Category: Climate Act Feasibility

This is my 400^th article on the Climate Leadership & Community Protection Act (Climate Act) net-zero transition.  It seems appropriate to look at where the state stands relative to the time when I started writing these articles and the Climate Act targets.  This summary supplements the progress status summary described by Francis Menton and the generation trend status prepared by Nuclear New York by looking at Greenhouse Gas (GHG) emissions.

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

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.”  In brief, that plan is to electrify everything possible using zero-emissions electricity. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  In 2023 the Scoping Plan recommendations were supposed to be implemented through regulation, PSC orders, and legislation.  Not surprisingly, the aspirational schedule of the Climate Act has proven to be more difficult to implement than planned.  Many aspects of the transition are falling behind, and the magnitude of the necessary costs is coming into focus.  When political fantasies meet reality, reality always wins.

Nuclear New York – Generation Trends

In a press release on January 8, 2024 Nuclear New York, “Independent Advocates for Reliable Carbon-Free Energy” explained that “four years since passing the Climate Act, New York struggles to replace shuttered clean energy “.  Their release stated (foot notes removed):

In 2023, nuclear power was once again the largest single source of clean energy in New York State. Electricity generation from this carbon-free source totaled 27.6 terawatt hours (TWh), up 2.7% over 2022. Nuclear covered 18.1% of the state’s total electricity demand (including behind-the-meter “rooftop” solar generation), and amounted to 42.7% of in-state clean electricity.

Hydro, the second largest source of carbon-free power, recovered 2.1% in 2023 to 27.2 TWh, covering 17.9% of demand. These two ‘firm clean’ generation sources provide on-demand power regardless of the time of day or weather.

Despite increasing deployed wind capacity in 2022 by 13% over 2021, generation from this source declined 3.9% in 2023 over 2022 to 4.7 TWh, demonstrating the perils of relying on weather-dependent renewable energy. New York Independent System Operator (NYISO) does not report grid-connected solar as a separate category, given its currently minuscule contribution to the generation mix. However, rooftop solar generation increased 18% to 5.2 TWh, covering 3.4% of demand.

New York’s electricity demand declined by 4.8 TWh over 2022 (-3.1%), which enabled the state to reduce net imports by 4.3 TWh. In-state fossil fuel combustion decreased by 2.3 TWh, but remained 11.0 TWh (21%) above 2019 levels, when clean energy generation peaked.

Updates on the March to the New York Great Green Future

Francis Menton’s update on the net-zero transition asks the question where are we and responds:

The Manhattan Contrarian Energy Storage Report of December 1, 2022, led off by sounding a clear alarm: getting electricity from intermittent wind and solar well past 50% of total generation would require enormous quantities of energy to be stored, with technical requirements, including duration of storage, well beyond the capability of any battery currently existing or likely to be invented any time soon. Essentially, if fossil fuels are to be eliminated, there is only one realistic possibility for meeting the storage requirements: hydrogen.

In mid-2023, the New York Independent System Operator, to its credit, recognized the problem — although it buried that recognition deep in a report when it should be shouting about the problem from the rooftops. From NYISO’s Power Trends 2023 Report, revised August 2023, page 7, starting in the middle of a paragraph and without any emphasis:

“[T]o achieve the mandates of the CLCPA, new emission-free generating technologies with the necessary reliability service attributes will be needed to replace the flexible, dispatchable capabilities of fossil fuel generation and sustain production for extended periods of time. Such emission-free technologies, either individually or in aggregate, are not yet available on a commercial scale.“

With hydrogen as the only possible such “emissions-free generating technology,” how much would hydrogen cost as the solution to this problem, particularly if one follows the hypothesis that it must be created without any use of fossil fuels? My Report, page 14, noted that existing commercial production of this so-called “green” hydrogen was “negligible,” leaving no good benchmark for understanding what the costs might be. As a substitute, I ran some rough numbers based on cost of wind and solar generators to make the electricity and efficiency of the electrolysis process. The result was a very rough estimate that this “green” hydrogen would cost “somewhere in the range of 5 to 10 times more” than natural gas (page 17).

Well, now some new precision has come into view. In July 2022 the UK government launched what it calls its First Hydrogen Allocation Round (HAR 1), to obtain bids and award contracts to produce this so-called “green” hydrogen using wind power. The process took a while, but here from December 14, 2023 is the announcement of the first round of contract awards. Excerpt:

“Following the launch of the first hydrogen allocation round (HAR1) in July 2022, we have selected the successful projects to be offered contracts. We are pleased to announce 11 successful projects, totalling 125MW capacity. HAR1 puts the UK in a leading position internationally: this represents the largest number of commercial scale green hydrogen production projects announced at once anywhere in Europe. . . . The 11 projects have been agreed at a weighted average strike price of £241/MWh.“

£241/MWh? At today’s exchange rate of 1.27 $/£, that would be $306/MWh. Prices of natural gas are generally quoted in $/MMBTU rather than per MWh, but here is EIA’s latest Electricity Monthly Update, dated December 21 and covering the month of October 2023. It gives natural gas prices in the per MWh units. The “price of natural gas at New York City” is given as $11.32/MWh. That would make the price that the UK has just agreed to pay to buy this “green” hydrogen stuff approximately 27 times what we can buy natural gas for here in New York to obtain the same energy content.

And that $306/MWh is just for the hydrogen. It includes nothing for the massive new facilities (underground salt caverns?) to store the stuff, for a new pipeline network to transport it, and for a new collection of power plants to burn it.

Electric Generating Unit Emission Trends

Electric generating units report emissions to the Environmental Protection Agency Clean Air Markets Division as part of the compliance requirements for the Acid Raiin Program and other market-based programs that require accurate and complete emissions data.  The 2023 emissions data submittal date was January 31 and I downloaded the data the next day.  Something has changed in the data access system so I could not check to see if all the facilities reported on time.  If some facilities had to ask for a delayed submittal this could mean that the totals are lower that actual emissions.

The following table lists the emissions since 2009 when the Regional Greenhouse Gas Initiative started.  Emissions of CO2, SO2, and NOx are down dramatically over this period.  The primary reason is that the fracking revolution made the cost of natural gas so cheap relative to other fuels that every facility that could convert to natural gas did so.  New York banned the use of coal in 2021 which forced the retirement of the remaining coal plants.  The state still has some facilities that primarily burn residual oil but those run infrequently.  The takeaway message is that the fuel switching options are no longer available so future reductions will only come as zero-emissions resources displace facilities burning fossil fuels.

The following graph shows the emission trends.  Note that I divided the CO2 emissions by 1,000 so that all the parameters would show up on the same plot.  The impact of the closure of the Indian Point nuclear facility mentioned in the Nuclear New York presentation is clearly shown as CO2 rose over the last three years until the 2023 emissions started down.  Importantly that could be mostly due to weather variations and not necessarily the addition of the renewables shown above.

New York State GHG Emission Trends

A relevant question is where we stand in regards to the Climate Act mandate for a 40% reduction from a 1990 baseline in GHG emissions by 2030.  Unfortunately, that is not easily answered in sufficient detail to be able to figure out what is going on.

The regulation setting the 1990 baseline emissions values that form the basis for the 2030 40% reduction and the 2050 85% reduction was promulgated in 2020.  It sets the limits

§ 496.4 Statewide Greenhouse Gas Emission Limits

(a) For the purposes of this Part, the estimated level of statewide greenhouse gas emissions in 1990 is 409.78 million metric tons of carbon dioxide equivalent, using a GWP20 as provided in Section 496.5 of this Part.

(b) For the purposes of this Part, the table below establishes statewide emission limits for the year specified, as a percentage of estimated 1990 statewide greenhouse gas emissions of 60 percent and 15 percent, respectively, measured in millions of metric tons of carbon dioxide equivalent gas using a GWP20 as provided in Section 496.5 of this Part.

Year	Statewide greenhouse gas emission limit (in million metric tons of carbon dioxide equivalent)
2030	245.87
2050	61.47

The Regulatory Impact Statement for the regulation included a table that breaks down the 1990 emissions by Intergovernmental Panel on Climate Change Sectors and gases.  As shown below there is not much of a breakdown.  Note that all the rest of the emissions will be reported as the CO2 equivalents so you do not need to worry about the component gases.

