Climate Act Costs & Benefits – Page 4 – Pragmatic Environmentalist of New York

Peer Review and Costs of Building Electrification for Commercial Users

This is an article primarily by Richard Ellenbogen that estimates projected annual operating costs and emission reductions for New York commercial facilities when the new building codes are implemented. It is also an example of how peer review should be done.

I am convinced that implementation of the New York Climate Act net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks. I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 500 articles about New York’s net-zero transition. The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

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

Heat Pump Hype

I am a long-time critic of the New York State Energy Research & Development Authority’s (NYDSERDA) biased promotion of all green energy technologies. Their description of cold climate heat pumps is a good example: “Today’s cold-climate heat pumps are a smarter, more efficient option to keep your home comfortable all year long. These all-in-one heating and air conditioning systems are environmentally friendly, extremely efficient, and affordable to operate.” In another example, they breathlessly exclaim that heat pumps outsell gas furnaces for the second straight year. This claim uses national figures and could be solely the result of new building sales that are much stronger in southern states where heat pumps are a cost-effective choice. Ellenbogen addresses the affordability claims below.

Ellenbogen Heat Pump Experience

Ellenbogen installed geothermal heat pumps when his house was completed in 2004. He has 21 years of experience with them and has maintained a database of the performance and costs. His monitoring system includes temperature sensors on the inputs and the outputs of the wells and water flow. Because he uses a geothermal system, he can rely on it even during the coldest periods when air source heat pumps cannot extract enough energy from the air to keep the house warm. Furthermore, his system uses deeper wells than are currently allowed by law that were legal when the system was developed. They are also open loop which greatly increases their efficiency but that is also no longer allowed. In his configuration, his heat pumps can pull 7 tons of heat transfer per well where current geothermal wells are limited to about 2.5 tons per well. As a result, his system can achieve a Coefficient of Performance (COP) of about 5.5 whereas current Geo-thermal systems can achieve a COP of about 3.5 with the restrictions on well depth and having to be closed loop. During long periods of cold temperatures that force the heat pumps to run for extended periods, the well temperatures can drop and the efficiency of the system decreases so it will use more energy.

One of the things I admire as a techno-weenie is Ellenbogen’s quantitative nature. He built his house “as a science project to satisfy his intellectual curiosity” and it has yielded an enormous amount of data. When the Indian Point nuclear station was operating, he ran a calculation and found his geo-thermal system was about 7% more carbon free than his 95% efficient modulating gas boilers that were originally installed as a backup in case of a power failure. After New York politicians shut down Indian Point the carbon emissions of local electricity increased and the GHG emissions advantage vanished. Given his concerns about GHG emissions he decided to figure out a cost and energy comparison. He turned the heat pumps off this winter and used the duplicate gas system to compare with multiple years of data with the heat pumps operating.

The results are notable. His gas bill went up less than the electric bill went down and this is for an electric system with an efficiency 57% higher than what can be built now during a colder winter. The electric bill was about $8600 lower than it would have been with the heat pumps operating. The gas bill only went up by $6057 for a net savings of $2543 using the natural gas heating and the current winter has been 120 degree days colder than last year. That figure has been adjusted for the higher electricity prices this year. Note that the heating system is well designed with 14,500 square feet of high mass radiant floors that use 100-degree water in the system and 18 separate zones which makes it even more efficient. The large scale of the system removes measurement aberrations that might occur with a smaller system.

To compare the costs of heating with electricity and natural gas it is appropriate to compare the cost to generate the same amount of heat. Table 1 lists the cost for the delivery of one therm (heat energy equal to 100,000 British thermal units) between a 95% efficient boiler and electric heat at relationship different Coefficient of Performance efficiency values. A COP of 1 is inefficient. A highly efficient ground source heat pump has a COP of 3.5. Even an efficient ground source heat pump is 16% more expensive ($2.85 for one therm compared to $2.45 for a 95% efficient gas system in the Downstate New York area which covers 60% of the state’s population. Also note that air source heat pumps on a very cold day can reach COP’s of 1 – 1.5 and easily go below 2. As a result, they can be two to three times as expensive to operate.

Commercial Facility Projection

New York State legislators passed a prohibition on the installation of fossil fuel equipment and building systems starting in 2026 for small buildings and 2029 for larger ones. The prohibition starts in 2026 for new buildings up to 7 stories tall, except for commercial and industrial buildings larger than 100,000 square feet. There are exemptions for certain types of buildings including emergency backup power systems, manufacturing facilities, commercial food establishments, laboratories, hospitals and medical facilities, critical infrastructure (e.g., water treatment plants), agricultural buildings, crematoriums.

Ellenbogen applied the numbers derived from his house experiment to his business and extrapolated them to the 55,000 square foot factory which would fall under the less than 100,000 square foot rule for new construction after 2026. Admittedly, there is no law currently in place that would require a developer who wanted to replicate Ellenbogen’s manufacturing facility because of the exemptions. Eventually, however, the net-zero mandates will require all electric construction of all new facilities and for the replacement of existing equipment before the end of useful life. Therefore, it is a relevant example of Climate Leadership and Community Protection Act (Climate Act). costs.

Ellenbogen’s home has a backup gas boiler heating system and his manufacturing plant has a combined heat and power system. In 2002 he installed the first microturbine-based Combined Heat and Power (CHP) system in the Con Ed service area. This approach generates electricity by burning natural gas. Waste heat is recovered “to heat the building in the winter, or to be sent to absorption chillers to cool the building in the summer.” This approach allows him to recover 70 to 75 percent of the energy content of the fuel and augments a solar array on the roof.

By doing a thermal analysis of his home’s gas usage he was able to determine what would be needed to heat the factory. The end result is that removing gas from his manufacturing facility would raise energy bills to about $147,000, more than doubling them, and raise his carbon footprint by about 15%. The key takeaway is that even using the most efficient electric heating/cooling system available, it still means that this gas ban policy will cost businesses in NY state enormously while raising carbon emissions. When and if the Downstate New York electric system reaches zero GHG emissions the carbon emissions will be reduced.

Environmental Impacts

Ellenbogen calculated that because the Downstate electric system is CO2 rate is 950 pounds per MWh according to 2022 EPA data, that the CO2 emissions from using the CHP system are actually less than if heat pumps were used. He also pointed out he has replaced three compressors in his home’s ground source system over the past 21 years and each time the failure resulted in a full loss of refrigerant. He said that it is not preventable and that you only find out when the unit gives a fault code with no early warning.

Discussion

This post is based on three emails from Ellenbogen. I did not include all the calculation details he provided in the originals but will provide them if requested. The reason for the three versions is that the details provided enabled a reader to point out an issue that he corrected. Ellenbogen noted that:

Those damned Laws of Thermodynamics are getting in the way again, but this may be a teaching moment to show what a real peer review looks like and that we have to acknowledge errors to make sure that the best information is in the public space. It also is a clear example of how we can’t escape those Laws in our calculations. Miscalculations introduce errors and a failure to account for the Laws of Thermodynamics entirely when setting energy policy introduces huge errors.

This raises an issue with the implementation of the Climate Act. The agencies responsible for the implementation plans have not provided adequate documentation to enable detailed review of the plan. Even if it is possible to make a detailed comment on an obvious issue, there hasn’t been any acknowledgement of any problem, much less evidence of a revision to the plans. The appropriate peer review process exemplified by Ellenbogen’s analysis is not a feature of the Climate Act stakeholder process. As a result, Ellenbogen notes “errors are apparent across the entire spectrum of NY State’s Energy plan.”

Ellenbogen summarized his peer review concerns in this regard.

While I hate to beat on academia, it has a great deal of responsibility for NY State’s energy mess. A certain University Professor that sat on the Climate Action Council still refuses to acknowledge that all of the technologies for this transition do not exist despite a Public Service Commission conference determining that fact in 2023. Unfortunately, people in the legislature and certain environmental groups have adopted those ideas despite there being known large deficiencies in those theories as it applies to putting them into practice. Untested theories that can’t be put into practice in the “Real World” are dangerous for society. State residents shouldn’t be turned into a science project and that is what is happening.

I received the following response to my email from a retired professor that now works in industry. I have redacted portions to keep them anonymous. While on average, the refrigerant replacement is every 20 years as there are three heat pumps, their observations are profound and are critical to understanding a huge issue now facing the NY State. It follows in italics.

This is the most sobering analysis of a heating system I have ever read. I constantly hear about the miracles of heat pumps, but the carbon footprint is never honestly presented. Plus the replacement of freon every 7 years is never included. Thanks for providing a clear analysis of a day in the life of a NY business and resident.

I’m still enjoying life in XXXXXXXX, and in no longer being a professor. Academia lives in a bubble, and you can’t see that until you leave. Professors need to do a real sabbatical leave in industry and be forced to solve real problems, not problems they dream up. It’s tough out here! I thought I knew something about XXXXXX after XX years as an academic doing research, but XX years at XXXXXXX has shown me I have much to learn. It is stimulating, I’m glad to be here. They need to have a similar experience.

Regarding the statement above, one of the reasons that the carbon footprints of heat pumps is never honestly mentioned is that the loudest voices in the space are the people selling them and other people don’t have enough experience to question the results. I’ve been using them for 21 years. My house was built as a science project to satisfy my intellectual curiosity. It has yielded an enormous amount of data, some of which has been used by the state.

One of the major issues that I have with NY State policy is that many of the people that are hired to do the energy analyses for the government actually work for the manufacturers or other interested parties. The reports read more like advertisements paid for by the NY State taxpayers than a sound scientific document. I dealt with that in a 2020 paper on the Lansing Gas moratorium. The company hired to do the Tompkins County energy analysis sold heat pumps and the resulting report reflected that and had a huge error in its results. The paper is very relevant to the building electrification discussion.

Regarding the professor’s comments, when someone is forced to deal with the consequences of their decisions as occurs in industry, it greatly changes their perspective. There are no negative consequences for someone theorizing about policy on a University Campus and that is okay because it can move society forward. However, if they don’t really test those ideas before pushing them into society as a gospel, there will be huge problems and that is what we are now seeing in NY State.

Conclusion

The ramifications of New York’s Climate Act on business development are becoming evident. In 2026, certain new buildings in New York will no longer be able to install fossil fuel equipment and building systems. Richard Ellenbogen has performed a “science project” that proves that New York’s net-zero transition electrification plans for heating will be more expensive than using natural gas. It is also notable that the experiment was best on a geothermal heat pump system that is more efficient than legally possible today. Adding to the already large energy costs in New York is not a good way to attract and maintain manufacturing in the state.

This exercise also shows the importance of robust peer review. Ellenbogen’s first draft contained an error that was identified because he showed his work. He acknowledged the problem and corrected his analysis. New York’s Climate Act stakeholder process does not document analyses well enough for considered review and the Hochul Administration does not acknowledge any comments that do not comport with their narrative. As a result, the broken stakeholder process in New York will likely ignore Ellenbogen’s real-world results.

Governor Hochul and Climate Act Affordability Part 2

I have argued that Climate Leadership & Community Protection Act (Climate Act) affordability would become a political issue. I also argued that when Governor Hochul assigns Climate Act responsibilities to the New York Power Authority (NYPA)and then says “Too many New Yorkers are already falling behind on their energy bills and I will do everything in my power to reign in these astronomical costs” when NYPA proposed raising rates to cover those costs it is hypocritical. This post looks at utility rate impacts. Those costs are already increasing dramatically.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. It includes two 2030 targets: an interim emissions reduction target of a 40% GHG reduction by 2030 and a mandate that 70% of the electricity must come from renewable energy by 2030. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” After a year-long review, the Scoping Plan was finalized at the end of 2022. Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation.

Personal Experience

This post was prompted by an email from a friend who sent along screen shots of his most recent and last year’s electric supply bills from New York State Electric & Gas (NYSE&G).

NYSE&G current bill screen shot:

NYSE&G electric bill from a year ago:

I looked up my electric bills. Here are screenshots of current Niagara Mohawk Power Corporation, dba– National Grid electric rates

Here is a screenshot of the same information from a year ago:

I compared the cost increases in Table 1. NYSE&G electric supply rates have increased sharply. National Grid went up but not nearly as much.

Table 1: New York Electric Supply Rate Increases Examples

New York State Electric Utility Rate Cases

The differences between the two utility rates in Table 1 is striking. Particularly because the service territories overlap so much (Figure 1).

Figure 1: NYS Electric Utility Service Territories

I suspected that the differences at this time are due to the status of New York State electric utility rate cases. NYSE&G has recently settled their rate case whereas National Grid is in a pending case. National Grid rates will go up as soon as a new rate case is settled and the only question is how much. I checked the Public Service Commission (PSC) Pending and Recent Electric Rate Cases web pages and found the following information.

