More Reasons to Pause Climate Act Implementation April 16 2025 Edition

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

I am convinced that implementation of the Climate Act net-zero mandates will do more harm than good because the proposed green energy programs are crimes against physics.  The energy density of wind and solar energy is too low and the resource intermittency too variable to ever support a reliable electric system relying on those resources. If this reality is not acknowledged soon and these policies paused, then the enormous costs of this futile gesture to control the climate will bankrupt the state. 

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 500 articles about New York’s net-zero transition.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes an interim reduction target of a 40% GHG reduction by 2030. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.”  After a year-long review, the Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation. 

Protecting American Energy from State Overreach

On April 8 President Trump issued an Executive Order protecting American energy from state overreach.   The purpose of the order: “My Administration is committed to unleashing American energy, especially through the removal of all illegitimate impediments to the identification, development, siting, production, investment in, or use of domestic energy resources — particularly oil, natural gas, coal, hydropower, geothermal, biofuel, critical mineral, and nuclear energy resources.”

New York earned a specific callout:

Many States have enacted, or are in the process of enacting, burdensome and ideologically motivated “climate change” or energy policies that threaten American energy dominance and our economic and national security.  New York, for example, enacted a “climate change” extortion law that seeks to retroactively impose billions in fines (erroneously labelled “compensatory payments”) on traditional energy producers for their purported past contributions to greenhouse gas emissions not only in New York but also anywhere in the United States and the world.  

But wait there’s more.  Trump implicitly addresses New York’s carbon taxation cap and invest plan:

Other States have taken different approaches in an effort to dictate national energy policy.  California, for example, punishes carbon use by adopting impossible caps on the amount of carbon businesses may use, all but forcing businesses to pay large sums to “trade” carbon credits to meet California’s radical requirements.  Some States delay review of permit applications to produce energy, creating de facto barriers to entry in the energy market.

The first section ends with this: “These State laws and policies are fundamentally irreconcilable with my Administration’s objective to unleash American energy.  They should not stand.”

Section 2 starts with this:

State Laws and Causes of Action.  

  • The Attorney General, in consultation with the heads of appropriate executive departments and agencies, shall identify all State and local laws, regulations, causes of action, policies, and practices (collectively, State laws) burdening the identification, development, siting, production, or use of domestic energy resources that are or may be unconstitutional, preempted by Federal law, or otherwise unenforceable.  The Attorney General shall prioritize the identification of any such State laws purporting to address “climate change” or involving “environmental, social, and governance” initiatives, “environmental justice,” carbon or “greenhouse gas” emissions, and funds to collect carbon penalties or carbon taxes.
  • The Attorney General shall expeditiously take all appropriate action to stop the enforcement of State laws and continuation of civil actions identified in subsection (a) of this section that the Attorney General determines to be illegal. 

That section also notes that the report from the Attorney General is due in 60 days.  I imagine that the report will prominently feature New York’ Climate Act as impeding American energy.  I think even the fanatics in the Hochul Administration are realizing that Climate Act implementation is going to be ruinously expensive even if it works and there are signs that it won’t.  However, admitting this will open the Administration to attacks that they are not trying hard enough.  What better excuse to pause than to blame this Trump Executive Order?

Electric Vehicle Mandates are Failing

Paul Homewood at Not a Lot of People Know That published three recent articles describing the progress of electric vehicle mandates in Great Britain.  There are no encouraging signs that it is working.

In the first article he documents that the electric vehicle (EV) sales figures are lower than the mandates. 

The second article notes that the EV costs are not coming down as projected which no doubt contributes to the poor sales.  He concludes with a note describing the government’s long awaited announcement of the new plans to rollout EVs.  He notes: “But strip away the waffle, greenwash and gaslighting, and we are left with rearranging to deckchairs on the Titanic to a higher deck, so that they don’t sink below the waves quite as soon!”

There is no way that the EV projections and rollout will be any different in New York.

Green Energy Jobs

Proponents of the Climate Act claim that the investments in green energy are creating new economic activity in New York.  The 2024 Clean Energy Industry Report claims in a factsheet that “New York’s clean energy industry gained 7,700 jobs between 2022 and 2023”.  I recently ran across a well-documented post by JoNova that suggests that this claim is a biased assessment:

It’s not rocket science. If energy costs more, that means we have to make do with less of it, or make do with less of something else. Thus if the government forces everyone to pay more for electricity, companies have less spare cash to employ people. Their margins are tighter, they can’t make and sell as many products. So when we are told the clean energy revolution is creating jobs, is it virtually self-evident that’s a mythical fairy claim.

Her article quotes analyses that show that each green job in Britain costs £100,000 (and 3.7 other jobs); in Spain for every green job created 2.2 jobs were lost; in Italy, each green job cost 5 jobs from the rest of the economy; in Germany, the subsidies far exceed the wages of the jobs created; and in Denmark wind power reduces the GDP.  If there is a full accounting of the costs of the Climate Act provided we will be able to calculate the cost per job created.  I doubt that New York will perform any better than the European countries when a final job accounting is completed.  

Pausing to assess whether the job benefits are real is not the only jobs-related issue.  The bigger problem is that the work needed relies on skilled tradespeople and there simply are not enough available to do what needs to be done.

Necessity for Nuclear Challenge

I have frequently written about the dispatchable emissions free resource (DEFR) necessary to keep the lights on during extended periods of low wind and solar resource availability in the Scoping Plan proposed electric system.   One major problem is that there are no commercially available DEFR resources.  I think the most promising DEFR backup technology is nuclear generation because it is the only candidate resource that is technologically ready, can be expanded as needed and does not suffer from limitations of the Second Law of Thermodynamics. However, it is not really ready to fulfill New York’s needs.

Ted Nordhaus describes the issues that the nuclear industry has to overcome before we can deploy it in New York effectively: “Rebooting the US nuclear sector for the 21st century is a hard problem in the face of an ossified industry, an overbearing and underprepared regulator, liberalized electricity markets that are ill-suited to investing in large public works projects, and competition from both cheap gas and a mature, subsidized renewables industry.”

Clearly it would be prudent to pause renewable development until DEFR feasibility is proven because nuclear generation may be the only viable path to zero emissions and that will not be ready to deploy as needed to meet the aspirational Climate Act schedule..

Implication of Assessment of Extreme Renewable Resource Lulls

Note: A version of this article was posted at Watts Up With That

I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act) could have devastating impacts on New York residents as long if proponents ignore lessons that could be learned elsewhere and continue down the current path.  This post describes work done in Great Britain that has direct bearing on New York’s implementation plans and shows we need to re-think the tradeoffs of Climate Act implementation.

I believe 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 article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes an interim reduction target of a 40% GHG reduction by 2030. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.”  After a year-long review, the Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation.  Recently, the State initiated the State Energy Plan process to update it to be consistent with the Climate Act.  It is not clear whether this proceeding will consider stakeholder comments that were ignored during the Scoping Plan process.

Renewable Resource Lulls

The Scoping Plan, Integration Analysis, New York Independent System Operator (NYISO), New York Department of Public Service, the New York State Reliability Council, and others all have noted that a new category of generating resources called Dispatchable Emissions-Free Resources (DEFR) is necessary to keep the lights on during periods of extended low wind and solar resource availability.  The frequency, duration, and intensity of wind and solar availability gaps must be known to properly plan to provide the generation, storage, and DEFR resources necessary to maintain reliable service.  Analyses done by the New York State Reliability Council Extreme Weather Working Group have shown that extended periods of low wind and solar resource availability will be challenging for the future New York electric system. 

On December 24, 2024 I submitted testimony for the December 18, 2024, Assembly Standing Committee on Energy Public Hearing regarding NYSERDA Spending and Program Review. I noted that the biggest feasibility challenge is the identified “gap” when wind and solar resources are low for long periods.  As one example of appropriate feasibility funding, I recommend analyzing the variability in low wind and solar resource availability.  The characteristics of the resource gaps must be quantified not only for New York but also for adjoining regional systems presuming that they also transition to an electric system with a similar reliance on wind and solar.

The Independent System Operator of New England (ISO-NE) Operational Impact of Extreme Weather Events  completed an analysis that addresses this need for New England.  The study evaluated 1-, 5-, and 21-day extreme cold and hot events using a database covering 1950 to 2021. The results found that the system risk or “the aggregated unavailable supply plus the exceptional demand” during an event increased as the lookback period increased.  If the resource adequacy planning for New England only looked at the last ten years, then the system risk would be 8,714 MW, but over the whole period of record, the worst system risk was 9,160 MW which represents a resource increase of 5.1%.  This means that the low renewable resource analysis should cover as long a period as possible to determine the longest period of exceptional demand and low renewable resources.

