Climate Act Feasibility – Page 2 – Pragmatic Environmentalist of New York

Zero by 2040 Technoeconomic Assessment – Resource Comparison

The New York State Energy Research & Development Authority (NYSERDA ) recently announced the completion of its Zero by 40 Technoeconomic Assessment (Zero by 40 Report). The report directly addresses what I think is the biggest reliability risk of the Climate Leadership & Community Protection Act (Climate Act) net-zero electric system transition. I summarized the report in my previous post. This is a companion article that does not include the background information in the first article and just compares the technologies evaluated

I am convinced that implementation of the New York Climate Act net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks. I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 600 articles about New York’s net-zero transition. The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The current focus of Climate Act implementation is on meeting the interim reduction target of a 40% GHG reduction by 2030 and the all electricity must be generated by “zero-emissions” resources by 2040 mandate. My previous post provides more background.

The previous post explains that the Zero by 40 report was prepared in response to the Public Service Commission (PSC) recognition that there is a “need for resources to ensure the reliability of the 2040 zero-emissions electric grid mandated by the Climate Act”. A May 2023 Order notes that the Climate Act directs the PSC to establish a program to ensure that the electric sector targets are achieved and explains that “there is a gap between the capabilities of existing renewable energy technology and expected future system reliability requirements.” It concludes: “This Order responds to the Petition and initiates a process to identify technologies that can close the gap between the capabilities of existing renewable energy technologies and future system reliability needs, and more broadly identify the actions needed to pursue attainment of the Zero Emission by 2040 Target.” This class of technologies has been dubbed Dispatchable Emissions-Free Resources (DEFR). This Zero by 40 Report responds to that order.

I acknowledge the use of Perplexity AI to generate a summary of the report used as an outline and to provide references included in this document.

Technologies Evaluated in the Zero by 40 Technoeconomic Assessment

I had originally planned only a second companion article about the implications to the Climate Act to my summary post but decided that I needed to describe the technologies too. Section 1.4 in the Zero by 40 Report describes the technologies evaluated:

This report evaluates potential resources that can provide firm energy and capacity in a zero-emissions power sector. The study examines seven technology categories that could serve as DEFRs. These technologies are grouped into three resource groups based on their expected operational characteristics. While some resources can be configured to serve different roles, these groupings reflect constraints on costs, emissions, and availability in New York State, which are discussed later in the report.

Low-capacity factor resources can be deployed during periods of high demand and low renewable generation, offering reliability, fast-ramping capabilities, and no duration limitations, assuming fuel availability, but are not operated as baseload units due to plant economics. Low-capacity factor Resources include:

Hydrogen (H₂)

Renewable natural gas (RNG) and renewable diesel (RD)

High-capacity factor resources operate the majority of the year and can provide reliable baseload power, including power during challenging events, but are less suitable for fast ramping or frequent starts and stops. High-capacity factor resources include:

Advanced nuclear

Carbon capture and storage (CCS) on thermal plants

Geothermal

Gap-rightsizing resources can help balance supply and demand to adjust the capacity gap. While they do not generate electricity directly, they enhance the utilization of other clean resources. Gap-rightsizing resources include:

Long duration energy storage (LDES) – Note that this refers to interday storage 10-36 hours

Virtual power plants (VPP)

Figure 1 provides an illustrative example of the role of these different DEFR resource groups. While renewables play a significant role in overall power generation, the high-capacity factor resources supplement renewables by providing an additional source of baseload power. Low-capacity factor resources help to meet peak demand when renewables are insufficient. Gap-rightsizing resources can shift generation or load, increasing the value of renewable generation by mitigating intermittency to balance supply with demand.

Figure 1. Role of DEFR Resource Types in Meeting Electricity Demand

Source: New York State Energy and Research Development Authority (NYSERDA). 2025. “Zero by 40 Technoeconomic Assessment, Final Report.” Prepared by Electric Power Research Institute, Palo Alto, CA. Zero by 40 Technoeconomic Assessment

Operational Characteristics

Figure 2 from the Zero by 2040 Report describes the characteristics of the three functional categories. It is instructive to consider these resources relative to three categories of generating resource production over time.

Figure 2. Functional Categories of DEFR Resource Types

Technology Assessment Technologies Summary

Chapter 9 in the Zero by 2040 report compares the potential DEFR technologies. The report uses the following criteria: performance attributes, readiness by 2040, infrastructure and supply chain readiness dynamics, project lead times, emissions and other considerations, cost, and scalability for 2040. Instead of looking at individual technologies the Chapter 9 summary describes the results for the three functional DEFR categories.

The Report describes Low-capacity factor resources as follows:

Low-capacity factor resources offer high flexibility and responsiveness to grid needs. They can be deployed during periods of high demand and low renewable generation, offering reliability and fast-ramping capabilities without duration limitations, assuming fuel availability. These resources are expected to be critical in any future zero-emission grid. However, they are expected to operate for only a limited number of hours per year due to a high operating-to-capital cost ratio, primarily driven by the cost of fuel, as well as fuel availability constraints. The low capacity factor resources evaluated in this study are H2, RNG, and RD.

The Low-Capacity resource summary states:

Low-capacity factor resources are expected to critical in any future zero-emission grid, offering reliability and fast-ramping capabilities on days with the most extreme system needs. Each technology evaluated has advantages and challenges. Infrastructure constraints and high costs may limit the widespread availability of H2 in 2040, but low GHG emissions, especially for green H2, will likely provide value across various industries in 2040 and beyond, making investments in pilot projects and eventual strategic infrastructure deployment important from an economywide perspective.

RNG and RD may be the most viable low-capacity factor resources for 2040 deployment given their technology readiness, existing fuel transport infrastructure, and ability to serve as drop-in fuels in existing plants. However, the combination of feedstock limitations, competition for fuels from other sectors and states, and GHG considerations necessitates limiting their use to low capacity factor applications.

High-capacity resources are described as follows:

High-capacity factor resources operate the majority of the year, providing reliable baseload power. These technologies can meet existing and growing load, reducing the need for both high-cost low-capacity factor DEFRs and some intermittent renewable deployment, often with a lower land footprint on a per-capacity basis. They also typically provide inertia and other ancillary grid services to support a grid increasingly dependent on variable renewables. While they have some ramping capabilities, they are less suitable for fast ramping or frequent starts and stops. This analysis compares LLWRs, lwSMRs, non-water-cooled reactors, NG combined cycle plants with 95% carbon capture and storage (CCS), and next-generation geothermal systems.

The High-Capacity resource summary states:

High-capacity factor resources are valuable for meeting existing load and expected load growth. While renewables are projected to supply most of the energy demand in 2040, high-capacity factor resources can provide firm power and grid services that support reliability in a predominantly renewable grid. Their high energy density also helps mitigate potential land-use challenges associated with large-scale renewable deployment. High-capacity factor resources could also reduce the need for low capacity factor resources, which are expensive and mostly idle. However, high-capacity factor resource technologies require long lead times, often 10 years or more. To ensure they are operational by 2040, stakeholders must take early action.

Each technology offers unique advantages and faces specific challenges. From a deployment-readiness perspective, LLWRs and CCS are the most prepared for near-term implementation. However, lwSMRs and non-water-cooled reactors could also become commercially viable by 2040. Geothermal, while promising, has lower readiness and limited scalability in New York State.

Gap-Rightsizing Resources are described as:

Gap-rightsizing resources help balance supply and demand, addressing the firm capacity gap. While these technologies do not generate electricity directly, they enhance the potential of other clean resources. They are expected to have significant value even today due to opportunities for energy arbitrage and infrastructure cost avoidance but will not be sufficient on their own to meet all grid needs due to duration limitations and because they do not generate electricity on their own. This study considers two main categories of Gap-Rightsizing Resources: LDES and VPPs. LDES includes mechanical, electrochemical, and thermal storage technologies. Within each of these buckets are several technologies with a range of attributes.

The Zero by 2040 report does not summarize this category. Both of the gap-rightsizing resources LDES and VPP are largely ready for deployment. Costs for VPP are lower than other technologies but depend on costumer participation which makes availability uncertain. Furthermore, there are limits to the energy potential of this technology. LDES batteries will be more expensive, but “has the potential for longer discharge durations and higher operational certainty, but it is also a net load on the grid due to the need to recharge and round trip efficiency losses.”

Discussion

There are two missing pieces to the path forward for the May 2023 Order. Someday some is going to have make recommendations about these technologies. The PSC needs another order specifying how it intends to “identify the actions needed to pursue attainment of the Zero Emission by 2040 Target”

The following caveat in Chapter 9 suggests the other component needed to move forward:

Most of the comparison focuses on comparing technologies within three resource groups: low capacity factor resources (hydrogen and biofuels), high capacity factor resources (advanced nuclear, carbon capture and storage, and next-generation geothermal), and gap-rightsizing resources (LDES and VPPs). Because technologies in different resource groups serve different functions, are expected to operate with very different profiles, and provide fundamentally different value to the grid, direct comparisons across resource groups are difficult and can be misleading. Ultimately, electric system modeling will be needed to understand the least-cost mix of resources and each of their potential unique contributions, which falls outside the scope of this study.

This report says more work is needed. It states that “electric system modeling will be needed to understand the least-cost mix of resources and each of their potential unique contributions, which falls outside the scope of this study.” In my opinion, it is not just the least-cost mix, but also the mix that minimizes reliability risks and environmental impacts. I think that New Yorkers need to know the impacts of this approach relative to impacts of continued use of fossil fuels, a lower-carbon approach that combines increased use of nuclear energy supplemented with fossil fuels where appropriate, and an all-in approach that uses nuclear as much as possible to reduce GHG emissions as much as possible. This report is committed to a mix of resources that includes massive amounts of wind, solar, and energy storage resources.

I also want to comment on the lack of urgency regarding this initiative. Responsible New York agencies all agree that the new Dispatchable Emissions-Free Resource (DEFR) technologies described in this report are needed to make a solar and wind-reliant electric energy system viable during extended periods of low wind and solar resource availability. Every day that a determination whether there is a viable DEFR approach is delayed means the costs, reliability risks, and environmental impacts associated with a wind and solar potentially false solution increase.

Conclusion

This is another reason that New York State needs to pause Climate Act implementation. The Legislature is required by a court decision to revisit the Climate Act to modify the schedule. It would also be appropriate for the politicians who insisted on this course of action to define affordability, reliability risk, and environmental impact boundary conditions that would frame a feasibility analysis be addressed. I further suggest that appropriate metrics be developed that ensure that implementation stops if those boundary conditions are exceeded. New Yorkers need to demand that the politicians who passed the Climate Act become accountable for its impact.

Zero by 2040 Technoeconomic Assessment Summary

The New York State Energy Research & Development Authority (NYSERDA ) recently announced the completion of its Zero by 40 Technoeconomic Assessment. This report directly addresses what I think is the biggest reliability risk of the Climate Leadership & Community Protection Act (Climate Act) net-zero electric system transition so I believe understanding the implications of the report findings is important. This article provides a summary overview of the report. I will follow up with another post describing the implications.

Overview

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

One fundamental flaw in the Climate Act is the mistaken belief by the authors of the law that existing wind, solar, and energy storage would be sufficient and that no new technology would be required. In May 2023 the Public Service Commission (PSC) initiated a process “to examine the need for resources to ensure the reliability of the 2040 zero-emissions electric grid mandated by the Climate Act” that directly contradicted that presumption. The Order notes that the Climate Act directs the PSC to establish a program to ensure that the electric sector targets are achieved. It goes on:

However, several studies indicate that renewable energy resources may not be capable of meeting the full range of electric system reliability needs that will arise as fossil generation is replaced. These studies suggest that there is a gap between the capabilities of existing renewable energy technology and expected future system reliability requirements.

The Order concludes: “This Order responds to the Petition and initiates a process to identify technologies that can close the gap between the capabilities of existing renewable energy technologies and future system reliability needs, and more broadly identify the actions needed to pursue attainment of the Zero Emission by 2040 Target.” This report responds to that order.

Zero by 40 Technoeconomic Assessment

The announcement for the study stated:

NYSERDA is pleased to share that following yearslong thorough, deliberative analysis in partnership with State agency staff, it has completed its Zero by 40 Technoeconomic Assessment, which is intended to help inform the State’s assessment of the readiness and timing for the introduction of new technologies. The Assessment has been filed with the New York State Public Service Commission to inform stakeholders engaged in the Commission’s proceeding investigating different technologies that could contribute to a zero-emission electricity system.

