Balancing the risks and benefits of environmental initiatives
Author: rogercaiazza
I am a meteorologist (BS and MS degrees), was certified as a consulting meteorologist and have worked in the air quality industry for over 40 years. I author two blogs. Environmental staff in any industry have to be pragmatic balancing risks and benefits and (https://pragmaticenvironmentalistofnewyork.blog/) reflects that outlook. The second blog addresses the New York State Reforming the Energy Vision initiative (https://reformingtheenergyvisioninconvenienttruths.wordpress.com). Any of my comments on the web or posts on my blogs are my opinion only. In no way do they reflect the position of any of my past employers or any company I was associated with.
A couple of years ago I posted an article about New York GHG emissions and found that they are less than one half of one percent of global emissions and that global emissions have been increasing on average by more than one half of one percent per year since 1990. I was recently asked to document that claim and updated that analysis. This post describes the results.
I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition. The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.
Overview
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.” In brief, that plan is to electrify everything possible using zero-emissions electricity. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies. That material was used to develop the Draft Scoping Plan outline of strategies. After a year-long review, the Scoping Plan was finalized at the end of 2022. In 2023 the Scoping Plan recommendations were supposed to be implemented through regulation, PSC orders, and legislation. Not surprisingly, the aspirational schedule of the Climate Act has proven to be more difficult to implement than planned and many aspects of the transition are falling behind. In addition, there has not been any additional documentation provided that proves that the transition will be affordable, keep the same standards of energy reliability, or not have unacceptable cumulative environmental impacts.
GHG Emissions
I frequently note that New York greenhouse gas emissions are less than one half of one percent of global emissions, and global emissions have been increasing by more than one half of one percent per year since 1990. This post shows that the claim is still true.
I originally used information from my post Climate Act Emission Reductions in Context to support that claim. I recently updated the analysis. I found CO2 and GHG emissions data for the world’s countries and consolidated the data in a spreadsheet. There is interannual variation, but the five-year annual average has always been greater than 0.79% until the COVID year of 2020. For the New York data I used GWP-100 data from Open Data NY through 2021 as documented in this post. New York’s share of global GHG emissions is 0.42% in 2019 so this means that global annual increases in GHG emissions are greater than New York’s total contribution to global emissions.
The data used are shown in the following table.
Global and New York State GHG and CO2 Emissions (million metric tonnes)
The following graph lists the five-year annual average GHG and CO2 NY emissions and the annual change in the five-year global GHG and CO2 emissions. Note that for most years the global change in emissions is greater than New York emissions. Anything New York does to reduce emissions will be supplanted by emission increases elsewhere in less than a year.
Conclusion
By any measure New York’s complete elimination of GHG emissions is so small that there will not be any effect on the state’s climate and global climate change impacts to New York. I previously showed that although New York’s economy would be ranked ninth relative to other countries, New York’s emissions are only 0.45% of global emissions which ranks 35th. This post graphically shows New York emissions are negligible compared to global emissions. The change to global warming from eliminating New York GHG emissions is only 0.01°C by the year 2100 which is too small to be measured much less influence any of the purported damages of greenhouse gas emissions. Finally, this post shows global emissions have increased more than New York’s total share of global emissions consistently since 1990. In other words, whatever New York does to reduce emissions will be supplanted by global emissions increases in a year.
The only possible conclusion is that the Climate Act emissions reduction program is nothing more than virtue-signaling. Given the likely significant costs, risks to reliability, and other impacts to New York society, I think that the schedule and ambition of the Climate Act targets needs to be re-assessed for such an empty gesture.
Richard Ellenbogen recently submitted comments as part of the record for the Department of Public Service Proceeding 15-E-0302 related to the net -zero mandate of the Climate Leadership and Community Protection Act (CLCPA), Last spring the New York State Public Service Commission (PSC) recently initiated an “Order initiating a process regarding the zero-emissions target” that will “identify innovative technologies to ensure reliability of a zero-emissions electric grid”. His comments discuss “a viable, affordable, and rapidly executable Plan B to assist NY State in reducing its carbon footprint using technologies that actually exist at scale, unlike the technologies proposed by the CLCPA which only exist at scale in the fantasies of its proponents.” I think it is important that his message gets out to all New Yorkers to try to avert the inevitable collision between aspiration and reality..
Ellenbogen is the President [BIO] Allied Converters and frequently copies me on emails that address various issues associated with the CLCPA. I have published other articles by Ellenbogen, 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 CLCPA implementation. There are only a few people in New York that are trying to educate people about the risks of the CLCPA with as much passion as I am, but Richard certainly fits that description. He comes at the problem as an engineer who truly cares about the environment and how best to improve the environment without unintended consequences. He has spent an enormous amount of time honing his presentation summarizing the problems he sees but most of all the environmental performance record of his business shows that he is walking the walk. The comments described here put his thoughts on the record.
CLCPA Overview
The CLCPA established a New York “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.” In brief, that plan is to electrify everything possible using zero-emissions electricity. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies. That material was used to develop the Draft Scoping Plan. After a year-long review, the Scoping Plan recommendations were finalized at the end of 2022. In 2023 the Scoping Plan recommendations are supposed to be implemented through regulation and legislation.
Although vocal members of the Climate Action Council refused to acknowledge that not all the technology necessary for net-zero transition is available today the PSC zero-emissions target order recognizes that is not true. The Council ideologues ignored the fact that the Integration Analysis recognized that “as renewable resources and storage facilities are added to the State’s energy supply, additional clean-energy resources capable of responding to fluctuating conditions might be needed to maintain the reliability of the electric grid”. I published a post last summer summarizing the proceeding, including an overview of the questions raised by the PSC, and describing t comments I submitted.
I described the first set of comments for this Order submitted by Ellenbogen last summer. In order to make it easier for readers I have copied his submittal here. I converted his footnotes into inline references because footnotes do not lend themselves to blog posts.
About the Author
The first section of his comments describes his background and its relevance to the Proceeding.
Richard Ellenbogen an active party in the case , a resident of the State of New York, the CEO of Allied Converters, and welcomes the opportunity to provide comments as requested by the Commission in the above referenced proceeding, issued in the May 18, 2023 “Order Initiating Process Regarding Zero Target”.
I am a Former Bell Labs Engineer that has done work on the Utility System with NYSERDA and Con Ed. I also decarbonized my factory starting in 1999 and those measurements resulted in the Public Service Commissions Case 08-E-0751 to reduce power line losses. I was an invited speaker to a PSC Utility Conference in 2008 for that case on Line Loss Reduction that was initiated by Steven Keller based upon my work at the factory and a paper written at the request of Con Ed after a factory visit. I was the Keynote Speaker at the 2023 Business Council of NY Renewable Energy Conference and an invited speaker at the Dutchess County Chamber of Commerce meeting on Energy. I was an early adopter of renewable technologies going back to the 1990’s and decarbonized both my home and my business two decades ago. Between 2006 and mid-2023, the business recycled or repurposed 100% of its waste and sent nothing to a landfill. Over the past 20 years, the factory has generated between 60% and 85% of its electrical energy onsite with a carbon footprint approximately 30% lower than the Con Ed System, even prior to the closing of Indian Point.
I have lived live in an “electric” house since 2004 with a solar array and a geo-thermal heating system with 100% radiant heat using 95–100-degree water with a COP between 5.5 – 6.0, far more efficient than what most places will build under NY State guidelines, and I have driven an EV for six years. As all of the parameters in both the house and factory are measured three times per minute, I see firsthand what implementing the CLCPA will do to the load every day. The house was written up in the NY Times in November, 2008 under “Going Green: Still Challenging Turf” and the factory was written up in the Wall Street Journal under, “Westchester Plastics Maker Embraced Renewable Energy Decades Before The Gas Moratorium”.4 Additionally, I defeated Con Ed in a tariff hearing (NY State Public Service Commission Case 08-E-1426 Allied Converters, Inc. – Petition For a Declaratory Ruling on the Administration of Solar Net Metering Provisions at Locations Where Multiple (Hybrid) Energy Efficient Generation Technologies Are Installed) in 2008-2009 to allow additional interconnection of renewables and the factory became the first building in NY State with multiple sources of high efficiency grid connected generation.
It is through this lens that I have developed an understanding of the shortcomings of renewables after over 20 years of living with them. They are a great way to reduce the reliance on fossil fuels but attempting to run the entire system on them is going to be an unmitigated disaster which will be documented in the following pages. The requirement in the CLCPA for 25 – 37 Gigawatts of Dispatchable Emission Free Generation (DEFR) by 2040 is problematic at best and is impossible to execute in the stated sixteen year time frame, especially when considering that a single 1.2 GW Power Cable will have taken nearly that long to plan, construct, and get operational (2011 – 2026). I recommend that this DEFR proceeding determine whether there is a dispatchable emissions-free resource that can provide sufficient baseload and, if not, recommend a Plan B.
Introduction
The introduction lays out reasons that things have changed since last summer that could affect the schedule and viability of the Scoping Plan list of control strategies.
Since the original filing was made in August, a lot has changed in the NY State energy landscape. Renewables projects requested $12 billion in infaltionary increases that were declined by the Public Service Commission and that led to the cancellation of numerous projects, including solar, offshore wind, and battery storage. Those resources are now being rebid, likely at a significantly higher price.
The NYISO has indicated that the peaker plants will be operating far longer than planned because of a lack of renewables needed to replace them. Champlain Hudson Power Express (CHPE) is running into issues with landholders in upstate NY and may have to make eminent domain filings for certain parcels. It will not cripple the project but may delay it.
As mentioned in the earlier filing, the NYSERDA 6 GW Energy Storage Report, on page 94 of the 104 pages documents a need for 1000+ hours of storage or 6000 GWh of storage. Text from page 94 follows in italics.
Solar output is highest in the summer and lowest in the winter, and wind output is complementary to solar, as shown in Figure 40. With seasonal storage (1000+ hours), the availability of a specific resource during critical weeks – or in between multiple critical weeks in a season matters less; instead, the cheapest form of energy, such as solar in the spring and summer, can be stored and discharged over multiple winter weeks.
Column C in Figure 1, below, shows the 6,000 GWh of storage on the same scale of generation and demand. It is almost non-existent relative to the loads and will be totally inadequate to support the system. Far more storage than that will be needed to support a renewable system, however the NYSERDA report also documents a cost of $560 per KWh. At that price, the 6,000 GWh will cost $3.4 trillion, or about 16 times NY State’s annual budget. Some have been proposing using EV batteries to support the system. Having driven an EV for six years, I am almost never near a charger except when I am charging so there would be no way to feed energy back into the system. Further, how many people will willingly use their car to support the utility when they find out they will rescive 20% less revenue for discharging than they paid for charging and that the more frequent cycling will shorten the battery life. There are also capacitive batteries now being manufactured that will have a longer life span and a greatly reduced fire risk, however that are not ready for mass distribution. They also have a much lower energy density which makes them larger. That will work for utility scale storage but not EV’s. However, the price is roughly comparable to Lithium-Ion batteries so they will still be prohibitively expensive if used to support the utility system..
The Renewable Generation shown in column D was based upon 2019 projections that are no longer applicable as several Offshore Wind contracts have been canceled and several land based solar and wind projects have been canceled and others are meeting local resistance.
Additional Issues
Ellenbogen explains that these are not the only issues.
We are reaching a crossroads in New York State whereby the cost of the renewable generation and other mandates included in the CLCPA may make it impossible to live or work here.
The New Jersey nuclear plants announced this past week that they no longer need state subsidies because of the Inflation Reduction Act (IRA) subsidies that are now available to them. This raises the question, what does nuclear generation cost relative to the renewables that NY State is having enormous difficulty getting installed? Is there a viable carbon free Plan B?
This link is from a paper from September, 2022, published by the Cato Institute, regarding the costs of different generating options and the effect of the IRA on the cost of nuclear generation.
If you look at Table 2 below, from the paper, in the lower left hand column (Baseline), you will see that the UNSUBSIDIZED HIGH CONSTRUCTION cost for nuclear generation is 14.4 cents per KWh. The expected bids for Offshore wind are expected to come in substantially higher than that and the earlier bids were nearly that large. The recently canceled wind bids in NY State varied from $107 per MWh to $118 per MWh, despite Wind generation in the United States being heavily subsidized.
The next table shows the recently canceled wind bids and their costs. The requested increase had an average cost of $167/MWh. These are going to be rebid at a higher price and many will not be available for over 6 years, at a minimum, if they are ever built. Also note that the total capacity listed is 5 GW short of NY State’s ultimate goals. I referred to the High-Cost nuclear construction scenario because that is approximately what the recently built Vogtle reactors costs correlate with. This is a worst-case comparison of nuclear generation compared to the renewable generation.
