Category: Climate Act Feasibility

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 (PM_2.5) 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, PM_2.5  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 PM_2.5 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.

Parker re-iterated his request for emission numbers and noted that the timeline may have to shift to accommodate numbers and physics.  He admitted that we are not on track for a variety of reasons.  More importantly he also said that  at the end of the day NY is not going to solve the climate crisis but we can still provide leadership.

Discussion

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.

David Turver supports my belief that New York’s Climate Leadership & Community Protection Act (Climate Act) is not in the best interests of New Yorkers.  The basis of his arguments is the unfolding disaster in Great Britain.  His post includes a video of a talk on the topic, copy of the slides, and the argument summary described below.

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.  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 post 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.” 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. 

Net Zero Cure is Worse Than the Disease

Turver introduces his arguments by noting that climate change impacts are exaggerated:

Although people like Antonio Guterres have made the foolish claim we have entered the era of global boiling, we have to acknowledge that the world has warmed a bit since pre-industrial times. The alarmist response to this is Net Zero which is an example of a so-called mitigation strategy that calls for everyone to reduce their emissions of carbon dioxide to save the planet.

Earlier this year I quoted Richard Lindzen’s description of the made-up rationale: “In this complex multifactor system, what is the likelihood of the climate (which, itself, consists in many variables and not just globally averaged temperature anomaly) is controlled by this 2% perturbation in a single variable? Believing this is pretty close to believing in magic.” 

The following paragraph eviscerates the entire rationale of the Climate Act.  Turver explains that the mitigation can never work:

The trouble with this approach is that it can only work if two conditions are met. First, mitigation can only work if CO2 is the only climate control knob. But we know this to be wrong, because the IPCC’s first report showed marked temperature fluctuations over thousand-, ten thousand- and million-year timescales when CO2 levels in the atmosphere were pretty constant. Second, mitigation can only work if everyone else follows the same strategy. But we know that global emissions of greenhouse gases are rising sharply even though ours have fallen into insignificance. Global consumption of coal, oil and gas are at record levels. Neither condition is met, so the UK’s Net Zero mitigation strategy can never work.

Turver is as frustrated as I am about the impact of net zero policies like the Climate Act:

Nevertheless, this has not stopped politicians and policymakers rushing headlong into Net Zero policies that have resulted in the UK having the most expensive industrial electricity costs in the IEA, some 4X those of the US and 2.6X Korean prices. This is leading to energy austerity with UK primary energy consumption down 23% since 1990 while global energy consumption is up 72% over the same period. Our National Energy System Operator, NESO wants to double down on energy austerity and halve our energy consumption per capita from 2023 levels by 2050.

High energy prices coupled with energy austerity have led to economic stagnation. There is a strong correlation between reduced energy use and slow growth, with the EU27 and US growing faster than the UK because they have had smaller cuts to energy use. Korea, India China and the rest of the world are using much more energy and their economies are powering ahead.

I do not see any scenario where these impacts will not occur in New York.

The rationale for the Climate Act is that we have a problem, that it can be solved by reducing greenhouse gas emissions, and that there is an easy way to reduce emissions.  Turver describes the myths created to promote renewables:

Despite the obvious economic and social costs of Net Zero, a series of myths have been created to support the renewables agenda. They claim renewables are cheap, but we pay £11bn/yr in renewables subsidies, £2.5bn for grid balancing and a further £1bn for the capacity market. National Grid have announced £112bn in spending on grid expansion by 2035 which will also find its way on to our bills. Moreover, the cost of renewables is rising and projects like Norfolk Boreas and Hornsea Project Four have been cancelled because the developers cannot make money at the prices they agreed. Ed Miliband wants to spend £260-290bn by 2030 on his Clean Power plan to save only around £7bn/yr of the money we spend on gas-fired generation.

Turver explains that the ideologues pursuing these policies think that it will improve the economy:

The second myth is that Net Zero will create jobs and growth. But the truth is expensive energy costs are destroying high-productivity industries like chemicals, petrochemicals, ceramics and steel that are growing more slowly than the rest of the economy or outright shrinking. Instead we are growing less energy intensive low-productivity sectors that are damaging productivity and growth for the whole economy. Green energy jobs are destroying real jobs and cost around £250K/yr per job.