This article will summarize the report. I acknowledge the use of Perplexity AI to generate a summary of the report and provide references included in this document.

The study was prepared by the Electric Power Research Institute (EPRI) under contract to NYSERDA.

The NYSERDA Zero by 40 Technoeconomic Assessment evaluates technologies needed for New York’s goal of a zero-emissions electric grid by 2040. NYSERDA and Department of Public Service staff “provided guidance, review, and strategic prioritization for this project.”

The Summary of the report gives a good overview. I have annotated the following quotes from the Summary below.

The Summary explains the reason for the report:

In May 2023, the New York State (NYS) Public Service Commission (PSC) issued an order initiating a process “to identify technologies that can close the gap between the capabilities of existing renewable energy technologies and future system reliability needs, and more broadly identify the actions needed to pursue attainment of [New York State’s] Zero Emission by 2040 target.” New York State has engaged in this process by conducting a study to evaluate candidate technologies that could close the gap.

The authors of the Climate Act relied on analyses that used a simplistic model of the electric system to conclude that no new technologies would be needed. The Summary describes the nuances not considered by the Climate Act authors:

A 2040 zero-emission grid will require resources with a mix of attributes to maintain reliability requirements. These include resources that can provide energy and capacity for long durations, that are dispatchable and flexible with quick-start and fast ramping capabilities over multiple starts in a day, and that can provide inertial response, frequency control, dynamic reactive control, and high short circuit current contribution to the grid. Every resource does not need to provide every attribute, but the grid needs enough of each to maintain reliability.

Meeting these needs will require a diverse set of resources. This includes intermittent zero-emission energy resources such as solar and land-based and offshore wind, short-duration energy storage, legacy resources like hydropower and existing nuclear, dispatchable emissions free resources (DEFRs), transmission infrastructure, and other technologies that can provide grid services, like grid-forming (GFM) inverters. This report focuses on DEFRs.

The Summary describes the technologies evaluated in the report:

This report evaluates seven candidate DEFR technology categories that could provide clean, firm power to the NYS grid to achieve a zero-emissions power sector. The candidate resources include hydrogen, biofuels (such as renewable natural gas [RNG] and renewable diesel [RD]), advanced nuclear, carbon capture and storage on thermal power plants, next-generation geothermal, long-duration energy storage (LDES), and virtual power plants (VPPs).

The next paragraph in the Summary describes the problem. In my opinion, the statements also reveal the bias of the EPRI authors and the guidance from NYSERDA and DPS. There is no consideration of the potential finding that nothing might be affordable and technically feasible within the constraints of the Climate Act. The report is skewed towards optimism that technologies can solve this challenge within the constraints of a net-zero grid.

Given that these technologies are not currently deployed at scale, each is expected to require a varying degree of innovation and deployment support. However, all of these technologies can still contribute usefully to the grid, and any present challenges faced by an individual technology should not exclude it from consideration. Even as certain technologies may see structural deployment obstacles in some regions—for example, near urban settings—smaller and more targeted deployments remain possible.

I had difficulty interpreting the following paragraph. I think it ranks the options. Things like hydrogen that require pipelines and fuel storage facilities are less preferable than the other options.

To continue reliably serving New York State’s energy needs, the State will need to deploy resources with more limited infrastructure barriers in the near term. Technologies that require significant infrastructure build, such as new pipelines, fuel storage facilities, and additional transmission, add costs and complexity. Therefore, resources with fewer infrastructure needs will play a crucial role in reliably and cost-effectively providing zero-emission electricity.

The next paragraph supports my belief that they are ranking the options.

Each resource has characteristics that make it better suited for some use cases over others. Figures S-1 and S-2 show how these candidate resources were classified for comparison in this report. This classification is based on resource performance, as well as technology-specific supply, cost, and emission constraints that could affect availability. This resource classification approach is a simplification—in some configurations, technologies could fit into multiple classes.

I think Figure S-2 has important ramifications. However, if I started to address these categories it would make this document too long. I will hold off further discussion for a subsequent post.

Technologies Evaluated

The report assesses seven candidate DEFR technologies based on performance, readiness, emissions, costs, and other factors:

Hydrogen: Explored for use in combustion turbines and fuel cells. This was the place holder DEFR technology in the Scoping Plan.
Biofuels: Recognized for near-term availability but limited by supply constraints.
Advanced Nuclear: Including small modular reactors (SMRs), noted for high-capacity factors and flexibility in meeting energy demands.
Carbon Capture and Storage (CCS): Evaluated for its potential to reduce emissions while utilizing existing fossil-fuel infrastructure.
Next-Generation Geothermal: Assessed for its capability to provide clean, firm power generation.
Long-Duration Energy Storage (LDES): Essential for addressing extended periods of low renewable output, beyond typical battery durations.
Virtual Power Plants (VPPs): Aggregated distributed energy resources that enhance grid flexibility and capacity.

Zero by 2050 Report Conclusions

In this summary article I will just list the conclusion highlights.

A 2040 zero-emission grid will require a mix of attributes to maintain reliability requirements, and meeting these needs will require diverse resources.
A mix of DEFR technologies within and across resource categories will best meet statewide needs, maximize benefits, and minimize the risk associated with overreliance on any one resource. The following three categories were identified:
Low capacity factor DEFR with fast ramping capabilities will play a vital role on days with the most extreme system needs and will be needed throughout New York State. Potential resources such as hydrogen and biofuels are expected to be needed throughout the State to support the grid during peaking events, but each type of fuel faces distinct geographic limitations and cost challenges.
High capacity factor DEFR can help meet growing loads, reduce the need for buildout of some intermittent renewables and mostly idle peaking plants, diversify the energy mix, and provide inertia and other critical grid services to support a grid increasingly dependent on variable renewables. Potential resources such as nuclear, Natural Gas combustion paired with carbon capture, and geothermal can increase energy diversity while meeting load growth, but projects face geographic limitations, high and uncertain capital costs per project, and timeline challenges.
Gap-rightsizing DEFR can balance supply and demand, reduce the need for upgrades to transmission and distribution infrastructure, and provide benefits to consumers even today. Regional variability may require different solutions in different locations. Potential resources such as VPPs and LDES can provide valuable support in balancing supply and demand and reducing infrastructure buildout needs, but they have inherent duration limitations.

The report described actions that can facilitate the readiness of these resources to achieve the scale needed for 2040.

Pursue a diverse set of resources to minimize the risk of overreliance on individual technologies.
Start early to increase the likelihood of readiness by 2040.
Invest in grid-enhancing technologies early to minimize the need for backstop resources.
Invest in innovation to enhance resource viability.
Develop strategies across industries for unlocking key resources with infrastructure hurdles.
Engage early with technology developers, end users, and other stakeholders.
Conduct grid modeling to understand tradeoffs of relying on different resources.
Conduct a regular assessment of options and remain flexible as new technology options come online.

Discussion

I think this report is a good first step towards addressing “the need for resources to ensure the reliability of the 2040 zero-emissions electric grid mandated by the Climate Act.” The question now is where do we go from here? Just like the Scoping Plan and the Draft Energy Plan, this document lists different technologies and their characteristics but does not include a feasibility analysis suitable for putting together an actual implementation plan. The Public Service Commission must propose a plan that can guide implementation, project the potential costs, and propose a realistic timeline. The Legislature should then revise the Climate Act to comply with those requirements.

I think there is a major issue with this report. The document is full of statements that when viewed objectively indicate that the schedule of the Climate Act is not realistic. That calls out for a re-assessment of the Climate Act itself. What is missing is that the authors did not address the presumption that an electric system reliant upon weather-dependent wind and solar resources can safely and affordably prevent a blackout during the worst-case renewable resource drought. I will address my arguments that this is not possible in my next post. In the meantime, I described the challenges just defining the worst case in a filing earlier this year.

Conclusion

In a rational world, New York politicians would announce that they wanted to develop regulations to achieve a zero emissions electric grid and then go to the organizations in New York responsible for the electric system and ask them for a plan. This report should be a component of a future plan to achieve zero emissions. There still is no feasibility analysis, comprehensive estimate of the costs, or realistic timeline to achieve the 2040 zero emissions goal. Instead, we have a Climate Act mandate to achieve a zero-emission electric grid by 2040 because the New York Legislature naively believed it was only a matter of political will. It is long past time that the Public Service Commission should break away from the ideology and admit that the Climate Act schedule and aspiration needs to be revisited.

Climate Act Fork in the Road

I recently described the Oct. 24, 2025, New York Albany Supreme Court decision pitting environmental organizations against the New York State Department of Environmental Conservation (DEC). The judge ordered DEC to issue final regulations establishing economy-wide greenhouse gas emission (GHG) limits on or before Feb. 6, 2026 or go to the Legislature and get the Climate Leadership & Community Protection Act (Climate Act) 2030 GHG reduction mandate changed. I have argued for months that there are so many issues coming up with the schedule and ambition of the Climate Act that it is obvious that we need to pause implementation and consider modifications to the Climate Act. This post summarizes the findings by the State of New York that support that position.

I am convinced that implementation of the Climate Act net-zero mandates will do more harm than good because of reliability and affordability risks. I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written nearly 600 articles about New York’s net-zero transition. The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

For this overview of New York State findings, I acknowledge the use of Perplexity AI to generate summaries and references included in this document.

Court Decision

The most important reason that the Legislature should consider revisions to the Climate Act is the recent court case. Environmental organizations initiated this lawsuit because the New York State Department of Environmental Conservation (DEC) did not promulgate regulations as mandated by the Climate Act. The State agued that regulations were inappropriate but Judge Schreibman’s decision stated that:

DEC does not have the discretion to say no or to decide that it has the authority to choose not to follow the express legislative directive at issue. Under our system of separation of powers, upon concluding, based on its subject-matter expertise, that achieving the goals of the Climate Act might be “infeasible” for the reasons stated, DEC had two options. One, it could issue compliant regulations anyway, and let the chips fall where they may for the State’s political actors. Or, two, it could raise its concerns to the Legislature so that the State’s elected representatives could make a determination about what costs their constituents can or cannot bear in the pursuit of reining in climate change.

This decision should prompt the Legislature to address the concerns raised by DEC. Furthermore, there are other State analyses that indicate that changes are in order as described below.

State Supplemental Letter

As part of the legal wrangling associated with the trial Assistant Attorney General Meredith G. Lee-Clark submitted further correspondence related to the litigation. The State’s submittal addressed “two categories of new developments: (1) the publication of the 2025 Draft New York State Energy Plan by the New York State Energy Planning Board on July 23, 2025 and (2) additional actions by the federal government that impede New York’s efforts to achieve the Climate Leadership and Community Protection Act’s (the Climate Act) goals in a timely manner.”

The State of New York argued that it was inappropriate to implement regulations that would ensure compliance with the 2030 40% reduction in GHG emissions Climate Act mandate because meeting the target is “currently infeasible”. The following paragraph concedes that there are significant upfront cost issues that out-weigh other benefits.

Ordering achievement of the 2030 target would equate to even higher costs than the net zero scenarios and would affect consumers even sooner. Undoubtedly, greenhouse-gas reducing policies can lead to longer-term benefits such as health improvements. This does not, however, offset the insurmountable upfront costs that New Yorkers would face if DEC were forced to try to achieve the Legislature’s aspirational emissions reductions by the 2030 deadline rather than proceeding at an ambitious but sustainable pace.

The letter concluded that the Climate Act is unaffordable:

Petitioners have not shown a plausible scenario where the 2030 greenhouse gas reduction goal can be achieved without inflicting unanticipated and undue harm on New York consumers, and the concrete analysis in the 2025 Draft Energy Plan dispels any uncertainty on the topic: New Yorkers will face alarming financial consequences if speed is given preference over sustainability.

Comptroller Audit

The New York State Comptroller Office audit of the NYSERDA and PSC implementation efforts for the Climate Act was an early acknowledgement that the implementation plan needs to be revised. The report titled Climate Act Goals – Planning, Procurements, and Progress Tracking (“Comptroller Report”) found issues that question the current plan. The Perplexity AI summary concludes that “the audit reveals critical deficiencies in planning, cost assessment, risk management, and progress tracking” and notes that “With outdated data, calculation errors, project cancellations, technology limitations, transmission constraints, and escalating costs all threatening goal achievement, the audit calls for immediate action to improve planning and transparency.”