Great Britain Renewable Assessment

David Turver blogs about energy issues in Great Britain. In an October 2023 post  he describes a report from the Climate Change Committee (CCC),  their equivalent to New York’s Climate Action Council. He explains that the Royal Society (RS) Large Scale Electricity Storage report authored by Professor Chris Llewellyn-Smith claims that Great Britain can meet its demand for electricity with wind and solar, supported by large-scale hydrogen storage.  Large-scale hydrogen storage is the placeholder DEFR technology in the Scoping Plan, so this analysis is directly applicable to New York’s DEFR resource issue.

Turver argues that the report is deeply flawed. Among his concerns are the following:

They begin by assuming that electricity demand will be 570TWh in 2050 which represents roughly halving the energy demand across residential, transport and industrial and commercial categories. The evidence from Our World in Data shows that rich economies require high energy consumption to thrive. There are no rich countries with low energy consumption and those countries that have reduced energy consumption have grown more slowly, or even shrunk. The first extraordinary claim of low energy consumption fails because the evidence shows that if we allow that to happen, we will be much poorer.

The report then goes on to assume that the profile of electricity demand will be the same as today. However, as we move from gas to electricity to heat our homes and offices, the winter surge in electricity demand will be further exaggerated. Moreover, demand will change from year to year such as during the cold winter in 2010 that also coincided with a calm period when we would have generated much less renewable electricity. These variations in demand profile will lead to more generation capacity and an even bigger energy store than RS assumes, pushing up costs.

He goes on to argue that there are other flaws.  the report assumes unrealistic load factors for both onshore and offshore wind. It underestimates the amount of offshore wind needed and goes on to assume efficiencies and costs for hydrogen electrolysers, storage, and generation that do not stand up to scrutiny.  He also points out that the economic assumptions are flawed. 

He describes the “main positive aspect of the report”:

The thing that stands out most is the painstaking analysis that has been conducted to understand the very significant changes in the weather that occur on yearly and decadal timescales. They analysed wind and solar records over 37 years to estimate the level of variation we might expect from wind power.

In a recent article Turver includes a graphic that shows this issue using the 37 year database.

The analysis of 37 years is longer than anything done to date for New York.  He also points out an aspect of DEFR that relies on hydrogen storage that I had not considered previously.  It is not just the annual worst-case episode but there can be multi-year issues:

They found that we can sometimes have several consecutive years where the wind speed is lower than average. This means that if we are to have a grid powered solely by wind, solar and storage, then we need to build up massive stores of energy in the windy years to be used in the calmer years. They conclude that to consistently deliver their 570TWh of electricity each year, we would need 123TWh of hydrogen storage. Some of that hydrogen may have to be stored for a decade or more before it is used.

He also points out that the requirement for decadal storage is another flaw for any DEFR backup resource:

This has important implications for the economics of storage and effectively rules out batteries as the storage medium. Who would want to spend millions on building a battery or hydrogen storage cavern, even more to fill it and maintain it, yet not see any revenue from it for years after it was completed?

DEFR Backup Reliability Risk

Turver’s article raises the ultimate reliability risk for a weather-dependent electric system.  Today’s electric system resource planners for a conventional system base the amount of capacity that they think will be needed based on decades of observations of the fallibility of power plants.  The result is that they know the probability there will be a shortage of available capacity to meet load when the installed reserve system capacity margin is a fixed percentage of the expected load very well.  In New York State the installed reserve margin to meet the accepted probability of a loss of load expectation of an outage no more than once in ten years reliability metric is around 20%.

A fundamental observation is that there is no expectation that the failure of conventional power plants will be correlated.  We do not expect that many will fail at the same time.  That in turn means that even if we decided to set the reliability metric based on a one in thirty-year probability that there would not be much of an increase in the installed reserve margin.

That all changes when the electric system transitions to one dependent upon wind and solar weather-dependent resources.  We know that solar energy is zero and night and much lower in the winter.  Similarly, we know that wind energy is much lower in a high-pressure system, and that those systems are huge and cover all Great Britain and much of western Europe or eastern North America at the same time.  Exacerbating the problem is the fact that those conditions are associated with the hottest and coldest episodes with the greatest expected electric loads.

Turver’s post shows that looking at one year is absurd.  Not looking at the worst year on record is nearly as bad: “They used 1987 as a 1-in-20 year stress test, when they admit that 2010 was a 1-in-50 year event”.  The insurmountable problem is that we know that if an even longer period of record was used there would very likely be an even worse event.  Instead of the confidence in the current planning process that increasing the lookback period will not markedly change the resources needed for the worst case, relying on weather-dependent resources means that inevitably there will be a period of extreme weather that exceeds the planning criteria chosen and the expected resources based on those criteria.  The costs to provide DEFR backup support will be extraordinary and building excess capacity for a very rare event will significantly add to those costs.  This trade-off means that eventually there will be a catastrophic blackout when the load exceeds the storage capacity.

Conclusion

Turver’s articles are further evidence of the DEFR “gap” problems for any electric system that relies upon weather-dependent renewable resources.  The first problem is that you have to determine how much DEFR capacity is needed using as long record as possible.  The second problem is that there is no commercially available DEFR technology that is available to deploy for the aspirational Climate Act targets.  Thirdly, until a DEFR strategy is proposed we have no idea how much this will all cost so any claims that the Climate Act will be “affordable” are incomplete.  Finally, there is the insurmountable weather-related probability that eventually there will be a unusual set of weather conditions and load requirements that exceed the DEFR resources deployed. 

To sum up: we know that a new resource will be needed, we don’t know how much, what it will be, how much it will cost, and that whatever we do eventually it won’t be enough so people will die in a catastrophic blackout.  This is insanity.

Energy Plan Board Meeting Misleading Information – Climate Change Impacts are Here

I recently wrote an article about the claim that renewable energy can reduce costs in the presentation by Jeff Freedman from the Atmospheric Sciences Research Center, University at Albany at the Energy Planning Board on March 3, 2025.  I concluded that the claim is based on hope not evidence.  Dr. Freedman’s presentation also included slides that support the Hochul Administration narrative that Greenhouse Gases (GHG) are the cause of the observed increases in global temperature and that the impacts of that warming are evident today.  This article explains why I disagree with those claims in Freedman’s presentation.

I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act) net-zero mandates will do more harm than good if the 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.

Energy Plan Overview

According to the New York State Energy Plan website (Accessed 3/16/25):

The State Energy Plan is a comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers. The Plan provides broad program and policy development direction to guide energy-related decision-making in the public and private sectors within New York State.

The current Plan was initially published in 2015, and updated in 2020, when it was amended to align with the objectives of the 2019 Climate Leadership and Community Protection Act (Climate Act). Since the last update, the Climate Action Council produced its Scoping Plan, examining many of the energy issues that contribute to climate change and offering recommendations that are currently being implemented by the State.

On September 9, 2024, the Hochul Administration initiated the State Energy Plan process to update the Plan consistent with the Climate Act.  The goal of the planning process is to “map the state’s energy future by showing how the state can ensure adequate supplies of power, reduce demand through new technologies and energy efficiency, preserve the environment, reduce dependence on imported gas and oil, stimulate economic growth, and preserve the individual welfare of New York citizens and energy users.” The major question that must be addressed is whether the Hochul Administration will use the energy planning process as an opportunity to consider the advice of stakeholders in its stakeholder process or just an obligation with no attempt to meaningfully engage with any comments inconsistent with the narrative.

If the March 3 meeting is any indication, then the Energy Plan will be another political show extolling the virtues of the Climate Act and ignoring anything inconsistent with the political narrative.  In other words, it looks just like the Scoping Plan process.  Many of the appointees to the Climate Action Council chosen to approve the Scoping Plan were chosen because of their position within the Hochul Administration or political connections and not their technical expertise.  One feature of the Scoping Plan process was the New York State Energy Research & Development Authority (NYSERDA) strict adherence to the political narrative rather than full disclosure of inconsistent issues.  This article addresses several arguments made in the NYSERDA presentation by Freedman that misled the Energy Planning Board members.

