Category: Climate Act Feasibility

On June 18, 2023 the Syracuse Post Standard published a commentary, Five Reasons New Yorkers Should Embrace a Solar Energy Future by Richard Perez, Ph.D.  According to the introduction “This essay aims to clarify common misunderstandings about solar energy and demonstrate its potential to provide an abundant, reliable, affordable and environmentally friendly energy future for New York”.  This post explains why I disagree with just about everything in the essay.

The only reason that New York is pushing solar as part of the energy future of New York is the Climate Leadership & Community Protection Act (Climate Act).  I have been following the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 300 articles about New York’s net-zero transition.  I have devoted a lot of time to the Climate Act because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Climate Act Background

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

According to the New York Independent System Operator (NYISO) “Gold Book” load and capacity report, in 2022 there were a total of 4,444 MW of solar nameplate capacity (154 MW of utility-scale solar and 4,290 MW of behind-the-meter) on-line in the state.   However, implementation of the Climate Act transition to net-zero will significantly increase that amount by 2030.  By 2030 the New York State Energy Research & Development Authority (NYSERDA) and consultant Energy + Environmental Economics (E3) Integration Analysis that provides quantitative estimates of resources for the Scoping Plan projects a total of 18,852 MW and the NYISO 2021-2040 System & Resource Outlook projects 14,731 MW.

Commentary

Against that backdrop I address the five reasons Dr. Perez uses to promote solar energy.

Abundance: The sun is a vast energy resource that powers our planet’s weather and sustains life. In just a few hours, Earth receives more solar energy than the total annual energy consumption of all economies, combined. In a week, it receives more solar energy than the combined reserves of coal, oil, natural gas and uranium.

So what?  According to the US Geological Service water covers the about 71% of the earth’s surface and yet there are deserts with very little water available for use.  The critical requirement is the need for energy when and where needed and New York solar is not situated well in that regard.  The Scoping Plan strategy to decarbonize relies on electrification of homes and transportation so future expected peak loads will occur in the winter.  In New York the winter solar resource is poor because the days are short, the irradiance is low because the sun is low in the sky, and clouds and snow-covered panels contribute to low expectations for solar resource availability.   The New York Independent System Operator does not plan on any solar contribution to resources available for the peak winter hourly load.

Growth of solar technology: Solar technology, known as photovoltaics (PV), has experienced significant expansion. Since the 1980s, PV deployment has consistently grown at a remarkable annual rate of 30%, overcoming economic and political fluctuations. This growth is due to improvements in efficiency, versatility and cost-effectiveness, enabling solar to enter new markets successfully. Experts predict this trend will continue, and, if the stable 30% annual rate persists, by the early 2040s, there may be enough solar installations worldwide to entirely power global economies.

If it is so good, then why does deployment rely on direct subsidies?  Solar proponents don’t acknowledge the incompatibility of solar resources with electric system reliability.  In order to match generation with load requirements grid operators must dispatch generating resources to match the load.  Solar PV facilities are not dispatchable so their deployment complicates rather than enhances grid operations.  Finally, there will always be limits on just how much power can be obtained from any solar panel.  Therefore, I suspect that solar will always rely on direct subsidies to make it competitive.

Affordability: Reports from leading financial advisers such as the Lazard Bank show that utility-scale solar electricity has become the least expensive form of electricity generation. Solar power is now considerably cheaper than new coal, natural gas, or nuclear energy. Experts anticipate solar electricity becoming even cheaper in the future, with a projected 50% cost decrease within the next 15 years. Moreover, solar plants can be built and operational within months, making them economically advantageous compared to the lengthy construction time for nuclear plants.

The claim that “utility-scale solar electricity has become the least expensive form of electricity generation” refers only to power capacity (MW).  Even if solar capacity is half the cost of fossil capacity the cost for delivered energy is much more.  We pay for the kWh electric energy we use each month and we expect it to be available 24-7 throughout the year.  In order to provide usable energy, other things must be considered that destroy the myth that utility-scale solar is cheaper than other types of power plants.  On average a well-designed solar facility can provide (round numbers) 20% of its potential energy possible in New York.  A natural gas fired power plant can operate to produce at least 80% of its potential energy over a year.  In order to produce the same amount of energy, that means that you need four times as much solar capacity.  Even if the solar capacity cost is half the cost for the capacity the energy cost is double simply due to this capacity factor difference. 

But wait, there is more.  In order to make the energy available when needed storage must be added to the cost of the solar capacity.  Also consider that the life expectancy of solar panels is half of the observed life expectancy of fossil-fired power plants.  There are unintended financial consequences that affect the viability of other generators that are needed for reliability that add to ratepayer costs. Because the solar resource is diffuse, it is necessary to support the transmission system to get the solar power to New York City.  There are inherent characteristics of conventional generation that contribute to the stability of the transmission system that are not provided by solar or wind generation.  Someone, somewhere must deploy a replacement resource to provide those ancillary transmission services and that cost should be included the cost comparison.  Finally, the Integration Analysis, NYISO, New York State Reliability Council, and the Public Service Commission all agree that another resource that can be dispatched and is emissions-free (DEFR) is needed when the electric grid becomes dependent upon solar and wind resources.  The state’s irrational fear of nuclear generation precludes the only proven resource that meets the necessary criteria so an entirely new resource must be developed, tested, and deployed.  The Integration Analysis and NYISO 2021-2040 System & Resource Outlook both project that the DEFR resource will be comparable in size to existing fossil resources but will operate no more than 9% of the time.  I have yet to see an expected cost for this resource but have no doubts that it will be extraordinarily expensive.  Summing all the costs necessary to make solar power usable for electric energy reliable delivery and there is no doubt that solar is much more expensive than conventional generation.

Reliability: Solar energy’s intermittency has been a concern, but solutions are emerging to ensure a continuous power supply available day and night year round without fail. These solutions include energy storage, optimized integration of solar and wind energy, and maintaining a small degree of flexibility with conventional power generation. The most efficient solution, however, involves overbuilding solar installations. These firm power solutions are expected to reduce the cost of reliable solar and wind electricity to levels competitive with current energy markets. The International Energy Agency predicts that most economies worldwide will achieve 100% renewable electricity generation at a cost of 3-7 cents per kWh.

The discussion of costs above listed all the resources necessary to provide reliable energy from intermittent solar resources.  Renewable energy proponents don’t acknowledge or understand the resource adequacy analyses the NYISO performs to ensure the system meets New York’s stringent reliability standards.  The NYISO has a process that has been developed and refined over decades that determines just how much extra power capacity is necessary to cover the unexpected loss of operating capacity at any one time.  A fundamental presumption based on observations in the NYISO analyses is that conventional generating resources operate independently.  The problem wih a generating system dependent upon wind and solar resources is that there is a very high correlation between wind and solar output across the state.  At night every solar resource provides zero energy and whenever there is a storm large portions of the state will be covered by clouds.  There are similar issues for wind resources that can last for days.   NYISO and the New York State Reliability Council are just coming to grips with this correlation problem for wind and solar resources and how future resource adequacy analyses will have to be modified to refine the reliability standards. Finally, note that this problem is exacerbated by the fact that the hottest and coldest periods in New York associated with the highest electrical loads correlate very well with high pressure systems with light winds.  In the summer, this improves solar resource availability but, in the winter, when the solar resource is low because days are shorter and irradiance lower this problem makes the supply challenge even more difficult.  The key point is this is a huge reliability risk that will have massive health and welfare impacts if not addressed adequately. 

