Category: Climate Act Feasibility

New York Building Decarbonization is Destined to Fail

Richard Ellenbogen frequently copies me on emails that address various issues associated with New York’s Climate Leadership and Community Protection Act (Climate Act).  I asked his permission to present his analysis explaining why New York’s building decarbonization push it is going to fail, just as Germany’s has, and will drive up state GHG emissions and raise utility costs for decades.  He has consolidated all of his material on this topic in one document and has included recommendations for an alternative approach.

I have published other articles by Ellenbogen because he truly cares about the environment and the environmental performance record of his business shows that he is walking the walk.   Ellenbogen is the President of Allied Converters  that manufactures food packaging.  His facility is about 55,000 square feet and does a lot of manufacturing with heat to seal the bags, all electrically driven.  The facility has solar panels and uses co-generation.  He explains:

In 2008, the average energy cost per square foot for a commercial facility in  Westchester was $1.80.  We were at 16% of that 12 years later and even with the increases, we are at 62% of that 14 years later.  That has been done while having a carbon footprint 30% – 40% lower than the utility system.  The $1.80 per foot  also included commercial office space and our operation is far more energy intensive than an office.  We use energy extremely efficiently and as a result, our bills are much lower than everyone else. 

Ellenbogen on Building Decarbonization

While it is being proposed with good intentions, NY State’s building decarbonization push is going to fail, just as Germany’s has, and will drive up state GHG emissions and raise utility costs for decades.  The analysis to justify that conclusion follows.  While there is new material included, a portion is a synopsis  of prior emails but as NY State gets closer to committing energy suicide, I felt obligated to put it all in one document.  As it is written, the state’s energy plan is going to be the fossil fuel company’s best friend.  NY State is adopting a “Chicken Little” approach to energy policy.  It is so focused on the acorn of fossil fuels and a belief that the sky is falling that it is ignoring science in the process.  As a result, the state will fall victim to the fox of energy failures, high GHG emissions,  and incredibly high utility rates that are going to eat NY State citizens and businesses.  For those who declare that  NY State must exhibit “Climate Leadership”, this policy isn’t that.  It is copying a failed policy from Germany.  For those not interested in the minutiae of the reasoning, the figure headlines and the final recommendations will give an accurate picture of the problems.

There is a way to get about a 44% GHG reduction in NY State while also having enough generation to support the system without imposing extremely high costs on the state’s residents and businesses.  It can be implemented in one-quarter  the time of the state’s current plan using a combination of improved fossil fuel plants and renewables, while replacing old gas equipment with newer gas equipment that won’t require an entire rewiring of NY State.

In lieu of doing something that will actually work, the state’s plan will face the following issues:

1 – Cost – Trillions of Dollars

First of all, the cost of the project will not be anywhere near as inexpensive as the $200 billion figure that is being thrown around.  Going through all of the figures, it will be at least $600 billion for the electrification portion, before adding storage and renewable generation to the totals.   For anyone that doubts that, the cost of a single 400 mile cable from Quebec to NY City has now risen to $6 billion and try to name a single infrastructure project in NY State that has come in on budget.  The Champlain Hudson Power Express Cable was projected to cost $2 billion in 2013.  That cost is now up to $6 billion, a 232% increase in inflation adjusted dollars.  Does anyone seriously believe that the entire state can be rewired for less than 100 times that cost?  If you add in storage costs at the present cost of Lithium Ion Batteries, the cost rises to approximately $4 trillion plus the cost of the renewable generation.  Even if you could get a 75% reduction in storage costs using a different technology, the total cost will be well over $1.5 trillion and much of that will depend on the usable life of the new storage.   At present, battery storage only lasts 10 years.   Pumped Storage would likely be much more cost effective but where in NY State can a utility site a large reservoir.  Also, based upon Con Ed’s experience with Storm King Mountain between 1960 and 1980, no utility will even try to build a pumped storage facility.

2 – Logistics – Size of Project and Lack of Labor will result in it requiring Over 60 Years – Policy is going to create situations where the mandates cannot be fulfilled

There are 112,000 miles of roads in NY State.  Of those, about 22,000 miles are major highways and likely don’t have electric distribution lines on them, leaving about 90,000 miles of distribution lines that were designed and sized for an era where onsite heating was delivered from fossil fuels or wood.  The vast majority of the transformers and conductors will not handle a tripling of the electric load during the during the winter.  If you eliminate 18,000 miles (20%) for areas upstate that are already using electric heat, that leaves 72,000 miles of distribution network to be rewired.  8,000 of those miles are in NY City where a substantial portion of the infrastructure is buried and the costs will be higher still.

When I did the utility project with Con Ed back in 2010 where we demonstrated that we could reduce transmission loads and line losses using reactive power correction on the local distribution system,  I added power monitoring devices to four transformers.  On hot days during the summer, three of the four transformers where the project was executed were operating at or near their capacity on a hot summer day. If heat pumps are added to the system, the winter time load on a cold day will be substantially higher than the summer time load on a hot day.  That is not my speculation.  The NYISO has determined that NY State will need an additional 25 Gigawatts of generation to support heat pumps in NY State. during the winter.  Winter peaks are expected to exceed summer peaks starting in the early 2030’s.

As a result, a substantial portion of that 90,000 miles will need to be rewired to support onsite electrification.  Using an existing project in California as a reference, PG&E has been required to bury 10,000 miles of high voltage transmission lines in the fire prone areas.  In 2022, they replaced 71 miles of cable.  By 2025, they expect to increase that to a rate of 1200 miles per year.  That doesn’t include replacing transformers or services to people’s homes which would be required to electrify onsite heating.  Even larger conductors will have to be added in rural areas of NY State where they expect to interconnect large solar arrays so that the projects don’t keep getting canceled because of interconnection costs.  While replacing overhead lines would take less time than burying them, replacing old equipment with higher capacity equipment for the larger heating loads and the additional time needed to increase the service sizes into people’s homes would about offset the time difference.

At 1200 miles per year, rewiring 72,000 miles of distribution lines in NY state will take 60 years to upgrade.  They have been burying larger electric and gas services in New Rochelle to support the extra 9,000 units of housing that they are building here and the roads have been like a slalom course for about 4 years to fix about 10 miles of services so the 60 years is not an unrealistic estimate.  NY City may take even longer to rewire and that is 40% of the state’s population.  What is going to happen to the people that cannot replace their gas equipment in areas where the service has not been upgraded to support the higher electric loads imposed on the system by NY State policy ?

3 – Bad Science Is Driving Initiatives – Results Will be Far worse than Estimated and It will add Enormous Costs On the Backs of the State’s Citizens

I have read extensively about the PAF (Population Attributable Fraction) technique that was used as the analytical tool to do the analysis for the recent paper about gas stoves and childhood asthma.  A slide from an upcoming PowerPoint that I will be presenting is below.  The caption at the bottom of the slide was copied from the introduction of a paper discussing PAF by people that developed an improvement to PAF.  However, the improved version needs very specific data directed at the variables involved, and not 30 – 40 year old data that was not asking the necessary questions from a time when the focus on health issues was very different.   Every PAF study with multiple variables warns of bias in the study and questionable results, whether it is from sugar intake  and type 2 diabetes to comorbidities and Covid.  Asthma falls into the multiple variable category.  Risk factors can include tree pollen, second hand smoke, proximity to large emission sources such as factories or power plants, pet dander, vehicle exhaust, nutrition, and yes, even gas stoves, among others.  But unless all of the data on the other variables was collected in the survey, PAF will return garbage, even in the updated format proposed by the authors of the PAF improvement.  Thus, the conclusions of the gas stove report have no validity.  

Another issue never explained by the authors of the gas stove study is why the top ten states for cases of asthma in the US are all 80% electric stoves and the top eight states for childhood asthma are 80% electric stoves.  If gas stoves were that large of a factor, at least one of the five states that is primarily gas stoves would appear higher on those lists.   The conclusions of the study could possibly be correct, but no one could be sure because the study was so poorly conceived, conducted, and analyzed.  It certainly should not be used as the basis for a public policy affecting 19.5 million people that is going to add an additional $72 billion in costs onto the backs of the state’s utility customers.  Results that will be at least 95% – 98% as effective can be obtained at a fraction of that cost using other techniques.

4 – Existing Transmission and Distribution System Will Not Support Installation of Large scale Renewable Generation – Too Many Resources are Being Wasted on Projects that will Yield No Environmental Benefits.  Not Enough is being spent On Grid Infrastructure to support renewables and vehicle electrification.

Another major issue, and one that is severely impacting the installation of renewables is the fact that the state’s utility system is wired backwards for what policy makers are trying to do with it.  The utility system was wired to have large sources of generation distributing energy outward from a few locations.   Now, the state is trying to site large generation sources in remote locations where the infrastructure won’t support it.  As a result, renewable generation installers are faced with long transmission line runs to interconnect into the system, making the projects non-cost effective.  The projects are being cancelled and as a result, NY State is falling well behind in their installation schedule that was already insufficient to fulfill the state’s requirements. 

This is also apparent with regard to the 9 GW of offshore wind.  There is a major concern about the availability of space to run the cables to interconnect the energy to where it is needed.  One possibility is running the cables across Long Island in an environment where every infrastructure project is faced with lawsuits.  As a result, even if they can build the 9 GW of Atlantic Wind, they may only be able to interconnect about 6 GW to where it is needed.  That is clearly  shown in another slide from the upcoming PowerPoint documenting a critical page in a NY State Power Grid report,  below.  Transferring renewable generation installation projects to NYPA may increase the rate of installation slightly but the node analyses will still have to be done that takes five years at present and the transmission lines will still have to be installed so the price will not be reduced.

5 – Air Source Heat Pumps On a System Not Fully Supported By Renewable Generation Will Not Reduce GHG.  There are not Enough Drillers to install Ground Source Heat Pumps, which actually work, in any time frame that will yield significant results.

As is clearly documented in the slide below, putting electric onsite heating into buildings that are not fully supported by renewables just shifts the load to existing generating plants.  In Germany, heat pump installation, primarily air source,  exceeds gas combustion installation.  However, despite installing massive amounts of renewable generation, while their household carbon emissions have declined by 28% since 1999, their utility system carbon emissions only declined by 3.4%.  While they closed nuclear plants, they actually installed more Gigawatt hours of renewables.  They should have seen a large GHG decrease, but heat pumps running on a system that uses fossil fuel generation add marginal additional load to the fossil fuel plants with higher emissions than an efficient gas boiler/furnace.   

Germany is playing “Whack-A-Mole” with its building emissions and NY State is about to do the same thing.  They beat down the emissions in one place and they pop up somewhere else.  That chart was copied from a Yale publication “Can Germany revive its stalled energy transition?” published in about 2018.  Based upon events 4 years later, the answer has been a resounding “NO”  Even prior to the war in Ukraine, Germany was reopening coal plants.  After the war started and they lost their gas supply, they opened even more coal plants and there were news articles about people across Europe stealing firewood,  cutting down trees, and burning anything that they could find to stay warm.  That will be the future of NY State with the proposed policies.  Germany has been exceedingly lucky this year with a relatively warm winter, however they recently signed an agreement with Qatar to import 20 million metric tons of Liquid Natural Gas over the next ten years.

As the chart shown below from a Cornell Geothermal report clearly show, all additional load added to the system is supported by fossil fuel generation.  Blue and Brown lines were added after to explain the difference between the upstate and downstate generation sources which in 2019 were within 5% of each other.  However, in terms of zero emissions sources, they were worlds apart.  The downstate system is almost entirely supplied by fossil fuels.

6 – Battery Storage is being added to the System Prematurely.  The batteries will wear out at least 50 years before the state has enough renewable generation to charge them.  As a result, they will be charged with fossil fuel generation with a 15% – 20% higher carbon footprint than the actual generation.

As all marginal generation in NY State is provided by fossil fuel generation, all new battery systems that are added will increase fossil fuel generation by a minimum of 15% related to that stored energy as 15% of the battery’s energy is lost in the Charge/Discharge cycle.  The batteries will need to be replaced after about 10 years, well before the system will be supported by renewable generation.  This is great news for Elon Musk, but not that good for the taxpayers and utility customers in NY State.  The following slide was also borrowed from the same report.

7 – An Energy “Shell Game” is Being Used to Make the New Micron Technology Facility Appear Greener than it Actually Will Be under CLCPA rules.  However, it could be made far “Greener” in reality by siting a combined cycle generating plant next to the Micron Facility.  Nuclear generation would be better still, but that would take far longer to build and would have much higher upfront costs.

The New Micron Technology Facility in Clay, NY will eventually use more energy than the state of Vermont.  NY State and NYPA have said that they will provide 140 Megawatts of NY Hydro to the plant.   For lack of a better word, that policy is a farce.  All of the NY State Hydro has been allocated for years.  If they allocate it to the Micron Facility, those customers that are currently using it will then effectively be using fossil fuels.  They want Micron to use all renewable energy.  From Where?  A solar array that could generate enough energy to support that facility would occupy 100 square miles.  They want Micron the buy Carbon Credits.  From whom?  NY State’s two largest neighbors to the south and west, Pennsylvania and Ohio, average 1.5% renewable energy.  If NY State has to import energy from either of those states to support the Micron facility, it will all be from fossil fuel generation, gas or coal fired, at a lower efficiency than a combined cycle generator.  The import of energy from long distances to the Micron Site will increase transmission line losses by approximately 350 Gigawatts compared with a generator on-site.  The new rules are going to make the Micron facility less energy efficient, more polluting,  and also increase Micron’s operational costs while imposing environmental costs on the state.  Forcing Micron to buy Carbon Credits does nothing to help the environment.  It literally papers over the problem while raising Micron’s costs and doing nothing tangible to reduce greenhouse gas emissions.

8 – Renewable Generation Installation Rates are Insufficient to Support NY State’s Plan

Even prior to many of the recent cancellations of renewable generation projects, NY State was not going to have enough renewable generation installed for about 60 years.  Prior to the cancellations, NY State was going to be at least 120,000 Gigawatt hours short of what it would need to support the system on all renewables by 2035 as is shown in the slide below.  With onsite fossil fuel combustion about to be banned in new building and replacement equipment banned after 2035,  while EV’s are mandated for all sales after 2035, the system load is going to grow far more rapidly than the expansion of renewable generation resulting in an energy shortfall.  Beyond the transmission issues facing the Atlantic Wind projects mentioned earlier, the Jones Act is going to slow the rate of installation for offshore wind by limiting the number of jack ships that will be available.   While NY State is short on land, money, and grid capacity, the one thing that NY State has in abundance is lawyers so that any renewable project will be faced with years of NIMBY lawsuits and the resulting delays.

Just because California tried it that doesn’t mean that NY State should.  California has a Mediterranean climate and is 20 degrees warmer in the winter so the orange and gray “energy blocks” in the fossil fuel column A on the chart below are much smaller.  If NY State had the same climate as California, it would eliminate a need for about 150,000 Gigawatt hours of renewable generation on the future system.  Keep in mind that California is having difficulty keeping the lights on without the albatross of onsite heating around their neck.

Four columns on the chart above are labeled A,B,C,D and are referred to in the conclusion. 

“A” is the Existing Fossil Fuel Consumption in NY State.  “B” is the Electric Load if all of that was converted to  electric technologies on a fully GHG free generation system.  “C” is 6 GW of 1000 hour storage as mentioned in the NY State Energy Storage report.  Current cost using Lithium-Ion batteries, $3.4 Trillion.  NY State is betting on technologies that don’t exist commercially yet and at present, have shorter lifespans than the 10 years of Lithium-Ion.  “D” was the projected renewable installation for 2035 estimated in 2019 using figures provided by NY State.  With solar projects being canceled, in 2023 that is an overly optimistic estimate.

Even if all of the existing fossil fuel generation remained static and no fossil fuel plants are closed, the additional load being mandated is going to outstrip the rate of renewable installation.  As NY State is not allowed to build any new fossil fuel generation, one of two things will happen as a result of the energy shortfalls shown in the slide above.  NY State citizens will be without lights and heat, or NY State will have to import large amounts of fossil fuel generation from out of state, just as California has had to do.  When the neighboring states don’t have it available, NY State will have to impose rolling blackouts just as California now does, only the blackouts will occur on the coldest days of winter which will be far more deadly than the hot days during the California summer.

If Climate Change is truly the existential crisis that the authors of the CLCPA claim it to be, and if the recent UN report about the need to halve atmospheric carbon within 10 years is true, then NY State’s 60 – 70 year plan that is going to increase carbon emissions for at least the first 30 years needs some rethinking.

 Keep in mind that NY States total GHG emissions are 350 million metric tons annually.   Worldwide GHG emissions increased in 2021 by 2 billion metric tons, 40% of that from increased coal combustion in China, India, Germany, Japan, and other countries.  So, the increase in worldwide GHG emissions in 2021 was six times NY State’s total annual emissions. 

Because of the above fact, it is apparent that the rate of Climate Change is not in the purview of NY State policy makers.  As resources are limited, instead of wasting money on building electrification that will yield no holistic improvements in GHG emissions, resources should be used to harden infrastructure against the inevitable negative effects of Climate Change, whether that is on grid infrastructure or flood mitigation.  The most expensive and severe impacts of Sandy were on the underground infrastructure of NY City and along the Hudson River.  Venice type barriers might be considered for under the Verrazano and the Triborough Bridges, however that will never happen if the state wastes $600 billion on an electrification plan with no positive upside.

A Better Plan –

The following, if executed properly could result in the energy chart, below, where the right hand column actually can supply NY State’s energy needs at a fraction of the cost of the current plan while also reducing fossil fuel energy use and the associated GHG emissions by 44%.  However, people will have to allow techniques that don’t meet the current standard of ideological purity in NY State.

By eliminating the push to electrify buildings, the energy savings and carbon reductions will actually be greater than what the CLCPA will yield in practice.  This alternative plan will need far less labor and storage resources.  Existing resources can be allocated to grid infrastructure to support renewable installation and vehicle electrification.  Vehicle electrification is the fastest way to improve GHG emissions.   Eliminating storage requirements will reduce battery demand and costs, making EV’s cheaper.