Bids For Offshore Wind In NY State
According to information developed by David Stevenson (described here) ) the new projects were approved by NYSERDA with an average nominal cost MWh of $145.07 which compares to $167.07 in the table above. The table prices were requested in December 2023 while the new projects bids were likely made in early 2023 and may not reflect the tine cost needed to obtain financing today. The projects in the table most likely would have started construction in 2025 while the new projects are slated to start in 2030. It is highly likely that by 2030 the projects could not be built at these prices and the developers will come back for higher prices.
A recent blog post presented by Parker Gallant Energy Perspectives and highlighted in a recent post by Roger Caiazza of The Pragmatic Environmentalist, analyzed the costs of various generation types in Ontario, Canada. The results are shown in the table below. In Ontario, Nuclear Generation is approximately 30% less expensive than wind and 40% less than solar despite the claims that wind and solar are less expensive. Combined cycle gas generation is slightly less than nuclear in Canada.
That shows that unsubsidized nuclear is less expensive than OSW and doesn’t kill any birds or people, despite the claims of the fear mongers. OSW and solar could cost NY State ratepayers 30% more than nuclear generation, not including the costs of the required batteries and the more extensive transmission lines needed for those technologies due to their low capacity factor. If batteries are added in to support the intermittent renewables, the costs will be higher still. As shown in the earlier analysis of battery costs based upon the NYSERDA Energy Storage Report, the required batteries will cost more than the nuclear generation, independent of the costs of the renewable generation.
Again, I have developed an understanding of the shortcomings of renewables after over 20 years of living with them. In my experience, I believe that they are a great way to reduce the reliance on fossil fuels but expectations that they can completely replace fossil fuels are misplaced. A primary concern is cost and maintaining public support for the process. Public support will evaporate quickly with the current projected costs of the wind, solar, and batteries.
Regarding “Cap and Invest”, Table 3 below is also from the Cato Paper. It shows the carbon taxes required to achieve parity between nuclear and fossil fuel generation. With the High Cost nuclear, the carbon tax required to bring nuclear into parity with combined cycle gas generation is $196 per Metric Ton of CO2. According to the EIA, combined cycle gas generation will yield 2.25 MWh per metric ton of CO2 (976 pounds per MWh). With wind being more expensive than nuclear by between 20% and 30%, it will cost between $235 – $275 per metric ton to bring wind and Combined cycle gas generation into parity. Doing the math, $235 / 2.25 to make wind cost effective when compared to natural gas, even with the current subsidies, the taxes would be over $100/MWh. It would double the cost of the energy in the entire downstate region. If electric heat is forced upon the downstate residents, a current doubling of operating costs will morph to a tripling or quadrupling of heating bills for downstate residents.
Keep in mind that natural gas prices have dropped since 2022 so the actual tax would have to be higher in 2024.
These are the kinds of taxes that Cap and Invest will have to assess to make the plan work and they are ludicrous. Even without Cap and Invest, these are the additional costs that are going to be incurred by NY State ratepayers if the CLCPA keeps progressing. What makes this situation even worse is that the state can’t effectively install generation that won’t be taxed, building owners don’t have space or can’t afford upgrades to avoid penalties from the mandates, and the proponents of this plan can’t define who is going to pay the tax, acting as if the ratepayers and the taxpayers are mutually exclusive. A Venn Diagram of NY State ratepayers and NY State taxpayers will have an enormous amount of overlap.
A Viable Low Carbon / Carbon Free Solution That Will Not Bankrupt NY State Residents and Businesses
Ellenbogen offers a pragmatic alternative.
As nuclear generation takes years to get approved and sited, new combined cycle natural gas generation that feeds the CO2 emissions into greenhouses will provide low carbon energy at a low cost for NY State ratepayers in the near term. It is the least expensive generation to build and at present, it is also the least expensive generation to operate. It can provide baseload generation so it will eliminate the cost of battery storage. As it operates with a capacity factor two to seven times higher than renewables, the cost per MWh of transmission will be that much less expensive. As an initial step, siting a large combined cycle generating plant in Central New York, near the Western end of CleanPath, would provide easy access to natural gas from Pennsylvania while also allowing CleanPath to be fully utilized, reducing its costs to taxpayers. Additionally, there is available land in Central NY that is already used for farming that would be ideal to support large greenhouses. Routes 81, 86, and 88 provide easy access for shipping the agricultural products to population centers in NY State within four hours.
As can be seen in the following graph (Figure 2) a comparison of the emissions of Long Island Generating plants, the newer Caithness plant, shown on the right, operates far more cleanly than the E F Barret Plant shown on the left. E F Barret, which is a conventional steam generating plant that is operating well past its useful lifetime because of flawed NY State policy, was supposed to be replaced by a combined cycle plant six years ago. However, the expectation that Offshore Wind would replace it has fallen flat and Long Island residents are suffering with higher emissions and twice the energy cost of what could have been built six years ago. The Offshore Wind, if it is ever built, will reduce the emissions but based upon the current cost structure, it will not improve upon the operating costs of the old plant. This issue was addressed at length in the earlier filing.
By feeding the CO2 output of the combined cycle plants into large greenhouses, it can be used to increase crop yield by providing a twelve month growing season for NY State farms and increase food security in the state while using less land and water than existing farms. It will also use far less land than renewable generation. Additionally, it will harden farming in NY State to the effects of climate change.
Unlike the 25–37 Gigawatts of as yet unknown and non-existent Dispatchable Carbon Free Generation fantasized about in the CLCPA, this technology exists now and the greenhouses will cost far less than the batteries while also generating revenue and extremely high crop yields. The greenhouses will also last well beyond the 10 year lifespan of the batteries so they are a far more cost effective capital investment to make.
Additionally, operating EV’s from combined cycle gas generation is far more energy efficient than using internal combustion engines and will greatly reduce harmful pollutant emissions in the population centers.
Conclusion
Ellenbogen concludes that an alternative that does not go to zero provides a better solution.
Interim Combined Cycle Natural Gas Generation phasing to nuclear over time is a far more cost effective and secure way to power the state than what the CLCPA is mandating. Recovering the Combined Cycle emissions in greenhouses will mitigate the negative effect of the carbon emissions. That will also provide energy security that renewables can’t, while simultaneously providing food security as climate change makes food production more challenging.
Pragmatic Environmentalist Conclusion
The Hochul Administration has supported the ideological insistence that the schedule is necessary, and that zero-emissions in the electric sector by 2040 is mandatory. This is a political construct that does not stand up to any realistic evaluation. I have shown that New York’s GHG emissions are less than one half of one percent of global emissions and that global emissions are increasing by more than one half of one percent per year. That fact destroys any urgency arguments. We have time to do this right. This also implies that not reaching zero will not influence the alleged impacts to global warming. Ellenbogen’s alternative does not meet the ideological mandates but would be affordable, reliable, and have fewer environmental impacts. I endorse his comments.
Offshore wind (OSW) is a key component of the Climate Leadership & Community Protection Act (Climate Act). This article highlights material on costs and the leasing process that suggests it is not going to end well. Affordability is a major concern of mine and the costs for offshore wind are extraordinarily high. David Stevenson prepared a summary of costs that deserves wider distribution. Bud’s Offshore Energy blog argued that unrealistic power generation deadlines should not be the focus of the Bureau of Ocean Energy Management (BOEM) leasing policy.
I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition. The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.
Overview
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. Because nothing says sound energy policy like one designed politicians, the Climate Act also includes a requirement for 9 GW of offshore wind by 2035. The Climate Action Council (CAC) is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.” In brief, that plan is to electrify everything possible using zero-emissions electricity. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies. That material was used to develop the Draft Scoping Plan outline of strategies. After a year-long review, the Scoping Plan was finalized at the end of 2022. In 2023 the Scoping Plan recommendations were supposed to be implemented through regulation, PSC orders, and legislation. Not surprisingly, the aspirational schedule of the Climate Act has proven to be more difficult to implement than planned and many aspects of the transition are falling behind.
Offshore Wind Costs
Richard Ellenbogen recently submitted comments that compared nuclear costs to other proposed dispatchable emissions-free resources which I cover in another post. His analysis included an assessment of OSW, but he was unable to come up with good cost numbers. David Stevenson has some numbers available which are shown below. David has spent the last twelve years as the Director of the Center for Energy & Environment for the Caesar Rodney Institute, a bipartisan free market think tank. He has published over 150 analytic studies including major studies on the Regional Greenhouse Gas Initiative, the EPA Clean Power Plan, electric grid reliability, the public policy drivers of energy cost, offshore wind, electric vehicles, carbon capture, nuclear energy, and climate change.
But this recent growth in the offshore wind industry does not necessarily reflect its long-term health. Two substantial headwinds threaten to make projects uneconomical. One is the recent high inflation, which raised the costs of materials and labor across all industries, and the other is bottlenecked supply chains that are causing a bidding-up of the prices of materials and components needed for building wind turbines.
Hanley explained the ramifications to the OSW projects in New York and linked to the request for increases:
Stevenson produced this summary of the costs associated with these requests for more money.
At issue was a request in June by ACE NY, as well as Empire Offshore Wind LLC, Beacon Wind LLC, and Sunrise Wind LLC, which are putting up the offshore wind tower farms.
All told, the request, which was in the form of a filing before the PSC, represented four offshore wind projects totaling 4.2 gigawatts of power, five land-based wind farms worth 7.5 gigawatts and 81 large solar arrays.
All of these projects are underway but not completed. They have already been selected and are under contract with the New York State Energy Research and Development Authority, or NYSERDA, to help New York transition to a clean power grid, as called for in the Climate Leadership and Community Protection Act, approved by the state Legislature and signed into law in 2019.
Developer response suggests that “a number of planned projects will now be canceled, and their developers will try to rebid for a higher price at a later date — which will lead to delays in ushering in an era of green energy in New York”. Karlin also quotes Fred Zalcman, director of the New York Offshore Wind Alliance: “Today’s PSC decision denying relief to the portfolio of contracted offshore wind projects puts these projects in serious jeopardy,”
Later in October new projects were approved by NYSERDA with an average nominal cost/ MWh of $145.07 which compares to $167.07 in the table above. Stevenson explains that the table prices were requested in December 2023 while the new projects bids were probably made in early 2023 and may not reflect the true cost needed to obtain financing today. The original four projects cancelled most likely would have started construction in 2025 while the new projects are slated to start in 2030.
Here is what NYSERDA reported about the recent projects that include Attentive Energy One at 1,404 MW, Community Offshore Wind at 1,314 MW, and Excelsior Wind at 1,314 MW:
“The weighted average strike price of the awarded offshore wind projects over the (25 year) life of the contracts is $96.72 per megawatt hour in 2023 (real) dollars, which equates to a nominal weighted average strike price of $145.07 per megawatt hour. The strike prices comprising the weighted average cited above are subject to certain adjustments in accordance with the terms of the awarded contracts, including, in some cases, adjustments based on certain price indices, interconnection costs and/or receipt of qualifying federal support.”
Stevenson said “it looks to me that the award allows prices to increase 3% a year”. The strike price is the guaranteed price. The premium payment to the wind developer will be reduced by any revenue they receive from selling the wholesale power and any capacity value which might total about $60/MWh over the life of the projects so the net premium price might be about $85/MWh. In addition, there may be other inflation adders based on NYSERDA’s wording.
Soon after the Public Service Commission refused to approve the higher costs for four contracts last October, the Hochul Administration announced that expedited offshore wind solicitations for the state will be held early in 2024.
Projects that previously petitioned the New York State Public Service Commission for financial relief can choose to participate, though the solicitation will also emphasize competition between these and other projects, ensuring the integrity of the process and best value for New York electricity consumers, according to the press release.
The solicitations were announced in January and the deadline for submittals recently passed. The results will be announced soon.
Stevenson also provided cost estimated for two new projects have been approved in New Jersey that he expects will be similar to the expedited New York solicitations. The 2,400 MW Invenergy project will average $152.91/MWh, and the 1,342 MW Attentive One will average $187.83 over their twenty-year life considering their 2.5% and 3% per year allowed price increases. In addition, each of the 2032 startups expect 30% federal Investment Tax Credits, and New Jersey is allowing up to 15% additional inflation adjusters that could bring average costs to $175.84 and $216.01/MWh. The New York projects may have a similar inflator.
