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.

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.

New York Future Energy Economy Summit Post Meeting Preliminary Update

On August 5 Governor Hochul announced a Future Energy Economy Summit that will “gather feedback on strategies to accelerate renewable energy deployment and explore the potential role of next generation clean energy technologies”. I described my initial thoughts on the summit and followed up with a second pre-meeting post. This post describes my initial reaction to the meeting. I will follow up with another post when the meeting recording is posted.

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.

Setting the Stage for the Meeting

As I have noted previously there are many reasons why an assessment of the future energy economy is needed. Three recent reports top the list. 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 may also be influencing the Governor and precipitating the need for the summit. The Business Council of New York has cited those reports and gave other reasons why it is needed. As a result, the governor said the state’s climate goals are something she “would love to meet, but also the cost has gone up so much. I now have to step back and say, ‘What is the cost on the typical New York family?’ Just like I did with congestion pricing.”

Annotated Agenda

Welcome

Doreen Harris, President and CEO, New York State Energy Research and Development Authority
- Reason to meet in Syracuse was because of Micron chip fabrication plant
- Administration is committed to Climate Act goals but refinements may be necessary

Morning Keynote

Kathy Hochul, Governor Press Release
- Reiterated commitment to Climate Act goals because of all the climate events
- Governor does not know difference between weather and climate
- She managed to appeal to a wide range of her constituents with specific statements

Fireside Chat: State of Technology

David Crane, Under Secretary for Infrastructure, U.S. Department of Energy
Richard Kauffman, Chair, New York State Energy Research and Development Authority
- I was not impressed with this session
- Neither speaker has a technical background and it showed
- Upton Sinclair’s quote is apropos: “It is difficult to get a man to understand something when his salary depends upon his not understanding it.

Accelerating Renewable Energy Deployment in New York State

Moderator, Georges Sassine, Vice President, Large Scale Renewables, New York State Energy Research and Development Authority
Laura Beane, President North America, Vestas
Lori Bird, Director of U.S. Energy Program and Polsky Chair for Renewable Energy, World Resources Institute
Eric Cohen, Head of Green Economy Banking, JP Morgan Chase
Frank Macchiarola, Chief Policy Officer, American Clean Power Association
Jonah Wagner, Senior Advisor to the Director, U.S. Department of Energy Loan Programs Office
- All of these speakers have a vested interest in the clean energy transition so my notes are sparse
- I posted a question asking if it was a good idea to build as much renewable energy as possible before the necessary dispatchable emissions-free resource technology is specified. There was no response to the question.

Status of Next Generation Energy Technologies

Moderator, Brandon Owens, Vice President, Innovation, New York State Energy Research and Development Authority
Dr. William Acker, Executive Director, New York Battery and Energy Storage Technology Consortium
Dr. Monterey Gardiner, Chief Engineer, National Renewable Energy Lab
Dr. Benjamin Houlton, The Ronald P. Lynch Dean, Cornell College of Agriculture and Life Sciences
Dr. Jack Lewnard, Program Director, Advanced Research Projects Agency – Energy, U.S. Department of Energy
Jeffery Preece, Director of Research and Development, Electric Power Research Institute
Julie Tighe, President, New York League of Conservation Voters
- One of the significant points made during the Summit is that certain industries are willing to pay more for reliable high-quality electric power.
- This broaches the idea that those companies would be willing to make investments in reliable power
- It also acknowledges that certain industries recognize that a future grid that relies on wind, solar, and energy storage will not be reliable enough

Lunchtime Keynote Speaker Clean Energy Supply for Large Loads

Rich Powell, Chief Executive Officer, Clean Energy Buyers Association
- He explained how large companies signal their climate virtue by claiming credits for zero-carbon generation virtually

Insights from Large Consumers of Electricity

Moderator, Hope Knight, President, CEO, and Commissioner, Empire State Development
Miranda Ballentine, Senior Advisor, Green Strategies
Amber Bieg, Lead Senior Program Manager for Global Sustainability, Micron
Moshe (Mo) Bonder, Director, Business Development Low Carbon Solutions, National Grid Ventures
Jennifer Lupo, Vice President, Energy Solutions, Supply Chain & Leasing, The Raymond Corporation
Dr. Varun Sivaram, Senior Fellow for Energy and Climate, Council on Foreign Relations
- This session gets into the real reason for the Summit
- In order to do justice to the commentary I need to review the meeting recording
- All these companies subscribe to the belief that it is important that the electricity they use be “clean”
- There was even a suggestion that to be competitive, companies demand clean energy. My impression was that affordability and reliability were weighed equally with cleanliness. That does not seem appropriate, so I need to get exact quotes

Global Perspective: Advanced Nuclear Development in Other States and Nations

Moderator, Rory Christian, Chair, New York State Public Service Commission
Nicolle Butcher, Chief Operations Officer, Ontario Power Generation
Steve Chengelis, Senior Director of Future Nuclear, Electric Power Research Institute
Dr. John Parsons, Deputy Director for Research, MIT Center for Energy and Environmental Policy Research
Dr. Andrew Whittaker, SUNY Distinguished Professor, University of Buffalo
- This session addressed the status of nuclear elsewhere
- Questions were posed and answers debunking common anti-nuclear talking points were included

Blueprint for Consideration of Advanced Nuclear Technologies

Moderator, John Williams, Executive Vice President of Policy and Regulatory Affairs, New York State Energy Research and Development Authority
Armond Cohen, Chair, Clean Air Task Force
Judi Greenwald, Executive Director, Nuclear Innovation Alliance
Christine King, Director, U.S. Department of Energy’s Gateway for Accelerated Innovation in Nuclear Program
Greg Lancette, Business Manager, United Association of Plumbers and Steamfitters Local 81
J. Ryan McMahon II, Onondaga County Executive
Marc Nichol, Executive Director of New Nuclear, Nuclear Energy Institute
- In the interest of full disclosure I bailed on this session

Wrap up and Next Steps

Doreen Harris, President and CEO, New York State Energy Research and Development Authority
I got into the meeting webinar when I got home in time for this
- Harris read accolades to her boss’s vision to fight the crisis
- She said there were three takeaways
- She doubled down on the need for building renewables and making them the primary energy source
- She acknowledged that dispatchable emission-free resources were needed
- She argued that we must not miss the opportunity to leverage federal initiatives to fund New York’s transition.
- She believes that the clean energy transition will grow a prosperous economy
- She encouraged everyone to review the draft blueprint for consideration of advanced nuclear technologies
Discussion

In an earlier post I noted that the State must confront the possibility that the safety valve criteria in New York Public Service Law § 66-p (4) for unsafe and inadequate electric service, impairment of existing obligations and agreements, and unacceptable increase in arrear or service disconnections will be exceeded. There was no suggestion whatsoever that the Hochul Administration has any doubts that a zero-carbon electric grid that relies on wind and solar will work.

It seems obvious that there are large consumers of electricity that want to at least be able to say that they use 100% renewable energy. I think this summit was in no small part designed to cater to those companies. However, there were some hints that high quality electric power was enough of a concern that nuclear might be an acceptable option.

The other reason for this meeting was to broach the nuclear power option to the State. The draft blueprint is potentially a referendum on its use. I have no doubts that the anti-nuclear activists are frantically developing their plan to inundate the comment process with negative comments. The political calculus of weighing the squeaky wheel crowd relative to the reliability of the wagon realists will be interesting. Will the Administration admit that reliability and resiliency are not just slogans.

Conclusion

I remain convinced that the current Scoping Plan implementation will do more harm than good. The Energy Summit could have been the start of a correction process that might reduce the inevitable increased risks to reliability, extraordinary price increases, and significant environmental impacts but that does not appear to be the case. As I said before the Summit is another Macbeth story: “A tale told by an idiot, full of sound and fury, signifying nothing”.

Offshore Wind Costs

Last month I described a flurry of offshore wind related news and last week I provided an update describing additional news. In my opinion these latest revelations suggest that a reassessment of the viability of offshore wind projects is in order. I did not address the costs but a couple of articles that have appeared since then do suggest that costs should also be considered in the reassessment.

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 has to be 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.

Offshore wind developments are a key Climate Act decarbonization strategy. There is a mandated target of 9,000 MW of offshore wind by 2035. The Integration Analysis projects that offshore wind capacity will exceed 13 GW by 2040. However, there are overlooked risks to this strategy that are now becoming obvious. The fact is that the huge, proposed wind turbines have not been field tested.

Why Is Cheap Wind Power So Expensive?

Willis Eschenbach poses the cost question that is ignored by the green energy activists. First he describes the overarching Biden Administration goals released in Marh 2021:

Eschenbach is a numbers guy and was immediately suspicious:

Hmmm, sez I, seems a mite ambitious. Current US grid-connected offshore wind is a mere 0.17 gigawatts … so we’d need to do ~ 175 times as much as we’ve done to date and do it in a short six years.

So I divided it out. There are 65 months until 2030. Thirty gigawatts is thirty thousand megawatts, less the 174 megawatts in place, that’s 29,826 megawatts more total generating capacity needed.

29,826 megawatts divided by 65 months means we’d have to add offshore wind generation to the tune of 465 additional megawatts of generation capacity per month. Every month. Starting now.

Get real. That’s not remotely possible. The biggest US offshore windfarm just came on line, 132 MW capacity. To reach the White House goal, every month we’d need to build three new windfarms of that size. No way that can happen. It’s just numbers picked out of the air to gain popular support.

