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.

Vermont Clean Heat Standard Lessons for New York

The Climate Leadership & Community Protection Act (Climate Act) could learn quite a bit from the experiences of Vermont and their Clean Heat Standard as documented by Robert Roper at his Behind the Lines Substack.  Roper did an overview of the Clean Heat Standard and a summary of the Public Utility Commission’s (PUC) long awaited Draft Clean Heat Standard Rule Companion Status Report that provide evidence that New York’s similar initiatives will run into the same problems he identifies.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 450 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% reduction by 2030. 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 Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation.

There are two relevant initiatives.  The CAC recommended an economywide cap-and-invest program. Plan that led to the New York Cap-and-Invest (NYCI) program that will “establish a declining cap on greenhouse gas emissions, limit potential costs to New Yorkers, invest proceeds in programs that drive emission reductions in an equitable manner, and maintain the competitiveness of New York businesses and industries.”  In the Legislature the New York Home Energy Affordable Transition Act, or NY HEAT that passed the last session but has not been signed is supposed to secure “affordable, clean energy for New York households.”

Vermont Clean Heat Standard

Roper’s overview of the Clean Heat Standard put together a “pocket guide” that describes what this law is supposed to do, how it’s supposed to work, and what it looks like it will cost to fully implement.  I recommend that you read the article for full details because Rober is a good writer that explains things well in an engaging manner.  I will quote from his article and compare to New York’s situation below.

Roper explains the origin of the Clean Heat Standard:

The Clean Heat Standard is an outgrowth of the Global Warming Solutions Act (GWSA), passed over the veto of Governor Scott in 2020. The GWSA mandated that Vermonters lower our greenhouse gas emissions to 26% below 2005 levels by 2025, 40% below 1990 levels by 2030 and 80% below 1990 levels by 2050. How we were going to do this, what it would cost, or if it were even possible the lawmakers who passed the GWSA did not know, but if we failed to meet these deadlines, they inserted a provision in the GWSA that gave literally anyone standing to sue the state at taxpayer expense.

As noted in the Overview the GHG emission reduction targets for the New York Climate Act are similar.  Like New York, the Vermont politicians assumed that the transition was only a matter of political will and that the details of how to get there would be a minor, easily resolved detail.  The Climate Act does not include the provision for lawsuits if the deadlines were not met.  Not to worry the Environmental Rights Amendment to the New York constitution will provide a similar basis for litigation.

Similar to New York’s Climate Action Council, the GWSA created a Vermont Climate Council that released their Climate Action Plan in December 2021.

This plan, released in December 2021, recommended that for the thermal sector of our economy (how we heat our homes and businesses, make hot water, and cook our food), which accounts for over 40 percent of our overall greenhouse gas emissions, that the legislature pass another law establishing a Clean Heat Standard.  The legislature did this in 2023 over Governor Scott’s veto with Act 18 — again not knowing what it would cost, how it would work, or if it were possible.

Roper describes the Clean Heat Standard:

In a nutshell, the Clean Heat Standard is a system requiring importers/sellers of heating oil, kerosene, propane, natural gas, and coal, to obtain (in most cases, especially for smaller dealers, this means buy) “credits” based on the amount of carbon released into the atmosphere when the fuels they sell are ultimately burned. According to the law, a carbon credit is defined as “a tradeable, nontangible commodity that represents the amount of greenhouse gas reduction attributable to a clean heat measure.” A “clean heat measure” is one of a dozen legally approved actions taken — by anyone — to reduce greenhouse gas emissions such as weatherizing a building or installing a heat pump.

Practically speaking, a carbon “credit” it is a financial instrument, much like a cryptocurrency, that a fuel importer/seller must obtain in order to legally sell their product(s) either by “mining” the credits themselves (performing clean heat measures) or buying them from a “Default Delivery Agent” (likely Efficiency Vermont) appointed by the state.

There are similarities to NYCI but significant differences too.  Both programs require compliance entities to obtain authorizations to emit amounts of carbon.  Affected Vermonters must earn those authorizations either themselves or buying them for someone else who performed the clean heat measures.  Affected New Yorkers buy the authorizations from the auction marketplace which is supposed to use the proceeds to fund clean heat measures.  New York’s proposed NY HEAT includes mandates to force electrification of home heating away from fossil fuels.  Both state approaches are intended to reduce emissions on a mandated trajectory consistent with their GHG targets.

In both States the nasty little detail of how many homes must be modified to achieve those goals is only now being addressed.  In Vermont “According to a taxpayer funded analysis done by The Cadmus Group for the Climate Council, in order to meet just the 2030 targets Vermonters will have to weatherize 120,000 homes, install 177,107 heat pumps, 136,558 heat pump water heaters, 14,992 advanced wood heating systems, and switch 21,086 homes to using biofuels before the end of the decade.” New York’s documentation for these numbers is buried in documents but in much less detail. In both cases the costs and where the money necessary to pay for them is unresolved.

There is a huge implementation issue for both states.  In Vermont:

How is the state even supposed to ensure and verify that all of these clean heat measures take place, calculate exactly how much greenhouse gas reduction will result from each unique measure so that each measure can be monetized into a tradable carbon credit value, assign ownership of the credits, and then establish a financial exchange where the creators of credits and the parties obligated to obtain them can buy and sell them while at the same time regulators track ownership and ensure compliance? When the legislature passed Act 18, they had no idea so handed off the task of figuring all that out to the Public Utilities Commission (PUC).

In New York, the unique Climate Act emissions accounting requirements means that the State must develop reporting and tracking mechanisms for emissions, develop an allowance system for ownership, and establish a financial exchange like Vermont.  In New York the assignment for this task was given to the Department of Environmental Conservation and the New York State Energy Research & Development Authority on a time frame years less than it took California to establish a similar program.

In my opinion based on years of experience with emissions accounting and reporting New York’s challenge is impossible on the mandated schedule but the Vermont approach is much worse.  Roper writes and I agree:

If that task sounds impossibly complicated, it is. In fact, Efficiency Vermont released a memo to the PUC on September 19, stating, “The complexity of these arrangements also give rise to concerns over the veracity of projects claiming credits and the rigor of their completion… Efficiency Vermont is unsure of the efficiency or efficacy of monetizing credits…. [and] that while compliance may ultimately be achieved after several years, the buying and selling of credits itself becomes grossly inefficient, asymmetrical, and potentially more costly for all parties.” Not an expression of confidence that this is going to work at all, let alone be cheap.

Costs

Roper writes:

Supporters of the Clean Heat Standard say we don’t know what it will cost, shouldn’t speculate, and that all indications so far are that the cost to implement the program will be minimal for consumers. This first position is misleading, and the second is demonstrably false.

As for not knowing what the Clean Heat Standard will cost, that’s only true if you’re looking for an exact price tag, which, of course, can’t be determined until the program’s rules are fully designed and approved. However, it is not difficult to get a ballpark figure with all of the data that has been collected and testimony taken over the three-plus years that this policy has been under consideration.

The excuse for not providing costs in New York’s Scoping Plan was we cannot give an exact price because of all the uncertainties.  The failure to provide a ballpark figure in New York is indicative of the likelihood that the costs are politically unacceptable.  There is no reason to believe that the New York cost experience will be markedly different than Vermont.

Roper documents how much money has been spent on implementation and concludes that “Given this level of financial and human resources engaged over this extended period of time the claim that we still don’t have enough information to know basically what the Clean Heat Standard will cost – not even a ballpark understanding – defies credulity.”  Inevitably the costs must come out, but in the meantime, here is a ballpark estimate:

According the newly released potential study done by NV5 through the Department of Public Service, the estimated incentive spending required to fund the number of clean heat measures necessary to meet the GWSA reduction mandates will cost about $3.3 billion over the first four years leading up to the 2030 target (and about $10 billion total to meet the 2050 target). To raise that much money off the sale of 200 million gallons of fossil heating fuel sold annually comes out to a just over $4 per gallon.

Roper goes on to flesh out more details of the implications of the Vermont initiative.  He describes who pays and who benefits.  Most importantly, who loses: “The biggest losers in this scheme are those who can’t transition away from heating with fossil fuels even if they want to because, for example, they can’t afford the upfront costs of doing so, can’t find the labor to do the work in a timely fashion, or their homes are logistically difficult or impossible to retrofit such as those living in mobile homes, older housing stock lacking open floor plans, or multi-unit apartment buildings.”  He closes this post to explain how this is supposed to be implemented.

PUC Clean Heat Status Report

Roper’s second post is a summary of the Public Utility Commission’s (PUC) long awaited Draft Clean Heat Standard Rule Companion Status Report.  I particularly like his description of the conclusion that the Clean Heat Standard is a dead end and recommend reading it.

As he has been writing for years the PUC concludes:

The Clean Heat Standard as currently conceived requires substantial additional costs and regulatory complexity above the funding needed to accomplish Vermont’s greenhouse gas emission reduction goals. For example, the Clean Heat Standard would require establishing a credit marketplace managed by what is likely to be a costly credit platform, the potential for fraud and market manipulation, the appointment of new or varied default delivery agents with administrative costs of their own, and the participation and regulatory engagement of hundreds of fuel dealers and other actors — e.g., companies and individuals that install clean heat measures — not currently or historically regulated by the Commission.

Our work over the past year and a half on the Clean Heat Standard demonstrates that it does not make sense for Vermont, as a lone small state, to develop a clean heat credit market and the associated clean heat credit trading system to register, sell, transfer, and trade credits. Because the Clean Heat Standard introduces these additional regulatory hurdles and costs, the Commission is considering other options to achieve Vermont’s greenhouse gas emission reduction goals for the thermal sector.

Given that the Clean Heat Standard won’t work what alternative was proposed?

[A] new thermal energy benefit charge on the sale of fuel oil, propane, and kerosene. Similar to the long-standing electric efficiency charge, the Commission would set the thermal energy benefit charge based on statutory criteria, including the need to provide sufficient funding to meet the Global Warming Solutions Act requirements.

Roper describes this as:

A straightforward carbon tax on home heating fuels. Strip away the Rube Goldberg Carbon Credit contraption, and that’s what you’re left with: a direct charge on your oil, propane, and kerosene home heating bill. And to “sufficiently fund” the number of clean heat measures necessary to meet the Global Warming Solutions Act mandates, that carbon tax will necessarily be massive. In the billions massive. Of course, per the report, “The Commission is not providing a cost estimate at this time.” Uh huh. I guess give them another eighteen months.

The NYCI approach is similar, it is nothing other than a disguised carbon tax.  In fact, given the uncertainties associated with devising a “declining cap” that appropriately accounts for all the uncertainties associated with renewable resource deployment, the necessity for new technologies to account for weather-dependent resource limitations, and the regulatory infrastructure necessary to implement the cap-and-invest auction and tracking system I believe a New York carbon tax is a better option.  However, in both Vermont and New York the political optics of another tax and one that will have to be this large, makes admitting this is simply a tax untenable. 

I love Roper’s closing comment on the fact that this has always just been a tax:

Now if lawmakers take the PUC’s recommendation to implement this direct tax/fee/surcharge, that plausible deniability (implausible really, but hey, they’ve been sticking to it, bless their hearts!) is gone. Do they have the guts — or a truly principled commitment to saving the planet — to face the voters with that proposition? It’s time to separate the true believers in catastrophic, anthropogenic climate change from the virtue signaling panderers!