He notes that Attentive Wind One is projecting a ridiculously high 56% capacity factor. Most projects estimate capacity factors of 42% to 44%, like actual results from the five turbine Block Island and two turbine Coastal Virginia projects. Two factors suggest much lower capacity factors for larger projects. Below is the annual production curve for six years at Block Island. Notice the highest generation occurs in the spring and fall when electric demand is lowest. The Virginia turbines show a similar pattern. With many large projects all doing the same the regional grids will not be able to take all the power produced so turbines will have to be shut down, or curtailed. PJM expects average capacity factors will be 37% because of this curtailment.
European studies of offshore wind show a second impact known as the “Wake Effect”. The first row of turbines absorb wing power leaving succeeding rows with less wind energy. The impact could be to drop electric generation another 5% to 10%. Lower generation means higher guaranteed prices will be needed. We will most likely see future nominal strike prices routinely above $200/MWh.
Deadlines and Wind Deployment
Bud’s Offshore Energy blog points out that unrealistic power generation deadlines should not be the focus of the Bureau of Ocean Energy Management (BOEM) leasing policy. This argument also applies to the Climate Act’s arbitrary offshore wind deployment requirements. In reference to wind leasing issues in Oregon he explained:
As concerns about wind leasing mount, it is becoming increasingly apparent that the rush to hold auctions may not be in the best long-term interest of the wind program. The primary objective should be cost-effective and responsible development, not gigawatt deadlines.The administration’s vision for wind energy capacity, particularly the 15 GW goal for floating turbines by 2035, is unlikely to be achieved and rushing the process is not helpful.
The Confederated Tribes of Coos, Lower Umpqua and Siuslaw tribal council unanimously passed a resolution opposing offshore wind energy development off the Oregon coast.
“The federal government states that it has ‘engaged’ with the Tribe, but that engagement has amounted to listening to the Tribe’s concerns and ignoring them and providing promises that they may be dealt with at some later stage of the process. The Tribe will not stand by while a project is developed that causes it more harm than good – this is simply green colonialism.”
These two perspectives address my concerns about affordability and reliability. The Climate Action Council got bogged down in its Scoping Plan review with ideological discussions. For example, an inordinate amount of time was spent arguing whether natural gas should instead be called fossil gas in the Scoping Plan.. As a result, the Council never established criteria for affordability and reliability presuming that because the Integration Analysis projections supported their narrative that those issues would not arise.
I believe that the issues are rapidly approaching the fan of reality and they will hit soon. Soon the reality that the aspirational schedule is untenable, the costs are higher than admitted, and there are ramifications to reliability because no new fossil power are being built to replace the irreplaceable aging fossil plants before the magical resources are developed. There is a safety valve that can be used by the Public Service Commission that gives me hope that this mess can be averted. New York Public Service Law § 66-p (4). “Establishment of a renewable energy program” includes safety valve conditions for affordability and reliability. § 66-p (4) 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 political ramifications of employing this would be enormous but the impacts of the failure to pause this absurd energy plan would be much worse. I believe that the Public Service Commission should assure that New Yorkers can continue to have access to reliable and affordable electricity by defining standards for those affordability and reliability criteria.
Conclusion
I cannot over-emphasize how much I agree that the primary objective of offshore wind development “should be cost-effective and responsible development, not gigawatt deadlines”. With the addition of evolving development costs as supply chain and infrastructure support requirements become clear, it is not in the interests of New York to continue the mad rush to try to meet arbitrary gigawatt deadlines. This also applies to the development of ll solar and wind. Legitimate affordability, reliability, and environmental concerns are being ignored in the rush to build as much as possible as soon as possible.
I have been a persistent critic of the Hochul Administration’s consistent linking of any extreme weather event to climate change as rationale for the Climate Leadership & Community Protection Act (Climate Act). In my articles responding to the claims I explain that according to the National Oceanic and Atmospheric Administration’s National Ocean Service “Weather reflects short-term conditions of the atmosphere while climate is the average daily weather for an extended period of time at a certain location.” The referenced article goes on to explain “Climate is what you expect, weather is what you get.” This post is in respond to a friend who says that he has “grappled with this statement in the past, but still don’t fully understand it”
I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition. The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.
Overview
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.” In brief, that plan is to electrify everything possible using zero-emissions electricity. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies. That material was used to develop the Draft Scoping Plan outline of strategies. After a year-long review, the Scoping Plan was finalized at the end of 2022. In 2023 the Scoping Plan recommendations were supposed to be implemented through regulation, PSC orders, and legislation. Not surprisingly, the aspirational schedule of the Climate Act has proven to be more difficult to implement than planned and many aspects of the transition are falling behind. In order to keep the public’s support for the transition the Hochul Administration links recent extreme weather events to climate change.
Weather vs. Climate
The link between extreme weather and climate is commonly made by the mass media egged on by climate activists. In response I have a page devoted to rebuttals to these claims. I also have another page addressing climate change attribution. I have noted that the standard climatological average is 30 years. In order to think about a change in today’s climate averages you really should compare the current 30 years against the previous 30 years. In order to get a trend, you need to look at as much data as possible. On the face of it that might seem easy but the reality is that the conditions for a representative trend are difficult to achieve. Ideally you need to use the same instruments, the same methodology, and keep the conditions around the observing location the same.
My reader friend still doesn’t understand why I am so dismissive of these claims. He wrote:
Perhaps there is a different way for you to say it that I will understand. It seems reasonable to conclude that an individual weather event can be plausibly linked to a changing climate, if the question can be asked: “But for ____ ______, would this have happened?”
I think that laypeople have heard the narrative that climate change is affecting weather today so often that it “seems reasonable that an individual weather event can be plausibly linked to a changing climate”. When I did a search on the term “what conditions can impact the weather” all that came up were articles arguing that there is a link. This story is everywhere so the presumption that there is a plausible link is logical. I show why that is wrong below.
My Response
I have given some thought to his perception relative to mine. For the record, I have a BS and a MS in meteorology, have been working in the field for 50 years, but have limited forecasting experience because my emphasis has been air pollution meteorology. I think that as a result of my background I know what is involved with weather forecasting and when I weigh all the parameters affecting a weather event relative to the limited effects associated global warming, I dismiss claims that climate change can cause any weather events. There might be a tweak in the observed observations but that is all.
Let me explain by considering what is involved with a weather forecast. Weather.US lists results from different weather forecast models. This link provides a response to the question what are weather forecast models?:
Numerical Weather Prediction
Weather models, known formally as “Numerical Weather Prediction” are at the core of modern weather forecasts. All the forecast information you see at weather.us is powered by weather models, do what are they and how do they work?
Weather models are simulations of the future state of the atmosphere out through time. Millions of observations are used as initial conditions in trillions of calculations, producing a three dimensional picture of what the atmosphere might look like at some time in the future. Massive computers are used to do these calculations at incredibly fast speeds to enable simulations to cover the entire globe, and extend up to two weeks into the future.
Global vs Regional models
There are two general types of weather models, global models and regional models. Global models produce forecast output for the whole globe, generally extending a week or two into the future. Because these models cover a wider area, and a longer timespan, they’re generally run at a lower resolution, both spatially (fewer forecast points per given area) and temporally (fewer time points get a forecast).
Regional models on the other hand have much higher resolutions, but only cover some part (region) of the globe, and only provide forecasts a couple days out in time. The advantage with these models is that their higher resolution lets them “see” features that the global models miss, most notably including thunderstorms.
Why are there so many models and how are they different?
Many different national weather centers have supercomputers that run weather models. Each of these is slightly different, using different equations to solve for various physical processes that shape our weather patterns. Many of them also have slightly different resolutions, and use slightly different combinations of initial data sources.
These slight differences multiply out through time because the atmosphere is a chaotic system. This also means any errors that the models make in the near term become exponentially larger with time. This is why the forecast for a week from now is far less accurate than the forecast for tomorrow.
Weather modelling centers attempt to control for the influence of chaos by running ensemble systems that each use slightly different initial conditions. Each ensemble “member” then produces a forecast as if its set of initial conditions were correct. This provides some way of quantifying how likely a given forecast outcome is, helping to show forecast uncertainty.
My education and background included an emphasis on measuring parameters that affect weather forecasts. The discussion above notes that models start with initial conditions that are based on these meteorological variables. The World Meteorological Organization Measurement of Meteorological Variables report describes measuring techniques for the following parameters that all affect weather forecasts:
Present weather
Past weather
Wind direction and speed
Cloud amount
Cloud type
Cloud-base height
Visibility
Temperature
Relative humidity
Atmospheric pressure
Precipitation
Snow cover
Sunshine and/ or solar radiation
Soil temperature
Evaporation
Keep in mind that the initial conditions must not only include the surface observations but also observations of wind, temperature, and humidity in layers above ground. As noted above, there are many different types of forecasts and the use of these parameters is determined by the type of forecast. For example, if I was forecasting the impacts of air pollution within 50 miles of a source, I would not be concerned about soil temperature and evaporation.
In this response I am addressing whether individual extreme weather events (less than a week) can be linked to climate change associated with the greenhouse gas (GHG) effect. Increased GHGs reduces long-wave radiation (earth surface temperature) creating warming. No weather forecast model incorporates long-wave radiation measurements because the variation is so small over a week. Claims that climate change is affecting weather events associated with the GHG effect presume that there is warming that affects the events.
Given all the parameters that affect weather forecasts I do not think that a tweak in temperature can be linked to the cause of a specific event for two reasons. The first is that the temperature effect associated with the greenhouse effect is only of many parameters associated with weather events and I don’t think it has a high impact on extreme events. The second reason is related to the discussion above about the chaotic atmosphere. It states that “Weather modelling centers attempt to control for the influence of chaos by running ensemble systems that each use slightly different initial conditions.” The change in atmospheric radiation due to GHG emissions is smaller than the initial conditions variation.
Given my lack of forecasting experience it is appropriate to consider another source. Presumably climate change would have the greatest impact on heat wave. Dr. Cliff Mass describes the effect of global warming on the Pacific Northwest Heatwave of 2021. His synopsis:
Society needs accurate information in order to make crucial environmental decisions. Unfortunately, there has been a substantial amount of miscommunication and unscientific handwaving about the recent Northwest heatwave, and this blog post uses rigorous science to set the record straight. First, the specific ingredients that led to the heatwave are discussed, including a high-amplitude ridge of high pressure and an approaching low-pressure area that “supercharged” the warming. Second, it is shown that global warming only contributed a small about (1-2F) of the 30-40F heatwave and that proposed global warming amplification mechanisms (e.g., droughts, enhanced ridging/high pressure) cannot explain the severe heat event. It is shown that high-resolution climate models do not produce more extreme high temperatures under the modest global warming of the past several decades and that global warming may even work against extreme warming in our region. Importantly, this blog demonstrates that there is no trend towards more high-temperature records. Finally, the communication of exaggerated and unfounded claims by the media, some politicians, and several activists are discussed.
Conclusion
The premise that it seems reasonable in the statement “It seems reasonable to conclude that an individual weather event can be plausibly linked to a changing climate, if the question can be asked: ‘But for ____ ______, would this have happened?’ “ is flawed. The greenhouse effect is only one of many parameters affecting weather and the change in atmospheric radiation due to GHG emissions is smaller than the initial conditions variation used to address chaotic atmospheric conditions means that there is no provable link. The suggestion that climate change causes unusual weather events ultimately is an unfalsifiable hypothesis because no test can ever show that it is not real because it cannot be detected.
I have been so busy lately with net-zero transition implementation issues that I have not had time to put together an article about every relevant post I have read. This is a summary of posts that I think would be of interest to my readers.
I have been following the. Climate Leadership & Community Protection Act (Climate Act) since it was first proposed and most of the articles described below are related to the net-zero transition. I have devoted a lot of time to the Climate Act because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good. The opinions expressed in this article do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.
Robert Bryce describes a court case which could have implications to New York:
Last month, the Ninth Circuit denied the city of Berkeley’s petition to re-hear its case after the city’s ban was ruled illegal last April. The January 2 ruling has national implications and is an enormous loss for the electrify everything movement, the lavishly funded campaign that seeks to ban natural gas stoves, water heaters, and other gas-fired appliances in the name of climate change.
He explains the history of gas bans and the dark money subsidizing the campaign then goes into the details of the case. He concludes with reference to New York State because there is a similar case under consideration here.
On October 12, Jorgenson filed suit on behalf of a group of plaintiffs, including propane dealers, homebuilders, and plumbers. In a press release, Jorgenson’s firm said the “The drastic step of requiring ‘all-electric’ new buildings despite an already-strained electric grid stands at odds with the public’s need for a reliable, resilient, and affordable energy supply. New York’s gas ban is preempted by federal law, is contrary to the public interest, and harms plaintiffs and the members they represent.”
