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.
In early March I posted an article about the addressed the energy needs of Micron Technology’s planned semiconductor fabrication plant. The takeaway message was that, when fully complete, the facility will consume more energy than the State of Vermont. As part of their environmental impact analysis, it was recently revealed that more electric power will be needed. More as in add the electric load of New Hampshire. Earlier this month I did an article on this. This post references an article by James Hanley at the Empire Center that describes other potential ramifications.
One of the implementation components of the (Climate Act) is a cap-and-invest program that sets a price on Greenhouse Gas (GHG) emissions. The first round of stakeholder comments were due in early July. This post provides an update on the process and another upcoming advocacy dogma and reliability conundrum that must be addressed. I recently noted that the retirement of peaking power plants is considered non-negotiable by environmental justice advocates but those facilities are needed for electric system reliability. The same advocates are demanding removal of certain components that are in every emissions trading program variation, such as the New York cap-and-invest, that must be included or the claimed affordability and cost-effectiveness benefits will not be produced.
I have been following the Climate Leadership & Community Protection Act since it was first proposed. I submitted comments on the Climate Act implementation plan and have written over 350 articles about New York’s 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 post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.
Climate Act Background
The Climate Act established a New York “Net Zero” target (85% reduction and 15% offset of emissions) by 2050 and an interim 2030 target of a 40% reduction by 2030. The Climate Action Council 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 and power the electric grid with zero-emissions generating resources by 2040. 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 write a 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. The cap and invest initiative is one of those recommendations.
Computer chip manufacturer Micron has revealed that by the 2040s its Onondaga County factories are going to be sucking up enough electricity to power New Hampshire and Vermont combined. Put another way, in a single year Micron will use enough energy to power the city of Buffalo for more than six years.
All of it is supposed to come from renewable energy—but to date, despite offering Micron $6.3 billion in taxpayers’ money to move to New York, the state has no plan for providing that much renewable power.
Micron predicts it will use over 16,000 gigawatt-hours of electricity annually. To get a sense of how much that is, a gigawatt-hour is roughly the amount of energy produced by a single large nuclear reactor in one hour. Micron’s expected demand is almost exactly what the two reactors at the Nine Mile Point nuclear plant produce each year.
But since their factories will allegedly use 100 percent renewable energy, the big question is where it will come from.
Micron will need to draw 1.85 gigawatts of power from the grid continually, 24 hours a day, to power its operations. The New York Power Authority has offered Micron 140 megawatts (0.14 gigawatts) of hydropower. It may not have that much to spare, except at night when statewide electricity demand drops. But even if it can steadily provide Micron that much power, that’s just over 7 percent of the company’s needs.
Micron has also signed a 178-megawatt (0.178 gigawatt) onshore wind power agreement. That will produce less than 467 gigawatt-hours annually, a mere three percent of Micron’s needs.
Add those together, and 90 percent of Micron’s power demand remains to be determined.
Even before Governor Hochul bribed Micron to come to New York, the state faced a 10 percent deficit in its energy supply by 2040, creating a risky future of probable blackouts due to insufficient power production.
The danger is caused by the state’s climate policies. As consumers are mandated to buy electric cars, and households are forced to switch from natural gas to electric heat, electricity demand is expected to as much as double by midcentury. And 70 percent of that future electricity demand must be supplied by renewable energy.
Because hydropower output will not increase significantly, solar and wind power must increase from their current output of approximately 7,600 gigawatt-hours to as much as 185,000 gigawatt-hours by 2050. When Micron is added to the mix, the need will rise to almost 200,000 gigawatt-hours of wind and solar, a 2,600 percent increase from today.
That’s a challenge New York simply has no real plan for achieving, because the state’s renewable and clean energy goals are based more on wishful thinking than hard-headed analysis about the technical challenges of radically restructuring the state’s power system.
Discussion
I agree with all the points made. I have a couple of other observations.
Hanley notes that Micron predicts it will use over 16,000 gigawatt-hours of electricity annually which is almost exactly what the two reactors at the Nine Mile Point nuclear plant produce each year. Those two reactors have a nameplate rating of 1900 MW.
As an informational scenario, this STAR includes an evaluation of the impact of additional large load interconnection projects primarily in western and central New York. The anticipated increases to the demand forecast due to these large loads in 2025 is 764 MW
Based on the new estimate of electric load needed a new assessment is going to have to incorporate that estimated increase, maybe not in the short-term but necessarily in the longer term.
To put the Micron facility’s usage into perspective, in its last full year of operation the 2 Gigawatt Indian Point nuclear plant generated 16.3 Tera-watt hours so the Micron facility will need to be supported by a 2 Gigawatt fossil fuel or nuclear plant on site or 2.1 Gigawatts of generation off site, 5% more. NY State’s policy makes absolutely no sense. To run the Micron facility would require using about 4 GW of the projected 9 GW of offshore wind to support the plant or 16 GW of solar arrays covering 128,000 acres (80 acres per 10 MW) or 200 Square miles. NY State has 7 million acres of farmland so solar arrays to support the Micron facility would use almost 2% of the farmland in the state and would also require an enormous amount of battery storage, the cost of which would greatly exceed the cost of a nuclear plant on site. A combined cycle generating plant on site would be about 75% less than the cost of the nuclear plant. Both the combined cycle gas plant and the nuclear plant on-site offer the option of recovering the waste heat and using it in the plant to make Micron even more energy efficient. With regard to the solar and wind, NY State is having major difficulties getting all of their renewable projects finished because of cost issues and interconnection issues, let alone adding this gigantic lead weight to the Camel’s back.
Conclusion
Ellenbogen emphasizes the point that “When fantasies meet reality, reality always wins.” Reality is that a modern manufacturing facility needs reliable electrical energy. Available renewable technology such as solar, wind, and energy storage is not currently able to provide the needs of the proposed semi-conductor facility. It was not so long ago that co-generation like that proposed by Ellenbogen was embraced by the environmentalists and politicians. The irrational mandate to go to zero eliminates this pragmatic approach that we know will work. Will the state sacrifice the benefits of the Micron facility to energy fantasy?
One notable feature of New York’s Climate Leadership & Community Protection Act (Climate Act) implementation process has been the emphasis on environmental justice (EJ) for disadvantaged communities. A dogmatic concern of New York City EJ advocacy organizations is peaking powerplants which are alleged to be a primary air quality problem in disadvantaged communities. Unfortunately, those generating facilities fulfill a critical reliability service so the New York Independent System Operator (NYISO) has been warning that premature shutdown of the facilities will cause reliability problems. This post highlights a relevant NYISO filing that concisely summarizes their concerns and recent comments by EJ advocates. Get your popcorn, it will be interesting to see how this gets resolved.
I have been following the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 350 articles about New York’s 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 post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.
Climate Act Background
The Climate Act 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 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 and power the electric grid with zero-emissions generating resources. 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 write a 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.
One of the implementation issues to be resolved is the subject of a New York State Public Service Commission (PSC) “Order initiating a process regarding the zero-emissions target” that will “identify innovative technologies to ensure reliability of a zero-emissions electric grid”. The ultimate problem with wind, solar, and energy storage technologies proposed to replace fossil-fired electric generation is that they do not work all the time. The Integration Analysis, NYISO, New York State Reliability Council, and the PSC order all recognize that a new technology is needed to support the grid during those periods. The problem is exacerbated because the periods when wind and solar resources provide the least power are frequently the periods of highest load when peaking power plants are needed to prevent blackouts.
Peaking Power Plants
I set up a page dedicated to this issue. The following is a top-level summary.
In order to provide electricity to everyone who needs it when they need it the NYISO must balance power availability with the load on the system. NYISO is responsible not only for the real-time delivery of power but also for reliability planning. If the load did not vary, then this would be much less difficult but the reality is that load varies diurnally and seasonally. Most important is meeting demand when loads are highest in the summer and winter because it is necessary to provide electricity to maintain the health and well-being of customers. Ultimately the problem boils down to the fact that there are short periods when so much load is needed that there are generating units dedicated by intent or circumstances to provide power during peak load demand.
About fifty years ago, when Consolidated Edison was responsible for generating power and providing it to their customers, they developed a fleet of around 100 simple cycle combustion turbines at locations within New York City to provide this peaking power. Those units were cheap but relatively inefficient and had high emission rates. In a considered process the Department of Environmental Conservation, NYISO, and the owners of the facilities are in a regulation that ensures that the units either meet more stringent NOx emission limits or shutdown if the NYISO and Consolidated Edison do not identify specific reliability issues. My point is that there is already a process in place to address the units that have always been considered peaking units.
The 2020 PEAK Coalition report entitled: “Dirty Energy, Big Money” is a primary reason that environmental justice organizations vilify all New York City peaking power plants. I described this 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.
There are two relevant aspects of the PEAK Coalition report. That report did not make a distinction between the traditional peaking simple cycle combustion turbines and other power plants that were originally designed for frequent operations. The fuel costs to burn oil at New York power plants is so expensive that they do not generally operate except in peak load periods. “Dirty Energy, Big Money” only defined a peaking unit as one that operates infrequently so the EJ advocates consider these relatively large steam boiler units peakers. The second point is that I found that the presumption of egregious harm from all the peaking facilities is based on selective choice of metrics, poor understanding of air quality health impacts, and ignorance of air quality trends. This is not as dire a problem as it is portrayed.
Peaking Power Plant Shutdowns
Environmental justice advocates believe that it is a problem. Marie French recently wrote a Politico article that noted that “Shutting the units down is a top priority for environmental justice groups in the city”. The article quoted Daniel Chu, the energy planner for the NYC Environmental Justice Alliance: “We think it’s unacceptable that for the sake of reliability, we would have to sacrifice communities for two more years or potentially even longer just to ensure that we don’t have blackouts or brownouts”. He went on to say: “We don’t want blackouts or brownouts, but we also don’t want continued pollution.”
Raya Salter who is the founder of Energy Justice Law & Policy Center and is a member of the Climate Action Council never misses an opportunity to emphasize her belief that these facilities are a root cause of air quality health impacts in New York City disadvantaged communities. In a recent Equity and Climate Justice Roundtable session, she argued that the New York Cap-and-Invest program should make shutting down the peaking units a priority. She believes that equity is only achieved when fossil plant emissions are zero saying that “Anything less than shutting down power plants is a distraction from the goals of the Climate Act”. However, she also says getting to zero mush be done “in a way that prioritizes emissions and co-pollutant reductions in front line communities and does not disproportionately burden disadvantaged communities”.
The disconnect between those goals will have to addressed in another post. You cannot have your cake and eat it too. In this post I will consider the unconditional demand for shutdowns relative to the concerns of NYISO.
