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.
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
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.
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.
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”.
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.
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 describes reasons to pause 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.
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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.
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.”
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).
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.
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.
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.
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.
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.
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.
In March 2025 Senator Mattera invited Richard Ellenbogen to Albany to address the NY State Senate Energy & Telecommunications Committee regarding NY State’s energy situation relative to the Climate Leadership & Community Protection Act (Climate Act). I was impressed that the meeting showed that the Committee agreed with Ellenbogen that there are implementation issues and course corrections are necessary. I previously described the emissions analysis I did for the Committee. This post describes the air quality aspects of New York power plant emissions.
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.
Senate Energy and Telecommunications Committee Meeting
On March 18, 2025 Senator Mattera invited Richard Ellenbogen to Albany to address the NY State Senate Energy & Telecommunications Committee regarding NY State’s energy situation. Senator Parker, the committee chair, gave Ellenbogen time to describe his thoughts on the Climate Act transition, describe his proposal to use of existing technology that will not get to zero but will maintain system reliability, and answer questions. There is a video of the hearing available and a previous post includes links to specific discussions within the video.
Ellenbogen’s presentation argued that there is a better way that “adheres to reality”. He believes that repowering existing power plants with combined cycle gas turbines gives significant carbon reductions. Replacing the old units reduces emissions, decreases reliability risks because the old units are so old that they are more likely to fail, and because the combined cycle plants are more efficient, they would burn less fuel to produce the same amount of electricity.
During the discussions at the meeting, Chairman Parker said a couple of times that he wanted to get specific numbers for potential emission reductions. I described the detailed description of the emissions analysis I provided to the Committee in another post. The last thing I want to address is air quality associated with New York electric generating units.
Context
The detailed analysis that I submitted to the Committee included this section on context. I joined Niagara Mohawk Power Corporation (NMPC) in 1981 and one of my responsibilities until I retired in 2010 was accounting and reporting air pollution emissions. I think it is important to understand that there have been massive reductions in electric generating unit emissions in New York since the time I joined the utility industry. The earliest records I have date back to 1984. At the time NMPC owned and operated oil-fired facilities in Albany and Oswego and coal-fired plants in Dunkirk and Tonawanda. In 1984 those facilities emitted 136,684 tons of sulfur dioxide (SO2), 37,221 tons of nitrogen oxides (NOx), and 12,530,220 tons of carbon dioxide. In 1995, according to the Environmental Protection Agency all the fossil fueled power plants in New York emitted 239,183 tons of sulfur dioxide, 120,138 tons of nitrogen oxides, and 54,000,913 tons of carbon dioxide. In 2024 all the fossil fueled power plants in New York emitted 698 tons of sulfur dioxide, 7,757 tons of nitrogen oxides, and 31,201,251 tons of carbon dioxide. The following table (NY Emissions Analysis.xls “NYS” tab) lists the annual values from 1980 until 2024.
New York Electric Generating Unit Annual Emissions from EPA Clean Air Markets Division
Air Quality Trends
There have been recent reports that noted that the American Lung Association (ALA) reported that dangerous air pollution is affecting more Americans than last year. Behind the headlines is the fact that the data they used included “exceptional (e.g., wildfires) and natural events (e.g., stratospheric intrusions)” that are the reason air quality worsened. Not mentioning the fact that the deteriorating air quality has very little to do with humans would not help their agenda and fund raising so that information isn’t included in the news stories. In this context, however, it leads the general public to believe that this indicates a trend towards worse air quality.
The National Ambient Air Quality Standards (NAAQS) establish air quality levels that are protective of public health and welfare with an adequate margin for safety, including protecting the health of ‘sensitive’ populations such as asthmatics, children, and the elderly”. From a regulatory standpoint, there is nothing that local jurisdictions can do to reduce exceptional and natural events. Consequently, the high air quality associated with those events is not counted against the attainment designation relative to the NAAQS. The air quality was worse last year in many places but in the absence of exceptional and natural events the air quality is getting better. I also believe that while there are extreme weather events that cause things like wildfires, that climate change is not exacerbating extreme weather to any observable degree.
Without those events the observed emission reductions have been accompanied by improvements in air quality. SO2 levels have decreased dramatically, with a 98% reduction in annual average levels from 2009 to 2017. I found that nitrogen dioxide one-hour ambient levels decreased 63%. There also have been decreases in particulate matter.
For the most part New York air quality reflects national and regional trends. According to the EPA nonattainment/maintenance status summary, there are multiple counties In New York that do not attain the current NAAQS for ozone and New York County does not meet the coarse particulate matter standard. Note that all of New York State meets the inhalable particulate (PM2.5) NAAQS. All the other pollutants are in attainment. Finally, note that over the years the NAAQS limits have become more stringent.