If Jorgenson prevails in New York, and she should, the next stop on the litigation is the U.S. Supreme Court, which should weigh in and declare that the electrify everything effort, is, as Jorgenson says, “contrary to the public interest.”
Parker Gallant summarizes what each generation source actually cost Ontario ratepayers/taxpayers to see if the claims that wind and solar are cheap are true. He found:
The only energy source cheaper than natural gas is hydro. Natural gas, hydro, and nuclear are all cheaper than wind and solar.
Tom Shepstone notes that the American Gas Association has put up a nice web page illustrating the numerous reasons why “natural gas has quickly become the indispensable energy source for America’s energy system.”
You may have heard about this recent court decision:
As many of you already know, a Washington, DC jury today found the Defendants (Mark Steyn and Rand Simberg) liable for defamatory speech and reckless disregard of provable facts. Putting aside the monetary damages, the real damage done by this case is to every American who still believes in the First Amendment.
The precedent set today, and as alluded to by Justice Alito when the case was petitioned before the U.S. Supreme Court, means that disagreement and/or criticism of a matter of public policy — the founding principle of this country — is now in doubt. And should you choose to give voice to any dissent, you can be brought before a jury, held responsible, and fined.
I recommend Judith Curry’s two articles on the science behind the claims and Dr. Mann’s behavior towards her. In short his science deserved ridicule and the man has no ethics.
On February 15, 2024 Governor Hochul announced $200 million in utility bill relief for 8 million New Yorkers. The press release quoted her as saying “Energy affordability continues to be a top priority in my clean energy agenda and this utility bill credit is just one of many actions New York is taking to reduce costs for our most vulnerable New Yorkers.” This post shows how some of the numbers given can be used to put implementation costs for the Climate Leadership & Community Protection Act (Climate Act) into context.
I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition. The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.
Overview
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.” In brief, that plan is to electrify everything possible using zero-emissions electricity. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies. That material was used to develop the Draft Scoping Plan outline of strategies. After a year-long review, the Scoping Plan was finalized at the end of 2022. In 2023 the Scoping Plan recommendations were supposed to be implemented through regulation, PSC orders, and legislation. Not surprisingly, the aspirational schedule of the Climate Act has proven to be more difficult to implement than planned and many aspects of the transition are falling behind. In addition, the magnitude of the necessary costs is coming into focus despite efforts to hide them. A political reckoning is inevitable in my opinion.
Press Release
This section quotes the press release and includes my comments.
The introduction outlines the rebate plan:
Governor Kathy Hochul today announced that the New York State Public Service Commission adopted a $200 million New York State energy bill credit to be administered by the large electric and gas utilities on behalf of their customers. The energy bill credit is a one-time credit using State-appropriated funds to provide energy bill relief to more than 8 million directly metered electric and gas customers. With today’s action, more than $1.4 billion has been or will be made available to New York consumers to help offset energy costs in 2024.
The rebate totals $200 million and gives a one-time credit to 8 million directly metered electric and gas customers. Ry Rivard in the February 16 edition of Politico Pro NY & NJ Energy notes that “The money, which will be spread across eight million electric and gas customers, amounts to roughly a one-time bill credit of about $24.”
Hochul provides the rationale for the rebate:
“Every New Yorker deserves affordable and clean energy, which is why I fought to secure additional funds to provide financial relief for hardworking families,” Governor Hochul said. “Energy affordability continues to be a top priority in my clean energy agenda and this utility bill credit is just one of many actions New York is taking to reduce costs for our most vulnerable New Yorkers.”
In Albany there are always working groups, advisory councils, and other committees set up to deflect blame and/or claim benefits. In this instance the Energy Affordability Policy working group, “a group of stakeholders that included the most prominent consumer advocacy groups in the state” made the recommendations. The press release states:
The program, proposed by the Energy Affordability Policy working group, provides that the $200 million appropriation included in the FY24 State Budget will be allocated to customer accounts through a one-time credit within roughly 45 days of the utilities receiving budget funds. This utility bill relief builds on several other key energy affordability programs administered by New York State, including $380 million in energy assistance program (EAP) funding for consumers through utilities, $360 million in Home Energy Assistance Program (HEAP) funding, $200 million in EmPower+ funding through the State Budget, over $200 million in ratepayer funding to provide access to energy efficiency and clean energy solutions for low-to -moderate income (LMI) New Yorkers through the Statewide LMI portfolio and NY Sun, and more than $70 million annually through the Weatherization Assistance Program (WAP).
The Department of Public Service (DPS), in consultation with the Energy Affordability Policy working group, was tasked with designing a utility bill relief program related to the costs of utility affordability programs in recognition of energy commodity cost increases and the costs of utilities’ delivery rate increases. The working group considered multiple proposals over several months to effectuate the desired relief. The majority of the working group agreed to the staff proposal after several key modifications and recommended the PSC implement a one-time energy bill credit that would primarily benefit residential and small business electric and gas customers.
The Energy Affordability Policy working group is made up of leading consumer groups and advocates, municipalities, relevant state agencies, and utilities in New York.
Ry Rivard explains that the PSC was asked to divvy up the money in a few different ways:
New York City, for instance, urged the commission to provide different credits to gas customers depending on whether they used gas to heat their homes or just for cooking. And AARP, among others, argued the bill credits should be targeted to people who need the help most.
Ultimately, the PSC went with a simple, rough and ready way that gets money out the door quickly and just in time to help reduce winter heating bills: divide the money available by the number of customers.
A large section of the press release was devoted to congratulatory statements and descriptions of other ways the Hochul Administration wants to help:
PSC Chair Rory M. Christian said, “We applaud Governor Hochul for continuing to address the high cost of utility bills in New York State head on. While global commodity price volatility and utility delivery rate requests for increases, the Governor’s new and innovative energy affordability initiatives are coming at exactly the right time.”
Public Utility Law Project (PULP) Executive Director and Counsel Laurie Wheelock said, “PULP extends our sincere gratitude to Governor Hochul and the State Legislature for the allocation of a historic $200 million in the FY 2023-24 State Budget to address energy affordability. PULP and other stakeholders, including the Department of Public Service, Joint Utilities, and fellow consumer advocates, worked together to put forward a proposal that would provide relief to customers. The Commission’s decision today underscores a shared commitment to find ways to aid all New Yorkers, including our most vulnerable households, facing rising utility costs and volatile electric and natural gas prices. As we celebrate this milestone, PULP remains committed to identifying and advocating for additional measures to ensure energy is affordable in 2024 and beyond.”
In addition to the energy bill credit funds and EmPower+, New York State programs offer funding and technical assistance that can assist homeowners, renters, and businesses manage their energy needs. This includes:
Apply for HEAP: As of November 1, applications were being accepted for the Home Energy Assistance Program (HEAP) which can provide up to $976 to eligible homeowners and renters depending on income, household size and how they heat their home (e.g., family of four with a maximum monthly gross income of $5,838 can qualify). For more information visit NYS HEAP.
Energy Affordability Program/Low Income Bill Discount Program: This program provides income-eligible consumers with a discount on their monthly electric and/or gas bills, as well as other benefits, depending on the characteristics of the particular utility’s program. New Yorkers can be enrolled automatically if they receive benefits from a government assistance program. For more information, they should visit their utility website or links can be found at DPS Winter Preparedness.
Community-based Service Programs: Service organizations and local community agencies provide financial aid, counseling services and assistance with utility emergencies. New Yorkers can contact organizations like the American Red Cross (800-733-2767), Salvation Army (800-728-7825), and United Way (2-1-1 or 888-774-7633) to learn more.
Receive a customized list of energy-related assistance in the State: New York Energy Advisor can help income-eligible New Yorkers locate programs that help them spend less on energy and create healthier and more comfortable spaces. With New York Energy Advisor, consumers answer simple questions and get connected with energy-saving offers in New York State. Sponsored by NYSERDA and utilities, qualified New Yorkers can get help paying utility bills, receive special offers on heating assistance, and more.
EmPower+: Income-eligible households can receive a home energy assessment and no-cost energy efficiency upgrades through the EmPower+ program, administered by NYSERDA. Get more information about the program, including information on how to apply at https://www.nyserda.ny.gov/All-Programs/EmPower-New-York-Program.
Weatherization Assistance Program (WAP): Administered by New York State Homes and Community Renewal, WAP provides income-eligible households with no-cost weatherization services. Rental properties can also be served, though there are additional requirements for owners of rental properties. For more information on WAP, including how to apply, visit https://hcr.ny.gov/weatherization-applicants.
The press release ends with a bragging reference to the Climate Act. Not mentioned here is how the Climate Act initiative will affect consumer costs. It is the same oft-repeated drivel seen before so I will not comment here.
New York State’s Nation-Leading Climate Plan
New York State’s nation-leading climate agenda calls for an orderly and just transition that creates family-sustaining jobs, continues to foster a green economy across all sectors and ensures that at least 35 percent, with a goal of 40 percent, of the benefits of clean energy investments are directed to disadvantaged communities. Guided by some of the nation’s most aggressive climate and clean energy initiatives, New York is on a path to achieving a zero-emission electricity sector by 2040, including 70 percent renewable energy generation by 2030, and economywide carbon neutrality by mid-century. A cornerstone of this transition is New York’s unprecedented clean energy investments, including more than $40 billion in 64 large-scale renewable and transmission projects across the state, $6.8 billion to reduce building emissions, $3.3 billion to scale up solar, nearly $3 billion for clean transportation initiatives, and over $2 billion in NY Green Bank commitments. These and other investments are supporting more than 170,000 jobs in New York’s clean energy sector as of 2022 and over 3,000 percent growth in the distributed solar sector since 2011. To reduce greenhouse gas emissions and improve air quality, New York also adopted zero-emission vehicle regulations, including requiring all new passenger cars and light-duty trucks sold in the State be zero emission by 2035. Partnerships are continuing to advance New York’s climate action with 400 registered and more than 100 certified Climate Smart Communities, nearly 500 Clean Energy Communities, and the State’s largest community air monitoring initiative in 10 disadvantaged communities across the State to help target air pollution and combat climate change.
Discussion
In this section I will put some context around these numbers: rebate totals $200 million and gives a one-time credit to 8 million directly metered electric and gas customers which “amounts to roughly a one-time bill credit of about $24.” In my opinion it is disappointing that this rebate apparently is being given to everyone and not limited to those who can least afford high energy costs. I calculated the rebate as function of the number of household percentiles. Using 7.5 million households as the state total and dividing by the $200 million rebate gives $26.67 per household. If only half the households are eligible for the rebate the $200 million is divided by 3,375,000 the rebate goes up to $53.33. The numbers quoted earlier are different simply because a different number of households was used.
Last year legislation mandated that auction funds from the New York Cap-and-Invest (NYCI) program be allocated to the Consumer Climate Action Account (CCAA) as part of the overarching investment framework established for the New York Cap-and-Invest (NYCI) program A recent webinar on plans for NYCI noted that the first 37% of revenue generated by NYCI auctions is “set aside for the affordability accounts, the Consumer Climate Action Account, the industrial small business climate action account and administrative expenses.” The Consumer Climate Action Account itself is supposed to get 30% of the revenues. Recall that 2030 total revenue is “estimated to be between $6 and $12 billion per year” so the Consumer Climate Action Account should get between $3.3 and $1.5 billion in 2030.
The amount of CCAA rebates to individual households is a function of the set-aside and the number of households eligible for the rebate. I previously found an overview of New York household income at Statistical Atlas that I used to estimate income percentiles and number of households at different levels in the following table. Note that the total number of households from this source is slightly different than what was used before. The NYCI webinar presentation stated that there will be no benefit for households in the top 20% which according to the table corresponds to an income exceeding $126,900. There are six million households under that threshold which means that around 1.5 million households in the top 20% of income will get no benefit. Low-income households are those below $35,000 and there are 2.3 million households in that category. There are 2.1 million households above $35,000 but below $75,000. Middle income is identified as the income band that contains the median annual household income in NYS, i.e., $50-75,000 for the purpose of the NYCI analysis. That leaves 1.6 million households with income between $75,000 and $126,900.