NYISO Reliability Concerns
Last month NYISO released its quarterly assessment of reliability of the bulk electric system which found a deficit in reliability margins for the New York City area beginning in summer 2025. I explained that report found that without changes to existing load pattern the summer peak load demand in New York City would be “deficient by 306 MW in 2025 for a duration of 7 hours”. It is possible, due to uncertain load demand forecasts, that the deficiency could be “446 MW over 9 hours.” They found that: “The deficient margin is primarily due to the increased demand forecasts within New York City combined with the planned unavailability of simple-cycle combustion turbines to comply with the DEC’s Peaker Rule in 2025”.
On August 25, 2023 NYISO submitted comments on a petition filed by Alliance for Clean Energy New York, Inc. seeking modification to Clean Energy Standard Tier 1 Renewable Energy Certificate purchase and sale agreements as part of Case 15-E-0302 – Proceeding on Motion of the Commission to Implement a Large-Scale Renewable Program and a Clean Energy Standard. The submittal includes a succinct description of the replacement power problem.
In the introduction to the comments, the letter states:
The NYISO is committed to operating an electric system that provides reliable service 24 hours a day, 365 days a year, and to planning a reliable system for the future grid. The Climate Action Council’s Scoping Plan accurately notes, “[w]hile transitioning away from fossil fuel use, maintaining reliable access to power, whether through centralized or distributed energy sources, is crucial for maintaining good public health in our energy-dependent society.” The NYISO takes no position on the issue of whether, and if so how, REC Agreements should be modified as requested in the Petition and related dockets. The NYISO offers these comments to highlight the importance of developing and deploying generation resources that comply with the CLCPA requirements in a manner that is rationally coordinated with the retirement of existing fossil resources so that system reliability is not jeopardized.
The following is the letter’s comments section (without footnote references):
New Yorkers have long enjoyed reliable electric service and will expect the same level of service to continue. Reliable electric generation supports every aspect of New Yorkers’ daily lives and is vital to the state’s economy. Economic development within the state is driving the interconnection of large loads to the grid and increasing the demand for electricity. As transportation and building heat turn to the electric grid to drive the required economy-wide greenhouse gas emission reductions, people will become even more dependent on reliable electric service for their health, welfare, and safety. Reliable electric service is critical today and will become more critical to everyone’s daily life and general well-being as other sectors of the economy electrify.
Reliable, dispatchable electric generation is in jeopardy as generation retires faster than new resources become operational. Electric system margins have decreased to unprecedentedly low levels. In fact, the NYISO’s Short-Term Assessment of Reliability for 2023 Quarter 2 concluded that the New York City locality is deficient by as much as 446 MW for a duration of nine hours on the peak summer day under expected weather conditions, after accounting for forecasted economic growth and policy-driven increases in demand for electricity. The deficiency would be significantly greater if New York City experiences a heatwave or an extreme heatwave. The narrowing margins and the identified deficiency in New York City demonstrate that the addition of new resources is timely and critical.
NYISO’s ability to facilitate a reliable electric system, including delivery to consumers, requires that the introduction of new resources be coordinated with and occur prior to the orderly retirement of any existing generators. This order of operations is critical for maintaining reliability after such retirements. Electric system reliability margins are already close to minimum reliability requirements in certain areas across New York and continue to tighten, as discussed above. If these margins are totally depleted, the reliability of the grid would be at risk and power outages could disrupt normal life or negatively impact public health, welfare, and safety.
The figures below demonstrate the trend of shrinking reliability margins. Figure 1 shows how resource retirements are beginning to outpace resource additions, notably over the last three years. Figure 2 depicts how this trend is leading to tighter reliability margins in the coming years. While the state’s bulk electric system meets current reliability requirements, risks to reliability and system resilience remain. One key factor driving this risk continues to be resource retirements outpacing additions.
A sufficient fleet of new generation resources that satisfy the CLCPA must be available before more of the existing, traditional generators retire voluntarily or are forced out of service. New generation resources are required now to serve consumers’ needs and to maintain electric system reliability as load increases and existing generators retire. Large-scale renewable energy
generation, offshore wind generation, storage, and distributed energy resources are needed to satisfy CLCPA mandates and to support electric system reliability. Renewable energy generation must still increase substantially to achieve the CLCPA’s 70 percent by 2030 renewable energy requirement and then increase further between 2030 and 2040. This transition will facilitate new renewable resources entering service in the near term, fossil generation will operate less and less prior to retiring, but remain available for when it is needed to serve load and maintain system reliability.
Conclusion
Two opposing viewpoints must be reconciled to resolve the direction of Climate Act implementation. On one hand, there are ideologues who have so far been setting Climate Act policy. Despite their lack of energy system qualifications, they argue that the Climate Act mandates require zero emissions. On the other side NYISO says that introduction of new resources to get to zero emissions must be coordinated with and occur prior to the orderly retirement of any existing generators. Failure to acknowledge this requirement will risk and power outages that could disrupt normal life or negatively impact public health, welfare, and safety.
I believe that those who believe that the Climate Act law has no implementation restrictions are wrong. There are reliability and affordability safety valve provisions in New York Public Service Law § 66-p (4). “Establishment of a renewable energy program”. §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”.
I have never seen anyone else suggesting that this is a possibility so it is likely that I am wrong. In any event, is the Hochul Administration so invested in appeasing the EJ constituency that they are willing to risk causing a blackout or out of control energy costs? In my opinion if the pragmatic approach to put the implementation on hold until the costs are known and reliability risks are minimized, the ideologues will have a meltdown and call for Hochul’s head. There is no sign whatsoever that they will accept any compromises or delays to their demands. As noted in the introduction, get out the popcorn watching this unfold is going to be fascinating.
I have been following the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 350 articles about New York’s 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 post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.
Climate Act Background
The Climate Act 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 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 and power the electric grid with zero-emissions generating resources. 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 write a 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.
My overarching concern with the Comptroller Report is that it underestimates the technological challenges of the net-zero transition. That is entirely consistent with the Scoping Plan and the beliefs that the politicians who dreamed up the Climate Act and the ideologues who controlled the Climate Action Council can develop rational energy policy. The introduction basically says all we must do is try harder:
New York state will have to take multiple steps to increase renewable electricity generation to achieve the objectives of the Climate Leadership and Community Protection Act (Climate Act). Success will also require state agencies to consistently and proactively identify and address problems, continue streamlining permit and interconnection study procedures, and develop the necessary infrastructure to connect renewable projects to the grid and New Yorkers’ homes, according to a report issued today by State Comptroller Thomas P. DiNapoli.
“New York State has rightly pursued an aggressive campaign to reduce greenhouse gas emissions to limit the most dangerous impacts of climate change,” DiNapoli said. “New York’s energy goals are attainable, but require careful attention and management to address challenges, meet ambitious deadlines and avoid future pitfalls.”
My first thought when I heard that the Comptroller had issued this report was why in the world did he get involved. The definition of comptroller, a public official who audits government accounts and sometimes certifies expenditures, wasn’t much help. The responsibilities listed on State Comptroller website includes “Providing independent fiscal oversight on State, New York City and local finances” which I suppose could provide justification.
Fiscal oversight means numbers and the report quotes New York Independent System Operator numbers:
DiNapoli’s report found that renewable generators in New York would need to produce an additional 78,073-gigawatt hours above 2022 levels, an increase of over 200%, to reach the Climate Act’s 2030 goal of 70% renewable electricity consumption. The analysis is based on projections from the New York Independent System Operator (NYISO).
NYISO has also projected that the state would need to add 20 gigawatts of installed renewable capacity by 2030, which is triple the 2022 capacity of approximately 6.5 gigawatts. In the last 20 years, New York added 12.9 gigawatts of total electric generation, including both fossil fuel and renewable sources.
The press release discusses the actions taken to try to meet the targets:
The state has taken steps to address these challenges:
Increased and consistent funding under the state’s Clean Energy Standard facilitated increases in the development of renewable electricity generation. Between 2017 and 2021, at least 1,100 megawatts of projects came under contract annually, compared to between 0 and 726 megawatts annually in the preceding years.
The Department of State’s Office of Renewable Energy Siting (ORES) was formed to streamline the permitting process, and the NYISO has also been improving the interconnection process to bring renewable electricity generation projects online more quickly. Continuing to improve the renewable electric project permitting and interconnection processes to allow for timely approvals, while ensuring community responsiveness and project impacts are mitigated, is critical to achieving the Climate Act goals.
The solutions proposed here are supposed to be a good thing. I am not impressed. Increased and consistent funding translates to throw more and more money at it without a plan that defines what the affordability tolerance level is. ORES is a gift to the renewable energy developers that circumvents environmental protections, home rule, and anything else that could slow down much less stop renewable development. Here is a new flash to the Albany bureaucrats – not all projects deserve to be built. ORES has no responsible solar siting requirements in place so solar developers routinely exceed the Department of Agriculture and Markets guidelines for protection of prime farmlands. My solar development scorecard found that prime farmland comprises 21% of the project area of 18 utility-scale solar project permitted applications which is double the Ag and Markets guideline.
The following paragraph talks about the transmission requirements. All the points raised are legitimate and there are few technological barriers to development. It is just a matter of cost and no one has owned up to the expected costs. The subsequent paragraph acknowledges the problem and implies the problem can be resolved can be resolved if the state wishes hard enough to hold down the costs.
The state will also face challenges given the volume and scale of new projects. The transmission capacity for connecting upstate regions to New York City is limited and renewable facilities in some upstate regions are already being forced to curtail generation due to transmission constraints. Significant new electric transmission infrastructure is needed to allow for the transmission of renewable electricity to customers throughout the state, including interconnect offshore wind projects and additional export capacity from Long Island, and bulk transmission connecting New York City and Long Island to upstate.
The costs of incentives to encourage renewable siting and the costs of transmission projects approved by the Public Service Commission are borne almost exclusively by New York’s utility customers. The state should make every effort to clearly identify how these costs will affect consumer electric bills and must hold down these costs to the state’s electric customers.
The final section of the press release explains “where New York ranks”. It is not clear how relevant the numbers are vis-à-vis Climate Act implementation or why the 2022 data presented in the report were not used. Also conspicuous by its absence is where New York ranks relative to global emissions. Clearly, acknowledging that New York GHG emissions are less than one half of one percent of global emissions and global emissions have been increasing on average by more than one half of one percent per year since 1990 is not a fact that the Comptroller wants to acknowledge lest someone ask what is the point?