Conclusion

It is not surprising how many similarities there are between the Vermont approach and that of New York even though the programs are packaged differently.  At the end of the day both states will face enormous costs, and their funding approaches are no more than disguised carbon taxes.  The only question left is which state will reach the inevitable reality wall when the citizens finally understand that politicians should not make energy policy.  The current approach in both states assures that affordability and reliability will suffer.  Roper’s work describes why this is happening in Vermont and New York will fare no differently unless changes are made soon.

Personal Comments on the Allocation of New York Cap-and-Invest Proceeds

The Scoping Plan outline of implementation options for the Climate Leadership & Community Protection Act (Climate Act) suggested a market-based program as an economy-wide strategy.  This effort is known as the New York Cap-and-Invest (NYCI) program.  Last month I published an article describing the New York State Department of Environmental Conservation (DEC) and the New York Energy Research & Development Authority (NYSERDA) “proposed framework for guiding the allocation of these funds and identification of potential areas that could receive investments.” DEC and NYSERDA also posed a series of questions seeking public feedback. This article describes the comments I submitted in response.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 450 articles about New York’s net-zero transition.  I worked on every market-based program from the start that affected electric generating facilities in New York including the Acid Rain Program, Regional Greenhouse Gas Initiative (RGGI), and several Nitrogen Oxide programs. I follow and write about the RGGI and New York carbon pricing initiatives so my background is particularly suited for tNYCI.   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% reduction by 2030. 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 Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation.

Cap-and-Invest

The CAC’s Scoping Plan recommended a market-based economywide cap-and-invest program.  The program works by setting an annual cap on the amount of greenhouse gas pollution that is permitted to be emitted in New York: “The declining cap ensures annual emissions are reduced, setting the state on a trajectory to meet our greenhouse gas emission reduction requirements of 40% by 2030, and at least 85% from 1990 levels by 2050, as mandated by the Climate Act.”  In addition to the declining cap, it is supposed to limit potential costs to New Yorkers, invest proceeds in programs that drive emission reductions in an equitable manner, and maintain the competitiveness of New York businesses and industries.  That is the theory, but I have doubts whether it will work and others do too.

Late last year DEC and NYSERDA released the pre-proposal outline of issues that included a long list of topics.  The Agencies said that they were “seeking and appreciate any feedback provided on these pre-proposal program leanings to inform final decisions in the State’s stakeholder-driven process to develop these programs.”  In a post describing my comments I provided additional background information and my concerns.  In late June I described my letter to the editor of the Syracuse Post Standard that argued that the delays were primarily due to staffing issues.  There has not been any substantive response to any comments submitted to date.

Comments

The request for comments asked for thoughts about how the auction proceeds should be invested.  I think that they are putting the cart before the horse because no vetted path to zero emissions has been identified.  In my comments I described the following tradeoff challenges that must be resolved if NYCI is to succeed. 

Fundamentally, there are political thresholds that limit how much money can be raised by NYCI before the electorate rebels, but investments must be sufficient to fund emission reduction projects to achieve the aspirational Climate Act schedule.  This has not been acknowledged in the NYCI implementation process.  Danny Cullenward and David Victor’s book Making Climate Policy Work describe this problem.  They note that the level of expenditures needed to implement the net-zero transition vastly exceeds the “funds that can be readily appropriated from market mechanisms”.  That observation and the conclusion that New York is going to have to fund alternative technologies means that emission reduction investments should be a priority for NYCI revenues.  However, there are competing priorities for funds including investments to advance equity and climate justice, funding for programs to reduce costs for those least able to afford higher energy prices, and funding to develop the new technology necessary for the zero-emissions electric grid.

These tradeoffs can only be resolved if there is a plan in place that is based on feasibility studies.  Unfortunately, there is nothing in place that will provide that information in a timely manner. The sources that are responsible for compliance with NYCI have very few options for on-site control so must rely on somebody else to make the investments for zero-carbon emitting resources to displace their operations for emission reductions.  The costs for those investments and market mechanisms for the required investments are unknown. In addition, it is acknowledged that to reach zero-emissions new technology must be developed and deployed.  All these issues should be addressed before NYCI implementation continues.

Proponents of the cap-and-invest approach admire the NYCI feature that “ensures annual emissions are reduced”.  However, the technological challenges of the transition must be resolved and adequate investments for the transition must be provided to achieve emission reductions.  Furthermore, the NYCI allowance cap trajectory means that resolution of those issues is further constrained.   If the displacement technologies are not deployed in a timely fashion, then the only compliance option left for the affected sources is to reduce or stop operations or cease sales of fossil fuels.  That could result in an artificial energy shortage.

Conclusion

The Climate Act and the implementation programs thus far proposed are risky.  I identified problems and tradeoffs that must be resolved before NYCI implementation continues.  While there are some hints that the ramifications of an unreasonable and unachievable energy transition are becoming so evident that they cannot be ignored, those issues should be resolved before NYCI implementation continues.  The NYCI program has a long way to go before New Yorkers can be assured that implementation will not do more harm than good.

Ultimately, any market-based program intended to reduce GHG emissions is a tax on CO2 emissions. Ron Clutz found a relevant political cartoon for a similar program in Canada that applies to NYCI.

Future Energy Summit Wrap Up

On September 4-5, 2024, the Hochul Administration hosted a Future Energy Summit. I described my initial thoughts on the Summit, followed up with a second pre-meeting post, and did a first impressions post-meeting article.  I also described the pushback by anti-nuclear activists against the Summit focus on the potential for nuclear power.  This post wraps up my thoughts on this meeting.

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 450 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% reduction by 2030. 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 Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation.

State Summit Summary

On September 11, 2024, NYSERDA Events sent an email to attendees of the Summit.  I think it gives a good summary of the Hochul Administration’s expectations.  I quote the letter below with my annotated comments.

The first two paragraphs provide overview information:

Thank you for attending the Future Energy Economy Summit. We hope you found the convening to be informative in exploring how advanced emissions-free technologies can play a key role in supporting renewable energy and economic development while accelerating progress toward a zero-emission electricity system. 

A recording of the Summit has been posted to the Summit website. While the Summit discussions were robust and the opportunities are exciting, there is considerable work ahead.

In my opinion, the suggestion that there was a discussion is misleading.  No speakers who have openly questioned the narrative were invited to participate, no utility or the NYISO participated, and the only way to submit questions was via a networked chat feature that ensured that no controversial questions were raised. 

The important part of the email listed the following key next steps:

Complete the ongoing Public Service Commission review of the Clean Energy Standard (CES) by early 2025 and advance key actions to accelerate and expand New York’s large-scale renewable energy industry, focusing on deployment goals, interconnection reforms and the timely implementation of the RAPID Act for expedited environmental reviews and permitting of major renewable energy and electric transmission facilities.

This description of the PSC review of the Clean Energy Standard could be problematic.  The CES is just one component of the programs needed to achieve the Climate Act mandates.  The Hochul Administration Scoping Plan excluded costs of the CES in its cost-benefit analysis.  As a result, they have never admitted what the total costs of Climate Act implementation could be.  This statement could be a similar gambit to hide costs and other problems.  I think I speak for just about everyone outside the Administration when I say we want to know the total costs to meet the Climate Act mandates and not a subset of costs from different regulations and laws.  If the PSC review only addresses the CES costs, then the citizens of New York will be shortchanged again.

Advancing key actions to “accelerate and expand New York’s large-scale renewable energy industry” ignores the fact that there hasn’t been a feasibility study to show it is possible.  The Climate Act is a political construct based on the premise that implementation is only a matter of political will.  Avowed Climate Act author Robert Howarth continues to misinform the public by saying that “We can meet all of the energy needs of New York with solar, with hydro and wind and appropriate (energy) storage.’’  The Scoping Plan flatly contradicts that statement,  the New York Independent System Operator is calling for a not yet commercially available dispatchable emissions-free resource (DEFR) in its future resource projections, and the Public Service Commission ‘Zero Emissions by 2040’ proceeding acknowledges this need.

Maximize leverage of federal programs by applying for relevant funding opportunities for economic development and next generation emissions-free energy technology planning and deployment.  

Given the availability of federal funding for advanced nuclear projects the Summit discussed the possibility those funds could be used In New York.

Advance Public Service Commission action on the pending ‘Zero Emissions by 2040’ proceeding that is investigating technologies that support the 2040 zero-emissions electricity system target established through New York’s Climate Act.

As noted previously, this proceeding directly contradicts the suggestion that solar, hydro, and wind with energy storage are sufficient for the future electrical energy system.   The Summit is another acknowledgement that DEFR is needed.  Advanced nuclear designs are a leading contender for future DEFR which explains why it was featured at the Summit and why there is activist pushback on the need for DEFR itself.

Solicit industry feedback on the draft Advanced Nuclear Technologies Blueprint, and finalize the draft Blueprint by the end of this year. To review the draft Blueprint click here, and to submit comments, please click here;

I have a couple of thoughts about this Blueprint.  They are asking for “industry” feedback which suggests that they want technical commentary on their ideas.  I have always thought that the Summit was mostly a referendum on the deployment of nuclear.  I predict that there will be massive letter writing campaigns organized in response to the blueprint comment period to try to influence this decision despite the request for industry feedback.  Already the anti-nuclear letters to the editor have started showing up.  My other observation is that the comments are due in November so any decisions made will be after the current election cycle.

Ensure that the forthcoming State Energy Plan appropriately considers the role advanced emissions-free technologies can play in the State’s move to a deeply renewable electric grid and capitalization of programs that will expand the State’s economy.

The State Energy Plan is very important for the future economy of New York.  If done properly it will include a feasibility study.  If a feasibility study correctly addresses costs, technological considerations, and the risks of relying on weather-dependent resources, then it will show that a major reassessment of the Climate Act mandates, and schedule are necessary. 

We look forward to continuing this discussion and appreciate your participation at the Future Energy Economy Summit.

My Impressions

Before the summit I thought that the overarching rationale was to address concerns that have been raised about the lagging schedule and lack of cost information.  Two of the five panels addressed nuclear power, so it appeared that the Hochul Administration was attempting to gauge public opinion on that option.  The organizers went to great lengths to control who attended and did not announce who was on the panels until just before the meeting.  I also thought that a primary reason to hold the meeting in Syracuse was because of the presence of three nearby nuclear generating plants that would provide a visible demonstration in favor of nuclear power.

I did a quick summary after the summit.  Governor Hochul showed up to kick off the summit and the point was frequently made that it was her idea.  There was no substantive response to the schedule and cost issues.  Nuclear was an emphasis point and I remain convinced that the Hochul Administration is attempting to gauge public opinion on that option.  A draft Advanced Nuclear Technologies Blueprint was announced that they plan to finalize by the end of this year.  I have never seen so much security around an energy meeting but there were no incidents even though there was a demonstration in favor of nuclear power and another against nuclear power outside the hotel.  Surprisingly there was not any kind of demonstration from the local nuclear unions.  I believe the reason for having the meeting in Syracuse was to emphasize the importance of reliable electric power for the Micron chip fabrication plant and other industries.

Conclusion

Only time will tell whether the Summit was an honest attempt to address the unmistakable implementation issues being observed or it was timed and motivated for political gain.  At some point reality must be addressed.  Energy policy dictated by politicians and ideologues is not in the best interests of society.  The Climate Act is a vivid example of a well intentioned course of action that will do more harm than good.  It is time for an honest and open assessment of the plans and schedule proposed.

NYISO Resource Outlook Dispatchable Emissions-Free Resource

A recent article of mine summarized analyses describing a new category of generating resources called Dispatchable Emissions-Free Resources (DEFR) necessary for a future grid that depends upon wind, solar, and energy storage resources. Most analysts of the future New York electric system agree that new technologies are necessary to keep the lights on during periods of extended low wind and solar resource availability.  This article describes Appendix F – Dispatchable Emission-Free Resources in the New York Independent System Operator 2023-2042 System & Resource Outlook (“Outlook”). 