Narrative Support

Climate Leadership & Community Protection Act Section 1. Legislative findings and declaration, subsection 3 defines the narrative:

Action undertaken by New York to reduce greenhouse emissions will have an impact on global greenhouse gas emissions and the rate of climate change. In addition, such action will encourage other jurisdictions to implement complementary greenhouse gas reduction strategies and provide an example of how such strategies can be implemented. It will also advance the development of green technologies and sustainable practices within the private sector, which can have far-reaching impacts such as a reduction in the cost of renewable energy components, and the creation of jobs and tax revenues in New York.

The  presentation slides for the March 3 meeting included Freedman’s Key Findings slide that support this narrative.   The first finding says that “Climate change is already constraining some sources of energy supply and stressing transmission and distribution infrastructure through extreme heat, changes in precipitation, and increasing storm intensity”.  The implication is that reducing GHG emissions in New York will affect the rate of climate change which they claim has already become evident.  The second finding that “Patterns of energy demand are shifting due to climate change and are expected to continue evolving over the coming decades” explicitly states that impacts are observable.

These findings were presented to the Energy Planning Boad as unequivocal statements of fact.  In reality, there is significant uncertainty that should be considered in the draft Energy Plan.

Comparison of CO2 and Global Temperature

The common basis of the threat of climate change caused by human emissions of GHG is the graph comparing the concentration of CO2 and global temperatures that was included in Freedman’s presentation.  There is no question that increasing the concentration of GHG in the atmosphere will reduce the out-going long wave radiation which will warm the atmosphere, and the graph shows a correlation.  However, the conclusion that reducing New York’s GHG will affect global temperatures and the alleged weather impacts given the small contribution to the global concentration is unwarranted.

Esteemed climate scientist Richard Lindzen describes the energy budget in context:

The energy budget of this system involves the absorption and re-emission of about 200 watts per square meter. Doubling CO2 involves a 2% perturbation to this budget. So do minor changes in clouds and other features, and such changes are common. 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?

Lindzen points out that believing this is “pretty close to believing in magic”.  Nonetheless, Freedman presents the graph of CO2 concentration and global temperature without any mention of the shortcomings and complexities of the climate system.

My point is that this is not as obvious a relationship as claimed.  Sabine Hossenfelder produces You Tube videos on science and technology.  Her climate change-related videos generally adhere to the narrative, but she has shown signs of waking up to reality. Peter Ridd commented on her awakening noting that she does not quite get there.  I call your attention to Ridd’s commentary where he talks about uncertainties about how the earth’s weather system works. Especially relevant to Freedman’s graphic is Ridd’s explanation of temperature and CO2 concentrations going further back in time than Freedman’s graph.  Ridd points out in the following graph that temperatures were higher many times in the last 10,000 years at the same time that CO2 concentrations were lower.  That directly contradicts the notion that global temperature is primarily driven by anthropogenic CO2 concentrations.

Climate vs. Weather

Freedman perpetuates the Climate Act myth that climate change is increasing extreme heat, changes in precipitation, and increasing storm intensity with a graph that shows increasing storm events in New York from 2001 to 2024.  In general, climate is what you expect, and weather is what you get.  To determine what you expect from climate, meteorologists use a 30-year climatological average.  Therefore, to have a climate trend you need to look at the difference between two 30-year averages at a minimum.  Freedman’s graph is a weather average trend unsuitable for making any climate trends claims.

After I drafted this article Anthony Watts summed up my problems with claims that climate change is an existential threat in a post entitled “Is Climate Change Real? Short Answer: Yes — But It’s Complicated.”  I published an article that quoted the article with my annotated comments relating the points he made to the Climate Act.  I highly recommend reading that aartilce.

Basis for Narrative Claims

Expert presentations designed to promote the Climate Act narrative to an audience such as the Energy Planning Board often cite the results of modeling.  In this instance there is a slide that describes the “effects of climate change on renewable energy distribution in New York State” based on “results from high-resolution dynamic downscaling”.  Sounds very scientific and above reproach.

The grid size for CMIP5 (Coupled Model Intercomparison Project Phase 5) climate models typically ranges between 125 km to 300 km.  This is too coarse for predicting the impacts of climate change on New York so higher-resolution regional models have been used in projects sponsored by NYSERDA to project impacts.  This process is called dynamical downscaling.  Unmentioned are the errors and inherited biases in the process from the Global Climate Models (GCM) for the following:

  • Temperature trends: Persistent warm/cold biases in coastal and inland regions, exacerbated by future GCM projections exceeding historical maxima.
  • Precipitation patterns: Systematic underestimation of seasonal rainfall in regions like the Caribbean and Southern Africa.
  • Extreme events: Misrepresentation of high-frequency, low-intensity rainfall (“drizzle problem”) due to GCM limitations.

I think that those issues underestimate the problems because the fact is the GCM projections do not include the physics of clouds.  The problem is that coarse grid size cannot incorporate precipitation or extreme events.  This is not to say that the models don’t predict storms, just keep in mind that they are little more than guesses strongly influenced by the biases of the modelers. 

There are structural RCM limitations that introduce their own errors despite higher grid size resolution:

  • Simplified physics: Inadequate representation of convective processes and local interactions (e.g., lake effects).
  • Scale mismatches: Difficulty resolving sub-grid features even at 10–50 km resolutions.
  • Computational constraints: Limited ability to run multiple GCM-RCM combinations, reducing uncertainty sampling.

Those limitations are relevant to the purported New York results.  For five months of the year much of Upstate weather is strongly influenced by the Great Lakes.  Convective processes and local interactions like lake effect are erroneous in the RCM because the scale of the lake effects is smaller than the resolution of the models.  I have been working with weather models and Upstate mesoscale weather regimes for decades and I am positive that the model projections are poor at best.   Combined with the fact that the projections use a totally unrealistic estimate of future emissions (the RCP 8.5 scenario), I do not believe the results presented have any value. 

Discussion

NYSERDA scripted the presentation to the Energy Board so that it was completely consistent with the narrative that climate change impacts are occurring today.  I recently showed that the uncertainty of the historical temperature measurements is similar to the alleged temperature increase due to GHG emissions.  This post explains that the claimed trend in storm events is not a climatic trend because the time range is too short, and that the model projections of weather have limited value. As a result, the Energy Planning Board came away from the meeting erroneously believing that the effects of climate change are occurring now and that reducing New York GHG emissions will reduce those impacts.

This is not in the best interests of New York.  The New York energy plan is supposed to be a roadmap for a “clean, resilient, and affordable energy system for all New Yorkers.”   There are conflicting priorities and challenges for those three goals.  The State Energy Planning Board should be given all the information so that they can “focus on strategies to meet future energy needs and advance economy-wide decarbonization, while balancing reliability, affordability, environmental and public health impacts and economic growth.”  The presentation did not give any of the qualifying information about uncertainties, so it gave the Board a false basis for evaluating the Climate Act approach and schedule.

The basic strategy for decarbonizing the economy is electrification of all sectors.  Authors of the Climate Act believed that no new technology was needed for the transition of the electric sector to “zero emissions” using wind, solar, and hydro.  All the organizations responsible for electric system reliability agree that a new dispatchable, emissions-free resource is necessary for extended periods of low wind and solar resource availability so that presumption is wrong.  That means that the schedule must be adjusted to account for the necessity to develop, test, and deploy this new technology. 

 A primary driver for the Climate Act schedule was the perceived necessity to do something immediately because the effects of climate change are evident now.  As shown here, that argument is not supported when temperature trend uncertainty is considered, long-term trends of weather events are evaluated, and the weaknesses of global climate models are acknowledged.  Those results do not necessarily mean that it is inappropriate to do something, but the results do mean that the claims we must act immediately are unwarranted.  We have time to do this right.  I think that is a primary concept that should be incorporated into the Energy Plan.

Conclusion

I am disappointed that NYSERDA has become so politicized.  The NYSERDA presentation by Dr. Freedman gave the Energy Planning Board misleading information about the threat of climate change and the need to act immediately.  It is becoming increasingly evident that there are so many unanticipated issues associated with the Climate Act implementation that a pause to re-evaluate the schedule and goals is in order.  If NYSERDA documentation had not been politicized the Scoping Plan could have included caveats and achievement milestones to provide an off-ramp to a Plan B that is clearly necessary.  As it stands now, admitting delays and unavailable technologies will be a political embarrassment.  However, it is necessary to ensure that reliability, affordability, environmental and public health impacts, and economic growth goals can be achieved.

