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.

Ellenbogen on the Comptroller Audit of the Climate Act

On July 16, 2024 the New York State Comptroller Office released an audit of the New York State Energy Research and Development Authority (NYSERDA) and Public Service Commission (PSC) of their implementation efforts for the Climate Leadership and Community Protection Act (Climate Act) titled Climate Act Goals – Planning, Procurements, and Progress Tracking.  The key finding summary states: “While PSC and NYSERDA have taken considerable steps to plan for the transition to renewable energy in accordance with the Climate Act and CES, their plans did not comprise all essential components, including assessing risks to meeting goals and projecting costs.”  As much as I would like to do a post on this, I am stretched too thin.  Fortunately, Richard Ellenbogen sent along his thoughts that I have incorporated into my overview of the background and context of this report.

Ellenbogen is the President [BIO] Allied Converters and frequently copies me on emails that address various issues associated with the Climate Act I have published other articles by Ellenbogen and collaborated on a position paper on New York City’s Local Law 97 with him. There are only a few people in New York that are trying to educate people about the risks of the Climate Act with as much passion as I am, but Richard certainly fits that description.  He comes at the problem as an engineer who truly cares about the environment and how best to improve the environment without unintended consequences.  He has spent an enormous amount of time honing his presentation summarizing the problems he sees but most of all the environmental performance record of his business shows that he is walking the walk.  

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  Since then, State agencies and the legislature have been attempting to implement the plans through regulations, PSC orders, and legislation. 

The New York State Comptroller Office audit of NYSERDA and PSC is available in  Climate Act Goals – Planning, Procurements, and Progress Tracking as a pdf format file.  The Audit Highlights section of the report lists the key findings and key recommendations:

Key Findings

While PSC and NYSERDA have taken considerable steps to plan for the transition to renewable energy in accordance with the Climate Act and CES, their plans did not comprise all essential components, including assessing risks to meeting goals and projecting costs. Specifically:

  • PSC is using outdated data, and, at times, incorrect calculations, for planning purposes and has not started to address all current and emerging issues that could significantly increase electricity demand and lower projected generation, such as increased push to transition to electric vehicles by 2035 and the cancellation or delay in renewable energy projects. Between 2005 and April 2023, 12% of contracted large-scale renewable projects were canceled. 
  • The costs of transitioning to renewable energy are not known, nor have they been reasonably estimated. Moreover, funding sources to cover those costs have not been identified, leaving the ratepayers as the primary source of funding. The lack of alternative funding sources adds additional risk to whether the State can meet its goals timely. Data shows utility costs have already risen sharply over the last two decades and more New Yorkers are having difficulty paying their utility bills. 
  • PSC has taken steps to address some risks and issues; however, it has not yet begun to formally review progress toward Climate Act goals with updated generation and electricity demand forecasts. While PSC noted it has until July 2024 to begin this assessment, waiting until that point to fully review all efforts and costs of the transition to renewable energy increases the risk that Climate Act goals will not be met within the established time frame.

Finally, a formal backup plan has not been established in the event Climate Act goals are found to be unachievable within the prescribed time frames, other than PSC suspending or modifying the obligations under the Climate Act and relying on the continued use of fossil fuels to generate electricity until sufficient renewable electric generation is developed. However, continuing to use fossil fuels as a backup plan would delay emission reductions and increase the burden on ratepayers by forcing them to continue to support fossil-fuel generation that otherwise could be retired—including the additional cost of the infrastructure to safely transport the fossil fuels to where they will be used to generate energy.

Key Recommendations

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

•            Continuously analyze the existing and emerging risks and known issues to ensure they are evaluated and addressed to minimize impact on the State’s ability to meet Climate Act goals.

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

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

Note that the key finding that states that the PSC “has not yet begun to formally review progress toward Climate Act goals with updated generation and electricity demand forecasts.”  It goes on to say that “While PSC noted it has until July 2024 to begin this assessment, waiting until that point to fully review all efforts and costs of the transition to renewable energy increases the risk that Climate Act goals will not be met within the established time frame.”  A couple of weeks ago the PSC released the Clean Energy Standard Biennial Review Report.  I do not think that report uses “updated generation and electricity demand forecasts” but it does conclude that the 2030 goal requiring 70% of the electricity supplied to the grid come from renewable sources will not be met without extraordinary efforts.

In addition, the biennial report does not address costs.  It states that:

Appendix A also provides CES funding and expenditures for recent years through 2023. Forward-looking cost estimates for the CES and other costs associated with pursuit of the CLCPA goals are provided separately in the Department of Public Service (DPS) Annual CLCPA Report.  The most recent such report was filed on July 20, 2024. Case 22-M-0149, Proceeding on Motion of the Commission Assessing Implementation of and Compliance with the Requirements and Targets of the Climate Leadership and Community Protection Act, New York State Department of Public Service First Annual Informational Report on Overall Implementation of the Climate Leadership and Community Protection Act (filed July 20, 2024). The next report is expected to be filed later in 2024.

In other words the biennial reports are not going to provide the cost data that the Comptroller audit recommends.

Ellenbogen Commentary

The following was included in an email from Ellenbogen on 17 July 2024.  I have made a few edits for consistency with this article and have added a couple of annotations.

Regarding DiNapoli’s request for more transparent information mentioned in the audit report, he is correct but he is directing his arrows at the wrong targets.  While I have major issues with some of the things that NYSERDA has done over the past couple of years, primarily their silence on the CLCPA, the PSC and NYSERDA are not the ultimate culprits here.  At the BCNYS Renewable Energy Conference, I asked the NYISO speaker why they were screaming between the lines and not just coming out and saying that the entire process is devoid of reality because the people that need to hear it can’t, or are unwilling to, read between the lines.  The NYISO says that, “Because we shut down gas generation too quickly, the system is compromised and has inadequate excess generation during times of extremely high load” which translates to, “If we have too many hot days in a row, there is going to be a blackout and people are going to die.”

In their 2022 6 GW storage report, NYSERDA stated that to get the system to work would require 1000+ hours of storage and the cost at the time was $560 per KWh.  Doing the math, that was $3.36 Trillion dollars for storage that would last only ten years.  That doesn’t include the renewables and transmission that would be required or the hundreds of billions of dollars to electrify the buildings.  The actual cost will be at least ten times NY State’s annual budget, if not more.   It will impose a tax burden on every New Yorker that none of them will be able to afford.  NYSERDA put the number out there, but everyone ignored it and just plowed along as though they could somehow overcome that little detail.  The cost also ignores logistical issues that I have mentioned on numerous occasions.

The problem with agency cost estimates is that they are buried in different reports. The Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda” is the logical place to provide comprehensive cost estimates for all the strategies proposed to achieve the Climate Act mandates.  However, the cost documentation is incomplete, sparsely referenced, and misleading, in short it does not provide the necessary information for estimating ratepayer costs to New Yorkers. 

This is a problem because New York Public Service Law  § 66-p (4), “Establishment of a renewable energy program”, states: “The commission may temporarily suspend or modify the obligations under such program provided that the commission, after conducting a hearing as provided in section twenty of this chapter, makes a finding that the program impedes the provision of safe and adequate electric service; the program is likely to impair existing obligations and agreements; and/or that there is a significant increase in arrears or service disconnections that the commission determines is related to the program”.  It is only possible to determine the impact on ratepayers in arrears or service disconnections if full cost estimates are available.  The Comptroller audit appropriately addresses this shortcoming with the recommendation to “Conduct a detailed analysis of cost estimates to transition to renewable energy sources and meet Climate Act goals” and “Periodically update and report the results of the analysis to the public.”

I agree with Ellenbogen’s following explanation why this information is not available:

No one wants to put the actual number into the public domain because it is so astronomical that the minute it was announced, the project would implode, and the political fallout will be staggering.  Further, I’m sure that the lesson of what happened to Justin Driscoll of NYPA when he told the truth about the process is fresh in everyone’s mind.  The acolytes of this process wanted to hang him upside down from a light pole, as was done to Mussolini.  He was just telling them the truth but that evidently doesn’t mean anything in NY State.  No sane person wants to put that number down on paper and get pilloried for it and called a liar.  Everyone at the state level that knows better is required by law to implement this ridiculous plan that can’t be implemented.  So, they can tell the truth and get fired or they can duck and cover and hope that the law gets changed when it becomes brutally obvious how flawed it really is.  In the interim, everyone is finger pointing, including the state comptroller.

The real targets for DiNapoli should be the Climate Action Council and the legislature that proposed this insanity based upon fantasies with no grounding in reality.  No realistic cost analysis was ever done prior to voting to pass the Climate Act.  The cost analysis for the Draft Scoping Plan was inadequate but the Climate Act Scoping Plan was still approved and that is the fault of the Climate Action Council (CAC).  The few numbers that I have seen in the Climate Act Scoping Plan are so devoid from reality that they would be funny if the situation wasn’t so serious.   You can make stuff up as the Climate Action Council did, but with math and physics, reality will eventually rear its ugly head and that is what is happening now.

In a second email Ellenbogen continued:

The issue isn’t that the PSC and NYSERDA aren’t planning properly.  If you look at the three key findings quoted from the Audit highlights above, they are unachievable under any circumstances.  It wouldn’t matter what NYSERDA and the PSC did.  They can’t pull rabbits out of hats last I checked.

There is a Climate Action Council mandate (section 16 of § 75-0103) to consider efforts at other jurisdictions: “The council shall identify existing climate change mitigation and adaptation efforts at the federal, state, and local levels and may make recommendations regarding how such policies may improve the state’s efforts”. Ellenbogen points out the there are lessons to be learned at other jurisdictions that have attempted to decarbonize using wind and solar that have been ignored.  Why?

The math behind the solar and wind utility system doesn’t work.  It hasn’t worked anywhere it has been tried and the time frames have been measured in decades to get to a fraction of a renewable system, not 10 years or 20 years like the CLCPA requires.  Germany is 34 years in, controls the banking system in their jurisdiction which NY State does not, and they’ve only gotten to 34% renewables after about 34 years with energy costs twice those of France next door.  Their politicians are paying for that.  The costs are rising because they are being required to install transmission that only operates 15% of the time for solar or 30% for wind where it would operate 93% of the time for fossil or nuclear.  That increases the transmission cost per megawatt-hour.   Offshore wind bids are coming in at three times the price of current generation.  Projects are being canceled because of high transmission costs and material costs.  Building electrification is prohibitively expensive.  How can you plan for that?  

Why didn’t the legislature request a cost analysis prior to passing the bill?  Why didn’t the Climate Action Council do a cost analysis of what they were proposing?  It’s because it was driven by a couple of college professors that have absolutely no understanding of procurement, energy, economics, or basically anything else in the real world.  In their minds, no cost was too high to eliminate fossil fuels from the state.  The question for politicians today is whether spiraling energy costs brought on by this bill are going to make re-election more difficult.

The net-zero transition plan requires “Distributed Emission Free Resources” or DEFR’s that don’t exist in the present day aside from nuclear and that is a dirty word in NY State.  Even if the State made the rational decision to decarbonize the electric sector with nuclear instead of wind and solar, it would also take about 30 – 40 years to build enough nuclear capacity to meet the state’s needs if they started today.  Waiting for an alternative new technology to fulfill the DEFR requirement will take even longer.  None of these time frames fits within the CLCPA mandate.

The only mistake that the PSC and NYSERDA made was not speaking up in 2019 before this mess was passed but Cuomo was ruling with an iron hand at the time.  What makes this all so senseless is that nothing NY State does is going to impact Climate Change.  I’m not saying that we should do nothing, but we should be intelligent in our planning.  Saying that NY State is an energy leader is a joke.  We’re only a leader in chasing our businesses to other states where they are assured of an adequate energy supply.  In 20 years NY State is going to be an example of what not to do.

The backup plan for the near term to ensure sufficient generation would require the construction of fossil fuel plants which will draw the ire of the lunatic fringe that has no understanding of energy or math.  I gave them a backup plan in comments I submitted to the record for Department of Public Service Proceeding 15-E-0302 but numerous groups will fight against that.  When the level of desperation gets high enough, they will be implemented.  Unfortunately, there may have to be a major blackout to bring people to their senses.

