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.

Graduation Speech Essay You Need to Hear has Climate Response Implications

I think this marvelous Robert Parham essay deserves wide distribution. It addresses the mis-placed pessimism of students in colleges today. Parham is an assistant professor at the University of Virginia’s McIntire School of Commerce. Witnessing firsthand the growing distress among college students, Parham originally published his essay “To the Class of 2024: You Are All Diseased,” in The Free Press. This post addresses the parallels between his college concerns and the environmental movement.

The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

To the Class of 2024

I recommend reading the essay but will summarize it here. The introduction states:

If you are graduating from college this year, I suspect you’re not too familiar with George Carlin. So before you become inflamed about the (intentionally) harsh title, let me tell you I plagiarized it from Carlin, who was one of the best American comedians of the last 100 years. His show You Are All Diseased is available on YouTube, and it is so good that I was willing to start by alienating you a bit just to plug it here. You’re welcome. It is especially recommended if you’re in any kind of altered state of mind.

Speaking of states of mind: I’m worried about yours.

Rates of anxiety, depression, and suicide among people your age in the U.S. are skyrocketing. I myself lost a student to suicide a few years ago—an experience I wish on no one. I’m here to tell you that I think it’s partly our (your professors’) fault. We, along with others, have been feeding you a distorted view of the world and your place in it, and I think this has caused a considerable part of the existential angst you all feel.

But I’m not just aiming to point fingers.

I want to lay a vision of the present and future, which I genuinely believe and yet know many of you don’t share. After all, exposing you to unfashionable ideas is a core part of a healthy education. My deeper hope in doing so is to start a conversation on changing this sad state of affairs and to get you on your way to a happy and healthy life. Isn’t that what commencements are all about?

The thrust of the article is that today’s college students are deeply pessimistic about the future despite, as he argues, the fact that human beings have never had it so good.

Based on every objective measure of well-being—safety, health, wealth—if you are a college student in America today you are better off and wealthier than the king of England was 300 years ago. You have better access to education, entertainment, leisure, and healthcare. You have cleaner water and more abundant food. You have a significantly safer and longer life. And you have access to all of the world’s knowledge, including this piece, in the palm of your hand.

Then he states: “Which then raises the question: Why? Why is it that “everything is amazing and nobody is happy”? He explains that the reason why we don’t think of ourselves as better off than the King of England:

We economists call this phenomenon “relative wealth concerns” or “keeping up with the Joneses.” These are just fancy terms to describe a simple psychological fact: we are constantly busy comparing ourselves to our peer group, and feel bad when we fall short in that comparison.

He goes on to describe our peer group:

“Peer group” is an essential term in the previous sentence. No one cares that they’re enormously better off than their grandparents; they just care that they’re worse off than Jeff Bezos or Elon Musk. You don’t feel wealthy, despite the fact the median human lives on the equivalent of $5,000 per year. Yes, you read that right. Imagine if you lived in the U.S., but only spent $5K a year at current U.S. prices, and you’ve imagined the life of the median human today. Your “peer group” isn’t humanity; it’s social media influencers and billionaires, and you are deeply unsatisfied when comparing your lives to theirs.

You live in the wealthiest country in the history of the world, yet you feel economic anxiety. The late Charlie Munger summarized it succinctly: “The world is not driven by greed. It’s driven by envy.” And in this era of instantaneous communication networks and social media, envy has been put into hyperdrive.

Professor Parham is not a fan of the emphasis on equity or fairness. He argues that envy is no longer a deadly sin, it has become the fairness virtue. He points out fairness issues for American college graduates relative to the rest of the world:

The world is unfair. Deeply so. It’s just that you’re the lucky ones. You won the birth lottery.

In a truly fair world, any dollar you make or spend above $5,000 a year would instead be given to someone else. Maybe a poor Kenyan, or Bangladeshi, or Indian. But that’s not the kind of fairness and equity anyone talking about “fairness” and “equity” around you seeks.

You’ve been lied to. You’ve been told, by the media, social networks, and not least your professors, that this fantastic world we live in is evil. Not only that, you’ve been told it’s your fault. You’re too racist, too greedy, too white, too privileged, not sufficiently attuned to the plight of the marginalized. It is not enough to be non-racist, they say, you must be anti-racist. Anything less than that, and you’re complicit in evil. Some of you are better by default due to some accidents of birth; some of you are worse. Small wonder you feel suffocated, anxious, and depressed.

Any human, weighed down with this responsibility and guilt, would be just as down. The cognitive dissonance of being told colonialism is evil, American slavery is uniquely evil, that wealth and the markets that enable it are evil, while going to school at a top-tier U.S. institution built on “Monocan land” using slave labor would incapacitate anyone.

He includes an informative description of the concept of money and how that creates a transaction where both parties become better off because of it. As society has evolved away from one-on-one transactions between people, now the transactions are between people and corporations. People earn money and can purchase what they need and want. He explains that when that happens: “We’re better off, the company we bought things from is better off, its employees and suppliers are better off, and so are their employees and suppliers. But in colleges today capitalism is frequently described as evil:

Without fail, at the end of the class a few students tell me that the content of the course was diametrically opposed to what they had been taught so far. Prior, they had class discussions about the exploitative nature of the market system and its inherent unfairness; the evil and greed of corporations; and the fight of exploited workers against oppressive capitalists.

In response he states:

I point out to them that these paradigms imply a zero-sum world in which wealth can only be created by taking it from others, whereas they live in the positive-sum world of markets, in which wealth is created by exchange. Markets have deposited a magic wand in their hands, which allows them to freeze moments in time, observe what is currently happening in foreign lands, and conjure loved ones for a face-to-face conversation out of thin air. Kings would have given half their kingdom for such a wand, but now anyone can have it for the low, low price of $69.99 per month. Or about five hours of student work. This is how we got wealthy.

He goes on to say:

My students arrive at my class steeped in zero-sum ideas, in which one person’s gain must be another person’s loss, and the only way to get a thing is by “oppressing” it from someone else. Then, they are shocked to hear heretical ideas about a world in which wealth is created, not stolen, and human interactions can be win-win and make all of us immensely well-off. The dissonance is severe, and they’re unsure how to deal with all the shame and guilt accumulated by years of accused “oppression.”

I hence want to close by telling you, the class of 2024: it’s not your fault. You are not evil. Being white / black / privileged / downtrodden / well-educated / illiterate / wealthy / poor / healthy / sickly / cisgendered / non-conforming does not make you bad (or good, for that matter). The sins of your forefathers are not your own. You did nothing wrong by being born. Yes, aiming to improve the state of human affairs is noble, but choosing instead to study, play games, and make out with the cute person you have your eye on does not make you bad. It makes you a normal, healthy human being. And no one seems to bother to tell you that. So there, I said it. You are not subject to the “original sin.” Go forth and have a happy and healthy life. There is still (much) room for progress, but things are currently better than they’ve ever been, and improving fast.

Or as Carlin put it, in his direct way: “Life gets really simple once you cut out all the bullshit they teach you in school.”

Environmental justice Parallels

I believe the environmental parallel is related to the “zero-sum idea”. The common perception is that emissions from a power plant or a factory are exploitive and come at the expense of harm to others, especially environmental justice communities. The concept that, within limits, emissions have positive-sum benefits is ignored.

No where is this dissonance more pronounced than the environmental justice movement. The EPA defines environmental justice:

“Environmental justice” means the just treatment and meaningful involvement of all people, regardless of income, race, color, national origin, Tribal affiliation, or disability, in agency decision-making and other Federal activities that affect human health and the environment so that people:

are fully protected from disproportionate and adverse human health and environmental effects (including risks) and hazards, including those related to climate change, the cumulative impacts of environmental and other burdens, and the legacy of racism or other structural or systemic barriers; and

have equitable access to a healthy, sustainable, and resilient environment in which to live, play, work, learn, grow, worship, and engage in cultural and subsistence practices

The difference between zero-sum and positive-sum environmental approach is in the definition of “disproportionate and adverse human health and environmental effects”. The environmental justice position I hear most often is a demand for no health and environmental effects.

In that regard I think my career is an instructive positive-sum example. When I completed my master’s degree in 1976 the United States Environmental Protection Agency (EPA) was only six years old and corporate America was just coming to grips with environmental management. I worked for five years for three different consulting companies that did contract work for EPA. In 1981 I started to work for Niagara Mohawk Power Corporation a vertically integrated electric utility. The environmental progress since I started working in the New York electric generating business has been astounding but is ignored by environmental justice activists.

One of my responsibilities at Niagara Mohawk was to prepare and submit emissions data to regulatory agencies. I recently found annual emissions data back to 1984. One of our facilities was the coal-fired Dunkirk Generating Station in Western NY. The facility had two 100 MW units and two newer 200 MW units. In 1984 the facility emitted 54,709 tons of SO2 at a rate of 3.26 lb per mmBtu and 10.020 tons of NOx at a rate of 0.598 lb per mmBtu. Over my time supporting the station, they installed controls for SO2, NOx, particulates, and mercury. In my last year with responsibilities for reporting at the station (2010) the facility emitted 7,380 tons of SO2 at a rate of 0.505 lb per mmBtu and 2,342 tons of NOx at a rate of 0.160 lb per mmBtu. Since then, the facility has been shut down. In 2023, the total electric generating sector emissions in the entire state of New York were 645 tons of SO2 at a rate of 0.003 lb per mmBtu and 7,488 tons of NOx at a rate of 0.030 lb per mmBtu. That is astounding progress.

Despite this tremendous reduction, environmental justice activists carry on about the egregious harm caused by power plants and claim numerous health effects from existing sources. However, if their health effect claims were true then there should be enormous observable improvements from the improvements made since 1984. I have not seen any such analysis. The other counter narrative is that the reason for the improvement is that natural gas became the cheapest fuel source and that occurred because of the fracking revolution that the environmental justice activists love to hate.

Discussion

My takeaway from Parham’s speech is that things are much better than portrayed by many academics. “There is still (much) room for progress, but things are currently better than they’ve ever been, and improving fast.” That sentence sums up the status of the environment in the US. There are environmental issues that still need to be addressed. However, the health of the environment has never been better in this country. There has been tremendous improvement over the last 40 years.

My concern is that as is the case with the academic focus on pessimism there are those who ignore environmental improvements and focus on current much smaller environmental risks all the while ignoring the benefits of a reliable electric system. The New York City peaking power plant issue is a prime example. Even though direct emissions from those plants comply with all existing environmental regulations, activists claim that they are the “most egregious energy-related example of what environmental injustice means today.” The activists paid a consultant to give them that answer and have been promoting the issue ever since. 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. In fact, analyses for the New York Cap-and-Invest have shown that was that the inhalable particulate emissions claimed as a particular problem are primarily from other sources.

Nonetheless, environmental justice activists are demanding that those facilities shut down. This is a problem because we do not have a zero-emissions technology that can replace them and maintain the same levels of reliability. If they are shut down too soon then blackouts are inevitable that will cause real impacts rather than the conjured impacts used to argue for the shutdowns. Their efforts would be better served by promoting inhalable particulate emission reductions from diesel trucks. Environmental justice advocates are arguing that would be appropriate but imagine that a zero-emissions solution is necessary. There could be a tremendous improvement using existing technology that only needs development of infrastructure but compressed natural gas has emissions and the natural gas used would be fracked so this practical solution is ignored.

Conclusion

Parham’s essay stands on its own as a great message for today. The difference between a zero-sum society in which wealth can only be created by taking it from others, and a positive-sum society in which wealth is created by exchange is being improperly ignored. Worse academics are promoting the zero-sum concept to the detriment of their students.

In my opinion, I think there are zero-sum versus positive-sum environmental parallels. The United States has developed a comprehensive set of environmental standards and there have been unquestioned overall environmental quality improvements over the last several decades. The sum of benefits and costs are positive. Regarding emissions in isolation, focusing only on the negatives and disregarding any benefits is an approach like the zero-sum concept of wealth. It creates an unnecessarily pessimistic outlook, hinders growth, and could lead to unintended consequences.