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 450 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% reduction. Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and a requirement that all electricity generated be “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 Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation.

Dispatchable Emissions-Free Resources

In my Compendium of DEFR Analyses I summarized  published posts describing DEFR that is highlighted as a concern in the NYISO Outlook.  I described six analyses describing the need for DEFR: the Integration Analysis, New York Department of Public Service (DPS) Proceeding 15-E-0302 Technical Conference, NYISO Resource Outlook, Richard Ellenbogen, Cornell Biology and Environmental Engineering, and Nuclear New York. 

The Overview in Appendix F – Dispatchable Emission-Free Resources describes the reason DEFR is needed:

Numerous studies have shown that a system comprised of intermittent renewable energy resources and short-duration storage (i.e. 4 and 8-hour capacity duration) that cycle daily can economically meet demand in most hours across a year.

Importantly NYISO is responsible for meeting demand at all times.  Most of the time it is easy but there are times when it is not:

However, due to the seasonal mismatch in electricity demand and weather dependent production from wind and solar resources, there remains a significant amount of energy that must be shifted from the low net load intervals of the spring and fall seasons to the peak load times during the summer and winter months, as discussed in Appendix E: Renewable Profiles and Variability.

I described Appendix E previously.  The data presented in Appendix E show that there are frequent periods when all the wind and solar resources are expected to provide much lower output than their rated capacity.  It appears that planners must, at a minimum, account for a 36-hour period when all the land-based wind, offshore wind, and solar combined provide less than 10% of their rated capacity.  The Overview goes on:

Advances in technological, economic, and modeling approaches are needed to better quantify and characterize the seasonal energy gap that remains to be served after the coordinated economic dispatch of renewables and storage resources. The NYISO seeks to improve the representation of this fleet segment in each of its successive study, while understanding that characterization of emerging technology implementation pathways can introduce its own uncertainty into the model. The NYISO continues to recognize that there is a need for supply beyond renewables and storage resources that can provide dependability supply during the summer and winter peak periods and when the output of renewable resources is low.

In the remainder of this article I will summarize the different sections of Appendix F – Dispatchable Emission-Free Resources.

Technologies

Appendix F in the Outlook evaluates three DEFR options that they believe represent the most likely viable approach but concede that there still are concerns even with these:

While DEFRs represent a broad range of potential options for future supply resources, two technology pathways being discussed as potential options for commercialization are: 1) utilization of low- or zero-carbon intensity hydrogen (typically generated by electrolysis derived from renewable generation) in new or retrofit combustion turbine or fuel cell applications or 2) advanced small modular nuclear reactors, which are currently seeking approval from the relevant regulatory bodies to design and operate these resources. Currently, both technologies have shown limited commercial viability on the proof of concept. Even assuming that they are commercially viable, there remains significant work in the implementation and logistics that must be overcome to economically justify transitioning the dispatchable fleet to some combination of new technologies in the next 15 years. Long-duration energy storage could potentially serve in the role of the modeled DEFRs in the Outlook. In many respects, long-duration energy storage closely mimics various hydrogen production and conversion pathways. Long-duration energy storage adds to load in many hours, similar to electrolysis production of hydrogen. However, a notable difference is that electrolysis production of hydrogen has a lower round-trip efficiency when injecting energy into the system compared to other long duration energy storage technologies under development.

I have a concern about these pathways.  Hydrogen and advanced nuclear both “have shown limited commercial viability on the proof of concept”.  Commercial viability is particularly important in New York’s deregulated environment because the State must entice some developers to risk an enormous amount of money to provide the necessary resources.  Consider that “there remains significant work in the implementation and logistics that must be overcome to economically justify transitioning the dispatchable fleet to some combination of new technologies in the next 15 years”. As a result, I think the State is going to find it very difficult to convince anyone to take on the risk of either technology.    

In its description of DEFR option Appendix F also notes “Understanding that many aspects of these technologies are currently unknown, and their capabilities and characteristics could change as more experience is gained, there is no standout leader among the options”.  It goes on to conclude that “that a combination of resources and approaches will be needed to serve the role of the DEFR fleet”. 

The Resource Outlook provides projections for future generating resources, so it needs to include some technology options.  To fulfil this need and consider the uncertainties, the Outlook “modeled several generic DEFRs to represent the range of potential capital and operating costs. In particular, the Low Capital/High Operating cost (LcHo) and High Capital/Low Operating cost (HcLo) DEFRs modeled in this Outlook are informed primarily by hydrogen and nuclear technologies, respectively.” 

Capital and Operating Costs

The models that NYISO uses to project future generating resource requirements necessarily incorporate costs.  The capital and operating cost DEFR labels refer to high and low values but those are relative costs.  This section of Appendix F provides some indications of costs but does not include expected costs to the consumers in the report.  I think this information is very important, so I plan to return to this topic in a future post.

Because DEFR technologies are still in development the NYISO cannot use historical cost data.  Instead, they used information from six different sources to estimate costs.  The results are presented in the two following figures.

Figure F-1: Generator Capital Cost vs. Variable Operating & Maintenance, Fuel, and Emissions Costs

Figure F-2: Generator Capital Cost vs Fixed Operating & Maintenance Costs

I have also included a graph of Dispatchable Emission-Free Resources: 2040 Capacity and Generation from the NYISO Public Information Session presentation on 8/8/24

For what it is worth the following table provides values for the DEFR costs from these three figures.  As noted, I will try to use these numbers to provide cost estimates in the future.  Regrettably the NYISO report does not provide specific numbers.

DEFR Cost Considerations

This section in Appendix F presented some of the factors that must be addressed when considering costs.  It explains that “since DEFRs are a developing technology, the first units built will likely be more expensive compared to similar DEFRs built thereafter”.  The Outlook used capital costs representing a mature deployment and “first-of-a-kind costs are not explicitly included as assumed cost components in this study”.  As the Outlook points out this means that “the costs for DEFRs in this Outlook are likely to be below the actual costs of the first DEFRs built on the system.” 

The Outlook points out that nuclear small modular reactors (SMRs) are a “developing technology and therefore, have varying approaches to their design”.  The theory is that “SMRs have the potential of reducing cost through the development and use of uniform designs”.   Although this will lower capital costs capital costs will still be higher than other technologies.  The expectation for DEFRs is that they will have low operating times and will ramp up and down.  The Outlook notes:

Like large-scale nuclear power plants, SMRs can mitigate the risk of high capital costs with lower operating costs and operating with high utilization rates. In other words, it is optimal for an SMR to consistently operate at 100% power to take advantage of its low operating cost. This has the potential to conflict with the notion of DEFRs being used for their ability to dispatch up and down based on variability in the load. The disconnect between a DEFR’s purpose and an SMR can be bridged by pairing the reactor with a behind-the-meter, dispatchable load. The SMR can remain at 100% power, while the behind-the-meter load dispatches up or down to effectively fluctuate the injection onto the grid, as needed.

Unsaid is the obvious alternative that if SMT nuclear is viable then it could be used to replace renewables rather than just provide backup support.  Nuclear energy generates zero-emissions electricity, provides firm power that does not require supplemental ancillary transmission support, has low land-use requirements, and requires less transmission development than wind and solar.  Going all in for nuclear would not eliminate the need for a peaking power source but it may be possible to use hydro for that purpose.  In a rational world keeping existing dual-fueled peaking plants available for this purpose would be an option too.

The Outlook also addresses hydrogen:

Hydrogen-burning combustion turbines or combined cycle units have effective cost mitigation strategies as well. To minimize hydrogen transport costs, the electrolyzer can be sited at the same facility as the resource. This eliminates the need for using an expensive hydrogen pipeline to import the hydrogen from elsewhere in state or even out of state. Additionally, as fossil fuel burning combustion turbines and combined cycle units retire, their assets can be repurposed and retrofit to burn hydrogen as a fuel instead. This has the potential to be less expensive than building a brand-new resource since many elements of the combustion turbine or combined cycle power plants can be reused with limited modification.

One of the more difficult electric system reliability problems is specifical considerations for New York City (NYC).  Specifically, there is a reliability requirement for in-city generation.  The 1977 NYC blackout was caused by transmission shutdowns and the inability of generating stations within the city to supply necessary load.  The reliability load specifies how much in-city generation must be available to replace the loss of transmission power.  I bring this up because this issue has not been discussed regarding DEFR.  There will have to be DEFR resources in NYC and if hydrogen is the chosen technology, then hydrogen will have to be stored within the city.  Hydrogen is a colorless, odorless, explosive gas that is hard to store.  What could go wrong.

Operating Parameters

This section describes how some technical parameters are defined and used.  The heat rate parameter is a measure of production efficiency, the lower the heat rate the less energy used to produce electricity.  Lower heat rate units operate more often.  The text lists the values used in the analysis.

There also is a discussion on the need for DEFRs to meet specific requirements such as the ability to be dispatched to follow load.  Existing nuclear power technologies in the US have not been used to provide this service.  The discussion describes how this service could be provided in future nuclear power designs.  It also notes that there is a possibility that future reactors could be re-fueled while online which is much different than today’s reactors that require significant outages to re-fuel.

Conclusion

The NYISO Resource Outlook chapter on DEFR provides further proof that new technology is in fact necessary for the future zero-emissions New York electric system mandated by the Climate Act.  The Hochul Administration has not provided cost estimates for the overall transition.  I believe that DEFR costs will be a particular problem because this resource is used as rare backup.  This report provides some cost information but not enough to estimate expected costs.

Personal Comments on Clean Energy Standard Biennial Review

The Climate Leadership & Community Protection Act (Climate Act) requires that the Public Service Commission (PSC) issue a review for notice and comment that considers “(a) progress in

meeting the overall targets for deployment of renewable energy systems and zero emission sources, including factors that will or are likely to frustrate progress toward the targets; (b) distribution of systems by size and load zone; and (c) annual funding commitments and expenditures.”  In July Clean Energy Standard Biennial Review Report (Biennial Review) was released in response to this requirement and this post describes my comments to the PSC.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 450 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 and Background

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% reduction by 2030. 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 Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation.

Biennial Review Summary

The Introduction to the Biennial Review is a good summary of the report.

The Climate Leadership and Community Protection Act of 2019 requires that the Public Service Commission (Commission) issue a review for notice and comment that considers “(a) progress in meeting the overall targets for deployment of renewable energy systems and zero emission sources, including factors that will or are likely to frustrate progress toward the targets; (b) distribution of systems by size and load zone; and (c) annual funding commitments and expenditures.” This Report serves to inform the Commission’s review. It summarizes the progress made toward the renewable energy and zero emission goals set by the CLCPA since the establishment of New York State’s Clean Energy Standard (CES), assesses what remains to be done to achieve those goals, presents policy options and proposals, and invites comments from stakeholders and the public on these or any other matters raised in this Report. The Report focuses in particular on New York’s goal to obtain 70% of New York’s electricity from renewable sources by 2030 (the 70% goal) and the related goal of 9 gigawatts (GW) of offshore wind by 2035.

My Comments

A comprehensive review of the Biennial Report would have been an enormous effort, so I confined my review to a limited number of issues. The Biennial Review concedes that the 2030 goal to achieve 70% of New York’s electricity from renewable sources is unlikely to be achieved.  However, it does not acknowledge that the issues that are causing delays may not be resolved anytime soon.  Public Service Law §66-p(4) provides an exemption that enables a delay of the Climate Act targets but no one has defined the safety valve criteria. 