Clean Energy Standard Biennial Review

The Public Service Commission (PSC) released the draft Clean Energy Standard Biennial Review Report (“Biennial Report”) in July 2024. It compares the renewable energy deployment progress relative to the Climate Act goal to obtain 70% of New York’s electricity from renewable sources by 2030 (the 70% goal). The final document found that 2030 goal will likely not be achieved until 2033. The Perplexity AI summary describes seven key factors impeding progress.

Global economic pressures,

Transmission system inadequacies,

Interconnection delays,

Capacity accreditation changes,

Federal policy uncertainty,

Siting and permitting complexity, and

Increasing electric load.

All these factors are part of the lessons learned since the implementation of the Climate Act that began five years ago. I think this shows that the Legislature needs to address the schedule and ambition of the law.

Second Informational Report

The Climate Act requires the Department of Public Service (DPS) to prepare an annual report as described in the following slide from the presentation that summarizes the report.

The Second Informational Report (Report) prepared by Department of Public Service (DPS) staff “focuses on Commission actions from January 2023 through August 2025, and includes the estimated costs and outcomes from 2023 through 2029 to provide the most up to date information.” According to the Perplexity AI summary there are four feasibility concerns: the 2030 renewable energy target is “likely unattainable”, offshore wind faces major obstacles, transmission remains a “critical bottleneck”, and grid reliability challenges are mounting. There also are cost trajectory concerns. Despite the report’s careful messaging—”emphasizing that CLCPA costs are not the primary bill driver and that multiple factors beyond climate policy contribute to rate increases” – it cannot hide the magnitude of the challenges to meet the Climate Act requirements schedule.

Draft State Energy Plan

The Energy Plan process is currently underway. The New York State Energy Research & Development Authority (NYSERDA) is processing stakeholder comments on the draft document for the Energy Planning Board to consider when it decides whether to approve the draft. I recently highlighted New York Independent System Operator (NYISO) comments on the Draft Energy Plan recommendations. There are six extensive quotations from the Draft Energy Plan that NYISO supports that represent previously unacknowledged concerns about the Climate Act ambition and schedule:

The State will need to be strategic about the pace of combustion unit retirements and/or replacement

Combustion generating units will remain essential parts of electric grid reliability and affordability. Retirement of these units will not be able to occur until resources that provide the same grid reliability attributes are put in place.

A primary challenge for New York’s energy system is its advancing age, which creates unique risks for reliability.

The State will need to be strategic in identifying and integrating clean firm technologies that have the attributes necessary to support the achievement of a zero emissions electric grid by 2040.

For the electricity system, continue to incorporate the impacts of climate change into future reliability planning scenarios.

Consider whether the current reliability-related metrics should be supplemented given the evolving nature of the grid and increased risks of high-impact reliability events

The Perplexity AI summary concludes that:

The 2025 Draft State Energy Plan represents New York’s effort to reconcile the CLCPA’s statutory mandates with economic, technical, and political realities that have emerged since 2019. By acknowledging that key deadlines will be missed while maintaining long-term decarbonization objectives, the plan shifts from aspirational targets to pragmatic pathways.

Discussion

Judge Schreibman’s decision is very straightforward. The law says that regulations must be promulgated to meet the Climate Act mandates so DEC must either do that or get the Legislature to modify the law. If the Hochul Administration cynically appeals the decision, it is simply a politically-motivated delaying tactic to kick the resolution off until after the gubernatorial primary and state-wide election in late 2026. Because there is so much evidence that the schedule and ambition of the law are infeasible, the Legislature should address the law, however unpopular lessons learned reality will be to the environmentalist community.

Bill Gates recently argued that climate change is not going to wipe out humanity and that we need to “put human welfare at the center of our climate strategies.”. That is another argument for modifying the Climate Act. Even if the premise of the Climate Act that human emissions of greenhouse gases is a primary driver of observed warming is true, New York cannot solve climate change by itself. New York GHG emissions are less than one half of one percent of global emissions and global emissions have been increasing on average by more than one half of one percent per year since 1990.

In my opinion, the best way to proceed is to modify the law. Revisions should couple a revised Climate Act schedule with clearly defined standards for affordability, reliability, and environmental impacts. A trackable metric for each should be developed and a tracking system put in place. The key point is that the law should be modified so that there are requirements to modify the mandates when those metrics are exceeded. In short, the safety valve provisions of Public Service Law (PSL) Section 66-P should be modified and incorporated into the Climate Act.

The process to establish these metrics should incorporate extensive public participation. New Yorkers need to understand the range of costs, impacts on personal choice, and changes to lifestyles that are buried in the Scoping Plan and Energy Plan. If the safety valve metrics have reasonable limits, I expect that affordability, reliability, and environmental impact targets will be exceeded as soon as tracking begins. That is the point. Eliminating fossil fuels sounds has been portrayed as simple and cheap but the reality is very different. Accepting that and developing a new way forward is necessary.

Conclusion

There is overwhelming evidence that something must give in the energy transition. The Climate Act has always been about politics and money. The authors of the Climate Act mistakenly believed that the energy transition would be simple and cheap. Experience shows otherwise. It is long past time for the politicians to revisit the Climate Act and make the proposed energy transition accountable. Unfortunately, there is a politically connected constituency that is dependent upon the status quo for their business plans.

NYISO Short-Term Assessment of Reliability October 2025 – Peaker Recommendations

On October 13, 2025 the New York Independent System Operator (NYISO) released its quarterly assessment of reliability of the bulk electric system. I recently published an overview of the report that mentioned I was uncomfortable about some aspects of the recommendations. This post describes the unique reliability rules for New York City that I think were not fully addressed relative to the replacement of New York City (NYC) peaker units.

STAR Report and New York City

The NYISO 2025 Quarter 3 Short-Term Assessment of Reliability (STAR report) was released on October 13, 2025. If you want background information about the report I refer you to my take and what Richard Ellenbogen had to say.

Environmental Justice organizations have made peaking power plants in New York City into an overblown issue, insisting that all peaking power plants must be shut down as soon as possible. Even though the presumption of egregious harm from these plants is based on selective choice of metrics, poor understanding of air quality health impacts, and ignorance of air quality trends, pressure by this special interest constituency resulted in the Build Public Renewables Act of 2023 (BPRA) that mandates shutdown of New York Power Authority peaking power plants by 2030. The NYPA units are state of the art, highly efficient, extremely low emissions, and only 27 years old.

The STAR report findings of interest for this post relate to two old, inefficient, and high emitting peaking turbine facilities that were supposed to be retired earlier based on a Department of Environmental Conservation (DEC) rule if the shutdown did not threaten reliability. The STAR report explains:

In this 2025 Quarter 3 STAR, the Gowanus Gas Turbine 2-1 through 2-8, Gowanus Gas Turbine 3-1 through 3-8, Narrows Gas Turbine 1-1 through 1-8 and Narrows Gas Turbine 2-1 through 2-8 units (collectively “Gowanus and Narrows”) have completed their generator deactivation notices and are now all Initiating Generators, requiring the NYISO and Con Edison to evaluate in this STAR if there are any Generator Deactivation Reliability Needs.

The STAR report identified a short-term reliability need beginning in summer 2025 within New York City primarily driven by a combination of forecasted increases in peak demand and the assumed unavailability of certain generation in New York City affected by the DEC regulation to limit emissions of nitrogen oxides, known as the “DEC Peaker Rule”. The report states:

In accordance with the DEC Peaker Rule, the Gowanus and Narrows generators may extend operation for up to an additional two years (until May 1, 2029) if the NYISO or Con Edison determine that the reliability need still exists and a permanent solution has been identified and is in the process of construction but not yet online. The DEC Peaker Rule, however, does not provide for peaker generators to continue operating after this date without meeting the emissions requirements.

This STAR report concluded these facilities are needed until Bulk Power Transmission Facilities (BPTF) can replace them.

NYC Reliability Rules

Before discussing the Bulk Power Transmission Facilities (BPTF) solution it is necessary to understand the unique reliability rules in NYC. I acknowledge the use of Perplexity AI to generate a summary of these rules. The reason for these rules is that NYC is a load pocket and within the City there are areas that are also considered load pockets. To keep the lights on the following rules have been implemented:

Locational Capacity Requirements Framework – This rule establishes a minimum amount of capacity relative to the expected peak load.
Reliability Rule G.1: New York City System Operations – This rule includes a set of more stringent requirements than used in the rest of the state.
Reliability Rule G.2: Loss of Gas Supply – New York City – This rule requires the system to be operated so that the loss of a single gas facility does not cause a blackout. To meet this rule gas-fired units in the City must be able to burn liquid fuel.

STAR Solutions

This STAR report concluded that the Gowanus and Narrows facilities are needed until BPTF can replace them. A BPTF is basically all the components of the transmission system (lines, transformers, and control systems) needed to move large amounts of electricity to where it is needed.

Consistent with the findings in 2023, this STAR continues to find that the New York City locality (Zone J) would be deficient in the summer through the entire five-year horizon without the completion and energization of future planned projects. This includes deficiencies on the BPTF and non-BPTF within Zone J.

Keep in mind that these facilities are needed to provide power during system peak loads. There are four future BPTF projects described as components of the solution.

Gowanus-Greenwood 345/138 kV feeder – This project will upgrade the electric grid to resolve a local problem in NYC. I do not see any issues with this project.

Champlain Hudson Power Express, 1,250 MW HVDC – This project brings hydropower from Quebec through a dedicated transmission line to NYC. When it first was proposed the peak loads were in the summer. The contract does not guarantee power from Hydro Quebec if it is needed within the province. In the future of the Climate Act, peak loads will shift to the winter when New York winter peak loads increase due to heating electrification. Because this is when Quebec peak loads occur there is a high probability that power will not be available when NYC needs it. I am not sure how the reliability rules will handle that contingency.

Empire Wind, 816 MW offshore wind – According to Perplexity AI, this project is “under active construction and approximately 40% complete as of fall 2025. The project is progressing toward its targeted commercial operation date of 2027.” Summer peak loads occur during heat waves and the meteorological conditions that favor the warmest temperatures are high pressure systems that cause light winds. Those conditions will undoubtedly reduce offshore wind output. Without sufficient storage this facility will not provide anywhere near 816 MW of power when it is needed most.

Propel NY Public Policy Transmission Project According to Perplexity AI, is a major electric transmission infrastructure initiative developed jointly by the New York Power Authority (NYPA) and New York Transco LLC to strengthen the electric grid and enable greater renewable energy delivery across southeastern New York State. The infrastructure creates transmission capacity to deliver at least 3,000 megawatts (MW) of offshore wind energy from Long Island into the broader New York grid, This has the same limitation as the Empire Wind project. Without storage it will not provide energy when needed most. In addition, there are issues associated with additional offshore wind development that suggest that 3,000 MW of offshore wind is unlikely.

The STAR report explains that these projects could address the identified reliability needs. Note however that there is a caveat that these projects must “demonstrate their planned power capabilities before the Gowanus and Narrows generating stations can be retired.” Even then the STAR report mentions potential issues:

The range in the demand forecast for expected weather is driven by key assumptions, such as

population and economic growth, energy efficiency, the installation of behind-the-meter renewable energy resources, and electric vehicle adoption and charging patterns.

Once CHPE, Empire Wind, and the Propel NY Public Policy Transmission Project enter service and demonstrate their planned power capabilities, the margins improve substantially assuming all existing generators remain available, but gradually erode as forecasted demand for electricity grows. Even with the future planned projects delivering power according to schedule, there remains a risk of a Zone J deficiency in summer 2029, following the deactivation of Gowanus and Narrows, assuming all other generators in Zone J are available.

In my overview article on the STAR report I noted that there were issues associated with timing issues associated with the DEC Peaker Rule retirement deadline of May 1, 2029. In my opinion,I think it is unlikely that in-kind replacements will be available by the May 1, 2029 deadline and that means the regulation must be modified.

The Build Public Renewables Act of 2023 compounds the problem requiring retirement of New York Power Authority (NYPA) peaking plants. The STAR report notes that “Beyond 2030, these deficiencies are further exacerbated with increasing demand for electricity and the planned deactivation of the NYPA small plants.”

Discussion

Although NYISO has become increasingly more vocal about the challenges meeting peaking load in the absence of natural gas peaker generating units, I am uncomfortable with the proposed BPTF projects proposed to solve the Gowanus and Narrows energy shortfall.