All is not Doom and Gloom

What can be done to reduce GHG emissions considering the state’s lack of financial resources and the lack of sufficient renewable generation for at least seven decades?  The following is a list of ten ideas that can be implemented relatively quickly that will help to rapidly lower GHG without breaking the piggy bank while also slowing or reversing the increase in utility bills

  1. Do not electrify buildings that run on natural gas – while it will reduce GHG at the building, it will increase it as much at the generating plants while forcing residents and the utilities to incur enormous rewiring costs. There will be no reduction in current fossil fuel energy, Column A in the New York Fossil Fuel Energy Load figure. Also, the gas stove analysis that was done recently was mathematically flawed and should not be used to set public policy.
  2. Focus heat pump efforts on locations that use oil heat or that use radiant electric heat. Those locations will see a significant reduction of GHG and heat pumps will reduce grid load when compared to radiant electric heat.
  3. Focus resources on expanding grid infrastructure. This will reduce the cost of installing solar in Upstate locations and reduce the number of system cancellations allowing the state to increase the proposed renewable generating resources, Column D in the New York Fossil Fuel Energy Load figure.
  4. Increasing grid infrastructure will also help with the installation of chargers for the electric vehicle wave that is about to arrive, with or without the state mandate.
  5. Do not install large amounts of battery storage until there is sufficient renewable generation to support the storage. It will increase current fossil fuel energy (Column A in the New York Fossil Fuel Energy Load figure) while incurring an enormous capital outlay and starving other projects of funding. They will also decay well before sufficient renewable generation is installed.
  6. Replace older generating plants with higher efficiency combined cycle natural gas generating plants. The state will need the energy to support the EV’s and the newer plants are far more efficient. It will lower Column A, reduce gas usage and put downward pressure on the commodity price.
  7. Place an emphasis on hydrogen injection into natural gas combustion plants. It will decrease gas usage and increase combustion temperatures which reduces NOx emissions and lowers current fossil fuel energy, Column A. It will greatly lower GHG emissions related to those generating plants
  8. Focus available natural gas resources on combined heat and power systems. It will reduce the utility bills for the system owners while also reducing requirements for grid infrastructure. Allow multiple building to form micro-grids to utilize the thermal output and increase the generation capacity. It will greatly reduce Column A
  9. Allow Micron Technolgies to build a combined cycle plant the size of Cricket Valley Energy Center on their property. The Micron facility will use more energy than the state of Vermont. Instead of letting them be “green” on paper by buying carbon credits, let them be green in reality with high efficiency generation and have lower energy costs to make them more competitive and able to recoup the $5 billion rebate without faking it. That will eliminate the increase in column a related to the facility.
  10. Figure out how the utilities can interconnect the 9 GW of offshore wind because at the moment, no one is certain how to do it. There is limited space for underwater cables. Without that, energy curtailments will occur and impede the increase of column d, unless they use the alternative idea which is to run transmission lines across Long Island.

Ellenbogen Conclusion

Ellenbogen Follow Up

The next day Ellenbogen followed up with another email with this warning.

In a speech to the British Parliament in 1948, Winston Churchill said, ‘Those who do not learn history are doomed to repeat it”.

As a conclusion to my email of yesterday, March 28, the following should serve as a warning to those proposing the current NY State Energy plan and expensive projects that are going to raise utility rates but do little for the environment. 

The statement above by Churchill not only applies to NY State following Germany’s failed energy program.  It also applies to something that happened just across Lake Ontario, much closer to home.

In 2009, Ontario, Canada passed the Green Energy Act.  Ontario has a similar population distribution to NY State with large population centers to the south and more rural areas to the north. Hardships were incurred by the more rural areas in the building of renewable generation and sending the energy to the wealthier, more densely populated southern areas.  In reading some articles on the subject, it was portrayed as a class war.   The act might have survived that issue, except energy costs skyrocketed along with the perceived injustices and the combination led to the repeal of the Act after only 10 years.   The Green Energy Act from 2009 is available here and an article documenting the repeal is here.

As I documented above, the state’s energy policies are going to cost trillions of dollars with far fewer carbon emission reductions than could otherwise be obtained at a far lower cost.  Hundreds of square miles of solar arrays and wind farms are going to have to be built in rural areas that are already exhibiting a substantial resistance to the projects.  The 2019 repeal of the act gave municipalities the right to control  what energy projects could be built within their borders, just the opposite of NY State’s proposed legislation.

The quest for the perfect will be anything but and the inevitable voter rebellion that is going to occur in the not-too-distant future is going to leave the state with massive debt, extremely high utility costs, and little to no GHG reduction to show for it.  In the interim, a decade will have passed where functional, inexpensive programs could be implemented that will actually reduce GHG in the real world, as opposed to the current program that only might work in Mark Zuckerberg’s fantasy Metaverse.  It certainly hasn’t worked in any cold climate on Earth where it has been tried.

Utility customers are already feeling enormous amounts of pain.  I have been receiving emails of late from politicians excoriating Con Ed for raising rates, however most of the increase is needed to comply with the mandates of the CLCPA.   The increases are due to terrible policy and not utility rate gouging.   As a clear example of how upside down this policy is, it actually has me defending Con Ed after they said some rather nasty things about me in a tariff hearing 12 years ago.  I have a long memory and no love for Con Ed but this energy policy is going to end up turning the state’s utilities into piñatas through no fault of their own. 

The utility rate increases are going to be far worse going forward as the costs documented in my email of yesterday are not figments of my imagination.  The plan will not be sustainable.  The state can’t borrow its way out of trillions of dollars of costs in an effort to subsidize utility rate payers to ease the pain that will be caused by this.

Beyond the actual costs, there is going to be a huge opportunity cost in terms of lost time imposed by the CLCPA that prevents working solutions from being executed, along with a souring of popular attitudes towards any future programs to reduce GHG. 

In their overreach for an unrealistic fantasy, they are going to achieve nothing.  Unfortunately, as bad as that is, that situation will be the best-case scenario.  The worst-case scenario will be that they continue to push forward, ignoring utility customers pain, still achieving no GHG reductions, while creating energy shortages that result in loss of life. 

The current energy policy has no long-term positive outcomes.

Caiazza Concluded Remarks

I could quibble with a few numbers and my take is slightly different for a few aspects but I am in complete agreement that this cannot possibly work.  The biggest flaw in the Hochul Administration’s net-zero transition plan is the lack of a feasibility analysis.  In 2018 I wrote the following.

We’re choosing between as yet undefined but surely expensive options trying to understand which one (or what mix) will be the least expensive. Unfortunately we don’t know but we need to start now because we’ve been told that we have to make reductions by 2030.  If we make a good pick then we’ll spend the least amount of a lot of money and will be left with the fewest negative outcomes, but if we get it wrong, we will be left with many more negative outcomes and even higher costs for a long time. 

Since then, the only thing I would change is that it is not just about the money, the possibility of catastrophic reliability outcomes must be considered because present wind, solar, and energy storage technology must be coupled with other ill-defined and speculative resources in order to work reliably.  Clearly the first step and priority should be a feasibility analysis before anymore time and money is spent on this. 

Other Voices on the Futility of the Climate Act

This blog post highlights an article and report that address New York’s  Climate Leadership & Community Protection Act (Climate Act).   I am highlighting them here because they make good points in ways that I think clearly show the futility of the Climate Act. 

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. 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.

Trying to Head Off New York’s Total Self-Destruction

Francis Menton writing at the Manhattan Contrarian blog wrote an excellent story about New York’s budget proposals that includes a section on energy policy.  He described the Empire Center’s just released Next New York report that offers “counter-proposals in the major policy areas: public safety, K-12 education, Medicaid and healthcare, energy, transportation and transit, housing, and so forth”.  

Menton’s article addressed energy policy. The energy section of the Next New York report, titled “Heading off New York’s Home-Made Energy Crisis,” begins at page 69, and was written by the Empire Center’s energy guru, James Hanley.  The following is a direct quote from the Menton’s article :

I guess it’s fair to say at this point that we do have an “energy crisis” in New York, but the key word is “home-made.” Everything about energy in New York that could remotely be called a “crisis” is entirely the creation of our politicians. There is no rational reason why energy policy should even be a significant political issue in New York. We have a perfectly good, functional energy system. By far the larger part of it — the non-electrified part, including nearly all transportation, industry, agriculture, and home heat outside the large cities — came into being through private initiative and works with little to no input or interference from politicians and bureaucrats. The other, smaller part — the electrified portion plus urban natural gas distribution — has historically been subject to substantial government regulation, but until quite recently the whole point of the regulation was only to prevent the monopoly utilities from raising their rates to a point of overcharging the customers.

Then our politicians got the idea that there was an imperative to address and solve “climate change” through the device of a politically-directed total re-do of the energy system into something that has never previously been tried nor proven to work. (Don’t get me started on the question of how a place like New York, with a fraction of 1% of world greenhouse gas emissions, is supposed to be able to affect “climate change” by using less fossil fuels, when the places that emit the large majority of world GHGs, like China and India, are adding new coal power plants as fast as they can build them.).

At pages 69-75 of the Report, Hanley provides a brief history of how this subject of reducing GHG emissions got a toe-hold in New York and then rapidly metastasized. Governors Pataki and Paterson began the game in the 90s and 00s, with things like a “renewable portfolio standard” and joining the Regional Greenhouse Gas Initiative (2005). Andrew Cuomo (first elected Governor in 2010) ramped things up by blocking fracking in the extensive Marcellus Shale that underlies a large part of the state, and by having his environmental bureaucrats block natural gas pipelines on bogus “water quality” concerns. But the full suppression of fossil fuels and the wind/solar mania did not really take full control in New York until 2019, when the progressive Democrats finally took both houses of the State Legislature. They used that control to pass something called the Climate Leadership and Community Protection Act (CLCPA), which was then signed by Cuomo.
Suddenly, we are on a crash program to get rid of all fossil fuels, electrify everything, and depend completely on the wind and sun for the generation of our energy. Hanley:

The CLCPA’s overarching goal is an 85 percent reduction in greenhouse gas emissions and a net-zero state economy by 2050. Intermediate steps on the way include 6,000 megawatts of installed solar and 185 trillion BTU savings in energy efficiency by 2025, 70 percent renewable energy production and 3,000 megawatts of battery storage by 2030, 9,000 megawatts of offshore wind production by 2035 and 100 percent zero-emissions electricity production by 2040.

I believe that I have used terms like “ridiculous,” “preposterous,” “incompetent,” and “irresponsible” to characterize the legally-mandated goals to which the CLCPA commits our state. Hanley is much more gentle in his use of words:

To say the CLCPA’s goals are ambitious is an understatement, and yet they will not be adequate to provide the state with sufficient clean energy to ensure the continuing reliability of the electrical grid.
One place where Hanley makes a real contribution to the debate is by producing a chart, based on data from the federal Energy Information Administration and Department of Energy, that makes the absurdity of the CLCPA goals apparent:

In the eleven years from 2010 to 2020, the percent of New York’s electricity coming from “renewables” inched up from about 22% to about 28%. But most of that 6% increase came from that blue line, “hydro,” aka almost entirely the Niagara Falls power plant, going from about 18% to about 22% of state electricity production. Meanwhile, in that 11 year period when everyone was starting to obsess about wind and solar and federal subsidies ramped up dramatically, the percent of electricity from wind (the orange line near the bottom of the graph) went all the way from about 2% to about 4%. And the percent from solar remained a barely-perceptible 1% or so, represented by a gray line that is so close to the x-axis of the graph that you can barely see it next to the brown line representing wood.

And then supposedly the percent of electricity from renewables takes off like the blade of a hockey stick in 2020 and gets to 70% by 2030. Unmentioned is that we don’t have another Niagara Falls. Therefore this whole increase now has to come from wind and solar. Oh, and we’re already two years in since the data in Hanley’s graph. How much of this has happened so far? Almost none.

Meanwhile the consumption of electricity is supposedly going to double or so, due to the electrification of automobiles and home heating.

I’ll throw in a few figures from research of my own to further illustrate the absurdity. According to EIA data here, New York’s electricity consumption in 2021 was 141,423,778 MWh. If that doubles from electrification of automobiles and heating, then we’ll need about 280 million MWh in a year. Per Hanley’s summary of the CLCPA above, the state authorities are calling for adding 6000 MW of solar and 9000 MW of offshore wind by 2035. At highly optimistic capacity factors of 25% for solar and 40% for wind, here’s what that will get you:

6000 x 0.25 x 8760 + 9000 x 0.40 x 8760 = 44,676,000 MWh

In other words, as ambitious as the plans for wind and solar may be, even if all gets built this will provide less than a sixth of the electricity that will be needed. And with wind and solar generation, such electricity as gets generated will come at random times that could include long weeks of no wind and almost no sun in the dead of winter.

But meanwhile they are proceeding apace to shut down the existing natural gas capacity.

Hanley concludes his section of the Report with a series of highly sensible recommendations, like ending the fracking ban, ending the pipeline moratorium, and scaling back renewable energy subsidies and tax credits. I actually think we will likely be better off going full speed ahead on the innumerate nonsense and running hard into the green energy wall.

Conclusion

The demand that we do something as quickly as possible does not square with reality. New York GHG emissions are less than one half a percent of global GHG emissions and global GHG emissions have been increasing by more than one half a percent per year.  Anything we do will be replaced by global GHG emission increases in less than a year.  That does not mean that we should not do something but it does mean that we should take the time to do “something” that it does not do more harm than good. Menton and Hanley show that the proposed implementation timeframe is extraordinarily risky and unlikely.  Their concerns must be addressed or the reliability and affordability of New York electricity will be unacceptably at risk.

The demand for compliance certainty inherent in the cap and invest proposed plan exacerbates the risks and impacts. In my last post on the cap and invest program proposal I noted that developing sufficient zero-emissions renewable energy to displace enough fossil-fired electric generation to meet the mandated emissions targets would be a challenge.  Both Hanley and Menton clearly show that the expectation that New York State can convert the electric energy system to meet the 2030 goal of 70% renewable energy is a dream and that meeting the emissions targets is a stretch.  Of particular concern is that the cap and invest approach includes penalties when those targets are not met.  Affected sources are going to err on the side of caution relative to their compliance obligations.  These results and that outlook increase the chance of an artificial energy shortage.

New York Independent System Operator Information for Policy Makers

I have published three previous articles about New York Independent System Operator (NYISO) analyses related to New York’s Climate Leadership and Community Protection Act (Climate Act).  This post describes their new webpage that summarizes their activities “to design and implement the operations, planning and market enhancements necessary for the grid in transition.”  It does a good job explaining some of the issues associated with a net-zero transition.  The only thing left is to get New York policy makers to listen.

This is another article about the Climate Act implementation plan that I have written because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

The implementation plan for New York’s Climate Act “Net Zero” target (85% reduction and 15% offset of emissions) by 2050 is underway.  At the end of 2022 the Climate Action Council completed a Scoping Plan that makes recommends strategies to meet the targets.   The Hochul Administration is developing regulations and proposing legislation to respond to those recommendations in 2023.

Unfortunately, the Scoping Plan is just a conglomeration of control strategies that are projected to provide the emission reductions required.  The Plan did not do any feasibility analyses or address any “what if” questions raised by the NYISO.  I have written three posts that described issues raised by NYISO,  The first post (New York Climate Act: Is Anyone Listening to the Experts?) described the NYISO 2021-2030 Comprehensive Reliability Plan (CRP) report (appendices).  The difficulties raised in the report are so large that I raised the question whether any policy maker in New York was listening to this expert opinion.  The second post (New York Climate Act: What the Experts are Saying Now) highlighted results shown in a draft presentation for the 2021-2040 System & Resource Outlook that all but admitted meeting the net-zero goals of the Climate Act are impossible on the mandated schedule.  The third article described the final version of the 2021-2040 System & Resource Outlook.  It shows that in order to minimize the storage and renewable over-build requirements that a Dispatchable Emissions-Free Resource (DEFR) is needed but goes on to point out that DEFRs such as hydrogen, renewable natural gas, and small modular nuclear reactors are not commercially viable today. “DEFRs will require committed public and private investment in research and development efforts to identify the most efficient and cost-effective technologies with a view towards the development and eventual adoption of commercially viable resources.” 

The NYISO oversees system reliability and the competitive electric market in New York.  They are responsible for “keeping the lights on for New Yorkers by managing today’s energy flows and by planning the grid far into the future.”  Frankly, with regards to the Climate Act transition they are in a very difficult position because New York’s Climate Act was written by climate activists who had a very poor understanding of the challenges of a transition to a zero-emissions grid.  There are two options for the future.  If the State comes to its senses and takes the work done by the NYISO to heart and chooses a path consistent with their recommendations, then NYISO will be characterized as obstructionists who just don’t understand that academics know better than anyone in the industry.  If the State ignores their warnings and there is a catastrophic blackout, then they will be blamed for improperly implementing the vision of the academics.  Either way they will be scapegoats.

Information for Policy Makers

The new website (pdf copy) is obviously designed to try to explain the complexities of electric system operations and planning for a non-technical audience.  The documentation has three main sections: “Planning for Reliability”, “Wholesale Electric Markets”, and “Our Independence and Transparency”.  Because the information is a useful overview, I will summarize each section below.

The Planning for Reliability section explains that the NYISO is responsible not only for the real-time matching of generation with load operations for the electric system, but also “planning far into the future to make sure the electric system and its interrelated components can meet customer demand.”   The introduction concludes: “The acceleration of New York’s transition to a zero-emission grid is creating a system of new, intermittent generation, which benefits the environment but can make it more challenging to keep the system reliable.”  So how does the website describe the challenges?

They explain that wind and solar are not dispatchable resources and are intermittent so energy storage is needed.  They point out that the current energy technology is limited.  The website goes on to explain:

The grid will always need sufficient flexible and dispatchable resources to balance variations in wind and solar resource output. These resources need to be long-duration, dispatchable, and emission-free.  Essentially, they must have the attributes of fossil generators (responding quickly to rapid system changes) without the emissions. Such resources are not currently commercially available and may not be for many years.

This is a wind-up to make the point that:

The retirement of fossil-based resources is outpacing the development of new renewable-based resources and other dispatchable, emissions-free resources. The effect is that reliability margins will thin to concerning levels beginning in 2023, highlighting the need for a careful transition that maintains grid reliability and resilience.

 I am a bit disappointed with this description.  In order to really emphasize the risk involved it is necessary to understand the current reliability standards are the result of decades of experience and evaluation.  The resulting standards have done a good job preventing blackouts.  However, in the future there are potential issues because the standards are based on the presumption that the system is static.  The unprecedented introduction of significant amounts of new intermittent and non-dispatchable resources changes things a lot.  I don’t think this discussion explains how much riskier planning is becoming as a result.

