Author: rogercaiazza

I am a meteorologist (BS and MS degrees), was certified as a consulting meteorologist and have worked in the air quality industry for over 40 years. I author two blogs. Environmental staff in any industry have to be pragmatic balancing risks and benefits and (https://pragmaticenvironmentalistofnewyork.blog/) reflects that outlook. The second blog addresses the New York State Reforming the Energy Vision initiative (https://reformingtheenergyvisioninconvenienttruths.wordpress.com). Any of my comments on the web or posts on my blogs are my opinion only. In no way do they reflect the position of any of my past employers or any company I was associated with.

Commentary on Recent Articles February 9, 2025

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

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

Videos

  • Mike Rowe’s podcast interviews Alex Epstein to talk about the greatest climate myths and misconceptions.
  • John Robson from Climate Discussion Nexus describes the origin of the LA fires.
  • Matthew Wielicki notes that alarmists blame every weather event on climate change and explains why this is erroneous in a Prager University video.

Ill Wind

Robert Bryce notes that wind energy projects are taking a hammering.  He notes that:

A few days ago, Jason Grumet, the head of the American Clean Power Association (annual revenue: $62.3 million), told Heatmap News that “probably more than half” of all new wind projects under development in the US could be killed due to President Trump’s executive order requiring a “comprehensive assessment” of federal permitting. Heatmap explained that Trump’s policies pose “a potential existential threat to the industry’s future. Just don’t expect everyone to say it out loud.

This has big ramifications for New York State’s net-zero transition efforts.  The NY plan calls for zero emissions from the electric sector by 2040.  State 2040 capacity (MW) projections call for 12% onshore wind, 12% offshore wind and 36% solar.  State energy generation (GWh) projections call for 17% onshore wind, 22% offshore wind, and 30% solar.  Solar in New York in the winter is a horrible resource due to latitude and the fact that a large portion of the state is affected by lake-effect clouds and snow that reduce solar irradiance.  Solar cannot be expanded to cover the lack of wind development so now what?

Bryce also published an article noting that:

The bad news for offshore wind keeps coming. On Monday, New Jersey canceled plans for another offshore wind solicitation, citing Shell’s decision to abandon the Atlantic Shores wind project “as well as uncertainty driven by federal actions and permitting.” Recall that New Jersey has some of the most ambitious offshore wind plans of any state on the Eastern Seaboard. And now, all those plans appear headed for Davy Jones’ Locker. But it’s not just New Jersey. This week, Danish wind giant Ørsted said it was slashing its planned investments through 2030 by 25% due to its beleaguered US offshore projects and said it would take a “stricter, more value-focused approach to capital allocation.” The same day Ørsted made its announcement, Equinor, Norway’s state-owned oil company, said it was slashing its renewable energy targets and increasing its focus on… wait for it…oil and gas production.

Vermont Insanity

Mark Whitworth describes Vermont’s Global Warming Solutions Act (GWSA). Incredibly it includes an extraordinary requirement that not even New York has incorporated.  Whitworth explains the essence of the GWSA;\: “I’m gonna flap my arms and fly over the Statehouse dome. And if I should fail, I will punch myself in the face.”  He goes on:

The “flap my arms and fly” portion of the GWSA is a set of unachievable carbon emissions reduction targets. The “punch myself in the face” part is the GWSA’s invitation to sue Vermont at taxpayer expense when the unachievable targets are not met. We will then face the prospect of a judge ordering the Secretary of Vermont’s Agency of Natural Resources to make rules that accomplish the impossible. It won’t be pretty.

Just like in New York proponents of the law established aspirational targets that cannot be met.  New York does not have an explicit mandate for a lawsuit funded by the state if the targets are not met.  However, on November 2, 2021, New York voters approved an Amendment to the State Constitution’s Bill of Rights providing that: “Each person shall have the right to clean air and water, and to a healthful environment.”  In those sixteen words, “the right to a healthy environment was, for the first time, cloaked in constitutional protection in New York and deemed the equivalent to the sixteen current constitutional guarantees in the state Bill of Rights.”  There is no doubt in my mind that someone will sue when New York’s targets are not met citing this amendment.

Oil Merits

Meredith Angwin describes the importance of oil generation in New England.  Everything she says is relevant to New York too.  Her article is notable also because it nicely describes how generating plants are dispatched.  She explains why even though natural gas is cheaper than oil, there are times when oil must be burned because natural gas is simply not available.  Green energy proponents look at this situation and argue that it proves the desirability of wind, solar, and energy storage but always ignore a key point.  They claim that these weather-dependent resources increase resiliency, but the resources invariably fail to show up when needed the most so that won’t work.  Angwin concludes “we need to think about being overly dependent upon any one fuel”. 

Natural Variability

Jamie Jessop explains that two natural climate drivers were the primary drivers of the recent global temperature peak.  The world warmed because of the Hunga Tonga undersea volcano that injected water vapor in the upper atmosphere, then some more because of a strong El Nino. She notes that “The effect of both natural events is now fading rapidly.”  Now we are at an inflection point.  If the climate models are correct such that the alarmists screeching about an existential threat has some basis, then temperatures will cool to a plateau maintaining or even accelerating the long-term warming trend. 

On the other hand, if “nature is in control of our climate”, then two climate cycles will cause global temperatures to fall.  According to Perplexity AI: “The Atlantic Multidecadal Oscillation (AMO) and Pacific Decadal Oscillation (PDO) are two important climate cycles that significantly influence global weather patterns and temperatures.”  Jessup concludes:

If you’re not a natural climate change denier and you consider that a positive AMO plus PDO has contributed significantly to global warming since 1950, then you might expect the globe to cool significantly in the coming decades. In that case, the end of the Era of Global Boiling might turn out to be the far more significant end of the era of global warming – which will mean that the climate crisis loons will be trying to convince us all that warming really means cooling (because AMOC shutdown or something).

CO2 Cannot Explain Current Warming

Matthew Wielicki explains that because during the last interglacial period global temperatures were significantly warmer than today but CO₂ levels were much lower CO₂ levels cannot be the primary driver of global warming.

This glaring inconsistency should give pause to anyone who accepts the idea that CO₂ is the sole or even primary climate control knob. If CO₂ is truly the driving force behind global temperature, why was it hotter 120,000 years ago when CO₂ was only 275-280 ppm? Why have climate models consistently failed to accurately recreate past climate conditions? If climate models cannot reliably reproduce known historical warm periods like the Eemian, how can we trust their projections for the future? These discrepancies highlight fundamental flaws in the assumptions underpinning climate modeling, raising serious doubts about their ability to predict long-term climate trends with precision.

In his article he explains that natural factors such as orbital shifts, solar insolation, ocean circulation, and long-term feedback mechanisms have played a much greater role in shaping past climate changes than CO₂. This is completely consistent with Jamie Jessup’s article mentioned above and I think his explanation is readable.  Wielicki concludes “Ignoring these factors in today’s climate debate is not just bad science; it’s deliberate deception.”

How the Green Energy Narrative Confuses the Climate Act

Russ Schussler, aka Planning Engineer, has published a prequel to an upcoming article discussing the narrative around the green energy transition that is a prominent component of the Climate Leadership & Community Protection Act (Climate Act).

I am convinced that implementation of the Climate Act net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 500 articles about New York’s net-zero transition.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Scoping Plan was finalized at the end of 2022.  Schussler’s article is relevant because the Scoping Plan proposes to meet the zero-emissions mandate using wind, solar, and energy storage.

Green Energy Narrative

Schussler describes the narrative of the wind and solar proponents aka green energy:

The green energy narrative works somewhat like a magician’s patter, overemphasizing many things of irrelevance and distracting the audience from the important things going on. Misdirection ensures small truths are misinterpreted and magnified, leading to completely unrealistic hopes and expectations.

For example, there have been many simple studies examining how much energy might be produced by a green resource, or set of green resources, such as wind and solar power. These studies ignore important issues such as deliverability, timing, reliability and costs. Based on simple studies the media, activists and policy makers frequently conclude that such resources can be used near universally on a large scale to provide electric service to consumers effectively, efficiently and economically.

This is precisely what happened in New York when the Climate Act authors developed the targets and mandates of the law.  These ideologues misinformed the Legislature and Governor Hochul with claims that “our State could rapidly move away from fossil fuels and instead be fueled completely by the power of the wind, the sun, and hydro” and “that it could be done completely with technologies available at that time (a decade ago), that it could be cost effective, that it would be hugely beneficial for public health and energy security, and that it would stimulate a large increase in well-paying jobs.”

Schussler explains the problem with this argument:

In the green energy narrative costs have been demonstrated, environmental impacts have been demonstrated, reliability has been demonstrated, deliverability has been demonstrated and all shown to possibly work, BUT NOT AT THE SAME TIME. In the eyes of many, such demonstrations cumulatively strengthen the green energy narrative. However, the gullible audience will be shocked when wind, solar and batteries are not at all well suited to support electric generation on their own.

Schussler highlights three tricks of the green energy narrative: misleading language, false problem and narrative control.

Misleading Language

Schussler addresses the term “renewable” calling it “one of the most misleading bits of language advancing the green agenda.”  He notes:

Different “renewable” resources have vastly differing capabilities. There is vast potential to develop some ‘renewables”. Some “renewables do a great job supporting the grid. Some “renewables” have low energy costs in some areas. Some “renewables” are environmentally sound in some areas. No matter how well individual “renewable” resources might be combined to tick off all the boxes of importance, that doesn’t mean that any combination of “renewable” resources can be found that will work well for any given area. It means little that hydro and geothermal provide excellent support for the grid in an area where you can only add wind and solar. Similarly, just because solar and wind have potential environmental benefits that doesn’t cancel out environmental concerns around hydro in delicate ecosystems.

The problem is that in most areas including New York, “there are no compatible combinations of renewables that at any significantly high penetration level that can provide  affordable, environmentally responsible energy in a reliable manner. Referring broadly to what “renewables” can and might do, serves to hide this inconvenient truth.”

The False Problem – Intermittency is not THE problem for Wind and Solar

Schussler argues that:

It is a fallacy to assume that because part or some of the difficulties associated with a technology can be overcome, that therefore all of the problems associated with a technology can be overcome. Worst case for a “partial solutions fallacy” is when a major problem is hidden by presenting a minor problem as the major stumbling block. Primarily focusing on the minor problem incorrectly implies that there will be smooth sailing once this solvable problem is overcome by hiding the large problem.

To implement a green transition bolstered by heavy wind and solar, all associated problems must be addressed. The major problem associated with wide-scale use of these resources  cannot be ignored.

Schussler goes on to argue:

The real problem is that wind, solar and batteries do not readily provide essential reliability services and support the grid. Most of the talk is around addressing intermittency through batteries and other storage approaches. Misdirection here focuses on intermittency, the smaller problem, while ignoring the major problem.