In 2020, New York produced 124,912 gigawatt hours of renewable energy, ranking 6th in the nation. This figure includes both renewable fuels, such as biodiesel, and renewable electricity sources, including hydropower, solar, and wind. New York was 3rd in the nation after Washington and Oregon in the generation of hydroelectric power, 10th in generation of solar electricity, and 18th in generation of electricity with wind.
As of 2022, approximately 29% of the electricity generated in the state came from renewable sources. Of this renewable generation, roughly 75% came from hydroelectric generation, with the remaining 25% primarily split between wind and solar.
Report Topics Not Included in Press Release
The press release was not an exhaustive summation of the contents of the Comptroller Report. The report also addressed the renewable energy goals,
The Comptroller Report notes that:
The State’s renewable electric generation averaged 20 percent of total electric generation between 2005 and 2016. Since then, the share grew to approximately 29 percent of State generation in 2022. To reach the CLCPA goal of 70 percent in 2030, renewable generators in New York would need to produce an additional 78,073 gigawatt hours above 2022 production levels, an increase of over 200 percent.
It goes on to describe the New York Independent System Operator 2021-2040 System & Resource Outlook projections for the renewable energy needed. It concludes that the State will have to increase the rate at which renewable electricity projects are permitted and approved for interconnection to the State electric grid.
This leads into a more detailed explanation of the challenges to meet the Climate Act goals.
There are three interrelated processes that play a role in the development of renewable electric generation resources in New York, and the State has faced challenges in each of these processes. These processes work on a parallel basis and project developers do not need to have completed any of the processes before they can enter one of the other processes.
Two of them, permitting and grid interconnection, are required for any all-new sources of generation.
Incentives – Through various programs, particularly renewable energy certificates, incentives are provided to stimulate the market and ensure that there are enough renewable electric generation projects to meet State goals.
Permitting and Siting – The permitting process is intended to ensure that projects are sited in areas and under conditions consistent with State and local laws and regulations.
Interconnection – The interconnection process is intended to ensure that there is sufficient electric transmission and distribution infrastructure to move the electricity generated by the facilities to consumers and that electric service reliability standards are met.
The State faced three key challenges that hindered its progress: inconsistent provision of incentives; project cancellations; and lengthy project timelines due to delays in siting and operationalization.
In the discussion of the inconsistent provision of incentives the report stated that “New York State has used two basic approaches to incentivize the development of renewable electricity generation: contracts for the purchase of renewable energy certificates (RECs) from project developers proposing to build large scale facilities that sell electricity into the State grid; and incentives to reduce the cost of installing small facilities sited behind a customer meter that primarily generate electricity for the customer’s use, but also sell unused electricity into the distribution grid (BTM solar).”
The BTM solar incentive was cited as a success because distributed solar generation has grown steadily. They claim that “the total combined capacity of complete projects and those in the pipeline for all years was approximately 7.1 gigawatts” as the result of increased funding commitments. I don’t think the authors of the report understand that the electric energy planning commitment to providing reliable power at all times is hindered by this program. There is no question that distributed solar generation reduce load requirements, but it creates operating challenges including short, steep changes in load that must be balanced, an oversupply risk when all the solar is operating at peak rates, and decreases resiliency when less resources are operating and available to automatically adjust electricity production to maintain grid reliability. When the costs to address those problems are considered it is clear that success is limited.
The Comptroller Report argues that the RECs program has had mixed results. Each REC represents a megawatt hour of electricity sold into the State’s electric grid. To date: “Most, but not all, of the large-scale renewable electricity generators that move through the permitting and interconnection processes are recipients of REC contracts.” However, an analysis by the Comptroller’s Office shows a lot of variation in the projects that have had contracts:
Funding commitments under the State’s CES increased dramatically, resulting in a significant increase in the projects under contract, as shown in Figure 5. Whereas the last procurement under the RPS in 2016 carried a commitment of $360 million, the funding commitment for the 2017 procurement was approximately $1.4 billion.
The Comptroller Report seems to be surprised by the number of project cancellations:
Between 2005 and April 2023, 28 projects totaling 1.3 gigawatts were canceled—an amount equal to 11.3 percent of capacity under contract during those years—with the largest amount of capacity canceled in 2017, 2018 and 2020. In these years, canceled projects represented 20.4 percent of contracted capacity. Projects may be canceled for a variety of reasons including opposition to the project, changes in the finances of the developer, or unforeseen costs for transmission needed for grid integration.
The report notes that facilities that are operating but have lost their REC subsidies “could potentially enter into long term contracts with consumers outside of the State, which could prevent their generation from counting toward State goals.” However, there is no mention of the operating facilities that already are under contract out-of-state. Robert Bryce reviewed data published by the Department of Energy and the New England Power Pool and found that “of the nearly 4 million megawatt-hours of wind energy produced in New York in 2018, the state exported 1.2 million megawatt-hours, or 30 percent, to New England. Furthermore, the Cassadaga Wind Project that was commissioned in 2021 produces power that was procured through the New England Clean Energy request for proposals’ in 2016 for a group of seven New England utilities. Note that I have never seen an acknowledgement of this in any of the Scoping Plan documentation.
Two additional considerations are mentioned. Getting the power from the wind and solar facilities to where it is needed is described:
New electric transmission and distribution capacity will be needed to connect the new renewable electric generation required to meet the CLCPA goals to the grid. Transmission capacity connecting upstate regions to New York City is limited and renewable facilities in some upstate regions are already being forced to curtail generation due to transmission constraints.
The other issue is affordability. The report notes: “The costs of incentivizing renewable electricity development and transmission upgrades are borne almost exclusively by New York’s utility customers through a charge per kilowatt hour of electricity consumed.” The RECs described earlier are funded by the ratepayers. In addition, the investments necessary to develop the transmission upgrades are buried in the rate cases. The document suggests without justification that this problem will be addressed by existing programs.
Conclusion
Not surprisingly this political document proposes political solutions. The acknowledged problems of the timeline can be resolved if “the projects currently under contract to sell RECs to the State and the projects in the NYISO’s interconnection queue are able to move through the interconnection and construction process and needed transmission and distribution infrastructure is completed in a timely way, the CLCPA’s goal of generating 70 percent of the State’s electricity with renewable technologies appears to be in reach.” The Comptroller’s Report falls back on the it is only a matter of political will faith-based creed. Reality is very likely to make that impossible.
In addition to political will, the report suggests that we can resolve issues by throwing more money at projects. The State’s prior poor performance is chalked up to inconsistent funding commitments. At the same time, it acknowledges that “mechanisms to hold down the cost of meeting its goals on the State’s electric consumers” are necessary.
Against the background that New York’s contribution to global GHG emissions is less than the rate of increase in global emissions my frustration is unbounded. Is it too much to ask Albany politicians to document the expected costs, the potential risks to reliable energy, and the environmental tradeoffs of the net zero transition called for in the Climate Act?
I have a “to-do” list of posts and analyses that I want to do. Some items on the list are over a month old. Rather than adding to the list with articles about specific posts that I have read that I think are relevant, this post describes articles that caught my attention.
I have been following the Climate Leadership & Community Protection Act (Climate Act) since it was first proposed and most of this blog articles are related to it. 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.
Weather and Climate
It seems that every day there is at least one article that claims that a recent extreme weather event is related to climate change caused by humans. Roger Pielke, Jr was prompted to write a post after the Lahaina, Maui fire disaster link to climate change. The post Signal and Noise that addresses this issue and includes the following lessons:
Just because the signal of climate change for particular variables cannot (yet) be detected in the context of historical variability does not mean that climate change is not real or important, and in many, if not most cases, a lack of signal is to be expected.
Natural variability is real and significant. It does not mean that climate change is not real or important, but that detecting signals is often difficult even when climate is changing and there is always a risk of erroneously detecting signals where none is present.
He concludes:
The challenges of detection and attribution should tell us that both adaptation and mitigation policies must be built upon a foundation that involves justifications for action that are much broader than climate change alone.
So far, climate advocates have sought to shape perceptions of science to support a climate-change-is-everything agenda. We will have a lot more success if we instead shape policy to align with what science actually says.
My pragmatic take concerns the tradeoff between the resources devoted to climate change mitigation relative to extreme weather adaptation. I was involved with emergency planning at a nuclear plant so I have experience with this kind of planning. From what I have seen the emergency planning for Lahaina relative to an identified wildfire threat was criminally negligent. Blaming climate change absolves blame for the guilty parties. Trying to mitigate climate change displaces resources that would be better employed to address existing weather problems.
I wrote the preceding paragraph before I read that Bjorn Lomborg said that politicians were blaming climate change for disasters like the wildfires on Maui to duck “responsibility” for “failures” in addressing them. It is reassuring that my thoughts agree with him.
One final note about the Maui fires. Professor Cliff Mass did an excellent job explaining what really happened: a high amplitude atmospheric wave forced by strong winds interacting with the mountains of northwest Maui. He explains that:
It did not matter whether the grass or light vegetation were wet or dry the days or weeks before: this extraordinary atmospheric animal would ensure they were dry enough to burn. Prior dry conditions during the weeks before were immaterial.
With respect to the current state of the climate, Judith Curry, Jim Johnstone, and Mark Jelinek presented a “deep dive into the causes of the unusual weather/climate during 2023. People are blaming fossil-fueled warming and El Nino, and now the Hunga-Tonga eruption and the change in ship fuels. But the real story is more complicated.” They conclude, among other things:
The exceptionally warm global temperature in 2023 is part of a trend of warming since 2015 that is associated primarily with greater absorption of solar radiation in the earth-atmosphere system. This increase in absorbed solar radiation is driven by a slow decline in springtime snow extent, but primary by a reduction in reflection from the atmosphere driven by reduced cloudiness and to a lesser extent a reduction in atmospheric aerosol. Any increase in the greenhouse effect from increasing CO2 (which impacts the longwave radiation budget) is lost in the noise.
Not dire: Humans are safer from climate than ever.
Not temporary: They will rise for decades.
Not in our control: We emit 1/7 of CO2—and falling.
He makes the point that a government “emergency” declaration is a temporary increase in power that should only be used if a problem meets three criteria:
Dire: Unusually deadly
Temporary: Of limited duration
In our control: Actually solvable by our government
His conclusion is that none of the conditions necessary to declare a climate emergency have been met and goes on to support his arguments in detail.
Climate Act and Electric Vehicles
The Climate Act is a political animal. While I focus primarily on the environmental and energy-related issues associated with GHG emission reductions, there is a social justice aka “Green New Deal” component that is a primary interest of many of the Act’s proponents. The contradiction between advocating for zero GHG emissions that will markedly increase energy prices and risk electric reliability that will impact those that can least afford to deal with the problems the most while at the same time demanding investments in disadvantaged communities has always seemed incongruous to me. No where is this tradeoff more stark than in the push for electric vehicles.
