Cassadaga Wind Concerns

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

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

I have followed the Climate Leadership & Community Protection Act (Climate Act)since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 450 articles about New York’s net-zero transition. I have over 40 yers experience with New York energy and environmental issues.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

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

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

 Ellenbogen Summary

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

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

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

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

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

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

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

The article

By Walker Orenstein

In the Minnesota Star Tribune states:

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

She gave up once the blades arrived.

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

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

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

Cassadaga Wind Farm Energy Contract

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

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

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

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

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

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

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

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

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

Conclusion

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

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

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

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

In the first two months of 2024 the New York State Department of Environmental Conservation (DEC) and the New York Energy Research & Development Authority (NYSERDA) worked on the  New York Cap-and-Invest (NYCI) Program stakeholder engagement process requesting comments on the pre-proposal outline of the regulations.  Since then, nothing much has happened until a webinar was held on August 15, 2024, where DEC and NYSERDA presented “a draft proposed framework for guiding the allocation of these funds and identification of potential areas that could receive investments.” DEC and NYSERDA also posed a series of questions seeking public feedback. The webinar presentation and recording are now available.

I have followed the Climate Leadership & Community Protection Act (Climate Act)since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 450 articles about New York’s net-zero transition. I have extensive experience with air pollution control theory, implementation, and evaluation of results having worked on every cap-and-trade program affecting electric generating facilities in New York including the Acid Rain Program, Regional Greenhouse Gas Initiative (RGGI) and several nitrogen oxide programs.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

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

Cap-and-Invest

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

The program recommended by the CAC works by setting an annual cap on the amount of greenhouse gas pollution that is permitted to be emitted in New York: “The declining cap ensures annual emissions are reduced, setting the state on a trajectory to meet our greenhouse gas emission reduction requirements of 40% by 2030, and at least 85% from 1990 levels by 2050, as mandated by the Climate Leadership & Community Protection Act (Climate Act).”  In addition to the declining cap, it is supposed to limit potential costs to New Yorkers, invest proceeds in programs that drive emission reductions in an equitable manner, and maintain the competitiveness of New York businesses and industries.

Late last year DEC and NYSERDA released the pre-proposal outline of issues that included a long list of topics.  The Agencies said that they were “seeking and appreciate any feedback provided on these pre-proposal program leanings to inform final decisions in the State’s stakeholder-driven process to develop these programs.”  In a post describing my comments I provided additional background information and my concerns.  In late June I described my letter to the editor of the Syracuse Post Standard that argued that the delays were primarily due to staffing issues.  In my submittals I have expressed two primary concerns.  The first is that the sources that are responsible for compliance with NYCI have very few options for on-site control so must rely on somebody else to make the investments for zero-carbon emitting resources to displace their operations.  The second concern is that the NYCI feature that “ensures annual emissions are reduced” must be integrated with the investments needed for those zero-carbon emitting resources.  If there are inadequate investments, then the only option for the affected sources is to reduce or stop operations.  If the affected source is an electric generating station, there could be reliability implications.

Public Webinar August 15, 2024

The meeting description said:

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

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

The agenda included the following items:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

.

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

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

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

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

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

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

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

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

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

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

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

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

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

Submitting Comments

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

online at:www.capandinvest.ny.gov

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

Attn: NYCI Investment Planning

17 Columbia Circle

Albany, NY 12203-6399

Discussion

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

In response to questions the webinar claimed that draft rules would be out later this year and that appropriations and spending of NYCI proceeds would begin in the next fiscal year beginning April 2025.  In the stakeholder engagement process earlier this year DEC and NYSERDA claimed they would propose regulations by summer and the final rules would be in place by the end of the year.  This update suggests that the regulations will be pushed back.  Although I believe that staffing issues are part of the reason for the delays, the political underpinning of the Climate Act should not be forgotten.

The Hochul Administration is certainly cognizant of costs for environmental initiatives.  On June 7, Governor Hochul explained that she reversed the decision to proceed with the New York City congestion pricing plan because of costs. At the Energy Access and Equity Research webinar sponsored by the NYU Institute for Policy Integrity on May 13, 2024 Jonathan Binder stated that the New York Cap and Invest Program would generate proceeds of “between $6 and $12 billion per year” by 2030.  Note that the current NYCI proposal outline analyzed allowance prices starting at $23 in 2025 with 5% escalation for 2026, and an increase to $54 in 2027, escalating by 6% annually thereafter.  Note that the cost increase comes after the next gubernatorial election year.  The New York State legislature elections are coming up in November.  I am now convinced that a major reason for the NYCI regulation delays is related to those elections. 

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

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

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

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

Conclusion

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

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

Renewable Generation Is Not Resilient

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

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

Solar Inverter Resiliency Issue

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

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

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

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


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

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

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

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

Ellenbogen explains that this is a problem:

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

He continues:

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

Ellenbogen summarized:

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

Conclusion

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

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

Commentary on Recent Articles 21 August 2024

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

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

Reasons to Oppose Renewable Energy

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

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

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

She goes on to make an elegant point about affordability:

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

I also endorse her moral accountability argument:

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

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

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

The entire article is well worth reading.

Farming, Mining, and Energy Development

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

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

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

Or we had to choose not to eat meat.

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

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

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

Alex Epstein – Sound Bites on Fossil Fuels

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

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

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

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

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

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

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

Weather Trend Confounding Factors

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

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

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

Net-Zero Test

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

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

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

She explains:

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

Time of Use Tariffs

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

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

Pragmatic Recommendations for Climate Act Review

Note – This post was revised to clarify my recommendation that the Climate Action Council should propose affordability and reliability criteria to explain the Council should work with the PSC and NYISO for consideration in a stakeholder process similar to the development of the Scoping Plan on 8/21/24.

The Business Council of New York (BCNY) recently  shared a set of concerns and recommendations — supported by a diverse group of business and labor interests — addressing the state’s climate change response efforts, driven by mandates in the Climate Leadership & Community Protection Act (Climate Act).  This post describes the concerns and recommendations in the BCNY statement and proposes a path forward for review of the Climate Act.

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

Overview

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

Recently three reports have come out that raise specific concerns about Climate Act implementation: schedule ambition, costs to implement, and electric system reliability risks.

The New York State Comptroller Office released an audit of the NYSERDA and PSC  implementation efforts for the Climate Act titled Climate Act Goals – Planning, Procurements, and Progress Tracking (“Comptroller Report”).  The audit found that: “The costs of transitioning to renewable energy are not known, nor have they been reasonably estimated”.

The Public Service Commission (PSC) recently released the Clean Energy Standard Biennial Review Report (“Biennial Report”) that compares the renewable energy deployment progress relative to the Climate Act goal to obtain 70% of New York’s electricity from renewable sources by 2030 (the 70% goal).  It found that 2030 goal will likely not be achieved until 2033.

The New York Independent System Operator (NYISO) 2023-2042 System & Resource Outlook (“Resource Outlook”) described issues that threaten reliability and resilience of the current and future electric system. The report described current and future challenges for the electric system.  The findings suggest that there will be significant reliability risks for the Climate Act transition.

Business Council of New York Statement

BCNY released their statement because it represents concerns expressed by various impacted businesses across New York about “the achievability of key Climate Act mandates and what that means for the future reliability and cost of the state’s energy system.”  The statement calls for the “state to identify and make necessary mid-course corrections based on updated information and significant economic and market changes.”   The statement argues that “These steps are essential to avoid significant unintended impacts on the well-being of New Yorkers and on the state’s economic competitiveness.”    They note that “Importantly, we believe that New York can continue to be a leader in state-level climate policy, but it needs to take a workable, affordable approach to meeting its energy and emission goals.”

The statement notes that the Climate Act implementation process has not provided a “comprehensive, publicly accessible assessment of implementation costs, the comparative costs of policy alternative programs, and the impact of new policies on residential and business energy consumers.”  This echoes the Comptroller Audit finding of inadequate cost information. 

The statement also describes concerns about “the practical achievability of key CLCPA provisions and the consequences of basing major policy decisions on unworkable statutory mandates”.  The Biennial Report notes that one of the statutory mandates will likely not be achieved.  

The statement takes pains to note that they are not opposed to many of the proposed control strategies.  However, “the state needs to ensure that its push toward emission reductions and the electrification of major sectors are technically and economically achievable.”  This is one of the findings of the Resource Outlook.