Grid Planning to Meet Climate Act Goals Documentation

Note: This documents all the slides in the Grid Planning to Meet Climate Act Goal presentation. I also prepared a summary of the material in this post.

In order to meet the Climate Leadership & Community Protection Act (Climate Act) mandates for a zero-emissions electric grid by 2040 a massive effort to deploy wind, solar, and energy storage resources and an enormous upgrade to the electric transmission system is needed. I have previously described issues associated with generating portion of this transition. This post documents the Alliance for Clean Energy New York (ACENY) webinar “Grid Planning to Meet Climate Act Goals” that addressed the transmission challenges in a lot of detail. A summary is also available.

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

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. 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. In 2023 the Scoping Plan recommendations were supposed to be implemented through regulation, PSC orders, and legislation. Not surprisingly, the aspirational schedule of the Climate Act has proven to be more difficult to implement than planned and many aspects of the transition are falling behind.

ACENY Webinar

On April 11, 2024, Alliance for Clean Energy New York (ACENY) hosted a webinar entitled “Grid Planning to Meet Climate Act Goals” that was recorded on a video. The webinar was moderated by Chris Casey, from the NRDC and featured speakers from the Department of Public Service (DPS), New York Independent System Operator (NYISO), and National Grid. This article describes each speakers presentation and provides links to sections of the video so that readers can follow the presentations.

Chris Casey, a lawyer from the NRDC opened the webinar with an overview. It was not surprising that his Chris Casey, a lawyer from the NRDC opened the webinar with an overview. It was not surprising that his introduction ticked all the boxes. New York is on the “forefront of the transition to address the “impacts of destructive climate change”, increase access to “affordable” renewable energy, bolster “resilience against life-threatening extreme energy events”, all while “creating jobs and delivering substantial economic benefits”. Behind the rhetoric, however, reality lurks, and it does not look so grand. In the following sections I include slides and links to the section of the video that discusses the slide.

DPS Presentation

Elizabeth Grisaru (Senior Policy Advisor) from the DPS made the first presentation “Planning for Future Electric System Needs”. One of her main job responsibilities is transmission planning associated with the Climate Act transition. During her introduction she included a slide that illustrates the connections between generators and customers that were the focus of the webinar.

The “Impact of Climate Objectives” slide describes the general issues associated with the transition.

The description of the slide “PSC Initiatives since 2020” outlined projects costing over $6 billion that are over and above what is needed to keep the system running. The investments are for both Climate Act needs and reliability issues. What was not included was the breakdown between the two needs or any estimate of how much more will be needed. It is clear that many more investments will be required.

Note, however, that the first of the new CGPP reports is not going to be available until the Fall of 2025. It is not clear if the CGPP is going to help at all to meet the 2030 target.

The DPS final slide addresses outstanding issues. On one hand existing sources of generation are being forced to retire while on the other hand electrification initiatives are increasing loads. She claimed that at the PSC “We all agree reliability is the most important thing we have to worry about”.

NYISO Presentation

NYISO Director of System Planning Yachi Lin talked about their plans to implement a clean and reliable grid. Her introductory explanation gave a good overview of the NYISO. The following slide describes the planning process. There is a two-year cycle of reliability planning that includes quarterly checks on the status of the system.

Lin explained that additional transmission is needed to meet the 2030 70% renewable energy goal. The following slide shows different areas of the state that do not have adequate transmission capabilities to prevent curtailments.

To respond to the need for additional transmission the NYISO planning process is supporting “unprecedented expansion”.

The quarterly Short-Term Assessment of Reliability (STAR) reports should be required reading for anyone interested in the New York electric system so Lin’s explanation is important. The following slide notes that last years second quarter report noted that there was a reliability deficit of 446 MW in the summer of 2025. The deficit was projected because of fossil unit deactivations. In response, NYISO opened a solicitation for market solutions or regulatory solutions. No feasible market solution was submitted.

To maintain reliability, NYISO had to resort to a regulatory solution. They designated two peaking generation plants as reliability needs and postponed their retirement for two years. The NY Department of Environmental Conservation “Peaker Rule” incorporates this provision and there is a potential for an additional two-year extension. If the Champlain Hudson Power Express transmission project is delayed beyond 2026 the additional extension might be required.

The Comprehensive Reliability Planning report incorporates changes associated with demand growth. In the following slide NYISO describes expected changes. As mentioned previously, fossil generator retirements and growth in demand are primary changes to the system. Part of the load demand shift changes the peak loads from summer to winter. This is troublesome because the winter diurnal peak will occur when there is no solar. She also mentioned the dual-fuel units. Many New York generating units normally burn natural gas because it is cheaper but have the capability to switch to oil firing when natural gas is needed by residential consumers. The increased reliance on these units which at the same time are targeted for retirement is a problem. The CRP analysis also identified added risks. The addition of the Micron chip fab plant near Syracuse will add load equivalent to the total load of Vermont and New Hampshire. The New York Power Authority operates small natural gas plants in New York City that are supposed to be phased out by December 2030 due to political pressure. Lin had to make the obligatory gesture to climate change extreme weather as a risk. Finally, the shift to a weather-dependent generating system mans that reliability design criteria need to be revised to account for extreme weather conditions outside current planning horizons.

The next four slides summarize the challenges to meet the 2040 Climate Act mandate for a “zero-emissions” electric grid. The next slide repeats the points raised in the previous slide. Lin remarked that the year of the cross over from summer to winter peaking can only be guessed at this time. Depending on the trends in load it could be almost anytime in the next decade. The 90/10 and 99/1 forecasts are probability estimates for the likelihood of extreme weather events. The final bullet in the slide points out that there could be substantial load growth needed to provide reliability services. The NYISO includes a high load policy case that incorporates this load.

The next slide lists the challenges on the generation side. Lin makes the point that generation issues extend beyond simply evaluating the capacity needed to match the load projections. Wind, solar, and energy storage are inverter-based resources that require ancillary service support to make the transmissions system reliable. Weak-grid interconnection and common mode failures are issues that most people, including me, do not understand well. The key point is that all the people that I know understand these issues are worried but there was never any indication of concern by the Climate Action Council. Consequently, the Scoping Plan outline produced by the Hochul Administration to guide the energy transition is incomplete. Lin makes the little recognized point that the Dispatchable Emissions Free Resources are not needed just for the long periods of low renewable resource availability but also to provide these ancillary services.

The next slide addresses DEFR specifically. I will not discuss this much because I covered the Department of Public Service (DPS) two-day technical conference last December that focused on characterization of the potential “gap” caused by low renewable energy resource availability over long periods of time. I mentioned but did not emphasize the importance of providing the “reliability attributes of retired synchronous generation”.

The focus of this webinar was on the transmission challenges as covered in the following slide. Lin explained that transmission expansion is required to get the diffuse wind and solar energy from where it is collected to where it is needed. The existing system is not adequate for this task.

In the next slide Lin explained how the NYISO is working with the PSC to identify the needed bulk and local transmission needed.

The final slide in Lin’s presentation presented the planning process expected progress. There is an enormous amount of work underway but the analysts have a big challenge dealing with changes in the development of resources. As noted earlier, the 2026 expectation is that the Champlain Hudson Power Express project will be online. Even after years of development work the right of way is still not fully permitted and there are numerous examples of supply chain issues delaying other projects so the planning process is subject to massive uncertainty.

National Grid Presentation

Brad Franey Vice President Clean Energy Development explained how National Grid is addressing the need for transmission support. As he points out the utilities receive funding for their transmission and distribution (T&D) system investments from rate cases. Those rate cases are, in no small part, influenced by politics. As a result, none of New York’s utility companies are going to overtly challenge the political narrative that the Climate Act objectives can be achieved on schedules mandated by the law. The following slide probably went through multiple iterations to achieve a description of plans that checks all the boxes for what the company thinks that the politicians want to hear.

I live in Upstate New York so I was particularly interested in the “Upstate Upgrade” described in the following slide. The following slide rationalizes the costs for the upgrades to over 1,000 miles of lines. In his description Franey gave the example of a town that attracts snow mobile tourists in the winter. The last two years there have been snow droughts because they “no longer have the snow like they used to.” Construction of a line nearby brought in a lot of business and locals said that those saved businesses. The entire slide is devoted to the mantra that the Climate Act will create jobs and investments. Last year I described the DPS rulemaking that foisted these projects on the Upstate ratepayers. This slide avoids the things I found: National Grid residential ratepayers will see their bills increase 3.8%, the fact that these upgrades are needed to get renewable energy to Downstate so don’t benefit the ratepayers directly, or that the percentage increase for upstate ratepayers will be greater than the increase for ratepayers who directly benefit from the investments.

The next slide gives an example of their proposed reliability solutions. He included the obligatory argument that we are seeing more “frequent storms” that ignores the differences between weather and climate. He went on to give examples where a reduction in outages would positively impact their community. The proposed solution is a microgrid with battery energy storage. In my opinion, however, this is another example of a clean energy solution that works well most of the time but will fail when needed most. The problem here is the specification for battery storage. In the future New York system when home heating and transportation are both electrified the worst case will be an extended outage due to an extreme weather event like an ice storm. Specifying the battery storage for an ice storm event that occurs every 20 years will probably be too costly but when the inevitable ice storm does occur everyone in the microgrid will be at extreme risk because the energy storage system will run out of power. Fossil fuels are energy dense and can be stored making them much better for emergency backup.

Another initiative that National Grid is starting to support is public charging. Again ratepayers get to pick up the tab for something that most will not use and don’t ever want to use. Their analysis indicates that the load at the service plazas along the thruway could go up to 20 to 40 MW which is the same load as “a small town or major sports stadium.” In order to provide that load they need to upgrade the local infrastructure. They are planning to use mobile energy storage along the Thruway until infrastructure is developed. This bridge to wires solution is a pragmatic approach given the likely futility of heavy duty electric trucks.

The latest rate case included funding for smart meters. Franey describes this initiative in the next slide. Ostensibly this is supposed to help consumers better understand their energy use and facilitate outage response but the ability to try to reduce peak loads either through rate mechanisms or eventually managing electric use are certainly on the table.

Questions and Answers

The question and answer portion of the webinar was interesting. The first question asked was “Is reliability a prerequisite for everything else or is it co-equal with our policy objectives?” I have heard suggestions that policy objectives should be considered more than they are currently but anyone hoping to hear that there have been changes to protections in place to make sure that our policies don’t get ahead of reliability would have been disappointed in the answers. Elizabeth Grisaru from the DPS made it clear that reliability comes first, that there are “off ramps” for the implementation schedule and that the PSC will not let our zeal for meeting de-carbonization goals get out in front of reliability. Yachi Lin from the NYISO emphasized the point that they are constantly evaluating reliability. The quarterly Short term assessment of reliability and the longer term reliability needs assessment both address it. She admitted that we are going to have outages because the network is not built to be 100% risk-free or outage free. The alternative it “gold plating the system” which we cannot afford.

The next question asked about interconnections when the grid is not ready to take new renewables. How does that come into play and how will this be alleviated? Grisaru from the DPS acknowledged that if the system is not ready then developer has to pay for interconnection upgrades. They are trying to address this but it takes time. Franey from National Grid said that they are working on the issue but reliability has to be maintained.

There was a question about the different planning cycles. I think this question came before the NYISO described their processes. Grisaru from the DPS explained that the Coordinated Grip Plan Process is supposed to put it all together. Liu from NYISO explained that constant planning is responding to continual changes to the system. Every new development changes some aspect of the T&D system in some way.

The panel responded to the question how does the public policy planning processes differ. Grisaru explained that when the DPS sees a need on the bulk transmission system they contact the NYISO to start a process to look for a solution. The NYISO system outlook can also identify bulk transmission requirements.