Resource adequacy by the experts responsible for the electric system contrasts starkly by the cavalier reliability explanation in this section.  Solutions are “emerging” is a hollow promise because of physics.  There is a real concern because all the emerging alleged solutions  must overcome the Second Law of Thermodynamics.  Any energy storage system must lose energy as it is stored and then again as it comes out of storage.  This limits the viability of every storage system proposed to meet this challenge.

Overbuilding is touted as the “most efficient solution” but it has consequences.  This solution recognizes that storage is expensive so overbuilding solar installations reduces the periods when it is necessary to rely on storage to meet demand peaks.   This affects the so-called duck curve created when distributed solar resources reduce net demand during the day (the duck’s belly) but sharply increase demnd at sunset (the duck’s neck).  As more solar resources are added the difference is increased and the challenge to balance load and generation is more difficult.

Given all the issues that I described above, the statement: “These firm power solutions are expected to reduce the cost of reliable solar and wind electricity to levels competitive with current energy markets” is mis-information.  Every jurisdiction that has increased the use of solar and wind resources without the use of other uniquely available resource like hydro or geothermal has seen massive increases in costs.

Environmental footprint: Solar energy has a significantly lower environmental impact compared to fossil fuels and nuclear power. While it is not entirely free of environmental concerns, it poses fewer climate, pollution and accident risks. Concerns regarding land area for solar farms are often exaggerated. Studies show that achieving a 100% renewable PV/wind future for New York would require less than 1% of the state’s total area. Furthermore, solar farming can generate revenue for communities, provide support for farmers, and be implemented efficiently. PV farms are considerably more space-efficient (50 to 200 times more) than exiting energy farming industries harvesting corn ethanol.

The comparison of environmental impacts in the Climate Act Scoping Plan and this statement is biased.  The Climate Act mandates that upstream emissions and impacts be considered but does not apply the same condition on wind and solar resources.  The claim that there are lower environmental impacts may be true for New York but that does not mean that there are no impacts.  Instead. they are moved elsewhere, likely where environmental constraints and social justice concerns are not as strict as here.

Solar panels, wind turbines and batteries all require significant processing and mining that are not considered in this assessment of environmental footprint.  Mark Mills explains:

It has long been known that building solar and wind systems requires roughly a tenfold increase in the total tonnage of common materials—concrete, steel, glass, etc.—to deliver the same quantity of energy compared to building a natural gas or other hydrocarbon-fueled power plant. Beyond that, supplying the same quantity of energy as conventional sources with solar and wind equipment, along with other aspects of the energy transition such as using electric vehicles (EVs), entails an enormous increase in the use of specialty minerals and metals like copper, nickel, chromium, zinc, cobalt: in many instances, it’s far more than a tenfold increase. As one World Bank study noted, the “technologies assumed to populate the clean energy shift … are in fact significantly MORE material intensive in their composition than current traditional fossil-fuel-based energy supply systems.”

Another ignored environmental issue is the disposal of the solar panels when they no longer work.  A recent BBC podcast, “The Climate Question,” raises serious issues about the lifespan and end-of-life management of solar panels.  Note that the Hochul Administration has not prepared a cumulative environmental impact assessment for the increased wind and solar development projected in the Integration Analysis so these impacts are not adequately addressed.

I have summarized all my solar development articles here.  Even though “a 100% renewable PV/wind future for New York would require less than 1% of the state’s total area” that does not mean that there will not be significant impacts because the Hochul administration has not developed a solar development implementation plan.  There is no mandate that solar developments meet the Department of Agriculture and Markets  goal for projects “to limit the conversion of agricultural areas within the Project Areas, to no more than 10% of soils classified by the Department’s NYS Agricultural Land Classification mineral soil groups 1-4, generally Prime Farmland soils, which represent the State’s most productive farmland.”   Projects approved to date have converted 21% of the prime farmland within project areas.  Another major failure is that there is no requirement for utility-scale solar projects to use tracking-axis solar panels.  As a result, the estimates of the capacity needed are under-estimates because I have yet to find a solar development that has committed to that type of panel.  Consequently, permitted facilities will have lower capacity factors than assumed in the Integration Analysis so more panels will be needed and more prime farmland lost.

Discussion

According to the article Dr. Perez:

Leads solar energy research at SUNY Albany’s Atmospheric Sciences Research Center. He has served multiple terms on the board of the American Solar Energy Society and as associate editor of Solar Energy Journal. Perez serves on the board of United Solar Energy Supporters, a statewide nonprofit group providing education and information to the public about solar energy.

I highly recommend the post by Russel Schussler Academics and the Grid because it does a good job explaining why academic studies of the energy system need to be considered carefully.  He concludes:

Academic research that promotes improvements to the power greed needs to be evaluated carefully with the understanding that the grid is a complex system full of interactions. Changes to the grid involve numerous hurdles. Language is often imprecise. For instance, when readers see a statement stating “Solar and wind could attain penetration levels of X”. What the statement really means is “Based on the factors I looked at and ignoring a vast number of critical requirements I have not looked at, solar and wind may be able to replace fossil resources at a level of X. But probably not.”    Unfortunately, the statement is often interpreted as “Solar and wind can attain penetration levels of X with no significant concerns.”

I believe that this is relevant to the commentary by Perez.  The abundance of solar energy argument ignores that availability when and where needed is a critical requirement.  Solar energy in New York is limited because of the latitude and weather so there are limits to the value of technological improvements.  The complexity of reliability planning and analysis is dismissed with promises of improvements but there are fundamental problems that must be overcome.  The affordability argument is a perfect example of ignoring a vast number of critical aspects and the experience of all the other jurisdictions that have tried something similar and found massive cost impacts.  The claim of limited environmental impacts is only tenable if the mining and waste disposal impacts are ignored.

Conclusion

Perez concludes “By dispelling these misunderstandings and recognizing the potential of solar energy, New York can embrace an abundant, dependable, affordable, and environmentally friendly energy future.”  The reasons given to address alleged misunderstandings do not stand up to scrutiny. 

The suggestion that a system depending on solar energy will be dependable and affordable would be laughable if it were not so dangerous.  The existing affordability and reliability of the existing electric system has evolved over decades using dispatchable resources with inherent qualities that support the transmission of electric energy.  The net-zero electric system will depend upon resources subject to the vagaries of weather, that do not support grid resilience, and include an unknown resource that must overcome the second law of thermodynamics.  This is a recipe for disaster because if the resource adequacy planning does not correctly estimate the worst-case period of abnormally low wind and solar energy availability then the energy needed to keep the lights on and homes heated will not be available when needed most and people will freeze to death in the dark.

Dennis Higgins passes on his commentaries associated with New York’s Climate Leadership and Community Protection Act (Climate Act).  I asked his permission to present his analysis of the New York State energy legislation associated with the budget.  This commentary was published in the Oneonta Star.

Dennis taught for just a few years at St Lawrence and Scranton University, but spent most of my career at SUNY Oneonta, teaching Mathematics and Computer Science.  He retired early, several years ago, in order to devote more time to home-schooling his four daughters. (Three will be in college next year and the youngest opted to go to the local public school, so his home schooling is ending this June.) Dennis and his wife run a farm with large vegetable gardens.  They keep horses and raise chickens, goats, and beef.  He has been involved in environmental and energy issues for a decade or more. Although he did work extensively with the ‘Big Greens’ in efforts to stop gas infrastructure, his views on what needs to happen, and his  opinions of Big Green advocacy, have served to separate them.

