Balancing the risks and benefits of environmental initiatives
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.
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 company I have been associated with, these comments are mine alone.
Supreme Court Ends the Chevron Defense
Francis Menton explains: “when the legality of a regulatory action of a federal agency is challenged in court, should (or must) the court “defer” to the interpretation that the agency itself has given to the governing statute, or to the challenged regulation?” the Chevron defense deferred to the agency. He states:
Chevron deference” is the ultimate unfettering of the government to enable it to expand as much as it wants, and with nothing to stop it. Of course every agency interpretation of a statute or regulation will be in a way to give the agency itself more power! For Exhibit A, look to the EPA under Obama, which has interpreted the term “waters of the United States” to cover every puddle and wet spot (in order to claim jurisdiction over a good half of all private land) and has determined that a colorless, odorless gas (CO2) is a “danger to human health and welfare” (in order to claim jurisdiction over the entire energy sector of the economy).”
Roger Pielke, Jr. explains why he would have joined the dissent on the decisions and Robert Bryce argues that the decision “finally brings some balance into the regulatory world”. I think the defense has led to one-sided decisions that are not in the best interests of society, so I applaud the decision.
The legislation would impose a retroactive tax on fossil energy companies that have emitted greenhouse gases and operated within the state over the last seventy years. If passed, the new law will impose $75 billion in repayment fees for “historical polluters,” who lawmakers assert are primarily responsible for climate change “damages” within the state. New York will “assign liability to and require compensation from companies commensurate with their emissions” over the last “70 years or more.” The bill would establish a standard of strict liability, stating that “companies are required to pay into the fund because the use of their products caused the pollution. No finding of wrongdoing is required.”
It is unclear why New York legislators believe $75 billion in repayment fees would not increase costs to consumers but numeracy is not a strong suit of the legislature. I suspect that there will be legal challenges as well. It is kind of mind boggling that the bill demands payment for something without requiring a finding of wrongdoing. Given that Hochul as indicated that she intends to run for Governor in 2026 I would not be surprised if she signs the bill.
Proposal to Raise the New York Distributed Solar Target
PV magazine describes a New York Solar Energy Industries Association (NYSEIA) report to Governor Kathy Hochul, requesting a raised target for the state’s distributed solar targets. The current target is 10 GW by 2030 and NYSEIA proposes raising the target to 20 GW by 2035. A quick look at the report suggests that I should address some of the claims made but, in this commentary, I want to address one issue.
Given the problems raised in the New York Independent System Operator Power Trends 2024 report, I believe that New York’s energy planning should focus on the wind and solar resource gap that was addressed at the first session of the Department of Public Service Proceeding 15-E-0302 technical conference held on December 11 and 12, 2023 entitled Zero Emissions by 2040. I described the problem and the new category of generating resources called Dispatchable Emissions-Free Resources (DEFR) necessary to keep the lights on during periods of extended low wind and solar resource availability.
The problem with solar is that it is not expected to provide any energy when the future winter load peaks after the sun has gone down. Distributed solar has a related problem. Roof top arrays are commonly used for distributed solar and in New York City many arrays are flat as shown below.
Just imagine how these panels will look after a significant snowstorm. There is no place to put the snow even if it could be cleared. It is not unusual for the coldest weather and the highest loads to occur after an impactful snowstorm. In that instance, rooftop solar will not only be unavailable during the peak hour but could be impacted for days after the snowstorm. Spending more money on distributed solar that will not help address future peak winter loads is a waste.
Jo Nova notes that India burns more coal than the US and Europe combined and just ordered $33b in “new coal plants”. I compared NYS GHG emissions with India and China using data from Our World in Data. In 2021, NYS GHG emissions (GWP-100) were 247 million metric tonnes (MMT). GHG emissions from China were 13,774 MMT and from India were 3,879 MMT. The increase in emission from 2020 to 2021 were 498 MMT in China and 265 MMT in India. New York emissions will be supplanted by emissions from China or India in less than one year.
Somebody explain to me why New York is doing this again.
Here are a few other items of interest.
Videos
Tony Heller provides an example of the integrity- and veracity-free world of the press and climate academics.
Reason for 2023 Record Warming Javier Vinós makes the case that the primary reason for the spike in temperatures was natural. In particular a very rare underwater volcano that injected water vapor into the stratosphere.
Chuck Schumer’s ‘Dear Friend’ Invested in Solar as Schumer Secretly Negotiated Climate Bill. You will never be able to convince me that it is not all about the money. “More and more, it appears the ‘green’ in much of the green agenda has a lot less to do with the environment than it does with transferring taxpayer funds to preferred special interest bank accounts,” said Michael Chamberlain, the director of government watchdog group Protect the Public’s Trust.
Adults take charge: “Chaotic and only occasional wind and solar generation is what you get when infants run the show. Now in a ‘wait til your father gets home’ moment, governments of an adult bent are taking a firm grip on energy policy. Ditching the suicidal renewable energy targets and plumping for nuclear power, principally because it works.” I love the illustration for the article.
Nuclear New York, Inc. submitted the report “Filling the Gap in the State’s Decarbonization Plan” to the New York Department of Public Service (DPS) Proceeding 15-E-0302 related to a new category of generating resources called Dispatchable Emissions-Free Resources (DEFR). All credible analyses of the future New York electric system agree that new technologies are necessary to keep the lights on during periods of extended low wind and solar resource availability. This article documents this analysis.
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 400 articles about New York’s net-zero transition. The opinions expressed in this article do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.
Overview
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” 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.
When the Climate Action Council voted to accept the Scoping Plan draft members made statements. I have previously described the outsized influence of Dr. Robert Howarth the David R. Atkinson Professor of Ecology & Environmental Biology at Cornell University on the findings of the Council. His statement, in support of approving the Scoping Plan draft included the following:
A decade ago, Jacobson, I and others laid out a specific plan for New York (Jacobson et al. 2013). In that peer-reviewed analysis, we demonstrated that our State could rapidly move away from fossil fuels and instead be fueled completely by the power of the wind, the sun, and hydro. We further demonstrated that it could be done completely with technologies available at that time (a decade ago), that it could be cost effective, that it would be hugely beneficial for public health and energy security, and that it would stimulate a large increase in well-paying jobs. I have seen nothing in the past decade that would dissuade me from pushing for the same path forward.
The Scoping Plan directly contradicts his statement that technologies available when the paper was written and today are sufficient for the transition away from fossil fuels. The Scoping Plan itself explains why DEFR is necessary. I provide more details about DEFR at a dedicated webpage and I am compiling a list of analyses that contend that it is necessary. This post describes the Nuclear New York report “Filling the Gap in the State’s Decarbonization Plan” that also argues that New York’s plans have underestimated the need for dispatchable resources in the future.
A New View of the Electric Grid
The Filling the Gap in New York’s Decarbonization Plan: A New View of the Electric Grid report was authored by Leonard Rodberg, PhD, Research Director, Nuclear New York, Inc.; Consultant, Energy Policy; Reiner Kuhr, Founder, Center for Academic Collaborative Initiatives (CAIC); and Ahmad Nofal, Co-founder, CAIC. The rest of this section quotes the Executive Summary and includes my annotations.
The report clearly describes the issue. At the same time load is expected to increase significantly, New York is proposing to rely on wind and solar that needs a firm dispatchable resource aka DEFR:
New York State has seriously underestimated the need for a large firm dispatchable source (A firm dispatchable source is always available and able to supply whatever additional electric output is needed) in its future decarbonized grid. The growth in demand from the expected electrification of automobiles and the heating of buildings requires that such a resource operate for more than a third of the year to provide a grid that is reliable and avoids rolling blackouts.
I believe that an hourly analysis is necessary. The authors used a model that “performs an hour-by-hour analysis of the projected electricity demand in 2040 to show how the in-state sources assumed in NYSERDA’s scenario actually behave when serving this varying demand.” The Center for Academic Collaborative Initiatives model “uses spreadsheet software to calculate, for each hour throughout the year, how the available energy sources, including battery storage and the DEFR, will be used to meet projected electric load.”
We have analyzed a Renewable-Focused Plan (RFPlan) with characteristics similar to scenarios describing the state’s future electric grid prepared by the NYS Energy Research and Development Authority (NYSERDA) for the Climate Action Council. (CAC). Using a new modeling tool that allows an hour-by-hour analysis of electric system behavior, we can see details of the hourly operation of each energy source, features not disclosed by existing models, including that used by NYSERDA. We can also estimate the cost to the purchasers of electricity and taxpayers of these scenarios.
The authors used the installed capacities included in the Integration Analysis Scenario 3 but the model dictates how the units operate.
The State’s Climate Leadership and Community Protection Act (CLCPA) requires that the electric grid be free of greenhouse gas emissions by 2040. NYSERDA’s scenarios create a plan which depends almost entirely on generating electricity with renewable sources. They retain existing nuclear plants, but no new ones are added.
The Executive Summary outlines the approach used in the Scoping Plan:
The Scoping Plan adopted by the CAC declares that “wind, water, and sunlight will power most of New York’s economy.” While its focus is on renewable sources, the CAC does recognize the need for an additional clean source: “plan analysis and current studies show that the 2040 zero-emission goal requires between 15 and 45 gigawatts (GW) of electric power from dispatchable zero-emission resources”. However, NYSERDA finds that little more than 2% of the potential output of such a dispatchable emission-free resource (DEFR) will actually be used.
The authors explain that the Scoping Plan approach is based on a lot of wishful thinking:
Simple arithmetic makes this seem highly questionable. By 2040, NYSERDA and NYISO, the grid operator, estimate that building and transportation electrification will have expanded so that the grid will have a peak load in winter of 46-50 GW. Yet, even with land-based and offshore wind blowing at full capacity, no more than 35 GW will be available during winter evenings. Little or no excess capacity exists to charge the batteries, and, of course, solar won’t be available. Much more than 2% of the dispatchable source’s potential output has to be available to get through the winter without blackouts.