Schussler believes that it may be possible to address intermittency:

The long-term problems associated with wind and solar due to their intermittency could and may likely be made manageable with improved technology and decreasing costs. But such changes will not make wind, solar and batteries comparable to more conventional generating resources, such that they can play a large role in a green energy transition, because the large problem is not intermittency.

The point of his discussion is that there is another, more serious problem that is a fatal flaw:

Overcoming intermittency though complex and expensive resource additions at best gets us around a molehill which will leave a huge mountain ahead. Where will grid support come from?  Wind, solar and batteries provide energy through an electronic inverter. In practice, they lean on and are supported by conventional rotating machines. Essential Reliability Services include the ability to ramp up and down, frequency support, inertia and voltage support. For more details on the real problem see this posting. “Wind and Solar Can’t Support the Grid” describes the situation and contains links to other past postings provide greater detail on the problems.

I think that in an electric system that is reliant on weather dependent wind and solar resource, intermittency creates an unacceptable reliability risk.  Current resource assessments are based on observations of the existing uncorrelated generating resources over many years that show that unplanned outages do not happen at the same time.  There is no reason to expect, for example, that all the nuclear plants will be forced offline at the same time.  This characteristic enables the resource planners to determine how much generating capacity is necessary to meet the probability of losing load not more than once in ten years loss of load expectation (LOLE) reliability criterion.  Importantly, I believe that the lack of correlation also means that the capacity needed above firm system load would not change substantially if the LOLE planning horizon was shifted to 1 day in 20 years or more.

The problem with weather intermittency is that it is correlated over large areas at the same time. As a result, variations in weather affecting wind and solar resource availability will require changes to electric resource planning.  Everyone has heard of a hundred-year flood which is the parameter used for watershed planning.  This is the one in a hundred probability that the water level in a river or lake will exceed a certain level in a given year.  Similar estimates of low wind and solar resource availability must be developed and incorporated into electric resource planning. Based on New York data I think a hundred-year planning horizon is appropriate.  The problem is that the costs for such a threshold are huge and the resources will be used less than their expected operating lifetimes.  The resulting reliability risk is that affordable backup resources will be insufficient to support the load during the hundred-year low wind and solar availability event and a catastrophic blackout will result.

Russ and I discussed my interpretation of this reliability risk, and we agreed that we are making the same point in different ways.  If money is not an issue, then it is possible that the intermittency issue can be overcome by overbuilding wind and solar resources, short-term energy storage, long-term energy storage to deal with extended low wind and solar resource periods, and transmission.  However, affordability is a fatal flaw because the costs necessary would be astronomical for a resource that would only be used less than the expected lifetime of the resources.  On the other hand, the grid support requirements cannot be resolved by throwing any amont of money at the problem so that is unsolvable.

Narrative Control – Shameless Hucksterism and the Media

The last green energy narrative trick is controlling the narrative.  Schussler explains:

The green energy narrative is propelled by stories of success. Often these “successes” are very different from what seemed to be represented. We see great stories of planned projects that should do wonderful things, but they go down the memory hole as they prove not to work out. We see incomplete stories where they talk of power generated but not of associated costs or how much better other alternatives might have been.

He goes on to describe an example headline that claims that seven countries get 99.7% of their electricity from geothermal, hydro, solar, and wind power. However, he points out:

Without the spin, collectively those countries get close to 99% of their energy from rotating synchronous geothermal and hydro resources and less that 2% of their combined electric energy from wind and solar. The fact that some countries have high amounts of hydro, does not provide evidence that we are approaching a tipping point involving wind and solar. In fact, one could observe that high levels of renewable penetration are associated with low levels of wind and solar.

Conclusion

Schussler and I agree that it is becoming increasingly apparent that wind, solar and batteries when pursued at high penetration levels result in high costs, lower reliability and poorer operational outcomes. He points out that “Expectations from the green energy narrative and real-world results are not consistent and this gulf will continue to widen as long as policy makers continue to reflexively buy into the green energy narrative.”

The high expectations in the green energy narrative shaped the promulgation of the Climate Act and is driving its implementation.  Schussler describes the inherent misinformation and other various deceptions to hide the real-world challenges for New York’s net-zero transition. As reality sets in, proponents must push this narrative harder and louder to hide the obvious flaws.  I look forward to Schussler’s follow up article that “will more systemically examine the components of the green energy narrative and raise many items of critical importance considerations that the green energy narrative ignores.”

Ellenbogen and Caiazza Comments on DPS Definitions for Renewable Energy Program

On November 4, 2024, the Department of Public Service (DPS) staff proposed definitions for two key components of the 2040 zero emissions Climate Leadership & Community Protection Act (Climate Act)  target.   Recently I described the electric industry response comments that suggest that there will be consequences if there is no plan and recommend a re-assessment of the schedule.  This post describes comments that Richard Ellenbogen and I filed that recommends the implementation process be paused until certain issues are resolved.

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 only reflect my position and not necessarily those of Richard Ellenbogen.

Richard Ellenbogen has been speaking to NY State policy makers and regulators since 2019 regarding the deficiencies inherent in NY State Energy policy.  He has a proven record implementing carbon reduction programs at his own manufacturing business in Westchester County where has reduced its electric utility load by 80% while reducing its carbon footprint by 30% – 40% below that of the downstate system.  I have previously published other articles by Ellenbogen including a summary description of his issues with the Climate Act. 

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation. 

I believe that the biggest shortcoming of the Hochul Administration’s implementation of the Climate Act is the lack of a plan.  For example, to implement a transition to meet the mandate that all electricity must be generated by “zero-emissions” resources by 2040 it is first necessary to define “zero emissions”.  Amazingly, draft definitions were not proposed for over four years.  On November 4, 2024, the DPS staff proposal concerning definitions for key terms (Staff Proposal) in Public Service Law §66-p that finally defined “zero emissions”.  The Introduction of the Staff Proposal explains:

In this proposal, the Department of Public Service Staff (Staff) suggests interpretations of key terms in the provisions of the Climate Leadership and Community Protection Act (Climate Act), codified in Section 66-p of the Public Service Law (PSL), which directs the Public Service Commission (Commission) to establish a renewable energy program and design it to achieve particular targets. At issue in this proposal is the language of PSL §66-p(2)(b), which directs the Commission to establish a program pursuant to which, by the year 2040, the “statewide electrical demand system will be zero emissions.” Of particular note, neither of the terms “statewide electrical demand system” nor “zero emissions” are expressly defined in the Climate Act or in the PSL. This lack of statutory definition requires the Commission’s interpretation of these terms to ensure proper regulatory implementation.

This post describes the comments that Ellenbogen and I filed for this proceeding.

Electric Industry Filings

We endorsed the filings made by the New York Independent System Operator and the Joint Utilities in response to the proposed definitions of “statewide electrical demand system” and “zero emissions” that I summarized earlier. We agreed that it is necessary to draft implementing regulations that rely on consistent and clear definitions to satisfy the zero emissions by the 2040 standard and to maintain electric system reliability.  It is also essential that imported energy is treated consistently and transparently. Moreover, to maintain system reliability in a zero emissions electric system that meets the aspirational Climate Act schedule, new technologies and expanded existing technologies must be deployed on an unprecedented scale.

The theme of our comments is that the implementation process should be paused until certain issues are resolved to prevent a waste of effort on false solutions.  One example reason is that a plan must be in place first and that is consistent with  this Joint Utility recommendation:

Given the potential for New York’s clean energy resources to fall short of demand, or suffer from delayed entry for various reasons, and the challenges associated with the commercial availability and maturity of new energy technologies, the Commission should require Staff to develop a plan for the development of incremental renewables, the retirement of non-compliant resources, and methodologies to address gaps between existing resources and the reliability needs of the system, while also ensuring that reliability and resource adequacy do not suffer.  Staff should also consider the development status and lead time of new and existing technologies from research and development to their commercial deployment. It is imperative to address these issues, set expectations and identify needs for the journey towards the 2040 zero emissions target.

Criteria for Pausing

The overarching reason to pause the process is that the safety valve provisions for affordability and reliability that are directly related to the zero emissions resource in New York Public Service Law  § 66-p (4). “Establishment of a renewable energy program” are not defined.  The implementation process should be paused for anything beyond Behind the Meter (BTM) generation sources and load reductions until criteria are defined and a tracking process established for “safe and adequate electric service” and “significant increase in arrears or service disconnections”.  Without established criteria it is impossible to fulfill this legal mandate.

Dispatchable Emissions-Free Resources (DEFR)

Responsible New York agencies all agree that new DEFR technologies are needed to make a solar and wind-reliant electric energy system work reliably.  No one knows what those technologies are.  We believe the only likely viable 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.

This situation is a fundamental reason why a pause is necessary.  If the only viable DEFR solution is nuclear, then the wind, solar, and energy storage approach cannot be implemented without nuclear power.  Using nuclear solely as a backup is inappropriate because it works best as a baseload resource.  Developing baseload nuclear eliminates the need for a huge DEFR backup resource and massive buildout of wind turbines and solar panels sprawling over the state’s lands and water.  Although nuclear power is expensive when compared to the resources needed for a wind, solar, energy storage, and DEFR system that all have shorter expected operational life spans it is likely that it would be cheaper.

NYSERDA and DPS have mentioned a related five-year plan presumably to determine what technology should be used going forward.   It is obviously prudent to pause renewable development until some DEFR technology is proven feasible.   The choice and even the viability of any DEFR technology will affect the entire design of the future electric structure necessary to meet the Climate Act net-zero energy system. 

Lithium-Ion Storage Safety Concerns

The Climate Act “Resilient and Distributed Grid goal is 1,500MW of energy storage, expanding to 3,000 MW by 2030”.  The Peak Coalition has recommended that battery storage replace peaking power plants and have endorsed the Rise Light & Power Renewable Ravenswood initiative that proposes to transition Ravenswood Generating Station into a clean energy hub. The plan involves the replacement of Ravenwood’s remaining peaking capacity with “a mix of offshore wind, upstate renewables, district heating, and large-scale battery storage”. 

However, there are substantive safety concerns.  These Battery Energy Storage Systems (BESS) must overcome space constraint issues and are not proven technology.  When a leading expert on batteries says: “Everybody has to be educated how to use these batteries safely”, we think the best course of action is to follow his advice.  It is not appropriate to make the residents of the disadvantaged communities near a BESS become unwilling lab rats to test whether a technology that can generate toxic gases, cause fires, and create explosions is appropriate in an urban setting. 