Then he researched the expected time to get an offshore wind farm on line:

The time from the proposal of an offshore wind farm to its grid connection typically ranges from 7 to 10 years. This timeline can be broken down into several phases:

Pre-development and Planning (1-2 years): This phase involves site identification, feasibility studies, and initial environmental assessments.

Permitting and Approvals (3-5 years): Securing the necessary permits and approvals is often the most time-consuming part of the process. This includes detailed environmental impact assessments, consultations with stakeholders, and obtaining state and federal permits.

Construction (2-3 years): Once all approvals are secured, construction of the wind farm, including the installation of turbines and subsea cables, takes place. This phase also includes the grid connection process.

Commissioning and Testing (several months): After construction, the turbines are tested, and the wind farm is gradually brought online.

The bottom line is that if a project is not well along it will not be available by 2030. He found cost information for South Fork Wind which in New York’s first offshore wind farm:

South Fork Wind just came online. This gives us a chance to look at some actual cost figures. It’s the biggest wind farm to date, a 132-megawatt addition to offshore wind. It cost $637 million.

However, Federal subsidies added $191 million to that, plus another couple of hundred million or so from Bureau of Ocean Energy Management (BOEM), the National Oceanic and Atmospheric Administration (NOAA), and the New York State Energy Research and Development Authority (NYSERDA).

Stop and consider. Some private company is building a six-hundred-million-dollar white elephant in the middle of the ocean, and it’s getting paid four hundred million of taxpayer money to do so.

So … what does the New York consumer get for all of this more than generous support?

The consumer gets wind power costing FOUR TIMES AS MUCH as the current cost of power in New York.

Stop and consider. Even when the developer gets two-thirds of the cost paid by the taxpayer, offshore wind power is still four times as expensive.

Eschenbach sums it up:

What’s next?

Well, I’m sure that what’s next is the Harris/Walz campaign will declare that they are 100% behind expensive, intermittent, unreliable wind power, and will claim that if elected, they’ll do what they already said they’d do when Ms. Harris was last elected, which was to screw the consumer and the taxpayer with the huge subsidies, tax breaks, and electricity costs of offshore wind.

Oh, yeah. They claim that the 30 GW of offshore wind will “avoid 78 million metric tonnes of CO2 emissions”. Tens of millions of tonnes, sounds impressive, right?

But IF the IPCC is correct, and that’s a big if, this will reduce the temperature in the year 2050 by …

… wait for it …

… 0.0016°C. Which is almost three-thousandths of one degree F.

Can we please pass a law saying people proposing any laws or regulations in the name of “climate change” be required to tell us (and show their math) how much actual temperature difference that will make by 2050?

All the points made in this article are direct analogies to what is happening in New York State.

Offshore Trojan Horses

Gordon Hughes from the National Center for Energy Analytics compares the subsidies for offshore wind projects to “the classic warning of the Trojan Horse legend, “Beware of Greeks bearing gifts”—in other words, the hidden dangers of accepting something that seems too good to be true.” He argues that “New York State ignored that warning when it agreed to pay very high prices for the electricity to be supplied from its new offshore wind farms—Empire Wind 1 and Sunrise Wind—located off the coast of Long Island.” He continues:

In announcing the final agreements, New York Governor Kathy Hochul triumphantly claimed that the new projects would create more than 800 jobs during the construction phase and deliver more than $6 billion in economic benefits for the state over 25 years.

Rather less emphasis was given to the fact that New York will pay an average price of over $150 per MWh (megawatt hour) for the electricity generated by Empire Wind 1 and Sunrise Wind.That’s more than four times the average wholesale price of electricity in New York during 2023–24, $36 per MWh. The total annual premium over the wholesale market price for the power from these wind farms will be about $520 million per year at 2024 prices. Over 25 years, New York ratepayers will be paying about $13 billion for alleged benefits of $6 billion.

That is not all. Thanks to tax credits, U.S. taxpayers will cover at least 40% of the costs of constructing the wind farms. At a minimum cost of $5.5 million per MW (million watts) of capacity, the total federal subsidy for New York’s two wind farms will be at least $3.8 billion.

He also evaluates the jobs and economic claims made by the Hochul Administration. He concludes that “The economic benefits of the two offshore wind farms are much lower than claimed by the governor and the jobs are, in large part, temporary assignments for professional services staff”. I would add that the temporary assignments will probably be filled by experienced staff from out of state.

Conclusion

The offshore wind proposed contracts are unsustainable. Eschenbach suggests that folks in New York should be asked” “Are you willing to pay four times the going rate for electricity for the rest of your life to MAYBE cool the globe by three-thousandths of one degree Fahrenheit a quarter century from now?” I agree and think that these facts need to be publicized because most New Yorkers have no clue that Climate Act implementation inevitably will increase costs significantly.

Lastly, note that Climate Act proponents have always argued that one of the goals was to demonstrate leadership for the energy transition. This article presents two examples where New York’s transition leadership is cited. Unfortunately, both are bad examples showing what to avoid.

New York Future Energy Economy Summit Pre-Meeting Update

On August 5 Governor Hochul announced a Future Energy Economy Summit that will “gather feedback on strategies to accelerate renewable energy deployment and explore the potential role of next generation clean energy technologies”. I described my initial thoughts on the summit and possible outcomes earlier. This post provides a pre-meeting update.

Overview

Purpose

Never forget that the Climate Act has always been mostly about politics and much less about rational energy policy. I do not think that there is any question that this Summit is intended in part to gauge the reaction of favored political constituencies. I have seen several notices from activist organizations calling for people to rally at the event against “false solutions” which I believe boils down to anything other than wind, solar, and energy storage. With nuclear being at the top of the worst example of a false solution.

In my opinion, the State must confront the possibility that the safety valve criteria in New York Public Service Law § 66-p (4) for unsafe and inadequate electric service, impairment of existing obligations and agreements, and unacceptable increase in arrear or service disconnections will be exceeded. I recently recommended that those criteria be specified so that there are quantifiable targets. I hope that there are discussions that can further that requirement during the summit.

The other missing piece to date is the implementation plan for the transition. The Scoping Plan is no more than a outline list of different strategies that someone has calculated will produce the emission reductions necessary and the energy required for New York State to meet the Climate Act mandates. There is insufficient documentation to meaningfully critique the outline, and the Hochul Administration failed to respond to technical comments on the draft before it approved the Final draft. A feasibility analysis has not been produced and must be included for a credible transition plan. Better still would be a small-scale net-zero demonstration for an isolated jurisdiction that proves that an electric system can rely on intermittent wind and solar resources as the primary source of generation. I hope that there will be discussion of this concept at the Summit.

Attendance

There is still no indication who will be on the panels. In my original post I mentioned that I was worried that this would just be another dog and pony show. I cannot comment on this until I know who is on the panels.

Public participation has been restrictred The meeting announcement mentioned that there was limited seating capacity for the event but at the same time it listed statements from eight different agencies. I fail to see a connection between the Department of Health and Department of Labor with respect to energy policy. If they send representatives, then fewer affected stakeholders or members of the public can attend. I heard from several people who were waitlisted and asked a politician for help but did not get invited. Contrary to my expectations, I managed to get invited.

Summit Agenda

On August 7 when I wrote the first summary of the Summit, I included the following list of sessions that had been posted:

Welcome Remarks and Morning Keynote
State of Technology
Status of Next Generation Energy Technologies
Luncheon Keynote
Insights from Large Consumers of Electricity
Global Perspectives: Representatives from other states and nations who are pursuing advanced nuclear installations.
New Nuclear Blueprint: Vet Draft Blueprint as framework for New Nuclear Master Plan
Wrap up and Next Steps

The agenda for the meeting on September 2 has changed. The original first session “State of Technology” has been changed to “Accelerating Renewable Energy Deployment in New York State”. The original first session “State of Technology” did not seem to be all that much different from the second session “Status of Next Generation Energy Technologies” so this makes sense. However, the title “accelerating renewable energy deployment” suggests that no one is willing to conceded that building as much renewable energy as possible as fast as possible without a plan or feasibility analysis might not be a good idea.

At the PSC Zero Emissions by 2040 Technical Conference last December there were sessions devoted to pandering to real “false solutions” for a future economy. Technology shills and activists subscribe to a dream that with enough energy conservation and “smart planning” the myriad problems identified by the organizations responsible for grid reliability can be ignored. I fear that the Status of Next Generation Energy Technologies panel will include the same proposals without anyone on the panel providing contrary feedback. It is long past time for the Hochul Administration to support the concerns expressed by the PSC, NYISO and other organizations with reliability responsibilities and stop pretending that some of the cockamamie schemes suggested by irresponsible entities can provide meaningful future support.

The opening and luncheon keynote speakers will likely set the tone for the meeting. One hour is set aside for the welcome and keynote presentations. If that is nothing more than bragging about the “success” so far and excuses for the findings of the negative assessments, then I will have little hope for any meaningful results. The same holds for the luncheon speaker.

One of the issues raised by the analyses to date is that loads will increase due to electrification of everything and new “Large Consumers of Electricity”. The huge, proposed Micron chip fabrication plant is the prime example. What are the odds that representatives from those facilities will tell the truth that unless there is demonstrated path to success or an alternative backup plan that it would be madness to invest billions of dollars because there is no assurance of reliable, affordable electricity.