Grifters Follow the Money

A recent letter to the editor of the Syracuse Post Standard Focus on economic benefits of NY’s renewable energy projects is the subject of this post.  I am very frustrated with the New York Climate Leadership & Community Protection Act (Climate Act) net zero transition because claims made by the supporters are so misleading that it beggars my mind that editors publish the letters.  The reality is that there are so many issues coming up with the schedule and ambition of the Climate Act that it is obvious that we need to pause implementation and figure out how best to proceed.

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

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes an interim reduction target of a 40% GHG reduction by 2030. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.”  After a year-long review, the Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation. 

Letter to the Editor

The following letter was written by Marguerite Wells from Ithaca, NY. 

Keeping an open mind is one of the hardest things to do. With a constant stream of social media, information and communication, we can develop opinions and stances that are very hard to change.

When I first entered New York’s renewable energy conversation as a farmer in Central New York, my focus was on protecting air and water quality and not relying on foreign sources for our energy. While these goals are admirable, it was harder to answer the more personal questions, “How does this help me, my farm, and my family?” I wasn’t the only one asking that question.

When you hear of a solar or wind farm being proposed near you, it’s fair to ask, “How will this help me?”

While these projects will contribute to our statewide energy transition, those who most stand to benefit are the towns and landowners who host these projects.

It isn’t just about climate goals. It is about the deli down the street getting more customers during and after construction. It is about towns receiving funds to fix the roads, or build a new park. It is about our children’s public school receiving millions from tax agreements from these private companies. Projects such as Morris Ridge Solar, New York’s largest solar farm, will pay $1.6 million in direct community payments each year, according to public data. This is an example of how these types of investments bring real, tangible benefits to local communities.

As a farmer, I was also drawn to the fact that these projects help preserve agricultural land. Rather than being permanently lost to real estate development, developing wind and solar can offer a lifeline to our family farms, providing them with new revenue, and helping keep farmland in the family for future generations.

Skepticism is good. Questions are good. Preconceived notions that don’t allow you to hear the facts are not.

Whether you’re a farmer, a town official, an everyday citizen or a skeptic, I invite you to continue this conversation. Join us at the 21st Annual Symposium on Energy on April 4 at the SUNY College of Environmental Science and Forestry in Syracuse. Learn more at energy21symposium.org.

Marguerite Wells

Ithaca

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Faced with incessant media messaging that the green energy transition is necessary and will save the planet keeping an open mind is indeed difficult.  Here is one aspect of the issue not pursued by the mass media. Robert Bryce describes the IRA lobbying frenzy currently underway in Washington:

The late economist Milton Friedman famously declared that “nothing is so permanent as a temporary government program.”

Friedman’s line comes to mind because a lobbying frenzy is underway in Washington, DC. Some of the city’s most powerful special interests are working to prevent a repeal or reduction of the lavish energy-related tax credits in the Inflation Reduction Act. No lobby group is working harder than the American Clean Power Association.

Why is the ACPA pushing so hard? The answer is simple: Its members have collected tens of billions of dollars in federal subsidies, loans, and loan guarantees over the past few years to install solar energy, wind energy, batteries, and other forms of alt-energy, and they don’t want that geyser of federal money to stop.

In the face of mounting evidence that the Climate Act net-zero transition is not going according to plan and should be paused for a re-assessment, New York’s green energy special interests are also pushing hard.  This letter is an example.

When I read the letter, my impression was that the author was a farmer who was only interested in the renewable energy conversation.  Her name was somewhat familiar, but it was not until I read an announcement for the New Yorkers for Clean Power April Renewables Supporters Speaker Series agenda for “Insights on Onshore Wind” that I made the connection.  The announcement said that Marguerite Wellswas an expert in onshore wind energy development and policy and she is the Executive Director at the Alliance for Clean Energy New York (ACE NY).  ACE NY mission is “to promote the use of clean, renewable electricity technologies and energy efficiency in New York state, in order to increase energy diversity and security, boost economic development, improve public health, and reduce air pollution.” My first observation is that readers deserve to know that Wells is not just a farmer but has more than a passing personal interest in the renewable energy transition.

Her association with ACE NY biases the letter contents.  Advocates like Wells invariably repeat the talking point that green energy will protect air and water quality while decreasing reliance on foreign sources for our energy. Russ Schussler compiled a document that addresses many green energy talking points.  He explains that claiming that green energy is environmentally neutral ignores the adverse impacts of renewable energy development. New York has not updated the environmental assessment of the cumulative impacts for the projected onshore wind, offshore wind, solar, and energy storage resources projected by the State in the Scoping Plan completed at the end of 2022.  The Final Supplemental Generic Environmental Impact Statement (SGEIS) on the proposed Climate Leadership and Community Protection Act was accepted in September 2020.  Since then, the projections for renewable resources have increased.  The Scoping Plan projects 830 additional 3 MW onshore wind turbines, 439 additional 18 MW offshore wind turbines, and over 100 million 350-watt solar panels compared to the SGEIS. There also were no projections for energy storage or Dispatchable Emissions-Free Resources that the Scoping Plan has determined are necessary for a zero-emissions electric generating system.  The Scoping Plan considered life-cycle impacts of fossil fuels but ignored the adverse impacts related to their operation and disposal of wind and solar components.  Recycling is challenging to impossible for the large structural components and also the scarce resources needed for energy conversion.

Another point that this letter ignores is the magnitude of the resources necessary and the resulting sprawl across New York.  The New York State Office of Renewable Energy Siting and Electric Transmission (ORES) and the Department of Public Service (DPS) have a new interactive map of solar and wind project siting status.  Here are the total capacity and the land covered by existing renewable energy sprawl.

The Scoping Plan’s Integration Analysis (IA) included three scenarios that projected future resources necessary (Strategic Use of Low-Carbon Fuels, Accelerated Transition from Combustion, and Beyond 85% Reduction) and the New York Independent System Operator made two projections too.  The number of acres required for those resources shown below is staggering.

According to Wells the development of wind and solar resources “bring real, tangible benefits to local communities” and help preserve agricultural land.  Wells mentions that the Morris Ridge Solar will pay $1.6 million in direct community payments each year and notes that rental payments “can offer a lifeline to our family farms, providing them with new revenue”.  One of the unintended consequences of extensive solar development is that it affects the viability of farmers that must rent land for their operations.  An agronomist and environmental planner in western New York explained that the problem is that farmers are now competing with solar developers who are paid direct and indirect subsidies that enable them to offer land owners up to ten times the current agricultural annual lease rates.   This raises the concern that farmers will not have enough available farmland to support the investment they have made in facilities, livestock, or equipment.  Furthermore, claims that these projects will support the agricultural economy overall is simply wrong.  It will reduce farm jobs when farmers rent their land rather than farm so economic activity may be improved during construction but once the facility is operational there are very few economic benefits to essential local businesses.

Wells claims that wind and solar development will “help preserve agricultural land”.  She does not mention that the New York state utility-scale solar siting program does not ensure responsible solar siting that protects agricultural land.  I have documented some of the issues with solar siting.  For example, the Department of Agriculture and Markets (“Department”) has a solar project siting goal “to limit the conversion of agricultural areas within the Project Areas, to no more than 10% of soils classified by the Department’s NYS Agricultural Land Classification soil groups 1-4, generally Prime Farmland soils, which represent the State’s most productive farmland.”  Undoubtedly due to lobbying pressure, the Department has submitted comments raising the issue when solar projects apply for permits but no application has been modified when the limit is exceeded.  The Morris Ridge Solar project is the biggest project in the state, and they did not convert any prime farmland so it can be done.  The Prime Farmland Scorecard at my solar issues page lists 35 solar projects and only 12 meet the Department goal and the average over all projects is 18%.  The total prime farmland converted to solar factories is 10,952 acres.

In her closing arguments she says that skepticism and questions are good, but “preconceived notions that don’t allow you to hear the facts are not.”  This leads up to an invitation to “continue this conversation at the 21st Annual Symposium on Energy in the 21st Century on April 4 at the SUNY College of Environmental Science and Forestry in Syracuse. This annual gathering of the grifters of the green energy scam is an example of the many ways that green energy can pay out.  I am familiar with examples of symposiums on issues of the day that provided the organizer with enough money to forgo full-time work.  I have little doubts that this symposium is any different.

Worse these purveyors of doom and gloom who claim it can be solved with their green energy solutions are a real danger to society.  Bryce provides two relevant reasons related to the Federal programs that are also applicable to New York:

First and foremost, the ITC and PTC are, to use the title of Meredith Angwin’s excellent 2020 book, shorting the grid. The massive subsidies for weather-dependent forms of generation are distorting electricity markets and contributing to the premature closure of the thermal plants needed to assure the affordability, reliability, and resilience of our electric grid.

