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.

Renewables are Cheaper Because of Fuel Volatility

I have run into a couple of instances where New York Climate Leadership & Community Protection Act (Climate Act) proponents have claimed that renewable energy development can reduce costs.  This article responds to the argument that reduced fuel price volatility will make renewables cheaper.

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.

Renewable Energy Can Reduce Costs

I am disappointed that the renewable energy can reduce costs claim has made it into the New York State Energy Plan process.  The Energy Plan is “a comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers”.  When the Energy Planning Board met on March 3, 2025 to adopt the scope for the state energy plan the claim was mentioned.  One item on the agenda was a discussion of the “planned approach for techno-economic pathways analysis”.  This is the analysis work whereby the state agencies and their consultants will “prove” the pre-conceived notion that the Climate Act net-zero transition concocted by politicians will work. 

The presentation by Jeff Freedman from the Atmospheric Sciences Research Center, University at Albany, Albany, New York included the following slide that makes the claim that renewable energy can reduce costs. One characteristic of the New York State Energy Research & Development Authority (NYSERDA) documentation for the implementation plan is inadequate documentation, so it is not surprising that the justification for the claim is not readily available.

Table 6-1 was in New York State Climate Impacts Assessment Chapter 06: Energy.  That chapter does not address renewable energy costs specifically.  I searched for references for costs in the chapter and found only one relevant reference on page 370:

Energy costs: Fossil fuel prices are increasingly volatile, largely because they are traded on global markets. In contrast, a power sector composed of large volumes of renewable resources that have no fuel costs could lead to less volatile energy bills due to the elimination of this driver of variability in energy costs. The presence of distributed resources amplifies this effect. Whether the costs of a clean power sector are lower than, comparable to, or higher than the status quo, they will be more predictable and less likely to create indirect costs that arise from unexpected price changes.

I am aware of one other instance where this rationale was mentioned.  The December 18, 2024 New York Assembly Committee on Energy public hearing enabled legislators to question NYSERDA and the New York State Department of Public Service (DPS) staff about Climate Act progress. When Jessica Waldorf, Chief of Staff & Director of Policy Implementation, DPS was asked what impact Climate Act GHG emission reductions would have given that New York emissions are smaller than the observed annual increases in global GHG emissions. Waldorf said that there are other reasons “to build renewable energy resources in New York that are not just related to emissions.”  She gave two reasons: energy security and price volatility. 

The other thing I would say about energy security is price volatility.  Customers are beholden to the whims of the fossil fuel industry and the up and down markets that we see from fossil fuels.  Localizing our energy production and renewables allows us for price stability.  That is definitely a benefit of building resources here. 

The presumption in this article is that the basis of these claims that renewable energy will be cheaper and less volatile is that a renewable energy dependent electric system will have less unstable fuel costs resulting in cheaper and more secure energy.  This in turn is based on two presumptions: fuel prices are volatile because of global markets and renewables would eliminate this cost driver.

Fuel Volatility

The US Energy Information Administration (EIA) noted in June 2024 that fossil fuel price volatility has shown significant changes over time, with recent years experiencing particularly high levels of volatility: “In 2022, natural gas price volatility reached extreme levels, with historical volatility peaking at 171% in February 2022, the highest since at least 1994.”  Note that EIA is only discussing natural gas volatility which has become a much larger electric generating fuel source in recent years.  In my opinion, the increasing reliance on a single fuel could be the fundamental reason for the observed increase in volatility.

In any case, the New York agency global market argument picks just one driver for fuel price volatility.  The EIA  gave other reasons for natural gas variability in August 2022:

Increased uncertainty about market conditions that affect natural gas supply and demand can result in high price volatility. Events that have contributed to changing market conditions include:

  • Production freeze-offs
  • Storms
  • Unplanned pipeline maintenance and outages
  • Significant departures from normal weather
  • Changes in inventory levels
  • Availability of substitute fuels
  • Changes in imports or exports
  • Other sudden changes in demand

U.S. natural gas prices are typically more volatile during the first quarter of a year because of the fluctuating demand for natural gas for space heating as weather changes. Factors that contributed to heightened volatility in the first three months of this year include:

Of the eight events that contribute to changing market conditions and fuel volatility is the only one is related to global market conditions.

Jurisdictional Proof

When I get around to submitting a comment on the weakness of this argument, I intend to demand that the proponents of the Climate Act offer an example of a jurisdiction where the electric system has become reliant on wind and solar renewable generation and consumer costs have gone down because the fuel volatility has decreased.  To my knowledge, all jurisdictions have seen consumer cost increases. 

I used Perplexity AI to research electric energy prices as a function of wind and solar deployment.  My experience showed the weaknesses of AI research.  The response to the question whether consumers in any jurisdiction have seen decreased costs when transitioning their electric system to rely on wind and solar claimed that it was true.  The response said: “This trend is driven by the rapidly declining costs of renewable energy technologies and their increasing cost-competitiveness compared to conventional fossil fuel sources.”  The reference cited was from Ember-Energy “a global energy think tank that accelerates the clean energy transition with data and policy” that can hardly be considered an unbiased source.  The response also does not address consumer rate costs.  It makes the mistaken claim that the cost of developing renewable technologies has little relation to the delivered cost of electricity to consumers. In the real world, the cost of storage to address intermittency, the cost of additional transmission support to address diffuse wind and solar, and the cost to provide the ancillary transmission support services not available from wind and solar, make renewables much more expensive than fossil fuels.   I was unable to frame a question that provided an answer that acknowledged that the costs necessary to provide consumers with reliable power made delivered renewable energy more expensive.

German Experience

However, if the claim is true then proponents should be able to point to jurisdictions where wind, solar, and energy storage have make electric prices cheaper.  The best example of the claim that renewable energy is cheaper because it reduces fuel volatility should be Germany.  Oil, coal and gas prices spiked in the immediate aftermath of Russia’s invasion of Ukraine and have been volatile ever since. Germany’s Energiewende is the country’s planned transition to a low-carbon, nuclear-free economy and is often cited as an example of what New York should do. Enerdata reports that “According to the German Federal Network Agency, the installed renewable power capacity in Germany increased by nearly 20 GW (+12%) to nearly 190 GW in 2024.” If the proponent’s claim is true then prices should be trending down.  However, since 2000, electricity prices for German households have risen by 116%, from 13.94 to 30.43 cents per kilowatt-hour in 2019 .  As of April 1, 2024, households with basic supplier contracts were paying around 46 cents per kilowatt-hour, making it “the most expensive option compared to other providers or special contracts” .

Another way to look at the claim is to compare electricity prices within the European Union.  I highly recommend  the Nemeth Report for its coverage of European energy issues. The post EU Action Plan for Affordable Energy  includes just such a comparison.  It quotes Ursula von der Leyen, President of the European Commission, as saying: “We’re driving energy prices down and competitiveness up. We have already significantly reduced energy prices in Europe by doubling down on renewables. “

However, the data in the following figure do not support her claim. 

The analysis states that:

Note that the household price average shows a large difference between EU countries that use coal, nuclear, and gas vs those that have focused on wind and solar. For example, as shown in the chart above, according to Statista, using 2023 data, Hungary’s electricity price was 9.68 Eurocents/kwh (50% of their electricity is from nuclear, 38% coal & gas) and Bulgaria which relies mostly on coal and nuclear was around 11 Eurocents/kwh, whereas Germany, which has “doubled down on renewables” (and closed down its nuclear), was the highest at 44.97 Eurocents/kwh and Denmark which has a small population and a whole lot of windmills was at 39.44 Eurocents/kwh! 

Data sources and the year of the data matters. Eurostat uses numbers from the first quarter of 2024 which reorder some of the countries but the overall argument, that countries that “doubled down on renewables” and made other poor choices of shutting down nuclear power plants and/or coal experienced higher prices, remains supported. 

Discussion

Roger Pielke, Jr recently posted an article about the politicization of expertise that is relevant here.  He argues that society needs to depend on the expertise of specialists in many fields – “Nobody knows enough to run the government”.  As a result, society needs all of us.  He explains that “We do not have to agree on everything, but we do have to work together”.  Then he points out that “In recent years, credential expertise—like many things—has become pathologically politicized.”         

Such is the case shown by the politicization of the Climate Act implementation led by NYSERDA.   Consider, for example, the presentation by Jeff Freedman to the Planning Board.  It is concerning on a couple of levels.  In the first place, the Planning Board is composed of agency heads and political appointees who for the most part do not have background and experience in the energy sector.  Freedman was presented as an expert from the energy sector whose claim that “renewable energy can reduce costs” was probably taken as the gospel.  However, his main research focus is on “renewable energy and atmospheric boundary layer (ABL) processes” so his bias is towards renewable energy virtues and he has no energy sector experience that qualifies him to make such a statement.  He was a spokesman because of his adherence to the narrative.

In the second place, the presentations at the meeting suggest that NYSERDA will follow the Scoping Plan approach in the stakeholder process for the Energy Plan.  The primary purpose of the meeting was to approve the final scope of the Energy Plan.  As was the case with the Climate Act Scoping Plan the NYSERDA response to stakeholder comments is to document the number of comments received by category and provide general descriptions of key themes and “responsive Scope revisions”.  My problem with this is that if anyone provides specific comments or raises specific issues with claims, there is no documentation that the submittal was addressed, and nothing included to respond to the issue raised.  For example, the claim that renewable energy can reduce costs was undocumented in Freedman’s presentation.  I have no doubts that NYSERDA will continue the charade that renewable energy can reduce costs and that costs of inaction are worse than the costs of action.  They have never responded to related issues raised and will continue to do so as long as they can get away with it.  In my opinion this is another instance of pathologically politicized expertise by NYSERDA because they are so arrogant that they don’t see any need to respond to stakeholder comments.

Conclusion

The biggest threat to Climate Act progress is the inevitable extraordinary cost of implementation.  The Hochul Administration has ducked the issue since the Climate Act was passed.  They can only hide reality for so long.  The question is whether the issues associated with the net-zero transition will be addressed before New York’s economy is severely compromised.

In the meantime, if you ever hear anyone say renewable energy can reduce costs, please ask them why German electric prices are so high or to cite an example of any jurisdiction that is transitioning their electric system that has reduced ratepayer bill costs when using the Climate Act strategy to rely wind, solar, and energy storage resources.

Commentary on Recent Articles  March 9, 2025

This is an update of articles that I have read that and want to mention but only have time to summarize briefly.  I have also included links to some other items of interest.  Previous commentaries are available here. 