The statement argues that “implementation challenges call for a reassessment of the underlying statutory mandates.”  It notes that they want to work with the Administration, state legislators, and other climate stakeholders to address the issues raised.  However, a specific path forward is not proposed.  I propose such a path forward below.

Recommendation for Climate Act Review

Although it has received little notice, there is a provision for renewable energy programs that should be the foundation of the recommended reassessment.  The Biennial Report refers to New York Public Service Law  § 66-p (4). “Establishment of a renewable energy program” that states: “The commission may temporarily suspend or modify the obligations under such program provided that the commission, after conducting a hearing as provided in section twenty of this chapter, makes a finding that the program impedes the provision of safe and adequate electric service; the program is likely to impair existing obligations and agreements; and/or that there is a significant increase in arrears or service disconnections that the commission determines is related to the program”. 

The essential first step for reassessment consideration is definition of the safety valve criteria in §66-p (4).  What are the criteria for unsafe and inadequate electric service, impairment of existing obligations and agreements, and unacceptable increase in arrear or service disconnections?  In my opinion, the Climate Action Council with the PSC and NYISO should propose suitable criteria for consideration in a stakeholder process similar to the development of the Scoping Plan.

The next step would be to provide the data necessary to determine the criteria for unsafe and inadequate electric service, impairment of existing obligations and agreements, and unacceptable increase in arrears or service disconnections.  Given this legal provision it is appropriate that the information be tracked somewhere.  The BCNY statement recommended an “accessible and understandable “dashboard” of the state’s climate change efforts, including a comprehensive accounting of direct state spending and state “directed” spending, the source of funds and their use, and the impact of these expenditures on achieving GHG emission reduction and renewable energy production goals.”  The §66-p (4) criteria parameters should be included in the dashboard.

Conclusion

The three agency reports raise legitimate reasons to be concerned about the mandates and schedule of the Climate Act.  The BCNY statement echoes those concerns and recommends a review and consideration of mid-course corrections.  There is a legal provision to “temporarily suspend or modify the obligations” of a renewable energy program that defines criteria consistent with the concerns raised by the BCNY, the PSC Biennial Report, the Comptroller Report audit of Climate Act implementation, and the NYISO Resource Outlook.  If the §66-p (4) criteria are explicitly defined and compared to observed data, it would form the basis for a pragmatic review of the Climate Act.

Future Role of Nuclear Power Worries Environmental Advocates

Update 8/26/24: Riverhead local published my response to the original op-ed

In a recent article describing a new category of generating resources called Dispatchable Emissions-Free Resources (DEFR) I noted there still are people who maintain that existing technologies—led by solar and wind—can solve the climate crisis.  A recent op-ed titled “With New York’s climate action goals in question, governor’s comments on future role of nuclear power worry environmental advocates” at Riverhead Local provides an example.

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 or organization I have been associated with, these comments are mine alone.

Overview

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

Three recent reports all have suggested that implementation of the Climate Act is not going as planned and that reassessment is necessary.  The Public Service Commission (PSC) Clean Energy Standard Biennial Review Report found that the 70% renewable energy goal will likely not be achieved until 2033.  The New York State Comptroller Office Climate Act Goals – Planning, Procurements, and Progress Tracking audit found that the PSC and NYSERDA implementation plans did not comprise all essential components, including “assessing risks to meeting goals and projecting costs.”  The New York Independent System Operator (NYISO) 2023-2042 System & Resource Outlook described issues that threaten reliability and resilience of the current and future electric system.

Dispatchable Emissions-Free Resources

One of the most important reliability issues is the need for a new category of generating resources called Dispatchable Emissions-Free Resources (DEFR) necessary for a future grid that depends upon wind, solar, and energy storage resources. Reputable 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.  Despite the overwhelming consensus of the organizations responsible for keeping the lights on that DEFR is needed there are people who believe otherwise.

One such person is Karl Grossman.  According to his bio published with the op-ed:

Karl is a veteran investigative reporter and columnist, the winner of numerous awards for his work and a member of the L.I. Journalism Hall of Fame. He is a professor of journalism at SUNY at Old Westbury and the author of eight books.

The basis of Grossman’s belief is Dr. Mark Z. Jacobson’s 2023 book “No Miracles Needed: How Today’s Technology Can Save Our Climate and Clean Our Air.”   Grossman interviewed Jacobson and quoted him as saying: “Whether New York can reach the 70% goal by 2030 is a matter of social and political willpower. It is not a question of technology or economics.” 

Grossman describes Jacobson’s claims, but I am not going to respond to those claims in detail.  In my recent article about DEFR I explained why I know that Jacobson is wrong.  In brief, I found six analyses describing the need for new technology: the Integration Analysis, New York Department of Public Service (DPS) Proceeding 15-E-0302 Technical Conference, NYISO Resource Outlook, Richard Ellenbogen, Cornell Biology and Environmental Engineering, and Nuclear New York.  Jacobson and his protégé Dr. Robert Howarth frequently refer to their “peer-reviewed” work as validation but neglect the rebuttal peer-reviewed responses to their work and the many other peer-reviewed analyses that show DEFR is needed.  Finally, I also found three books that refute the Jacobson book and his claims that the energy transition can be accomplished with no new technologies at low cost with large benefits.

Environmentalist Responses

I recently noted that Governor Hochul seems to be floating the idea that reassessment is necessary.  Grossman noted that Newsday headlined a two-page spread two weeks ago: “Hochul Says New York Won’t Meet 2030 Climate Goal.” In the article, Newsday cited Gov. Kathy Hochul’s comments in an Albany Times Union newspaper podcast.

“We’re gonna get to our goals, but if we miss it by a couple of years—which is probably what’ll happen—the goals are still worthwhile,” Hochul said. But we have to think about the collateral damage of all of our major decisions… either mitigate them or you have to rethink them.” In the podcast, she also termed herself as “a staunch environmentalist.”

The Grossman op-ed described how environmentalists are reacting.  Not surprisingly they still claim that the state has not done enough on renewable energy.

Judith Enck, for seven years regional administrator of the U.S. Environmental Protection Agency for an area that includes New York State and before that deputy secretary for the environment for two New York governors, said delaying the 70% goal “is a terrible decision by the governor. I hope she revisits it. We’re in a climate crisis. She says things have changed—and they have: the climate crisis has gotten worse. The governor should look at ways to accelerate meeting the goals, not delaying them.” Renewable energy, she said, is not a priority for state government.

Liz Moran, New York political advocate for the group Earthjustice, said: “The administration has been appearing to slow walk it from the jump. It’s a fear-based approach rather than a brave and bold approach that we need in the face of this crisis.” 

“We’re certainly not ready to wave the white flag,” said Julie Tighe, president of the New York League of Conservation Voters.

Environmental advocates such as these ignore or disparage analyses such as the NYISO 2023-2042 System & Resource Outlook that describes issues that threaten reliability and resilience of the electric system.  I recently described how the proposed transition that relies on wind and solar exacerbates their concerns. Unfortunately, the document is full of technical jargon and politically correct terminology, so the full implications of this analysis are not readily apparent.  NYISO cannot bluntly say this cannot work as proposed on the schedule mandated but that is the underlying message.

Environmental advocates also ignore New York’s role in this global problem.  Using GHG emissions data from Our World In Data I looked at recent NY emissions with global 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.  Overall, New York’s emissions are less than a half a percent of global emissions.  This does not necessarily mean that we should not do something, but it does mean that meeting the arbitrary goals of the Climate Act will not have a meaningful impact on global warming impacts.

Grossman’s op-ed goes on:

Meanwhile, Politico published a report in May headlined “New York policymakers thaw on nuclear energy.” The piece by Marie J. French began: “Gov. Kathy Hochul has cracked the door open to the potential for new, small nuclear power plants as a way for the state to try to meet its ambitious climate coals.”

The article told of this happening “at a private dinner with environmentalists April 29, according to two attendees who spoke on the condition of anonymity because of the private conversations. It’s not the first time that her administration has raised the idea. One of her top aides suggested as much earlier this year.”

Enck said last week: “I think the governor even speculating on nuclear power in New York is trouble.” Enck spoke of how decades were spent in “shutting down the Indian Point nuclear plants” 25 miles north of New York City. We “shouldn’t promote the same thing again.”