A question about longer planning processes planning and deployment timing was also addressed. Liu explained that the NYISO resource adequacy process identifies risk factors and the timelines to develop the responses. Franey explained that the building component is the fastest but still takes years. The process has to determine what is needed and where before the planning permitting, and construction plans can be developed. Only when all that is done can construction begin but there are procurement and supply chain issues that also have to be addressed.

How can the state policies that affect energy use affect transmission planning. Climate activists are proponents of smart grids, energy efficiency, and other technologies that reduce energy use as a way to minimize the need for transmission development. In response, Grisaru explained that non-wires solution have been used for a long time and is incorporated into the Coordinated Grip Plan Process. The problem is that the de-carbonization transformation is going to require transmission solutions. Franey explained that urban city electrification (bringing rural diffuse renewables to the cities) is going to be the next challenge,

Discussion

My impression of the speakers at this meeting is that they were desperately trying to make the point that the transmission challenges for the Climate Act mandates and schedule were impossible goals without actually saying that. I believe that all the technical people who really understand the electric grid in the DPS, NYISO and the electric companies are being held hostage to the political narrative that “All is well”. That did not work out for Kevin Bacon in Animal House and it won’t work out here either.

The transmission challenges are different than the generation challenges. While it may not be necessary to develop and deploy a not yet commercially available technology like the generation sector to make this all work there still are inverter-based resource integration issues that need to be resolved. I have the utmost respect for the electric system engineers, but I fear that they will be hit by unanticipated combinations of conditions that they could not foresee. The result will be blackouts.

In my opinion the bigger problem is the scale of the transmission upgrades and additions needed. New York has already committed to $6 billion to start “unbottling” renewable resources which is code in New York for Upstate utilities paying for support for New York City access to renewables. New York also has plans for three major bulk transmission projects to get hydroelectric power from Quebec, another to collect the energy from part of Upstate to New York City, and the third to start the process of connecting the expected 9 GW of offshore wind into the grid. Nobody has admitted to the total costs.

The other New York problem that I suspect is common elsewhere is that the politicians who enacted these net-zero laws were more concerned with the optics of aspirational timelines and not the feasibility of those schedules. A question about longer planning processes planning and deployment timing made the point that the NYISO resource adequacy process that identifies specific need for transmission development, New York’s de-regulated market process to propose, bid, and choose the development, and the project planning, permitting, and construction plans development which all need to be completed before construction can begin takes a lot of time. Reading between the lines all the speakers are highly skeptical that the artificial deadlines of the Climate Act can be achieved.

One final point not addressed in the webinar but certainly affecting the viability of New York’s energy transition goal is the decarbonization of heating and transportation. That is going to require a complete rewiring of the distribution network.

Conclusion

The magnitude, costs, and technical challenges of the generation and transmission electric grid transition ensure that that there is no question that New York will hit the Green Energy Wall. The Hochul Administration has not provided a feasibility analysis that includes the expected costs, ensures that current reliability standards can be maintained, and documents the cumulative environmental impacts of the generation resources and the transmission and distribution deployments for the electric system to meet the 2030 70% renewable energy mandate. The fact that no jurisdiction anywhere has developed a system that depends on wind and solar as in the proposed New York system suggests that a proof of concept demonstration is appropriate.

Grid Planning to Meet Climate Act Goals Summary

Note: This is a summary of the presentation that is a version of a post at Watts Up With That. In order to prepare the summary, I documented all the slides and made that into another post.

In order to meet the Climate Leadership & Community Protection Act (Climate Act) mandates for a zero-emissions electric grid by 2040 a massive effort to deploy wind, solar, and energy storage resources and an enormous upgrade to the electric transmission system is needed. I have previously described issues associated with generating portion of this transition. This post summarizes the Alliance for Clean Energy New York (ACENY) webinar “Grid Planning to Meet Climate Act Goals” that addressed the transmission challenges in a lot of detail.

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

Overview

ACENY Webinar

On April 11, 2024, the Alliance for Clean Energy New York (ACENY) hosted a webinar entitled “Grid Planning to Meet Climate Act Goals” that was recorded on a video. The webinar was moderated by Chris Casey, from the Natural Resources Defense Council (NRDC) and featured speakers from the Department of Public Service (DPS), New York Independent System Operator (NYISO), and National Grid. This article describes each speaker’s presentation and provides links to sections of the video so that readers can follow the presentations.

Chris Casey, a lawyer from the NRDC opened the webinar with an overview. It was not surprising that his introduction ticked all the boxes. New York is on the “forefront of the transition to address the “impacts of destructive climate change”, increase access to “affordable” renewable energy, bolster “resilience against life-threatening extreme energy events”, all while “creating jobs and delivering substantial economic benefits”. Behind the rhetoric, however, reality lurks, and it does not look so grand. In the following sections I include slides and links to the section of the video that discusses the slide.

DPS Presentation

Since the inception of the Climate Act, DPS has begun several initiatives. These projects total $6 billion over and above what is needed to keep the system running. The investments are for both Climate Act needs and reliability issues. What was not included was the breakdown between the two needs or any estimate of how much more will be needed. Clearly many more investments will be required.

The transition to an electric system that depends upon diffuse wind and solar requires a significant upgrade to the transmission system. The PSC has a new “Coordinated Grid Planning Process” to address this issue. However, the first report will not be available until the fall of 2025. The Climate Act an interim 2030 electric grid target of 70% power from renewable sources by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. I have to say I don’t think the schedules match.

The DPS final slide addresses outstanding issues. On one hand existing sources of generation are being forced to retire while on the other hand electrification initiatives are increasing loads. Grisaru claimed that at the PSC “We all agree reliability is the most important thing we have to worry about”.

NYISO Presentation

NYISO Director of System Planning Yachi Lin talked about their plans to implement a clean and reliable grid. The following slide describes the NYISO planning process. There is a two-year cycle of reliability planning that includes quarterly checks on the status of the system. NYISO is constantly evaluating future reliability needs.

The following slide describes the generation system and the investments expected to be needed. Existing generating capacity is 37.4 GW, but an additional 20 GW must be in service in seven years to meet the 2030 goal. Note that the feasibility question has been studiously avoided by the state and the NYISO and utility companies have not overtly called the aspirational schedule out as impractical.

Lin explained that additional transmission is needed to meet the 2030 70% renewable energy goal. There are different areas of the state that do not have adequate transmission capabilities to move the solar and wind power out without curtailments. To address those needs the NYISO planning process is supporting “unprecedented expansion”.

One of the planning reports is the quarterly Short-Term Assessment of Reliability (STAR). Anyone interested in the status of the New York electric system would do well to listen to Lin’s explanation. The following slide notes that last year’s second quarter report noted that there was a reliability deficit of 446 MW in the summer of 2025. The deficit was projected because of fossil unit deactivations. In response, NYISO opened a solicitation for market solutions or regulatory solutions. No feasible market solution was submitted so they had to go to Plan B.

The Comprehensive Reliability Planning (CRP) report incorporates changes associated with demand growth. In the following slide NYISO describes expected changes. As mentioned previously, fossil generator retirements and growth in demand are primary expected changes to the system. Part of the load demand shift changes the peak loads from summer to winter. This is troublesome because the winter diurnal peak will occur when there is no solar. She also mentioned the dual-fuel units. Many New York generating units normally burn natural gas because it is cheaper but have the capability to switch to oil firing when natural gas is needed by residential consumers. The increased reliance on these units, which at the same time are targeted for retirement is a problem. The CRP analysis also identified added risks. The addition of the Micron chip fab plant near Syracuse will add load equivalent to the total load of Vermont and New Hampshire. The New York Power Authority operates small natural gas plants in New York City that are supposed to be phased out by December 2030 due to political pressure. Lin had to make the obligatory gesture that climate changes to extreme weather was a risk. Finally, the shift to a weather-dependent generating system means that reliability design criteria need to be revised to account for extreme weather conditions outside current planning horizons.

The next four slides summarize the challenges to meet the 2040 Climate Act mandate for a “zero-emissions” electric grid. The next slide repeats the points raised in the previous slide. Lin remarked that the year of the cross over from summer to winter peaking can only be guessed at this time. Depending on the trends in load it could be almost any time in the next decade. The 90/10 and 99/1 forecasts are probability estimates for the likelihood of extreme weather events. The final bullet in the slide points out that there could be substantial load growth needed to provide reliability services. The NYISO includes a high load policy case that incorporates this possibility.

The next slide lists the challenges on the generation side. Lin makes the point that generation issues extend beyond simply evaluating the capacity needed to match the load projections. Wind, solar, and energy storage are inverter-based resources that require ancillary service support to make the transmissions system reliable. Weak-grid interconnection and common mode failures are issues that most people, including me, do not understand well. The key point is that all the people that I know who understand these issues are worried but there has not been any wavering of the official political position that all is well. Consequently, the Scoping Plan outline produced by the Hochul Administration to guide the energy transition is incomplete. Lin makes the little recognized point that the Dispatchable Emissions Free Resources are not needed just for the long periods of low renewable resource availability but also to provide these ancillary services.

The next slide addresses DEFR specifically. I will not discuss this much because I covered the Department The next slide addresses DEFR specifically. I will not discuss this much because I already covered the Department of Public Service (DPS) two-day technical conference last December that focused on characterization of the potential “gap” caused by low renewable energy resource availability over long periods of time. I mentioned but did not emphasize the importance of providing the “reliability attributes of retired synchronous generation”.

The final slide in Lin’s presentation presented the planning process expected progress. There is an enormous amount of work underway, but the analysts have a big challenge dealing with changes in the development of resources. As noted earlier, the 2026 expectation is that the Champlain Hudson Power Express project will be online. Even after years of development work the right of way is still not fully permitted and there are numerous examples of supply chain issues delaying other projects, so this may not occur. Clearly longer-term planning is subject to massive uncertainty.

National Grid Presentation Brad Franey Vice President Clean Energy Development explained how National Grid is addressing the need for transmission support. As he points out the utilities receive funding for their transmission and distribution (T&D) system investments from rate cases. Those rate cases are, in no small part, influenced by politics. As a result, New York’s utility companies are held hostage and are not going to overtly challenge the political narrative that the Climate Act objectives can be achieved on schedules mandated by the law. The following slide probably went through multiple iterations to achieve a description of plans that checks all the boxes for what the company thinks that the politicians want to hear.

In the remainder of his presentation he described specific projects that the utility is doing in its service territory. If you are interested in that information, check out my post that covers all the slides.

Questions and Answers

The question and answer portion of the webinar was interesting. The first question asked was “Is reliability a prerequisite for everything else or is it co-equal with our policy objectives?” I have heard suggestions from climate activists that policy objectives should be considered more than they are currently but anyone hoping to hear that there have been changes to protections in place to make sure that those policies don’t get ahead of reliability would have been disappointed in the answers. Elizabeth Grisaru from the DPS made it clear that reliability comes first, that there are “off ramps” for the implementation schedule, and that the PSC will not let the zeal for meeting de-carbonization goals get out in front of reliability. Yachi Lin from the NYISO emphasized the point that they are constantly evaluating reliability. The quarterly short term assessment of reliability and the longer term reliability needs assessment both address it. She admitted that we are going to have outages because the network is not built to be 100% risk-free or outage free. The alternative it “gold plating the system” which we cannot afford.

that the NYISO resource adequacy process identifies risk factors and the timelines to develop the responses. Franey explained that the building component is the fastest but still takes years. The process has to determine what is needed and where before the planning permitting, and construction plans can be developed. Only when all that is done can construction begin but there are potential delays due to procurement and supply chain issues that also must be addressed.

Discussion

In my opinion the bigger problem is the scale of the transmission upgrades and additions needed. New York has already committed $6 billion to start “unbottling” renewable resources which is code in New York for Upstate utilities paying for support for New York City access to renewables. New York also has plans for three major bulk transmission projects to get hydroelectric power from Quebec, another to collect the energy from part of Upstate to New York City, and the third to start the process of connecting the expected 9 GW of offshore wind into the grid. Nobody has admitted to the total costs.