The CAIC model projects a dramatic difference in the use of DEFR:
Our hour-by-hour analysis shows that the firm dispatchable source has to run two-thirds of the year. The total load has increased from today. The summer peak has been replaced by a much higher winter peak. That greater demand is met by the extended operation of the DEFR which runs during most evenings in the cooler portion of the year. In fact, we find a capacity factor — the fraction of potential output actually used –of 14.4%. Our detailed results are shown below.
In my opinion, the CAIC analysis treats DEFR differently than the Integration Analysis does. I believe that when the Integration Analysis determines which resources should be applied to meet load, they use DEFR as a last resort. On the other hand, CAIC uses DEFR much more frequently. That could be due to a difference in the hourly projections of wind, solar, energy storage, and load for the two models or presumptions in the models.
The final aspect of the modeling is a proposal for an alternative approach:
In this paper we suggest alternatives to NYSERDA’s plan that use baseload nuclear power along with a nuclear-powered firm dispatchable resource (DEFR) to ensure a reliable grid. Our plan costs one-third less than the RFPlan.
DEFR Implications
The CAIC model was also used to evaluate the placeholder Integration Analysis DEFR technology:
NYSERDA suggests, in its Integration Analysis, the use of hydrogen produced with renewable generated electricity to fuel the DEFR. We have examined this case and find that supplying sufficient energy to produce the required hydrogen would necessitate a 40% increase in the number of solar and wind installations, beyond those envisioned in the RFPlan. We are unable to estimate that system’s cost, since it would require creating a new infrastructure to produce, transport, and store a large supply of hydrogen during the summer for use in the winter. Analyzing such a construction project is beyond the scope of this study.
It is not clear how the Integration Analysis deals with hydrogen. I think that they believe that they have included sufficient wind and solar resources to support hydrogen production using electrolysis. However, I also think that the Integration Analysis has arbitrarily decided that half of the needed hydrogen will come from out of state. I think that is a wildly optimistic presumption and very unlikely to occur. In any event, no one can estimate how much this will cost using the documentation provided.
Nuclear Option
Not surprisingly Nuclear New York proposes nuclear energy as a DEFR candidate. The Scoping Plan makes a token suggestion that nuclear should be considered but there is no serious attempt to compare nuclear relative to their other technology recommendations. The report describes the Nuclear New York proposal:
The following scenarios, which we term “Brighter Future,” build upon a 2022 policy proposal
prepared by Nuclear New York, Clean Energy Jobs Coalition NY, and A Campaign for a Green Nuclear Deal. Recognizing that much of New York’s electricity demand is constant throughout the year, Brighter Future utilizes nuclear power as a principal source of clean power throughout the year, not simply as a DEFR when solar and wind are incapable of meeting the load. Nuclear becomes the backbone of the system, not simply a backup to intermittent, weather-dependent renewables.
These scenarios include 7 GW of new baseload nuclear power – adding more than twice what is
already operating in upstate New York – along with 26 to 30 GW of DEFR. Far fewer solar and wind installations are needed; we assume 80% fewer installations than in RFPlan. Our grid model presently does not allow for the DEFR to charge batteries. Since adding batteries that are seldom charged adds unnecessary costs, we exclude them from the Brighter Future scenarios. We will evaluate their inclusion in future research.
The first, Brighter Future 1, has 9 GW of offshore wind, the minimum called for in the CLCPA.
Brighter Future 2 has no offshore wind and costs significantly less. Not only does offshore wind add to the system cost, but it will be shut down, and possibly seriously damaged whenever frequent and increasingly intense storms arrive from the Caribbean and South Atlantic.
The following table from the report summarizes their findings and provides total per-unit generation costs for in-state resources under two DEFR capital cost scenarios: current-cost at ~$6,000/kW and low-cost at ~$3,000/kW.
I agree that nuclear must be used if New York wants to decarbonize safely and suspect that the all-in costs of nuclear will be less than wind, solar, energy storage, and DEFR.
DEFR Options
The report also includes a section describing alternative DEFR technologies. The report evaluates a number of suggested options:
Fuel cells or gas turbines powered by “green hydrogen”: Hydrogen fuel cells or combustion power plants similar to those now burning fossil fuels could run on “green hydrogen” produced in electrolyzers powered by renewable energy, as NYSERDA has suggested. However, such a plan requires the creation of an expensive infrastructure to transport and store the hydrogen, as well as a buildout of additional costly, land-hungry solar and wind facilities to power the hydrolysis plants that produce the hydrogen. Using hydrogen for energy storage is challenged, also, by the fact that the round-trip power-to-gas-to-power (P2G2P) efficiency is just 40%.34 This means more than twice as much additional energy is needed as will be generated by the DEFR, with a commensurate drain on material resources, land, and societal wealth.
Long-duration storage: This might help, but currently no realistic scalable form of such storage exists. If it did, it, too, would require a vast expansion of generating capacity if solar and wind power charges whatever storage medium is used.
Carbon capture and storage (CCS) attached to gas-fired power plants: This only exists on an experimental basis. It would add substantial cost to the power it was attached to, and there would be upstream leakage of greenhouse gases and other pollutants to the environment. The captured CO2 would have to be disposed of, presumably underground, adding additional cost as well as potential environmental damage.
Nuclear power: This is the DEFR energy source used in each of our scenarios, as well as for additional baseload generation in the Brighter Future scenarios. Only nuclear power has been demonstrated to have the necessary capabilities, not only in the gigawatt-scale reactors now operating in New York State and elsewhere, but in the smaller reactors now under commercial development and operating on submarines and ships for over fifty years (many designed in New York State at the Knolls Atomic Power Laboratory).
Alternate nuclear options: Alternate ways of using nuclear energy will deserve consideration. Nuclear reactors, like most energy sources, are most cost-efficient when they run more of the time to meet demand. We found that the DEFR would be operating at partial capacity for most of the year. A more cost-effective plan might use a smaller number of reactors running continuously to produce hydrogen which could be used in fuel cells. Another option would be to use nuclear facilities to produce carbon-neutral synthetic fuels.35,36 Full analysis of the cost and suitability of these options is beyond the scope of this paper, but they deserve serious study.
I agree with their findings. I will only believe that the State seriously wants to reduce carbon emission if and only if they abandon the wind and solar approach and go nuclear. As this report explains it is the only viable approach.
Discussion
The report lists some limitations of the modeling and their research. Those include: a simplified view of the in-state transmission system, absence of reserves mandated by reliability requirements, fixed cost assumptions, a couple of potential refinements for the nuclear proposals, and optional DEFR designs.
I caution readers that this analysis is not as sophisticated as the work that NYISO does. Transmission constraints will definitely affect the outcome of projections. NYISO projections handle all the complications associated with those constraints. I do not think that the Integration Analysis includes sophisticated transmission constraints either.
Despite its limitations I do not believe that these limitations affect the general outcomes: DEFR is needed and nuclear is the best option available because it markedly reduces the amount needed.
Dunkelflaute
Dunkelflaute is a “German term that is used in the energy industry to describe a period of multiple consecutive days in which low or minimal energy can be generated by renewable energy sources, such as solar or wind”. Of course this describes the conditions that drive the need for DEFR.
In response to comments I submitted on this topic to the Proceeding on Motion of the Commission to Implement a Large-Scale Renewable Program and a Clean Energy Standard – Zero Emissions Target Case No. 15-E-0302author Leonard Rodberg sent me the following information:
Your analysis of the frequency of overcast and wind lull (“Dunkelflaute”) conditions is impressive and important. However, there are much larger problems with the State’s renewable-focused plan which they and everyone else seem to be ignoring.
On many winter nights in a fossil-free 2040, there will only be wind and the remaining nuclear and hydro to power the grid. No sun, of course, and batteries uncharged since there’s no excess power during the day to charge them. The result will be many nights when the grid shuts down unless a gap-filling clean firm source is available.
In fact, it’s even worse than that. Both NYSERDA and NYISO project winter peaks of 46-50 GW, but even with their projected wind power at its peak output, there’s just 35 GW available (see the graph below). No one seems to have bothered to add these up, and the model they’re using hides it .
The gap is large and is present much of the year. I’ve used an hourly dispatch model to show what’s really likely to happen in that situation. It’s shown and explained here. (This is a reference to the report described in this article.)
I included this because I think it reinforces the position I wanted to publicize. DEFR is necessary and the State’s analyses are not treating it well.
Conclusion
I concur with the report conclusion:
We have shown, with a modeling tool capable of performing an hour-by-hour analysis, that
dispatchable emission-free resources are essential to meeting the goal of a reliable, zero-emission grid. Further, this clean dispatchable source must be able to run a large portion of the year. The only such source likely to be available within the next several decades is nuclear power. The state will further benefit from the deployment of additional baseload nuclear power. This combination of nuclear resources will be more cost-efficient and environmentally-protective than an alternative focused on intermittent weather dependent sources.
Finally note that is another analysis that destroys the Climate Action Council argument that New York can rapidly move away from fossil fuels and instead be fueled completely by the power of the wind, the sun, and hydro using technologies available at this time. That is simply not true.
The Climate Leadership & Community Protection Act (Climate Act) requires that the Public Service Commission (PSC) issue a review for notice and comment that considers “(a) progress in meeting the overall targets for deployment of renewable energy systems and zero emission sources, including factors that will or are likely to frustrate progress toward the targets; (b) distribution of systems by size and load zone; and (c) annual funding commitments and expenditures.” The recently released Clean Energy Standard Biennial Review Report contains a lot of information that will be addressed in future posts. This post provides my first impression of the document. Spoiler – there is no chance that the 2030 mandate for the 70% renewable electric energy will be met.
I have followed the Climate act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition. The opinions expressed in this article do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.
Overview
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. It includes an interim 2030 reduction target of a 40% reduction by 2030, a requirement for 70% renewable energy for electric production by 2030, and a requirement that all electricity generated be “zero-emissions” 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.