Despite the fact that there have been significant improvements and New York is mostly in attainment with the NAAQS there is another approach to air quality health impacts that regulators and activists have used to claim more reductions are necessary. They claim that levels of pollution lower than the NAAQS have health impacts based on simplistic epidemiological extrapolations that assume there are no health impact thresholds.
For example, even though New York City is in attainment for inhalable particulates, this pollutant is used as a rationale for shutting down peaking power plants because of claims that reducing inhalable air quality impacts is beneficial. The New York City Department of Health and Mental Hygiene’s (DOHMH) 2011 Air Pollution and the Health of New Yorkers report is often referenced in this regard. The DOHMOH report concludes: “Each year, PM2.5 pollution in [New York City] causes more than 3,000 deaths, 2,000 hospital admissions for lung and heart conditions, and approximately 6,000 emergency department visits for asthma in children and adults.” These conclusions are for average air inhalable particulate pollution levels in New York City over the period 2005-2007 of 13.9 µg/m3.
I submitted comments on the Draft Scoping Plan where I showed that the New York City 2018-2020 average PM2.5 concentration was 7.4 µg/m3 which is substantially lower than the DOHMOH goal of 10.9 µg/m3. If the epidemiological linear no-threshold model is correct, then because inhalable particulate levels have come down In New York City there should be significant observed health benefits since the 2011. However, DOHMH has not verified their projections against observations. Until such time that the projected health impacts using this approach are validated with observed data, I will be skeptical of this metric. The fact that asthma and other health impacts have not improved at the same rate as the air quality improvements suggests that other factors are driving those outcomes. In my opinion, there should be a commitment to determining the more likely causes rather than wasting money on reducing already low power plant emissions.
Current Air Quality Conditions
During the Energy & Telecommunications Committee hearing on March 18, 2025 Chairman Parker questioned air quality levels around power plants. He said that there are “people sitting in the shadow of both industrial plants and nuclear power plants who are developing health outcomes that are negative because of these plants”. I need to address this misconception as it applies to fossil-fired power plants. First, I want to point out that there is no credible health outcome threat of air quality related to nuclear power plants.
I think that Chairman Parker has been misled by a “righteous risk”. In a post on this risk I noted that these risks arise from a “value-based policy approach that filters out facts and data within an ethical perspective.” The importance of these risks are “influenced by what is perceived as ethical rather than what is rational or scientific.” The Climate Act includes specific mandates to address righteous risks.
The Climate Act includes a commitment to address equity for “communities within New York that have been historically overburdened by environmental pollution”. One of the most repeated claims is related to air quality levels around power plants and reductions in co-pollutants is a prime benefit of the Climate Act.. The PEAK coalition has stated that “Fossil peaker plants in New York City are perhaps the most egregious energy-related example of what environmental injustice means today.” I believe this argument influenced Senator Parker. However, the presumption of egregious harm is based on selective choice of metrics, poor understanding of air quality health impacts, and ignorance of air quality trends. I have documented my concerns based on my extensive experience with air pollution control theory, implementation, and evaluation over my 45+ year career.
One of the legislative attempts to facilitate the Climate Act is the Build Public Renewables Act that gives the New York Power Authority (NYPA) renewable development responsibilities. This law is supposed to speed up the energy transition but it also includes a requirement for NYPA to shut down its existing fossil-fired power plants including a number of peaking power plants in New York City. I think this is as poor a policy choice as the decision to shutdown of the Indian Point nuclear power plant.
I have been an air quality meteorologist for 45+ years. A foundational presumption in my career is that if the ambient air quality effect of any polluting source is lower than the NAAQS then public safety and welfare is protected. There are two additional levels of air quality security. When the NYPA peaking power plants were permitted NYPA had to demonstrate that the increase in pollution due to the facilities was less than the Prevention of Significant Deterioration increment put in place to assure that new sources of pollution do not meaningfully worsen the air quality. In addition, the facilities had to install Lowest Achievable Emission Rate air pollution control equipment which is as good as it gets. My point is that the facilities that New York politicians are forcing to close may not have zero impacts, but they are close enough to no impacts, that they cannot possibly adversely affect health outcomes.