The last two sessions address nuclear energy projects. In my opinion, this is the primary driver of this Summit. The only jurisdictions that have significantly reduced their GHG emissions from the electric sector without relying on hydro or geo-thermal resources used nuclear. However, nuclear is unacceptable to many of the activists who are the strongest supporters of the Climate Act. I have seen several pleas for people to come to rally against the false solutions. The meeting was held in Syracuse and that just happens to be the closest city to three operating nuclear reactors. I will be shocked if there aren’t visible signs of support from staff at those facilities.

Conclusion

There are some encouraging signs that people are catching on that no matter how you feel about doing something about climate change the reality is that New York’s plan is deeply flawed. I am convinced that the plan will do more harm than good. The Energy Summit could be the start of a correction process that might reduce the inevitable increased risks to reliability, extraordinary price increases, and significant environmental impacts if there is no course correction. On the other hand, it could be another story from Macbeth “A tale told by an idiot, full of sound and fury, signifying nothing”.

Stay tuned for an update later this week.

Commentary on Recent Articles 30 August 2024

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.

Natural Gas Politics and Production

Canadian Terry Etam describes the natural gas conundrum in which the widespread deployment of fracking technology enabled producers to accelerate the production of natural gas “while simultaneously driving prices into the toilet”.

Etam describes the graph:

First, the gradual increase in production from about 2006 onwards was the result of the high prices of 2002-2006, which spurred development and led to the unlocking of the US’ vast shale gas resource. High prices footed the bill for shale exploration and experimentation, which set the stage for future growth.

One of the biggest reasons for these wild trajectories is that the industry just keeps getting better and better at getting gas out of tough formations. (While there are many ways drilling and completions are improving, these advancements should not be confused with the simple act of drilling longer horizontals which is often viewed as an efficiency gain – it is a capital efficiency gain, no doubt, but not like an improved frac is – a longer lateral simply chews up the reservoir faster. One day in a decade or two we will look back and go, oh yeah, maybe that was significant…).

Those technological/fracking improvements drove the first waves of growth, but don’t completely explain the steepest part of the curve. Note in particular the pinkish shaded box, corresponding to roughly April 2017 to April 2021. Over that four-year period, the US added about 27 bcf/d, which is about 1.5 times Canada’s entire output, while prices fell from about $3.00/mmbtu to $2.00. That’s the sort of antics a guy like Warren Buffett really frowns on.

He goes on to explain that the future is not clear:

Today, here in mid 2024, the future is murky. We know a few things: that the US (and Canada) are both capable of a lot more natural gas production. We know that demand is going to go up over the next half decade at a minimum, possibly by as much as 30 percent, due to new LNG export terminals and data center/AI demand.

What we don’t know is how easy it will be to build any new infrastructure to enable new volumes to get to where they need to be. We’re well used to this problem in Canada, of course, which is a basket case; it is a miracle that Coastal GasLink was built at all, and it is hard to imagine any entity having the intestinal fortitude to attempt any new greenfield interprovincial infrastructure, which is federally regulated, which means the ruling alliance would laugh you off Parliament Hill for even showing up with your briefcase

The US is not far behind; the only significant interstate gas pipeline to go into service in the past few years has been the Mountain Valley Pipeline which was many years delayed by swarming activist attacks, and was completed at double the initial cost estimate (MVP was first proposed in 2014, and was scheduled to come onstream in 2018; it finally started flowing gas in 2024). A more realistic reading of the current US natural gas interstate pipeline system is this: In July 2020 the Atlantic Coast Pipeline, a large and critical new pipe that would have taken excess Appalachia gas to a thirsty US east coast, which was six years in planning, was shelved despite receiving a 7-2 vote of approval from the United States Supreme Court (from the project cancellation news release: “A series of legal challenges to the project’s federal and state permits has caused significant project cost increases and timing delays. These lawsuits and decisions have sought to dramatically rewrite decades of permitting and legal precedent including as implemented by presidential administrations of both political parties. As a result, recent public guidance of project cost has increased to $8 billion from the original estimate of $4.5 to $5.0 billion… This new information and litigation risk, among other continuing execution risks, make the project too uncertain to justify investing more shareholder capital.”)

To emphasize just how tough it is to actually build a new pipeline, Dominion Energy, one of the Atlantic Coast partners, took a $2.8 billion charge to earnings in cancelling the project. Think about that. A public company chose to eat a $2.8 billion loss rather than attempt to build a new, approved pipeline.

He concludes that there is so much uncertainty in the gas markets that any projections for the future are speculative. I conclude that politicians and energy policies don’t work well together.

National Center for Energy Analytics

I received an email from an interesting organization that can help is all understand energy policies. The National Center for Energy Analytics is a “new energy think tank devoted to data-driven analyses of policies, plans, and technologies surrounding the supply and use of energy essential for human flourishing.” Executive Director Mark P. Mills explains:

Modern civilization hinges on abundant, affordable, and reliable energy. Policies ignoring those fundamentals are doomed to fail. There is of course the constant refrain that an energy transition—a shift away from oil, natural gas, and coal—is not only underway, but accelerating. However, hydrocarbons continue to supply over 80 percent of America’s and the world’s energy, a proportion largely unchanged in two decades. The Inflation Reduction Act (IRA), designed to expedite a transition, is projected to cost between $2 trillion and $3 trillion, far exceeding initial claims. That level of spending, alongside similar state-level initiatives, means that energy issues are unavoidably a central feature of U.S. economic and policy debates.

Energy policies are essentially bets on how we can meet future demands. But, setting aside the usual aphorisms about predicting the future, history shows that innovators have always created far more ways to consume energy than to produce it. Thus effective energy policies must not only anticipate the future but also do so while simultaneously meeting the three core energy metrics of ensuring abundance, affordability, and reliability. The energy transition is a popular narrative, but the practicalities of physics, engineering, and economics point to a future that will see an enduring reliance on hydrocarbons.

Claptrapping

Irina Slav captures my frequent feeling of helplessness when I try to see how uninformed political pressures are adversely affecting the energy system.

One of the marks of helplessness is the frequent use of a specific word or a group of words to describe a situation you cannot change, which fact invokes the feeling of said helplessness.

I know this because I frequently use the word stupid and synonyms to describe the people leading us into the energy transition. This is in part because they are, indeed, stupid, and in part because I cannot do anything to stop them. On a positive note, it seems some of the most devout transitionistas are also feeling quite helpless.

She goes on to describe a recent article:

In a commentary piece for the Financial Times on Wednesday, its business columnist and associate editor Pilita Clark called out Elon Musk and Donald Trump for what she described as “misleading, misinformed or just plain baffling utterances that continue to gush forth in the face of an increasingly evident problem.”

She also described the pushback against the climate change narrative as “claptrap”. A total of seven times. In an 800-word piece. Ms. Clark was not a happy associate editor when she wrote that piece.

Slav describes the whole commentary. Ms. Clark complains that there are people who have the audacity to make “rubbish claims” about the green technologies that are supposed to save us from climate Armageddon. Slav responds that despite the obvious issues with the technologies and the cost of implementing them that the UK political war on fossil fuel companies is driving the companies away:

“If the government implements the kind of windfall taxes they are talking about, then you end up with a cliff edge in UK energy production because the industry will be taxed into uncompetitiveness,” Chris Wheaton from Stifel said. “That is going to cause a very dramatic decline in investment and therefore production and jobs, and a big hit to energy security.”

I recommend reading the whole article. She offers several more examples of the cost and environmental impacts of the “clean energy” transition in an entertaining way.

Billion Dollar Disasters

One of the arguments used by activists is that we must address climate change because we are seeing the effects now. As proof the apparent increase in the costs of disaster losses from the National Oceanic and Atmospheric Administration (NOAA) are frequently cited. Roger Pielke, Jr. called their numbers out noting that their dataset is “a clever public relations gimmick, to be sure, but it should never be used in scientific research, climate assessment reports, or as a grounding for policy.”

Early this year he submitted a “request for correction” and notes that NOAA did respond. They admitted that the documentation and transparency of the disaster loss dataset needs to be improved. Pielke suggested that NOAA align their methods to be consistent with the Intergovernmental Panel on Climate Change but, not unlike New York, the response blew off the issue and suggested that they will continue to do what they are doing. Pielke concludes “Based on what NOAA has found, no one should be using the dataset in research or in a scientific assessment — Unless of course the goal is PR, not science.”

Lomborg Newsletter

The always informative Bjorn Lomborg newsletter had several interesting articles. He explained why a scare story of polar bears dying out is a tactic that leaves us poorly informed. I agree with his argument that in order to achieve the transition proposed that clean energy innovation is necessary. He also makes persuasive argument that it is not in the best interests of the third world to decarbonize with existing technology that is so expensive. In my opinion that underscores the need for clean energy innovation. Even though there are green energy subsidies of almost $2 trillion each year he explains that “when societies add more renewable energy, most of it never replaces coal, gas or oil. It simply adds to energy consumption”.

Follow the Energy Transition Money

Bill Peacock quantifies the subsidies given to fossil fuels, nuclear and renewables. He includes a table based on information sourced from Bennett, et al; U.S. Joint Committee on Taxation 2019 & 2023; U.S. EIA; Congressional Budget Office.