There are a couple of broad concerns.  An overarching issue with Climate Act implementation is the lack of a comprehensive a feasibility study.  The recent announcement of the long-delayed State Energy Plan offers hope that there will be feasibility analyses from that effort, but that will not be available until late next year.  In the meantime, the Biennial Review should address whether building as much wind and solar as possible as fast as possible is appropriate.  There is another enormous risk that should be addressed.   I maintain that the differences between resource planning for the existing system and the proposed weather-dependent electric energy system introduce reliability risks that need to be addressed now.

There has never been a clear and transparent accounting of costs.  It is long past time for the impacts on rates to be provided.  I recommended that this report should address consumer costs

Finally, I commented on a couple of potentially disingenuous approaches used in the Biennial Review.  The emphasis on the Clean Energy Standard underestimates the challenge of meeting all the Climate Act mandates.  In the Scoping Plan the unique use of the Reference Case gave misleading cost impact results.

Implications of Progress Issues

The Biennial Review concedes that the 2030 goal to achieve 70% of New York’s electricity from renewable sources is unlikely to be achieved.  However, it does not acknowledge that the issues that are causing delays may not be resolved anytime soon.  Section 5 provides a speculative path to the 2030 70% goal.  Table 8 summarizes the outlook.  There is a projected gap of 42,145 GWh or 37% of the 70% goal. 

The remainder of Section 5 proposes new development estimates and CES reform options that can accelerate progress.  However, while there is an assessment of major factors that have affected and will likely continue to affect progress towards the goals, there is no acknowledgment that those factors are likely to continue to be issues.  It concludes that there is a potential path so the 70% goal could be met by 2033 but does not address how building as much wind and solar as possible as fast as possible will ensure a reliable system.  It is time to consider a reassessment of the schedule and goals to develop a realistic revised schedule.

The introduction to the Biennial Review mentions New York Public Service Law  § 66-p (4) “Establishment of a renewable energy program” that includes safety valve conditions for affordability and reliability that are directly related to the zero emissions resource.   § 66-p (4) states: “The commission may temporarily suspend or modify the obligations under such program provided that the commission, after conducting a hearing as provided in section twenty of this chapter, makes a finding that the program impedes the provision of safe and adequate electric service; the program is likely to impair existing obligations and agreements; and/or that there is a significant increase in arrears or service disconnections that the commission determines is related to the program”. 

The criteria used to define “safe and adequate electric service” and “significant increase in arrears or service disconnections” should be defined in the Biennial Review.  This is necessary so that there is a clearly defined standard for determining the need to conduct the hearing included in § 66-p (4) that would form the basis for a schedule revision.

Feasibility

The Biennial Review is supposed to assess what remains to be done to achieve transition goals and present policy options and proposals, However, the Review does not confront the biggest problem – feasibility.  At this time, the State has not presented any credible plan demonstrating that in the early to mid-2030s there will be sufficient reliable electricity generation to meet the demands anticipated from both current uses, from the expected addition of new large sources of load like chip fabrication plants and data centers, and from the load added as part of electrification decarbonization strategies.  Indeed, the State has admitted that, in lieu of a definitive plan, it relies instead on a speculative hope for new technologies not yet invented or deployed at scale to bridge the large difference in electricity supply that will inevitably arise from the conflicting mandates.  The State can point to no Demonstration Project showing how its hope for a de-carbonized electrical grid can succeed.  Clearly this should be addressed in the Biennial Review.

I am particularly concerned about the unacknowledged inherent risks of relying on weather dependent resources to provide a substantial portion of future electric power in New York.  Wind and solar are inherently intermittent – the sun does not shine at night and the wind does not always blow.  Renewable resource 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.  All the solutions proposed to deal with solar and wind intermittency have failed to acknowledge that weather dependency makes the reliance on correlated resources very risky.  The draft Biennial Review unacknowledged risk is that whatever criteria are used to determine how many resources are necessary to provide an affordable and practical system to meet the worst-case weather induced wind and solar resource lull there will be a high probability that eventually there will be a more extreme case that exceeds the criteria.  When that happens, rolling blackouts are inevitable and there is risk of a larger and more severe blackout.

Consumer Costs

On July 16, 2024 the New York State Comptroller Office released an audit  of the New York State Energy Research and Development Authority (NYSERDA) and Public Service Commission (PSC) implementation efforts for the Climate Act titled Climate Act Goals – Planning, Procurements, and Progress Tracking (“Comptroller Report”).  The Comptroller Report included the following key recommendation:

Conduct a detailed analysis of cost estimates to transition to renewable energy sources and meet Climate Act goals. Periodically update and report the results of the analysis to the public.

The Biennial Review should directly respond to this recommendation.  In an interview with Susan Arbetter NYSERDA’s Doreen Harris said the  “The proceeding that is before the PSC is intended to ‘specifically they look at all this in the context of consumer cost”.   If the Biennial Review is part of the Proceeding, then costs should be included.  However, consumer costs are not included in the report.

Disingenuous Approaches

The Introduction to the Biennial Review includes the following description in the contents of each section: “Policy options and proposals under consideration in this Report are limited to the Clean Energy Standard (CES) itself.”  The problem is that the CES includes a 9-gigawatt (GW) goal for offshore wind by 2035, a 6 GW by 2025 goal for distributed solar, and a 3 GW energy storage resources goal by 2030.  Those only cover a portion of the resources needed to achieve Climate Act goals.  I think I represent most New Yorkers when I state that the Biennial Review should include all aspects of the transition not a subset of programs.  Choosing subsets of related programs is inappropriate because we want to know the total costs to achieve all mandates and all challenges that must be addressed to meet the targets.

There is a related CES issue.  In Section 5.1 on page 53 of the Biennial Review the document states: “In all other respects, this Report’s base case reflects the Reference Case presented in NYSERDA’s Integration Analysis”.  There is a cost related problem relative to the Scoping Plan “Reference Case” that I have described in a blog post and in my comments on the Draft Scoping Plan. I noted that the Integration Analysis modeling scenarios used an unusual approach.  In this type of analysis policy scenarios are typically compared to a “business-as-usual” future without any policy components.  However, the Integration Analysis uses a Reference Case that is different than a typical business-as-usual future scenario because it includes already implemented policies.  In the Scoping Plan this unique approach was used to suggest the costs of inaction are more than the costs of action, but that claim did not include all the costs to achieve the Climate Act mandates because it excluded the CES components.  Everyone outside the Hochul Administration wants to know the costs to achieve the Climate Act, not some subset of component programs.

Discussion

The draft Biennial Review does not address fundamental issues.  It does acknowledge that the schedule is in danger but does not concede there are fundamental problems that may not be resolvable.  The presumption that a law written by ideologues with a schedule determined for political ends must be met no matter what needs to be laid to rest.  A feasibility analysis that addresses the fundamental technology and implementation schedule issues is the only rational way forward.

As it stands the draft Biennial Review is another political document that fulfills a tortured interpretation of the Climate Act requirements.  It apparently parses out different components of the implementation efforts.  All the transition components must be considered, and the citizens of New York deserve to know the costs for the entire implementation effort.

It is time to confront overarching issues.  There are technological issues related to the Integration Analysis strategies for a zero emissions electric grid by 2040.  Until the challenges associated with dispatchable emissions-free resources are resolved then it is inappropriate to shut down any existing fossil-fired generators.  Relying on weather-dependent resources introduces significant reliability risks that have not been acknowledged.  Until this risk is understood better, it is inappropriate to continue to just build as much wind and solar as possible and hope it works out.

The recently  announced draft Advanced Nuclear Technologies Blueprint is important for two reasons.  It is an appropriate outline for a feasibility study for one of the transition components that should be expanded to all technologies.  Secondly, it is recognition that nuclear is the only existing technology that has a proven record of significant carbon reductions.  The implications of this blueprint should be incorporated into the Biennial Review.

Conclusion

Only time will tell if the Biennial Review is only a check the box response.  While there are some hints that the ramifications of an unreasonable and unachievable energy transition are become so evident that they cannot be ignored, the draft Biennial Review does not confront the problems sufficiently.  Public Service Law §66-p (4) provides for a potential delay of the Climate Act schedule and it was mentioned in the draft.  In my opinion, if the Hochul Administration is truly committed to addressing the problems identified in the draft, then this requirement must get more attention in the final Biennial Review.

The Math Does Not Support New York’s Climate Plan

I frequently collaborate with Richard Ellenbogen regarding issues related to the Climate Leadership & Community Protection Act (Climate Act).  This post describes his recent blog article The Math Does Not Support New York’s Climate Plan published at the Empire Center for Public Policy.  He explains why the numbers show that the Climate Act implementation plan is doomed to failure based on his experience adopting renewable and lower-emission combustion technologies in his home and business.  This post condenses his findings and publicizes his work.

Ellenbogen is the President [BIO] Allied Converters and frequently copies me on emails that address various issues associated with the Climate Act. I have published other articles by Ellenbogen including a description of his keynote address to the Business Council of New York 2023 Renewable Energy Conference Energy titled: “Energy on Demand as the Life Blood of Business and Entrepreneurship in the State -video here:  Why NY State Must Rethink Its Energy Plan and Ten Suggestions to Help Fix the Problems” and another video presentation he developed describing problems with Climate Act implementation.   He comes to the table as an engineer who truly cares about the environment and as an early adopter of renewable technologies going back to the 1990’s at both his home and business two decades ago.

Overview and Background

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% reduction by 2030. 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 Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation.

Introduction

Ellenbogen introduces the problem:

I have been analyzing the numbers coming out of Albany regarding the Climate Leadership and Community Protection Act (CLCPA), New York’s plan to drastically reduce the use of fossil fuels, for over five years now.  

I am not anti-renewable and I am not a climate denier. What I am is an engineer that lives by numbers. The numbers underpinning the CLCPA—namely the belief that New York can replace most of its natural gas-fired electricity generation with renewables in the next six or even nine years—are a fantasy.

  • New York is letting the perfect be the enemy of the good, prohibiting or frustrating viable solutions that could reduce emissions. 
  • Instead, New York is relying on older, less efficient power plants, in hopes that wind and solar—built in more rural areas or offshore—can someday replace them. 
  • Even if New York were to build the wind, solar and battery backup necessary to keep the lights on without fossil fuels, the storage requirements, either onsite or grid-based, would be cost-prohibitive. 

State Comptroller Tom DiNapoli in July described “inadequate planning, monitoring and assessment of risks and challenges” by state energy officials. That’s just the tip of the iceberg. 

Greener Than The Grid

In the next section of the article, Ellenbogen describes his manufacturing business and the steps he has taken to reduce energy use at his facility.  His company, Allied Converters, manufactures food packaging for large bakeries and supermarket chains. The machinery is thermally intensive and uses large amounts of electricity.  

In 2002 he “installed the first microturbine-based Combined Heat and Power (CHP) system in the Con Ed service area.”  This approach generates electricity by burning natural gas.  Waste heat is recovered “to heat the building in the winter, or to be sent to absorption chillers to cool the building in the summer.”  This approach allows him to recover 70 to 75 percent of the energy content of the fuel. 

He compares the factory efficiency to the grid:

Most of downstate’s electricity comes from burning natural gas. New York’s single-cycle gas generating plants are in the neighborhood of 30 to 35 percent efficient. Newer combined-cycle plants are in the range of 55 to 60 percent efficient. For both, about 7 percent of energy produced is lost as heat in the transmission lines, a loss we avoid by generating electricity onsite. 