Discussion
After much thought I think I have an analogy that puts this in perspective. Think of power plant controls like cleaning the kitchen floor. Power plants have different levels of control equipment just like we all have different options to clean the floor. Keeping the kitchen floor clean is necessary for food safety given the likelihood of spills. In my opinion, sweeping the floor daily and mopping it regularly is “good enough”. Many don’t think that mopping the floor is good enough now because there are more sophisticated options like the Swiffer PowerMop or even steam mops. For some once-a-week mopping is not good enough and they may want to do that daily. The point is that there is a tradeoff between time and money for cleaning the floor “good enough”. In my opinion, the NYPA peaking power plants in New York City with Lowest Achievable Emission Rate controls are equivalent to using a steam mop several times a day. Demands to shut down the NYPA power plants is equivalent to deciding not use the kitchen because it is not clean enough even when using a steam mop several times a day.
Conclusion
A state-of-the-art combined cycle natural gas-fired turbine provides great grid support and is so efficient that it has significantly lower CO2 emissions than existing fossil-fired units in New York. To correctly consider the value of this technology for New York’s electric system it is necessary to use appropriate comparison metrics, have a comprehensive understanding of air quality health impacts, and consider air quality trends.Three things described in my emissions status article should also be considered. I found that a future electric system that uses nuclear power as the backbone and natural gas-fired combined cycle combustion turbines for backup support resolves the reliability risks and overall costs of a wind, solar, and energy storage system. At the same time it could reduce emissions from about 30 million tons per year today to less than 2 million tons per year in the future. I also noted 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. Even Senator Parker acknowledges that this means “at the end of the day New York is not going to solve the climate crisis”. Finally, I pointed out that New York’s impact on global warming is unmeasurable. These three points lead to the inescapable pragmatic conclusion that nuclear power as the backbone combined with combined cycle combustion turbines is good enough for environmental risks even if there are some GHG emissions and co-pollutant emissions are not zero.
On March 18, 2025 Senator Mattera invited Richard Ellenbogen to Albany to address the NY State Senate Energy & Telecommunications Committee regarding NY State’s energy situation relative to the Climate Leadership & Community Protection Act (Climate Act). I was impressed that the meeting showed that the Committee agreed with Ellenbogen that there are implementation issues and course corrections are necessary. This post describes the emission estimates that I provided and puts electric generating unit emissions in context.
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.
Senate Energy and Telecommunications Committee Meeting
On March 18, 2025 Senator Mattera invited Richard Ellenbogen to Albany to address the NY State Senate Energy & Telecommunications Committee regarding NY State’s energy situation. Senator Parker, the committee chair, gave Ellenbogen time to describe his thoughts on the Climate Act transition, describe his proposal to use existing technology that will not get to zero but will maintain system reliability, and answer questions. There is a video of the hearing available and my previous post includes links to specific discussions within the video.
Ellenbogen’s presentation argued that there is a better way that “adheres to reality”. He believes that repowering existing power plants with combined cycle gas turbines gives a carbon reduction of “30 to 40%.” Replacing the old units reduces emissions, decreases reliability risks because the old units are so old that they are more likely to fail, and because the combined cycle plants are more efficient, they would burn less fuel to produce the same amount of electricity.
During the discussions at the meeting, Chairman Parker said a couple of times that he wanted to get specific numbers for potential emission reductions. In my description of the meeting, I promised to publish a post describing my supplemental emissions analysis that provided those numbers. This article fulfills that promise.
Observed and Projected Electric Generating Unit Emissions Analysis
Following the meeting I sent Ellenbogen material to send on to Senator Parker. The evaluation of observed electric generating unit carbon dioxide (CO2) emissions for selected New York power plants that represent the current state-of-the-art compared with other existing units included the information requested. My submittal included a detailed description of the analysis as well as the spreadsheet that generated the data in each table in the report. The description includes references to each tab within the spreadsheet that provides the data for every table. I am only going to summarize the evaluation because the documentation provides the details.
The analysis was complicated because it was necessary to combine two different data sets for the comparison. I used the EPA Clean Air Markets Division data that includes CO2, SO2, and NOx emissions along with several operating parameters. Unfortunately, the EPA load data represents gross load and net loads are needed to project CO2 emissions for the different scenarios. The New York Independent System Operator (NYISO) annual load and capacity data report, universally known as the “Gold Book, provides net loads. I chose 2020 because I wanted to include the Somerset coal-fired power plant information to represent the highest CO2 emissions. Because of naming convention and facility component differences, it was not possible to include all the steam turbine, combined cycle or cogeneration units in the state. However, the 43 units (Note that the report refers to 45 units but there are only 43 units in the tables) included provide a representative sample of the state, representative data for state-of-the-art generating units and includes specific units that were requested by the Committee.