Second, these subsidies are fueling the landscape-wrecking, bird-and-bat killing, property-value-destroying energy sprawl that comes with the expansion of Big Solar and Big Wind. They are also fueling the insane expansion of offshore wind energy into the known habitat of the critically endangered North Atlantic Right Whale and other marine mammals.

Conclusion

The Scoping Plan and all the proposed green energy programs are crimes against physics.  The energy density of wind and solar energy is too low and the resource intermittency too variable so that no electric system relying on those resources for most of its energy can ever hope to provide reliable electricity.  If this reality is not acknowledged soon and these policies paused, then the enormous costs of this futile gesture to control the climate will bankrupt the state. 

Despite all the evidence that this can never work, the Hochul Administration continues to push the Climate Act, supporters like Wells continue to get misleading opinions published, and people flock to meetings to congratulate each other on their virtuous plans.  I believe that ultimately the reason for the continuing support is the money.  For every advocate motivated to save the planet for selfless reasons, there is someone whose primary motivation is cashing in on the scam.

Commentary on Recent Articles April 8, 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

My primary focus lately has been New York’s Climate Leadership & Community Protection Act (Climate Act).  I have been following the it since it was first proposed and most of the articles described below are related to the net-zero transition. My 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.

Interactive Renewables Map

The New York State Office of Renewable Energy Siting and Electric Transmission (ORES) and the Department of Public Service (DPS) have a new interactive map  of solar and wind project siting status.  Here are the total capacity and the land covered by renewable energy sprawl.

It gets worse.  The following table lists the expected sprawl (acres covered)  in 2040 when all the wind and solar resources are built for projections made by the New York Independent System Operator (NYISO) and the Integration Analysis (IA).

Solar Net-Metering

An interview in the Express Tribune describes hidden costs of solar energy

The current net metering system allows solar users to sell excess electricity back to the grid at rates that do not account for the full costs of electricity generation, distribution, and infrastructure maintenance. Unlike large-scale renewable energy projects that are directly integrated into the grid, individual net-metered solar users contribute less to grid upkeep, shifting the financial burden onto traditional grid customers and utilities.

The More You Add the Worse It Gets

Bjorn Lomborg explains that Adding more solar and wind to the energy supply pushes up the price of electricity for consumers and businesses.  He goes on to explain:

In Germany, electricity costs 43 cents per kWh—much more than twice the Canadian cost, and more than three-times the Chinese price. Germany has installed so much solar and wind that on sunny and windy days, renewable energy satisfies close to 70 per cent of Germany’s needs—a fact the press eagerly reports. But the press hardly mentions dark and still days, when these renewables deliver almost nothing. Twice in the past couple of months, when it was cloudy and nearly windless, solar and wind delivered less than 4 per cent of the daily power Germany needed.

Current battery technology is insufficient. Germany’s entire battery storage runs out in about 20 minutes. That leaves more than 23 hours of energy powered mostly by fossil fuels. Last month, with cloudy skies and nearly no wind, Germany faced the costliest power prices since the energy crisis caused by Russia’s invasion of Ukraine in 2022, with wholesale prices reaching a staggering $1.40 per kWh.

Lessons from California

Like many New Yorkers I worry that too many New York politicians aspire to follow California’s lead on issues.  Joel Klotkin describes the cost of California climate politics.  Tom Shepstone summarized the article.  I found this quote especially pertinent:

In embracing the catastrophism that defines climate change as an existential threat to life on the planet, Newsom has left behind the old progressive notion of focusing on materially improving people’s lives by embracing inherently uncertain computer models predicting danger.

In California, experts from what Bjorn Lomborg, a leading skeptic of climate catastrophism, calls “the climate industrial complex” provide the justification for staggeringly expensive, socially regressive mandates based on the conjured models; the state mandates GHG reductions but leaves implementation in the hands of state agencies closely aligned with the green lobby.

As far as I can see this situation is playing out in New York as well.  The whole article is worth a read.

A Mystery Solved

Michael Mann is the mainstream media’s go to person when they want to further the existential threat of climate change narrative because he is the author of the infamous hockey stick graph.  In a recent article I explained that his lawsuit aimed at critics of his work had come back to bite him. Stephen McIntyre is a retired mining engineer who got interested in the numbers associated with the hockey stick and discovered that Mann concealed adverse verification statistics that proved that his conclusions were wrong.  Watts Up With That published an article combining McIntyre’s “Substack, Russiagate and Other Analysis” that primarily addressed his analysis of the portion of the Mann trial that addressed Mann’s supposed loss of grants due to the people criticizing his work.

In 2009 Mann received grants totaling $2.5 million under the 2009 Obama “stimulus” bill – the so-called American Recovery and Reinvestment Act (ARRA).  The article explains:

The American Recovery and Reinvestment Act (ARRA) was passed on February 17, 2009, in the first month of the Obama presidency, and had a total budget of $831 billion – about the same, allowing for inflation, as the $893 billion budget of Biden’s so-called Inflation Reduction Act in 2022. Approximately $3.1 billion of ARRA funding was allocated to the National Science Foundation (NSF).

In an interesting recent Jon Stewart podcast (link at 44 minutes), Ezra Klein noted the total failure of the ARRA program to deliver anything on its signature promises: high-speed rail, “smart” grid or interoperable electronic health care records.

That certainly does not portend well for the Inflation Reduction Act.

The article then explained one mystery that has bothered me for years.  Have you noticed the ADA compliant crosswalks that do not connect to anything when new traffic signals are installed?  It turns out that ARRA (link) did succeed in building thousands of “ADA corner crosswalk things that didn’t actually connect to anything”. 

There is No Existential Threat from Climate Change

Anthony Watts has summed up my problems with claims that climate change is an existential threat in a post entitled “Is Climate Change Real? Short Answer: Yes — But It’s Complicated.”  This post reproduces the article with my annotated comments.

I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act) net-zero mandates will do more harm than good if the 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.  I also am an air pollution meteorologist with bachelor and master of science degrees in meteorology and was a Certified Consulting Meteorologist before I retired with nearly 50 years of experience. 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.  The Climate Leadership & Community Protection Act Section 1. Legislative findings and declaration, subsection 3 defines the alleged threat and goal: “Action undertaken by New York to reduce greenhouse emissions will have an impact on global greenhouse gas emissions and the rate of climate change.”  I have tried to argue against this point many times, but I think Watts has provided a concise well-documented case that the basic premise that New York can have an effect on the rate of climate change is misplaced.

Is Climate Change Real?

Anthony Watts prepared the post addressing this question because he gets asked this a lot.  His response to the question shows that New York does not need to rush to comply with the aspirational Climate Act schedule and targets set by politicians during the always rushed and hectic New York budget process.  Watts provides a simple primer that makes five key points.  Note that all the bold passages in the following quotes were highlighted by Watts.

1. The Basics: Climate Does Change

His first point cuts to the nub of the problem.  Climate change is real and is always occurring.  That makes it easy for everyone to have an impression that the climate isn’t what it used to be.

First, let’s be clear — climate change is real in the literal sense. The Earth’s climate has been changing for billions of years. We have geological records showing periods that were much warmer (like the Eocene, with crocodiles in the Arctic), and much colder (like the Ice Ages that covered North America in glaciers).

Even more recently, we have the Holocene Climate Optimum, significantly warmer than present day:

Watts explains that there is a nuance to the fact that the climate is changing.  Those nuances are being ignored as he notes:

So, yes — the climate changes, and it always has. The debate isn’t about whether it changes, but whyhow fast, and how much humans are influencing it today. The debate is also about how accurately we are able to detect temperature change, plus the overreliance on climate models to predict the future rather than actual data.

2. What the “Consensus” Says — and Where It Falls Short

Folks like me who publicly decry the claim of an existential threat must confront the consensus argument he describes. 

The mainstream position (IPCC, NOAA, NASA, etc.) holds that recent warming — roughly 1.1°C since the late 1800s — is largely due to increased CO₂ from human activity, mainly fossil fuels.

But here’s the rub: this view is heavily dependent on climate models, which are notoriously uncertain.

The fact that the extreme risks claimed are based on models is frustrating because I know the limitations of model projections and they never get mentioned in the mainstream coverage of climate change. The only thing I would add to his remarks is that he could have included many more issues.

As someone with a meteorology background, I can tell you models struggle with cloud feedbacksocean cyclessolar variability, and regional forecasts — all of which are crucial to understanding climate.