This section also points out the importance of transmission.  The fact is that New York City will never be able to produce enough electricity from in-City wind and solar so the power necessary will have to be transmitted from elsewhere.  They are constraints on this transmission regionally and also locally where upgrades are needed to get the power from newly developed wind and solar projects.  The website explains the transmission planning process and concludes: “A historic level of investment in the transmission system is currently underway, with projects that will deliver more clean energy to consumers while enhancing grid resilience and reliability”. 

The website raises a little discussed aspect of the transition process.  There is an interconnection procedure where the NYISIO determines if a proposed new resource will have reliability issues and whether transmission system upgrades are needed to address them.  The website brags about the transparency of their process but does not bring up another uncertainty.  In particular, the interconnection hardware for intermittent resources must be able to differentiate between power fluctuations caused by variable wind, for example, and transient power changes in the grid.  If they don’t handle this correctly problems ensue.  For example, the 2022 Odessa Texas disturbance illustrates the “need for immediate industry action to ensure reliable operation of the bulk power system with the ever-increasing penetrations of inverter-based resources”.

This section of the website concludes with a description of the planning process and “NYISO’s role in identifying system needs, and finding solutions, is part of the process of planning for the grid of the future.”

The next section, Wholesale Electric Markets, gives an overview of competitive wholesale electric markets.  It is not surprising that they extoll the virtues of market-based solutions including consumer benefits because that is the basis for their existence.  Nevertheless, it also is a useful overview of how the markets work. 

In order to match the generation with the load the NYISO has three markets: the energy market, ancillary service market, and capacity market. 

These three markets work together. In simple terms:

  • Energy markets secure resources to supply the demand on a minute-to-minute basis.
  • Ancillary service markets procure a variety of additional services to protect the electric system and balance supply and demand to meet system needs instantaneously.
  • Capacity markets provide incentives to generation resources to maintain additional energy reserves over a longer period. Through the capacity market, we determine how much capacity is needed to meet the expected peak demand for the year plus a margin of additional resources to call on, if necessary.

According to the NYISO website the wholesale market can support New York’s Climate Act goals. It states:

Competitive, wholesale markets can help with the transition to a zero-emission grid by sending the right economic signals to developers to invest in new technologies in the right geographic area to best serve the grid. These markets leverage competition to keep electricity as cost-effective and efficient for New Yorkers as possible, and to help make sure there are adequate resources in place in the future.

I disagree with the implication of the statements that “Competitive markets have over time created pressure on the generating fleet to switch to newer, more efficient generation plants” and “Since 2000, electric generators that primarily combust natural gas increased from less than 50% to more than 60% of the generating capacity in the state”.   This is the same argument that proponents of the Regional Greenhouse Gas Initiative make when they argue that emissions have come down significantly and insinuate that the emissions trading system was a primary factor in the emission reductions.  The price of natural gas came down so much relative to other fuels that the generating fleet would have switched to newer, more efficient generating plants with or without the RGGI program. I believe that the conversions would have happened even without competitive markets.

I am disappointed with the following explanation how the market can support the Climate Act:

Additionally, the NYISO has implemented market enhancements to support climate goals and to position the NYISO as a national leader in competitive wholesale electricity markets. Through engagement with stakeholders and regulators, new market rules for energy storage integration, participation in our wholesale electricity markets by distributed energy resources, and new ancillary services products support reliability and minimize costs for consumers. Market rules that incentivize investment in resources that can respond rapidly to changing conditions will be essential for maintaining reliability of the grid of the future.

In my opinion, the transformation of the electric system that was built up over decades using dispatchable synchronous generating resources into a system that relies on a significant amount of intermittent, asynchronous generating resources is an enormous challenge.  NYISO planners have to not only attempt to anticipate all the effects of all these changes to the electric grid but also try to design market rules that provide the resources needed.  The addition of the market component should have been highlighted as a significant additional challenge to get a system that works.

The final portion of this section discussed electricity prices in the NYISO region.

The Our Independence and Transparency section explains how the NYISO was formed and how it operates.  It provides a concise overview of the regulatory and reliability organization oversight requirements for any independent system operator.  There is a description of the governance policies and budgeting.

They also emphasize their independence but there is some backstory here.  At one point in the previous Mario Cuomo Administration, the current chairman of the New York State Energy Research & Development Authority, Richard Kauffman was Cuomo’s energy czar.  In a filing to the Public Service Commission, the NYISO noted that in order to meet Cuomo’s Clean Energy Standard, a predecessor regulation to the Climate Act, New York would have to install over 1,000 new miles of bulk transmission lines at great cost and effort.  In response, , Richard Kauffman, accused NYISO Director Brad Jones and his NYISO report as “misleading, incomplete, and grossly inaccurate…revealing an alarming lack of developed analysis into the imperative to address climate change…” Kauffman’s letter accused Jones of protecting fossil fuel generators and said that he was “dismayed by [Jones’] public comments. Not long after that Jones left and ever since comments have been much more guarded.  Kaufmann also authored a commentary for The Hill  about a “carbon bubble” that claimed that government intervention will be necessary if the market response to climate change is delayed too long.  In this political climate it is not surprising that all NYISO planning reports are carefully worded to not antagonize the Administration. In my opinion, however, the Administration needs to hear the unvarnished truth.

Discussion

The title for this webpage says it is information for policy makers.  New York climate policy is driven by the Climate Act’s Climate Action Council.  That body consists of 22 members that were chosen by ideology not expertise. Their contribution to the Climate Act implementation was the Scoping Plan that was approved last December.  The Council only paid lip service to any pretense of addressing reliability concerns with the NYISO so even if this document had been available at the start of the Scoping Plan development process I doubt that the majority of the members would have read it, much less acted on the recommendations.

This year the Hochul Administration is pushing to implement the recommendations of the Scoping Plan either by new legislation or by proposing new regulations.   When pressed about the lack of feasibility analyses in the Scoping Plan the Climate Action Council has said those concerns would be addressed in the regulatory process.  I imagine the policy makers who are responsible for the new legislation and regulations are the target audience.  Unfortunately, I fear their minds are already made up and the issues raised here will be ignored.

The summary for policy makers has several key messages that New York policy makers need to consider as they develop legislation and regulations.  The state should not shutdown existing fossil-fuel generators until sufficient clean energy resource are available.  A new resource is needed but is not ready for use and may not be available for “many” years so an emphasis on developing that resource must be a priority.   Because New York’s fossil resources are retiring faster than new resources are coming on line there already are concerns about the reliability margin. Unprecedented upgrades to the transmission system will be required to get the power from wind and solar projects to New York City where it is needed the most.

Conclusion

I think this is a very useful overview of policy issues that the NYISO is considering relative to the implementation of the Climate Act.  However, I am not optimistic that the target audience will consider these issues as implementation proceeds.  In the political climate of Albany it is not clear how to get policy makers to consider the risks of ignoring the issues raised.

Here is What New York Climate Activists Want

Gov. Kathy Hochul’s proposed budget for fiscal year 2024 includes billions of dollars for climate-related funding but climate activists are not satisfied.  This post highlights things they want to implement in the Climate Leadership and Community Protection Act  (Climate Act).  I also want to point out that these are only the acknowledged parts of the funding because there are major costs buried in the utility costs that won’t be counted by the Governor.

This is another article about the Climate Act implementation plan that I have written 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.

Governor Hochul’s Executive Budget Climate Act – Funding

The impetus for this post was an article in the Gothamist titled Gov. Hochul’s state budget prioritizes climate fixes — but will it be enough?  The introduction states:

Even with its billions of dollars in climate-related funding, policy experts said Gov. Kathy Hochul’s proposed budget for fiscal year 2024 needs more vigor to meet the urgency of the climate emergency.

The article mentioned that the budget package includes specific items that will add costs.  There is a proposal for a cap and invest program. To my knowledge the Hochul Administration has not admitted how much this is expected to cost.  The Executive Budget would also add 231 new staff positions at the DEC to enact and enforce regulations for climate laws.  The article notes that “The budget is sprinkled with incentives such as $200 million to start EmPower Plus, a program from the state’s energy research and development authority that will provide 200,000 low-income residents with free energy-efficiency solutions for their homes, such as insulation, electrification and energy-saving appliances.”  I was not surprised by the statement in the introductory paragraph because I think costs will be enormous.

What did catch my attention were the comments by Julie Tighe, president of the New York League of Conservation Voters.   “We know ultimately it’s going to take a lot more money to do that,” Tighe said. “It’s a good down payment to make sure that we’re starting to take action and helping people who are least able to afford it.”  I want readers to know her vision:

The governor’s budget also includes big-ticket items like more than $9 billion for mass transit improvements, a historic amount that’s 10% more than last year. But the state continues to invest record amounts on infrastructure for modes of transportation that are responsible for 28% of the state’s greenhouse gas emissions, such as roads and bridges. Tighe contends that massive counterinvestments are needed to get New Yorkers to stop driving and use cleaner forms of transportation that are also affordable and viable alternatives.

“We can’t drive our way out of the climate crisis,” Tighe said. “We need people to take mass transit. We need people to be taking e-bikes and walking more and using regular bikes.”

An organization that is located at 30 Broad Street in New York City has mass transit options.  For those of us that live in upstate New York public transit options are limited and e-bikes, walking and regular bikes are not a credible option in the winter even if there are no distance limitations. 

It has been educational to watch the gas ban messaging unfold.  The Gothamist explains:

The executive budget, for example, features a controversial gas ban for new buildings, except it doesn’t go as far as some state legislators and environmental experts think it could. The All-Electric Building Act — a state bill currently stalled in the Senate’s finance committee — would prohibit the use of fossil fuels in newly constructed buildings and require those structures to rely completely on the electrical grid on a faster timeline than the governor is recommending.

Hochul’s version also comes with many exemptions and later deadlines for switching from gas to electric in homes and buildings. Buildings are the state’s largest climate polluters, responsible for 32% of total greenhouse gas emissions. Experts have called the electrification of buildings “low-hanging fruit” when it comes to making an impact in mitigating global warming.

That sums up the climate activist position.  But the reality is that they are a small, albeit loud, constituency. I suspect that the majority of those currently using gas want to continue using it.  In response to concerns raised by those folks, there also has been a flurry of news articles worried that “misinformation is spreading about Governor Kathy Hochul’s plans with a phase-out of fossil fuel systems.”  James Hanley eviscerates the Administration response to the gas stove ban:

As the old Marx Brothers joke goes, “Who are you going to believe, me or your own eyes?”

Doreen Harris, president and CEO of the New York State Energy Research and Development Authority,  told lawmakers that she was setting the record straight, and that “We are not taking away gas stoves, as one example of perhaps misinformation we need to correct.”

But the Climate Action Council that she Co-Chaired produced a Climate Leadership and Community Protection Act (CLCPA)  Scoping Plan – which she voted to approve – that says the state will in fact be taking away gas stoves.

It’s right there on page 190, in the chapter on buildings, for all the world to read.

So where’s the misinformation?

Indeed, where is the misinformation?  My position is that much of the misinformation is coming from the Hochul Administration.  Most of this is political gamesmanship where the exact wording of the legislative or regulatory proposal allows some wiggle room when confronted with an inconvenient question.  In the instance of the gas stove ban she falls back on claiming that she only wants to ban gas in new homes and moves on before the Scoping Plan reference can be brought up.  The biggest item of the Administration’s overt misinformation is the ultimate cost to get to the Climate Act target of net-zero by 2050.  The Administration claim in the Scoping Plan is that the “costs of inaction are more than the costs of action”.  Aside from the biases and exaggerations of the alleged benefits, the official line consistently ignores the caveat that the Scoping Plan costs only include the costs of the Climate Act itself and not the costs of “already implemented” programs that are necessary to get to net-zero by 2050.  The already implemented programs include the following:

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

Needless to say when the costs of these programs are added to the Climate Act program costs, the costs of the actions necessary to get to the Climate Act net-zero by 2050 target far exceed the costs of inaction.  Nonetheless, the climate activists want more funding:

“The governor’s budget proposal is lacking when it comes to ambitious climate funding,” said Elizabeth Moran, a New York policy advocate with EarthJustice, a nonprofit public interest environmental law organization. “There’s some funding there, but it’s far from what we know is needed.”

Governor Hochul’s Executive Budget – Buildings

The Gothamist article describes proposed policies for buildings:

When it comes to carbon emissions from buildings, Hochul has planted some long-awaited policies in her budget, including a mandate for all-electric new construction that includes a few exemptions, such as commercial kitchens.

But the timeline is delayed relative to other state proposals and some local laws. For smaller buildings, Hochul’s plan would take effect in 2026. That differs from the All-Electric Building Act, which calls for the electrification of new smaller buildings by 2024. Likewise, New York City’s Local Law 97 wants to electrify any new building larger than 25,000 square feet by next year.

Hochul’s plan would delay this regulation for new commercial buildings until 2029. The All-Electric Building Act calls for implementation by July 2027. Facilities such as laundromats and hospitals would not be required to comply. Fossil fuels will continue to be used in backup generators.

I am opposed to any “all-electric” legislation or regulation because of safety: what happens when there is an extended electric outage?  The article notes that the Adminstration tries to get around this by saying “fossil fuels will contine to be used in backup generators”.  What is the percentage of fossil fuel sales for backup gnerators sold by suppliers?  My guess is that it is a small fraction, at most 10%, of their sales.  Is there any scenario where those suppliers will be able to remain viable when they lose 90% of their business?

Another example of the desires of climate activists is an accelerated schedule.  It can be argued that the state’s leading climate activist is Robert W. Howarth, Ph.D., the David R. Atkinson Professor of Ecology & Environmental Biology at Cornell University.  In his statement supporting his vote to approve the Scoping Plan, he reiterated his claim that he played a key role in the drafting of the Climate Act, developed the irrational methane requirements, and credited one politician for getting the Act passed. The article noted his desire and others that the phase-in should speed up:

Dr. Robert Howarth, a member of the Climate Action Council, said there is no reason to wait to require electric appliances in new construction, especially when they will have to be replaced in the case of heating and hot water, when laws take effect. Howarth said following the new regulations could save homeowners money in the long run while also cutting emissions faster. More than a third of building emissions come directly from natural gas use in cooking, heating and hot water. And a year does make a difference when the total leaks nationwide from turned-off gas stoves add up to the annual carbon dioxide emissions from half a million cars.

To speed up the transition, more incentives and assistance for homeowners in the budget could go a long way, said Dr. Gernot Wagner, a climate economist at Columbia Business School. Even homeowners who don’t qualify may also switch to electric as a result of wider adoption. The proposed $200 million for the EmPower program is a drop in the bucket when there are more than 7.5 million households in the state, and Tighe said assistance is needed for other homeowners, even large building owners, especially since New York is the country’s No. 1 user of heating oil.

Under Hochul’s proposal, new buildings can’t have cooking appliances that use fossil fuels such as natural gas. Existing buildings won’t be required to swap their gas stoves for electric models, even when purchasing replacements. By 2030, the governor would ban fossil fuel-powered heating or hot water equipment in homes.

The author of this article did not pick up on the fact that the Scoping Plan recommends that existing buildings will have to replace any fossil-fired appliance with an electric appliance starting in 2035.  By then it will be somebody else’s problem and Hochul will be long gone.

Governor Hochul’s Executive Budget – Energy

The Gothamist article discussed two aspects of the electric energy system.  Apparently because there isn’t enough interest by the private sector to build the infrastructure necessary for the net-zero transition, the Executive Budget proposed letting the public power operator get involved:

The Hochul is empowering the New York Power Authority to develop, finance, construct, own, operate and maintain renewable energy projects. This move will ensure that enough zero-emissions power sources are built. The governor is calling for the phaseout of electricity production from gas-fired peaker plants by 2035, and wants to support the training of a green power workforce.

The private sector and customers have traditionally shouldered the cost of renewable energy projects. They’re handled outside of the budget, mostly through renewable energy credits.

I have no opinion on the value of this approach but picking and choosing when the State depends on the market for electricity supply seems to be a slippery slope.  The other aspect concerns transmission projects:

“The state budget does not include funding for transmission infrastructure,” said Jason Gough, deputy communications director for the governor’s office. “Utilities typically pay for the cost of power infrastructure, including transmission lines. These costs are passed to utility ratepayers through the delivery charge for electric service.”

Let me translate Gough’s comments. “These costs are passed to utility ratepayers through the delivery charge for electric service” means “The costs of the Administration’s policies that we won’t let the utility companies itemize for their ratepayers, are passed on so that the ratepayers will vent their anger at the utility companies rather than the Administration”.  The next press release will say “The utility bill increase is not our fault, it is greedy industry’s fault.”

The article goes on:

But transmission lines and other infrastructure are needed to bring clean power to the downstate grid, which is mostly dependent on fossil fuels. New York City doesn’t have the space, Tighe said, to build enough solar and wind power. The absence of direct funding for this key infrastructure could hinder the city in reaching its goal of a zero-emission grid.

“New York City needs a lot more power lines going toward the city in order to enable the sort of clean energy transition, the rapid transition that is necessary now,” Wagner said. “Transmission is the biggest bottleneck to decarbonize New York state.”

Several days ago, I wrote about the hidden costs for this infrastructure.  The New York Public Services Commission recently approved rate increases for this purpose in case 20-E-0197.  The transmission upgrade projects will cost $4.4 billion to support 3.5 GW of renewable energy or $1.26 billion per GW. An additional 2.8 GW is expected by 2025 and another 4.1 GW by 2030 according to Scenario 2 of the Scoping Plan.  At that rate, ratepayers will be on the hook for a total of $13.05 billion through 2030.  It is disappointing to me that Upstate ratepayers are on the hook for bill impacts up to and exceeding twice the bill impacts of Con Ed ratepayers who need Upstate power to reach the goal of a zero-emission grid.  If the Hochul Administration would stop pandering to her political base and have the courage to be responsible for these costs then they should be spread equitably over all the state. 

Governor Hochul’s Executive Budget – Transportation

The Gothamist article describes proposed policies for transportation:

Public transportation will receive a big boost in the proposed budget. The MTA could get around $8 billion, a 10% increase. The funds will address the revenue deficit incurred as a result of a drop in ridership during the pandemic. But Moran said additional financial support is needed for faster fleet electrification, and more of it.