I manually combined 2020 data from the two data sets for 43 electric generating units as shown in Table 3 from the report (NY Emissions Analysis.xls “Compare 2020” tab). It combines the NYISO net energy (GWh) and the EPA CO2 emissions (tons) to determine the state-of-the-art CO2 emission rate (tons/GWh). Note that the CO2 emission rate ranges from just over 400 for the combined cycle gas turbines to 1200 tons per GWh for a coal plant. I assumed that the new Cricket Valley, CPV-Valley, and Caithness combined cycle gas turbines represent a state-of-the art combined cycle power plant. Table 3 shows that those three facilities do represent the lowest emission rates and that the Bethlehem Energy Center is within their ranges so also state-of-the-art. I assumed that the average of the blue highlighted cells represents a representative state-of-the-art combined cycle power plant CO2 emission rate (410.8 tons CO2 per GWh).
Table 3 : Combine the NYISO Net Energy (GWh) and the EPA CO2 Emissions (tons) to Determine State of the Art CO2 Emission Rate
Table 4 (NY Emissions Analysis.xls “2020 Projections” tab) compares existing emissions to estimated emissions if the facility were replaced with a state-of-the art combined cycle combined cycle gas turbine power plant with and without a carbon capture and sequestration (CCS) control equipment. The observed CO2 Mass column lists 2020 annual emissions. The state-of-the-art projected CO2 emissions column equals the state-of-the-art combined cycle power plant CO2 emission rate (410.8 tons CO2 per GWh times the observed 2020 net energy rate. The column that adds the CCS control at 90% efficiency lists the emissions if the control equipment were in place. There are also columns that list the difference between observed emissions and these projections.
Table 4:Projected CO2 Emissions – Replace with Combined-Cycle GT or Combined-Cycle GT with Carbon Capture
In 2020 the electric sector emitted 26,920,636 tons of CO2. The 45 units included in this analysis emitted 21,305,661 tons representing 79% of the total. If all 45 units were state-of-the-art combined cycle natural gas fired combustion turbines, the emissions would be reduced to 17,955,036 tons which is a 16% reduction. If all 45 units added carbon capture and sequestration control equipment, the emissions would be reduced to 1,795,504 tons, a 76% reduction. My results are less than the Ellenbogen presentation because I did not account for the improved efficiency and resulting lower fuel use that would reduce emissions more.
Future Electric System
I also projected 2040 CO2 emissions for a pragmatic future electric system that relies on nuclear power but uses state-of-the-art combined cycle natural gas fired combustion turbines (CCGT) for peaking support. Making projections for future electric energy sector resource allocations is best left to the professional electric system planners who can use complex and sophisticated models that can incorporate the nuances of the capabilities and performance of different types of generation. The biggest problem is that an electric system that relies on wind and solar resources needs to overbuild wind and solar capacity. That introduces a significant error in my projection approach. Nonetheless, this analysis gives a rough idea of potential emissions for two scenarios – building CCGT instead of renewables and building nuclear for everything except peaking generation.
The detailed description of the analysis provides specifics. In brief, I first chose a New York Independent System Operator (NYISO) annual energy forecast for the emissions projection. The second step was to allocate the generation needed to provide the NYISO future energy projection. I made many assumptions to establish the arbitrary generation resource categories I used in my projections.
I considered two future scenarios for 2040. In Scenario 1 the existing nuclear and hydro capacity and generation stay the same but new combined cycle gas turbines provide all the capacity and generation necessary to meet the NYISO forecast. In Scenario 2 the existing hydro capacity and generation stayed the same, new combined cycle gas turbines provide the peaking power and all the remaining capacity and generation necessary is provided by nuclear power.
My results showed that significant reductions are possible with these scenarios. If nuclear and hydro stay the same and new CCGT is used to make up the capacity and energy necessary to match the NYISO forecast, then the emission projection is 70,301,856 tons of CO2 or 7,030,186 tons with 90% CCS controls. This is an overestimate because the NYISO projection incorporates over-building wind and solar capacity that would not be necessary if conventional generating resources are used. The second scenario in which nuclear is used for everything except peaking generation and CCGT is only used for peaking purposes is probably closer to a realistic estimate. That scenario predicts that using fossil fuels solely for that purpose would produce 1,226,718 tons of CO2 and only 122,672 tons if 90% CCS was employed. This also is an over-estimate because of the renewable over-building but the significantly lower emissions shows how effective nuclear power is for reducing emissions.
Relative Impacts
The nuclear/CCGT approach does not eliminate 100% of CO2 emissions. However, 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. Even Senator Parker acknowledges that this means “at the end of the day New York is not going to solve the climate crisis”.
There is one other argument in favor of this pragmatic approach. In short, New York’s impact on global warming is unmeasurable. Table 9 (NY Emissions Analysis.xls “Warming Averted” tab) projects the amount of global warming “savings” for the projection scenarios and historical emissions. The calculations are based on a Perplexity AI query “What is the expected change in global warming per ton of CO2 reduced”. None of the emission scenarios for the projected warming predict measurable changes in global warming.