Niagara Mohawk Power Corporation dba National Grid:

NMPC is requesting an increase in annual electric revenues of approximately $525 million (20 percent increase in delivery revenues or 11 percent in total revenues) for the rate year ending March 31, 2026. NMPC estimates that the requested increase in delivery revenues will result in a monthly bill increase of $18.92 (23.4 percent increase in delivery bill or 15.3 percent increase in total bill) for a typical residential customer using 625 kilowatt-hours (kWh).

For the record here is information on other rate cases listed at the PSC website.

Central Hudson:

Central Hudson Gas and Electric Corporation is requesting an increase in annual electric delivery revenues of approximately $47.2 million (8.8 percent increase in base delivery revenues, or 4.6 percent increase in total system revenues), compared to the revenues approved by the Commission for the Company’s current Rate Year. The requested increase in electric delivery revenues results in a monthly bill increase of $9.19 (8.6 percent increase on the delivery bill, or 5.3 percent increase on the total bill) for an average residential customer using 630 kilowatt-hour per month.

Consolidated Edison:

Con Edison is requesting an increase in annual electric delivery revenues of approximately $1,612 million (an 18.0 percent increase in base delivery revenues, or an 11.4 percent increase in total revenues). The requested increase in delivery revenues results in an average residential monthly delivery bill increase of $26.60 (a 19.1 percent increase on the delivery bill, or a 13.4 percent increase on the total bill) for a 600 kilowatt-hour/month customer.

The primary drivers of the requested electric increase are local property taxes (which account for an overall electric bill increase of 3.1 percent), new infrastructure investment (2.6 percent) and operating expenses (2.6 percent). Con Edison purports that its filing will help accommodate demand growth, especially with clean energy options and substation investments, while maintaining reliability with investments in feeder replacements. The Company is also enhancing its system resiliency for more frequent and severe storms, as well as warmer temperatures.

In addition, the Company’s filing purportedly includes a focus on improving customer outreach and accessibility, enhancing customer support and the customer experience, and promoting energy efficient programs. The Company plans to expand outreach efforts to enroll eligible customers in the Energy Affordability Program.

I also did a Perplexity AI search asking the question: What is the status of New York State electric utility rate cases. The results noted that “as of February 17, 2025, there are no pending or recent electric rate cases for New York State Electric & Gas (NYSEG). However, there are some notable developments in the New York electric utility landscape”. The response stated:

Con Edison’s proposed rate hike: Governor Hochul has directed the state agency to reject Con Edison’s proposed rate increase, which would have raised electricity rates by 11.4% in 2026.

Orange & Rockland Utilities: There is a pending case (Case 24-E-0060) for Orange and Rockland Utilities, Inc. The company is requesting a 7.3% increase in electric delivery revenues for the rate year ending December 31, 2025.

National Grid: The company filed a request in May 2024 for new electric and gas rates in upstate New York, proposing to reset prices beginning in Spring 2025.

Previous rate increases: Con Edison has already implemented rate increases of 9% in 2023, 4% in 2024, and 1.4% in January 2025.

Discussion

The Perplexity AI response also noted that “It’s worth noting that Governor Hochul has also directed the Department of Public Service to conduct a statewide audit of utility company salaries and compensation, which may impact future rate cases.” The referenced article notes that Governor Hochul “pushed back against proposed rate hikes from Con Edison, directing the state’s Department of Public Service to reject the company’s request for approval.” I believe that there should be a line on bills that documents the Climate Act costs. That transparency could be politically damaging so that will never happen.

I am also concerned about the Public Service Commission. Given that all the Commissioners are partisan political appointees when she directs them to reject the rate case, that is what will happen. Furthermore, most of the board has ties to green energy. This will certainly lead to biased outcomes that I think will not be in the best interests of New York.

I asked Perplexity AI another question – Are the commissioners of the New York Public Service Commission partisan appointees of the governor. It responded that was true. The response was based primarily upon New York Public Service Law Section 4 and stated that:

The governor appoints the commissioners with the advice and consent of the New York State Senate.

However, there are restrictions on partisan composition:

The commission consists of up to seven members.

No more than three commissioners may be members of the same political party if there are five commissioners.

If the number of commissioners is increased to seven, no more than four may be from the same political party.

These rules ensure some level of bipartisan representation on the commission, despite the commissioners being appointed by the governor. The commissioners serve six-year terms on a full-time basis.

However, the current composition is anything but bipartisan. Technically there are only three Democrats and one Republican but four members have direct experience with green energy non-governmental organizations. The Public Service Commission website for the Commissioners lists the backgrounds of the seven members.

Rory M. Christian, Chair of the Commission – Chairs of New York agencies are chosen for political allegiance to the party of the Governor so I count him as a Democrat. He also was the Director of New York Clean Energy at Environmental Defense Fund.
James S. Alesi – Held an office as a Republican.
David J. Valesky – Held an office as a Democrat.
John B. Maggiore – Worked in Democrat administrations.
Uchenna S. Bright – Has not held political office but worked with environmental non-governmental organizations include the Natural Resources Defense Council (NRDC).
Denise M. Sheehan has not held political office but has “30 years of experience in government and non-profit sectors” and currently serves as Senior Advisor to the New York Battery and Energy Storage Technology Consortium (NY-BEST).
Radina R. Valova has not held political office. Served as Vice President of the Regulatory Program at the Interstate Renewable Energy Council (IREC), a national non-profit organization that builds the foundation for clean energy and energy efficiency. Prior to joining IREC, Ms. Valova served as Senior Staff Attorney and Regulatory Affairs Manager for the Pace Energy and Climate Center in White Plains.

I make that one Republican, three Democrats, and three that could conceivably be called non-partisan but certainly could also be called environmentalists. As a result, I think the makeup of these Commissioners will acquiesce to anything the Governor wants. At the top of that list is the Climate Act green energy narrative that transitioning away from fossil fuels to “free” solar and wind will lower prices. If that does not happen it must be because of the greedy utility companies.

There is only one problem with that approach – reality. In the real world, providing reliable wind and solar energy is expensive. The utility companies will be on the hook to provide the distribution and transmission system upgrades necessary to get the diffuse solar and wind power from where it is generated to where it is needed. The utility companies have also been told to develop infrastructure for electric vehicle charging. If Hochul’s grandstanding disapproval of rate cases continues, then how are those necessary components of the net-zero transition going to get built?

Conclusion

Hochul was quoted as saying “Too many New Yorkers are already falling behind on their energy bills and I will do everything in my power to reign in these astronomical costs.” I can’t believe that the Hochul Administration does not understand that the transition will cost enormous amounts of money and is a major reason for those “astronomical” costs. In my opinion, the political solution is to stop the transition and blame someone else. I expect that the Trump Administration’s slow down of offshore wind, cancellation of electric vehicle mandates, and the cut back on components of the Inflation Reduction Act will provide the political cover for Hochul to say we tried but evil Trump makes it impossible. Stay tuned to the political theater as this unfolds.

Governor Hochul and Climate Act Affordability

I have argued that Climate Leadership & Community Protection Act (Climate Act) affordability would become a political issue soon. My previous article concluded that there is no way to simultaneously achieve the Climate Act emission reduction goals and maintain affordability such that it will not be a campaign issue for Governor Hochul 2026 re-election campaign. This article follows that up with the ramifications of this news “The New York Power Authority (NYPA) backed down from a significant rate increase proposed for hydropower after facing bipartisan backlash, but it was an order from Gov. Kathy Hochul herself that ultimately doomed the plan.”

Overview

NYPA Rate Hike

According to the Governor’s press release:

Governor Kathy Hochul today announced that she is demanding the New York Power Authority suspend its proposed electric rate hike, protecting consumers from sky-high utility costs that are making New York State less affordable.

“Today, I’m calling for an end to the Power Authority’s unacceptable proposal to raise electric rates on its customers statewide,” Governor Hochul said. “Too many New Yorkers are already falling behind on their energy bills and I will do everything in my power to reign in these astronomical costs. While I recognize the Power Authority’s critical importance in providing invaluable, clean, baseload power from its large hydroelectric power plants Upstate, I expect NYPA to go back to the drawing board, shelve this existing proposal, and figure out a better way forward.”

Spectrum News provided background on the news:

The New York Power Authority backed down from a significant rate increase proposed for hydropower after facing bipartisan backlash, but it was an order from Gov. Kathy Hochul herself that ultimately doomed the plan.

The increase, which was in the midst of a lengthy implementation process, would have sent hydropower rates from $12.88/MWh to $33.05 over the next four years before settling back to a rate of $24.26 by 2029.

Republican lawmakers in Western New York pushed back on the proposal.

Sen. George Borrello told Spectrum News 1 he is thankful that NYPA called the rate hike off.

“As a business owner in New York state, this is one of he few things that is actually a positive when doing business in New York, the ability to get low cost power,” Borrello said.

Spectrum News noted that:

“At Governor Hochul’s request, NYPA will move to withdraw the 2025 proposed rate increase. We understand that New Yorkers are struggling right now, and we intend to make every effort to collaborate with our customers and stakeholders to find a way forward,” NYPA told Spectrum News 1 in a statement

NYPA had said the increases were necessary to keep pace with maintenance and operational costs.

I question the claim that the costs were primarily related to maintenance and operational costs. I am not alone. Spectrum News said that:

Borrello and others have blamed both instances on the state’s drive toward clean energy to meet its climate goals.

“It’s all directly related to the [Climate Leadership and Community Protection Act] then you add to it the reliability, the fact that we’ve shut down reliable forms of energy like Indian Point which supplies 20% of New York City’s power,” Borrello said.

Not surprisingly Hochul has pushed back on that premise. When discussing the large proposed Con Ed hike, she said: “It is a factor, but to increase rates to this percentage is not supported by that.”

New NYPA Climate Act Responsibilities

In the magical world of political cost accounting, adding responsibilities to state agencies is free. In the last year Governor Hochul has placed significant mandates on NYPA related to the Climate Act. According to the NYPA Strategic Renewables Plan dated January 28, 2025:

The 2023-24 State Budget authorized the most significant expansion of NYPA’s authority under the Power Authority Act in a generation. This expanded authority builds on the day-to-day work of NYPA staff to supply the state with reliable electricity, expand New York’s transmission system, and provide clean, affordable power and innovative energy services to our customers.

The enactment included four new areas of responsibility for NYPA, one of which expanded our authority to develop, own, and operate renewable energy generation projects to help meet the state’s clean energy goals. The expanded authority directed NYPA– beginning in 2025 and biennially thereafter– to develop and publish a renewable energy generation strategic plan that identifies our renewable energy generating priorities for the next two years. In addition, NYPA is directed to update the plan annually and may update the plan more often than annually if needed.

Beyond directing NYPA to build renewables, the budget enactment contained several other mandates:

NYPA will work with the New York State Public Service Commission (PSC) to establish the REACH program to provide renewable energy bill credits to low- or moderate-income New Yorkers in disadvantaged communities;

NYPA will invest up to $25 million annually in workforce training in collaboration with the New York State Department of Labor (DOL);

NYPA will cease fossil fuel generation at its small natural gas power plants by the end of 2030, so long as electric system reliability and environmental conditions allow.

In addition, NYPA will lead the Decarbonization Leadership Program, which calls for the development of energy and emissions profiles for state government’s largest carbon-emitting facilities and decarbonization action plans that will guide state agencies on facility improvements that will reduce carbon emissions.

If I was a betting man, I would wager that the costs of these efforts are a significant chunk of the revenues raised by increasing hydropower rates from $12.88/MWh to $33.05 over the next four years before settling back to a rate of $24.26 by 2029.

Time for a Cost Reckoning

It is time for the Hochul Administration to acknowledge the total costs of all the programs associated with Climate Act implementation. The Climate Act requires that the Public Service Commission (PSC) issue a biennial review for notice and comment that considers “(a) progress in meeting the overall targets for deployment of renewable energy systems and zero emission sources, including factors that will or are likely to frustrate progress toward the targets; (b) distribution of systems by size and load zone; and (c) annual funding commitments and expenditures.” The draft Clean Energy Standard Biennial Review Report released on July 1, 2024 will fulfill this requirement. The final report was due at the end of 2024 but was delayed on December 17, 2024.