Peacock notes:

Perhaps these claims are efforts to distract from massive renewable energy subsidies that are driving the “energy transition” from fossil fuels to renewables. As seen above, renewables received $74 billion from the U.S. government in 2010–19. They are expected to increase to $244 billion from 2020 to 2029. The subsidies are the only reason that wind and solar generation exist on the U.S. grid at commercial scale.

He also provides costs per energy produced or MWh:

Peacock goes on to document the impacts on reliability and increased costs that are a direct result of these subsidies. I agree with his conclusion:

When politicians take over markets, bad things happen. Costs increase, consumer choices are thwarted, and well-connected businesses get rich off taxpayers. We see all these things happening in the U.S. energy transition from fossil fuels to renewables. The only way to eliminate these and other harms is to let the market work and eliminate all energy subsidies—federal and state—in America.

Offshore Wind Meets Reality

Last month I described a flurry of offshore wind related news and there have been enough stories since then for another update. In my opinion these latest revelations suggest that a reassessment of the viability of offshore wind projects is in order.

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 has to be 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.

Turbine Blade Failures

Bud’s Offshore Energy reports that:

The “highly unusual and rare” talking point for turbine blade failures seems to have finally been discarded.

3 new GE Haliade-X blades failed shortly after installation at Dogger Bank and Vineyard Wind. A total of only 48 turbines had been installed.

Siemens Gamesa and Vestas, the other 2 leading manufacturers, have also experienced unacceptable failure rates. Also

One of the reasons for waiving the “pay as you build” financial assurance requirement for Vineyard Wind was “the use of proven wind turbine technology.”

Dr. Edgar Gunter (RIP 😢), founder of the University of Virginia’s Rotor Dynamics Lab, suggested the cause of the Vineyard Wind blade failure was not a material bonding problem, but rather “a classical torsional fatigue failure of the blade at the base.” (His message is below)

Bud’s Offshore Energy continues with some other thoughts:

The offshore safety regulator (BSEE) has a very capable technical staff and should produce an informed report on the Vineyard Wind blade failure. The concern is with the internal review process that has seriously delayed the publication of accident investigation reports and safety alerts.

Presumably, DNV, the Vineyard Wind CVA, will provide input into the BSEE investigation. Perhaps the effectiveness of the CVA process and quality control procedures should be separately considered.

Will Equinor, a major oil and gas producer, Dogger Bank partner, and offshore wind advocate, be investigating the Dogger Bank failures?

A comprehensive International data base on turbine incidents and performance is needed.

As previously noted, offshore substations are large structures. A closeup of the Vineyard Wind 1 substation is pasted below.

Consequences of Turbine Blade Failures

Paul Driessen points out that one broken wind turbine blade shut down Massachusetts beaches and asks what would happen if a hurricane struck. He describes the impact of the Vineyard Wind failure:

Shards, chunks and finally the rest of a turbine blade fell into the ocean. One blade … from a 62-turbine project that’s only three-fourths completed … broken by its own weight, not by a storm.

And yet beaches had to be closed amid peak tourist season, while crews picked up pieces of fiberglass-resin-plastic-foam blades, and boats dodged big pieces floating in the water. Worse, Vineyard Wind didn’t tell Nantucket officials about the problems until two days after the blade began disintegrating.

Each blade is 350 feet long and 140,000 pounds. That’s more than a fully occupied Boeing 737 jetliner. Vineyard Wind involves 186 blades: 65,000 feet (12 miles) in total combined length, weighing in at a combined 26,000,000 pounds!

Vineyard Wind will have 62 wind turbines and a total capacity of 800 MW. Driessen notes that:

The Biden-Harris offshore wind plan calls for 30,000 megawatts of generating capacity by 2030. That’s 2,500 gigantic 12-MW offshore turbines. That won’t even meet New York State’s current peak summer electricity needs, before all these extra demands kick in. Offshore wind’s contribution toward meeting future demands for all Atlantic Coast states could easily require 5,000 such turbines: 15,000 blades, weighing a combined 2 billion pounds and spanning a combined 5,250,000 feet (995 miles)!

Source posted by Brian J @Mainsail23

He points out the obvious problem that the planned offshore wind facilities on the East Coast can all be affected by hurricanes:

Even more disturbing, the entire Atlantic coastline is hurricane country. Every year, almost without fail. The only questions are how many hurricanes, how powerful, and where each one will hit.

NOAA records for landfalling hurricanes – those that actually hit US beaches and cities – reveal that 105 Category 1-5 hurricanes struck the Atlantic seaboard, from Florida to Maine, from 1851 through 2023. Add in those that remained at sea, where the turbines will be, and that number could double.

Of that total, 23 were Category 3-5 (111-157 or higher mph winds). Most struck Florida, Georgia and South Carolina. But 39 made landfall between North Carolina and Delaware – and 19 hit Northeastern States, including nine Category 2-3 monsters (96-129 mph winds).

Mind you – these turbines will be weakened by constant corrosive salt spray and frequently by sub-hurricane storms. When the inevitable big hurricane roars up the coast, devastation will follow.

The 1935 Labor Day Hurricane clobbered Florida with 200+ mph devastation, Georgia with Category 1 winds. The Great New England Hurricane of 1938 smashed into New York, Connecticut, Rhode Island and Massachusetts with 115-120 mph force. 1944’s Great Atlantic Hurricane – punished the coast from North Carolina to New Jersey and Massachusetts with Category 2 winds.

Edna hit the Northeast with Category 2 winds in 1954, Donna did it again in 1960, and Gloria clobbered the region with 96-115 mph blasts in 1985, even reaching New Hampshire and Maine! Isabel hit North Carolina and Virginia in 2003. The “minor” Category 1 hurricane of 2012, better known as Superstorm Sandy, was also devastating.

This summary includes just some that hit North and Mid-Atlantic States, and a few that slammed Florida, Georgia and South Carolina – all prime territory for forests of offshore turbines, fixed to the seafloor or insanely sitting atop enormous floating platforms off Maine and other states. They’d all flounder.

I have found one reference to offshore wind turbine expectations relative to hurricanes. Our EnergyPolicy (OEP) hosted a panel discussion on New York State’s emerging offshore wind market and the policy and business challenges facing this evolving sector, in its Energy Leaders Luncheon Series December 2019 event in New York City. The question was asked “Will wind turbines in New York be able to withstand a Category 5 storm?”

Clint Plummer who was the head of market strategies and new projects for Ørsted, the world’s largest owner, developer, and operator of offshore wind responded that “wind turbines are designed to withstand a Category 3 hurricane, and they have built into their permit applications an insurance fund that can pay for repairs in cases of catastrophic loss from a storm more severe”. He said “a Category 5 hurricane has a return period in excess of 100 years, while the design life of a wind farm is 30-35 years, so wind turbines are not designed to withstand a Category 5 storm because they are not expected to experience one”. “Anything less than that up to a certain speed is just a really good day for producing a lot of wind power,” he said

At the time of this response the offshore wind turbines proposed were smaller. Since then, the quest for higher capacity availability has led to bigger turbines that recent events suggest may not be as robust as the smaller designs. It is conceivable that when a hurricane with intensities like those observed inevitably reoccurs after the massive buildouts proposed are in place that many (most?) wind turbine blades will fail. Driessen argues that it will take months or years to replace widespread broken wind turbine blades and that it may require the construction of alternative generating sources:

Hopefully, politicians and bureaucrats could expedite new gas turbine and modular nuclear power plants. That would mean only a few years of deprivation and blackouts, instead of many years, perhaps decades.

Otherwise, floating slabs of broken turbine blades would endanger boats for months or years, until they are retrieved, hauled ashore and landfilled. Cleaning up billions of sharp shards of fiberglass – each an inch to a couple feet in length, and nearly invisible – would likely take decades, during which time they would impale and imperil beach walkers, swimmers, fish, whales, dolphins and other marine life.

I’m not a microbiologist, but I’m not aware of any microbes that devour fiberglass, resin or plastic foam.

With no bonds or requirements that Big Wind cover cleanup and turbine removal costs, electricity-bereft taxpayers and ratepayers would be left holding the bag.

Before we rush any further into this “renewable energy transformation,” can we first have some realistic, commonsense analysis? Can we at least think before casting our ballots this fall?

Maine’s Floating Turbines

As if the construction of wind turbines on fixed platforms is not enough of a challenge there are proposals for floating wind turbines. Bud’s Offshore Energy noted that recent bids on lease areas were much lower than previous sales.

David Wojick describes the curious first lease for floating offshore wind turbines in the Gulf of Maine. The State of Maine was awarded the lease which is described as a research lease rather than a commercial development lease.

To begin with, the lease is for a 144 MW “research array” of turbines, as it is called. Well, 144 MW is huge for research. The South Fork Wind site (fixed, not floating) that is already running is a 12-turbine, 132 MW commercial facility, so this array will be bigger than commercial.

It could cost $3 billion-plus the cost of the factory to make the dozen or so floaters. Different websites suggest different turbine sizes from 10 to 12 MW. Of course, if this is really research, they might use a variety of sizes, but the total is still huge.

Why so big is the first mystery, and the official explanations are far too vague to justify it. They mostly talk about research into things like efficiency, supply chain, and even jobs.

Wojick makes a couple of other points. This “research” lease development is occurring at the same time there are commercial developments underway so the results will not benefit project developments. The payment structure of this project is mirky: “if a Purchase Power Agreement (PPA) is supposed to pay for the array, plus profit, then it is very much a commercial development meanwhile research is expensive and unpredictable so how can there be an advance PPA to pay for it?”.