Table 9: Potential Warming Savings for Emission Scenarios and Historical Emissions
Conclusion
The purpose of this analysis is to show that a state-of-the-art combined cycle natural gas-fired turbine is so efficient that it has significantly lower CO2 emissions than existing fossil-fired units in New York. If a cost-effective carbon capture and sequestration system could be added to those facilities the emissions are reduced much more. When combined with nuclear power for baseload electric power, there are advantages to using a system with combined cycle gas turbines when compared to using a system based on using wind, solar, and energy storage. The energy density of wind and solar energy is so low and the resource intermittency so variable hat no electric system relying on those resources for most of its energy can ever hope to provide reliable electricity. The low energy density requires a massive buildout of transmission, and an intermittent weather-dependent system requires an unproven dispatchable emissions-free resource. The nuclear/CCGT approach resolves those challenges. When the potential effects of New York emissions on global warming are considered, it is apparent that zero emissions mandates do not provide any measurable benefits.
The negligible relative impacts of New York emissions does not mean that we should do nothing, but it does suggest that strategies that do not go to zero should not be rejected. That is especially true if those strategies can be implemented for a fraction of the cost of the current plan. In addition, the emissions from combined cycle gas turbines used to replace existing generation would not meaningfully contribute to global warming but their continued use not only reduces emissions over historical levels but also resolves reliability challenges that must be addressed if zero emissions are mandated. The concept of natural gas as a bridge fuel for even lower emission alternatives is a pragmatic approach.
On March 18, 2025 Senator Mattera invited Richard Ellenbogen to Albany to address the NY State Senate Energy & Telecommunications Committee regarding NY State’s energy situation. This article describes the presentation and documents meeting materials and follow up information.
Ellenbogen is the President [BIO] of Allied Converters and frequently copies me on emails that address various issues associated with the New York Climate Leadership and Community Protection Act (Climate Act). I have published other articles by Ellenbogen including a description of his keynote address to the Business Council of New York 2023 Renewable Energy Conference Energy titled: “Energy on Demand as the Life Blood of Business and Entrepreneurship in the State -video here: Why NY State Must Rethink Its Energy Plan and Ten Suggestions to Help Fix the Problems”. He is an engineer who truly cares about the environment and is an early adopter of renewable technologies at both his home and business.
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.
Senate Energy and Telecommunications Committee Meeting
On March 18, 2025 Senator Mattera invited Richard Ellenbogen to Albany to address the NY State Senate Energy & Telecommunications Committee regarding NY State’s energy situation. Senator Parker, the committee chair, was extremely gracious and essentially gave him an unlimited amount of time to describe his thoughts on utility decarbonization using existing technologies. There is a video of the hearing available. Ellenbogen’s presentation starts at 12:40.
Senator Parker has shown signs of pragmatism regarding the implementation of the Climate Act. During the 2023 budget process he co-sponsored a bill to modify the Climate Act to use the 100-year global warming potential (GWP) that the Environmental Protection Agency and the Intergovernmental Panel on Climate Change use instead of the 20-year GWP mandated by the Climate Act. The only reason to use the 20-year GWP is the irrational belief that methane is a significant threat to global climate. New York’s environmental community went ballistic calling the proposed revision an attempt to gut the Climate Act. The proposal was quietly withdrawn in response to the pressure. Frankly, I thought that experience would mean that Ellenbogen’s presentation on the heretical idea that using natural-gas fired combined cycle combustion turbines with carbon capture (that can get a 90% CO2 reduction but not reach zero emissions) would be given short shrift but it wasn’t.
Ellenbogen Presentation
Ellenbogen referred to a handout during his presentation and the full version of the document is available. He also referenced recent comments on utility system decarbonization 15-e-0302 that provide more background information. The remainder of this section describes highlights of the hearing with links to the video for each highlight.
Ellenbogen’s presentation started with a description of his background. As noted in the introduction he has a proven record of reducing GHG emissions, waste reductions, and energy efficiency deployment at both his home and manufacturing facility. He emphasized that his strategies reduced emissions significantly but did not eliminate them entirely so his efforts would not be enough to meet Climate Act mandates.
Ellenbogen made the point that the Climate Act authors placed too much reliance on Academic “Science”. He gave an example describing how the emphasis on methane is misplaced. I agree that the methane obsession in the Climate Act is irrational.