According to the 2023 Statewide GHG Emissions webpage “The Climate Act requires the New York State Department of Environmental Conservation (DEC) to issue an annual report on statewide greenhouse gas emissions, pursuant to Section 75-0105 of the Environmental Conservation Law.”  The most recent report covering the years 1990 through 2021 was released in late December 2023. The following reports were released at that time:

• Summary Report (PDF)
• Sectoral Report 1: Energy (PDF)
• Sectoral Report 2: Industrial Processes and Product Use (PDF)
• Sectoral Report 3: Agriculture, Forestry, and Land Use (PDF)
• Sectoral Report 4: Waste (PDF)
• Appendix: CLCPA Emission Factors (PDF)

I extracted summary data from each of the sectoral reports to provide some idea of where New York stands relative to the 2030 targets in the following table.  The Part 496 1990 column lists the regulatory baseline numbers.  The estimated emissions in the 2023 Statewide GHG Emissions are listed for 1990, 2005, and the last five years.  I list the sector 2030 targets (40% of 1990 emissions) and the percentage reduction necessary to meet the targets. 

The first thing that pops out is that the 2023 inventory has a different estimate for 1990.  GHG emission inventories require indirect estimates of many of the emission sources and the assumptions regarding the emission factor that estimates emissions with an activity and the activity rate.  This is a fundamental problem with emission factors and means that for full transparency all the emission factors and associated activity levels should be clearly documented.

The second thing of note is that none of the IPCC sectors are even close to the 2030 targets.  The Scoping Plan’s quantitative assessment in the Integration Analysis essentially is a list of control strategies, presumed control efficiencies, and expected emission reductions that when added up meet the limits.  That assessment was poorly documented, contains inconsistencies with similar New York Independent System Operator (NYISO) analyses, and there has never been any response to comments about inconsistencies and other issues identified in the Scoping Plan comments.  There is no feasibility analysis to determine if those targets can be met with any assurance.

I tried to analyze the data used for the 2023 Statewide GHG Emissions.  Those data are available for download from Open Data NY.  This is another instance where it is not easy to break down the components of the IPCC sectors to determine if it is realistically possible to meet the 2030 targets because state agencies do not provide consistent data.

The Regulatory Impact Statement for Part 496 included Table 4 that broke down fuel combustion GHG emissions within the IPCC energy sector.  Because I used the dataset itself, I picked the sector categories that I believe match the Table 4 categories.  Note that I did not include fuel combustion from petroleum refining in the table because I could not find categories that I thought matched it.  The following table lists the results for the last ten years and compared the 2021 emissions to the 2030 target. Fuel combustion in the electric and industrial sectors are already lower than the equivalent 2030 targets.  On the other hand, transportation and fuel combustion in the commercial and residential sectors will require significant reductions to meet the targets. 

Is that feasible?  Consider what is needed for just one parameter.  To determine if the transportation fuel combustion reductions are feasible, the expected reductions per gasoline vehicle must be estimated.  Miles per gallon and the annual mileage need to be estimated for a range of users and locations so that a reasonable estimate of state-wide fuel use can be estimated.  Once you know that then you can determine how many zero-emissions vehicles must be deployed.  Is that estimate realistic?  That is not all because zero-emissions vehicles also require charging infrastructure and that affects the distribution infrastructure. It is easy to say the model projections meet the 2030 targets but the range of parameters that can be tweaked is so large that any pre-conceived answer can be produced. 

I also put these data in a graph.  I am not sure it adds much value, but I spent enough time on it that I don’t want to waste the effort.  The overall trend suggests that it might be possible to meet the targets if, and only if, the historical rate of emission reductions can be replicated.  Given that the electricity and industrial sectors have achieved the greatest reductions but have no readily available additional reductions, I am not optimistic. 

Conclusion

The 400 articles I have written on the Climate Act all lead to the same result.  When you look at the numbers as shown in this post, the enormity of the challenge is clear. Paraphrasing Francis Menton:

No person looking at these charts would ever conclude that New York has spent the past five years embarked on a crash program to replace fossil fuels with wind and solar. That process is going absolutely nowhere.

Richard Ellenbogen recently sent an email to his distribution that highlighted an inevitable problem with New York State’s net-zero mandate of the Climate Leadership and Community Protection Act (Climate Act).  The plan is to electrify everything possible using renewable energy.  That brings up the problem that the local electric distribution system is not up to the task so it is likely that electric use could be limited at times in New York’s future.

Ellenbogen is the President [BIO] Allied Converters and frequently copies me on emails that address various issues associated with the Climate Act.  I have published other articles by Ellenbogen and 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.” I recently described his presentation on New York’s Energy Transition that is a detailed explanation why the State’s quest for zero emissions electricity generated by wind and solar is doomed to failure.

There are only a few people in New York that are trying to educate people about the risks of the Climate Act with as much passion as I am but Richard certainly fits that description.  He comes at the problem as an engineer who truly cares about the environment and how best to improve the environment without unintended consequences.  He has spent an enormous amount of time honing his presentation summarizing the problems he sees but most of all the environmental performance record of his business shows that he is walking the walk.  

Climate Act Overview

The Climate Act established a New York “Net Zero” target (85% reduction and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.”  In brief, that plan is to electrify everything possible using zero-emissions electricity. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan.  After a year-long review, the Scoping Plan recommendations were finalized at the end of 2022.  In 2023 the Scoping Plan recommendations were supposed to be implemented through regulation and legislation.  Ellenbogen’s discussion describes one of the issues that was not addressed in 2023.

Record Christmas Lights

Ellenbogen described a home in Union Vale, NY where the residents set the world record for most lights in a residential Christmas display with 720,420 lights in the display.  He provided links describing the the record lights from the New York Times:

I cannot get around the Times paywall so I could not see those articles but found a relevant story at Good Morning America that includes a video.

Ellenbogen writes:

Independent of any issues raised in the article, the following comment by a neighbor stands out.

Bernadette and William Burke, who love to watch the show from their hot tub, but for years could not use their washing machine or dishwasher while the lights were on. Mr. Gay said the problem was resolved when the electric company put the Gay house on its own transformer.

He estimated the power requirements:

Below is a table of power consumption of various Christmas bulbs. Using a back-of-the-napkin calculation, the display probably draws about 75 – 100 KVA.   Most utility transformers in residential areas are sized between 70 KVA and 150 KVA.  Below are photos from a NYSERDA report that I wrote in 2010 for the reactive power project I did for them.  Note that a transformer used to support five buildings in a Garden Apartment complex had a capacity of 150 KVA and a transformer for two buildings had a capacity of 75 KVA.  Both of these transformers operated near their capacity on a hot summer day and would far exceed that capacity with widespread installation of heat pumps.

Ellenbogen compared the power consumption of the display to heat pumps and car charging that are components of the Scoping Plan outline of control strategies to meet the Climate Act mandates:

The three heat pumps in my home will draw about 22 KW at peak load for 250,000 BTU of heat transfer in heating mode (1000 watts per ton  COP=3.52 ).  The power draw in cooling mode is about 60 % of that (600 watts per ton  COP=5.86 ).  We also have gas furnaces with an output of 400,000 BTU that will operate on extremely cold days or will operate if there is an issue with the heat pumps.

My car charges at a peak load of 14,000 watts.  I have seen loads of 38,000 watts on the power monitor at my house when I am charging the car during the winter.  When I built my house, I had a 400 amp 3phase service installed.  It can deliver 144 KVA ( 144,000 watts) at peak load and the transformer across the street is 150 KVA.  Most newer homes might have a 200 amp single phase service (40 KVA) and older homes will have a 100 amp or 150 amp service (20 – 30 KVA).

Discussion

Ellenbogen argues that the fact that a neighbor was impacted by a large load by a neighbor has ramifications when everyone has to increase their electrical requirements:

The point is that if the utility system can’t support a Christmas display, even a large one, and allow the neighbors to wash their clothes at the same time, how is it going to support the massive load of heat pumps and vehicle charging that is being mandated.  That combination will far exceed the demand of a Christmas light display.  As I have mentioned previously, every transformer in the state is going to have to be replaced or have their service upgraded as occurred at the home in the article.  The problem is that there is an acute transformer shortage along with a shortage of electricians and utilities are worried about having a sufficient number of transformers to recover after a bad storm, let alone having enough to rebuild the entire system.

Also note that the GMA piece on the record light display mentioned that the owners claim that their electric bill is only $300.  New York utilities are installing smart meters that will eventually enable them to charge customers different rates at different times of the day.  The idea is that they will increase rates to incentivize customers to reduce use during peak load periods.  In the all-electric future the peak load will be in the early evening when homeowners get home from work and turn on appliances.  I would not be surprised at all if the costs for the massive display might increase so much that they would be unable to afford the costs even with LED lights.

Although the utilities claim that customers will not lose control of their electric use, I suspect that is also inevitable because of the scale of the problem.  As a result, someday Scrooge will say no you cannot have a record light show.