For individual vehicle electrification, the DOT expects to receive $175 million from the federal government as part of the Infrastructure Investment and Jobs Act over the next five years to build fast charging stations along New York’s interstate highways.

Hochul has also included congestion pricing as a revenue stream to help fund the ailing transportation authority. Tighe applauded the measure as a “good incentive for people to stop driving in Manhattan.”

The governor’s proposal also wants to fund mass transit outside of New York City. It includes nearly $1 billion for non-MTA public transportation, including some bus electrification and rehabilitation of upstate light rail.

Affordability is important in making public transportation a viable alternative to driving, Tighe said.

As noted previously, climate activists are big proponents of public transit.  Unfortunately, that is only a solution in urban areas.  None of these proposals benefit rural Upstate New York.

Cleaner modes of transportation require more funding to substantially reduce emissions, Wagner said. New bike lanes and the expansion of car-free pedestrian areas would make an impact on reaching goals and encourage these commuting modes, he added. The budget proposal doesn’t specify how much money will go to these environmentally friendly travel alternatives, and there are no direct amounts either. But these projects can be funded through the state DOT’s small umbrella programs such as the Transportation Alternatives Program and clean air funding initiatives.

Other climate activist strategy favorites are bike lanes and pedestrian areas.  One of the issues with these green solutions is that they don’t work all the time but the activists demand complete compliance.  In the winter bike lanes in many parts of the state are dangerous and pedestrian areas challenging.  Winter is also a reason that many Upstaters are reluctant to depend completely on battery electric vehicles. 

“Is this [budget] going to set us on a completely different path commensurate with the challenge? No,” said Wagner. “It is doing a lot of good things. Not to be ungrateful, but I thought we all recognized that we are in a climate crisis here.”

New York’s Greenhouse Gas (GHG) emissions are less than one half one percent of global emissions and since 1990 global GHG emissions have increased by more than one half a percent per year.  That does not mean that we should not do something but it does mean that even if there is a climate crisis New York cannot do anything about it alone.  We must make sure that we are not doing more harm than good with the net-zero implementation.

Discussion

This is just a part of the legislative initiatives to meet the Climate Act targets.  There are many member items also up for consideration.  In addition, there are also regulatory initiatives.  For example, the Department of Environmental Conservation is promulgating Part 218: Advanced Clean Cars II (ACC II) as part of the reckless push for all electric transportation.  The emergency/proposed rulemaking will incorporate the State of California’s Advanced Clean Cars II (ACC II) regulation into New York’s existing rules. 

My overarching problem with all these initiatives to meet the recommendations of the Scoping Plan is that the Integration Analysis that provided the background for the Plan did not include a feasibility analysis.  The Integration Analysis is simply a list of potential control strategies with estimated emission reductions that when combined together provide the controlled emissions appropriate for the emission targets.  There was no consideration of “what if and how about” questions like how are all the people who live in homes that have to park on the street going to be able to charge their cars?  What if the magical solution necessary to keep the lights on called dispatchable emissions-free resources is not available on the schedule of the Climate Act.  The Hochul Administration has not given consumers the expected costs or addressed the question what happens after everything is electrified and there is an ice storm.

Consider the feasibility of just one control strategy component.  The article notes that NYSDOT expects funding of $175 million from the federal government as part of the Infrastructure Investment and Jobs Act over the next five years to build fast charging stations along New York’s interstate highways..  A gas station fuel pump costs about $20,000 and can serve a customer in less than six minutes. A 50-kilowatt fast DC charger costs about $100,000 and can serve an EV customer in about 30 minutes. The gas pump can serve five times as many customers for one-fifth of the capital cost of a high-speed charger.  Think about the feasibility issues.  The $175 million can only fund 1,750 fast chargers.  The closest NYS Thruway service center to my home has ten automotive fuel pumps but is a small service center.  Consider what would be needed to maintain the same level of refueling capacity.  The service center would need 50 charging stations to provide the same amount of refueling capacity and I suspect that would blow through the $175 million for the 27 service centers on the NYS Thruway.  The space available and energy needed for those chargers means physical upgrades are needed at the service centers.  Throw in the fact that for a long time it will be necessary to provide gasoline too.  Finally, the NYS Thruway is just under 500 miles and the total NYS interstate mileage is 1730 miles so the $175 million would provide recharging support for less than half the interstate mileage.  The implementation logistics for this component of the electric vehicle requirement appear unrealistics so the onus should be on the State to prove that this can work.  They have not done this for any of the control strategies included in the Scoping Plan.

If any reader has concerns similar to mine, I encourage you to contact your elected officials and demand answers to these “what if” and “how about” questions before they vote on or support any legislation related to the Climate Act.  There are opportunities to comment on regulations.  A virtual hearing is scheduled for March 1, 2023 at 1 pm for Part 218: Advanced Clean Cars II (ACC II).  The comment deadline is 5 pm, Monday, March 6, 2023. Written comments may be submitted to NYSDEC, 625 Broadway, Albany, NY 12233-3254, ATTN: James Clyne, P.E., or by e-mail to air.regs@dec.ny.gov.

Conclusion

Climate activists like Robert Howarth and Julie Tighe are pushing the state down a road towards a canyon without a bridge.  Howarth’s arguments that Mark Jacobson’s academic analysis of wind, water, and solar energy is proof that a net-zero transition is cost-effective and possible is misplaced.  The reality is that the Climate Act is promoting a system with less stability, robustness, and reliability that will undoubtedly raise costs a lot. 

It is not only the disconnect relative to technical limitations but the attitude of the activists that disappoints.  Tighe said: “We can’t drive our way out of the climate crisis” relegating everyone in the State who must rely on driving because they have no viable alternative to second class citizenship. This is no less demeaning than Marie Antoinette’s infamous “Let them eat cake”.  Unfortunately, it can only get worse.  Now there are climate scientists who are arguing for rationing to fight climate change. 

If the Hochual Administration wants to solve their alleged climate crisis then they have to come up with a solution that provides the developing world with the prosperity and quality of life that comes with abundant and cheap energy.  It is immoral to deny them that right because the best adaptation strategies for extereme weather require prosperous societies.  The onus is on New York to provide them with affordable emissions-free energy technology or get out of the way.  At home, the only means left to avoid the Climate Act stampede that will destroy our existing reliable and affordable energy system is to speak up now and vote anyone who supports this out of office before the we go over the cliff.

New York State GHG Emissions Update

The Climate Leadership and Community Protection Act (Climate Act) includes a target for a 40% reduction of greenhouse gas (GHG) emissions from 1990 levels by 2030.  This post describes the latest New York State (NYS) GHG emission inventories and some implications.

This is another article about Climate Act implementation activities that I have written 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.

NYS Electric Generating Unit Emissions

According to the Environmental Protection Agency (EPA): “Emissions trading, sometimes referred to as ‘cap and trade’ or ‘allowance trading,’ is an approach to reducing pollution that has been used successfully to protect human health and the environment.”  One of the requirements for such a program is a monitoring system that consistently and accurately measures the emissions.  NYS electric generating units are in different emissions trading systems and have developed an accurate measuring system that relies on continuous emissions monitoring systems that record pollution levels that are reported to EPA. 

The only GHG monitored and reported to EPA is CO2.  In 2022 the units that report to EPA emitted 30.7 million short tons.  The NYS GHG inventory reports emissions as million metric tons and the 2022 emissions were 27.8 million metric tons.  As shown in the following table NYS emissions had been trending down until 2019 as generation from coal and oil was displaced by generation from natural gas.  The last three years the effect of the shutdown of the Indian Point nuclear generating station and the loss of its zero-emissions capacity have become evident.  Since 2019 CO2 emissions have increased 5.8 million tons or 23%.

NYS GHG Emissions

At the end of 2022 the New York State Department of Environmental Conservation (DEC) released the 2022 statewide GHG emissions report (2022 GHG Report).  I published an overview post of this greenhouse gas (GHG) inventory last year that described the games played using that inventory to “prove” that there are societal benefits for the emission reduction programs needed to meet the Climate Act targets. 

New York State greenhouse gas (GHG) emissions accounting it includes upstream emissions and is biased against methane.  Obviously if upstream emissions are included then the total increases but at the same time it makes the inventory incompatible with everybody else’s inventory.  There are two methane effects.  Global warming potential (GWP) weighs the radiative forcing of a gas against that of carbon dioxide over a specified time frame so that it is possible to compare the effects of different gases.  The values used by New York are compare the effect on a molecular basis not on the basis of the gases in the atmosphere so the numbers are biased.  Almost all jurisdictions use a 100-year GWP time horizon but the Climate Act mandates the use of the 20-year GWP which increases carbon dioxide equivalent values.  In addition, I believe the State is using higher emission estimates for methane production, transport, and processing.  As a result, NY GHG emission inventory estimates are nearly double values determined by other jurisdictions.

The 2022 GHG Report includes the following documents:

In order to calculate all the emissions in New York and estimate the upstream emissions it took DEC, the New York State Energy Research & Development Authority (NYSERDA) and consultants two years to produce the reports.  This article is concerned only with electricity generation especially as it relates to overall emission trends and emissions data could be used for a market-based control program. 

2020 GHG Emissions

Table ES.2 in the Summary Report presents emissions for different sectors.  Electric generation emissions are listed as electric power fuel combustion, imported electricity, and as part of imported fossil fuels.  In 2020, GHG gas emissions from electric power fuel combustion totaled 22.12 million metric tons of carbon dioxide equivalent (mmt CO2e) using a 20-year global warming potential.  Imported electricity totaled 7.81 mmt CO2e.  Fuel combustion and imported electricity emissions were primarily CO2.  The Table ES.2 imported fossil fuel value shown covers all fossil fuel used in other sectors.  I found another source that breaks out the electric upstream emissions that I used to calculate emissions.

When I first started looking at the electric sector numbers, I compared the State numbers to the emissions reported by the generating companies to EPA.  The reported 2020 EPA numbers were 24.4 mmt CO2e but the 2022 GHG Report electric sector emissions were 52.3 mmt CO2e.  The 2022 GHG Report Sectoral Report 1: Energy chapter on electricity generation does not provide much detail but references a NYSERDA report: Technical Documentation: Estimating Energy Sector Greenhouse Gas Emissions Under New York State’s Climate Leadership and Community Protection Act that does provide details.  I provide more details on the calculation methodology here.  The following table combines Table 28 electric sector emissions by fuel type in that document with EPA Clean Air Markets Division emissions data.  In Table ES.2 above the total imported fossil fuel emissions in 2020 were 94.08 mmt CO2e and in the NYSERDA technical documentation the upstream emissions are 21.7 mmt CO2e.  New York’s biased accounting methodology doubles electric sector emissions from the emissions reported to EPA.  The claim that upstream emissions are on the order of direct emissions is not credible.

NYS GHG Emissions Data

The 2020 GHG Report includes a sectoral report covering the energy sector.   The results section notes:

The most significant emission reduction in this report was the decrease in fuel combustion emissions in the electricity sector from 1990 to current by over 60%. This is related to the transition away from fuels with higher combustion emissions to those with lower combustion emissions; as natural gas usage has increased, the use of coal and petroleum fuels such as residual fuel oil has declined. As described in NYSERDA (2022a), the emissions from the extraction, processing, transmission, and distribution of these fuels have not followed the same pattern.

I also evaluated the data used in the report.  It is available along with just about everything else at the NYS data website. This is part of the Open NY initiative described as:

Open NY is the award-winning initiative of policies, programs and tools that provide public access to digital data for collaboration and analysis. Empowering the public and government with data for the digital age.

Everything may be there but it is not easy to use.

The data used in the 2020 GHG emissions report are available.  I have developed a spreadsheet (documentation) that simplifies the use of the data for more refined evaluation. 

One finding in my evaluation is that there are changes in the total emissions reported relative to last year’s inventory.  The spreadsheet lists all the differences.  Importantly there is a difference between the regulatory Part 496 1990 baseline emissions of 409.78 million metric tons and this inventory that says 1990 emissions were 404.26 and last year’s baseline emissions were 402.54.  Recall that Part 496 determines the 2030 emissions limit, 245.87 million metric tons and 2050 emission limit, 61.47 million metric tons as percentages of the baseline.  At some point DEC will have to address these differences.

Another interesting result is the distribution of emissions by economic sector as shown in the following figure.  Overall emissions have been going down since the mid-2000’s.  The electric sector reductions have been the primary cause.  As noted previously electric sector emissions were decreasing over time until 2019 but started increasing since then.   

Projected 2021 and 2022 NYS GHG Emissions

In order to determine where NYS stands relative to the 2030 target currently, it is necessary to combine the EPA and NYS datasets.  The 2020 GHG Report notes that the pandemic shutdowns affected 2020 emissions.  In order to project 2021 emissions, I used the average of the years 2016-2020 for all sectors except electricity and for 2022 I used the average of 2017-2021 excluding 2020. 

Because the electric sector emissions include upstream and imported electricity emissions, I had to do something more refined.  The direct emissions used the EPA reported emissions.  The upstream and imported electricity emissions are in Table 28: electric sector emissions by fuel type of the  NYSERDA (2022a) technical documentation.  I took the average of the 2019 and 2020 data for the imported component.  The upstream emissions are related to the direct emissions.  I assumed that relationship was equal to the ratio of the 2019 and 2020 average EPA emissions to the out-of-state upstream emissions.  Using these assumptions, I project that the 2022 emissions increase to levels not seen since 2018.

Discussion

The Climate Act includes a target for a 40% reduction of greenhouse gas (GHG) emissions from 1990 levels by 2030.  The NYS Part 496 1990 baseline emissions are 404.26 mmt CO2e.  The total 2020 NYS emissions were 344.85 mmt CO2e which is a 15% reduction from the baseline.  The 2030 limit is 245.9 CO2e which will require a further 29% reduction.

I looked at alternative emission reduction trajectories to get to the 2030 limit.  The following table estimates the emissions needed to meet the targets from starting points in 2018 to 2022.  Using the observed 2020 emissions noted above would require a 2.96% reduction per year.  Using the projected 2021 emissions (381.00 mmt CO2e) the annual reduction rate would be 3.94%.  Similarly, for 2022 because the emissions have gone up the annual reduction rate would have to be 4.52%.  Even if the 2022 emissions turn out to equal the 2020 emissions the annual reduction rate would have to be 3.59%.

Because of the variation of weather-related fuel usage GHG emissions have quite a bit of interannual variability (on the order of 3%).  My impression is that the annual reduction rates required to meet the 2030 target will be a significant challenge.  It is not clear what will happen if anyone of many issues causes delays in the implementation compliance trajectory.

There is another aspect of these data that is relevant with respect to the proposed cap and invest program.  The electric generating sector has developed a verifiable emissions reporting system that provides compliance data two months after the end of the year.  That system uses traceable direct measurements.  The 2020 GHG emissions report that represents the “official” compliance reporting by the DEC takes two years to produce.  It uses fuel use data, emission factors, and many assumptions in a process that is anything but open and transparent.  There have been three iterations of NYS GHG emission inventories and the historical data has changed in each subsequent iteration.  That approach does not meet the EPA emissions trading system recommendation for a timely, consistent, and accurate emissions reporting system.

Conclusion

There are a few takeaway points with these data.  The EPA electric generating unit emissions for 2022 increase over past years because of the NYS decision to shut down 2,000 MW of zero-emissions generating capacity at Indian Point.  Clearly, if the net-zero transition is to succeed then maintaining and expanding the state’s nuclear resources is necessary.  The data also show that the emission reduction trajectory is ambitious and, I believe, unlikely to be met.

The Climate Act GHG emission reporting requirements double the electric sector emissions over the direct measurements used by EPA.  The reporting system developed for EPA gets the results in two months but the reporting system used to generate the Climate Act GHG emissions takes two years. One of the arguments used by the Climate Action Council to justify the proposal for a cap and invest market-based control program was that the Regional Greenhouse Gas Initiative (RGGI) trading system was a successful model that could be used.  RGGI uses the EPA reporting data to provide timely, consistent, and accurate data for compliance requirements.  There is no favorable comparison between the EPA system and the Climate Act reporting system.  The reality that the NYS GHG emissions reporting data are incompatible with any emissions trading system is just one of the practical problems that the cap and invest proposal must address before it can be implemented.

Arctic Blast Foreshadows Problems with Climate Act Renewable Future

This past Friday and Saturday (February 3-4 2023) there was a brief shot intensely cold air to the Northeast US.  This post includes a couple of descriptions of the implications of this weather event relative to the Climate Leadership and Community Protection Act  (Climate Act) and I present some data describing the event.

This is another article about the Climate Act implementation plan that I have written 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.

I am Thankful – Mark Stevens

Mark is a regular reader at this blog and has contributed several recent items for posting.  He is a retired science and technology teacher from Long Island.  His email to me this weekend is a perfect introduction to the issues raised by this weather event.

It was 3 degrees F Saturday morning with a wind chill of -3 degrees.  All night the north wind raged, rattling “sealed” windows and doors but still blowing frigid air through them. I did everything I could: raise the boiler’s temperature, cover the big expanse of glass on the patio doors windows, pull the shades.  I even added an electric heater in the room my tropical parrot resides so he doesn’t get a fatal pneumonia.

The possibility of a power failure crossed my mind with the overhead wires, high winds, many surrounding trees, and almost monthly power interruptions in the past.  It would be an absolutely worst-case scenario if the power went out tonight. Frozen pipes next? I have a backup generator but the thought of going out in the howling cold night, fueling it, hooking it up, starting it, and monitoring the systems wasn’t that appealing.

But LIPA’s tree trimming maintenance and generation/distribution system upkeep allowed the power to stay on through the night and into the next day as I write this. We’re cozy, comfortable and safe.  This kind of cold can kill.

I’m thankful we have a reliable, cost-effective electrical generation and distribution system.  I’m thankful I have a natural gas-fired boiler that works 24/7 keeping me and my family safe and alive.  I am thankful that I don’t rely on intermittent, expensive wind and solar generation as electricity sources that can fail at any time leaving me without power.  I’m grateful I don’t have to rely on “backup” battery power that is grossly inadequate, expensive, highly polluting to manufacture and can cause a non-extinguishable toxic gas fire. I pray it does not change.

What’s Keeping the Heat On – James Hanley

James is a Fellow at the Empire Center.  His post yesterday is a great overview of the problem facing New York as it continues the implementation of the Climate Act.