A recent incident reinforces this energy storage safety issue and is another reason to pause implementation. Our comments argued that it is appropriate to consider what would happen if there was a fire at Ravenswood like the fire at the Moss Landing energy storage facility in California.  Our comments were based on the analysis described in my Implications of the Moss Landing Battery Plant Fire article.  At Moss Landing, there were 7,676 acres under evacuation with only 1,214 people living there. Richard Ellenbogen described the impacts of a fire at Ravenswood if it required a similar evacuation zone.  A similar fire would require at least a shelter in place order and possibly an evacuation order for nearly a million people to say nothing about shutting down highways within the entire area circled by Routes 278 and 495 as well as the East River.   Our comments posed questions about the ramifications within this area and the Roosevelt Island community in the East River opposite Ravenswood.  Clearly, these safety concerns must be addressed before BESS facilities are built to replace peaking power plants in New York City.

BESS Timing

There are deployment timing issues that also should be addressed.  Our comments posed the question why these facilities are even needed at this time.  As Ravenswood is being redeveloped as a “Clean Energy Hub” it is not clear how much clean energy will there be to charge the batteries in the foreseeable future.  The Clean Path NY transmission line designed to bring renewables to NY City from Central NY is up in the air.  The termination of offshore wind by the Trump administration is another roadblock.  Even if it weren’t threatened by the Trump administration it is likely that significant offshore wind is likely more than 10 years away due to high costs, supply chain constraints and a lack of Jones Act compliant Jack ships needed for the installations.  We concluded that it will be years before sufficient zero-emissions energy is available for this facility.

A BESS facility built today will be storing fossil fuel-based generation with an average carbon footprint of approximately 950 pounds of CO2 per MWh as per EPA figures for the downstate NY utility system.   With 15% – 20% charge-discharge losses added that carbon footprint is increased to over 1100 pounds of CO2 per MWh for any BESS System in the downstate area.  In comparison, a highly polluting 60-year-old generating plant like EF Barrett or any of the peaking power plants that the Peak Coalition wants replaced could be replaced with a Combined Cycle gas plant with CO2 emissions of about 800 pounds per MWh, 30% lower than the battery facilities and will have a lifetime five to six times longer. 

This is another reason to pause the process.  New York State and New York City are not California where renewable development is much further along.  Solar arrays generate far less energy per acre in NY State and as a result, the state is many years away from needing these BESS facilities.  By the time that there are sufficient renewables available in NY State to create the Duck Curve and a need to charge the batteries, any Li-ion batteries installed now will have deteriorated past their 8 – 10-year operating life.  As a result, NY State ratepayers will be saddled with hundreds of millions of dollars of expenses on their utility bills that had the net effect of raising New York City and state carbon footprint more than the peaker plants that they are designed to replace

Conclusion

We concluded our comments by endorsing the Joint Utility statement recommendation that the Commission direct Staff to develop a clear roadmap that addresses, among other things, clean energy technology readiness.  This recommendation would not be necessary if there was a clear roadmap available.  In the absence of such a plan the Hochul Administration’s approach to meet the Climate Act targets has been to push ahead without consideration of technological ramifications.  The Moss Landing BESS fire underscores the risk of such an approach.  It would be inappropriate to proceed with BESS installations in New York City and the other densely populated regions of New York State until the full scope of safety risks are understood.  Additionally, the entire process should be paused until the state has a clear understanding of what resources will be needed to safely implement a sound energy plan.  This will prevent the squandering of resources on technologies that will not reduce GHG emissions and will help to ensure safety and economic vitality for New York State residents.

New York State Electric Sector Emissions Trends

This is my annual update of electric utility sector emission trends in New York State.  The data presented are derived from the Environmental Protection Agency Clean Air Markets Division database.

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.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes two electric sector targets: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation.  Not surprisingly, the aspirational schedule of the Climate Act has proven to be more difficult to implement than planned.  This article shows that electric sector emissions increased in 2024 relative to 2023.

Electric Generating Unit Emission Trends

Electric generating units report emissions to the Environmental Protection Agency Clean Air Markets Division as part of the compliance requirements for the Acid Raiin Program and other market-based programs that require accurate and complete emissions data.  The 2024 emissions data submittal deadline was January 31, and I downloaded the data on 2/3/2025. 

The following table lists emissions and operating data since 2009 when the Regional Greenhouse Gas Initiative started.  Emissions of CO2, SO2, and NOx are down dramatically over this period. 

Table 1: New York State Emissions and Operating Parameter Trends

Table 2 lists CO2 emissions by fuel type since 2000.  It shows the impact of fuel switching.  The primary reason for the observed fuel switching is that the fracking revolution made the cost of natural gas so cheap relative to other fuels that every facility that could convert to natural gas did so.  New York banned the use of coal in 2021 which forced the retirement of the remaining coal plants.  The state still has some facilities that primarily burn residual oil but those run infrequently.  The takeaway message is that the fuel switching options are no longer available so future reductions will only come as zero-emissions resources displace facilities burning fossil fuels.

Table 2: New York State CO2 Emissions by Fuel Type

The following graph illustrates emission trends.  Note that I divided the CO2 emissions by 1,000 so that all the parameters would show up on the same plot.  The impact of the closure of the Indian Point nuclear facility starting in 2020 is clearly shown.  CO2 levels in 2024 were nearly as high as the 2016 levels.    Inter-annual variability is primarily due to weather variations but the primary reason for the higher CO2 emissions is the closure of Indian Point.

Figure 1: NYS Emission Trends – SO2 (tons), NOx (tons) & CO2 (1000 tons)

New York State GHG Emission Trends

The Climate Act requires the Department of Environmental Conservation to issue an annual report on statewide greenhouse gas emissions.   The current report covers the years 1990 through 2022 and was posted late last year. Inexplicably, the emission data are unavailable.  When it is available for download from Open Data NY I will update this summary to include GHG emission trends.

Discussion

New York has significantly reduced pollution emissions from the electric sector.  However, the reductions were due to fuel switching to natural gas.  There are two implications.  There are no more significant opportunities to reduce emissions via fuel switching.  That means New York State must provide the emission reductions by investments in zero-emissions technology that can displace existing generation.  New York’s policy decisions for emission reductions have been poor to date.  The natural gas fuel switching was driven by the economics of fracking natural gas which drove prices down elsewhere but not in New York because fracking is prohibited. The other emissions policy error was the closure of Indian Point.  According to the 2024 data, that decision set back emissions progress by years. 

Conclusion

When you look at the numbers shown in this post, the enormity of the emissions reduction challenge is clear. The Climate Act has been in place for five years.  The crash program to replace fossil fuels with wind and solar has shown no sign of emission reduction success.

Climate Whiplash and California Wildfires

The difference between weather and climate is constantly mistaken by Climate Leadership & Community Protection Act (Climate Act) advocates and has been the subject of articles at this blog.  Recently Southern California wildfires have been blamed on climate change.  Patrick Brown addressed the question how much did “Climate Whiplash” impact the Los Angeles fires.  His excellent analysis raises issues that I want to highlight.

I have been a practicing meteorologist for nearly 50 years, was a Certified Consulting Meteorologist, and have B.S. and M.S. degrees in meteorology.  My particular expertise is air pollution meteorology in the electric utility sector with a focus on meteorological and pollution measurements.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Weather vs. Climate

The Climate Act legislation and the implementation meetings confuse weather and climate.  According to the National Oceanic and Atmospheric Administration’s National Ocean Service “Weather reflects short-term conditions of the atmosphere while climate is the average daily weather for an extended period of time at a certain location.”  The referenced article goes on to explain “Climate is what you expect, weather is what you get.” 

Hydroclimate Volatility

Patrick Brown described the Swain et al. (2025): Hydroclimate Volatility on a Warming Earth Nature review paper. He quoted the first line of the UCLA Press Release for the paper: “Los Angeles is burning, and accelerating hydroclimate whiplash is the key climate connection.”  He then stated: “Thanks in no small part to the huge journalistic audience that lead author Dr. Daniel Swain commands, the “climate whiplash” vernacular was immediately adopted in international headlines covering the recent Los Angeles fires.”  This is a classic example of an extreme weather event that is linked to climate change by organizations and individuals that have a vested interest in advancing the threat of climate change.

Brown noted that: “the paper has demonstrated incredible reach and is in the 99.99th percentile in terms of online attention for all research (not just climate research) of a similar age.”  However he echoes my concern: “But as is the case for so much high-profile climate science, there is a large gap between the impression conveyed by the coverage and the impression left from the observational data.”

Climate Whiplash

I have never heard of the concept of climate whiplash before this story broke.  Brown explains:

Dangerous, intense wildfires require dry vegetation. The idea behind the climate whiplash connection to the Los Angeles fires is that very wet winters in Southern California in 2022-2023 and 2023-2024 enabled a great deal of vegetation growth but that the very dry beginning of the 2024-2025 winter allowed that vegetation to dry out, resulting in a landscape primed for uncontrollable wildfires. Swain explains the mechanism in interviews with Adam Conover and Neil deGrasse Tyson.

In order for this to be a climate change problem, we need to know whether these events are increasing.  Brown noted that:

The idea being conveyed is that these climate whiplash events are dramatically increasing not just in Southern California, but globally.  “Every fraction of a degree of warming speeds the growing destructive power of the transitions” Swain said.

Brown described background for this concept:

Taking a step back, the fundamental theory undergirding changing “hydroclimate” (think water cycle where we are considering not just how precipitation provides moisture but also how evaporation takes moisture) whiplash is nothing new. It is a basic fact of atmospheric physics that a warmer atmosphere can “hold” more water vapor (about 7% more per °C of warming). This warming influence on the water cycle has been discussed in detail since at least the 1980s (e.g., Manabe, & Wetherald, 1986)). At first, most research discussed a general intensification of the water cycle, typically emphasizing that already dry areas would get drier and already wet areas would get wetter as the globe warmed. However, by the mid-2000s, studies like Trenberth et al. (2003), Chou & Neelin (2004), Meehl et al. (2005), and Held & Soden (2006) began pointing out that the same physics (warmer atmosphere holds more moisture) can drive larger variability in the same place—heavier rain events juxtaposed with prolonged and/or more intense dry spells.

These concepts are taught regularly as a part of Climate Change 101 classes, including my own, and they are accepted as consensus climate science, articulated with “high confidence” in the IPCC’s most recent assessment report:

“A warmer climate increases moisture transport into weather systems, which, on average, makes wet seasons and events wetter (high confidence)”

“Warming over land drives an increase in atmospheric evaporative demand and the severity of droughts (high confidence).”

The reason I wanted to highlight Brown’s analysis of this paper is because he highlights a key complication for the general public’s understanding of climate change.  It is accepted that a warmer climate increases moisture in the atmosphere and drought severity.  The implications of those mechanisms are important with respect to GHG emission reduction policies.  The question is so what? What is the magnitude of the change, what impacts might result from these mechanisms, and do we expect that changes in global temperatures due to GHG emissions will result in significant impacts from these mechanisms are all questions that should be addressed.

