 18, 2025 Chairman Parker questioned air quality levels around power plants. He said that there are “people sitting in the shadow of both industrial plants and nuclear power plants who are developing health outcomes that are negative because of these plants”. I need to address this misconception as it applies to fossil-fired power plants. First, I want to point out that there is no credible health outcome threat of air quality related to nuclear power plants.

I think that Chairman Parker has been misled by a “righteous risk”. In a post on this risk I noted that these risks arise from a “value-based policy approach that filters out facts and data within an ethical perspective.” The importance of these risks are “influenced by what is perceived as ethical rather than what is rational or scientific.” The Climate Act includes specific mandates to address righteous risks.

The Climate Act includes a commitment to address equity for “communities within New York that have been historically overburdened by environmental pollution”. One of the most repeated claims is related to air quality levels around power plants and reductions in co-pollutants is a prime benefit of the Climate Act.. The PEAK coalition has stated that “Fossil peaker plants in New York City are perhaps the most egregious energy-related example of what environmental injustice means today.” I believe this argument influenced Senator Parker. However, the presumption of egregious harm is based on selective choice of metrics, poor understanding of air quality health impacts, and ignorance of air quality trends. I have documented my concerns based on my extensive experience with air pollution control theory, implementation, and evaluation over my 45+ year career.

One of the legislative attempts to facilitate the Climate Act is the Build Public Renewables Act that gives the New York Power Authority (NYPA) renewable development responsibilities. This law is supposed to speed up the energy transition but it also includes a requirement for NYPA to shut down its existing fossil-fired power plants including a number of peaking power plants in New York City. I think this is as poor a policy choice as the decision to shutdown of the Indian Point nuclear power plant.

I have been an air quality meteorologist for 45+ years. A foundational presumption in my career is that if the ambient air quality effect of any polluting source is lower than the NAAQS then public safety and welfare is protected. There are two additional levels of air quality security. When the NYPA peaking power plants were permitted NYPA had to demonstrate that the increase in pollution due to the facilities was less than the Prevention of Significant Deterioration increment put in place to assure that new sources of pollution do not meaningfully worsen the air quality. In addition, the facilities had to install Lowest Achievable Emission Rate air pollution control equipment which is as good as it gets. My point is that the facilities that New York politicians are forcing to close may not have zero impacts, but they are close enough to no impacts, that they cannot possibly adversely affect health outcomes.

Discussion

After much thought I think I have an analogy that puts this in perspective. Think of power plant controls like cleaning the kitchen floor. Power plants have different levels of control equipment just like we all have different options to clean the floor. Keeping the kitchen floor clean is necessary for food safety given the likelihood of spills. In my opinion, sweeping the floor daily and mopping it regularly is “good enough”. Many don’t think that mopping the floor is good enough now because there are more sophisticated options like the Swiffer PowerMop or even steam mops. For some once-a-week mopping is not good enough and they may want to do that daily. The point is that there is a tradeoff between time and money for cleaning the floor “good enough”. In my opinion, the NYPA peaking power plants in New York City with Lowest Achievable Emission Rate controls are equivalent to using a steam mop several times a day. Demands to shut down the NYPA power plants is equivalent to deciding not use the kitchen because it is not clean enough even when using a steam mop several times a day.

Conclusion

A state-of-the-art combined cycle natural gas-fired turbine provides great grid support and is so efficient that it has significantly lower CO2 emissions than existing fossil-fired units in New York. To correctly consider the value of this technology for New York’s electric system it is necessary to use appropriate comparison metrics, have a comprehensive understanding of air quality health impacts, and consider air quality trends.Three things described in my emissions status article should also be considered. I found that a future electric system that uses nuclear power as the backbone and natural gas-fired combined cycle combustion turbines for backup support resolves the reliability risks and overall costs of a wind, solar, and energy storage system. At the same time it could reduce emissions from about 30 million tons per year today to less than 2 million tons per year in the future. I also noted 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. Even Senator Parker acknowledges that this means “at the end of the day New York is not going to solve the climate crisis”. Finally, I pointed out that New York’s impact on global warming is unmeasurable. These three points lead to the inescapable pragmatic conclusion that nuclear power as the backbone combined with combined cycle combustion turbines is good enough for environmental risks even if there are some GHG emissions and co-pollutant emissions are not zero.