On December 18, 2024, the New York Assembly Committee on Energy held a public hearing where the status of the Biennial Report was discussed. At 28:01 of the video, Jessica Waldorf, Chief of Staff & Director of Policy Implementation, New York State Department of Public Service (DPS) explained the decision to delay:

The decision to pull the report yesterday was really based on the fact that we did a major review of the main program that would have otherwise been included in that report – the Clean Energy Standard that governs all the renewable energy programs. That report is currently under consideration by the Commission. Rather than do things piece meal we’re going to release the next version of the CLCPA annual report once the commission has acted on that CES biennial review. We will include one comprehensive review report that will look back two years and also respond to other stakeholder feedback that we’ve received in response to the issuance of the first report.

My interpretation of this statement is that there is no commitment when the costs report is coming out. If they could get away with delaying the report, they would wait until after the 2026 election. More troubling was her comment about NYSERDA spending increases:

It also can’t be attributed to just the Climate Act. Many of the initiatives go back several years all the way to 1996 when we started authorizing funds for things like energy efficiency investments and so a lot of programs and initiatives preceded the Climate Act.

My concern is that this suggests that the DPS is going to hide the total costs of all the programs needed to achieve Climate Act mandates when the biennial report cost estimates are released. The emphasis on the Clean Energy Standard when describing the review suggests that they will try to list only the costs of that component of New York’s energy plan net-zero transition. If the costs of programs and initiatives like the Clean Energy Standard, that preceded the Climate Act are not included, then Hochul can claim lower costs but New Yorkers are still on the hook for all the costs. I recently described this as mal-information because while the costs listed are based on reality it is misleading and harms New Yorkers because it improperly excludes necessary costs to achieve all the goals of the energy transition. New Yorkers deserve to know all the costs associated with Climate Act implementation.

Discussion

The costs of green energy policies has become an issue elsewhere as well. Gordon Tomb of the Commonwealth Foundation recently explained that

Last October, electric grid operator PJM Interconnection received a joint letter from five Democrat governors—Pennsylvania’s Josh Shapiro, Illinois’ JB Pritzker, New Jersey’s Phil Murphy, Maryland’s Wes Moore, and Delaware’s John Carney. According to them, PJM, which supplies electricity to 13 states and the District of Columbia, has gouged customers with its annual capacity auctions

Just like Hochul rather than take accountability for destructive policies that produced the higher costs these Democrat governors are playing the blame game. Tomb concludes:

It is time for policymakers to face the economic and physical realities of energy production. Their misguided efforts to reduce carbon emissions—from cap-and-trade schemes to government mandates favoring solar and wind—have proved costly to consumers and damaging to the reliability of power systems.

This perfectly exemplifies Progressive New York Democrats led by the Governor Hochul. Their Climate Act fantasies are going to cost enormous amounts of money and risks to reliability have been largely ignored by them. So far, the Hochul Administration has not fulfilled the mandate to document the “annual funding commitments and expenditures” and I suspect that they when they finally provide numbers they will continue the mal-information coverup used to minimize Scoping Plan costs y excluding costs not associated with the Climate Act itself.

There is another missing piece in the cost assessments. The cost projections in the Scoping Plan are approaching several years old now. It is time that those numbers were updated. To do it right, clear documentation for all the energy use and emission reduction strategies proposed that includes assumptions, expected costs, and projected emission reductions is necessary.

Conclusion

Hochul was quoted as saying “Too many New Yorkers are already falling behind on their energy bills and I will do everything in my power to reign in these astronomical costs.” It is inconceivable that her Administration does not understand that these new NYPA responsibilities will cost a lot of money. That makes her actions hypocritical. She was indignant that the companies and NYPA would hike rates when people are struggling but conveniently overlooks all the costs for renewables and other Climate Act mandates that are buried in the rate cases. It is time for transparency. There should be a line on consumer bills that documents Climate Act costs.

Climate Leadership & Community Protection Act Mal-Information

I recently evaluated the New York Affordable Energy Future proposal for revenues generated by the New York Cap-and-Invest (NYCI) program. Their report includes a perfect example of New York State Energy Research & Development Authority (NYSERDA) mal-information created by NYSERDA’s intentional misrepresentation of their cost estimates for the Climate Leadership & Community Protection Act (Climate Act) implementation plan.

I am convinced that implementation of the New York Climate Act net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks. I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 490 articles about New York’s net-zero transition. The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

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

NYSERDA claims that there was “robust public input” during the draft Scoping Plan process that “included 11 public hearings across the State and more than 35,000 written comments” that supposedly were read, summarized, and presented to the CAC. However, the summary was a slide presentation. The public comment period for the Draft Scoping Plan closed on July 1, 2022. The CAC reviewed the feedback received from stakeholders over a series of five meetings from August 23, 2022 to October 25, 2022. The presentations for all CAC meetings are posted and all public comments received by the CAC are available. However, NYSERDA did not summarize the comments or provide a response to them.

False Information

There is a bigger problem with the Scoping Plan implementation process than the lack of documentation. The Hochul Administration and NYSERDA are guilty of peddling false information. Media Defence defines three false information terms:

Disinformation: Disinformation is information that is false, and the person who is disseminating it knows it is false. “It is a deliberate, intentional lie, and points to people being actively disinformed by malicious actors”.
Misinformation: Misinformation is information that is false, but the person who is disseminating it believes that it is true.
Mal-information: Mal-information is information that is based on reality, but it is used to inflict harm on a person, organization or country.

I am not going to assign motives to the agencies and staff responsible for the Scoping Plan component of Climate Act implementation, so I am not going to accuse anyone of disinformation. However, there are examples of misinformation and mal-information on the record in the Scoping Plan process.

Misinformation

At the May 26, 2022 Climate Action Council meeting the topic of misinformation came up as I documented here. CAC Co-Chair Basil Seggos discussed his thoughts starting at 19:50 of the recording and brought up the subject of public engagement. He admitted that when they got out into public that they gained a better appreciation of the scale of the challenge. He said it was tough to communicate the challenges but when on to say there is lots of “misinformation and misunderstanding but also lots of excitement and support”.

One topic for misinformation according to CAC member comments was concerns about the reliability of an electric system that relies on wind and solar. Paul Shepson (starting at 23:39 of the recording said:

Mis-representation I see as on-going. One of you mentioned the word reliability. I think the word reliability is very intentionally presented as a way of expressing the improper idea that renewable energy will not be reliable. I don’t accept that will be the case. In fact, it cannot be the case for the CLCPA that installation of renewable energy, the conversion to renewable energy, will be unreliable. It cannot be.

Robert Howarth, starting at 32:52 of the recording) picked up on the same issue. He said that fear and confusion is based on misinformation, but we have information to counter that and help ease the fears. He stated that he thought reliability is one of those issues: “Clearly one can run a 100% renewable grid with reliability”, although he did admit it had to be done carefully.

Since then, the claims that the conversion to renewable energy had no reliability challenges that could not be overcome with existing technology have been shown to be false. The CAC members who dismissed anyone who disagreed as purveyors of misinformation were clearly wrong. I have documented that experts, including those that are responsible for electric system reliability, agree that a new category of generating resources called Dispatchable Emissions-Free Resources (DEFR) is necessary during extended periods of low wind and solar resource availability. The fact that this requirement was included in the Integration Analysis and Co-Chair Seggos did not call out the CAC members who claimed that no new technologies would be needed and allowed them to enter those statements in the record is clear misinformation.

Mal-Information

The authors of the New York Affordable Energy Future proposal were tricked by mal-information in the Scoping Plan. The report notes that “NYSERDA has estimated that decarbonizing the state will cost $11 billion in 2030, counting both private and public spending. That statement was document with the following reference: “According to p. 131 of the NY Climate Action Scoping Plan (NYS Climate Action Council 2022).” The Scoping Plan states “In 2030, annual net direct costs relative to the Reference Case are around $11 billion per year, approximately 0.5% of GSP; in 2050, costs increase to $41 billion per year, or 1.3% of GSP.

Lest you think this is an isolated reference, Governor Hochul’s executive budget described in the FY2026 NYS Executive Budget Book included the following paragraph:

From the beginning of her administration, Governor Hochul has made it clear that responding to climate change remains a top priority for New York State. Acknowledging that the cost of inaction greatly outweighs the cost of any actions we can take together, New York will continue to pursue an aggressive agenda in transitioning to a sustainable green energy economy, in a way that is both environmentally effective and economically affordable for all New Yorkers.

Unfortunately, the statement is deliberately misleading. The Hochul Administration wanted to be able to say that implementing the Climate Act would be beneficial. NYSERDA provided support for the sound bite “The costs of inaction are more than the costs of action” that has been the mantra of the Administration. However, that statement is misleading and inaccurate as I documented in my verbal comments and in my written comments on the Draft Scoping Plan. I described the machinations based on reality used to mislead and harm New York as a shell game in a summary post.

The reason that this claim is a shell game is that the cost estimate everyone wants to know is how much it is going to cost to achieve the New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050 and all the other targets in the Climate Act. The “New York Affordable Energy Future” authors said “NYSERDA has estimated that decarbonizing the state will cost $11 billion in 2030, counting both private and public spending” I believe that they presumed that number included all the costs of all the decarbonization programs needed to achieve the Climate Act targets.

The NYSERDA gimmick used to support the narrative picks and chooses what control strategies are included in the costs of de-carbonization. To evaluate the effects of different policy options, this kind of modeling projects future conditions for a baseline case. The evaluation analysis makes projections for different policy options, and then the results are compared relative to the baseline. The standard operating procedure is to use a business-as-usual or status quo case for the baseline.

NYSERDA did not do that. In my review of the Draft Integration Analysis supplement, I showed that NYSERDA conjured up a Reference Case to fulfill their imperative to “prove” Climate Act benefits. Instead of a typical baseline case, the Reference Case used in the scenario excluded programs that are needed to meet the Climate Act targets but were implemented before the Climate Act was passed. I think it is troubling that this approach was hidden. I identified the problem only after I searched the Scoping Plan documents for the phrase “reference case” to try to determine what “already implemented” decarbonization programs were included in the Reference Case. The following figure reproduces the page with the documentation on page 12 in Appendix G Integration Analysis Technical Supplement Section I. The documentation is buried in the footnote for the circled reference for the blank caption to Figure 4.

Given its importance to the cost/benefit claim, my Draft Scoping Plan comment noted that this reference case caveat should have been clearly described in the text rather than in a footnote. The Final Scoping Plan document included explanatory text in section 5.3 of the document. However, that text was not even included in the draft document!

The appropriate descriptive text is in the final Appendix G section 5.3: Scenario Assumptions chapter and lists the “already implemented” programs. It states:

The integration analysis evaluated a business-as-usual future (Reference Case) a representation of recommendations from CAC Advisory Panels (Scenario 1), and three scenarios designed to meet or exceed GHG limits and carbon neutrality (Scenarios 2 through 4). Scenarios 2, 3, and 4 all carry forward foundational themes based on findings from Advisory Panels and supporting analysis but represent distinct worldviews. A detailed compilation of scenario assumptions can be found in Annex 2.

For the record Annex 2 refers to a massive spreadsheet that is certainly detailed but most certainly does not provide an easily accessible compilation of scenario assumptions. In particular, the documentation does not provide explicit information to determine what costs are specifically included in the Reference Case relative to the other scenarios.

The Reference Case described as “Business as usual plus implemented policies” includes the following:

Growth in housing units, population, commercial square footage, and GDP
Federal appliance standards
Economic fuel switching
New York State bioheat mandate
Estimate of New Efficiency, New York Energy Efficiency achieved by funded programs: HCR+NYPA, DPS (IOUs), LIPA, NYSERDA CEF (assumes market transformation maintains level of efficiency and electrification post-2025)
Funded building electrification (4% HP stock share by 2030)
Corporate Average Fuel Economy (CAFE) standards
Zero-emission vehicle mandate (8% LDV ZEV stock share by 2030)
Clean Energy Standard (70×30), including technology carveouts: (6 GW of behind-the-meter solar by 2025, 3 GW of battery storage by 2030, 9 GW of offshore wind by 2035, 1.25 GW of Tier 4 renewables by 2030)

Mal-information is information that is based on reality, but it is used to make misleading statements that improperly convey a false narrative. In this case, the uncommon definition of the base case used for the implementation cost modeling led most New Yorkers to believe that annual net direct costs to achieve the Climate Act targets were around $11 billion per year. The Scoping Plan mentions that those costs are “relative to the Reference Case” but the draft Scoping Plan did not document what programs were included in the Reference Case. This is why I believe that the “costs of inaction and more than the costs of action” narrative is mal-information.