Conclusion

Ellenbogen said he was going to send a magic wand to the Public Service Commission to help them with the Climate Act transition because they are going to need all the help that they can get.  I agree with his conclusion: “Since math and science have been thrown out the window in New York State, we might as well turn to the occult.”

On November 29, 2023 the New York Independent System Operator (NYISO) released its 2023-2032 Comprehensive Reliability Plan (CRP).  This is a key part of New York’s reliability planning process and addresses the Climate Leadership & Community Protection Act (Climate Act) net zero transition mandate for the 70% renewable energy by 2030 and the zero-emissions grid by 2040.  The report includes recommendations that are odds with climate activists’ demands.  This post summarizes recommendations related to the Climate Act.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 350 articles about New York’s net-zero transition.  I have devoted a lot of time to the Climate Act because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good by increasing costs unacceptably, threatening electric system reliability, and causing significant unintended environmental impacts.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.”  In brief, that plan is to electrify everything possible using zero-emissions electricity. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan.  After a year-long review, the Scoping Plan recommendations were finalized at the end of 2022.  In 2023 the Scoping Plan recommendations are supposed to be implemented through regulation, PSC orders, and legislation. 

In order to ensure that the onslaught of regulations and orders is feasible the NYISO follows its reliability planning process.  The press release for the 2023-2032 Comprehensive Reliability Plan (CRP) says that it “highlights growing risks to electric system reliability, including: projected increases in peak demand due to electrification of the transportation and building sectors; additional generator deactivations; delayed implementation of planned infrastructure projects; and extreme weather.” It is a part of the NYISO reliability planning process that “sets forth a plan to maintain a reliable bulk electric grid based on expected changes and conditions over a ten-year planning period.”  It is issued every two years.  The report and appendices are available from the NYISO.

Press Release Highlights

In this section I will annotate the points made in the press release.  The first paragraph after the introduction notes:

In addition to rising demand due to continued electrification, several large commercial projects in upstate New York are in development and are forecasted to significantly increase energy use over the planning period.  Further, state legislation enacted last year will require the phase-out of the New York Power Authority’s small natural gas plants located in New York City by December 31, 2030. If demand on the grid grows at a rate greater than the buildout of new generation and transmission, reliability deficiencies could arise within the CRP’s ten-year planning period. 

Electrification of the transportation and building sectors is a direct consequence of the Climate Act plan to reduce greenhouse gas emissions (GHG) by electrifying everything possible.  The building and transportation sectors are the two largest sectors of emissions.  There is no question that replacing energy used by direct combustion of fossil fuels with electricity will increase loads.  NYISO is particularly concerned that this transition will not only increase the loads but also shift the peak loads from summer to winter and affect the daily load patterns as well.

The electric grid is an incredibly complex system best left to experts.  The hubris of the progressive wing of the Democratic majority in the New York State Legislature that they should get involved in power planning is blatant pandering to favored constituencies.  The NYPA legislation is a case in point.  Phasing out the New York Power Authority’s small natural gas plants in New York City by any date certain is a risk that is major issue in the CRP.  Increasing load on one hand and retiring generation at the same time is a primary risk identified in the report.

The press release explains how the problem can be addressed:

The potential risks and resource needs identified in the CRP may be resolved by new capacity resources coming into service, construction of additional transmission facilities, increased energy efficiency, integration of distributed energy resources and/or growth in demand response participation.

I do not think that there are any surprises in these recommendations.  It is imperative to build more, connect more, and reduce load to the extent possible but electrification of buildings and transportation means we cannot expect much help there.

The press release highlights risks related to deployment of new resources:

“Our latest report demonstrates the continued importance of the NYISO’s in-depth planning process and the need to closely monitor the rapidly changing electric grid,” said Zach Smith, Vice President, System and Resource Planning.  “In this CRP, we highlight several risk factors that could adversely affect system reliability in the months and years ahead.”

The plan underscores the importance of the timely completion of planned transmission projects – primarily the Champlain Hudson Power Express (CHPE) project – to maintain system reliability. Without the CHPE project in service by May 2026 or other offsetting solutions, reliability margins within New York City would be deficient beginning in 2026.

I cannot over-emphasize how important the NYISO planning process is during this transition.  It is the most prominent process to introduce reality.  Unfortunately, I am concerned that the transition to weather-dependent resources that cannot be dispatched and do not provide ancillary transmission support services is unprecedented and that even the experts at the NYISO will be unable to anticipate all the possible problems.  This could result in blackouts that will be more impactful than any of the potential impacts of a tweak to climatic conditions due to GHG emissions.

In the politicized energy policy environment of New York the NYISO cannot come out and say that risking the reliability of New York City’s electric grid by counting on a specific transmission project is unacceptable. Underscoring the importance of “timely completion” really means we should not make any changes to the existing system until the Champlain Hudson Power Express project is complete.  In addition there are risks to the technology.  I have heard anecdotal evidence that there have been issues with underwater electric cables connecting Long Island to the mainland that lasted longer than expected.  CHPE is mostly underwater from Quebec to New York City but there are above ground lines in Quebec that are even more liable to disruptions.

The strategy to electrify everything will shift the peak load from summer to winter.  This introduces additional issues:

Transition from a summer peaking system to a winter peaking system also poses challenges to grid reliability. This shift, driven by the electrification of the building and transportation sectors, is forecasted to occur within ten years. A winter peaking system introduces new reliability concerns, particularly around fuel availability for gas-fired generators. Based on a recent assessment of New York’s fuel and energy security, the CRP states the following:

Preliminary results of the 2023 Fuel and Energy Security study demonstrate that NYISO will need to rely significantly on dual-fuel generation resources to support winter system reliability into the next decade and changes to the resource mix may complicate system operations during multi-day cold snap conditions. The frequency and severity of projected potential loss of load events grow over the modeling time horizon as the generation mix evolves and the demand for electricity increases.

One of the prominent claims of the Scoping Plan is that the “zero-emissions” electric grid of the future will be “diverse”.  Nothing could be further from the truth.  The ugly secret of wind and solar resources is that their output is correlated.  The CRP notes: “Solar resources will have little to no output during the evening and nighttime hours and reduced output due to cloud cover, while wind resources can experience significant and sustained wind lulls. Periods of reduced renewable output will occur for short durations due to cloud cover or changes in wind speed and for prolonged periods across a daily/seasonal cycle.”  The CRP does not point out that wind lulls frequently occur over the entire state which magnifies the difficulties.

The New York generating system used to be more diverse than today.  New York regulated coal-firing out of business but the coal plants could store on-site fuel.  Natural gas is cheaper and has less environmental impact, but it is also used for home heating and thus subject to curtailment.  New York has significant oil-fired resources that have the advantage that they can be store oil on-site.  The reference to dual-fuel generation refers to the ability of certain facilities to burn oil and natural gas so that they can provide power when natural gas is curtailed.

The press release closes with the following:

Given the rapid pace of change on the bulk electric system, the NYISO will continue to monitor these and other developments to determine whether changing system resources and conditions could impact the reliability of the New York electric grid.

The competitive wholesale electricity markets administered by the NYISO are an essential tool to mitigate risks on the electric system, as well as facilitate the transition of the grid to increased renewables and decarbonization as required under state law.  The competitive markets continue to evolve and adapt to guide and attract new market entry and retention of resources that support reliability. 

The NYISO is a product of the de-regulated electric system that depends on markets.  I am not as optimistic as NYISO that the markets will succeed as suggested.  Energy developers have to be consider the risks and rewards of all the investments they make.  One of the problems in New York City is that the in-city peaking power plants are old.  I know that many of the facilities had plans to re-power with new and much cleaner units and had all the permits in place to build them. However, market uncertainties led to the decision not to build them.  Without expensive guaranteed subsidies I expect that this will be the case for renewable developments.  That sounds less and less like a de-regulated system to me.

Key Reliability Risk Takeaways

The CRP Executive Summary outlines the reliability risks.  There is an important caveat:

The CRP’s finding of no long-term reliability violations reflects the Reliability Planning Process assumptions, which are set in accordance with applicable reliability design criteria and NYISO’s procedures. There are, however, risk factors that could adversely affect system reliability over the planning horizon. These risk factors may arise for several reasons including climate, economic, regulatory, and policy drivers.

The ultimate concern is whether the risk factors are so problematic that it is appropriate to consider if a implementation pause is in order.  It is de rigor to say that climate will affect the availability of electricity, but they are really talking about extreme weather not climate. There are economic issues associated with the renewable developers that could slow or cancel developments,  The Hochul Administration is trying to remove all regulatory barriers but the Federal Energy Regulatory Commission, New York State Reliability Council, New York Public Service Commission, and even the NYISO have regulatory requirements that can affect implementation particularly on the arbitrary schedule of the Climate Act. 

