Category: Climate Act Feasibility

Guest Post Draft Scoping Plan Comments on Practicality and Others

This post describes the comments submitted on the Climate Leadership and Community Protection Act (Climate Act) Draft Scoping Plan by Gary R. Schoonmaker. If I knew how to do guest posts on this site, I would have made this a guest post.  My apologies but I am going to have to wing it.

Gary R. Schoonmaker is a lifetime citizen of New York State; a licensed Landscape Architect with over 18 years experience at an electric and gas utility in New York State; and involvement in many environmental organizations in Central New York. He designed and built an energy efficient home in 1978 which had an air-to-air heat pump and now has solar panels; and has over 40 years experience in real estate development.

Schoonmaker Verbal Comments

On April 26, 2022, Schoonmaker used his two minutes at the public hearing at the College of Environmental Science and Forestry in Syracuse (3:22:15 of the video recording) to present his credentials and raise serious concerns about the practical limitations on implementing the plan as proposed in the draft scoping plan.  If you want a good overview of the comments then I recommend his comments in no small part because of his effective presentation.

He described his verbal comments as follows:

In my testimony, I questioned the reasonableness of coercing compliance from state residents instead of offering people a solution similar to previous energy transitions where people chose the change themselves, e.g. kerosene or whale oil to electricity, or horses to automobiles. One could add any number of other transitions: pony express to telegraph, telegraph to radio, radio to television; crank telephone to corded telephone to wireless to cell phones; coal or wood to other fossil fuels for space heating; open windows to air conditioning; the list goes on and on! The commonality for all of these is that people chose to adopt these changes for themselves because they believed the new technologies bettered their lives and were in their own best interests. The government did not dictate or coerce the whole of society to change based on their assumed wisdom. They trusted the people to make the best decisions for themselves.


In the present situation however, the government, in the form of the State Legislature, the Governor, the Climate Action Council, and other agencies (including the Public Service Commission), have now decided they know best and are proposing to use the power of the State to coerce change because they think they know best. No gas connections after 2024; no gas appliances after 2030; no fossil fueled vehicles after 2035……. And on and on with little regard for the desires of the citizens or their freedom to live their lives as they see fit.

I also addressed the impracticality of doubling the capacity of the electrical system: generation; transmission; distribution, in the next eight years as proposed. Ask anyone in the utility industry with experience in constructing new facilities how long it takes to design, get approval for and construct new or even upgraded facilities and they will tell you that doubling capacity in eight years (or less) is not only impractical, but impossible. Even if by fiat the State was to order such a change, there is little recognition in the plan for the social upheaval that would result from constructing hundreds of miles of new transmission lines and digging up every urban area and suburban neighborhood with underground utility services for years in order to implement the upgrades.

Written Comments

I have posted the complete set of comments for your information.  Because they are so extensive, I am not going to provide them all here.  Instead, I will provide some highlights of the main points presented.

The comments pointed out the practical problems converting the entire energy system to electricity.  The schedule is impractical solely due to the number of conversions of homes, businesses, and vehicles.  Throw in supply chain, technology development needs, and supporting infrastructure requirements he notes that the level of this transition on the proposed schedule just can’t work as proposed.

He raises philosophical concerns.  He asks “how sure are we that climate change is real; that man is the principal driver of climate change; that man’s actions can be modified to effect a meaningful change; and that such change would actually benefit mankind?”  I particularly like his discussion of “settled science”:

Man-induced climate change is not “settled science” no matter what we are told. In fact “settled science” is an oxymoron to science itself. Science is the continual process of questioning everything. When someone tells you not to question, they have stopped being scientists and become politicians with an agenda. In fact, there are many highly qualified scientists who question the theory of man-induced climate change and the practicability of man being able to control the climate in meaningful ways. Honestly, the idea that men can control climate is egotistical at best and ridiculous at worst. Man is much more capable of adapting to, rather than controlling climate or weather.

He also raises technical issues with climate modeling.  I like this comment:

They are trying to project the climate for the next hundred years. Really!?! There are so many data points and interactions, that such an effort is futile. Considering that the input data is from a couple of hundred of years at best, the period of record seems horrifically short considering that climate has been changing for thousands of years. Then they want us to believe that they understand and have programmed the models to accurately predict the interactions of the millions of variables.

He also raises two legal issues: 

When is the New York State Environmental Quality Review Act (SEQRA) triggered and the plan subjected to that review?

The plan appears to violate the “taking” provision of the United States Constitution’s 5th amendment and the New York State Constitution.