Contrast that with New York’s plan to replace gas and oil furnaces at homes and businesses with electric heat pumps, which will—at least for the foreseeable future—require more electricity generation from fossil fuels, farther away from where the electricity is needed (and therefore more line losses). 

In 2007 he installed the first commercial-scale solar array in New Rochelle.  His article describes the tribulations related to being an early adopter with the planning agency and the utility.  Later that year he added a “Reactive Power Mitigation System and in conjunction with the onsite generation, reduced load on the utility by 80 percent.  To top it off he collects data on all the electric parameters in the building. 

This massive amount of data, along with my training as an electrical engineer, has formed my frame of reference regarding the CLCPA. Renewable generation has a place in the energy mix but it cannot be used as the backbone of the utility system. Renewables are a tool and when you misuse a tool, bad things will happen. When you need a hammer, you don’t use a screwdriver, but that is essentially what the state is trying to do with renewables.

Energy System Model

His facility is a template for a pragmatic energy system:

The factory is a microcosm of NY’s energy system. It has a fossil fuel-based high efficiency generator to provide baseline load which it supplements with a solar array. The balance of the energy is dispatched by the utility when we need more.

All told, the factory’s carbon footprint is 30 to 40 percent smaller than it would be otherwise.  Additionally, our utility bill, including the cost of natural gas, is less than half of what it would have been if we hadn’t added the energy systems. We have not only reduced our carbon emissions but we have also saved money through reduced energy usage and the associated expenses, about $1 million over the past 17 years. Our savings have been relatively higher during recent years as the business has grown and we have used more energy. Contrast that with current bills for other utility customers that are rising at an increasing rate. 

The New York grid relies on nuclear, fossil, and hydro resources for most of its load, wind and solar to supplement the other resources, and imports the rest.  The grid load varies more than the factory.  As a result, resources are called for varying loads depending on their operating characteristics and costs.  Ellenbogen describes current reliability issues.

The New York Independent System Operator (NYISO), the independent nonprofit organization that operates the electric grid and oversees the state’s wholesale electricity market, has been warning about potential blackouts due to closing existing fossil-fuel generators before new generators come online. 

A 2019 plan by the state Department of Environmental Conservation to close smaller “peaker” power plants risked causing rolling blackouts on hot days as soon as 2025, before NYISO officials pushed back and kept some of the plants open. 

As NYISO officials warned earlier this summer, reliability margins—the cushions in each region that ensure there’s enough electricity to meet demand at all times—“are also observed to be narrowing across the grid in New York, which poses significant challenges for the electric system over the next ten years.” 

The reality is that the issue is going to extend well past 2033 and the energy shortages will get worse as gas plants aren’t replaced. 

Future Model

Ellenbogen describes what would be needed at his factory if he were to rely only on solar and not use natural gas.  Note that wind is not a practical source at his location.

To generate the same amount of electric energy that we currently use, we would need a solar array six times the size of what we currently have. Below is a photo of the 25,000+ square foot roof of the factory with the 50,000 watt (50 KW) solar array on it. (The factory is 55,000 square feet across two floors).    

Ellenbogen,s factory, with its 50 KW rooftop solar array, in New Rochelle, NY

We could fit an additional 50 KW array on our roof for a total of 100 KW. However, we would need a roof three times the size of what we currently have to house a large enough solar array to generate the amount of electrical energy that we currently use. That doesn’t include the heat generated by the CHP system. 

If we switched to heat pumps, we would need at least an additional 300 KW of solar arrays to support the building’s thermal load. So in total we would need 12 times the panels—on a roof six times the size. 

Beyond the enormous additional costs needed to build a system of that magnitude, we don’t have the physical space or the roof area to remotely come close to supporting a system of that size. 

The Model Storage Problem

The Climate Act insists on a zero-emissions mandate so that fossil-fired generators cannot be used to support intermittent wind and solar.  This leads to the enormous challenge of storage.

Because of the looming plight of New York utility system, my team and I have been looking for ways to supply the building during a power failure. We first looked at a backup generator but Con Ed wanted $140,000 to run a larger gas line to our building. That being cost-prohibitive, we have been looking at a new type of energy storage that does not have the deficiencies of lithium-ion batteries. 

The newer storage, using supercapacitors, has a comparable cost to lithium-ion, will last 25 to 40 years instead of the eight to 10 years of lithium-ion, and it will not go into a state of thermal runaway and burn at 2600 degrees Fahrenheit as occasionally happens with lithium-ion batteries. It will fit in a space the size of a sea container and it can be charged at night from our CHP system and on weekends from our solar array. With an energy storage system of 720 to 900 KWh in conjunction with the CHP system and the solar array, we could operate 100 percent free of the utility with a carbon footprint 10 percent lower than what we have now. 

However, the Climate Act prohibits the use of the natural gas fired micro turbine currently in use.  That means more storage would be required.

We would have to install nearly sixty times the amount of energy storage as what we currently need for backup purposes—at sixty times the price–to ensure that the panel’s energy was available at night or for extended periods during the winter months. That storage would occupy a volume approximately equivalent to that of fifty large sea containers—for my factory alone.  

When the example for his factory is considered relative to the State the lunacy of the Scoping Plan becomes clear.

NYSERDA, the state’s energy agency, in late 2022 said “complete replacement” of fossil fuel plants with solar and wind generation would require 2,400 gigawatt-hours of storage to get the state through lulls when wind isn’t blowing and output from solar panels is low. At $567 per kilowatt-hour, the recent average cost of new non-residential energy storage, that works out to more than $1.3 trillion in new costs, or about $68,000 per New Yorker.

Summing Up

Ellenbogen describes his misgivings about the Climate Act.

Unlike New York’s plan that is relying on resources that either don’t exist, don’t exist at scale, are prohibitively expensive to install, are opposed by the residents near the sites, double utility costs, and as a result cannot be installed in any reasonable time frame so that they are not reducing GHG emissions, the technologies that we have used to achieve our carbon reductions are just the opposite. My neighbors are unaware of what we have onsite. The only thing that is visible is the solar array on the roof that can be seen with aerial photos or from a distance from the new high rises that have been built. 

The technologies we used existed 20 years ago, reduce GHG emissions, are cost-effective, reduce line losses, reduce transmission and distribution costs, save money for the end user and the utility simultaneously, and can be implemented now in densely populated areas eliminating the need for multi-billion dollar transmission lines. 

This conclusion wasn’t derived from what I like or don’t like, or about what I want or don’t want, and unlike the Climate Act, it is not based upon emotion. It is based upon tens of millions of data points that definitively say that if NY State keeps proceeding on this path, it will be a calamity for the state. If the Comptroller or others in state government wonder why the Climate Action Council never did a financial analysis of the Climate Act that they forced upon the state, with the assistance of unknowing legislators, it is because the costs are so ridiculously high that if the number was actually publicized, it would be political suicide. 

Climate Act Nuclear Reality and Clueless Anti-Nuclear Activists

Two recent Syracuse Post Standard letters, “Nuclear power emits no carbon dioxide but is anything but clean” and “Coverage of Hochul energy summit did not convey dangers of nuclear waste” oppose the idea of using nuclear power as part of the zero-emissions generating resources needed to achieve the Climate Leadership & Community Protection  Act (Climate Act) goals.  In this post I explain why their knee jerk rejection of nuclear is not in the best interests of New York.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 450 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 and Background

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% reduction by 2030. 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 Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation.

Evidence is mounting that the implementation is not going to as planned.  The Public Service Commission (PSC) Clean Energy Standard Biennial Review Report found that the 70% renewable energy goal will likely not be achieved until at least 2033.  The New York State Comptroller Office Climate Act Goals – Planning, Procurements, and Progress Tracking audit found that the PSC and NYSERDA implementation plans did not comprise all essential components, including “assessing risks to meeting goals and projecting costs.”  The New York Independent System Operator (NYISO) 2023-2042 System & Resource Outlook described issues that threaten reliability and resilience of the current and future electric system. The Department of Public Service Proceeding 15-E-0302 has initiated a process to “identify technologies that can close the gap between the capabilities of existing renewable energy technologies and future system reliability needs, and more broadly to identify the actions needed to pursue attainment of the Zero Emission by 2040 Target”. The Business Council of New York cited those reports and gave other reasons in a letter asking for a reassessment of the Climate Act goals. 

A technical conference held under the PSC’s auspices on December 11 and 12, 2023 entitled “Zero Emissions by 2040” included a session titled “Gap Characterization.”  Panelists at the session recognized the need for some new resource that would need to be developed to provide electricity to meet demand when wind and solar production are low.  They referred to this new, not-yet-existing, hypothetical technology as the Dispatchable Emissions-Free Resource, or “DEFR.”  The panel also described a few potential DEFR technologies.  Nuclear is the only proven technology that can be expanded sufficiently to fulfill the DEFR energy requirements projected for the future electric grid.

Future Energy Summit

In an apparent response to these issues, on September 4-5, 2024, the Hochul Administration hosted a Future Energy Summit that announced the draft Advanced Nuclear Technologies Blueprint.  The blueprint notes that a “growing and innovative group of advanced nuclear energy technologies has recently emerged as a potential source of dispatchable carbon-free power”. The blueprint introduces the goals:

The term advanced nuclear represents a suite of technologies, a description of which is provided in subsequent sections of this document. Advanced nuclear technologies could offer attractive possibilities for New York, with its scalability, economic development, low land use, and potential applications of process heat. It may represent an opportunity for additional grid capacity to support an electrifying economy, that can complement New York’s buildout of renewables. Yet advanced nuclear technologies raise a host of questions that would have to be addressed before planning on it, regarding technological readiness, costs and cost risks, environmental justice, among other factors.

Accordingly, this discussion paper examines a number of advanced nuclear technology options from the standpoint of technological readiness and systemic challenges and issues. The objective is to surface the most important opportunities, issues, and questions associated with these options to create a platform for additional analysis and stakeholder input on these options that moves New York forward towards its energy, economic, climate, and equity goals.

Tim Knauss described the Summit and the initial public response.  He noted that the Summit attracted two street demonstrations – one for nuclear energy and the other against.  He described the two protests:

Several speakers at the energy summit noted that both Democrats and Republicans in Washington support expanding nuclear power. And polling shows that a majority of Americans — some 56% — support building new nuclear plants, according to Pew Research Center.

But at the local level, the subject can still be divisive.

That was evident Thursday outside the energy summit at the Marriott Downtown Syracuse, where about 60 protestors gathered to denounce the discussions of nuclear power.

“Governor Hochul’s climate leadership is in freefall,’’ said Laura Shindell, New York director of Food & Water Watch, an environmental group. “Now, at the very moment that we need Gov. Hochul to be our climate’s strongest defender, she is instead wining and dining the slow, expensive, dirty and dangerous nuclear industry.”

Shindell and other activists called nuclear power a “fairytale distraction’’ that will weaken the state’s efforts to meet climate goals mandated by the 2019 Climate Leadership and Community Protection Act.

They were joined by Cornell University professor Robert Howarth, who served with Harris on the Climate Action Council that drew up the state’s plan to comply with the law’s mandates.

Aside from its environmental hazards – including uranium mining, much of which mars lands occupied by Indigenous peoples – nuclear power is too expensive and too slow to construct to help meet New York’s emission reduction goals, Howarth said.

Spending on nuclear will detract from the development of more beneficial power sources, he said.  “It’s nonsense in terms of our energy future in New York, even if it had an acceptable environmental and health footprint, which it does not,’’ Howarth said. “We can meet all of the energy needs of New York with solar, with hydro and wind and appropriate (energy) storage.’’