Nuclear reactors are key to sustainable energy

This year’s late state budget has already been soundly criticized by regional legislators (covered in this paper — “Area reps are critical of state budget,” May 3). Most surprising, though, was that Assembly and Senate criticisms overlooked the biggest blunders in the budget’s small print: Albany has dug its heels in on a bizarre slogan-driven energy plan.

Andrew Cuomo’s last budget instituted accelerated siting of industrial solar and wind projects, enabling the state to ignore both local ordinances and thorough environmental review. Gov. Kathy Hochul’s budget continues the assault. To speed the bulldozing of farmland and forest, to silence recalcitrant communities, the budget obviated court action by upstate towns against Albany.

The legislature approved and back-dated an appraisal process that robs rural municipalities of fair tax revenue from the sprawling renewable buildout forced upon them. The governor’s budget includes a “Build Public Renewables” component, instructing the New York Power Authority to join the attack on home rule, private property and the environment. Because NYPA is a government entity, it would pay no taxes at all. Using eminent domain, NYPA can seize your property for the hundreds, perhaps thousands, of miles of transmission lines the state’s energy plan will need.

German renewable assets comprise a third of its energy capacity but they have not enabled it to decarbonize. Germany relies on biomass and fossil-fuels, including coal, for half of its electricity. On paper, 30% of California’s capacity is in intermittent resources, but California continues to burn about as much fossil fuel as ever. California imports 30% of its energy from neighbor states, much of it coal-generated. California customers pay near double the U.S. average per kilowatt-hour. Germany’s energy costs are twice those of its neighbor, France. Germany and California have invested decades and billions of dollars in order to show us how to fail calamitously if we follow a nonsensical plan — pretty simple lessons which Albany can’t seem to digest: renewable buildout fails to lower prices, cut fossil-fuel use or ensure reliability.

New York remains determined to forfeit farmland and forest to sprawling solar arrays and gigantic turbines which, mostly, generate nothing. Last year’s wind capacity factor in the state was 22%, so the proposed 10 gigawatts of onshore wind would, on average, generate just over 2 GW. But it could still gobble up a thousand square miles. New York’s solar capacity factor is not much better than Alaska’s. The 60 GW or more of solar the plan projects will generate, on average, about 7 GW, but will require 500 square miles. The state’s energy research and development authority, NYSERDA, suggests that by 2050, New York’s grid might need just 6.8 GW of 8-hour storage. In 27 years, that won’t power New York City for three hours.

Unfortunately, a reliable affordable grid can’t be designed using press releases and Big Green talking points as blueprints. No one applauding the plan seems to have taken the semester of physics or engineering needed to learn that there is a difference between power and energy.

Power is the maximal amount a resource can generate in optimal conditions, instantaneously. But the energy needed to meet demand any time anywhere depends on how many hours those solar panels, wind turbines, hydro or nuclear or gas power plants can keep generating at or near capacity.

Here is a quick lesson: A 2,100 MW nuclear plant such as Indian Point could generate 47,000 megawatt-hours of energy in a day; fully a quarter of what was needed to keep lights, elevators, heat, AC and everything else in New York City running smoothly. Although a 2,100 MW solar farm might reach full capacity for a minute or two at noon during mid-summer, it will generate, on average, only 6,000 MWh daily, possibly none of that when you need it. The nuclear power plant needed 240 acres and supported a thousand skilled workers. The solar farm might need sixty times as much land — about 15,000 acres — and have five permanent employees.

Imagine covering an area the size of Albany or Binghamton in Chinese-made glass panels every single year until 2050, and then discovering that we are still burning as much gas as ever. Backup power for intermittent resources must ramp up faster than combined-cycle gas plants. Lots of simple cycle plants — only half as efficient as combined-cycle — are needed. In fact, the state’s plan requires as much backup capacity as all our current fossil-fuel plants can deliver. The plan triples the state’s required energy imports and exports, so the grid looks reliable on scrap paper.

Albany hopes there will be eager buyers for any renewable energy we can’t use on summer days, and willing sellers for the energy we need all the rest of the time. The grid operator, NYISO, is already projecting an insufficient capacity margin for the metro region. Think for a minute about the expensive, dangerous experiment Albany is undertaking. What happened in Texas when energy failed? People died. How would New York City fare for a week in January with no electricity?

Albany is like an ostrich, head in the sand, refusing to acknowledge that there is a better way. A nuclear power plant can run day and night, generating baseload energy at 90% of capacity. While solar and wind need replacement in two decades, nuclear plants can be licensed for 80 years. According to the UN Economic Commission, “there is no science-based evidence that nuclear energy does more harm to human health or to the environment than other electricity production technologies.” Indeed, nuclear has the lowest life cycle environmental impact of any generating source. Further, the UNECE report determined that the “maximum consequences of a single [severe accident] are … still comparable with other electricity production technologies.”

Sweden and France demonstrated in the late 1970s and ’80s that decarbonizing with nuclear power could be done in about 10 years. For less money, much less land, generating hundreds of times more permanent jobs than the state’s plan, we could have reliable affordable carbon-free energy, by replacing our fossil-fuel fleet with next-generation nuclear reactors.

Comment

I think Higgins did a great job summarizing the nonsense in the “bizarre slogan-driven energy plan”.  The distinction between power and energy that he defines is a critical consideration.  Building power capacity is easy but providing energy when it is needed most is a challenge that proponents of the proposed Climate Act net-zero transition plan do not acknowledge adequately even if they understand.  Combined with an insistence that zero is the only acceptable level of pollution the plan is unrealistic for all the reasons he describes and will have many unrecognized impacts that will do more harm than good.  I agree that nuclear generation should be a feature of the future energy system.

In my last post I explained that the New York Public Service Commission has initiated a process to “identify technologies that can close the gap between the capabilities of existing renewable energy technologies and future system reliability needs, and more broadly identify the actions needed to pursue attainment of the Zero Emission by 2040 Target”.  In order to implement the Climate Leadership & Community Protection Act (Climate Act) net-zero transition the Integration Analysis, the New York Independent System Operator and the New York State Reliability Council all agree that a new resource that has all the characteristics of a natural gas fired turbine but no emissions is needed.  This post reviews an article about this topic: New York Begins Exploring Non-Renewable Energy to Meet Climate Target.

I am a retired air pollution meteorologist who specialized in the electric generating sector.  I have been following the Climate Act since it was first proposed. I submitted comments on the Climate Act implementation plan and have written over 300 articles about New York’s net-zero transition because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Climate Act Background

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

My previous article described the reason why a new proceeding on this topic is required. The professional staff at the agencies responsible for keeping the lights on in New York and the analysts who developed the Integration Analysis used for the Scoping Plan all believe that a new resource that can be dispatched as necessary but has zero emissions will be needed.   In the discussion section of the order the PSC agrees that efforts to meet the Climate Act targets “must include exploration of technologies that can support reliability once conventional fossil fuel generation has been removed from the system”.  The order states:

We see this exploration as integral to our responsibility under the PSL to ensure reliable electric service as we approach the Zero Emissions by 2040 Target. With this Order, we are initiating process to determine appropriate next steps to address this gap including consideration of whether it is appropriate for the Commission to allocate ratepayer funds to incentivize the deployment of zero-emission technologies.