When models are run backward, they often fail to replicate past climate variability accurately — like the Medieval Warm Period or the Little Ice Age — unless they’re tuned heavily. That calls into question their reliability for long-term projections.

3. Natural Variability: The Elephant in the Room

As Watts explains, natural variability is not understood well.  I think the thing to keep in mind is that this variability is driven in large part by the patterns of the upper air steering currents like the jet stream.  The massive flooding due to Helene in western North Carolina was caused by a rare weather pattern that stalled the storm in one place.  A similar pattern occurred in 1916 so today’s level of CO2 and warming were not the cause.  Unfortunately, we don’t know what caused that pattern or if it was just normal variability.  Watts describes the variability of observed warming:

A lot of warming in the 20th century happened before CO₂ rose sharply post-WWII. For example:

  • The warming from 1910 to 1940 occurred with much lower CO₂ levels.
  • Then there was a cooling trend from the 1940s to 1970s, despite rising CO₂ emissions during that time period.

Clearly, natural factors — like solar cycles, ocean oscillations (PDO, AMO), volcanic activity, and cloud dynamics — are still in play and possibly underestimated in mainstream assessments.

Keep in mind that the consensus says that the recent warming was caused by GHG emissions, but I don’t see any big difference between that warming and the previous one that was “natural”.  We know there are natural factors in play but we don’t understand them well enough to be able to discern what the impact of the greenhouse effect is relative to them.

4. The CO₂ Connection: Overstated?

The second complicating factor is that the greenhouse effect is real and increased CO2 in the atmosphere should also increase warming.  However, as Watts explains even that fact is conditional on at least one factor rarely mentioned.

CO₂ is a greenhouse gas, no question. But its effect on temperature is logarithmic — meaning, the more CO₂ you add, the less warming you get per unit. The first 100 ppm has the biggest impact, and we’re well past that as seen in the figure below.

Moreover, satellite data from UAH and RSS shows a slower warming trend than surface datasets like HadCRUT or GISS. That discrepancy raises questions about data adjustments, urban heat island effects, and instrument biases.

I addressed a couple of warming trend issues in two recent articles about measuring temperature trends here and here.  This primer just touches the surfaces of isues.

5. Are We in a Crisis?

Ultimately the only reason we are being forced to endure the insane transition policies that defy physics, math, and economics is the existential threat.  Watts points out problems with that claim. 

Even if we accept that humans are influencing climate, the notion that we’re in an “existential crisis” is unproven. Extreme weather trends (hurricanes, tornadoes, droughts) don’t show clear worsening patterns once you account for improved detection and population growth in vulnerable areas such as coastal developments.

The Intergovernmental Panel on Climate Change (IPCC) agrees, suggesting a “low confidence” in many current and future weather events being affected by climate change. The “existential crisis” view is heavily dependent on climate model projections, which are notoriously uncertain and refuted by data.

Sea level is rising — but at a slow, linear pace of about 3 mm/year. That’s about 12 inches per century, similar to what’s been observed since before industrial CO₂ emissions.

Away from the bluster and hype in the real-world evidence is clear that even if there is a potential for massive impacts due to climate change, the pace observed is slow and not accelerating.  That means that we have time to consider and modify the politically motivated schedule of the New York Climate Act.

Bottom Line

I cannot conclude this post any better than Anthony Watts did in his bottom line.

Yes, the climate is changing. It always has. The idea that global climate must be unchanging is simply wrongheaded. The real issue is how much of today’s change is due to human activity, how reliable our predictions are, and whether proposed policy responses are justified — or likely to do more harm than good.

At Watts Up With That, we’ve been pointing out for years that this issue is riddled with confirmation bias, model overconfidence, and selective reporting. There is no justification for shutting down economies or reshaping civilization based on the incomplete science of climate change.

So yes, climate change is real, but no, it’s not a crisis.

Upstate New York Air Source Heat Pump Experience

 “Green energy” advocates continue to lobby for the NY HEAT Act that would end “New York’s gas mandate and forced ratepayer subsidies for gas expansion”.  This is part of their irrational war on natural gas which will only be successful if they prevent the use of natural gas in the future which means a switch to heat pumps for heating.   Constantine Kontogiannis  has calculated the costs of heat pumps Upstate that complements an earlier analysis by Richard Ellenbogen for Downstate.

I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act) net-zero mandates will do more harm than good if the 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.

Background

The “NY HEAT Act that would end the gas mandate that proponents claim means that “a single home that wants to stay on the gas system can prevent an entire neighborhood from having the opportunity to receive cheaper, cleaner heating alternatives from their utility.”

I recently posted an article in collaboration with Rich Ellenbogen that detailed the excessive winter operating cost of a geothermal-source heat pump (GSHP) system at his Westchester County residence, using his secondary heating source (a high-efficiency natural gas boiler) for comparison). After it was posted I was contacted by Constantine Kontogiannis who offered to describe his experience with a heat pump.  Mr. Kontogiannis is a mechanical engineer by training with over 25 years of energy related experience.   I jumped at the opportunity for him to describe his heat pump experience.  The following is his lightly edited submittal.

Another Heat Pump Experience – Constantine Kontogiannis

If your readers are wondering how relevant Rich’s experience is to a typical participant of the NYS Clean Heat Program, I have some additional information that might be of interest.  In 2023, I installed a cold climate air-source heat pump (ccASHP) system at my residence in Albany.  According to the NYS Clean Heat 2022 Annual Report, ccASHP systems are much more common than GSHP systems in residential applications, with approximately 18,730 ccASHPs installed in New York State in 2022 (not including Long Island), compared to approximately 670 GSHPs.  That’s a ratio of about 28 to 1 in favor of ccASHP systems.

The stated goal of the NYS Clean Heat Program (which commenced in 2020) is to convert 100,000 homes to heat pumps statewide, and based on the 2022 Annual Report I would estimate that the program is nearly 75% of the way towards that objective.  The data collected so far implies that the vast majority of these heat pumps will be ccASHP systems just like the one that I recently installed.

When I was researching my various heat pump options, I was concerned about their cost effectiveness in heating mode.  So I decided to retain my existing natural gas heating system, which consists of a condensing boiler and radiant underfloor piping.  In hindsight, this proved to be a wise decision, as my 2023/24 heating costs were nearly double what they had been previously.  

For the 2024/25 heating season, I decided to switch back to using my natural gas heating system instead.  Sure enough, my heating costs dropped substantially – even though this winter seemed to be much colder.  To confirm this, I found the following comparison of Heating Degree Days (HDDs) over the past two winters:

From this table, it’s pretty clear that the winter of 2024/25 was much colder than last year.  Here in Albany, our cumulative HDD for this winter was within 3% of a “Normal” heating season, which makes it an ideal time window to calculate the respective heat pump and natural gas system heating costs over a typical winter.  That’s what I decided to do, and to get started, I compiled a summary of my most recent energy and cost data:

(If you’re wondering why my electric consumption is so high from Thanksgiving to Valentines Day, it’s our exterior Christmas lights – they’re all LED, but maybe we go a bit overboard.)

From the table above, I used 988 Therms this winter at a total cost of roughly $817.  I have low temperature (110 degF) radiant underfloor piping, so my boiler is always set to operate in fully condensing mode at the rated 96% AFUE.  If I had chosen to use my heat pumps this winter, I would have needed approximately 948.5 equivalent Therms (988 x 0.96).  This translates to 27,791 kWh at a COP of 1, which is how much energy would be needed if I was using electric resistance heat (948.5 x 100,000 / 3,413).  

The appeal of heat pumps is their vastly improved COP compared to electric resistance heat.  To determine the seasonal COP of my ccASHP system in heating mode, it’s available in the manufacturer’s product data:

My heat pump system uses ducted 3-ton units – this is a common application, particularly when heat pumps are replacing an existing natural gas furnace and air conditioner combination.  Since ducted units retain the existing heating and cooling distribution ductwork, they are significantly less costly to install and more effective in heating dominant climates when compared to the alternative of using multiple split-system terminals throughout the house (in a ducted system, there’s generally at least one supply air register in each room).  

From the table above, my heat pumps have an HSPF2 rating of 10.0 (the left “Ducted” column).  This is a typical HSPF2 value for ccASHPs installed through the NYS Clean Heat Program, which requires a higher efficiency for program participation than generally stipulated by building code.  

To calculate the seasonal COP, we take the HSPF2, divide it by 0.85 and multiply it by 0.293, which is approximately 3.4 for my system.  Here’s the calculator .   