Discussion

This post was prompted by my realization that the authors of the New York Affordable Energy Future report were misled by NYSERDA mal-information related to the expected annual net direct costs needed to achieve the Climate Act mandated targets. When I did some background research I found Media Defence definitons of three false information terms and realized that NYSERRDA was guilty of two out of three.

NYSERDA is guilty of misinformation because the Scoping Plan was approved because information fundamental to the implementation schedule was known to be false. The only way to justify the Climate Act schedule is to believe that no new technology is needed so the only constraint is deployment. CAC member Dr. Robert Howarth is the primary source of that presumption, and I am sure he believes that no new technology is needed. However, the Integration Analysis recognized that during extended periods of low wind and solar resource availability that a new DEFR technology is needed. The leadership of the CAC should have addressed this fundamental issue. That they didn’t was likely because acknowledging the problem is tantamount to admitting that the Climate Act law was deeply flawed.

NYSERDA and Governor Hochul are guilty of peddling mal-information. Their oft-repeated sound bite that the “costs of inaction are more than the costs of inaction” is based on reality but mis-leads and harms New Yorkers because it does not include all the costs necessary to meet the Climate Act mandates. No one cares which regulation, or law mandates a specific portion of the total costs necessary to meet the goals. The total costs are all we care about.

NYSERDA claims that there was “robust public input” during the draft Scoping Plan process that “included 11 public hearings across the State and more than 35,000 written comments” that supposedly were read, summarized, and presented to the CAC. The problem is that NYSERDA and DEC staff screened the comments and only presented generalities and not specific comments that questioned any of the narrative that the Administration wanted pushed. I specifically addressed this issue in my verbal and written comments but have never seen any evidence that anyone on the

I recently found an example of how a stakeholder process should work. The Santa Clara County Rapid Transit Development Project includes a master plan for transportation for Silicon Valley. An interview with the founding manager notes: “Part of the plan is a four-year public stakeholder review process. In the reviews, if the public came up with good ideas, the ideas went into the plan. If an idea wasn’t good, we had the responsibility of explaining why.”[1]

That commitment to responding to comments is sorely needed in New York. In my opinion, the CAC should have been informed about this issue. A summary describing what I claimed, their response to my concern, and a recommendation for the CAC is necessary to assure public confidence in Climate Act implementation. If NYSERDA is to have any credibility regarding their stakeholder process, then they must provide better documentation showing that all the comments were considered and addressed.

Conclusion

The Hochul Administration has been the first to pitch a fit and throw around the misinformation label when anyone says something contrary to their narrative. They are not only guilty of pushing misinformation but worse, they spout egregious mal-information whenever they claim the costs of inaction are more than the costs of action.

[1] “California’s High-Speed Rail Visionary” Bill Buchanan, Trains, Volume 85, No. 1, January 2025, pages 30-37.

Catastrophic Costs of Green Energy

The New York State Comptroller Office released an audit of the NYSERDA and PSC implementation efforts for the Climate Leadership & Community Protection Act (Climate Act) titled Climate Act Goals – Planning, Procurements, and Progress Tracking. The audit found that: “The costs of transitioning to renewable energy are not known, nor have they been reasonably estimated”. This post describes a couple of articles that suggest that when the costs of the Climate Act transition are finally revealed they will be extraordinarily high.

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

Overview and Background

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

To date, however, the costs of the transition have not been revealed. The Comptroller Report audit found that: “While PSC and NYSERDA have taken considerable steps to plan for the transition to renewable energy in accordance with the Climate Act and CES, their plans did not comprise all essential components, including assessing risks to meeting goals and projecting costs.” It noted that the “PSC is using outdated data, and, at times, incorrect calculations, for planning purposes and has not started to address all current and emerging issues that could significantly increase electricity demand and lower projected generation”. Regarding costs the audit notes that “The costs of transitioning to renewable energy are not known, nor have they been reasonably estimated” and goes on to point out that the sources of funding have not been identified.

Crippling Costs of Electrification and Net-Zero Energy Policies in the Pacific Northwest

Jonathan Lesser and Mitchell Rolling have released a new research report from Discovery Institute’s Reasonable Energy program that will “produce staggering costs to individuals and businesses without providing any meaningful environmental benefits”. The Discovery Institute announcement of the report summarizes the report as follows.

Authors Jonathan Lesser and Mitchell Rolling conclude that policies in Oregon and Washington State that require their state electrical utilities to eliminate fossil-fuel energy sources to produce 100% of electricity from zero-emissions sources by 2040 (Oregon) and 2045 (Washington) will double existing electricity demand.

Both states have adopted California’s Advanced Clean Car rules, which require 100% of all new cars and light trucks sold to be electric by 2035.

Both states intend to reach zero energy-related greenhouse gas emissions by 2050, including replacing all fossil-fuel space- and water-heating systems with electric heat pumps.

Both states envision replacing existing fossil fuel generation and meeting the projected increase in electricity demand with thousands of megawatts (MW) of wind turbines and solar photovoltaics.

The Climate Act mandates are similar to those in Oregon and Washington.

The inherent intermittency of wind and solar power, together with peak electric demands taking place in the early evening hours when there is no solar generation available (and often no wind), means the two states will require large amounts of storage capacity, in addition to the existing hydroelectric storage dams that have been built on the Columbia River and its tributaries.

New York electric system projections highlight the same problem with intermittency as described here.

Because no new hydroelectric dams will be built, the additional storage capacity required will need to come from large-scale battery storage facilities and perhaps a few new pumped hydroelectric storage facilities, whose siting remains controversial.

New York also has no ability to build more hydro so will have to rely on battery energy storage.

Their research considered the costs by 2050 associated with three scenarios: 1) the renewables-only strategy; 2) a lower-cost renewable strategy (a more optimistic low-cost renewables scenario in which wind, solar, and storage capital costs decrease by 50% in real (inflation-adjusted) terms by 2050); and 3) an alternative scenario in which the electricity goal is achieved with new nuclear plants and additional natural gas generators. The assessed total costs (in inflation-adjusted dollars) are as follows:

Renewables Only: $549.9 Billion

Lower-cost Renewables: $418.5 Billion

Natural Gas and Nuclear: $85.9 Billion

The Climate Act precludes the pragmatic option to consider natural gas and nuclear so our costs will be closer to the high end.

Their research indicates that the effects on electricity bills will be devastating.

A typical residential customer’s bill will increase by 450%, from about $110 per month today to over $700 per month in 2050 (assuming a modest inflation rate of just 2.0% annually).

Commercial customers will see their monthly bills increase from an average of about $600 per month today to approximately $3,800 per month in 2050.

The Hochul Administration has not provided any ratepayer impacts, but I expect the costs will be similar in New York.

The negative economic impacts will not be limited to soaring electricity bills.

Prices for virtually all goods and services will dramatically increase.

Jobs will be lost as businesses relocate to other states with lower-cost energy.

Energy poverty rates will soar.

Negative economic impacts are a feature not a bug of net-zero transition efforts.

The enormous costs to consumers and businesses will be accompanied by negligible environmental benefits.

The reduction in greenhouse gases (GHGs) from the policies would total about 1.8 billion metric tons between 2024 and 2050, which is a small fraction of estimated 35 billion metric tons world carbon emissions in just one year.

If both states eliminated all energy-related GHG emissions by 2040, the resulting decrease in world temperatures would be only 0.003 ⁰C. By comparison, the best outside thermometers have an accuracy of about +/- 0.5 ⁰C, about 170 times larger.

I estimate that New York reduction in GHG emissions is about the same (1.5 billion metric ton reduction) as the reduction projected from Oregon and Washington so the estimates of environmental benefits are similar.

The report concludes that the two states would be best served by abandoning these goals, focusing instead on providing reliable and far less costly electricity from new natural gas and nuclear plants.

I believe this conclusion would be appropriate for New York.

Catastrophic Costs of Green Energy

Alex Epstein described his testimony in front of the House Budget Committee on the topic “The Cost of the Biden-Harris Energy Crisis.” You can watch his testimony and the Q&A at the link.

The transcript of his testimony states:

The basic idea of government-dictated green energy is that the government should force us to rapidly reduce our use of fossil fuel energy and replace it with so-called “green energy,” mostly solar and wind, such that we reach net zero greenhouse gas emissions by 2050 at the latest.

There are three basic truths you need to know about the costs of government-dictated green energy. And I think these are really under-appreciated even by critics.

One is they have been enormous so far.

Two is they would have been catastrophic had it not been for the resistance of their opponents. This is very important when you hear the Biden administration has record production. That’s in spite of them, not because of them.

And three, they will be apocalyptic if not stopped in the future.

He goes on to summarize the reason for the cost increases:

So let’s talk about the cost so far of government-dictated green energy. All the energy related problems we have experienced in recent years, which have been a lot: high gasoline prices, higher heating bills, higher electricity bills, and unreliable electricity, which is a huge problem we need to talk much more about, are the result of government-dictated green energy.

And its very simple. When you shackle the most cost effective and scalable source of energy, fossil fuels, and you subsidize unreliable solar and wind, that wouldn’t otherwise be competitive, energy necessarily becomes more expensive, less reliable and less secure. So again, it’s very simple.

This is exactly what will happen in New York because of the Climate Act net-zero transition. He goes on to explain why inflation and increased energy costs are inextricably linked:

Prices are determined by supply and demand. If oil and gas companies could control energy prices in their favor, why didn’t they do this from 2015 to 2020 when they were losing money? The truth is that government-dictated green energy policies are fundamentally responsible for all the energy related costs we experience today compared to a decade ago.

And in fact, it’s worse than that. There’s an opportunity cost. Because were it not for these policies, energy would have gotten considerably cheaper and more reliable, especially with lower natural gas prices, which should have lowered electricity prices. Instead, they’ve gone up because we’ve added a bunch of wasteful energy and unreliable stuff. And it gets worse, since energy is the industry that powers every other industry. By making energy more expensive and less reliable, we make everything more expensive and less reliable, which means government-dictated green energy drives price inflation. Very important point.

His testimony notes that at least on the Federal level that the attempts to rapidly eliminate fossil fuel use have failed. Consequently, the nation has been spared energy ruin and a third-world grid. Of course, reality has not stopped the Climate Act. His testimony is a grim warning of our future if this madness continues.

Conclusion

In the absence of a clear accounting of costs for the Climate Act we can only guess what will happen here. I believe that the crippling and catastrophic adjectives used by these authors will surely describe our energy costs.

Vermont Clean Heat Standard Lessons for New York

The Climate Leadership & Community Protection Act (Climate Act) could learn quite a bit from the experiences of Vermont and their Clean Heat Standard as documented by Robert Roper at his Behind the Lines Substack. Roper did an overview of the Clean Heat Standard and a summary of the Public Utility Commission’s (PUC) long awaited Draft Clean Heat Standard Rule Companion Status Report that provide evidence that New York’s similar initiatives will run into the same problems he identifies.

Overview

There are two relevant initiatives. The CAC recommended an economywide cap-and-invest program. Plan that led to the New York Cap-and-Invest (NYCI) program that will “establish a declining cap on greenhouse gas emissions, limit potential costs to New Yorkers, invest proceeds in programs that drive emission reductions in an equitable manner, and maintain the competitiveness of New York businesses and industries.” In the Legislature the New York Home Energy Affordable Transition Act, or NY HEAT that passed the last session but has not been signed is supposed to secure “affordable, clean energy for New York households.”

Vermont Clean Heat Standard

Roper’s overview of the Clean Heat Standard put together a “pocket guide” that describes what this law is supposed to do, how it’s supposed to work, and what it looks like it will cost to fully implement. I recommend that you read the article for full details because Rober is a good writer that explains things well in an engaging manner. I will quote from his article and compare to New York’s situation below.

Roper explains the origin of the Clean Heat Standard:

The Clean Heat Standard is an outgrowth of the Global Warming Solutions Act (GWSA), passed over the veto of Governor Scott in 2020. The GWSA mandated that Vermonters lower our greenhouse gas emissions to 26% below 2005 levels by 2025, 40% below 1990 levels by 2030 and 80% below 1990 levels by 2050. How we were going to do this, what it would cost, or if it were even possible the lawmakers who passed the GWSA did not know, but if we failed to meet these deadlines, they inserted a provision in the GWSA that gave literally anyone standing to sue the state at taxpayer expense.

As noted in the Overview the GHG emission reduction targets for the New York Climate Act are similar. Like New York, the Vermont politicians assumed that the transition was only a matter of political will and that the details of how to get there would be a minor, easily resolved detail. The Climate Act does not include the provision for lawsuits if the deadlines were not met. Not to worry the Environmental Rights Amendment to the New York constitution will provide a similar basis for litigation.