I have been following the Climate Leadership & Community Protection Act (Climate Act) since it was first proposed and most of the articles described below are related to the net-zero transition.  I have devoted a lot of time to the Climate Act because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good. The opinions expressed in this article do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Alex Epstein

Epstein recently published two great articles.  The first proposed a solution to America’s electricity crisis.  The post included a video of his spoken testimony and Q&A, along with his prepared remarks, for a House Oversight Committee’s hearing on “Leading the Charge: Opportunities to Strengthen America’s Energy Reliability.” He described five damaging restrictions on reliable power that need to change:

  1. End criminalization of nuclear power
  2. End forced shutdowns of fossil fuel plants
  3. End onerous permitting processes
  4. End electricity market rules that devalue reliability
  5. End subsidies for unreliable power

In his second article he described the Full cost of IRA subsidies.  He described eight subsidies that increase the debt, increase the cost of living, prevent productive business and jobs from being created, and increase corruption.

Offshore Wind

There are signs that the offshore wind grift is running out of steam.  The entire clean energy sector is in trouble.  Charles Rotter notes that Nishant Gupta, founder and chief investment officer at London-based Kanou Capital LLP, didn’t mince words when describing the dire state of solar, wind, hydrogen, and fuel cell investments.

“The whole sector… is dead for now,” Gupta stated plainly​. This marks a turning point—when even those inside the financial world, who have long played along with the green energy narrative, admit that the numbers simply don’t add up.

It’s no secret that the clean energy sector has been in trouble. Over the past year, the S&P Global Clean Energy Index has plummeted by 20%, while the broader S&P 500 has gained 16%​. That’s a devastating underperformance, especially in an industry that was supposed to be on the cusp of taking over the world.

Gupta cites several reasons for the industry’s collapse, including high interest rates, supply chain struggles, and what he calls “political headwinds” in the U.S. The latter is a reference to the Biden administration’s green agenda losing steam, and with the Trump administration poised to undo climate-focused regulations, green investors are panicking​.

In simple terms, the entire “green energy revolution” has been built on a foundation of government intervention rather than market fundamentals. Now, as subsidies and mandates run into reality, the industry is showing just how weak it really is.

The offshore wind industry is not doing itself any favors too.  Recall that last summer a wind turbine failed at the Vineyard Wind industrial offshore wind complex near Nantucket, MA.  One of the problems was that the company did not alert the locals about the problem.  One would think that they would have learned that it is always best to explain what is going on sooner rather than later.  The turbine that broke up was hit by lightning and there was no notification.  Such actions will not engender public support.

Climate Science Dishonesty

Roger Pielke, Jr. frequently comments on the undeniable issues of scientific integrity in climate science.  In his latest article on the topic he describes an investigation by Sveriges Radio (Swedish public radio)   into multiple exaggerations and falsehoods about climate change that have been promoted by the United Nations.  Examples included Sea Level Rise Misinformation, adolescent deaths due to climate change, women and children are more likely to die because of climate change, and there are increases in weather disasters.  Pielke concludes:

The climate science community has a poor track record of addressing misinformation associated with those promoting climate change as a political agenda. This has been called noble cause corruption. If the United Nations is among those promoting such misinformation, we should not be surprised if the credibility of IPCC — which sits under the UN — becomes called into question, fairly or unfairly.

You can listen to the Swedish Radio report in English here — highly recommended, excellent and rare reporting on climate.

CO2 as the Control Knob for Climate

I have been thinking about writing an article about the drivers of climate change.  The popular narrative and the rationale of all GHG emission reduction programs is that the greenhouse effect is the primary reason for climate change so that reducing emissions will reduce climate changes.  There is no question that increasing greenhouse gas emissions will result in warming within the atmosphere but the associated caveats and impacts of this driver relative to all the other drivers suggests that emission reductions could just as easily have no discernable effect on global warming.  Two articles illustrate the implications.             

Andy May and Tom Shula consider the roles of energy, water vapor, and convection in the earth’s atmosphere argue that the greenhouse effect is a minor driver.  However, note that WUWT editors are skeptical:

We find aspects of the CO₂ thermalization theory presented in this article to be inconsistent with well-established experimental and empirical evidence. As Richard Feynman famously stated, “It doesn’t matter how beautiful your theory is, it doesn’t matter how smart you are. If it doesn’t agree with experiment, it’s wrong.”

Extensive laboratory spectroscopy and direct atmospheric observations confirm that CO₂ plays a role in radiative heat transfer, and while water vapor is indeed the dominant greenhouse gas, the claim that CO₂’s effects are negligible does not align with measured data. That said, scientific inquiry thrives on scrutiny and debate, and we encourage readers to critically evaluate all perspectives in light of experimental validation and real-world measurements. Anthony has written primer on Carbon Dioxide Saturation in the Atmosphere also worth reading, as it describes how the logarithmic effect of CO₂ versus temperature will continue to lessen its impact even as atmospheric CO₂ concentrations increase.

Roy Spencer points out that if the greenhouse gas warming needs to be addressed then it would be appropriate to regulate the most potent greenhouse gas – water vapor.  Burning any fuel produces water vapor resulting in local impacts as well as increased global warming.  However, this aspect of the greenhouse effect is ignored.  He notes:

The climate scientists who publish papers about the supposed dangers of greenhouse gas emissions make sure to exclude water vapor from their concerns, claiming CO2 is the thermostat that controls climate. I have commented extensively on the sleight of hand before. The vast majority of climate scientists believe CO2 controls temperature, and then temperature controls water vapor. CO2 is the forcing, water vapor is the feedback. But this argument (as I have addressed for many years) is just circular reasoning. The amount of water vapor in the atmosphere (did I forget to mention it’s our main greenhouse gas?) is partially controlled by precipitation processes we don’t even understand yet. The climate modelers simply tune their models to remove water vapor (through precipitation processes) in an arbitrary and controlled way that has no basis in the underlying physics, which are not yet well understood. Often, these simplifying assumptions translate into assuming relative humidity always remains constant.

Clearly frustrated he describes why he believes that water vapor is not regulated:

Clearly it’s not because water vapor is “necessary” to the functioning of the Earth system, since CO2 is necessary for life on Earth to exist. Which brings me back to my question, is the EPA really trying to help us when it comes to climate-related regulation?

I’m increasingly convinced that science has been hijacked in an effort to (among other motives) shake down the energy industry. This has been planned since the 1980s. It makes no difference that human flourishing depends upon energy sources which are abundant and affordable. It doesn’t matter how many people are killed in the process of Saving the Earth. The law demands regulation, and that’s all that matters.

I have evidence. In the early 1990s I was at the White House visiting Al Gore’s environmental advisor, Bob Watson, a ex-NASA stratospheric chemist who was just coming off the successful establishment of the Montreal Protocol on Substances that Deplete the Ozone Layer. He told me (as close as I can recall), “We succeeded in regulating ozone-depleting chemicals, and carbon dioxide is next“.

Keep in mind this was in the early days of the IPCC, which was tasked to determine whether humans were changing the climate with greenhouse gas emissions. Their work was just getting started, including the scientists who would assist the process. But the regulatory goal had (wink, wink, nod, nod) already been established.

So, I don’t believe the EPA is actually trying to help Americans when it comes to climate regulation. I’m sure many of their programs (waste cleanup, helping with the Flint, MI water problem, and some others) are laudable and defensible.

But when it comes to regulation related to global climate (or even local climate, as the government tries to pack even more people into small spaces, e.g. with “15 minute cities“), my experience increasingly tells me no one in the political, policy, regulatory, legal, or environmental advocacy, side of this business really cares about the global climate. Otherwise, they would admit their regulation (unlike, say, regulating the precursors to ground-level ozone pollution in cities) will have no measurable impact. They wouldn’t be trying to pack people into urban environments which we know are 5-10 deg. F hotter than their rural surroundings.

It’s all just an excuse for more power and vested interests.

Peer Review and Costs of Building Electrification for Commercial Users 

This is an article primarily by Richard Ellenbogen that estimates projected annual operating costs and emission reductions for New York commercial facilities when the new building codes are implemented.  It is also an example of how peer review should be done.

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.

Ellenbogen is the President [BIO] of Allied Converters and frequently copies me on emails that address various issues associated with the New York Climate Leadership and Community Protection Act (Climate Act). I have published other articles by Ellenbogen including a description of his keynote address to the Business Council of New York 2023 Renewable Energy Conference Energy titled: “Energy on Demand as the Life Blood of Business and Entrepreneurship in the State -video here:  Why NY State Must Rethink Its Energy Plan and Ten Suggestions to Help Fix the Problems”. He comes to the table as an engineer who truly cares about the environment and as an early adopter of renewable technologies at both his home and business two decades ago.

Heat Pump Hype

I am a long-time critic of the New York State Energy Research & Development Authority’s (NYDSERDA) biased promotion of all green energy technologies.  Their description of cold climate heat pumps is a good example: “Today’s cold-climate heat pumps are a smarter, more efficient option to keep your home comfortable all year long. These all-in-one heating and air conditioning systems are environmentally friendly, extremely efficient, and affordable to operate.”  In another example, they breathlessly exclaim that heat pumps outsell gas furnaces for the second straight year.  This claim uses national figures and could be solely the result of new building sales that are much stronger in southern states where heat pumps are a cost-effective choice.  Ellenbogen addresses the affordability claims below.

Ellenbogen Heat Pump Experience

Ellenbogen installed geothermal heat pumps when his house was completed in 2004.  He has 21 years of experience with them and has maintained a database of the performance and costs.  His monitoring system includes temperature sensors on the inputs and the outputs of the wells and water flow.  Because he uses a geothermal system, he can rely on it even during the coldest periods when air source heat pumps cannot extract enough energy from the air to keep the house warm.  Furthermore, his system uses deeper wells than are currently allowed by law that were legal when the system was developed.  They are also open loop which greatly increases their efficiency but that is also no longer allowed. In his configuration, his heat pumps can pull 7 tons of heat transfer per well where current geothermal wells are limited to about 2.5 tons per well.  As a result, his system can achieve a Coefficient of Performance (COP) of about 5.5 whereas current Geo-thermal systems can achieve a COP of about 3.5 with the restrictions on well depth and having to be closed loop.  During long periods of cold temperatures that force the heat pumps to run for extended periods, the well temperatures can drop and the efficiency of the system decreases so it will use more energy.

One of the things I admire as a techno-weenie is Ellenbogen’s quantitative nature.  He built his house “as a science project to satisfy his intellectual curiosity” and it has yielded an enormous amount of data. When the Indian Point nuclear station was operating, he ran a calculation and found his geo-thermal system was about 7% more carbon free than his 95% efficient modulating gas boilers that were originally installed as a backup in case of a power failure.  After New York politicians shut down Indian Point the carbon emissions of local electricity increased and the GHG emissions advantage vanished.  Given his concerns about GHG emissions he decided to figure out a cost and energy comparison.  He turned the heat pumps off this winter and used the duplicate gas system to compare with multiple years of data with the heat pumps operating.

The results are notable.  His gas bill went up less than the electric bill went down and this is for an electric system with an efficiency 57% higher than what can be built now during a colder winter.  The electric bill was about $8600 lower than it would have been with the heat pumps operating.  The gas bill only went up by $6057 for a net savings of $2543 using the natural gas heating and the current winter has been 120 degree days colder than last year.  That figure has been adjusted for the higher electricity prices this year.   Note that the heating system is well designed with 14,500 square feet of high mass radiant floors that use 100-degree water in the system and 18 separate zones which makes it even more efficient.  The large scale of the system removes measurement aberrations that might occur with a smaller system.