But the energy summit also drew a pro-nuclear protest. U.S. Rep. Brandon Williams, R-Sennett, and members of Nuclear New York held their own sidewalk event to protest the anti-nuclear protest. 

Williams, a former nuclear submarine officer, said he strongly supports new nuclear power for New York. But he does not support New York’s mandate of zero-emission electricity, which he said is costly and ineffective.  “This goal of net-zero emissions is based on ideology, not on economics and not on engineering and not on science,’’ Williams said.

Anti-Nuclear Letters

The Syracuse Post Standard published two anti-nuclear letters after the Summit.  “Nuclear power emits no carbon dioxide but is anything but clean” was written by Donald Hughes, Ph.D., a longtime resident of Syracuse and environmental activist with Sierra Club and Sustain CNY.  “Coverage of Hochul energy summit did not convey dangers of nuclear waste” was written by Carole Resnick from Syracuse.  I have submitted rebuttals to those letters but there are space constraints and there is no assurance that my letter will be published.  This section describes my concerns with these letters.

Hughes argues that nuclear is anything but “clean.”  He claimed that the construction of reactors has a huge carbon footprint but ignored the mineral intensity of wind, solar, and energy storage technologies.   He said the nuclear fuel cycle is highly toxic and cited problems with uranium mining in the American Southwest.   I have compiled references for similar issues with the resources he claims are “clean”.  As part of the Nuclear New York demonstration mentioned previously ,Chris Denton assembled a booklet with numbers and pictures that show that ignoring the impacts of wind and solar when complaining about nuclear is poor form.

Hughes dismisses the advanced nuclear technology under consideration in the Advanced Nuclear Technologies Blueprint because of concerns with safety, nuclear waste, and costs. However, nuclear advocates see an opportunity to develop different types of reactors that could address these issues.  Ronald Stein explains:

The nuclear power production industry has the best industrial safety record among all industries for electricity production. So, the fear that most needs attention is the one surrounding spent nuclear fuel, which is commonly referred to as “nuclear waste.” The solution, then, lies in educating heads of state, mainstream media, and policymakers by extending the concept of recycling to include the unspent energy in used nuclear fuels, a method that can convince people that the “nuclear waste” issue is being dealt with, the cost of power is competitive, and that the production of nuclear power is safe.

Recycling Slightly Used Nuclear Fuel (SUNF) in a Fast Breeder Reactor (FBR) provides all these remedies in a way that is competitive and publicly acceptable.  The advantages to recycling used nuclear fuel in Fast Breeder Reactors are many:

  1. It provides a solution to the disposition of the stockpile of Slightly Used Nuclear Fuel (SUNF).
  2. Current inventories of SUNF provide an essentially unlimited supply of domestic fuel.
  3. The fuel material is already mined, so the energy produced is much closer to 100% clean, and further environmental degradation from mining operations is not required.
  4. The public would be more receptive to nuclear power because “waste” is being used as “fuel,” reducing the retention of unspent fuels and diminishing perceived risks.
  5. The design is “intrinsically safe”. This means that the reactor is designed to cool sufficiently in the case of an accident without human intervention.
  6. The current stockpile of SUNF has a value of $10 Trillion when the electric power that it produces is sold at 1 cent per kWh.
  7. Process heat can be used for industrial purposes such as hydrogen, freshwater production, and synthetic fuel production.

Hughes complains that the costs make nuclear a poor choice.  His main argument is that the relative costs of nuclear compared to wind, solar, and energy storage are high.  For example he cites a study by Lazard, that estimated that the unsubsidized levelized cost of electricity from new nuclear plants in the U.S. will be between $141 and $221 per megawatt hour. In comparison, a newly constructed utility-scale solar facility, with battery storage to provide power after the sun sets, will produce power at an unsubsidized levelized cost of between $46 and $102 per megawatt hour.

Willis Eschenbach evaluated that Lazard April 2023 annual report and summarized the problem with the Lazard Levelized Cost of Energy (LCOE) methodology:

The LCOE estimates the total capital, operations, and maintenance costs for new electric power plants coming into service. People use the Lazard LCOE all the time to claim that renewable electricity sources are now cheaper than fossil fuel electricity. However, the Lazard data has a problem—it doesn’t include the cost of backup and other costs for renewable energy. These costs fall into four groups:

  1. Backup costs – All power sources require backup power for the times when they are not generating any or enough power. However, the amount of backup required is much larger for intermittent sources.
  2. Balancing costs – Extra equipment is required when you have intermittent sources, to keep their highly variable input to the grid from destabilizing it.
  3. Grid connection costs – Renewable wind and solar power is variable voltage direct current. Before it can be fed into the grid, it must be run through costly synchronous inverters to convert it to stable voltage, stable frequency alternating current.
  4. Grid reinforcement/extension costs – Unlike fossil or nuclear plants, which can generally be sited as required, renewable sources of energy are often located far from where the power is needed. As a result, the grid will generally need to be extended, strengthened, or both for such source

Eschenbach’s analysis includes the following figure that compares the original Lazard costs relative to the addition of potential costs for the cost groups described above.

Note that nuclear costs are still higher than solar and wind.  However, these projections are based on a 50% penetration of generating sources.  New York’s Climate Act requires 100% penetration of wind and solar.  As a result, it does not include the necessity for a DEFR resource to backup solar and wind.  When DEFR cost support is included I believe that nuclear will be the cheaper option.

The only proven DEFR technology is nuclear so it is possible that there won’t be any choice but to develop it.  However, note that DEFR is not needed very often so it does not make much sense to use it solely for DEFR.  Instead, the obvious solution is to go all in for nuclear and stop trying to develop wind and solar.  Ron Stein sums it up: “Rather than pursue renewables of wind and solar that require huge land footprints, huge taxpayer subsidies, and even then, only generate electricity occasionally, it’s time to focus our technology resources on the nuclear power production industry that has the best industrial safety record among all companies and a track record of producing the cheapest non-subsidized electricity.”

The letter from Carole Resnick was long on emotion and short on numbers.  She believes professor of ecology and evolutionary biology professor Robert W. Howarth’s claim that “We can meet all of the energy needs of New York with solar, with hydro and wind and appropriate (energy) storage.”  Her belief is misplaced because Howarth is wrong.  I have analyzed his arguments that no new technology is needed and found them wanting.  More importantly, the Scoping Plan Integration Analysis, all analyses done by the New York Independent System Operator, and the Public Service Commission ‘Zero Emissions by 2040’ proceeding described previously all agree on the need for a new dispatchable emissions-free resource to support the electric system.  Her arguments against nuclear power itself echo the same points argued by Hughes

Conclusion

Hughes anti-nuclear claim is that “The reality is that it’s an unaffordable, slow to build and highly toxic process that has no place in a clean energy future.” Resnick claims that nuclear is a false solution and insinuates that is being considerable because it is profitable.  Neither of their arguments stands up to inspection.

I believe when the total costs of a wind, solar, and energy storage system are compared to the cost of a system that relies on nuclear for electricity generation that the nuclear system will be cheaper.  In addition, it will be more reliable because there is no reliance on weather-dependent generating resources.

The letter authors suggest that wind, solar, and energy storage have no downsides.  However, when the emissions from the full life cycle of those technologies, the impacts of renewable energy sprawl across the countryside, and the cumulative environmental impact of thousands of wind turbines and thousands of acres of solar panels necessary to provide the electricity projected are compared to the nuclear option, those technologies are anything but green. 

It is time for a nuclear renaissance.

Commentary on Recent Articles

Frequent readers of this blog know that many of my posts are long because I get document all my statements and get bogged down in details.  This is because of my background in industry where it is necessary to prove my arguments to have credibility.  This is an update of articles that I have read that I want to mention but do not require a detailed post.  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 organization I have been associated with, these comments are mine alone.

Hurricane Risk to Offshore Wind

I published a couple of articles about offshore wind recently (recent news and costs) in the last couple of weeks.  When I saw the headline “Wind Turbines Destroyed by Typhoon Yagi,” I figured another update was coming.  Robert Bradley described the not so good news about this storm and its impact on wind turbines: “Not only were older turbines destroyed by the 150 mile-per-hour typhoon (Category 4 in hurricane terms); new “more efficient typhoon-resistant versions” were leveled too.”

He referenced a 2012 article that is relevant today.  The Proceedings of the National Academy of Sciences research article, “Quantifying the Hurricane Risk to Offshore Wind Turbines” (February 13, 2012) included the following conclusions:

“The U.S. Department of Energy has estimated that if the United States is to generate 20% of its electricity from wind, over 50 GW will be required from shallow offshore turbines. Hurricanes are a potential risk to these turbines. Turbine tower buckling has been observed in typhoons, but no offshore wind turbines have yet been built in the United States.”

“We present a probabilistic model to estimate the number of turbines that would be destroyed by hurricanes in an offshore wind farm. We apply this model to estimate the risk to offshore wind farms in four representative locations in the Atlantic and Gulf Coastal waters of the United States. In the most vulnerable areas now being actively considered by developers, nearly half the turbines in a farm are likely to be destroyed in a 20-y period.”

“Typically, wind turbines are designed based on engineering design codes for northern Europe and the North Sea, where nearly all the offshore and coastal wind turbines have been built. These codes specify maximum sustained wind speeds with a 50-y return period of 42.5–51.4 m/s (83–100 knots), lower than high intensity hurricanes.”

“Offshore wind turbines … will be at risk from Atlantic hurricanes…. Wind turbines are vulnerable to hurricanes because the maximum wind speeds in those storms can exceed the design limits of wind turbines. Failure modes can include loss of blades and buckling of the supporting tower.”

“In 2003, a wind farm of seven turbines in Okinawa, Japan was destroyed by typhoon Maemi, and several turbines in China were damaged by typhoon Dujuan. Here we consider only tower buckling, because blades are relatively easy to replace (although their loss can cause other structural damage).”

“There is a very substantial risk that Category 3 and higher hurricanes can destroy half or more of the turbines at some locations.”

I think it is important to point out that these conclusions were based on risks for 2012 turbines.  Since then, the size of turbines has increased substantially and when that happens the structure is subject to faster winds at the upper levels.  In other words a Category 3 storm could have Category 4 impacts on these huge structures.  The implementation plans for the Climate Act have not mentioned the potential impacts of a loss of a large proportion of the offshore wind resources due to hurricanes but I think it is time to assess this problem.

German Energy Transition

George Santayana’s quote “Those who forget history are condemned to repeat it” is also applicable to the lessons that could be learned by observing what has happened to net-zero early adopters.  Four articles about the German Energiewende, or clean energy transition should be setting alarm bells off the Hochul Administration. 

Francis Menton notes that “Germany is running faster and faster to stay in place but in the meantime, it is destroying its economy.”  He notes that:

According to a chart at this page, also from Clean Energy Wire and sourced to the UBA, Germany’s solar generation capacity went from 67.6 GW at year-end 2022 to 79.2 GW at year-end 2023 — an increase of more than 17%; and its wind generation capacity went from 66.1 GW to 68.8 GW, an increase of over 4%. That’s rather an enormous amount of additional capital invested in wind and solar to achieve an additional 0.3% market share in electricity generation.

From what I have seen this is a feature not a bug.  At a certain point adding more solar and wind capacity does not proportionally increase market share.  More importantly, what about the costs?  Menton looks at the big economic picture for Germany. First, how do its electricity prices compare to other places? Here is a very useful chart from the Energy Policy Research Foundation, comparing second-half 2023 consumer electricity prices among EU countries and U.S. states:

Germany way at the top of the list, over 38 cents per kWh, well over double the U.S. average. New York is position 22.  I intend to keep track of this metric in the future because I don’t think NY will fare as well when the Climate Act costs kick in. 