Nuclear is the only proven DEFR technology that can be expanded sufficiently to fulfill the energy requirements of the Climate Act goals.  Nuclear energy generates zero-emissions electricity, provides firm power that does not require supplemental ancillary transmission support, has low land-use requirements, and requires less transmission development than wind and solar.  The dangers of nuclear are consistently over-hyped.   Bill Gates has pointed out that “nuclear energy, in terms of an overall safety record, is better than other energy.”  It is a mystery to me why any environmental advocate continues to harbor this irrational fear of nuclear power and consider its use troubling,

Discussion

Grossman concludes:

The central message of Jacobson’s “No Miracles Needed” book is how existing technologies—led by solar and wind—can solve the climate crisis, and he emphasizes how nuclear power is not needed and also investing in it would obstruct a transition to green renewable energy.

I conclude Grossman has naively backed the wrong source for this op-ed.  Even the Climate Act Scoping Plan acknowledges the need for the new DEFR technology directly contradicting Jacobson’s primary claim.  The Scoping Plan also contradicts all the other cost, schedule, and technology requirement claims made by Jacobson.  The NYISO 2023-2042 System & Resource Outlook findings are consistent with the Scoping Plan.  In my opinion, the arguments of anyone who does not face any repercussions if proven wrong should be given much less weight than arguments from those who have responsibilities.

With regards to the nuclear power recommendations Grossman is also wrong.  The article does not provide any rationale for not developing nuclear other it would obstruct the transition to green renewable energy.  The fact is that France successful cut its GHG emissions using nuclear power, but no jurisdiction has managed similar electric sector reductions relying on wind and solar.  As a utility meteorologist with over 40 years’ experience I think the variability of wind and solar is an insurmountable challenge for a reliable electric grid.  In my opinion, one of the advantages of nuclear is that it would preclude the need for “green renewable energy”.

Conclusion

On August 5 Governor Hochul announced a Future Energy Economy Summit that will “gather feedback on strategies to accelerate renewable energy deployment and explore the potential role of next generation clean energy technologies”.  Grossman’s op-ed is the first article I have seen to suggest that nuclear power should not be one of the next generation clean energy technologies.  In my article describing the announcement of the summit I noted that it will be interesting to see how legislators, the Big Green NGOs, climate activists, and the renewable energy shills react to nuclear power. Based on this article it appears Big Green NGOs and climate activists will not acknowledge that nuclear and other pragmatic considerations are necessary for the Climate Act implementation.

Meredith Angwin – Shorting the Grid

Update 8/11/2024: A colleague of mine who is much more aware of New York grid governance contacted me.  He said that the New York State Reliability Council should have been cited earlier in the article. Our New York reliability rules are more stringent than other Regional Transmission Organizations. and the Council is addressing all of the technical issues that this book highlights as concerns.

My background in the electric sector has always been associated with power plant operations.  However, the relationship between power plants and the electric grid was something that I really did not bother to understand because it was mostly irrelevant to my responsibilities.  In recent years I started to try to understand more about how the plants are dispatched and became increasingly uncomfortable with what seemed to be happening.  Meredith Angwin’s book Shorting the Grid – The Hidden Fragility of Our Electric Grid has been a revelation.  It is an easy-to-understand description of the arcane world of current electric grid operations, and it explained why some of the things I see happening are leading to a more fragile electric grid.

New York’s Climate Leadership & Community Protection Act (Climate Act) mandates a massive change to the electric system which is complicated by New York’s electric grid structure.  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 organization that 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% GHG reduction by 2030, a 70% electric system renewable energy mandate 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 used to reduce greenhouse gas emissions.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized and approved by the CAC at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, Public Service Commission orders, and legislation.  

However, recent reports have raised problems with the implementation process.  The New York Independent System Operator (NYISO) recently released the 2023-2042 System & Resource Outlook notes that there are complications that the proposed New York electric system must address related to reliance on weather-dependent wind and solar resources.  My particular concern is that the NYISO planning process must not only identify technological solutions but also devise market mechanisms consistent with New York’s electric energy market. 

Meredith Angwin describes herself in the book:

As a working chemist, Meredith Angwin headed projects that lowered pollution and increased reliability on the electric grid. Her work included pollution control for nitrogen oxides in gas-fired combustion turbines, and corrosion control in geothermal and nuclear systems.

She was one of the first women to be a project manager at the Electric Power Research Institute. She led projects in renew- able and nuclear energy.

In the past ten years, she began to study and take part in grid oversight and governance. For four years, she served on the Coordinating Committee for the Consumer Liaison Group associated with ISO-NE, her local grid operator. She teaches courses and presents workshops on the electric grid.  She is also an advocate for nuclear energy. Finally, she is the author of the Electric Grandma blog.

Angwin’s book describes how the electric grid works and current problems facing the system.  It concludes with a discussion of what kind of grid we should strive to have.  I thought that her framing of grid goals was very good.  She said that we need to ask ourselves two practical and moral questions.

  • Do we deserve to have electricity available at all times?  Or is an intermittent, fragile grid good enough?
  • How important are the various aspects of our electric supply?  That is, what are the values we assign to things like reliability, cost, low environmental impact, and low carbon dioxide releases?

I am going to review the book with respect to those questions in the context of the Climate Act and New York energy policy.  The chapters are grouped into five sections.

Angelic Miracles and Easy Problems

The first section encompasses ten chapters of the book that describe the shift in electric grid governance over the last few decades.  When I started work at Niagara Mohawk Power Corporation (NMPC) in 1981 the electric grid was operated by vertically integrated utilities.  After the 1965 blackout in the Northeast the utilities realized that they needed a state-wide transmission operator, and the New York Power Pool was formed.  The state’s utility companies owned and operated generating assets and the Power Pool dispatched the plants.  The NYS Public Service Commission and the utilities emphasized reliability.  When I joined NMPC, management was very proud that they had coal, oil, hydro, and nuclear generating stations (at the time natural gas was too expensive to use for power production).  Not only that, the coal and oil plants had alternate ways to supply fuel to the plants.  The result was a robust and stable generating system and grid.

A summary of how electric deregulation occurred in New York describes the transition away from vertically integrated utilities in New York.  New York’s legislature thinks they know how to deal with energy policy and they passed legislation that had the goal of a competitive wholesale market by 1997 and a competitive retail market by 1998. As part of this legislation all utility companies were required to restructure to enable these changes.  Angwin describes how regional transmission organizations (RTOs) like the New York Independent System Operator (NYISO) replaced bodies like the New York Power Pool as part of this deregulation process. 

A key difference between the old approach and the new de-regulated approach is that “no group or agency has the responsibility for grid reliability”.  The NYISO and the Public Service Commission determine what they think is necessary and solicit developers to build those resources.  If those resources do not get built because nobody bids, the developers realize that they cannot make money and cancel commitments, there are delays in deployment, or for any other reason, there is nobody on the hook.   

This section of the book describes how the electric system works.  That is a very difficult challenge, but she does a good job – the glossary of acronyms and jargon is worth the price of the book.  She fills in details of the differences between the vertically integrated utilities and the regional transmission operators.  The last chapter describes a specific event that illustrates the challenges of the new approach that has made reliable electricity more difficult to provide.

Policy, Markets, and Fuel Security

The next 15 chapters delve into the world of de-regulated electricity markets.  The impetus for de-regulated electric grids was the presumption that monopolies were inextricably linked to higher prices and poorer outcomes. Successful deregulation of the phone companies and airlines drove the de-regulation bandwagon.  Angwin argues that electric deregulation has not been a success because consumers do not have much choice in providers, there is minimal transparency within the market, and accountability for the system has been spread across different players.

The complexity of the system, the vested interests of generating companies, transmission owners, and the system operators coupled with a lack of accountability to the public has led to gaming the system for financial gain.  Trying to adjust the rules when the games are discovered leads to complexity, unintended consequences, and more opportunities to game the system.  Angwin points out that:

Market manipulation was successful in California because there was nobody responsible for making the system work.  In an RTO area, the buck never stops anywhere.  Not even today.

The rest of the chapters in this section provide details of the de-regulated system and how they have made the electric system more fragile and costly.  Electric markets that were supposed to provide flexibility and innovation have become complex systems with “new regulations constantly tweaking and trying to improve regulations.”  Angwin sums it up:

It’s Orwellian.  RTOs are “deregulated” only if “deregulated” actually means “lots more regulation.”

Renewables on the Grid

The electric systems in the de-regulated states would be problematic even if there was no overarching initiative to decarbonize the electric sector.  The drive to reduce emissions using renewable energy adds another enormous level of difficulty to electric system planning.  The nine chapters in this section describe the issues associated with renewable energy deployment.