Conclusion

The Comptroller Climate Act Goals – Planning, Procurements, and Progress Tracking and the PSC Clean Energy Standard Biennial Review Report both acknowledge that Climate Act implementation is not going as planned.  I believe Ellenbogen agrees with me that all the recommendations in the audit report should be implemented as soon as possible:

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

•            Continuously analyze the existing and emerging risks and known issues to ensure they are evaluated and addressed to minimize impact on the State’s ability to meet Climate Act goals.

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

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

Richard Ellenbogen and I have long argued that a clear and transparent accounting of all the costs to meet the Climate Act goals is not available.  It is heartening to see that the Comptroller audit agrees with our position that this information is necessary.  The biennial review report concludes that the 2030 electric grid goal for 70% renewable energy is not likely.  It is time for New York State to acknowledge these problems should be resolved before continuing.  I recommend a pause in implementation until all the recommendations in the audit report are implemented and a feasibility study reconciles the electric system projections in the Scoping Plan and the New York Independent System Operator resource adequacy analyses.

Ellenbogen sums up the situation:

There is nothing happening now that I didn’t tell them would happen five years ago.  I’m not Nostradamus.  I just know how to count.

Climate Act Presumption That DEFR is Unnecessary

The New York Department of Public Service (DPS) Proceeding 15-E-0302 addresses among other things  a new category of generating resources called Dispatchable Emissions-Free Resources (DEFR).  All credible analyses of the future New York electric system agree that new technologies are necessary to keep the lights on during periods of extended low wind and solar resource availability.  This article describes the presumption of the authors of the Climate Leadership & Community Protection Act (Climate Act) that no new technologies would be required.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations and legislation.

I have written about the out-sized and misleading impact that Robert W. Howarth, Ph.D., the David R. Atkinson Professor of Ecology & Environmental Biology at Cornell University had on many of the members of the Climate Action Council.  His statement supporting the approval of the Draft Scoping plan claimed that he played a key role in the drafting of the Climate Act and explained why he believes that no new technologies are needed to meet the Climate Act goals:

I further wish to acknowledge the incredible role that Prof. Mark Jacobson of Stanford has played in moving the entire world towards a carbon-free future, including New York State. A decade ago, Jacobson, I and others laid out a specific plan for New York (Jacobson et al. 2013). In that peer-reviewed analysis, we demonstrated that our State could rapidly move away from fossil fuels and instead be fueled completely by the power of the wind, the sun, and hydro. We further demonstrated that it could be done completely with technologies available at that time (a decade ago), that it could be cost effective, that it would be hugely beneficial for public health and energy security, and that it would stimulate a large increase in well-paying jobs. I have seen nothing in the past decade that would dissuade me from pushing for the same path forward. The economic arguments have only grown stronger, the climate crisis more severe. The fundamental arguments remain the same.

The presumption that “it could be done completely with technologies available at that time (a decade ago)” was a primary driver of the Climate Act schedule and confidence of success by the legislature and the Climate Action Council.  The feeling was that all it takes is a matter of political will because the professor said it will work.  Howarth appealed to the authority of peer-reviewed science to provide credibility for the Jacobson analysis that is the basis of his claims. However, science is a continuous process where hypotheses are constantly challenged and confirmed.  In this instance Howarth neglected to mention the analyses that discredit the Jacobson work. 

Jacobson Wind, Water, and Solar

The Jacobson analysis cited was a continuation of previous work broadly labeled as Wind, Water, and Solar.  For example, in a widely publicized November 2009 Scientific American article, Mark Jacobson and Mark Delucchi suggested all electrical generation and ground transportation internationally could be supplied by wind, water and solar resources as early as 2030. However, other contemporary projections were less optimistic, for example two examples: the 2015 MIT Energy and Climate Outlook has low carbon sources worldwide as only 25% of primary energy by 2050, and renewables only 16% and the International Energy Agency’s two-degree scenario has renewables, including biomass, as less than 50%.

Howarth’s statement cites a specific plan for New York (Jacobson et al. 2013) that he and Jacobson laid out a decade ago.  He says that “In that peer- reviewed analysis, we demonstrated that our State could rapidly move away from fossil fuels and instead be fueled completely by the power of the wind, the sun, and hydro.”   Table 2 from that report follows.  This analysis includes power from exotic resources such as waves, geothermal, tidal turbines, and concentrated solar power but no energy storage.  It is significantly different than the projections in the Integration Analysis and the New York Independent System Operator (NYISO) 2021-2040 System & Resource Outlook that exclude all the exotic renewable generating capacity, contain significant amounts of energy storage, and include a new dispatchable, emissions-free resource for a set of resources that they think can provide sufficient electrical power for the future.  Furthermore, Jacobson and Howarth claim that end-use power demand can be decreased by 37%.   In my opinion, there are many flaws in his claims.  For example, any analysis that suggests that concentrated solar power is a viable source of energy in New York is simply not credible because that resource would never work in New York.  It is too cloudy to operate enough to cover costs and the environmental impacts would be too great.

There was a formal rebuttal paper to this analysis by Nathaniel Gilbraith, Paulina Jaramillo, Fan Tong, and Felipe Faria. The rebuttal paper argued that: 

The feasibility analysis performed by Jacobson et al. (2013) is incomplete and scientifically questionable from both the technical and economic perspectives, and it implicitly assumes, without sufficient justification, that social criterion would not produce even larger feasibility barriers.

Jacobson et al. responded to that rebuttal claiming  that “The main limitations are social and political, not technical or economic.”  Given the significant differences between that analysis and the most recent projections by the organization responsible for keeping the lights on, I agree with the Gilbraith et al. conclusion cited above.  I do not believe that the 2013 WWS analysis includes a defensible feasibility analysis.

Using Jacobson as the basis for the idea that the Climate Act transition needs no new technology gets worse.  Unmentioned by Dr. Howarth is that in a 2015 article for a different iteration of the wind, water, and solar roadmap Clack et al, 2017 discredited the Jacobson approach:

In this paper, we evaluate that study and find significant shortcomings in the analysis. In particular, we point out that this work used invalid modeling tools, contained modeling errors, and made implausible and inadequately supported assumptions. Policy makers should treat with caution any visions of a rapid, reliable, and low-cost transition to entire energy systems that relies almost exclusively on wind, solar, and hydroelectric power.

In the scientific process, when issues with your work are noted, the proper response is to provide more evidence supporting your modeling tools, explain why the claimed errors are not errors, and defend your assumptions.  Instead, Jacobson filed a lawsuit, demanding $10 million in damages, against the peer-reviewed scientific journal Proceedings of the National Academy of Sciences and the authors for their study showing that Jacobson made improper assumptions in order to make his claims that he had demonstrated U.S. energy could be provided exclusively by renewable energy, primarily wind, water, and solar. In my opinion this is an appalling attack on free speech and scientific inquiry but want to emphasize that the bad actions by Jacobson in no way should be attributed to Howarth.

In February 2018, following a hearing at which PNAS argued for the case to be dismissed, Jacobson dropped the suit.  The defendants then filed, based on the anti-SLAPP — for “Strategic Lawsuit Against Public Participation” — statute in Washington, DC, for Jacobson to pay their legal fees. In September 2022, he was ordered to pay the defendants’ legal fees based on a statute “designed to provide for early dismissal of meritless lawsuits filed against people for the exercise of First Amendment rights.”  Jacobson appealed that award but lost that appeal in February 2024 thus closing this sad tale of academic controversy.

In Meredith Angwin’s 2020 book Shorting the Grid: The Hidden Fragility of Our Electric Grid (Carnot Communications, Wilder, VT, 422 pp.) she also addressed the Jacobson analysis.  Her description in a section entitled Hard-Core Renewables at page 195 is consistent with my portrayal above:

Wind and solar are the technologies that most people think about when they think of “renewables.” Indeed, many hard-core renewables advocates accept only solar, wind, and (sometimes) hydro as renewables. Biomass rarely makes the cut as a true renewable. Professor Mark Z. Jacobson of Stanford plans WWS (Wind Water Solar) as the energy sources for the world. In 2015, Jacobson and others published an article in the Proceedings of the National Academy of Sciences on using WWS for all purposes.125

In 2017, a group of professors headed by Christopher Clack responded with an evaluation article also in the Proceedings.126 The first paragraph of the Clack article stated that “We find that their (Jacobson analysis) involves errors, inappropriate methods, and implausible assumptions.” For example, their rebuttal paper pointed out that the Jacobson paper describes hydro power as providing 700 to 1300 GW. However, existing installed hydro capacity is 87 or 145 GW, depending on whether pumped hydro is included, and the most useful sites have already been exploited.127

When the Clack paper appeared, Jacobson published a letter in the same issue of the Proceedings, claiming “The premise and all error claims (of the Clack paper)… are demonstrably false.”128 Jacobson said that his assertion on the availability of hydro power was an “assumption,” not an error. As Jacobson wrote in the published letter: “The value of 1,300 GW is correct, because turbines were assumed added to existing reservoirs to increase their peak instantaneous discharge rate without increasing their average annual energy consumption.” Shortly after the Clack paper and the Jacobson rebuttal were published in the Proceedings, Jacobson sued Clack and the Proceedings for defamation.

Jacobson later dropped his lawsuit. On the Greentech Media website, Julian Spector wrote an article about the controversy and the lawsuit.129 In his article, Spector notes that “this ‘assumption’ (about hydro) was unwritten” in the original Jacobson article. In other words, in his original paper, Jacobson did not describe his assumption that multiple turbines would be added to existing dams. Frankly, adding about ten times as many turbines to existing powerhouses seems very unlikely to me. Dam construction is a massive undertaking. Putting many more turbines in an existing powerhouse … well, I can’t see how that could even work.130

Jacobson did drop his lawsuit, which should be a happy ending, I suppose. However, many people, including myself, feel that the fact that Jacobson even brought a lawsuit has had a chilling effect on the whole renewable-energy debate. If scientists can’t debate each other in peer-reviewed journals without fear of lawsuits, science will not be able to move forward very well.

There are two books directly refuting the Jacobson plan. Roadmap to Nowhere: The Myth of Powering the Nation With Renewable Energy by Mike Conley and Tim Maloney is available as a free PDF download on the web.131 Mathijs Beckers, of the Netherlands, wrote The Non-Solutions Project, available as an ebook or paperback.132 The work of these authors is clear and easy to follow.

Footnotes

  1. Mark Z. Jacobson, Mark A. Delucchi, Mary A. Cameron, and Bethany A. Frew, “Low-cost solution to the grid reliability problem with 100% penetration of intermittent wind, water, and solar for all purposes,” Proceedings of the National Academy of Sciences, 112, no. 49 (December 8, 2015): 15060-15065, https://wwu .pnas.org/’content/112149115060.
  2. Christopher T. M. Clack et al., “Evaluation of a proposal for reliable low- cost grid power with 100% wind, water, and solar,” Proceedings of the National Academy of Sciences 114, no. 26 (June 27, 2017): 6722-2627, https://www.pnas . o rg/con tent/114/2 6/6722.
  3. Supporting information for the above article by Clack et al., https://www.pnas .org/content/pnas/suppl/2017/06/16/16103 81114. DCSupplemental/pnas. 1610381114 .sapp.pdf
  4. Mark Z. Jacobson, Mark A. Delucchi, Mary A. Cameron, and Bethany A. Frew, “The United States can keep the grid stable at low cost with 100% clean, renewable energy in all sectors despite inaccurate claims” (letter), Proceedings of the National Academy of Sciences 114, no. 26 (June 27, 2017), https://www.pnas .org/content 1114126/P5021.
  5. Julian Spector, “Mark Jacobson Drops Lawsuit Against Critics of His 100% Renewables Plan,” gtm: (website of Greentech Media), February 26, 2018. https://www.greentechmedia.com/articles/read/mark-jacobson-drops-lawsnit- against-critics-of-his-100-renewables.
  6. Besides my general knowledge of the grid and several visits to working dams, I also headed a project on predicting and preventing corrosion in the penstocks of several medium-size dams in mountainous country. This project was not published: it was only a report to the client, so I cannot provide a link. While I would not claim hydro power as an area of deep expertise for me, I have enough knowledge to be seriously skeptical about the idea of adding ten times as many turbines to existing hydro plants.
  7. Mike Conley and Tim Maloney, “Road Map to Nowhere: The Myth of Powering the Nation with Renewable Energy,” Road Map to Nowhere (website), December 2017, https://www.roadmaptonowhere.com.
  8. Mathijs Beckers, “The non-solutions project,” CreateSpace Independent Publishing Platform January 18, 2017), https://www.amazon.com/gp/product/ B01N6SN5El/re/=dbs_a_def_rwt_hsch_vapi_tkin_pl_il.