The following list of key risks are all the result of the Climate Act net-zero transition.  In this overview I will include some brief comments.

The CRP is concerned with the speed of change in the electric grid.  Unsaid in the following is that there are no in-kind replacements available for the NYPA small gas plants.  Legislators may think that replacement is only a matter of political will, but reality is different.

The pace of generation retirements has exceeded the pace of resource additions to date. Should this trend continue, reliability needs will be identified both locationally and statewide. For example, retirement of the NYPA small gas plants without adequate replacement would result in a deficiency in New York City of more than 600 MW.

The list includes concerns related to the CHPE project which I addressed earlier:

The reliability of the grid is heavily reliant on the timely completion of planned transmission projects, chiefly the CHPE project. Without the CHPE project in service or other offsetting changes or solutions, the reliability margins would be deficient for the ten-year planning horizon.

The Climate Act transition to electrified heating and transportation is unprecedented. 

There is a clear upward trend forecasted in peak demand over the next ten years, with significant uncertainty driven by electrification of heating and transportation coupled with the development of multiple high-electric demand facilities (e.g., microchip fabrication and data centers). As the demand on the grid grows at a rate greater than the build out of generation and transmission, deficiencies could arise within the ten-year planning horizon.

The NYISO is making their best estimates of the effect on peak load but the estimates are uncertain.  Another big concern is the potential addition of major high demand facilities.  At the top of the list of high demand facilities is the proposed Micron chip fabrication plant near Syracuse which is expected to need as much power as Vermont and New Hampshire combined.

Another key risk is imported power:

New York’s current reliance on neighboring systems is expected to continue through the next ten years. Without emergency assistance from neighboring regions, New York would not have adequate resources throughout the next ten years.

Extreme weather has always been the biggest threat to reliability.  This risk is also listed:

Extreme events, such as heatwaves or storms, pose a threat to grid reliability throughout the planning horizon and could result in deficiencies to serve demand statewide, especially in New York City. This outlook could improve as more resources and transmission are added to New York City.

The CRP links imported power and extreme events.  The document states that:

Statewide resource adequacy during these extreme events relies on neighboring regions for assistance during emergencies. Grid analysis demonstrates that New York would not have adequate resources throughout the next ten years if not for emergency assistance. Such emergency assistance assumes availability of resources from neighboring systems to send power to New York in an event that New York resources are inadequate. The NYISO will maintain interregional collaboration with neighboring systems to monitor the availability of emergency assistance as the resource mix transitions throughout the entire Eastern Interconnection.

I think the extent of the reliance on imported power represents a new paradigm.  It is not clear to me that it is in the best interests of New York to be dependent upon other jurisdictions.  This is especially true as the dependency upon wind and solar resources increases throughout the Eastern Interconnection.  The fact is that the winter worst-case coldest temperature extreme events are associated with low wind and solar resource availability.  The under appreciated problem is that the extent of the low resource availability during those events goes beyond adjacent systems.  Those systems may not be able to provide emergency support even if they wanted to.

There is an unmentioned reliability risk with the potential for devasting consequences.  Projections for future New York electrical energy generation (MWh) call for offshore wind to provide between 15 and 20% of the annual energy needs of the grid.  If a category 4 hurricane hits the offshore wind farms, then a significant fraction of the wind turbines could be damaged or destroyed.  Replacing them in a timely fashion would be a huge problem.

The problems of a winter-peaking system are another reliability risk.  I cannot add anything to the CRP summary:

The New York statewide grid is projected to become a winter-peaking system in the mid-2030s, primarily driven by electrification of space heating and transportation. The New York statewide grid is reliable for normal weather in the winter for the next ten years, but deficiencies would arise as early as winter 2027-2028 for an extreme 1-in-100-year winter cold snap coupled with a shortage of gas fuel supply. This deficiency would grow to a 6,000 MW shortfall by winter 2032-2033. Additional deactivations of dual-fuel generation beyond what is planned will exacerbate the winter reliability risk.

The final reliability risk addresses changes to the planning process:

Planning for the more extreme system conditions of heatwaves, cold snaps, and fuel availability is currently beyond established design criteria. However, several reliability organizations are investigating whether applicable reliability rules and design criteria should be revised to account for these events.

I am disappointed that the CRP did not mention the link between low wind energy resource availability and heatwaves and cold snaps.  Large and intense atmospheric high-pressure systems lead to the most extreme temperatures and cause light winds over enormous areas.  The reliability organizations are just getting their heads around the ramifications of the magnitude, duration, and extent of these events.  They have not addressed the effect on design criteria.  One of the primary criteria today is the loss of load expectation over a ten-year period.  If analysis determines that once every fifteen years that the expected availability of wind resources requires additional support, that means a new planning horizon. 

The unaddressed issue is where do you stop.  A 15-year criterion could require a substantial investment for some resource that will only be used once every fifteen years.  The problem is that you must make the investment because the weather conditions that cause the problem will occur- it is only a question of time.  If the investments are not made, then electricity won’t be available and a catastrophic blackout will occur.  In February 2021, the Texas electric grid failed to provide sufficient energy when it was needed.  The storm was the worst energy infrastructure failure in Texas history and 4.5 million homes and residences were without power, at least 246 people died, and total damages were at least $195 billion. 

Conclusion

The North American electric power grid has been described as the  largest machine in the world.  Incredibly all the fossil, hydro, and nuclear generating stations in the Eastern Interconnection from Saskatchewan to Florida, Oklahoma to Nova Scotia are connected and work together. It relies on the ability of operators to constantly match load demand with generation output.  In order to provide 60 Hz power, the generating turbines are synchronized to run at 3600 revolutions per minute.  Operators keep the voltages as constant as possible in the entire area but have the advantage that those turbines provide inertia, and they can dispatch generating resources as necessary.

The CRP raises important reliability issues, but I think it does not fully convey the magnitude of the proposed “zero-emissions” transition challenge.  The success of the existing power grid and the benefits of affordable and reliable power it provides developed over decades.  Converting the existing system to one that relies on weather-dependent resources and does not inherently provide the ancillary services such as inertia that are inherent to the turbines relied on presently is a massive challenge.  Meeting the ”zero-emission” by 2040 schedule mandated by politicians without relying on nuclear energy exacerbates that challenge.  It is not politically correct for the NYISO to call out this challenge in detail or to explicitly suggest that it is not possible without enormous reliability risks.  I have no such restraints.  Unless the Climate Act mandates are modified and the schedule changed, blackouts will result, and people will freeze to death in the dark;

I believe that single biggest flaw in the Climate Leadership & Community Protection Act (Climate Act) net zero transition is the failure to include a feasibility analysis.   I agree with Francis Menton, the Manhattan Contrarian, that the ultimate test would be a demonstration project to determine the feasibility of a fully wind/solar/battery electric generation system.  This post describes a series of articles by Ed A. Reid, Jr. at the Right Insight blog describing what he believes should be included in a grid-scale demonstration project.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 350 articles about New York’s net-zero transition.  I have devoted a lot of time to the Climate Act because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good by increasing costs unacceptably, threatening electric system reliability, and causing significant unintended environmental impacts.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.”  In brief, that plan is to electrify everything possible using zero-emissions electricity. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan.  After a year-long review, the Scoping Plan recommendations were finalized at the end of 2022.  In 2023 the Scoping Plan recommendations are supposed to be implemented through regulation, PSC orders, and legislation. 

The Problem

In my opinion a feasibility analysis that addresses reliability, affordability, and cumulative environmental impacts should be a prerequisite for the proposed changes to the New York energy plan.  State leaders claim that the Scoping Plan is sufficient, but I disagree.  The Scoping Plan lists various control strategies that it claims meets the Climate Act requirements but no where does it document the expected costs, emission reductions, and assumption for the components of the control strategies in sufficient detail to verify the total costs necessary to determine expected costs to New Yorkers.  It does not even include projected ratepayer costs or an affordability standard.  Even though Climate Action Council members claimed that the Scoping Plan adequately addressed reliability, and some went so far as to say that no new technology was needed, the reality is that the New York Independent System Operator (NYISO) has raised many unaddressed reliability issues.  Furthermore, the NYISO, the Integration Analysis and the New York State Public Service Commission (PSC) agree to the need to “identify innovative technologies to ensure reliability of a zero-emissions electric grid”.  The most recent cumulative environmental impact assessment does not include between 20% and 40% more onshore wind, about twice as much offshore wind, and over three times as much distributed and utility-scale solar projected in the Scoping Plan.  In addition, no previous cumulative environmental impact analysis considered the impacts of massive energy storage facilities or the “zero-carbon firm resource” that the Integrated Analysis presumes will be provided by hydrogen resources. 