I concluded that on one hand it is encouraging that there is finally an effort underway to define “zero emissions” resources and there is recognition that new technologies must be evaluated.  On the other hand, this is a recognized problem that should have been the priority of Climate Action Council and the Scoping Plan from the start.  I have always decried the lack of a feasibility analysis of the affordability, reliability, and permitting acceptability of zero emission resource options and the net-zero transition as a whole.  I believe that the Climate Action Council reliance on non-experts is a leading cause for this delay.  I wrote this article because it interviewed some of the non-experts that caused the delay and had some mis-understandings that deserve clarification.

New York Focus

The article was published at the New York Focus website.  According to the about link:

New York Focus is an independent nonprofit newsroom investigating power in the Empire State.  Launched in October 2020, New York Focus publishes in-depth journalism that explains how the state really works.

As the state’s only nonprofit statewide newsroom, our goal is to help rebuild a local news ecosystem that has faced years of relentless cuts: Almost half of New York’s newspapers have died in the last two decades. We focus on decisions made in Albany and how they impact communities around the state; Albany is the state’s center of power but receives a fraction of the scrutiny it warrants.

We’re guided by the belief that politics is not a sport. Decisions made in New York’s executive mansions, legislative chambers, state administrative offices, courts, nonprofits, union halls, and campaign headquarters don’t stay there. They determine how many New Yorkers sleep on the street each night; how large public college classes are; how many hospital beds are available during a pandemic.

The New York Begins Exploring Non-Renewable Energy to Meet Climate Target article was written by Colin Kinniburgh. 

He is a reporter at New York Focus, covering the state’s climate and environmental politics. Over a decade in media, he has worked in print, television, audio, and online news, and participated in fellowship programs at CUNY’s Graduate School of Journalism and the Metcalf Institute. His reporting has appeared in outlets including France 24, Grist, Dissent, and The Nation.

New York Begins Exploring Non-Renewable Energy to Meet Climate Target

I have annotated the article in this section. 

Biofuels, hydrogen, carbon capture, and nuclear: These are some of the technologies that will be on the table as New York weighs how to clean up its grid over the next 17 years.

When New York passed its climate law four years ago, it declared wind, solar, and battery storage to be the energy sources of the future. The law not only required the state to get 70 percent of its electricity from renewables by 2030, but set precise benchmarks for technologies like offshore wind.

As I have written before, the Climate Act is a political statement.  The implication here is that the Legislature developed a plan that was based on an understanding of the power system and developed schedules based on evaluation of technology.  That was not the case.

That riled power companies, who have long argued that picking technologies in advance will stifle innovation needed for the energy transition. There was still an opening for them to make their case. New York’s climate law requires the state to produce 100 percent of its energy from “zero emissions” sources by 2040, but what exactly that means is still up for debate.

Power plant operators’ lead trade group, the Independent Power Producers of New York (IPPNY), have spent years pushing the state to focus on that more distant goal. The group’s president, Gavin Donohue, pressed the legislature, the Public Service Commission, and the Climate Action Council to back a new subsidy for technologies that will close the gap in New York’s energy supply when the sun isn’t shining and the wind isn’t blowing. Those could include hydrogen; nuclear; alternative fuels like waste products from agriculture; or carbon capture and storage, which could allow plants to keep burning fossil fuels as long as they keep emissions out of the air.

Donohue wasn’t alone in this effort. Along the way he won support from the AFL-CIO, the leading voice of organized labor in the state.

The reference to new technologies that will close the gap in energy supply refers to the Dispatchable Emissions-Free Resource (DEFR). The article does not recognize that the professional staff at the New York Independent System Operator and the New York State Reliability Council  who are responsible for keeping the lights on in New York and the analysts who developed the Integration Analysis used for the Scoping Plan all believe that DEFR will be needed to keep the lights on. 

But environmentalists pushed back, arguing that the effort was a ploy to keep polluting plants open with the help of expensive technologies that have yet to be proven commercially. For much of the last two years, they’ve maintained the upper hand: the IPPNY-backed bill died in committee last session, and the state’s climate plan de-emphasized the kinds of alternative fuels the power industry says will be needed.

The environmentalist push back is rooted in a mis-understanding of the way the electric system works and an overly optimistic expectation for wind and solar resource availability.  I have given a presentation explaining my skepticism of the Climate Act benefits relative to its risks.  My article describing that presentation focused on electric grid reliability risks that environmentalists do not consider.

Now, state regulators are signaling that the issue deserves a fresh look. On Thursday, the Public Service Commission ordered the state to begin studying which new technologies — beyond renewables — it will need to meet its climate targets.

Announcing the decision at a Public Service Commission meeting on Thursday, chair Rory Christian called it an important step. “If we’re successful, this will give us the tools to address many of the emerging issues that we’re seeing, and help us hit our various reliability needs and long-term goals,” Christian said.

State officials have stressed that the effort is intended to complement, not supplant, the central role of renewables. New York is already planning a massive buildout of wind, solar, and transmission lines: To meet the climate law’s requirements, it will need to build 100 times as much large-scale solar in the next five years as it did in the last ten, for example.

Yet even that explosion of renewables won’t be enough to ensure reliable energy while phasing out fossil fuels, studies by the state energy authority NYSERDA and the New York Independent System Operator have found. New York will also need to build new clean energy systems that don’t rely on the weather, and can be turned on at a moment’s notice.

As is the case with many of the green technology solutions advocated by proponents of the Climate Act, the idea that just existing wind and solar technology is all that is needed for the electric grid is flawed.  The general green technology problem is that the technologies do not work all the time.  For the electric system the issue is that there can be extended wind lulls in the winter when solar resources are inherently low is exacerbated because those periods coincide with the coldest weather and thus the highest loads.  The professionals responsible for reliability all conclude that DEFR is necessary for those periods.

The state’s climate plan asks the PSC, along with NYSERDA , to draw up the final criteria for those “firm” or “dispatchable” resources, and that’s what it started doing on Thursday. Like many regulatory decisions, the order published on Thursday is only the start of a lengthy process. It kicks off a two-month public comment period, which will be followed by a technical conference — likely in the fall — to decide what kinds of technologies qualify as “zero emissions” under state law.

Donohue, the head of the power plant lobby, said the move was a long time coming.  “The fact that the commission has finally said, ‘We need these technologies,’ and the fact that they did not limit technologies in this order, is a positive thing,” Donohue said. Still, he called it “incremental progress,” coming nearly two years after IPPNY petitioned the state to take the issue on.

The PSC’s order, which responds explicitly to IPPNY’s petition, meets the group halfway. It stops short of creating a state-backed market for the technologies that ultimately meet the criteria, as IPPNY has sought. The state currently has such markets for wind, solar, and other renewables: Through a mechanism known as the Clean Energy Standard, the state signs contracts for qualifying renewable energy projects, guaranteeing a buyer for the power they generate. The cost of underwriting those contracts trickles down to New Yorkers through their utility bills.

No such guarantees exist for technologies like hydrogen, making them a riskier bet to develop. That isn’t changing for now. But IPPNY hopes the PSC decision will pave the way toward such a subsidy before long.

Setting up a subsidy for these technologies is putting the cart before the horse.  They must find something that might possibly work before they can consider how much it might cost.  Getting something that will work may well be impossible because of the Second Law of Thermodynamics. I do not consider myself an electric system expert but I have talked to experts and they all say this is a challenge because of physics.

The effort’s most vocal backer among state regulators is Commissioner Diane Burman, who was appointed by then–Governor Andrew Cuomo in 2013 and is PSC’s longest-serving member.