He suggests that there is another possibility: “This project is not about research it is about building the floater factory and demonstrating the University of Maine technology.”

There is a monster wild card in the floating wind game, and that is the factory. Fixed bottom wind is very simple onshore. All you need is a good dock, a big crane, and a place to sit the components until they are taken to the site and installed. There are just a few simple components — monopile, tower, turbine, and blades. It is all made elsewhere.

Floating wind is made from scratch onshore then towed as a whole to the offshore site. The Uni-patented technology uses concrete floaters which might weigh 15,000 tons or more and are complex structures. Factory construction of floaters will be a huge job.

This fact about floating wind is seldom mentioned, and when it is, the language is usually deceptive. The industry talks about “ports,” not factories, and the Maine floater factory is called a port. See my. note that the factory will be operated by Diamond.

So here is what might happen. As part of the “research” Maine builds the floater factory and enough floaters to demonstrate that the patented Uni- technology works. Developers of the 15,000 MW of commercial Gulf wind have to choose technologies for their various sites. If they choose any other technology, out of over a hundred candidates, they will have to build the factory to make it.

Once the floater factory is built then a powerful incentive to use it exists. Given that they are talking about $100 billion in floaters the developers, the State of Maine and the University of Maine will make a huge amount of money. Of course, the money has to come from somewhere so expect the ratepayers in Maine to be on the hook for that. Wojick concludes:

Mind you I am not claiming this is what is going on, but it certainly makes sense out of this supposed research array. The primary obstacle is that the Uni-technology has never been built at 10-12 MW scale and it might not be feasible. Also, the factory design that I have seen does not work, but that is a separate issue.

Hot Air Renewable Notes

Beege Welborn has a nice overview article: Blade Failures Continue and Don’t Go Missing in an Offshore Wind Farm on the Hot Air website. The article describes blade failures in Missouri, covers the problems at Vineyard Wind, notes that the plans for huge offshore wind farms require mind-boggling amounts of material, and notes that there are radar interference issues with planes and offshore wind farms. Finally the article includes a reference to an incident where “wind industry henchmen are showing their true colors during citizen meetings”. The thug” walked up and grabbed” a bag belonging to a woman showing fiberglass shards that washed ashore from the damaged turbine while she attempted to explain her concerns about offshore wind development at a Newport, RI wind farm forum. The guy had been featured at Senator Sheldon Whitehouse’s website until the incident. Thankfully, the goon’s facing assault charges.

Conclusion

The Hochul Administration’s Integration Analysis projects that offshore wind capacity will exceed 13 GW by 2040. These latest revelations suggest that a reassessment of the viability of offshore wind projects is in order. The technology has not been tested on the scale proposed and it sure appears that there are survivability issues even without storms. What could possibly go wrong?

Cassadaga Wind Concerns

Rich Ellenbogen sent an email today after receiving a link to a video describing the construction of the Cassadaga Wind Farm in Chautauqua County, New York. Rich describes the video, provides some background information, and expresses concern about end-of-use disposal. The email triggered a recollection of an article about a post by Robert Bryce that found that the output from the facility was contracted to New England. I have combined Rich’s email with relevant parts of my earlier article in this post.

Ellenbogen is the President [BIO] Allied Converters and frequently copies me on emails that address various issues associated with the Climate Leadership and Community Protection Act (Climate Act). I have published other articles by Ellenbogen including a description of his keynote address to the Business Council of New York 2023 Renewable Energy Conference Energy titled: “Energy on Demand as the Life Blood of Business and Entrepreneurship in the State -video here: Why NY State Must Rethink Its Energy Plan and Ten Suggestions to Help Fix the Problems” 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

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 has to be 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.

Current projections for land-based wind in New York State in 2040 when all electricity must be generated by “zero-emissions” resources range from 15,549 MW in the New York Independent System Operator 2023-2042 System & Resource Outlook (State Scenario Capacity Expansion Model Results – No Headroom case) to the 13,096 MW in the latest Integration Analysis. In 2021 there were 2,277 MW of land-based wind so in the next 19 years between 13,322 and 10,869 MW more wind capacity is projected.

Ellenbogen Summary

In this section I have edited and reformatted the material in Ellenbogen’s email.

The video Green Madness – The Waste and Destruction Caused by One Industrial Wind Project was made by people in western New York whose beautiful countryside has been damaged by industrial wind. The compelling video shows the massive destruction involved. For scale here is a satellite view from Bing maps.

Source: Bing Maps Several miles SW of Cherry Creek, NY

Ellenbogen continues noting that what is happening now in New York State is very similar to what occurred in Ontario in 2018 – 2019 that led to a change in the government. Now they are tearing down completed wind farms. It started with a “rebellion” in the rural areas because of the exact same thing that is shown in the video and then progressed to the urban areas when the energy prices spiked.

Someone else that received the video sent the chart below that shows the materials needed to generate one megawatt hour of electricity with the different technologies. The 20% capacity factor for solar is high for NY State so the Material per MWh will be higher.

Ellenbogen notes that upstate residents are not only angry with the amount of material used and the clear cutting of large amounts of forest but also the net holistic impact on the environment, especially when considering the end of life disposal. This link documents the issue that a town in Minnesota is having with that.

Seriously, this sucks’: How a small Minnesota town was left with a giant pile of wind turbine blades Grand Meadow wants someone to get rid of the mess after a failed effort to recycle the massive, worn-out parts.

The article

By Walker Orenstein

In the Minnesota Star Tribune states:

GRAND MEADOW, MINN. – Darcy Richardson had big plans for a garden patio enveloped by flowers in her backyard in this little community south of Rochester.

She gave up once the blades arrived.

Trucks dropped off more than 100 fiberglass turbine blades on the empty lot next door in 2020, haphazardly stacked to the edge of Richardson’s property. Almost four years later, the mountain of old wind parts — which is visible on Google Earth — is still there.

Some blades are cracked and stained. Locals say they draw feral cats and foxes and are a safety risk because kids climb on the junk.

They’re also ugly, ruining Richardson’s view, hurting property values and attracting the curiosity of seemingly everyone who drives the highway into town.

Cassadaga Wind Farm Energy Contract

I found that the story for this wind farm is even worse. Robert Bryce, writing on the Real Clear Energy blog described an aspect of New York wind development that I wrote an article about in June 2020.

Bryce explained how New York is becoming “a wind-energy plantation for New England” with massive projects proposed in the state’s poorest counties. In particular, he describes one project:

“The 126-megawatt Cassadaga Wind Project is now being built in Chautauqua County, New York’s westernmost county. The project includes 37 turbines, each standing about 500 feet high, spread over 40,000 acres (62 square miles). The project is owned by Innogy, a subsidiary of the Essen, German-based utility E.On.”

On January 18, 2018, the New York Department of Public Service published the Order Granting Certificate of Environmental Compatibility and Public Need, With Conditions which approves the application to build the facility. Buried in this document is the following: “the output of the Facility is contracted for out-of-state purchase”. Mr. Bryce explains that generation will be credited toward renewable goals in Massachusetts, Connecticut and Rhode Island. He notes that in an email:

“a spokesperson for Innogy confirmed that the buyer of the power to be produced by Cassadaga is a group of seven New England utilities procured through the New England Clean Energy request for proposals’ in 2016. How will the juice from New York get to New England? It won’t. Instead, the Innogy spokesperson told me that the energy produced by the turbines at Cassadaga ‘will be used to serve local energy requirements in areas surrounding the project. Export to areas outside New York would require dedicated point-to-point transmission lines’.”

Mr. Bryce also reviewed data published by the Department of Energy and the New England Power Pool to look the overall picture. He found that “of the nearly 4 million megawatt-hours of wind energy produced in New York in 2018, the state exported 1.2 million megawatt-hours, or 30 percent, to New England. When the Cassadaga wind project begins operating, it will likely add another 364,000 megawatt-hours per year in renewable-energy credits to that export total”.

As a result, the Cassadaga Wind Farm cannot be considered as part of the renewable energy that should not be included in the Climate Act renewable energy credit claims because that would be double counting. I have no idea how many other NY facilities have renewable energy credit agreements with New England, but I bet it is not zero.

The Cassadaga permit application approval Order Granting Certificate of Environmental Compatibility and Public Need, With Conditions noted that the output of the facility will be credited out-of-state:

“As the Examiners demonstrated, the goals of the State Energy Plan are not restricted to renewable electricity consumed within the state, but are also oriented toward national and international goals of reducing carbon and transforming the energy industry. For that reason, the Examiners’ finding was not changed by the fact that the output of the Facility is contracted for out-of-state purchase. This conclusion is bolstered by the decision of the Appellate Decision in a previous Article X proceeding that production of electricity within the state is beneficial irrespective of the contract path of the output. No party took exception to the RD’s proposed findings and determinations on this issue, and we adopt them.”

Conclusion

There are 37 wind turbines in the Cassadaga project. There are 27 Nordex N117 turbines rated at 3.675 MW and 10 Siemens Gamesa Renewable Energy G114-2.625 MW turbines rated at 2.625 MW. Recall that the NYISO Resource Outlook and the Integration Analysis have projected that between 13,322 and 10,869 MW more wind capacity will be needed. That means that there will be at least 2,958 new turbines and could be as many as 5,075 turbines. That means impacts on the order of 100 times those shown in the video will be coming soon to New York State.