The following table lists the CCAA rebates for the four income categories described above. I assumed that the rebates would be assigned across the income categories included for the two NYCI revenue categories ($6 to $12 billion). If the auction revenues are distributed only to low-income households with incomes less than $35K, then each household will get between $774 and $1547 per year. At the other end of the range where every household with incomes less than the 80th percentile gets an equal share then the CCAA rebate will be between $300 and $600. I think it is more equitable to focus benefits on the lower brackets. The lower table apportions the rebates so that the upper bracket gets 20% while the lower two brackets each get 40%. In this example, rebates range from $225 to $619 per year.
Hochul’s press release noted “Energy affordability continues to be a top priority in my clean energy agenda and this utility bill credit is just one of many actions New York is taking to reduce costs for our most vulnerable New Yorkers.” This program is a $200 million appropriation coming from some never mentioned pot of money in the 2024 budget. This utility bill relief builds on several other key energy affordability programs administered by New York State: $380 million in energy assistance program (EAP); $360 million in Home Energy Assistance Program (HEAP) funding; $200 million in EmPower+ funding through the State Budget; over $200 million in ratepayer funding for energy efficiency and clean energy solutions for low-to -moderate income (LMI) New Yorkers; and more than $70 million annually through the Weatherization Assistance Program (WAP).
The hypocrisy of this press release is astonishing. It claims a total of $1.41 billion for programs that help with energy affordability. Today energy affordability is affected by the energy policy of the Hochul Administration and in the future those costs will increase much more. The Administration has never quantified how these investments will affect global GHG emissions. My analysis has shown that while there is interannual variation, the five-year annual average increase in global GHG emissions has always been greater than 0.79% until the COVID year of 2020. I also found that New York’s share of global GHG emissions is 0.42% in 2019 so this means that global annual increases in GHG emissions are greater than New York’s total contribution to global emissions. Anything we do will be supplanted by emissions elsewhere in less than a year. In that context, it is appropriate to ask whether the Climate Act transition plan is appropriate because it is forcing over a billion dollars to help reduce the cost impacts of the transition. Eventually all this money must come out of the pockets of New Yorkers for no quantifiable benefit to global emissions.
Conclusion
The Hochul Administration has never admitted how much households can expect to pay to implement the Climate Act net-zero transition plan. The plan is to electrify as much energy use as possible. That means we will be required to electrify home heating, cooking, and hot water as well as moving to electric vehicles. Recent electric rate cases have included double digit increases needed so support the Climate Act transition. I have no doubt that the costs of the transition for households will far exceed these rebates described in the press release. I urge all New Yorkers to demand an open and transparent accounting of the costs so we can all decide if we are willing to foot the enormous bills coming our way. There is no way the State can rebate its way to prevent those who can least afford the regressive increases in energy prices to not be adversely affected.
Mark Sertoff, a science/technology educator, occasionally sends me information. This post describes his comments on the Long Island Power Authority’s (LIPA) Integrated Resource Plan “where they want to replace fossil generation with mythical wind, battery and solar power.”
Integrated Resource Plan Comments
I have lightly edited Mark’s comments and added some references.
LIPA’s plunge into wind and solar power replacing reliable, cost-effective, clean fossil generation is the path to energy disaster. Through decades of solid engineering and execution, Long Island has developed the most reliable and economical above ground power distribution system in New York State. The defective initiative to wind and solar generation will leave Long Island with seriously unreliable and costly power.
Wind and solar work about 20% of the nameplate capacity. They need battery backup, which is very expensive, requires rare earths mined in unfriendly countries with child labor that creates environmental pollution in refining. Existing storage technology only lasts a few hours when a week may be required. To top it off the batteries have safety issues because they can explode and burn in unquenchable fires emitting toxic fumes. Europe tried wind and solar with massive problems in reliability and cost so is reopening fossil generation plants. Germany, the former industrial powerhouse of Europe, is losing its industrial base due to high energy costs.
There are significant environmental impacts. Wind turbines in the marine environment have drastically shorter lives and kill land and sea birds. Solar panels are negligibly recyclable and require rare earths sourced from unfriendly foreign countries via child labor and create copious pollution in fabrication while being barely recyclable. There are mountains of scrap wind turbine blades now that can’t be recycled. Marine wind turbines in construction and operation have caused the deaths of many whales along the East Coast. Machine gun sonar, pile driving, and sub sonic rotor vibrations injure and disorient sea mammals leading to beaching and ship collisions. Solar panels have such low energy density that habitats are destroyed to install solar when conventional generation would make many times more reliable power in a fraction of the land area at lower per-watt cost.
There are questions about the renewable energy business model. No wind or solar generation would be viable without government taxpayer subsidies. That says it all. It’s a defective business and energy plan. If it were a real upgrade, the market would support it without subsidies.
Finally, there is no climate crisis. This “crisis” is based on defective UN climate computer models. Thousands of scientists around the world concur. The greenhouse gas effect is real, but it is only one of many different drivers of climate. We experience cyclical weather in decadal, century, and millennial cycles and we do not understand those natural cycles well. It is likely that those cycles are the primary drivers of the observed changes in global temperatures observed and that the greenhouse effect has a minor impact, Certainly nothing that warrants the proposed changes to our energy system.
Conclusion
I published this because it is a concise summary of the myriad issues associated with New York’s net-zero obsession. It cannot end well and won’t make a difference.
To her credit Susan Arbetter, the host of Spectrum News Capital Tonight program, has tried to expose viewers to issues related to the Climate Leadership & Community Protection Act (Climate Act). Unfortunately, she allows speakers from the Hochul Administration to constantly conflate extreme weather with climate change and misleadingly claim that the costs of inaction are more than the costs of action. In this post I comment on her February 12 interview with Basil Seggos on the climate transition.
I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition. The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.
Overview
The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.” In brief, that plan is to electrify everything possible using zero-emissions electricity. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies. That material was used to develop the Draft Scoping Plan outline of strategies. After a year-long review, the Scoping Plan was finalized at the end of 2022. In 2023 the Scoping Plan recommendations were supposed to be implemented through regulation, PSC orders, and legislation. Not surprisingly, the aspirational schedule of the Climate Act has proven to be more difficult to implement than planned and many aspects of the transition are falling behind. In addition, the magnitude of the necessary costs is coming into focus despite efforts to hide them. A political reckoning is inevitable in my opinion.
Seggos Interview: Climate transition will be ‘the toughest thing we ever do’
The video of the interview is available but I am going to concentrate on two paragraphs from the cover story on the Capital Tonight webpage:
The cost of the doing nothing on climate will far outweigh the cost of a climate transition for New York, according to state Department of Environmental Conservation (DEC) Commissioner Basil Seggos, who addressed concerns on Capital Tonight.
“I just want to make sure viewers are clear. People are already paying for the impacts of climate change. That is a certainty. We spent $36 billion to recover from Superstorm Sandy,” Seggos said. “We see a $55 billion bill, potentially, if we don’t do the right things in New York, just on adaptation over the next 10 years.”
The political slogan “the cost of the doing nothing on climate will far outweigh the cost of a climate transition” is repeated as often as possible by representatives of the Hochul Administration. It is a deeply flawed argument for multiple reasons.
It is misleading because it refers to the costs in the Scoping Plan that do not include the costs of “already implemented” programs that exist solely to reduce GHG emissions. In other words, it does not include all the costs to reach net zero Climate Act targets only the costs of programs started after the Climate Act itself. The two biggest programs not included in the cost side of the slogan are the Zero-emission vehicle mandate (8% LDV ZEV stock share by 2030) and the Clean Energy Standard (70×30), including technology carveouts: (6 GW of behind-the-meter solar by 2025, 3 GW of battery storage by 2030, 9 GW of offshore wind by 2035, 1.25 GW of Tier 4 renewables by 2030). These programs, among others, are listed in Section 5.3: Scenario Assumptions in New York State Climate Action Council Scoping Plan Appendix G: Integration Analysis Technical Supplement Section I page 130.
The ”cost of doing nothing” does not include benefits of GHG emission reductions. The basis for the benefits are described in the Scoping Plan Costs and Benefits white paper documents. The actual numbers in that document have been updated since its release. The Plan describes health benefits due to improvements in air quality but observed improvements in recent years are 16 times greater than those projected for the Climate Act. If the State can show that the health benefits projected have been observed comparable to those observed then these benefits are supportable but there has never been any attempt to validate the estimates.
The benefits include a couple of tenuous estimates. The first is for “active transportation”. The active transportation health theory claims that as people are forced out of their personal vehicles some will switch to walking and biking. Those activities are healthier so there is a benefit. The increased active transportation benefit of $39.5 billion is based on a first-order approximation based on state-wide numbers but the benefits will likely only occur in certain areas. As a result, the benefit estimate is far too high. The second is for energy efficiency interventions benefits in low- and middle-income homes. The majority of the health benefits claimed are the result of “non-energy interventions”. The Climate Act intends to transform the energy sector so it is disingenuous to claim health benefits not directly related to energy efficiency programs themselves. Of the $8.7 billion in benefits claimed $3 billion is due to reduction in asthma-related incidents resulting from better ventilation not directly due to energy efficiency. The $2.4 billion in benefits from reduced trip or fall injuries and reduced carbon monoxide poisoning benefits are non-energy interventions and should not be claimed as benefits for GHG emission reduction programs.
The final reason that the slogan is flawed is the biggest. There are issues with the benefits for the societal avoided cost of GHG emissions known as the social cost of carbon or value of carbon. The values used are determined by a wide range of value judgements and economic projections. The Climate Act manipulates emissions to increase benefits and uses a lower discount rate than current Federal guidance resulting in societal benefits of GHG emission reductions that are 4.5 times higher for 1990 emissions and 5.4 times higher for 2019 emissions than other jurisdictions. The largest manipulation of these benefits is caused by incorrect guidance for calculating benefits. In particular, the benefits of reductions are counted multiple times. If only that error is corrected the total benefits do not outweigh the projected costs.
Another Climate Act narrative tactic is to claim that people are already paying for the impacts of climate change. Seggos said “We spent $36 billion to recover from Superstorm Sandy” implying that climate change was responsible for those costs. The difference between weather and climate is constantly misunderstood by Climate Act proponents that make this simplistic argument.
According to the National Oceanic and Atmospheric Administration’s National Ocean Service “Weather reflects short-term conditions of the atmosphere while climate is the average daily weather for an extended period of time at a certain location.” The referenced article goes on to explain “Climate is what you expect, weather is what you get.” Seggos consistently claims that extreme weather is proof of climate change but the interview showed he has no meteorological expertise whatsoever. More than once when described implementation challenges he stated that the state is facing trade winds but the appropriate term is head winds.
If, in fact, Superstorm Sandy was connected to climate change then the weather over extended periods of time should show increased hurricane activity and there should be a trend in disaster losses. Roger A. Pielke, Jr, specializes in tracking these parameters so I checked his work.
He posted information in June 2022 on hurricane trends on Atlantic hurricane activity. He noted that:
1. The Intergovernmental Panel on Climate Change, in its latest report, concluded that there remains “no consensus” on the relative role of human influences on Atlantic hurricane activity.
Here is what the IPCC says exactly:
“[T]here is still no consensus on the relative magnitude of human and natural influences on past changes in Atlantic hurricane activity, and particularly on which factor has dominated the observed increase (Ting et al., 2015) and it remains uncertain whether past changes in Atlantic TC activity are outside the range of natural variability.”
One reason for the inability to unambiguously attribute causality to Atlantic hurricane activity is the large interannual and interdecadal variability.
Pielke, Jr. argues that in order to assess disaster loss trends ”it is necessary to normalize disaster losses by taking into account changes in exposure and vulnerability.” He explains that:
The UN Sendai Framework recommends looking at disaster losses as a proportion of GDP as a method of normalization.
Since 1990, the toll of disasters as a proportion of the global economy has gone down from about 0.25% of GDP to less than 0.20%. That is good news and indicates progress with respect to the goals of the Sendai Framework.
Some quick questions and answers.
Can we conclude from this data that climate change is making disasters more frequent or costly? No
Can we conclude from this trend that climate change signals are not detectable in trends in various extreme events? No
What can we say about climate change by looking at this graph? Nothing
What about those journalists and campaigners who claim that economic losses from disasters indicate the detection and attribution of trends in extreme weather? They are wrong
How would we know if disasters are becoming more costly due to climate change? Follow this methodology
Needless to say the Scoping Plan ignored these recommendations and observations when it justified the Climate Act. It is also obvious that these inconvenient results are routinely ignored by apologists for the Climate Act.