Biennial Report
The Introduction to the report states:
The Climate Leadership and Community Protection Act (CLCPA) of 2019 requires that the Public Service Commission (PSC) issue a review for notice and comment that considers “(a) progress in meeting the overall targets for deployment of renewable energy systems and zero emission sources, including factors that will or are likely to frustrate progress toward the targets; (b) distribution of systems by size and load zone; and (c) annual funding commitments and expenditures.” This Report serves to inform the Commission’s review. It summarizes the progress made toward the renewable energy and zero emission goals set by the CLCPA since the establishment of New York State’s Clean Energy Standard (CES), assesses what remains to be done to achieve those goals, presents policy options and proposals, and invites comments from stakeholders and the public on these or any other matters raised in this Report. The Report focuses in particular on New York’s goal to obtain 70% of New York’s electricity from renewable sources by 2030 (the 70% goal) and the related goal of 9 gigawatts (GW) of offshore wind by 2035.
The footnote for the first sentence states: PSL §66-p(3). PSL §66-p(4) provides the Commission with authority to “temporarily suspend or modify” the obligations created by the Program if, after conducting a hearing, it finds that the Program “impedes the provision of safe and adequate electric service,” “is likely to impair existing obligations and agreements,” and/or is related to “a significant increase in arrears or service disconnections.” The Introduction goes on:
Section 1 identifies the key regulatory actions taken to date to support renewable energy deployment in New York, including the establishment of the CES. Section 2 summarizes progress to date in achieving the CLCPA and CES goals in terms of current contributions of operational renewable energy systems and zero-emission sources to the State’s energy portfolio. Section 3 offers a detailed assessment of major factors that have affected and will likely continue to affect progress towards the goals. Section 4 reports on the pipeline of contracted renewables from previous Tier 1 and offshore wind solicitations. Section 5 accesses the amount of renewables that would need to be procured, under the CES or a modified version of the program, to achieve the 70% goal and recommends adjustments to NYSERDA’s procurement authorization that may be necessary to do so. Section 6 considers other programmatic options for accelerating development and construction of renewable energy resources. Policy options and proposals under consideration in this Report are limited to the CES itself.
I could do a post on each section and may end up doing that. It is encouraging that the PSC acknowledges the safety valve mechanism in Public Service Law §66 that I have mentioned on many occasions. Optimistically could this signal recognition that if the aspirational scheduled mandates of the Climate Act are not feasible that the schedule must be modified?
Progress to Date
Section 5 summarizes the “Path to the 70% goal”. The description of the Table 8 “Summary of progress” states:
Under the base case load forecast assumption of 164,910 GWh by 2030 as described above, the 70% goal equates to 115,437 GWh. Table 8 below summarizes the contributions towards the goal from currently operational and contracted renewables, as set out above in Section 2 and Section 4 of this Report. In addition, it projects 10 GW of distributed generation by 2030 secured outside the CES framework.
I will follow up with a post addressing the assumptions used to calculate the numbers in Table 8. Sections 2 and 4 described how operational and contracted/awarded renewable estimates were projected and that discussion is also worthy of its own post. At this time it is notable that one of the key points in the report is the admission that contracted projects don’t always get built.
The report describes Table 8:
With these conservative assumptions, the expected amount of renewable generation from operational and awarded/contracted sources in 2030 totals 73,292 GWh. Under the base case forecast for the 2030 statewide electric load, there is a renewable energy supply deficit of 42,145 GWh that would have to be addressed through future procurements in order to reach the 70% goal amount of 115,437 GWh.
Consider these numbers in context. There is an admitted gap of 42,145 GWh which is greater than the total operational renewable generation in 2022, 2022 imports and operational after 2022 (37.692 GWh). Trying to cover that gap is an ambitious challenge.
2030 Projected Renewables
The Biennial report proposes to double down on building renewables to cover the gap and meet the target.
To fill the expected gap, three Tier 1 annual solicitations – those for 2024, 2025, and 2026 – are currently scheduled and will seek projects capable of deploying by 2030. However, the amounts procured in these solicitations would need to be adjusted to secure the needed quantity of 42,145 GWh. The analysis suggests NYSERDA would have to procure approximately 14,048 GWh per solicitation, assuming no project attrition, or, assuming a 30% attrition rate, an amount of 20,068 GWh per solicitation. This volume is significantly higher than the annual procurement quantity of 4,500 GWh per Tier 1 solicitation (before attrition) estimated in the 2020 CES White Paper and 2020 CES Order.
The best efforts of the State to date for renewable solicitations are far lower than what is needed. The report admits that “the maximum annual new project development rate would likely be in the range of 6,000-7,000 GWh per year at least in the near term” and that is contingent on meeting a number of conditions. Table 9 below describes what the report argues is feasible.
Even under the revised assumptions the PSC projects that the 70% renewable energy goal will not be achieved until 2033 when the historic renewable resource deployments are considered.
Conclusion
The State has never done a feasibility analysis to prove that their plan to rely on wind and solar will work. The Climate Act deadlines were set arbitrarily by politicians so achieving that is another level of wishful thinking.
Get out the popcorn. Reality is catching up to the Climate Act net-zero transition. This report is the first indication that things are not going as planned. How will the Hochul Administration handle the obvious need to relax the deadlines?
Stay tuned for future articles on this important report.
According to Pew Research, Americans still want renewable energy, but support is waning. This comes as the impacts of the Climate Leadership & Community Protection Act (Climate Act) are becoming clear. It would be interesting to see a similar poll for New York residents.
I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition. The opinions expressed in this article do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.
Overview
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” 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, State agencies and the legislature have been attempting to implement the plans.
How Americans View National, Local and Personal Energy Choices
The Pew Research Center released the results of its survey on June 27, 2024
How Americans View National, Local and Personal Energy Choices
Most Americans want more renewable energy, but support has dipped. Interest in electric vehicles has also declined
There’s been a decline in the breadth of support for wind and solar power. The shares who favor expanding solar and wind power farms are down 12 percentage points and 11 points, respectively, since 2020, driven by sharp drops in support among Republicans.
Interest in buying an electric vehicle (EV) is lower than a year ago. Today, 29% of Americans say they would consider an EV for their next purchase, down from 38% in 2023.
Still, a majority of Americans (63%) support the goal of the U.S. taking steps to become carbon neutral by 2050. When asked which is the greater priority, far more Americans continue to say the country should focus on developing renewable energy than fossil fuel sources (65% vs. 34%).
The survey, conducted May 13-19 among 8,638 U.S. adults, finds a fairly modest share of U.S. adults (25%) say it’s extremely or very important to them personally to limit their own “carbon footprint.” Far more give this middling or low priority.
These findings illustrate how large shares of Americans back more renewable energy that would decrease overall carbon emissions. Still, this general orientation does not necessarily translate into strong commitment to reducing personal carbon emissions or interest in buying an EV.
Maybe it is just me but the lead sentence claim that record heat is spurring action smacks of bias. I checked the description of how they did the survey to see if my concerns were warranted:
Pew Research Center conducted this study to understand Americans’ views of energy issues. For this analysis, we surveyed 8,638 U.S. adults from May 13 to 19, 2024.
Everyone who took part in the survey is a member of the Center’s American Trends Panel (ATP), an online survey panel that is recruited through national, random sampling of residential addresses. This way, nearly all U.S. adults have a chance of selection. The survey is weighted to be representative of the U.S. adult population by gender, race, ethnicity, partisan affiliation, education and other categories. Read more about the ATP’s methodology.
The questions used for the survey were not overtly biased. Nothing like “In order to save the planet from imminent doom are you in favor of solar farms?” My only reservation is that these questions were part of a bigger survey, so it is not clear if previous questions primed the pump towards climate impact alarm. One other point is that the methodology was different from most surveys. Instead of a phone survey the Pew Research Center has established the American Trends Panel “a nationally representative panel of randomly selected U.S. adults who participate via self-administered web surveys.” I have no opinion if this affects survey results.
Rather than just provide the results of the survey the Pew website description addresses the question of what’s behind the declines in support for wind and solar.
Declines in public support for renewable energy have been driven by Republicans and Republican-leaning independents, whose support started to fall sharply after President Joe Biden took office in early 2020.
64% of Republicans say they favor more solar panel farms, down from 84% in 2020.
56% of Republicans say they favor more wind turbine farms, a 19-point drop from 2020.
Over this same time period, views among Democrats and Democratic leaners on these measures are little changed, with large majorities continuing to support more wind and solar development.
In some cases, gaps between Republicans and Democrats over energy policy now approach the very wide partisan divides seen over the importance of climate change.
In May 2020, Democrats were 26 points more likely than Republicans to say the country’s priority should be developing renewable energy (91% vs. 65%). Four years later, that gap has ballooned to 49 points, due almost entirely to changing views among Republicans – 61% of whom now say developing fossil fuels like oil, coal and natural gas should be the more important priority.
However, the authors do admit that it is not just political affiliation:
But changes in attitudes about policies that would reduce carbon emissions are not solely the result of more negative views among Republicans. For instance, the share of Democrats who say they are very or somewhat likely to consider an EV for their next car purchase has declined from 56% to 45% in the last year. And the share of Democrats who call climate change a very big problem for the U.S. has declined from 71% in 2021 to 58% today.
New York’s Climate Leadership & Community Protection Act (Climate Act) mandates massive changes to the energy choices of New Yorkers that require action today. I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition. One over-riding conclusion based on my work and discussions with others who share my concerns is that the majority of New Yorkers have no clue what is coming at them.
Nationally the mandates and potential impacts are much less imminent, I believe that a big part of the decline in support of wind and solar is increased knowledge. The survey includes more detailed questions regarding solar developments – Would solar development make the landscape unattractive, take up too much space, bring in more tax revenue, and lower the price you pay for electricity. I believe that answering those questions requires personal knowledge and in my personal experience it has only been in the last several years that I have seen solar developments. Having seen them I doubt many would think they are attractive and do not take up too much space. The more knowledge people have the lower the favorability in my opinion.
The survey also addresses electric vehicles.
Amid a major policy push at the federal level for electric vehicles, Americans are unenthusiastic about steps that would phase out gas-powered vehicles.
In March of this year, the Biden administration announced a rule aimed at dramatically expanding EV sales. Overall, 58% of Americans say they oppose these rules that would make EVs at least half of all new cars and trucks sold in the U.S. by 2032. Republicans overwhelmingly oppose this policy (83%). Among Democrats, 64% support these rules to expand EV sales, while 35% say they oppose them
In support of my belief that knowledge spurs skeptical concerns note the following results for a question about EV reliability:
As more people hear about electric vehicle experiences the reality of problems with the technology become evident.