Conclusion

New York Assembly Cap and Dividend Bill Naiveté

In order to meet the Climate Leadership & Community Protection Act (Climate Act) the Hochul Administration has proposed the New York Cap-and-Invest (NYCI) program. The regulatory process to set up this market-based emissions trading program is underway. Not content to let the that process play out Assemblyperson Anna Kelles has introduced a bill to “amend the environmental conservation law and the public authorities law, in relation to establishing an economy-wide cap and invest program to support greenhouse gas emissions reductions in the state”. Unfortunately, the basis for this legislation is flawed because its authors do not understand what makes market-based emission reduction programs work.

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. I have worked on every emissions trading program affecting electric generating facilities in New York since 1990 including the Acid Rain Program, Regional Greenhouse Gas Initiative (RGGI), and several Nitrogen Oxide programs since the inception of those programs. I also participated in RGGI Auction 41 and successfully won allowances which I held for several years. I follow and write about the RGGI cap and invest CO2 pollution control program and New York carbon pricing initiatives so my background is particularly suited for evaluating the NYCI proposal and this proposed legislation. The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

Capital Tonight Interview with Kelles

Susan Arbetter interviewed Kelles about her legislation on Capital Tonight. The description of the interview stated:

New York state Assemblymember Anna Kelles has introduced legislation that serves as an alternative to the state’s emerging cap and trade system.

Cap and trade is a program used to help meet climate goals by capping pollution and then authorizing tradable allowances between companies, creating a new market.

New York is currently creating a cap and trade system under its 2019 climate law.

Assemblymember Kelles is carrying legislation that would transform this system into what she’s calling a “cap and invest” system. She joined Capital Tonight’s Susan Arbetter to discuss her bill.

The video for the interview is embedded in the description. Arbetter introduced the interview with a slide “Cap and Trade” that made the following points:

Caps emissions in New York
Emissions credits for sale
Companies can sell emissions credits for profit
Proposal would reinvest revenues of credit sales in climate projects

Arbetter claims that the Kelles legislative proposal would make the market-based system a cap and invest program. There is disconnect here. The NYCI proposal is a cap-and-invest program as I have described previously. The program will cap emissions in New York. The permits to emit a ton of GHG emissions, known as allowances, will be distributed primarily though auctions. The proceeds will be used to invest in projects that reduce GHG emissions and prioritize investments in “frontline disadvantaged communities”. Arbetter’ s statement that companies can sell the allowances for profit is technically true, but the reality is that the affected companies buy what they need for their own compliance and do not purchase allowances at the auctions to play the market for profit. On the other hand, there are no limits to participation in the proposed NYCI design so traders can purchase allowances and try to make profits.

Arbetter asked Kelles what she was not happy with in the proposed NYCI design. The first reason she gave was that “instead of what we agreed to in last year’s budget to create a cap-and-invest program this is instead a cap-and-trade program”. As noted previously, the state plan is a cap-and-invest program. I think her mis-conception is that NYCI allows trading of the allowances, so it is “cap-and-trade”. NYCI also allows entities to bank or carry over unused allowances between compliance periods.

The Kelles legislation includes the following that upends the approach used in all previous market-based emission reduction systems:

§ 75-0123. Use of allowances.

1. Allowances must be submitted to the department for the full amount of greenhouse gas emissions emitted during a given compliance period. If greenhouse gas emissions emitted during a given compliance period exceed allowances submitted for such compliance period, such shortfall shall be penalized pursuant to section 75-0129 of this article.

2. Any allowances not submitted at the end of the compliance period in which they are issued by the authority shall automatically expire one hundred eighty days after the end of such compliance period if not submitted prior to such date of expiration.

3. Allowances shall not be tradable, sellable, exchangeable, or otherwise transferable.

In addition to these limitations in NYCI there is a three-year compliance period and in the Kelles legislation there is a one-year compliance period. These differences destroy the flexibility that has made market-based emissions control program successful. All programs include penalties if an affected source is unable to surrender an allowance for each ton emitted. The limitations that allowances not used expire and that allowances “shall not be tradable, sellable, exchangeable, or otherwise transferable” are incompatible with previous programs and would be unfair to market participants.

The NYCI proposal builds on the experience of RGGI which New York State claims has been successful and has worked for market participants. NYCI offers the allowances in quarterly auctions and compliance is for a three-year period. Participants in the program will develop a bidding strategy to purchase the number of allowances that they expect to use during the compliance period. Experience in the RGGI cap-and-invest program showed that a three-year compliance period enabled affected sources to effectively match their allowance needs with their emissions. Because GHG emissions are closely tied to energy use, emissions vary with weather conditions with more emissions and allowances needed in hot or cold years and less in average conditions. The ability to bank and trade allowances enables entities to correct their projections and account for inter-annual variation.

In the Kelles proposal if each individual source did not match their allowances purchases based on projected operations to their actual emissions, then they would be stuck with excess allowances that they cannot sell or trade and will expire. That is an unfair approach. In the first place, allowances are purchased in lots of 1,000. The odds of any source emissions being in multiples of 1,000 is nearly zero and many sources total emissions are less than 1,000. As it stands now, a company with multiple sources purchases allowances for them all and allocates them to individual accounts for compliance. This practice would be outlawed by the prohibition on trading. Many participants rely on emission marketers who purchase allowances at auction for resale or facilitate trades between those companies that have excess allowances and those that need them. Small companies rely on these marketers for their allowances because they don’t have the expertise to participate in the auctions. The RGGI cap-and-invest approach enables flexibility that makes compliance cost-effective.

Another issue that Kelles said she was not happy with is that NYCI “creates an extensive secondary market”. One example she gave was that the limit on the number of allowances purchased is 25% so you “could have a situation potentially where only four entities own all the allowances” and they could exert market control and sell them for profit. This has been an on-going concern with RGGI, but they included a market monitoring component expressly to address the concern. RGGI started in 2009 and the problem has not come up. NYCI proposes to use the same mechanism.

Kelles also said that her legislation would shift the emphasis to investments rather than profits which she wants to see. When you look at a market-based emissions system from the outside, the activist community that is providing information to Kelles only see dollar signs and believe that somehow industry is profiting from the program at the expense of consumers. I also think that academics have contributed to this perception because they believe that the allowances are treated as marketable commodities by the compliance entities. In reality, entities affected by these emissions trading programs prioritize compliance above all and rarely treat the allowances as a source of profit. It is simply wrong to think of these programs as evil because there are some profits involved. Those profits incentivize the flexibility that in the big picture reduces overall costs.

The activists who are influencing Kelles rank protections to disadvantaged communities very high. There are very few examples where emissions market programs have adversely affected those communities and most studies disagree. The bigger problem with this concern is that market-based emissions programs are not designed to address local issues. Kelles said that emitters are predominantly in disadvantaged communities, and it is “necessary to reduce the GHG emissions that are negatively impacting those communities”. Greenhouse gases do not have direct health-based air quality impacts so activists use co-pollutants for the adverse impacts claims. That ignores the fact that there are programs in place designed to address co-pollutants emitted by sources in disadvantaged communities. Clearly the reason we are reducing GHG emissions is to influence global climate change so claiming negative local impacts is a stretch. Moreover, it is necessary to put what we can do to affect climate change impacts in context. 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 so eliminating New York emissions Anything we do will be completely replace by emissions elsewhere in less than a year.

Kelles also stated that she was not happy that NYCI is considering not obligating the electricity sector to participate in NYCI. She suggested that because there are power plants in disadvantaged communities that not including them eliminates the ability to protect residents there. I believe that the decision to exclude the electricity sector at the start is a practicality issue. They already are covered in RGGI and the agencies do not have sufficient resources to include them and everything else at the same time. My impression was that the electricity sector will be added later. With respect to her concern about the power plants in disadvantaged communities that whole issue is a contrived artifact of environmental justice activists. The presumption of egregious harm from power plants in disadvantaged communities is based on selective choice of metrics, poor understanding of air quality health impacts, and ignorance of air quality trends.

There also was a discussion of the emissions intensive and trade exposed industries provisions. These are industries that will be put to disadvantage when they try to compete against companies outside New York that do not have the NYCI costs. Kelles claims that her plan is to encourage them to transition to renewable energy infrastructure without acknowledging the competitive implications of that transition. I frankly have not followed the particulars of this aspect because I think it is hopeless. There will be inevitable increased costs and, at some point, industries will not be able to compete. The Business Council of New York memo in opposition to the legislation addresses these concerns.

Discussion

I am going to limit this article to the issues raised in the Arbetter interview. There are some other examples where the poor understanding of components of these programs that led to the success of previous programs will be hampered or destroyed by this legislation. The examples included are sufficient to show the legislation is flawed because its authors do not understand what makes market-based emission reduction programs work.

First, and foremost, market-based emission reduction programs are trading programs. The ability to buy, sell, or trade allowances and bank them for later use enables the flexibility that makes these programs a cost-effective solution. Eliminate them and there is no assurance that they will work like previous programs.

NYCI is called a cap-and-dividend program because the primary way that allowances will be distributed is through an auction. The proceeds from the auction are the dividends that will be invested to reduce emissions and minimize impacts to disadvantaged communities of the inarguably regressive energy costs necessary to implement the zero-emissions by 2040 Climate Act mandate.

In my opinion, the guardrails around the allowance costs are so inflexible that NYCI is basically a carbon tax. The Kelles legislation would remove any pretense that the program is anything but a tax. There are some advantages to that and some disadvantages too but I think that if there is any legislation is passed it should be to set a carbon tax because that is the responsibility of the legislature.

There is no question that disadvantaged communities have had disproportionate historical impacts. However, cap-and-invest programs are not the appropriate tool to protect them and reduce their environmental impacts because cap-and-invest programs are designed for regional and global pollutant reductions. There are regulations in place that address local impacts and the Department of Environmental Conservation is implementing additional regulations to strengthen and enhance those safeguards. The demands of environmental justice activists that have influenced this legislation unfortunately demand zero impacts without any consideration of pragmatic tradeoffs. For example, the focus on peaking power plants ignores the vital role those facilities play to keep the lights on despite results that show that the alleged impacts are over-stated.

Conclusion

The fundamental flaw in the Climate Act is the presumption by its authors that getting to net-zero emissions was only a matter of political will. There never has been an open and transparent feasibility analysis to clearly account for the necessary costs and threats to system reliability but all indications are that this cannot work as outlined in the Scoping Plan.

On the other hand, the NYCI proposal builds on the existing RGGI model. That program has shown how a cap-and-invest program can ensure compliance and raise money for investments fairly. The Kelles legislation ignores the factors that made RGGI work and eliminates them. That will ensure that the program does not provide any pretense of cost-effective reductions.

The presumption of the Hochul Administration and the Kelles legislation is that a cap-and-dividend program will work as well as previous programs. I think the real debate should be whether that is a justified position because I think the differences between the ambition of this program and previous programs is far greater. When the results of previous programs are considered the odds that NYCI will work as hoped are not very good.

Roger Pilke, Jr – Bullish on Solar

I have great admiration for Roger Pielke, Jr and his work on addressing climate change. However, his recent post explaining why he is bullish on solar does not stand up to his usual standards. This post explains why I disagree with his optimism for solar in the context of New York’s net-zero transition.

I have followed the Climate Leadership & Community Protection Act (CLCPA) since it was first proposed, submitted comments on the CLCPA implementation plan, and have written over 400 articles about New York’s net-zero transition. I am convinced that the CLCPA will adversely affect affordability, reliability, and that the environmental impacts of the proposed transition are greater than the possible impacts of climate change. The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The CLCPA 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 CLCPAion Council (CAC) was responsible for preparing the Scoping Plan that outlines 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. In 2023 the Scoping Plan recommendations were supposed to be implemented through regulation, PSC orders, and legislation.