In an ideal deregulated electric system, policies would be fuel neutral but state and federal decarbonization policies override that goal.  Angwin explains how renewables affect the operation of the grid.  She aptly argues that all renewable electric systems “could” work but because of intermittency the grid has to work around them.  That is not a recipe for a robust and secure system.

As an aside Angwin and New York are concerned primarily with wind and solar renewables.  All the other potential renewable resources are not viable sources that can provide the amount of energy needed to replace fossil fuels because of geographical limitations (hydro), ideological considerations (e.g. biomass), or unproven technology (tidal).  Hence the emphasis on wind and solar.

Angwin describes three issues with renewables: “spikiness”, reliability, and their effect on power supply itself.  To provide electricity when needed grid operators must constantly match generating resources to the load.  The intermittency or ‘spikiness” of wind and solar complicates that balancing challenge.  To provide reliable power, alternative sources are needed to backup wind and solar.  The backup could come from fast reacting fossil fired generation but that is not an option in New York.  Instead, energy storage is needed.  The problem with that is there are multiple scales of storage required.  On a daily basis, solar needs backup for night backup but changes in the length of days means there also is a seasonal component.  Finally, Angwin points out that quality of electricity is important and wind, solar, and batteries adversely affect electric quality.  She also points out that there are potential solutions for many of these data quality problems, but the issue is who pays for them.

The remainder of this section delves into the details of certain aspects of the proposed renewable -dependent electric grids of the future. One chapter addresses renewable policies that affect consumer prices.  There is a chapter that discusses renewable energy credits or RECs and how they are being used to support preferred generating resources.  She concludes that games with RECs and complex policies “do not lead to a reliable grid”.

The chapter titled “The Purpose of Renewables” addresses the reasons why renewables are attractive.  She argues that a primary attraction is that they have “zero” emissions.  This raises the question why nuclear is not generally promoted given that there are no emissions, and it has none of the shortcomings of wind and solar. She describes zero emission credits (ZECs) which are being used to support existing nuclear facilities and uses a New York example.  

The RTO and the Customer

The next six chapters summarize the negative consequences of the RTO electric grid to customers. 

In the first chapter Angwin explains that the American electric grid is considered the largest machine on earth and that means the interdependence of so many different and diverse components make planning very difficult but also a necessity.  Before deregulation many utilities had to file integrated resource plans that explained how expected load would be met in the next 20 years.  She writes that the scope of planning diminished with the rise of RTOs.  However, this has led to an unacknowledged critical problem that she describes:

In the RTO areas, without any real oversight of requirements, renewable resources are overbuilt, and they lock the grid into gas-turbine backup. It’s like building a car without a blueprint but taking the lowest bid for someone who can supply “part of a car.” You may be able to procure wheels and tires, but transmissions will be way too expensive to buy. Buying tires may be inexpensive, but building a car needs a blueprint, and a car needs a transmission.

In other words, I am not against renewables per se. When I started working in the utility field, I aimed at expanding the role of renewables.

However, I am against greenwashing. “Come to our restaurant. It uses 100% renewable electricity. And the RECs were pretty cheap.” I am against the no-planning idea that all types of generation are equivalent: that inexpensive, reliable baseload power is unimportant, because every part of the modern grid will be optimized to be “flexible.”

The largest machine in the world is the North American grid. Not all parts on the grid are interchangeable. Not all types of plants have the same optimizations. With just a “market” for tires, a car won’t be built. With a “market” that treats all sources of electricity as equivalent, despite differences in availability and other parameters the grid becomes more fragile.

The grid will fail in RTO areas.  New types of auction carveouts will not prevent rolling blackouts.

When that happens, in an RTO area, the buck will stop …. nowhere.

Fortunately, the NYISO recognized the importance of planning on this scale and has added a System and Resource Outlook to their reliability planning process.  The latest Outlook covers 2023-2042 and necessarily addresses the Climate Act policies that promote renewables.  it is encouraging for New York that planning is considering this problem there is still a missing piece.  Unless state energy policy becomes less dogmatic and more consistent with New York’s electric energy planning experts rolling blackouts are inevitable.

Two chapters in this section addressed specific aspects of renewable development: overinvesting in renewables and distributed generation.  The lack of accountability in many RTOs leads to overinvestment in renewables that has led to physical and financial problems.  Renewable advocates hope that the world will move away from the current system with large generators and extensive transmission systems.  Their solution is distributed generation which uses smaller units located close to their customers.  The problem with this approach is that there is still a need for backup power and that makes them impractical for widespread use.

Angwin describes personal responsibility issues.  She gives an example where a sincere concerned person argued that if she took actions to reduce her emissions and use of electricity that it would make a difference for climate goals.  Angwin gives several examples that show individual actions will not make a difference and that the only way to meaningfully change emissions is for big changes.  Despite the fact that individual actions have little effect, utilities are trying to control consumer demand.  They offer time of use pricing that gives breaks for shifting electric use to off-peak times.  To provide that incentive utilities are installing smart meters that can track time of use.  Angwin points out that it is a small step from a voluntary program to an involuntary program once smart meters are installed.

The final chapter in this section looks at the actions of generating companies in RTOs.  Given that the independent generators no longer have an obligation to serve when operators decide that the market rules don’t provide sufficient incentives to remain competitive, they shut down or sell the assets.  Selling assets may buy some time but when the financial outlook does not improve, they will be shut down.  Angwin explains how this is affecting the resiliency of the grid in a bad way.

Is There a Way Forward?

In the last six chapters Angwin sums up her concerns and makes suggestions for improving the existing situation.  In the introduction I mentioned two philosophical questions she posed:

  • Do we deserve to have electricity available at all times?  Or is an intermittent, fragile grid good enough?
  • How important are the various aspects of our electric supply?  That is, what are the values we assign to things like reliability, cost, low environmental impact, and low carbon dioxide releases?

In the first chapter of this section she explains why she thinks we deserve to have electricity available when we want it.  When prosperity increases energy use increases and that is a good thing because it means people can escape energy poverty.  Lack of electricity hurts people because the alternatives are invariably more dangerous.  In the third world the advantages are obvious but even in New York lack of electricity is dangerous and must be avoided.

Angwin’s description of a high-quality electric grid is important.  Her criteria are:

  • The grid should work very reliably for all customers. Everyone should have access to energy, every hour of every day.
  • The power plants on the grid should be as clean as reasonably possible.
  • Similarly, safety concerns for nuclear energy have to be balanced with the positive benefits of the technology.
  • Electricity prices should be as low as reasonably possible. In particular, no residential customer should pay an increased bill in order to provide lower prices for another residential customer. Low-carbon, non-fossil sources of electricity should be encouraged, as much as reasonably possible.
  • We should be ready to use more electricity, not less. If we want to reduce pollution from the heating sector and the transportation sector, we will have to use electricity in those sectors. While there is much excitement about microgrids, solar power, and so forth, the grid design should acknowledge that only a small portion of electricity users will be prosumers.

The main message in the book is that current policies in RTO areas is that the grid is being moved inexorably to a strong reliance on renewable energy coupled with an equally strong reliance on just-in-time natural gas delivery as backup.  In New York the shift to a reliance on natural gas has already occurred.  The only exceptions are oil-fired units used to back up the gas plants when demand is very high or there are interruptions to natural gas delivery.  Renewable energy from wind and solar is not much of a factor yet but the Climate Act plan ensures that they will be a factor soon.

There are credible scenarios for this type of grid to collapse so she offers suggestions to ensure that the gird meets the high-quality criteria mentioned.  She advocates for a return to the older vertically integrated utility model because the current approach has the following issues:

  • Excessive tariffs and complex regulation.
  • Excessive deference to stakeholders/insiders.
  • Nobody has responsibility for keeping the grid operational.
  • A grid that becomes more fragile with increased reliance on just-in-time gas without new pipelines to bring more gas.
  • Extra consumer costs introduced by the RTOs because nobody claims that the RTO areas save money for the customers.
  • States can make rules while assuming that some other state in the RTO area will bear the cost.

The final chapter includes recommendations for what can be done.  Many of the recommendations are for RTOs that cover multiple states and thus are inapplicable to New York.  Even though New York is in  one state system I am concerned because there are disconnects between the long-term planning by the NYISO and the Climate Act Scoping Plan.  Those differences need to be reconciled and there is no apparent process to do that.