The primary reason for the unique NYC reliability rules is experience with blackouts. For example, the NYC blackout of July 1977 occurred when a storm knocked out transmission lines coming into the city and there was insufficient in-city generation to keep the system going. Reliability Rule G.1 includes provisions for special operating rules during severe weather, enhanced operating reserves, and operating the system for a more stringent shutdown contingency that address the problems that led to the blackout.

I have great respect for the state’s electric resource planners. The electric system has been called the most complex machine because it is an extraordinarily intricate and vast network involving thousands of generating plants, millions of miles of transmission and distribution lines, and hundreds of millions of users continuously relying on it. The NYISO operators balance load and generation on a second-by-second basis, and the resource planners have provided the resources necessary for them to prevent blackouts. Those peaking units s all provide dispatchable power without weather limitations and provide other ancillary electric system services precisely where needed. Losing those resources makes the challenges even more difficult.

The STAR report warns that the grid is at a “significant inflection point” with converging threats including an aging generation fleet, rapid load growth, and difficulty developing new supply resources due to policy constraints, supply chain issues, and rising equipment costs. In the future Climate Act grid, the renewable resources are going to require Dispatchable Emissions Free Resources (DEFR) during dark doldrums when wind and solar resources are low to non-existent for extended periods to ensure that sufficient energy is available. Complicating the challenge is the fact that those conditions are also associated with extreme temperatures and peak loads. These factors all tweak the system in complex ways that may be too complicated to anticipate.

I know the NYISO and New York State Reliability Council planners are considering the impact of increasing reliance on weather-dependent resources. However, in my opinion, NYISO is not adequately acknowledging the intractable problem with an electric system that relies on renewables. To date the primary concerns about the commercially unavailable DEFR technology are expected to occur in the late 2030’s as renewable penetration increases. This may give time to address the issue.

However, I worry that this problem could become an issue in NYC sooner. The CHPE, Empire Wind, and the Propel NY Public Policy Transmission Project projects are all weather dependent, and I think there is underappreciated correlation between the generating sources. For an intense wintertime dark doldrum CHPE would not provide power if Hydro Quebec needs it for its ratepayers. If the dark doldrum started with a strong snowstorm that ushered in a large high-pressure system, NYC’s rooftop solar units could be covered with snow reducing their output. At the same time, the offshore wind resources could be becalmed. In that scenario short-term energy storage will not be sufficient, DEFR would be needed.

In a recent Capital Tonight segment Susan Arbetter interviewed Earthjustice attorney Rachel Spector.. I made a transcript and added my comments because I think the responses to her questions exemplify the position of environmental organizations that support the Climate Act. It is troubling that in response to a question about the implications of the STAR report, Spector said “Well, this is a complicated issue, and I could talk for a while about what the NYISO put forward but I will say New York is not facing an energy crisis and the reports that are coming out are extremely conservative.”

Fortunately, the NYISO recognizes their responsibility to protect the citizens of New York requires conservative approaches based on decades of experience. The STAR report recognizes that the BPTF projects must demonstrate their planned power capabilities before the peaking units can be retired. Furthermore, the Draft State Energy Plan found that reliability considerations will prevent the shutdown of any of the peaking power plants for the foreseeable future. If the NYISO warnings are heeded and the ideological zealots are ignored the worst-case catastrophe should be avoided.

Conclusion

Keeping the lights on in NYC during peak load conditions is challenging. In the future, the problem will become even more challenging because the meteorological conditions that cause the peak loads also are associated with low wind resource availability. The STAR report lays the foundation to address these challenges but the usual suspects are whining that their recommendations are too conservative.

The NYC peak load problem addressed by the STAR report cannot be endangered by risky unproven environmentalist strategies. Keeping the lights on is incredibly challenging at the best of times and a rushed transition away from existing system components is too risky to consider. The STAR report describes a safe transition approach. I believe that there is adequate time to address my concerns about the over-reliance on weather-dependent resources in the BPTF projects proposed.

The challenges of achieving a 100% renewable electricity system in the United States

I am very frustrated with the New York Climate Leadership & Community Protection Act (Climate Act) net zero transition because the reality is that there are so many issues coming up with the schedule and ambition of the Climate Act that it is obvious that we need to pause implementation and figure out how best to proceed. In my opinion, the Hochul Administration failed to acknowledge that the observed problems were inevitable during the development of the Scoping Plan. This post describes an article that came out in June 2021 prior to the preparation of the Draft Scoping Plan that should have guided the development of the plan.

I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act or CLCPA) net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks. I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 550 articles about New York’s net-zero transition.

The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Net-Zero Aspirations

The Climate Leadership & Community Protection Act (Climate Act) established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050 and has two electric sector targets: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040. The Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda” was based on an Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA). The Climate Act is not the only legislation or regulation that was promulgated to achieve reductions in greenhouse gas emissions to address climate change.

Challenges for a 100% Renewable Electricity System

The article, The challenges of achieving a 100% renewable electricity system in the United States, (Challenge Article) was authored by staff from the National Renewable Energy Laboratory, Office of Energy Efficiency and Renewable Energy, United States Department of Energy and the University of Colorado Boulder, Renewable and Sustainable Energy Institute. That means that it represented the mainstream “consensus” of Federal government renewable energy thinking at the time the New York State Energy Research & Development Authority (NYSERDA) was preparing the Scoping Plan.

The following information is the formal citation for the document.

The challenges of achieving a 100% renewable electricity system in the United States,

Paul Denholm, Douglas J. Arent, Samuel F. Baldwin, Daniel E. Bilello, Gregory L. Brinkman, Jaquelin M. Cochran, Wesley J. Cole, Bethany Frew, Vahan Gevorgian, Jenny Heeter, Bri-Mathias S. Hodge, Benjamin Kroposki, Trieu Mai, Mark J. O’Malley, Bryan Palmintier, Daniel Steinberg, Yingchen Zhang, Joule, Volume 5, Issue 6, 2021, Pages 1331-1352, ISSN 2542-4351, https://doi.org/10.1016/j.joule.2021.03.028.

Abstract:

Understanding the technical and economic challenges of achieving 100% renewable energy (RE) electric power systems is critical, given the increasing number of United States regional and state commitments toward this goal. Although no detailed study of a major utility of large interconnection under 100% RE system has been published, considerable literature explores the potential to greatly increase RE penetration. This literature, combined with real-world experience with increased RE deployment, points to two main challenges associated with achieving 100% RE across all timescales: (1) economically maintaining a balance of supply and demand and (2) designing technically reliable grids using largely inverter-based resources. The first challenge results in a highly nonlinear increase in costs as the system approaches 100% RE, in large part because of seasonal mismatches. The second challenge might require new inverter designs, depending on the mix of RE technologies. Analysis and experience to date point to no fundamental technical reasons why a 100% RE electric power system cannot be achieved, but the economic challenges indicate the need for advancements in several technologies and careful consideration of the suite of options that could be used to achieve equivalent carbon-reduction goals.

Previous work also points to the need for analytic tool development, and techno-economic feasibility analysis must also consider the host of regulatory, market, and policy issues that might limit the ability to deploy mixes of resources that are suggested by least-cost modeling exercises.

Climate Act Technology

One fundamental flaw in the Climate Act was the mistaken belief by the authors of the law, including Dr. Robert Howarth, that no new technology would be required. I have described this erroneous presumption and its impacts many times but will reference just one example.

The Challenge Article provides “a perspective on the most technically and economically challenging

aspects of achieving a 100% RE electric power system while maintaining a reliable, cost-effective balance of electricity supply and demand.” As noted in the Abstract two challenges were emphasized: the need to balance supply and demand and the engineering challenge of incorporating inverter-based resources. Both issues were discounted by the Climate Action Council.

The report concludes that:

Understanding the technical and economic challenges of achieving 100% RE electric power systems is critical, given the assumed role of these systems in achieving many regional and state commitments to reduce GHG emissions on aggressive timelines. Furthermore, these are complex, multidisciplinary challenges that cannot be solved by any individual entity but rather will require collaboration across technical research communities, academia, laboratories, and industry.

In the United States, several regions have met more than half of their load with renewables for multi-hour periods, and studies have indicated pathways to achieve cost-competitive penetrations of RE that are much greater than current levels.

Significant unanswered questions remain regarding moving toward or achieving 100% RE at a national scale for all hours of the year. There is no simple answer to how far we can increase RE penetration before costs rise dramatically or reliability becomes compromised. Studies have found no specific technical threshold at which the grid ‘‘breaks,’’ and we cannot extrapolate from previous cost analyses because of nonlinearities and unknown unknowns. Additional research is needed to evaluate the suite of technologies needed to ensure the supply of RE matches demand patterns across all time periods. Substantial engineering and design are needed to transition the grid from one that is dependent on synchronous machines to one that is based on inverters. This science, analysis, and engineering must consider the interaction of multiple low-carbon technologies to identify least-regrets pathways to decarbonizing both the electricity and energy systems in the United States and internationally.

In my opinion, these findings should have been incorporated into the Scoping Plan. The impacts of the failure to do so are evident now and will be felt for years to come if there is no pause in implementation to consider how best to proceed. While the Climate Act mandates a net-zero transition, the Public Service Commission (PSC) also has a broad mandate to “ensure access to safe, reliable utility service at just and reasonable rates.” It is not at all clear that the Climate Act “zero-emissions” electric system can meet the PSC mandate because of the issues raised in the Challenge Article.

It is Even Worse

The Challenge Article emphasized engineering issues, but I think that they neglected one issue that has received much attention in New York. The Challenge Article included a section on “Exploring the balance challenge” that includes an important graph:

Figure 1 provides a framework to discuss the balance challenge, which conceptually illustrates how the expected costs and challenges might change with increasing penetration of RE. The figure loosely defines regions of annual RE penetration. As discussed in what we know about the balance challenge we know about the balance challenge from real-world re deployment, at current RE penetration levels (18% nationally in 2019), RE is cost competitive with traditional generation sources in many regions of the United States. This is caused by the utility industry cost effectively integrating these resources by addressing the hourly and sub-hourly variability of VRE and load.

Figure 1. A simple framework for discussing the degree of difficulty and cost of increased RE deployment

Beyond these levels, we reach the second zone, where studies discussed in what we think we know about the balance challenge from grid studies have explored how the diurnal mismatch problem might be cost effectively addressed with some combination of current and near-future technologies to reach annual contributions in the range of 80% RE. Beyond this point, in the third zone, the seasonal balance may require technologies that have yet to be deployed on a large scale, with highly uncertain costs and requirements.

I think a fourth zone is appropriate. The Challenge Article emphasis on the engineering challenges neglects the weather challenge. Any electric system reliant on weather-dependent resources like wind and solar must address the dark doldrums, the extended periods of low wind and solar resource availability. The Scoping Plan, Integration Analysis, New York Independent System Operator (NYISO), and independent analysis by Prof. C. Lindsay Anderson, Chair of Department of Biological and Environmental Engineering Cornell all have noted that a new category of generating resources called Dispatchable Emissions-Free Resources (DEFR) is necessary to keep the lights on during these periods. This topic has received much attention at this blog because of my background as a meteorologist and is covered at my DEFR page.

I have incorporated the DEFR challenge as a fourth zone into the Figure 1 simple framework in Figure 2. I think that this problem will be more expensive and more challenging than the seasonal problem so it must be added to the figure. New York is addressing DEFR in Case 15-E-0302 – Proceeding on Motion of the Commission to Implement a Large-Scale Renewable Program and Clean Energy Standard, but progress has been slow given that there is agreement that the resource is needed but there is no state recommendation how to proceed.

Figure 2 Modified simple framework for discussing the degree of difficulty and cost of increased RE deployment

I believe the only likely viable DEFR backup technology is nuclear generation despite its costs because it is the only candidate resource that is technologically ready, can be expanded as needed, and does not suffer from limitations of the Second Law of Thermodynamics. If the only viable DEFR solution is nuclear, then the wind, solar, and energy storage approach cannot be implemented without nuclear power. Nuclear power works best as a baseload resource so using it solely as DEFR backup is inappropriate. Developing baseload nuclear eliminates the need for a huge DEFR backup resource and means that the “build as much as we can as fast as we can” wind and solar buildout currently in progress is unnecessary. When all the costs associated with the proposed Scoping Plan wind, solar, and energy storage approach are compared to an electric system based on nuclear I believe that nuclear will be cheaper especially if life expectancies are considered.