There is one final aspect of the slogan “the cost of the doing nothing on climate will far outweigh the cost of a climate transition” that needs to be considered. The implication is that New York’s investments for the climate transition will make a difference. I recently updated my post Climate Act Emission Reductions in Context that documented how New York GHG relate to global emission increases. I found CO2 and GHG emissions data for the world’s countries and consolidated the data in a spreadsheet. There is interannual variation, but the five-year annual average has always been greater than 0.79% until the COVID year of 2020. The Statewide GHG emissions inventory came out in December but the comparable GWP-100 data that I used from Open Data NY through 2021 are not available. This analysis relies on last year’s data. New York’s share of global GHG emissions is 0.42% in 2019 so this means that global annual increases in GHG emissions are greater than New York’s total contribution to global emissions. Our actions will have no effects on the next superstorm because the increase in annual global emissions are greater than our total emissions. Implying other wise is disingenuous.
With all due respect to Commissioner Seggos, his cost benefit rationale for the Climate Act transition or his claim that climate change is affecting costs now do not stand up to scrutiny. Consider that the largest benefit claimed is based on counting benefits multiple times. If I managed to lose five pounds and keep it off for five years I cannot claim that I lost 25 pounds but that is what the basis for the slogan is doing. The IPCC science directly contradicts the insinuation that hurricane trends are outside the range of normal variability.
Conclusion
Seggos claimed that the climate transition will be ‘the toughest thing we ever do’. I think it might be the worst thing we ever do. The Climate Act transition plan is poorly documented, results are obfuscated, and there are no transparent cost estimates. As a result, I do not believe that the Hochul Administration has made a persuasive case that the transition is feasible with regards to affordability and reliability. I am disappointed that the media does not call them out on this.
Dennis Higgins passes on his commentaries associated with New York’s Climate Leadership and Community Protection Act (Climate Act). I asked his permission to present his status analysis of the transmission system components of the Climate Act net-zero transition that was published in AllOtsego. I also became aware of a puff piece claiming all is well by Basil Seggos, co-chair of the Climate Act’s Climate Action Council that provides the State’s story. Comparing the two pieces I don’t see how this will end well.
Dennis taught for just a few years at St Lawrence and Scranton University, but spent most of my career at SUNY Oneonta, teaching Mathematics and Computer Science. He retired early, several years ago, in order to devote more time to home-schooling his four daughters. (Three will be in college next year and the youngest opted to go to the local public school, so his home schooling is ending this June.) Dennis and his wife run a farm with large vegetable gardens. They keep horses and raise chickens, goats, and beef. He has been involved in environmental and energy issues for a decade or more. Although he did work extensively with the ‘Big Greens’ in efforts to stop gas infrastructure, his views on what needs to happen, and his opinions of Big Green advocacy, have served to separate them.
The game plan for the Climate Act public narrative is to point to a recent weather event and claim that is proof of climate change. The difference between weather and climate is never acknowledged and there has never been any estimate of how much Climate Act implementation will affect the alleged weather impacts. Seggos follows the script:
As made clear by the recent storms that ravaged many Long Island communities, time is running short to comprehensively address the flooding, erosion, and regional economic damage being wrought by increasingly common extreme weather events. We are witnessing the impacts of the climate crisis in real time, both here in New York and across the planet. It’s time for bold action at every level of society.
The next item in the usual script is to tout some new effort and its alleged benefits. That is the primary purpose of this article:
With the ongoing leadership of Governor Kathy Hochul, New York State is taking sweeping actions to reduce the many sources of greenhouse gas emissions that cause climate change. And in her recent State of the State Address and 2024-25 Executive Budget, Governor Hochul proposed a suite of actions to address climate change’s effects – including $435 million for initiatives to support long-term resiliency projects and protect communities across the state.
The funding will help create a new ‘Resilient & Ready Program’ with resources for low- and moderate-income households experiencing flood damage to assist with necessary repairs in the aftermath of storms, as well as improvements to prevent future damage.
The Governor also proposes a ‘Blue Buffers’ Voluntary Buyout Program to compensate residents in communities most vulnerable to flooding so they can relocate to another area with lesser flood risk. This not only saves taxpayer dollars when inevitable flooding occurs, it spares households the tangible and emotional losses that come with each rising tide and record rainfall.
Supported with $250 million from the $4.2 billion Clean Water, Clean Air and Green Jobs Environmental Bond Act, Blue Buffers would first educate property owners on the benefits of relocating homes and businesses regularly affected by high water, sea-level rise, and storm surges, and then partner with willing sellers on projects that could be eligible for buyouts. Purchased properties then revert to becoming permanently protected as open space, serving as a buffer against future flooding and benefiting the resiliency of the surrounding community.
Building on past investments, Governor Hochul is bolstering New York’s efforts to mitigate the effects of climate change with new proposals to repair aging flood control projects and remove hazard dams. The Governor also directed an update of Coastal Erosion Hazard Area maps essential to the protection of beaches, dunes, and bluffs that maintain and enhance flood resilience, and to overhaul building codes design to create higher standards for resistance to wind, snow, and temperature extremes.
As many Long Islanders know, since Superstorm Sandy, New York aggressively stepped-up efforts to boost targeted investments for critical infrastructure, flood-proofing, shoreline restoration, and disaster response. The response included ongoing work with federal and local partners to use every tool at our disposal.
The recent U.S. Army Corps of Engineers determination of eligibility for the process to assess, fund, and repair their damaged coastal projects on Fire Island, as requested by the Governor and Department of Environmental Conservation (DEC), is welcome news. It is one of many projects that DEC will continue to help implement to protect homes, critical infrastructure, and shorelines.
Climate change is here. With the ongoing cooperation and collaboration of Long Islanders, New York’s comprehensive approach to adaptation and resiliency will help ensure the Empire State is prepared for the gathering storm.
As far as I can tell the only way for the State to meet the Climate Act targets is magical game-changing technology. I do not see anything in these projects that makes me think that these programs are game changers. Another component of the narrative is to never discuss the status of the transition and the component programs. The question whether the existing programs are having any sort of an effect are not mentioned and no issues associated with recently proposed programs are ever addressed.
Flawed Energy Plan Moves Forward
On the other hand, Dennis Higgins’s article Flawed Energy Plan Moves Forward in AllOtsego takes a critical look at one new effort. This one is associated with transmission development.
Legislation proposed in Albany would create “RAPID,” a new department in the Office of Renewable Energy Siting to accelerate transmission buildout. Per megawatt-hour—amount of energy moved—those new lines will be very expensive. We must build full nameplate transmission for wind, which has a capacity factor under 25 percent. Solar has a capacity factor of under 14 percent: Although full capacity generation might occur mid-day in summer, much of the rest of the time solar yields little or no energy. Transmission for hundreds of solar and wind resources represents a lot of expensive wire to buy and install and maintain; wire which will need to be run across private land; wire that mostly will move nothing at all.
With each of New York’s staggering missteps in decarbonization efforts, we reflect on the mess we’re in. ORES itself has stalled out in efforts to site intermittent resources. Solar and wind builders cancelled contracts late last year when the state would not simply award them more money. They are rebidding, and the state will make new, more expensive, awards. Upstate communities are pushing back at the state’s efforts to locate solar and wind projects where local laws say “no” to industrial development.
New York gets about 20 percent of its baseload energy from hydroelectric on the St. Lawrence and Niagara rivers. Solar and wind currently account for about 7 percent of total state electricity. The fast approaching 70-by-30 goal in the Climate Leadership and Community Protection Act requires that 70 percent of the state’s electricity come from renewables. In other words, 50 percent of the state’s capacity must come from solar and wind. The state must multiply all the installed solar and wind built over the last 20 or more years by seven- or eight-fold in the next six years. Hochul has no ruby slippers and no magic wand, so press releases can safely be ignored. The 70-by-30 CLCPA goal is not going to happen.
Still, the state has decided lack of transmission must be the culprit. Let’s take a closer look at some of the problems with the state plan.
In its 20-year “Outlook” report, the grid operator NYISO detailed transmission constraints across Long Island, the Southern Tier and Finger Lakes. These will prevent energy moving from intermittent resources to downstate through this decade, and maybe the next. Can we fix the state plan by building high-voltage lines over rural New Yorkers’ objections to support energy resources that may never exist?
In its 2023 Power Trends, NYISO indicated that most—70 percent, or about 17,000 megawatts—of the state’s fossil-fuel capacity will need to be available after 2030. NYISO has already determined that peakers, which CLCPA says must be shut down, will need to be kept online. The storage projected in state planning, a hundred times the largest lithium-ion battery on earth and costing many billions of dollars, if fully charged, would not power New York City for a day. Alberta Canada, like Texas, recently issued energy alerts to its citizens as it discovered that wind power does not work well when it is very cold. Of course, solar generates almost nothing in the winter. Assuming we could get anyone in Albany to listen, is there some sort of broader lesson in all this?
California—following the same wacky blueprint New York is using—has had 20 years to build out its solar and wind assets, including transmission lines to move generated energy. California gets twice the electricity from every panel that New York could hope to get. California has deserts to site intermittent resources and transmission, while New York must sacrifice its farmland and forest. California exports solar to Nevada at a loss to avoid curtailment, yet still dumped something like three terawatt-hours of energy in 2023, enough to keep the lights on in New York City for a week. California has struggled to reduce reliance on fossil fuels: It has built new gas plants and still needs to import coal-fired electricity to ensure reliability.
The 2015 Mark Jacobson publication—which was in part the model for New York’s energy plan—was soundly debunked by about two dozen climate scientists two years before the CLCPA was enacted. The Jacobson paper is nevertheless a sort of bible to the Big Greens. As noted in MIT’s technology review, that paper “contained modeling errors and implausible assumptions that could distort public policy and spending decisions.” Consequently, the CLCPA and the resulting scoping plan, following similar flawed analysis, have already led to “wildly unrealistic expectations” and “massive misallocation of resources.”
“Jacobson and his coauthors dramatically miscalculated the amount of hydroelectric power available and seriously underestimated the cost of installing and integrating large-scale underground thermal energy storage systems…They treat U.S. hydropower as an entirely fungible resource. Like the amount [of power] coming from a river in Washington state is available in Georgia,instantaneously… )“
Following this flawed plan, it always looks like there is a transmission problem, since the grid is not one big copper plate.
In fact, no new energy solution or gigantic storage mechanism is needed at all. New York only needs to look around the world at those places that have successfully decarbonized their grids. New York only needs to look in the mirror: the downstate grid is over 90 percent “dirty,” powered by gas and oil. Upstate is over 90 percent emission free, and like those large economies that have cut fossil-fuel use, it is powered by hydro and nuclear.
But don’t tell Albany: New York is intent on pursuing an expensive land-hungry plan which we already know will fail.
Discussion
The Hochul Administration is not addressing the implementation issues associated with their Climate Act net-zero transition. Instead, we get a barrage of slick announcements claiming that we have to do something and here’s a whole new pile of “something” that we think might work, will appeal to the constituencies that demand action, and likely provide political payola to some politically connected constituency.
Dennis Higgins provides the other side of the story. He describes numerous issues with the transition and relates them to the fundamentally flawed Jacobsen/Howarth transition plan. The fact is that if New York State is serious about de-carbonizing the electric grid nuclear power must be part of the solution. Dennis advocates for that position but to little avail. Without a commitment to nuclear this will never work.
Conclusion
Higgins noted that his piece was incomplete: “The mess is so big you can’t say it all — fiscally irresponsible/unsound engineering and, already failed where it’s been tried.” He noted that he did not have the space to make the point that RAPID will give developers authority to use eminent domain for transmission. He thinks that this is something we all need to push back on with local and state elected reps.
I agree with Dennis that “New York is intent on pursuing an expensive land-hungry plan which we already know will fail.” He speaks to reality and in the end reality always wins.
On February 6, 2024 the PEAK Coalition sponsored a webinar entitled “Replacing NYC’s Peaker Plants With Clean Alternatives: Progress, Barriers, and Pathways Forward” that follows up on their recent report: Accelerate Now! The Fossil Fuel End Game 2.0. There are disconnects between the findings of that report and the first webinar of this year’s New York Cap-and-Invest (NYCI) Program stakeholder engagement process: The Role of Cap-and-Invest (slides and webinar video) and the material presented at the Department of Public Service Proceeding 15-E-0302 technical conference held on December 11 and 12, 2023 entitled Zero Emissions by 2040.
I did not intend to write so much about this topic but Pragmatic Environmentalist the Baloney Asymmetry Principle came into play. Alberto Brandolini has explained that: “The amount of energy necessary to refute BS is an order of magnitude bigger than to produce it.” My apologies for the length.
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 380 articles about New York’s net-zero transition. The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.