The survey also included questions about personal carbon footprints.
Discussions about reducing carbon emissions often include the everyday actions people can take to reduce the amount of energy they use. One-in-four Americans say it is extremely or very important to them personally to limit their own “carbon footprint.” Larger shares say this is either somewhat (42%) or not too or not at all (32%) important to them.
There is one important aspect of energy choice that was not included in the survey. What about the costs? The follow up questions for wind and solar development included a question asking whether respondents thought that those developments would reduce electricity prices. There were also questions about electric vehicle cost to purchase and refuel them. Nothing about overall costs was included. I have yet to see a poll that indicates that people are willing to pay much for the energy transition being forced down our throats.
The description of the survey claims that “large shares of Americans back more renewable energy that would decrease overall carbon emissions.” It also admits that “this general orientation does not necessarily translate into strong commitment to reducing personal carbon emissions or interest in buying an EV”. If the willingness to pay aspect had been incorporated into the poll, I have no doubts that support for wind and solar would drop significantly. I am confident that as more people become aware of the hidden costs of renewable energy the inevitable result will be much less support.
Recently the New York Independent System Operator (NYISO) released the latest edition of Power Trends 2024. This is the NYISO’s annual analysis of factors influencing New York State’s power grid and wholesale electricity markets. This post highlights some of the key points made.
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 400 articles about New York’s net-zero transition. The opinions expressed in this article do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.
Overview
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” 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, State agencies and the legislature have been attempting to implement the plans.
Power Trends includes a letter from the NYISO CEO Rich Dewey. He highlights concerns about the Climate Act and grid:
New York’s public policies are increasingly prioritizing clean energy production and a rapid transition away from fossil fuels. It is imperative that during this time of rapid change we maintain adequate supply necessary to meet growing consumer demand for electricity. Power Trends shows that achieving this balance will be the central industry challenge over the next decade.
The shift from fossil fuel-based generation to clean energy resources is advancing with a quickening pace. At the same time, consumer demand for electricity is increasing as state policies decarbonize the building and transportation sectors and attract large economic development projects to New York. The successful transition of the electric grid depends on the careful balance of reliable energy supply with the forecasted increase in demand.
NYISO planning must address public policies intended to drive rapid change in the electric system in the state, impacting how electricity is produced, transmitted, and consumed. There are two Climate Act direct drivers for the electric system. In addition to the requirement that all electricity generated be “zero-emissions” by 2040 there is a mandate that the electric grid be 70% renewable energy by 2030.
This article highlights the following challenges raised in the report: status of the system, electrification challenges, Climate Act schedule, the interconnection process, the technology required, and the electric market.
Status
Power Trends included a discussion of the present status of the electric systems. It concludes that “electricity supplies are adequate to meet expected summer demand under normal conditions, but extreme weather and other factors pose reliability risks.” In a recent post about the June heatwave I quoted the following from the Summer 2024 reliability outlook:
For summer 2024, the NYISO expects 34,913 MW of resources available to meet 31,541 MW of forecasted demand under normal conditions. Under extreme summer weather conditions, however, forecasted reliability margins could potentially be deficient without reliance on emergency operating procedures. For example, if the state experiences a heatwave with an average daily temperature of 95 degrees lasting three or more days, demand is forecasted to rise to 33,301 MW, while predicted supply levels are reduced to 34,502 MW. When accounting for the required 2,620 MW of operating reserves that must be maintained, this scenario results in a forecasted reliability margin of -1,419 MW. That reliability margin declines further to -3,093 MW under an extreme heatwave with an average daily temperature of 98 degrees. Under these more extreme summer weather conditions, the NYISO forecasts an available supply of 34,317 MW to meet the required 2,620 MW of operating reserve requirements, plus a forecasted demand of 34,790 MW.
The Climate Act strategy to reduce building emissions through electrification will eventually shift the peak loads to winter. In the meantime, there are potential issues. The report notes that “On the coldest days, the availability of natural gas for power generation may be limited and significant interruptions to natural gas supply can disrupt reliable operations.” In addition, electric planners across the country as well as New York are dealing with “evolving challenges and considerations for ensuring power system reliability under extreme winter conditions.” The increased reliance on natural gas is a problem when there is intense cold weather because it stresses gas networks and electricity grids across the nation. An unintended consequence of the shift from coal to natural gas is the loss of electricity generated by facilities with on-site storage. Now there is reliance on the gas network and something else that can go wrong. New York addresses this with dual-fueled units that can burn oil stored on-site.
The last Power Trends status issue is declining reliability margins as illustrated in the following figure. As noted, this is mostly because fossil units are retiring faster than the zero emissions replacements are coming on-line. In addition, the New York Department of Environmental Conservation (DEC) is pressuring existing power plants to reduce emissions or shut down and they have rejected several applications to replace existing old generators with modern new facilities because of the Climate Act. Unfortunately, there is no direct link between the proposed facilities and a particular reliability issue. As a result, the permit decisions were considered in isolation and the permits were rejected exacerbating the declining reliability margin.
Electrification Control Strategy
The Power Trends report addresses the trend for higher electric loads. The primary Climate Act emissions reduction strategy is to electrify everything possible using zero-emissions electricity. In addition, economic development initiatives are driving projected demand higher. The following graphic describes the proposed energy-intensive projects. Not included is the potential for new data centers needed to power the artificial intelligence applications coming out.
As shown below, the New York statewide grid is projected to become a winter-peaking system in the 2030s, primarily driven by electrification of space heating and transportation. This means that the focus on future generating sources will have to change. In particular, the value of solar resources is lower during the shorter days of winter and reduced solar intensity due to lower sun angles. Moreover, there is the potential for even more reductions if solar panels are covered in snow.
Schedule
The Climate Act was promulgated without consideration of feasibility. Nowhere is this more impactful than with respect to the schedule. A rational New York energy plan would implement the zero-emission resources before retiring existing generating resources. New York is not rational. Despite the obvious delays in construction of new supply and transmission due to a whole host is issues the Hochul Administration has not broached the possibility of postponing any Climate Act targets.
The Power Trends report includes a description of their reliability planning process. Four reports are included:
Short-Term Assessment of Reliability (STAR): Conducted every quarter to assess reliability needs within a five-year horizon to determine whether the grid will be able to supply enough power to meet demand.
Reliability Needs Assessment (RNA): Evaluates the reliability of the New York bulk electric system considering forecasts of peak power demand, planned upgrades to the transmission system, and changes to the generation mix over the next ten years.
Comprehensive Reliability Plan (CRP): integrates STAR reports and the most recent RNA, resolves any identified reliability needs and develops a ten-year reliability plan.
System and Resource Outlook (Outlook): The Outlook will provide a comprehensive overview of system resources and transmission constraints throughout New York, highlighting opportunities for transmission investment driven by economics and public policy over a 20 year period.
Implementing the resources necessary to meet the Climate Act is not just a matter of building as many zero-emissions resources as possible as soon as possible. These reliability planning reports indirectly affect the implementation schedule. The process identifies specific issues which triggers a procedure to address them. All that takes time. The bigger issue is NYISO’s interconnection process. Before any generator can be added to the electric grid NYISO has to evaluate its impact. This process is so important that it was highlighted.
Improving the interconnection process
The Power Trends report notes that “NYISO’s interconnection processes continue to evolve to balance developer flexibility with the need to manage the process to more stringent timeframes.” NYISO is trying to speed up the turnaround time and make the process more efficient while protecting grid reliability. The report notes:
Driven by state and federal policies, an unprecedented number of renewable and clean energy projects are entering our interconnection queue. In 2019, there were 275 projects in the queue. Today, more than 500 projects are under consideration. Recent enhancements to our processes, interconnection team, and technology have led to measurable improvements.
There is another complication. Wind and solar project electric out has different characteristics than fossil-fired units. The Federal Energy Regulatory Commission’s Order 2023 addresses those differences and NYISO is incorporating that order into their processes. They hope that “Those reforms will further shorten the total study period while maintaining a focus on system reliability.”
Despite these improvements it takes years from the time a company starts to develop a wind or solar project until it gets online.
DEFR
The Power Trends report describes a major technological issue:
Renewable energy generation, subject to sudden changes in weather, also provides new challenges to grid operators that must balance supply and demand in real time. These variables highlight the need for new generation technologies that can fill in when weather-dependent resources are unavailable. Such new technologies, collectively referred to as Dispatchable Emission Free Resources (DEFRs), must be dispatchable, emissions free, and able to respond quickly to changing grid conditions. Such technologies do not exist yet on a commercial scale.
The NYISO described this resource in the last System and Resource Outlook:
DEFRs are a classification of emission- free resources that provide the reliability attributes of synchronous generation and can be dispatched to provide both energy and capacity over long durations. DEFRs must be developed and added to the system at scale to reliably serve demand when intermittent generation is unavailable. The lead time necessary for research, development, permitting, and construction of DEFR supply will require action well in advance of 2040 if state policy mandates under the CLCPA are to be achieved.
Both descriptions closed with the caveat that these resources do not exist. I described other DEFR issues raised at a Department of Public Service technical conference last December. The report statement that research and development are required before permitting and construction can begin underscores the scheduling challenge that this resource entails.
Markets
When the New York electric system was de-regulated the NYISO was formed to operate the electric system. To transition the electric markets to meet the Climate Act mandates the NYISO must attract necessary investments. The report explains:
Managing wholesale electric markets is a core responsibility for the NYISO. We are committed to administering and overseeing the competitive electricity markets as the most cost-effective way to attract and retain new resources to meet our reliability needs as we transition to a decarbonized grid.
For 25 years, competitive electricity markets have provided New Yorkers with reliable, least- cost power. Since 2000, the carbon dioxide emissions rate in the power sector decreased by 45%. Competitive markets produce real-time price signals that allow power suppliers to respond to the grid’s changing needs. With ever-increasing intermittency, extreme weather, and demand from electrification and economic development, the balancing force of markets is essential.
Our market design team is hard at work developing new tools and programs to encourage investment in resources that are fast-ramping, flexible, dispatchable, and emissions-free ― resource characteristics that are becoming increasingly important for grid reliability.