There is another argument in favor of abandoning weather-dependent resources in favor of nuclear. To ensure that there are sufficient backup resources the magnitude and duration of a dark doldrum must be determined. That is a significant challenge because of the tradeoff between the enormous costs of this necessary but infrequently used resource and the risks if insufficient electric energy is available when the de-carbonized energy system is completely electrified. This economic and safety tradeoff is not an issue in a de-carbonized system that relies on nuclear energy.

Conclusion

I want to emphasize two points. This comprehensive analysis should have been incorporated into the Scoping Plan discussions because it makes an irrefutable case that there are unsolved issues that require further research. Given that uncertainty, the Scoping Plan should have incorporated safety valves if the issues are unsolved at certain points in the transition. The second point is that the article did not address the dark doldrum DEFR problem so it underestimates the challenges of a 100% renewable system.

This is further evidence that a pause is necessary in Climate Act implementation.

In Search of the Climate Act Safety Valve

Proponents of the New York Climate Leadership & Community Protection Act (Climate Act) don’t acknowledge that there are affordability and reliability safety valves. Worse, the rate case proceedings ignore them too. This post documents references to Public Service Law 66-p safety valves in the New York State Department of Public Service (DPS) Document and Matter Management Proceedings.

I am convinced that implementation of the Climate Act net-zero mandates will do more harm than good because the energy density of wind and solar energy is too low and the resource intermittency too variable to ever support a reliable electric system relying on those resources. I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 540 articles about New York’s net-zero transition. The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

Safety Valves

Public Service Law (PSL) Section 66-P Establishment of a renewable energy program includes subsection 2 that states that the commission shall establish a program to require that:

a minimum of seventy percent of the state wide electric generation secured by jurisdictional load serving entities to meet the electrical energy requirements of all end-use customers in New York state in two thousand thirty shall be generated by renewable energy systems; and

that by the year two thousand forty (collectively, the “targets”) the statewide electrical demand system will be zero emissions. In establishing such program, the commission shall consider and where applicable formulate the program to address impacts of the program on safe and adequate electric service in the state under reasonably foreseeable conditions. The commission may, in designing the program, modify the obligations of jurisdictional load serving entities and/or the targets upon consideration of the factors described in this subdivision.

These two requirements are mandates in the Climate Act so Public Service Law 66-P is simply executing those provisions. It charges the Public Service Commission (PSC) with implementing renewable energy programs but includes feasibility safety valve conditions for affordability and reliability. Section 66-p (4) states: “The commission may temporarily suspend or modify the obligations under such program provided that the commission, after conducting a hearing as provided in section twenty of this chapter, makes a finding that the program impedes the provision of safe and adequate electric service; the program is likely to impair existing obligations and agreements; and/or that there is a significant increase in arrears or service disconnections that the commission determines is related to the program”.

I have started following some of the rate cases for electric and gas services which are universally requesting markedly higher rates. Based on what I have found so far. program costs to implement the Climate Act mandates are part of the reason that the costs are increasing. The rationale to include those programs is that the Climate Act is a law that requires it. Thus far, they have ignored the safety valve provisions of 66-p(4).

The DPS Document and Matter Management (DMM) system is the online repository for all cases before the Public Service Commission. There are thousands of cases in the system and individual cases can have thousands of filings. Before the availability of artificial intelligence programs, it was impossible for me to determine how many of the filings in the system referred to the safety valve provisions in 66-p(4). Now I can check out whether anyone besides me is questioning this requirement.

Response to DMM Safety Valve References Query

This post describes the findings to the following question I posed to Perplexity AI: “In the New York State Department of Public Service Matter Master Proceedings have any of the filings acknowledged Public Service Law Section 66-P, Establishment of a renewable energy program requirements section 66-p (4)? This section quotes the Perplexity AI response with my annotated comments. Note that I have included links for the references. I want to make the point that AI is not without faults so I do not claim that the following documents are the only ones with references to PSL section 66-p(4).

The order (Case 15-E-0302) adopting the modifications to the Clean Energy Standard for consistency with the Climate Act describes all the provisions of PSL 66-P. If this reference had not shown up, then the AI search would have failed.

Direct Acknowledgment of PSL Section 66-P(4) in DPS Proceedings

Clean Energy Standard Case (15-E-0302)

The most significant acknowledgment of PSL Section 66-P(4) appears in Case 15-E-0302, the proceeding on the Clean Energy Standard Reference Link 1.In this case, the Commission explicitly recognized that “PSL §66-p(4) provides the Commission with authority to ‘temporarily suspend or modify’ the obligations created by the Program if, after conducting a hearing, it finds that the Program ‘impedes the provision of safe and adequate electric service,’ ‘is likely to impair existing obligations and agreements,’ and/or is related to ‘a significant increase in arrears or service disconnections'” Reference Link 1.

At least one entity acknowledged that there are bounds to the implementation of the Climate Act. I do not know if there were others or just this example.

Independent Power Producers Filing

Independent Power Producers of New York, Inc. (IPPNY) filed comments in Case 15-E-0302 that directly reference PSL Section 66-P(4) Reference Link 2. Their filing states that “the CLCPA is also carefully bounded to ensure reliability and affordability, providing that ‘the Commission may temporarily suspend or modify’ the program if it finds ‘that the program impedes the provision of safe and adequate electric service; the program is likely to impair existing obligations and agreements; and/or that there is a significant increase in arrears or service disconnections that the commission determines is related to the program'” Reference Link 2.

The following response illustrates a shortcoming of AI searches. I suppose I could have refined the search to ask for the number of unique individual stakeholders who referenced 66-p(4) but I did not. The quotation is from one of my submittals and I know I have referenced this safety valve numerous times. I suspect that the reference to multiple public comments means the search program found my comments in multiple filings.

Public Comments and Stakeholder Acknowledgment

Individual Stakeholder Comments

Multiple public comments filed in DPS proceedings have acknowledged PSL Section 66-P(4) Reference Link 3. One commenter specifically stated: “Section 66-p (4) states: ‘The commission may temporarily suspend or modify the obligations under such program provided that the commission, after conducting a hearing as provided in section twenty of this chapter, makes a finding that the program impedes the provision of safe and adequate electric service; the program is likely to impair existing obligations and agreements; and/or that there is a significant increase in arrears or service disconnections that the commission determines is related to the program'” Link 3.

The Perplexity AI report incorrectly refers to environmental advocacy comments twice. In the first instance, the comment was from a renewable developer instead of an advocacy group.

Environmental Advocacy Comments

A September 2024 filing by Darren Suarez directly quotes PSL Section 66-P(4), noting that “the law grants the Commission the power to temporarily suspend or modify the program, but only after a hearing and a specific finding” Reference Link 4. This filing acknowledges the statutory framework while expressing concerns about the State’s ability to meet the legal standards for suspension Link 4.

It is interesting to note that the State Comptroller noted the requirement in its July 2024 audit of Climate Act progress.

State Comptroller’s Office Recognition

The New York State Comptroller’s Office has acknowledged PSL Section 66-P(4) in its audit reports of Climate Act implementation Reference link 5. The Comptroller’s report states: “According to the Climate Act, PSC may temporarily suspend or modify obligations after a hearing if it determines the implementation of the renewable energy program is impeding the provision of safe and reliable electric service, impairing existing obligations or agreements, or resulting in a significant increase in arrears or service disconnections” link 5.

The New York University School of Law Institute for Policy Integrity was referenced but the link provided does not work.

Academic and Legal Analysis

Policy Integration Analysis

Academic and policy analysis documents filed in DPS proceedings have recognized the significance of PSL Section 66-P(4) as a safeguard mechanism Reference Link 6.These analyses acknowledge that while PSL Section 66-p charges the Commission with implementing renewable energy programs, “it does not alter the extent of the Commission’s jurisdiction or authority to do so” and that the Commission should “carry out its responsibilities under PSL Section 66-p within the bounds of its jurisdictional constraints” Link 6.

The second reference to environmental advocacy also mislabeled the commenter. I am not sure real environmental advocates would count this website as one of their own, but Perplexity AI did.

Stakeholder Process Documentation

Environmental advocacy groups have noted that PSL Section 66-P(4) establishes “safety valve criteria” for renewable energy program implementation Reference Link 7. These comments emphasize that “it is incumbent upon the Commission to define ‘safe and adequate electric service’ and ‘significant increase in arrears or service disconnections’ before the LT Plan is implemented” Link 7.

The reference for the following section is to a PSC order to “measure and track compliance with, and develop and consider proposals to implement, the provisions” of the Climate Act.

Regulatory Framework Context

Commission Authority Recognition

DPS staff documents and Commission orders acknowledge that PSL Section 66-P(4) provides necessary flexibility in renewable energy program implementation Reference Link 8. The Commission has recognized that this provision ensures renewable energy programs can be adjusted if they compromise electric system reliability or create significant customer impacts Link 8.

Procedural Requirements

Several filings acknowledge the specific procedural requirements of PSL Section 66-P(4), particularly the requirement for conducting a hearing “as provided in section twenty” before any suspension or modification can occur Link 1 and Link 3. This procedural safeguard ensures due process in any decision to suspend or modify renewable energy program obligations.

Discussion

The Comptroller report audited Climate Act progress and acknowledges the safety valve and then makes the ultimate point:

PSC’s mission is to ensure affordable, safe, secure, and reliable access to utility services for the State’s consumers at just and reasonable rates while protecting the natural environment and to stimulate effective competitive markets for clean, renewable, and distributed energy resources along with product and service innovations to benefit consumers. PSC thus must determine the rates are reasonable for both the consumer and the producer so that New York can successfully transition to the level of renewable energy it desires to achieve.

One of the key findings of the Comptroller report addressed affordability:

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

The problem is that PSC has not determined whether the rates are reasonable and the transition can provide safe, secure and reliable energy. Nor has it established the criteria to trigger a hearing if the program impedes the provision of safe and adequate electric service; the program is likely to impair existing obligations and agreements; and/or that there is a significant increase in arrears or service disconnections that the commission determines is related to the program.

With regards to the rate case expenditures, the utilities are in a difficult spot. They are under tremendous pressure to invest in mandated programs to achieve Climate Act goals. However, when they include the costs for those programs the costs go up so much that there is as much pressure to keep the rates down. In my opinion, their rate case filings should at least acknowledge that there are limits to how much money can be squandered trying to decarbonize New York.

In my opinion, the Hochul Administration is doing everything in its power to hide the costs of Climate Act implementation. On July 20, 2023 the first annual informational report (“Informational Report”) on the implementation of the Climate Act was released. It included a description of financial data from 2022. There hasn’t been an update since the initial report.

Conclusion

This search for the safety valve provisions in DMM filings found multiple references to it, albeit a large percentage were my submittals that have been mostly ignored. Importantly there is no sign that the provision has not been addressed by DPS. This is more consistent with political pressure to focus on renewable energy program expansion than to protect the interests of New York ratepayers.

I recently evaluated National Grid Upstate New York customer in arrears data and found that there has been a significant increase in arrears. On the face of it that could be a safety valve trigger. However, it is impossible to determine whether there has been a significant increase in arrears related to the Climate Act because there have been no updates to the DPS Informational Report and the other Agency information highlighted by the Comptroller Report.

Given the magnitude of the rate case proposed increases observed, it long past due for the DPS and NYSERDA to provide sufficient financial status information to determine the impact of the Climate Act. I believe that the Commission should hold a hearing as provided in PSL 66-P because it is likely that the safety valve triggers have been exceeded.

NYISO 2025 Power Trends Report

Recently the New York Independent System Operator (NYISO) released Power Trends 2025. This is the NYISO’s annual analysis of factors influencing New York State’s power grid and wholesale electricity markets. This post highlights some of the key points made.

I am convinced that implementation of the Climate Act net-zero mandates will do more harm than good because the energy density of wind and solar energy is too low and the resource intermittency too variable to ever support a reliable electric system relying on those resources. I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 500 articles about New York’s net-zero transition. The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” After a year-long review, the Scoping Plan was finalized at the end of 2022. Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation. One law is Public Service Law Section 66-P Establishment of a renewable energy program that requires the Public Service Commission to establish a program to meet the interim targets for 70% of the energy delivered in 2030 “shall be generated by renewable energy systems” and that “by the year two thousand forty the statewide electrical demand system will be zero emissions”.