I discovered something interesting about the HSPF2 rating – it’s based on heating performance in a warmer region – Climate Zone 4, which only includes eight downstate counties in New York from Westchester to NYC through Long Island.  See the definitions at the bottom of this webpage  and the map.  

A higher resolution climate zone map with a table of the individual NY counties in each zone was used in this analysis.  From the earlier HDD table, the upstate cities in Climate Zone 5 (Albany, Syracuse, Rochester, and Buffalo) have roughly 40% more heating degree days than NYC, which is in Climate Zone 4.  So it’s likely that since I live in Climate Zone 5, the true seasonal COP of my heat pump system is lower than the value calculated from an HSPF2 rating in Climate Zone 4.  

But let’s put that aside for now – we’ll just be conservative and utilize the seasonal COP of 3.4 derived from the HSPF2 rating.  In an earlier paragraph, I calculated the equivalent energy at a COP of 1 required to heat my home this winter at 27,791 kWh.  Dividing this by the seasonal COP of 3.4 for our ccASHP system, our estimated heating energy consumption this winter would be 8,174 kWh.  

At my current winter electric rate of $0.214/kWh, this translates to a seasonal heating bill of $1,749.  That’s more than double my $817 natural gas bill this winter, 114% more to be exact.    

To offset a portion of the installation cost, the NYS Clean Heat Program provides an average rebate of $4,600 to replace a gas furnace with a ccASHP, and a $2,000 tax credit is also applicable.  But if the system costs between $8,000 and $12,000 to install, and then adds $900 to the utility bill every year, the rebate and tax credit aren’t very helpful.  Over a 15-year equipment lifespan, the detrimental cost impact could add up to $16,000 or more.  

Caiazza Comment

Proponents of NY HEAT suggest that one advantage of the legislation is to save money.  The New York State Energy Research & Development Authority (NYSERDA) produces featured stories  that “provide insights into New York’s clean energy transition and offer practical information for New Yorkers to incorporate clean energy into their homes and businesses.”  The Experience the Comfort of Clean Heat story does not explicitly address costs.  Kontogiannis and I agree that at one time NYSERDA claimed universal savings. To their credit NYSERDA’s Heat Pump Program description does explicitly state that replacing oil, propane, or electric baseboards with air source heat pumps as your primary heating source is a more efficient way to keep your home comfortable. I recently heard an advertisement by approved contractor who did not explain that savings were unlikely for a home that burns natural gas, apparently without any pushback from the program administrator.

The five-year estimate (2017-2021) of space heating totals of occupied housing units in New York shows that there are 7,530,150 housing units and 59.6% or 4,489,695 of them use utility gas for space heating.  The two analyses that compared heat pump costs and NYSERDA agree that natural gas heating is cheaper.  Kontogiannis estimates that at least 30,000 heat pumps installed through this NYSERDA program have replaced natural gas.  He notes that according to the 2022 summary report, “very few of the installations include the decommissioning of the previous heating system”.  As a result we are skeptical of any carbon savings claims. The bottom line is that the Climate Act will make home heat more costly for more than half of the state but I have not seen any advocate admitting that fact.

My thanks to Rich Ellenbogen and onstantine Kontogiannis for their insights.

Temperature Trend Measurement Uncertainty

Late last year I published an article that described the difficulties involved with a fundamental aspect of the climate change debate – measuring global temperature trends.   This article describes an analysis of a data set that compares two different ways to calculate the daily temperatures used to determine global temperature trends.  Ray Sanders reproduced Stephen Connolly’s description an analysis that shows how temperature measurement techniques affect trend interpretation. 

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.

Background

My fifty-odd year career as an air pollution meteorologist in the electric utility sector has always focused on meteorological and pollution measurements.  Common measurement challenges are properly characterizing the parameter in question, measuring it in such a way that the location of the sensor does not affect the results, and, when operating a monitoring system, verifying the data and checking for trends.  On the face of it, that is easy.  In reality, it is much more difficult than commonly supposed.

I prepared the previous article to highlight recognized instrumental and observational biases in the temperature measurements.  One problem is measurement methodology.  The longest running instrumental temperature record is the Central England Temperature (CET) series that extends back to 1659.  In the United States temperature data are available back to the mid 1800’s. In both cases the equipment and observing methodology changed and that can affect the trend.  Too frequently, when observing methods change there is no period of coincident measurements that would enable an analysis of potential effects on the trends.

Only recently have computerized data acquisition systems been employed that do not rely on manual observations, and even now many locations still rely on an observer.  For locations where temperature records are still manually collected, observers note the maximum and minimum temperature recorded on an instrument that measures both values daily.  A bias can be introduced if the time of observation changes.  If observations are taken and the max-min thermometers are reset near the time of daily highs or lows, then an extreme event can affect two days and the resulting long-term averages.  Connolly’s work addresses another bias of this methodology.

Uncertainty Caused by Averaging Methodology

The issue that Stephen Connolly addressed in his work was the bias introduced when a station converts from manual measurements of maximum and minimum temperatures to a system with a data acquisition system. Typically, those data acquisiton systems make observations every second, compute and save minute averages, and then calculate and report hourly and daily averages. 

Ray Sanders explained that he came across Stephen Connolly’s analysis of temperature averages based on data from the Valentia weather station on the south west of the Republic of Ireland. He asked Stephen if he could refer to his work, to which he agreed on the condition he duly credited him. So by way of a second-hand proxy “guest post” I have reproduced Stephen’s unadulterated X post at the end of this article.  I offer my observations on key parts of his work in the following.

I highly recommend Connolly’s article because he does a very good job explaining how sampling affects averages.  He describes the history of temperature measurements in a more comprehensive way than I did in my earlier post.  He explains that the daily average temperature reported from a manual observation station calculated as the average of the maximum and minimum temperature (Taxn) is not the same as an average of equally spaced observations over a 24-hour period (Tavg).  Using a couple of examples, he illustrates the uncertainties introduced because of the sampling differences. 

Connolly goes on to explain that:

In 1944 Met Éireann did something a bit unusual, they started measuring the temperature every hour. Rain or shine, sleet or snow, the diligent staff of Met Éireann would go out to the weather station and record the temperature. Between January 1944 and April 2012 when the station was replaced with an automated station only 2 hours were missed.

The data enabled Connolly to compare the two techniques to calculate the daily average temperature.  In his first graph he plots the difference between the two techniques as blue points. Overlaid is the 1 year rolling average as a red line. He states that Tavg is greater than Taxn in Valentia on average by 0.17oC (std deviation 0.53, N=29339, min=-2.20, max=3.20).

Connolly plots the difference between the two averaging approach and notes that:

If we just look at the rolling average, you can see that the relationship is not constant, for example in the 1970’s the average temperature was on average 0.35ºC warmer than the Meteorological estimate, while in the late 1940’s, 1990’s and 2000’s there were occasions where the Meteorological estimate was slightly higher than the actual average daily temperature.

He goes on:

It’s important to highlight that this multi-year variability is both unexpected and intriguing, particularly for those examining temperature anomalies. However, putting aside the multi-year variability, by squeezing nearly 30,000 data points onto the x-axis we may have hidden a potential explanation why the blue points typically show a spread of about ±1ºC… Is the ±1°C spread seasonal variability?

The shortest day of the year in Valentia is December 21st when the day lasts for approximately 7h55m. The longest day of the year is June 21st when the day lasts for 16h57m. On the shortest day of the year there is little time for the sun to heat up and most of the time it is dark and we expect heat to be lost. So we expect the average temperature to be closer to the minimum temperature during the winter than during the summer.

I found this line of reasoning interesting:

We can check the seasonal effects in the difference between Tavg and Taxn by looking at a time dependent correlation. As not everyone will be familiar with this kind of analysis, I will start by showing you the time dependent correlation of Tavg with itself in the following graph.

The x-axis is how many days there are between measurements and the y-axis is the Pearson correlation coefficient, known as r, which measures how similar measurements are averages across all the data. A Pearson correlation coefficient of +1 means that the changes in one are exactly matched by changes in the other, a coefficient of -1 means that the changes are exactly opposite and a correlation coefficient of 0 means that the two variables have no relationship to each other.  The first point on the x-axis is for 1 day separation between the average temperature measurements.

When I was in graduate school, a half century ago weather forecasting performance was judged relative to two no-skill approaches we called persistence and climatology.  Connolly explains that persistence is assuming that “Tomorrow’s weather will be basically the same as today’s”.  This graph shows that the approach is approximately 82% accurate.