To compare the costs of heating with electricity and natural gas it is appropriate to compare the cost to generate the same amount of heat.  Table 1 lists the cost for the delivery of one therm (heat energy equal to 100,000 British thermal units) between a 95% efficient boiler and electric heat at relationship different Coefficient of Performance efficiency values.  A COP of 1 is inefficient.  A highly efficient ground source heat pump has a COP of 3.5.  Even an efficient ground source heat pump is 16% more expensive ($2.85 for one therm compared to $2.45 for a 95% efficient gas system in the Downstate New York area which covers 60% of the state’s population.  Also note that air source heat pumps on a very cold day can reach COP’s of 1 – 1.5 and easily go below 2.  As a result, they can be two to three times as expensive to operate.

Commercial Facility Projection

New York State legislators passed a prohibition on the installation of fossil fuel equipment and building systems starting in 2026 for small buildings and 2029 for larger ones. The prohibition starts in 2026 for new buildings up to 7 stories tall, except for commercial and industrial buildings larger than 100,000 square feet. There are exemptions for certain types of buildings including emergency backup power systems, manufacturing facilities, commercial food establishments, laboratories, hospitals and medical facilities, critical infrastructure (e.g., water treatment plants), agricultural buildings, crematoriums.

Ellenbogen applied the numbers derived from his house experiment to his business and extrapolated them to the 55,000 square foot factory which would fall under the less than 100,000 square foot rule for new construction after 2026.  Admittedly, there is no law currently in place that would require a developer who wanted to replicate Ellenbogen’s manufacturing facility because of the exemptions.  Eventually, however, the net-zero mandates will require all electric construction of all new facilities and for the replacement of existing equipment before the end of useful life.  Therefore, it is a relevant example of Climate Leadership and Community Protection Act (Climate Act). costs.

Ellenbogen’s home has a backup gas boiler heating system and his manufacturing plant has a combined heat and power system.  In 2002 he installed the first microturbine-based Combined Heat and Power (CHP) system in the Con Ed service area.  This approach generates electricity by burning natural gas.  Waste heat is recovered “to heat the building in the winter, or to be sent to absorption chillers to cool the building in the summer.”  This approach allows him to recover 70 to 75 percent of the energy content of the fuel and augments a solar array on the roof.

By doing a thermal analysis of his home’s gas usage he was able to determine what would be needed to heat the factory.  The end result is that removing gas from his manufacturing facility would raise energy bills to about $147,000, more than doubling them,  and raise his carbon footprint by about 15%.  The key takeaway is that even using the most efficient electric heating/cooling system available, it still means that this gas ban policy will cost businesses in NY state enormously while raising carbon emissions.  When and if the Downstate New York electric system reaches zero GHG emissions the carbon emissions will be reduced.

Environmental Impacts

Ellenbogen calculated that because the Downstate electric system is CO2 rate is 950 pounds per MWh according to 2022 EPA data, that the CO2 emissions from using the CHP system are actually less than if heat pumps were used.  He also pointed out he has replaced three compressors in his home’s ground source system over the past 21 years and each time the failure resulted in a full loss of refrigerant.  He said that it is not preventable and that you only find out when the unit gives a fault code with no early warning.

Discussion

This post is based on three emails from Ellenbogen.  I did not include all the calculation details he provided in the originals but will provide them if requested.  The reason for the three versions is that the details provided enabled a reader to point out an issue that he corrected.  Ellenbogen noted that:

Those damned Laws of Thermodynamics are getting in the way again, but this may be a teaching moment to show what a real peer review looks like and that we have to acknowledge errors to make sure that the best information is in the public space.  It also is a clear example of how we can’t escape those Laws in our calculations.  Miscalculations introduce errors and a failure to account for the Laws of Thermodynamics entirely when setting energy policy introduces huge errors.

This raises an issue with the implementation of the Climate Act.  The agencies responsible for the implementation plans have not provided adequate documentation to enable detailed review of the plan.  Even if it is possible to make a detailed comment on an obvious issue, there hasn’t been any acknowledgement of any problem, much less evidence of a revision to the plans.  The appropriate peer review process exemplified by Ellenbogen’s analysis is not a feature of the Climate Act stakeholder process.  As a result, Ellenbogen notes “errors are apparent across the entire spectrum of NY State’s Energy plan.”

Ellenbogen summarized his peer review concerns in this regard.

While I hate to beat on academia, it has a great deal of responsibility for NY State’s energy mess.  A certain University Professor that sat on the Climate Action Council still refuses to acknowledge that all of the technologies for this transition do not exist despite a Public Service Commission conference determining that fact in 2023.   Unfortunately, people in the legislature and certain environmental groups have adopted those ideas despite there being known large deficiencies in those theories as it applies to putting them into practice.  Untested theories that can’t be put into practice in the “Real World” are dangerous for society.  State residents shouldn’t be turned into a science project and that is what is happening. 

I received the following response to my email from a retired professor that now works in industry.  I have redacted portions to keep them anonymous.  While on average, the refrigerant replacement is every 20 years as there are three heat pumps, their observations are profound and are critical to understanding a huge issue now facing the NY State.  It follows in italics.

This is the most sobering analysis of a heating system I have ever read. I constantly hear about the miracles of heat pumps, but the carbon footprint is never honestly presented. Plus the replacement of freon every 7 years is never included. Thanks for providing a clear analysis of a day in the life of a NY business and resident.

I’m still enjoying life in XXXXXXXX, and in no longer being a professor. Academia lives in a bubble, and you can’t see that until you leave. Professors need to do a real sabbatical leave in industry and be forced to solve real problems, not problems they dream up. It’s tough out here! I thought I knew something about XXXXXX  after XX  years as an academic doing research, but XX years at XXXXXXX  has shown me I have much to learn. It is stimulating, I’m glad to be here. They need to have a similar experience.

Regarding the statement above, one of the reasons that the carbon footprints of heat pumps is never honestly mentioned is that the loudest voices in the space are the people selling them and other people don’t have enough experience to question the results.  I’ve been using them for 21 years.  My house was built as a science project to satisfy my intellectual curiosity.  It has yielded an enormous amount of data, some of which has been used by the state.

One of the major issues that I have with NY State policy is that many of the people that are hired to do the energy analyses for the government actually work for the manufacturers or other interested parties.  The reports read more like advertisements paid for by the NY State taxpayers than a sound scientific document.  I dealt with that in a 2020 paper on the Lansing Gas moratorium.  The company hired to do the Tompkins County energy analysis sold heat pumps and the resulting report reflected that and had a huge error in its results.  The paper is very relevant to the building electrification discussion.

Regarding the professor’s comments, when someone is forced to deal with the consequences of their decisions as occurs in industry, it greatly changes their perspective.  There are no negative consequences for someone theorizing about policy on a University Campus and that is okay because it can move society forward.  However, if they don’t really test those ideas before pushing them into society as a gospel, there will be huge problems and that is what we are now seeing in NY State.

Conclusion

The ramifications of New York’s Climate Act on business development are becoming evident.  In 2026, certain new buildings in New York will no longer be able to install fossil fuel equipment and building systems.  Richard Ellenbogen has performed a “science project” that proves that New York’s net-zero transition electrification plans for heating will be more expensive than using natural gas.  It is also notable that the experiment was best on a geothermal heat pump system that is more efficient than legally possible today.  Adding to the already large energy costs in New York is not a good way to attract and maintain manufacturing in the state. 

This exercise also shows the importance of robust peer review.  Ellenbogen’s first draft contained an error that was identified because he showed his work.  He acknowledged the problem and corrected his analysis.  New York’s Climate Act stakeholder process does not document analyses well enough for considered review and the Hochul Administration does not acknowledge any comments that do not comport with their narrative.  As a result, the broken stakeholder process in New York will likely ignore Ellenbogen’s real-world results. 

New York State 2024 GHG Emissions Inventory

This post describes the latest New York State (NYS) GHG emission inventory report that provides data through 2022.   The Climate Leadership & Community Protection Act (Climate Act) includes a target for a 40% reduction of greenhouse gas (GHG) emissions from 1990 levels by 2030 and the inventory has some implications relative to that target. 

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.  In addition to the 2030 GHG emission target, the electric sector is required to be 70% renewable. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The 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. 

NYS GHG Emissions

At the end of 2024 the New York State Department of Environmental Conservation (DEC) released the 2024 statewide GHG emissions report (2024 GHG Report).  DEC is required by the Climate Act to follow unique inventory requirements.  I published an overview post of this greenhouse gas (GHG) inventory that described things that maximize emissions in an apparent attempt to make GHG emissions as large as possible.

Climate Act emissions accounting includes upstream emissions and is biased against methane.  Obviously if upstream emissions are included then the total increases but at the same time it makes the inventory incompatible with everybody else’s inventory.  There are two methane effects.  Global warming potential (GWP) weighs the radiative forcing of a gas against that of carbon dioxide over a specified time frame so that it is possible to compare the effects of different gases.  The values used by New York compare the effect on a molecular basis not on the basis of the gases in the atmosphere, so the numbers are biased.  Almost all jurisdictions use a 100-year GWP time horizon, but the Climate Act mandates the use of the 20-year GWP which increases carbon dioxide equivalent values. 

The 2024 GHG Report includes the following documents:

To calculate all the emissions in New York and estimate the upstream emissions it takes DEC, the New York State Energy Research & Development Authority (NYSERDA) and consultants two years to produce the reports.  This article compares NYS GHG inventory electric sector emissions with EPA emissions and GHG emissions through 2022 relative to the 2030 40% reduction target.

Electric Generating Unit Emission Trends

Last month I summarized New York electric sector emissions trends.  Electric generating units report emissions to the Environmental Protection Agency Clean Air Markets Division as part of the compliance requirements for the Acid Rain Program and other market-based programs that require accurate and complete emissions data.  Table 1 lists the EPA CO2 emissions by fuel type for the available years and the total electricity sector GHG emissions from the NYS GHG Inventory.

Table 1: EPA and NYS Electric Sector Emissions

The EPA electric sector emissions are significantly less than the NYS GHG inventory.  There are three primary reasons: the inclusion of upstream emissions, imported electricity emissions, and including three other greenhouse gases: methane (CH4), nitrous oxide N2O, and sulfur hexafluoride (SF6).  Note that the choice of the GWP-20 rather than GWP-100 increases the final numbers further.

2022 GHG Emissions

Table ES.2 in the Summary Report presents emissions for different sectors.  Electric generation emissions are listed as electric power fuel combustion, imported electricity, and as part of imported fossil fuels.  In 2022, GHG gas emissions from electric power fuel combustion totaled 27.79 million metric tons of carbon dioxide equivalent (mmt CO2e) using a 20-year global warming potential.  Imported electricity totaled 8.71 mmt CO2e.  Fuel combustion and imported electricity emissions were primarily CO2.  The Table ES.2 imported fossil fuel value shown covers all fossil fuel used in other sectors. 