Ellenbogen offered to discuss his concerns about the results of Ignoring science during his summary of the problem. His personal decarbonization experience made him aware of logistical issues so the labor and supply chain that are delaying the Climate Act strategies were no surprise to him. He argues that physics makes the reliance on wind and solar an impossible proposition. He has explained to me that 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
Ellenbogen says that one of the huge issues is New York’s existing fossil load. He described the following chart explaining that the first column is the load in 2019. If we were to electrify everything you would get the second column because many of the electric technologies are more efficient. The problem is that without energy storage the system breaks down. The third column shows the energy storage in the NYSERDA report New York’s 6 GW Energy Storage Roadmap: Policy Options for Continued Growth in Energy Storage. Column D lists the state plan for renewables in 2035. The point of the graph is that the projected renewables do not come anywhere near what is needed.
Ellenbogen’s presentation argued that there is a better way that “adheres to reality”. He believes that repowering existing power plants with combined cycle gas turbines gives a carbon reduction of “30 to 40%.” Replacing the old units reduces emissions, decreases reliability risks because the old units are so old that they are more likely to fail, and because the combined cycle plants are more efficient, they would burn less fuel to produce the same amount of electricity.
Note: I will eventually publish a post describing my supplemental emissions analysis of this proposal. For this article note that when I evaluated 2020 emissions and I found that if 45 existing New York fossil-fired units were replaced by state-of-the-art combined cycle natural gas fired combustion turbines, annual emissions would be reduced 16%. My results are lower than the Ellenbogen presentation because I did not account for the improved efficiency and resulting lower fuel use that would reduce emissions more. Ellenbogen’s email description of the analysis provides background information until I do a detailed post on emissions.
Questions
I am not going to address all the questions and issues that were raised during the presentation. The following are some highlights.
Senator Parker had questions about methane. Ellenbogen responded that the emphasis on methane reductions is misleading because recent analysis shows that anthropogenic activities are not the primary source of methane in the atmosphere. Consequently, reducing natural gas in New York is not going to significantly affect potential global warming.
There was a cost discussion. Ellenbogen did not respond to the issues raised during the presentation because he needed to review recent information. He did respond to the questions in a follow-up letter that referenced a Central Hudson response to a rate case question about the costs of the Climate Act. It has been my experience that every issue I have looked at is more complicated than it appears at first glance. Such is the case with the Central Hudson $4.269 trillion cost estimate based on the Scoping Plan. Suffice to say here that there is a lot of uncertainty associated with that figure. I have addressed some of the affordability problems recently but will explain the issues associated with the Scoping Plan cost estimates some other time.
I want to discuss is the comment by Parker that the state will not be repealing the Climate Act. He asked Ellenbogen what we can do to make it successful. Ellenbogen responded that we need to broaden the terms to overcome physics reality. He explained that the energy density of wind and solar is insufficient for what is needed. Intermittency is another issue because it needs over-building and storage. Ellenbogen’s recommendation is for a non-zero alternative because it is energy-dense and dispatchable. There still are significant reductions but reliability risks are eliminated.
Parker said he would need to see the difference between the various options described. We know existing emissions levels but he also wants to see the improvements due to more efficient combined cycle units and the improvements if carbon capture is added to that. The analysis of mine described earlier was prepared to directly respond to these questions.
When Ellenbogen was asked for recommendations going forward, he said “We have to be realistic” because the reality is that physics and math limit what can be done for the transition. That leads to his recommendation to pursue combined cycle combustion turbines with carbon capture until other proven zero-emissions technologies like nuclear can be deployed.
Ellenbogen’s recommendation is a pragmatic solution that I support. Unfortunately, there was no one at this hearing who was aware of the recent history of re-powering proposals for combined cycle natural gas plants and relevant nuances of the Climate Act that make this approach a tough sell.
For example, at one point Senator Parker stated that if there are companies out there that want to submit proposals for combined cycle plants, they should submit proposals. The problem is that three repowering project applications have all been rejected or withdrawn since the Climate Act passed. The Danskhammer Energy Center proposed a replacement gas-fired combined-cycle combustion turbine but DEC denied the permit stating that “The proposed project would be inconsistent with or would interfere with the statewide greenhouse gas emissions limits established in the Climate Act.” Although not a combined cycle proposal, NRG Energy proposed replacing their old units with modern units but the DEC decision letter claimed that “the Project would be inconsistent with or would interfere with the attainment of the Statewide greenhouse gas (GHG) emission limits established in Article 75 of the Environmental Conservation Law (ECL)”. A subsidiary of Eastern Generation LLC proposed to repower their old turbines at Gowanus and Narrows with modern simple cycle turbines. As far as I could tell everyone at this hearing understood the benefits of replacing old with new and trying to avoid stranding the investments. This development was for barge mounted turbines. Once it was clear that they could be replaced with something consistent with the Climate Act they could have been moved elsewhere but the company withdrew their application because of DEC’s position on consistency with the Climate Act.