The graph also illustrates the accuracy of the second no-skill forecast – climatology.  In other words the climatology forecast for the average temperature is simply the average for the date.  At a year separation the r value of 0.67 days that 44% of today’s average temperature can be explained as seasonal for this time of year. What this means is that actually the persistence forecast is only explaining 38% better than the climatological forecast

Connolly notes that the maximum and minimum temperatures behave the same and concludes that the above graph basically tells us what to expect when something is strongly seasonal.

Connolly goes on to ask what happens when we plot the time-dependent correlation of Tavg-Taxn? He shows the results in the following graph.

The 1 day correlation is 0.19, this tells us that approximately 4% of today’s correction factor between Tavg and Taxn can be predicted if we know yesterday’s correction factor. The seasonality is even worse, the 6 month correlation coefficient is -0.02 and the 1 year correlation coefficient is +0.07.

He points out that this answers the question whether this is seasonal variability and concludes that the ±1°C spread is not seasonal variability.  The important point of this work is that this means that if we only know daily average temperature based on the average of the maximum and the minimum temperature then comparison to the average measured using a data acquisition system the two methodologies could be anywhere between ±1°C different

He provides another graph to illustrate this.

The x-axis is Tavg and the y-axis is Taxn. Now obviously when the average daily temperature is higher, the average of the minimum and maximum temperatures is also higher and so we get a straight line of slope 1, but the thickness of the line represents the uncertainty of the relationship, so if we know Taxn is say 15°C then from this graph we can say that Tavg is probably between 13.5°C and 16.5°C.

Here is the important point:

Now because most weather stations were not recording hourly until recently, most of our historical temperature data is the Taxn form and not the Tavg. That means that if Valentia is representative then the past temperature records are only good to ±1°C. If somebody tells you that the average temperature in Valentia on the 31st of May 1872 was 11.7°C, the reality is that we just do not know. It’s 95% likely to have been somewhere between 10.6ºC and 12.7ºC.

He ends his analysis with another graph

In this last graph the blue points show the average Taxn of each year at Valentia since 1873 with vertical error bars showing the 95% confidence interval. The red points show the average Tavg for each year starting from 1944 with error bars showing the annual variation. The blue poking out from under the red shows the difference, even on the scale of a yearly average between the Meteorologist’s estimate of average temperature and the actual average temperature.

Discussion

Connolly explains:

Valentia Observatory is one of the best weather stations globally. the switch to automated stations in the 1990s, we can now get precise average temperatures.  Thanks to the meticulous efforts of past and present staff of Valentia Observatory and Met Éireann, we have 80 years of data which allows comparison of the old estimation methods with actual averages.

The takeaway from Connolly’s evaluation of these data is that out “historical temperature records are far less accurate than we once believed.”

I second Sanders acknowledgements of the work done by Connolly:

I would like to thank Stephen for allowing me to refer to his excellent research. Whatever one’s views are on the validity of the historic temperature record of the UK, this evaluation has again highlighted one area of many where there are significant questions to be asked regarding long term accuracy.

Conclusion

I would like to thank Stephen for allowing the posting of this excellent research.  One fundamental truth I have divined in my long career is that observed data are always more trustworthy than any model projection.  However, there are always limitations to the observed data that become important when trying to estimate a trend. 

I think these results are important because they highlight an uncertainty that climate catastrophists ignore.  I will concede that average temperatures are likely warming but the uncertainty around how much is within the observational uncertainty.  In other words, the claims the magnitude of the observed warming is not known well.  The science is not settled on the amount of warming observed.

Commentary on Recent Articles  March 29, 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

My primary focus lately has been New York’s Climate Leadership & Community Protection Act (Climate Act).  I have been following the it since it was first proposed and most of the articles described below are related to the net-zero transition. My 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.

As a pragmatic environmentalist I cannot over-emphasize the necessity of tradeoffs between environmental impacts and other societal benefits.  New York’s energy policies offer two examples that ignore tradeoffs in an poorly considered appeal to ill-informed but politically powerful constituents.  The first example is the premature shutdown of two nuclear power plants – the completed but never run Shoreham plant on Long Island and Indian Point, and the second is the political decision to ban fracking in New York.  In my opinion, the best energy plan approach would be to embrace both natural gas and nuclear power.

What Might Be

David Catalfamo notes that ten years ago  “New York’s leaders turned their backs on upstate communities, banning fracking in a purely political move that had nothing to do with science”.  He points out that the decision at the time was because of uncertainties.  Since then, it has been demonstrated that the water contamination and air quality risks are manageable, the technology has evolved to further mitigate concerns, and that New York’s ban on fracking resulted in a massive lost economic opportunity.  He notes that:

While Pennsylvania added 100,000+ jobs and billions in tax revenue, upstate New York withered. The wealth didn’t disappear—it just went next door.

New York State is in desperate need for revenue to rebuild roads, fund transit, and support public services.    He concludes that New York can provide funding and join the rest of the country or stay stuck in the mistakes of 2014.

Combine Natural Gas and Nuclear

Jim Willis of Marcellus Drilling News argues that the urgent need for electric energy brought on by data centers and energy-intense manufacturing proposals could be addressed by combining natural gas and nuclear in new ways.  He references a new article that suggests that using small modular reactors and a different kind of gas fired power plant (reciprocating natural gas generator) offer advantages that make them a good choice for this application.

Green Energy Makes You Poorer

Sadly New York is going down a different path that will not end well.  Ron Klutz describes a post by Matt Ridley that explains How the Green Energy Transition Makes You Poorer.  Ridley cites a United Kingdom analysis that the net-zero transition there will reduce the GDP by 10% by 2030 if it succeeds.  Giving up all the fossil fuel infrastructure strands so many assets that will be an expensive economic disaster. 

The problem is simple:

If the new technologies are more efficient than the old ones, fine. LED light bulbs use about 90% less electricity than incandescent bulbs did. So yes, it does make sense to throw out your old bulbs before they expire, stranding those assets, to save electricity and money. Is the same true of a wind farm or a heat pump? No, they are demonstrably more expensive and less reliable at producing the same electricity as the devices they are replacing. They are worse, not better.

Ridley concludes:

Electricity is not an end in itself; it is a means to an end, an essential input allowing us to do the one and only thing that does, really does, represent growth—achieving more output with less input.  Right now, the Net Zero transition is doing the very opposite

Battery Backlash

Robert Bryce has put together a Global Battery Rejection Database that “shows 52 communities from California to Australia have rejected battery projects. The fire at Vistra’s Moss Landing site will ignite even more opposition.”

Wind Farm Decision

The lawyer who successfully battled a massive Nebraska wind farm development describes the legal approach used.  A news story explains:

A federal judge has dismissed most of a lawsuit filed by North Fork Wind against Knox County, Nebraska, after the county changed its zoning regulations, effectively halting development of a proposed 600-megawatt wind farm. U.S. District Court Judge John Gerrard ruled that North Fork Wind had not proven that Knox County’s new setback requirements and other regulations had interfered with its contracts or violated its constitutional rights to due process and equal protection. However, the judge did allow the company to proceed with a Fifth Amendment claim, arguing that the county’s actions amounted to an unlawful taking of property.

New York Climate Superfund

Ed Reid explains why the Climate Change Superfund bill is lawfare.  He notes that “An appropriate topic for any discussion of lawfare, whether lawsuits alleging violation of existing laws or legislation leading to new law, is the issue of standards of evidence.“  Then he points out that alleged extreme weather of concern claims are inconsistent with the IPCC Sixth Assessment Report (AR6, Chapter 12) that “indicates no linkage between global warming and climate change and the frequency and intensity of extreme weather events with the exception of heatwaves, which are affected by increasing average temperatures.”  Not surprisingly, the law is the subject of a lawsuit filed by 22 states based on constitutional grounds.

Vermont Cap and Invest Impacts

Robert Roper describes the Treasurer’s Report on their version of a cap and invest program.  The estimated costs are shown below.  Note that the Report concludes that the only way to get to the targets is the high price scenario.

It gets worse.  The high price scenario includes the mandate for “full reinvestment”.  Roper explains:

What does “full reinvestment” mean? It means that all the money collected from this fuel tax must be spent on greenhouse gas reduction measures. No money collected can be redistributed to lower income Vermonters as a safety net to mitigate the cost impacts of the program. In other words, the GWSA screws poor, rural Vermonters. Hard. Especially and royally.

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