I have documented issues with New York’s solar energy rollout and its issues. The Scoping Plan uses unrealistic estimates of the energy that can be produced by solar in New York so the estimate that New York will need 18.9 GW in 2030 and 43.4 GW in 2040 of solar capacity are too low. There is no policy in place to protect prime farmland from utility-scale solar development and over 8,000 acres of prime farmland have been lost. The last cumulative environmental impact assessment did not address the total solar capacity that is now expected.

Bullish on Solar

Pielke’s blog post gave three reasons why he is “very bullish on solar energy technologies — solar is scalable, solar is cheap and getting cheaper, and solar is safe, simple, and popular.” I am not bullish on solar for reasons that Pielke mentioned but did not follow through on. Importantly my primary concern is New York’s Climate Act net-zero transition and some of his caveats are inapplicable to New York. Pielke does not quality his bullishness relative to any geographical limitations.

First, I want to explain my overarching concern. My Climate Act issues are related reliability when the system depends on weather-related wind and solar for most of the electric power generation as outlined in the Scoping Plan. Electric system resource adequacy planning must address the worst-case conditions and this challenge is made more difficult when intermittent wind and solar resources are used. While Pielke recognizes the challenge of extended periods of low solar availability, I do not think Pielke’s enthusiasm for solar considers this challenge enough.

Scalable Solar

Pielke argues that solar can be installed incrementally from rooftops to massive utility-scale arrays. He points out that “in the U.S., the Energy Information Agency (EIA) reports that about one third of solar generation comes from small-scale solar (defined as less than 1 MW capacity)”. This gives unquestioned flexibility for the development of resource capacity but that comes at a system reliability cost.

The New York Independent System Operator (NYISO) is responsible for matching generation with load. Small-scale solar is “behind the meter” and cannot be controlled by the electric system operator. Instead, they analyze its capacity to reduce the load from those locations that have solar installations. The problem is that this capability fluctuates and cannot be always relied on. For example, roof top arrays can be affected by accumulated snow and the NYISO has no idea how much that will affect load in the winter.

The other scalability issue is that solar resource value is geographically limited. What works in low-latitudes and “sunshine” states will not work as well in New York’s high latitudes and cloudy regions downwind of the Great Lakes. In the worst case a solar array above the Arctic Circle may work well in the summer but is useless in the winter. New York is not as bad but, in the winter, the solar resource is much reduced and the NYISO does not count on any solar for the diurnal peak.

Solar Affordability

I am a big fan of Pielke’s work and have included his Iron Law of Climate Policy as one of my pragmatic environmentalist principles. He argues that it is appropriate relative to solar energy:

The Iron Law of climate policy means that it is difficult to motivate an energy transition by intentionally making types of energy appreciably more expensive. But is also means that when clean energy becomes cheaper, it readily gobbles up market share, eventually displacing dirtier and more expensive energy.

He includes a graph of the cost of solar modules with time that shows the module costs have declined 99.6% since 1976. Not mentioned is that solar modules lose efficiency over time and that their expected lifetimes are half those of conventional fossil plants. Pielke argues:

The low costs of solar energy, which are positioned to drop even further, has led some in the U.S. to question — quite fairly — why federal subsidies for wind energy are necessary today and far into the future. With or without U.S. subsidies, solar costs should be expected to continue to drop, motivating further deployment, which will lead to greater reductions in costs — a virtuous cycle.

I am worried about how solar energy can be used for the New York Climate Act net-zero transition, specifically the intermittency. Pielke acknowledges the issue:

Even if solar were free, the technology will always have an intermittency problem when the sun doesn’t shine. The New York Times explained last week that massive battery storage can smooth over demand, but it cannot address intermittency with today’s technologies:

Today’s lithium-ion batteries typically only deliver power for two to four hours before needing to recharge. If costs keep falling, battery companies might be able to extend that to eight or ten hours (it’s a matter of adding more battery packs) but it may not be economical to go far beyond that, said Nate Blair, an energy storage expert at the National Renewable Energy Laboratory.

That means additional long-duration storage technologies could be needed. If California wants to rely largely on renewable energy, it will have to handle weeklong periods where there’s no wind and little sun. Another challenge: There’s far more solar power available in summer than in winter, and no battery today can store electricity for months to manage those seasonal disparities.

I have three problems with claiming that solar is cheap and getting cheaper while ignoring the storage costs. Storage for solar is needed on different scales. As noted, there is a difference between summer and winter but there is even a daily difference. The expected annual output of solar is on the order of 25% of the total which means that a system to provide 100 MW of constant energy would need to overbuild solar to 400MW of capacity and roughly 300 MW of storage. That is the average annual need and when the worst-case long duration solar drought is considered energy storage becomes impracticable so a new dispatchable emissions-free resource is needed. In the real world, it is even more complicated, and every complication adds more capacity requirements. All these considerations add to the costs and are not considered by Pielke.

My second problem is that as Pielke notes today’s technology cannot address intermittency. His solution is pragmatic but not applicable to the Climate Act transition to zero-emissions electricity:

As solar gets cheaper, it will see continued expansion, but accompanying that expansion will be the associated costs of reliable back-up generation, which today means natural gas. Even though natural gas is a fossil fuel, the expanded use of solar backed up by gas has considerable potential to reduce emissions, especially in places where that combo displaces coal generation. The low costs of solar mean that we should expect to see more such displacement.

The third problem is that solar and energy storage are inverter-based resources. It turns out that solar, energy storage, and wind do not provide ancillary services needed to maintain the electric grid. If you have no idea what I am talking about I recommend the Practical Engineering You Tube channel video Connecting Solar to the Grid is Harder than You Think

New York’s aspirational goal is to eliminate fossil-fueled generation so natural gas backup is off the table. Even if natural gas backup were a potential solution, cost projections should consider all the costs of solar plus energy storage versus just using natural gas and nuclear. At some point a solar plus natural gas backup system will need new fossil generating units. That approach would necessitate over-built solar, energy storage, ancillary support services, and backup natural gas resources. If you just used natural gas you eliminate all those other components. However, using natural gas for baseload electricity is a waste of this valuable resource. Nuclear is a great zero-emissions baseload resource but has some deficiencies that are best resolved using natural gas units. In my opinion, a full life cycle analysis that incorporates the life expectancies of the resources would show that renewables would be the more expensive option and also require development of new resources.

Solar is Safe, Simple, and Popular.

Pielke’s argument for safety relies on a review by Our World in Data that finds that the safest source of energy production, as measured by deaths per terawatt-hour of production is solar. His arguments for simple and popular follow:

Searching Google Scholar, I have not been able to find a single paper addressing fears of solar energy. There are of course concerns about solar supply chains, solar waste, and risks to solar installations but these issues are common across all energy technologies.

A 2023 survey by Glocalities of 21,000+ people in 21 countries found solar energy to be the most favored energy technology, and overwhelmingly so, with 68% favoring solar over other technologies, as shown in the figure below.

The strong public support for solar and lack of public fears mean that among energy technologies, solar has strong political tailwinds that are unique in the energy space. Correspondingly, the ongoing expansion of solar generation will face much less opposition than proposed new wind and nuclear. Of course, the fact that effective solar deployment also means more gas back-up may result in greater opposition in the future from those who believe that we can just stop fossil fuel use.

Compared to solar energy technologies, wind technologies appear like a convoluted series of Rube Goldberg devices. To be sure, modern wind turbines are a testament to human ingenuity and technological prowess. But they are also massive installations with many moving parts often exposed to harsh conditions — offshore wind in particular. Solar technologies are elegantly simple in comparison.

I cannot document anything different. Anecdotally however, the “not in my backyard” folks are not enamored when a utility-scale solar development is built nearby. Given the space requirements for solar energy that is no small consideration. I do not disagree that in comparison to wind technologies solar is simpler but the additional technologies necessary to integrate solar to the grid are anything but simple and untested at commercial scale to boot.

Discussion

After years of research and study of the challenges of wind, solar, and energy storage I have evolved away from any support for those technologies in anything but niche applications. Ultimately, relying upon weather-dependent resources necessitates unacceptable risk. The weeklong periods where there’s no wind and little sun mentioned earlier introduces tradeoffs not present in the existing electric system. After decades of experience with the components of the existing electric system the electric planners at the NYISO and other regional operators have a very good understanding of resource availability. The key point is that they do not have to worry about correlated outages across the electric system. In the future, relying on wind and solar means that there will be correlated periods across vast areas when wind and solar resources are low. Furthermore, those periods correspond to the highest load demands at the same time the Climate Act wants to electrify everything possible.

The proposals for electric system resources in New York call for enormous additions of wind, solar, energy storage, and the as yet unidentified dispatchable emissions free resource. Just building it is an enormous challenge. The video Connecting Solar to the Grid is Harder than You Think notes that there are poorly understood aspects of the inverter-based resources on the grid. Despite my admiration for the capabilities of the electric planning community, the fact is that they will be in a steep learning curve and the odds favor learning by experience. That experience means blackouts.

That is not the worst of it. It is well recognized now that the long duration wind and solar droughts is a massive problem. However, what is not clear to many is the scale of the problem. In my opinion, the most dangerous future period will be an immense polar vortex that covers most of the North American Interconnect. In that case there will be no imports from where the wind is blowing, or the sun is shining. The problem is that you cannot build an electric system based on a one in fifty-year return period because the resources can never be paid off. But it will happen and when it does electricity will run out. Inevitably there will be a massive blackout that endangers the health and safety of millions of people.

I believe that the pursuit of zero-emissions electricity is a mirage. To justify this transition imaginary benefits are conjured up but the immense costs of trying to do it will be real. The conjured health benefits will be dwarfed by real deaths when there is no heat, no transportation, and no lights during the coldest period of the year.

Conclusion

Pielke’s optimism for solar neglects key considerations. There are geographical areas and niche applications where it may make sense to rely on solar. New York’s high latitude and cloudiness is one location where it does not. I do not disagree that it is scalable and safe. His arguments for solar cheapness ignore the expensive challenge to integrate solar energy into the electric grid when and where it is needed. Full consideration of the ancillary services requirements suggests that it will not be simple either. When enormous tracts of land are covered up with solar panels I think that its popularity will wane. I am not a New York solar energy optimist.

NY HEAT is not so hot

According to New York climate activist non-governmental organizations New York is “failing to lead on climate.” These organizations are lobbying very hard for the New York Home Energy Affordable Transition Act, or NY HEAT, legislation currently being considered. I recently described Rich Ellenbogen’s response to Sane Energy Voice claims that NY HEAT Act should be enacted. This post documents additional op-eds that argue this legislation not a good idea.

Overview

NY HEAT

According to Environmental Advocates of New York:

The purpose of the bill is to give the Public Service Commission the authority and direction needed to align gas utility regulation and gas system planning with the Climate Leadership and Community Protection Act (CLCPA) mandates. Overall, the bill removes the legal basis and subsidies driving the expansion of gas systems and requires the commission to adopt rules and develop a statewide gas service transition plan that is consistent with decreasing gas reliance and, where appropriate, decommissioning gas systems.

Fossil fuels burned in buildings for heating, hot water, and cooking account for approximately one-third of greenhouse gas emissions in New York State. Additionally, heating and cooking with fossil fuels like natural gas quietly impact our indoor air quality, contributing to cases of asthma and heart disease. The Public Service Law, as is, promotes gas system expansion in its stated obligation to serve customers and its business model. This undermines the important climate justice directives and binding emissions limits in the CLCPA. Instead of letting this incompatibility issue continue, this bill better aligns the rules and business practices of the Commission with reduced gas reliance, transition to more sustainable utilities, and prevents energy bill burden among low-income ratepayers.

The bill makes several amendments to the Public Service Law. One of which includes directing the Commission to integrate “the utility sector achievement of the CLCPA” as a core planning objective to its public service responsibilities. Notably, this bill codifies the state goal that low-to-moderate income customers must be protected from bearing energy burdens greater than 6% of their income, including those burdens imposed by the cost to purchase and operate electric equipment.