I have yet to see any acknowledgement of this kind of contract’s impact on Climate Act renewable energy accounting. This is another complication ignored by the Scoping Plan implementation program. Acknowledgement of the issue would make compliance harder so it is not surprising that it has been ignored.

It never ceases to amaze me how every single aspect of the Climate Act transition is more complicated and uncertain than acknowledged by the Hochul Adminstration. Those factors certainly will add to the ultimate costs and make it less likely that the political aspirations can overcome reality. This is madness.

August 2024 Update on the New York Cap-and-Invest Plan – Investment Framework

In the first two months of 2024 the New York State Department of Environmental Conservation (DEC) and the New York Energy Research & Development Authority (NYSERDA) worked on the New York Cap-and-Invest (NYCI) Program stakeholder engagement process requesting comments on the pre-proposal outline of the regulations. Since then, nothing much has happened until a webinar was held on August 15, 2024, where DEC and NYSERDA presented “a draft 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. The webinar presentation and recording are now available.

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. I have extensive experience with air pollution control theory, implementation, and evaluation of results having worked on every cap-and-trade program affecting electric generating facilities in New York including the Acid Rain Program, Regional Greenhouse Gas Initiative (RGGI) and several nitrogen oxide programs. 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 has to be 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.

Cap-and-Invest

The Climate Action Council’s Scoping Plan recommended a market-based economywide cap-and-invest program. Since my last post on this subject, I have read a couple of relevant articles that provide background information on this approach. Dr. Lars Schernikau is an energy economist who explained why an emissions market solution for CO2 is not likely to succeed. He explained that CO2 pricing (also falsely called “carbon pricing”) is a terrible idea fit only for discarding in The Dilemma of Pricing CO2. Ron Klutz summarized the article with emphasis and added images. The other article noted explained that the label cap-and-invest is a political marketing term “to boost their appeal and reflect the growing use of funds for climate protection.” In brief, cap-and-invest is a marketing cover for the politically toxic carbon tax.

The program recommended by the CAC 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 Leadership & Community Protection Act (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.

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. In my submittals I have expressed two primary concerns. The first is that 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. The second concern is that the NYCI feature that “ensures annual emissions are reduced” must be integrated with the investments needed for those zero-carbon emitting resources. If there are inadequate investments, then the only option for the affected sources is to reduce or stop operations. If the affected source is an electric generating station, there could be reliability implications.

Public Webinar August 15, 2024

The meeting description said:

The New York State Department of Environmental Conservation (DEC) and New York State Energy Research and Development Authority (NYSERDA) are seeking public input as they develop a framework for the use of New York Cap-and-Invest (NYCI) proceeds from the Climate Investment Account. The Climate Investment Account is a critical component in supporting New York’s transition to a less carbon-intensive economy by directing NYCI auction proceeds to projects that benefit New Yorkers, prioritizing frontline disadvantaged communities that historically suffered from pollution and environmental injustice.

In the Fiscal Year 2024 State Budget, Governor Kathy Hochul laid out the structure of the Climate Action Fund for NYCI proceeds. The Climate Investment Account is one component of the fund and will be used to direct two-thirds of future NYCI proceeds. The remaining proceeds will go to an account to directly mitigate consumer costs, guided by the Climate Affordability Study, and a third account will support energy affordability for small businesses.

The agenda included the following items:

Climate Leadership & Community Protection Act Overview
Introduction to New York Cap-and-Invest (NYCI)
Use of Proceeds from the Climate Investment Account
Request for Public Input
Questions and Answers
How to Submit Comments and Stay Involved

Nothing new was provided in the first two agenda items. If you are interested in this background information I have linked the start of the video description for each section to the following links: overview of the Climate Act and introduction to NYCI.

The focus of the webinar was on Investment of Proceeds. Maureen Leddy, Director of the Office of Climate Change, described the investments plan. In the first slide she explained that the proceeds from the NYCI auction are distributed to the Climate Action Fund. The Fiscal Year 2021 Budget established this Fund and how the proceeds would be invested and then allocated. There are three parts:

Consumer Climate Action Account: At least 30% of future NYCI proceeds to New Yorkers every year to mitigate consumer costs.
Industrial Small Business Climate Action Account: Directs 3% of future NYCI proceeds benefits to help mitigate cost.
Climate Investment Account: Directs two-thirds of future NYCI proceeds to support the transition to a less carbon-intensive economy

Readers should keep in mind that the ostensible purpose of the Climate Act is to address the existential threat of climate change. To make the reductions necessary to mitigate this threat only two thirds of the proceeds are directed to the “less-carbon-intensive” economy. The other two carveouts appease consumers and small businesses that will be impacted by the increase in energy costs caused by NYCI.

The Consumer Climate Action Account is supposed to mitigate consumer costs. As has been the case throughout the Climate Act implementation, the Climate Affordability Study that recommends how the funds will be delivered is just a list of options with no discernible plan to implement them. The proceeds to small businesses are nothing other than a bribe to try to appease that constituency. The Climate Investment Account is supposed to support the necessary investments in zero-emissions resources necessary for compliance.

The focus of the webinar is the Climate Investment Account. Even though 67% is supposed to support the emission reductions for the transition, the New York legislators mandated how it will be allocated further diluting the amount targeted for transition investments:

Purposes consistent with the findings of the Scoping Plan.
Measures which prioritize Disadvantaged Communities (DACs) by supporting actions consistent with the requirements to maximize net reductions of greenhouse gas emissions and co-pollutants in DACs and investing 35% with a goal of 40% in DACs, identified through community decision-making and stakeholder input, including early action to reduce GHG emissions in DACs.
Administrative and implementation costs, including auction support, program design, and evaluation.

These allocation requirements reduce the potential effectiveness of the investments to make emission reductions. I find it troubling that this legislative mandate and the webinar presentation made no mention of cost-effective investments to reduce emissions. In a recent post I evaluated the State’s investments from the Regional Greenhouse Gas Initiative. The good news is that investments in energy efficiency were relatively effective investments. As a result, I think the emphasis on DAC investments should be on energy efficiency improvements, but the legislative mandate states that community decision-making and stakeholder input will decide.

The final statement that the “Allocation of funds will be finalized through the State Budget process” is important. In my opinion, taxes must be levied by the legislature and not through a regulatory proceeding. It may be that the process outlined here is intended to fulfill that mandate. As we shall see, the questions posed in the webinar provide a basis for how the revenues (aka the tax) will be allocated.

The next slide outlined the timeline and is consistent with my impression that this is intended to fulfill the legislative mandate. The presentation noted that they “laid out our process for seeking public input on the use of NYCI proceeds under the climate account.” It went on to say that “today we’ll share a draft framework for the investment and start this comment intake to connect, collect initial public input on the use of proceeds.”

Leddy went on to describe the comments received earlier this year. They claimed that “As part of extensive stakeholder engagement since 2023, DEC and NYSERDA received thousands of comments about Cap and Invest implementation.” Previously the comments focused on regulatory program design but 128 organizations and institutions “submitted comments addressing the use of proceeds, equity, and/or affordability.” The presentation claimed that it is a good thing that 39 advocacy organizations,

37 trade associations & 3 labor unions, 35 businesses & 7 utilities, 11 governmental bodies/authorities,

3 think tanks responded with comments about the use of proceeds.

The first summary slide describing the comments received listed three main themes. The first is to “advance the deployment of decarbonization technologies in key sectors & enable emissions reductions”. Leddy just read the slide so there was no indication of the necessity to deploy technologies so that the emission reduction trajectories can be met. The second theme was “Support the clean energy workforce & prioritize labor protections”. There is no question that worker training is necessary, but I have two concerns. The first is that the necessary training does not lead to direct emission reductions, and I doubt very much that those costs were included in the Hochul Administration’s estimates of the costs and benefits, so I suspect that those projections underestimate costs. The second point is that emphasizing labor projections is an appeal to a specific constituency not necessarily incorporating the most cost-effective reductions. The final theme was “Prioritize affordability & lower the cost of the energy transition”. The examples are for low-income New Yorkers and business & industry. I worry the average ratepayer will be overlooked.

One of the primary topics emphasized is climate justice as it relates to equity and affordability. The next slide described two themes. The first theme was the specific challenges facing disadvantaged

communities (DACs): air quality impacts, vulnerability to energy price increases, and structural and financial barriers to implementing control strategies. I worry that addressing these concerns make take precedence over strategies that actually reduce emissions. The climate justice aspect of the Climate Act has focused on disadvantaged communities (DACs) and, in my opinion, could be overlooking rural concerns. For example, deployment of clean energy technologies in DACs included transportation concerns: “public transit; electric vehicles (including buses and heavy-duty vehicles); and public chargers/fast charging networks.” All those are primarily urban concerns.