The Power Trends Resources landing page provides documentation and links to the Power Trends 2025 report itself, and a Power Trends Fact Sheet. The Fact Sheet describes the report and summarizes the findings:

Power Trends explores the issues and challenges shaping the grid of the future based on the latest economic data, forecasts of peak demand and changing generation mix. Our 2025 report underscores the heightened uncertainty of future system conditions and key assumptions such as population and economic growth, installation of behind-the-meter renewable resources, electric vehicle adoption and charging patterns. Specifically, the impact on the load forecast of several energy-intensive economic development projects, such as data centers and semiconductor manufacturing, provides additional forecasting and planning challenges.

I have summarized the key points made in the Fact Sheet, the Power Trends report and the Press Release with my comments.

Reliability Margins

The Fact Sheet, Power Trends Report, and Press Release emphasize the concern about declining reliability margins. The Press Release explains:

Generator deactivations are outpacing new supply additions. Electrification programs and new large-load customers associated with economic development initiatives are pushing projected demand higher. Together, these forces are also narrowing reliability margins across New York and increasing the risk of future reliability needs.

Recent Power Trend reports have included the declining reliability margins issue. The following figure shows last year’s status compared to this year. The decline in margin is mostly because fossil units are retiring faster than zero emissions replacements are coming on-line.

Fossil Plants

All three NYISO documents note that the average age of the fossil fleet is increasing. They also point out the advantages of modernizing old fossil facilities. The Press Release explains:

Repowering aging power plants can lower emissions, meet rising consumer demand, and provide reliability benefits to the grid that are needed to integrate additional clean energy resources.

The declining margin and the age of the fossil plants reflects a lack of foresight by the New York Department of Environmental Conservation (DEC) who has been pressuring existing power plants to reduce emissions or shut down.

Power Trends states that: “Repowering aging power plants can lower emissions, meet rising consumer demand, and provide reliability benefits to the grid that are needed to integrate additional clean energy resources.” DEC has rejected several repowering applications to replace existing old generators with modern new facilities because of the Climate Act. Unfortunately, there is no direct link between the proposed facilities and a particular reliability issue, so DEC rejected the applications. This is an example of poor New York energy planning – the permit decisions were considered in isolation not in the context of the system. While I applaud the fact that this is a recommendation of Power Trends, it is also fair to ask why the NYISO did not intervene in the repowering applications.

New Load Growth

Future reliability margins will also be affected by new load growth. The Fact Sheet and Report note that “New high-tech, AI and data center projects are having an impact on future electric demand and load growth”. Figure 1 from the Report notes that 2,567 MW of new load capacity is needed by 2035 and the document notes that other projects could add around 1,900 MW of capacity after that. I am disappointed that the NYISO Report did not mention that these new load centers require constant energy and clean power that is free from electrical noise, surges, voltage spikes, and drops which exacerbates the challenge of the Public Service Law Section 66-P “Establishment of a renewable energy program” requirements.

Winter Shift

The three NYISO documents all note that the peak loads are projected to shift to the winter from the summer. The Press Release notes that:

New York is projected to become a winter-peaking electric system by the 2040s, driven primarily by electrification of space heating and transportation. On the coldest days, the availability of natural gas for power generation can be limited, and interruptions to natural gas supply will introduce further challenges for reliable electric grid operations.

There is another unmentioned issue with winter peaking. When the Public Service Law Section 66-P “Establishment of a renewable energy program” electric system that relies on wind and solar generating resources is in place, the winter solar availability is much lower than in the summer. This is another challenge that I think the Power Trends report should have acknowledged.

Competitive Market

The Fact Sheet, Power Trends Report, and Press Release all extoll the power of competitive markets to support the transition while maintaining reliability and minimizing consumer costs. The NYISO is a product of the de-regulated competitive market. The report explains that: We are committed to administering and overseeing the competitive electricity markets as the most cost-effective way to attract and retain new resources to meet our reliability needs as we transition to a decarbonized grid.” I do not share their optimistic outlook for the ability to attract and retain new resources. At this time, it is not clear what kind of resources and how much of those resources are needed, so the presumption that they can design a market to attract those resources is questionable.

Interconnection Process

The three NYISO documents all note that there are interconnection issues. The Press Release states:

New supply, load, and transmission projects are seeking to interconnect to the grid at record levels. NYISO’s interconnection processes continue to evolve to balance developer flexibility with the need to manage the process to more stringent timeframes.

This is an issue that is directly within the purview of NYISO, and it is a problem. Power Trends describes proposed modifications to the process but does not acknowledge that there are fundamental issues. Many of the new projects are inverter-based resources and integrating this new category of resources is problematic for grid stability and reliability. Regulatory frameworks are under development to address this problem, and this has contributed to the interconnection delays.

Discussion

The Climate Act was promulgated without consideration of feasibility. Nowhere is this more impactful than with respect to the schedule. A rational New York energy plan would implement the zero-emission resources before retiring existing generating resources. New York is not rational. Despite the obvious delays in construction of new supply and transmission due to a whole host is issues the Hochul Administration has not broached the possibility of postponing any Climate Act targets.

The current Climate Act implementation plans appears to just be a matter of building as many zero-emissions resources as possible as soon as possible. These reliability planning reports indirectly affect the implementation schedule. The process identifies specific issues which triggers a procedure to address them. All that takes time. Coupled with the interconnection process it is no wonder that deployments are lagging behind the Scoping Plan schedule.

In my opinion the biggest reliability challenge for the Public Service Las Section 66-P “Establishment of a renewable energy program” is the necessity of a new category of electric system support technology that can be reliably dispatched to provide both energy and capacity over long durations with no emissions. NYISO calls this resource the Dispatchable Emissions-Free Resource (DEFR). They are “crucial for meeting energy demands when intermittent renewable sources like solar and wind are unavailable.” The challenge is we don’t know what will work and we don’t know how much is needed because an analysis of potential renewable resource availability using the longest duration dataset available has not been completed.

I think that NYISO has become more forthcoming about the Climate Act issues in this edition of the report. I am still disappointed with the NYISO for several reasons. In the first place, it is still necessary to read between the lines in all their reports to understand that they know there are enormous challenges associated with the transition to a renewable energy electric system. I think that is a disservice to the residents of New York. A truly independent agency should explicitly describe the reliability and affordability difficulties facing the electric system without holding back.

I am also disappointed that the Power Trends document did not describe specific issues with the key points presented. As noted above, this edition of Power Trends does not acknowledge challenges associated with the need for clean and reliable electric energy for proposed new load centers, fossil retirements and repowering policies, weather-related complications associated with the shift to winter peaking, interconnection feasibility concerns, and DEFR

Finally, I wish that NYISO would be more assertive in New York energy policy matters. It is understandable given the bully-tactics of the Cuomo Administration but New York State needs to hear from the experts. Power Trends notes that we need to do repowering, but NYISO did not intercede directly to advocate for repowering applications that were rejected.

Conclusion

The following conclusion is identical to last year’s summary here because nothing has changed.

The Power Trends 2025 report provides an excellent overview of New York State’s power grid and wholesale electricity markets. Unfortunately, NYISO does not consolidate all the warning signs about Climate Act implementation, nor does it call out state policies that are exacerbating problems.

Ultimately the problem is that New York has no comprehensive energy plan. The Scoping Plan is just a list of technologies that describe an electric system that is zero-emissions. However, there is no feasibility study that shows how it will work nor has the Hochul Administration reconciled the differences between the Scoping Plan and NYISO resource outlooks. As it stands now the Administration plan is to build as many wind and solar facilities as possible and hope someone works out how they are supposed to be integrated into the electric system. When that does not work, I predict the NYISO will be blamed.

The only way to ensure the safety of New Yorkers is to do a demonstration project that proves that an electric system that relies on wind and solar energy will work. A poor second choice would be a comprehensive feasibility analysis that reconciles the Integration Analysis and NYISO analyses. Failing to do either is planning to fail.

More Reasons to Pause Climate Act Implementation

I am convinced that implementation of the Climate Act net-zero mandates will do more harm than good because the energy density of wind and solar energy is too low and the resource intermittency too variable to ever support a reliable electric system relying on those resources. I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 500 articles about New York’s net-zero transition. The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

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

Energy Austerity Dangers

David Turver writing at Eigen Values explains that as more energy dense sources of power were used in England that less time and effort to survive was needed. That freed up time and resources were made available for innovation and development of art and culture. Furthermore, he states “Arguably, the availability of cheap, abundant energy enabled the Slavery Abolition Act to be passed in 1833 and the British Empire had sufficient surplus of energy, men and money to afford a Royal Navy to enforce the ban in the North Atlantic.” The use of cheap, abundant energy has transformed society in many positive ways.

There are problems brewing:

Unfortunately, the expansion of energy and wealth can lead to complacency and we collectively forget what it was that allowed us to create the most prosperous society the world has ever known. Bad ideas like Malthusianism can flourish and luxury beliefs that undermine the very principles on which society was built can begin to take over.

………………..

In the name of saving the planet, we are being forced to give up on concentrated, reliable energy and energy supply is dwindling as shown by the orange line in Figure 3 below.

Energy prices have risen as supply has fallen through a combination of taxes on hydrocarbons, subsidising expensive renewables and incurring the extra costs of intermittency and remote connections. As a result, energy consumption is falling and the economy is stagnating as shown by the blue line in Figure 3 (data sourced from OWID).

Turver goes on to argue that the wealth gap will increase as the energy use per person decreases. People will have to spend more of their time just getting by so that societal disorders will increase. He concludes that “If we continue down this Net Zero path, we will soon find that political change from energy austerity gets very ugly, very quickly.” England is further down this unsustainable path, but New York will surely follow unless we acknowledge the folly of chasing intermittent and diffuse energy.

Zero-Emissions Transportation

Chapter 11 in the Scoping Plan outlines the zero-emissions strategy for the transportation sector:

Transitioning the transportation sector to zero-emission technologies is central to achieving GHG emission reduction requirements. In most cases, this means replacing existing vehicles that run on gasoline or diesel fuel with either battery electric, hydrogen fuel cell, or future zero-emission propulsion technologies.

Recent experience in Korea is not encouraging for the hydrogen fuel cell option.

In my comments on the Draft Scoping Plan I noted the admission in the document that the “transition to ZEVs for this subsector will entail a mix of battery electric and hydrogen fuel cell vehicles” depends on technologies that are “just beginning to emerge into the market”. The text goes on to say: “Achieving the aggressive transition in this market will require a mix of regulations, incentives (which will require identifying new sources of funding), and removal of market barriers and depends on industry greatly accelerating the expansion of production capacity for these vehicles”. I commented that the Final Scoping Plan must include a feasibility analysis to prove that these strategies are viable. This suggestion was ignored.

So how is deployment of hydrogen fuel cells working out in Korea? Hyundai Motor Company has sold over 1,000 hydrogen fuel cell buses in Korea. On May 15, 2025, MPR Korea Certification described Hyundai’s Elec City FCEV bus:

Equipped with a 180 kW fuel cell system, an 875-liter hydrogen tank, and a 78.4 kWh high-output battery.
Offers a driving range of up to 550 kilometers per charge.
Each bus can reduce CO₂ emissions by approximately 72 tons annually

According to the MPR website: “Hydrogen drive related components and equipment usually require KGS certification in order to be approved for import and sale in Korea.” “KC Certification (also known as KC Safety Certification or KC Mark Korea Certification) is a product certification that proves the compliance of products with Korean safety regulations.”

Someone has a sense of humor because on May 21, 2025, Hydrogen Insight reported that:

Hyundai is recalling all units of its hydrogen-powered Elec City buses in South Korea after a faulty part was found to create a risk of hydrogen leakage, according to the country’s Ministry of Land, Infrastructure and Transport (Molit).

Nick Carter notes that:

In September, the South Korean government decreed that 25 per cent of its metropolitan bus fleet would be powered by hydrogen by the decade’s end.

Three months later, a hydrogen-fueled bus exploded, sending debris into the face of a refueling station attendant in the city of Chungju and injuring two innocent passers-by.

Carter reports on the net-zero transition in Australia. He pointed out that like New York, the net-zero transition is supposed to rely on green hydrogen to decarbonize hard to electrify sectors. He explains:

Green hydrogen is vital to the government’s plan for net-zero emissions by 2050. In October, Chris Bowen set a target of producing a million tonnes of green hydrogen by the end of the decade, earmarking $8 billion in subsidies to achieve that goal.