Conclusion

Much of this material was published 18 months ago.  I wrote this article for two reasons.  I wanted to update some information and add the reference by Angwin.  The other reason is that I am compiling articles about DEFR to be used in a reference page.

Howarth’s argument that no new technology is needed has been refuted in the peer reviewed literature but also in other work.  When I publish the reference page it will include multiple examples of other analyses that conclude that the new DEFR technology is required for New York’s electric grid zero-emissions transition.  Successful implementation is not just a matter of political will.

It is unsettling that Howarth continues to claim that no new technology is needed in that light and relative to the lawsuits associated with Jacobson’s work.  Angwin and I agree that Jacobson’s attempted lawsuit was because his work could not stand on its own.  It is time for the Climate Action Council to disavow itself from any suggestions that DEFR will not be needed.

Lessons from the RGGI Investment Proceeds Reports

I have prepared seven annual updates on the Regional Greenhouse Gas Initiative (RGGI) annual Investments of Proceeds report.  While preparing the most recent edition I realized that there were some lessons to be learned concerning the relative emission reduction effectiveness of the different investments categories used in the reports.  This post compares the dollars per ton of CO2 reduced for five investment categories.

I have been involved in the RGGI program process since its inception.  I blog about the details of the RGGI program because very few seem to want to provide any criticisms of the program. The opinions expressed in this post 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.

Background

RGGI is a market-based program to reduce greenhouse gas emissions (Factsheet). It has been a cooperative effort among the states of Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New York, Rhode Island, and Vermont to cap and reduce CO2 emissions from the power sector since 2008.  New Jersey was in at the beginning, dropped out for years, and re-joined in 2020. Virginia joined in 2021 and dropped out at the end of 2023.  Pennsylvania has joined but is not actively participating in everything due to on-going litigation. According to a RGGI website: “The RGGI states issue CO2 allowances which are distributed almost entirely through regional auctions, resulting in proceeds for reinvestment in strategic energy and consumer programs. Programs funded with RGGI investments have spanned a wide range of consumers, providing benefits and improvements to private homes, local businesses, multi-family housing, industrial facilities, community buildings, retail customers, and more.”

Proceeds Investment Report

The 2022 investment proceeds report was released on July 8, 2024.  For general information I refer you to my most recent  update.  In this article I am going to present data from the last five reports.  Each report breaks down the investments into major categories.  The 2022 investment report explains:

Energy efficiency makes up 49% of 2022 RGGI investments and 61% of cumulative investments. Programs funded by these investments in 2022 are expected to return about $1.5 billion in lifetime energy bill savings to more than 189,000 participating households and over 2,000 businesses in the region and avoid the release of 6.5 million short tons of CO2.

Clean and renewable energy makes up 7% of 2022 RGGI investments and 6% of cumulative investments. RGGI investments in these technologies in 2022 are expected to return over $139 million in lifetime energy bill savings and avoid the release of more than 660,000 short tons of CO2.

Beneficial electrification makes up 12% of 2022 RGGI investments and 4% of cumulative investments. RGGI investments in beneficial electrification in 2022 are expected to avoid the release of 315,000 short tons of CO2 and return over $97 million in lifetime savings.

Greenhouse gas abatement and climate change adaptation makes up 3% of 2022 RGGI investments and 8% of cumulative investments. RGGI investments in greenhouse gas (GHG) abatement and climate change adaptation (CCA) in 2022 are expected to avoid the release of more than 11,000 short tons of CO2.

Direct bill assistance makes up 21% of 2022 RGGI investments and 15% of cumulative investments. Direct bill assistance programs funded through RGGI in 2022 have returned over $77 million in credits or assistance to consumers.

Emission Reduction Cost Efficiency

Ultimately RGGI is supposed to be a CO2 emission reduction program. GHG emission reduction efforts are complicated by the fact that there are no cost-effective add-on GHG emission controls available for existing sources.  That means the owners of the electric generating units in RGGI have only two options to reduce emissions: switch to lower CO2 emitting fuels or operate less.  Importantly, in order maintain reliability in the electric system when facilities run less, somebody else must develop replacement zero-emissions generating resources to replace their output. Proponents of cap-and-dividend programs like RGGI tout the use of the auction proceeds to fund the deployment of alternative resources and load reduction programs.  However, as is the case with any source of funding controlled by a political bureaucracy, money can get diverted away from the original purpose of the program in many ways.  There always is a rationale for all the other purposes but if insufficient resources are not available to support the deployment of alternative resources there will be problems providing sufficient load when it is needed while complying with the RGGI requirements.

All my summaries of the RGGI Investment Proceeds reports have found the same results.  Since the beginning of the RGGI program RGGI funded control programs have been responsible for a small fraction of the observed reductions (e.g., only 7.5% in 2022).  The primary reason for the observed reductions has been fuel switching away from coal and oil to natural gas.  Importantly, the availability of potential fuel switching in the RGGI fleet of electric generating units is running out.  Consequently, future reductions will have to rely on the deployment of zero-emission generating resources and load reductions which makes cost-effective emission investments important. 

This makes the cost-effective investment for alternative resources all the more important.  I calculate cost effectiveness by dividing the RGGI total investments divided by the estimated avoided CO2 emissions. In my annual summaries I only looked at the overall values.  In 2022 the CO2 emission reduction efficiency was $941 per ton of CO2 reduced.  In 2023 NY RGGI emissions totaled 28,654,177. If RGGI investments were the sole approach for emission reductions, then it would cost $27.0 billion to go to zero.

There is one more complication that I should note.  I believe that the appropriate methodology to calculate the CO2 emissions reduction efficiency is to use the annual investment and avoided emission estimates.  The problem is that the RGGI reports provide annual values and expected lifetime values.  The metric for net-zero is annual emissions so it is inappropriate to consider lifetime values.  The Proceeds reports always include a caveat that the states continually refine their estimates and update their methodologies, but the historical annual numbers are not included in the proceed reports so my estimates do not reflect subsequent refinements. 

In the following sections I will provide specific information for each of the investment categories

Energy Efficiency

The RGGI report glossary describes energy efficiency programs as follows:

Programs designed to improve energy efficiency by reducing overall energy use without degrading functionality. This includes programs directed at assisting low-income families and small businesses. Program costs include evaluation and measurement. Examples: home energy audit programs, home and building weatherization, energy efficient appliance or industrial equipment rebate programs, compact fluorescent light bulb programs, and energy efficiency workforce training programs.

The following table lists information for this investment category for the last five years.  Note that the effectiveness ($ per ton removed) ranges from $249 per ton to $1,665 per ton and the five-year average is $687 per ton.  The range is so large that it suggests that there is an inconsistency.  It could be differences due to different methodologies amongst the state agencies who prepared data for the report and interannual variation between analysts.  Based on my experience with similar estimates this is more art than science because the assumptions and input data used can lead to markedly different estimates. In addition, the states included in the analysis varies so the effects of methodological differences changes.  In my opinion, those issues would not account for the this wide a range so the possibility that there were typos in the data could also be a factor.  The RGGI state decision to not update the annual values also could be a factor inasmuch they might have identified an error that subsequent analyses corrected.  It is also possible that I made an error that is responsible for the variation.

Clean and renewable energy

The RGGI report glossary describes clean and renewable programs as follows:

Programs directed at accelerating the deployment of renewable or other non-carbon emitting energy technologies. Program costs include evaluation and measurement. Examples include incentives for residential solar panels, financing of commercial renewable energy projects through green banking, research and development of new energy technologies.

The following table lists information for this investment category for the last five years.  Note that the effectiveness ($ per ton removed) ranges from $158 per ton to $862 per ton with a 5-year average of $429.  Because of the wide range in values the previously mentioned caveats for potential errors are also relevant here.

Beneficial electrification

The RGGI report glossary describes beneficial electrification programs as follows:

Programs designed to reduce fossil fuel consumption by implementing or facilitating fuel-switching to replace direct fossil fuel use with electric power. Examples include incentives for electric vehicles and home appliances, and installation of electric vehicle infrastructure. Program costs include evaluation and measurement.

This category is complicated.  The report notes that:

Often, these programs result in an increase in MWh, but do reduce carbon emissions overall. As the grid becomes cleaner, the emissions from electrified appliances become cleaner, as opposed to the fixed emissions intensity of fossil-powered appliances.

The report argues that net emissions are lower, but the details of the calculations are not provided.  The net emissions calculation is highly dependent upon the characteristics of the electric generation resources that are displaced so I am skeptical with this claim.  The reported values may also be affected if the power and energy estimates consider the energy losses between the generating stations and the electrification applications.  This category was added in 2020 so the following table lists information for this investment category for the last three years.  The cost effectiveness ranges from $1,769 to $2,198 per ton with a 3-year average of $1,986 per ton. Note that there is not as much variation in the cost per ton reduced effectiveness but that the cost efficiencies are much higher than the other investment categories.

Greenhouse gas abatement and climate change adaptation

The RGGI report glossary describes GHG abatement and climate change adaptation programs as follows:

Programs promoting the research and development of advanced energy technologies, the reduction of vehicle miles traveled, the reduction of emissions in the power generation sector, tree-planting projects designed to increase carbon sequestration, other initiatives to reduce greenhouse gases, and climate adaptation and community preparedness initiatives. Some projects can support multiple functions, such as natural area restoration that also serves flood mitigation planning purposes. Program costs include evaluation and measurement.

The following table lists information for this investment category for the last five years.  Note that the 2021 and 2022 reports did not include avoided power and bill savings information.  There is a huge variation in the cost effectiveness values with 2021 listed as 100 times higher than the lowest value.  It appears that the avoided CO2 value is much lower than the other values.  If that value is incorrect then it would explain the high outlier.  The average value excluding the outlier is $842 per ton removed.

Direct bill assistance

The RGGI report glossary describes direct bill assistance programs as follows:

Programs providing energy bill payment assistance, including direct bill assistance to low-income ratepayers. Program costs include evaluation and measurement.

This category does not provide any emission reductions.  The following table lists information for this investment category for the last five years.  Note that the total direct bill assistance totals $243 million.

Administration and RGGI, Inc.

There are two other categories for administrative costs that do not provide any emission reduction benefits.  The RGGI report glossary describes administration as “Funds directed to administrative overhead expense associated with all RGGI-funded programs, including outsourced and in-house overhead expenses” and RGGI Inc. as: “Funds provided to RGGI, Inc. to support and implement state CO2 Budget Trading programs.”

The following tables show the information for the last five years.  Administration costs total $89 million and RGGI costs total $13 million.

Summary

I summed the values for each category over the last five years to provide the following summary.  Note that the overall cost effectiveness is $959 per ton avoided.

Cost Effectiveness Implications

RGGI is supposed to be an emissions reduction program.  One of my big concerns about any cost on carbon emissions is that it is a regressive stealth tax on energy.  There is a tradeoff between trying to minimize those impacts and reducing emissions.  In the last five years $243 million or 17.4% of the RGGI auction proceeds went to direct bill assistance which is good but that means that much less was available to reduce emissions.  Throw in the $102 million over the last 5 years for administration that means that 24.7% of the RGGI auction proceeds were not used to reduce emissions.

The primary goal of this article is to compare the cost effectiveness of emission reductions for the following investment categories: energy efficiency, clean and renewable energy, beneficial electrification, greenhouse gas abatement and climate change adaptation.  The following table summarizes the cost effectiveness.  For the investment categories that provided emission reductions Clean and Renewable Energy was the most effective way to reduce emissions.  As far as I can tell this category provides the most funding for projects that directly reduce emissions.  It is encouraging that the energy efficiency is right around the average over all the categories.  This means that energy efficiency programs targeted at low- and middle-income households most affected by this energy tax will still provide effective emission reductions. 