In an email Richard Ellenbogen pointed out that the authors of the Climate Act should have checked the literature because they would have seen the following from Yale.edu in December, 2018 before the passage of the Act: “Carbon Crossroads: Can Germany Revive Its Stalled Energy Transition?” It is not the only document that should have raised red flags.  The article notes that:

Although the country has made a Herculean effort to shift to a clean energy economy — in just the past five years government support and costs to consumers have totaled an estimated 160 billion euros ($181 billion) — Germany’s greenhouse gas emissions have not declined as rapidly as expected in response to the vigorous expansion of renewable energy, which now generates 40 percent of the country’s electricity. Germany’s politicians are even resigned to falling significantly short of the country’s 2020 goal of reducing emissions by 40 percent below 1990 levels.

The article goes on:

Today, the Energiewende finds itself stalled and floundering. Germany’s carbon emissions have stagnated at roughly their 2009 level. The country remains Europe’s largest producer and burner of coal, which generates more than one-third of Germany’s power supply. Moreover, emissions in the transportation sector have shot up by 20 percent since 1995 and are rising with no end in sight, experts say. German consumers have seen their electricity bills soar since 2000, in part because of the renewable energy surcharge.

The transportation transition situation is getting more dire.  Irina Slav describes the EV situation in Germany:

Take the latest news from the EV world, for example. Global sales were up by a lovely 20% in August. But in Europe, EV sales were down. By 33%. And that includes hybrids.

The drop was led by Germany, which last year axed subsidies for the vehicles. The axing led to a sharp decline in EV sales, so earlier this month, the government surrendered to reality — and approved new incentives, under which, per Reuters, “companies would be able to deduct up to 40% of the value of newly purchased electric and qualifying zero-emission vehicles from their tax bill in the year of their purchase, falling progressively to 6%.”

In other words, Germany’s government still thinks it’s only a matter of time until EVs become competitive. They just need a leg up. Another leg up. They might soon need a couple of more legs up because the Chinese are coming — and they’re bringing their cars as knock-down kits as their government advises they keep key EV tech at home. This would compromise some green job plans and that’s tragic.

Finally, in a breaking news report by Eric Worral   he examines the German government’s attempt to fact check Trump on the green energy debacle.  He summarizes recent articles documenting the failures of the Energiewende.

I could go on, because the examples show up frequently.  It is obvious that there are problems with the German net-zero transition that will inevitably show up here.  Why is the Hochul Administration ignoring these red flags?

Climate Act Costs and the Election Cycle

The Climate Leadership & Community Protection Act (Climate Act) was passed five years ago and the Scoping Plan that outlines how the to implement the required transition was completed 20 months ago.  However, the Hochul Administration still has not admitted how much it will cost the consumers of New York.  In my opinion, the reason this information is not available is because the costs are politically toxic.  This post describes the requirements to provide costs that have been ignored by Governor Hochul.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 450 articles about New York’s net-zero transition.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes an interim reduction target of a 40% GHG reduction by 2030, and two targets that 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 Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation.

Scoping Plan Costs

The Scoping Plan outline for achieving the “State’s bold clean energy and climate agenda” should have provided substantive cost information.  Although costs to ratepayers and citizens were requested frequently by several Climate Action Council members the Scoping Plan went to great lengths to obfuscate the expected costs for the net-zero transition.  The Scoping Plan supporting documentation does not provide a transparent description of the information needed to estimate consumer costs.  At a minimum it should have provided clear descriptions of all proposed control measures, the assumptions made for those control measures, the expected costs for each measure, and the expected emission reductions projected for them.  The Scoping Plan does not even summarize sectoral expected costs for the different projection scenarios.  The numbers that are provided are buried in an enormous spreadsheet with inadequate documentation so it is impossible to determine what was used.

Instead of providing substantiated numbers the Scoping Plan cost benefit projections provided nothing more than support for the oft-repeated sound bite: the costs of inaction are more than the costs of action.  I summarized the machinations used to support this statement in a blog post and argued that the statement was misleading and inaccurate in my Draft Scoping Plan verbal comments  and written benefit, and cost/benefit comments.  There never has been a response to my comments.

There are substantive problems with the claim that the costs of inaction are more than the costs of action.  It is misleading because the Scoping Plan did not include all the costs to meet the Climate Act mandates.  Instead, it only included costs directly related to the Climate Act itself and not already implemented programs such as the Clean Energy Standard including 6 GW of behind-the-meter solar, 3 GW of battery storage, and 9 GW of offshore wind.  As a result, the acknowledged costs are much less than the total costs of implementation.  Also note that this accounting trick was very poorly referenced to hide this chicanery.

The overarching thing to keep in mind is that the costs are real, but the benefits are based on value judgements with a wide range of possible values.  Worse, the calculation of the societal benefits expected from carbon dioxide emission reductions was incorrectly applied.  The societal benefit was incorrectly applied multiple times rather than just once.  Their approach is equivalent to claiming that a wight loss of five pounds five years ago should be counted as a loss of 25 pounds if it was kept off.

All this results in unrealistically low-cost estimates and value-laden high benefit estimates to “prove” the costs of inaction are more than the costs of action. 

New York Cap and Invest

The Climate Action Council’s Scoping Plan recommended a market-based economywide cap-and-invest program.  The New York State Department of Environmental Conservation (DEC) and NYSERDA are developing the  New York Cap-and-Invest (NYCI) Program.  In March they took comments on the pre-proposal outline of the regulations but have only had one stakeholder meeting since.  On August 15, 2024 a webinar presented “a draft proposed framework for guiding the allocation of these funds and identification of potential areas that could receive investments.” During the webinar they claimed that draft rules would be out later this year and that appropriations and spending of NYCI proceeds would begin in the next fiscal year beginning April 2025.  In the stakeholder engagement process at the beginning of the year DEC and NYSERDA claimed they would propose regulations by summer and the final rules would be in place by the end of the year.  Clearly this is not happening according to plan.

Implementing a program like this is a major undertaking and I believe that the DEC is unable to respond as quickly as they would like simply because of staffing issues.  On the other hand, this program is a carbon tax.  There is no way that it will not affect prices significantly so I doubt very much there is any desire to get the program details out quickly.  At the Energy Access and Equity Research webinar sponsored by the NYU Institute for Policy Integrity on May 13, 2024 Jonathan Binder stated that the New York Cap and Invest Program would generate proceeds of “between $6 and $12 billion per year” by 2030.  In my opinion, these costs are one reason that the Hochul Administration is not in a hurry to release the regulations and proceed with the implementation process.

Comptroller Report

On July 16, 2024 the New York State Comptroller Office released an audit of the New York State Energy Research and Development Authority (NYSERDA) and Public Service Commission (PSC) of their implementation efforts for the Climate Act titled Climate Act Goals – Planning, Procurements, and Progress Tracking.  The key finding summary states: “While PSC and NYSERDA have taken considerable steps to plan for the transition to renewable energy in accordance with the Climate Act and Clean Energy Standard, their plans did not comprise all essential components, including assessing risks to meeting goals and projecting costs.” 

The Audit Highlights section of the Comptroller Report listed cost-related key findings and key recommendations.  The summary of the key findings included a cost-related specific finding:

  • The costs of transitioning to renewable energy are not known, nor have they been reasonably estimated. Moreover, funding sources to cover those costs have not been identified, leaving the ratepayers as the primary source of funding. The lack of alternative funding sources adds additional risk to whether the State can meet its goals timely. Data shows utility costs have already risen sharply over the last two decades and more New Yorkers are having difficulty paying their utility bills. 

There were three key recommendations related to costs:

•            Begin the required comprehensive review of the Climate Act, including assessment of progress toward the goals, distribution of systems by load and size, and annual funding commitments and expenditures.

•            Conduct a detailed analysis of cost estimates to transition to renewable energy sources and meet Climate Act goals. Periodically update and report the results of the analysis to the public.

•            Assess the extent to which ratepayers can reasonably assume the responsibility for covering Climate Act implementation costs. Identify potential alternative funding sources.

There has been no formal response directly to these findings.  Susan Arbetter’s Capital Tonight  show featured an interview with NYSERDA President and CEO Doreen Harris and Rory Christian, Chair and CEO of the PSC where the cost findings came up.  I wrote an article that focused on Arbetter’s attempts to get either one of them to open up about the costs.  Arbetter asked: “I just want make sure that while there are factors that have contributed to the delay in implementation of our energy goals, is there anything leading the Administration to delay this because of cost.” (Note that this is not an exact quote but it is pretty close – check out the video at 1:40/9:00).  Harris responded (2:00/9:00 of the video): “The proceeding that is before the PSC is intended to look at just that”.  Harris explained: “How much progress have we made, do we need to make, and specifically they look at all this in the context of consumer cost”. 

Biennial Report

The Climate Act requires the Public Service Commission (PSC) issue a biennial review for notice and comment that considers “(a) progress in meeting the overall targets for deployment of renewable energy systems and zero emission sources, including factors that will or are likely to frustrate progress toward the targets; (b) distribution of systems by size and load zone; and (c) annual funding commitments and expenditures.”  I believe this is the PSC proceeding referenced by Harris.  The draft Clean Energy Standard Biennial Review Report released on July 1, 2024 fulfills this requirement.

However, contrary to the Harris claim, I do not think that this report addresses the progress “in the context of consumer cost”. I searched the Biennial Report for “consumer” and only got three results: one for consumer price index and the other two in a paragraph describing the motivation for deregulating the power sector of New York.  That may not disprove the claim that the report looks at all of this in the context of consumer costs, but I have not found any sections addressing consumer costs. 

The timing is convenient for the election cycle.  My cynical take on this is that the draft did not include consumer costs because of the potential for political fallout.  By the time that costs are added to the document the current election cycle will be over.

Energy Plan

According to the New York State Energy Plan website:

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

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

In recognition of the State’s historic clean energy transition, the State Energy Planning Board will now convene, chaired by the New York State Energy Research and Development Authority (NYSERDA), to begin the process of developing a new Plan. Stakeholder engagement is an integral component in the development of the State Energy Plan, and the public will have the opportunity to provide comments on the draft scope and the draft plan throughout the process.

The Energy Plan is a political construct.  The Board consists of ten Commissioners all appointed by the Governor, three appointed by the Governor, the President of the Senate, and Speaker of the Assembly, and a non-voting member from the New York Independent System Operator.  Given the make up of the Board I expect that all decisions will fit the Governor’s energy narrative.

With respect to the schedule § 6-106. Conduct of the state energy planning proceeding (1) states:

Every four years, the board shall adopt a state energy plan, which addresses each item identified in subdivision two of section 6-104 of this article provided, however, the board may adopt such a plan more frequently for good cause shown. The board shall prepare biennial reports, every second year following the issuance of the final state energy plan, including a discussion and evaluation of the ability of the state and private markets to implement the policies, programs, and other recommendations as found in the state energy plan, and recommendations for new or amended policies as needed to continue successful movement towards implementation and realization of such policies and programs.

The 2015 Energy Plan was the latest edition and the last biennial report came out in 2017.  In 2019 the Climate Act was promulgated and in April 2020 an amendment to the plan was adopted that incorporated the new targets.  I have never heard an explanation why the plan was not updated.  Clearly the Climate Act has a major impact on energy planning but it has been 20 months since the Scoping Plan was completed.