I fully endorse Brown’s explanation:

However, I like to point out that it is useful to break down lines of evidence in climate science into categories of

  1. Historical observations/trends
  2. Fundamental theory
  3. Mathematical modeling

I know from teaching the “wet gets wetter, dry gets drier” concept that the evidence for increased variability in the same location is much stronger in the theory and modeling categories than it is in observations. This is important because observations should take precedence over the other two. Focusing on observations tells us a lot about how big of an effect we’re talking about (i.e., do we see major trends emerge through the noise of the observation system and natural variability?). Furthermore, a fundamental point of doing science is to explain observations. The canonical order of operations is that first you observe some phenomenon, and then you use the tools of theory and modeling to make sense of it.

I cannot over-emphasize the point that observations should take precedence over theory or modeling.

Observations

Brown goes on to evaluate observations of the whiplash where increased precipitation enabled a great deal of vegetation growth followed by a period of decreased precipitation that allowed that vegetation to dry out, “resulting in a landscape primed for uncontrollable wildfires”.  I am only going to summarize two of the results.

Brown evaluated observations of year-to-year water cycle variability following the methodology of the Swain et al. (2025) paper. Note that he only evaluated the effect over land because it has no effect on wildfires if it occurs over the ocean.  He did not find any compelling evidence for an increase in these events in California.  The results for global land were described:

So, over all global land, at the timescale that is most relevant to the Los Angeles fires (annual), in the premiere observational dataset (ERA5), using Swain et al. (2025)’s own data, we have seen a long-term decrease in whiplash frequency (this, by the way, is acknowledged in passing in the text of Swain et al. (2025) on page 37).

Let’s pause for a second to recall the first line of the UCLA press release (“Los Angeles is burning, and accelerating hydroclimate whiplash is the key climate connection.”) and the global news coverage it generated. Would any reader of this coverage have any idea about the incredibly important caveats above? Not that I can tell.

In the next section Brown discussed the magnitude of changes in annual water cycle variability.  He stated that:

Now, to be fair, Swain et al. (2025) purport to show evidence of increasing whiplash frequency at multiple timescales, spatial extents (over the ocean, for example), and in other datasets.

However, highlighting changes in arbitrarily-defined “event” frequency without reporting changes in “event” magnitude is misleading, and it goes against one of the core recommendations of the National Academies of Sciences 2016 report on Attribution of Extreme Weather Events in the Context of Climate Change. As Ted Shepherd recently put it in his presentation to the committee responsible for the next such report: “Frequency is the more impressive number, but magnitude is perhaps the more physically interpretable number.”

Brown’s analysis of the magnitude of the changes found: “1 we see no long-term increase in water cycle variability at the location and timescale relevant to the Los Angeles fires.”

Patrick Brown Summary

Brown’s summary is important.  He notes that the choice of analysis data used affects the conclusion:

While “climate whiplash events” may be increasing in frequency under most of the very specific, selected definitions used and datasets investigated in Swain et al. (2025), the general idea that annual precipitation (or more generally, the water cycle, which includes evaporation) is becoming dramatically more variable is not supported when a broader set of datasets and definitions are used.

Brown worries that this analysis and the publicity it received is a problem:

Would a reader of Swain et al. (2025), or especially its coverage, have any idea about the weakness of its broader conclusions or the lack of robustness of its results to different definitions and datasets? Almost certainly not, and I contend that this is a major problem for public understanding and trust in climate science.

One of my over-arching issues with the existential threat narrative is that the accepted science is distorted with respect to reality of natural variability.  Brown explains:

Why don’t we see a robust increase in water cycle variability given the strong theory underpinning “wet gets wetter, dry gets drier”? For one thing, the theoretical size of the effect is known to be quite small relative to natural, unforced variability, making it inherently difficult to detect. For example, we see in Figure 7 above that year-to-year rainfall in Los Angeles naturally varies by as much as 300%, yet the signal we are looking for is one to two orders of magnitude less than this. It is also apparently the case that observational uncertainty is larger than the signal (or there would not be such disagreement between datasets). Physically, perhaps increasing mean precipitation is offsetting the increase in calculated evaporation in the SPEI index, reducing its variability. Maybe reduced temperature variability (via arctic amplification) is reducing calculated evaporation variability.

I agree with Brown’s concluding remark:

My main discomfort with Swain et al. (2025) and its rollout is that it appears that the primary goal was to create and disseminate the “climate whiplash” meme rather than conduct a truly rigorous evaluation of the evidence, including countervailing evidence. Ultimately, this makes the research a much larger advance in marketing than an advance in science.

Conclusion

Patrick Brown does an excellent job eviscerating the climate whiplash headlined stories based on Swain et al. (2025)’s recent paper.  It is frustrating that biased analyses that confirm pre-conceived get so much attention.  It will require many evaluations like Brown’s to address the misinformation.

There is another important point.  There is no question that adding greenhouse gases to the atmosphere will result in warming and that the warming will result in “wet gets wetter, dry gets drier”.  However, Brown shows that the magnitude of these effects is important and that checks based on historical observations indicate that those effects are about the same as natural variability.  Whenever I have evaluated similar claims, I found the same result.  Claims that climate change impacts are observable now are not supported by historical observations.

Climate Leadership & Community Protection Act Mal-Information

I recently evaluated the New York Affordable Energy Future proposal for revenues generated by the New York Cap-and-Invest (NYCI) program.    Their report includes a perfect example of New York State Energy Research & Development Authority (NYSERDA) mal-information created by NYSERDA’s intentional misrepresentation of their cost estimates for the Climate Leadership & Community Protection Act (Climate Act) implementation plan. 

I am convinced that implementation of the New York Climate Act net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 490 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 2030 reduction target of a 40% GHG reduction by 2030.  The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantified the impact of the electrification strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022. 

NYSERDA claims that there was “robust public input” during the draft Scoping Plan process that “included 11 public hearings across the State and more than 35,000 written comments” that supposedly were read, summarized, and presented to the CAC.  However, the summary was a slide presentation.   The public comment period for the Draft Scoping Plan closed on July 1, 2022.  The CAC reviewed the feedback received from stakeholders over a series of five meetings from August 23, 2022 to October 25, 2022.  The presentations for all CAC meetings are posted and all public comments received by the CAC are available. However, NYSERDA did not summarize the comments or provide a response to them.

False Information

There is a bigger problem with the Scoping Plan implementation process than the lack of documentation.  The Hochul Administration and NYSERDA are guilty of peddling false information.  Media Defence defines three false information terms:

  • Disinformation: Disinformation is information that is false, and the person who is disseminating it knows it is false. “It is a deliberate, intentional lie, and points to people being actively disinformed by malicious actors”.
  • Misinformation: Misinformation is information that is false, but the person who is disseminating it believes that it is true.
  • Mal-information: Mal-information is information that is based on reality, but it is used to inflict harm on a person, organization or country.

I am not going to assign motives to the agencies and staff responsible for the Scoping Plan component of Climate Act implementation, so I am not going to accuse anyone of disinformation.  However, there are examples of misinformation and mal-information on the record in the Scoping Plan process.

Misinformation

At the May 26, 2022 Climate Action Council meeting the topic of misinformation came up as I documented here.  CAC Co-Chair Basil Seggos discussed his thoughts starting at 19:50 of the recording and brought up the subject of public engagement.  He admitted that when they got out into public that they gained a better appreciation of the scale of the challenge.  He said it was tough to communicate the challenges but when on to say there is lots of “misinformation and misunderstanding but also lots of excitement and support”. 

One topic for misinformation according to CAC member comments was concerns about the reliability of an electric system that relies on wind and solar.  Paul Shepson (starting at 23:39 of the recording said:

Mis-representation I see as on-going.  One of you mentioned the word reliability.  I think the word reliability is very intentionally presented as a way of expressing the improper idea that renewable energy will not be reliable.  I don’t accept that will be the case.  In fact, it cannot be the case for the CLCPA that installation of renewable energy, the conversion to renewable energy, will be unreliable.  It cannot be.

Robert Howarth, starting at 32:52 of the recording) picked up on the same issue.  He said that fear and confusion is based on misinformation, but we have information to counter that and help ease the fears.  He stated that he thought reliability is one of those issues: “Clearly one can run a 100% renewable grid with reliability”, although he did admit it had to be done carefully. 

Since then, the claims that the conversion to renewable energy had no reliability challenges that could not be overcome with existing technology have been shown to be false.  The CAC members who dismissed anyone who disagreed as purveyors of misinformation were clearly wrong.  I have documented that experts, including those that are responsible for electric system reliability, agree that a new category of generating resources called Dispatchable Emissions-Free Resources (DEFR) is necessary during extended periods of low wind and solar resource availability.  The fact that this requirement was included in the Integration Analysis and Co-Chair Seggos did not call out the CAC members who claimed that no new technologies would be needed and allowed them to enter those statements in the record is clear misinformation.

Mal-Information

The authors of the New York Affordable Energy Future proposal were tricked by mal-information in the Scoping Plan.  The report notes that “NYSERDA has estimated that decarbonizing the state will cost $11 billion in 2030, counting both private and public spending.  That statement was document with the following reference: “According to p. 131 of the NY Climate Action Scoping Plan (NYS Climate Action Council 2022).”  The Scoping Plan states “In 2030, annual net direct costs relative to the Reference Case are around $11 billion per year, approximately 0.5% of GSP; in 2050, costs increase to $41 billion per year, or 1.3% of GSP. 

Lest you think this is an isolated reference, Governor Hochul’s executive budget described in the FY2026 NYS Executive Budget Book included the following paragraph:

From the beginning of her administration, Governor Hochul has made it clear that responding to climate change remains a top priority for New York State. Acknowledging that the cost of inaction greatly outweighs the cost of any actions we can take together, New York will continue to pursue an aggressive agenda in transitioning to a sustainable green energy economy, in a way that is both environmentally effective and economically affordable for all New Yorkers.

Unfortunately, the statement is deliberately misleading.  The Hochul Administration wanted to be able to say that implementing the Climate Act would be beneficial.  NYSERDA provided support for the sound bite “The costs of inaction are more than the costs of action” that has been the mantra of the Administration.  However, that statement is misleading and inaccurate as I documented in my verbal comments and in my written comments on the Draft Scoping Plan.  I described the machinations based on reality used to mislead and harm New York as a shell game in a summary post.

The reason that this claim is a shell game is that the cost estimate everyone wants to know is how much it is going to cost to achieve the New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050 and all the other targets in the Climate Act. The “New York Affordable Energy Future” authors said “NYSERDA has estimated that decarbonizing the state will cost $11 billion in 2030, counting both private and public spending” I believe that they presumed that number included all the costs of all the decarbonization programs needed to achieve the Climate Act targets.