That won’t happen, no matter how much borrowed money the government might throw at it. In Europe, EU member countries are scaling back their expectations and preparing to renege on their obligation under the European Union’s Renewable Energy Directive, which set a target of 42% green hydrogen usage in industry by 2030.

In a Facebook post, Norwegian cabinet minister Ola Borten Moe admitted that the technology was “light years away from being justifiable or sensible”.

New York is further behind in adoption. There are pilot programs in Rochester and New York City for hydrogen fuel cell buses. They are also used in forklifts in the warehouse sector but there is no evidence that any private vehicles are using fuel cells.

Another Example of a Net-Zero Plan Disaster in the Making

The Energy Bad Boys recently described a partnership with the Arizona Free Enterprise Club to analyze the Integrated Resource Plan (IRP) of Arizona Public Service (APS). Their findings were published in a March report detailing how APS’s self-imposed Environmental and Social Governance (ESG) goals of reaching 100 percent Net Zero by 2050 are going to cost its ratepayers billions of dollars in unnecessary costs and undermine grid reliability.

The IRP Preferred Plan proposes to replace coal and meet load growth with wind, solar, batteries, and demand management. The Preferred Plan does see some savings in fuel expenses, but these savings are far dwarfed by the additional cost of building and maintaining new wind, solar, and battery storage facilities.

The authors conclude that “even in states without mandates for unreliable energy sources, monopoly utilities are rushing in to close down their reliable power plants to replace them with billions of dollars in new capital expenditures in the form of solar panels, battery facilities, and wind turbines.” The inescapable conclusion is that even those resources aren’t very productive utilities are sacrificing reliability because it actually helps the utility’s bottom line.

One Big Beautiful Bill NY Implications

The environ MENTAL blog had an article that described changes in the recent “One Big Beautiful Bill Act” (1BBB) passed by the U.S. House of Representatives last week. If the Senate passes a version of the bill without substantive changes to Title IV “Energy and Commerce” where 1BBB hammers or eliminates the key federal tax incentives that have underpinned wind and solar energy for too long, primarily by targeting “clean energy” tax credits, accelerating their expiration and imposing strict new eligibility requirements it will remove critical incentives to the renewable energy industry.

The hyperbolic response to the loss of the endless subsidy stream by renewable energy developers chronicled in the article belie the argument that a transition to wind and solar will be cheaper. The Energy Bad Boys article mentioned the passage of this legislation and included a figure that showed the subsidy extensions.

The chart below summarizes the change to the subsidies.

If this passes it will have an immediate and substantial impact to New York’s renewable energy development plans. I believe that many of the proposed wind and solar projects proposed for New York will not be viable without the subsidies. If New York cannot develop those resources, then it is clear that a pause in Climate Act implementation is necessary.

Conclusion

New York cannot “solve” climate change on its own because our greenhouse gas contributions to the atmosphere are dwarfed by emissions elsewhere. The best we can help for is a successful model for other jurisdictions, but the continuing ride of unresolved questions and unacknowledged issues suggests that the current approach is not on the right path. Pausing the insanity before it does more damage is the only rational path.

Personal Statement on Niagara Mohawk Rate Case Joint Proposal

I have followed the Climate Leadership & Community Protection Act (Climate Act or CLCPA) since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 500 articles about New York’s net-zero transition. I believe that Governor Hochul’s Administration has forced New York utilities to incorporate programs to try to meet the goals of the Climate Act despite never proving that it is feasible and mounting evidence that implementation is not working out as planned. My frustration that no one is acting on those concerns led me to join Constantine Kontogiannis in a submittal in the Niagara Mohawk Power Corporation dba National Grid (NMPC) rate case proceeding. This post describes our statement in opposition to the Joint Proposal (JP) settlement plan.

I am convinced that implementation of the Climate Act net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks. The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. It includes a requirement to make the electric grid zero-emissions by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” After a year-long review, the Scoping Plan was finalized at the end of 2022. Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation. The NMPC rate case is one example of these efforts.

NMPC Rate Case

This rate case has been moving slowly. On May 28, 2024, NMPC filed revised tariffs, supporting testimony, and exhibits for new rates and charges for electric and gas service to be effective July 3, 2024. The new tariffs were designed to increase electric and gas delivery revenues by approximately $525 million and $148 million, respectively. On July 22, 2024 NMPC filed corrections and updated testimony and exhibits decreasing the electric revenue requirement to approximately $509.6 million and increasing the gas revenue requirement to approximately $156.5 million.

On October 21, 2024, NMPC notified the active parties that settlement negotiations were starting. Settlement negotiations were held from October 30, 2024, to April 15, 2025. On April 25, 2025, a Joint Proposal (“JP”) that would establish a three-year rate plan running from April 1, 2025 through March 31, 2028, was filed by the following parties: NMPC; trial staff of the New York State Department of Public Service; Multiple Intervenors; Walmart; the Alliance for a Green Economy; the New York Solar Energies Industry Association; Independent Power Producers of New York, Inc. (IPPNY); the United States Department of Defense and all other Federal Executive Agencies; the New York Geothermal Energy Organization; Turning Stone Enterprises, LLC; Fedrigoni Special Papers North America; Empire National Gas Corporation; New Yorkers for Clean Power; the New York Power Authority, and the International Brotherhood of Electrical Workers Local Union No. 97.

Initial statements on the JP were due on May 14, 2025. Reply statements are due on May 23, 2025, and on June 3 there will be an Evidentiary Hearing. I cannot explain all this because I have ignored rate cases in the past.

Caiazza and Kontogiannis Initial Statement

Kontogiannis shares my frustration with the Climate Act transition plan. We are convinced that the current plan is dangerous and will lead to extraordinary price increases. We decided that submitting a statement in opposition to the JP would force a response to our concerns that have been ignored to date.

The rate request filing states that NMPC is focused on three priorities: (1) continuing to deliver safe, reliable energy service to its more than two million customers, (2) enabling customers to affordably meet their energy needs while improving NMPC’s customer service, and (3) supporting the goals of the Climate Act. Kontogiannis and I referred to the greenhouse gas (GHG) emission reduction transition plan described in the Climate Act Scoping Plan as the “CLCPA Electrification Mandate”. We defined “CLCPA Generation Plan” as the projected electric grid changes described in the Climate Act Scoping Plan that relies on wind, solar, energy storage, and Dispatchable Emissions-Free Resources (DEFR) resources to achieve the 2040 Climate Act mandate for a zero-emissions electric system.

Our primary concern is ensuring reliable, affordable, and environmentally responsible service to ratepayers while at the same time supporting the goals of the Climate Act is impossible. Simply stated, the goals of Climate Act are in direct contradiction to the statutory and regulatory obligations of NMPC and Public Service Commission.

Five arguments were included. I will highlight some of the key points in our arguments. I also need to apologize for the length of the post but providing all the background was necessary. I encourage interested readers to follow up and read the entire submittal.

Argument 1

The first argument made in our Statement is that the “JP burdens the ratepayers with additional Climate Act-related costs that sacrifice reliability for unproven sustainability benefits.” Kontogiannis described several examples of Climate Act electrification initiatives imposed on NMPC ratepayers that have created significant cost and reliability safety issues without a tangible environmental benefit.

NMPC and NYSERDA have jointly promoted building electrification using heat pumps, but without properly vetting the applicable technologies and host site suitability. Many of the installations have replaced efficient natural gas-fired equipment, with those ratepayers now subject to substantially higher heating costs that are not nearly offset by program incentives and tax credits for air source heat pumps and ground source heat pumps. Less than 15% of those ratepayers decommissioned their old heating equipment and many likely returned to using it after experiencing the higher operating costs of the heat pumps, negating most of the GHG savings claimed by the program administrators. Moreover, nearly all of the heat pumps installed through this program to date utilize a high global warming potential (GWP) refrigerant that is currently being phased out, which will likely necessitate early replacement instead of routine mid-life servicing.

There is one provision that illustrates the futility of the heat pump transition plan. The rate case includes an effort to minimize the need to repair leak prone pipelines by offering non-pipeline alternatives. This program includes heat pump incentives for disadvantaged communities with the intention to eliminate the gas service rather than repair it. After all, this will eventually be required anyway, so the reasoning goes. However, the JP admits that the heat pump conversion will not save money because their proposed solution is to offer a monthly credit after installation. The payoff is only for five years, does not cover all the conversion and operating costs of the conversion, will likely not be available for everyone who needs it, and will increase costs for everyone else.

Argument 2

The second argument says that the JP does not acknowledge New York Public Service Law § 66-p (4). In no small part this triggered my desire to submit a statement in opposition to the JP because I have been arguing for years that New York Public Service Law § 66-p (4). “Establishment of a renewable energy program” includes safety valve conditions for affordability and reliability that must be addressed. The provision states: “The commission may temporarily suspend or modify the obligations under such program provided that the commission, after conducting a hearing as provided in section twenty of this chapter”, makes a finding that the program impedes the provision of:

safe and adequate electric service;
the program is likely to impair existing obligations and agreements; and/or
that there is a significant increase in arrears or service disconnections that the commission determines is related to the program”.

This argument was included to force the PSC to acknowledge that the safety valves must be addressed. The submittal included an attachment that was summed up my analysis that showed that the number of people in arrears has significantly increased since the state of the Climate Act. Our statement argued that it is inappropriate to invest in Climate Act programs until the PSC defines the criteria for the Section 66-p(4) safety valves, institutes a tracking system, and determines if the Climate Act implementation should be suspended or modified.

Argument 3

The third argument is that dispatchable emissions free resources (DEFR) must be resolved to ensure safe and adequate supply. Until this issue is resolved it is imprudent to invest in any support of the Climate Act Generation Plan. An attachment was included based on my many articles on DEFR. The attachment documents the need for DEFR, explains the requirements for this new resource, describes potential options, and notes the challenges associated with specifying how much capacity and energy will be needed to prevent a reliability crisis.

The JP does not adequately address the fact that a new category of Dispatchable Emissions-Free Resources (DEFR) must be identified, tested, and deployed to provide energy during extended periods of low wind and solar resource availability. There is a very real chance that nothing will be feasible. Furthermore, because the DEFR technologies have not been identified it is impossible to determine if they are affordable.

In our opinion, the most promising DEFR backup technology is nuclear generation because it is the only candidate resource that is technologically ready, can be expanded as needed and does not suffer from limitations of the Second Law of Thermodynamics. If the only viable DEFR solution is nuclear, then renewables cannot be implemented without it. But nuclear works best as a baseline resource rather than as backup so nuclear power can replace renewables, eliminating the need for a massive DEFR backup resource. Therefore, all the JP investments included to support renewable energy development are imprudent because nuclear generation may be the only viable path to zero emissions making all those investments worthless.

Argument 4

The fourth argument pointed out that the JP does not properly consider alternatives to the Climate Act Generation Plan that provide similar environmental benefits without the reliability risks of dependency upon intermittent and diffuse renewable energy. To maintain adequate system reliability, the CLCPA Generation Plan must include substantial overbuilding of renewable sources, energy storage, and equipment for ancillary grid support. The JP does not address the fact that the Climate Act fails to consider other options that would largely satisfy its sustainability target without as many ratepayer reliability and affordability risks.

Kontogiannis and I agree with Richard Ellenbogen’s pragmatic approach described at the March 18, 2025 NYS Senate Energy and Telecommunications Committee meeting. We all believe that substantial interim reductions can be achieved simply by deploying natural gas fired combined cycle gas turbines (CCGT). For large sources of new load, a CCGT power plant requires no additional ancillary service support infrastructure, can provide process heat, and when coupled with an agricultural park, can further lower CO2 emissions by using the CO2 to boost plant productivity. CCGTs will last longer than any wind, solar, or energy storage infrastructure, can be used for peaking support when a better long term zero emissions technology is developed and deployed, and converted to burn hydrogen if necessary. Moreover, if it becomes economical to produce and store hydrogen this approach eliminates the need to develop ways to transport it because it can be stored and used in one location.

Unfortunately, this rational approach is not lawful at this time. However, the approach is emerging as a preferred low carbon solution in other areas of the U.S. and abroad. The significant tradeoffs of the CLCPA Generation Plan must be reevaluated by NMPC and the Public Service Commission as part and parcel of the JP to ensure protection of the ratepayers.