Overview
The PEAK coalition has stated that “Fossil peaker plants in New York City are perhaps the most egregious energy-related example of what environmental injustice means today.” The influence of this position on current New York State environmental policy has led to this issue finding its way into multiple environmental initiatives. I have prepared a summary of this issue for this blog that explains why the presumption of egregious harm is based on selective choice of metrics, poor understanding of air quality health impacts, and ignorance of air quality trends. The page documents my concerns based on my extensive experience with air pollution control theory, implementation, and evaluation over my 45+ year career as an air pollution meteorologist. Before I discuss their latest report and the webinar I provide some background information from the Role of Cap-and-Invest webinar and the Zero Emissions by 2040 technical conference.
Relevant “Role of Cap-and-Invest” Webinar Findings
I explained in my post on this webinar that the “Current Emissions” section of the webinar set the stage for the webinars that covered emissions and costs. One of the primary points made was that inhalable particulate (PM2.5) emissions are primarily from non-peaking power plant sources. The following slide shows that “Individually controlled (permitted) stationary sources, including electric generation units, large industrial sources, and large commercial and institutional sources represented approximately 4% of the total.”
The next slide in the webinar described the sources that create inhalable air pollution burdens in New York. It points out that:
Individually controlled (permitted) stationary sources yield a minority of the air pollution emissions in New York.
In 2020, electric generation units represented 8.5% of non-wood fuel combustion PM25 emissions in NY, and other permitted sources represented approximately 3.5%.
Area and mobile sources dominate, which means that individual stationary source-focused policy is important but doesn’t address the bulk of sources.
The webinar slides also explicitly address power plant emissions in New York. The next slide addressed electricity sector emissions. It states that:
Existing policies will go a long way to addressing sources of emissions in the electric sector.
RGGI, the Clean Energy Standard, and other programs will substantially reduce the use of fossil fuels for our electricity needs.
The Peaker Rule will ultimately retire the most polluting plants in New York. 35 peaking units representing 955 MW have already retired and an additional 265 MW are expected to retire in 2025.
NYCI cannot be designed to compel the closure of individual generators, and pricing may not reduce the use of peaking facilities.
Relevant Zero Emissions by 2040 Technical Conference Findings
Unfortunately, the Public Service Commission has not announced availability of a recording of the Zero Emissions by 2040. technical conference held on December 11 and 12, 2023 so details are still not available. I published a summary of the presentation given by Zachary Smith from the New York Independent System Operator (NYISO) describing a new category of generating resources called Dispatchable Emissions-Free Resources (DEFR) that are needed to keep the lights on during periods of extended low wind and solar resource availability. It is important to note that the meteorological conditions that cause the low wind and solar resource availability also are the same that cause the highest load peaks. As a result, DEFR will eventually be needed to replace peaking power plants.
I think the ultimate problem for reliability in an electric system that depends on wind and solar is illustrated in the following slide from Smith’s presentation. It highlights a 7-day wind lull when the average wind capacity is 25%. The sum of the grey area under the load curve during that period is the amount of energy (MWh) that must be provided by DEFR sources based on an analysis of historical weather data. Note that the load curve peaks during the low wind and solar resource availability drought. If there are insufficient resources during a wind lull, then electric load cannot be met, and a blackout will occur.
Zachary Smith included a slide (shown below) that describes the generating resource expected for the Climate Act to make the point that a large amount of new generating resources needs to be developed. Note that in both scenarios the amount of DEFR required (purple column) is on the order of the current existing fossil capacity (orange column).
New York City has the densest concentration of urban power plants in the US, impacting the health of 750,000 New Yorkers and increasing the cost of electricity for all utility customers.
The PEAK Coalition — UPROSE, THE POINT CDC, New York City Environmental Justice Alliance (NYC-EJA), New York Lawyers for the Public Interest (NYLPI), and Clean Energy Group (CEG) —aims to end long-standing pollution from fossil fuel peaker power plants and the negative effects on New York City’s most climate-vulnerable people.
In a new report, the PEAK Coalition documents progress made since the coalition was founded and examines the steps taken by state, city, utility, and energy industry stakeholders to hasten or delay the shift from polluting power plants to clean, zero-emissions alternatives. The report, “Accelerate Now! The Fossil Fuel End Game 2.0“, details evidence of encouraging progress, with 700 MW of the city’s peaking capacity fully retired and announced plans for the retirement of an additional 3,300 MW before 2040, representing nearly two-thirds of the city’s fossil peaking capacity. However, the transition has not progressed at the pace needed to protect the health of environmental justice communities and meet the state’s climate goals. More than 75 percent of the city’s dirty and inefficient fossil peaker capacity may remain online and operating beyond 2025, when stricter peaker plant emissions limits are intended to take full effect. In this webinar, hosted by CEG for the PEAK Coalition, report authors will discuss the negative impacts these power plants are having on surrounding communities, highlight progress and barriers impeding the speed of the transition, and recommend pathways forward to accelerate the transition from peaker plants to clean alternatives.
Below I describe some of the points that the author saw fit to highlight and compare this work to the NYCI webinar and DEFR conference.
Disclaimer
This document is a perfect example of grey literature. Grey (or gray) literature is defined by the Cochrane Handbook for Systematic Reviews of Interventions as “…literature that is not formally published in sources such as books or journal articles.” “This can include information such as government reports, conference proceedings, graduate dissertations, unpublished clinical trials, and much more.“ The key point with respect to grey literature is that anyone using must independently check the analysis. If the data, methodology, and results are not transparently available, then the results should be questioned.
It is troubling to me that references to previous reports from the Peak Coalition have not recognized that the work did not fully disclose the data, methodology, and results, was not peer-reviewed, or disclose that it was not endorsed by the Department of Environmental Conservation (DEC). In that regard it is interesting that a new disclaimer section is included in this report that states:
This document is for informational purposes only. The authors make no warranties, expressed or implied, and assumes no legal liability or responsibility for the accuracy, completeness, or usefulness of any information provided within this document. The views and opinions expressed herein do not necessarily state or reflect those of funders or any of the organizations and individuals that have offered comments as this document was being drafted. The authors alone are responsible for the contents of this report. Before acting on any information, you should consider the appropriateness of the information to your specific situation. The information contained within is subject to change. It is intended to serve as guidance and should not be used as a substitute for a thorough analysis of facts and the law. The document is not intended to provide legal or technical advice.
It would be interesting to know why this was added because it clearly expresses my concerns with its contents.
Highlights of the DocumentFossil Fuel End Game 2.0
Most of the technical aspects of this document I have already addressed in previous posts. The PEAK Coalition report entitled: “Dirty Energy, Big Money” describes the original analysis designed to vilify all New York City peaking power plants. I described that work in three posts. I published a post that provided information on the primary air quality problem associated with these facilities, the organizations behind the report, the State’s response to date, the underlying issue of environmental justice and addressed the motivation for the analysis. The second post addressed the rationale and feasibility of the proposed plan to replace these peaking facilities with “renewable and clean energy alternatives” relative to environmental effects, affordability, and reliability. Finally, I discussed the Physicians, Scientists, and Engineers (PSE) for Healthy Energy report Opportunities for Replacing Peaker Plants with Energy Storage in New York State that provided technical information used by the PEAK Coalition.
For this article I am going to respond to some of the highlighted sections in the report. For example, one of the big issues in the Dirty Energy, Big Money report is highlighted:
Analysis of capacity payments found that an estimated $4.5 billion in ratepayer dollars flowed to the owners of the city’s fleet of peaker plants over a decade. These exorbitant payments to peaker plant owners make electricity from New York City’s fossil fuel peaker power plants some of the most expensive power in the country.
This is a good example of poor understanding of the role of peaking power plants by the PEAK Coalition. These facilities operate for a small percentage of the time (typically less than 5%) but fulfill a critical reliability support function. They only run during peak load periods when insufficient generation resource adequacy could lead to a blackout. The power market pays the highest prices during peak load periods in part because these facilities must get support for all their annual operating costs during the limited periods. The Coalition does not acknowledge the tradeoff that without the peaking units, there will be blackouts.
The Peak Coalition narrative relies on emotion. There is a specially highlighted section entitled: “Peakers and a Legacy of Community Harm: A Story from the Bronx” written by Victor Davila, Community Organizer, THE POINT CDC; He writes:
The people of the South Bronx share a universal trauma. Whatever the particulars of their life circumstances, every child growing up in the South Bronx is acutely aware that the city does not care about them. The moment they step outdoors, it is clear that their neighborhoods are unimportant to the city. The infrastructure reflects historical scorn for their existence. The Bronx burned for a decade in the 1970s and 1980s, and city officials stood by and watched. Landlords set fire to buildings for insurance, and in reaction, local legislators slashed fire department funding to the Bronx in the hopes of driving residents out.
But thanks to the strength of community members, the spirit of the Bronx was able to resist the decade of fire; however, since then its infrastructure has continued to slowly choke the health of its residents.
There is no question that there has been disproportionate harm to disadvantaged communities (DACs), but the emotional implication of this text is that it has been the result of a deliberate action by outsiders. Never mentioned in the Peak Coalition reports is that there have been marked improvements in air quality and that most DACs are in compliance with most National Ambient Air Quality Standards. Instead, the report highlights asthma effects: “In the Hunts Point neighborhood of the Bronx, one in every three children and one in every four adults suffer from asthma.”
The number of confounding variables associated with asthma is very large including things like smoking and indoor air quality. One inconsistency never reconciled by the Peak Coalition is why asthma rates are increasing at the same time air quality is improving.
Another highlighted section notes that: “In 2022, 7 percent of the electricity produced in upstate New York came from oil and fracked gas, whereas more than 95 percent of electricity produced in and around New York City came from oil and gas plants.”
This is another example of a poor understanding of the electric system and tradeoffs associated with the peaking units. Upstate load is near the hydro projects on the Niagara and St Lawrence Rivers and four nuclear power plants so oil and gas is not needed as much as in the City where these same groups cheered on the closure of 2,000 MW of zero-emissions nuclear power. In addition, there are specific reliability rules for in-city generation limit the amount that can be transmitted into the City. The rules were added because insufficient in-city generation caused the 1977 blackout. Lightning strikes abruptly reduced the amount of generation transmitted into the city and the in-city power plants were unable to ramp up load in time to prevent the blackout. The quick start capability of many of the peaking units is a service that must be replaced before all units can retire.
Progress to Date Chapter
The Peak Coalition admits that the New York State Department of Environmental Conservation (DEC) has recently adopted the so called “Peaker Rule” that sets more stringent ozone season NOx emissions limits for simple cycle and regenerative combustion turbines that will eventually phase out old, inefficient, and relatively dirty units. A highlight points out that: “Replacing and retiring these older fossil units could reduce 1,849 tons of NOx emissions on some of the highest ozone days of the year, with its biggest impact felt in nearby communities.”
A point of clarification is that the tonnage refers to the annual total emissions not daily totals. It is also important to note that the emission limits include specific reliability provisions that affect implantation timing. The units can only be retired if the New York Independent System Operator (NYISO) signs off that they will not be needed for resource adequacy.
A prominent argument in this report is summarized in this highlight: “Despite the Peaker Rule taking full effect, New York City may still have more than 75 percent (4,591 MW) of its fossil peaking capacity online and operating in 2025.” The tradeoff between keeping these units online and operating and their contribution to keeping the lights on is not emphasized.
Generating Company Plans
From what I can see, the advocates representing the Peak Coalition will be satisfied with nothing less than zero-emissions. The report addresses each company that has power plants in New York City and includes the following quotes from the highlights in each section:
“We remain steadfast in our fight for an emissions-free future for Asthma Alley residents and all New Yorkers in line with New York’s climate goals.” – Daniel Chu
“Can NYC become the first city in the nation to have all its peaker plants replaced? We believe we can—especially if we follow the visionary direction established by the New York State Climate Leadership and Community Protection Act.” – Eddie Bautista
I think there is a disconnect between what the Peak Coalition thinks this represents and the electric market itself. The report sums up Eastern Generation plans as follows:
In June 2022, the PSC approved Eastern Generation’s permit to build a 135-MW energy storage system at the Astoria Generating Station facility. In a statement about the approval, Eastern Generation again noted that the company is planning to submit applications for additional storage projects at Gowanus and Narrows, totaling 350 MW of energy storage capacity across the two sites. Eastern Generation has submitted a deactivation notice to NYISO for the 16-MW peaker at the company’s Astoria facility; however, the Peaker Rule does not apply to the three 60-year-old steam turbines at the site. It is unclear whether the development of battery storage at the site will result in the retirement of these peaking units, which have a combined capacity of 943 MW.