On the other hand, programs promoting the research and development of GHG abatement and climate change adaptation are less effective at reducing emissions.  Perhaps a greater emphasis on programs promoting reduction of emissions in the power generation sector and advanced energy technologies and less emphasis on programs for the reduction of vehicle miles traveled, tree-planting projects designed to increase carbon sequestration, and climate adaptation and community preparedness initiatives would improve emission reduction efforts consistent with the emission reduction goal of RGGI.

The worst emission reduction programs are associated with beneficial electrification that are “designed to reduce fossil fuel consumption by implementing or facilitating fuel-switching to replace direct fossil fuel use with electric power.“  This category was added recently.  There are two ways to look at the high numbers.  On one hand, it could be that it recognizes that reductions of overall fossil fuel consumption require efforts across all sectors.  On the other hand, I think it inappropriately transfers costs to the electric sector that do not provide efficient emission reductions.

Discussion

As noted previously, since the beginning of the RGGI program RGGI funded control programs have been responsible for a small fraction of the observed reductions (e.g., only 7.5% in 2022).  The primary reason for the observed reductions has been fuel switching away from coal and oil to natural gas. There are limited opportunities to make further fuel switching changes.   Consequently, future reductions will have to rely on the deployment of zero-emission generating resources.  This means that compliance with the RGGI emission caps is out of the control of the affected generating units and that RGGI investments must fund much of the reductions needed.

There are associated ramifications with the  RGGI Third Program Review currently underway but stalled for months.  The Acadia Center has been lobbying to resolve the impasse and “Set a new cap that is in line with the States’ goals, we are in support of a cap that goes to zero by 2040”. The most effective compliance strategy to date, fuel switching, cannot reduce emissions to zero.   The affected sources are unable to guarantee compliance because the deployment of zero-emissions resources are out of their control.  The recently released Clean Energy Standard Biennial Review Report found that New Yorks deployment of renewable resources is incompatible with the 2030 Climate Act goal to reach 70% by 2030.  Combined with the inefficient emission investment results, it is clear that Acadia’s position is incompatible with the reality of these findings.

Conclusion

To this point RGGI implementation has been able to rely on emission reductions from fuel switching at affected sources.  In the current program review process, climate activists are demanding that the future emission reduction trajectory be consistent with a zero-emissions electric grid at some point.  This means that fuel switching will eventually not be a viable option and, given that fuel switching opportunities are more limited than in the past, the ramifications are likely soon.  This is troubling because the ultimate compliance strategy for an affected source that has insufficient allowances due to an inappropriate reduction strategy is to simply stop running.

If RGGI investments could effectively support the development of zero-emissions resources or reduce load efficiently, then the affected sources could meet reasonable emission reduction trajectories.  Unfortunately, the results shown here suggest that RGGI investments have not been particularly cost efficient.  The bigger issue is that pressure to use RGGI funds to support electrification of other sectors not only causes an increase in load and likely emissions for the affected sources, but these results show that those investments have the worst cost per ton removed efficiencies.  Coupled with pressure to make equity-based investments that may or may not be efficient, this means that RGGI investments may be inadequate to support aspirational emission reductions targets.  All this suggests that the likelihood that RGGI compliance requirements will cause artificial energy shortages when units stop operating because they have inadequate allowances is increasingly likely.

Commentary on Recent Articles 14 July 2024

Frequent readers of this blog know that many of my posts are long because I get document all my statements.  This is because of my background in industry where it is necessary to prove my arguments to have credibility.  This is an update of articles that I have read that I want to mention but do not require a detailed post.  Previous commentaries are available here. 

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

Basic Economics and Renewable Energy Development

This is a great article I recommend that you read the whole thing.  Irina Slav explains a fundamental factor affecting the deployment of wind and solar. 

The biggest developer of wind and solar in Europe, Norway-based Statkraft, said last month that electricity prices in Europe have gone too low and production costs have gone too high, so it’s planning fewer projects for the immediate future.

“The transition from fossil to renewable energy is happening at an increasing pace in Europe and the rest of the world. However, the market conditions for the entire renewable energy industry have become more challenging,” Statkraft’s chief executive told the Financial Times.

Obviously, she was being modest and if she was being honest instead, the quote would have gone as follows: “The attempted transition to renewable energy is happening at an increasing pace, so market forces are kicking in more noticeably than before, making conditions for the industry more challenging.”

Slav goes on to argue that supply and demand is the fundamental driver of economic growth:

presence of so many massively huge corporations) supply and demand play equal roles as fuel for the growth engine. When supply for a product goes too high, demand lags behind, supply declines and, unless demand remains low and the product is replaced by another, demand begins to exceed supply and causes a supply rebound.

Of course this is as basic an explanation as is possible to produce but it serves my purpose, which is a comparison with planned economies. In planned economies, demand is a secondary concern. In planned economies, you buy what’s in front of you and don’t ask for a choice because there is none.

I encourage you to read the article because her arguments that the net-zero transition planned economy is destined to fail are compelling.  She concludes:

Twenty years of transition attempts and we are still at the “wind and solar are free” stage of denial. The market will fix all this eventually but the signs are multiplying that the pain during the healing process will be of the more rather than less severe variety.

Gaslighting of the Year Nominee

Gaslighting refers to “the act or practice of grossly misleading someone especially for one’s own advantage”.  The Free Press TGIF edition describes Jack Schlossberg:

Jack Schlossberg is Vogue’s newest political correspondent. But besides being insanely hot and the only surviving grandson of JFK, Schlossberg’s contribution to the political landscape amounts to a series of bizarre videos on Instagram where he puts on different accents to tell his followers why they should vote Biden. There’s one where he’s pretending to be a guy from Southie who cares about reproductive rights and another where he plays a British character called Reginald who wants to tell you about oil production under our current president.

In his monologue about oil production, he claims that it has reached record levels under Biden.  Bud’s Offshore Energy notes that the opinions of State and local governments and tribes are fully considered as long as they are aligned with the preordained political decision.  The example given was the Bureau of Land Management (BLM) rule making the National Petroleum Reserve in Alaska (NPR-A) off limits to oil and gas development.  To claim that Biden contributed to the record oil production when in the first week of his administration he introduced  a moratorium on new oil and gas leasing on federal lands makes Schlossberg a gaslighter of the year nominee.

Crude oil isn’t just for electricity

Ronald Stein makes a very good case that ridding the world of crude oil without a replacement is global suicide.  The fact is that there are so many products produced with oil that society would basically would come to a stop without them.

The world has also experienced significant economic growth and prosperity, benefiting from the more than 6,000 products that are derived from fossil fuels. These products support the following infrastructures and were not around a few short centuries ago because they all need components and parts made from fossil fuels that were NOT available in the pre-1800s.

  • Non-animal powered Transportation
  • Airports
  • Hospitals
  • Electronics
  • Telecommunications
  • Communications systems
  • Militaries
  • Space programs

I am continually amazed by the folks that think we can go cold turkey from fossil fuels that provide so many benefits.  This article is a good reminder of those benefits.

Methane

One of the most glaring examples of the misinformed “science” behind the Climate Act is the irrational obsession with methane.  Steve Gorham explains that “Claims about the global warming potential of methane are accurate in the laboratory, but not in the atmosphere.”  He goes on to point out “Because of greenhouse gas saturation in the atmosphere, methane regulations across the world will have no measurable effect on global temperatures.”  The article is a good overview of the irrelevance of methane. There is more information on this topic on my methane page. 

Ithaca NY Climate Goal

Rich Ellenbogen describes the link between a Christian Science Monitor article on the Ithaca climate goal and our warning about New York City’s Local Law 97.  One recommendation in our report is the necessity of a test case to prove the viability of wholesale electrification relying on renewables.  We arbitrarily picked Ithaca because I knew they had some climate goals, but I did not realize how ambitious the Ithaca plan was.

On July 10, there was a puff piece in the Christian Science Monitor regarding Ithaca’s electrification plan.  It discusses building retrofits for electrification but totally ignores all of the associated infrastructure that will be needed to support the electrified buildings.  Infrastructure that does not presently exist at utility scale, and won’t for decades.  It also shows all of the difficulties that a city of 33,000 – 40,000 is having achieving this, and despite having large amounts of funding lavished upon them, they are missing their deadlines.

For a city of over 8 million, those issues will be orders of magnitude greater and funding will run out well before the process is even 5% completed.  Ithaca also does not have the major power transmission issues that exist in the downstate region that will make the transition even more difficult.

This is nothing that hasn’t been obvious for over 5 years but as the implementation deadlines approach, it is more critical than ever to educate people as to the mess that the city and state government have placed us in so that we can hopefully prevent loss of life.

New York City Local Law 97 – Don’t Do It

I have the pleasure to announce the availability of a new report prepared for New York Co-op and Condo Boards and Trade Associations regarding New York City Local Law 97 mandated conversion to electric heat.  Local Law 97 mandates that “most buildings over 25,000 square feet are required to meet new energy efficiency and greenhouse gas emissions limits as of 2024, with stricter limits coming into effect in 2030.” Our report (“LL97 Impacts Report”) argues that in the absence of a credible and feasible plan demonstrating where the electricity will come from, backed up by a functioning Demonstration Project showing how the transformed grid will work and how much the electricity will cost, Co-op and Condo Boards cannot responsibly undergo the enormously costly process of conversion to electric heat. 

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.

Background

Co-authors Francis Menton, Richard Ellenbogen, and I prepared this report without compensation and on a pro bono basis because we felt duty-bound to warn people of the significant impending threat to their health and safety.  We received no funding of any kind from the real estate industry, the energy industry, or anyone else for this report.

I believe that the three of us represent different but complementary backgrounds that provide a unique take on the implementation of this law.  Francis Menton retired from the law firm Willkie Farr & Gallagher LLP after 31 years as a partner and brings a legal background to our team.  He has written about climate and energy issues for publications including the City Journal, Gatestone Institute, Real Clear Energy, and others, and is the main author at ManhattanContrarian.com with many of his articles reposted here.  Richard Ellenbogenhas a Bachelor’s degree and a Master’s Degree in Electrical Engineering from Cornell University.  He worked at Bell Telephone Laboratories in their Power Systems Laboratory, before joining Allied Converters, a plastic food packaging manufacturer in New Rochelle, N.Y.  As president of Allied Converters, Ellenbogen has overseen the company’s transformation into a green manufacturer with 100% waste recycling/repurposing, a 65 KW CHP System, and a 50-kilowatt solar array. Very few if any people in New York bring as much practical experience related to reducing energy use and lowering GHG emission.  For nearly the past two decades, Allied Converters has generated approximately 80% of its electric energy onsite and has operated with a Carbon Footprint 40% lower than the utility system. I am a retired air pollution meteorologist who started working at the interface between the electric utility industry and New York regulatory agencies starting in 1981.  I still closely follow New York regulatory initiatives and provide personal comments on energy and environment topics for regulatory proceedings and policy proposals.  I author the Pragmatic Environmentalist of New York blog and occasionally post articles here.

Francis Menton’s daughter Jane lived in a Queens co-op and was on their Board when Local Law 97 (LL97) was passed.  She and the members of her Board had an analysis done of the costs to meet the LL97 mandates.  In short, it was unaffordable. Not only that, but Jane also knew, based on her understanding of energy constraints in NYC, that it was unworkable and would result in an energy catastrophe. She recruited her father to write a report explaining the limitations of the electric grid.  Menton contacted me, I contacted Ellenbogen and the three of us agreed that, based on our backgrounds and experiences, we had a moral obligation to document the problems we expect will occur.  This report is intended to provide information for a grass roots organization, directed by Jane, that we hope will coordinate a response by co-ops and condo boards throughout New York City (NYC).

Local Law 97

The goal of LL97 is to reduce the emissions produced by the city’s largest buildings 40 percent by 2030 and net zero by 2050.  Similar to New York’s Climate Leadership and Community Protection Act (Climate Act) this is political theater without regard to practicality.  The law also established the Local Law 97 Advisory Board and Climate Working Groups which are supposed to advise the city on how best to meet the LL97 mandates.