The NYISO is responsible for keeping the lights on in New York.  They have a very sophisticated resource adequacy modeling process and are required to provide regular reliability assessments.  There are staff dedicated to addressing those requirements and I have a lot of respect for their skill and body of knowledge.  They have been analyzing the electric system for many years and have a great understanding of the current electric system.  However, I have enough modeling experience and background to still be skeptical that the existing resource adequacy process will be able to address all the inter-related components and unintended consequences of the transition to an electric system that relies on weather-dependent and inverter-based resources.  As a result, I worry that some combination of circumstances will occur that causes unexpected reactions that will result in blackouts despite their best efforts.  We know that an electric grid that relies on nuclear and hydro “zero-emissions” resources will work.  What is needed is a demonstration project that can be used to test whether wind, solar, and energy storage resources can work and refine the resource adequacy modeling to address those resources.

Reid’s Renewable Demonstration

Ed Reid agrees with this need and writes “I believe it is essential that at least one large scale demonstration of a completely freestanding renewable plus storage powered grid be conducted under carefully controlled conditions.”  Even if such a project was implemented, he points out an important caveat: the long duration storage or alternative “zero-carbon firm resource” cannot be tested because neither resource is currently commercially available.

He proposes a demonstration for a selected zone within the grid. His proposal would only consider sources within the zone isolated from external sources of power and incorporate storage initially using “pseudo-storage” by tracking exports from the isolated zone and what is needed from outside the isolated zone. He suggests an iterative development process whereby:

The demonstration managers would be able to import electricity from external sources if required to avoid demonstration grid failure but would then be required to install additional generation capacity or contract for more pseudo-storage to avoid a repeat of the imminent grid failure condition. The demonstration managers should not be permitted to deliver electricity outside the demonstration zone, other than to pseudo-storage.

His first demonstration project article concludes:

It might be ideal to site the demonstration zone in the metropolitan Washington, DC area to assist agencies of the federal government and federal legislators to understand the various issues with a renewable plus storage grid in real time and work to resolve them in a timely fashion.

In the next article Reid argues that transparency should be a key component of the demonstration.  He proposes that the first step be complete documentation describing the generation and energy storage resources within the demonstration zone.  He goes on to explain:

The next step in the process would be the initial design of the renewable plus storage system to replace the existing conventional, dispatchable fossil generation resources. This would include designation of the types and capacities of the wind and solar generators, plus designation of the capacities and delivery rates of short, intermediate and long duration storage to be installed or simulated by pseudo-storage.

After a period of testing, the wind, solar, and energy storage resources “would be used to meet the contemporaneous demand of the grid and to charge both actual and pseudo-storage”.  The reporting system would track all the generation and energy usage.  He suggests that in order to address the affordability component that “all renewable generation and storage resources installed in the demonstration zone be capitalized at their full cost, with no federal or state incentives of any kind”.  

Market costs also must be tracked. 

He concludes the second article:

These approaches to the demonstration should assure that the demonstration zone facilities would be designed to be a reliable and flexible renewable electric system and that the electricity costs in the demonstration zone would representative of a renewable plus storage grid on a national scale.      

The third article suggests a reporting format for the renewable plus storage demonstration proposed.  If you are interested in those details, I refer you to the article.

The fourth article raises an important point about the ultimate viability of renewable energy plus storage electric system.  Climate Act accounting requirements mandate that fossil-fired generating resources include upstream emissions.  Reid points out that a true “zero-emissions” electric system should also eliminate emissions in the supply chain.  He argues:

The supply chain begins with the use of electric mining equipment to mine the raw materials required to fabricate the wind, solar and storage components of the renewable plus storage grid in US mines and the use of electric transportation to move these raw materials to the manufacturing facilities at which the components of the system would be fabricated. The fabrication of the components would occur in US plants using electric processing equipment.

The steel and cement required for installation of the system components would also be produced in US plants. In the case of the calcining of limestone to produce cement, carbon capture and storage (CCS) systems would be required to capture the CO2 released from the limestone.

Preparation of the installation sites for the wind and solar generators and the storage systems would be performed by US manufactured electric earthmoving equipment. The system components would be transported to the installation sites by US manufactured electric trucks or electrified trains and erected using US manufactured electric cranes.

Considering supply chain emissions introduces much more complexity.  He argues that all the claims about clean energy job creation ignore the current reality that the “current supply chains for wind turbines, solar collectors and storage batteries, all of which currently require mining and processing of minerals in Asia and Africa and frequently rely on foreign manufacture, particularly of solar collectors and wind turbines” has many jobs outside of the United States.  My concern is that it is not only the jobs but also there are lower environmental and safety considerations.  Finally, there is a moral aspect because the “mining and processing jobs in Asia and Africa and the manufacturing jobs in Asia reputedly rely on child, forced and prison labor”.

Conclusion

I think there is a clear need for a feasibility demonstration project.  Attempting to convert the current electric system that has evolved over decades to a system relying on significantly different resources by 2040 is such an enormous challenge that I think it is inappropriate to rely on modeling to check feasibility.  Reid describes a feasibility demonstration on a utility-scale.  Menton has argued for a smaller project:

Before embarking on “net zero” for a billion people, how about trying it out in a place with, say, 10,000, or 50,000, or 100,000 people.  See if it can actually work, and how much it will cost.  Then, if it works at reasonable cost, start expanding it.

While there are some large jurisdictions that have achieved very low-carbon grids, they did not do so by relying on underperforming intermittent wind and solar generation.  Instead, they achieved low emissions by using high-capacity-factor firm resources—namely hydropower and nuclear. To my knowledge no jurisdiction has demonstrated the ability to achieve “zero-emissions” using wind, solar, and energy storage.  Ideally a large-scale test such as the one proposed by Reid should be done before New York goes any further.  However, I think that even the small-scale demonstration proposed by Menton would show that the Climate Act “zero-emissions” electric system is infeasible on reliability and affordability grounds.

I believe that the fatal flaw of all “green” technologies is that they do not work all the time.  “On average”, “in general”, or for “many people”, it may be possible to argue that electric vehicles, heat pumps, or renewable generation technologies are feasible.  However, when the criteria are raised to include 24-7, 365 reliability and overall affordability with all the hidden costs included, then these technologies fail to deliver.  The only way I will be convinced otherwise is if there is a demonstration project that proves otherwise.

A coalition of community-based environmental groups and a few individuals, including me, recently filed comments with the New York Public Service Commission (PSC).  Our comments called for reconsideration of the PSC’s plan for reducing power plant emissions principally with large-scale renewables to meet the mandates in the New York Climate Leadership & Community Protection Act (Climate Act).  This post describes the submitted comments.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 350 articles about New York’s net-zero transition.  I have devoted a lot of time to the Climate Act because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good by increasing costs unacceptably, threatening electric system reliability, and causing significant unintended environmental impacts.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.”  In brief, that plan is to electrify everything possible using zero-emissions electricity. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan.  After a year-long review, the Scoping Plan recommendations were finalized at the end of 2022.  In 2023 the Scoping Plan recommendations are supposed to be implemented through regulation, PSC orders, and legislation.  The comments described follow a recent decision by the PSC to deny petitions seeking to amend contracts with renewable energy projects. 

Coalition Calls for Rethinking of Energy Plan

All Otsego recently described the comments submitted by an ad hoc coalition.  The submittal was filed to the Proceeding on Motion of the Commission to Implement a Large-Scale Renewable Program and a Clean Energy Standard, Case Number:15-E-0302.  The following listed parties submitted the comments: Glen Families Allied for the Responsible Management of Land (GlenFARMLand), Protect Columbia, Farmersville United, Freedom United, Litchfield United, Flyway Defense, No Big Wind, Centerville’s Concerned Citizens, Concerned Citizens of Rushford, Save Sauquoit Valley Views, StopCricketValley, Protect Orange County, Cattaraugus County Legislator Ginger D. Schroder, Esq, Gary Abraham, Esq., Roger Caiazza, David Sunderwith, and Greg Woodrich.

The All Otsego article provides a good summary of the comments:

TOWN OF COLUMBIA—A coalition of community-based environmental groups around the state filed comments with the New York Public Service Commission last week, calling for a reconsideration of the PSC’s plan for reducing power plant emissions principally with large-scale renewables.