Angwin argues that grassroot advocacy is the best approach for change to try to address these problems.  She offers some suggestions on how to do that. 

She also persuasively argues that over-reliance on natural gas will lead to problems.  In the absence of new technology natural gas will be the preferred backup resource.  If reducing emissions is a primary concern, then she argues that nuclear energy has many advantages. 

She concludes that we need to pay attention to these issues for a number of reasons:

There are systematic problems with grid governance in the RTO areas. The grid is becoming more single-fuel, more vulnerable, and more expensive. Insiders make the rules, and the public cannot participate in a meaningful way.

In trying to talk about the grid problems, I have found that most people have deep opinions on power plants. They hate coal or nuclear, or they hate wind turbines, or whatever. They are often completely unaware of how the ratepayer-serfs are getting robbed by the insiders in an RTO area. Grid governance just isn’t on most people’s radar.

I hope you will pay attention to grid governance and take part in the debates. Ratepayers are not usually “allowed” to take part in the debates, but we have to try.

If we are not concerned with the grid, we will not have a safe and happy country to leave to our children.

I can’t say it any more starkly than that. We must take the grid away from the insiders, or our children may be outsiders, in some very unpleasant ways.

Discussion

Tom Shepstone has written a much shorter and more readable review of the book.  I recommend reading both his summary and the book itself.  Angwin makes a persuasive case that the present path will lead to rolling blackouts based on how the RTOs operate.

One of the big issues mentioned is that individual states policies have unintended consequences in multi-state RTOs.  New York has the advantage that the NYISO only must worry about New York policies.  New York also has the New York State Reliability Council “whose mission is to promote and preserve the reliability of electric service on the New York State Power System by developing, maintaining, and, from time-to-time, updating the Reliability Rules which shall be complied with by the New York Independent System Operator (“NYISO”) and all entities engaging in electric transmission, ancillary services, energy and power transactions on the New York State Power System.”  I know that they have addressed many of the issues raised by Angwin.  I do not know if there are similar organizations in other RTOs.

Nonetheless, I think that New York’s grid is in danger.  The problem is that New York’s Climate Act has imposed an arbitrary schedule on the NYISO and PSC to convert from the present system.  The ambition and schedule did not consider feasibility.  Furthermore, Angwin makes the pragmatic recommendation that policies like the Climate Act should look at what has actually worked to decarbonize grids in other jurisdictions.  Given that no jurisdiction has transitioned away from fossil fuels using wind and solar this means New York’s plans to rely on wind and solar are likely doomed.

Conclusion

I learned a lot about New York’s deregulated market from this book.  The Climate Act electric system transition to “zero” emissions by 2040 has two challenges.  New technology is going to be required and it is not clear whether any technology can provide everything that is needed to maintain current standards of reliability.  The book confirmed my suspicion that the RTO model for grid governance is going to have a huge challenge developing the market mechanism to ensure that the new technology will be available when and where needed in sufficient quantities to keep the lights on.  Finally, the grid governance policies to address this overarching issue will not have customer priorities very high in their decision process.

NYISO System & Resource Outlook – Renewable Profiles and Variability

The New York Independent System Operator recently released the 2023-2042 System & Resource Outlook (“Outlook”).  It examines “a wide range of potential future system conditions and compares possible pathways to an increasingly greener resource mix.”  This post summarizes the key findings of Appendix E: New York Renewable Profiles and Variability.

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 organization 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% GHG reduction by 2030, a 70% electric system renewable energy  mandate 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 used to reduce greenhouse gas emissions.  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, Public Service Commission orders, and legislation.

Overview of the Outlook Report

I provided an overview of the NYISO 2023-2042 System & Resource Outlook earlier.  The document and 11 appendices are available at the NYISO website:

The Executive Summary explains that:

  • The Outlook examines a wide range of potential future system conditions and compares possible pathways to an increasingly greener resource mix. By simulating several possible future system configurations and forecasting the transmission constraints for each, the NYISO:
  • Postulates possible resource mixes that achieve New York’s public policy mandates, while maintaining reserve margins, and capacity requirements;
  • Identifies regions of New York where renewable or other resources may be unable to generate at their full capability due to transmission constraints;
  • Quantifies the extent to which these transmission constraints limit delivery of renewable energy to consumers; and
  • Highlights potential opportunities for transmission investment that may provide economic, policy, and/or operational benefits.

Renewable Resource Characterization

The information presented in Appendix E was developed by DNV.  They modeled “long-term hourly simulated weather and generation profiles for representative offshore wind (OSW), land-based wind (LBW), and utility- scale solar (UPV) generators” in two phases.  Initially DNV assessed the OSW production for seven locations.   In the second phase, the analyzed LBW and UPV generation for nearly 80 LBW and UPV locations each throughout the state.  The projections were used to “determine the zonal or county aggregate net capacity factor (NCF) profiles that the NYISO used as inputs for this Outlook.

The goal of this work is to estimate the energy production of LBW, OSW, and solar—both UPV and behind the meter (BTM) PV.  The report explains:

The production amounts of each type of generation are considered when determining the representative days selected for the capacity expansion model and are used as hourly generation shapes in the production cost model for this Outlook.  The NYISO acknowledges that advances in renewable energy technology are continuously occurring and can lead to improved performance among generators built in the later years of the study period. Offsetting this effect, however, is that better sites may be utilized before less favorable resource sites leading to older technology on more favorable sites. Moreover, once installed, equipment performance can degrade over time. While these impacts are known, the exact magnitude of the impacts is difficult to quantify. Accordingly, this Outlook does not make any assumptions about improved performance of renewable generators built in the later years of the study period or performance degradation of resources once in operation.

The NCF data can be combined with hypothetical wind and solar projects sited throughout the state and in the New York Bight on the Outer Continental Shelf to estimate the generation production that represents actual historical weather conditions.  As the report notes: “The increasing weather dependent supply resources and electrified load will necessitate more attention be paid to the modeling of spatiotemporally correlated renewable generation and loads in long-term planning studies.”

These data can be used in multiple ways: “Resource production profiles can be characterized in various ways to describe interannual variability in, for example, resource output, hourly ramps, variability, and duration of low output.”

Metrics for Characterizing Renewable Production

There is a lot of information in this report that can be used to describe how renewable energy production will be affected by weather.  For example, Figure 1 shows the interannual variation for the net capacity factor of land-based wind (LBW), utility-scale solar photovoltaic (UPV), and offshore wind (OSW).  Net capacity factor (NCF) is the annual amount of electrical energy produced divided by the maximum potential energy that could be produced.  This parameter is used to determine how many resources need to be built to provide sufficient generation production to supply the necessary load.  The Integration Analysis assumed a single capacity factor value for the three generating resources and these figures show that a proper analysis of resource requirements needs to address the variability shown.

Figure E-1: Annual Capacity Factor of UPV, LBW, and OSW: 2030 Contract Case

I derived the latest Integration Analysis capacity factors from the total capacity (MW) and annual energy production (MWh).  I calculated that the 2040 projected LBW capacity factor was 37%, OSW capacity factor was 47%, and the solar capacity factor was 21%.  I eyeballed the capacity factors in Figure E-1 for Table 1 that lists annual capacity factors.  The projected mean annual capacity factors were less than the Integration Analysis for LBW and OSW while the solar projection was more than the Integration Analysis value.  This means that the wind generation capacity resources projected by the Integration Analysis are insufficient to meet the average resource availability.  It would be much easier for electric resource projections if planners only had to worry about average resource availability, but to provide electricity all the time planners need to consider the worst-case scenario.  The minimum average annual capacity factor over this 22-year period was less than the Integration Analysis projections for all three resource categories.  This means that the Integration Analysis underestimates the average generating resources needed and thus the costs of implementation.

Table 1: Annual Capacity Factors

The figures in Appendix E include results for the entire 22-year period of record and 2018.  The NYISO report supports their resource adequacy planning efforts that focus on an individual year, in this case 2018.  Appendix E notes that “understanding the variation in production over the years by comparing the annual capacity factors by technology type provides an initial indication of the energy impact of the choice of 2018 relative to other years in the DNV database.” For this article, I only present the combined 2000-2001 results and have modified the following quoted text to exclude any references to 2018. The Appendix describes the characterization approach:  

Renewable production profiles can be characterized on a more granular level by examining statistics within individual month and hour bins. Commonly referred to as “twelve by twenty-fours” (12×24), this calculation allows the diurnal and seasonal contributions of different renewable generation types to be accessed from the hourly timeseries. Further comparison of the net load provides insight on when and how much other supply resources are needed across the year and when there is a potential for renewable oversupply (i.e., negative net loads).