In December 2022, the NYC Buildings Department released a report (“NYC LL97”) from the LL97 Advisory Board.  The NYC LL97 report “represents the culmination of hundreds of hours of work of the Advisory Board, Working Groups, and staff members who dedicated their time and expertise to help the City advance building energy efficiency and emissions reduction efforts”.  This is a political document.  LL97 mandated the appointment of sixteen people – eight appointed by the mayor and eight of appointed by the speaker of the City Council.  In theory the membership was supposed to represent “key stakeholder interests from the building sector” but I can guarantee that the primary qualification for membership was alignment with the political goals – just like the advisory panels for the Climate Act’s planning process. 

There were seven Climate Working Groups. These Working Groups “leveraged subject-matter experts in a variety of fields to present proposals to the Board on specific issue areas.  I do not want to disparage the work of these folks but the basic working premise of all these efforts is that we must do this because it is the law.  There are plenty of organizations that are happy to provide experts that can develop implementation plans that purport to show that it will work.  Pursuant to LL97, the NYC LL97 report included “recommendations regarding several issues related to implementation of the law, including improving performance requirements to achieve at least a 40% reduction in aggregate GHG emissions by 2030”. The report provides these recommendations.

The NYC LL97 report includes chapters on calculating and reporting GHG emissions; recommendations for “tailored emission reduction approaches based on different building types; mechanisms for maximizing emission reductions; assistance to “assist properties, especially those in high need areas, with compliance, rather than to fine them for noncompliance” approaches to maximize “compliance with LL97 through clear communications to the public and robust, direct outreach to covered property owners and stakeholders”; achieving consistency across existing regulations; and recommendations for further analysis.  The bottom line is that to meet the mandated emission limits buildings will eventually have to electrify their heating, cooking, and hot water systems.

The NYC LL97 report is incomplete.  Like the Climate Act Scoping Plan, the report does not address feasibility.  This is a particularly critical point because at the same time as this law is mandating increased use of electricity, the Climate Act mandates 70% renewable electrical generation by 2030 and 100% zero emissions generation by 2040.   Our report (“LL97 Impacts Report”) argues that credible and feasible plan must be prepared that demonstrates where the electricity will come from.  In order to guarantee health and safety a functioning Demonstration Project showing how the transformed grid will work and how much the electricity will cost is needed before Co-op and Condo Boards can responsibly undergo the enormously costly process of conversion to electric heat.

Report to Co-op and Condo Boards and Trade Associations regarding New York City Local Law 97

The LL97 Impacts Report points out that LL97 mandates that most large residential buildings in the City must convert to electric heat by 2030, and all of them by 2035.  Such conversions, should they occur, will add substantially to the demand on the City’s electrical grid.  Simultaneously, New York State has enacted the Climate Act, an even more comprehensive climate statute, that mandates that power plants that run on natural gas — the generators of most of the City’s reliable electricity — must be closed during the 2020s and 30s, and all of them closed by 2040.  The State has also mandated that a portion of new vehicle sales be zero-emissions vehicles starting in 2026, ramping up to 100% of all such sales by 2035, further dramatically increasing the demand on the City’s grid.  These several mandates are in irreconcilable conflict.  They cannot all be met simultaneously; and, in combination, they will inevitably undermine the reliability of the City’s electric grid.

The LL97 Impacts Report points out that neither the State nor the City of New York has presented any credible plan demonstrating that in the early to mid-2030s there will be sufficient reliable electricity generation to meet the demands anticipated from both current uses, and from the large additions that have been mandated.  Indeed, the State has admitted that, in lieu of a definitive plan, it relies instead on a speculative hope for new technologies not yet invented or deployed at scale to bridge the large gap in electricity supply that will inevitably arise from the conflicting mandates.  The State can point to no Demonstration Project showing how its hope for a de-carbonized electrical grid can succeed, nor to any detailed projection of the anticipated costs.

Even the New York Independent System Operator (NYISO) – the entity responsible for maintaining the reliability of the grid it oversees – has recently issued warnings as to the looming dangers ahead from insufficient and unreliable electricity supply.  In its recent 10-year Power Trends study, NYISO sees the danger of unreliability of the grid as arising no later than the phasing out by December 31, 2030 of the New York Power Authority’s small natural gas plants located in New York City. The NYISO report states:

 “If demand on the grid grows at a rate greater than the buildout of new generation and transmission, reliability deficiencies could arise…”. 

In addition, the Public Service Commission recently released its Clean Energy Standard Biennial Review Report that admits that the Climate Act 70% renewable electrical generation by 2030 goal will not be met until 2033 at the earliest.  The report cites global interest rates, inflation, and supply chain pressures as factors affecting the progress needed to meet the 2030 mandate.  Those factors also impact LL97 implementation.

The LL97 Impacts Report provides detailed descriptions of the issues raised in the NYISO and PSC report.  It explains that the ongoing pursuit of New York’s irreconcilable energy mandates creates especially severe potential consequences for the City’s large co-ops and condominiums. The boards of most of these buildings currently face a mandatory 2030 deadline for conversion to electric heat.  Complying with this mandate can only be done at very large cost, indeed a cost so large that it would stretch the finances of nearly all buildings to the breaking point.  Boards also have under New York law a fiduciary duty to their shareholders and members, which encompasses protecting the health and safety of all residents, and not squandering their constituents’ money.

The LL97 Impacts Report notes that in the absence of a credible and feasible plan demonstrating where the electricity will come from, backed up by a functioning Demonstration Project showing how the transformed grid will work and how much the electricity will cost, Boards cannot responsibly undergo the enormously costly process of conversion to electric heat.  Because of their fiduciary duties, Board members can face severe personal liability if, for example, they put their residents in the position of losing heat when the electrical grid fails on the coldest days of winter; or if they commit their building to borrowing large sums that must be repaid to install a heating system that then does not work when needed.

Conclusion

The NYC LL97 report falls far short of what is needed to provide Co-op and Condo Boards and the residents of those buildings with any assurance that the LL97 mandates can be met at the same time the Climate Act is transforming the electric energy system with massive deployments of wind, solar, and energy storage as well as not yet commercially available resources.  This means extraordinary risks for keeping the heat on in the winter in NYC.

The fines that are slated to be imposed on buildings failing to convert by 2030, although substantial, are small compared to the combined exposures of conversion costs plus potential liabilities.  Moreover, when it becomes apparent that the grid cannot handle the mandated demands, the laws imposing impossible and irreconcilable mandates must inevitably be modified.  The LL97 Impacts Report concludes that no responsible Board can go down the road of converting a large building to electric heat until NYC proves that the mandates are demonstrably feasible without threatening the safety and welfare of affected residents.

Investment of RGGI Proceeds Report for 2022  

This is the seventh installment of my annual updates on the Regional Greenhouse Gas Initiative (RGGI) annual Investments of Proceeds report.  This post compares the claims about the success of the investments against reality.  As in my previous posts I have found that the claims that RGGI successfully provides substantive emission reductions are unfounded and that the revenue investments cost per ton reduced far exceed all social cost of carbon estimates.

I have been involved in the RGGI program process since its inception.  I blog about the details of the RGGI program because very few seem to want to provide any criticisms of the program. The opinions expressed in this post 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.

Background

RGGI is a market-based program to reduce greenhouse gas emissions (Factsheet). It has been a cooperative effort among the states of Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New York, Rhode Island, and Vermont to cap and reduce CO2 emissions from the power sector since 2008.  New Jersey was in at the beginning, dropped out for years, and re-joined in 2020. Virginia joined in 2021 and dropped out at the end of 2023.  Pennsylvania has joined but is not actively participating in everything due to on-going litigation. According to a RGGI website: “The RGGI states issue CO2 allowances which are distributed almost entirely through regional auctions, resulting in proceeds for reinvestment in strategic energy and consumer programs. Programs funded with RGGI investments have spanned a wide range of consumers, providing benefits and improvements to private homes, local businesses, multi-family housing, industrial facilities, community buildings, retail customers, and more.”

Proceeds Investment Report

The 2022 investment proceeds report was released on July 8, 2024  According to the press release:

The participating states of the Regional Greenhouse Gas Initiative (RGGI) today released a report tracking the investment of proceeds generated from RGGI’s regional CO2 allowance auctions. The report tracks investments of RGGI proceeds in 2022, providing state-specific success stories and program highlights. The RGGI states have individual discretion over how to invest proceeds according to state-specific goals. Accordingly, states direct funds to a wide variety of programs, touching all aspects of the energy sector.

In 2022, $364 million in RGGI proceeds were invested in programs including energy efficiency, clean and renewable energy, beneficial electrification, greenhouse gas abatement, and direct bill assistance. Over their lifetime, these 2022 investments are projected to provide participating households and businesses with $1.8 billion in energy bill savings and avoid the emission of 6.6 million short tons of CO2.

The largest share of the investments was directed to energy efficiency, with 49% of the 2022 total. Other categories receiving significant investments include direct bill assistance, clean and renewable energy programs, beneficial electrification, and greenhouse gas abatement and climate adaptation programs. Approximately 30% of these investments went towards environmental justice and equity focused programs. For more details on both 2022 and cumulative investments and benefits, see the full report, Investment of RGGI Proceeds in 2022.

The report breaks down the investments into five major categories:

Energy efficiency makes up 49% of 2022 RGGI investments and 61% of cumulative investments. Programs funded by these investments in 2022 are expected to return about $1.5 billion in lifetime energy bill savings to more than 189,000 participating households and over 2,000 businesses in the region and avoid the release of 6.5 million short tons of CO2.

Clean and renewable energy makes up 7% of 2022 RGGI investments and 6% of cumulative investments. RGGI investments in these technologies in 2022 are expected to return over $139 million in lifetime energy bill savings and avoid the release of more than 660,000 short tons of CO2.

Beneficial electrification makes up 12% of 2022 RGGI investments and 4% of cumulative investments. RGGI investments in beneficial electrification in 2022 are expected to avoid the release of 315,000 short tons of CO2 and return over $97 million in lifetime savings.

Greenhouse gas abatement and climate change adaptation makes up 3% of 2022 RGGI investments and 8% of cumulative investments. RGGI investments in greenhouse gas (GHG) abatement and climate change adaptation (CCA) in 2022 are expected to avoid the release of more than 11,000 short tons of CO2.

Direct bill assistance makes up 21% of 2022 RGGI investments and 15% of cumulative investments. Direct bill assistance programs funded through RGGI in 2022 have returned over $77 million in credits or assistance to consumers.

Emissions Reductions

In my previous articles on the Proceeds reports, I have argued that RGGI mis-leads readers when they claim that the RGGI states have reduced power sector CO2 pollution over 50% since 2009. In the following table, I list the 9-state RGGI emissions and percentage reduction from a three-year baseline before the program started in 2009.

I have argued that the implication in the report’s 50% claim is that the RGGI program investments were primarily responsible for the observed reduction even as the economy grew (Chart 1 from the report).

I believe that their insinuation that RGGI was primarily responsible for the emission reductions is wrong.  The following table lists the emissions by fuel types for ten RGGI states.  It is obvious that the primary cause of the emission reductions was the fuel switch from coal and residual oil to natural gas.  This fuel switch occurred because it was economic to do so.  I believe that RGGI had very little to do with these fuel switches because fuel costs are the biggest driver for operational costs and the cost adder of the RGGI carbon price was too small to drive the use of natural gas over coal and oil. 

I believe that the appropriate measure of RGGI emissions reductions is the decrease due to the investments made with the auction proceeds so I compared the annual reductions made by RGGI investments.  The biggest flaw in the RGGI report is that it does not provide the annual RGGI investment CO2 reduction values accumulated since the beginning of the program.  In order to make a comparison to the CO2 reduction goals I had to sum the values in the previous reports to provide that information. 

The following table lists the annual avoided CO2 emissions generated by the RGGI investments from previous reports.  The accumulated total of the annual reductions from RGGI investments is 4,277,230 tons while the difference between the three-year baseline of 2006-2008 and 2022 emissions is 56,704,448 tons.  The RGGI investments are only directly responsible for 7.5% of the total observed annual reductions over the baseline to 2022 timeframe! 