“​​We need all the tools in the toolkit to help us achieve our clean energy goals,” she said on Thursday, echoing longstanding talking points from the power industry. “To do that, we need to not be so focused on picking winners and losers, in that we are actually going to chill the opportunities that may be there.”

A week earlier, Burman spoke at IPPNY’s annual conference, where Donohue called her a “good friend.” The conference dedicated a 90-minute session to the issue of dispatchable resources, featuring a program manager at NYSERDA, a chemical engineer, an executive at a fuel cell company, and a pipefitters’ union leader.

“We don’t have to displace middle-class union jobs to achieve our goals,” said John Murphy, the pipe trades union representative. “Intermittent renewables can’t do it alone.”

Speaking to New York Focus on Thursday, Donohue said the PSC’s expected decision on IPPNY’s petition shaped the conference lineup.

“I didn’t do this in the dark,” he said, adding that the PSC’s decision was a sign of regulators warming up to IPPNY’s agenda.

Given the expert concern about this technology it is encouraging that it is finally being addressed.  I worry that it will become politicized with environmental groups disparaging the very idea that it is needed.  The next section in the article, Environmental Groups Wary, confirmed my suspicions.

Environmentalists, who came out in uniform opposition last year to IPPNY’s push, remain wary. Environmental justice advocates in particular have condemned biofuels and hydrogen as “false solutions” that would roll back hard-fought commitments in the state’s climate law.

The “false solution” slogan is the mantra of environmental activists.  To date they have been very successful pushing their emotion-laden agenda that the only acceptable pollution burden is zero based on a selective science.  Anything that is inconsistent with that is labeled as a “false solution”.  See, for example, my work on the peaker power plant issue that discusses tradeoffs.

“If the intention is to have an honest discussion about what actually is zero emissions, and what’s industry hype and… gaslighting, then that’s one thing,” said Eddie Bautista, executive director of the NYC Environmental Justice Alliance. “However, a lot of us are skeptical and worried because of actions that we’ve seen of late by the Hochul administration themselves, looking to potentially undermine the climate law.”

Bautista pointed to the sudden proposal from Hochul’s office in late March, just days before the state’s budget deadline, to overhaul how New York counts carbon emissions. The shift could have allowed polluters to continue burning gas and other fuels for longer, and could have opened the door to more fuels derived from biological sources like wood, or methane gas captured from farms or landfills. Hochul dropped the proposal from budget talks following an uproar from climate groups, but officials have said they intend to revisit it.

Bautista is referring to a proposed change in the emissions accounting proposed earlier this year.  I don’t think very many people understand the actual ramifications to the Climate Act targets.  I don’t agree that it would have “allowed polluters to continue burning gas and other fuels for longer”.  They only proposed to change the accounting label.  The actions necessary to meet the percentage reductions don’t care whether the starting number is 200 and the 2030 40% emissions limit is 120 or the starting number is 100 and the 2030 40% reduction emission limit is 60.  The control strategies still have to get a 40% reduction.  The environmental community is wound up about bio-fuels but ignore the fact that most other jurisdictions with similar programs enable their use.

The plan adopted by the state’s Climate Action Council in December rejected most uses of alternative fuels, to the relief of environmental justice advocates — and the dismay of the three industry-aligned members, including Donohue, who voted against. Now, Bautista is nervous that Hochul might be wavering on the council’s recommendations.  “It’s hard not to see signs of the Hochul administration not fully embracing the plan,” he said.

Raya Salter, an environmental justice advocate and lawyer who sat on the Climate Action Council, was not surprised to see the state moving forward with IPPNY’s petition. She said it was up to climate groups to “hold the line” against any move that would “increase costs to New Yorkers and put disadvantaged communities at risk.”  “We set the bar high in New York, in terms of what any technology that will be used in our state will do in terms of affordability, health, cost, etc.,” she said. “Through the fog, we’re talking about emerging technologies that are unproven and really have a long way to go before clearing any bar.”

The rhetoric of these two ideologues is frightening.  Neither has ever acknowledged the concerns of the agencies responsible for electric system reliability.  I suspect that they would prefer to risk the current standards for reliability and affordability than concede that some of their aspirational goals are threats to them.

The PSC’s order acknowledges some uncertainties around new nuclear, biofuels, and hydrogen, but it doesn’t rule any technologies out. Aside from possible pollution, critics worry that many of these technologies remain prohibitively expensive — though new federal funding, mostly from the Inflation Reduction Act, could change the economics.

Critics of the technologies are worried about the costs of these technologies.  They should be but apparently do not understand that the potential risks of not having this technology dwarf those costs.  In February 2021, the Texas electric grid failed to provide sufficient energy when it was needed.  As a result, over 4.5 million homes and residences were without power, at least 246 people died, and total damages were at least $195 billion.  Those are real costs and deaths not some contrived benefits and projected health impacts associated with GHG emissions. 

It is hypocritical to worry about the DEFR costs but ignore the costs of the rest of the net-zero transition.  Both Bautista and Salter support the narrative that the costs of inaction for the net zero Climate Act transition outweigh the costs of action.  That too is nothing more than a slogan.  It is misleading, because the costs in the Scoping Plan do not include the costs of “already implemented” programs.  In other words, it does not cover the costs to get to net-zero only the costs of the Climate Act itself.  My analyses of costs found that there are significant “already implemented” program costs that likely would make the statement false.  It gets worse because as far as I can tell the Integration Analysis does include the benefits of already implemented programs while it excludes the costs.  My analysis of the benefits shows that they over-estimated the benefits in any event.

Officials say some state investment is necessary to bring emerging, zero-emissions resources to market, just like the technologies that came before them.  “All of our energy infrastructure, at some point, was built with public injection of funds,” said NYSERDA operations manager Richard Bourgeois at the IPPNY conference.

There is one difference overlooked by proponents however.  In the past there was an end to the public injection of funds.  The public injection of subsidies for wind and solar have been on-going for decades.  Given the technological risk of DEFR it is likely that similar on-going subsidies will be required.  There is likely no end for the new “zero-emissions” technologies.

The state will need at least 17 gigawatts’ worth of these clean, “firm,” systems by 2040, NYSERDA estimates — about two-thirds the capacity of all the fossil fuel plants that serve New York today.  Those dispatchable systems will run very rarely, generating only about 1 percent of the power New Yorkers actually end up using, according to a recent presentation by Vlad Gutman-Britten, assistant director of policy and markets at NYSERDA.

The current business model for peaking generation resources is to use the cheapest technology available (simple cycle natural gas turbines) because cost recovery for a facility that only runs 5% or less of the time for the rare conditions is challenging.  It seems unrealistic to expect that any of the new DEFR technologies will be cheaper than a gas turbine which means that cost recovery will be much more difficult.  Somebody, somewhere is going to have to pick up that tab.

Bautista says that limited role means there’s no need for the state to rush into supporting these technologies, particularly given advances in battery storage. “Their solution is always shooting an elephant gun to kill a fly,” he said. “They can’t say in 10 years where battery technology is going to be.”

Gutman-Britten sees things differently.  “That resource is really going to carry New York through some of the most difficult weeks of every year, when renewables are not generating at the times when demand is highest,” he said.

Gutman-Britten has it right.  Without this resource there will be serious reliability problems.  In my opinion failure to provide DEFR will inevitably result in a Texas February 2021 blackout disaster.  Bautista’s naïve position is dangerously wrong.