The next item on the agenda was the framework and areas for investment for the proposal. Vanessa Olmer (?) went through the draft proposal to guide the use of NYCI proceeds. Make no mistake that the Climate Act is all about politics and the NYCI proposed plan to use the proceeds is no exception. The draft proposal is “designed to be consistent with the five core principles that the Governor set forth for the cap and invest program”. My comments on the pre-proposal draft addressed these principles. My comments noted that The Hochul Administration has never clearly admitted the expected costs of the Climate Act net-zero transition because the costs are politically toxic. This principle is an attempt to suggest the costs are under control. The climate leadership slogan is inconsistent with the Climate Act unique emissions accounting approach that prevents other states from joining New York or linking programs with New York. Creating jobs is a much-repeated tenet of the Climate Act but I do not believe it is possible to create more jobs than lost due to the increased costs inherent in a net-zero transition. While there is no question that Climate Justice investments in DACs are appropriate it is not clear that those investments will make those least able to afford higher energy prices whole when the full costs of the transition hit the economy. The final principle is funding a sustainable future. My comments emphasized the need for investment in zero-emissions technologies that can displace greenhouse gas emitting technologies.

The presentation went on to describe a framework for the investment of NYCI proceeds. “This framework would inform the identification of draft investment areas that NYCI proceeds will be directed toward.” The agencies asked for public input to “refine the framework and to help identify and prioritize investment areas for the Climate Investment Account.”

As shown in the next slide the description of the proposed investment framework is linked to the guiding principles. It is encouraging that the framework places funding for the sustainable future at the top. Funding investments that reduce greenhouse gas emissions and sequester carbon are necessary to meet the Climate Act mandates. Sadly, the speaker again just read the slide and failed to emphasize the link between effective emission reductions and the NYCI limits to emit. The last framework item is to “Support policy-relevant research and program evaluation tied to emissions reducing projects”. In this instance the presentation noted the importance to use “some NYCI proceeds to conduct policy relevant research and program evaluation tied to emission reducing projects” While this is necessary, NYSERDA has not been a good steward of the proceeds from the similar Regional Greenhouse Gas Initiative. Considerable funding has been diverted away from the original intent of the program to fund peripherally related tasks more appropriately funded by other sources. I fear that this will be an issue with NYCI proceeds. Also note that buried in the administrative costs is the Cost Recovery Fee which is assessed on public authorities by New York State for an allocable share of state governmental costs attributable to the provision of services pursuant to Section 2975 of the Public Authorities Law. This takes a percentage of the funds off the top for bureaucratic administration.

The next four slides gave examples of proposed investment areas. Think of it as a menu for special interest lobbying to get a place at the trough.

The final section of the presentation presented specific requests for public input. The first request was related to the investment framework: in reference to the last slide shown in this summary “Do you have feedback on the proposed draft NYCI investment framework for guiding the use of NYCI proceeds from the Climate Investment Account?” NYSERDA asked specific questions about the proposed investment areas – priorities and other potential projects that could benefit from NYCI-funded investments.

The third question, feedback on appropriate interventions, piqued my interest. It asked, “what interventions do you see as critical to receive investment of NYCI proceeds through the Climate Investment Account?” It included these follow-on prompts:

What funding needs do you see existing today that seem appropriate for NYCI?
How should NYS consider costs relative to associated impacts and benefits? For example, should NYS orient investments towards lower-cost opportunities that produce faster emissions reductions or more difficult and/or expensive areas where emissions reductions might otherwise not be achieved or achieved more slowly?
How should NYS balance funding for mass deployment of market-ready clean energy technologies vs. innovation to address the costs, feasibility, and access barriers for emerging solutions?

My response to the first question about funding needs is simple. The state investments must fund the deployment of emission reduction strategies that provide emission reductions consistent with the availability of NYCI permits to emit GHG emissions. If this is not done correctly, emitters will have no choice but to shut down or limit operations with bad consequences. It is impossible to answer the other two questions because the Scoping Plan documentation is inadequate. There is no indication that there is a plan for investments to achieve the necessary emission reductions that I maintain should have been included in the Scoping Plan. These are all valid questions but other than saying these tradeoffs must be considered I don’t see how anyone can respond meaningfully.

The final question is “How should we approach the process for planning for the programming of NYCI

proceeds through the Climate Investment Account?” The follow-on prompts shown in the following slide raise an important question in my mind. What is more important: emission reductions consistent with the Climate Act mandated schedule or appeasing the community-directed investment requests from the DACs. Will emission reduction effectiveness be considered?

Submitting Comments

If you are interested in submitting comments, then you should check out these instructions and the following slide. They asked for feedback preferably by September 30, 2024:

online at:www.capandinvest.ny.gov

by mail to:New York State Energy Research and Development Authority

Attn: NYCI Investment Planning

17 Columbia Circle

Albany, NY 12203-6399

Discussion

Leddy described the Consumer Climate Action Account noting it states: “At least 30% of future NYCI proceeds to New Yorkers every year to mitigate potential consumer costs.” She says “potential” in relation to consumer costs either because the narrative is to downplay costs or because she thinks the costs are not concerning. Either way I think it reflects the mindset of agency staff that are totally invested in the Climate Act cause. Outside of that bubble costs are going to be an issue.

In response to questions the webinar 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 earlier this 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. This update suggests that the regulations will be pushed back. Although I believe that staffing issues are part of the reason for the delays, the political underpinning of the Climate Act should not be forgotten.

The Hochul Administration is certainly cognizant of costs for environmental initiatives. On June 7, Governor Hochul explained that she reversed the decision to proceed with the New York City congestion pricing plan because of costs. 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. Note that the current NYCI proposal outline analyzed allowance prices starting at $23 in 2025 with 5% escalation for 2026, and an increase to $54 in 2027, escalating by 6% annually thereafter. Note that the cost increase comes after the next gubernatorial election year. The New York State legislature elections are coming up in November. I am now convinced that a major reason for the NYCI regulation delays is related to those elections.

The stakeholder process for this framework for guiding the allocation of NYCI funds and identification of potential areas that could receive investments is entirely appropriate. It will guide the legislative process to allocate at least $6 billion per year. Leddy said that the intention of the engagement process is to provide the Governor and the legislature to have the benefit of public input as they develop next year’s budget.

Unfortunately, see no recognition of the challenges of funding the transition. There also is no indication that there is a plan to consider the funding requirements of the Scoping Plan strategies with the mandated emission reduction trajectories. Those two issues are concerning.

One of the characteristics of the proposed net-zero Climate Act transition is over-reliance on the presumption that control strategies that have worked elsewhere will work in this application. NYCI is a prime example. Past performance does not guarantee future success. Given the differences between past successful programs and the one proposed I am convinced that NYCI will fail to deliver as advertised.

My other concern is that I believe that funding ambitious clean energy investments is more difficult than acknowledged. My analysis of the Regional Greenhouse Gas Initiative proceeds shows that the investments were not cost efficient averaging $565 per ton reduced. As noted, the investments to reduce emissions are diluted by other mandates. There is no acknowledgment that NYCI funding priorities should consider observed cost effectiveness results and be consistent with the NYCI allowance allocation reduction trajectory.

Conclusion

The NYCI process is behind schedule, and I think that is primarily because the enormous costs of the transition cannot be hidden when the regulations are proposed. It is getting increasingly difficult to continue to hide the costs. The New York State Comptroller Office audit of the NYSERDA and PSC implementation efforts for the Climate Act found that: “The costs of transitioning to renewable energy are not known, nor have they been reasonably estimated”. The Regulatory Impact Statement for the NYCI regulations must provide costs. Delaying the release of the proposed regulations is very likely politically motivated to continue hiding the costs.

While I agree that a framework for investing the NYCI proceeds is necessary it does not appear that the proposed framework is going to prioritize funding emission reduction strategies consistent with the allowance reduction trajectories consistent with the Climate Act mandates. That could lead to bad outcomes, but the apparent emphasis is on providing funding for favored political constituencies. I believe that the political calculus driving NYCI implementation is perverting the effectiveness of this market-based program to the point that it will not work.

Renewable Generation Is Not Resilient

Recently Rory Christian, Chair and CEO of the Public Service Commission said, “We are modernizing the grid not to just take on the challenge of adopting more renewable energy but to create greater flexibility, greater resiliency and the ability to recover more quickly in the face of these extreme climate events”. I believe that making our electric grid dependent upon weather-impacted resources is anything but resilient. Richard Ellenbogen describes one resilience-related issue in this article.

Solar Inverter Resiliency Issue

Joanne Nova recently identified a major issue with Behind-the-Meter (BTM) solar. The article discusses the fact that all new solar inverters are internet connected and many of them are made in China. Last October it was found that they may have communication vulnerabilities where they could be turned off simultaneously. She writes:

What if a few gigawatts of solar power disappeared without a warning or a cloud in the sky?

Imagine a hostile force had control of half your national power generation at lunchtime and could just flip a switch to bring you to your knees? Or how about a crime syndicate wanting a ransom paid by 5 pm?

Her article goes on to describe the problem in more detail. Nova quotes Daniel Croft, CyberDaily (October 2023):

Cyber Security CRC chief executive Rachael Falk said… that an attack on the solar grid could spark a “black start” event, which could result in the entire power grid going down. … “This could bring down an entire power grid, and it could take a week to recover,” she said.

It turns out that security vulnerabilities have been identified in the Netherlands and the US. In Australia half of the grid power can come from solar panels at noon. As a result, Nova suggests that the solution is to test and possibly replace inverters and fix the software.