NY State Senate Energy and Telecommunications Committee Meeting – Emission Status

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 relative to the Climate Leadership & Community Protection Act (Climate Act). I was impressed that the meeting showed that the Committee agreed with Ellenbogen that there are implementation issues and course corrections are necessary. This post describes the emission estimates that I provided and puts electric generating unit emissions in context.

Overview

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, gave Ellenbogen time to describe his thoughts on the Climate Act transition, describe his proposal to use existing technology that will not get to zero but will maintain system reliability, and answer questions. There is a video of the hearing available and my previous post includes links to specific discussions within the video.

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.

During the discussions at the meeting, Chairman Parker said a couple of times that he wanted to get specific numbers for potential emission reductions. In my description of the meeting, I promised to publish a post describing my supplemental emissions analysis that provided those numbers. This article fulfills that promise.

Observed and Projected Electric Generating Unit Emissions Analysis

Following the meeting I sent Ellenbogen material to send on to Senator Parker. The evaluation of observed electric generating unit carbon dioxide (CO2) emissions for selected New York power plants that represent the current state-of-the-art compared with other existing units included the information requested. My submittal included a detailed description of the analysis as well as the spreadsheet that generated the data in each table in the report. The description includes references to each tab within the spreadsheet that provides the data for every table. I am only going to summarize the evaluation because the documentation provides the details.

The analysis was complicated because it was necessary to combine two different data sets for the comparison. I used the EPA Clean Air Markets Division data that includes CO2, SO2, and NOx emissions along with several operating parameters. Unfortunately, the EPA load data represents gross load and net loads are needed to project CO2 emissions for the different scenarios. The New York Independent System Operator (NYISO) annual load and capacity data report, universally known as the “Gold Book, provides net loads. I chose 2020 because I wanted to include the Somerset coal-fired power plant information to represent the highest CO2 emissions. Because of naming convention and facility component differences, it was not possible to include all the steam turbine, combined cycle or cogeneration units in the state. However, the 43 units (Note that the report refers to 45 units but there are only 43 units in the tables) included provide a representative sample of the state, representative data for state-of-the-art generating units and includes specific units that were requested by the Committee.

I manually combined 2020 data from the two data sets for 43 electric generating units as shown in Table 3 from the report (NY Emissions Analysis.xls “Compare 2020” tab). It combines the NYISO net energy (GWh) and the EPA CO2 emissions (tons) to determine the state-of-the-art CO2 emission rate (tons/GWh). Note that the CO2 emission rate ranges from just over 400 for the combined cycle gas turbines to 1200 tons per GWh for a coal plant. I assumed that the new Cricket Valley, CPV-Valley, and Caithness combined cycle gas turbines represent a state-of-the art combined cycle power plant. Table 3 shows that those three facilities do represent the lowest emission rates and that the Bethlehem Energy Center is within their ranges so also state-of-the-art. I assumed that the average of the blue highlighted cells represents a representative state-of-the-art combined cycle power plant CO2 emission rate (410.8 tons CO2 per GWh).

Table 3 : Combine the NYISO Net Energy (GWh) and the EPA CO2 Emissions (tons) to Determine State of the Art CO2 Emission Rate

Table 4 (NY Emissions Analysis.xls “2020 Projections” tab) compares existing emissions to estimated emissions if the facility were replaced with a state-of-the art combined cycle combined cycle gas turbine power plant with and without a carbon capture and sequestration (CCS) control equipment. The observed CO2 Mass column lists 2020 annual emissions. The state-of-the-art projected CO2 emissions column equals the state-of-the-art combined cycle power plant CO2 emission rate (410.8 tons CO2 per GWh times the observed 2020 net energy rate. The column that adds the CCS control at 90% efficiency lists the emissions if the control equipment were in place. There are also columns that list the difference between observed emissions and these projections.

Table 4: Projected CO2 Emissions – Replace with Combined-Cycle GT or Combined-Cycle GT with Carbon Capture

In 2020 the electric sector emitted 26,920,636 tons of CO2. The 45 units included in this analysis emitted 21,305,661 tons representing 79% of the total. If all 45 units were state-of-the-art combined cycle natural gas fired combustion turbines, the emissions would be reduced to 17,955,036 tons which is a 16% reduction. If all 45 units added carbon capture and sequestration control equipment, the emissions would be reduced to 1,795,504 tons, a 76% reduction. My results are less than the Ellenbogen presentation because I did not account for the improved efficiency and resulting lower fuel use that would reduce emissions more.