Conclusion

The Hochul Administration’s deference to a few naïve individuals is increasing the threat to reliable and affordable electricity in New York.  The responsible experts all say that this new resource that can be dispatched as needed without any emissions is necessary for the net-zero transition.  Instead of confronting the discrepancy between the activists who believe that existing technology is sufficient and the Integration Analysis that said that this new technology was needed, the Climate Action Council frittered away a couple of years arguing semantics and nomenclature on less critical issues.

Even if the technologies necessary for the transition turn out to be affordable and work as necessary, the arbitrary schedule of the Climate Act is a problem.  The proposed cap and invest program promises compliance certainty with respect to the mandated schedule.  What is missing is implementation certainty.  There are a whole host of reasons (e.g., funding, supply chain issues, and lack of trained workers) why the generating resources necessary to meet the mandates might not get built as fast necessary.  If that happens the final compliance option is to shut down when the cap is reached.  I do not think that an artificial energy shortage to meet the targets is in the best interest of anyone.  Are the climate activists so naïve as to believe that rationing gasoline, heating fuels and electricity will be selling points for their vision of the future?

In order to implement the Climate Leadership & Community Protection Act (Climate Act) net-zero transition the Integration Analysis, the New York Independent System Operator and the New York State Reliability Council all agree that a new resource that has all the characteristics of a natural gas fired turbine but no emissions is needed.  The New York Public Service Commission has initiated a process to “identify technologies that can close the gap between the capabilities of existing renewable energy technologies and future system reliability needs, and more broadly identify the actions needed to pursue attainment of the Zero Emission by 2040 Target” for New York electric generating sources intended to address that need.  This is an overview of the proceeding.

I have been following the Climate Act since it was first proposed. I submitted comments on the Climate Act implementation plan and have written over 300 articles about New York’s net-zero transition because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Climate Act Background

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

Dispatchable Emissions-Free Resources

The Integration Analysis, the New York Independent System Operator, and the New York State Reliability Council all agree that a new resource that provides all the services of existing natural gas fired generating units without emissions is needed because of the reliability problem illustrated in the following figure.  This graph illustrates the long-duration wind lull problem from an early presentation to the Climate Action Council.  It explicitly points out that emissions-free firm capacity or dispatchable emissions free resources (DEFR) is needed to meet multi-day periods of low wind and solar resource availability.  The thing to remember is that in order to prevent catastrophic blackouts caused because intermittent wind and solar resources are not able to support expected loads, all three groups are banking on DEFR capacity.  Using wind, solar and storage exclusively makes meeting the worst-case renewable resource gap much more difficult, if not impossible, to address.

I compared the state’s scoping plan resource estimates and the New York Independent System Operator analysis that both projected how much more energy (MWh would be needed when everything is electrified and what resources would be needed to provide them.  The issues are summarized in the New York State Reliability Council Draft Scoping Plan comments.  They made the point that the new resources required are enormous and also raised other concerns:

Practical considerations affecting the availability, schedule and operability for new interconnections include: interconnection standards; site availability; permitting; resource equipment availability; regulatory approval; large volume of projects in NYISO queue and study process; scalability of long-term battery storage and other technologies; operational control; impact of extreme weather; consideration of a must- run reliability need for legacy resources. In addition, the pace of transportation and building electrification, the timing of any natural gas phase-out and their impact on the electric T&D system must also be carefully studied from technical, economic and environmental perspectives. Together, these practical considerations require the development of reliable zero emission resources to be conscientiously sequenced and timed in the near term (through 2030) to ensure broader GHG reductions in all sectors beyond 2030.

It all boils down to the fact that a reliable zero emission resource that can backup intermittent renewable energy does not exist.  The NYISO and NYSRC both waffle around saying that such a magical resource must be developed and tested but they have not admitted publicly the possibility that such a resource may well be impossible because of the Second Law of Thermodynamics.  The Scoping Plan chose green hydrogen as its candidate resource and in order to prove that it can work a comprehensive feasibility analysis is required. 

Scoping Plan and DEFR

In my opinion the Hochul Administration lost track of the plot regarding the Climate Action Council’s handling of the Scoping Plan.  In particular, the Council managed to get bogged down into technical details that were outside the expertise of the membership but forged ahead anyway.  I believe they went off in the wrong direction. 

At the meeting where the Climate Action Council approved the Scoping Plan Council members gave statements.  The statement of Robert W. Howarth, Ph.D., the David R. Atkinson Professor of Ecology & Environmental Biology at Cornell University illustrates my concern.  He claimed that he played a key role in the drafting of the Climate Act and summarized his position regarding the transition of the electric grid:

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.

The professional staff at the agencies responsible for keeping the lights on in New York and the analysts who developed the Integration Analysis used for the Scoping Plan all believe that DEFR will be needed to keep the lights on.  Their position is at odds with Howarth’s assertion that the existing technologies for wind, sun, and hydro generating resources are all that is necessary for a reliable electric system.  The failure of the Hochul Administration to make it clear that Dr. Howarth’s opinion cannot be the basis of New York policy has resulted in unacceptable delays in the development of a feasibility analysis for this resource.

Public Service Commission DEFR

On May 18, 2023 the Public Service Commission (PSC) announced that a process has been started to “examine the need for resources to ensure the reliability of the 2040 zero-emissions electric grid mandated by the Climate Act”.  The press release went on:

The Climate Act, passed by the State Legislature in 2019, directs the Commission to establish, among other things, a program to ensure that by 2030, at least 70 percent of electric load is served by renewable energy, and that by 2040, there are zero emissions associated with electrical demand in the State. The initiative will help deliver on the Climate Act zero-emissions electric grid mandate and will enable the necessary types of clean energy to reach all New Yorkers. The Commission’s decision follows a substantial climate package announced by Governor Kathy Hochul in the FY24 enacted State Budget that will advance sustainable buildings, clean energy, and an affordable Cap-and-Invest program.

Today’s action recognizes that as renewable resources and storage facilities are added to the State’s energy supply, additional clean-energy resources capable of responding to fluctuating conditions might be needed to maintain the reliability of the electric grid. The Commission’s work to meet the Climate Act targets must include exploration of technologies that can support reliability once fossil generation has been removed from the system.

The order initiates a process to identify technologies that can close the anticipated gap between the capabilities of existing renewable energy technologies and future system reliability needs. Within the order, the Commission asks stakeholders a series of important questions, including how to define ‘zero-emissions’ for purposes of the zero emissions by 2040 target, and whether that definition should include cutting edge technologies such as advanced nuclear, long duration energy storage, green hydrogen, and demand response. The order further elicits feedback from stakeholders on how to best design a zero-emissions by 2040 program, consistent with the Climate Act’s requirement of delivering substantial benefits to disadvantaged communities and New York State’s electric grid reliability rules, while also leveraging other state and federal efforts to research, develop, and deploy zero-emission resources.

After a 60-day public comment period, Commission staff will convene at least one technical conference to examine a series of issues and questions raised in this important proceeding. The Commission may take additional actions on zero-emission resources based on the information obtained through those processes.

The order provided more background and rationale.  When the Climate Act was passed the PSC modified the Clean Energy Standard (DES) to align with its requirements.  The order explains:

The pathway established by the CES Modification Order focuses on options for procuring sufficient renewable energy resources to meet CLCPA requirements. However, several studies indicate that renewable energy resources may not be capable of meeting the full range of electric system reliability needs that will arise as fossil generation is replaced. These studies suggest that there is a gap between the capabilities of existing renewable energy technology and expected future system reliability requirements.