While bringing down the cost of EVs is crucial, so is the availability of chargers. And that is something of a chicken-and-egg proposition.
Some on the panel — moderated by CalMatters’ climate reporter Alejandro Lazo — called for building out the charging infrastructure in disadvantaged communities in advance, especially residential chargers.
Steve Douglas, vice president of energy and environment for the Alliance for Automotive Innovation: “You can’t ask low-income residents to spend an hour, three hours, six hours away from their families, every week, just to charge their car, while affluent people pull in, plug in and wake up to a full car.”
But others said without enough EV owners in a neighborhood, it’s a recipe for vandalism and disuse.
Ted Lamm, senior research fellow in the climate program at UC Berkeley’s Center for Law, Energy, & the Environment: “When charging is installed in an area where there is no demand for the vehicles and no local desire to use them, it’s this sort of dead infrastructure. It has no use to the local population and local community, and so it is more likely to be subjected to vandalism, or just disuse and disrepair.”
Montana Court Climate Decision
A group of young people in Montana won a landmark lawsuit on August 14, when a judge ruled as unconstitutional the state’s failure to consider climate change when approving fossil fuel projects. While this has been hailed as a turning point by the usual suspects the reality is different.
Much ado is being made from the supposed win of a kid’s climate lawsuit in Montana. The alarmists call it a victory, the skeptics a tragedy, but it is neither. What was won is almost funny, while the big ask was in fact denied. The climate kids won a little, but lost a lot.
On the win side the judge merely ruled that the Montana law forbidding consideration of GHG emissions in permitting was unconstitutional. How it is considered is up to the agency or legislature. This need not slow down or stop any project.
The Montana constitution says there is a right to a healthful environment. Alarmism says emissions are harmful which all Courts to date have bought, including this one. So given the possible harm, one cannot simply ignore emissions which the law said to do. Hence the decision to kill the law.
Gregory Wrightstone debunked the claim that Montana is a “major emitter of greenhouse gas emissions in the world” and the state’s emissions “have been proven to be a substantial factor” in affecting the climate. He explains:
Montana’s CO2 emissions are 0.6% of the total U.S. emissions. If Montana had gone to zero emissions of CO2 in 2010, it would only avert 0.0004 degree Fahrenheit of greenhouse warming by 2050 and 0.001 degree by 2100, according to the MAGICC simulator, a tool created by a consortium of climate research institutes including the National Center for Atmospheric Research. These numbers are far below our ability to even measure and certainly not the “substantial factor” as claimed.
New York’s emissions are a greater proportion of total U.S. emissions but I have found they are not high enough to measure and are also not a “substantial factor”.
The Montana Attorney General’s office considered arguing against the plaintiff’s witnesses about the alleged harms of climate change. They retained Dr. Judith Curry to prepare evidence but ended up not using it. She explained the inside story, her written expert report, and why she was not asked to testify at the trial. I found it fascinating and there is plenty of ammunition included to debunk many of the arguments used by proponents of the net-zero transition. This will be useful when the inevitable lawsuit is filed in New York.
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”. Implementation of the Climate Leadership & Community Protection Act (Climate Act) started soon after the law was passed at the end of 2019. It was recognized early 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 recently summarized the proceeding and my comments. This post summarizes the comments by Richard Ellenbogen that I think describe the overarching problems of the Climate Act.
I have been following the Climate Act since it was first proposed. I submitted comments on the Climate Act implementation plan and have written over 300 articles about New York’s net-zero transition. I have extensive experience with meteorological aspects of electric generation because I have worked in the sector as a meteorologist for over four decades. I have devoted a lot of time to the Climate Act and the issues raised in this proceeding 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. I represent the Environmental Energy Alliance of New York on the New York State Reliability Council Extreme Weather Working Group. The opinions expressed in this article do not reflect the position of the Alliance, the Reliability Council, the Extreme Weather Working Group, any of my previous employers or any other company I have been associated with, these comments are mine alone.
Climate Act Background
The Climate Act established a New York “Net Zero” target (85% reduction and 15% offset of emissions) by 2050 and an interim 2030 target of a 40% reduction by 2030. The Climate Action Council 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 and power the electric grid with zero-emissions generating resources by 2040. 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 write a 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. The zero emissions analysis is part of that effort.
Ellenbogen Background
I have published other articles by Ellenbogen because he truly cares about the environment and the environmental performance record of his business shows that he knows how to protect the environment while running a business. At the Business Council of New York 2023 Renewable Energy Conference Energy he [BIO] gave the keynote address (presentation and video) – Why NY State Must Rethink Its Energy Plan and Ten Suggestions to Help Fix the Problems.” which I summarized here. His comment submittal includes more background information.
Comments
Ellenbogen’s comments are available on the DPS DMM website. Many of the points in the Business Council keynote presentation were incorporated into his comments.
His introduction notes:
While Mr. Ellenbogen is in favor of the decarbonization identified in the CLCPA, the way that the policy is structured cannot possibly work and it is going to cost the state hundreds of billions of dollars, while not reducing atmospheric carbon, and worse yet, it precludes methods of reducing carbon emissions that actually will work much more rapidly based upon the physics of how utility systems actually operate.
Issues Raised in the Comments
He goes on to describe five issues related to Climate Act bet-zero transition:
There is a lack of available energy to support the Plan
Costs to implement the Plan will far exceed other, better solutions
These costs accrue based upon shortages of materials and skilled labor, high energy storage costs, and a lack of financial adequacy
Atmospheric Carbon Levels will rise far above what could be achieved using other alternatives
Planned timing mandates are unachievable
There are major non sequitur issues contained within the CLCPA
He argues that the Scoping Plan does not accurately estimate the energy available from wind and solar and how much energy will be needed when the electrification proposed is in place. His analyses, indicate that “even if all of the renewables specified in the CLCPA are installed, the state will still be over 100,000 GWh short of what is needed and there will be hundreds of hours of rolling blackouts annually.” He also notes that renewable facility installation rate is falling behind the Scoping Plan schedule.
Ellenbogen has hands-on experience designing, building and operating a low-carbon energy system for his business. Based on that background he believes “project costs will far exceed other, better solutions, based upon a shortage of materials, labor, and capital needed to complete Plan implementation”. This is based on energy storage requirements, transmission upgrades, and the materials and labor needed to resolve those needs.
He points out that GHG emissions will not decrease as quickly as projected because the renewable energy/ carbon free energy resources won’t be available in time. When other sectors of the economy are electrified that means that the additional loads will be supported by fossil fuel generation. He points out that the demands for no new fossil fuel infrastructure means that old power plants will be kept on line longer. He argues that building new, more efficient power plants for the decades long transition is the better solution.
The reason for this proceeding is that there is only one zero-emissions resource that fulfills most of the electric system requirements and nuclear is politically toxic. In addition, it is unlikely that even if nuclear power were embraced it would be unlikely that the targets of the Climate Act could be met. His discussion of schedule issues also raise a problem associated with the proposed dispatchable emissions-free resource (DEFR) included in the Scoping Plan. As envisioned there, these resources will only be used 3% of the time:
That doesn’t work in the real world. Most generating technologies don’t lend themselves well to being dormant 97% of the time. Additionally, based upon the math, the 3% is an extremely low estimate. It would be far more cost effective to build more nuclear generation and fewer renewables. That would remove the intermittency issue and the storage cost issue documented earlier.
Finally, Ellenbogen explains that the conclusions of the Climate Act are based on fantasy. He notes that the projected solar annual energy production from the listed capacity requires an annual capacity factor of 22% but that the state has a solar capacity factor of 13% when the arrays are new. As a result, the calculated solar output is overestimated by 72% or 51,000 GWh. Using the correct solar capacity factor results in only 70,768 GWh of solar output in 2050, 51,000 GWh less. Combined with his estimate that the amount of energy needed is going to be 120,000 GWh more than the 2050 Scoping Plan projections is the reason he believes “that we can expect hundreds of hours of rolling blackouts every year if the Climate Act is executed as planned. “
Viable Alternatives in the Comments
Ellenbogen argues that natural gas-fired combined cycle power plants are a viable alternative during the transition. They can be built relatively quickly and would replace the old more inefficient power plants that have to be kept on-line in the absence of adequate resources. He makes a persuasive case that the huge electricity load of the proposed Micron chip fabrication plant north of Syracuse should include a combined cycle co-generation plant that would provide both electricity and heat for the facility. He explains:
With regard to Micron Technologies, one could be built on-site that would eliminate 350 GWh of line loss while also providing Micron easy access to high temperature thermal energy. The Energy on Demand aspect of the generating plants also eliminates the need for trillions of dollars of battery storage. It is not a perfect solution, but it is a far better solution than “ideal” solutions that can’t be executed because of the previously documented issues. As hydrogen technologies are perfected and a sufficient supply of hydrogen is developed, hydrogen injection technologies can help to further reduce the GHG emissions of the plants.
Overview Conclusion
He concludes:
The prior analysis is based upon facts, math, and physics, not opinions or wishful thinking.. The issues don’t require an understanding of calculus. They just require an open mind and a knowledge of arithmetic. People can’t only say, “Follow the science” when it tells them what they want to hear. Any engineer knows that science, math, and reality can screw up the best plans.
Einstein defined “Insanity” as repeating the same thing over and over again and expecting different results. Why is NY State repeating Germany’s failed renewable experiment that hasn’t worked in 33 years and expecting it to work in seven years or seventeen years. The results in NY State are going to be just as bad as they have been in Germany. However, time is now an issue and significant GHG reductions need to be achieved quickly. The CLCPA in New York State will not be any more successful than Germany policy has been in their efforts to combat climate change.
NY State is currently in the CLCPA, mandating a non-functional utility system which will be plagued by greater fossil fuel use, higher carbon emissions, energy failures, and stability issues that will result in deaths, and a mass exodus of people and businesses that will destroy the tax base and with it, the state economy.
Response to Questions
The zero-emissions proceeding request for comments included 14 questions. He did not respond to specific questions Instead, I quote his response “Regarding Answers to Some of the 14 Questions”:
“How should zero be defined?” Zero is zero. If they meant otherwise, they should have used the word “low”. Carbon offset projects still have to be distinguished from true zero emission technologies such as solar, wind, and nuclear. If the state wants to offer credits to a process that offsets carbon for accounting purposes, that’s fine but don’t call it zero. It should be in a separate “offset” category.
Regarding Carbon Capture, many of the technologies cool the exhaust to separate the CO2 as a liquid and either use it in other materials or pump it underground in a deep well to sequester it. While that will greatly reduce atmospheric CO2, it will greatly increase energy use. That energy has to be accounted for. Where is it going to come from?