Although proponents claim that this program has been an unqualified success I disagree.  Based on the numbers there are some important caveats to the simplistic comparison of before and after emissions.   The numbers in the previous paragraph show that emission reductions from direct RGGI investments were only responsible for 6.7% of the observed reductions.   In a detailed article I showed that fuel switching was the most effective driver of emissions reductions since the inception of RGGI and responsible for most of the reductions.

Benefits

Table 1 from the report lists two benefits of 2022 RGGI Investments: emission reductions and energy bill savings.  Energy bill savings derive from investments in energy efficiency savings and other efforts that directly reduce costs to consumers.  These energy saving benefits typically account for total savings over the lifetime of the project investment.  RGGI does the same thing with the CO2 emission reductions but I think that is misleading because the emission reduction metric is annual emissions and not lifetime emissions. 

Emission Reduction Cost Efficiency

There is another aspect of this report that is mis-leading and after arguing with RGGI and New York State about the issue, I have concluded that the deception is intentional.  I believe that a primary concern for GHG emission reduction policies is the cost effectiveness of the policies and I have argued that this report should provide the information necessary to determine a cost per ton reduced value for control programs for comparison to the social cost of carbon.  If the societal benefits represented by the social cost of carbon for GHG emission reductions are greater than the control costs for those reductions, then there is value in making the reductions.  If not, then the control programs are not effective.

Recall that RGGI provides lifetime CO2 emission reductions but I think that is misleading because it suggests that the emission reduction cost efficiency of the investments is the total investments divided by the lifetime benefits of those benefits.   For example, dividing the 2022 investments of $364 million by the lifetime avoided CO2 emissions (7,507,128) yields a value of $49.  The Biden administration is re-evaluating the social cost of carbon values but for the time being has announced an initial estimate of $51 per ton and this suggests that RGGI investments are close to being cost effective relative to the Federal social cost of carbon.

However, the social cost of carbon value is calculated for an annual reduction of one ton.  In particular,

the social cost of carbon is an estimate, in dollars, of the present discounted value of the benefits of reducing annual emissions by a metric ton. I believe that using the lifetime emissions approach is wrong because it applies the social cost multiple times for each ton reduced.  It is inappropriate to claim the benefits of an annual reduction of a ton of greenhouse gas over any lifetime or to compare it with avoided emissions. In my comments on the New York Climate Act Scoping Plan, I explained that the value of carbon for an emission reduction is based on all the damages that occur from the year that the ton of carbon is reduced out to 2300.  Clearly, using cumulative values for this parameter is incorrect because it counts those values over and over.  I contacted social cost of carbon expert Dr. Richard Tol about my interpretation of the use of lifetime savings and he confirmed that “The SCC should not be compared to life-time savings or life-time costs (unless the project life is one year)”. 

In order to calculate the CO2 emissions reduction efficiency consistent with the social cost of carbon, the proper estimate is the total investments since the start of the program divided by sum of the annual emission reductions.  The problem is that the RGGI reports do not provide that total and instead only provide the sum of the annual lifetime CO2 avoided emissions.  The Proceeds reports always include a caveat that the states continually refine their estimates and update their methodologies, but the annual numbers are not updated to reflect those changes.  Ideally to get the best estimate of the annual numbers the RGGI states should provide the revised annual numbers for each year of the program. Because that is not the case, I have had to rely on the original annual numbers provided in previous editions of the report.  I summed the values in the previous reports to provide that information as shown in the Accumulated Annual Regional Greenhouse Gas Initiative Benefits Through 2022 table shown above.  The accumulated total of the annual reductions from RGGI investments is 4,277,230 tons through December 31, 2022. The sum of the RGGI investments in the previous table is $4,023,548,913 over that time frame.  The appropriate comparison to the social cost of carbon is $4.024 billion divided by 4,277,230 tons or $941 per ton reduced. 

Conclusion

The 2022 RGGI Investment Proceeds report tries to put a positive spin on the poor performance of RGGI auction proceeds reducing CO2.  The alleged purpose of the program is to reduce CO2 from the electric generating sector to alleviate impacts of climate change.  Since the beginning of the RGGI program RGGI funded control programs have been responsible for 7.5% of the observed reductions.  The report does not directly provide the numbers necessary to calculate that estimate which I have come to believe is deliberate.  When the sum of the RGGI investments is divided by the sum of the annual emission reductions the CO2 emission reduction efficiency is $941 per ton of CO2 reduced.  I conclude that although RGGI has been effective raising revenues it is not an effective CO2 emission reduction program.

Commentary on Recent Articles 7 July 2024

Frequent readers of this blog know that many of my posts are long because I get document all my statements.  This is because of my background in industry where it is necessary to prove my arguments to have credibility.  This is an update of articles that I have read that I want to mention but do not require a detailed post.  Previous commentaries are available here. 

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

Supreme Court Ends the Chevron Defense

Francis Menton explains: “when the legality of a regulatory action of a federal agency is challenged in court, should (or must) the court “defer” to the interpretation that the agency itself has given to the governing statute, or to the challenged regulation?” the Chevron defense deferred to the agency.  He states:

Chevron deference” is the ultimate unfettering of the government to enable it to expand as much as it wants, and with nothing to stop it.  Of course every agency interpretation of a statute or regulation will be in a way to give the agency itself more power!  For Exhibit A, look to the EPA under Obama, which has interpreted the term “waters of the United States” to cover every puddle and wet spot (in order to claim jurisdiction over a good half of all private land) and has determined that a colorless, odorless gas (CO2) is a “danger to human health and welfare” (in order to claim jurisdiction over the entire energy sector of the economy).”

Roger Pielke, Jr. explains why he would have joined the dissent on the decisions and Robert Bryce argues that the decision “finally brings some balance into the regulatory world”.  I think the defense has led to one-sided decisions that are not in the best interests of society, so I applaud the decision.

New York Climate Super Fund

The New York legislature has passed the Climate Change Superfund Act but it has not been signed by Governor Hochul.  The Institute for Energy Research explains:

The legislation would impose a retroactive tax on fossil energy companies that have emitted greenhouse gases and operated within the state over the last seventy years. If passed, the new law will impose $75 billion in repayment fees for “historical polluters,” who lawmakers assert are primarily responsible for climate change “damages” within the state. New York will “assign liability to and require compensation from companies commensurate with their emissions” over the last “70 years or more.” The bill would establish a standard of strict liability, stating that “companies are required to pay into the fund because the use of their products caused the pollution. No finding of wrongdoing is required.”

It is unclear why New York legislators believe $75 billion in repayment fees would not increase costs to consumers but numeracy is not a strong suit of the legislature.  I suspect that there will be legal challenges as well.  It is kind of mind boggling that the bill demands payment for something without requiring a finding of wrongdoing.  Given that Hochul as indicated that she intends to run for Governor in 2026 I would not be surprised if she signs the bill.

Proposal to Raise the New York Distributed Solar Target

PV magazine describes a New York Solar Energy Industries Association (NYSEIA) report to Governor Kathy Hochul, requesting a raised target for the state’s distributed solar targets.  The current target is 10 GW by 2030 and NYSEIA proposes raising the target to 20 GW by 2035.  A quick look at the report suggests that I should address some of the claims made but, in this commentary, I want to address one issue.

Given the problems raised in the New York Independent System Operator Power Trends 2024 report, I believe that New York’s energy planning should focus on the wind and solar resource gap that was addressed at the first session of the Department of Public Service Proceeding 15-E-0302 technical conference held on December 11 and 12, 2023 entitled Zero Emissions by 2040.  I described the problem and the new category of generating resources called Dispatchable Emissions-Free Resources (DEFR) necessary to keep the lights on during periods of extended low wind and solar resource availability. 

The problem with solar is that it is not expected to provide any energy when the future winter load peaks after the sun has gone down.  Distributed solar has a related problem.  Roof top arrays are commonly used for distributed solar and in New York City many arrays are flat as shown below.

Source: https://www.brightpower.com/new-york-city-solar-co-op/

Source: https://www.gothamgazette.com/authors/130-opinion/5800-new-york-city-can-shine-with-solar-power-leibowitz-richards

Just imagine how these panels will look after a significant snowstorm.  There is no place to put the snow even if it could be cleared.  It is not unusual for the coldest weather and the highest loads to occur after an impactful snowstorm.  In that instance, rooftop solar will not only be unavailable during the peak hour but could be impacted for days after the snowstorm.  Spending more money on distributed solar that will not help address future peak winter loads is a waste.

California in one License Plate

The Free Press TGIF edition published this cartoon by David Mamet:

India is Going Gangbusters on Coal

Jo Nova notes that India burns more coal than the US and Europe combined and just ordered $33b in “new coal plants”.  I compared NYS GHG emissions with India and China using data from Our World in Data.  In 2021, NYS GHG emissions (GWP-100) were 247 million metric tonnes (MMT).  GHG emissions from China were 13,774 MMT and from India were 3,879 MMT.  The increase in emission from 2020 to 2021 were 498 MMT in China and 265 MMT in India.  New York emissions will be supplanted by emissions from China or India in less than one year.

Somebody explain to me why New York is doing this again.

Here are a few other items of interest.

Videos

Articles

  • New York City sea-level rise alarmism is misplaced.
  • Reason for 2023 Record Warming Javier Vinós makes the case that the primary reason for the spike in temperatures was natural.  In particular a very rare underwater volcano that injected water vapor into the stratosphere.
  • Chuck Schumer’s ‘Dear Friend’ Invested in Solar as Schumer Secretly Negotiated Climate Bill.  You will never be able to convince me that it is not all about the money.  “More and more, it appears the ‘green’ in much of the green agenda has a lot less to do with the environment than it does with transferring taxpayer funds to preferred special interest bank accounts,” said Michael Chamberlain, the director of government watchdog group Protect the Public’s Trust.
  • Adults take charge: “Chaotic and only occasional wind and solar generation is what you get when infants run the show. Now in a ‘wait til your father gets home’ moment, governments of an adult bent are taking a firm grip on energy policy. Ditching the suicidal renewable energy targets and plumping for nuclear power, principally because it works.”  I love the illustration for the article.

Filling the Gap in New York’s Decarbonization Plan: A New View of the Electric Grid

Nuclear New York, Inc. submitted the report “Filling the Gap in the State’s Decarbonization Plan” to the New York Department of Public Service (DPS) Proceeding 15-E-0302 related to a new category of generating resources called Dispatchable Emissions-Free Resources (DEFR).  All credible analyses of the future New York electric system agree that new technologies are necessary to keep the lights on during periods of extended low wind and solar resource availability.  This article documents this analysis.

I have followed the Climate Leadership & Community Protection Act (Climate Act)since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022. 

When the Climate Action Council voted to accept the Scoping Plan draft members made statements. I have previously described the outsized influence of Dr. Robert Howarth the David R. Atkinson Professor of Ecology & Environmental Biology at Cornell University on the findings of the Council. His statement, in support of approving the Scoping Plan draft included the following:

A decade ago, Jacobson, I and others laid out a specific plan for New York (Jacobson et al. 2013). In that peer-reviewed analysis, we demonstrated that our State could rapidly move away from fossil fuels and instead be fueled completely by the power of the wind, the sun, and hydro. We further demonstrated that it could be done completely with technologies available at that time (a decade ago), that it could be cost effective, that it would be hugely beneficial for public health and energy security, and that it would stimulate a large increase in well-paying jobs. I have seen nothing in the past decade that would dissuade me from pushing for the same path forward.

The Scoping Plan directly contradicts his statement that technologies available when the paper was written and today are sufficient for the transition away from fossil fuels.  The Scoping Plan itself explains why DEFR is necessary.  I provide more details about DEFR at a dedicated webpage and I am compiling a list of analyses that contend that it is necessary.   This post describes the Nuclear New York report “Filling the Gap in the State’s Decarbonization Plan” that also argues that New York’s plans have underestimated the need for dispatchable resources in the future.

A New View of the Electric Grid

The Filling the Gap in New York’s Decarbonization Plan: A New View of the Electric Grid report was authored by Leonard Rodberg, PhD, Research Director, Nuclear New York, Inc.; Consultant, Energy Policy; Reiner Kuhr, Founder, Center for Academic Collaborative Initiatives (CAIC); and Ahmad Nofal, Co-founder, CAIC.  The rest of this section quotes the Executive Summary and includes my annotations.