It is not surprising that NYISO places great faith in markets given that they are the reason for its existence. However, even market advocates must admit that developing the market for DEFR and all the other components of the grid needed for the transition adds another layer of complexity. It is not only that a new resource has to be developed but now the NYISO has to develop some sort of market mechanism to ensure that it is available when it is needed. Given the likely high costs for this new technology and the expected low utilization rate that is a serious challenge.
Discussion
The Power Trends report explains that Climate Act mandates on the electric system will drive electric system planning and development efforts through 2040. It notes that “The successful transition of the electric grid depends on the careful balance of reliable energy supply with the forecasted increase in demand.” The NYISO reliability planning analyses are based on decades of experience with dispatchable resources. Balancing demand with weather-dependent resources is an extraordinary test for the Climate Act schedule.
In its review of the status of the system NYISO notes important reliability caveats. An extended heatwave or limits on natural gas in winter could cause problems today and New York energy policies are reducing options to address those concerns. New York energy policy eliminated coal-fired generation and environmental requirements have reduced the number of facilities that provide peaking power. State policy has also restricted the development of more natural gas pipelines that directly contributes to increasing risk for the problems noted.
The report also describes potential scheduling issues but does not explicitly compare the real scheduling issues with the aspirational schedule. Other NYISO reports have projected that the number of new resources needed to meet the Climate Act mandates is unprecedented. Despite obvious delays in deployments today for reasons (e.g., supply chain issues, lack of trade personnel, and inflation) that show no sign of abating, the NYISO has not broached the idea that delays should be considered. This report describes interconnection issues and the requirement for a new resource that must be developed from scratch that exacerbate the problem.
Finally, market mechanisms must be developed to encourage the investments necessary to deploy all these resources. Despite the optimism of NYISO I suspect that investors are going to be reluctant to jump into the New York market without guarantees. All that uncertainty adds to potential costs and time to deploy resources.
There is an overarching issue unrecognized by the State and not addressed in this report. The NYISO resource adequacy planning process is based on decades of experience with independently operating generators. Probabilistic estimates of their performance are used to evaluate reliability standards. There is no expectation that many of the facilities will not be available at the same time. The proposed Climate Act transition to wind and solar resources changes that paradigm. Weather-dependent resources are highly correlated in space and time, and this is the reason DEFR is needed. The unresolved issue is that the worst-case wind and solar resource lull is very rare. Deploying sufficient DEFR to provide adequate resources based on the historical worst-case is likely impractical. However, if society does not develop those resources, then when those weather conditions inevitably reoccur in the future, there will be a catastrophic blackout.
Conclusion
The Power Trends 2024 report provides an excellent overview of New York State’s power grid and wholesale electricity markets. Unfortunately, NYISO does not consolidate all the warning signs about Climate Act implementation, nor does it call out state policies that are exacerbating problems.
Ultimately the problem is that New York has no comprehensive energy plan. The Scoping Plan is just a list of technologies that describe an electric system that is zero-emissions. However, there is no feasibility study that shows how it will work nor has the Hochul Administration reconciled the differences between the Integration Analysis and NYISO resource outlooks. As it stands now the apparent Administration plan is to build as many wind and solar facilities as possible and hope someone works out how they are supposed to be integrated into the electric system. When that does not work, I predict the NYISO will be fall guy.
The only way to ensure the safety of New Yorkers is to do a demonstration project that proves that an electric system that relies on wind and solar will work. A poor second choice would be a comprehensive feasibility analysis that reconciles the Integration Analysis and NYISO analyses. Failing to do either is planning to fail.
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, there have not been any signs of progress. This post describes my recent letter to the editor published at Syracuse.com.
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 400 articles about New York’s net-zero transition. The opinions expressed in this article do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.
Overview
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” 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.” In brief, that plan is to electrify everything possible using zero-emissions electricity. 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, State agencies and the legislature have been attempting to implement the plans.
Cap-and-Invest
The Climate Action Council’s Scoping Plan recommended a market-based economywide cap-and-invest program. The program works by setting an annual cap on the amount of greenhouse gas pollution that is permitted to be emitted in New York: “The declining cap ensures annual emissions are reduced, setting the state on a trajectory to meet our greenhouse gas emission reduction requirements of 40% by 2030, and at least 85% from 1990 levels by 2050, as mandated by the Climate 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. The stakeholder engagement process was supposed to refine the proposal, DEC will and NYSERDA will propose regulations by summer, and the final rules are supposed to be in place by the end of the year.
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.
Letter to the Editor
Because I knew that NYCI would eventually get released I contacted the editorial staff at the Syracuse Post Standard weeks ago with a proposed commentary (800-word limit). After no response to that I submitted a letter (250-word limit) and that was published. In the following I will annotate the letter with background and reference information.
The published letter points out that Governor Hochul’s recent decision to pause implementation of the New York City congestion pricing was based on costs. I believe that the costs of the Climate Act should be considered in the same light.
On June 7, 2024, Gov. Kathy Hochul explained why she reversed the decision to proceed with the New York City congestion pricing plan, stating: “Now my job is not to make it harder or more expensive for New Yorkers to live in our state — working hard, make ends meet, raise their families.” The ultimate question is whether this concern also should be raised relative to the Climate Leadership & Community Protection Act (Climate Act).
With the word limit it was impossible to provide much detail on the NYCI plan.
This summer, her administration will be rolling out an economy-wide cap-and-invest plan to fund Climate Act decarbonization projects. The New York Cap-and-Invest (NYCI) Program is simply a tax on carbon. It will require large-scale distributors of heating and transportation fuels to purchase permits to pay for carbon emissions in the fuels they sell. Those costs will be passed on to consumers.
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.
Administration officials estimate that NYCI auctions will generate “between $6 [billion] and $12 billion per year” by 2030. The New York City congestion pricing program was projected to raise $1 billion per year.
I used the example of gasoline costs for consumer impacts.
Consider gasoline costs. The current NYCI proposal outline analyzed allowance prices starting at $23 per ton of CO2 in 2025 with 5% escalation for 2026, and an increase to a higher ceiling in 2027, escalating by 6% annually thereafter. According to the U.S. Energy Information Administration, 17.86 pounds of CO2 are emitted per gallon of finished motor gasoline; 112 gallons burned equals 1 ton of CO2. A price of $23 per ton of CO2 translates to an increase in gasoline prices of 21 cents per gallon in 2025, 48 cents per gallon in 2027 and 57 cents per gallon in 2030.
Faced with the word limit, I concluded that New Yorkers want to know how much this will cost.
Raising the cost of fuel makes it harder to make ends meet. It is time to demand a transparent accounting of all Climate Act costs.
Commentary Version
In the longer version that was rejected I made some other points.
I pointed out that there are significant unaddressed issues and insufficient documentation to verify that it will not adversely affect energy affordability. Everyone wants a cleaner, greener, safer planet, but not at the cost of a decent standard of living and quality of life. There are unacknowledged tradeoffs associated with the Climate Act requirements that its supporters are covering up. Everyone has a different tolerance for these tradeoffs but resolving them requires much more information than is presently available. The state needs to provide the public with a clear New York Cap-and-Invest (NYCI) roadmap to achieve the 2030 targets, including additional emission reduction mandates, their costs, and how they will be paid for.
I also included information based on the comments I submitted. NYCI proponents argue that similar programs are a “well-tested mechanism for addressing climate change.” Past performance does not guarantee future success especially as the NYCI proposal contains significant revisions to earlier programs. Differences include proposals for limitations to trading and banking of allowances included in previous programs, emission reduction schedules in NYCI that did not include any evaluation of practicality, and a mandate to reach zero emissions.
I am convinced that affordability is the main concern of New Yorkers, so I addressed that in more detail. No price adder can drive emission reductions at existing sources because control technology to go to zero emissions does not exist. The only control strategy available is to displace fossil fuel usage with a different technology. The entities responsible for NYCI compliance do not control the deployment of the replacement technology and determining the market price necessary to incentivize their development is uncertain. If the 2030 allowance price is $64.31 the total auction proceeds will be $10.9 billion. There is a state law that mandates that 30% or $3.3 billion will be allocated to the Consumer Climate Action Account. The NYCI outline proposes that 63% or $6.8 billion be dedicated to clean energy investments. The State has not provided an analysis that specifies affordability targets or the requirements for the zero-emissions technology necessary to displace existing fossil fuel use.
There is another underappreciated NYCI risk that I included in the commentary. The allowances available for auctions will be determined by the Climate Act targets. If insufficient investments are made for the deployment of replacement zero-emissions technologies or there are issues that delay implementation, then the emissions will not decrease at a rate consistent with allowance availability. Without a safety-valve provision, the only compliance option available is to stop burning fossil fuels. If gasoline distributors, for example, think they have insufficient allowances near the end of the year they would stop selling gasoline. Fortunately, the NYCI outline proposal includes a safety valve provision that will prevent an artificial energy shortage.
Even though there is a safety valve mechanism included, climate activists have argued that is inappropriate. Their ideological position is inconsistent with reality. In 2021 CO2 emissions in the Chinese energy sector increased by 400 million tons. Total New York GHG emissions for all greenhouse gases and all sectors in 2021 were 268 million tons. If the safety valve provision is needed it will only cover a small fraction of the total NY emissions. Insistence on meeting an arbitrary cap when annual emission increases elsewhere are greater than total NY emissions is not in the best interest of New Yorkers.
Conclusion
To meet the promise that NYCI implementing regulations would be in place by the end of the year, the proposed regulations have to be released soon. I think that the process has been delayed in large part because DEC has staffing issues. From what I understand the California environmental agency had ten times more staff working on the project and took longer than the time available to meet the end of the year target. This is a very big ask for DEC.
I have no idea whether the pre-proposal outline will have significant changes. The climate activists have made their position known and the Hochul Administration has given them pretty much whatever they have demanded in the past. The pragmatic inclusion of a safety valve will ensure that there are consumer safeguards in place but I am not confident it will make the final draft.
I recently stumbled upon an old New York State Energy Research and Development Authority report describing the first New York industrial wind facility. This post compares the projections for the facility with the observed performance.