NYS GHG Emissions Data

There is one notable feature of the GHG inventory.  DEC and NYSERDA previously conducted an analysis of statewide emissions in 1990 to establish a baseline for the “Statewide GHG Emission Limits” established by ECL 75-0107 and reflected in 6 NYCRR Part 496. It is important to understand that GHG emission inventories are not based completely on measured emissions.  The EPA CAMD data are based on direct measurements but all the other estimates are derived using emission factors and estimates of activities such as fuel use or vehicle miles traveled.  The last four emission inventories all have estimated a different 1990 value than the regulatory limit in Part 496.  The report notes “The 6 NYCRR Part 496 regulation may be revised at a later date using updated information. For your information, I have compiled all four tables explaining the differences between the estimate of gross statewide emissions in 1990 from the 6 NYCRR Part 496 rulemaking and in this report.

Trends in Sectors

The 2022 GHG Inventory includes four  sectoral reports for energy, industrial processes and product use, agriculture, forestry and land use, and waste.  The Summary Report describes the observed trends:

 In Figure ES.2, emissions are organized into the sectors described in the IPCC approach (IPCC 2006). The Energy sector encompasses emissions associated with the energy system, including electricity, transportation, and building/industrial heating. The Industrial Process and Product Use (or IPPU) sector covers emissions associated with manufacturing and manufactured products. The Waste sector encompasses any activities to manage human-generated wastes. Finally, the Agriculture, Forest, and Other Land Use (or AFOLU) sector encompasses emissions from the management of lands and livestock as well as net emission removals from land management and the long-term storage of carbon in durable goods.

The Energy sector represents the majority of emissions (76%, 2018-2022), but energy emissions in 2022 were 17.7% lower than in 1990 (Figure ES.2). The overall reduction in energy emissions was offset by increases in all other sectors and by a 1.7% decline in net emission removals. The largest increases occurred in IPPU due to the increasing use of hydrofluorocarbons (4.66mmt CO2e) and in AFOLU resulting from changes in agricultural practices (2.37mmt CO2e). Waste sector emissions declined by 4.36mmt COze over the period, primarily due to implementation of landfill gas capture systems.

Discussion

The implications of the GHG inventory are important.  The Climate Act includes a target for a 40% reduction of greenhouse gas (GHG) emissions from 1990 levels by 2030.  The NYS Part 496 1990 baseline emissions were 404.26 million metric ton (mmt) CO2e.  The total 2022 NYS emissions were 371.38 mmt CO2e which is only a 9% or 37.9 mmt CO2e reduction from the baseline.  The 2030 limit is 245.9 mmt CO2e which will require a further 34% or 163.4 mmt CO2e reduction. 

It is beyond the scope of the GHG inventory to provide any commentary regarding the achievability of meeting the 2030 target, but it is clear that, absent a miracle, the targets will not be met.  It is time for the Hochul Administration to acknowledge that the 2030 targets cannot be achieved.  The Climate Act requires that the Public Service Commission (PSC) issue a biennial review for notice and comment that considers “(a) progress in meeting the overall targets for deployment of renewable energy systems and zero emission sources, including factors that will or are likely to frustrate progress toward the targets; (b) distribution of systems by size and load zone; and (c) annual funding commitments and expenditures.”  The draft Clean Energy Standard Biennial Review Report released on July 1, 2024 will fulfill this requirement.  The final report was due at the end of 2024 but was delayed on December 17, 2024.  The draft document compared the renewable energy deployment progress relative to the Climate Act goal to obtain 70% of New York’s electricity from renewable sources by 2030.  It projects that the 70% by 2030 goal will not be achieved until 2033 when historic renewable resource deployments are considered.  The report did not address the 40% reduction of GHG emissions by 2030 target.

The Climate Act has always been a political ploy to gain favor with certain constituencies and has had little basis with reality.  Nowhere is the missing link to reality starker than regarding the implementation of emission reduction programs.  The green narrative is that the transition away from fossil fuels will be economic, simple, and only a matter of political will.  The reality is completely the opposite.  The fact is that to reduce GHG emissions to zero as mandated means that existing energy use of fossil fuels requires replacement of existing infrastructure, development of additional supporting infrastructure, and development of new implementation resources (supply chains and trained trades people).  To compound the challenge the Climate Act schedule was not developed on the basis of a rational plan.  Instead, the politicians arbitrarily chose the deadlines.  We are now seeing the results of this boondoggle and the ramifications are unclear.

Conclusion

The 2024 GHG emission inventory reports should be a wake-up call regarding Climate Act implementation.  It is clear that the 2030 GHG emission reduction target cannot be met.  In addition, the transition of the electric generating system requires a new technology to ensure reliability and the Hochul Administration has not yet responded to last summer’s Comptroller report that found that: “While PSC and NYSERDA have taken considerable steps to plan for the transition to renewable energy in accordance with the Climate Act and Clean Energy Standard, their plans did not comprise all essential components, including assessing risks to meeting goals and projecting costs.”  It is obvious that that New York State should pause implementation of the Climate Act and address the myriad issues uncovered to date.

Extreme Power Plant Fear Mongering

The Applied Economics Clinic (AEC) report titled ”A Community Assessment of Health Impacts from the Pittsfield Generating Facility on Local Communities”, prepared on behalf of the Massachusetts Clean Peak Coalition has to be in the running for the most egregious example of inflammatory peaker power plant fear-mongering of all time.  This post compares the claims against reality.

I am an air pollution meteorologist and have studied the relationship between atmospheric conditions and air pollution for nearly 50 years.  My background in air pollution control theory, implementation, and extensive personal experience with peaking power plants and their role during high energy demand days is particularly well-suited to this topic. The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

Environmental non-governmental organizations have latched onto peaking power plants as an example of power company greed and disregard for neighboring communities.  For example, 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.”  The influence of this position on current environmental policy has led to this issue finding its way into multiple environmental initiatives. However, I have found that 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. The AEC report takes the claims to ridiculous levels.

The AEC report example is extreme even compared to the Peak coalition accusations. Researcher Jordan Burt, Assistant Researcher Elisabeth Seliga, Researcher Tanya Stasio, PhD, Research Assistant Lila McNamee, and Principal Economist Liz Stanton, PhD, prepared a report that summarizes the negative health impacts of fossil fuel-fired emissions on communities living near the Pittsfield Generating Facility (Figure 1).    They claim that the facility exacerbates negative health outcomes of overburdened residents and asserts there are three key takeaways:

  • First, as long as the Pittsfield Generating Facility is in operation, it has the potential to produce much higher greenhouse gas emissions and co-pollutants in any given year.
  • Second, Pittsfield’s vulnerable populations live in close proximity to the Facility, putting them at a disproportionate risk for the negative health impacts associated with fossil fuel-fired generation.
  • Lastly, replacing the Facility with clean energy resources can not only improve the health outcomes for residents, but also aid the Commonwealth in achieving its decarbonization goals.

Figure 1: Pittsfield Generating Station in Relative to Pittsfield, MA

This article addresses these takeaways.

Pittsfield Generating Company

According to the Massachusetts Department of Environmental Protection (DEP) Final Operating Permit Renewal for the facility:

The Pittsfield Generating Company LP is an electric power generation facility located at 235 Merrill Road in Pittsfield, Massachusetts. The facility largely consists of three (3) General Electric (GE) Frame 6 6001B combustion turbines, known as Emission Units (EU) – 1, 2, and 3, which are each equipped with steam injection and a selective catalytic reduction system for control of nitrogen oxides (NOX) emissions. Each combustion turbine has a maximum heat input rate of 430.25 million British thermal units per hour (“MMBtu/hr”) and is exhausted to an associated Deltak heat recovery steam generator (“HRSG”). The steam generated in the three (3) heat recovery steam generators is combined to supply a single (1) GE steam turbine. Emission Units 1, 2, and 3 burn natural gas or #2 fuel oil and operate in combined-cycle mode with a net total output of nominally 165-megawatts.

A common claim about peaking power plants is that they are old, dirty, and inefficient units, but these units are modern, well-controlled, and efficient generating units.  Despite their efficiency, in the last seven years the units have only run less than 10% of the time which qualifies them to be peaking units. By definition, for EPA reporting purposes 40 CFR Part 75  §72.2, a combustion unit is a peaking unit if it has an average annual capacity factor of 10.0 percent or less over the past three years and an annual capacity factor of 20.0 percent or less in each of those three years.  Note that because peaking plants run so little the units can be designed for that mode of operation.  The specifications for those units are primarily focus on costs.  The Pittsfield units include all the pollution control equipment associated with units designed to run as much as possible.  They became peaking units because of market conditions that priced them out of the market, so they simply run less.  Nonetheless, they serve an important reliability role providing dispatchable power when needed on high energy demand days.

Takeaway 1

AEC claims that the facility has the potential to produce much higher greenhouse gas emissions and co-pollutants in the future.  Table 1 lists the annual emissions and operating information for the last 25 years from the EPA Clean Air Markets Division website.  That potential may exist but the historical data show that there has been vast operating and emission reductions since 2000.  As a result, any alleged impacts from the facility should have improved significantly over time.

Table 1: Pittsfield Generating Company Facility Emissions and Operating Parameters

Takeaway 2

In the second takeaway AEC states that Pittsfield’s vulnerable populations live near the Facility, putting them at a disproportionate risk for the negative health impacts associated with fossil fuel-fired generation.  They offer no estimates of the potential health impacts.

Last year I published a detailed critique of a General Accounting Office (GAO) report “Information from Peak Demand Power Plants” that discussed air quality impact evaluation.  The fundamental air quality presumption has always been that the National Ambient Air Quality Standards (NAAQS) is the primary metric used to determine health impacts.  As an air pollution meteorologist one of my jobs was to run air quality models to determine the air quality impacts of existing and proposed facilities.  The essential consideration was whether the modeling proved that the projected impacts from a facility were less than the NAAQS limits.  Industry and regulatory agencies believed that when an applicant showed compliance with those standards, they proved that they were protecting the health of “sensitive” populations such as asthmatics, children, and the elderly.  Regulatory agencies are required to ensure that any facility that cannot show compliance with the NAAQS must modify its permitted operations, or it cannot be allowed to operate.  The Massachusetts DEP only issues air permits if they are confident that the facility attains the NAAQS, so I am sure that Pittsfield Generating meets those standards.

The air quality pollutant of concern is nitrogen oxides or NOx.  The DEP set an emission limit of 22.8 lb NOx/hr.  I calculated the average hourly emission using the total NOx mass and the operating hours as 10.4 lb NOx/hr.  This is well below the emission rate that we know attains the NAAQS.  It is beyond the scope of this analysis and my presently available computer capabilities to quantify specific NOx impacts.   However, I only recall doing impacts assessment of power plants that used tons per hour not pounds per hour for an emission rate.  My point is that a pounds per hour rate is extraordinarily small and my experience suggests that local impacts at those levels would be so low that they would be difficult to measure and if they cannot be measured there is little chance of any health impact.