In my opinion the response to the SEQRA question raised will be that they did do an analysis.  However, to my knowledge they have not evaluated the current projections for wind, solar, and energy storage development.  Also note that there is a generating type called dispatchable, emission-free resource that is projected to have a capacity (MW) approximately equal to the current fossil-fired capacity.  They cannot possibly determine environmental impacts without knowing what that resource will be.

The legal question about the taking” provision of the United States Constitution’s 5th amendment and the New York State Constitution is an interesting point.  As he points out “the forced abandonment of natural gas systems, fossil fired generation facilities, natural gas appliances, personal and commercial fossil fueled vehicles, and perhaps other privately held property, would constitute a “taking” and therefore require compensation”.  There is no indication in the Draft Scoping Plan that those costs have been considered.

Schoonmaker also raised ethical issues:

At what point does the concept of individual freedom become subservient to the State’s coercive powers? This is something that is questioned in far more than the subject at hand, but in this case, as in earlier energy transitions, people should not be coerced under an arbitrary and unsubstantiated timeline, but allowed to choose for themselves as the change actually benefits them at the proper time. In the meantime, we can all adapt as we see fit.

He concludes:

Instead of the heavy-handed coercion of the present plan (and even legislation), we should slow down and let people choose for themselves as the technology matures and provides the incentives for people to change if it benefits them. I have a friend who just bought a hybrid pick-up truck and he is very happy with it. Perhaps that is a better way to go than pure electric. This draft plan doesn’t allow for that option.

Natural gas is a relatively clean fuel as is nuclear, but both are excluded.

Hydrogen and fuel cell technology also hold significant promise for working towards the goals of the plan, but would be excluded if the plan was to be implemented as scheduled. People at the hearings made strong arguments for winterizing older homes as an initial step towards reaching the goals of the plan, but they were apparently dismissed for not being aggressive enough. Actually, aggression is a good word to describe the proposed plan: aggressive and confrontational and offensive to the American principles of individual freedom, free choice and justice.

My Thoughts

I had not thought of the transition in the way Schoonmaker described it in his comments before I heard him speak.  His point that this transition is different is spot on.  In the past energy transitions occurred because it was in the best interests of society because of cost and quality of life improvements.  In this transition we are expected to swallow more expensive, less convenient energy options because we are told the science says we have to do it.  However, when we ask questions about that science, we are told it cannot be questioned and that we are deniers for even considering that maybe the rationale is not as strong as we have been told.  Schoonmaker questions the climate science but notes that he is not a climate scientist.  Neither am I but at its core the belief that anthropogenic greenhouse gas emissions will cause an inevitable climate crisis is an air pollution meteorology problem.  I have 45 years experience in that field and I know the air pollution science does not support the energy transition proposed.  The climate science part of this is only a portion of the whole issue and very few climate scientists have the air pollution background necessary to understand the limitations of their approach.

The same tactic is being used for the energy transition.  Schoonmaker has enough experience in the electric energy sector to know that transitioning away from the current system to one dependent upon wind and solar generation poses real risks to affordability and reliability.  The Climate Action Council’s last meeting included one member claiming that raising that concern is “misinformation”.  With all due respect, he simply does not understand if that is what he believes.  The Council has not adequately addressed the reliability concerns raised by people who understand the issues.  If the Administration does not step in and insist that the Final Scoping Plan reconcile their concerns, then it will lead to unaffordable electricity and catastrophic reliability problems.

Climate Act and New York State 2021 Wind Resources

The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050. One of the targets is a zero-emissions electricity grid by 2040.  In order to meet that target the plan is to expand wind and solar generating resources.  This post looks at the 2021 wind resource availability relative to Climate Act expected wind resource builds.

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 have written extensively on implementation of New York’s response to climate change risk because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that it will adversely affect reliability, impact affordability, risk safety, affect lifestyles, and will have worse impacts on the environment than the purported effects of climate change in New York. 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. Moreover, the reductions cannot measurably affect global warming when implemented.  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 establishes a “Net Zero” target by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”. They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council. Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that quantified the impact of the strategies. That analysis was used to develop the Draft Scoping Plan that was released for public comment on December 30, 2021.

Draft Scoping Plan Wind Resources

The Integration Analysis has three mitigation scenarios.  The Mitigation Scenarios Summary Fuel Mix table projects that 9,445 MW of on-shore wind capacity will need to be developed in the Scenario 2, “Strategic Use of Low-Carbon Fuels”; 10,154 MW in Scenario 3, “Accelerated Transition Away from Combustion”; and 11,052 MW in Scenario 4, “Beyond 85% Reductions”. 