The graphics below present the hourly and monthly average NCF by technology type and present the NCF of the capacity weighted aggregation of UPV, LBW, and OSW. The figures show the averages over the 22-year period (2000-2021)

A number of salient features of the input data can be observed using this methodology. The concentration of UPV generation in the summer and mid-day hours is clearly observed, as well as comparably lower UPV generation in the winter months due to shorter daytime periods. In the shoulder months, UPV production is slightly higher in the spring relative to the fall. On the other hand, production of both LBW and OSW is concentrated on average to the winter evening hours, with this impact more pronounced for OSW than LBW. Across the board, OSW produces at higher NCF levels than LBW. The combined impact of the wind and UPV display clear features of each of the technologies with the highest overall renewable production during the summer mid-day. The lowest production persists during the evening hours in the summer and early fall with fleet capacity factors under 20% on average.

Electric resource planners need to consider these observations in their capacity resource projections.  As noted previously, the planners cannot rely on projections based on annual averages because generation must always match load.  The proposed dependence wind and solar means the resource availability considerations described above must be considered for future resource projections.  These results are the most comprehensive estimates for New York to date.  In short, they make all the Integration Analysis projections obsolete.

Figure E-2: “12×24” Average Net Capacity Factors for UPV, LBW, OSW, and Combined: 2030 Contract Case

The Appendix explains why this information is important:

By comparing renewable energy supply to the timing of the expected load, the remaining supply resources needed to serve demand (e.g., hydro, nuclear, imports, fossil-fuel and other generation, storage, and DEFRs) can be better understood. Using a similar framework to simplify the comparison, the figure below displays the variability in net load by displaying 12×24 charts for average, minimum, and maximum net load in GW. The figure displays net load over the 22-year period (assuming the same load in each year but varying the renewable energy shapes).

The Appendix goes on to describe an alternate way to present the data that focuses on supply requirements:

Average net loads are highest in the summer and winter evening hours after sunset. This indicates the need for additional supply beyond the assumed wind and solar resources to meet expected demand. Net loads are lowest during the mid-day spring and fall months when loads are lower and renewable energy production is generally high. The minimum net loads, which may be negative, provide an indication of the minimum generation levels needed from the remaining fleet when loads are lowest and renewable output is high. Negative net loads indicate intervals where the renewable energy supplied by wind and solar resources exceeds the demand on the New York Contral Area and coincides with times of low average net load during the shoulder mid-day periods, primarily due to the concentration of solar output.

Figure E-3: “12×24” Average, Minimum, and Maximum Net Loads (GW): 2030 Contract Case

The Appendix briefly describes how these observations could be addressed:

Storage resources would potentially be able to shift a significant amount of this excess mid-day renewable output during the day or across a few days. However, storage resources may not be fully capable of economically addressing the seasonal mismatch between times of low and negative net loads in the shoulder seasons and high positive net loads during peak season after the sun goes down. This impact is only exacerbated as weather-dependent electrified load (e.g., building heating) increases the potential peak load sensitivity of the system during temperature or weather extremes. This results in the requirement for even further supply resources to meet the larger net load peak without significant efforts to mitigate the potential peak load growth impacts.

After a discussion of ramping rate implications, the Appendix goes on to address low renewable resource availability ramifications and the analysis performed:

Characterization of the magnitude and frequency of low output intervals of renewable output is an important consideration when analyzing the impact of serving demand during longer duration events of low renewable production. Different output levels and durations must be considered, and one threshold must be selected to perform this analysis on an input renewable generation profile. For this analysis, low output events, or lulls, are defined as continuous durations where the production is below the identified threshold. Events are then binned by the duration of the number of hours for each event for each year. This analysis was performed for LBW, OSW, and a combination of LBW, OSW, and UPV to examine the impact of the combined assumed renewable fleet on the number of lulls of a given set of duration bins.

This issue has always been my biggest concern, so I was glad to see it addressed.  Note, however, that the threshold selected makes all the difference in the results.  The analysis presented uses a 10% NCF threshold which means that 90% of the resource capacity is unavailable.  The question is what threshold should be used.  This is a new planning criterion that should be watched carefully.  The results show:

Figure E-6 presents the results of reviewing the LBW profiles over the 2000-2021 period on an annual basis assuming a 10% hourly NCF threshold (i.e., lull hours are defined as those with a NCF less than 0.1). The x-axis displays the event duration bins (e.g., “[1,4]” collect all one-to-four-hour events while “97+” collects all events that are 97 hours or longer) except for the last bin that displays the longest duration event in hours during the year. Each bar within a bin going from left to right represents the number of events in each duration bin for one year from 2000-2021, with 2018 labeled with black bars and the corresponding number of events. The dashed line across each bin shows the average value of the number of lulls (and maximum duration) across the 22-year period. The analysis shows that, in 2018, the longest event where LBW output stayed below 10% of capacity across New York was 83 hours long and there were 12 events between 25 and 48 hours long. The chart also shows that there were less short duration LBW lull events in 2018 relative to the 22-year average but that there were in general more lulls longer than one day in duration than in a typical year.

The Appendix also presents results for OSW:

Comparison of the DNV renewable production shapes shows that LBW has more and longer wind lulls than the OSW shapes. This is expected, in part, as OSW has higher average capacity factors as shown in the monthly-hourly analysis earlier in this section.

The combination of resource lulls is most useful for planning:

Combining the LBW, OSW, and UPV shapes on a capacity weighted basis and performing the same analysis results in less lulls of all durations because the diversity in timing of production from the different generation types has the effect removing or splitting longer lulls into more shorter events.

I modified Figure E-8 to highlight the worst-case duration of a combined lull as shown by the red line.  It appears that there was a 36 period when 90% of the OSW, LBW and UPV resources were unavailable.  Keep in mind that light winds are associated with high-pressure system weather that also correlates highly with extreme cold and hot temperatures that mean high electric loads.  This has resource planning ramifications that must also be addressed.

The Appendix concludes:

Analysis of the input renewable and load shapes over the course of a single year can provide significant information about when additional resources will most likely be needed to provide additional supply to the system. Using the 22-years of simulated renewable NCF profiles applied to the zonal capacity mix in the 2030 Contract Case provides significant insight into general system characteristics and potential needs for additional supply resources. Comparative review of these metrics for the 2035 Lower and Higher Demand scenarios in the Policy Case shows largely similar features across all of the discussed metrics but with larger impacts due to the higher loads and slightly larger renewable builds present in the 2035 Policy Case relative to the 2030 Contract Case.

Discussion

The NYISO has started to incorporate weather variability in future planning for an electric system that depends on wind and solar resources.  I want to make two points.

The current NYISO resource adequacy planning process is based on decades of experience with the existing system that relies on fossil, nuclear, and hydro resources.  Over the years, the resource planners have developed a good idea how much surplus capacity is needed on the system to ensure that when the load peaks that there will be adequate generation in place to service the load.  Those projections are based on the fact that outages across the system are not correlated for the most part.  These data show that there are frequent periods when all of the wind and solar resources are expected to provide much lower output than their rated capacity.  It appears that planners must account for a 36 hour period when all the LBW, OSW, and solar combined provide less than 10% of their rated capacity.  This is a huge challenge.

The second point is that the developing adequate resource to backup the wind and solar resources during these extended low resource periods must now account for weather variability.  These results are based on a 22-year data set and is analogous to the 100-year flood metric.  For flood management planning, analysts use the 100-year flood probability of a certain flood height to develop a resilient plan for the flood plain.  Future electric resource planning is going to have to develop something similar.  I am concerned that while the ramifications of a flood that exceeds the planning criteria are bad, the effects of inadequate electric power when New York has electrified homes, businesses, and transportation will be catastrophic.

I have long advocated a similar analysis that expands on this one.  Because New York depends on imports from adjoining regional transmission operators the geographical scope should be expanded to cover those regions.  The period of record should be as long as possible.  There are data available that could be used to extend the analysis to 1950.  Even if the resource planning is based on such a study, the over dependence upon weather related resources means that eventually there will be an even worse resource lull that causes a catastrophic blackout.  There is a limit to how much society can invest to avoid such an outcome, and I think that dynamic will inevitably lead to disaster. 