Takeaway 3

AEC asserts that “replacing the Facility with clean energy resources can not only improve the health outcomes for residents but also aid the Commonwealth in achieving its decarbonization goals.”  Environmental justice organizations will read this without understanding the background. In context, the impacts of this facility are well within the NAAQS, probably could not be measured, and the carbon emissions are a negligible fraction of the state total (Table 2).  In the last five years the CO2 emissions have been less than or equal to 0.5% of the state total.

Table 2: Pittsfield Emissions Relative to Total Massachusetts Emissions and Operating Characteristics

This table brings up other questions.  In New York the coal and oil generation was displaced to natural gas, but the overall Massachusetts generation has dropped significantly while there was a shift away from coal and oil.  The Massachusetts CO2 reduction from 2009 to 2023 was 84% while New York only dropped 38%.  I do not know why they managed such a substantial decrease.

Pragmatic Concerns

Pragmatic environmentalism is all about tradeoffs. There is no question that disadvantaged communities have suffered and continue to suffer disproportionate environmental impacts, but it is important to understand what causes the harm, balance expectations, and determine potential solutions. 

In this instance, it is likely that transportation sources have a bigger impact on air quality for Pittsfield’s vulnerable population.  There are just under 44,000 residents in the city, there are 19,566 households, and the average number of cars per household is 2.  I assume the estimated 39,132 cars drive two thirds of the Massachusetts average 12,117 miles per year within the city and that means that city mile traveled equals 316,108,296 miles per year. The estimated U.S. average vehicle NOx emission rate per automobile in 2023 was 0.00129 lb. per mile.  The result is that in 2023 automobiles emitted 204 tons of NOx.  That is more than double the annual emissions from the power plant since 2003 and 57 times higher than the 2024 emissions from the power plant. In addition, auto emissions are close to the ground while the power plant emissions are from elevated stacks so the auto emissions have a greater impact.  Clearly, the vilification of the emissions from the power plant is unwarranted.

AEC proposes that the plant be replaced with an “alternative, cleaner energy source like a solar plus storage facility can help reduce community exposure to pollution”.  The Title V permit says that emission units 1, 2, and 3 have a “net total output of nominally 165-megawatts.”  I estimate that 165MW of solar would cover 973 acres.  However, to ensure reliable reinforcement of a gas plant requires more than a one for one replacement.  Based on this reference, the solar required would be 660 MW covering 3,894 acres. The storage system may need to be oversized as well, potentially requiring 410 MW of 4-hour storage to replace 100 MW of gas peaker capacity.  Replacing  perfectly good power plant with solar plus storage prematurely does not seem to be a good investment.

AEC claims that the solar plus storage option would reduce exposure to pollution.  However, there are substantive safety concerns with currently available battery energy storage systems.  On January 16, 2025 a fire was reported at the Vistra Moss Landing Energy Storage Facility located in Moss Landing, California.  The fire burned at a temperature of between 2500 – 5000 degrees Fahrenheit.  Since the fire heavy metals have been measured at levels 100 to 1,000 times higher than normal in soil within a mile of the facility.  During the fire there was an evacuation zone within 1.5 miles of the facility.  In my opinion, the risks of environmental impacts from a battery fire far outweigh the “benefits” of eliminating the minimal emissions of this facility.

Moreover, there is no currently available technology that has been proven at the scale necessary that can replace fossil-fired generation safely, reliably, and affordably. If those characterized are not prioritized, then it could easily result in an electric system that does not maintain current standards.  More importantly, problems associated with reliability impact disadvantaged communities most so those concerns must be considered when decisions are made about peaking power plants benefits and potential impacts. 

Conclusion

This analysis epitomizes my frustration with pragmatic tradeoffs for peaking power plants.  AEC claims that the facility has the potential to produce much higher greenhouse gas emissions and co-pollutants in the future ignoring the fact that emissions have gone down significantly since the plant started operating.  AEC also claims that Pittsfield’s vulnerable populations live near the Facility, putting them at a disproportionate risk for the negative health impacts associated with fossil fuel-fired generation.  AEC overlooks the fact that facility emissions are so small that adverse health impacts are unlikely from the plant and that transportation emissions are much higher which means adverse air quality impacts are more likely from other sources.  AEC’s final takeaway claim is that “replacing the Facility with clean energy resources can not only improve the health outcomes for residents but also aid the Commonwealth in achieving its decarbonization goals.”  That is true in theory, but it ignores the fact that there are other emission reduction strategies that are likely to be more effective and pose less risk to the electric system than shutting down a dispatchable generating resource.  Fear mongering based on emotion and not facts is not in the best interests of a reliable electric system and this report is the best example of this folly I have seen to date.

NYSERDA Electric Vehicle Propaganda

The New York State Energy Research & Development Authority (NYSERDA) has an important role in the Climate Leadership & Community Protection Act (Climate Act) implementation.  They facilitate the implementation plans for the Climate Act and publish “featured stories” that “take you inside the work to build a clean energy future in New York.”  In a recent article they bragged that a record number of battery electric vehicles were sold in 2024 but did not put the numbers in context.

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

New York’s Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes two 2030 targets: an interim emissions reduction target of a 40% GHG reduction by 2030 and a mandate that 70% of the electricity must come from renewable energy 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. 

NYSERDA publishes “featured stories” that “take you inside the work to build a clean energy future in New York.”  Last March NYSERDA requested proposals to hire a public relations outfit, using $500,000 per year of public money, to “maintain a positive narrative” and “respond to negative viewpoints” about the Climate Act.  Ken Girardin evaluated the proposal request and noted that:

NYSERDA is especially concerned about certain areas of the climate program, noting they should be able to “immediately address emerging unforeseen events that draw media scrutiny” in areas including:

  • “Concerns related to transitioning cars, trucks, and SUVs sold in New York to zero emissions, and requiring all school buses in operation in the state to be zero-emission by 2035;” (This last policy, required by a separate state law, has given school districts sticker-shock, both with the cost premium of electric models and the unexpected cost of electricity infrastructure upgrades).

I assume (without any evidence that I could find at the NYSERDA website) that the February 11, 2025 Clean Energy Growth story “EVs hit record numbers in NY and the US” is part of that program.  My problem is that I believe that the concerns related to the zero emissions vehicles are real.  As a result, the only way NYSERDA can convince incredulous people to change their minds is to provide biased and misleading information.  In other words, all they have left is propaganda to promote their agenda.  This article compares the numbers in the “EVs hit record numbers in NY and the US” story and the numbers in the Scoping Plan to see if the story is propaganda.

EVs Numbers in NY

NYSERDA gave the following numbers for New York based on this reference:

In 2024, New York saw 90,221 new EV registrations, bringing the total number of EV drivers to more than 271,000 at the start of 2025. EV registration in 2023 totaled 78,950, meaning that 2024 saw a 14.3% jump in electric vehicle adoption across New York State.

Of the new EVs registered in New York State, 54,664 were battery-electric models and 35,557 were plug-in hybrid electric vehicles[2]. Battery-electric EVs run completely on electricity, whereas plug-in hybrids have an all-electric range of around 20 to 50 miles and an internal combustion engine fueled by gasoline that kicks in once the battery power is exhausted.

Scoping Plan EV Numbers

The Scoping Plan is New York’s blueprint for meeting the Climate Act mandates.  NYSERDA hired a contractor who developed a list of control strategies, estimated costs and emission reductions, turned a crank and conjured up  three decarbonizing scenario “plans”  for New York to meet the aspirational Climate Act schedule.  Feasibility, accountability, and transparency are not valid descriptors of the results produced. 

After no little effort I found the projected EV data.  Table 1 lists the projected 2024 EV sales for the three scenarios compared to the observed sales. Scenario 1 (Strategic Use of Low-Carbon Fuels) was the most realistic projection, the other two (Accelerated Transition Away from Combustion and Beyond 85% Reductions) were based on fantasies from the beginning.  For our purposes, note that battery electric vehicle sales were 10% lower than projected and plug in hybrid vehicle sales were 34% lower than Scenario 1 projections last year.

 Table 1: 2024 NY EV Sales Comparison Scoping Plan Scenarios vs. Observed Sales

Comparing the Strategic Use of Low-Carbon Fuels scenario projections over time shows that 2023 was te only year when the observed Battery Electric sales exceeded the projections.  The Plugin Hybrid vehicle sales exceeded projections only in the first year. 

Table 2: EV Sales Comparison Strategic Use of Low-Carbon Fuels Projection vs. Observed Sales

The trends are shown in Figure 1.  The Scoping Plan modeling projects that Battery Electric sales will increase sharply in the future.  The modeling also projects that Plugin Hybrid sales will peak in 2026 and then tail off. 

Figure 1: EV Sales Comparison Strategic Use of Low-Carbon Fuels Projection vs. Observed Sales

Discussion

Trying to estimate how every sector will be affected by changes in energy use and fuels in the NYSERDA sponsored modeling for the Climate Act implementation is a massive effort.  The additional effort required to completely document the reduction strategies, emissions changes expected, and costs for each strategy undoubtedly led to the decision to not provide sufficient information for meaningful stakeholder review.  Conveniently, the lack of transparency means that stakeholders have difficulty asking embarrassing questions.  However, New York State is proposing a complete transformation of all facets of the energy system of the state at a likely cost of over a trillion dollars so in my opinion, the lack of comprehensive documentation is unacceptable.

Attempting to verify the Scoping Plan projections to observations is difficult.  Given these results, the obfuscation is likely deliberate.  In 2024 the Battery Electric vehicle sales were 10% less than projected.  This is not a good result given that the projection was made three years ago suggesting no confidence in 2040 predictions.  The model projects that sales will rapidly increase in 2026 and beyond. Note that Plugin Hybrids are not good enough for New York’s zero-emissions aspiration so the modeling projects that sales will peak and tail off. 

My problem with the modeling results is that they are too convenient.  I am convinced that the projections just interpolated between the Climate Act goals and current conditions to quantify vehicle sales.  The rationale driving the sales is not documented.  Why does the state expect that electric vehicle sales will increase as projected?

Up until Trump paused the program there was a Federal mandate that said all vehicles sold at a certain date will be electric.  All the mandates and incentives for the manufacturers are fruitless if the public says no thanks.  In this case there is no evidence that there is pent up demand for electric vehicles as shown by the result that Ford lost $5.1 billion in 2024 and $4.7 billion in its electric vehicle business.  Common sense says the projected sales trajectory is wishful thinking.

Conclusion

New York electric vehicle sales are not meeting the projections necessary to meet the Climate Act mandates.  NYSERDA’s reports describing “record sales” don’t bother to mention that fact.  That is misleading and biased so it looks like propaganda to me.