The overarching problem with NY HEAT is that it is another piece of energy legislation drafted by climate activist non-governmental organizations and pushed by gullible politicians. The biases of these constituencies and their lack of technical expertise has led to the situation where New York is mandated to meet an aspirational schedule that can only be met by revoking the laws of physics. Energy policy should not be dictated by politicians and NGOs that have no responsibilities for their actions.

Alternate Views from the Real World

This post provides three op-ed pieces that provide other reasons that NY HEAT is inappropriate. On Sunday May 12, the New York Daily News published pieces by NY State Senator George Borrello and one co-authored by Richard Ellenbogen and myself. Last week Dennis Higgins had another opinion piece published by All Otsego.

Senator Borrello’s paywalled opinion was titled: Don’t raise the N.Y. HEAT Act: We have to be honest about energy costs. Borrello represents the 57th state Senate District which includes Cattaraugus, Chautauqua, Genesee and Wyoming counties, as well as a portion of Allegany County. He is also a member of the Senate Energy Committee. He stated:

The failure of climate-related items to pass in the “Big Ugly” of the New York State budget was no accident. Reason prevailed among pragmatic lawmakers, and reality set in that the New York Home Energy Affordable Transition Act (NY HEAT) would have placed New Yorkers at risk and wreaked havoc with reliability and affordability.

However, advocates have regrouped and are waging a media campaign, arguing that NY HEAT is necessary to “save New Yorkers billions every year,” trying to confuse the public and pressure lawmakers into passing this horrendous piece of legislation. We cannot let ideology and a radical climate agenda override facts and real progress.

Unfortunately, false and misleading claims about the cost savings that New York ratepayers would realize under the NY HEAT Act are everywhere. Those perpetrating this narrative conveniently ignore the costs to New Yorkers that will come with a mandated conversion to an all-electric future for the state. These advocates also sell their drastic, one-size-fits-all solution as the only path forward.

The fact is, there is a more balanced approach that addresses pollution and environmental concerns without threatening safety, reliability, and affordability. The balanced approach clearly works: our state is already one of the greenest in the nation, ranking seventh in renewable-sourced electricity generation. Much of the credit goes to hydroelectric power, which supplies 21% of New York’s total in-state power generation.

While the HEAT Act would end the 100-foot rule requiring utilities to connect new customers within 100 feet of an existing gas pipeline, it should be noted that utilities are already taking steps in this direction. They are proposing provisions that would allow them to voluntarily make determinations on new service connections based on relevant factors.

While we all recognize the value in pursuing a cleaner energy future, we must acknowledge that utilities have a legal and moral obligation to replace aging pipe infrastructure to ensure safe, reliable service to all their customers and the communities they serve. Claims by advocates that the maintenance of natural gas infrastructure is a burden on ratepayers that would disappear under the HEAT Act are disingenuous, at best.

The reality is that ratepayers already subsidize the maintenance of all utilities — electric, water, and sewer. Utility maintenance costs will not disappear if the HEAT Act is enacted. Additionally, many of the cost estimates being cited for critical maintenance of gas infrastructure are grossly inflated, which only serves to further mislead the public.

The real factors fueling utility rate increases are largely driven by government. More than 70% of the bill for the average ratepayer is the result of the following: federal and state pipeline safety mandates, property tax increases, expanded energy efficiency programs, supports for low-income customers, state-mandated purchases of costly wind and solar energy, increases in the cost of capital, supply chain shortages and inflation.

The replacement of pipes, while a regulatory mandate, is not a major driver — and those costs are just a fraction of what’s to come once the impacts of renewables and new transmission lines hit customer bills later this decade.

Finally, NY HEAT Act advocates are conspicuously silent about the fact that electrifying homes is many times more expensive than pipe replacement, and residents often bear those costs on their own.

According to a recent analysis, electrifying just one co-op in Brooklyn took four years and cost nearly $1 million. Even with rebates, that comes out to $40,000 per apartment, and residents are now responsible for the full cost of heating their homes, rather than sharing costs with the entire building. The cost to operate those electrical systems to heat homes will cost more on a monthly basis than to heat that same home on natural gas.

The reality is that the most fervent advocates of New York’s aggressive climate agenda believe that no cost is too great to address the climate crisis. That is why they misrepresent the facts and mislead New Yorkers into believing a transition to all-electric will save them money. The truth is that New Yorkers are in for a far costlier and less reliable energy future if proposals like the HEAT Act are adopted.

Rich Ellenbogen and I had an op-ed published next to the Senator’s. The title of our paywalled piece was “Don’t raise the N.Y. HEAT Act: It threatens the safety of all New Yorkers”. We wrote:

The New York Home Energy Affordable Transition Act, or NY HEAT, is before the Legislature now. However, until questions regarding its feasibility, affordability, and reliability are answered, the HEAT Act should be allowed to lay dormant.

The Climate Leadership & Community Protection Act (NYS’s climate law) mandates that the electric grid be 100% zero emissions by 2040, and the law’s scoping plan projects that by 2040 more than 60% of the capacity and more than 69% of the energy will come from wind and solar.

This total transformation of New York’s energy production and use is being undertaken in spite of the fact that no jurisdiction anywhere in the world has yet succeeded in raising the percentage of the supply of electricity to its grid from wind and solar — beyond about 50% of total supply — on a consistent basis.

The reason for these limits is because both wind and solar are intermittent and therefore unreliable. As a result of these realities, the state Public Service Commission is considering what new technologies must be developed to address those coldest and hottest periods where there will be insufficient generation from existing wind, solar, and energy storage technologies.

Unfortunately, there is no commercially available technology that can be deployed in sufficient quantities today for this reliability requirement. As a consequence of these facts on the ground (and in the air), it is prudent for New York’s decisionmakers to determine the technological feasibility of the zero emissions transition before passing NY HEAT.

The Empire Center’s recent Green Guardrails describes why the Climate Law implementation plan is flawed. It notes that “The process that has played out in the five years since the law’s passage has been marred by a lack of transparency, with state officials failing to issue legally required cost estimates and crucial studies designed to guide state energy policy.” Before the state passes NY HEAT, a full, transparent accounting of all the costs, benefits, and emission reductions for the proposed control strategies is necessary.

It is premature — and unquestionably dangerous — to mandate the additional electrification requirements of NY HEAT. The mandate to deploy massive amounts of wind, solar, and energy storage resources, and simultaneously upgrade and expand the distribution and transmission systems, means that an enormous quantity of transformers, wires, and generating equipment will be required.

There already is a shortage of transformers which will inevitably get worse and spread to other infrastructure components. Even if the hardware is available, there is insufficient labor to execute the plan. There is also a shortage of both electricians and plumbers, and there are not enough people to train even if they could develop the training programs. Without these new resources, current reliability standards of the electric grid cannot be maintained.

NY HEAT removes the “obligation to serve,” a regulation that requires utilities to offer natural gas to any customer who requests it; and the bill also enables the network to be decommissioned in favor of neighborhood-scale electrification. In addition, it will codify a goal of protecting residential customers from paying more than 6% of their household income for energy bills.

When NY HEAT eliminates the obligation to serve, and enables the decommissioning of existing gas systems, it eliminates consumer choice and does not acknowledge — as the state’s scoping plan to implement the Climate Law does — that not all homes will be able to electrify home heating safely and affordably.

A political mandate to decommission a gas network is a drastic step that should only be undertaken until the full ramifications of New York’s total energy transformation is understood. Otherwise, we risk jeopardizing the safety of all New Yorkers.

Lastly, the HEAT bill’s proposal to limit energy bills to no more than 6% of a household’s income is an inadequate energy poverty safeguard. It does not cover household costs: to replace existing home heating equipment with the preferred heat pump alternatives; to upgrade building shells to eliminate or minimize the time that backup heating systems will be needed; to pay for backup heating systems if needed; or to pay for the upgrades to the electric service for the household to cover the increased electric load when the entire household is electrified.

The shortcomings of the HEAT bill are to some extent a product of its authors’ faulty assumptions, but they are exacerbated by the even more unrealistic and unachievable goals built into the larger Climate Law. Until these issues are properly addressed, we should set aside the HEAT bill because it will simply make a bad situation worse.

The Dennis Higgins article in the All Otsego Partial Observer was titled HEAT Act Nothing But a Hot Mess. He wrote:

The proposed NY HEAT Act, which would mandate a rapid transition to air-source heat pumps, is yet another toxic plan, currently shunted to the back burner in Albany. Although it did not make it into the budget, with pressure from advocates it could be passed this session. NY HEAT, like its Climate Leadership and Community Protection Act launch pad, runs counter to sound engineering and responsible fiscal policy. What’s wrong with it? Let me count the ways.

A five-ton ASHP unit may cost $9,000.00. Installation in the New York City area would cost as much as the pump, assuming existing panel boxes could support the load. There is currently a shortage of plumbers and electricians to do that work. New panel boxes, wiring, and post-installation repair, combined with labor shortages, would serve to increase costs and undermine any timetable. Further, an ASHP may require 5,000 kilowatt-hours a year. Electric bills are already climbing, as rate-payers finance new transmission lines and utilities deal with gas shortages. For homes and apartments with new pumps, electric bills could double.

The independent system (grid) operator, the NYISO, is projecting a 450-megawatt capacity shortfall in the metro region as early as summer 2025, assuming normal weather conditions and without factoring in NY HEAT’s additional load. With building and vehicle electrification, the NYISO already expects demand to double in the next 25 years. But NY HEAT implementation would require a capacity-constrained grid to deliver lots more electricity in the very near term.

Increased electricity demand would in turn increase the load on every transformer in the state. Transformers would have to be replaced, but—as has been reported on National Public Radio and elsewhere—replacements do not exist. The increases to load would also require replacing transmission lines. This could take decades and would require lots of aluminum. Currently, there isn’t enough aluminum for beverage cans, let alone thousands of miles of wire.

Even ignoring the sluggish pace of buildout and lack of battery support, solar and onshore wind are intermittent and have low-energy density, rendering them unsuitable to support additional demand. Offshore wind will not help. Many of New York’s offshore wind projects were cancelled. Driving bid prices and cancellations, supply-chain and construction hurdles mean significant offshore installation may not happen this decade. The Jones Act prohibits foreign jack ships from installing turbines in U.S. waters. The U.S.’s first Jones-Act-compliant ship, Dominion’s Charybdis, may not be ready until early 2025 and is already booked for Virginia’s 2.6 gigawatt project.

Ultimately, increases in demand from ASHPs—a Micron factory, bitcoin mining, or AI hubs—will rely on our fleet of fossil-fuel power plants. The metro region is currently at capacity, so peaker plants will continue to be needed. Even before the NY HEAT proposal, NYISO indicated that deadlines for closing peakers will need to be extended. Gas supply constraints downstate mean Cricket Valley—a combined-cycle plant in Dover—can’t currently run at full capacity. Compression expansion projects on the Iroquois and Algonquin pipelines may be needed to fuel peakers and big plants at Ravenswood and Cricket Valley, as well as for private homes.

If California is a model for New York, it is also an admonition. California is 20 years ahead of us in solar and wind installations and has about 40 percent intermittent capacity. California can boast a solar capacity factor twice what New York gets and has deserts in which to put the panels. Nevertheless, it has extended deadlines for closing gas plants and, with an EPA waiver, has also built new ones. Even with the largest lithium-ion battery in the world, California can’t store summer solar and had to dump about three terawatt-hours of energy last year. Can New York do better? The state Energy Research and Development Authority’s storage projections would cost hundreds of billions of dollars for batteries that might last 10 years. And if all that storage were fully charged, we could not keep the lights on in New York City—let alone the rest of the state—for one day.