According to the press release, the coalition is comprised of environmentally-minded people participating in the review of large-scale renewable energy projects around the state. The coalition points to physical constraints on the ability of wind and solar to contribute to carbon emission reductions and energy analysts who project that the electric grid will become less reliable as more intermittent renewables are connected. Backup power plants to ensure grid reliability and extensive infrastructure changes are needed to utilize wind and solar energy, coalition members contend, saying these are not warranted given the environmental damage renewables cause, along with potential health and safety hazards associated with the projects, including their battery storage systems.

“Large-scale renewables are being sited on prime agricultural land and are clearing thousands of acres of forests,” according to Ginger Schroder, a Cattaraugus County legislator and member of the coalition.

Schroder pointed to the 100-square-mile project area needed for the proposed Alle-Catt wind farm in western New York.

“Renewables require massive amounts of land, not only for sprawling solar and wind projects, but also for all of the additional transmission, storage, and backup generation needed. These are destroying communities,” Schroder said.

Steve Helmin with GlenFARMLand in the Town of Glen said, “Small rural communities across New York are being targeted as a result of poor planning and over-zealous expectations. The commission needs to step back and review what can work to meet our climate goals.”

Coalition member Nathan Seamon, with Protect Columbia in the Town of Columbia, added, “Since the passage of the Climate Leadership and Community Protection Act, New York State has moved from a 60 percent carbon-free grid in 2019 to one that is only 50 percent carbon-free today. Meanwhile, energy costs—for both natural gas and electricity—continue to rise.

“Upstate communities have been robbed of robust environmental review and fair tax revenue from underperforming industrial solar and wind projects which they are forced to host. How this makes any sense should be baffling to anyone who has paid attention to this over the past several years,” Seamon said.

The group is calling on the PSC to support a jobs and cost analysis of an energy transition that uses a diverse set of technologies, including nuclear and expanded hydropower, compared to one that relies on intermittent, unreliable, and environmentally unsound wind and solar.

“The Public Service Commission needs to put the words ‘leadership’ and ‘community’ back into the Climate Leadership and Community Protection Act,” coalition members insist. “Real climate leadership requires solutions that work in the real world and that do not destroy communities in the process.”

The 22-page document filed with the PSC on November 2 concludes: “…by respecting communities and embracing a balanced energy plan that supports the expansion of all carbon-free resources—including those capable of generating reliable electricity within an energy-dense footprint—the state can meet its climate goals, protect the environment and natural beauty of New York, and meet the needs of a vibrant economy. We urge the Commission to exercise its authority to help New York chart a course that accomplishes the latter.”

Can the State Respond?

Advocates for the Climate Act and the renewable energy developers argue that the energy transition must proceed no matter what because the Climate Act law says so.  However the recent PSC Order Denying Petitions Seeking to Amend Contracts with Renewable Energy Projects suggested that there are conditions that must be considered.  On page 39 of this order, it states:

We recognize that PSL §66-p(2) adds the pursuit of the 70 by 2030 and Zero Emissions by 2040 Targets to the Commission’s obligations but do not read the provisions of the more recent statute as superseding the Commission’s longstanding mandate to ensure that rates are just and reasonable. There is no indication in the statutory language or history that the legislature intended such a result, which could have the undesirable effect of driving ratepayer costs so high as to put the entire program at risk. To the contrary, the legislature provided the Commission with significant discretion under PSL §66-p(2) regarding how to establish the program to implement the 70 by 2030 and Zero Emissions by 2040 Targets by authorizing the Commission to “address impacts of the program on safe and adequate electric service in the state under reasonably foreseeable conditions,” as well as to “modify the obligations of jurisdictional load serving entities and/or the targets” based on consideration of such factors.

I believe that another provision of New York Public Service Law  § 66-p. “Establishment of a renewable energy program” includes safety valve conditions.  Section §66-p (4) states “The commission may temporarily suspend or modify the obligations under such program provided that the commission, after conducting a hearing as provided in section twenty of this chapter, makes a finding that the program impedes the provision of safe and adequate electric service; the program is likely to impair existing obligations and agreements; and/or that there is a significant increase in arrears or service disconnections that the commission determines is related to the program”. 

The PSC has a longstanding mandate to provide safe and adequate electric service.  The comments submitted describe many of the problems with the plan to use intermittent wind and solar resources that I believe will inevitably lead to unsafe and inadequate electric service.  I think that there are mechanisms that can be used to respond to the comments.  However, it is an open question whether the Hochul Administration will risk the wrath of the environmentalist constituency in the progressive left wing of her party and admit that implementation of the Climate Act may not be affordable and has unacceptable risks to reliability.

Discussion

I was asked to join the coalition late in the game so did not have a chance to provide comments to modify anything in the text.  Had I had a voice in the development of the text I would have pointed out that the claim that the New York State Department of Environmental Conservation (DEC) has not provided a Generic Environmental Impact Statement solar and wind development is incorrect.  They have done that evaluation, but it was completed in 2019 and does not consider the much larger number of wind turbines and solar panels that the Scoping Plan projects are necessary for the net-zero transition.  The cumulative ecological impact of the current plan due to its extremely low energy density and permanence of extensive infrastructure still needs to be evaluated. 

My only other quibble is the implication that fossil fuels should not be considered in the future.  Reliance on weather dependent wind and solar resources must address extreme variability in resource availability.  If that constraint is handled incorrectly, then electric energy will run out at the worst possible time.  The challenge of developing a dispatchable emissions-free resource to handle this possibility is immense.  The worst part, in my opinion, is that any long-duration storage option must push the physics envelope so this technology may be impossible.  Even if that challenge is overcome, the comments point out that the projected resources are on the order of the existing fossil fuel system resources and the expectation is that they will be used infrequently.  For example, if the future system is designed to provide support for a once in twenty-year event, then some portion of this resource will only be used every twenty years.  I cannot see any way to overcome the economics needed to pay the huge costs for this entirely new and untested resource such that it would be viable.  In order to address the problem, I think that retaining fossil fired resources for this rare but impactful event makes sense.  Even if the State came to its senses and developed nuclear resources as proposed in the comments, some share of reliable fossil resources probably makes economic sense.  The incremental global warming impact of those rarely fossil-fired resources would be insignificant.

Conclusion

The comments urge the PSC to “exercise its authority to avoid this tragedy by conducting substantive engineering, economic, and logistical analyses that should have occurred long before now.”  Obvious problems in other jurisdictions should be addressed now rather than wished away.  New York should also learn from places that successfully decarbonized. Throughout the world, “large economies that have achieved very low-carbon grids did so not by relying on underperforming intermittent generation, but instead by using high-capacity-factor firm resources—namely hydropower and nuclear—which are capable of producing abundant, reliable energy.”

I am fed up with rent-seeking capitalists and naïve academics who claim that wind, water, and solar resources are the only ones needed to provide reliable electric power.  This narrative was used as rationale for the Climate Leadership & Community Protection Act (Climate Act). This post shows by way of example that this is an unrealistic argument.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 350 articles about New York’s net-zero transition.  I have devoted a lot of time to the Climate Act because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good by increasing costs unacceptably, threatening electric system reliability, and causing significant unintended environmental impacts.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Climate Act Background

The Climate Act established a New York “Net Zero” target (85% reduction and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.”  In brief, that plan is to electrify everything possible using zero-emissions electricity. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan.  After a year-long review, the Scoping Plan recommendations were finalized at the end of 2022.  In 2023 the Scoping Plan recommendations are supposed to be implemented through regulation and legislation.  Over nine months into 2023 and reality is starting to set in and cast aspersions on the aspirational plans.

My primary focus over the last several years has been New York’s the Climate Leadership and Community Protection Act (Climate Act).   Robert W. Howarth authored sections of the Climate Act and was a member of the Climate Action Council that is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.” .  He submitted a statement supporting the Scoping Plan that exemplifies the narrative that no new technology is needed: 

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

I addressed Howarth’s claim and others in his statement in a post here late last year. I include this because it exemplifies the idea that wind, sun, and hydro can power New York’s electric grid completely.  In this post I consider the challenge of using wind, solar, and hydro to replace one component of the NY grid – New York City’s existing fossil fired units

According to the New York Independent System Operator (NYISO) Gold Book the New York City (Zone J) fossil generation summer capability in 2022 was 9,026 MW.  This represents the capacity needed to replace New York City’s fossil generation capacity at any hour.  For the purposes of this thought experiment,  I am going to ignore reliability rules related to transmission constraints and in-city generation.  I assume only that New York City needs dedicated availability of 9,026 MW.  There is no chance that an additional 9,026 MW of hydro can be developed in New York and there is no guarantee that the amount of capacity will only be needed during the day which means we cannot use solar.  This example estimates how much wind capacity from somewhere will be needed to provide this dedicated capacity requirement.