There is another consideration.  The lack of evidence that the electric vehicle transportation sector emission reduction plan will work is one more reason that New York State needs to pause the process and determine if the plans are feasible before more money is squandered.   I suspect that this is a universal problem for all similar initiatives.  No number of cheerful claims of record sales will be able to hide the facts much longer.

Commentary on Recent Articles February 22, 2025

This is an update of articles that I have read that I want to mention but only have time to summarize briefly.  I have also included links to some other items of interest.  Previous commentaries are available here. 

I have been following the Climate Leadership & Community Protection Act (Climate Act) since it was first proposed and most of the articles described below are related to the net-zero transition.  I have devoted a lot of time to the Climate Act because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good. The opinions expressed in this article do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

All Goal and No Plan

Ed Reid explains that UN Framework Convention on Climate Change Conference of the Parties 21 (COP21) in Paris, France produced the Paris Accords, a non-binding agreement under which the participating nations agreed to take actions necessary to achieve a goal of Net Zero CO2 emissions by 2050.  Since then, Reid notes:

It has become increasingly clear that, while the developed nations adopted the Net Zero by 2050 goal, none of them have developed a detailed plan to achieve the goal, nor have any of them analyzed in detail the cost of achieving the goal. Also, none of them has demonstrated that the transition to renewable generation they are pursuing would lead to a stable, reliable and economical energy economy. In spending hundreds of billions of dollars in pursuit of the goal without a plan or a demonstration, they have clearly “put the cart before the horse”.

 New York has joined the developed nations because this description is perfectly apt for the Climate Act.  It is truly “All goal and no plan”.

What Does No More Fossil Fuels Mean?

Ronald Stein regularly writes articles about energy illiteracy with a focus on the role of crude oil in society. Whenever I read one of his articles I wonder if the folks who demand that we stop using fossil fuels understand the implications.  In a recent piece he argues that over the last 200 years, world population has grown from 1 to 8 billion “because of the more than 6,000 products and different fuels that did not exist before the 1800s.”    He sums up:

Policymakers have no comprehension that crude oil is virtually never used to generate electricity, but when manufactured into those petrochemicals that are the basis of more than 6,000 products, it is the basis for virtually all the products that support hospitals, medical equipment, appliances, electronics, transportation, telecommunications, heating and ventilating, and communications systems.

Bugged by Wind Turbines

Chris Morrison describes the “Devastating Ecological Carnage Wrought by Wind Turbines”.  It is not just the birds but also flying insects – tons of insects.  Work in Germany found that each turbine killed 40 million each during the growing season. 

Recent work from researchers at the University of Wyoming suggests that moths, butterflies, beetles, flies and true bugs may be the most vulnerable to the giant revolving blades. Wind turbines create vortices, sucking in wildlife and causing problems for both bats and large birds such as eagles. “The vast amount of avian and insect deaths at the hands of wind turbines is disastrous in and of itself, from a conservation and ecological standpoint,” states Heartland.

Morrison sums up noting that “the loss of insects is particularly disastrous since they are decomposers, crop pollinators and a crucial basis of the entire food chain.”

Affordability is not the only risk of politicians dictating energy policy.  As I was finalizing this draft, I found an article by Robert Bradley that explains why doing the transition right is necessary.  The article is a retrospective on the Great Texas Blackout that describes how politicians are wrecking electric grid reliability.

It was not so much the story of freak weather triggering a market failure writ large. It was a classic application of the political economy of government intervention: the seen and the unseen, expert/regulatory failure, and unintended consequences.

I recommend the article highly.

NY Climate Superfund Lawsuit

ABC News reports that Twenty-two states sued New York on Thursday, contending that a new law forcing a small group of major energy producers to pay $75 billion into a fund to cover climate change damage is unconstitutional.

According to a statement, West Virginia Attorney General JB McCuskey led the coalition of states against New York’s Climate Change Superfund Act, which requires payments for damage allegedly done from 2000 to 2018.

The law requires major fossil fuel companies to pay into the fund over the next quarter-century based on their past gas emissions.

“This lawsuit is to ensure that these misguided policies, being forced from one state onto the entire nation, will not lead America into the doldrums of an energy crisis, allowing China, India and Russia to overtake our energy independence,” McCuskey said in a release.

“This law is unconstitutional, and I am proud to lead this coalition of attorneys general and brave private energy companies and industry groups in our fight to protect against this overreach,” McCuskey added. “If we allow New York to get away with this, it will only be a matter of time before other states follow suit – wrecking our nation’s power grid.”

I cannot imagine that anyone is surprised that this act of New York Progressive Democrat political grandstanding would not produce this pushback. 

EPA Funding Mismanagement

In my December 8, 2024 commentary I described a Project Veritas report that EPA is getting money out for climate change things before the Trump Administration comes in.  The money quote was from  Brent Efron, Special Advisor for Implementation, Environmental Protection Agency: “Now it’s how to get the money out as fast as possible before they [Trump Administration] come in … it’s like we’re on the Titanic and we’re throwing gold bars off the edge.”

Jo Nova describes a New York Post article with Trump appointee EPA Administrator Lee Zeldin who describes the most egregious example of waste uncovered so far: “It’s extremely concerning that an organization that reported just $100 in revenue in 2023 was chosen to receive $2 billion,” EPA Administrator Lee Zeldin told the outlet, referring to Power Forward Communities’ latest tax filings. “That’s 20 million times the organization’s reported revenue.”

Thomas Shepstone notes:

How could someone set up a non-profit NGO and then almost immediately grab $2 billion Greenhouse Gas Reduction Fund grant from taxpayers? That it happened under the thoroughly corrupt administration of Joe Biden explains most of it, of course. The suggestion in this Climate Change Dispatch story is that it all had to do with the influence of Stacey Abrams, a hero of the left.

He goes on to describe the NGO: Power Forward Communities is a 501(c)(3) NGO set up in 2023 with but $100 in assets according to its 990 return.  He describes the five NGOs that he brought together.  In every instance, the top officers of the organizations were paid enormous salaries.  For example, one NGO collected $51,568,253, and it paid its CEO $1,045,416.

Shepstone concludes and I concur:

What is unmistakably clear from the above is simply this: the $2 billion in supposed climate expenditures made with our descendants’ taxes is nothing more than a gigantic green grift. Simply put, NGOs are corrupting everything about our government. They need to be denied any government funding whatsoever if we ever hope to regain control over our republic.

If you thought that such an egregious misuse of funding would be embarrassing for environmental advocates, then you would be wrong.  Inside Climate News describes Zeldin’s efforts to claw back the money:

Environmental advocates said Zeldin was unfairly smearing the Greenhouse Gas Reduction Fund, or “green bank,” program, on which EPA worked for more than a year with the Treasury Department to design a standard financial agent arrangement—the kind the government has used many times before to collect and distribute funds.

Unraveling the Narrative Supporting a Green Energy Transition

I recently wrote an article about wind intermittency that created quite a few comments for the version that was published at Watts Up With That.  The commenters were more loud than correct and I found myself wishing that I could reference a document that addressed Green Energy advocacy talking points.  Russ Schussler, aka Planning Engineer, has provided just such a document. 

I am convinced that implementation of the Climate Leadership & Community Protection Act (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 post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Scoping Plan was finalized at the end of 2022.  The Climate Act green energy transition outlined in the Scoping Plan is starting to unravel as the politician’s aspirational fantasies meet reality.

Before he retired Russ Schussler was a long-time electric utility planning engineer.  Starting in 2014 he wrote 45 articles at the Climate Etc. blog on a wide variety of topics related to the net-zero transition that is the basis of the Climate Act. He recently published a prequel to this article that discussed the narrative around the green energy transition.  He concluded that “Expectations from the green energy narrative and real-world results are not consistent and this gulf will continue to widen as long as policy makers continue to reflexively buy into the green energy narrative.”

Schussler describes his article:

The purpose of this article is to summarize and debunk many of the issues in the narrative surrounding the proposed green energy transition.   The issues are so numerous that this piece is both too long and too short. A full unraveling deserves a book or series of books. This posting however challenges the narrative through summary comments with links to previous posts and articles which can be read for a more detailed explanation or greater depth. 

Unraveling the Narrative Supporting a Green Energy Transition

In my opinion, the typical green energy transition plan is to primarily deploy wind, solar, and energy storage to replace fossil-fired sources of electric energy. Other sources are included as “green” and clean but mostly as an afterthought.  The green energy transition narrative can be summarized as GHG emissions can be reduced to some aggressive net-zero goal simply by deploying existing technology, will be cheaper because there are no fuel costs, and will not affect the reliability of the electric grid.  Schussler notes that the components of this narrative are appealing and dangerous:

This narrative is compelling to many consumers and major policy makers. Unqualified acceptance of this powerful narrative makes it clear we should all be behind the movement to increase wind and solar generation along with other efforts to expand renewable resources.  Most all of the above statements making up the narrative are “somewhat” true. Unfortunately, the collective narrative as frequently adopted is at odds with the economics and physical realities of providing electric power and supporting civilization. 

How did a “false” narrative become so widely accepted despite dismal real-world results?  A previous posting discussed, “How the Green Energy Narrative Confuses Things” through misleading language (#44). Additionally,  tribal loyalties enable distortions and suppress more realistic assessments (#18, #10,#22, #42, & #39). While others should chime in on the social psychology supporting this movement, astute observers can’t miss the power of fear-based narratives, groupthink, demonization of dissenters and misplaced altruism (#39, #18,& #10).  Incentives and their impact on key actors play a major role (#38 & #29). The media overblowing trivialities and focusing on continually emerging “good news” helps cement undeserved optimism.   Finally, it should be noted that the electric grid has been very robust. In the short run you can make a lot of “bad decisions” before negative consequences emerge to challenge the narrative.

Narrative Statements

Schussler lists 19 component statements of the green energy narrative that are “widely believed, embraced and supported by various experts, a large part of the public and far too many policy makers”.  The article provides a response to each statement that is supported by references to 45 articles he has written since 2014.   This is an excellent resource that can be used to refute the usual suspects when they make narrative claims.  The following topics are included:

  1. Renewable Energy can meet the electric demand of the United States and World
  2. Renewable Energy is economic
  3. Renewable Energy sources can provide reliable electric service to consumers and support the grid
  4. Renewable energy sources are inexhaustible and widely available
  5. Clean Energy resources don’t produce carbon and are environmentally neutral
  6. Renewable Energy Costs are decreasing over time 
  7. It will become easier to add renewables as we become more familiar with the technologies
  8. The intermittency problems associated with wind and solar can be addressed through batteries.
  9. Inverter based generation from wind, solar and batteries can be made to perform like conventional rotating generator technology  
  10. Battery improvements will enable the green transition
  11. We are at a tipping point for renewables
  12. Wind, Solar, and Battery technologies collectively contribute to a cleaner environment, economic growth, energy security, and a sustainable future
  13. The world is facing severe consequences from increased CO2 emissions.
  14. There will be an inevitable and necessary transition to clean economic renewables
  15. Green Energy will allow independence from world energy markets
  16. The clean grid will facilitate clean buses, trucks, tanks, planes
  17. The third world will bypass fossil fuels and promote global equity
  18. Replacing fossil fuels with green energy will have huge health benefits
  19. It’s all about Urgency and Action

He acknowledges that it may be argued that the responses are short and lack detailed substantial evidence. He responds:

While there is quite a bit out there that can be referenced, it should be pointed out that the arguments supporting a green transition are asserted without with much serious reasoning and far flimsier support than provided here.  That which is easily asserted without foundation should not require overly demanding refutations. Clearly when and if more detailed claims supporting a green energy transition are made, they can be answered with more detailed rebuttals.