New York currently has only about eight percent renewable capacity. To meet a 70 percent-by-2030 renewable target, industrial solar and wind installed over the last 30 years would have to be multiplied six-fold in four years. There is no reason, beyond press releases, to believe this can happen. Rural opposition to solar and wind buildout has also grown. 2020 Executive Law 94-C established the Office of Renewable Energy Siting to speed up installation. ORES can ignore local legislation and even reasonable environmental safeguards in project permitting. Last year’s budget requires communities to use an assessment formula supplied by Albany, cutting tax revenue by up to 80 percent. As reported (4/30/2024 Times Union), a dozen towns in Schoharie are suing the state over the current assessment model. Combined with eminent domain authority for developers to run wire and poles—in this year’s budget—we can expect significantly more pushback from communities. Environmentalists concerned with preservation of farmland and forest, increasing eagle-and-bat deaths, as well as water supply threats from large wind installations, are also raising their voices.

Who will pay for NY HEAT? The cost of a $672-million bailout for a few of the hundreds of thousands of utility customers currently in arrears will be borne by other utility customers. Every New Yorker will help fund subsidies for industrial solar and wind projects which could gobble up a million acres and yet fail to provide reliable electricity.

It continues to be a mistake to let political appointees and Big Green organizers craft energy policy. CLCPA and NY HEAT do not meet the fiscal or engineering standards needed to shape a reliable, carbon-free grid.

Conclusion

This legislation was passed by both the Assembly and the Senate – remember that next November. It currently awaits a decision by Governor Hochul. I urge readers to call 518/ 474-8390 or email the Governor’s office urging her not to sign this legislation.

Articles of Note May 12, 2024

I have been so busy lately with net-zero transition implementation issues that I have not had time to put together an article about every relevant topic I have discovered. This is a summary of articles that I think would be of interest to my readers.

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.

Videos

The Heart of Climate Deception Temperature. Good summary of the issues related to global temperature measurements
Roger Pielke, Jr. on the best kept secret of climate science
Mapping Offshore Wind Projects And Critically Endangered Whales Robert Bryce produced a four-minute video that clearly shows:

The Biden administration has approved a slew of projects that could result in hundreds of offshore wind turbines being placed right in the middle of the North Atlantic Right Whale’s habitat. As you likely know, the North Atlantic Right Whale (Eubalaena glacialis) is one of the world’s most endangered whales. Only about 360 individuals are left. So why are so few climate NGOs speaking out against the industrialization of our oceans and the danger that offshore wind poses to the whale?

The Climate Industry’s Misdirection Campaign

Jessica Weinkle has written a highly recommended description how institutions are being delegitimized in the name of climate catastrophism. She concludes:

Dark money may or may not be a problem the public wants to address.

Concerning however is the extent to which the sprawling empire of the multifaceted climate industry has managed to discredit critique of its methods.

Those who do are dubbed obstructionists, and in no insignificant part by the billionaires moving money around in opaque ways.

Policymakers unwilling to acknowledge this dynamic are also turning their back on genuine problems in scientific integrity, misleading policy, courts, public health research, and threatening food security and development. The public is left with a sea of technocratic propaganda and limited ways to engage because the expertise barrier is too high.

Robbins claimed that “it is not what you look at that matters… It’s what you see.” All around us we look at the massive influence of the climate industry on climate change science and public messaging. But what most see are flashy graphs, dire futures, and get rich quick investment opportunities.

All the while, the legitimacy of our democratic and scientific institutions are being snatched before our very eyes.

Climate Change Reality

The CO2 Coalition published a paper prepared by Richard Lindzen, William Happer, Steven Koonin on April 16, 2024 titled Fossil Fuels and Greenhouse Gases Climate Science that is an excellent summary of reasons why there is no climate crisis. Three sections are included: There will be disastrous consequences for the poor, people worldwide, future generations and the west if fossil fuels, co2 and other ghg emissions are reduced to “net zero”; The IPCC is government controlled and thus only issues government opinions, not science; and Science demonstrates fossil fuels, CO2 and other GHGs will not cause catastrophic global warming and extreme weather. John Robson at Climate Discussion Nexus also praises the paper: “The paper does not break new ground, but summarizes the grounds for skepticism about the real impact of climate policy, the credibility of the IPCC, the reliability of climate computer models and claims that CO2 has made the weather worse and will only continue to do so”.

Judith Curry gave a great presentation Climate Uncertainty and Risk to the Global Warming Policy Foundation. Video of the presentation [here]. Powerpoint slides can be downloaded here [ GWPF uncert & risk (2)]. She makes the point that the political strategy by the UN and New York’s Climate Act is “deeply polarizing, whereas the strategy on the right seeks to secure the common interest of communities.” She concludes that:

Once you separate energy policy from climate policy, the way forward for energy policy is fairly straightforward. A more pragmatic approach to dealing with climate change drops the timelines and emissions targets, in favor of accelerating energy innovation. The goal is abundant, secure, reliable, cheap & clean energy.

The problem with climate policy is that it is a “wicked problem” that necessitates an approach that recognizes the deep uncertainties we have associated with climate understanding. Of course those concerns are routinely ignored by the advocates for the Climate Act.

Social Cost of Carbon

The Social Cost of Carbon (SCC) is a contrived parameter used to justify policies that are designed to eliminate fossil fuels. It is a difficult parameter to describe and show how it is used. Jonathan Lesser from the National Center for Energy Analytics wrote an excellent article that describes it well.

Electric Vehicles

Ford lost a lot of money on each electric vehicle it sold in the first quarter of 2024. CNN claimed that Ford sold 10,000 electric vehicles for a loss of $132,000 per vehicle but Robert Bryce said Ford sold 20,233 electric vehicles for a loss of “only” $65,272 per vehicle. Words fail to describe this madness.

Chinese EV manufacturers are poised to flood the American car market with cheap, high-quality SUVs by exploiting loopholes in tariff laws utilizing plants built in Mexico as the jumping-off point. This will happen even sooner. Chinese-owned carmaker Volvo (a subsidiary of China’s Geely) is about to beat the competition as soon as this summer with the introduction of a small battery electric SUV, the EX30, in the US.

The EX30 will directly compete with the Tesla Model Y in terms of performance and features, but at a price tag of $35,000, $8,000 less than the Model Y’s current cost. Reuters writes that, “[t]he competitive price reflects an unusual combination of Geely’s China-specific cost advantages and Volvo’s ability to skirt US tariffs on Chinese cars because it also has US manufacturing operations.” Even better, Volvo says that, even at that market-undercutting price, it expects to realize a 15-20 per cent profit margin on the EX30, meaning it has room to cut the price further should Tesla or other companies find ways to meet its initial price tag.

Used EV timebomb – Many EVs could become almost impossible to resell because of their limited battery life.

Experts said that the average EV battery guarantee lasts just eight years. After this time, the battery may lose power more quickly and so reduce mileage between charges. Many EVs will lose up to 12 per cent of their charge capacity by six years. Some may lose even more.

The cost of a replacement battery can be more than the value of the car. As a result used EVs have little value which increases the total lifetime cost of an EV compared to a internal combustion engine.

Irina Slav describes the possible last straw for EV that i wrote up for Watts Up With That. She notes that governments need to start thinking about a tax to replace their lost income from fuel duty collection when EVs predominate. There is no option that will not either add to the purchase price or be regressive. Her conclusion sums it all up:

For the umpteenth time, then, we have our dear Western governments try to have their transition cake and eat it, too, and not gain a single ounce of extra weight. They wanted combustion engine cars out but forgot that these cars bring in billions in tax income. They wanted a fully electrified transport but forgot it wouldn’t bring in money unless they made it more expensive. They wanted a revolution but forgot rule #1 for revolutions: the successful ones never start from the top. They start from the bottom.

Separating NRDC “Facts” From Fiction Reality Check

The lead to the Natural Resources Defense Council (NRDC) blog post Separating Fact from Fiction: Setting the Record Straight on New York’s Climate Law states “Don’t be fooled by the fossil-fueled campaigns to delay climate progress. The Climate Leadership and Community Protection Act is New York State’s chance for a cleaner, healthier future.” It goes on to refute four claims allegedly pushed by fossil fuel industry. I am only going to respond to one of the responses.

Overview

The NRDC blog post describes the Scoping Plan framework as “pathways for a planned and orderly transition to a clean, resilient energy future.” The Scoping Plan is just a list of potential control strategies that when combined are supposed to meet the CLCPA mandates. A feasibility analysis has never been completed to show that the list of strategies is practical. Furthermore, transparent accounting for the costs of the transition have not been provided and the Cumulative Environmental Impact Assessment has not been updated to account for the Scoping Plan estimates of the wind, solar, and energy storage resources needed.

NRDC Setting the Record Straight

The blog post Separating Fact from Fiction: Setting the Record Straight on New York’s Climate Law includes responses to four claims:

The CLCPA will result in higher energy costs for ratepayers because it is costly to implement.

The CLCPA will reduce the reliability of energy delivered to homes and businesses.

Your gas stove is going to be taken away from you.

There will be an adverse impact on the state’s overall economic climate that will discourage new investments and job growth.

I am only going to address the response to the second claim that the CLCPA will “reduce reliability of energy delivered to homes and businesses”. The response to that claim states:

The framework outlined by the CLCPA-mandated Scoping Plan provides pathways for a planned and orderly transition to a clean, resilient energy future. The idea of a regenerative rather than an extractive economy strikes fear in the fossil fuel industry, which has been making record profits from recent price fluctuations and market volatility; in reality, reliability failures are often due to fossil-fueled superstorms and the historical lack of investment in our nation’s aging infrastructure. By contrast, homegrown renewable energy can and will be more resilient, more plentiful, and more cost-effective than finite oil and gas resources.

I will address each of these statements. The first sentence states “The framework outlined by the CLCPA-mandated Scoping Plan provides pathways for a planned and orderly transition to a clean, resilient energy future.” As noted previously there has never been a feasibility analysis to determine if the components of the Scoping Plan are practical. The Climate Action Council never resolved the discrepancy between the Council faction that believed that no new technology is needed for the transition and the experts responsible for the system that argued otherwise. A recent technical conference showed that the work of Prof. C. Lindsay Anderson, Chair of Department of Biological and Environmental Engineering Cornell; Zach Smith, VP System Resource Planning, New York Independent System Operator; and Kevin Steinberger, Director, Energy and Environmental Economics all found that a new resource that can be dispatched when needed, is firmly available, and has no emissions is needed. Technologies to meet this requirement are not commercially available at this time. Moreover, no jurisdiction anywhere has been able to convert their electric system to one that relies on wind, solar, and energy storage. Given the myriad technical issues that must be overcome to provide electricity when it is needed most, I think the most prudent course of action would be a demonstration project because the transition to the energy system mandated by the CLCPA would be unprecedented.

The second sentence unnecessarily questions the motivations of those who worry about reliability “The idea of a regenerative rather than an extractive economy strikes fear in the fossil fuel industry, which has been making record profits from recent price fluctuations and market volatility; in reality, reliability failures are often due to fossil-fueled superstorms and the historical lack of investment in our nation’s aging infrastructure.” The concern about profiting from price fluctuations and market volatility is naïve. When the electricity market is dominated by weather dependent generating resources the variability of wind and solar output will increase price fluctuations. The New York Independent System Operator will have to modify the electric market to address this volatility as they learn how this new aspect of the system affects prices. I have been involved with the weather-related impacts on the electric system for over 40 years and it has always been true that extreme weather has the greatest impact on system outages. A common theme throughout this blog post is that all weather events are necessarily related to climate change without acknowledging that extreme weather events exactly like those before the climate change would still have major impacts. Any increase in severity due to climate change is just a tweak and not the primary driver.

The final sentence got my attention: “By contrast, homegrown renewable energy can and will be more resilient, more plentiful, and more cost-effective than finite oil and gas resources.” I wondered how the author managed to claim that extreme weather will have more of an effect on today’s generators in weather proof buildings than the exposed wind turbines and solar panels. The more resilient reference was to the Babcock Ranch a Florida “solar town” that fared well during recent hurricanes. The article claims the town came out of Hurricane Ian “almost unscathed and notes that one resident says they survived ‘by design.’ Florida Power and Light is proud of the Babcock Ranch solar system:

Babcock Ranch’s clean energy efforts were taken to the next level when FPL created the largest solar-plus-storage system operating in the U.S. today. Each of the ten large gray steel battery storage units at the FPL Babcock Ranch Solar Energy Center can store 1 megawatt of power and discharge for 4 hours. The adjacent 440 acres with 330,000 solar panels can generate up to 74.5 megawatts of power. Currently the solar installation generates more power than the town needs, so the surplus goes into the electric power grid. The new battery storage system ensures a steady output of power even on partly cloudy days.