Regarding “Green Hydrogen”, hydrogen electrolysis should not qualify. There is going to be an enormous shortage of electrical energy to support the utility system, even if all of the renewables are magically installed. A recent study done in Australia found that if all of their current proposals to produce green hydrogen by electrolysis were implemented, the total energy required would exceed all of Australia’s generating capacity. The math will be no different in NY State. A better solution would be to generate hydrogen by investing in a thermo-chemical process using the waste heat of the nuclear plants to power or by using the NYSERDA Biomass Power Guide qualifying waste to energy plants to generate the hydrogen.
Pragmatic Environmentalist Conclusion
I highly recommend reading his comments. Ellenbogen offers alternatives that would be cheaper, will reduce GHG emissions in the short term, and are technologies that will actually “work much more rapidly based upon the physics of how utility systems actually operate.” Alas he argues that going to zero is not appropriate. The ideologues on the Climate Action Council who shaped the Scoping Plan demand perfection but do not seem to comprehend that the real world makes that impossible.
I don’t think the ideologues understand the risk to their goals. The proposed Scoping Plan cannot work as written and will cost enormous amounts of money. There is no indication that proponents understand the risks to reliable energy inherent in the Scoping Plan and that poor energy policy will cause greater health and economic damage than climate change. When these problems get to the point that they cannot be denied, I believe it is likely that public backlash will be so strong that there will be no appetite for any of the idealistic dogma in the Scoping Plan energy policy. Moreover, even the alternatives proposed by Ellenbogen will be off the table for future energy policy.
I have been following the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 350 articles about New York’s 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 post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.
Background
The Climate Act 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 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. In addition, as the utilities determine what expenditures are necessary to support the Climate Act goals those costs are incorporated into their rate case requests.
Before the utilities in New York were de-regulated there were seven vertically integrated utility companies serving New York. Even though those companies have been re-organized the rate case proceedings are based on the original service territories. Subsequent to de-regulation New York State Electric & Gas (NYSEG) and Rochester Gas & Electric (RG&E) were purchased by Spanish owned Iberdrola and both companies are now in Avangrid. Avangrid Networks, Inc. is a subsidiary of Avangrid, Inc. and “combines the resources and expertise of eight electric and natural gas utilities with a rate base of $11.7 billion, serving 3.3 million customers in New York and New England.” This article documents post
An evidentiary hearing was held in these proceedings on July 17, 2023 and July 18, 2023. The
purpose of the hearing was to receive into evidence and evaluate the Joint Proposal (JP) filed on June 14, 2023. The hearing also provided an opportunity to consider the reasonableness of the JP and develop the record to determine whether the JP is in the public interest in accordance with the Settlement Guidelines of the New York Public Service Commission (Commission). At the hearing, Alliance for a Green Economy (AGREE), Multiple Intervenors (MI), Public Utility Law Project (PULP), AARP, Fossil Free Tompkins (FFT), and Ratepayer and Community Intervenors (RCI) conducted limited cross-examination of the Department of Public Service Trial Staff (Staff) and the New York State Electric & Gas Corporation (NYSEG) and Rochester Gas and Electric Corporation (RG&E; collectively, the Companies) Panel who testified in support of the JP.
The hearing addressed specific issues raised by the parties. I am going to focus on the MI’s cross-examination concerning the affordability of the revenue requirements and other comments related to affordability.
DPS Hearing Brief
The DPS hearing brief argued that the JP helps customers with affordability by mitigating the revenue requirement (Note that all the footnote references have been excluded for clarity):
At the evidentiary hearing, MI’s cross-examination implied that Staff did not adequately consider affordability as part of its analysis of the provisions contained in the JP. Furthermore, MI questioned whether Staff was “aware of the relative economic conditions impacting …your handling of these rate proceedings?” In fact, the JP addresses affordability by: 1) reducing the Companies’ proposed expenditures from their initial filing; 2) accelerating the amortization of the excess depreciation reserve (EDR); and 3) phasing in a necessary increase in storm reserve rate allowance over the term of the rate plan. These provisions significantly reduce the revenue requirement to make the rates more affordable for customers.
The DPS explanation claims that the “proposed revenue requirement increases in the current cases are largely due to the impact of the Covid-19 pandemic (Pandemic) during the Companies’ last rate cases.” During the Pandemic the PSC reduced rate increases “to help customers who were facing economic upheaval by limiting rate increases to less than two percent total bill impact in each rate year of the rate plan”. To achieve this reduction, the PSC cut cost recovery for “energy efficiency program and vegetation management spending; limited recovery of certain storm regulatory assets by extending the time period over which the costs would be amortized; and passed back several regulatory liabilities to customers in an expeditious time period.” They note:
These efforts were warranted given the magnitude of the economic impacts that the Companies’ customers faced at that time, however, these costs and resulting build up of regulatory assets at both NYSEG electric and RG&E electric now have to be addressed in the current proceeding. Although there are unavoidable rate drivers in these cases, Staff has worked diligently to mitigate the impact of the revenue requirements on customers, which is reflected in the JP.
The DPS staff claims that they reduced the revenue requirements in several ways. NYSEG and RGE have reduced discretionary capital expenditures. They “reprioritized the Companies’ electric capital budget and delayed several infrastructure projects that do not address immediate safety and reliability needs.” The DPS brief notes states that “When compared to the initial filing, the JP reflects a reduction to the requested electric capital budget from 2024 through 2026 by $2.28 billion for NYSEG and $280.59 million for RG&E.” My interpretation of this is that these projects will still be needed in the future so they are just being delayed so that this rate increase is not so bad.
Another major cost savings related to vegetation management programs. These programs are needed to improve system reliability and reduce tree-related outages. The JP proposes a vegetation management program that sets NYSEG on a longer cycle of vegetation trimming projects. There is a tradeoff here between the desire to reduce outages and costs.
The JP also utilizes additional excess depreciation reserve (EDR) funds to reduce revenue requirements and help address affordability for customers. This looks like accounting magic to reduce costs but the brief claims that they will be “within the 10% band commonly accepted by the Commission.” It goes on to say “Using any additional EDR could negatively impact the Companies’ credit ratings and would lead to an inevitable sharp rate increase or a hockey stick in subsequent rate cases, when there simply is not any additional EDR that can be used.”
In another example of accounting magic to keep the costs down the JP changes the major storm Operations and Maintenance (O&M) expense allowance to lessen the impact on customers. If there is a major storm and more money is needed than set aside this will come back and result in less timely storm restoration. “Although the revenue requirement allowances for major storm restoration should be much higher based on historical levels experienced at the Companies, Staff supports the inclusion of a lesser amount to mitigate the immediate rate impact on customers.
The DPS brief concludes that “even with the proposed increases, the rates for residential customers of both Companies will remain among the lowest in the State, which demonstrates that the provisions referenced above will help to keep rates affordable for customers.”
Conspicuous by its absence was any mention of Climate Act spending.
Climate Act Spending
The costs associated with the Climate Act were not a subject of the evidentiary hearing. In order to estimate those costs I relied on the June 29, 2022 Technical Conference presentation. I did not try to determine if the costs in this initial proposal are still the same as what ended up in the final rate case but I believe the results are indicative. The following slide lists capital expenditure estimates that includes costs for the Climate Act.
The important part of the slide is the following excerpt.
The following table calculates the total and lists percentages for each program.
There are three capital expenditure programs that are directly associated with the Climate Act. The Electric and Common Capital Expenditures Testimony describes plans. The following plans were associated with the search term “CLCPA” that I think are included in the CLCPA category:
CLCPA Transmission Projects Phase 1
Project Description: The CLCPA Phase 1 Transmission Projects consist of 23 projects for the purpose of unlocking transmission-connected renewable resources by increasing headroom on the system.
CLCPA Transmission Projects Phase 2 “Areas of Concern”
Project Description: The CLCPA Phase 2 “Areas of Concern” Transmission Projects consist of 46 projects for the purpose of unlocking an incremental amount of transmission-connected renewable resources and to increase headroom on the system.
Low Income Clean Generation
Program Description: This project will develop one or more solar photovoltaic (“PV”) facilities at both NYSEG and RG&E. NYSEG will install 50 MW of installed capacity while RG&E will install 20 MW of installed capacity
EV Charging Hub Project
Project Description: This project is a large-scale, purpose-built facility that will serve 10 corridor charging needs for light-duty, medium-duty, and heavy-duty vehicles within the NYSEG service area.
The other two programs are Make Ready and Ithaca Electrification. Make Ready supports electric vehicle (EV) charging infrastructure:” With our new Make-Ready Program, businesses can now quickly install electric vehicle (EV) charging stations with up to 100 percent reimbursement of costs for the electrical improvements needed to support EV charging.” The Ithaca Electrification project is described as local transmission and distribution projects needed to address existing reliability needs and will help to support timely execution of the City of Ithaca’s electrification initiative.” The following might be another description of this initiative.
In addition to the capital expenditure projects other clean energy initiative within the rate case were described that support the Climate Act.
Another major Climate Act initiative is energy efficiency support. The presentation describes the associated costs as follows:
These energy efficiency programs are part of a New York State Energy Research & Development Authority program. New Efficiency: New York (NE:NY) is a “comprehensive mix of strategies to support building developers, commercial and institutional building owners, industrial facilities, and residential households to pursue improvements that reduce energy consumption across the State. These efficiency improvements will enable New York to meet an ambitious new target of 185 trillion Btus (British thermal units) of end-use energy savings below the 2025 energy-use forecast. That’s equivalent to saving the energy consumed by 1.8 million New York homes.”
Apparently DPS staff had an issue with the proposed costs and this was an issue during negotiations. The following table shows the differences.
Affordability Issue
Three parties addressed affordability. The Public Utility Law Project of New York, Inc. (PULP) post-hearing brief described the JP rate increases as a ratepayer “affordability crisis”. AARP New York called the rate increases “unjust and unreasonable”. Multiple Intervenors commented that the “delivery rate increase are enormous” and “unprecedented”.
Multiple Intervenors argued that the delivery rate impacts are magnitudes higher than the impacts that the Commission previously found to be unacceptably high and included the following summary table of impacts. The cumulative percentage total reflects the fact that the first rate-year is in effect for all three years, the second rate-year is in effect for two years, and the final rate-year is in effect for one year. That approach projects that NYSEG electric delivery rates will be double the current rate in three years
Safety Valve
None of the comments raised the safety valve conditions for affordability in New York Public Service Law § 66-p (4). “Establishment of a renewable energy program”. §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”.