Under the existing market dynamic, Eastern Generation is proposing to redevelop its assets at the Gowanus, Narrows and Astoria Generating Station locations. In a de-regulated market developers like Eastern Generation make development decisions based on the market situation which currently favors energy storage assets. Importantly, they have no responsibilities for system reliability. On the other hand, the NYISO must ensure that sufficient resources are available.
There is an important technical qualifier for this discussion that needs to be clarified. All of the numbers provided in the quoted section refer to the instantaneous electric power available from the facilities or the capacity as rated in MW. Consumers pay for energy used per month in kWh. The NYISO resource adequacy planning is also primarily concerned with electric energy in MWh which is 1000 kWh. The existing capacity at the Eastern Generation facilities totals 1,915 MW of nameplate capacity and they can run 24 hours a day during extreme load conditions so can produce 45,960 MWh of energy. The proposed energy storage capacity is just 350 MW and current energy storage lasts only four hours, so the total energy production is a paltry 1,400 MWh or 32 times less potential available energy than the existing facility. The lower energy availability is not Eastern Generation’s problem but is the crux of the NYIOSO resource adequacy concerns for New York City.
I don’t think the Peak Coalition understands the implications of the difference between capacity and energy. The report states:
“These findings support previous reports put out by PEAK—that battery storage could replace
the operations of each individual NYPA peaker power plant in NYC, coupled with clean renewable energy sources on the grid, by 2030”. – Eddie Bautista
Next, I will review the report’s section on transition challenges that provides the support for this statement.
Challenges Impeding the Transition
Supporters of the Climate Act maintain that the net-zero transition is only a matter of will. The introduction for this chapter notes that “market barriers, regulatory obstacles, and other challenges have slowed progress and threaten the state’s ability to meet its climate mandates.” There is no indication that the challenge identified previously, or the issues raised at the Public Service Commission technical conference have been considered in the analysis.
The report correctly notes that as sectors reduce their GHG emissions by electrification the inevitable result is increasing demand. The report downplays the effect.
However, increased electrification also represents an opportunity to shift and shape demand in new ways. The timing of EV charging is often flexible, with most vehicles just sitting around most of the time. This creates an opportunity to shift charging to times when demand is lower and renewable generation is plentiful. Many high-power building loads, such as heating and cooling, can also be automatically adjusted to shift the majority of electricity demand to non-peak times while maintaining comfortable temperatures for occupants.
In my opinion, the biggest problem with all the net-zero technology solutions proposed including these, is that they don’t work all the time. EV charging is “often” flexible, but during the coldest periods charging does not work as well so EV owners are going to want to charge when electric heating demand is highest. The opportunity to shift charging to times when “renewable generation is plentiful” ignores the intermittency problems with renewables in general and the worst-case high load and low availability conundrum. Shifting heating and cooling loads to non-peak times presumes that consumers will lose control of their ability to choose their comfort levels. Details matter for these claims!
The report argues that virtual power plants are a potential solution. A highlighted section notes:
Unlike nearby states that have implemented statewide customer battery storage programs to meet peak demand, New York has yet to realize the important role that virtual power plants can play in reducing reliance on fossil peaker plants.
The implication that New York is not considering this option is incorrect. I am very pessimistic about the technology but I could be convinced otherwise if the Department of Public Service Proceeding 15-E-0302 that is addressing the technology determines that it is feasible. Until then claiming that this technology is a suitable replacement for existing peaking power plants is premature.
The report addresses reliability with another highlighted section:
“UPROSE, alongside the PEAK Coalition, is deeply concerned by the NYISO Reliability Report. Emergency rooms get full, and the work and school day is interrupted because of the health impacts our communities have suffered from peaker plant pollution for too long. The 2025 energy reliability gap highlights the urgent need for a swift transition to clean, equitable energy solutions like renewable generation and storage. We urge the state to act decisively in accelerating this transition and ensuring environmental justice for the most vulnerable.” – Elizabeth Yeampierre
There are two problems with this characterization. The first is the mistaken idea that no new technology is needed for the net-zero transition. The Climate Act Integration Analysis, the NYISO resource adequacy evaluations, and the Department of Public Service Proceeding 15-E-0302 all argue otherwise because they point to the need for new DEFR.
The other problem with this is the emotional argument that peaker plant pollution is the root cause of the alleged health effects. The “Role of Cap-and-Invest” webinar confronted this misconception and dismissed the claim. The analysis found that “Individually controlled (permitted) stationary sources, including electric generation units, large industrial sources, and large commercial and institutional sources represented approximately 4% of the total”; for inhalable air pollution burdens in New York “Area and mobile sources dominate, which means that individual stationary source-focused policy is important but doesn’t address the bulk of sources”; and “Existing policies will go a long way to addressing sources of emissions in the electric sector.” The point that “individual stationary source-focused policy is important but doesn’t address the bulk of sources” explicitly contradicts the idea that focusing on peaker power plants will have a discernible effect. In fact, it could have a negative effect by mis-allocating resources to a lower impact problem.
The reliability section also includes this highlight:
All of New York City’s projected load growth and peak demand needs could be reliably met, hour-by-hour, with the right mix of renewables, short-duration battery storage, and efficiency.
This is another statement that contradicts the Integration Analysis, NYISO resource adequacy analyses, and the Department of Public Service Proceeding 15-E-0302 that all conclude that DEFR is needed for a reliable electric system.
In 2023 delays in renewable energy development due to supply chain issues, interest rate increases, and contract negotiations have slowed the pace of renewable developments that could be used to displace the peaking units. A statement from the POINT CDC, UPROSE, and NYC-EJA highlights their concerns with renewable energy economics:
Significant delays for critical renewable energy projects disproportionately impact the health and well-being of communities suffering from fossil fuel power generation. More years of poor air quality will only exacerbate poor health outcomes for Black and Brown communities, and other communities of color. It is also a lost opportunity for a Just Transition for places like Sunset Park and Hunts Point, where offshore wind projects may be a transformative opportunity to ensure that communities most impacted by pollution can grow and flourish under a new green re-industrialization.
The report does not make specific recommendations how this can be resolved but says “These unforeseen interruptions and economic uncertainties must be addressed by the state to ensure that fossil peaking resources are still able to retire on time or even ahead of schedule.” I suspect that this is easier said than done.
The report admits that there are challenges to replacing the peaking power plants in New York City.
In addition to limited space for large-scale renewable energy and energy storage development within the city, New York City has some of the strictest building codes and zoning regulations in the country. These stringent regulations add cost and complexity to the development of solar and energy storage and the implementation of building efficiency measures. Fire department setback and clearance requirements limit the availability of rooftop space for solar panels, and energy storage fire code regulations continue to prevent lithium-ion batteries from being installed indoors, severely curtailing commercial storage development.
The report suggests that these regulatory constraints rather than the limited space and higher in-city development costs are the reason that in-city buildout of clean energy resources in New York City has lagged the rest of the state. I disagree with the suggestion in the report that the “perceived” safety concerns should be revised to accelerate development because I think safety risks are more significant than the report acknowledges and the other factors affecting in-city generation will still slow development relative to the rest of the state.
The section titled “False solutions” epitomizes the single-minded devotion to the demand for zero emissions. The idea that compromise and tradeoffs might lead to a pragmatic lower emissions solution is not acceptable to the ideologues because there still would be some emissioins. The highlight for this section states:
Misguided support for polluting false solutions, such as burning blue or green hydrogen and RNG in power plants, has served as an unnecessary distraction that threatens the state’s ability to achieve its emissions goals mandated by the Climate Act.
False solutions is a commonly used slogan to vilify any technology that does not comport with zero-emissions dogma. Although there are emissions associated with hydrogen combustion and renewable natural gas there are benefits for their use. The placeholder technology for DEFR in the Climate Act Scoping Plan is green hydrogen but it is not commercially viable currently. On the other hand, the technology to burn it in combustion turbines to generate electricity is viable. The ideologues demand that the hydrogen be used in fuel cells which is another technology not in commercial use at the scale needed. This ideological demand makes the DEFR challenge using hydrogen for nthe net-zero transition that much more difficult.
Furthermore, the motives of those who suggest more practical solutions are questioned. Even the widespread support for an analysis of DEFR is characterized as a fossil fuel lobbying effort:
However, at the request of the Independent Power Producers of New York, a trade group representing owners of the state’s fossil fuel power plants, the PSC has initiated a process to “examine the need for resources to ensure the reliability of the 2040 zero-emissions electric grid mandated by the Climate Leadership and Community Protection Act” and is seeking input on how to define zero-emissions, including whether the definition should include green hydrogen.
The highlight for that section notes:
Fossil fuel interests and legacy power plant and pipeline owners continue to push for ways to continue operating existing infrastructure and perpetuate reliance on fossil fuels.
The fact is that until we have suitable replacement technology premature retirement of fossil fuel infrastructure risks serious impacts. The perspectives described are not conducive to developing sound energy policy. As a result, I am not going to bother describing the Peak Coalition’s ideas for a path forward.
The final highlighted section states:
The clean energy transition does not mean sacrificing the reliability of the electric grid, and ensuring the reliability of the grid should not mean sacrificing the health and well-being of New Yorkers.
This is a slogan from biased ideologues who do not understand the complexities of the electric system. I have no doubt that premature shutdown of peaking power plants without acceptable DEFR technologies available will adversely affect the reliability of the electric grid.
Discussion
There are disconnects between the Peak Coalition Fossil Fuel End Game 2.0 report and the findings of the NYCI webinar “The Role of Cap-and-Invest” and the material presented at the Department of Public Service technical conference Zero Emissions by 2040. The rationale that peaking power plants are responsible for all the health effects claimed by the Peak Coalition is contradicted by the DEC/NYSERDA analysis reported in the webinar. The reality is that other emission sources are a much more likely source of health effects. The report states that all the technology necessary is available which contradicts the webinar and PSC proceeding on DEFR and casts aspersions on the motives of the organizations responsible for reliability.
The importance of the PSC proceeding should not be underestimated. The Integration Analysis and all the projections by the NYISO pointed to this need and the Public Service Commission recognized that there are fundamental unanswered questions that need to be addressed. DEFR is a recognized response to the problem that the meteorological conditions that cause the low wind and solar resource availability also are the same that cause the highest load peaks. The Peak Coalition report does not recognize that until adequate DEFR technologies are available and deployed it would be inappropriate to retire any more of the peaking power plants.
It is very frustrating that the environmental justice advocates do not prioritize prevention of blackouts as much as the organizations responsible for reliability. Victor Davila, Community Organizer, The Point CDC claimed that “The Bronx burned for a decade in the 1970s and 1980s, and city officials stood by and watched”. The picture of Davila on the staff page for the The Point CDC looks like he is younger than 46 so has no firsthand knowledge of the impact of the 1977 blackout which included fires in the Bronx.
The impact of the 1977 blackout was felt long after the lights came back on: The blackout cost the city more than $300 million, both directly and indirectly. In neighborhoods affected by burning buildings or looting, the recovery process was lengthy—in some places, it took years to recover. And the blackout led Con Edison to “move[] to avoid the mistakes that led to the blackout, adding sophisticated monitoring equipment and modifying the flawed procedures that drew public acrimony and thousands of lawsuits, some still unsettled,” according to a New York Times article from 1987.
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In some places—perhaps most memorably, Bushwick and parts of the Bronx—the extended power outage led to looting and instances of arson.
The effects of an extended blackout are immediate, acute, and, in my opinion, a greater threat to disadvantaged communities than peaking power plants. The Peak Coalition Fossil Fuel End Game 2.0 report does not adequately account for the complexities of the New York City electric system. Zach Smith’s presentation on DEFRs at the PSC technical conference outlined the need for this resource. There was a panel discussion that addressed other relevant issues, but the recording is not available. One point made was that the location and capacity of generating resources matters. Given the spatial power density of the peaking power plants relative to the proposed energy storage solutions the possibility that they cannot be replaced cannot be dismissed.
Conclusion
Peak Coalition members passionately want the best the communities that they represent. I do not think that electric energy policies that risk reliability and, affordability for that matter, are properly prioritized in their report. The complete focus on peaking power plants is simply not in the best interest of the communities that they purport to represent.
Nonetheless, appeasing these environmental advocacy organizations is a priority for the Hochul Administration. Unfortunately, I do not think that the ideologues will ever be satisfied with anything less than their demands. Their demands are incompatible with a reliable electric system. It will be fascinating to see how this plays out.
Pragmatic Environmentalist of New York 