As another Arctic blast hits the Northeast and temperatures plunge, more energy is needed to keep New Yorkers warm.   Where is that energy coming from? 

A lot of it comes from natural gas, but there’s a big supply problem. Because of the state’s ban on fracking and its refusal to allow new and upgraded natural gas infrastructure, not enough gas can get to power plants to generate the electricity needed to keep the lights and heat on in everyone’s houses during times of extreme demand. 

What gas is available gets bid up to eye-wateringly high prices. It’s hard to speak meaningfully of an average price for natural gas because the market is volatile, but the 2022 high price in Pennsylvania was $12.95 per million British thermal units (mmbtu). According to one energy industry source, during last Christmas’s cold snap, the price in New York hit $100 per mmbtu. 

That translated into an electricity price of nearly 90 cents per kilowatt hour, compared to the average New York price of 19 cents. 

That assumes the power plant can even get the gas it needs to operate. With such severe gas shortages, some natural gas-fired plants had to shut down for lack of fuel. What gets burned to take their place – fuel oil – is not only expensive, but also much dirtier and producing more carbon dioxide than natural gas. 

So, ironically, because New York has limited the supply of the much cleaner burning natural gas in order to prevent pollution and CO2, the power industry has no choice at times but to spew more pollution into disadvantaged communities and add more carbon to the atmosphere. 

The hope is that renewables will one day suffice to supply the electricity we need to heat our homes on a day like this. That hope is irresponsible, because wind and solar aren’t reliable and there is no available “clean” backup power source. 

Below is a graph from the New York Independent System Operator’s (NYISO) real-time dashboard, showing fuel use on February 2 into the early hours of February 3. On what was otherwise a reasonably good day for wind power (the light green line), we can see it declining in the early hours of February 3 as the cold front moved in, while the use of dual fuel generators (the top line), which can burn fuel oil, dramatically increased. Building more wind turbines has limited effect – as the wind drops across the state, all the turbines decrease in output. 

NYISO has repeatedly warned – and the Climate Action Council’s Scoping Plan admits – that wind and solar will not be sufficient. New York will need between 25 and 45 gigawatts of dispatchable power – power that unlike wind and sun, but like natural gas, fuel oil, and hydro, can be turned on and off at will. 

To comply with the Climate Leadership and Community Protection Act (CLCPA), these sources are supposed to be emissions free, leading NYISO to coin the ugly acronym DEFRs – dispatchable emissions-free resources. But they coined that term because they can’t identify any source that meets that standard and is currently available at utility scale and a commercially competitive price. 

This means that for the foreseeable future, fossil fuels will be the only proven source of dispatchable backup to keep the heat and lights on during weather that is killingly cold. Since New York no longer has any coal plants, that can be oil – which is more polluting and has higher carbon content – or natural gas. 

The CLCPA has a clear goal of eliminating all greenhouse gas emitting power production by 2040, which would mean shutting down all natural gas-fired power plants. But it also provides a path for keeping open those plants that are necessary to ensure a reliable electrical supply. That path, however, faces considerable political opposition. 

New York will soon be forced to make a choice: plunging forward with shutting down natural gas-fired power plants, risking rolling blackouts during extreme cold, or moving forward more slowly on its emissions goals, but keeping the heat on. There is no third way.

The Numbers

The past two days were ideally suited to staying inside.  I am a numbers guy so I spent time the last several days watching the weather and the electric system using two different resources.  The go to resource for weather observations in New York is the NYS Mesonet At UAlbany.  I watched the arctic air come into the region and then tracked the event over time.  The NYISO Real-Time Dashboard is a fascinating link into the New York electricity market.  I suspected correctly that this weather would cause a spike in electric load and I could see that play out over the period.

The weather data presented here is all from the NYS Mesonet at the University of Albany.  The following graph lists the last seven days of temperature, dew point temperature, and solar irradiance data at Elbridge, NY which is near my home.  Note that at the time I write this it is February 5 at 8:00 AM and that corresponds to 05/13 or 1300 universal coordinated time or Greenwich mean time, the standard for meteorological observations.  On the night of February 2 the temperature (red) was around 38oF about 7:00 PM EST or 0000 UTC.  Then the front came through and the temperature plunged overnight and during the day before briefly leveling out a few degrees above zero until nightfall when it dropped down to 7 or so below.

The next graph is for the same time period but shows the wind speed, wind gusts, and pressure.  Frontal passage was accompanied with a dip in the station pressure.  The pressure gradient was strong for most of the period so winds were steady slightly above 10 mph with gusts peaking at 38 mph.

The NYISO Real-Time Dashboard has two relevant graphical displays:  the load and real-time fuel mix. The following graph shows the actual and forecast New York total load on February 3-4 (all times are EST).  It is noteworthy that the actual loads on both days were  significantly higher than forecast loads.  The load peaked on 2/3 at 6:50 PM at 23,447 MW and at 6:10 PM on 2/4 at 21,990 MW. 

The NYISO 2022 Load and Capacity Data report winter peak demand projections are all greater than the observed peak loads so this should not have been a demand response problem with the existing fleet.

The real-time fuel mix data shows how the existing fleet met the peak loads during this weather event.  The following table lists the daily statistics for the different fuel types.  The fuel-mix categories are Nuclear; Hydro, including pumped storage; Dual Fuel, units that burn natural gas and other fossil fuels; Natural Gas only; Other Fossil Fuels, units that burn oil only; Other Renewables are facilities that produce power from solar, energy storage resources, methane, refuse or wood; and Wind (at this time exclusively land-based wind).

The graphs show how important the fossil fuel units are to keeping the lights on.  One notable feature of the fuel type data on 2/3 is that the wind generation was not very high even though winds across the state were quite high.  I believe this is because wind turbines don’t provide optimal power if the winds are too light or too strong.  The strong winds on this date apparently affected the wind production so even on a windy day New York’s land based wind provided only 65% of the maximum potential capability.

On 2/4/2023 the wind resource was affected by light winds.  On this date New York’s land based wind provided only 32% of the maximum potential capability.

Conclusion

Stevens explains how important it is for our safety and well-being to have fossil fuels available during extremely cold weather.  Hanley showed that natural gas played an important role keeping the lights on during this arctic blast and described some of the uncertainty associated with the planned net-zero transition.  My contribution was to provide more documentation for the weather, resulting electric load peak, and the contribution of different fuels to meeting that peak.  I am going to follow up on this post with a deeper dive into the resource availability and implications to the Scoping Plan recommendations for generating resource allocations.

Hanley’s conclusion is spot on:

New York will soon be forced to make a choice: plunging forward with shutting down natural gas-fired power plants, risking rolling blackouts during extreme cold, or moving forward more slowly on its emissions goals, but keeping the heat on. There is no third way.

No New Fossil Fuel Infrastructure Question

I recently got an email from Ronald Stein that raised an energy literacy issue that has been something I wanted to write about for some time.  New York’s Climate Leadership and Community Protection Act  (Climate Act) mandates a transition of the energy system to one with no fossil fuel infrastructure.  What about the 6,000 products that are manufactured using fossil fuel feedstocks?

Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies.  Unfortunately, looking solely at fossil fuels as evil and not considering the enormous benefits of fossil fuel as an energy source and as the material used to manufacture so many items used by society is misplaced.   I submitted comments on the Climate Act implementation plan and have written over 275 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.

Energy Literacy

In this section I quote and paraphrase the material from the email.

Ronald Stein is a professional engineer, energy advisor, and national TV commentator, Ron has spent much of his life trying to get more people to truly understand energy – where it comes from, how it works, and what we can expect in the future. After starting off his career as a project manager for refineries and chemical plants, Ron later did a stint at Universal Studios where he oversaw the building of the Jaws ride. Eventually, he would start his own company, PTS Advance, which partners with engineering firms and refineries to augment their core staff when excess needs arise. The family-owned business now has locations across the country, with over 1000 contractors staffing various energy infrastructure projects.

His email explained:

Energy literacy starts with the knowledge that renewable energy is only intermittent electricity generated from weather dependent breezes and sunshine. For the 8 billion on this planet, wind turbines and solar panels cannot manufacture any of the 6,000 products in our daily lives, nor any of the fuels for ships, planes, militaries, and space programs.

It went on to provide a few takeaways on energy literacy, i.e., the elephant in the room that no one wants to talk about:

The potential for nuclear fusion for unlimited zero-emission electricity is exciting. It has the potential, in the decades ahead, to wean the world from coal and natural gas for electricity generation.

Facing reality, fusion, like wind, solar, nuclear, and hydro, ONLY generate electricity. None can manufacture any products, or fuels for transportation infrastructures needed by the 8 billion on this planet.

On the other hand, we have crude oil that is never used for generating electricity, AND is virtually useless until its manufactured into usable products via the 700 refineries around the world.

Today, the world’s 8 billion are dependent on more than 6,000 products made from the oil derivatives manufactured from crude oil, and the 50,000-merchant ships and 50,000 jets, and militaries, and space programs are based on the fuels manufactured from crude oil.

We may have long-range plans to generate electricity from wind, solar, and nuclear fusion, but no plans to replace crude oil that is manufactured into everything in our daily lives.

Energy literacy will enhance one’s comprehension that the cost of energy affects everything, from the food we eat, the clothes we wear, transportation, communications, housing, healthcare, and the leisurely living made possible by energy.

The world needs to comprehend that energy is more than intermittent electricity from wind and solar. Ever since the discovery of the versatility of products available from petroleum derivatives, and the beginning of manufacturing and assembly of cars, truck, airplanes, and military equipment, the world has had almost 200 years to develop clones or generics to replace the crude oil derivatives that are the basis of more than 6,000 products we use such as: medications, electronics, communications, tires, asphalt, and fertilizers.

The social needs of our materialistic societies are most likely going to remain for continuous, uninterruptable, and reliable electricity from coal, natural gas, or nuclear electricity generation backup, and for all those chemicals derivatives that get manufactured out of crude oil, that makes everything else that’s part of our daily lifestyles and economies.

The purpose of the email was to announce a podcast posted January 14, 2023 at Energy Media about the elephant in the room, the products manufactured from fossil fuels that built the world from 1 to 8 billion in less than 200 years, beginning right after the discovery of oil.  Ron explains:

There’s no doubt about it, our entire modern society – from medication to food to infrastructure and beyond – all was made possible thanks to the discovery of oil. When talking about the energy transition, Ron cautions dropping oil and gas before reliable alternatives are readily available. To him, that’s like “jumping out of a plane without a parachute.”

For more, check out Ron’s interview with The Epoch Times  for a video that has already been viewed more than 200,000 times! “The 35-minute YouTube video is a conversation about the elephant in the room that no one wants to talk about: the lack of energy literacy in the bizarre California energy policies.”  The emphasis on the video is on California’s policies.  It is entirely relevant to New York’s Climate Act.

Climate Act Implications Conclusion

One of the talking points of proponents of the Climate Act is that many clean energy jobs will be created.  Stein’s work makes the point that the clean energy jobs are only associated with making electricity.  In addition, most of the clean energy jobs are construction jobs and not associated with operating the generating resources.  New York’s over-riding emphasis on reducing GHG emissions means that fossil fuels that can be used to make electricity but also provide fuel for heating and transportation and support manufacturing will be prohibited.  I am pretty sure that is going to lead to a net loss of jobs.

The other relevant point is that the Climate Act fails to consider any positive impacts of fossil fuels.  Eliminating fossil fuel infrastructure in the state means that no manufacturing that uses fossil fuels as feed stock will be welcome in the state.  I also find it hypocritical that there is no backup plan for the replacing fossil fuel feedstocks used to make the products in the following figure.

Stein makes the important point that today’s society requires not only reliable electricity but all the chemicals derivatives that get manufactured out of crude oil and natural gas.  Failure to consider the value of 6,000 products that are manufactured using fossil fuel feedstocks under values fossil fuel benefits to society in the Climate Act.

The Pied Piper has no Clothes

At the last meeting (presentation and recording) of the Climate Action Council, Dr. Robert Howarth’s statement supporting his vote to approve the Scoping Plan described the genesis of the Climate Leadership and Community Protection Act (Climate Act).   This post uses two children’s tales to illustrate my concerns about his claimed basis for the plan.

Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies.  I submitted comments on the Climate Act implementation plan and have written over 250 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 “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. 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 that was released for public comment at the end of 2021 and approved on   December 19, 2022.

Children’s Stories

I believe that two children’s fables illustrate the false presumptions of the Climate Act.  According to Wikipedia, the Pied Piper of Hamelin is a Middle Ages tale from the town of Hamelin, Germany.  The pied piper, dressed in multicolored (“pied”) clothing, was a rat catcher hired by the town to lure rats away with his magic pipe. When the citizens refuse to pay for this service as promised, he retaliated by using his instrument’s magical power on their children, leading them away as he had the rats. The phrase “pied piper” has become a metaphor for a person who attracts a following through charisma or false promises. The other fable is the Emperor’s New Clothes.  This Danish fairy tale written by Hans Christian Andersen was first published in 1837.  In this story, swindlers convince the emperor, who spends lavishly on clothing at the expense of state matters, that they can provide magnificent clothes that are invisible to those who are stupid or incompetent. The emperor and his court don’t see any clothes but pretend otherwise to avoid being thought a fool.  When the emperor marches through the city to show off his new clothes the townsfolk uncomfortably go along with the pretense, not wanting to appear inept or stupid, until a child blurts out that the emperor is wearing nothing at all. The people then realize that everyone has been fooled.  The phrase “The Emperor Has No Clothes” is often used in political and social

contexts for any obvious truth denied by the majority despite the evidence of their eyes, especially when proclaimed by the government. 

The Pied Pipers of the Climate Act

The statement of Robert W. Howarth, Ph.D., the David R. Atkinson Professor of Ecology & Environmental Biology at Cornell University was very illuminating relative to the motives of the Climate Act authors.  He reiterated his claim that he played a key role in the drafting of the Climate Act, developed the irrational methane requirements, and credited one politician for getting the Act passed:

Assembly Person Steven Englebright was hugely instrumental in the passage of the Climate Leadership & Community Protection Act that established the Climate Action Council. I thank him for his leadership on this, and particularly for his support of the progressive approach on greenhouse gas emissions that is a central part of the CLCPA. I originally proposed this to Assembly Person Englebright in 2016, and he enthusiastically endorsed and supported it through multiple versions of the bill that finally led to passage of the CLCPA in 2019. In this accounting for greenhouse gases, a major government for the first time ever fully endorsed the science demonstrating that methane emissions are a major contributor to global climate change and disruption. Further, in passing the CLCPA New York recognized that consumption of fossil fuels (and not simply geographic boundaries) is what matters in addressing the climate crisis. New York wisely banned the use of high-volume hydraulic fracturing (“fracking”) to develop shale gas in our State. But since the time of that ban, the use of fossil natural gas has risen faster in our State than any other in the Union. Methane emissions from this use of shale gas are high, but much of that occurs outside of our boundaries in the nearby states of Pennsylvania, West Virginia, and Ohio. Through the CLCPA, the citizens of New York are taking responsibility for these out-of-state emission caused by our use of fossil fuels, particularly for fossil natural gas. The way to reduce these emissions is to rapidly reduce our use of fracked shale gas.

Based on the work of David Zaruk I recently wrote an article describing his analysis of the motives of people like Englebright and Howarth who insist on reducing their perceived priority risks to zero.  One of Zaruk’s articles explained that the use of definite articles is “abused by activists needing definite truths to win policy debates on complex problems.”  Dr. Howarth’s monomaniacal vilification of natural gas is well described by that statement.  During the discussions at the Climate Action Council meetings, he constantly referred to the science and his background as a scientist.  Zaruk writes:

In declaring: “This is the science on XYZ” an activist is attempting to own the issue and shut down any discussion or analysis. In a policy framework where there may be uncertainty or grey areas, imposing a “the” provides a wedge between others’ false opinions and “the” truth.

With all due respect to Dr. Howarth, it is appropriate to consider why a “Professor of Ecology & Environmental Biology” is qualified to be an expert on methane emissions from fracking.  In my opinion, scientists getting paid to deliver a specific result from trust fund philanthropic organizations, no matter how noble the perceived motive, is the same as the much vilified “tobacco industry” scientists.  The funding stream ends when the results don’t match the funder’s requirements so their arguments are biased.  They may be right but the arguments must be considered in that context and debated.

As a member of the Climate Action Council, Howarth was considered a saint and most unquestioningly accepted whatever he said as gospel.  This deference to his concerns is also apparent in the Integration Analysis and Scoping Plan.  However, his views are not universally accepted.  For example, the Climate Act requires New York to account for upstream emissions from fossil fuel used in the state because Howarth has claimed in a 2020 paper that “Some evidence indicates that shale-gas development in North America may have contributed one-third of the total global increase in methane emissions from all sources over the past decade (Howarth 2019).”  This paper and other similar papers claim that “methane emissions can contribute significantly to the GHG footprint of natural gas, including shale gas” and form the rationale of the Climate Act vilification of natural gas.

Despite the Climate Act mandate to provide a “detailed explanation of any changes in methodology or analysis, adjustments made to prior estimates, as needed, and any other information necessary to establish a scientifically credible account of change” any contradictory information has been ignored.  No comments on the Integration Analysis numbers that formed the basis for the Scoping Plan were mentioned at any of the Climate Action Council meetings.  For example, I noted that there is a high quality, long-term monitoring network that measures methane (Lan et al., 2019) over the period when Pennsylvania shale-gas production increased tremendously.  According to the plain language summary for the report:

In the past decade, natural gas production in the United States has increased by ~46%. Methane emissions associated with oil and natural gas productions have raised concerns since methane is a potent greenhouse gas with the second largest influence on global warming. Recent studies show conflicting results regarding whether methane emissions from oil and gas operations have been increased in the United States. Based on long‐term and well‐calibrated measurements, we find that (i) there is no large increase of total methane emissions in the United States in the past decade; (ii) there is a modest increase in oil and gas methane emissions, but this increase is much lower than some previous studies suggest; and (iii) the assumption of a time‐constant relationship between methane and ethane emissions has resulted in major overestimation of an oil and gas emissions trend in some previous studies.