Unfortunately, the Hochul Administration has never defined these criteria which I believe should have been a primary responsibility of the Climate Action Council. The criteria used to define “safe and adequate electric service” and “significant increase in arrears or service disconnections” should be defined so that proceedings like this have acceptability limits.
Multiple Intervenors expressed the frustration of ratepayers relative to the desire to support the Climate Act within certain bounds of affordability:
Multiple Intervenors supports reasonable efforts to maintain, if not improve, electric and gas reliability and customer service, and reduce greenhouse gas emissions. Significantly, however, customers of all types need to be able to afford electric and gas service, and that is where the Joint Proposal fails miserably. Although Multiple Intervenors identified many specific areas of concern regarding the Joint Proposal in prior submissions, it is not in a position to unilaterally rebalance often-competing priorities to fix the Joint Proposal’s numerous shortcomings. Rather, that authority and responsibility rests solely with the Commission. Multiple Intervenors urges the Commission to (i) conclude that the balancing of priorities reflected in the Joint Proposal fails to weigh affordability concerns adequately, and (ii) take decisive action to ensure that delivery rate impacts are moderated to acceptable levels. This is no “ordinary” Joint Proposal, the Commission needs to reject or modify it to protect customers from excessive delivery rate impacts.
Climate Act Cost Discussion
The rationale for the increased costs ignores the costs of the Climate Act. I did not find specific information in the Proceeding documentation that summarized all the costs. Note, however, that most of the capital expenditures are related to Climate Act costs which I believe are primarily due to transmission upgrades necessary to get solar and wind project energy to where it is needed. As an aside the primary place it is needed is New York City so Upstate ratepayers are paying to support that need. The bottom line for the Climate Act portion of the capital expense in rate year 4/23 to 3/24 is $603 million of $1,085 million (56%) total. If the costs for advanced metering infrastructure (smart meters) are included as Climate Act costs which I believe is appropriate the rate year costs are $713 million or 66% of the total.
JP Climate Act Implementation
I believe that a major problem with Climate Act implementation is that the vast sums of money attract crony capitalists and rent-seeking opportunists all eager to take advantage of the money. This money is going to come out of the pockets of New Yorkers so these grifters need to be called out. The parent company of NYSEG and RGE is a good example of a company taking advantage of the Climate Act to reduce their risks and make money.
The Iberdrola group has undergone a profound transformation, anticipating the current energy transition by 20 years to meet the challenges of climate change and the need for a clean, reliable and smart business model.
Today, it is a leader in renewables and smart grids, has a diversified portfolio of businesses and geographies, is present in highly rated countries and has demonstrated its financial strength, expertise and execution capabilities. Furthermore, 90% of the group’s long-term investment plan is aligned with the green investment criteria included in the EU taxonomy.
Briefing comments show how they are trying to fleece ratepayers under the guise of supporting the energy transition. Commenters argued that the proposed earning adjustment mechanism, incentive awards for non-wires alternatives and procurement of environmental attributes, and treatment of Climate Act-related capital expenditures all increase the rate case request at the expense of consumers.
This article is already too long so I am not going to delve into specifics of all these adjustments. One example will have to suffice. PULP addressed the 9.2% return on equity (ROE) included in the JP. ROE is considered a gauge of a corporation’s profitability and how efficient it is in generating profits. PULP explains:
The Companies are looking to increase from the current ROE of 8.8%, to the 9.2% ROE, which substantially adds to the already historic rate increases included in this JP. PULP generally urges careful consideration of every aspect of the JP when looking for ways to cut costs. Specifically, we urge the ALJs and the Commission to modify the JP so that the ROE is not set through confidential settlement negotiations, but rather through calculations using the generic finance model, while also providing for an annual recalculation.
The PULP comment argues that uncertainties associated with the Climate Act are not an appropriate reason to increase the ROE as asserted in the JP. They note that it is “reasonable to assume that the risks presented by the CLCPA would be addressed in a manner that is consistent with past Commission policy that utilities should be able to recover all their operating costs and an adequate return on their investments, assuming efficient and economical management”. Cynics like me look at this kind of sweetheart deal and wonder if this part of the political calculus of the Climate Act. The utilities that know that there are enormous affordability and reliability risks for the net-zero transition get a bit more profit for not speaking up about those risks.
Conclusion
The bottom line is that Climate Act costs are a major factor in the extraordinarily large rate case request. No one has stepped up to say that this is an issue in this instance and every future rate case for every New York utility is going to have to have similarly large costs.
Public Service Law §66-p (4) requires consideration of affordability and reliability for Climate Act implementation but the specific criteria have not been defined. New York GHG emissions are less than one half of one percent of global emissions and global emissions have been increasing on average by more than one half of one percent per year since 1990. The Hochul Administration has no plan in place to address affordability. As a result, New York emission reductions are not going to affect climate change, so it is unacceptable to prove that affordability and reliability considerations are not adversely affected.
The PULP briefing notes that recent collection activity reports are a good indication of whether residential customers are currently able to pay their bills. They note:
Unfortunately, these numbers are striking. As of June 2023, 130,637 residential NYSEG accounts were behind on their payments by 60-days or more, for a total of $79.3 million. For RG&E, 78,112 residential accounts were behind on their bills for a total of $61.8 million.
It is unimaginable to me that any reasonable affordability criterion defined per Public Service Law §66-p (4) would find that these rate case impacts would be acceptable. The PSC should temporarily suspend or modify the obligations of the Climate Act until we have a better understanding of the costs to implement the Act.
I sent a link to my All Otsego commentary Zero Emissions Transition Realistic to my distribution list and received some feedback that prompted this article. The commentary noted that the Public Service Commission’s first annual informational report on the implementation of the Climate Leadership & Community Protection Act (Climate Act) included the first admission of ratepayer costs. It mentioned that more costs were coming but I did not estimate specific ratepayer impacts and the feedback suggested that information would be useful. . In the worst case, my analysis estimates that upcoming Climate Act related costs for every utility in the state will be greater than the total current monthly bill.
I have been following the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 300 articles about New York’s 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 post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.
Climate Act Background
The Climate Act 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 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. In 2024, and every two years thereafter, there will be a program review of the progress in meeting the overall targets for deployment of renewable energy systems and zero emission sources and annual funding commitments and expenditures.
The Climate Act’s directives require the Commission to build upon its existing efforts to combat climate change through the deployment of clean energy resources and energy storage technologies, energy efficiency and building electrification measures, and electric vehicle charging infrastructure. In recognition of the scale of change and significant work that will be necessary to meet the Climate Act’s aggressive targets, the Commission directed DPS staff to assess the progress made in line with its directives under the Climate Act and to provide guidance, as appropriate, on how to timely meet the requirements of the Climate Act.
The Scoping Plan does not provide any ratepayer cost impacts but the New York State Department of Public Service First Annual Informational Report on Overall Implementation of the Climate Leadership and Community Protection Act (Informational Report”) does provide estimates for 2022. I have published three articles about the Informational Report: first impressions, a comparison of the goals in the report and the New York Cap-and-Invest (NYCI) Program Reference Case with respect to affordability implications of the Informational Report and NYCI.
Ratepayer Impacts in Informational Report
Much of the information in this section was previously published here. I converted the tables in the Informational Report to a spreadsheet so that I could combine the data from multiple tables. Three tables are of particular interest: Table 4: 2022 Electric CLCPA Recoveries, Table 7: 2022 Typical Monthly Electric Bills with CLCPA related costs disaggregated, and Table 8: Authorized Funding to Date.
Table 4: 2022 Electric CLCPA Recoveries summarizes costs recovered in 2022 by utilities for electric programs. The costs recoveries include: CES (electric only), CEF (electric only), certain VDER (electric only), Electric Vehicle Make Ready Program (electric only), Clean Heat programs (electric only), Integrated Energy Data Resource (electric only), and Utility Energy Efficiency programs (electric and gas). The table states that $1,175,788,000 in Climate Act costs were recovered in 2022. In the context of total ratepayer costs note that transmission upgrades are not included in the 2022 estimates and that there also are gas costs that are relatively small.
Table 7: 2022 Typical Monthly Electric Bills with CLCPA related costs disaggregated is the first admission by the Hochul Administration of potential costs of the Climate Act to ratepayers. The basis for the typical electric delivery and supply bills for 2022 was provided for the following customer types:
A. Residential customers (600 kWh per month),
B. Non-residential customers (50 kW & 12,600 kWh per month),
C. Non-residential customers (2,000 kW & 720,000 kWh per month), and
D. Non-residential high load factor customers (2,000 kW & 1,296,000 kWh per month).
PSC Staff requested that utilities disaggregate the cost components reported in Table 2 (electric) to determine CLCPA related impacts on customers as shown in Table 7. Climate Act costs added between 9.8% and 3.7% to residential monthly electric bills in 2022.
The Climate Act costs in 2022 are just the start of eventual costs to consumers. Table 8: Authorized Funding to Date “gives a sense” of expenditures that will ultimately be recovered in rates. The Informational Report explains:
This annual report is a review of actual costs incurred by ratepayers to date in support of various programs and projects to implement the CLCPA and does not fully capture potential future expenditures, including estimated costs already authorized by the Commission but not yet recovered in rates. To complement this overview of cost recoveries incurred to date, we also present below a table of the various programs and the total amount of estimated costs associated with each authorized by the Commission to date. Table 8 gives a sense of expenditures that ratepayers could ultimately see recovered in rates. These values are conservative and reflect both past and prospective estimated costs.
It is important to note that the Commission authorized some of the estimated costs in Table 8 prior to CLCPA enactment and that the cost associated with these authorized programs will be recovered over several years to come, based on the implementation schedules for these projects or programs and will mitigate the cost impacts to ratepayers year over year. These estimated costs represent either total program budget, estimated total cost for the program over its duration, or costs incurred to date in support of the program. Additionally, these initiatives will result in a variety of other changes that will impact how much consumers pay for energy. A number of these would put downward pressure on costs, including benefits in the form of reduced energy usage and therefore reduced energy bills to consumers. The Department has also previously described market price effects that are a result of these investments. When load is reduced or more low-cost generation is added, it would be anticipated that energy prices would fall because the market would rely less on higher cost generators. In addition, investments in transmission infrastructure not only unbottle renewable energy but also yield production cost savings and reliability benefits.
In sum, the total estimated costs associated with these programs or projects should not be considered as entirely incremental costs to what ratepayers would otherwise pay. Subsequent annual reports may include additional information about costs recovered relative to the funding previously authorized by the Commission in these programs, including funds already expended in support of these programs.