Future Electric System

I also projected 2040 CO2 emissions for a pragmatic future electric system that relies on nuclear power but uses state-of-the-art combined cycle natural gas fired combustion turbines (CCGT) for peaking support. Making projections for future electric energy sector resource allocations is best left to the professional electric system planners who can use complex and sophisticated models that can incorporate the nuances of the capabilities and performance of different types of generation. The biggest problem is that an electric system that relies on wind and solar resources needs to overbuild wind and solar capacity. That introduces a significant error in my projection approach. Nonetheless, this analysis gives a rough idea of potential emissions for two scenarios – building CCGT instead of renewables and building nuclear for everything except peaking generation.

The detailed description of the analysis provides specifics. In brief, I first chose a New York Independent System Operator (NYISO) annual energy forecast for the emissions projection. The second step was to allocate the generation needed to provide the NYISO future energy projection. I made many assumptions to establish the arbitrary generation resource categories I used in my projections.

I considered two future scenarios for 2040. In Scenario 1 the existing nuclear and hydro capacity and generation stay the same but new combined cycle gas turbines provide all the capacity and generation necessary to meet the NYISO forecast. In Scenario 2 the existing hydro capacity and generation stayed the same, new combined cycle gas turbines provide the peaking power and all the remaining capacity and generation necessary is provided by nuclear power.

My results showed that significant reductions are possible with these scenarios. If nuclear and hydro stay the same and new CCGT is used to make up the capacity and energy necessary to match the NYISO forecast, then the emission projection is 70,301,856 tons of CO2 or 7,030,186 tons with 90% CCS controls. This is an overestimate because the NYISO projection incorporates over-building wind and solar capacity that would not be necessary if conventional generating resources are used. The second scenario in which nuclear is used for everything except peaking generation and CCGT is only used for peaking purposes is probably closer to a realistic estimate. That scenario predicts that using fossil fuels solely for that purpose would produce 1,226,718 tons of CO2 and only 122,672 tons if 90% CCS was employed. This also is an over-estimate because of the renewable over-building but the significantly lower emissions shows how effective nuclear power is for reducing emissions.

Relative Impacts

The nuclear/CCGT approach does not eliminate 100% of CO2 emissions. However, 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. Even Senator Parker acknowledges that this means “at the end of the day New York is not going to solve the climate crisis”.

There is one other argument in favor of this pragmatic approach. In short, New York’s impact on global warming is unmeasurable. Table 9 (NY Emissions Analysis.xls “Warming Averted” tab) projects the amount of global warming “savings” for the projection scenarios and historical emissions. The calculations are based on a Perplexity AI query “What is the expected change in global warming per ton of CO2 reduced”. None of the emission scenarios for the projected warming predict measurable changes in global warming.

Table 9: Potential Warming Savings for Emission Scenarios and Historical Emissions

Conclusion

The purpose of this analysis is to show that a state-of-the-art combined cycle natural gas-fired turbine is so efficient that it has significantly lower CO2 emissions than existing fossil-fired units in New York. If a cost-effective carbon capture and sequestration system could be added to those facilities the emissions are reduced much more. When combined with nuclear power for baseload electric power, there are advantages to using a system with combined cycle gas turbines when compared to using a system based on using wind, solar, and energy storage. The energy density of wind and solar energy is so low and the resource intermittency so variable hat no electric system relying on those resources for most of its energy can ever hope to provide reliable electricity. The low energy density requires a massive buildout of transmission, and an intermittent weather-dependent system requires an unproven dispatchable emissions-free resource. The nuclear/CCGT approach resolves those challenges. When the potential effects of New York emissions on global warming are considered, it is apparent that zero emissions mandates do not provide any measurable benefits.

The negligible relative impacts of New York emissions does not mean that we should do nothing, but it does suggest that strategies that do not go to zero should not be rejected. That is especially true if those strategies can be implemented for a fraction of the cost of the current plan. In addition, the emissions from combined cycle gas turbines used to replace existing generation would not meaningfully contribute to global warming but their continued use not only reduces emissions over historical levels but also resolves reliability challenges that must be addressed if zero emissions are mandated. The concept of natural gas as a bridge fuel for even lower emission alternatives is a pragmatic approach.