The fact that the relevant high quality, long-term monitoring network does not show a trend consistent with the work of Howarth is a fatal flaw in his claims.  In addition, those measurements unequivocally support another contradictory analysis by Lewan that concludes his ideas, perspectives, and calculations on methane emissions from shale gas are invalid.  The bottom line is that two pied pipers are responsible for the Climate Act’s irrational war on natural gas.   The Climate Act’s elimination of natural gas is based on the false promises of one biased individual supported by one charismatic motivated politician.  These pied pipers are going to lead New York over an energy cliff.

The Climate Act Has No Clothes

Howarth’s statement went on to claim that the Scoping Plan development process ”brought in a large number of experts and key stakeholders who worked diligently to advise the Council on our Scoping Plan”.  After extolling the success of the stakeholder process and the staff members who contributed, he explained why everything will work out:

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 believe that this is the fundamental basis for the Climate Act’s aggressive schedule.  The Jacobson analysis approach unfortunately is pretty much the same as the Integration Analysis modeling approach for the Scoping Plan.  Both modeling efforts project future load requirements, then list a bunch of control strategies, estimate the energy they could produce, and presume everything will work together if we cross our fingers.  Neither includes a feasibility analysis that considers reliability, affordability, or cumulative environmental impacts.

Howarth appeals to the authority of peer-reviewed science to provide credibility to the Jacobson analysis. However, science is a continuous process where hypotheses are constantly challenged and confirmed.  In this instance Howarth neglects to mention the analyses that discredit the Jacobson work. 

The Jacobson analysis cited was a continuation of previous work.  For example, in a widely publicized November 2009 Scientific American article, Mark Jacobson and Mark Delucchi, suggested all electrical generation and ground transportation internationally could be supplied by wind, water and solar resources as early as 2030. However, other contemporary projections were less optimistic. Two examples: the2015 MIT Energy and Climate Outlook has low carbon sources worldwide as only 25% of primary energy by 2050, and renewables only 16% and the International Energy Agency’s two-degree scenario has renewables, including biomass, as less than 50%.

Howarth’s statement cites a specific plan for New York (Jacobson et al. 2013) that he and Jacobson laid out a decade ago.  He says that “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.”   Table 2 from that report follows.  This analysis includes power from exotic resources such as waves, geothermal, tidal turbines, and concentrated solar power but no energy storage.  It is significantly different than the projections in the Integration Analysis and the New York Independent System Operator (NYISO) 2021-2040 System & Resource Outlook that exclude all the exotic renewable generating capacity, contain significant amounts of energy storage, and include a new dispatchable, emissions-free resource for a set of resources that they think can provide sufficient electrical power for the future.  Furthermore, it claims that end-use power demand can be decreased by 37%.   In my opinion, any analysis that suggests that concentrated solar power is a viable source of energy in New York is simply not credible because that resource would never work in New York.  It is too cloudy to operate enough to cover costs and the environmental impacts would be too great.

There was a formal rebuttal paper to this analysis. The rebuttal paper argued that: 

The feasibility analysis performed by Jacobson et al. (2013) is incomplete and scientifically questionable from both the technical and economic perspectives, and it implicitly assumes, without sufficient justification, that social criterion would not produce even larger feasibility barriers.

Jacobson et al. responded to that rebuttal claiming  that “The main limitations are social and political, not technical or economic.”  Given the significant differences between that analysis and the most recent projections by the organization responsible for keeping the lights on, I agree with the conclusion cited above.  I do not believe that the 2013 analysis includes a defensible feasibility analysis.

Using Jacobson as the basis for the Climate Act transition gets worse.  Unmentioned by Dr. Howarth is that in a 2015 article for a different iteration of the wind, water, and solar roadmap Clack et al, 2017 discredited the Jacobson approach:

In this paper, we evaluate that study and find significant shortcomings in the analysis. In particular, we point out that this work used invalid modeling tools, contained modeling errors, and made implausible and inadequately supported assumptions. Policy makers should treat with caution any visions of a rapid, reliable, and low-cost transition to entire energy systems that relies almost exclusively on wind, solar, and hydroelectric power.

In the scientific process, when issues with your work are noted, the proper response is to provide more evidence supporting your modeling tools, explain why the claimed errors are not errors, and defend your assumptions.  Instead, Jacobson filed a lawsuit, demanding $10 million in damages, against the peer-reviewed scientific journal Proceedings of the National Academy of Sciences and the authors for their study showing that Jacobson made improper assumptions in order to make his claims that he (and by extension Howarth) had demonstrated U.S. energy could be provided exclusively by renewable energy, primarily wind, water, and solar. In my opinion this is an appalling attack on free speech and scientific inquiry but want to emphasize that the bad actions by Jacobson in no way should be attributed to Howarth.

In February 2018, following a hearing at which PNAS argued for the case to be dismissed, Jacobson dropped the suit.  The defendants then filed, based on the anti-SLAPP — for “Strategic Lawsuit Against Public Participation” — statute in Washington, DC, for Jacobson to pay their legal fees. In September 2022, he was ordered to pay the defendants’ legal fees based on a statute “designed to provide for early dismissal of meritless lawsuits filed against people for the exercise of First Amendment rights.” 

In my opinion Jacobson’s attempted lawsuit was because his work could not stand on its own.  Therefore, it is unsettling that it is claimed to be the basis of the Climate Act.  Howarth’s statement explicitly lays out his position for the Jacobson analysis:

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.

Unfortunately, Howarth’s technology demonstration is not supportable.  Nonetheless, it forms the basis for the Climate Act schedule and zero-emission electric system by 2040 mandate.  The Climate Action Council has embraced it despite the projections in the Integration Analysis and the NYISO Resource Outlook that reject it.  The Council is denying the majority opinion despite the evidence presented in their own analysis.  The Climate Act has no clothes. 

Conclusion

Pied piper Dr. Robert Howarth stated that “Our final Scoping Plan from the Climate Action implicitly endorses the vision of the Jacobson et al. paper and is quite clear: we can meet the goals of the CLCPA and we can and will do so in way that is affordable and that will benefit all New Yorkers.”  Unfortunately, that vision has no clothes.  The implementing regulations and additional legislation necessary to implement this vision must include independent, unbiased feasibility analyses to determine if the proposed plans can maintain current standards of reliability, will preserve the affordability of energy, and not create environmental impacts to New York State that are greater than the alleged impacts of climate change.  Failure to do so will ensure that the state ends up as badly as the children’s stories.

Update 1/5/2023

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 (like the work of Jacobson and Howarth) need to be considered carefully.  It 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.”

Skeptical Overview of the Climate Act Presentation

This is a summary of the presentation I gave to the Central New York Chapter Air & Waste Management Association on November 29, 2022 explaining why I believe that the risks, costs, and impacts of the Climate Leadership and Community Protection Act (Climate Act) exceed the protections, savings, and benefits.

Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies.  I submitted 23 comments on the Climate Act implementation plan and have published over 250 blog posts on  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 this supposed cure will be worse than the disease.  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.

Introduction

I explained that given the time constraints it was only possible to give sound bites to describe why I am skeptical of the ultimate impacts of the Climate Act.  This blog post gives an overview of the presentation and, more importantly, a link to detailed information supporting my arguments.  Everything presented draws on my blog posts and Draft Scoping Plan comments.

I discussed three primary concerns: reliability, affordability and environmental impacts.  In every instance, my evaluation of the components of the transition plan has found that issues are more complicated, uncertain, and costly than portrayed by the State.   Moreover, they have not provided a feasibility analysis to document whether their list of control strategies could work.  In addition there is no implementation plan.  The Climate Act is simply too fast and too far.

Overview of the Climate Act

I described the transition plan for New York’s Climate Act “Net Zero” target (85% reduction and 15% offset of emissions) by 2050.  The Climate Action Council has been working to develop plans to implement the Act.  The 22 members of the Council were chosen for their ideology and not their expertise and the lack of clear direction by the Hochul Administration led to misplaced priorities.  Instead of focusing on overarching policy issues there has been inordinate attention to personal concerns of Council members. 

Over the summer of 2021 the New York State Energy Research & Development Authority (NYSERDA) and its consultant Energy + Environmental Economics (E3) prepared an Integration Analysis to “estimate the economy-wide benefits, costs, and GHG emissions reductions associated with pathways that achieve the Climate Act GHG emission limits and carbon neutrality goal”.  Integration Analysis quantitative implementation strategies were incorporated into the Draft Scoping Plan when it was released at the end of 2021.  Since the end of the public comment period in early July 2022 the Climate Action Council has been addressing the comments received as part of the development of the Final Scoping Plan.  Most recently they have been revising the Scoping Plan to come up with a final document.  The intention is to release the Final Scoping Plan by the end of the year.

I expressed my disappointment with the public stakeholder process associated with the Draft Scoping Plan comments. Seven hundred people spoke at Climate Act Public Hearings and around 35,000 comments were received.  However, on the order of 25,000 comments were “potentially the same or substantially similar”, i.e., form letters.  That still left 10,000 unique comments that the Council promised would be “acknowledged”.  In my opinion, the comment process was treated as an obligation not as an opportunity to improve, correct, or clarify the scoping plan.

Of course it is unreasonable to expect that the Council members could be expected to review all the comments themselves.  Agency staff categorized the comments and then filtered them in presentations to the Climate Action Council that described themes with very little specificity.  I think there was a clear bias in the presentations.  Anything inconsistent with Administration’s narrative was disparaged, downplayed, or ignored.  I was most disappointed that no comments on the fundamental basis of the Draft Scoping Plan, that is to say the Integration Analysis, were mentioned, much less discussed.

I also addressed the Climate Act mandates for 2023.  The expectation is that the regulations that implement policies that force the transition away from fossil fuels will be implemented by the end of 2023.  However, the Climate Act also mandates a public comment and consultation process before promulgating regulations.  It requires the Department of Environmental Conservation (DEC) to complete a public comment and consultation process before it can promulgate the 2024 Implementing Regulations.  This process includes public workshops and consultation with the Climate Action Council, the Environmental Justice Advisory Group, the Climate Justice Working Group, representatives of regulated entities, community organizations, environmental groups, health professionals, labor unions, municipal corporations, trade associations and other stakeholders. At least two public hearings and a 120-day public comment period must be provided. Only after this extensive stakeholder process concludes is DEC authorized to propose the implementing regulations.  When the regulations are formally proposed the State Administrative Procedures Act requires a 60 day public comment period, public hearings, and that the agency respond to all comments.  I think this is a very ambitious plan.

Electric Grid Risks

Many of the most vocal supporters of the Climate Act believe that existing renewable technology is sufficient to transition the New York electric grid to zero-emissions resources by 2040 and that suggestions that may not be true are misinformation.  In order to address that fallacy my presentation concentrated on my concerns about the reliability risks of an electric grid that is dependent upon intermittent and diffuse renewable resources.  The electric grid is crucial to New York’s energy future because the primary de-carbonization strategy is to electrify everything possible using those resources.  I described the existing grid, generation resource planning, the current New York State system, and the projected New York State system.  Electric grid reliability requires that generation resources match electric load at all times and the challenges associated with wind and solar in this regard are ignored by those who believe that existing technology is sufficient.

I made the point that failure to adequately plan will mean an inevitable catastrophic blackout like the Texas February 2021 blackout.  In short, weather related issues due to freezing rain, snow and then an extended period of cold weather led to periods when the generating resources did not match the load necessary.  The storm was the worst energy infrastructure failure in Texas history.  Over 4.5 million homes and residences were without power, at least 246 people died, and total damages were at least $195 billion. 

In order to illustrate the basic electric grid I included the following diagram.  It shows that generating station provide power using turbine generators that convert mechanical energy into electric energy using water, steam, or other means to spin the turbines.  I have heard the argument that the grid is inefficient because there are power losses between the generating station and the users but the fact is that New York will always be dependent upon a transmission system because there is insufficient space in New York City for sufficient renewable resources to provide the energy needed to keep the lights on.  Power output from generating plants is stepped up at substation transformers for long distance transmission and then substation transformers step down the power for the distribution system for use by consumers.

I included the following diagram to make the point that New York is in the Eastern Interconnection which is the largest machine in the world.  Incredibly all the fossil, hydro, and nuclear generating stations in the Eastern Interconnection work together.  In order to provide 60 Hz power the generating turbines are synchronized to run at 3600 revolutions per minute.  Operators keeps 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.  Unfortunately, wind and solar resources are inverter based and cannot be dispatched as needed.

New York State has its own regional operator – the New York Independent System Operator (NYISO).  Within Power the Eastern Interconnection system operators match the load with the generation in smaller regional systems. Regional system operators manage imports and exports between neighboring systems.  New York has unique system constraints related to New York City and Long Island that warrant its own system operator.

NYISO operates the electric grid for New York State.  There are 11 control areas with specific load, interconnection, and generation characteristics that must be addressed on a six-second basis to keep the lights on.  New York State’s major challenge is that there are limits to transmission to the highly populated New York City and Long Island control areas.  The NYISO has to address different time scales for load management:

  • Sub-minute fluctuations are addressed automatically
  • Hourly and daily fluctuations are handled by operators
  • Annual peaks require planning so that operators can respond

New York’s high reliability performance standards are the result of decades of experience working with dispatchable resources and implementation of specific metrics developed after blackouts in 1965 and 1977.

In order to educate those who believe that existing renewable resources are sufficient for maintaining current reliability standards I described generation resource planning.  The following load duration curve is a key concern of load management planning.  There are three general resources.  Baseline resources ideally are dispatched so they can run at a constant rate which enables the resource owners to tune the units to run as efficiently as possible.  Daily load variations require some resources to follow load during the day.   The biggest planning challenge is capacity and energy for peak loads that occur when temperatures are highest or lowest.  Before deregulation, each utility was responsible for meeting all these resource needs.  In New York City the solution for the peak load problem was a fleet of simple-cycle turbines dedicated for use to provide peaking power when and where needed.

The problem with existing renewable resource technology is matching load when the system is dependent upon renewable resources that cannot be dispatched and provide variable energy.  This is a new and difficult challenge.  It is exacerbated by intermittent renewable energy availability associated with peak loads. Load peaks with the coldest and hottest weather but those conditions typically are low wind resource periods.  Wind lulls in the winter when solar is low availability is the critical reliability issue.

The NYISO 2022 Power Trends Report  includes this description of the capacity (power available in MW) for the existing system.  It shows that 70% of installed capacity is fossil fueled and 25% is zero emissions. Wind and other renewables (solar energy, energy storage resources, methane, refuse, or wood) account for only 6% of installed capacity.  Note that NYISO does not measure distributed solar directly.  In their accounting it reduces the load so less generation is needed.

The NYISO 2022 Power Trends Report  includes this description of Energy Production (MWh).  Note that 50% of New York’s generated electricity is zero-emissions.  There is a Climate Act target to “Increase renewable sources to 70 percent by 2030” that does not include zero-emissions nuclear. One reason that I am skeptical of the Climate Act is because 24% of renewable source energy produced is hydro and hydro pumped storage.  Wind and other renewables (solar energy, energy storage resources, methane, refuse, or wood) account for 5% of energy produced.  The 29% of the energy produced  from renewable sources is far less than the 70% by 2030 target. I don’t think that it is feasible to develop over 29GW of renewable resources between now and 2030 with supply chain issues, constraints on permitting, procurement, and construction when development of supporting infrastructure is also needed for off-shore wind development.

The capacity factor is a useful metric to understand electric generation resources.  The annual capacity factor equals the actual observed generation (MWh) divided by maximum possible generation (capacity (MW) times the 8,760 hours.  In New York nuclear is a key contributor but the Administration recently shut down 2,000 MW at Indian Point.  At this time the simple-cycle peaking turbines are being phased out and peaking power is produced by oil-fired units and spare capacity in the gas and dual fuel units.  Note that oil is a unique New York resource.  Imagine the difficulty replacing that capacity with a resource that would only need to run 1% of the time.  Note that in 2021 New York land-based wind only had a 22% capacity factor.

It is commonly argued that renewables are the cheapest type of new electric generating resources.  For example, that was the claim in a Dave Davies interview on National Public Radio Fresh Air: “A new climate reality is taking shape as renewables become widespread” with New York Times staff writer David Wallace-Wells.  Wallace-Wells said: “In fact, according to one study, 90% of the world now lives in places where building new renewable capacity would be cheaper than building new dirty capacity. And indeed, in a lot of places, it’s already cheaper to build new renewables than even to continue running old fossil fuel plants.” He went on to say “…we should be going all in on renewables here. We shouldn’t be building new coal or new oil or new gas capacity.”

The key to this claim is the reference to capacity.  If that were the only factor involved in getting the electricity when and where it is needed 24-7, 365 days a year without losing load due to extreme (one in ten year) conditions then his argument that we shouldn’t be building new coal, oil, or natural gas capacity” would be valid.  It is not.  Obviously electric users want power even when the wind is not blowing at night.  Electric system innumerates under-estimate the challenge of the energy storage requirements for extreme renewable resource lulls which correlate well with weather events that are safety threats because of extreme cold and heat. 

Given time restraints I could not fully describe all the NYISO’s planning responsibilities.  I did not include the following slide but made the point that their modeling analyses incorporate all of the complexities of the New York electric system.  I did not describe the three primary components of their responsibilities: comprehensive system planning which examines near-term and longer-term issues impacting reliability, economic, and public policy transmission planning; interconnection planning to evaluate the reliability implications of resources interconnecting and deactivating from the grid; and inter-regional planning with neighboring grid operators. One of the primary functions of the NYISO is electric system planning.  NYISO modeling incorporates all the complexities of the eleven control areas in the New York energy system.

I included the following summary of the NYISO Comprehensive System Planning Process to show all the components and to highlight the recent addition of a new component.  In order to address the Climate Act NYISO added “Develop the System & Resource Outlook” component that looks at a longer planning horizon that was included previously. 

The first report for the resource outlook component was released a couple of months ago.  The 2021-2040 System & Resource Outlook can be downloaded from NYISO and a datasheet summary of key takeaways of the Outlook report is also available.  The summary describes the four key findings: an unprecedented buildout of new generation is needed, load will increase when we electrify everything, transmission is necessary and must be expended to get diffuse renewables to New York City and a new resource has been identified: Dispatchable Emissions-Free Resource (DEFR).  That resource is essentially a fossil-fueled turbine without any emissions. 