I particularly endorse his description of the academics whose work plays an out-sized role in the Climate Act:

Academics are a key part of the problem of a sustained false narrative. Much of the “evidence” out there comes from small studies of single variables with academic models which are stretched far behind what was analyzed.  Additionally, expert opinions come from many “experts” who “preach” far outside their fields of expertise and training. There are rewards in academia for furthering optimism on the green transition.  There are not so many incentives for nay-sayers.  Academics who understand the problems and would offer caution, generally do not have the reach of those who promote optimism by clouding the facts.  The many half-truths presented from different sources cannot be summed up to imply a credible narrative, even though many have the impression this makes a strong case.  #44

Necessary Energy Transition Narrative Truths

Another section of the article lists and references truths that need to be part of energy transition narrative.  These truths include:

  1. Adequately addressing the energy future requires we understand the true costs and benefits of ALL available and potentially available technologies. #1 & #3
  2. Large grids are dependent upon and run on rotating machines. #3, #7, #11, #26 & #12
  3. No grids run on asynchronous generation only (or majority asynchronous) without significant backup.  Asynchronous wind, solar and batteries without rotating backup resources are not feasible power supply elements for large power systems.
  4. Hydro, biomass and geothermal are fine for grid support, but are problematic and/or not available in many areas.
  5. Wind and solar face major challenges in achieving significant penetration levels and have many underdiscussed issues. 
  6. Costs of Wind and solar resources are often hidden and assigned to others. #5, #6, & #31
  7. If Nuclear is the right direction, current efforts at wind and solar are misguided. Nuclear plants run best full out with low incremental cost.   Displacing nuclear power with intermittent wind and solar makes little to no sense.
  8. It’s possible to subsidize a few things that have small costs to support development of green resources, but small costs multiplied by orders of magnitude are crushing. #6
  9. Utility costs are regressive, dis-proportionally hitting those less well-off and least able to afford rising costs. These costs are more regressive than taxation schemes. #5 #6, & #31
  10. If we must cut carbon emissions without nuclear and hydro, drastically changing civilization is an option that needs to be on the table, openly and frequently discussed and given full considered.
  11. Energy markets are not working well.  Perhaps I am wrong, but experience tells us markets uncharacteristically are not working well for energy and energy services. #45
  12. Credible plans for any electric energy future, let alone a major transition, will need to integrate studies of both supply and deliverability while balancing economics, costs and public responsibility. No conclusions about what may be worthwhile is possible without such considerations. #16 & #39

Other Topics

Schussler describes other topics that need to be considered:

  1. Givern that India and China emissions are greater than US emissions what role should we play in the proposed transition?
  2. What about developing countries in the Third World?
  3. Can effective regulation, as opposed to current regulatory practices revive nuclear construction significantly?
  4. Energy density problem (EROEI) – Can solar and wind provide enough energy to be self-perpetuating considering full lifetime needs?
  5. Grid and energy prices are globally critical to healthy economies and a reasonable quality of life.
  6. How do we incentivize policy makers to prioritize long term goals versus what’s expedient the next few years. #38 & #1

The last section of text addresses the question – when will reality force a re-assessment of the myths of the green energy narrative.  I will address that section in another post.

Discussion

My experiences writing this blog parallel Schussler’s.  As a result, he provides insights that I empathize with.  For example:

Clearly there are many discontinuities between theory and what is observed in the real world with regards to the potential for wind, solar and batteries.  Milton Friedman said, “One of the great mistakes is to judge policies and programs by their intentions rather than their results.” I’d add, “What happens in the field should be more convincing what you calculated on paper”

I have long advocated for a demonstration project and was encouraged that Schussler agrees:

The case for an energy transition based on wind, solar and batteries is grossly incomplete and stands against evidence and reason.  The green narratives sub-propositions in isolation contain some truths, but they are extended in misleading ways.   A collection of 200, 800, or ten million studies showing that isolated challenges around renewable resources can be addressed cannot make a case for reliable, affordable deliverable energy.  When the resources are ready, proponents can make a case by operating a small system without connection to conventional generation that experiences  varied load conditions and real-world challenges.  When a case for large scale penetration of wind, solar, and batteries has been made with adequate considerations of costs, reliability and deliverability, it can then be reviewed and challenged with detail.

I want to emphasize an important point about Schussler’s work.  It is from an expert whose career was dedicated to electric resource planning.  The following paragraph is advice that New York politicians that think they know best for energy policy should take to heart:

Planning must balance economics, reliability and environmental responsibility using  real workable technology which conforms with the physics of the grid and meets the needs of society (#15,#16, #25, #23 & #32).  Electric supply and the grid are too important to base policies upon poor narratives and incomplete understandings. Hope for future improvements must be based on realistic expectations.  Going a short way down the “green” path is easy.  Adding a bit more “renewables: isn’t that expensive and the gird is plenty robust for incremental hits.  For most involved, it’s easier to go with that flow than to stand up for long-term concerns.  But we are getting closer to the cliff as costs continue to increase and reliability problems become more prevalent. 

Conclusion

I think it is frightening that someone whose expertise I admire is worried about the scope of the problem and the possible ramifications.  Schussler concludes:

Policy makers need to consider a fuller and more complete array of truths around renewables and the grid. Rigorous considerations of many complex and interlinking issues between generation and transmission are needed to build and support modern grids. No-one, even those with a lifetime in the business, fully understands everything involved. Experience and incremental changes have served the development and operation of the grid well.  Many outside “experts”,  have next to no real knowledge of the complexities involved and propose dramatic changes. Without serious and time-consuming efforts from policy makers, real grid experts can’t compete with proposals that are basically founded upon tee-shirt slogans.  Spending money, altering systems, and hoping for the best based on the green narrative alone is a recipe for disaster. 

Net Zero Cure is Worse Than the Disease

David Turver supports my belief that New York’s Climate Leadership & Community Protection Act (Climate Act) is not in the best interests of New Yorkers.  The basis of his arguments is the unfolding disaster in Great Britain.  His post includes a video of a talk on the topic, copy of the slides, and the argument summary described below.

I am convinced that implementation of the 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 post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes an interim 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.” 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. 

Net Zero Cure is Worse Than the Disease

Turver introduces his arguments by noting that climate change impacts are exaggerated:

Although people like Antonio Guterres have made the foolish claim we have entered the era of global boiling, we have to acknowledge that the world has warmed a bit since pre-industrial times. The alarmist response to this is Net Zero which is an example of a so-called mitigation strategy that calls for everyone to reduce their emissions of carbon dioxide to save the planet.

Earlier this year I quoted Richard Lindzen’s description of the made-up rationale: “In this complex multifactor system, what is the likelihood of the climate (which, itself, consists in many variables and not just globally averaged temperature anomaly) is controlled by this 2% perturbation in a single variable? Believing this is pretty close to believing in magic.” 

The following paragraph eviscerates the entire rationale of the Climate Act.  Turver explains that the mitigation can never work:

The trouble with this approach is that it can only work if two conditions are met. First, mitigation can only work if CO2 is the only climate control knob. But we know this to be wrong, because the IPCC’s first report showed marked temperature fluctuations over thousand-, ten thousand- and million-year timescales when CO2 levels in the atmosphere were pretty constant. Second, mitigation can only work if everyone else follows the same strategy. But we know that global emissions of greenhouse gases are rising sharply even though ours have fallen into insignificance. Global consumption of coal, oil and gas are at record levels. Neither condition is met, so the UK’s Net Zero mitigation strategy can never work.

Turver is as frustrated as I am about the impact of net zero policies like the Climate Act:

Nevertheless, this has not stopped politicians and policymakers rushing headlong into Net Zero policies that have resulted in the UK having the most expensive industrial electricity costs in the IEA, some 4X those of the US and 2.6X Korean prices. This is leading to energy austerity with UK primary energy consumption down 23% since 1990 while global energy consumption is up 72% over the same period. Our National Energy System Operator, NESO wants to double down on energy austerity and halve our energy consumption per capita from 2023 levels by 2050.

High energy prices coupled with energy austerity have led to economic stagnation. There is a strong correlation between reduced energy use and slow growth, with the EU27 and US growing faster than the UK because they have had smaller cuts to energy use. Korea, India China and the rest of the world are using much more energy and their economies are powering ahead.

I do not see any scenario where these impacts will not occur in New York.

The rationale for the Climate Act is that we have a problem, that it can be solved by reducing greenhouse gas emissions, and that there is an easy way to reduce emissions.  Turver describes the myths created to promote renewables:

Despite the obvious economic and social costs of Net Zero, a series of myths have been created to support the renewables agenda. They claim renewables are cheap, but we pay £11bn/yr in renewables subsidies, £2.5bn for grid balancing and a further £1bn for the capacity market. National Grid have announced £112bn in spending on grid expansion by 2035 which will also find its way on to our bills. Moreover, the cost of renewables is rising and projects like Norfolk Boreas and Hornsea Project Four have been cancelled because the developers cannot make money at the prices they agreed. Ed Miliband wants to spend £260-290bn by 2030 on his Clean Power plan to save only around £7bn/yr of the money we spend on gas-fired generation.

Turver explains that the ideologues pursuing these policies think that it will improve the economy:

The second myth is that Net Zero will create jobs and growth. But the truth is expensive energy costs are destroying high-productivity industries like chemicals, petrochemicals, ceramics and steel that are growing more slowly than the rest of the economy or outright shrinking. Instead we are growing less energy intensive low-productivity sectors that are damaging productivity and growth for the whole economy. Green energy jobs are destroying real jobs and cost around £250K/yr per job.

Turver describes another myth that has been used in New York:

The third myth is that renewables increase energy security. But intermittent sources like wind and solar can never deliver security because we cannot control the weather. As a result we came close to blackouts last month as NESO suffered a margin call. We cannot rely upon interconnectors either, because the Norwegian Government fell because of the impact interconnectors are having on their electricity prices.

The Climate Act mandates that all environmental impacts of fossil fuels be considered but pointedly ignores any consideration of wind and solar development impacts.  Turver notes that this is a common flaw:

Finally, it is claimed that wind and solar renewables are green and kind to the environment. But both have very high mineral intensity, meaning massive mines will be scarring the landscape to produce the copper, silver, cobalt and rare earth metals required. They also take up a lot of land, land that would be better utilised to grow food.