New York Wind Variability

In May 2022 I published Climate Act and New York State 2021 Wind Resources that evaluated New York State onshore wind availability.  I used a New York Independent System Operator (NYISO) resource that provides 2021 wind production and 2021 wind curtailment.  The data sets list the hourly total wind production and curtailments for the entire New York Control Area (NYCA).  I have summarized the data in the following table.  Curtailments are those hours when the system load is small enough that wind production is greater than what is needed so the wind power is curtailed, i.e., not used. 

Table 1: NYISO 2021 Hourly Wind Production at the Aggregated NYCA-Wide Level

These data are representative of every wind energy resource data set I have ever seen.  See, for example, analyses for Belgium by Michel at the Trust Yet Verify website or for Australia by Anton Lang.  The crux of the problem is that low-energy density wind resources are highly correlated across wide areas.  Across New York, and other regions, the wind speeds drop across the entire area frequently.  Frequently, as in every time a high-pressure system crosses over the area.  As a result, the mean annual average availability for all the NYCA onshore wind turbines is only 22% and the median is 16%. 

Moreover, I believe it is unlikely that additional sources in a region will change the availability much.  I do not expect any significant change to the low-end onshore wind numbers when all the land-based wind resources proposed to meet the Climate Act net-zero transition are developed.  The overall distribution of expected offshore wind will be similar although the numbers will show slightly higher availability. 

Implications

Wind variability has implications on the use of wind energy to replace firm dispatchable generation.  I use these data as a starting point for this analysis to explain why the fact that the wind is always blowing somewhere does not mean it can be used cost-effectively to replace dispatchable fossil-fired generating in an electric grid that relies on wind and solar as claimed by Dr. Howarth and others.

To estimate the wind resources needed to replace New York City’s 9,026 MW of existing fossil-fired generation I will use the distribution of New York land-based wind with the following assumptions.  In the absence of offshore observed wind energy historical data, I assumed that the wind production would be increased by a five-percentile category from the onshore wind distributions.  In other words, when the onshore wind is at the 75% percentile capacity availability level, I assumed that offshore wind resources are at the 80% capacity level. 

Table 2 estimates the amount of land-based or offshore wind capacity from the New York Control Area necessary to replace  New York City’s 9,026 MW fossil capacity.  Because the observed wind production capability at the 99^th percentile is 78%, 11,563 MW of wind turbine capacity are needed (9,026 divided by 78%) to assure replacement of the existing fossil-fired units in New York City.  For reliability support the wind resources must be able to cover all the levels of wind resource availability.  Half of the time (50^th percentile) 55,068 MW of capacity would be needed.  In order to ensure reliability, wind capacity must be available at all hours but the wind capacities at the lower end of the distribution are unrealistic so a system dependent upon only wind energy is going to have to go wherever the wind is blowing.  The proponents of the wind is always blowing somewhere respond that all New York must do is to import electricity from outside the NYCA to address this but have not used this kind of distribution to determine how much, from how far, would be necessary

Table 2: NYCA Wind Capacity Support Requirements to Replace NYC Fossil – 9,026 MW

To determine how much wind capacity is needed outside of New York, I first determined the

potential wind energy availability within the New York Control Area (NYCA).  For capacity potential I used the larger capacity projections for land-base and offshore wind from two different modeling analyses.  The offshore wind capacity (MW) in the Integration Analysis Scenario 2: Strategic Use of Low-Carbon Fuels was 12,675 MW.  The onshore wind capacity in the NYISO  2021-2040 System & Resource Outlookwas 19,087 MW. Table 3 uses those resource projections to provide estimates of the available energy in the NYCA at each resource potential level.  For each percentile I calculated the available capacity at each percentile for on-shore and offshore wind, summed them, and listed the deficit if the sum was less than 9,026 MW.  For this thought experiment, the projected wind resources can replace the fossil resources up to the 70^th percentile if all the wind power can be dedicated just to New York City at the hour when 9,026 MW of wind capacity is needed in the City.  This means that somewhere between 65% and 70% of the time, wind resources outside the NYCA must provide additional power to replace New York City’s existing fossil resources.

Table 3: NYCA Wind Energy Available from Climate Act Wind Resource Projections

Table 4 provides an estimate of the wind generated capacity available to cover the deficit margin in Table 3 outside the control area in an area similar in size and characteristics to the NYCA 500 miles away from New York City.  For this thought experiment I assumed that the wind capacity at any hour in this region would be at a production percentile 25% higher than the corresponding NYCA percentile.  I believe that there is higher level of spatial correlation than those who believe that the wind is always blowing somewhere acknowledge.  In this example, when NYCA wind levels are at the 65^th percentile I presume that 500 miles away the wind resource will be at the 90^th percentile. Because I believe that wind in all regions of a similar size to New York will exhibit the same wind distribution pattern, a key takeaway is that wind resources 500 miles away are insufficient to always provide support when power outside the NYCA is needed.  The 500-mile resources only cover the NYCA deficit down to 55^th NYCA percentile corresponding to the 500-mile 80^th percentile.  We must go out at least another 500 miles for reliable power.

Table 4: Wind Resource Availability from 10,000 MW of Turbines 500 Miles from NYC

Table 5 provides an estimate of the additional wind generated capacity needed outside the control area in an area 1000 miles away from New York City. I assumed that the wind capacity at any hour would be at a production percentile 50% higher than the corresponding NYCA percentile.  In this example, when NYCA wind levels are at the 50^th percentile I presume that 1000 miles away the wind resource will be at the maximum level of 86%.   Importantly, this assumption is the same as assuming there is no correlation between NYCA wind and 1000- mile wind.  I do assume that the correlation has the same directionality.  In other words, winds in both regions go down at the same time.  Of course, it is more complicated because “somewhere else” winds could go up when NYCA winds go down.  In order to address that issue an analysis for the entire onshore and offshore wind resource availability is needed.

The 1000-mile resource availabilities cover the NYCA deficit down to 25^th NYCA percentile and the 1000-mile 75^th percentile so we must go out another 500 miles to assure replacement of the existing fossil generation. 

Table 5: Wind Resource Availability from 10,000 MW of Turbines 1000 Miles from NYC

Table 6 provides an estimate of the additional wind generated capacity needed within NYCA and the 500- and 1000-mile resource areas in an area 1500 miles away from New York City. I assumed that the wind capacity at any hour would be at a production percentile 75% higher than the corresponding NYCA percentile.  In this example, when NYCA wind levels are at the 5^th percentile I presume that 1000 miles away the wind resource will be at the 80^th percentile.   Even the addition of these resources is insufficient to cover all the power needed by New York City existing fossil resources.  However, it is so close that adding another 1,049 MW of capacity in any of the regions would assure that New York City’s existing fossil generation could be replaced by resources where” the wind is always blowing”.

Table 6: Wind Resource Availability 1500 Miles from NYC

Discussion

The forgoing analysis confirms that the wind is indeed always blowing somewhere and that wind energy resources could replace the existing fossil generation in New York City as suggested by Howarth and others  However, just because it is possible does not mean it is feasible.  The fatal flaw is that New York City requires dedicated resources to replace existing generation when it is needed to keep the lights on.  This is particularly important because the high pressure systems that characterize low wind availability over large areas also are associated with hottest and coldest periods of the year when the electric load peaks and the need for reliable power is the greatest.

Existing fossil generation capacity in New York City totals 9,026 MW.  New York’s Climate Act projected onshore and offshore wind planned capacity is 31,762 MW.  Relying on wind only requires another 30,000 MW located “somewhere else”.  The fatal flaw to the wind blowing “somewhere else” argument for New York City is that those resources must be dedicated to New York City.  The idea that anyone could afford to build 10,000 MW and 500 mile transmission lines for use as backup that will only be used 65% of the time, another 10,000 MW and 1,000 mile transmission lines for backup 50% of the time, and another 10,000 MW with 1,00 mile transmission lines for backup 25% of the time is disconnected from reality. 

Of course, there are suggestions that the surplus power could be stored in batteries or used to make “green hydrogen” to address the low wind availability problem.  However, Howarth claimed that New York “could rapidly move away from fossil fuels and instead be fueled completely by the power of the wind, the sun, and hydro”  and that “it could be done completely with technologies available at that time (a decade ago) and that that it could be cost effective”.   This simple analysis suggests otherwise.