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 400 articles about New York’s net-zero transition. The opinions expressed in this article do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.
Overview
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” 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.” In brief, that plan is to electrify everything possible using zero-emissions electricity. 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 State agencies and the legislature have been attempting to implement the plans.
The Madison Wind Farm is a power generation plant located in the town of Madison, New York. Constructed in 1999-2000, it was the first wind farm completed in New York state and the first merchant wind farm in the country. The power plant consists of seven Vestas V66-1.65 MW wind turbines,[1] generating enough energy to power up to 10,000 homes. The Vestas V66-1.65 MW wind turbines have a hub height of 67m and a 66m rotor diameter totally 100m to the top of the rotor
This report covers the development and operation of the Madison Windpower Project in Madison County, New York developed by PG&E Generating. The project began commercial operation in October 2000 and consists of seven Vestas V66-1.65 MW OptiSlip® wind turbines for a total capacity of 11.55 MW. Long term wind resource estimates predicted an annual hub-height average wind speed of 7.3 m/s. The net annual plant energy production was predicted to be 23,621 MWh, which would produce a capacity factor of 23.3%. The wind turbines were dispatched and controlled from the PG&E Pittsfield operations center, which was also responsible for substation maintenance. Vestas took charge of inspection, adjustment, and repair of the turbines (both scheduled and unscheduled) and established an operations and maintenance facility in the Madison area. The wind plant produced a total of 61,379 MWh of electricity for three years for an annual average of 20,460 MWh and an overall capacity factor of 21%. The capacity factor is lower than the expected value of 23.3% primarily due to lower than predicted wind speeds and turbine and grid outages.
Observed Operations
The New York Independent System Operator (NYISO) prepares a report describing load and capacity data for all New York generating units that participate in the electric market. Universally known s the “Gold Book” it is the best reference for New York electric generation data. The 2024 Load & Capacity Data Report presents load and capacity data for 2024 and future years. To prepare this summary of Madison Wind Farm operations I relied on a compilation of observed data from Gold Book reports dating back to 2006.
The following table lists the observed net energy (GWh) and capacity factors from 2006 to 2023 and the projections made in 2003 by AWS. In that analysis the observed capacity factor was 21% in the first three years. Since then, only one year achieved that level and the last three years the capacity factor was less than 14%. AWS projected that 425 GWh would be produced since 2006 but the energy produced by this facility was only 332 GWh, 22% less.
Table 1: Madison Wind Farm Performance Based on NYISO “Gold Book” Load & Capacity Data Report Table III-1 Including AWS 2003 Projections
The Conclusion of the AWS report summarizes the key findings:
The experience at Madison shows that the energy production from a wind facility is primarily dependent on the actual wind experienced and the performance and reliability of the turbines. The Vestas V66 turbines performed well when they were online because they produced the expected amount of energy for a given windspeed. However, the actual wind speeds experienced during the period and the reliability of the turbines were both lower than expected.
The wind speeds were lower than expected due to the incomplete meteorological record used to predict the wind resource, the lower-than-average wind speeds in this region of the state during plant operation, and the difference in elevation of the project met towers. This experience demonstrates the need to have sufficient long-term meteorological data in order to predict a wind plant’s energy production accurately. Continued evaluation of the projected wind speeds during plant operation can clarify trends and enhance understanding of the site’s wind resource. As such, it is expected that the overall wind resource at Madison will be more favorable during the lifetime of the plant.
The reliability of the machines was lower than expected due to the gearbox failures and other component difficulties discussed earlier in the report. These failures highlight the need for robust turbine reliability warrantees to protect turbine owners against loss of revenue in the case of such unexpected turbine component failures. On the positive side, excellent lightning protection in the V66 resulted in fewer outages due to static discharge than have been observed at other sites.
Discussion
As the first industrial wind facility Madison Wind Farm performance was evaluated in the AWS project. The report claims that it was a successful demonstration of large-scale wind development. I agree that it provides power and the information learned from it has been used to integrate other projects. However, I have concerns about the poor availability and decreasing capacity factors.
It was obvious at the time of the analysis that the projected capacity factor was lower than projected. The report argues that this was due to inadequate meteorological monitoring but optimistically notes the wind resource will be “more favorable during the lifetime of the plant”. That did not happen. The actual production since 2006 is 22% lower than they anticipated.
I think over-optimism is a characteristic of NYSERDA. The NYSERDA Integration Analysis projected a state-wide wind capacity factor of 29% in 2020 increasing to 34% in 2030. The Gold Book statewide capacity factor in 2020 was 23.9%. The Integration Analysis projected New York land-based wind in 2030 would generate 5,043 GWh but the actual production was only 4,162 GWh, 18% lower than they projected. In addition, the Integration Analysis did not acknowledge that as wind systems age their performance drops.
NYSERDA’s Integration Analysis quantified the generating resources that will be needed to meet the Climate Act mandates. However, comparison of observed and projected energy production shows that they have overestimated energy production which means that more wind capacity will have to be developed and that the costs will necessarily be higher than they projected. Unfortunately, there has not been any reconciliation between Integration Analysis projections and observations to refine their projections. This is in keeping with their complete lack of response to technical issues raised in comments on the Scoping Plan.
Conclusion
The performance of the first wind farm in New York is considerably less than projected. This is consistent with the observed and projected Integration Analysis 2020 statewide wind generation. These results should be used to refine the Scoping Plan but there is no indication that NYSERDA is considering such an effort. This is just one more example of the flaws hidden behind a veneer of political slogans that claim all is well with the Climate Act. Eventually it will become obvious that the Hochul Administration electric system “plan” is incompatible with reality. Unfortunately failing to address these issues promptly will increase costs and reliability risks
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 400 articles about New York’s net-zero transition. The opinions expressed in this article do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.
Power Trends
The New York Independent System Operator (NYISO) recently issued its Power Trends 2024
report which is billed as their “annual analysis of factors influencing New York State’s power grid and wholesale electricity Markets”. In the WUWT post I focused on the NYISO Summer 2024 Reliability Outlook chapter. I highlighted the particular concern for heat waves in the following:
For summer 2024, the NYISO expects 34,913 MW of resources available to meet 31,541 MW of forecasted demand under normal conditions. Under extreme summer weather conditions, however, forecasted reliability margins could potentially be deficient without reliance on emergency operating procedures. For example, if the state experiences a heatwave with an average daily temperature of 95 degrees lasting three or more days, demand is forecasted to rise to 33,301 MW, while predicted supply levels are reduced to 34,502 MW. When accounting for the required 2,620 MW of operating reserves that must be maintained, this scenario results in a forecasted reliability margin of -1,419 MW. That reliability margin declines further to -3,093 MW under an extreme heatwave with an average daily temperature of 98 degrees. Under these more extreme summer weather conditions, the NYISO forecasts an available supply of 34,317 MW to meet the required 2,620 MW of operating reserve requirements, plus a forecasted demand of 34,790 MW.
The intent of the article was to alert readers that the extreme summer weather conditions highlighted by NYISO could occur with the heat wave.
Observations
In brief, the June 2024 heatwave came nowhere near the potential deficit criteria. Table 1 shows that the average daily temperature did not exceed 84o F over the last four days. This was not a real stress test for the New York State electric grid.
NYISO Fuel Mix
Even though the heat wave did not push the New York grid the fuel-mix load data from the NYISO Real-Time Dashboard provides some interesting information. I have compiled the data for 17-21 June here. The following graph shows the hourly fuel type generation throughout the period. The generator types include “Hydro” that includes pumped storage hydro; “Wind”, land-based wind; “Other Renewables” that covers solar energy, energy storage resources, methane, refuse, or wood; “Other Fossil Fuels” is oil; “Nuclear”; “Natural Gas”; and “Dual Fuel” which are units that burn both natural gas and oil.
The NYISO Summer 2024 Reliability Outlook expects 34,913 MW of resources available to meet 31,541 MW of forecasted demand under normal conditions. During this period, the maximum hourly generation was 30,525 MW at hour 18 on June 18. There are important considerations relative to the fuel mix at that time.
The following table lists the fuel mix for generating facilities in New York for June 18. NYISO does not track behind-the-meter solar that reduces the load that NYISO must provide. Note that nuclear is constant throughout the day and hydro, dual-fuel, and natural gas increases to match the load peak.
The remaining three categories are of particular interest. The following graph only includes these three categories because they are small relative to the other fuel types.
In the “Other Renewables” categories the Gold Book lists the following capabilities at the end of 2023: utility-scale solar energy 254 MW, energy storage resources 20 MW, methane 104 MW, refuse 239 MW, and wood 56 MW for a total of 653 MW. The graph suggests that solar was providing its peak load during each day. The methane, refuse, and wood generators are dispatched so that they reduce load at night to a little under 300 MW.
One of the notable features during this period was that the wind resource consistently was lowest during the daily peak load. Despite this result New York is continuing to double down on renewable development. On June 20 the New York State Energy Research & Development Authority announced:
Governor Hochul today announced a new NYSERDA large-scale renewable energy solicitation to deliver clean electricity to New Yorkers. Building on New York’s 10-Point Action Plan , this solicitation seeks proposals for the development of new large-scale land-based renewable energy projects which are expected to spur billions in clean energy investments and create thousands of family-sustaining jobs in the State’s green economy.
Given that when needed most during the peak load observed here that all the New York land-based wind went to very low levels this solicitation will not solve this problem. Higher wind capacity with zero wind resource yields zero electricity.
There is another notable feature of the observed wind resources. The peak winds occurred in the early morning hours which are the lowest load periods. I believe this is a feature of the nocturnal wind pattern. Low-level winds affecting wind turbines increase with height as the effect of surface roughness and atmospheric mixing are reduced. At night the solar surface heating stops and the level of reduced wind speed contracts. This causes the wind speeds to increase and wind energy resources to improve. It also is another load balancing issue that must be addressed for an electric grid that depends on wind power generation.