Similar to New York’s Climate Action Council, the GWSA created a Vermont Climate Council that released their Climate Action Plan in December 2021.

This plan, released in December 2021, recommended that for the thermal sector of our economy (how we heat our homes and businesses, make hot water, and cook our food), which accounts for over 40 percent of our overall greenhouse gas emissions, that the legislature pass another law establishing a Clean Heat Standard. The legislature did this in 2023 over Governor Scott’s veto with Act 18 — again not knowing what it would cost, how it would work, or if it were possible.

Roper describes the Clean Heat Standard:

In a nutshell, the Clean Heat Standard is a system requiring importers/sellers of heating oil, kerosene, propane, natural gas, and coal, to obtain (in most cases, especially for smaller dealers, this means buy) “credits” based on the amount of carbon released into the atmosphere when the fuels they sell are ultimately burned. According to the law, a carbon credit is defined as “a tradeable, nontangible commodity that represents the amount of greenhouse gas reduction attributable to a clean heat measure.” A “clean heat measure” is one of a dozen legally approved actions taken — by anyone — to reduce greenhouse gas emissions such as weatherizing a building or installing a heat pump.

Practically speaking, a carbon “credit” it is a financial instrument, much like a cryptocurrency, that a fuel importer/seller must obtain in order to legally sell their product(s) either by “mining” the credits themselves (performing clean heat measures) or buying them from a “Default Delivery Agent” (likely Efficiency Vermont) appointed by the state.

There are similarities to NYCI but significant differences too. Both programs require compliance entities to obtain authorizations to emit amounts of carbon. Affected Vermonters must earn those authorizations either themselves or buying them for someone else who performed the clean heat measures. Affected New Yorkers buy the authorizations from the auction marketplace which is supposed to use the proceeds to fund clean heat measures. New York’s proposed NY HEAT includes mandates to force electrification of home heating away from fossil fuels. Both state approaches are intended to reduce emissions on a mandated trajectory consistent with their GHG targets.

In both States the nasty little detail of how many homes must be modified to achieve those goals is only now being addressed. In Vermont “According to a taxpayer funded analysis done by The Cadmus Group for the Climate Council, in order to meet just the 2030 targets Vermonters will have to weatherize 120,000 homes, install 177,107 heat pumps, 136,558 heat pump water heaters, 14,992 advanced wood heating systems, and switch 21,086 homes to using biofuels before the end of the decade.” New York’s documentation for these numbers is buried in documents but in much less detail. In both cases the costs and where the money necessary to pay for them is unresolved.

There is a huge implementation issue for both states. In Vermont:

How is the state even supposed to ensure and verify that all of these clean heat measures take place, calculate exactly how much greenhouse gas reduction will result from each unique measure so that each measure can be monetized into a tradable carbon credit value, assign ownership of the credits, and then establish a financial exchange where the creators of credits and the parties obligated to obtain them can buy and sell them while at the same time regulators track ownership and ensure compliance? When the legislature passed Act 18, they had no idea so handed off the task of figuring all that out to the Public Utilities Commission (PUC).

In New York, the unique Climate Act emissions accounting requirements means that the State must develop reporting and tracking mechanisms for emissions, develop an allowance system for ownership, and establish a financial exchange like Vermont. In New York the assignment for this task was given to the Department of Environmental Conservation and the New York State Energy Research & Development Authority on a time frame years less than it took California to establish a similar program.

In my opinion based on years of experience with emissions accounting and reporting New York’s challenge is impossible on the mandated schedule but the Vermont approach is much worse. Roper writes and I agree:

If that task sounds impossibly complicated, it is. In fact, Efficiency Vermont released a memo to the PUC on September 19, stating, “The complexity of these arrangements also give rise to concerns over the veracity of projects claiming credits and the rigor of their completion… Efficiency Vermont is unsure of the efficiency or efficacy of monetizing credits…. [and] that while compliance may ultimately be achieved after several years, the buying and selling of credits itself becomes grossly inefficient, asymmetrical, and potentially more costly for all parties.” Not an expression of confidence that this is going to work at all, let alone be cheap.

Costs

Roper writes:

Supporters of the Clean Heat Standard say we don’t know what it will cost, shouldn’t speculate, and that all indications so far are that the cost to implement the program will be minimal for consumers. This first position is misleading, and the second is demonstrably false.

As for not knowing what the Clean Heat Standard will cost, that’s only true if you’re looking for an exact price tag, which, of course, can’t be determined until the program’s rules are fully designed and approved. However, it is not difficult to get a ballpark figure with all of the data that has been collected and testimony taken over the three-plus years that this policy has been under consideration.

The excuse for not providing costs in New York’s Scoping Plan was we cannot give an exact price because of all the uncertainties. The failure to provide a ballpark figure in New York is indicative of the likelihood that the costs are politically unacceptable. There is no reason to believe that the New York cost experience will be markedly different than Vermont.

Roper documents how much money has been spent on implementation and concludes that “Given this level of financial and human resources engaged over this extended period of time the claim that we still don’t have enough information to know basically what the Clean Heat Standard will cost – not even a ballpark understanding – defies credulity.” Inevitably the costs must come out, but in the meantime, here is a ballpark estimate:

According the newly released potential study done by NV5 through the Department of Public Service, the estimated incentive spending required to fund the number of clean heat measures necessary to meet the GWSA reduction mandates will cost about $3.3 billion over the first four years leading up to the 2030 target (and about $10 billion total to meet the 2050 target). To raise that much money off the sale of 200 million gallons of fossil heating fuel sold annually comes out to a just over $4 per gallon.

Roper goes on to flesh out more details of the implications of the Vermont initiative. He describes who pays and who benefits. Most importantly, who loses: “The biggest losers in this scheme are those who can’t transition away from heating with fossil fuels even if they want to because, for example, they can’t afford the upfront costs of doing so, can’t find the labor to do the work in a timely fashion, or their homes are logistically difficult or impossible to retrofit such as those living in mobile homes, older housing stock lacking open floor plans, or multi-unit apartment buildings.” He closes this post to explain how this is supposed to be implemented.

PUC Clean Heat Status Report

Roper’s second post is a summary of the Public Utility Commission’s (PUC) long awaited Draft Clean Heat Standard Rule Companion Status Report. I particularly like his description of the conclusion that the Clean Heat Standard is a dead end and recommend reading it.

As he has been writing for years the PUC concludes:

The Clean Heat Standard as currently conceived requires substantial additional costs and regulatory complexity above the funding needed to accomplish Vermont’s greenhouse gas emission reduction goals. For example, the Clean Heat Standard would require establishing a credit marketplace managed by what is likely to be a costly credit platform, the potential for fraud and market manipulation, the appointment of new or varied default delivery agents with administrative costs of their own, and the participation and regulatory engagement of hundreds of fuel dealers and other actors — e.g., companies and individuals that install clean heat measures — not currently or historically regulated by the Commission.

Our work over the past year and a half on the Clean Heat Standard demonstrates that it does not make sense for Vermont, as a lone small state, to develop a clean heat credit market and the associated clean heat credit trading system to register, sell, transfer, and trade credits. Because the Clean Heat Standard introduces these additional regulatory hurdles and costs, the Commission is considering other options to achieve Vermont’s greenhouse gas emission reduction goals for the thermal sector.

Given that the Clean Heat Standard won’t work what alternative was proposed?

[A] new thermal energy benefit charge on the sale of fuel oil, propane, and kerosene. Similar to the long-standing electric efficiency charge, the Commission would set the thermal energy benefit charge based on statutory criteria, including the need to provide sufficient funding to meet the Global Warming Solutions Act requirements.

Roper describes this as:

A straightforward carbon tax on home heating fuels. Strip away the Rube Goldberg Carbon Credit contraption, and that’s what you’re left with: a direct charge on your oil, propane, and kerosene home heating bill. And to “sufficiently fund” the number of clean heat measures necessary to meet the Global Warming Solutions Act mandates, that carbon tax will necessarily be massive. In the billions massive. Of course, per the report, “The Commission is not providing a cost estimate at this time.” Uh huh. I guess give them another eighteen months.

The NYCI approach is similar, it is nothing other than a disguised carbon tax. In fact, given the uncertainties associated with devising a “declining cap” that appropriately accounts for all the uncertainties associated with renewable resource deployment, the necessity for new technologies to account for weather-dependent resource limitations, and the regulatory infrastructure necessary to implement the cap-and-invest auction and tracking system I believe a New York carbon tax is a better option. However, in both Vermont and New York the political optics of another tax and one that will have to be this large, makes admitting this is simply a tax untenable.

I love Roper’s closing comment on the fact that this has always just been a tax:

Now if lawmakers take the PUC’s recommendation to implement this direct tax/fee/surcharge, that plausible deniability (implausible really, but hey, they’ve been sticking to it, bless their hearts!) is gone. Do they have the guts — or a truly principled commitment to saving the planet — to face the voters with that proposition? It’s time to separate the true believers in catastrophic, anthropogenic climate change from the virtue signaling panderers!

Conclusion

It is not surprising how many similarities there are between the Vermont approach and that of New York even though the programs are packaged differently. At the end of the day both states will face enormous costs, and their funding approaches are no more than disguised carbon taxes. The only question left is which state will reach the inevitable reality wall when the citizens finally understand that politicians should not make energy policy. The current approach in both states assures that affordability and reliability will suffer. Roper’s work describes why this is happening in Vermont and New York will fare no differently unless changes are made soon.

The Math Does Not Support New York’s Climate Plan

I frequently collaborate with Richard Ellenbogen regarding issues related to the Climate Leadership & Community Protection Act (Climate Act). This post describes his recent blog article The Math Does Not Support New York’s Climate Plan published at the Empire Center for Public Policy. He explains why the numbers show that the Climate Act implementation plan is doomed to failure based on his experience adopting renewable and lower-emission combustion technologies in his home and business. This post condenses his findings and publicizes his work.

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

Overview and Background

Introduction

Ellenbogen introduces the problem:

I have been analyzing the numbers coming out of Albany regarding the Climate Leadership and Community Protection Act (CLCPA), New York’s plan to drastically reduce the use of fossil fuels, for over five years now.

I am not anti-renewable and I am not a climate denier. What I am is an engineer that lives by numbers. The numbers underpinning the CLCPA—namely the belief that New York can replace most of its natural gas-fired electricity generation with renewables in the next six or even nine years—are a fantasy.

New York is letting the perfect be the enemy of the good, prohibiting or frustrating viable solutions that could reduce emissions.

Instead, New York is relying on older, less efficient power plants, in hopes that wind and solar—built in more rural areas or offshore—can someday replace them.

Even if New York were to build the wind, solar and battery backup necessary to keep the lights on without fossil fuels, the storage requirements, either onsite or grid-based, would be cost-prohibitive.

State Comptroller Tom DiNapoli in July described “inadequate planning, monitoring and assessment of risks and challenges” by state energy officials. That’s just the tip of the iceberg.

Greener Than The Grid

In the next section of the article, Ellenbogen describes his manufacturing business and the steps he has taken to reduce energy use at his facility. His company, Allied Converters, manufactures food packaging for large bakeries and supermarket chains. The machinery is thermally intensive and uses large amounts of electricity.

In 2002 he “installed the first microturbine-based Combined Heat and Power (CHP) system in the Con Ed service area.” This approach generates electricity by burning natural gas. Waste heat is recovered “to heat the building in the winter, or to be sent to absorption chillers to cool the building in the summer.” This approach allows him to recover 70 to 75 percent of the energy content of the fuel.

He compares the factory efficiency to the grid:

Most of downstate’s electricity comes from burning natural gas. New York’s single-cycle gas generating plants are in the neighborhood of 30 to 35 percent efficient. Newer combined-cycle plants are in the range of 55 to 60 percent efficient. For both, about 7 percent of energy produced is lost as heat in the transmission lines, a loss we avoid by generating electricity onsite.

Contrast that with New York’s plan to replace gas and oil furnaces at homes and businesses with electric heat pumps, which will—at least for the foreseeable future—require more electricity generation from fossil fuels, farther away from where the electricity is needed (and therefore more line losses).

In 2007 he installed the first commercial-scale solar array in New Rochelle. His article describes the tribulations related to being an early adopter with the planning agency and the utility. Later that year he added a “Reactive Power Mitigation System and in conjunction with the onsite generation, reduced load on the utility by 80 percent. To top it off he collects data on all the electric parameters in the building.