The takeaway message from Table 8 is that the authorized funding to date of program costs that will eventually make their way to ratepayer bills totals $43.756 billion. Note that the spreadsheet version of this table details the footnote costs.
Future Ratepayer Impacts
The ratio of the authorized Climate Act funding to date ($43.8 billion) to the Climate Act costs that have been authorized and were in the 2022 residential bills ($1.2 billion) is 37.2. It is tempting to simply multiply the ratio by each of the monthly Climate Act disaggregated cost components reported by the utilities to determine CLCPA future related impacts on customers. However, this will not give an exact utility-specific estimate because the money authorizations per utility for 2022 and the future will not necessarily be the same. For example, earlier this year I wrote about the PSC approving requests to develop 62 local transmission upgrades that would alleviate congestion on the transmission system to get power to NYC from wind and solar projects upstate. The transmission upgrade projects will cost $4.4 billion to support 3.5 GW of renewable energy. The estimated bill impacts were not the same for each utility because costs were a function of where the upgrades were located. At this time no one knows how the costs will be allocated amongst the utilities.
In addition, the costs will not be allocated all at once. There is no documentation that explains the annual 2022 allocations relative to the total costs of each program. In the worst case all the costs could be allocated in a single year.
In order to give a rough idea, I used a lower ratio. The following table gives a conservative estimate of future costs by using a ratio of 30. I multiplied the ratio of 30 by the 2022 utility-specific monthly Climate Act related costs to estimate the future Climate Act costs. The future total monthly bill equals the 2022 bill minus the 2022 Climate Act related costs plus the future authorized funding Climate Act cost estimated as 30 times the 2022 costs.
Summary of Ratepayer Costs
The informational Report notes that. Climate Act costs that have been authorized and were in the 2022 residential bills total $1.2 billion. The Report notes that in 2022 the costs already associated with the Climate Act increased the Upstate residential monthly electric bills 7.6% or $7.15 per month for NYSE&G customers; 7.7% or $7.54 for RG&E customers; and 9.8% or $9.38 for Niagara Mohawk customers.
The report does not attempt to project future ratepayer costs of the authorized Climate Act funding to date that total another $43.8 billion. Using the conservative ratio of 30 and assuming a similar distribution of costs per utility and that all costs will be in one year, I estimate that the monthly ratepayer costs associated with the Climate Act will total at least $214.50 for NYSE&G consumers, $226.50 for RG&E customers, and $281.40 for NMPC customers. The Climate Act related costs for every utility in the state will be greater than the total current monthly bill.
Discussion
In two recent articles I explained why the claims that the net-zero transition will result in cheaper electricity are rubbish. The claim that wind and solar are cheaper is only possible if you ignore all the additional costs necessary to get the energy to consumers when and where needed. In another post I explained arguments that solar and wind are only cheaper than fossil fuels in at most a small fraction of situations and for the overwhelming majority of the world’s energy needs, solar and wind are either completely unable to replace fossil fuels or far more expensive. These ratepayer costs are for some of the many other services and support necessary to integrate wind and solar into a “zero-emissions” electric grid. I suspect that future additional costs will be at least an order of magnitude higher.
Unfortunately, these are not the only costs for New Yorkers. The Scoping Pan proposes to electrify everything possible. These costs do not include what it will take to electrify home heating, cooking, clothes drying and hot water heating. Nor does it include the costs for home electric vehicle chargers or the very likely need to upgrade the electric service to the residence when everything is electrified. In addition to electrification of the home there will be the costs for an electric vehicle.
These estimated costs are high, but there is no escaping the fact that ratepayers are on the hook for an additional $43.8 billion in Climate Act costs. I admit that the distribution of costs is unlikely to be as concentrated as I have assumed. The absence of an estimate in the PSC report suggests that even if the eventual ratepayer impact is lower, it is still significant.
Conclusion
New York GHG emissions are less than one half of one percent of global emissions and global emissions have been increasing on average by more than one half of one percent per year since 1990. These facts coupled with the extraordinary costs noted in the PSC Informational Report suggest that it is time to step back and wrest control of New York’s energy future from the innumerate ideologues who have foisted the Climate Act on New York.
These costs may not mean New York should not do something but it does mean that we have time to re-evaluate the Scoping Plan. We need determine how much the transition will cost, whether we can maintain current levels of reliability with an electric grid that relies on wind and solar, and determine all the environmental impacts of wind and solar resources at the scale necessary for the net-zero transition before it is too late to prevent an affordability crisis, blackouts, and more damage to the environment from this supposed “cure” than any climate change impacts.
Note that an earlier post was just the copy that links to the page of principles. This post describes the other principles too.
When I started this blog, I included a page of principles that I think represent pragmatic environmentalism. My overarching belief is that it is necessary to balance environmental impacts and public policy. However, I did list specific principles that characterize what is needed to reflect this balance and to highlight specific rules that characterize environmental and energy related issues. This post describes Robert Bryce’s Iron Law of Power Density that I am going to include as another pragmatic environmental principle.
The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.
Pragmatic Environmental Principles
The existing principles cover several of my concerns. An over-riding problem for anyone skeptical of any public policy initiative is exemplified by Alberto Brandolini’s Baloney Asymmetry Principle: “The amount of energy necessary to refute BS is an order of magnitude bigger than to produce it.” After hundreds of posts, I definitely agree with Brandolini
With respect to resolution of environmental issues I have included some observations that should be kept in mind.
Environmental Issues are Binary: In almost all environmental issues there are two sides. Pragmatic environmentalism is all about balancing the risks and benefits of the two sides of the issue. In order to do that you have to show your work.
Sound Bite Environmental Issue Descriptions: Sound bite descriptions in the media typically emphasize only one side of the story. As a result, they frequently are misleading, are not nuanced, or flat out wrong.
Environmental Issues are Rarely Definitive: The binary issue principle states that almost all environmental issues have two legitimate sides because two people can look at ambiguous and conflicting data and come up with opposite conclusions. This corollary principle asserts that as a result there are two legitimate arguments based on how each side interprets data.
There are some underlying factors that should necessarily constrain discourse and resolution of environmental issues:
We can do almost anything we want, but we can’t do everything: Russel Schussler explains that environmental initiatives often are presented simply as things we should do but do not consider that in order to implement those initiatives tradeoffs are required simply because the resources available are finite.
Iron law of climate: Roger Pielke, Jr says the “iron law” simply states that while people are often willing to pay some price for achieving environmental objectives, that willingness has its limits.
Gresham’s Law of Green Energy: Gresham’s Law of Green Energy is named after Sir Thomas Gresham, a 16th-century British financier who observed that “bad money drives out the good.” Lesser shows that green energy subsidies transfers wealth and does not create wealth. The subsidies or “bad” money take money out of the system that was “good” inasmuch as it was being used productively.
Ridley’s Paradox: Matt Ridley notes that economic damage from man-made ‘climate change’ is illusory whereas damage from man-made ‘policies’ to fight the said change is real.
Pareto Principle: The Pareto principle or 80-20 rule states that 20% of efforts or inputs can yield 80% of results or outputs. For environmental issues, it’s important for environmental issues because it suggests that if we don’t aim to achieve 100% reduction we still will have accomplished most of the benefits and removed most of the risks.
Kicking a dead whale on the beach: Engineers will rarely tell you something is impossible, even when your proposal is a very bad idea. Computer scientists at Stanford and MIT in the 1970s came up with a wonderful expression for this, an assignment that was technically feasible, but highly undesirable. They called it “kicking a dead whale down a beach”. Credit to Andrew Orlowski.
Iron Law of Power Density
Robert Bryce makes a persuasive argument that ultimate problem with wind and solar resources is simply a matter of “basic math and simple physics.”
Bryce explains that there are a couple of facets to the Iron Law of Power Density. The first is the effect on resources needed and the second is the area needed to produce power. He describes the effect on resource intensity:
The shape and size of our energy systems are not being determined by political beliefs about climate change. Instead, those systems are ruled by the Iron Law of Power Density which says: the lower the power density, the greater the resource intensity. This can easily be seen in the graphic below. It includes a screen grab from a 2021 International Energy Agency report on the mineral intensity of various methods of electricity generation. The mineral intensity of offshore wind, including huge amounts of copper and zinc, is shocking: roughly 15,400 kilograms per megawatt of generation capacity. That is roughly 13 times more than the amount needed for natural gas-fired generation (1,148 kg) and six times more than what’s needed for a coal plant (2,479 kg).
Bryce points out that this is part of the reason that there are cost issues associated with offshore wind development:
As Howard Rhodes of EnergyPortal.eu explained earlier this month, the offshore sector is facing “a financial crisis as costs continue to rise. Inflation in components and labor costs, along with rising interest rates, has led to a 57% increase in the costs associated with U.S. offshore wind projects since 2021.” Soaring commodity prices have also increased the cost of making onshore wind turbines. By one estimate, the cost of building a wind turbine has surged by 38% over the past two years.
Bryce explains why the area needed to produce power is an important component of the Iron Law of Power Density:
Power density is the measure of energy flow that can be harnessed from a given area, volume, or mass. Power density is a measure of how many watts we can get per square meter, liter, or kilogram from a given source. This article focuses on areal power density. Proving why low-power-density sources are the wrong choice for modern society takes only a modicum of effort.
Let’s start by looking at corn ethanol and other biofuels, which have a power density of about 0.1 watt per square meter. Counteracting that paltry power density requires lots of other resources, including fertilizer, diesel fuel, water, and staggering amounts of land. In 2021, Dave Merrill, a reporter and data analyst at Bloomberg, reported that “Two-thirds of America’s total energy footprint is devoted to transportation fuels produced from agricultural crops, primarily corn grown for ethanol. It requires more land than all other power sources combined.” Merrill determined that biofuels require the cultivation of about 80,000 square miles of cropland. That’s an area bigger than the state of Nebraska.
Bryce summarizes the land-use implications:
The only way to substantially increase the production of wind and solar energy is by seizing more and more land, (or ocean) so they can be covered with more and more steel, concrete, copper, and silicon. As I reported in these pages on August 4, in “Massive Riots, Renewable Resentments,” the backlash against the encroachment of large wind and solar projects is real, it’s global, and it’s growing. As can be seen in the Renewable Rejection Database, the total number of rejections and restrictions on wind and solar in the U.S. now totals 575.
Conclusion
This is an important addition to my list of pragmatic environmental principles. Power density affects the resources needed to develop the resource. Its importance is confirmed as the costs of wind developments have increases significantly recently. In addition, power density means that much more land is needed to develop wind and solar resources.