The last of these three categories illustrates another related issue. The category “Other Fossil Fuels” provides generation for units that are exclusively oil-firing. In New York there are two types of these units – residual oil-fired steam boilers and simple-cycle peaking turbines. All the oil-fired boilers must remain at minimum loads higher than the lowest hourly values listed above to be able to ramp up for the diurnal peak. Therefore, the generation came from simple-cycle peaking turbines. As I have previously explained, New York City peaking turbines are vilified as “the most egregious energy-related example of what environmental injustice means today.” However, the presumption of egregious harm is based on selective choice of metrics, poor understanding of air quality health impacts, and ignorance of air quality trends. I wish I could say that there is no chance that these units will not be shutdown sooner than necessary to mollify Environmental Justice activists who demand it, but I am unconvinced.
Discussion
I am not optimistic that New York State energy policy will be up to the task addressing the future system resources challenge for a zero-emissions electric grid. One of the issues highlighted by the NYISO Power Trends report is illustrated in the following figure from the Power Trends Fact Sheet.
Overall, the capacity reduction from generator retirements relative to additions is 57%. However, if you compare the energy capability of the deactivated generators, especially the 2,000 MW of nuclear power retired, with the addition of primarily solar and wind capacity the energy available to the system is even less.
One other recent development is relevant. The owners of the Danskammer power plant north of New York City have had an application to repower and replace the existing Danskammer generating station with the Danskammer Energy Center, a new state-of-the art, efficient natural gas-fired combined cycle generating unit. Unfortunately, like a couple of other proposals to replace old fossil generating units with much cleaner and modern units, the New York State Department of Environmental Conservation has denied the permits to construct basically because there are Climate Leadership & Community Protection Act mandates coming. The fact that there is no feasibility analysis that proves that those mandates can be achieved was ignored. After years of court battles the developers gave up and withdrew their application this week. As a result, the electric system will continue to rely on aging and dirtier fossil generation for however long it takes for the State to figure out that existing technology is incapable of replacing fossil fired peaking power plants needed to keep the lights on.
Conclusion
The latest heat wave in New York State did not exceed the criteria determined by the NYISO for potential problems. Nonetheless, the facts that wind resources were a fraction of potential capacity during the peak hours and the grid relied on peaking power plants that environmental activists demand be shut down as soon as possible suggest that the potential problem is not going to go away anytime soon. Stay tuned.
Yesterday, I published an article that summarizes comments I submitted to the New York Department of Environmental Conservation (DEC) in response to a request for feedback. After I published the article, I received an answer to a question I asked EPA about the calculation methodology used by DEC and that inspired me to reiterate my contention that New York’s application of the societal benefits of greenhouse gas emission reductions results in misinformation.
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 400 articles about New York’s net-zero transitionThe opinions expressed in this article do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.
Overview
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” 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.” In brief, that plan is to electrify everything possible using zero-emissions electricity. 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, there have been regulatory and legislative initiatives to implement the recommendations, but progress has been slow.
Yesterday’s post included extensive documentation for the New York Value of Carbon so I will not repeat it here. For this article the key point is that the DEC Climate Change Guidance Documents webpage notes that it was established for use by State entities to “aid decision-making and for the State to demonstrate the global societal value of actions to reduce greenhouse gas emissions in line with the requirements of the Climate Leadership and Community Protection Act.”
Methodology Comment
Yesterday’s article described my submitted comment on the Value of Carbon methodology. In short, I am convinced that the State calculation methodology is incorrect. I believe that the guidance methodology is wrong because it applies the social cost multiple times for each ton reduced.
Last weekend I reviewed the EPA webpage description of the ““Report on the Social Cost of Greenhouse Gases: Estimates Incorporating Recent Scientific Advances”. That page includes links to the following information:
I reviewed the Final Report and thought that their description of the proper benefit calculation methodology supported my arguments. That webpage also includes a “Contact Us” form for questions. To confirm my interpretation I submitted the following to EPA.
I have a question about the first two sentences in the first paragraph in Section 4.2 of the Final Report.
The sentences say: “The Social Cost of Greenhouse Gases (SC-GHG) reflects the future stream of damages associated with an additional ton of emissions discounted back to the year of the emissions. Several steps are necessary when using the SC-GHG estimates in an analysis that includes GHG emissions changes in multiple future years in addition to other benefits and costs.”
I interpret that to mean that the SC-GHG benefit value is applied for an additional ton of emission reductions once. If you are looking at changes over multiple years, the first-year reductions are not applied cumulatively in multiple future years.
Is that the correct interpretation?
I received the following response from Elizabeth Kopits, PhD, Economist, National Center for Environmental Economics, Office of Policy, U.S. EPA:
Thank you for reaching out to our office with your question regarding EPA’s SC-GHG estimates.
The sentences you refer to are just intending to say that if you are analyzing a policy that is expected to result in emission reductions (or increases) in multiple years, then there are several steps to estimating the present value of the full stream of climate benefits (or disbenefits) that are expected from the emissions changes.
If I’m understanding your question correctly then I think the answer is yes.
For example, suppose it has been estimated that a policy will reduce CO2 emissions by 100 tons in 2025, 105 tons in 2026, and 110 tons in 2027, and the analyst is interested in calculating the total climate benefits from these emission reductions and comparing it to the estimated costs and other benefits of the policy. First, one would calculate the climate benefits in each year.
That is, the climate benefits in 2025 from the emission reductions expected in 2025 = 100 tons multiplied by the SC-CO2 for 2025 ($/t). (Recall this SC-CO2 value reflects the present value of the future stream of avoided damages from a one-ton reduction in 2025, so there is nothing more to calculate in 2026 and later related to the emission reductions that occurred in 2025.) Similarly, the climate benefits in 2026 from the emission reductions expected in 2026 = 105 x SC-CO2 in 2026, and the climate benefits in 2027 from the emission reductions expected in 2027 = 110 x SC-CO2 in 2027.
Finally, one can calculate the present value of the benefits resulting from the full stream of emission changes from the perspective of the base year of analysis (e.g., 2024) by discounting the 3 numbers back to 2024 and summing.
I hope this helps to clarify a bit. The SC-GHG workbook available on our webpage (https://www.epa.gov/environmental-economics/scghg) contains detailed instructions and example tabs that may be more helpful than my simple example above. If you continue to have questions, please feel free to reach out any time.
I believe that the key is the “SC-CO2 value reflects the present value of the future stream of avoided damages from a one-ton reduction in 2025, so there is nothing more to calculate in 2026 and later related to the emission reductions that occurred in 2025”. If the intent is to determine “the present value of the full stream of climate benefits (or disbenefits) that are expected from the emissions changes, then lifetime calculations are inappropriate. I want to know the value of the climate benefits for New York to reach an 85% reduction of GHG emissions by 2050.
Discussion
The New York Value of Carbon regulatory policy enables the State to “demonstrate the global societal value of actions to reduce greenhouse gas emissions”. New York’s climate policy making is nearly all political theater. To justify the costs of the Climate Act, the political slogan is “the costs of inaction are more than the costs of action”. To make that claim NYSERDA twisted the interpretation of the analyses to minimize the overall costs, biased costs low and benefits high, and, I have no doubt, influenced the Value of Carbon methodology to maximize benefits.
Yesterday’s post also included related correspondence with DEC staff responding to my interpretation. It stated that “We ultimately decided to stay with the recommendation of applying the Value of Carbon as described in the guidance as that is consistent with how it is applied in benefit-cost analyses at the state and federal level.” Dr Kopits response letter flatly contradicts the claim relative to the Federal level. To give the benefit of doubt to DEC staff I will concede that the interpretation of what is appropriate for this benefit-cost analysis may be different. However, I think that New Yorkers deserve clarification and ultimately get the total costs for the Climate Act mandated reductions.
The DEC response went on to say that “When applying the Value of Carbon, we are not looking at the lifetime benefits rather, we are looking at it in the context of the time frame for a proposed policy in comparison to a baseline.” Finally, it noted that “The integration analysis will apply the Value of Carbon in a similar manner as it compares the policies under consideration in comparison with a baseline of no-action.” This is where the interpretation of the policies under consideration were twisted. In brief, the Hochul narrative that the costs of inaction are more than the costs of action only applies to Climate Act policies and not the total costs to achieve the Climate Act mandates. The baseline of “no-action” described in the Scoping Plan as “Business as usual plus implemented policies” includes the following programs:
Growth in housing units, population, commercial square footage, and GDP
Federal appliance standards
Economic fuel switching
New York State bioheat mandate
Estimate of New Efficiency, New York Energy Efficiency achieved by funded programs: HCR+NYPA, DPS (IOUs), LIPA, NYSERDA CEF (assumes market transformation maintains level of efficiency and electrification post-2025)
Funded building electrification (4% HP stock share by 2030)
Corporate Average Fuel Economy (CAFE) standards
Zero-emission vehicle mandate (8% LDV ZEV stock share by 2030)
Clean Energy Standard (70×30), including technology carveouts: (6 GW of behind-the-meter solar by 2025, 3 GW of battery storage by 2030, 9 GW of offshore wind by 2035, 1.25 GW of Tier 4 renewables by 2030)
That means that the costs of all these programs that are required to meet the Climate Act mandate of an 85% reduction in emissions by 2050 are not included in the evaluation. Due to the lack of transparent cost and benefit estimates I cannot determine if the NYSERDA Integration Analysis excluded the benefits associated with those programs. However, it would be another way to achieve the goal of a sound bite justification of benefits and costs.
Conclusion
New York’s climate policy making is nearly all political theater. The shenanigans that the Scoping Plan authors used to make sure they could claim benefits were greater than costs and hiding their methodology and results is a long, disappointing story. The Value of Carbon methodology is dictated by the desire to prove a point rather than provide any rigor in establishing its definition and level. Given the necessity to maximize benefits to “prove” the costs of inaction are more than the cost of action and the lack of accountability to meaningfully respond to all stakeholders, ignoring my comments is a simply expedient.
I believe the ultimate question is “What are the benefits of New York’s 85% emission reductions mandated by the Climate Act?” To answer that the value of carbon or social cost of carbon benefits should use the EPA methodology. I believe that benefit is what all New Yorkers want to know and the Hochul Administration is deliberately covering up those numbers because it runs contrary to their narrative.