This massive amount of data, along with my training as an electrical engineer, has formed my frame of reference regarding the CLCPA. Renewable generation has a place in the energy mix but it cannot be used as the backbone of the utility system. Renewables are a tool and when you misuse a tool, bad things will happen. When you need a hammer, you don’t use a screwdriver, but that is essentially what the state is trying to do with renewables.

Energy System Model

His facility is a template for a pragmatic energy system:

The factory is a microcosm of NY’s energy system. It has a fossil fuel-based high efficiency generator to provide baseline load which it supplements with a solar array. The balance of the energy is dispatched by the utility when we need more.

All told, the factory’s carbon footprint is 30 to 40 percent smaller than it would be otherwise. Additionally, our utility bill, including the cost of natural gas, is less than half of what it would have been if we hadn’t added the energy systems. We have not only reduced our carbon emissions but we have also saved money through reduced energy usage and the associated expenses, about $1 million over the past 17 years. Our savings have been relatively higher during recent years as the business has grown and we have used more energy. Contrast that with current bills for other utility customers that are rising at an increasing rate.

The New York grid relies on nuclear, fossil, and hydro resources for most of its load, wind and solar to supplement the other resources, and imports the rest. The grid load varies more than the factory. As a result, resources are called for varying loads depending on their operating characteristics and costs. Ellenbogen describes current reliability issues.

The New York Independent System Operator (NYISO), the independent nonprofit organization that operates the electric grid and oversees the state’s wholesale electricity market, has been warning about potential blackouts due to closing existing fossil-fuel generators before new generators come online.

A 2019 plan by the state Department of Environmental Conservation to close smaller “peaker” power plants risked causing rolling blackouts on hot days as soon as 2025, before NYISO officials pushed back and kept some of the plants open.

As NYISO officials warned earlier this summer, reliability margins—the cushions in each region that ensure there’s enough electricity to meet demand at all times—“are also observed to be narrowing across the grid in New York, which poses significant challenges for the electric system over the next ten years.”

The reality is that the issue is going to extend well past 2033 and the energy shortages will get worse as gas plants aren’t replaced.

Future Model

Ellenbogen describes what would be needed at his factory if he were to rely only on solar and not use natural gas. Note that wind is not a practical source at his location.

To generate the same amount of electric energy that we currently use, we would need a solar array six times the size of what we currently have. Below is a photo of the 25,000+ square foot roof of the factory with the 50,000 watt (50 KW) solar array on it. (The factory is 55,000 square feet across two floors).

Ellenbogen,s factory, with its 50 KW rooftop solar array, in New Rochelle, NY

We could fit an additional 50 KW array on our roof for a total of 100 KW. However, we would need a roof three times the size of what we currently have to house a large enough solar array to generate the amount of electrical energy that we currently use. That doesn’t include the heat generated by the CHP system.

If we switched to heat pumps, we would need at least an additional 300 KW of solar arrays to support the building’s thermal load. So in total we would need 12 times the panels—on a roof six times the size.

Beyond the enormous additional costs needed to build a system of that magnitude, we don’t have the physical space or the roof area to remotely come close to supporting a system of that size.

The Model Storage Problem

The Climate Act insists on a zero-emissions mandate so that fossil-fired generators cannot be used to support intermittent wind and solar. This leads to the enormous challenge of storage.

Because of the looming plight of New York utility system, my team and I have been looking for ways to supply the building during a power failure. We first looked at a backup generator but Con Ed wanted $140,000 to run a larger gas line to our building. That being cost-prohibitive, we have been looking at a new type of energy storage that does not have the deficiencies of lithium-ion batteries.

The newer storage, using supercapacitors, has a comparable cost to lithium-ion, will last 25 to 40 years instead of the eight to 10 years of lithium-ion, and it will not go into a state of thermal runaway and burn at 2600 degrees Fahrenheit as occasionally happens with lithium-ion batteries. It will fit in a space the size of a sea container and it can be charged at night from our CHP system and on weekends from our solar array. With an energy storage system of 720 to 900 KWh in conjunction with the CHP system and the solar array, we could operate 100 percent free of the utility with a carbon footprint 10 percent lower than what we have now.

However, the Climate Act prohibits the use of the natural gas fired micro turbine currently in use. That means more storage would be required.

We would have to install nearly sixty times the amount of energy storage as what we currently need for backup purposes—at sixty times the price–to ensure that the panel’s energy was available at night or for extended periods during the winter months. That storage would occupy a volume approximately equivalent to that of fifty large sea containers—for my factory alone.

When the example for his factory is considered relative to the State the lunacy of the Scoping Plan becomes clear.

NYSERDA, the state’s energy agency, in late 2022 said “complete replacement” of fossil fuel plants with solar and wind generation would require 2,400 gigawatt-hours of storage to get the state through lulls when wind isn’t blowing and output from solar panels is low. At $567 per kilowatt-hour, the recent average cost of new non-residential energy storage, that works out to more than $1.3 trillion in new costs, or about $68,000 per New Yorker.

Summing Up

Ellenbogen describes his misgivings about the Climate Act.

Unlike New York’s plan that is relying on resources that either don’t exist, don’t exist at scale, are prohibitively expensive to install, are opposed by the residents near the sites, double utility costs, and as a result cannot be installed in any reasonable time frame so that they are not reducing GHG emissions, the technologies that we have used to achieve our carbon reductions are just the opposite. My neighbors are unaware of what we have onsite. The only thing that is visible is the solar array on the roof that can be seen with aerial photos or from a distance from the new high rises that have been built.

The technologies we used existed 20 years ago, reduce GHG emissions, are cost-effective, reduce line losses, reduce transmission and distribution costs, save money for the end user and the utility simultaneously, and can be implemented now in densely populated areas eliminating the need for multi-billion dollar transmission lines.

This conclusion wasn’t derived from what I like or don’t like, or about what I want or don’t want, and unlike the Climate Act, it is not based upon emotion. It is based upon tens of millions of data points that definitively say that if NY State keeps proceeding on this path, it will be a calamity for the state. If the Comptroller or others in state government wonder why the Climate Action Council never did a financial analysis of the Climate Act that they forced upon the state, with the assistance of unknowing legislators, it is because the costs are so ridiculously high that if the number was actually publicized, it would be political suicide.

Climate Act Costs and the Election Cycle

The Climate Leadership & Community Protection Act (Climate Act) was passed five years ago and the Scoping Plan that outlines how the to implement the required transition was completed 20 months ago. However, the Hochul Administration still has not admitted how much it will cost the consumers of New York. In my opinion, the reason this information is not available is because the costs are politically toxic. This post describes the requirements to provide costs that have been ignored by Governor Hochul.

Overview

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

Scoping Plan Costs

The Scoping Plan outline for achieving the “State’s bold clean energy and climate agenda” should have provided substantive cost information. Although costs to ratepayers and citizens were requested frequently by several Climate Action Council members the Scoping Plan went to great lengths to obfuscate the expected costs for the net-zero transition. The Scoping Plan supporting documentation does not provide a transparent description of the information needed to estimate consumer costs. At a minimum it should have provided clear descriptions of all proposed control measures, the assumptions made for those control measures, the expected costs for each measure, and the expected emission reductions projected for them. The Scoping Plan does not even summarize sectoral expected costs for the different projection scenarios. The numbers that are provided are buried in an enormous spreadsheet with inadequate documentation so it is impossible to determine what was used.

Instead of providing substantiated numbers the Scoping Plan cost benefit projections provided nothing more than support for the oft-repeated sound bite: the costs of inaction are more than the costs of action. I summarized the machinations used to support this statement in a blog post and argued that the statement was misleading and inaccurate in my Draft Scoping Plan verbal comments and written benefit, and cost/benefit comments. There never has been a response to my comments.

There are substantive problems with the claim that the costs of inaction are more than the costs of action. It is misleading because the Scoping Plan did not include all the costs to meet the Climate Act mandates. Instead, it only included costs directly related to the Climate Act itself and not already implemented programs such as the Clean Energy Standard including 6 GW of behind-the-meter solar, 3 GW of battery storage, and 9 GW of offshore wind. As a result, the acknowledged costs are much less than the total costs of implementation. Also note that this accounting trick was very poorly referenced to hide this chicanery.

The overarching thing to keep in mind is that the costs are real, but the benefits are based on value judgements with a wide range of possible values. Worse, the calculation of the societal benefits expected from carbon dioxide emission reductions was incorrectly applied. The societal benefit was incorrectly applied multiple times rather than just once. Their approach is equivalent to claiming that a wight loss of five pounds five years ago should be counted as a loss of 25 pounds if it was kept off.

All this results in unrealistically low-cost estimates and value-laden high benefit estimates to “prove” the costs of inaction are more than the costs of action.

New York Cap and Invest

The Climate Action Council’s Scoping Plan recommended a market-based economywide cap-and-invest program. The New York State Department of Environmental Conservation (DEC) and NYSERDA are developing the New York Cap-and-Invest (NYCI) Program. In March they took comments on the pre-proposal outline of the regulations but have only had one stakeholder meeting since. On August 15, 2024 a webinar presented “a draft proposed framework for guiding the allocation of these funds and identification of potential areas that could receive investments.” During the webinar they claimed that draft rules would be out later this year and that appropriations and spending of NYCI proceeds would begin in the next fiscal year beginning April 2025. In the stakeholder engagement process at the beginning of the year DEC and NYSERDA claimed they would propose regulations by summer and the final rules would be in place by the end of the year. Clearly this is not happening according to plan.

Implementing a program like this is a major undertaking and I believe that the DEC is unable to respond as quickly as they would like simply because of staffing issues. On the other hand, this program is a carbon tax. There is no way that it will not affect prices significantly so I doubt very much there is any desire to get the program details out quickly. At the Energy Access and Equity Research webinar sponsored by the NYU Institute for Policy Integrity on May 13, 2024 Jonathan Binder stated that the New York Cap and Invest Program would generate proceeds of “between $6 and $12 billion per year” by 2030. In my opinion, these costs are one reason that the Hochul Administration is not in a hurry to release the regulations and proceed with the implementation process.

Comptroller Report

On July 16, 2024 the New York State Comptroller Office released an audit of the New York State Energy Research and Development Authority (NYSERDA) and Public Service Commission (PSC) of their implementation efforts for the Climate Act titled Climate Act Goals – Planning, Procurements, and Progress Tracking. The key finding summary states: “While PSC and NYSERDA have taken considerable steps to plan for the transition to renewable energy in accordance with the Climate Act and Clean Energy Standard, their plans did not comprise all essential components, including assessing risks to meeting goals and projecting costs.”

The Audit Highlights section of the Comptroller Report listed cost-related key findings and key recommendations. The summary of the key findings included a cost-related specific finding:

The costs of transitioning to renewable energy are not known, nor have they been reasonably estimated. Moreover, funding sources to cover those costs have not been identified, leaving the ratepayers as the primary source of funding. The lack of alternative funding sources adds additional risk to whether the State can meet its goals timely. Data shows utility costs have already risen sharply over the last two decades and more New Yorkers are having difficulty paying their utility bills.

There were three key recommendations related to costs:

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

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

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

There has been no formal response directly to these findings. Susan Arbetter’s Capital Tonight show featured an interview with NYSERDA President and CEO Doreen Harris and Rory Christian, Chair and CEO of the PSC where the cost findings came up. I wrote an article that focused on Arbetter’s attempts to get either one of them to open up about the costs. Arbetter asked: “I just want make sure that while there are factors that have contributed to the delay in implementation of our energy goals, is there anything leading the Administration to delay this because of cost.” (Note that this is not an exact quote but it is pretty close – check out the video at 1:40/9:00). Harris responded (2:00/9:00 of the video): “The proceeding that is before the PSC is intended to look at just that”. Harris explained: “How much progress have we made, do we need to make, and specifically they look at all this in the context of consumer cost”.

Biennial Report

The Climate Act requires the Public Service Commission (PSC) issue a biennial review for notice and comment that considers “(a) progress in meeting the overall targets for deployment of renewable energy systems and zero emission sources, including factors that will or are likely to frustrate progress toward the targets; (b) distribution of systems by size and load zone; and (c) annual funding commitments and expenditures.” I believe this is the PSC proceeding referenced by Harris. The draft Clean Energy Standard Biennial Review Report released on July 1, 2024 fulfills this requirement.

However, contrary to the Harris claim, I do not think that this report addresses the progress “in the context of consumer cost”. I searched the Biennial Report for “consumer” and only got three results: one for consumer price index and the other two in a paragraph describing the motivation for deregulating the power sector of New York. That may not disprove the claim that the report looks at all of this in the context of consumer costs, but I have not found any sections addressing consumer costs.