Conclusion

I agree with Francis Menton who has argued that we need a demonstration project to prove all the wind, solar, and energy storage components necessary for a zero-emissions electric grid that does not rely on nuclear power can work.  In addition, I believe that a comprehensive analysis of wind and solar resource availability across the continent that addresses the correlation and energy density deficiencies of wind and solar is also needed.  Based on my work, I think that this sort of analysis would show the need for far more resources than anyone is contemplating at this time.  If New York does not address these concerns correctly people will literally freeze to death in the dark.

I have been writing about the Climate Leadership & Community Protection Act (Climate Act) for over four years and a constant theme in my work has been concerns about affordability and reliability.  For all the analyses and pontification by the State of New York about the net-zero transition, there still is no documentation describing the costs of the control strategies proposed by the Scoping Plan and estimates of how New Yorkers will pay for the transition.  The focus of this post is on reliability.  I believe that the only way we can be sure that the plans proposed to operate an electric grid that relies primarily on wind and solar is to prove it with a demonstration project.  The project should include all the key elements: wind and solar generation, energy storage, a dispatchable emissions-free resource and any other resources needed to provide necessary ancillary services.   This post highlights work by Francis Menton that advocates just such a demonstration project.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 350 articles about New York’s net-zero transition.  I have devoted a lot of time to the Climate Act because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good by increasing costs unacceptably, threatening electric system reliability, and causing significant unintended environmental impacts.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Climate Act Background

The Climate Act established a New York “Net Zero” target (85% reduction and 15% offset of emissions) by 2050.  It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.”  In brief, that plan is to electrify everything possible using zero-emissions electricity. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan.  After a year-long review, the Scoping Plan recommendations were finalized at the end of 2022.  In 2023 the Scoping Plan recommendations are supposed to be implemented through regulation and legislation.  Over nine months into 2023 and reality is starting to set in and cast aspersions on the aspirational plans.

Demonstration Project Proposal

Last February I did a post on Climate Smart Communities and I proposed a challenge to the local governments that pledged to be climate smart.  Go for it, but not just this virtue-signaling public relations gesture to get some money.  I described Francis Menton’s article explaining that a demonstration project of a mainly renewables-based electrical grid is a common sense prerequisite before there are any more plans or pledges.  I said that Climate Smart Communities of New York should prove their bona fides and develop a demonstration project for their community to address the issues he raised:

Could anybody possibly be stupid enough to believe the line that wind and solar generators can provide reliable electricity to consumers that is cheaper than electricity generated by fossil fuels? It takes hardly any thought about the matter to realize that wind and solar don’t work when it is calm and dark, as it often is, and particularly so in the winter, when it is also generally cold. Thus a wind/solar electricity system needs full backup, or alternatively storage — things that add to and multiply costs. Surely, our political leaders and top energy gurus are fully aware of these things, and would not try to mislead the public about the cost of electricity from a predominantly wind/solar system.

……………..

Nobody would be happier than me to see a demonstration project built that showed that wind and solar could provide reliable electricity at low cost. Unfortunately, I know too much about the subject to think that that is likely, or even remotely possible. But at least the rest of us need to demand a demonstration project from the promoters of these fantasies.

A few days ago Menton followed up on his February post with What Passes For A “Demonstration Project” Among Our Government Geniuses.  I recommend readers check out both articles.  I will summarize the key points from the more recent article here.

Menton describes people who don’t support the need for an encompassing fossil-fuel-free renewable grid demonstration project.  Government officials and green energy advocates won’t support this because:

(1) they are not bright enough to understand the subject, or (2) their understanding is impaired because they are too blinded by religious fervor to “save the planet,” or (3) they are intentionally deceiving the public to make money or fame or career advancement for themselves. Or it could be all three!

Instead of a single comprehensive demonstration, net-zero proponents promote projects that only “attempt to demonstrate various portions of the full system that would be needed to provide reliable 24/7/365 electricity from predominantly wind and solar generation.”  I believe a common problem of all the “green” energy solutions is that they do not work all the time and renewable resource availability is correlated over large distances which makes demonstrations of individual components worthless.

Menton agrees and describes the example of the latest news on energy storage. He explain that on October 13, the Department of Energy announced big new grants and subsidies for a series of what they call “hydrogen hubs.” Here is a report from E&E News Energy Wire. Excerpt:

The Department of Energy on Friday announced seven projects that will receive $7 billion to build landmark hydrogen hubs, delivering a major boost to a nascent U.S. industry. The long-awaited move is a key piece of the Biden administration’s climate agenda. On Friday, the White House said it expects the DOE funding to help cut 25 million metric tons of carbon dioxide annually, roughly equivalent to removing 5.5 million gasoline-powered vehicles from the road each year. “With this historic investment, the Biden-Harris administration is laying the foundation for a new, American-led industry that will propel the global clean energy transition,” said Secretary of Energy Jennifer Granholm.

The New York placeholder for dispatchable emissions-free resources is “green” hydrogen.  Menton explains that according to this further piece from Energy Wire on August 21, the Biden Administration has set a goal of having the U.S. produce 10 million metric tons of “green” hydrogen (by electrolysis from water) by 2030. The E&E piece states that the massive funding for “hydrogen hubs” is for “demonstrations.”  He points out that this is not the demonstration project needed to prove viability of the net-zero transition because the demonstrations focus on production, storage, transport and consumption but not the integrated resource necessary.  He notes:

They are clearly leaving out the critical piece of the puzzle, which is the demonstration of how much of this hydrogen, and capacity to make more of it, will be needed, and at what cost, to get the country — or even some small town — through a full year (or two or five) without need for fossil fuel backup. That completely obvious elephant is not part of this multi-billion dollar “demonstration.”

Another dispatchable emissions-free resource for New York’s net-zero transition could be long duration energy storage. Menton notes that the Department of Energy has a “separate big bucks effort called the “Long Duration Storage Shot” that is throwing bucketsful of cash at various research efforts into batteries.”  Unfortunately, he notes:

The battery efforts are even farther removed from any relevant demonstration project. From DOE’s opening webpage describing that initiative (with a date of September 2021):

The U.S. Department of Energy’s (DOE) Energy Earthshots Initiative aims to accelerate breakthroughs of more abundant, affordable, and reliable clean energy solutions within the decade. Achieving the Energy Earthshots will help America tackle the toughest remaining barriers to addressing the climate crisis, and more quickly reach the Biden-Harris Administration’s goal of net-zero carbon emissions by 2050 while creating good-paying union jobs and growing the clean energy economy. . . . The Long Duration Storage Shot establishes a target to reduce the cost of grid-scale energy storage by 90% for systems that deliver 10+ hours of duration within the decade.

On September 22, 2023 the Administration announced some $325 million for “15 projects across 17 states and one tribal nation” to “accelerate the development” of these “long duration” battery technologies. He writes:

So are these battery technologies, or any one of them, even a potential solution to the problem of making a mostly wind/solar electricity grid work without fossil fuel backup? Again, you will not find any mention at those links, or at other government or advocate sites discussing the issue of how many of these batteries would be necessary and at what cost to actually fully back up a predominantly wind/solar grid and make it into a functional 24/7/365 electricity system.

I cannot over-emphasize how challenging these two technologies are.  I fear that some aspects of some of these demonstrations will be deemed a success which will be used to argue that the concerns of  organizations responsible for keeping the lights on and skeptical technical experts who have no vested interests in the green energy scam are unwarranted.  Theory, small prototype tests, and these demonstration projects all will not prove the feasibility of a fully-functioning wind/solar/hydrogen storage 24/7/365 electricity grid.

Another aspect of this is that until we have a proof-of-concept demonstration that incorporates all the components needed to get to a reliable system, we cannot know how much it will cost.  Menton argues that a rough cost estimate  “would come to a multiple (not necessarily a huge one, but nonetheless a multiple) of what our current electricity system costs.”  He does not bother to make an estimate writing:

The reason I’m not going to do it is that there as an obvious fact that tells you all you need to know, which is that no one in the country is spending their own private money to build out this system. They are all waiting for the government handouts. If this system could be built profitably at a cost competitive with what we have, there would be investors falling all over themselves to build it. When Thomas Edison built his first electricity plant, he did not go to the government for handouts to build it.  Because this is all a fantasy kept alive by government handouts, as soon as the handouts go away or even slow down, the whole thing will dry up and fade away.

Conclusion

We do not know if the net-zero transition is technically possible.  All we have is assurances from vested interests and slick marketing claims from the state.  Richard Feynman said “For a successful technology, reality must take precedence over public relations, for Nature cannot be fooled.”  Before New York goes any further, a comprehensive demonstration project for a smaller jurisdiction is the pragmatic approach.