I compared the NYISO Resource Outlook modeling analysis with the Integration Analysis modeling.  The Outlook analysis was based on three scenarios.  In order to evaluate the effects of different policy options, this kind of modeling analysis projects future conditions for a baseline or business-as-usual case.  The evaluation analysis makes projections for different policy options, and then the results are compared relative to the business-as-usual case.  NYISO ran two policy scenarios: one based on their estimates of future demand and one that tried to simulate the Integration Analysis projections.  I compared their scenario 1 to the Integration Analysis in the presentation.

The Integration Analysis modeling was used to develop the Draft Scoping Plan.  It is important to note that contrary to usual practice the Integration Analysis baseline was a reference case that included “already implemented” programs.  In other words there are some programs incorporated into the Reference Case that only exist to reduce GHG emissions.  This definition of the Reference Case instead of a Business-As-Usual case is different practice and motivated to get a specific answer. The Integration Analysis considered four different policy projections.  The first considered the Advisory Panel recommendations for control measures, but the modeling showed that they did not meet the Climate Act targets.  The Integration Analysis came up with three mitigation scenarios that did meet the targets.  The model used for the analysis is not as sophisticated as the NYISO model.  Modelers plugged in a set of control measures at varying efficiencies until they met the targets.  Note, however, they have not claimed that the scenario measures as scoped out will provide electricity that meets current reliability standards.  In my opinion this approach gave the impression to the Council that meeting the targets would be relatively easy.  Council members requested scenarios that considered a faster implementation schedule and more reductions that the 85% target.   The cost/benefit results claim that those more stringent scenarios provide more benefits primarily because of reduced costs.  I think that is a counter-intuitive result so my comparison was against Scenario 2: Strategic Use of Low-Carbon Fuels.

I compare the installed capacity for the two models in the next table.  As noted by the NYISO, an extraordinary development of renewables by 2030 is required and both models agree on that.  There also are some key differences.  The NYISO modeling projects more onshore wind, less offshore wind, less solar, and more DEFR.  The NYISO model simultaneously optimizes resource capabilities and costs to come up with a least-cost solution. I think the wind differences are due to cost and availability differences.  The two modeling approaches handle distributed solar differently.  NYISO does not measure generation from distributed sources and only considers it as a way to reduce the load needed.  The Integration Analysis explicitly includes distributed solar capacity and generation as an output.  Note that existing storage is pumped hydro but any new storage will be batteries.  Finally, it is notable that both modeling analyses project that 2040 DEFR will be comparable to existing fossil capacity albeit NYISO projects significantly more and Integration Analysis a little less.

I compare the energy produced (GWh) for the two models in the next table.  The largest difference between the models is that NYISO projects that DEFR generates ten times more energy.  It turns out that NYISO has DEFR generating 14% of the total energy in 2040 but Integration Analysis projects only 1%.  NYISO projects more onshore wind than offshore wind and the Integration Analysis projects the opposite.  There is huge difference between solar but I believe that is related to the fact that NYISO does not explicitly include distributed solar.   Clearly the two models handle storage differently.

I noted earlier that I was disappointed that the Hochul Administration ignored my comments on the Integration Analysis.  The capacity factor table shows one of the points I made in my comments.  I pointed out that the Integration Analysis land-based wind capacity factors were unrealistically high.  The model projected the 2020 generation with a capacity factor of 29% but the 2021 observed capacity factor was only 22%.  As a result the Integration Analysis projections for the land-based wind needed to meet the load is too low.  For all renewable resources the Integration Analysis capacity factors are higher than the NYISO projections.  I prefer the projections from the organization responsible for New York reliability to those from the unelected bureaucrats who have no such responsibilities. 

There is one other point in this table.  The DEFR capacity factors are different.  To this point the extra capacity needed to keep the lights on during peaking periods was provided by relatively cheap sources of energy.  When new peaking resources were needed, cheap simple-cycle turbines were installed.  Currently peak energy resources are primarily from existing old, amortized facilities.  As we shall see, the new DEFR required to keep the system working will use much more expensive resources.  In our deregulated system the NYISO will have to develop a market payment scheme to cover those increased costs.

As noted earlier, I believe that the NYISO projections based on more sophisticated modeling has a much better chance than the Integration Analysis to describe a mix or resources that will maintain current reliability standards.  Nonetheless, I have reservations about any projections because the future electric grid will depend on unprecedented amounts of renewable energy resources.  The following slide lists six of concerns for an electric system dependent upon renewable resources.  For my presentation I only mentioned the first three.  Because wind and solar are intermittent that means you have to have storage for daily, seasonal, and peak load requirements.  The lack of an implementation plan ignores that wind and solar success is location specific.  New York needs a plan that encourages development where the resource is better during the winter lulls.  Specifically, it is not a good idea to offer the same incentives to utility-scale developments on the Tug Hill plateau where over 200” of snow are common as areas where snowfall amounts are lower.  The third concern is reliability services and they are a reason that wind and solar are far more expensive for deliverable energy than fossil.

I found a good summary of the essential reliability services in a paper by National Renewable Energy Laboratory authors entitled Getting to 100%: Six strategies for the challenging last 10%.   It describes ancillary services that must be provided to keep the transmission system going.    Wind and solar do not provide those services so someone, somewhere else has to provide them at some additional cost.

The ultimate reliability problem is 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 firm capacity (DEFR) is needed to meet multi-day periods of low wind and solar resource availability.  The Council has known about the problem all along but have basically pushed it aside as inconvenient.  The thing to remember is that in order to prevent catastrophic blackouts caused because intermittent wind and solar are unavailable, NYISO and the Integration Analysis are both banking on DEFR capacity.  Using wind, solar and storage exclusively makes meeting the worst-case renewable resource gap much more difficult.

There is no doubt that the fate of future reliability is inextricably tied to DEFR success.  The next slide discusses DEFR options.  The Draft Scoping Plan acknowledges the need for DEFR and proposes seasonal hydrogen storage as a placeholder technology.  NYISO, while explaining that the resource is necessary, has offered no recommendations what technology could fill the need.  The NREL authors of Getting to 100%: Six strategies for the challenging last 10% described six DEFR strategies

  • Seasonal storage which could be hydrogen or some other kind of long term storage solution
  • Renewable energy is basically overbuilding with battery energy storage.  I believe this represents the preferred approach of those who claim existing technology is sufficient.
  • Existing technology adherents also claim that demand side resources can flatten the load peaks so much that less DEFR is needed
  • The problem with other renewables (e.g. hydro) in New York is that they cannot be scaled up enough to meet identified needs
  • Nuclear is the only proven and scalable DEFR technology currently available but it is a toxic option for NY politicians
  • Carbon capture is unacceptable to the activists and has technological challenges that make it an unlikely a DEFR option.
  • Because of the challenges of carbon sequestration to net out the 15% net-zero emissions, the Draft Scoping plan mentions the CO2 removal strategy but in my opinion it is unlikely.

There are two approaches advocated by those who believe that existing technology is sufficient to maintain electric system reliability in a zero-emissions electric grid.  Some claim that only minimal storage is needed because renewables are available somewhere else, that is to say, the wind is always blowing somewhere.  Others claim that overbuilding renewables supplemented with battery energy storage systems is a viable solution.

While the concept that the wind is always blowing somewhere else is indisputably true the issue is that in order to keep the lights on we need power at specific times and places from a dedicated source.  New York City’s peaking turbines were located in specific locations to maintain reliability and they were dedicated to that application.  New York’s reliability standards were developed based on decades of experience that showed that a certain installed reserve margin would guarantee that New York reliability standards could be maintained.   Against that backdrop consider the following weather map on February 17, 2021.  The Texas energy debacle was associated with this intensely cold polar vortex huge high pressure system.  Remember that winds are higher when the isobars are close together.  On this day there are light winds from New York to the southeast, west, and north including the proposed New York offshore wind development area.  There are packed isobars in northeastern New England, in the western Great Plains, and central Gulf Coast.  In order for New York to guarantee wind energy availability from those locations, wind turbines and the transmission lines between New York and those locations would have to be dedicated for our use.  Otherwise I think it is obvious that jurisdictions in between would claim those resources for their own use during these high energy demand days.  It is unreasonable to expect that building those resources for a once in a few years situation could possibly be an economic solution.

Another way of looking at this issue is to consider the NYISO fuel mix data available at the NYISO Real-Time Dashboard.  I downloaded four days of February 2021 data to generate the following table.  It shows that a high pressure system reduces wind resource availability across the state.  The data show that less than a quarter of the daily wind capacity is available for this period. Note that the worst-case hour on 2/18/21 at 7:00 AM wind production was only 138 MW out of a New York total of 1,985 MW for a capacity factor of 7%.  If we were to overbuild wind resources to replace the fossil capacity of 7,191 MW on that hour you would need 102,729 MW of wind resources.

Clearly, overbuilding alone is not a viable solution.  You have to have new energy storage and the currently available technology is battery energy storage systems.  Both the Integration Analysis and NYISO Resource Outlook optimized the balance between renewables and storage but still found that DEFR was needed.  Existing technology proponents claim that over-building wind, solar, and storage is viable but have not countered the NYISO or Integration Analysis modeling results.  I am concerned about the risks associated with the current preferred technology: lithium-ion storage battery systems.  The first risk is logistical inasmuch as battery storage footprints are larger than the existing peaking turbine sites so finding space for the batteries is an issue.  Worse is the fact that lithium-ion storage batteries have the risk of thermal runaway fires and explosions that trade an acute health risk for chronic, and speculative, in my opinion, risks.  Paul Christensen, Professor of Pure and Applied Electrochemistry at Newcastle University in the United Kingdom gave a presentation at PV magazine’s Insight Australia event in 2021 that describes the risks. His videos of thermal runaway tests are terrifying.  He is one of the world’s leading experts on battery fires and safety and said global uptake of lithium-ion battery technology has “outstripped” our knowledge of the risks.  He also stated that he is “astounded and appalled that if there is no appreciation of the safety issues involved” with large battery energy storage systems.  This is another feasibility issue that is unaddressed by the Draft Scoping Plan.

Hydrogen storage is the Draft Scoping Plan DEFR placeholder technology.  The plan is to use wind and solar electrolysis to produce “green” hydrogen from water.  The stored hydrogen would either be combusted to power turbines or used in fuel cells.  There are fundamental issues associated with the use of hydrogen that I detail on my blog.  Hydrogen generation, storage and use loses much more energy than alternatives and may not even have a net energy benefit so it is unlikely to be sustainable.  In order for it to provide the necessary peaking power in New York City a colorless, odorless, hard to store explosive gas will have to be stored and used.  I don’t think that the technology will be embraced in the City.  All the infrastructure necessary to produce, store, and use will have to be built and paid for to meet a projected capacity factor of 2%.  I doubt that makes economic sense.

I concluded my discussion of the risks to electric system reliability by summing up the NYISO Resource Outlook Key Findings Datasheet.  According to the organization that is responsible for keeping the lights on, DEFR is necessary for future reliability.  Because a politically acceptable DEFR that can be scaled up to meet the levels needed for reliability is not currently available, a new technology has to be developed, tested, and put on line well before 2040.  The NYISO makes the point that until you have the necessary DEFR technology on line shutting down existing fossil generation is inappropriate.  I am disappointed that the NYISO Resource Outlook has not mentioned any costs.  This is likely to be a particular issue relative to DEFR.  Clearly conditional implementation dependent upon the availability of DEFR would be a rational approach.

There is no documentation that lists the specific costs of control strategies, the expected benefits, or the expected emission reductions making it impossible to estimate the total costs of the Climate Act.  That information is necessary to determine whether the Integration Analysis projections are feasible. The Draft Scoping Plan claims that the cost of inaction is more than the cost of action but a variation of this graph is the only documentation for that claim.  I directly addressed this misleading and inaccurate statement in my comments at the Syracuse public hearing but there has been no response or mention of the issues I raised at any Climate Action Council meeting.  The statement is misleading because costs are given relative to the Reference Case and not a business-as-usual case as explained earlier.  I believe that the Reference Case includes at least the cost of the “already implemented” electric vehicle mandate.  That means that all of the costs for electric vehicles, charging infrastructure, and distribution system upgrades necessary for electric vehicle charging are excluded from the cost of action.  Correcting that “trick” would mean the costs of action are more than the costs of inaction. 

There is another egregious cheat that further undermines the claim.  It is inaccurate because the Draft Scoping Plan counts the societal benefits of avoided greenhouse gas emissions multiple times.  My Draft Scoping Plan comments on benefits documents why I believe that their claim for $235 billion in societal benefits should only be $60 billion.  Their approach is equivalent to me saying that because I lost 10 pounds five years ago, I can say that I lost 50 pounds.  Correcting that error would also by itself invalidate their benefits claim.  Bottom line is that I estimate that the real costs are at least $760 billion more than the imaginary claimed benefits.

In my opinion one of the biggest environmental success stories in my lifetime is the reintroduction of Bald Eagles.  When I moved to Syracuse in 1981 it was inconceivable that it would be possible to see a Bald Eagle from my home but I have seen several in the last few years.  One of the missing pieces of the Climate Act implementation plan is an update of the Cumulative Environmental Impact Statement to reflect the latest estimates of the number of wind turbines and areal extent of solar panels. I worry that the combined effect of all that development will threaten Bald Eagles.

The following table was not included in the presentation but shows the capacity of the resources not considered in the cumulative impact statements. Clearly, much more renewable capacity will be required than has been evaluated.

Comparison of Integrated Analysis Projected Capacity and Cumulative Environmental Impact Statements (MW)

The following table used in the presentation shows the number of wind turbines and areal extent considered in the completed cumulative impact statements relative to the projected numbers in the Integration Analysis.  The Draft Scoping Plan calls for at least 497 more onshore wind turbines, 493 more offshore wind turbines and 602 more square miles covered with solar equipment than has been evaluated in cumulative analysis.

I have considered the avian impact of the Bluestone Wind Project in Broome County New York to show impacts for a single facility. It will have up to 33 turbines and have a capability of up to 124 MW covering 5,652 acres. Over the 30-year expected lifetime of the facility the analysis estimates that 85 Bald Eagles and 21 federally protected Eastern Golden Eagles will be killed. A first-order approximation1 is to scale those numbers to the total capacity projected for the Draft Scoping Plan. This back of the envelope approximation suggests that at least 216 Bald Eagles could be killed every year when there are 9,445 MW of on-shore wind. There were 426 occupied bald eagle nest sites in New York in 2017. In my comments on this topic I stated that the Final Scoping Plan must include proposed thresholds for unacceptable environmental impacts like this.  There has been no response whatsoever to my comment.

When New York’s GHG emissions are considered relative to global emissions I conclude that New York only action is pointless.  In the presentation I compared New York emissions to global emissions in two graphs.  I used CO2 and GHG emissions data for the world’s countries and consolidated the data in a spreadsheet.  I used the New York State GHG data set CO2e AR4 100 year global warming potential GHG values for consistency.   Plotted on the same graph New York GHG and CO2 emissions cannot be differentiated from zero.

When the New York emissions are plotted relative to global emission increases the futility of New York affecting global emissions is shown.  The trend results indicate that the year-to-year trend in GHG emissions was positive 21 of 26 years and for CO2 emissions was positive 24 of 30 years.  In order to show this information graphically I calculated the rolling 3-year average change in emissions by year.  New York’s emissions are only 0.45% of global emissions and the average change in three-year rolling average emissions is greater than 1%.  In other words, whatever New York does to reduce emissions will be supplanted by global emissions increases in less than a year.

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

Despite the fact that the ostensible rationale for GHG emission reduction policies is to reduce global warming impacts, the Draft Scoping Plan continues an unbroken string of the Administration not reporting the effects of a policy proposal on global warming.   The reason is simple.  The change to global warming from eliminating New York GHG emissions are simply too small to be measured much less have an effect on any of the purported damages of greenhouse gas emissions.  I have calculated the expected impact on global warming as only 0.01°C by the year 2100 if New York’s GHG emissions are eliminated.

Conclusion

My presentation explained why I am skeptical of the value of the Climate Act.  Attempting to get to zero emissions is an extraordinary challenge that is downplayed by the Climate Act, the Council and the Draft Scoping Plan so most people are unaware of the likelihood of success.  The experts say we need DEFR but it has to be developed for New York in less than a decade which I believe is unlikely.  There is no reason to expect that the costs won’t be huge despite the Hochul Administration’s cover up of costs and benefits.  The cumulative impacts of the required renewable developments have not been evaluated and could be unacceptable.  There is no plan for implementation so there are going to be problems. Finally, what is going to happen when we have electrified everything and there is an ice storm?  Extreme weather events can have devastating consequences on a more fragile wind and solar electricity network.  I am particularly worried about ice storms.  On a local level it is not clear how the public will be able to survive a multi-day power outage caused by an ice storm when the Climate Act mandates electric heat and electric vehicles but the bigger reliability concern is that fact that ice storms can take out transmission lines.  The January 1998 North American ice storm struck the St Lawrence valley causing massive damage and required weeks to reconstruct the electric grid.  When everything is electrified how will it be possible to rebuild?

Comparison of NYISO Resource Outlook and Draft Scoping Plan Generating Resource Projections

The final version of the important New York Independent System Operator (NYISO) 2021-2040 System & Resource Outlook that addresses New York’s Climate Leadership and Community Protection Act (Climate Act) was released on September 22, 2022.  This post compares the projections for resources needed to meet the Climate Act targets in this report and the Draft Scoping Plan. 

Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies.  I submitted comments on the Climate Act implementation plan and have written extensively on 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 this supposed cure will do more harm than good.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

The implementation for the New York’s Climate Act “Net Zero” target (85% reduction and 15% offset of emissions) by 2050 is underway.  The Climate Action Council has been working to develop plans to implement the Climate Act.  Over the summer of 2021 the New York State Energy Research & Development Authority (NYSERDA) and its consultant Energy + Environmental Economics (E3) prepared an Integration Analysis to “estimate the economy-wide benefits, costs, and GHG emissions reductions associated with pathways that achieve the Climate Act GHG emission limits and carbon neutrality goal”.  Integration Analysis implementation strategies were incorporated into the Draft Scoping Plan when it was released at the end of 2021.  Since the end of the public comment period in early July 2022 the Climate Action Council has been addressing the comments received as part of the development of the Final Scoping Plan that is supposed to provide a guide for the net-zero transition.