The timing is convenient for the election cycle. My cynical take on this is that the draft did not include consumer costs because of the potential for political fallout. By the time that costs are added to the document the current election cycle will be over.

Energy Plan

According to the New York State Energy Plan website:

The State Energy Plan is a comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers. The Plan provides broad program and policy development direction to guide energy-related decision-making in the public and private sectors within New York State.

The current Plan was initially published in 2015, and updated in 2020, when it was amended to align with the objectives of the 2019 Climate Leadership and Community Protection Act (Climate Act). Since the last update, the Climate Action Council produced its Scoping Plan, examining many of the energy issues that contribute to climate change and offering recommendations that are currently being implemented by the State.

In recognition of the State’s historic clean energy transition, the State Energy Planning Board will now convene, chaired by the New York State Energy Research and Development Authority (NYSERDA), to begin the process of developing a new Plan. Stakeholder engagement is an integral component in the development of the State Energy Plan, and the public will have the opportunity to provide comments on the draft scope and the draft plan throughout the process.

The Energy Plan is a political construct. The Board consists of ten Commissioners all appointed by the Governor, three appointed by the Governor, the President of the Senate, and Speaker of the Assembly, and a non-voting member from the New York Independent System Operator. Given the make up of the Board I expect that all decisions will fit the Governor’s energy narrative.

With respect to the schedule § 6-106. Conduct of the state energy planning proceeding (1) states:

Every four years, the board shall adopt a state energy plan, which addresses each item identified in subdivision two of section 6-104 of this article provided, however, the board may adopt such a plan more frequently for good cause shown. The board shall prepare biennial reports, every second year following the issuance of the final state energy plan, including a discussion and evaluation of the ability of the state and private markets to implement the policies, programs, and other recommendations as found in the state energy plan, and recommendations for new or amended policies as needed to continue successful movement towards implementation and realization of such policies and programs.

The 2015 Energy Plan was the latest edition and the last biennial report came out in 2017. In 2019 the Climate Act was promulgated and in April 2020 an amendment to the plan was adopted that incorporated the new targets. I have never heard an explanation why the plan was not updated. Clearly the Climate Act has a major impact on energy planning but it has been 20 months since the Scoping Plan was completed.

The energy plan required analyses have not been updated since 2015. § 6-104, State Energy Plan (2) (b) says the state energy plan shall include:

(b) Identification and assessment of the costs, risks, benefits, uncertainties and market potential of energy supply source alternatives, including demand-reducing measures, renewable energy resources of4 electric generation, distributed generation technologies, cogeneration technologies, biofuels and other methods and technologies reasonably available for satisfying energy supply requirements which are not reasonably certain to be met by the energy supply sources identified in paragraph (a) of this subdivision, provided that such analysis shall include the factors identified in paragraph (d) of this subdivision;

Identification and assessment of the costs, risks, benefits, uncertainties and market potential of energy supply source alternatives is only possible if there is a feasibility study. There hasn’t been a feasibility study for the Climate Act. On September 9, 2024 the State Energy Planning Board met to kick off this version of the Energy Plan. The following slide outlines the schedule. Note that the comment period on the plan itself is not anticipated until summer 2025.

Given that there is an explicit requirement for a cost assessment my money is on this process sliding until after the 2026 elections.

Conclusion

Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies. There is no question that the Climate Act costs will test the commitment of most New Yorkers to doing something about climate change once the costs are revealed.

During the Draft Scoping Plan review by the Climate Action Council, members Gavin Donohue and Donna DeCarolis repeatedly asked for consumer price cost projections. Co-chair Harris did not provide that information then and appears to be stonewalling now.

My cynical take on this is that Scoping Plan contents, the timing for the NYCI carbon tax, the response to the Comptroller’s audit report, the contents of the biennial report, and the timing for the energy plan all are being manipulated to prevent dissemination of expected consumer costs because of the potential for political fallout. As it stands the bad news will not be let out until after the 2024 election cycle. Given the enormity of the potential costs I recommend voting against any candidate who supports the Climate Act simply because we deserve to know the costs.

Offshore Wind Costs

Last month I described a flurry of offshore wind related news and last week I provided an update describing additional news. In my opinion these latest revelations suggest that a reassessment of the viability of offshore wind projects is in order. I did not address the costs but a couple of articles that have appeared since then do suggest that costs should also be considered in the reassessment.

Overview

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

Offshore wind developments are a key Climate Act decarbonization strategy. There is a mandated target of 9,000 MW of offshore wind by 2035. The Integration Analysis projects that offshore wind capacity will exceed 13 GW by 2040. However, there are overlooked risks to this strategy that are now becoming obvious. The fact is that the huge, proposed wind turbines have not been field tested.

Why Is Cheap Wind Power So Expensive?

Willis Eschenbach poses the cost question that is ignored by the green energy activists. First he describes the overarching Biden Administration goals released in Marh 2021:

Eschenbach is a numbers guy and was immediately suspicious:

Hmmm, sez I, seems a mite ambitious. Current US grid-connected offshore wind is a mere 0.17 gigawatts … so we’d need to do ~ 175 times as much as we’ve done to date and do it in a short six years.

So I divided it out. There are 65 months until 2030. Thirty gigawatts is thirty thousand megawatts, less the 174 megawatts in place, that’s 29,826 megawatts more total generating capacity needed.

29,826 megawatts divided by 65 months means we’d have to add offshore wind generation to the tune of 465 additional megawatts of generation capacity per month. Every month. Starting now.

Get real. That’s not remotely possible. The biggest US offshore windfarm just came on line, 132 MW capacity. To reach the White House goal, every month we’d need to build three new windfarms of that size. No way that can happen. It’s just numbers picked out of the air to gain popular support.

Then he researched the expected time to get an offshore wind farm on line:

The time from the proposal of an offshore wind farm to its grid connection typically ranges from 7 to 10 years. This timeline can be broken down into several phases:

Pre-development and Planning (1-2 years): This phase involves site identification, feasibility studies, and initial environmental assessments.

Permitting and Approvals (3-5 years): Securing the necessary permits and approvals is often the most time-consuming part of the process. This includes detailed environmental impact assessments, consultations with stakeholders, and obtaining state and federal permits.

Construction (2-3 years): Once all approvals are secured, construction of the wind farm, including the installation of turbines and subsea cables, takes place. This phase also includes the grid connection process.

Commissioning and Testing (several months): After construction, the turbines are tested, and the wind farm is gradually brought online.

The bottom line is that if a project is not well along it will not be available by 2030. He found cost information for South Fork Wind which in New York’s first offshore wind farm:

South Fork Wind just came online. This gives us a chance to look at some actual cost figures. It’s the biggest wind farm to date, a 132-megawatt addition to offshore wind. It cost $637 million.

However, Federal subsidies added $191 million to that, plus another couple of hundred million or so from Bureau of Ocean Energy Management (BOEM), the National Oceanic and Atmospheric Administration (NOAA), and the New York State Energy Research and Development Authority (NYSERDA).

Stop and consider. Some private company is building a six-hundred-million-dollar white elephant in the middle of the ocean, and it’s getting paid four hundred million of taxpayer money to do so.

So … what does the New York consumer get for all of this more than generous support?

The consumer gets wind power costing FOUR TIMES AS MUCH as the current cost of power in New York.

Stop and consider. Even when the developer gets two-thirds of the cost paid by the taxpayer, offshore wind power is still four times as expensive.

Eschenbach sums it up:

What’s next?

Well, I’m sure that what’s next is the Harris/Walz campaign will declare that they are 100% behind expensive, intermittent, unreliable wind power, and will claim that if elected, they’ll do what they already said they’d do when Ms. Harris was last elected, which was to screw the consumer and the taxpayer with the huge subsidies, tax breaks, and electricity costs of offshore wind.

Oh, yeah. They claim that the 30 GW of offshore wind will “avoid 78 million metric tonnes of CO2 emissions”. Tens of millions of tonnes, sounds impressive, right?

But IF the IPCC is correct, and that’s a big if, this will reduce the temperature in the year 2050 by …

… wait for it …

… 0.0016°C. Which is almost three-thousandths of one degree F.

Can we please pass a law saying people proposing any laws or regulations in the name of “climate change” be required to tell us (and show their math) how much actual temperature difference that will make by 2050?

All the points made in this article are direct analogies to what is happening in New York State.

Offshore Trojan Horses

Gordon Hughes from the National Center for Energy Analytics compares the subsidies for offshore wind projects to “the classic warning of the Trojan Horse legend, “Beware of Greeks bearing gifts”—in other words, the hidden dangers of accepting something that seems too good to be true.” He argues that “New York State ignored that warning when it agreed to pay very high prices for the electricity to be supplied from its new offshore wind farms—Empire Wind 1 and Sunrise Wind—located off the coast of Long Island.” He continues:

In announcing the final agreements, New York Governor Kathy Hochul triumphantly claimed that the new projects would create more than 800 jobs during the construction phase and deliver more than $6 billion in economic benefits for the state over 25 years.

Rather less emphasis was given to the fact that New York will pay an average price of over $150 per MWh (megawatt hour) for the electricity generated by Empire Wind 1 and Sunrise Wind.That’s more than four times the average wholesale price of electricity in New York during 2023–24, $36 per MWh. The total annual premium over the wholesale market price for the power from these wind farms will be about $520 million per year at 2024 prices. Over 25 years, New York ratepayers will be paying about $13 billion for alleged benefits of $6 billion.

That is not all. Thanks to tax credits, U.S. taxpayers will cover at least 40% of the costs of constructing the wind farms. At a minimum cost of $5.5 million per MW (million watts) of capacity, the total federal subsidy for New York’s two wind farms will be at least $3.8 billion.

He also evaluates the jobs and economic claims made by the Hochul Administration. He concludes that “The economic benefits of the two offshore wind farms are much lower than claimed by the governor and the jobs are, in large part, temporary assignments for professional services staff”. I would add that the temporary assignments will probably be filled by experienced staff from out of state.

Conclusion

The offshore wind proposed contracts are unsustainable. Eschenbach suggests that folks in New York should be asked” “Are you willing to pay four times the going rate for electricity for the rest of your life to MAYBE cool the globe by three-thousandths of one degree Fahrenheit a quarter century from now?” I agree and think that these facts need to be publicized because most New Yorkers have no clue that Climate Act implementation inevitably will increase costs significantly.

Lastly, note that Climate Act proponents have always argued that one of the goals was to demonstrate leadership for the energy transition. This article presents two examples where New York’s transition leadership is cited. Unfortunately, both are bad examples showing what to avoid.

Risks of Climate Act Net Zero

I believe the Climate Leadership & Community Protection Act (Climate Act) transition will negatively affect affordability, reliability, and the environment. I have been meaning to summarize my concerns for quite a while and two recent articles prompted me to write this. David Turver explains how the transition to Net Zero has negatively affected affordability in the United Kingdom. Robert Bryce provides an example of how the Climate Act mandates for offshore wind development will negatively affect the endangered North American Right Whale. Finally, I describe why I worry that the reliance on wind and solar generating resources markedly increases reliability risks.

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

Introduction

David Turver’s Risks of Net Zero article prompted me to write this post. He is the author of the Eigen Values Substack. He is a retired consultant, CIO and project management professional. His description says that he is a first principles thinker who is tired of superficial media simply republishing press releases without critical analysis. His Substack incudes articles about contentious issues such as climate, energy, and net zero.

The Introduction to Risks of Net Zero provides an overview of the general concern about the risk. He states:

We hear a lot about how we are supposedly in a climate crisis and how The Science™ tells us we are about to succumb to global boiling. Most climate activists claim that we must cut emissions by spending more money on windmills and solar panels or we will all burn to a crisp.

I would describe myself as a lukewarmer, by which I mean that I acknowledge the earth is warming and that human emissions of CO₂ have made some contribution to that warming. However, it is also true that the climate has changed dramatically without human intervention; clearly, there are other causes of climate change too.

The strategy of reducing emissions of greenhouse gases to Net Zero is classified as a “mitigation strategy” in the parlance of the IPCC. The alternative strategy is adaptation which means taking measures to adjust to climate change such as building flood defences, irrigation systems or developing new strains of crops to cope better with changing weather patterns. Most spending effort in the West is geared towards mitigation. But, what if the Net Zero cure is worse than the disease? What if mitigation is less effective than adaptation?

Before he addresses affordability Turver compares mitigation against adapatation. He and I agree that adaptation is likely to be more effective than mitigation. He explains why in the following.