There also is a problem with the recommendation to capture the carbon. My reading of the Climate Law is that it prohibits the use of carbon capture and sequestration for an electric generating unit. The references to sequestration in the law are associated with the definition of “Greenhouse gas emission offset projects” that includes the following project: carbon capture and sequestration. Section 75-0109 “Promulgation of regulations to achieve statewide greenhouse gas emissions reductions (4. a.)” states that “The department may establish an alternative compliance mechanism to be used by sources subject to greenhouse gas emissions limits to achieve net zero emissions.” However, carbon capture and sequestration at electric units is expressly prohibited in § 75-0109, (4,f) “Sources in the electric generation sector shall not be eligible to participate in such mechanism.”
Conclusion
I was very encouraged by the meeting. Senator Parker’s admission that there are implementation issues and course corrections are necessary is refreshing because most of his colleagues have not shown any departure from the orthodoxy. At one point during the meeting Senator Mattera and Senator Parker agreed on the need to be more flexible which Richard Ellenbogen notes is the equivalent of seeing a Unicorn. All this suggests that there might be support for a course correction of the Climate Act.
Nonetheless, I want to point out that at the end of the meeting Ellenbogen left a gift for Albany – a wand in a glass case with a note saying in case of a blackout break glass. A magical solution still may be the last hope.
I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act) could have devastating impacts on New York residents as long if proponents ignore lessons that could be learned elsewhere and continue down the current path. This post describes work done in Great Britain that has direct bearing on New York’s implementation plans and shows we need to re-think the tradeoffs of Climate Act implementation.
I believe 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. 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. Recently, the State initiated the State Energy Plan process to update it to be consistent with the Climate Act. It is not clear whether this proceeding will consider stakeholder comments that were ignored during the Scoping Plan process.
Renewable Resource Lulls
The Scoping Plan, Integration Analysis, New York Independent System Operator (NYISO), New York Department of Public Service, the New York State Reliability Council, and others all have noted that a new category of generating resources called Dispatchable Emissions-Free Resources (DEFR) is necessary to keep the lights on during periods of extended low wind and solar resource availability. The frequency, duration, and intensity of wind and solar availability gaps must be known to properly plan to provide the generation, storage, and DEFR resources necessary to maintain reliable service. Analyses done by the New York State Reliability Council Extreme Weather Working Group have shown that extended periods of low wind and solar resource availability will be challenging for the future New York electric system.
On December 24, 2024 I submitted testimony for the December 18, 2024, Assembly Standing Committee on Energy Public Hearing regarding NYSERDA Spending and Program Review. I noted that the biggest feasibility challenge is the identified “gap” when wind and solar resources are low for long periods. As one example of appropriate feasibility funding, I recommend analyzing the variability in low wind and solar resource availability. The characteristics of the resource gaps must be quantified not only for New York but also for adjoining regional systems presuming that they also transition to an electric system with a similar reliance on wind and solar.
The Independent System Operator of New England (ISO-NE) Operational Impact of Extreme Weather Events completed an analysis that addresses this need for New England. The study evaluated 1-, 5-, and 21-day extreme cold and hot events using a database covering 1950 to 2021. The results found that the system risk or “the aggregated unavailable supply plus the exceptional demand” during an event increased as the lookback period increased. If the resource adequacy planning for New England only looked at the last ten years, then the system risk would be 8,714 MW, but over the whole period of record, the worst system risk was 9,160 MW which represents a resource increase of 5.1%. This means that the low renewable resource analysis should cover as long a period as possible to determine the longest period of exceptional demand and low renewable resources.
Great Britain Renewable Assessment
David Turver blogs about energy issues in Great Britain. In an October 2023 post he describes a report from the Climate Change Committee (CCC), their equivalent to New York’s Climate Action Council. He explains that the Royal Society (RS) Large Scale Electricity Storage report authored by Professor Chris Llewellyn-Smith claims that Great Britain can meet its demand for electricity with wind and solar, supported by large-scale hydrogen storage. Large-scale hydrogen storage is the placeholder DEFR technology in the Scoping Plan, so this analysis is directly applicable to New York’s DEFR resource issue.
Turver argues that the report is deeply flawed. Among his concerns are the following:
They begin by assuming that electricity demand will be 570TWh in 2050 which represents roughly halving the energy demand across residential, transport and industrial and commercial categories. The evidence from Our World in Data shows that rich economies require high energy consumption to thrive. There are no rich countries with low energy consumption and those countries that have reduced energy consumption have grown more slowly, or even shrunk. The first extraordinary claim of low energy consumption fails because the evidence shows that if we allow that to happen, we will be much poorer.