Turver describes another myth that has been used in New York:

The third myth is that renewables increase energy security. But intermittent sources like wind and solar can never deliver security because we cannot control the weather. As a result we came close to blackouts last month as NESO suffered a margin call. We cannot rely upon interconnectors either, because the Norwegian Government fell because of the impact interconnectors are having on their electricity prices.

The Climate Act mandates that all environmental impacts of fossil fuels be considered but pointedly ignores any consideration of wind and solar development impacts.  Turver notes that this is a common flaw:

Finally, it is claimed that wind and solar renewables are green and kind to the environment. But both have very high mineral intensity, meaning massive mines will be scarring the landscape to produce the copper, silver, cobalt and rare earth metals required. They also take up a lot of land, land that would be better utilised to grow food.

The Climate Act does include a requirement to consider adaptation.  Turver explains that adaptation is a superior strategy:

By contrast, adaptation is a far superior strategy. Deaths from natural disasters and weather events have fallen more than 10-fold over the past century as we have used cheap, abundant energy to tame nature. Global life expectancy has doubled since 1850 and cereal yields are up three times since 1961. These remarkable achievements have come despite, some might argue because of, the rise in temperatures and global CO2 levels.

In my opinion, New York short changes this strategy because at its root the Climate Act is a political tool.  Politicians passed the law to cater to specific constituencies but the opportunities to make money via adaptation are small. Given that there are no organized rallies organized by politically connected constituencies at the Capitol lobbying for adaptation policies this strategy is not a priority.

Turver concludes that nuclear power is the answer:

Turning now to the answer. For humanity to thrive, we need cheap, abundant and reliable energy. This will give us the surplus energy that we need to continue to adapt by building flood defences, improving irrigation developing new crop varieties and so on. Adaptation has the big advantage is that it works regardless of the cause of global warming or climate change. The only technology that is proven to work at scale is nuclear power. This will take time, so we need gas as a transition technology. Nuclear power has the added advantage of being energy dense, reliable and requires very little mining so has the smallest overall environmental footprint. We need nuclear power everywhere all at once.

I agree that developing nuclear power is a better choice.  His pragmatic approach to use natural gas as a bridge fuel used to be the accepted path forward.  The vilification of natural gas is based almost entirely upon emotion and precludes a strategy that has proven success.

Conclusion

Philosopher George Santayana, originally stated, “Those who cannot remember the past are condemned to repeat it”.  In this instance New York is ignoring what is currently happening with respect to the net-zero transition in Great Britain.  The consequences will be the same.  Turver concludes:

Net Zero is ineffective in achieving its primary goal and can never stop the weather changing. The impact of Net Zero policies is devastating for the economy and high productivity, energy intensive industries in particular. Renewables are not kind to the environment and the lies being told to promote them are untenable. The Net Zero cure is worse than the climate change disease.

Russ Schussler, aka Planning Engineer, has published a prequel to an upcoming article discussing the narrative around the green energy transition that is a prominent component of the Climate Leadership & Community Protection Act (Climate Act).

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.  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 post 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.  Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Scoping Plan was finalized at the end of 2022.  Schussler’s article is relevant because the Scoping Plan proposes to meet the zero-emissions mandate using wind, solar, and energy storage.

Green Energy Narrative

Schussler describes the narrative of the wind and solar proponents aka green energy:

The green energy narrative works somewhat like a magician’s patter, overemphasizing many things of irrelevance and distracting the audience from the important things going on. Misdirection ensures small truths are misinterpreted and magnified, leading to completely unrealistic hopes and expectations.

For example, there have been many simple studies examining how much energy might be produced by a green resource, or set of green resources, such as wind and solar power. These studies ignore important issues such as deliverability, timing, reliability and costs. Based on simple studies the media, activists and policy makers frequently conclude that such resources can be used near universally on a large scale to provide electric service to consumers effectively, efficiently and economically.

This is precisely what happened in New York when the Climate Act authors developed the targets and mandates of the law.  These ideologues misinformed the Legislature and Governor Hochul with claims that “our State could rapidly move away from fossil fuels and instead be fueled completely by the power of the wind, the sun, and hydro” and “that it could be done completely with technologies available at that time (a decade ago), that it could be cost effective, that it would be hugely beneficial for public health and energy security, and that it would stimulate a large increase in well-paying jobs.”