This post summarizes comments I submitted to the New York Department of Environmental Conservation (DEC) in response to a request for feedback on “additional updates to the guidance to align methodologies with recent updates from the U.S. Environmental Protection Agency.”
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 400 articles about New York’s net-zero transitionThe opinions expressed in this article do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.
Overview
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” 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.” In brief, that plan is to electrify everything possible using zero-emissions electricity. 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, there have been regulatory and legislative initiatives to implement the recommendations, but progress has been slow.
The value of carbon requirement was one of the first initiatives. Four years ago, I published an article on section § 75-0113 of the Climate Act. That section explicitly mandates how the value of carbon will be determined:
No later than one year after the effective date of this article, the department, in consultation with the New York state energy research and development authority, shall establish a social cost of carbon for use by state agencies, expressed in terms of dollars per ton of carbon dioxide equivalent.
The social cost of carbon shall serve as a monetary estimate of the value of not emitting a ton of greenhouse gas emissions. As determined by the department, the social cost of carbon may be based on marginal greenhouse gas abatement costs or on the global economic, environmental, and social impacts of emitting a marginal ton of greenhouse gas emissions into the atmosphere, utilizing a range of appropriate discount rates, including a rate of zero.
In developing the social cost of carbon, the department shall consider prior or existing estimates of the social cost of carbon issued or adopted by the federal government, appropriate international bodies, or other appropriate and reputable scientific organizations.
The DEC published the calculation methodology as mandated and has since updated New York’s Value of Carbon Guidance. The DEC Climate Change Guidance Documents webpage notes that it was established for use by State entities to “aid decision-making and for the State to demonstrate the global societal value of actions to reduce greenhouse gas emissions in line with the requirements of the Climate Leadership and Community Protection Act.” It includes an Appendix that provides social cost values for the greenhouse gases incorporated into the Climate Act. Also note that the documents include a report by the New York State Energy Research & Development Authority (NYSERDA) and Resources for the Future that was used to determine the values used.
Comment Process
The bottom line is that the DEC goes through the motions for the comment process. I pretend that someone will listen when I comment, the agencies pretend to appreciate my comments but inevitably go on to do whatever fits the political narrative, and, in most cases, I never hear anything about my comments. There is a requirement that requires DEC to respond to comments for proposed regulations so at least I get some feedback. It is not clear to me whether this request for feedback requires responses to comments received. When the original draft guidance was proposed DEC went through the regulatory process which included a formal comment period and required them to respond to comments. I described my November 2020 comments in a post and followed up with commentary on their response to my in January 2021.
As frustrated as I am with the DEC stakeholder process it is orders of magnitude better than the NYSERDA stakeholder process. Even when responses are not required, DEC staff acknowledges followup questions and sometimes answers them. I believe that they are also subject to intense political pressure to maintain the Administration’s narrative on all things climate-related. NYSERDA’s stakeholder process for the Scoping Plan consisted of a list of comments received and a heavily condensed and biased summary of the comments received. They consistently refuse to answer questions about technical issues or the resolution of comments received. I appreciate DEC staff for being open to discussion and condemn NYSERDA for ignoring stakeholders that do not agree with the political narrative.
Social Cost of Carbon Comment
Given the unlikelihood of any changes based on my comments, I did not spend a lot of time developing comments. Moreover, the request for feedback regarded using new information from EPA. Any attempt to argue that EPA got it wrong after EPA went through a similar process would have no chance of success.
Nonetheless I took the opportunity to argue that the societal value of greenhouse gas emission reductions approach is not in the public consciousness. I stated:
The Request for Feedback notes that “the new approach to discounting addresses public concerns regarding intergenerational equity.” For the record I have two issues with these concerns. I do not believe that the public raised concerns about intergenerational equity. Instead, that concern was raised by climate activists and non-governmental organizations whose monomaniacal focus on the alleged existential threat of climate change disregards any tradeoffs between costs, reliability, and environmental impacts of their favored solutions and the contrived benefits they claim. The second issue is that the public is unaware of these contrived calculations. If they were aware that New York’s Value of Carbon calculations project alleged impacts out to 2300, I am sure that they would wonder about the impacts today relative to those ten generations in the future. They would not look kindly at the hubris involved with claims that we can predict or even imagine what the world would like 275 years in the future. Moreover, Bjorn Lomborg notes in his 2020 book False Alarm – How Climate Change Panic Costs Us Trillions, Hurts the Poor, and Fails to Fix the Planet (Basic Books, New York, NY ISBN 978-1-5416-4746-6, 305pp.) that the costs of global warming will only reach 2.6% of GDP by 2100 but that global GDP will be so much higher at that time that this number is insignificant.
A recent article by Alex Trembath gives another take about why this metric is troubling. In response to his views about the social cost of carbon he did not want to disregard it entirely but said:
fundamentally, impossible. And it’s not just the fat tails of climate risk distribution, the controversies about the discount rate, or the other long-standing hurdles to a more robust SCC consensus. It’s that climate change is a slow-moving and massively complex global threat. We simply have no access to essential information, such as the size of the global economy decades from now and its resilience to climate impacts or even the exact sensitivity of the climate to emissions, that would inform a robust cost-benefit analysis.
Substantive Comment
I only made one substantive comment on the Value of Carbon methodology. I make this comment every chance I get and so far, have not been able to get a change. In short, I am convinced that the State calculation methodology is incorrect.
My comment addresses the “Estimating the emission reduction benefits of a plan or goal” section in the 2023 version of the Value of Carbon Guideline that states:
Estimating the emission reduction benefits of a plan or goal. An agency has developed a strategic plan with the goal of reducing carbon dioxide emissions 50% over ten years from current levels, or 50,000 metric tons over 10 years. In order to determine the benefits to society in terms of avoided damages, the agency will need to determine the annual level of emission reductions (or emissions avoided) compared to a no action scenario. If split evenly across all 10 years, the annual reduction is 5,000 metric tons per year (see table).
The net present value of the plan is equal to the cumulative benefit of the emission reductions that happened each year (adjusted for the discount rate). In other words, the value of carbon is applied to each year, based on the reduction from the no action case, 100,000 tons in this case. The Appendix provides the value of carbon for each year. For example, the social cost of carbon dioxide in 2021 at a 2% discount rate is $123 per metric ton. The value of the reductions in 2021 are equal to $123 times 5,000 metric tons, or $615,000; in 2022 $124 times 10,000 tons, etc. This calculation would be carried out for each year and for each discount rate of interest. The results for all three recommended discount rates are provided below. [The table below modifies the Guidance document with updated values of carbon and the correct annual benefits.]
My comments noted that the Climate Act mandates an 85% reduction in greenhouse gas emissions from 1990 levels by 2050. I believe that New York’s Value of Carbon should be applied in the context of the reduction of greenhouse gas emissions necessary to meet that goal. In particular, the reduction in annual emissions year to year. In this context, I believe that the guidance approach is wrong because it applies the social cost multiple times for each ton reduced. It is inappropriate to claim the benefits of an annual reduction of a ton of greenhouse gas over any lifetime or to compare it with avoided emissions. As shown above, the Value of Carbon methodology sums project benefits for every year for some unspecified lifetime subsequent to the year the reductions. The value of carbon for an emission reduction is based on all the damages that occur from the year that ton of carbon is reduced out to 2300. Clearly, using cumulative values for this parameter is incorrect because it counts those values over and over. I contact social cost of carbon expert Dr. Richard Tol about my interpretaton of the lifetime savings approach and he confirmed that “The SCC should not be compared to life-time savings or life-time costs (unless the project life is one year)”.
The preceding table calculates the benefits of the example project correctly. Note that if done correctly that the projected benefits are at least 5.5 times less than the in the flawed Value of Carbon methodology.
As mentioned before, although I am frustrated by the DEC stakeholder process, I did manage to get DEC staff to define their position on this topic. As I described in another article, I wrote to DEC and Climate Action Council about this problem in the guidance document. I received the following response:
We did consider your comments and discussed them with NYSERDA and RFF. We ultimately decided to stay with the recommendation of applying the Value of Carbon as described in the guidance as that is consistent with how it is applied in benefit-cost analyses at the state and federal level.
When applying the Value of Carbon, we are not looking at the lifetime benefits rather, we are looking at it in the context of the time frame for a proposed policy in comparison to a baseline. Our guidance provides examples of how this could be applied. For example, the first example application is a project that reduces emissions 5,000 metric tons a year over 10 years. In the second year you would multiply the Value of Carbon times 10,000 metric tons because although 5,000 metric tons were reduced the year before, emissions in year 2 are 10,000 metric tons lower compared to the baseline where no policy was implemented. You follow this same methodology for each year of the program and then take the net present value for each year to get the total net present value for the project. If you were to only use the marginal emissions reduction each year, you would be ignoring the difference from the baseline which is what a benefit-cost analysis is supposed to be comparing the policy to.
The integration analysis will apply the Value of Carbon in a similar manner as it compares the policies under consideration in comparison with a baseline of no-action.
I should have explicitly referenced this in my comments. It does not address my primary concern that the proper cost-benefit analysis is for meeting the Climate Act mandated target of an 85% reduction in GHG since 1990. Moreover, the benefit-cost analysis argument further biases their societal benefit claims when numbers are presented to the public.
Conclusion
To justify implementation of the Climate Act, the Hochul Administration political narrative is “that the costs of inaction are more than the costs of action”. The Scoping Plan basis for the claim included air quality health benefits, active transportation, and energy efficiency interventions in low- and middle-income homes. These benefits were not large enough to prove the case. The largest benefits claimed were based on the value of carbon avoided cost of GHG emissions. Absent the incorrect value of carbon methodology, the costs of action are more than the costs of inaction. I submitted this as a Scoping Plan comment and made the comment in a public hearing but have never received any response.
I do not expect any meaningful response to these comments. Most disappointing however is that despite my documentation of this error and other shenanigans used by the Scoping Plan authors to make sure they could claim benefits were greater than costs there has never been any response to them. Perhaps they hope that ignoring it means that it will just go away. It is not for a lack of trying but trying to shift the political narrative of New York’s climate policy is unlikely to succeed. It does give me something to do in retirement though.
Pragmatic Environmentalist of New York 