Mitigation Drawbacks

Turver points out issues related to mitigating climate change by reducing emissions. Mitigation only works if CO₂ is the only climate control knob but that cannot be the case because we have observed temperature changes over the last thousand years. Mitigation can only work if everyone else slashes emissions too and we can see from Figure 2 (from Our World in Data) that this is not happening.

Adaptation Successes

Turver explains that adaptation since 1900 has dramatically decreased death rates. He includes a figure sourced from Our World in Data.

Not mentioned but certainly a factor is that the death rate went down in no small part because fossil fuels increased the ability of society to address the causes listed. Based on past success the obvious alternative is to emphasize adaptation. Turver explains:

Adaptation measures have many benefits. First, they require no international treaty, and they can be applied locally where they produce results quickly. They also work to protect against changes in the climate that are not driven by CO₂. Adaptation measures might also have additional benefits such as more efficient water use or more robust crop varieties. There is no reason why we cannot continue to adapt.

New York Effect on Climate Change

There is another aspect of mitigation that is routinely ignored by proponents of the Climate Act. New York emissions are tiny relative to global emissions. In 2021, NYS GHG emissions (GWP-100) were 247 million metric tonnes (MMT). GHG emissions from China were 13,774 MMT and from India were 3,879 MMT. The increase in emission from 2020 to 2021 were 498 MMT in China and 265 MMT in India. New York emissions will be supplanted by emissions from China or India in less than one year. New York’s net-zero transition plan emission reductions will have no effect on emissions and thus no effect on the purported effects of climate change. Adaptation investments in New York infrastructure to reduce the costs of extreme weather impacts will focus on New York so the benefits will be to New Yorkers.

Climate Act advocates frequently argue that New York must take action because our economy is large. I analyzed that claim and summarized the data here. New York’s 2020 Gross State Product (GSP) ranks ninth if compared to the Gross Domestic Product (GDP) of countries in the world. However, when New York’s GHG 2016 emissions are compared to emissions from other countries, New York ranks 35^th. More importantly, a country’s emissions divided by its GDP is a measure of GHG emission efficiency. New York ranks third in this category trailing only Switzerland and Sweden. We are already doing our share.

Net Zero Affordability Risks

I think the biggest issue with the Climate Act is affordability. Everyone wants a clean and safe environment but just how clean, how safe and at what price are all value judgements. Turver points out that implementation of net-zero policies like the Climate Act have poorly acknowledged risks:

First and most obvious, they cannot work against climatic changes that are driven by forces other than CO₂. Second is the outright cost.

He goes on to describe observed cost increases in the United Kingdom. He makes the point that additional costs also make manufacturing and other production less competitive, which leads to job losses. Ultimately the inability to produce basic needs reduces security. He also points out that renewable energy development requires more materials than alternatives. That has environmental and cost implications.

Turver explains that the increased penetration of renewables in the United Kingdom has led to a massive increase in electricity bills. This increase comes from “renewables subsidies as well as grid balancing costs and the massive costs of expanding the grid out to remote offshore wind farms”. The article compares recent United Kingdom industrial gas prices and industrial electricity prices:

As can be seen in Figure 5, from 2008 to 2020, industrial electricity prices rose 53.8% while industrial gas prices actually fell slightly over the same time period. Both gas prices and electricity rose in 2021 as gas prices started to spike as demand increased after Covid lockdowns ended and supply could not keep up with demand. However, even though there was a spike in gas prices in 2021, the increase from 2008 is still only 33%, whereas electricity prices have surged 71.4% over the same period. The figures for 2022 are not yet available, but we might expect to see a big surge in both gas and electricity prices due to supply shortages resulting from the war in Ukraine.

There is no doubt that all these impacts will inevitably occur in New York as the Climate Act mandates are implemented. A recurring theme of many of my posts is that the Hochul Administration has never provided clear and comprehensive cost estimates for all the control strategies in the Scoping Plan

American Offshore Wind Energy Scandal

I believe that the environmental impacts of wind and solar development are greater than the impacts of fossil-fueled or nuclear resource development. In my Draft Scoping Plan comments I noted that on September 17, 2020 the Final Supplemental Generic Environmental Impact Statement (SGEIS) for the Climate Leadership and Community Protection Act was released. It covered the “environmental impacts of the offshore wind and distributed solar procurement goals, and the estimate of utility-scale solar capacity required to meet the meet the 70 by 30 goal” based on the resources estimated necessary at that time. Since then, considerably more resources have been projected but the cumulative assessment has not been updated.

Robert Bryce published an article entitled The Offshore Wind Scandal is Even Worse Than You Think that addresses one of the cumulative environmental impacts that the Scoping Plan ignored. Bryce is an author, filmmaker, and public speaker who has been reporting on the energy sector for more than 30 years. His background enables him to provide graphical evidence to support his arguments that I think are well done. In this article he includes 11 charts that “show how America’s biggest NGOs are colluding with foreign corporations that want to industrialize our oceans with thousands of turbines that will hurt whales and ratepayers”.

He writes:

The hard reality is that America’s offshore wind sector is a subsidy-dependent industry that is dominated by foreign companies who are in bed with some of America’s biggest climate NGOs, including the NRDC (gross receipts: $555 million) and Sierra Club (Gross receipts: $184 million). Those NGOs and others, including the National Wildlife Federation (gross receipts: $142 million) and Conservation Law Foundation (gross receipts: $17.5 million), are leading the most shameful environmental betrayal in modern American history. Rather than seek to protect marine mammals and stop the industrialization of our oceans, they are eagerly promoting the installation of hundreds of offshore wind platforms smack in the middle of the known habitat of the critically endangered North Atlantic Right Whale.

I recommend the article for its details. In this summation I am not going to address all the charts in detail. The first four charts support the quotation above. The fifth chart addresses environmental impacts. The offshore wind shills claim that there aren’t impacts on whales, but Federal scientists disagree.

Bryce describes Chart 6:

I’m old enough to remember when environmental groups cared about whales. Alas, that was a long time ago. On Sunday, the Daily Mail published an article about Apostolos Gerasoulis, a Rutgers professor emeritus of computer science who built a software system to analyze the dozens of whale deaths that have occurred on the Eastern Seaboard over the past few years. Gerasoulis set out to determine if the whale deaths were related to the loud blasts of sonar used by offshore wind survey vessels. His conclusion: “Offshore wind kills whales…The numbers never lie. There is a cause. We have shown that the cause for death of the whales is offshore wind. Period.” (H/t fellow Substack writer David Blackmon.)

In Chart 7 Bryce notes that the Massachusetts Sierra Club notes that “Because the North Atlantic Right Whale has such a small population and a low annual reproductive rate, a single whale death can have a significant negative impact on the species’ ability to recover.” In Chart 8 he provides a plain English translation of a statement in the Bureau of Ocean Energy Management environmental impact statement of Vineyard Wind: “These projects won’t make any difference on climate change. But they are good because they allow state-level bureaucrats to say they met their policy goals.”

The remaining charts compare offshore wind capacity and costs relative to other resources. He concludes that these developments will markedly increase costs for states that already have some of the highest electricity rates in the country.

I maintain that the New York State has shirked its commitment to the environment because it has not addressed cumulative environmental impacts of the Scoping Plan buildout of wind and solar. No where is this more impactful than the effects on whales in general and the remaining North American Right Whales in particular. Bryce quotes an opponent of offshore wind: “What is Big Wind going to say when they kill the last whale? ‘Sorry’?”

Reliability Risks

I described my concern about the enormous risk of an electric grid relying on wind and solar resources in this post. Since then, I have refined my description of the problem. It boils down to “correlated intermittency”. Let me explain.

Wind and solar are inherently intermittent – the sun does not shine at night and the wind does not always blow. That intermittency is correlated. All the solar in New York is unavailable at night. It turns out that wind resources across New York also are usually high or low at the same time. There are exceptions but there is a high incidence of similar behavior.

That matters for electric resource planning. Today electric resource planning relies on decades of performance experience with hydro, nuclear, and fossil plants that do not correlate, that is to say there is no reason to expect that all the nuclear plants will be offline at the same time. As shown in the following New York Independent System Operator (NYISO) slide, this characteristic enables the resource planners to determine how much generating capacity is necessary to meet the loss of load expectation (LOLE) criterion. The probability of losing load not more than once in ten years is based on observations of the existing uncorrelated generating resources. Importantly, I believe that the lack of correlation also means that the capacity needed above firm system load would not change substantially if the LOLE planning horizon was shifted to 1 day in 20 years.

Source: NYISO Amount of Capacity Required, Intermediate ICAP Course, June 2023

The variation in weather that affects wind and solar resource availability will require changes to electric resource planning. Everyone has heard of a hundred-year flood which is the parameter used for waterway planning. This is the one in a hundred probability that the water level in a river or lake will exceed a certain level. Similar estimates of low wind and solar resource availability must be developed and incorporated into electric resource planning.

The unresolved problem is what return period probability is acceptable. If the resource planning process does not provide sufficient backup resources to provide capacity for a peak load period, then blackouts are inevitable. Two factors exacerbate the challenge of this problem:

Periods of highest load are associated with the hottest and coldest times of the year and frequently correspond to the periods of lowest wind resource availability.
The decarbonization strategy is to electrify everything possible so the impacts of a peak load blackout during the coldest and hottest periods will be greater.

In an earlier post I described an analysis by the Independent System Operator of New England (ISO-NE) Operational Impact of Extreme Weather Events. The study evaluated 1, 5, and 21-day extreme cold and hot events using a database covering 1950 to 2021. Not surprisingly the system risk or “the aggregated unavailable supply plus the exceptional demand” during an event increased as the lookback period increased. If the resource adequacy planning for New England only looked at the last ten years, then the system risk would be 8,714 MW, but over the whole period the worst system risk was 9,160 and that represents a resource increase of 5.1%. There is no question that a similar analysis for New York would find a similar result.

The correlated intermittency of wind and solar resources means that we will depend on energy-limited resources that are a function of the weather causing low resource availability at the same time. The unresolved issue is how to design an affordable and practical system to meet the worst-case weather induced lull. Consider the ISO-NE analysis where it was found that the most recent 10-year planning lookback period consistent with current LOLE evaluations would plan for a system risk of 8,714 MW. If the planning horizon covered the period back to 1961, the worst-case to 1950, an additional 446 MW would be required to meet system risk. I cannot imagine a business case for the deployment of electric system resources that will only be needed once in 63 years. For one thing, the life expectancy of these technologies is much less than 63 years. Even over a shorter horizon such as the last ten years, how will a required facility be able to stay solvent when it runs so rarely? The only solution is subsidies to build and very high payments when they do run.

Reliability risks have also been identified by the North American Electric Reliability Corporation. They have expressed concerns that extreme weather events, rapid demand growth, and systemic vulnerabilities pose risks for supply shortfalls and grid reliability. These are serious risks to the Climate Act net-zero transition plan that must be resolved sooner rather than later.

Conclusion

I believe that the Climate Act will do more harm than good. Affordability is the first problem. The Hochul Administration has not provided transparent and comprehensive cost estimates for the control strategies proposed for the net-zero transition. The New York State Comptroller Office audit of costs in Climate Act Goals – Planning, Procurements, and Progress Tracking agrees with my concern and recommends a detailed analysis of cost estimates to transition to renewable energy sources and meet Climate Act goals. I believe such an analysis will agree with observed results elsewhere that show the costs will be extraordinary and will certainly affect affordability.

The Hochul Administration has not provided a cumulative environmental impact assessment for the generating resources projected in the Scoping Plan. Nowhere is the potential impact more critical than with respect to whales and the massive deployment of offshore wind proposed. It is incumbent upon the State to prove that there will not be adverse impacts to the critically endangered North American Right Whales.

Finally, there ae reliability risks inherent in a weather-dependent electric grid when all the wind and solar output is reduced at the same time. This raises overarching questions that have not been addressed. Furthermore, even if these weather risks can be addressed in theory, the solution will involve technologies that are not commercially available today. I have no doubts that the only safe way to decarbonize the electric grid is to rely on nuclear power. The Hochul Administration needs to confront these issues before it is too late.

The risks of the Climate Act are all associated with mitigation efforts to reduce GHG emissions. I agree with Turver that mitigation should be emphasized. He concludes:

The risks of climate change can be averted by continuing to adapt, just as we have for millennia. It is certain that unilateral action by the UK, or indeed multilateral action by much of the West, will do nothing to change the weather while the developing world continues to increase their consumption of hydrocarbons to make themselves richer. Indeed, even if mitigation measures were adopted globally, it is naïve to believe that bad weather will cease and we will suddenly get the “stable climate” demanded by more than 170 lawyers.