The report then goes on to assume that the profile of electricity demand will be the same as today. However, as we move from gas to electricity to heat our homes and offices, the winter surge in electricity demand will be further exaggerated. Moreover, demand will change from year to year such as during the cold winter in 2010 that also coincided with a calm period when we would have generated much less renewable electricity. These variations in demand profile will lead to more generation capacity and an even bigger energy store than RS assumes, pushing up costs.
He goes on to argue that there are other flaws. the report assumes unrealistic load factors for both onshore and offshore wind. It underestimates the amount of offshore wind needed and goes on to assume efficiencies and costs for hydrogen electrolysers, storage, and generation that do not stand up to scrutiny. He also points out that the economic assumptions are flawed.
He describes the “main positive aspect of the report”:
The thing that stands out most is the painstaking analysis that has been conducted to understand the very significant changes in the weather that occur on yearly and decadal timescales. They analysed wind and solar records over 37 years to estimate the level of variation we might expect from wind power.
In a recent article Turver includes a graphic that shows this issue using the 37 year database.
The analysis of 37 years is longer than anything done to date for New York. He also points out an aspect of DEFR that relies on hydrogen storage that I had not considered previously. It is not just the annual worst-case episode but there can be multi-year issues:
They found that we can sometimes have several consecutive years where the wind speed is lower than average. This means that if we are to have a grid powered solely by wind, solar and storage, then we need to build up massive stores of energy in the windy years to be used in the calmer years. They conclude that to consistently deliver their 570TWh of electricity each year, we would need 123TWh of hydrogen storage. Some of that hydrogen may have to be stored for a decade or more before it is used.
He also points out that the requirement for decadal storage is another flaw for any DEFR backup resource:
This has important implications for the economics of storage and effectively rules out batteries as the storage medium. Who would want to spend millions on building a battery or hydrogen storage cavern, even more to fill it and maintain it, yet not see any revenue from it for years after it was completed?
DEFR Backup Reliability Risk
Turver’s article raises the ultimate reliability risk for a weather-dependent electric system. Today’s electric system resource planners for a conventional system base the amount of capacity that they think will be needed based on decades of observations of the fallibility of power plants. The result is that they know the probability there will be a shortage of available capacity to meet load when the installed reserve system capacity margin is a fixed percentage of the expected load very well. In New York State the installed reserve margin to meet the accepted probability of a loss of load expectation of an outage no more than once in ten years reliability metric is around 20%.
A fundamental observation is that there is no expectation that the failure of conventional power plants will be correlated. We do not expect that many will fail at the same time. That in turn means that even if we decided to set the reliability metric based on a one in thirty-year probability that there would not be much of an increase in the installed reserve margin.
That all changes when the electric system transitions to one dependent upon wind and solar weather-dependent resources. We know that solar energy is zero and night and much lower in the winter. Similarly, we know that wind energy is much lower in a high-pressure system, and that those systems are huge and cover all Great Britain and much of western Europe or eastern North America at the same time. Exacerbating the problem is the fact that those conditions are associated with the hottest and coldest episodes with the greatest expected electric loads.
Turver’s post shows that looking at one year is absurd. Not looking at the worst year on record is nearly as bad: “They used 1987 as a 1-in-20 year stress test, when they admit that 2010 was a 1-in-50 year event”. The insurmountable problem is that we know that if an even longer period of record was used there would very likely be an even worse event. Instead of the confidence in the current planning process that increasing the lookback period will not markedly change the resources needed for the worst case, relying on weather-dependent resources means that inevitably there will be a period of extreme weather that exceeds the planning criteria chosen and the expected resources based on those criteria. The costs to provide DEFR backup support will be extraordinary and building excess capacity for a very rare event will significantly add to those costs. This trade-off means that eventually there will be a catastrophic blackout when the load exceeds the storage capacity.
Conclusion
Turver’s articles are further evidence of the DEFR “gap” problems for any electric system that relies upon weather-dependent renewable resources. The first problem is that you have to determine how much DEFR capacity is needed using as long record as possible. The second problem is that there is no commercially available DEFR technology that is available to deploy for the aspirational Climate Act targets. Thirdly, until a DEFR strategy is proposed we have no idea how much this will all cost so any claims that the Climate Act will be “affordable” are incomplete. Finally, there is the insurmountable weather-related probability that eventually there will be a unusual set of weather conditions and load requirements that exceed the DEFR resources deployed.
To sum up: we know that a new resource will be needed, we don’t know how much, what it will be, how much it will cost, and that whatever we do eventually it won’t be enough so people will die in a catastrophic blackout. This is insanity.
Pragmatic Environmentalist of New York 