The energy plan required analyses have not been updated since 2015.  § 6-104, State Energy Plan (2) (b) says the state energy plan shall include:

(b) Identification and assessment of the costs, risks, benefits, uncertainties and market potential of energy supply source alternatives, including demand-reducing measures, renewable energy resources of4 electric generation, distributed generation technologies, cogeneration technologies, biofuels and other methods and technologies reasonably available for satisfying energy supply requirements which are not reasonably certain to be met by the energy supply sources identified in paragraph (a) of this subdivision, provided that such analysis shall include the factors identified in paragraph (d) of this subdivision;

Identification and assessment of the costs, risks, benefits, uncertainties and market potential of energy supply source alternatives is only possible if there is a feasibility study.  There hasn’t been a feasibility study for the Climate Act.  On September 9, 2024 the State Energy Planning Board met to kick off this version of the Energy Plan.  The following slide outlines the schedule.  Note that the comment period on the plan itself is not anticipated until summer 2025.

Given that there is an explicit requirement for a cost assessment my money is on this process sliding until after the 2026 elections.

Conclusion

Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies.  There is no question that the Climate Act costs will test the commitment of most New Yorkers to doing something about climate change once the costs are revealed.

During the Draft Scoping Plan review by the Climate Action Council, members Gavin Donohue and Donna DeCarolis repeatedly asked for consumer price cost projections.  Co-chair Harris did not provide that information then and appears to be stonewalling now.

My cynical take on this is that Scoping Plan contents, the timing for the NYCI carbon tax, the response to the Comptroller’s audit report, the contents of the biennial report, and the timing for the energy plan all are being manipulated to prevent dissemination of expected consumer costs because of the potential for political fallout.  As it stands the bad news will not be let out until after the 2024 election cycle.  Given the enormity of the potential costs I recommend voting against any candidate who supports the Climate Act simply because we deserve to know the costs.

Has the Electricity Reality Check Arrived?

An article by Todd Snitchler originally published by RealClearEnergy  and republished at Watts Up With That provides an excellent overview of the issues confronting the electric system today.  It is also a response to clean energy advocates that demand that New York double down on its efforts to meet the Climate Leadership & Community Protection Act (Climate Act) mandates using wind and solar resources.  This post annotates the Snitchler article with comments framing the New York context.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 450 articles about New York’s net-zero transition.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes an interim reduction target of a 40% GHG reduction by 2030, and two targets that 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 Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation.

On September 4-5 the Hochul Administration hosted a Future Energy Summit.  I have written several preliminary impression articles about it and plan to do a final summary after the video is posted.  My impression is that Hochul suggested the idea for the Summit, but the primary rationale is not obvious.  Initially I thought it was in response to three recent independent reports that found that there were schedule issues, inadequate cost support and potential reliability risks.  Those findings coupled with a Business Council of New York letter that cited those reports in a plea for a reassessment I thought were compelling reasons for a meeting.

However, the Summit did not address the problems identified.  There were a couple of passing mentions of some of the problems but none of the panelists made any statements contrary to the Administration’s narrative.  However, two sessions were devoted to incorporating nuclear energy in the implementation plan and a draft blueprint for consideration of advanced nuclear technologies was released for comment.  I now think that the purpose was to gauge the political blowback for that option.

In this context, Spectrum News with Susan Arbetter has recently hosted guests (here and here) to discuss the “benefits of nuclear energy, specifically as a dispatchable resource that can fill in the gaps that arise with solar and wind.”  The most recent interview was with Blair Horner from the New York Public Interest Research Group (NYPIRG).  I address his comments in my annotations of the article below.

Has the Electricity Reality Check Arrived?

The author of the article is Todd Snitchler.  He is President and CEO of the Electric Power Supply Association (EPSA).  He introduces the article by noting that dispatchable generation is needed.  For background keep in mind that electric system operators must balance the load with available generation constantly.  That challenge is much easier if they have resources available that can be dispatched, that is to say controlled, as needed. Wind and solar are not dispatchable.

At meetings of energy regulators, policymakers, consumer advocates, and industry this summer, the content and tone of the conversations around electric system reliability have changed dramatically. Executives from across the industry all agree that dispatchable generation is needed now and will be needed for many years to come.

Electric system owners have economic goals that are inordinately affected by politicians.  As a result, they are reticent to say anything that is inconsistent with the current political narrative.  In this case the political narrative is the constant refrain about the need to do something about the “existential” threat of climate change.  Consequently, everyone who knows better that works for the utilities or the state has not been speaking out about the risks of relying on generating resources that cannot be dispatched. However, reality is forcing their hands and suggestions that laws like the Climate Act might not work as touted are coming out.

Most prominently, the realization and willingness to say publicly that dispatchable resources like natural gas-fired generation will be needed as the energy expansion continues and load growth accelerates for the first time in decades is a welcome admission.

For several years the discussion around the future of the electrical grid was about how inexpensive it will be and how “out of political favor” resources would be moved off the grid in favor of politically favored ones without creating any disruptions or reliability challenges. And just like that, the story has changed – dramatically. Why?

Privately all the experts who really understand the electric system admit that the proposed Climate Act transition plan is very unlikely to work and certainly cannot work on the arbitrary schedule mandated by the Climate Act.  On the other hand, advocates like NYPIRG’s Horner cling to the incorrect notion that no new technologies are needed.  That belief underpinned the Climate Act law’s schedule and presumption that meeting the schedule was just a matter of political will.  Snitchler describes three reasons why plans like the Climate Act cannot work as advertised in the real world.

First, load growth – and a substantial amount of it is expected in the short term. The second is the pace of dispatchable generation retirements, without replacement generation with similar performance characteristics. The third is consistent and increasing warnings coming from reliability organizations and grid operators that a crisis is coming and coming quickly if system planning does not improve.

The authors of the Climate Act did not understand how the electric grid operates and the impacts of wind and solar intermittency on the proposed changes to the system.   In the interview with Arbetter at about the 2:00 mark Horner makes the point that the law established a schedule that must be met.  Ignoring all the issues related to the massive shift in resources proposed and all the difficulties associated pandemic impacts to supply chains, he whines that the Hochul Administration is not doing what they are supposed to be doing.  Snitchler’s description of grid operation realities is inconsistent with the Climate Act mandates so the State is in an impossible situation relative to the schedule.

What does this mean? In short, it is a long-awaited recognition of the reality of grid operations combined with the acknowledgment (albeit grudgingly in some circles) that dispatchable resources, like natural gas, will need to be retained and operated for a longer time horizon than many were willing to admit. This recognition matches the significant number of credible studies, including work done by McKinsey and EFI, that all said dispatchable natural gas generation would be needed even in a high renewable resource penetration scenario.

The problem of dispatchability is compounded in New York because natural gas generation is prohibited by the Climate Act.  Instead, the credible plans for the future electric system plan to use a not yet commercially available “Dispatchable Emissions-Free Resource (DEFR)”.  It is long past time that anyone who denies this need should be ignored in the conversation but unfortunately the Hochul Administration has not done anything to confront this problem.

That is not all.  Snitchler describes other issues that have impacted the Climate Act schedule that Horner ignores when he whines that the State is not meeting the schedule:

As the reality of load growth, supply chain issues, permitting, siting, and construction challenges impacting all types of resources settled in and the sharp warnings of imminent reliability issues combined, it became clear that the rhetoric was far ahead of reality. Recognizing the problem is the first step in solving it.

Unfortunately, there is a crisis brewing as the reliability margins shrink.  This summer there were operator alerts for generation emergencies.  Snitchler explains that this is largely due to retirements of fossil-fired generating resources before adequate replacements were available.  He goes on to recommend a solution.

Because all resources are now accountable for reliability, including dispatchable, intermittent, and storage resources, the requirement to acknowledge and adapt to grid realities is no longer optional – it’s mission critical. The retirement of significant amounts of dispatchable resources without adequate replacements has pushed us ever closer to a system with zero margin of error.

To correct this situation, policymakers and regulators should take steps to minimize the risk to customers. First, the timing gap between retirements and additions to the system must be addressed; we can’t let existing resources off the grid before the replacements are ready. The process for connecting new generation to the grid must be reformed to ensure projects match system needs, not just policy pronouncements. Permitting and siting reforms are needed so we can deliver development of all types of energy projects.

I agree with Snitchler that one thing that must be done is to readjust the aspirational targets of energy transition laws like the Climate Act.  I endorse the idea that offramps for reliability is necessary. 

Second, policymakers must temper enthusiasm and set goals that align with the reality of system needs and operational constraints. This could mean pausing policies that hinder the deployment of needed resources or including offramps in legislation to ensure grid reliability.

I do have a concern with his plea for siting reforms and pausing policies that hinder deployment of needed resources.  I do not agree if that approach is used to justify deploying wind and solar faster because I think there is a fundamental issue that has not been addressed.  Analyses of renewable resource availability have identified periods where DEFRs are required.  What has not yet been addressed is the risk that designing an electric system to meet a weather-dependent requirement will inevitably mean that practicality and affordability constraints will lead to a situation where an extreme event exceeds the planning criteria.  That would lead to blackouts.  I do not believe this has received adequate evaluation and discussion.  As a result, I think it is more appropriate to consider reliability constraints before proceeding to build as much solar and wind as possible as fast as possible.

Snitchler raises another practicality issue that is not on the radar of advocates like Horner.  New York policies must be consistent with other states or bad outcomes will result.  In addition, there must be a plan for developing a market signal for DEFRs.  This will be an expensive resource that is not used much raising market viability concerns.

Third, grid operators must move more quickly to adjust markets to send the appropriate signals that will drive investment of the required resources. States must recognize the broader benefits of market participation and positive outcomes for their constituents and stop merely demanding grid operators do what one state wants to the detriment of another. States must again appreciate that the benefits of their utilities joining markets far outweigh their ability to dictate resources and timelines and then disclaim responsibility for the issues those decisions create.

Advocates like Horner are first to accuse market participants of biased motives when there are inconsistencies with their goals.  Everyone wants a better environment and would like to reduce the risks of extreme weather impacts due to climate change.  Snitchler correctly points out that unrealistic goals raise the risk of reliability problems that, in my opinion, are a much worse outcome than effects of climate change that these policies could possibly alter.

To close, lest anyone accuse market participants of not wanting to reduce emissions or only wanting to profit from their current resources, this reality check in no way means walking away from striving to meet policy goals. Bottom line – we can set goals, but they must be tethered to operational reality to ensure success and reliability are both achieved.

Discussion

I think this is a good summary of issues confronting all the electric grid operators in the United States.  The risks in New York are even greater because of the unrealistic Climate Act mandates and the attitude of many that because it is a law the mandates must be met with no acknowledgement that there has never been a feasibility analysis to confirm whether it can be done and how fast it could be done.  It is unfortunate that the Future Energy Summit did not address these concerns.  I believe that a reassessment is overdue.

One of the most important topics for a reassessment is that the need for dispatchable resources destroys the myth that wind, solar, and energy storage are the only technologies needed.  Energy storage can provide some of the necessary dispatchability, but the overwhelming consensus is that new DEFR technology is necessary.  It is time to stop giving Robert Howarth, the self-avowed author the Climate Act, any platform to say “We can meet all of the energy needs of New York with solar, with hydro and wind and appropriate (energy) storage.’’  That statement is wrong and incorrectly influences advocacy groups like NYPIRG.

Conclusion

Snitchler summarizes the reality check issues that need to be confronted nationally and in New York.  If these issues continue to be ignored and unresolved, then the only outcome will be grid reliability problems.  I fear that there are many who will only admit that these problems are real only after there has been a catastrophic blackout.