The NYSERDA gimmick used to support the narrative picks and chooses what control strategies are included in the costs of de-carbonization.  To evaluate the effects of different policy options, this kind of modeling projects future conditions for a baseline case.  The evaluation analysis makes projections for different policy options, and then the results are compared relative to the baseline.  The standard operating procedure is to use a business-as-usual or status quo case for the baseline. 

NYSERDA did not do that.  In my review of the Draft Integration Analysis supplement, I showed that NYSERDA conjured up a Reference Case to fulfill their imperative to “prove” Climate Act benefits.  Instead of a typical baseline case, the Reference Case used in the scenario excluded programs that are needed to meet the Climate Act targets but were implemented before the Climate Act was passed.  I think it is troubling that this approach was hidden.  I identified the problem only after I searched the Scoping Plan documents for the phrase “reference case” to try to determine what “already implemented” decarbonization programs were included in the Reference Case.  The following figure reproduces the page with the documentation on page 12 in Appendix G Integration Analysis Technical Supplement Section I. The documentation is buried in the footnote for the circled reference for the blank caption to Figure 4. 

Given its importance to the cost/benefit claim, my Draft Scoping Plan comment noted that this reference case caveat should have been clearly described in the text rather than in a footnote.  The Final Scoping Plan document included explanatory text in section 5.3 of the document.  However, that text was not even included in the draft document!  

The appropriate descriptive text is in the final Appendix G section 5.3: Scenario Assumptions chapter and lists the “already implemented” programs.  It states:

The integration analysis evaluated a business-as-usual future (Reference Case) a representation of recommendations from CAC Advisory Panels (Scenario 1), and three scenarios designed to meet or exceed GHG limits and carbon neutrality (Scenarios 2 through 4). Scenarios 2, 3, and 4 all carry forward foundational themes based on findings from Advisory Panels and supporting analysis but represent distinct worldviews. A detailed compilation of scenario assumptions can be found in Annex 2.

For the record Annex 2 refers to a massive spreadsheet that is certainly detailed but most certainly does not provide an easily accessible compilation of scenario assumptions.  In particular, the documentation does not provide explicit information to determine what costs are specifically included in the Reference Case relative to the other scenarios.

The Reference Case described as “Business as usual plus implemented policies” includes the following:

  • Growth in housing units, population, commercial square footage, and GDP
  • Federal appliance standards
  • Economic fuel switching
  • New York State bioheat mandate
  • Estimate of New Efficiency, New York Energy Efficiency achieved by funded programs: HCR+NYPA, DPS (IOUs), LIPA, NYSERDA CEF (assumes market transformation maintains level of efficiency and electrification post-2025)
  • Funded building electrification (4% HP stock share by 2030)
  • Corporate Average Fuel Economy (CAFE) standards
  • Zero-emission vehicle mandate (8% LDV ZEV stock share by 2030)
  • Clean Energy Standard (70×30), including technology carveouts: (6 GW of behind-the-meter solar by 2025, 3 GW of battery storage by 2030, 9 GW of offshore wind by 2035, 1.25 GW of Tier 4 renewables by 2030)

Mal-information is information that is based on reality, but it is used to make misleading statements that improperly convey a false narrative.  In this case, the uncommon definition of the base case used for the implementation cost modeling led most New Yorkers to believe that annual net direct costs to achieve the Climate Act targets were around $11 billion per year.  The Scoping Plan mentions that those costs are “relative to the Reference Case” but the draft Scoping Plan did not document what programs were included in the Reference Case.  This is why I believe that the “costs of inaction and more than the costs of action” narrative is mal-information. 

Discussion

This post was prompted by my realization that the authors of the New York Affordable Energy Future report were misled by NYSERDA mal-information related to the expected annual net direct costs needed to achieve the Climate Act mandated targets.  When I did some background research I found Media Defence definitons of three false information terms and realized that NYSERRDA was guilty of two out of three.

NYSERDA is guilty of misinformation because the Scoping Plan was approved because information fundamental to the implementation schedule was known to be false.  The only way to justify the Climate Act schedule is to believe that no new technology is needed so the only constraint is deployment.  CAC member Dr. Robert Howarth is the primary source of that presumption, and I am sure he believes that no new technology is needed.  However, the Integration Analysis recognized that during extended periods of low wind and solar resource availability that a new DEFR technology is needed.  The leadership of the CAC should have addressed this fundamental issue.  That they didn’t was likely because acknowledging the problem is tantamount to admitting that the Climate Act law was deeply flawed. 

NYSERDA and Governor Hochul are guilty of peddling mal-information.  Their oft-repeated sound bite that the “costs of inaction are more than the costs of inaction” is based on reality but mis-leads and harms New Yorkers because it does not include all the costs necessary to meet the Climate Act mandates.  No one cares which regulation, or law mandates a specific portion of the total costs necessary to meet the goals.  The total costs are all we care about.

NYSERDA claims that there was “robust public input” during the draft Scoping Plan process that “included 11 public hearings across the State and more than 35,000 written comments” that supposedly were read, summarized, and presented to the CAC.  The problem is that NYSERDA and DEC staff screened the comments and only presented generalities and not specific comments that questioned any of the narrative that the Administration wanted pushed. I specifically addressed this issue in my verbal and written comments but have never seen any evidence that anyone on the

I recently found an example of how a stakeholder process should work.  The Santa Clara County Rapid Transit Development Project includes a master plan for transportation for Silicon Valley.  An interview with the founding manager notes: “Part of the plan is a four-year public stakeholder review process.  In the reviews, if the public came up with good ideas, the ideas went into the plan.  If an idea wasn’t good, we had the responsibility of explaining why.”[1] 

That commitment to responding to comments is sorely needed in New York.  In my opinion, the CAC should have been informed about this issue.  A summary describing what I claimed, their response to my concern, and a recommendation for the CAC is necessary to assure public confidence in Climate Act implementation.  If NYSERDA is to have any credibility regarding their stakeholder process, then they must provide better documentation showing that all the comments were considered and addressed.

Conclusion

The Hochul Administration has been the first to pitch a fit and throw around the misinformation label when anyone says something contrary to their narrative.  They are not only guilty of pushing misinformation but worse, they spout egregious mal-information whenever they claim the costs of inaction are more than the costs of action.

[1] “California’s High-Speed Rail Visionary” Bill Buchanan, Trains, Volume 85, No. 1, January 2025, pages 30-37.

Peak Coalition: Current Grid is Not Reliable

In my post about the implications of the Moss Landing Battery Plant fire I discussed the implications of the fire on the proposal by the PEAK Coalition to the shutdown of New York City peaking power plants.  I also quoted comments made at their webinar entitled “Replacing NYC’s Peaker Plants with Clean Alternatives: Progress, Barriers, and Pathways Forward”.  The subject of this post is one of the comments made at the webinar that illustrates the gulf between the emotion-driven ideologues who make are responsible for these proposals and reality.

I am convinced that implementation of the New York Climate Act net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 490 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 PEAK coalition has stated that “Fossil peaker plants in New York City are perhaps the most egregious energy-related example of what environmental injustice means today.”  The influence of this position on current New York State environmental policy has led to this issue finding its way into multiple environmental initiatives. I have prepared a summary of this issue that explains why the presumption of egregious harm is based on selective choice of metrics, poor understanding of air quality health impacts,  and ignorance of air quality trends.  The page documents my concerns based on my background in air pollution control theory, implementation, and evaluation over my 45+ year career as an air pollution meteorologist and extensive personal experience with peaking power plants and their role during high energy demand days.

Reality Disconnect

The Peak Coalition webinar entitled “Replacing NYC’s Peaker Plants with Clean Alternatives: Progress, Barriers, and Pathways Forward” included a presentation by Megan Carr, Skadden Fellow – Environmental Justice Program, New York Lawyers for the Public Interest.  She talked about regulatory barriers for battery storage.  She claimed the current grid is not reliable:

When we talk about reliability concerns, we also have to remember that our current grid is not reliable. Having over 70% of our downstate energy generated by fossil fuels that we’re buying on a volatile global market that’s subject to price spikes is not actually reliable.  When we’re talking about uncertain economics, the cost of peak electricity in New York City is 1300% higher than the average cost of other electricity in the state.  Those are not reasonable economics.  That means there are over 600,000 New Yorkers paying over 6% of their annual income in energy payments. That is untenable.  Most importantly as Sebastian and Victor already touched on, it is unacceptable because it requires that some of our communities are sacrificed and regularly exposed to harmful air quality which has devastating health effects.  

Her interpretation of reliability is absurd.  It is what you would expect from an environmental justice lawyer who received her master’s degree in childhood education from Canisius College, and her B.A. from Kenyon College.  There certainly is a link between keeping the lights on and being able to afford to turn on the lights.  However, connecting fuel costs to reliability shows just how weak advocate arguments concerning reliability really are.

Wind, solar, and energy storage advocates like the New Yorkers for Clean Power who want to “rapidly shift to an equitable clean energy economy” acknowledge that reliability is a real issue.   At a webinar titled “Get Charged Up for the New York Energy Plan” Janet Joseph is a former employee at the New York State Energy Research & Development Authority (NYSERDA) who managed work associated with the Climate Act Scoping Plan.  She correctly recognized that reliability and affordability are real issues for the proposed wind and solar reliant electric grid and must be addressed. She said that “the advocacy community must be armed to fight that battle and address the impact on reliability and affordability as best you can.”

Reliability Reality

The Peak Coalition does not acknowledge the reliability challenges of the electric grid, which I think is because they do not understand the system.  More importantly they dismiss the enormous reliability risks of an electric grid relying on weather-dependent generators backed up by energy storage resources. I talked about my fears of such a system in this post and later I refined my concerns noting that it boils down to “correlated intermittency”. 

Wind and solar are inherently intermittent – the sun does not shine at night and the wind does not always blow.  That intermittency is correlated.  All the solar in New York is unavailable at night.  It turns out that wind resources across New York also are usually high or low at the same time. There are exceptions but there is a high incidence of similar behavior.  That matters for electric resource planning.  Today electric resource planning relies on decades of performance experience with hydro, nuclear, and fossil plants that do not correlate, there is no reason to expect that all the nuclear plants will be offline at the same time. 

The variation in weather that affects wind and solar resource availability will require changes to electric resource planning.  It will be necessary to develop weather dependent probabilistic energy production estimates.  The unresolved problem is what return period probability is acceptable.  If the resource planning process does not provide sufficient backup resources to provide capacity for a future peak load period that occurs when wind and solar resources are low, then blackouts are inevitable.  Two factors exacerbate the challenge of this problem:

  1. The periods of highest load are associated with the hottest and coldest times of the year and frequently correspond to the periods of lowest wind resource availability. 
  2. The decarbonization strategy is to electrify everything possible so peak loads will be larger and the impacts of a peak load blackout during the coldest and hottest periods will be greater.