Ellenbogen recently distributed an email addressing this issue that is quoted below. His solar panels have inverters too. He writes:

This is something that hadn’t occurred to me as my inverters were older and only the power monitor was web connected. I recently replaced the inverters at my house and those are web connected but everything is behind a firewall. The inverters are also, in theory, American made. It did occur to me when I was purchasing thermostats for the factory. I will not buy a NEST or Honeywell internet connected thermostat because they all can be centrally controlled. A few years ago, all the NEST thermostats in the US went offline. They said that it was a computer glitch in their system, but was it? If you don’t remember it, don’t try to Search for it. It’s as though they scrubbed the internet of the event. Google owns NEST. You can find more information with Yahoo. I remember it vividly because it confirmed my worst fears of why I didn’t buy one in the first place.

Ellenbogen explains that this is a problem:

This is a huge issue as, according to the NYISO Gold Book (Table below), there will be 4560 Megawatts at, maximum output, of BTM solar in NY State as of next year and the state is becoming very reliant on it. If a significant portion of that was shut down simultaneously on a hot day at solar noon, the system would find it extremely difficult to respond to maintain stability. If more of the present generation fleet is retired, the NYISO would find it almost impossible to ramp up generation quickly enough to offset the drop in generation. It would be the equivalent of removing the entire nuclear fleet and one-third of the hydro generation from the system in an instant.

He continues:

While many of the panels may not have that vulnerability, in the future they might and there will be even less backup generation to offset that. With renewable projects under extreme financial pressure, the easiest place to cut corners would be in cyber-security because it wouldn’t be noticed until something happened. In light of the article, it could also be the most hazardous place to cut corners.

Ellenbogen summarized:

When I was speaking at the Pelham Picture House last November, someone got up and said that they were glad Indian Point closed because it was a target of a terror attack. That was last decades terrorist technique. The new danger is hackers, or even worse, state actors that have implanted ticking time bombs throughout our energy infrastructure. This is not being paranoid. The Dutch hacker got into 4 million solar arrays in 150 countries.

Conclusion

Ellenbogen concluded his note saying “The question now is, what are the ISO’s and regulators around the country going to do about it?

As far as I can tell the issues that might affect resiliency like this are not on the radar of the people in charge of the Climate Act transition. I am sure staff are aware of the problem described but I am also sure that there is no mandate in New York to minimize this risk. Christian’s claim that adopting more renewable energy will provide greater resiliency is an empty slogan.

Commentary on Recent Articles 21 August 2024

Frequent readers of this blog know that many of my posts are long because I get document all my statements. 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 organizatin I have been associated with, these comments are mine alone.

Reasons to Oppose Renewable Energy

Brenda Hansen at Go Constitutional responded to the question why she opposed renewable energy in a post republished at Energy Security and Freedom Substack. She explained that she opposes large-scale solar and wind projects on moral grounds:

The political movement to pivot away from high-density energy sources (such as fossil fuels, natural gas, and nuclear) and attempt to transition to solar and wind is unethical because it will diminish human flourishing and will harm my fellow human beings – starting first with the most vulnerable.

Hansen does a good job explaining that when it comes to human flourishing, energy matters. If energy is not abundant and affordable, then “people need to spend an inordinate amount of time seeking and obtaining it”. The problem with renewables is that “Power from solar and wind is inherently unreliable, and this built-in characteristic of these energy sources will never change.”

She goes on to make an elegant point about affordability:

Turning our attention to affordability, energy that is unreliable cannot be considered abundant. Abundant energy, after all, always is there, always available, always ready to use. Such is not the case with solar and wind. When a product or commodity is not abundant, it becomes expensive.

I also endorse her moral accountability argument:

Considering these scientific realities (the unpredictable, unreliable, intermittent, low-density, low-efficient nature of solar and wind), ought to cause a pause. Do officials and bureaucrats who make energy decisions for us ever ponder the science and consider the consequences of the policies they are promoting?

As much as the developers and attorneys who represent them may annoy me, I understand they are doing what they were designed to do – maximize profit – and so I point my finger squarely at leaders in high office of government and academia and ask:

“Do you care about human flourishing? Do you care about the vulnerable in the world – such as the children who are laboring in mines in the Congo or Angola to collect the rare earth metals and nickel and cobalt needed for your solar arrays, wind turbines, and battery systems? In your pride and arrogance – patting yourself on the back for your concern toward a carbon-free future – have you no shame for the green colonialism you are forcing on the most vulnerable nations and peoples of the world? Why don’t you care about the science that reveals that what you are trying to accomplish – net zero – will only come at a devastating cost to humanity?”

The entire article is well worth reading.

Farming, Mining, and Energy Development

Tom Shepstone provided a link to an op-ed about farming and mining that epitomizes pragmatic environmentalism. The question raised is “Why does it seem we are comfortable demanding a supply when we are uncomfortable supplying the materials to meet the demand?”

As the child of a farmer that also ran a locker plant that “served for decades as the meat-processing and freezer storage facility for local beef and hog farmers” Julie C. Lucas learned about tradeoffs early:

I was forced to look my dinners in the eye from the moment I first bottle-fed a calf or chased a piglet around the barn to the moment we loaded the animals onto a trailer to make the short drive to the locker plant. We were taught that our choices have consequences, that sustaining our lives sometimes meant taking the lives of animals, and we had to accept responsibility for that and demonstrate compassion and gratitude for those resources.

Or we had to choose not to eat meat.

As the executive director of Mining Minnesota Lucas now is working to advance responsible development of natural resources. She points out:

While we all have the option of giving up meat or animal products if we are uncomfortable with the sourcing, we do not have the option of living in a world without minerals and mining. Even living off the grid requires mining the Earth’s resources for the necessary tools to build and maintain life. Saying “no mining here” while continuing to consume electricity, heat our homes, and live our 21st-century lives should make us all uncomfortable. We need to look our consumerism in the eye and demonstrate understanding and gratitude for the miners and resources that sustain us.

The op-ed closes with a plea to have an honest conversation about the tradeoffs between the mining necessary for society and local impacts. Responsible mining can minimize impacts while providing the necessities for society only if pragmatic tradeoffs are accepted.

Alex Epstein – Sound Bites on Fossil Fuels

Epstein describes easy-to-remember points on the advantages of fossil fuels with three articles describing core truths about fossil fuels:

1. We must think about fossil fuels in a balanced way.

2. Only by using fossil fuels can 8 billion people have the energy they need to survive and flourish.

3. The climate positives of fossil fuels far outweigh the climate negatives.

Fossil fuels have positives as well as negatives. Detractors only consider the negatives. Fossil fuels are essential to the infrastructure necessary to master climate danger – too hot and too cold weather.

Activists who want to stop using fossil fuels ignore the benefits of fertilizer and modern agricultural practices essential to feeding 8 billion people. Epstein points out that fossil fuels are uniquely cost-effective due to being naturally stored, concentrated, and abundant, they are uniquely cost-effective due to 100+ years of innovation, and only nuclear rivals fossil fuels’ natural attributes—but it has been crippled by irrational policy.

The use of fossil fuels has led to climate mastery that has made society better able to cope with extreme weather. This is proven by the massive reduction in extreme weather and drought death rates. Epstein includes other examples that are well worth checking out.

Weather Trend Confounding Factors

Adirondack Explorer reports: Meteorologists this week confirmed, through the help of satellite data, that two more tornadoes hit upstate New York during the severe weather event of July 16 — meaning a total of seven twisters hit the Adirondacks that day.

The recent additions were in remote, wooded areas without roads — necessitating a damage analysis through satellite and radar, said Christina Speciale, a meteorologist with the National Weather Service in Albany. An EF-1 tornado was confirmed in Limekiln on the Herkimer and Hamilton County border. That twister reached a high speed of 100 mph, and caused 4 miles’ worth of damage. Another EF-1 tornado was confirmed in Wilcox Lake Forest on the border of Hamilton and Warren counties; the damage was similar to the one recorded in Limekiln.

The point is that these tornadoes would not have been counted before the advent of satellite and radar damage analysis. Claiming that climate change is here and happening now because there are more tornadoes is a weak argument because sampling differences affect trends.

Net-Zero Test

Francis Menton, Rich Ellenbogen, and I have argued that a fully functioning demonstration project to prove that the a net-zero jurisdiction can work should be a prerequisite before proceeding with the Climate Act implementation. Irina Slav points out that the Paris Olympics attempted to do exactly that.

Since I don’t really follow the Olympics, it was belatedly that I learned this year’s edition was supposed to be the greenest in the history of the games but when I did learn it eventually, it was more than I could have ever asked for.

Predominantly vegetarian food, no air conditioning in athletes’ rooms and on the buses that transport the athletes to the venues, eco-friendly mattresses, swimming in the Seine instead of pools (I’m not sure how exactly this falls under the net-zero label but whatever) — the French had really taken their net-zero mission seriously. And they promptly turned into a laughing stock.

She explains:

The Paris Olympics have turned into a summary of the energy transition in a nutshell: a complete disregard of physical realities in favour of a fantastical goal that has about the same chance of succeeding as a vegan hockey team beating a meat-eating team.

Time of Use Tariffs

Smart meters are coming to New York State. The utilities claim that they will not be involuntarily used to set a time of use price but I believe that once they are installed in sufficient numbers that consumers will be forced into such a rate structure. David Turver describes issues with this approach in Great Britain.

In theory incentivizing consumers to use less power when load traditionally peaks will make markets more efficient. Turver explains how this is supposed to work. He points out that this demand side approach could eventually be coupled with solar variability to encourage consumers to use more when solar generation peaks to reduce the impact of surplus power. He concludes that consumers will be on the losing end of this approach.