At this time the New York Independent System Operator (NYISO) is preparing its capacity expansion projections.  I previously described that effort and noted that the analysis includes 27 sensitivity cases in addition to the preliminary baseline.   With the caveat that those projections are the first draft and could change significantly, it is important to note that the preliminary baseline projection for land-based wind is 22,789 MW and that the sensitivity cases range from 16,702 MW to 31,678 MW.  Clearly, at some point the differences between the Integration Analysis and the NYISO projections have to be resolved given that the NYISO is projecting on the order of double the Integration Analysis.

2021 Wind Resources

The NYISO Gold Book summarizes New York load & capacity data.  It includes a table that lists pertinent information for every generating unit in New York.  I have been extracting wind facility information so that I could calculate capacity factors for many years as shown in this table.   In 2021 two new facilities came on line.  At the start of the year the nameplate capacity of all the wind facilities was 1,985 MW and it increased to 2,191 MW after the new facilities came on line.  However, the capacity factor, the actual generation produced relative to the maximum possible generation was only 22.3%.

I found another NYISO resource dated March 31, 2021 that provides the 2021 wind production  the 2021 wind curtailment.  The data sets list the hourly total wind production and curtailments for the entire New York Control Area (NYCA).  I have summarized the data in the following table.  Curtailments are those hours when the system load is small enough that wind production is greater than what is needed so the wind power is curtailed, i.e., not used. 

With respect to production, I believe that these data show that the New York wind resource is not particularly good.  The percentiles are shown in the first column and the data indicate that wind power is greater than 78% of the total capacity only 87 hours (99th percentile) in 2021.  Three quarters of the time the production is less than 696 MW equivalent to one third of the total capacity.  If you assume that production less than 10% is the threshold for no value then wind won’t be producing appreciable power 30% of the time.   

Discussion

These results have an important ramification for resource planning.  The existing wind facilities are spread across the state.  NYISO cannot provide individual unit generation so I cannot definitively say that those facilities are highly correlated.  However, given that half the time the total generation capacity is only 16% of the total I am sure that is the case.  As a result, that improving energy production at the lower levels requires a lot more generation capacity.  For example, at the 25th percentile the total capacity is 151.6 MW.  If planners predict we need wind generation capacity to equal 1,000 MW 75% of the time. then, based on 2021 data, the state land-based wind capacity would have to increase to 13,900 MW, over six times greater than current capacity

The key point of this article is that there are limitations to New York’s wind resource capability.  Dietmar Detering and I have corresponded about the Integration Analysis wind resource projections.  He has found that “The Integration Analysis predicts between 10,997 MW and 13,239 MW of land-based wind installed within New York by 2050, and estimates annual generation between 31,224 GWh and 37,896 GWh which corresponds to a capacity factor of about 33%.  My capacity factor table shows that the maximum state-wide capacity was 28% in 2014 and was only 22.3% in 2021.  The Climate Action Council needs to reconcile those differences.

There are a few possible explanations.  New York’s decreasing capacity factors could reflect the age of the fleet.  The Integration Analysis could reflect larger wind turbines that have higher capacity factors because they can reach higher wind speed layers.  In either case that suggests that all the New York existing land-based wind facilities need to be replaced.  There is insufficient documentation available in the Draft Scoping Plan to confirm whether the Plan assumes complete replacement.  As far as I can tell the Integration Analysis assumes “indefinite” expected lifetimes for energy storage, wind and solar infrastructure and assigns lifetimes to other resources despite the fact that renewable resource lifetimes are half that of other resources.  Given that creative bookkeeping I doubt that existing resource replacements are included in the total costs of the mitigation scenarios.

Conclusion

The Climate Act 2040 zero-emissions target will require much greater reliance on wind and solar generating resources.  Unfortunately, the authors of the Climate Act did not recognize limitations for those resources.  These results show that land-based wind in New York is not a particularly good resource.  Winter time solar is poor because of New York’s high latitude with short days in the winter and excess cloudiness downwind of the Great Lakes.   Overall, New York’s has a poor wind and solar resource capability.

It is imperative that the State conduct a detailed evaluation of renewable energy resource availability to determine the generation and energy storage requirements of the future New York electrical system.  As these results show, the annual wind resources capabilities are low. I submitted comments in March that explain that in order to ensure electric system reliability for an energy system that depends on renewable generators and energy storage, the resources available during periods of low wind and solar energy production must be known.  To date, many studies do not consider the importance of worst-case conditions on reliability planning and I believe that the Draft Scoping Plan also fails to address this issue.  The comments explained that there is a viable approach that could robustly quantify the worst-case renewable energy resources and provide the information necessary for adequate planning.