Argument 5

The fifth argument addressed the electric system planning risks that are inherent in the transition to weather-dependent generating resources. The DEFR argument mentioned the difficulties associated with figuring out how much DEFR will be required because the assessment must account for weather variability. This argument and the associated attachment explained all the challenges of defining the frequency, duration and intensity of low wind and solar resource availability events. Two reliability metrics were evaluated with respect to weather variability. The argument concluded that the associated uncertainties may not be reconcilable.

The presumption in the JP that the CLCPA Generation Plan will be safe does not stand up to scrutiny. Grid planners recognize that unanticipated adverse events—such as line outages, generator trips, substation failures, and major faults—will continue to impact power grids. Their challenge is to ensure the grid is robust enough to withstand and recover from such disturbances without major consequences. Kontogiannis and I believe that it is unrealistic to expect that the grid planners will be able to anticipate all the additional adverse events that will occur when the electric system depends on weather-reliant resources. It would be prudent to pause the Climate Act projects within the JP until grid planning improves.

Conclusion

Kontogiannis and I submitted the Statement of Opposition because of our concern that, with its disproportionate efforts to support the goals of the Climate Act, the JP does not properly balance NMPC and Public Service Commission responsibilities to ensure reliable, affordable, and environmentally responsible energy generation and delivery to ratepayers.

With so many legacy hydroelectric and nuclear assets, by all accounts New York State should have some of cleanest, most reliable, and affordable energy in the United States – but we are failing on all counts. Special interests have effectively hijacked what should be a relatively straightforward exercise of prudent engineering – shuttering a critical nuclear asset, denying legacy fossil fuel powerplants permission to repower as CCGT generators, and forsaking cost-effective and fuel-neutral building and transportation energy efficiency initiatives – all for the well-intentioned but sorely misguided fantasies of climate scientists in academia and policy advocates who have no idea of the complexities involved in the safe and reliable production and delivery of arguably the most essential commodity for the modern world. As if the failure isn’t complete, the stated sustainability targets are nothing more than smoke and mirrors – an honest accounting of the lifecycle carbon impacts shows no improvement compared to what solid engineering and standard industry practice afford.

Even if the Climate Act was to fully achieve its sustainability objectives, the effect on global emissions is negligible and the resulting global temperature change is infinitesimally small. If New York were able to eliminate all its GHG emissions, the effect of global emission increases elsewhere would supplant our efforts in one year. New York GHG emissions are less than one half of one percent of global emissions and global emissions have been increasing on average by more than one half of one percent per year since 1990. Furthermore, New York’s impact on global warming is unmeasurable. A Perplexity AI query “What is the expected change in global warming per ton of CO2 reduced” found that “Current estimates suggest that reducing 1 gigaton (1 billion tons) of CO₂ emissions prevents approximately 0.00045°C of warming”. That conversion was applied to the expected NMPC GHG emission reductions expected in Exhibit CLCPA-2 included in NMPC’s Climate Act Panel testimony on May 8, 2024 as well as historical emissions (Table 1). Emissions attributable to the Climate Act and historical emissions predict no measurable changes in global warming.

Table 1: Potential Warming Savings for JP Emission Reductions and Historical Emissions

NMPC’s NY Climate Resiliency Plan website states that: ”National Grid is committed to urgent action to address climate change as we’ve outlined in our vision for a fossil free future, but we all must recognize that climate change is no longer a future threat, but a current threat based on the extreme climate hazards we are witnessing today.” Kontogiannis and I believe that the crisis facing NMPC customers is not from the changing climate, but rather the irrevocably flawed climate policy. Kontogiannis and I concluded that a properly conceived statewide energy plan can achieve essentially the same sustainability target at a much lower cost to ratepayers and with no diminishment of system reliability.

Spain and Portugal Blackout – Another Reason to Pause the Climate Act

I am very frustrated with the New York Climate Leadership & Community Protection Act (Climate Act) net zero transition because the reality is that there are so many issues coming up with the schedule and ambition of the Climate Act that it is obvious that we need to pause implementation and figure out how best to proceed. This article explains that the ramifications of the recent blackout in Spain and Portugal need to be considered to ensure that the cause of the blackout is not a feature of all renewable-energy dependent electric systems.

I am convinced that implementation of the Climate Act net-zero mandates will do more harm than good because the proposed green energy programs are crimes against physics. The energy density of wind and solar energy is too low and the resource intermittency too variable to ever support a reliable electric system relying on those resources. I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 500 articles about New York’s net-zero transition. The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. It includes an interim target of a 100% zero-emissions electric system by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” After a year-long review, the Scoping Plan was finalized at the end of 2022. Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation.

In 2023 the New York Independent System Operator (NYISO) reports that solar capacity was 254 MW for utility scale facilities and 5,172 MW for behind-the-meter solar capacity. NYISO data shows that the utility-scale capacity factor was only 16.6%. The Scoping Plan Strategic Use of Low-Carbon Fuels scenario projects that 40,860 MW of total solar capacity will be needed to meet the 2040 zero-emissions target. The report projects that solar will be 30% of the total capacity of New York.

Spain and Portugal Blackout – April 29,2025

Earlier this week there was a massive blackout that started in Spain. According to Reuters:

At around 12:30 p.m. (1030 GMT), electricity generation in Spain dropped rapidly from around 27 gigawatts to just over 12 GW. The 15 GW loss was equivalent to 10% of Spain’s total installed capacity.

The sudden drop in grid load destabilized electricity flows, which require an extremely stable frequency of 50 Hertz to maintain supply. This, in turn caused a break in the Spanish and French electricity interconnection that goes through the Pyrenees mountains, resulting in the total collapse of the Spanish power system.

Spain exports electricity to Portugal, so the collapse of power in Spain quickly spread throughout the Iberian Peninsula. Some areas in France also suffered brief outages on Monday.

The blackout in Spain is projected to cost 2-4 billion euros. It is imperative to figure out what caused it. Currently there hasn’t been any definitive explanation. Nonetheless, there are reasons tp believe that it could have been caused by Spain’s reliance on wind and solar.

Potential Causes Related to Wind and Solar

Net Zero Watch described a potential problem:.

Grid analysts have suggested a high likelihood that the extent of yesterday’s blackout in Iberia was a result of the Spanish grid operating almost entirely on renewables at the time. The stability of power grids depends on so-called ‘inertia’, a resistance to rapid change that is an inherent feature of large spinning turbines, such as gas-fired power stations, but not of wind and solar farms. Too much renewables capacity on a grid can therefore mean inadequate inertia. As a result, in grids dominated by wind and solar, faults can propagate almost instantaneously across grids, leading to blackouts.

In a recent Net Zero Watch paper, entitled Blackout Risk in the Great Britan Grid, energy system analyst Kathyn Porter pointed out that the Great Britain electricity system is becoming increasingly unstable. “Large fluctuations in grid frequency – the first sign of problems – are becoming much more common”. This has not been observed in New York, yet.

Richard Ellenbogen sent an email with more information. He explained:

While the exact cause of the blackout is uncertain, both Spain and Portugal have become heavily reliant on renewables. The power loss was caused by the sudden disappearance of 15 GW of generation for five seconds. To understand the scale of the problem, the five nuclear power plants in Spain have a combined installed capacity of 7.4 GW.

There is a reliability criterion in New York that boils down to keeping enough generation capacity online and available to that if the largest source of power trips offline that the spare capacity can replace it easily. If we have to worry about all the solar going offline this quickly there is a huge challenge to resolve. Ellenbogen explained that a few minutes before the blackout, 60% of Spain’s energy was coming from solar. He also quoted an article by Robert Bryce:

The best explanation of grid inertia and its importance was published in 2016 by University of Queensland professor Simon Bartlett. In a paper written for the Energy Policy Institute of Australia, “The ‘Pressure Cooker’ Effect of Intermittent Renewable Generation on Power Systems,” Bartlett declared that the “practical upper limit for renewables is around 40% of total electricity generated.” He continued, “The scale-up of intermittent renewables not only diminishes the robustness of a particular power system but can also magnify the short and long-term risk of investing in non-renewable generation assets and the power grid itself.”

Ellenbogen also provided a link that provides an explanation about utility frequency issues for anyone that wants to read further.

Discussion

Ellenbogen closed his email with the thought that “with all of the investment that has been made in their renewable infrastructure, will we see a realistic report from the Spanish utility? An article in Reuters by Ron Bousso titled “Don’t blame renewables for Spain’s power outage” supports Ellenbogen’s concern that advocates for renewables are too invested in them to admit their proposed use may be irretrievably flawed. The article opens:

While it may be tempting to blame the unprecedented power outage that hit the Iberian peninsula this week on the rapid growth of wind and solar power in Spain, reliance on renewables is not to blame. Rather, the issue appears to be the management of renewables in the modern grid.

I love this. We don’t know what happened, but he claims it could not have been the renewables. This was followed by the description of what occurred that I quoted earlier. The next section noted that the “cause of the initial drop that led to the catastrophic cascade of events is unclear, though a collapse in Spain’s solar power system was certainly involved.” At least he admits that the solar power system was “certainly involved”. Bousso notes:

One possible contributor is the lack of so-called ‘grid inertia’ as a result of the relatively small share of nuclear and fossil fuel generation in Spain’s power mix.

Inverter-based wind and solar power, which generated just under 70% of Spain’s total electricity at the critical moment on Monday, does not involve physical rotation and therefore inertia could not compensate for the sudden loss of power.

What grid management of renewables in the modern grid is possible? His short-term solution? “An obvious short-term solution to avoid a repeat of the blackout would be to maintain a higher baseload of rotating power generation.” The current generation payment system that gives solar and wind power preferential treatment means that wholesale changes to the payment system would have to be implemented. Furthermore, if we must keep enough rotating power generation on-line to cover the sudden loss of all wind and solar due, then it begs the question why we just don’t use those resources and skip the charade of green energy.

His long-term solution is batteries:

Over the long term, however, power systems will need to invest heavily in battery capacity to store electricity as well as technologies for synchronising the grid that are critical to maintaining the 50 Hz frequency. In theory, this should be doable, as battery costs have declined sharply in recent years and are being deployed at scale around the world.

There is a critical caveat that is glossed over when he says “this should be doable”. One of the poorly understood aspects of inverter-based resources like wind and solar is the energy management systems in the inverters. It is beyond my experience to explain but the experts that I have talked to about this note that distinguishing between a problem with the equipment that requires a shutdown to protect the equipment and a grid problem that requires the system to stay on and support the system is no easy task. It gets worse when you consider that there are behind-the-meter resources like residential solar that cannot be expected to have sophisticated energy management systems. The other aspect is the cost:

But all this would still require heavy investment. While spending on new solar capacity reached around $500 billion last year, investment in grids was only at around $400 billion, becoming bottlenecks for the energy transition, according to the International Energy Agency.

Professor Simon Bartlett declared that the “practical upper limit for renewables is around 40% of total electricity generated. The New York Scoping Plan projects that in 2040 solar capacity will be 40,860 MW, onshore wind 13,096 MW, and offshore wind 13,484 MW so the renewable total is 67,440 MW. The question is whether the Scoping Plan analysis capped the amount of wind and solar output at any one time at 40%. I doubt it but this is a nuance that cannot be answered by looking at the impenetrable Scoping Plan documentation. Clearly this is another reason to pause implementation because now we know that this can be a billion-dollar risk and we don’t know how the Scoping Plan or for that matter the NYISO analyses addressed it.

Conclusion

In the coming months the green energy apologists will be saying that it is unfair to blame renewables for Spain’s power outage. My first observation is that it would be incredibly insulting to the public to say that renewables were not the original cause of the problem. The question is whether an electric system can be designed and operated to address this problem. I have the utmost respect for electric system planners and their ability to design the system to address known problems. However, given the complexity of the electric generating and transmission system I do not think that they can anticipate every potential problem that could cause a blackout. Another important consideration is whether the proposed New York electric system has incorporated features that would preclude the observed problem from happening here when we become as dependent upon inverter-based resources.

This is another reason to pause the Climate Act implementation. We simply don’t know if the proposed zero-emissions system that relies so much on wind and solar will work. If New York decides that the future electric system must be zero-emissions and it turns out that no more than 40% of the power at any time can come from wind and solar, then the only viable approach is nuclear power. Nuclear replace can replace renewables, eliminate the need for a massive backup resource to address this problem, and provide an electric system that we know can maintain current standards of reliability. Therefore, it would be prudent to pause renewable development until this issue is resolved because nuclear generation may be the only viable path to zero emissions.