On August 18, 2021 the Independent Power Producers of New York, Inc., New York State Building and Construction Trades Council, and New York State AFL-CIO (Petitioners) filed a Zero Emissions Petition that also raised this issue. The proceeding notes:

This Order responds to the Petition and initiates a process to identify technologies that can close the gap between the capabilities of existing renewable energy technologies and future system reliability needs, and more broadly identify the actions needed to pursue attainment of the Zero Emission by 2040 Target. As a first step, rather than adopting a new CES tier as requested in the Zero Emissions Petition, this Order seeks input from stakeholders on options for addressing that gap. In particular, the Commission welcomes responses to the questions posed in the body of this Order and directs the Department of Public Service staff (Staff), in consultation with the New York State Energy Research and Development Authority (NYSERDA), to convene a technical conference that addresses the same list of questions.

In the discussion section of the order the PSC admits that efforts to meet the Climate Act targets “must include exploration of technologies that can support reliability once conventional fossil fuel generation has been removed from the system”.  The order states:

We see this exploration as integral to our responsibility under the PSL to ensure reliable electric service as we approach the Zero Emissions by 2040 Target.²⁵ With this Order, we are initiating process to determine appropriate next steps to address this gap including consideration of whether it is appropriate for the Commission to allocate ratepayer funds to incentivize the deployment of zero-emission technologies.

The order goes on to seek comment on related topics and asks specific questions.

I find it particularly enlightening as an example of poor planning that the one of the topics relates to the term “zero emissions”.  It turns out nobody has bothered to define what technologies qualify as “zero emissions”:

Many of the questions posed below relate to how the term “zero emissions” should be defined. This is a particularly important issue given that neither PSL §66-p(2)(b) nor any other provision of the CLCPA defines the technologies that should be considered “zero emissions.” Section 66-p(2) (b) simply states that “by the year [2040] the statewide electrical demand system will be zero emissions.” The CES Modification Order established that the technologies defined as “renewable energy systems” under PSL §66-p(l)(a) are de facto “zero emissions” for purposes of meeting the 2040 target.26 Additionally, the Commission recognized existing nuclear generation as a zero-emission technology in its 2016 CES Framework Order, which created the ZEC program.27 However, PSL §66-p(2) (b) does not say more about what is meant by “zero emissions,” leaving it to the Commission to define the term.

Notice Soliciting Public Comments

The order asks for comments on the following questions.

1. How should the term “zero emissions,” as used under PSL §66-p(2)(b), be defined?
2. Should the term “zero emissions” be construed to include some or all of the following types of resources, such as advanced nuclear (Gen III+ or Gen IV), long-duration storage, green hydrogen, renewable natural gas, carbon capture and sequestration, virtual power plants, distributed energy resources, or demand response resources? What other resource types should
   be included?
3. How should a program to achieve the Zero-Emission by 2040 Target address existing and newly constructed nuclear energy resources. Should the program be limited to specific types of nuclear energy technologies and exclude others?
4. Should new measures adopted to pursue compliance with the Zero-Emission by 2040 Target focus exclusively on generation and resource adequacy, or should they also encompass a broader set of technologies that could be integrated into the transmission or distribution
   system segments, or installed and operated behind-the-meter?
5. Should any program to achieve the Zero-Emission by 2040 Target specify subcategories of energy resources based on particular characteristics, such as ramp rates, the duration of their operational availability, or their emissions profile with respect to local pollutants?
6. What role does technology innovation need to play to meet the CLCPA’s Zero-Emission by 2040 Target?
7. Should life cycle emissions impacts be considered when characterizing energy resources? If so, how?
8. Given that the feedstocks and other resources required to produce renewable natural gas are limited and will be in demand in other sectors of New York’s economy, how should this fuel be considered in the context of this proceeding?
9. In what ways might a program to meet the Zero-Emission by 2040 Target require reexamination and possibly revision of different tiers of the Clean Energy Standard? Should one or more of the policy approaches that have been used to implement the CES be considered to meet the Zero-Emission by 2040 Target?
10. What is necessary to align a program to meet the Zero-Emission by 2040 Target with the priority of just transition embedded within the CLCPA?
11. How might the benefits of a program to meet the Zero-Emission by 2040 Target be measured for the purpose of ensuring that, consistent with PSL §66-p(7), it delivers “substantial benefits” to Disadvantaged Communities?
12. NYISO has adopted an effective load carrying capacity (ELCC) rubric and treatment of Zones J and K as load pockets with special resource adequacy requirements. How should these constructs and other NYISO market rules inform design of a program meant to support the development and deployment of resources capable of achieving a zero emissions grid?
13. What additional studies, if any, should the Commission undertake with respect to the development and deployment of resources capable of achieving a zero emissions grid?
14. Given that New York is not the only jurisdiction investigating options and opportunities for the research, development, and deployment of new technologies capable of achieving a zero emissions grid, how should the State seek to coordinate with and otherwise draw upon efforts that are underway elsewhere?

Conclusion

On one hand it is encouraging that there is finally an effort underway to define “zero emissions” resources and there is recognition that new technologies must be evaluated.  On the other hand, this is a recognized problem that should have been the priority of Climate Action Council and the Scoping Plan.  It has been 21 months since the Zero Emissions Petition was filed and they are just starting to address the problem.  I have always decried the lack of a feasibility analysis of the affordability, reliability, and permitting acceptability of zero emission resource options.  I believe that the Climate Action Council reliance on non-experts is a leading cause for this delay.

My other concern is that this could become politicized.  I expect massive pushback from Climate Act proponents if the proceeding finds that the only proven option available for affordable “zero emissions” resources that must be included in the future energy system mix to maintain reliability is nuclear.  If New York truly wants to reduce GHG emissions to the extent proposed nuclear must be in the mix but the entrenched anti-nuclear sentiment likely precludes that rational approach.  Furthermore, all the other options may well be impossible because of the Second Law of Thermodynamics   If the analysis determines that the other options are technologically infeasible or too expensive in the mandated Climate Act schedule, the only rational approach would be to adjust the schedule.  That would cause a meltdown for all the Climate Activists. The Hochul Administration has painted itself into a corner because I think the most likely result of this proceeding is inconsistent with the Scoping Plan.  They will have to either admit that the Scoping Plan schedule is untenable or modify the results to fit the political narrative.

Update

As I was getting ready to publish this I heard the Susan Arbetter on Spectrum News Capital Tonight had interviewed Dr. Howarth.  She had two members of the Climate Action Council on her show to discuss Climate Act Implementation: Howarth and Gavin Donohue of the Independent Power Producers of New York. I generally agree with Donohue’s description of the current status. At 7:20 of the interview video she talked to Howarth.  Her last question (13:12 of the video) was: “What is the greatest obstacle to meeting the goals of the Climate Act”.  Howarth’s response was completely consistent with his earlier statements:

Well, they are not technical.  We know how to move the state to a 100% fossil free future.  The technology has been around for more than a decade to do that. And it is actually cost-effective.  The Scoping Plan and the Climate Action Council lays that out in great detail.  The cost of inaction is more than the cost of moving forward with this plan, which is why 19 out of 22 of us voted for it.  Gavin is only one of three people who voted against it

Arbetter had to ask him at this point to answer the question.  He responded:

The challenges are political and educational.  Letting people know why it is good for the state.  Letting them know why they can afford it.  Counter-acting some of the misinformation and fear mongering that is out there.