In addition, note that these results show that the Integration Analysis projections for future wind and solar capacity are underestimated.  The net capacity factors used are greater than the observed capacity factors.  This is another aspect of the state plan that needs to be reconciled with the most current NYISO work.

Conclusion

These results highlight the complications that weather-dependent electric grid planning must address.  Given the magnitude of the planning challenges I am not optimistic that planners will be able to anticipate all the effects to prevent reliability crises.  The results also destroy the myth that the wind and solar future grid will be more resilient than the existing grid.  That is just an empty slogan with no basis.

Hochul Announces a Clean Energy Summit

This is an intriguing development.  On August 5 Governor Hochul announced a Future Energy Economy Summit that will “gather feedback on strategies to accelerate renewable energy deployment and explore the potential role of next generation clean energy technologies”.  In this post I offer some thoughts on the reason for the summit and possible outcomes.

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 organization that 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% GHG reduction by 2030, a 70% electric system renewable energy mandate 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 used to reduce greenhouse gas emissions.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized and approved by the CAC at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, Public Service Commission orders, and legislation.   However, recent reports have raised problems with the implementation process and Hochul has threatened to pause the process due to costs.

Announcement for Clean Energy Technology Summit

The press release for the Clean Energy Technology Summit stated:

Governor Kathy Hochul today announced New York State will convene global experts to discuss the role of next generation clean energy technologies and strategies to accelerate renewable energy deployment while collectively supporting economic development in New York. The “Future Energy Economy Summit,” to be held on September 4-5, will convene relevant state agencies and authorities, global and federal leaders, power producers, technical experts, labor groups, environmental groups, business groups and other interested stakeholders. The summit will explore how next generation clean energy technologies can support the establishment and expansion of commercial and industrial enterprises, as well as how the state can accelerate the deployment of dispatchable emissions-free resources that will be needed to bolster its notable and ongoing efforts to scale renewable energy.

Note that the summit is only one day.  Registration is the only activity available the evening before the meeting.  After the obligatory political bragging that I am not going to include, the press release went on to say:

The Governor has appointed New York State Energy Research and Development Authority (NYSERDA) Board Chair, Richard Kauffman, to serve as chair of the summit with contributions from leadership and staff from NYSERDA, the Department of Public Service (DPS), Empire State Development (ESD), New York Power Authority (NYPA), Department of Environmental Conservation (DEC), Department of Health (DOH), Division of Homeland Security and Emergency Services (DHSES) and Department of Labor (DOL).

I find it troubling that there will be so many agencies involved in the summit.  The heavy involvement of different agencies suggests that his may end up being no more than a dog and pony show to highlight the Administration’s commitment to fighting climate change.  Among the real issues that have to be addressed are those raised at last December’s technical conference entitled Zero Emissions by 2040 held as part of the Department of Public Service Proceeding 15-E-0302.  The conference confirmed the need for a new category of generating resources called Dispatchable Emissions-Free Resources (DEFR) but there hasn’t been any public progress addressing this resource.  The problem is DEFR technologies simply do not exist yet on a commercial scale, and it is very unlikely that the they will be available when needed to meet the arbitrary Climate Act schedule.  There are hints in the next paragraph that the summit might be intended to address this problem.

New York State anticipates major growth in electric demand in coming years driven by historic economic development projects and the increased adoption of electrification technologies in the building and transportation sectors. Building upon New York State’s unprecedented and continued commitment to scaling up and accelerating renewable energy such as offshore wind, hydropower, solar and onshore wind statewide, a key component of the summit will be gathering further input on technologies including next generation geothermal, advanced nuclear, clean hydrogen, long duration energy storage, as well as other emerging technologies. The input received will inform State strategies in the use of these technologies to support economic development across the state and provide context for the Public Service Commission (Commission) proceeding that is investigating technologies that can help meet the 2040 zero-emissions electricity system target established through New York’s Climate Act.

The technologies mentioned, next generation geothermal, advanced nuclear, clean hydrogen, and long duration energy storage are all potential DEFR solutions.  The following paragraph reinforces the idea that the summit is intended to address the need to implement currently unavailable DEFR technologies.

NYSERDA and DPS staff are currently developing technology and economic studies of diverse generation technologies that could complement the state’s wide scale deployment of renewable energy and play an expanded role in a decarbonizing economy. These studies will gather information and examine technologies ranging from small modular nuclear reactors to long-duration energy storage technologies to grid-forming inverters. The studies will complement the outputs from this summit and inform the State’s options for future generation including through the Commission’s proceeding.

So far the NYSERDA and DPS studies like the Scoping Plan are long on ambition and short on facts.  Worse, there hasn’t been any meaningful attempt to engage stakeholders by responding to comments submitted.  I worry that this summit is part of the packaging for whatever the Administration has already decided to do.  We can only wait and see what happens at this meeting.

Unfortunately, resolving the technological challenge for DEFR development and implementation is not the only implementation problem.  The green new deal aspect of the Climate Act mandates investments in disadvantaged communities which complicates implementation.  While I agree that all the factors described in the following paragraph are important, I am worried that there is no mention of a feasibility analysis.  The presumption of the state is that once they set a goal, it will happen despite the lack of any evidence that it is possible.

This summit will address advancing key factors to develop these technologies’ supply chain investments in New York, workforce opportunities, and how these investments can be leveraged to support large load growth and low-carbon economic development across New York while benefiting disadvantaged communities. The summit will also inform the development of a blueprint to advance issues and considerations for the deployment of advanced nuclear power generation and potentially leverage federal funding programs, including but not limited to, nuclear planning grants.

Summit Agenda

The only information on the summit itself is the following list of sessions:

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

Tim Knauss described the meeting for Syracuse.com. 

Two of the five panel discussions at the daylong conference will be focused on “new nuclear” technology such as small advanced nuclear reactors, according to a draft agenda.

The meeting also will include discussions about accelerating the deployment of renewable power sources like wind and solar. And there will be a focus on developing new power sources that can be dispatched when renewable power falls short.

Knauss interviewed Doreen Harris, president and CEO of the New York State Energy Research and Development Authority.  She said the summit “will explore a wide variety of technologies for achieving a clean system” and went on to say:

At this point, nuclear power is a more mature technology than many alternatives, she said.

“It is actually a more, I’d say, advanced area of commercial viability, as opposed to some of the other resources that we see on the technical horizon at this point,’’ Harris said in an interview Monday.

NYSERDA plans to develop a roadmap for the potential deployment of new nuclear power, similar to the Offshore Wind Master Plan the authority crafted to guide development of that resource, Harris said. NYSERDA plans to gain expert feedback at the Syracuse summit to help prepare a policy for new nuclear power, she said.

“New nuclear is a resource that we see strong federal support for,’’ Harris said. And frankly, we see deployment of these technologies — such that it is, I would say, ripe for consideration. Is this a resource that New York would consider? But it’s not to say we have the answer to that.”

Discussion

Three recent reports all have suggested that reassessment is necessary.  The Public Service Commission (PSC) Clean Energy Standard Biennial Review Report found that the 70% renewable energy goal will likely not be achieved until 2033.  The New York State Comptroller Office Climate Act Goals – Planning, Procurements, and Progress Tracking audit found that the PSC and NYSERDA implementation plans did not comprise all essential components, including “assessing risks to meeting goals and projecting costs.”  The New York Independent System Operator (NYISO) 2023-2042 System & Resource Outlook described issues that threaten reliability and resilience of the current and future electric system.

As a result of these findings and perhaps pressure by the business community, the governor said the state’s climate goals are something she “would love to meet, but also the cost has gone up so much. I now have to step back and say, ‘What is the cost on the typical New York family?’ Just like I did with congestion pricing.”  The Department of Public Service Proceeding 15-E-0302 may also be influencing the Governor and precipitating the need for the summit. 

The fact is that reality is an energy policy that was promulgated by motivated politicians without a vetted analysis of the scope and schedule was never going to be successful.  This summit might be an attempt to provide political cover to broach the need for schedule adjustments and to consider alternatives that have thus far not been considered seriously in the implementation process.  At the top of the list is the nuclear power that is the only technology that has a proven record of deep decarbonization success but most certainly cannot be deployed on the Climate Act schedule.  It will be interesting to see how legislators, the Big Green NGOs, and the renewable energy shills react to this development.  Will they acknowledge that nuclear is necessary for the Climate Act goals?  Stay tuned.