The New York Independent System Operator 2024 Reliability Needs Assessment identified reliability risks.  Risks have also been identified by the North American Electric Reliability Corporation.  Both have expressed concerns that extreme weather events, rapid demand growth, and systemic vulnerabilities pose risks for supply shortfalls and grid reliability.  In a rational world these reliability issues would be at the forefront of New York energy policy and a complete feasibility analysis would be completed before the state proceeds with a wind, solar, and energy storage grid.  Sadly, New York is not rational.

Advocacy Reliability

In the absence of anything rational to address the impact on reliability and affordability the supporters of the Climate Act are left with argument that volatile global markets affect fossil fuel prices so much that it is not affordable.  I see no way that has anything to do with reliability. 

The volatile fuel prices affecting electric affordability argument came up at last month’s New York Assembly Committee on Energy hearing addressing NYSERDA’s revenues and expenditures effectiveness.  Jessica Waldorf, Chief of Staff & Director of Policy Implementation, New York State Department of Public Service said that there are reasons “to build renewable energy resources in New York that are not just related to emissions.”  She gave two reasons: energy security and price volatility.  Waldorf’s explanation of energy security mentioned “localizing energy production here”.  She went on to state:

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

In a post describing this testimony I noted that at first glance, the price volatility argument is persuasive because we have all experienced the impact of increased fuel costs in recent memory.  However, in the last two months the European electric market has shown what happens when an electric system becomes overly dependent upon wind and solar:

From November 2 to November 8 and from December 10 to December 13, Germany’s electricity supply from renewable energies collapsed as a typical winter weather situation with a lull in the wind and minimal solar irradiation led to supply shortages, high electricity imports and skyrocketing electricity prices.

The electric transmission connections to other countries raised prices elsewhere when German wind and solar failed to provide sufficient energy.  Prof. Fritz Vahrenholt says they went up so much in Norway that the energy minister “wants to cut the power cable to Denmark and renegotiate the electricity contracts with Germany”.  Swedish Energy Minister Ebba Busch stated: “It is difficult for an industrial economy to rely on the benevolence of the weather gods for its prosperity.” He went on to respond directly to Habeck’s green policy: “No political will is strong enough to override the laws of physics – not even Mr. Habeck’s.”

There is no question that the same thing will happen in New York.  Note that the technologies proposed as backup for extended periods of low wind and solar resource availability are expected to operate even less than the peaking power plants have operated historically.  Those resources will have to be paid very high rates during those hours to be economically viable.  High spot prices is one of the problems identified by the Peak Coalition to vilify peaking power plants.  The price volatility argument that Megan Carr claims causes reliability issues will be a more pronounced feature of the system she advocates.

It is also notable that responsible New York agencies all agree that new Dispatchable Emissions-Free Resource technologies are needed to make a solar and wind-reliant electric energy system work reliably during extended periods of low wind and solar resource availability.  No one knows what those technologies are.  At the New York State Energy Research & Development Authority (NYSERDA) Regional Greenhouse Gas Initiative Operating Plan Advisory Stakeholder meeting held on December 5, 2024  NYSERDA Staff  mentioned that they were working with the Department of Public Service to start a five-year plan to address DEFR. The NYSERDA projections for renewable energy and the New York Independent System Operator (NYISO) projections do not anticipate deployment of DEFR starting before 2035.  However, those analyses also assume that existing generators in New York City do not retire as the Peak Coalition recommends. 

Comments submitted by NYISO on the DPS zero emissions proceeding warned:

Electric system reliability margins are already close to minimum reliability requirements in certain areas across New York and are tightening. If these margins are totally depleted, the reliability of the grid would be at an unacceptable risk and power outages could disrupt normal life or negatively impact public health, welfare, and safety. 

I believe that the most likely reason that New York City reliability will degrade would be implementation of Peak Coalition recommendations.

Conclusion

I have never been impressed with the technical background and experience of the ideologues who represent the Peak Coalition.  This is exemplified by baseless claims that “We also have to remember that our current grid is not reliable” and “Having over 70% of our downstate energy generated by fossil fuels that we’re buying on a volatile global market that’s subject to price spikes is not actually reliable.”  If the system was not reliable then blackouts would be common.  They are not.  Fuel prices affect affordability but there is no link to reliability.  That biased organizations like this catch the attention of politicians and affect New York policy is a sad commentary on New York energy policy.

Commentary on Recent Articles January 26, 2025

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

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

How to Think About Climate

William Happer gave a talk entitled How to Think About Climate at the National Leadership Symposium at Hillsdale College on February 19, 2021.  A video of the presentation is available and Watts Up With That published a transcript with illustrations recently.  Dr. Happer is professor Emeritus in the Department of Physics at Princeton University.  He is a specialist in modern optics, optical and radiofrequency spectroscopy of atoms and molecules, radiation propagation in the atmosphere, and spin-polarized atoms and nuclei.  Activists claim that he is not a climate scientist but he is an expert in atmospheric radiation propagation, you know the physics of the greenhouse effect.  It is well worth your time to read or listen to this talk because it is an excellent summary of the science and the politics of the climate change crusade.

He concludes with two takeaways:

So, the takeaway message is that policies that slow CO2 emissions are based on flawed computer models which exaggerate warming by factors of two or three, probably more. That is message number one. So, why do we give up our freedoms, why do we give up our automobiles, why do we give up a beefsteak because of this model that does not work?

Takeaway message number two is that if you really look into it, more CO2 actually benefits the world. So, why are we demonizing this beneficial molecule that is making plants grow better, that is giving us slightly less harsh winters, a slightly longer growing season? Why is that a pollutant? It is not a pollutant at all, and we should have the courage to do nothing about CO2 emissions. Nothing needs to be done.

Endangerment Finding

Francis Menton did an excellent review of the EPA Endangerment Finding of 2009.  He explains that this declared that CO2 was a pollutant which gave the EPA the mandate to regulate CO2 making it the basis of all the EPA regulations limiting emissions.  Menton described litigation associated with the Finding that was intended to rescind the finding that CO2 was a “danger” to human health and welfare.  Unfortunately, the first Trump Administration ignored the litigation, and it was dismissed.

The good news highlighted in his article is that among the blizzard of Executive Orders signed by Trump was “Unleashing American Energy.”

There is a large amount of important material in this EO. In overall summary, it directs the reversal of all of the Biden administration efforts to restrict and suppress the production and development of America’s energy resources. But one provision, I would argue, is important above all the rest. That is Section 6(f), which directs a reconsideration of the so-called Endangerment Finding (EF) of December 2009. That provision of the EO reads as follows:

(f)  Within 30 days of the date of this order, the Administrator of the EPA, in collaboration with the heads of any other relevant agencies, shall submit joint recommendations to the Director of OMB on the legality and continuing applicability of the Administrator’s findings, “Endangerment and Cause or Contribute Findings for Greenhouse Gases Under Section 202(a) of the Clean Air Act,” Final Rule, 74 FR 66496 (December 15, 2009).

Menton concludes: “If the EF is rescinded with a well-reasoned regulatory action, the courts will have little to no ability to stop the Trump roll-back of all the Obama/Biden restrictions on fossil fuels and energy transition.”  Needless to say I think that would be an enormous victory.

The scourge of prosocial censorship

John Ridgway describes a recent research paper published in The Proceedings of the National Academy of Sciences argued that both self-censorship and the prosocial censorship of colleagues are commonplace within the sciences — and the problem is only getting worse. 

Ridgway explains that prosocial censorship is a “form of censorship in which work is rejected, and individuals cancelled, not because the work is substandard or flawed, but because it threatens to undermine a cherished ideology or someone else’s concept of societal safety and harmony. Such censorship is never portrayed as such, of course; the reason given is always that the individual(s) concerned were peddling substandard work leading to harmful misinformation.”

He provides multiple examples of experts in their field who fell from grace by publishing something that gatekeepers felt was inappropriate.  He describes the range of this cancellation of individuals and describes climate skeptics like me.

Somewhere in the middle are the concerns harboured by the climate sceptic. Whilst we understand that science is not supposed to operate by consensus, we would, nevertheless, like to believe that an emergent consensus is the result of a developing common knowledge, rather than the result of social engineering enabled by prosocial censorship

For my part I fear the science is getting lost in the pursuit of the climate change religion.

Green Hydrogen

The Climate Act Scoping Plan proposed to use “green” hydrogen to provide the needed dispatchable emission-free resource (DEFR) required to backup wind and solar during extended periods of low resource availability.  Vijay Jayaraj explained that the “miracle” of green hydrogen is becoming a faded mirage.  He explains:

Green hydrogen start-ups are shuttering operations, major projects are being shelved, and investors are retreating from what was once seen as the next frontier in “renewable” energy. This shouldn’t come as a surprise to anyone whose attention to fundamentals has not been diverted by the extravagant claims of promoters.

The latest analyses predict that green hydrogen prices are likely to remain stubbornly high for decades. The goal of achieving production costs below $2 per kilogram – the threshold for competitiveness with fossil fuels – remains far out of reach. In most parts of the world, the economics simply do not add up.  The reasons are multifaceted. One of the fundamental flaws of green hydrogen is its reliance on wind and solar energy that is expensive, intermittent and unreliable.  The entire green hydrogen cycle is also inherently inefficient. 

Broken record time – Why is New York pushing ahead without a solution to DEFR when the placeholder technology is clearly a non-starter?

Data Tampering

Tony Heller at Real Climate Science compares historical newspaper clippings for extreme weather events to recent weather events and invariably finds that there were events similar if not more extreme than the “unprecedented” events that the make today’s front page.  He also tracks what can only be called malfeasance at the National Oceanic and Atmospheric Administration National Centers for Environmental Information.  In his latest example he looks at the U.S. Historical Climatology Network (USHCN) data.  These data are “used to quantify national and regional-scale temperature changes in the contiguous United States (CONUS). The dataset provides adjustments for systematic, non-climatic changes that bias temperature trends of monthly temperature records of long-term COOP stations. USHCN is a designated subset of the NOAA Cooperative Observer Program (COOP) Network, with sites selected according to their spatial coverage, record length, data completeness, and historical stability.” 

The issue is the adjustments to the USHCN (United States Historical Climatology Network) RAW temperatures.  These are “unadjusted temperature measurements collected from a network of high-quality weather stations across the contiguous United States.”  According to my Perplexity AI query these are the key points about USHCN RAW temperatures:

  • They represent original, unaltered temperature measurements from weather stations.
  • The raw data may contain biases due to factors such as changes in station location, instrumentation, or observation times.
  • The number of active raw data stations has been decreasing rapidly since 2005.
  • Raw temperatures are used as a baseline for comparison with adjusted or “final” temperatures in climate studies.
  • The raw data are flagged for possible quality issues but are not adjusted for these potential biases.