The Climate Act does include a requirement to consider adaptation.  Turver explains that adaptation is a superior strategy:

By contrast, adaptation is a far superior strategy. Deaths from natural disasters and weather events have fallen more than 10-fold over the past century as we have used cheap, abundant energy to tame nature. Global life expectancy has doubled since 1850 and cereal yields are up three times since 1961. These remarkable achievements have come despite, some might argue because of, the rise in temperatures and global CO2 levels.

In my opinion, New York short changes this strategy because at its root the Climate Act is a political tool.  Politicians passed the law to cater to specific constituencies but the opportunities to make money via adaptation are small. Given that there are no organized rallies organized by politically connected constituencies at the Capitol lobbying for adaptation policies this strategy is not a priority.

Turver concludes that nuclear power is the answer:

Turning now to the answer. For humanity to thrive, we need cheap, abundant and reliable energy. This will give us the surplus energy that we need to continue to adapt by building flood defences, improving irrigation developing new crop varieties and so on. Adaptation has the big advantage is that it works regardless of the cause of global warming or climate change. The only technology that is proven to work at scale is nuclear power. This will take time, so we need gas as a transition technology. Nuclear power has the added advantage of being energy dense, reliable and requires very little mining so has the smallest overall environmental footprint. We need nuclear power everywhere all at once.

I agree that developing nuclear power is a better choice.  His pragmatic approach to use natural gas as a bridge fuel used to be the accepted path forward.  The vilification of natural gas is based almost entirely upon emotion and precludes a strategy that has proven success.

Conclusion

Philosopher George Santayana, originally stated, “Those who cannot remember the past are condemned to repeat it”.  In this instance New York is ignoring what is currently happening with respect to the net-zero transition in Great Britain.  The consequences will be the same.  Turver concludes:

Net Zero is ineffective in achieving its primary goal and can never stop the weather changing. The impact of Net Zero policies is devastating for the economy and high productivity, energy intensive industries in particular. Renewables are not kind to the environment and the lies being told to promote them are untenable. The Net Zero cure is worse than the climate change disease.

Governor Hochul and Climate Act Affordability Part 2

I have argued that Climate Leadership & Community Protection Act (Climate Act) affordability would become a political issue.  I also argued that when Governor Hochul assigns Climate Act responsibilities to the New York Power Authority (NYPA)and then says “Too many New Yorkers are already falling behind on their energy bills and I will do everything in my power to reign in these astronomical costs” when NYPA proposed raising rates to cover those costs it is hypocritical.  This post looks at utility rate impacts.  Those costs are already increasing dramatically.

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 two 2030 targets: an interim emissions reduction target of a 40% GHG reduction by 2030 and a mandate that 70% of the electricity must come from renewable energy 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. 

Personal Experience

This post was prompted by an email from a friend who sent along screen shots of his most recent and last year’s electric supply bills from New York State Electric & Gas (NYSE&G).

NYSE&G current bill screen shot:

NYSE&G electric bill from a year ago:

I looked up my electric bills.  Here are screenshots of current Niagara Mohawk Power Corporation, dba– National Grid electric rates

Here is a screenshot of the same information from a year ago:

I compared the cost increases in Table 1.  NYSE&G electric supply rates have increased sharply.  National Grid went up but not nearly as much. 

Table 1: New York Electric Supply Rate Increases Examples

New York State Electric Utility Rate Cases

The differences between the two utility rates in Table 1 is striking.  Particularly because the service territories overlap so much (Figure 1).

Figure 1: NYS Electric Utility Service Territories

I suspected that the differences at this time are due to the status of New York State electric utility rate cases.  NYSE&G has recently settled their rate case whereas National Grid is in a pending case.  National Grid rates will go up as soon as a new rate case is settled and the only question is how much.  I checked the Public Service Commission (PSC) Pending and Recent Electric Rate Cases web pages and found the following information.

Niagara Mohawk Power Corporation dba National Grid:

NMPC is requesting an increase in annual electric revenues of approximately $525 million (20 percent increase in delivery revenues or 11 percent in total revenues) for the rate year ending March 31, 2026. NMPC estimates that the requested increase in delivery revenues will result in a monthly bill increase of $18.92 (23.4 percent increase in delivery bill or 15.3 percent increase in total bill) for a typical residential customer using 625 kilowatt-hours (kWh).

For the record here is information on other rate cases listed at the PSC website.

Central Hudson:

Central Hudson Gas and Electric Corporation is requesting an increase in annual electric delivery revenues of approximately $47.2 million (8.8 percent increase in base delivery revenues, or 4.6 percent increase in total system revenues), compared to the revenues approved by the Commission for the Company’s current Rate Year. The requested increase in electric delivery revenues results in a monthly bill increase of $9.19 (8.6 percent increase on the delivery bill, or 5.3 percent increase on the total bill) for an average residential customer using 630 kilowatt-hour per month.

Consolidated Edison:

Con Edison is requesting an increase in annual electric delivery revenues of approximately $1,612 million (an 18.0 percent increase in base delivery revenues, or an 11.4 percent increase in total revenues). The requested increase in delivery revenues results in an average residential monthly delivery bill increase of $26.60 (a 19.1 percent increase on the delivery bill, or a 13.4 percent increase on the total bill) for a 600 kilowatt-hour/month customer. 

The primary drivers of the requested electric increase are local property taxes (which account for an overall electric bill increase of 3.1 percent), new infrastructure investment (2.6 percent) and operating expenses (2.6 percent). Con Edison purports that its filing will help accommodate demand growth, especially with clean energy options and substation investments, while maintaining reliability with investments in feeder replacements. The Company is also enhancing its system resiliency for more frequent and severe storms, as well as warmer temperatures.

In addition, the Company’s filing purportedly includes a focus on improving customer outreach and accessibility, enhancing customer support and the customer experience, and promoting energy efficient programs. The Company plans to expand outreach efforts to enroll eligible customers in the Energy Affordability Program.

I also did a Perplexity AI search asking the question: What is the status of New York State electric utility rate cases.  The results noted that “as of February 17, 2025, there are no pending or recent electric rate cases for New York State Electric & Gas (NYSEG). However, there are some notable developments in the New York electric utility landscape”.  The response stated:

Con Edison’s proposed rate hike: Governor Hochul has directed the state agency to reject Con Edison’s proposed rate increase, which would have raised electricity rates by 11.4% in 2026.

Orange & Rockland Utilities: There is a pending case (Case 24-E-0060) for Orange and Rockland Utilities, Inc. The company is requesting a 7.3% increase in electric delivery revenues for the rate year ending December 31, 2025.

National Grid: The company filed a request in May 2024 for new electric and gas rates in upstate New York, proposing to reset prices beginning in Spring 2025.

Previous rate increases: Con Edison has already implemented rate increases of 9% in 2023, 4% in 2024, and 1.4% in January 2025.

Discussion

The Perplexity AI response also noted that “It’s worth noting that Governor Hochul has also directed the Department of Public Service to conduct a statewide audit of utility company salaries and compensation, which may impact future rate cases.”   The referenced article notes that Governor Hochul “pushed back against proposed rate hikes from Con Edison, directing the state’s Department of Public Service to reject the company’s request for approval.”  I believe that there should be a line on bills that documents the Climate Act costs.  That transparency could be politically damaging so that will never happen.

I am also concerned about the Public Service Commission.  Given that all the Commissioners are partisan political appointees when she directs them to reject the rate case, that is what will happen.  Furthermore, most of the board has ties to green energy.  This will certainly lead to biased outcomes that I think will not be in the best interests of New York.

I asked Perplexity AI another question – Are the commissioners of the New York Public Service Commission partisan appointees of the governor. It responded that was true.  The response was based primarily upon New York Public Service Law Section 4 and stated that:

The governor appoints the commissioners with the advice and consent of the New York State Senate.

However, there are restrictions on partisan composition:

  • The commission consists of up to seven members.
  • No more than three commissioners may be members of the same political party if there are five commissioners.
  • If the number of commissioners is increased to seven, no more than four may be from the same political party.

These rules ensure some level of bipartisan representation on the commission, despite the commissioners being appointed by the governor. The commissioners serve six-year terms on a full-time basis.

However, the current composition is anything but bipartisan.  Technically there are only three Democrats and one Republican but four members have direct experience with green energy non-governmental organizations.  The Public Service Commission website for the Commissioners lists the backgrounds of the seven members. 

  • Rory M. Christian, Chair of the Commission – Chairs of New York agencies are chosen for political allegiance to the party of the Governor so I count him as a Democrat.  He also was the Director of New York Clean Energy at Environmental Defense Fund.
  • James S. Alesi – Held an office as a Republican.
  • David J. Valesky – Held an office as a Democrat.
  • John B. Maggiore – Worked in Democrat administrations.             
  • Uchenna S. Bright – Has not held political office but worked with environmental non-governmental organizations include the Natural Resources Defense Council (NRDC).
  • Denise M. Sheehan has not held political office but has “30 years of experience in government and non-profit sectors” and currently serves as Senior Advisor to the New York Battery and Energy Storage Technology Consortium (NY-BEST).
  • Radina R. Valova has not held political office.  Served as Vice President of the Regulatory Program at the Interstate Renewable Energy Council (IREC), a national non-profit organization that builds the foundation for clean energy and energy efficiency.  Prior to joining IREC, Ms. Valova served as Senior Staff Attorney and Regulatory Affairs Manager for the Pace Energy and Climate Center in White Plains.

I make that one Republican, three Democrats, and three that could conceivably be called non-partisan but certainly could also be called environmentalists.  As a result, I think the makeup of these Commissioners will acquiesce to anything the Governor wants.  At the top of that list is the Climate Act green energy narrative that transitioning away from fossil fuels to “free” solar and wind will lower prices.  If that does not happen it must be because of the greedy utility companies.

There is only one problem with that approach – reality.  In the real world, providing reliable wind and solar energy is expensive.  The utility companies will be on the hook to provide the distribution and transmission system upgrades necessary to get the diffuse solar and wind power from where it is generated to where it is needed.  The utility companies have also been told to develop infrastructure for electric vehicle charging. If Hochul’s grandstanding disapproval of rate cases continues, then how are those necessary components of the net-zero transition going to get built?

Conclusion

Hochul was quoted as saying “Too many New Yorkers are already falling behind on their energy bills and I will do everything in my power to reign in these astronomical costs.”  I can’t believe that the Hochul Administration does not understand that the transition will cost enormous amounts of money and is a major reason for those “astronomical” costs.    In my opinion, the political solution is to stop the transition and blame someone else.  I expect that the Trump Administration’s slow down of offshore wind, cancellation of electric vehicle mandates, and the cut back on components of the Inflation Reduction Act will provide the political cover for Hochul to say we tried but evil Trump makes it impossible.   Stay tuned to the political theater as this unfolds.