Commentary on Recent Articles 4 August 2024

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

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

Vermont Clean Heat Standard

Robert Roper publishes the Behind the Lines Substack where he writes about Vermont politics. His latest article describes the Vermont Clean Heat Standard which is their equivalent to the New York HEAT Act.  I recommend reading it highly. 

Roper explains that when the “Agency of Natural Resources secretary, Julie Moore, testified to the Senate Natural Resources & Energy Committee back in January 2023 that the cost of the Clean Heat Standard program would be $2 billion over the first five years, 2026-2030, — an amount that she said would result in an additional 70¢ per gallon for home heating fuels– oh, did she catch hell!  Supporters of the program decried her “back of the envelope” calculations and demanded that a proper study be done:

Critics seized on Moore’s honest assessment of the limitations of her own calculations, “I’m confident this is wrong. I could easily be off by a factor of two here,” to imply that her assumptions were not just wildly wrong but wildly high.

So the State did a professional study that was just completed and the draft released.  Roper writes:

The Clean Heat Standard Potential Study, Final Draft Results were presented to the Public Utilities Commission’s Technical Advisory Group (TAG) on July 25, and according to their professional (let’s see if Senator Bray gives them weight) calculations, the Clean Heat Standard program will cost Vermonters $17.3 billion between 2026 and 2050. In the up-front years that Secretary Moore analyzed (2026-2030), the report shows the cost at being around $7.25 billion, or over three and a half times more than Moore’s estimates.

Roper concludes with the point that these costs are just for the home heating sector.  No costs yet for the transportation sector.

Green Hydrogen

The placeholder technology to provide the necessary dispatchable emissions-free resource is green hydrogen.  However, there are physical constraints that make this an impossible dream.  At Stop These Things two articles describing those constraints were describedJohn Gideon Hartnett describes the ways hydrogen can be generated and concludes “It is pure fiction to believe you can somehow separate water into its natural component gases and then burn them again to produce energy efficiently.”  An article by Graham Lloyd describes the demise of an Australian green hydrogen project.

Electric School Buses

This news article gives a good overview of the New York electric school bus program.  It makes the point that when New York school districts borrow money to buy buses they must get specific approval from the voters.  As a result, there is local veto power over an unfunded state mandate.

Even proponents admit that electric bus costs are higher and that there are range limitations today.  One quote by a National Grid spokesperson epitomizes a common belief amongst advocates: “The technology is going to drastically improve by 2035,” she said. “So we don’t encourage you right now to be thinking about the field trips or the state championships, because we need time to build out the infrastructure.” The first problem is that for the technology to improve a lot it might be necessary to repeal some laws of physics.  School districts have pointed out that current technology is incompatible with long trips such as field trips. The cavalier wait until “they” build more infrastructure remark ignores the amount of infrastructure needed and the costs. 

CO2 Impact on Global Temperatures

Stephen Heins references a study published in Science Direct, concludes that even though most publications attempt to depict a catastrophic future for the planet due to an increase in CO2, there is serious doubt that this is, in fact, the case.

Judith Curry notes that calling warming is dangerous is questionable:

“This whole issue of ‘dangerous’ is the weakest part of the whole argument,” Curry, Professor Emeritus and former chair of the School of Earth and Atmospheric Sciences at the Georgia Institute of Technology, said. “What is dangerous? Everybody has a different idea of what’s good. The only harm from warming is rising sea levels. And that’s a slow creep unless something catastrophic happens, say, to the West Antarctic ice sheet. And if something catastrophic happens there, that’s as likely to be associated with under-ice volcanoes as it is to be with global warming.”

Residential Solar

Norman Rogers looks at residential solar from three points of view:

Three points of view are relevant, of the homeowner, of the utility company, and of society. The homeowner is usually pleased because in most cases he thinks he pays less for electricity. This is not because solar energy is cheap, but because the rest of world is subsidizing him. He may not realize the true cost of the solar electricity. The utility doesn’t like residential solar because it makes the utility lose money and lose control of the grid subjected to uncontrollable input from thousands of residential solar installations. From the viewpoint of the larger society, it is a waste of resources that accomplishes nothing for the economy while making the public incorrectly think solar is a bargain.

I do not like residential solar installations because I subsidize them.  Rogers explains that residential solar owners do not contribute to the utility’s cost of capital investment. “The utility must have infrastructure sufficient to handle the hottest day in July. The rest of the time the equipment is underutilized.”  Solar owners expect that the rest of this will provide them with power on the hottest day when the grid is most stressed but do not pay their fair share for that infrastructure.

Rogers goes on to explain why he thinks that it is time to kill the residential solar industry.

Calling for a Pause to the Climate Act

In the past couple of weeks there have been calls to conduct a comprehensive assessment of the Climate Act.  The Business Council of New York issued a statement calling for a pause.  The Orlean Times Herald   quoted Ken Pokalsky: ““Stakeholders in the state’s climate policy implementation efforts are increasingly concerned about the achievability of key (Climate Act) mandates, and what that means for the future reliability and cost of the state’s energy system.”

Responding to the comptroller’s report, Upstate United Executive Director Justin Wilcox stated, “Following the release of the New York State Comptroller’s most recent audit, we reiterate our calls to pause the implementation of the Climate Leadership and Community Protection Act (CLCPA) until critical issues are addressed. Moreover, the report shared today highlights what we have been saying publicly for years – utility bills are rising dramatically, and New Yorkers continue to be left in the dark when it comes to the true costs associated with the CLCPA.”

Senator Tom O’Mara opined in the Hornell Sun that “Doubts continue to grow over New York’s climate mandates”.  He called for a public discussion of the Climate Act:

That discussion must start out with what the Albany Democrats failed to do in the first place six years ago: a true cost-benefit analysis of New York State eliminating our 0.4% of global carbon emissions and what impact that will have on the climate change issues we have been dealing with. While I fully support efforts to lower emissions, it must be done in a responsible manner that will actually make a difference on climate. If that answer is nil, which I believe it will be, we should focus our resources toward resiliency on the effects of climate change.

Senator George Borrello urged state leaders to hit the pause button on this effort in order to devise workable, affordable plan:

Now is a good time to hit the pause button on this collapsing house of cards. A climate agenda developed primarily by bureaucrats and environmental activists was bound to be unworkable in the real world. Rather than continuing to flounder in the face of unachievable goals and burdening ratepayers, businesses, school districts and organizations with the costs of poorly supported mandates, I urge the governor and majorities in the legislature to reassess and authorize a thorough study, led by energy experts and engineers, of how our state can pursue green energy goals in a way that is affordable and achievable.

How Much?

Institute for Energy Research describes Treasury Secretary Janet Yellen’s recent statement that the global energy transition will cost $78 trillion through 2050 or $3 trillion a year, of which the United States should spend $1 trillion per year–more than it spends for national defense.  The article notes that:

Under President Biden, the climate change spending movement began with the Democrat-passed Inflation Reduction Act that was supposed to cost taxpayers $369 billion in climate spending. But the congressional budget estimators misjudged the number of firms and consumers wanting to reduce their taxes by capturing tax credits and other incentives of the bill with estimates now showing the bill will cost over a trillion dollars—three times the original estimate.

Meredith Angwin explains how the capacity market in the adjoining PJM market capacity market clearing price went from $28.92/MW-day for the 2024-2025 auction to $269.92/MW-day for the 20205-2026 auctions.  Angwin does a good job describing the policy framework of electric markets like PJM.  I recommend reading the article and the comments to understand what will eventually come to NY.

New York Might Not be the First

I have always thought that either New York or California would be the first states to see a catastrophic blackout due to the energy transition away from fossil fuels.  Isaac Orr and Mitch Rolling presented slides from their presentation on the state of the Midcontinent Independent System Operator (MISO) for the Energy Policy Research Foundation’s Electricity Policy Working Group.  They describe issues resulting from premature retirement of resources in favor of renewable energy and demand response programs to reduce load.  They conclude:

Obviously, something will have to give. The region will either need to scale back the scheduled retirements of coal, nuclear, and natural gas power plants to meet this rising demand or forego the economic growth that would accompany the increase in electricity consumption.

This reality exposes the silliness of arguments that rely heavily on demand response—or, as we like to call it, the opposite of Motel 6: We’ll turn the lights out on you—to keep the grid solvent. Not consuming energy comes at a cost, and states like Michigan are currently bending over backward to get these energy-hungry projects.

Unless MISO states get their energy policies in order, there won’t be any room at the inn.