Tony Heller compared the original, unaltered RAW temperatures in this animated graph: USHCN RAW Tampering 2-13-2024 To 1-12-2025.  Data since 2007 are markedly higher.  The only reason I can think of is that the average values are affected by the choice of active stations used.  If stations with lower temperatures are excluded then the average will get higher.  If the result fits the narrative of dangerous warming all the better.

Be sure to click this link to see the malfeasance: USHCN-RAW-(MEASURED)-MONTHLY-TMAX-minus-Average-Maximum-Temperature (2)

Dunkelflaute

Timera Energy published a piece, Impact of German Dunkelflaute on flex asset value that examines the impact of Dunkelflaute  or “dark doldrums”, referring to multi-day periods of low wind & solar resource periods on baseload prices, price volatility, and the value of flexible power assets. These are the periods where we expect that dispatchable emissions-free resources will be needed.  Timera Energy provides consulting services to energy companies, investment funds, banks & utilities.  I am not going to even attempt to explain their analysis of Dunkelflaute opportunities.

I mention this because these consultants are salivating over possibility that there will be “clear price signals” that spell opportunities for profits.  Not mentioned when they discussed “the longer-duration storage solutions to bridge more sustained dips in renewable energy and storage output” was the fact that the technology does not exist.  I cannot tell you how this issue will haunt you if this headlong rush over the green energy cliff is not halted, but I am sure that it will hit your wallet and the reliability of your electric supply.

New York State Climate Superfund

Last December Governor Hochul signed the “Climate Superfund” legislation to” bolster New York’s efforts to protect and restore the environment by requiring large fossil fuel companies to pay for critical projects that protect New Yorkers.”  A commentary by Scott Axelson and Michael Dee in the Jamestown Post Journal examines a few of the absurd claims made by Superfund supporters.  After debunking those claims the authors conclude:

Who will actually bear the cost of the Superfund? It will always be working people of NYS who bear the burden. Our cost of living will soar, and more jobs will move from NYS to more enlightened states that have not fallen for climate catastrophism.

One question for the Governor: Will your Superfund pay for the disposal of millions of tons of toxic and non-recyclable waste from Wind, Solar, and Battery Farms? Why do you ignore the massive environmental damage caused by “Green Energy”?

Instead of vilifying fossil fuels, we should be turning our attention to the greedy politicians who created the Superfund to extort our hard-earned money to benefit their wealthy friends in the Legal industry.

Madison County Wind Farm Retirement

Postscript: On September 17, 2025 the wind turbine towers were imploded thus ending the life of the first New York wind farm.

In June 2024 I published Madison County Wind Farm – Theory vs. Results comparing the performance of the first New  York industrial wind facility with an old New York State Energy Research and Development Authority (NYSERDA) report projecting performance.  On January 14, 2025 the New York Independent System Operator (NYISO) posted a Completed Generator Deactivation Notice for the facility. 

I have followed the Climate Leadership & Community Protection Act (Climate Act)since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 490 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 company 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 2030 reduction target of a 40% GHG reduction by 2030.  The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.”  The Integration Analysis prepared by NYSERDA and its consultants quantified the impact of the electrification strategies. The Scoping Plan was finalized at the end of 2022.

Madison Wind Farm

According to its Wikipedia page:

The Madison Wind Farm is a power generation plant located in the town of Madison, New York. Constructed in 1999-2000, it was the first wind farm completed in New York state and the first merchant wind farm in the country. The power plant consists of seven Vestas V66-1.65 MW wind turbines, generating enough energy to power up to 10,000 homes. The Vestas V66-1.65 MW wind turbines have a hub height of 67m and a 66m rotor diameter totally 100m to the top of the rotor.

It is now owned by EDP renewables.  There have been maintenance issues and last year I mentioned talk about decommissioning the project.  On January 14, 2025 NYISO posted a Completed Generator Deactivation Notice for the facility.  The notice said that the Nameplate capacity was 11.6 MW.  The notice stated that “The submitting entity has proposed to deactivate the Generator on May 1, 2025. The desired Retirement date is less than 365 days after the completed Notice was submitted.”

NYSERDA sponsored an assessment of the facility that was published in December 2003.  The Madison Windpower Project Final Report was prepared for NYSERDA by AWS Scientific, Inc.  The Abstract for the report stated that:

This report covers the development and operation of the Madison Windpower Project in Madison County, New York developed by PG&E Generating. The project began commercial operation in October 2000 and consists of seven Vestas V66-1.65 MW OptiSlip® wind turbines for a total capacity of 11.55 MW. Long­ term wind resource estimates predicted an annual hub-height average wind speed of 7.3 m/s. The net annual plant energy production was predicted to be 23,621 MWh, which would produce a capacity factor of 23.3%. The wind turbines were dispatched and controlled from the PG&E Pittsfield operations center, which was also responsible for substation maintenance. Vestas took charge of inspection, adjustment, and repair of the turbines (both scheduled and unscheduled) and established an operations and maintenance facility in the Madison area. The wind plant produced a total of 61,379 MWh of electricity for three years for an annual average of 20,460 MWh and an overall capacity factor of 21%. The capacity factor is lower than the expected value of 23.3% primarily due to lower than predicted wind speeds and turbine and grid outages.

Observed Operations

The New York Independent System Operator (NYISO) prepares a report describing load and capacity data for all New York generating units that participate in the electric market.  Universally known as the “Gold Book” it is the best reference for New York electric generation data. The 2024 Load & Capacity Data Report presents observed load and capacity data for 2023. The 2024 data are not available.  To prepare this summary of Madison Wind Farm operations I relied on a compilation of observed data from Gold Book reports back to 2006.

The following table lists the observed net energy (GWh) and capacity factors from 2006 to 2023, and the projections made in 2003 by AWS.  In that analysis the observed capacity factor was 21% in the first three years.  Since then, only one year achieved that level and in the last three years the capacity factor was less than 14%.  AWS projected that the energy production would be 23.6 GWh per year.  The last column in the table lists the observed minus projected annual deficit.

Table 1: Madison Wind Farm Performance Based on NYISO “Gold Book” Load & Capacity Data Report Table III-1 Including AWS 2003 Projections

Discussion

As the first industrial wind facility Madison Wind Farm performance was evaluated in the AWS project.  The report claims that it was a successful demonstration of large-scale wind development.  I agree that it provides power, and the information learned from it has been used to integrate other projects.  However, I have concerns about the poor availability and decreasing capacity factors.

In my previous article I noted that over-optimism is a characteristic of NYSERDA.  The NYSERDA Integration Analysis projected a state-wide wind capacity factor of 29% in 2020 increasing to 34% in 2030.  The Gold Book statewide capacity factor in 2020 was 23.9%.  The Integration Analysis projected land-based wind in 2030 would generate 5,043 GWh but using that capacity factor he actual production was only 4,162 GWh, 18% lower than they projected.  In addition, the Integration Analysis did not acknowledge that as wind systems age their performance drops.

In comments I submitted regarding the Draft Scoping Plan, I noted that the Integration Analysis assumes that the expected lifetimes of the wind facilities is indefinite.  As a result, units were assumed to remain online throughout the study period and no costs for replacements between now and 2050 were included.  This generator deactivation notice blows that assumption out of the water.

NYSERDA’s Integration Analysis quantified the generating resources that will be needed to meet the Climate Act mandates.  However, comparison of observed and projected energy production shows that they have overestimated energy production which means that more wind capacity will have to be developed and that the costs will necessarily be higher than they projected.  Now we have confirmation that the retirement of wind resources will occur which adds another layer of overestimated wind energy projection. 

There has not been any reconciliation between Integration Analysis projections and observations to refine projections.  This is in keeping with their complete lack of response to technical issues raised in comments on the Scoping Plan. 

Conclusion

The performance of the first wind farm in New York is considerably less than projected and now it is retiring after less than 25 years of operation.  The Madison Windpower Project Final Report found that the capacity factor 21% the first three years which was lower than the projected value of 23.3%.  Performance degraded over the period of record and was only 12% in 2023.  Over 18 years the facility produced 93.2 GWh less than projected.  This is another indication that the Scoping Plan projections for future wind operations were overly optimistic and means that the Scoping Plan costs for the net zero transition are too low.

This is just one more example of the flaws hidden behind a veneer of political slogans that claim all is well with the Climate Act.  Eventually it will become obvious that the Hochul Administration electric system “plan” is incompatible with reality.  It is past time to pause implementation and address the many issues that have been identified with the Scoping Plan.

Comments on DPS Definitions for Establishment of a Renewable Energy Program

On November 4, 2024, the Department of Public Service (DPS) staff proposed definitions for two key components of the 2040 target.   This post describes some of the comments submitted on the draft.  It is necessary to read between the lines of the electric industry comments to appreciate their concerns about the future electric system.

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.

Summary – if you don’t have over ten minutes to read the whole thing

The Climate Act has a target that all electricity must be generated by “zero-emissions” resources by 2040. DPS staff proposed a definition of “zero-emissions” in November 2024 nearly five years after the law was promulgated.  It is increasingly obvious that the Scoping Plan is inadequate for the task of implementing a “zero emissions” electric system. Both the electric grid operator and a consortium of electric utilities provided comments on the proposed definition that emphasized the need for a comprehensive plan that prioritizes electric reliability.  Environmental advocacy organization comments underestimate the reliability challenges and recommend changes that would hinder development of a reliable grid.  I believe that the Hochul Administration is at a crossroads, and it is not clear that they will change direction to a rational approach based on reality or continue the present path of ideological purity.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation. 

I believe that the biggest shortcoming of the Hochul Administration’s implementation of the Climate Act is the lack of a plan.  For example, to implement a transition to meet the mandate that all electricity must be generated by “zero-emissions” resources by 2040 it is first necessary to define “zero emissions”.  Amazingly, draft definitions were not proposed for over four years.  On November 4, 2024, the DPS staff proposal concerning definitions for key terms (Staff Proposal) in Public Service Law §66-p that finally defined “zero emissions”.  The Introduction of the Staff Proposal explains:

In this proposal, the Department of Public Service Staff (Staff) suggests interpretations of key terms in the provisions of the Climate Leadership and Community Protection Act (Climate Act), codified in Section 66-p of the Public Service Law (PSL), which directs the Public Service Commission (Commission) to establish a renewable energy program and design it to achieve particular targets. At issue in this proposal is the language of PSL §66-p(2)(b), which directs the Commission to establish a program pursuant to which, by the year 2040, the “statewide electrical demand system will be zero emissions.” Of particular note, neither of the terms “statewide electrical demand system” nor “zero emissions” are expressly defined in the Climate Act or in the PSL. This lack of statutory definition requires the Commission’s interpretation of these terms to ensure proper regulatory implementation.