There are two resiliency features that matter: Babcock Ranch was built 30 feet above sea level and all power lines are buried underground to keep them safe from strong winds. New York’s net zero transition does not include buried power lines. The Babcock Ranch website refutes the claim that “homegrown renewable energy can and will be more resilient”:

Electric power always flows from the nearest generation, so during the day the town will use energy from the FPL Babcock Ranch Solar Energy Center. When the sun goes down and the solar plant is not generating energy, Babcock Ranch will pull electricity off the grid from the closest FPL natural-gas power plant.

Babcock Ranch is not clean energy self-sufficient as the Climate Act envisions the entire state will be. The NRDC response also claims that renewable energy is more plentiful and more cost-effective than finite oil and gas resources. It may be true that solar and wind energy is free but harvesting those resources, storing them for when they will be needed during an extended period of light winds in the winter when solar resources are low is an extraordinary challenge that requires the new resource described above. Like all the Green Energy solutions advocated by the NRDC, wind and solar may work well most of the time but when you really need them, they don’t work at all. The concern about finite oil and gas resources ignores the value of their storable concentrated energy and whether running out is a concern in the foreseeable future.

Conclusion

I believe I have shown that the NRDC fact-check claims that the CLCPA energy transition does not threaten reliability are invalid. Ignoring the mounting evidence that this may be an insurmountable challenge is not in the best interest of New Yorkers. At a minimum, CLCPA implementation should be delayed until we are sure that we can afford the CLCPA mandates, prove that the transition will not adversely affect reliability, and understand all the cumulative environmental impacts.

As is typical, whenever someone is screaming about misinformation it usually means that they are guilty of that charge. In addition, trying to respond to this tripe takes an order of magnitude more work to respond. Finally, whenever I make the effort to check the numbers I find the alarmists have their thumbs on the scale and are peddling a narrative to support their livelihoods. I only wish that they could be held accountable when reality slaps their aspirational net-zero transition dreams back to earth.

“Powerless in the storm” Climate Industry Misdirection

A version of this post appeared at Watts Up With That

I came across a paper that concludes “The US power grid is proven to be highly reliable in general; however, the resilient and reliable grid operation is increasingly challenged by severe weather events–events that are increasing in frequency and magnitude due to climate change.” I have many issues with this paper, but I am only going to discuss one. Apparently peer reviewed papers today require marginal support for claiming increasing severity because everyone knows that climate change affects the frequency and magnitude of severe weather events

This analysis is typical of the reports used to justify the Climate Leadership & Community Protection Act (Climate Act). 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. This post explains why the connection between this work and climate change is tenuous. The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Powerless in the Storm

The paper in question is “Powerless in the storm: Severe weather driven power outages in New York State, 2017–2020” (Flores NM, Northrop AJ, Do V, Gordon M, Jiang Y, Rudolph KE, et al. (2024) Powerless in the storm: Severe weather-driven power outages in New York State, 2017–2020. PLOS Clim 3(5): e0000364. https://doi.org/10.1371/journal.pclm.0000364)

The only proof cited to “support climate change is increasing weather variability” is the reference to this sentence: “The power grid’s vulnerability to severe weather events becomes even more critical in the context of climate change, which is expected to increase weather variability and prevalence of extreme events (e.g., storms, wildfires, heatwaves, floods)”. The reference included cites the latest Intergovernmental Panel on Climate Change report: IPCC, 2022: Climate Change 2022: Impacts, Adaptation, and Vulnerability. Contribution of Working Group II to the Sixth Assessment Report of the Intergovernmental Panel on Climate Change [Portner H.-O., Roberts D.C., Tignor M., Poloczanska E.S., Mintenbeck K., Alegrı´a A., Craig M., Langsdorf S., Lo¨schke S., Mo¨ ller V., Okem A., Rama B. (eds.)]. Cambridge University Press. Cambridge University Press, Cambridge, UK and New York, NY, USA, 3056 pp., https://doi.org/10.1017/9781009325844

The Other Side of the Story

However, if the authors were to look at the actual IPCC report rather than what they assumed it would say about the example weather events (storms, wildfires, heatwaves, floods) the narrative falls apart.

The CO2 Coalition published a paper prepared by Richard Lindzen, William Happer, Steven Koonin on April 16, 2024 titled Fossil Fuels and Greenhouse Gases Climate Science. Richard Lindzen, Professor of Earth, Atmospheric, and Planetary Sciences, Emeritus Massachusetts Institute of Technology; William Happer Professor of Physics, Emeritus Princeton University; and Steven Koonin University Professor, New York University, Senior Fellow at the Hoover Institution reviewed what the IPCC documents actually said about these extreme weather events. The paper explains:

Hurricanes. A deep analysis of the facts reveals that “the data and research literature are starkly at odds with this message” — “hurricanes and tornadoes show no changes attributable to human influences.” Id. pp. 111-12. Further, “There has been no significant trend in the global number of tropical cyclones nor has any trend been identified in the number of U.S. land-falling hurricanes.” U.S. Global Climate Research Program, 3rd National Climate Assessment, Appendix 3, p. 769 (footnotes omitted).

Wildfires. There is a powerful new source of data on wildfires, “Sophisticated satellite sensors first began monitoring wildfires globally in 1993.” Id. p. 142.

The result of this new source of data is totally contrary to what is in the news. Unsettled cites NASA data and others that show the global area burned by fires declined each year from 1998 to 2015:

“Unexpectedly, this analysis of the images shows that the area burned annually declined by about 25% from 1998 to 2015.” Further, “Despite the very destructive wildfires in 2020, that year was among the least active globally since 2003.” Id. p. 142.

Heat Waves. On extreme temperatures in the U.S., we all agree: “The annual number of high temperature records set shows no significant trend over the past century, nor over the past 40 years.” Koonin, supra, p. 110.

Flooding: US data shows “modest changes in US rainfall during the past century haven’t changed the average incidence of floods.” Globally, data from the IPCC shows that there is “low confidence regarding the sign of trend in the magnitude and/or frequency of floods on a global scale.” We all agree with the summary in Unsettled: “we don’t know whether floods globally are increasing, decreasing, or doing nothing at all.” Id. p. 137.

Discussion

I have nothing to add to the main point that the authors of this paper just assumed that the IPCC found that extreme weather events were increasing despite evidence in the latest report to the contrary. The peer review process did not call them out on this.

For the record the authors, their roles and affiliations follow:

Nina M. Flores

ROLES Conceptualization, Data curation, Formal analysis, Writing – original draft, Writing – review & editing

AFFILIATION Department of Environmental Health Sciences, Mailman School of Public Health, Columbia University, New York, New York, United States of America

Alexander J. Northrop

ROLES Conceptualization, Data curation, Writing – review & editing

AFFILIATIONS Department of Environmental Health Sciences, Mailman School of Public Health, Columbia University, New York, New York, United States of America, Vagelos College of Physicians and Surgeons, Columbia University, New York, New York, United States of America

Vivian Do

ROLES Conceptualization, Writing – review & editing

AFFILIATION Department of Environmental Health Sciences, Mailman School of Public Health, Columbia University, New York, New York, United States of America

Milo Gordon

ROLES Conceptualization, Writing – review & editing

AFFILIATION Department of Environmental Health Sciences, Mailman School of Public Health, Columbia University, New York, New York, United States of America

Yazhou Jiang

ROLES Conceptualization, Writing – review & editing

AFFILIATION Department of Electrical and Computer Engineering, Clarkson University, Potsdam, New York, United States of America

Kara E. Rudolph

ROLES Conceptualization, Methodology, Writing – review & editing

AFFILIATION Department of Epidemiology, Mailman School of Public Health, Columbia University, New York, New York, United States of America

Diana Hernández

ROLES Conceptualization, Writing – review & editing

AFFILIATION Department of Sociomedical Sciences, Mailman School of Public Health, Columbia University, New York, New York, United States of America

Joan A. Casey

ROLES Conceptualization, Funding acquisition, Methodology, Writing – review & editing

AFFILIATIONS Department of Environmental Health Sciences, Mailman School of Public Health, Columbia University, New York, New York, United States of America, Department of Environmental and Occupational Health Sciences, University of Washington, Seattle, Washington, United States of America

One final point is that my impression of the analysis is that the authors had pre-conceived conclusions in mind and tortured the data to get the results desired.

Conclusion

I have to assume that this is an example of the Climate Industry’ Misdirection Campaign described recently by Kip Hansen. All of the authors are associated in some way with public health departments at universities. I doubt that any of them has any background in climatology or meteorology beyond a possibly a class or two in introduction to Climate Change – The Existential Threat. Today it is sufficient to just note that extreme weather is getting worse due to climate change to hype the results claimed because the peer reviewers know that is “true”.

Facebook Post that Gets It

Pragmatic Environmentalist of New York Principle 6 is Roger Pielke Jr’s: Iron Law of Climate: “While people are often willing to pay some price for achieving climate objectives, that willingness has its limits.” A recent Facebook comment to a National Grid Facebook social media campaign post provides a perfect example related to New York’s Climate Leadership & Community Protection Act (Climate Act).

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

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. 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 outlines 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. In 2023 the Scoping Plan recommendations were supposed to be implemented through regulation, PSC orders, and legislation. Not surprisingly, the aspirational schedule of the Climate Act has proven to be more difficult to implement than planned and many aspects of the transition are falling behind. There is growing evidence that the state will be unable to achieve its goals without significantly affecting the cost of living and doing business in New York and harming the reliability of its electric grid.

National Grid

In my opinion no company doing in business can publicly question the Climate Act narrative without facing the wrath of emotion-driven activists and getting crosswise with the Hochul Administration. Although the Public Service Commission utility rate-making process to establish “just and reasonable” rates is supposed to be apolitical, the old days when governors appointed Commissioners from both parties to maintain balance are gone. I have no doubt whatsoever that any utility that does not encourage electrification to save the environment at every opportunity would find itself not getting their rate case proposals approved. Moreover, an electric utility has incentives to sell more electricity. The problem is that electrification everywhere is not a pragmatic solution.

I am in the former Niagara Mohawk Power Corporation service territory now served by National Grid New York. Given the political climate of New York it is no surprise that National Grid advocates for the “Journey to net-zero”. I am not a big social media person but do get on Facebook occasionally. Frequently, there are posts from National Grid advocating for the latest and greatest gadgets for electrification. For example, the following recently showed up.

There were options for different “learn more” links. What caught my eye was the following comment to this post. It the perfect example of Pielke’s Iron Law:

The Iron Law can be described as wallets have limits. Beyond the simple cost impacts there is another concern. The National Grid Upstate New York Residential Gas Heating program is paused and not accepting rebate applications. National Grid is forgoing efficiencies now to encourage adoption of cold-climate heat pumps. This is disservice to National Grid ratepayers because it does not acknowledge thatthe State’s Scoping Plan to implement the Climate Act notes that not all homes will be able to electrify home heating safely and affordably. Exactly the case in this example. It is not only that there is a cost factor but there is a safety factor for electrification. Removing incentives for homeowners that have no other choices is short-sighted.

Conclusion

Implementation of the Climate Act is going to affect affordability and safety. The public is starting to catch on to these impacts. It is time to pause implementation until the Hochul Administration provides comprehensive and transparent cost estimates for the transition and the Public Service Commission provides a plan to ensure safe and reliable service to electric customers for an electric system that relies on wind and solar. The utility industry is not going to step up and ask for an implementation pause so it is up to the voters of the state to make their concerns known.