The report clearly describes the issue.  At the same time load is expected to increase significantly, New York is proposing to rely on wind and solar that needs a firm dispatchable resource aka DEFR:

New York State has seriously underestimated the need for a large firm dispatchable source (A firm dispatchable source is always available and able to supply whatever additional electric output is needed) in its future decarbonized grid.  The growth in demand from the expected electrification of automobiles and the heating of buildings requires that such a resource operate for more than a third of the year to provide a grid that is reliable and avoids rolling blackouts. 

I believe that an hourly analysis is necessary.  The authors used a model that “performs an hour-by-hour analysis of the projected electricity demand in 2040 to show how the in-state sources assumed in NYSERDA’s scenario actually behave when serving this varying demand.”  The Center for Academic Collaborative Initiatives model “uses spreadsheet software to calculate, for each hour throughout the year, how the available energy sources, including battery storage and the DEFR, will be used to meet projected electric load.”

We have analyzed a Renewable-Focused Plan (RFPlan) with characteristics similar to scenarios describing the state’s future electric grid prepared by the NYS Energy Research and Development Authority (NYSERDA) for the Climate Action Council. (CAC). Using a new modeling tool that allows an hour-by-hour analysis of electric system behavior, we can see details of the hourly operation of each energy source, features not disclosed by existing models, including that used by NYSERDA. We can also estimate the cost to the purchasers of electricity and taxpayers of these scenarios.

The authors used the installed capacities included in the Integration Analysis Scenario 3 but the model dictates how the units operate.

The State’s Climate Leadership and Community Protection Act (CLCPA) requires that the electric grid be free of greenhouse gas emissions by 2040. NYSERDA’s scenarios create a plan which depends almost entirely on generating electricity with renewable sources. They retain existing nuclear plants, but no new ones are added.

The Executive Summary outlines the approach used in the Scoping Plan:

The Scoping Plan adopted by the CAC declares that “wind, water, and sunlight will power most of New York’s economy.”  While its focus is on renewable sources, the CAC does recognize the need for an additional clean source: “plan analysis and current studies show that the 2040 zero-emission goal requires between 15 and 45 gigawatts (GW) of electric power from dispatchable zero-emission resources”. However, NYSERDA finds that little more than 2% of the potential output of such a dispatchable emission-free resource (DEFR) will actually be used.

The authors explain that the Scoping Plan approach is based on a lot of wishful thinking:

Simple arithmetic makes this seem highly questionable. By 2040, NYSERDA and NYISO, the grid operator, estimate that building and transportation electrification will have expanded so that the grid will have a peak load in winter of 46-50 GW. Yet, even with land-based and offshore wind blowing at full capacity, no more than 35 GW will be available during winter evenings. Little or no excess capacity exists to charge the batteries, and, of course, solar won’t be available. Much more than 2% of the dispatchable source’s potential output has to be available to get through the winter without blackouts.

The CAIC model projects a dramatic difference in the use of DEFR:

Our hour-by-hour analysis shows that the firm dispatchable source has to run two-thirds of the year. The total load has increased from today. The summer peak has been replaced by a much higher winter peak. That greater demand is met by the extended operation of the DEFR which runs during most evenings in the cooler portion of the year. In fact, we find a capacity factor — the fraction of potential output actually used –of 14.4%. Our detailed results are shown below.

In my opinion, the CAIC analysis treats DEFR differently than the Integration Analysis does.  I believe that when the Integration Analysis determines which resources should be applied to meet load, they use DEFR as a last resort.  On the other hand, CAIC uses DEFR much more frequently.  That could be due to a difference in the hourly projections of wind, solar, energy storage, and load for the two models or presumptions in the models.

The final aspect of the modeling is a proposal for an alternative approach:

In this paper we suggest alternatives to NYSERDA’s plan that use baseload nuclear power along with a nuclear-powered firm dispatchable resource (DEFR) to ensure a reliable grid. Our plan costs one-third less than the RFPlan.

DEFR Implications

The CAIC model was also used to evaluate the placeholder Integration Analysis DEFR technology:

NYSERDA suggests, in its Integration Analysis, the use of hydrogen produced with renewable generated electricity to fuel the DEFR. We have examined this case and find that supplying sufficient energy to produce the required hydrogen would necessitate a 40% increase in the number of solar and wind installations, beyond those envisioned in the RFPlan. We are unable to estimate that system’s cost, since it would require creating a new infrastructure to produce, transport, and store a large supply of hydrogen during the summer for use in the winter. Analyzing such a construction project is beyond the scope of this study.

It is not clear how the Integration Analysis deals with hydrogen.  I think that they believe that they have included sufficient wind and solar resources to support hydrogen production using electrolysis.  However, I also think that the Integration Analysis has arbitrarily decided that half of the needed hydrogen will come from out of state.  I think that is a wildly optimistic presumption and very unlikely to occur.  In any event, no one can estimate how much this will cost using the documentation provided.

Nuclear Option

Not surprisingly Nuclear New York proposes nuclear energy as a DEFR candidate.  The Scoping Plan makes a token suggestion that nuclear should be considered but there is no serious attempt to compare nuclear relative to their other technology recommendations.  The report describes the Nuclear New York proposal:

The following scenarios, which we term “Brighter Future,” build upon a 2022 policy proposal

prepared by Nuclear New York, Clean Energy Jobs Coalition NY, and A Campaign for a Green Nuclear Deal. Recognizing that much of New York’s electricity demand is constant throughout the year, Brighter Future utilizes nuclear power as a principal source of clean power throughout the year, not simply as a DEFR when solar and wind are incapable of meeting the load. Nuclear becomes the backbone of the system, not simply a backup to intermittent, weather-dependent renewables.

These scenarios include 7 GW of new baseload nuclear power – adding more than twice what is

already operating in upstate New York – along with 26 to 30 GW of DEFR. Far fewer solar and wind installations are needed; we assume 80% fewer installations than in RFPlan. Our grid model presently does not allow for the DEFR to charge batteries. Since adding batteries that are seldom charged adds unnecessary costs, we exclude them from the Brighter Future scenarios. We will evaluate their inclusion in future research.

The first, Brighter Future 1, has 9 GW of offshore wind, the minimum called for in the CLCPA.

Brighter Future 2 has no offshore wind and costs significantly less. Not only does offshore wind add to the system cost, but it will be shut down, and possibly seriously damaged whenever frequent and increasingly intense storms arrive from the Caribbean and South Atlantic.

The following table from the report summarizes their findings and provides total per-unit generation costs for in-state resources under two DEFR capital cost scenarios: current-cost at ~$6,000/kW and low-cost at ~$3,000/kW.

I agree that nuclear must be used if New York wants to decarbonize safely and suspect that the all-in costs of nuclear will be less than wind, solar, energy storage, and DEFR.

DEFR Options

The report also includes a section describing alternative DEFR technologies.  The report evaluates a number of suggested options:

  • Fuel cells or gas turbines powered by “green hydrogen”: Hydrogen fuel cells or combustion power plants similar to those now burning fossil fuels could run on “green hydrogen” produced in electrolyzers powered by renewable energy, as NYSERDA has suggested. However, such a plan requires the creation of an expensive infrastructure to transport and store the hydrogen, as well as a buildout of additional costly, land-hungry solar and wind facilities to power the hydrolysis plants that produce the hydrogen. Using hydrogen for energy storage is challenged, also, by the fact that the round-trip power-to-gas-to-power (P2G2P) efficiency is just 40%.34 This means more than twice as much additional energy is needed as will be generated by the DEFR, with a commensurate drain on material resources, land, and societal wealth.
  • Long-duration storage: This might help, but currently no realistic scalable form of such storage exists. If it did, it, too, would require a vast expansion of generating capacity if solar and wind power charges whatever storage medium is used.
  • Carbon capture and storage (CCS) attached to gas-fired power plants: This only exists on an experimental basis. It would add substantial cost to the power it was attached to, and there would be upstream leakage of greenhouse gases and other pollutants to the environment. The captured CO2 would have to be disposed of, presumably underground, adding additional cost as well as potential environmental damage.
  • Nuclear power: This is the DEFR energy source used in each of our scenarios, as well as for additional baseload generation in the Brighter Future scenarios. Only nuclear power has been demonstrated to have the necessary capabilities, not only in the gigawatt-scale reactors now operating in New York State and elsewhere, but in the smaller reactors now under commercial development and operating on submarines and ships for over fifty years (many designed in New York State at the Knolls Atomic Power Laboratory).
  • Alternate nuclear options: Alternate ways of using nuclear energy will deserve consideration.  Nuclear reactors, like most energy sources, are most cost-efficient when they run more of the time to meet demand. We found that the DEFR would be operating at partial capacity for most of the year. A more cost-effective plan might use a smaller number of reactors running continuously to produce hydrogen which could be used in fuel cells. Another option would be to use nuclear facilities to produce carbon-neutral synthetic fuels.35,36 Full analysis of the cost and suitability of these options is beyond the scope of this paper, but they deserve serious study.

I agree with their findings.  I will only believe that the State seriously wants to reduce carbon emission if and only if they abandon the wind and solar approach and go nuclear.  As this report explains it is the only viable approach. 

Discussion

The report lists some limitations of the modeling and their research.  Those include: a simplified view of the in-state transmission system, absence of reserves mandated by reliability requirements, fixed cost assumptions, a couple of potential refinements for the nuclear proposals, and optional DEFR designs.

I caution readers that this analysis is not as sophisticated as the work that NYISO does.  Transmission constraints will definitely affect the outcome of projections.  NYISO projections handle all the complications associated with those constraints.  I do not think that the Integration Analysis includes sophisticated transmission constraints either. 

Despite its limitations I do not believe that these limitations affect the general outcomes: DEFR is needed and nuclear is the best option available because it markedly reduces the amount needed.

Dunkelflaute

Dunkelflaute is a “German term that is used in the energy industry to describe a period of multiple consecutive days in which low or minimal energy can be generated by renewable energy sources, such as solar or wind”.  Of course this describes the conditions that drive the need for DEFR. 

In response to comments I submitted on this topic to the  Proceeding on Motion of the Commission to Implement a Large-Scale Renewable Program and a Clean Energy Standard – Zero Emissions Target Case No. 15-E-0302author Leonard Rodberg sent me the following information:

Your analysis of the frequency of overcast and wind lull (“Dunkelflaute”) conditions is impressive and important. However, there are much larger problems with the State’s renewable-focused plan which they and everyone else seem to be ignoring.

On many winter nights in a fossil-free 2040, there will only be wind and the remaining nuclear and hydro to power the grid. No sun, of course, and batteries uncharged since there’s no excess power during the day to charge them. The result will be many nights when the grid shuts down unless a gap-filling clean firm source is available.

In fact, it’s even worse than that. Both NYSERDA and NYISO project winter peaks of 46-50 GW, but even with their projected wind power at its peak output, there’s just 35 GW available (see the graph below). No one seems to have bothered to add these up, and the model they’re using hides it .

The gap is large and is present much of the year. I’ve used an hourly dispatch model to show what’s really likely to happen in that situation. It’s shown and explained here. (This is a reference to the report described in this article.)

I included this because I think it reinforces the position I wanted to publicize.  DEFR is necessary and the State’s analyses are not treating it well.

Conclusion

I concur with the report conclusion:

We have shown, with a modeling tool capable of performing an hour-by-hour analysis, that

dispatchable emission-free resources are essential to meeting the goal of a reliable, zero-emission grid.  Further, this clean dispatchable source must be able to run a large portion of the year. The only such source likely to be available within the next several decades is nuclear power. The state will further benefit from the deployment of additional baseload nuclear power. This combination of nuclear resources will be more cost-efficient and environmentally-protective than an alternative focused on intermittent weather dependent sources.

Finally note that is another analysis that destroys the Climate Action Council argument that New York can rapidly move away from fossil fuels and instead be fueled completely by the power of the wind, the sun, and hydro using  technologies available at this time.  That is simply not true.