This post describes some of the comments submitted on these definitions.

New York Independent System Operator (NYISO)

NYISO runs the electricity market and is “dedicated to planning a reliable grid of the future, leveraging open and fair electricity markets, and informing policymakers and stakeholders.”  They submitted their comments on January 21, 2025.  The NYISO frustrates me because they pull their punches when they file comments.  Rich Ellenbogen shares my frustration and sent me an email describing their filing that exemplifies my concern.  He wrote: “The NYISO is screaming between the lines of their filing again.  The filing is attached and addresses electricity reliability margins across the state”.  He commented on three of their comments.

NYISO comment on Page 4:

To achieve the zero-emission standard, significant quantities of new resources, which satisfy the zero-emission definition, and provide the necessary energy and reliability attributes, will be required to support a reliable electric system. Development, permitting, siting, and interconnection of existing and emerging zero-emission electricity supply will require significant capitalization over a relatively short period of time.

Ellenbogen Response:

Regarding the above statement, financing, siting, permitting, and interconnection will do nothing if the technologies don’t exist at scale to implement the plan.  At present, the necessary technologies don’t exist at scale or don’t exist at all, with the exception of nuclear which is a four-letter word in NY State.  You can’t buy and install Dispatchable Emission Free Resources (DEFR’s) that aren’t available and sufficient nuclear generation won’t exist at scale until well after the CLCPA mandated dates even if planning was started today.

NYISO comment on Page 5:

Overly restrictive compliance obligations could prevent emitting generators from operating to support system reliability or serving consumer demand and potentially force generators to retire before suitable replacement resources are available. Insufficient availability of electric generation could adversely impact public health, welfare, and safety.

NYISO comment on Page 6:

Electric system reliability margins are already close to minimum reliability requirements in certain areas across New York and are tightening. If these margins are totally depleted, the reliability of the grid would be at an unacceptable risk and power outages could disrupt normal life or negatively impact public health, welfare, and safety.  The NYISO’s 2024 Reliability Needs Assessment (“RNA”) identifies a reliability need beginning in summer 2033 within New York City, primarily driven by a combination of forecasted increases in peak demand, limited additional supply, the assumed retirement of the NYPA small gas plants based on state legislation, and assumed unavailability of generators impacted by the DEC Peaker Rule.

Ellenbogen Response:

A translation for the two statements above, simply put is: “If you don’t let us run the existing generation that we have and force us to shut them down to meet your standards of ideological purity, you won’t have any lights or electricity for anything else.  We are already running on fumes, and it is going to get worse.”

Why the NYISO can’t just come out and say what they mean without such subtlety is a disservice to the people of NY State.  No one wants to say outright how ridiculously bad the state energy policy is so everyone keeps beating around the bush and in the interim, the state is like a runaway train headed towards a collapsed bridge. 

The utilities aren’t doing a service for their ratepayers or themselves either.  I understand that they don’t want to run afoul of the state government and lose their certification, but they are the ones that are going to be turned into piñatas when this goes bad, which is inevitable.  It’s not a matter of if, just when.  Are people actually going to have to die before someone comes out directly and acknowledges how bad this energy policy is?

Joint Utilities

An ad hoc group of utilities also submitted comments.  The Joint Utilities are Central Hudson Gas & Electric Corporation, Consolidated Edison Company of New York, Inc. Niagara Mohawk Power Corporation d/b/a National Grid, New York State Electric & Gas Corporation, Orange and Rockland Utilities, Inc., and Rochester Gas and Electric Corporation. As Ellenbogen noted these companies face existential threats if they speak out too strongly in the politically charged New York environment because there are proposals to take them over and have the State operate them.  Even if the politicians don’t shut them down, the Hochul Administration certainly can punish the companies when their rate cases are decided.  Nonetheless, I agree that they are doing a disservice to their customers by not speaking out. Their comments on this proceeding are a step forward because they made recommendations that imply there are problems.

I was encouraged by the following statement because it aligns with my argument that there is no plan in place to implement the Climate Act:

The reliability of electricity in the state is of primary importance to the Joint Utilities. For the reasons set forth below, the Joint Utilities request that the Commission direct Staff to collaborate with the NYISO and the Joint Utilities to develop a comprehensive plan to achieve zero emissions generation to meet New York State’s demand by 2040 in a manner that ensures reliability of the electric system throughout the clean energy transition to a zero emissions electric system. This plan should address current supply and demand trends within the power sector. If the cessation of greenhouse gas-emitting generation post-2040 creates a large gap between supply and demand, the plan should also include strategies of how best to retain, manage and retire generation to maintain system reliability and resource adequacy.

It is important to read between the lines of this paragraph:

Clear guidance and decisive action are essential to advancing our state’s zero-emission targets while ensuring resource adequacy and affordability are not compromised. There are fewer than five years before the first target takes effect and only fifteen years to achieve zero emissions by 2040, so it is crucial to act promptly. From an electric planning, permitting, and construction perspective, the feasibility of this timeline will be significantly challenging.

My interpretation is that they are saying there isn’t clear guidance and decisive recommendations for action that ensure resource adequacy and affordability are not compromised.  I wholeheartedly agree. They also point out time is getting short to meet the electric sector targets.  When regulated companies with significant exposure to political retribution say “significantly challenging” they are really saying this won’t work!  The Joint Utility comments go on:

The Joint Utilities recommend that the Commission direct Staff to develop a clear roadmap that addresses future system needs, potential gaps in supply and demand and clear methodologies to characterize those gaps, clean energy technology readiness, sufficient access to generation to the extent gaps are identified, and resource attributes necessary for the reliable operation of New York’s electric system amid ongoing growth in intermittent renewable supply and electric demand.

I have been taught that failing to plan is planning to fail.  This comment is a clear indictment of the Scoping Plan and the transition implementation to date because it says that there is no comprehensive plan that addresses these concerns.  I endorse the Joint Utility recommendation that:

Given the potential for New York’s clean energy resources to fall short of demand, or suffer from delayed entry for various reasons, and the challenges associated with the commercial availability and maturity of new energy technologies, the Commission should require Staff to develop a plan for the development of incremental renewables, the retirement of non-compliant resources, and methodologies to address gaps between existing resources and the reliability needs of the system, while also ensuring that reliability and resource adequacy do not suffer.  Staff should also consider the development status and lead time of new and existing technologies from research and development to their commercial deployment. It is imperative to address these issues, set expectations and identify needs for the journey towards the 2040 zero emissions target.

The missing point is an explicit statement explaining if the Commission does not follow these recommendations, then there will be blackouts.  There is one other comment I want to highlight:

Lastly, the Coordinated Grid Planning Process (“CGPP”) confirms the conclusion of the NYISO and academic research that there is a large gap between supply and demand and “there is no consensus among CGPP participants about the technologies that could be deployed to meet the estimated 17GW need.” These factors are concerning, and it is imperative to incorporate these realities into the roadmap assumptions. While transitioning to a clean energy system, it is also imperative to ensure adequate generating resources are retained and available, regardless of technology, which is permissible because the Clean Energy Standard does not require the retirement of existing generators.

The large gap between supply and demand is referring to the dispatchable emissions-free resource (DEFR) issue that I discuss whenever I suggest a feasibility study is needed before any more money and effort is invested in what could be a false technology solution.  Note that the last sentence emphasizes that existing facilities should not be shut down prematurely. 

Environmental Advocacy Comments

Earthjustice, Sierra Club, the Alliance for Clean Energy New York, NY Renews, and Fossil Free Tompkins also filed comments.  I think that these organizations underestimate the challenge of meeting the large gap between supply and demand.  They submitted comments in June arguing that the December 2023 technical conference presentations had overestimated the magnitude of the gap.  In July I filed a comment  explaining that if anything, projections of the severity of the gap have been under-estimated because winds across large areas are correlated . Earthjustice and Sierra Club responded arguing among other things that “There is no reason to believe that wind speeds offshore of New York City, Long Island, and the Massachusetts Cape will be significantly correlated with land-based wind resources located in Upstate New York.”  I dropped the ball and have not responded to that documenting the results of an analysis released after their comments were filed that shows that New York onshore and offshore winds do correlate. 

I did publish an article describing a New York wind lull last September that shows that land-based wind resources do correlate with New York’s South Fork offshore wind project.  New York presently has 2,454 MW of wind capacity.  I analyzed a 192- hour period from 12 September 2024 hour 0000 to 19 September 2024 hour 2300. I found that the minimum wind capacity occurred on 13 September at hour 12 when a total of 0.2 MW of wind power was generated.  There were 96 hours representing half the period when the capacity of all the wind generation in New York was less than 5%.  All but one of the hours had a capacity factor of less than 20%.  Even the best was unimpressive.  The maximum wind capacity occurred on 19 September at hour 21 when 502 MW of wind power was generated, only 20.5% of the total capacity.  Because South Fork was in operation and included in the total, it is reasonable to assume that for at least 96 hours the wind speeds offshore were significantly correlated with New York land-based wind. 

The emphasis in the environmental organization comments on the zero-emission definition was ideological support of the strictest interpretation of “zero”.  They disagreed with pragmatic Department of Public Service recommendations and suggested that: “the Public Service Commission adopt a plain meaning interpretation of “emissions” that includes both greenhouse and non-greenhouse gases and interpret the “statewide electrical demand system” to include behind-the-meter resources that participate indirectly in jurisdictional markets.  Their suggestions make what I think is already impossible challenge even more difficult and expensive.

Conclusion

This post notes that both the NYISO and the Joint Utilities’ comments on the zero-emission definitions suggest that there will be consequences if there is no plan and recommend a re-assessment of the schedule.  I agree completely.

The environmental organizations who commented reiterated their ideological position that zero emissions of all pollutants is required and must occur as fast as possible to maintain the Climate Act schedule.  Those comments disregard all the indications that it is impossible,

The Trump Administration’s recent announcements, last summer’s acknowledgment that the 2030 electric sector goal would not be met, and the increasingly desperate comments by New York’s electric sector are all warnings to the Hochul Administration.  It seems to me that a pause to re-assess what can be done without endangering affordability and reliability could be proposed because of all the factors beyond New York’s control.

Ellenbogen asked whether people are going to have to die before someone comes out directly and acknowledges how bad this energy policy is.  I wish I was optimistic that this will not be the case but there is no evidence yet that the leadership of New York is willing to back off their ideological soapbox and admit the current Climate Act energy policy cannot work despite a plethora of evidence.