I have previously written that the Climate Action Council has not confronted reliability issues raised by New York agencies responsible for keeping the lights on.  The first post (New York Climate Act: Is Anyone Listening to the Experts?) described the NYISO 2021-2030 Comprehensive Reliability Plan (CRP) report (appendices) released late last year and the difficulties raised in the report are large. The second post (New York Climate Act: What the Experts are Saying Now) highlighted results shown in a draft presentation for the 2021-2040 System & Resource Outlook that all but admitted meeting the net-zero goals of the Climate Act are impossible on the mandated schedule.  Recently I wrote about the “For discussion purposes only” draft of the 2021-2040 System & Resource Outlook report described in the previous article and the concerns raised.  It is amazing to me that these issues continue to be ignored.

Description of Resource Outlook and Draft Scoping Plan Mitigation Scenarios

This section compares two alternate approaches to meeting the Climate Act net-zero transition requirements. 

The NYISO Resource Outlook report includes two scenarios that “reflect full achievement of the Climate Act targets”. 

Outlook Scenario 1 – Utilizes industry data and NYISO load forecasts, representing a future with high demand (57,144 MW winter peak and 208,679 GWh energy demand in 2040) and assumes less restrictions in renewable generation buildout options.

Outlook Scenario 2 – Utilizes various assumptions consistent with the Climate Action Council Integration Analysis and represents a future with a moderate peak but a higher overall energy demand (42,301 MW winter peak and 235,731 GWh energy demand in 2040).

The Resource Outlook describes the scenarios:

In both Policy Case scenarios, a significant amount of land-based wind capacity was built by 2040. The model selected land-based wind due to its assumed capital cost, energy output, and capacity ratings. In both scenarios, land-based wind capacity builds to the assumed capacity build limits imposed (~16 GW).

In both scenarios, a significant amount of capacity from renewable generation and dispatchable emission free resources (DEFRs) is projected by 2040, with the most installation forecasted in the last five years, to help offset the projected fossil-fueled generation retirements. Dispatchable emission free resources are a proxy generator type assumed for generation expansion in the Policy Case to represent a yet unavailable future technology that would be dispatchable and produces emissions-free energy (e.g., hydrogen, RNG, nuclear, other long-term season storage, etc.). As noted above, all existing fossil-fueled generation (~26 GW) was modeled as retired by 2040 due to the CLCPA requirement of a zero emissions grid by 2040. In addition, in Scenario 2 the age-based retirement assumption captured the retirement of 12 GW, nearly half the fossil fleet. The models expanded to approximately 111 GW of total capacity for Scenario 1 and 124 GW of total capacity for Scenario 2, inclusive of NYCA generators, BTM-PV, and qualifying imports from Hydro Québec. This level of total installed capacity would be needed in 2040 to satisfy the state policy, energy, and resource adequacy constraints for Scenario 1 and Scenario 2, respectively. Of this total, approximately 85 GW to 100 GW represent generation expansion for Scenario 1 and Scenario 2, respectively, beyond the 9.5 GW planned through state contracts.25 For comparison, the Contract Case has approximately 51 GW of total installed capacity by 2040.

In general, resources take years from development to deployment. By year 2030, roughly seven years from the publication of this report, an estimated 20 GW of additional renewable generation needs to be in-service to support the energy policy target of 100% zero-emission generation by 2040. For reference, 12.9 GW of new generation has been developed since wholesale electricity markets began more than 20 years ago in 1999. Over the past five years, 2.6 GW of renewable and fossil-fueled generators came on-line while 4.8 GW of generation deactivated26. This Outlook demonstrates the need for an unprecedented pace of project deployment, which will require significant labor and materials available for New York over a long period of time.

Offshore wind capacity buildout remains near the 9 GW policy objective through 2040 for both scenarios. This outcome results primarily from the assumed high capital cost of offshore wind technology in the model, which was the highest cost renewable technology available. Additionally, considering the declining marginal capacity reliability value curves assumed, offshore wind at the levels modeled is an inefficient resource to meet peak capacity needs and Locational Capacity Requirements because the capacity contribution of intermittent renewable resources declines as more are added to the system.

Overall, results for Scenario 2 showed a higher level of renewable buildout than Scenario 1, most notably in utility-scale solar capacity, and had a different projection of the capacity expansion throughout the study period as compared to Scenario 1 for all generator types. The main factors for these differences are the assumptions for load forecasts and differences in generator types eligible for capacity expansion as well as the maximum allowable capacity builds by technology type modeled between the two scenarios. One major difference in Scenario 2 is that a reduced land-based wind capacity limit was used, which changed the projection of capacity builds for all types. Notably, the projections for offshore wind were higher earlier in the model horizon (e.g., 2030) in Scenario 2 as compared to Scenario 1 to help achieve the 70 x 30 target.

Two primary drivers are attributable to increased renewable resources in capacity expansion: (1) high operating cost of dispatchable generators, and (2) low capital costs for renewable generators. High fuel (e.g., natural gas prices, clean DEFR fuel prices) and/or high CO2 emissions prices result in significant decrease in fossil generation and subsequent increase in renewable generation earlier than otherwise projected. Low capital costs for renewable generators result in capacity builds much earlier than otherwise projected, and often an increase in the total amount of capacity built.

In terms of the zonal location for capacity buildouts determined by the capacity expansion model, limitations were imposed on the zonal level as to which generator type(s) could build in each zone. For instance, land-based wind was eligible for expansion in upstate regions (Zones A-G), utility-scale solar was eligible for expansion in upstate regions and Long Island (Zones A-G and Zone K), and offshore wind was eligible for expansion in New York City and Long Island (Zones J and K). Dispatchable emission free resource (DEFR) technologies and battery storage were included as generation resource options in all NYCA zones.

The Draft Scoping Plan includes a reference case and four mitigation scenarios.  The first mitigation scenario only includes the initial recommendations of the Climate Act Advisory Panels but it did not meet the targets.  The three remaining mitigation scenarios meet or exceed GHG emission limits and achieve carbon neutrality by 2050.  They all include:

  • Zero emission power sector by 2040
  • Enhancement and expansion of transit & vehicle miles traveled (VMT) reduction
  • More rapid and widespread end-use electrification & efficiency
  • Higher methane mitigation in agriculture and waste
  • End-use electric load flexibility reflective of high customer engagement and advanced technologies

The three mitigation scenarios that meet the Climate Act targets address concerns raised by the Climate Action Council membership:

Draft Scoping Plan Scenario 2: Strategic Use of Low-Carbon Fuels: Includes the use of bioenergy derived from biogenic waste, agriculture & forest residues, and limited purpose grown biomass, as well as green hydrogen, for difficult to electrify applications

Draft Scoping Plan Scenario 3: Accelerated Transition Away from Combustion: Includes Low-to-no bioenergy and hydrogen combustion and accelerated electrification of buildings and transportation

Draft Scoping Plan Scenario 4: Beyond 85% Reduction:  Accelerated electrification + limited low-carbon fuels: This scenario adds additional VMT reductions; additional innovation in methane abatement; and avoids direct air capture of CO2

I prepared Draft Scoping Plan comments on these mitigation scenarios that includes descriptions and a comparison of the differences between them based on Appendix G of the Draft Scoping Plan.  Unfortunately, the documentation is so poor that it does not explain the rationale for the generation sector differences described in the next section.

Comparison of Scenarios

The following table provides an overview of the capacity (MW) and energy generated (GWhr) generating resources in the five scenarios described above.  Because it is difficult to read the table I have also provided a spreadsheet with the table and the input data extracted from the NYISO and Integration Analysis spreadsheets.  I will compare each of the resource categories in the following from 2019 up to 2040 when the state’s electric grid is supposed to be zero-emissions.

The first resource category is nuclear.  There is no significant difference in the capacity and power generated between the scenarios.  They all reflect the irrational shutdown of over 2,000 MW at the Indian Point Nuclear Station and continued operation of the remaining nuclear facilities to 2040.  Despite the fact that nuclear is the only dispatchable emissions-free generating resource that can be scaled up neither analysis believes that additional nuclear power generation could be part of New York’s future.

There are interesting differences between the scenarios in the fossil generation resource category.  Resource Outlook Scenario 1 reduces fossil capacity 19% from 2019 to 2030, keeps it the same in 2035, and then goes to zero in 2040.  Resource Outlook Scenario 2 reduces fossil capacity 33% from 2019 to 2030, reduces it another 9% by 2035, and then goes to zero in 2040.  Note that the energy produced is the same for both scenarios in 2030 but in 2025 Scenario 1 is reduced 8% more. So even though there is more fossil capacity in 2035 in Scenario 1 it is used less.  This is problematic for me because it means that the production resource model is treating the fossil resources differently between the scenarios.  It is not clear what would cause this difference.

The Integration Analysis scenario fossil projections raise similar concerns.  Scenario 2, Accelerated Transition from Combustion, capacity and generation is higher in 2030 compared to the other two scenarios but then does show a marked decrease in 2035.  If it is accelerated, why is it higher in 2030?  Integration Analysis Scenarios 2 and 4 are comparable to Resource Outlook Scenario 1 and Integration Analysis Scenario 3 is comparable to Resource Outlook Scenario 2.  I assume that this reflects similar assumptions by the analysts at NYISO and NYSERDA.

All the Hydro category scenarios show an increase in capacity between 2019 and 2030.  I assume that a large part of that is due to the Clean Path New York (CPNY) and Champlain Hudson Power Express projects. 

The remaining categories are the key parts of the transition.

The land-based wind (LBW) resource category is the first where there are significant differences between the Resource Outlook and the Integration Analysis scenarios.  Resource Outlook Scenario 1 increases LBW capacity 3.1 times whereas Scenario 2 only doubles the amount in 2030.  Integration Analysis Scenario 2 also doubles capacity by 2030, Scenario 3 goes up 2.7 times, and Scenario 4 goes up 2.4 times.  The differences between scenarios disappear by 2035 but the Resource Outlook projects land-based wind capacity will be 53% higher than the mitigation scenarios in the Integration analysis with 42% more generation.

The NYISO production resource model apparently does not think that offshore wind is a cost-effective option because both scenarios do not increase the projected capacity significantly beyond the Climate Act mandate of 9,000 MW.  On the other hand, the Integration Analysis scenarios nearly double the amount of offshore wind resources projected.   Overall, the Resource Outlook offshore wind capacity is 40% lower than the average of the Integration Analysis scenarios and generation is 43% lower. 

For the solar resource there is a significant difference between Resource Outlook Scenario 1 and all the other scenarios.  The capacity is 63% lower and the generation is 71% lower than the averages of the other scenarios.  In 2040 the capacity factor for the projected resource capacity and expected generation is a reasonable 15% for Resource Outlook Scenario 1 whereas Resource Outlook Scenario 2 is 17% but 21% for the Integration Analysis scenarios.  In my opinion I question why there is a difference for the Resource outlook scenarios. I don’t think that the Integration Analysis expectation that the solar capacity factor can bas high as 21% in 2040 is reasonable for New York’s latitude and snowfalls.

The energy storage resource category capacity values are pretty much the same all the scenarios.  However, the generation projections are presented differently so that it is not possible to compare them.

As noted in the Resource Outlook, the Dispatchable Emissions-Free Resource (DEFR) category is a proxy generator type that represents a yet unavailable future technology that would be dispatchable and produces emissions-free energy (e.g., hydrogen, RNG, nuclear, other long-term season storage, etc.).  The DEFR capacity and generation is substantially higher in Resource Outlook Scenario 1 and all the other scenarios.  Even Resource Outlook Scenario 2 is higher than the Integration Analysis scenarios.  In addition, Resource Outlook Scenario 1 capacity factor is 9% whereas the others are all around 2%.

Getting to 100%: Six strategies for the challenging last 10%

My most recent post described a recent paper, Getting to 100%: Six strategies for the challenging last 10%, that provides a concise evaluation of six zero-emissions technologies.  It is instructive to consider these strategies in the context of these projections.  The authors from the National Renewable Energy Laboratory provided the following summary of the challenge:

Meeting the last increment of demand always poses challenges, irrespective of whether the resources used to meet it are carbon free.  The challenges primarily stem from the infrequent utilization of assets deployed to meet high demand periods, which require very high revenue during those periods to recover capital costs.  Achieving 100% carbon-free electricity obviates the use of traditional fossil-fuel-based generation technologies, by themselves, to serve the last increment of demand—which we refer to as the ‘‘last 10%.’’

The Getting to 100% paper describes six strategies that are summarized in the following table.  Note that the strategies are compared to an ideal solution.  Ideally, the solution for peak loads would have low capital expenses and low operating expense, low resource constraints, be technologically mature, have low environmental impacts, and work well with other resources.  Needless to say, no technology comes close to meeting those ideal conditions.  The authors note that: “Although existing studies generally highlight the same fundamental causes associated with the last 10% problem, there is a lack of consensus on the preferred strategies for meeting this challenge. This is not surprising, given the diversity of possible solutions and the speculative nature of their costs, given their early stage of development.”

The Getting to 100% paper described strategies for the last 10% challenge which for this resource refers to increasing the use of wind, solar, and storage to cover what I call the ultimate problem.  Both the Resource Outlook and the Integration Analysis models predict that the primary resource for this challenge will be seasonal storage using DEFR.  Although there are mentions of the other strategies the emphasis is on the dispatchable emissions-free resource.  The proxy technology in the Integration Analysis is hydrogen although the production and use options are not specified. 

There are other options for seasonal storage.  The report notes:

This group of technologies is not well defined, but it could include batteries with very low-cost electrolytes capable of longer-than-diurnal durations. Because of the requirement for very low-cost energy storage, most seasonal storage pathways focus on hydrogen, ammonia, and other hydrogen-derived fuels stored in geologic formations.

Ultimately the Getting to 100% paper evaluates hydrogen used either in a combustion turbine or a fuel cell for electricity production.  In the New York implementation plan the dispatchable emissions-free resource (DEFR) place holder is hydrogen produced using wind and solar.  There are members of the Climate Action Council that insist that the hydrogen has to be used in a fuel cell rather than a combustion turbine because combustion causes emissions.

The Draft Scoping Plan calls for the use of so-called “green hydrogen” whereby hydrogen is produced by a carbon-free process of electrolysis from water. The Draft does not include a feasibility analysis of the production and use of hydrogen in some form as the placeholder technology for DEFR.  The Resource Outlook does not specify a specific technology but emphasizes the risks of depending upon an unproven technology: “Both scenarios include significant DEFR capacity by 2035, but it is important to note that the lead time necessary for commercialization, development, permitting, and construction of DEFR power plants will require action much sooner if this timeline is to be achieved.”

I submitted a Draft Scoping Plan comment specifically addressing this presumption.  I do not believe that the Integration Analysis correctly accounted for the energy needed to produce the hydrogen needed for the DEFR requirement. I think that there will be siting issues for all the fuel cells, electrolyzers, pipelines, and hydrogen storage facilities.  .  In the exisitng system the generating sources assigned for peaking power for this reliability requirement used the cheapest technology available (simple-cycle gas turbines).  Meeting this requirement in the future using the hydrogen DEFR resource will be using the most expensive generating technology available.  The capacity factors for this resource in the Draft Scoping Plan are 2% for all mitigation scenarios so it will be difficult to cover these costs for the short periods needed.  I guarantee the usual suspects will complain about profiteering when the costs spike during these periods.

In addition, the Getting to 100%: Six strategies for the challenging last 10% report notes that “current high-cost electrolyzers need to operate almost continuously to recover their capital expense”.  The Draft Scoping Plan plans to use intermittent wind and solar that preclude any continuous processes.  That issue has been completely ignored in the Draft Scoping Plan. 

Recall that there are members of the Climate Action Council that insist that hydrogen used for electric generation has to be used in fuel cells.  The Getting to 100% paper addresses fuel cells:

Fuel cells have diverse applications, but their use for bulk power generation is currently limited. Given the range and scale of applications especially for transportation, substantial capital cost reductions for fuel cells are possible. With low capital costs for combustion turbines and future potential cost reductions for fuel cells, the economic case for hydrogen mainly hinges on lowering the cost of electrolytic hydrogen.

According to Table 1 in the Getting to 100% paper, it really is a stretch to say that there are any positive aspects for using hydrogen.  For hydrogen used in combustion turbines the report claims low capital expenses (apparently referring only to the combustion turbine but not including the generation of the hydrogen itself), medium operating expenses and resource constraints, and concerns about hydrogen storage and transport as well as competition for using hydrogen in other sectors.  For hydrogen used in fuel cells there is a potential for low capital expenses, high operating expenses, low resource constraints (apparently referring only to the fuel cell and not assuming that the hydrogen is generated with wind and solar resources), low technological maturity, and the same other considerations as hydrogen used in combustion turbines.

Discussion

This analysis found significant differences between the projections for land-based wind, offshore wind, energy storage and dispatchable emissions-free resources in the Resource Outlook and the Integration Analysis.  I think that those differences should be discussed in an open forum.  Most importantly to New York citizens the costs associated with the different options have to be made available from the NYISO and Climate Action Council.  I am pretty sure costs account for the differences in the NYISO scenarios but without that information we cannot be sure.  Most importantly, the feasibility of a dispatchable emissions-free resource has to be addressed and the projected DEFR utilization difference between Resource Outlook Scenario 1 and all the other scenarios reconciled.  I also believe that both organizations have to address the economic viability challenge of DEFR stemming from the infrequent utilization of those assets deployed to meet high demand periods, which require very high revenue during those periods to recover capital costs. 

Moreover, the forum should also address implementation concerns raised by the New York State Reliability Council in their 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.

One final point about the modeling analyses.  The programs are proprietary and the documentation is sparse so it is not possible to fully understand the results.  For example, the Integration Analysis Accelerated Transition Away from Combustion scenario has higher fossil generation projections in intermediate years than the other scenarios.  Untangling the reason for that would be a challenge.  I believe that the models can create projection differences as much by input tweaks as by the projection algorithms.  Because the models are so complicated and include so many input parameters the modelers have to be careful to limit changes between scenarios that could affect the outcomes.

Conclusion

I have repeatedly made the point that the differences between the NYISO projected resources and the Integration Analysis projections need to be reconciled.  This post attempted to explicitly list those differences.  Unfortunately, this concern does not seem to be shared by the Climate Action Council and the Hochul Administration.  It is only a matter of time until the ramifications of this abrogation of responsibility affects reliability and affordability of the state’s electric grid.

The other unresolved issue is the feasibility of any dispatchable emissions-free resource.  It is staggering that the State is pushing ahead without an independent analysis of the options available for this critical resource.  As it stands it will not end well.