Initial Impression of Clean Energy Standard Biennial Status Report

The Climate Leadership & Community Protection Act (Climate Act) requires that the Public Service Commission (PSC) issue a review for notice and comment that considers “(a) progress in meeting the overall targets for deployment of renewable energy systems and zero emission sources, including factors that will or are likely to frustrate progress toward the targets; (b) distribution of systems by size and load zone; and (c) annual funding commitments and expenditures.”  The recently released Clean Energy Standard Biennial Review Report contains a lot of information that will be addressed in future posts.  This post provides my first impression of the document.  Spoiler – there is no chance that the 2030 mandate for the 70% renewable electric energy will be met.

I have followed the Climate act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% reduction by 2030, a requirement for 70% renewable energy for electric production by 2030, and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022. 

Biennial Report

The Introduction to the report states:

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

The footnote for the first sentence states: PSL §66-p(3). PSL §66-p(4) provides the Commission with authority to “temporarily suspend or modify” the obligations created by the Program if, after conducting a hearing, it finds that the Program “impedes the provision of safe and adequate electric service,” “is likely to impair existing obligations and agreements,” and/or is related to “a significant increase in arrears or service disconnections.”  The Introduction goes on:

Section 1 identifies the key regulatory actions taken to date to support renewable energy deployment in New York, including the establishment of the CES. Section 2 summarizes progress to date in achieving the CLCPA and CES goals in terms of current contributions of operational renewable energy systems and zero-emission sources to the State’s energy portfolio. Section 3 offers a detailed assessment of major factors that have affected and will likely continue to affect progress towards the goals. Section 4 reports on the pipeline of contracted renewables from previous Tier 1 and offshore wind solicitations. Section 5 accesses the amount of renewables that would need to be procured, under the CES or a modified version of the program, to achieve the 70% goal and recommends adjustments to NYSERDA’s procurement authorization that may be necessary to do so. Section 6 considers other programmatic options for accelerating development and construction of renewable energy resources. Policy options and proposals under consideration in this Report are limited to the CES itself.

I could do a post on each section and may end up doing that.  It is encouraging that the PSC acknowledges the safety valve mechanism in Public Service Law §66 that I have mentioned on many occasions. Optimistically could this signal recognition that if the aspirational scheduled mandates of the Climate Act are not feasible that the schedule must be modified?

Progress to Date

Section 5 summarizes the “Path to the 70% goal”.  The description of the Table 8 “Summary of progress” states:

Under the base case load forecast assumption of 164,910 GWh by 2030 as described above, the 70% goal equates to 115,437 GWh. Table 8 below summarizes the contributions towards the goal from currently operational and contracted renewables, as set out above in Section 2 and Section 4 of this Report. In addition, it projects 10 GW of distributed generation by 2030 secured outside the CES framework.

I will follow up with a post addressing the assumptions used to calculate the numbers in Table 8.  Sections 2 and 4 described how operational and contracted/awarded renewable estimates were projected and that discussion is also worthy of its own post.  At this time it is notable that one of the key points in the report is the admission that contracted projects don’t always get built.   

The report describes Table 8:

With these conservative assumptions, the expected amount of renewable generation from operational and awarded/contracted sources in 2030 totals 73,292 GWh. Under the base case forecast for the 2030 statewide electric load, there is a renewable energy supply deficit of 42,145 GWh that would have to be addressed through future procurements in order to reach the 70% goal amount of 115,437 GWh.

Consider these numbers in context.  There is an admitted gap of 42,145 GWh which is greater than the total operational renewable generation in 2022, 2022 imports and operational after 2022 (37.692 GWh).  Trying to cover that gap is an ambitious challenge.

2030 Projected Renewables

The Biennial report proposes to double down on building renewables to cover the gap and meet the target. 

To fill the expected gap, three Tier 1 annual solicitations – those for 2024, 2025, and 2026 – are currently scheduled and will seek projects capable of deploying by 2030. However, the amounts procured in these solicitations would need to be adjusted to secure the needed quantity of 42,145 GWh. The analysis suggests NYSERDA would have to procure approximately 14,048 GWh per solicitation, assuming no project attrition, or, assuming a 30% attrition rate, an amount of 20,068 GWh per solicitation. This volume is significantly higher than the annual procurement quantity of 4,500 GWh per Tier 1 solicitation (before attrition) estimated in the 2020 CES White Paper and 2020 CES Order.

The best efforts of the State to date for renewable solicitations are far lower than what is needed.  The report admits that “the maximum annual new project development rate would likely be in the range of 6,000-7,000 GWh per year at least in the near term” and that is contingent on meeting a number of conditions.  Table 9 below describes what the report argues is feasible.

Even under the revised assumptions the PSC projects that the 70% renewable energy goal will not be achieved until 2033 when the historic renewable resource deployments are considered.

Conclusion

The State has never done a feasibility analysis to prove that their plan to rely on wind and solar will work.  The Climate Act deadlines were set arbitrarily by politicians so achieving that is another level of wishful thinking.

Get out the popcorn.  Reality is catching up to the Climate Act net-zero transition.  This report is the first indication that things are not going as planned.  How will the Hochul Administration handle the obvious need to relax the deadlines? 

Stay tuned for future articles on this important report.

Pew Research: How Americans View National, Local and Personal Energy Choices

A version of this article was published at Watts Up With That.

According to Pew Research, Americans still want renewable energy, but support is waning.  This comes as the impacts of the Climate Leadership & Community Protection Act (Climate Act) are becoming clear.  It would be interesting to see a similar poll for New York residents.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  Since then, State agencies and the legislature have been attempting to implement the plans.

How Americans View National, Local and Personal Energy Choices

The Pew Research Center released the results of its survey on June 27, 2024

How Americans View National, Local and Personal Energy Choices

Most Americans want more renewable energy, but support has dipped. Interest in electric vehicles has also declined

By Alec Tyson and Brian Kennedy

The planet’s continued streak of record heat has spurred calls for action by scientists and global leaders. Meanwhile, in the United States, energy development policy is being hotly debated on the national and local levels this election year. How do Americans feel about U.S. energy policy options, and what steps are they willing to take in their own lives to reduce carbon emissions? A new Pew Research Center survey takes a look.

Among the major findings:

There’s been a decline in the breadth of support for wind and solar power. The shares who favor expanding solar and wind power farms are down 12 percentage points and 11 points, respectively, since 2020, driven by sharp drops in support among Republicans.

Interest in buying an electric vehicle (EV) is lower than a year ago. Today, 29% of Americans say they would consider an EV for their next purchase, down from 38% in 2023.

Still, a majority of Americans (63%) support the goal of the U.S. taking steps to become carbon neutral by 2050. When asked which is the greater priority, far more Americans continue to say the country should focus on developing renewable energy than fossil fuel sources (65% vs. 34%).

The survey, conducted May 13-19 among 8,638 U.S. adults, finds a fairly modest share of U.S. adults (25%) say it’s extremely or very important to them personally to limit their own “carbon footprint.” Far more give this middling or low priority.

These findings illustrate how large shares of Americans back more renewable energy that would decrease overall carbon emissions. Still, this general orientation does not necessarily translate into strong commitment to reducing personal carbon emissions or interest in buying an EV.

Read more: https://www.pewresearch.org/science/2024/06/27/how-americans-view-national-local-and-personal-energy-choices/

Maybe it is just me but the lead sentence claim that record heat is spurring action smacks of bias.  I checked the description of how they did the survey to see if my concerns were warranted:

Pew Research Center conducted this study to understand Americans’ views of energy issues. For this analysis, we surveyed 8,638 U.S. adults from May 13 to 19, 2024.

Everyone who took part in the survey is a member of the Center’s American Trends Panel (ATP), an online survey panel that is recruited through national, random sampling of residential addresses. This way, nearly all U.S. adults have a chance of selection. The survey is weighted to be representative of the U.S. adult population by gender, race, ethnicity, partisan affiliation, education and other categories. Read more about the ATP’s methodology.

Here are the questions used for this report, along with responses, and its Methodology.

The questions used for the survey were not overtly biased.  Nothing like “In order to save the planet from imminent doom are you in favor of solar farms?”  My only reservation is that these questions were part of a bigger survey, so it is not clear if previous questions primed the pump towards climate impact alarm.  One other point is that the methodology was different from most surveys.  Instead of a phone survey the Pew Research Center has established the American Trends Panel “a nationally representative panel of randomly selected U.S. adults who participate via self-administered web surveys.”  I have no opinion if this affects survey results.

Rather than just provide the results of the survey the Pew website description addresses the question of what’s behind the declines in support for wind and solar.

Declines in public support for renewable energy have been driven by Republicans and Republican-leaning independents, whose support started to fall sharply after President Joe Biden took office in early 2020.

  • 64% of Republicans say they favor more solar panel farms, down from 84% in 2020.
  • 56% of Republicans say they favor more wind turbine farms, a 19-point drop from 2020.

Over this same time period, views among Democrats and Democratic leaners on these measures are little changed, with large majorities continuing to support more wind and solar development.

In some cases, gaps between Republicans and Democrats over energy policy now approach the very wide partisan divides seen over the importance of climate change.

In May 2020, Democrats were 26 points more likely than Republicans to say the country’s priority should be developing renewable energy (91% vs. 65%). Four years later, that gap has ballooned to 49 points, due almost entirely to changing views among Republicans – 61% of whom now say developing fossil fuels like oil, coal and natural gas should be the more important priority.

However, the authors do admit that it is not just political affiliation:

But changes in attitudes about policies that would reduce carbon emissions are not solely the result of more negative views among Republicans. For instance, the share of Democrats who say they are very or somewhat likely to consider an EV for their next car purchase has declined from 56% to 45% in the last year. And the share of Democrats who call climate change a very big problem for the U.S. has declined from 71% in 2021 to 58% today.

New York’s Climate Leadership & Community Protection Act (Climate Act) mandates massive changes to the energy choices of New Yorkers that require action today.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition.  One over-riding conclusion based on my work and discussions with others who share my concerns is that the majority of New Yorkers have no clue what is coming at them. 

Nationally the mandates and potential impacts are much less imminent, I believe that a big part of the decline in support of wind and solar is increased knowledge.  The survey includes more detailed questions regarding solar developments – Would solar development make the landscape unattractive, take up too much space, bring in more tax revenue, and lower the price you pay for electricity.  I believe that answering those questions requires personal knowledge and in my personal experience it has only been in the last several years that I have seen solar developments.  Having seen them I doubt many would think they are attractive and do not take up too much space.  The more knowledge people have the lower the favorability in my opinion.

The survey also addresses electric vehicles. 

Amid a major policy push at the federal level for electric vehicles, Americans are unenthusiastic about steps that would phase out gas-powered vehicles.

In March of this year, the Biden administration announced a rule aimed at dramatically expanding EV sales. Overall, 58% of Americans say they oppose these rules that would make EVs at least half of all new cars and trucks sold in the U.S. by 2032. Republicans overwhelmingly oppose this policy (83%). Among Democrats, 64% support these rules to expand EV sales, while 35% say they oppose them

Source: https://www.pewresearch.org/science/2024/06/27/how-americans-view-national-local-and-personal-energy-choices/

In support of my belief that knowledge spurs skeptical concerns note the following results for a question about EV reliability:

As more people hear about electric vehicle experiences the reality of problems with the technology become evident.

The survey also included questions about personal carbon footprints.

Discussions about reducing carbon emissions often include the everyday actions people can take to reduce the amount of energy they use. One-in-four Americans say it is extremely or very important to them personally to limit their own “carbon footprint.” Larger shares say this is either somewhat (42%) or not too or not at all (32%) important to them.

There is one important aspect of energy choice that was not included in the survey.  What about the costs?  The follow up questions for wind and solar development included a question asking whether respondents thought that those developments would reduce electricity prices.  There were also questions about electric vehicle cost to purchase and refuel them.  Nothing about overall costs was included.  I have yet to see a poll that indicates that people are willing to pay much for the energy transition being forced down our throats.

The description of the survey claims that “large shares of Americans back more renewable energy that would decrease overall carbon emissions.”  It also admits that “this general orientation does not necessarily translate into strong commitment to reducing personal carbon emissions or interest in buying an EV”.  If the willingness to pay aspect had been incorporated into the poll, I have no doubts that support for wind and solar would drop significantly.  I am confident that as more people become aware of the hidden costs of renewable energy the inevitable result will be much less support.