Robert Bryce makes a persuasive argument that ultimate problem with wind and solar resources is simply a matter of “basic math and simple physics” associated with the Iron Law of Power Density
Bryce explains that there are a couple of facets to the Iron Law of Power Density. The first is the effect on resources needed and the second is the area needed to produce power. He describes the effect on resource intensity:
The shape and size of our energy systems are not being determined by political beliefs about climate change. Instead, those systems are ruled by the Iron Law of Power Density which says: the lower the power density, the greater the resource intensity. This can easily be seen in the graphic below. It includes a screen grab from a 2021 International Energy Agency report on the mineral intensity of various methods of electricity generation. The mineral intensity of offshore wind, including huge amounts of copper and zinc, is shocking: roughly 15,400 kilograms per megawatt of generation capacity. That is roughly 13 times more than the amount needed for natural gas-fired generation (1,148 kg) and six times more than what’s needed for a coal plant (2,479 kg).
Bryce points out that this is part of the reason that there are cost issues associated with offshore wind development:
As Howard Rhodes of EnergyPortal.eu explained earlier this month, the offshore sector is facing “a financial crisis as costs continue to rise. Inflation in components and labor costs, along with rising interest rates, has led to a 57% increase in the costs associated with U.S. offshore wind projects since 2021.” Soaring commodity prices have also increased the cost of making onshore wind turbines. By one estimate, the cost of building a wind turbine has surged by 38% over the past two years.
Bryce explains why the area needed to produce power is an important component of the Iron Law of Power Density.
Power density is the measure of energy flow that can be harnessed from a given area, volume, or mass. Power density is a measure of how many watts we can get per square meter, liter, or kilogram from a given source. This article focuses on areal power density. Proving why low-power-density sources are the wrong choice for modern society takes only a modicum of effort.
Let’s start by looking at corn ethanol and other biofuels, which have a power density of about 0.1 watt per square meter. Counteracting that paltry power density requires lots of other resources, including fertilizer, diesel fuel, water, and staggering amounts of land. In 2021, Dave Merrill, a reporter and data analyst at Bloomberg, reported that “Two-thirds of America’s total energy footprint is devoted to transportation fuels produced from agricultural crops, primarily corn grown for ethanol. It requires more land than all other power sources combined.” Merrill determined that biofuels require the cultivation of about 80,000 square miles of cropland. That’s an area bigger than the state of Nebraska.
Bryce summarizes the land-use implications:
The only way to substantially increase the production of wind and solar energy is by seizing more and more land, (or ocean) so they can be covered with more and more steel, concrete, copper, and silicon. As I reported in these pages on August 4, in “Massive Riots, Renewable Resentments,” the backlash against the encroachment of large wind and solar projects is real, it’s global, and it’s growing. As can be seen in the Renewable Rejection Database, the total number of rejections and restrictions on wind and solar in the U.S. now totals 575.
This is an important addition to my list of pragmatic environmental principles. Power density affects the resources needed to develop the resource. Its importance is confirmed as the costs of wind developments have increases significantly recently. In addition, power density means that much more land is needed to develop wind and solar resources.
It seems that every day we are faced with another claim that we are facing an existential threat from climate change and the proof is right in front of us. So simple, so obvious and so wrong. I do not have time to do my own analysis so I am going to use the work of others to rebut the fear mongering stories about these events tied to climate change in July.
July was the Hottest Month Ever
The story that July was the hottest month in 120,000 years is the best example of the media glomming on to a story that does not stand up to scrutiny. A post at Watts Up With That explains:
Via The Australian: Cliff Mass, professor of Atmospheric Sciences at University of Washington, said the public was being “misinformed on a massive scale”: “It‘s terrible. I think it’s a disaster. There’s a stunning amount of exaggeration and hype of extreme weather and heatwaves, and it’s very counter-productive,” he told The Australian in an interview. “I’m not a contrarian. I‘m pretty mainstream in a very large [academic] department, and I think most of these claims are unfounded and problematic”. …
Professor Mass said the climate was “radically warmer” around 1000 years ago during what’s known as the Medieval Warm Period, when agriculture thrived in parts of now ice-covered Greenland. “If you really go back far enough there were swamps near the North Pole, and the other thing to keep in mind is that we‘re coming out of a cold period, a Little Ice Age from roughly 1600 to 1850”.
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John Christy, a professor of Atmospheric Sciences at the University of Alabama at Huntsville, said heatwaves in the first half of the 20th century were at least as intense as those of more recent decades based on consistent, long-term weather stations going back over a century. “I haven‘t seen anything yet this summer that’s an all-time record for these long-term stations, 1936 still holds by far the record for the most number of stations with the hottest-ever temperatures,” he told The Australian, referring to the year of a great heatwave in North America that killed thousands.
Professor Christy said an explosion of the number of weather stations in the US and around the world had made historical comparisons difficult because some stations only went back a few years; meanwhile, creeping urbanization had subjected existing weather stations to additional heat. “In Houston, for example, in the centre it is now between 6 and 9 degrees Fahrenheit warmer than the surrounding countryside,” he explained in an interview with The Australian.
Professor Christy, conceding a slight warming trend over the last 45 years, said July could be the warmest month on record based on global temperatures measured by satellites – “just edging out 1998” – but such measures only went back to 1979.
Phoenix Heat Wave
Phoenix Arizona had a streak of 31 days when the high temperature was 110 degrees or higher. The article, “Explaining The Heat Wave: Separating Weather From Climate Change,” claims that recent warming trends in Phoenix, Arizona are due primarily to increasing atmospheric carbon dioxide levels in the atmosphere. However, this is false because data show that the high levels of warming, especially at night and as measured at an airport, are primarily due to urbanization over time, with the modest warming of the past hundred-plus years playing a very small part in comparison. Another rebuttal notes:
But, it must be climate change, look how hot it was!” My dear readers, that’s why they named it Death Valley. The Monthly Report from the U.S. National Weather Service for the Death Valley station shows that every day during July this year, the average daily temperature (Daily Maximum + Daily Minimum divided by 2) was in excess of 100 °F (37.7 °C). That’s the average! The daily highs were above 110 °F (43 °C) every single day, above 120 °F (49 °F) twenty of the days.
Is this unusual? Is this “extreme”? No, the U.S. National Park Service reports on the general the Weather in Death Valley: “Death Valley is famous as the hottest place on earth and driest place in North America. The world record highest air temperature of 134°F (57°C) was recorded at Furnace Creek on July 10, 1913. [ emphasis mine – kh ] Summer temperatures often top 120°F (49°C) in the shade with overnight lows dipping into the 90s°F (mid-30s°C.) Average rainfall is less than 2 inches (5 cm), a fraction of what most deserts receive. Occasional thunderstorms, especially in late summer, can cause flash floods.” All of those conditions, except the record high temperature of 1913, occurred this summer in Death Valley, just as the National Park Service advised visitors to expect. There was not any extreme weather, it was usual weather for Death Valley.
Climate Fact Check
If you want short rebuttal summaries to these and other false climate change stories for July check out this fact check report. It covers the following stories: monthly average temperature is the hottest, the UN proclamation that we are in an era of global boiling, the hottest day in 125,000 years, Atlantic current to collapse by 2025, record for hot days in Phoenix, hottest day in Death Valley, emissions causing hot oceans, hottest seawater ever, and more.
Heat Health Impacts
The rationale for alarm for the excessive heat stories is the argument that heat results in more deaths than any other weather-related event. Five years ago I explained why there are analyses that find “most of the temperature-related mortality burden was attributable to the contribution of cold”. Studies that show that extreme heat results in more deaths than any other weather-related event use a data base that only includes direct deaths. An epidemiological study that does include indirect deaths concludes most deaths are associated with moderate cold weather. Roger Pielke Jr. reports how this information can be presented to support the alarmist version:
The Lancet was caught red-handed publishing a figure that, to be as fair as possible, lent itself to misinterpretation (it was first called to my attention by Bjorn Lomborg and is in a paper by Masselot et al. 2023).
Take a look and decide for yourself. Here is the original figure comparing mortality from cold (blue) and heat (orange) in Europe from 2000-2019.
And here is how it looks when the data is graphed using a consistent scale.
Another Examples of Propaganda
We have all seen the graphs that show inexorable global warming. However this article describes how “alarmist scientists have scared the bejesus out of people by turning a very small temperature change into a monster.” Jim Steele writes:
Dr. Lindzen graphed the average seasonal anomalies for each weather station in the BEST temperature data base from 1900 to the present. A station’s anomaly is defined as any deviation from its 30-year mean. The results are not very scary. On any given day about half the weather stations experience warm anomalies while half experience cooling anomalies.
Most anomalies cluster between ± 4°C (+/- 7.2°F) causing each data point to merge into the thick black band of the graph. Still, larger anomalies are not uncommon, so the y-axis of the above graph scales between ± 12°C (+/- 21.6°F). The yellow dots represent the average for those anomalies on any given day. We see a small trend that is relatively tiny compared to the variation in actual temperatures. Not very scary either.
So, the showtime graphs isolate the average anomalies from reality, as done in the bottom graph. Now the scale on the y-axis only spans from -0.8°C (-1.4°F) to 1.2°C (2.2°F), turning a small 1°C (1.8°F) rise over 120 years into the illusion of a monster increase. That allows click-bait media, alarmists scientists and politicians to claim that climate change could lead to mass extinctions.
Reporting Issues Influence Results
Roger Pielke Jr. is an expert on the topic of global disaster accounting. He recently posted an article that makes two relevant points to this post:
Below is the updated time series of global hydrological, climatological and meteorological disasters in the EM-DAT database, along with the linear trend, over the period 2000 to 2022.
You can see that there is no upwards trend. This lack of trend has not been reported by anyone in the legacy media (and I would be happy to be corrected). However, the completely false notion that global weather and climate disasters have increased and will continue to increase is commonly reported in the legacy media, buoyed by the promotion of false information by organizations that include the United Nations. In 2020 the U.N. claimed falsely of a “staggering rise in climate-related disasters over the last twenty years.”
The second point he makes is careful examination of the disaster data clearly shows that “the increase in disasters in its database to 2000 is due to better reporting, and not changes in underlying counts of actual disasters.” He concludes: “Regardless what happens with trends in disaster counts, it is absolutely essential to remember that if you are looking for a signal of changes in climate — always look directly at weather and climate data, not data on economic or human impacts.”
Conclusion
There is a constant barrage of doom and gloom articles connecting any extreme weather event or disaster to the existential threat of climate change. In my opinion they all are more propaganda than unbiased reporting. Every time I have checked a weather event attributed to climate change claim on my own, I have found that the issue is more complex and less threatening than portrayed. Don’t get scared by these stories!
Pragmatic Environmentalist of New York 