If I was not clear enough in this post let me reiterate my concern.  The Integration Analysis that was used to develop the Scoping Plan; the organizations responsible for providing reliable electric energy -New York Independent System Operator and New York State Reliability Council, and by way of this proceeding, the Public Service Commission all agree that we do not know how to move the state to a 100% fossil free future because meeting that target requires dispatchable emissions free resources that do not presently exist.  Dr. Howarth claims that education is necessary to counter-act misinformation and fear-mongering but given that his technology position directly contradicts the state experts on electric system reliability I conclude he is the one guilty of misinformation.

This post describes some articles I have noted recently that relate to the Climate Leadership & Community Protection Act (Climate Act) net-zero transition plans.  At the core of the Climate Act the key questions are is there a problem that warrants the complete conversion of our energy system and can the alternatives proposed replace the existing system affordably while maintaining current standards of reliability.  The articles referenced here address those questions.

I have been following the Climate Act since it was first proposed. I submitted comments on the Climate Act implementation plan and have written over 300 articles about New York’s net-zero transition. The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Climate Act Background

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

Climate Change Problem

The rationale for the Climate Act is that there is a climate crisis.  The Intergovernmental Panel on Climate Change (IPCC) is the United Nations organization that assesses science related to climate change and the IPCC reports were referenced in the Scoping Plan.  In March the latest Synthesis Report describing the latest IPCC AR6 assessment was released.  Climate Intelligence (CLINTEL)  has published a new report entitled “The Frozen Climate Views of the IPCC: Analysis of the AR6”:

“The new Report provides an independent assessment of the most important parts of AR6. We document biases and errors in almost every chapter we reviewed. In some cases, of course, one can quibble endlessly about our criticism and how relevant it is for the overall ‘climate narrative’ of the IPCC. In some cases, though, we document such blatant cherry picking by the IPCC, that even ardent supporters of the IPCC should feel embarrassed.”

Judith Curry described this report in a recent post.  She describes the key issue:

The IPCC focuses on “dangerous anthropogenic climate change,” which leads to ignoring natural climate change, focusing on extreme emissions scenarios, and cherry picking the time periods and the literature to make climate change appear “dangerous.”

I recommend her post as a good overview of the flaws in the IPCC assessment.  I endorse Curry’s conclusion:

In any event, UN-driven climate policy has moved well past any moorings in climate science, even the relatively alarming version reported by the IPCC.  The insane policies and deadlines tied to greenhouse gas emissions are simply at odds with the reality of our understanding of climate change and the uncertainties, and with broader considerations of human well-being.

Proposed Solutions

I think one of the fundamental flaws associated with the Scoping Plan is the presumption that the raw materials necessary for the electrification proposed are readily available.  Furthermore, the “clean energy” and “zero emissions” descriptions in the Plan ignore the total life cycle impacts of those raw materials.  On April 26, 2026 Mark P. Mills, Senior Fellow, Manhattan Institute, gave testimony before the Subcommittee on Environment, Manufacturing, and Critical Materials, U.S. House Committee on Energy and Commerce Hearing on: “Exposing the Environmental, Human Rights, and National Security Risks of the Biden Administration’s Rush to Green Policies”.  His testimony makes a strong case that New York’s presumptions are misplaced.

His introduction includes the following:

Permit me to begin by observing two indisputable facts about our future. First, economic growth is the fundamental driver of energy demand. And second, while periods of slow growth and recessions are inevitable in all societies, those periods always end. But any subsequent growth can be stifled if energy supplies are either unavailable or too expensive.

Energy supply itself is not as much a matter of finding resources as it is one of building machines, regardless of the natural resource used, whether sun, wind, water, oil, gas, coal, or uranium. Thus realities around machine-building determine costs and all the associated environmental, social, and geopolitical impacts.

We know a lot about those impacts—both the good and the bad—associated with energy machines that use hydrocarbons because we’ve been using those technologies at scale for a long time, and because that’s how 85 percent of U.S. and global energy is supplied. We’ve learned a lot less about impacts from wind, solar, and battery technologies because they’re relatively new and, so far, supply only a few percent of society’s overall energy.

 The Biden Administration has a stated policy goal to see America powered increasingly, eventually entirely by renewable energy. I should like to stipulate that the future will doubtless see far greater use of wind and solar technologies, and electric cars, if for no other reason than the sheer scale of future energy needs, and because developed countries are wealthy enough to pay higher costs.

However, there are many misconceptions about the realities of renewable energy technologies at scale, especially if the goal is to replace rather than supplement hydrocarbons. It begins with the core reality that renewables aren’t green. In fact, nor are renewable technologies inherently cheaper, nor more geopolitically secure.

That renewable energy isn’t green is a consequence of an unavoidable feature of wind and solar resources; they have very low energy density. That means, compared to using hydrocarbons, one must build machines that occupy roughly ten-times more of the earth’s surface to deliver the same amount of energy to society—whether it’s an hour of heat, or light, or computing time, or a mile of driving.

Essentially all life occupies the thin, surface interface of our planet, whether it’s land or water. One of humanity’s greatest achievements has been the radical reduction in the amount of that interface we use to deliver increasing quantities of food and fuel.

The inherent low-energy-density of renewables also means that far more machinery must be fabricated to deliver the same energy as now supplied by hydrocarbon machines. That in turn translates into a radical increase in global mining and minerals processing to supply all the critical materials needed to build renewable machinery.

Renewable plans proposed or underway will require from 400 percent to 8,000 percent more mining for dozens of minerals, from copper and nickel, to aluminum, graphite, and lithium. The IEA says the world will need hundreds of new mines, soon. Given regulatory realities, those won’t be here. Instead, most will be in emerging economies and most will be on or near the lands of indigenous people in areas that are culturally and ecologically valuable and fragile.

And given machine realities, the huge jump in mining required will increase energy use in that sector, thus offsetting a lot, in some cases all the CO2 emissions saved later by replacing hydrocarbons in powerplants and cars. Global mining today already accounts for 40 percent of worldwide industrial energy use, which is dominated by hydrocarbons, and will be for decades.

Mills makes similar arguments in a couple of videos available at PragerU.

Electric Vehicles

I also want to highlight a couple of articles about the electric vehicle mandates in New York and elsewhere.  Robert Bryce asked how can the conversion to electric vehicles possibly work out when Ford loses $66,446 per vehicle sold?  He argues that Ford can currently swallow the losses incurred by its electric vehicle sales but:

If a business isn’t profitable it isn’t sustainable. The history of electric vehicles goes back more than a century and that history is one of failure tailgating failure. In 1915, the Washington Post declared “Prices on electric cars will continue to drop until they are within reach of the average family.”  Today, 108 years later, Ford and other EV makers are still trying to make that prediction come true.

Timothy Nash described 25 reasons why Biden’s EV goals are economically and environmentally harmful.  One of the points he made was that thermal runaway issues with the battery packs are a problem. An industry insider told me recently that there is some talk about limiting vehicle range because battery over heating is more of a problem with the bigger batteries.  Given that range is a major concern that tradeoff is especially problematic.  The ultimate question is what is supposed to happen when people don’t buy the electric vehicles required by the government mandates.

Conclusion

The Climate Act is an example of an insane policy with unrealistic deadlines that is tied to the IPCC analyses.  In 2023 the Scoping Plan recommendations are supposed to be implemented.  The legislature is in session for another month or so and it will be interesting to see how things play out. The disconnect between reality and the aspirations of the Climate Act is still evident.  I hope that the issues described in these articles get addressed in the conversations.