Schussler explains the problem with this argument:

In the green energy narrative costs have been demonstrated, environmental impacts have been demonstrated, reliability has been demonstrated, deliverability has been demonstrated and all shown to possibly work, BUT NOT AT THE SAME TIME. In the eyes of many, such demonstrations cumulatively strengthen the green energy narrative. However, the gullible audience will be shocked when wind, solar and batteries are not at all well suited to support electric generation on their own.

Schussler highlights three tricks of the green energy narrative: misleading language, false problem and narrative control.

Misleading Language

Schussler addresses the term “renewable” calling it “one of the most misleading bits of language advancing the green agenda.”  He notes:

Different “renewable” resources have vastly differing capabilities. There is vast potential to develop some ‘renewables”. Some “renewables do a great job supporting the grid. Some “renewables” have low energy costs in some areas. Some “renewables” are environmentally sound in some areas. No matter how well individual “renewable” resources might be combined to tick off all the boxes of importance, that doesn’t mean that any combination of “renewable” resources can be found that will work well for any given area. It means little that hydro and geothermal provide excellent support for the grid in an area where you can only add wind and solar. Similarly, just because solar and wind have potential environmental benefits that doesn’t cancel out environmental concerns around hydro in delicate ecosystems.

The problem is that in most areas including New York, “there are no compatible combinations of renewables that at any significantly high penetration level that can provide  affordable, environmentally responsible energy in a reliable manner. Referring broadly to what “renewables” can and might do, serves to hide this inconvenient truth.”

The False Problem – Intermittency is not THE problem for Wind and Solar

Schussler argues that:

It is a fallacy to assume that because part or some of the difficulties associated with a technology can be overcome, that therefore all of the problems associated with a technology can be overcome. Worst case for a “partial solutions fallacy” is when a major problem is hidden by presenting a minor problem as the major stumbling block. Primarily focusing on the minor problem incorrectly implies that there will be smooth sailing once this solvable problem is overcome by hiding the large problem.

To implement a green transition bolstered by heavy wind and solar, all associated problems must be addressed. The major problem associated with wide-scale use of these resources  cannot be ignored.

Schussler goes on to argue:

The real problem is that wind, solar and batteries do not readily provide essential reliability services and support the grid. Most of the talk is around addressing intermittency through batteries and other storage approaches. Misdirection here focuses on intermittency, the smaller problem, while ignoring the major problem.

Schussler believes that it may be possible to address intermittency:

The long-term problems associated with wind and solar due to their intermittency could and may likely be made manageable with improved technology and decreasing costs. But such changes will not make wind, solar and batteries comparable to more conventional generating resources, such that they can play a large role in a green energy transition, because the large problem is not intermittency.

The point of his discussion is that there is another, more serious problem that is a fatal flaw:

Overcoming intermittency though complex and expensive resource additions at best gets us around a molehill which will leave a huge mountain ahead. Where will grid support come from?  Wind, solar and batteries provide energy through an electronic inverter. In practice, they lean on and are supported by conventional rotating machines. Essential Reliability Services include the ability to ramp up and down, frequency support, inertia and voltage support. For more details on the real problem see this posting. “Wind and Solar Can’t Support the Grid” describes the situation and contains links to other past postings provide greater detail on the problems.

I think that in an electric system that is reliant on weather dependent wind and solar resource, intermittency creates an unacceptable reliability risk.  Current resource assessments are based on observations of the existing uncorrelated generating resources over many years that show that unplanned outages do not happen at the same time.  There is no reason to expect, for example, that all the nuclear plants will be forced offline at the same time.  This characteristic enables the resource planners to determine how much generating capacity is necessary to meet the probability of losing load not more than once in ten years loss of load expectation (LOLE) reliability criterion.  Importantly, I believe that the lack of correlation also means that the capacity needed above firm system load would not change substantially if the LOLE planning horizon was shifted to 1 day in 20 years or more.

The problem with weather intermittency is that it is correlated over large areas at the same time. As a result, variations in weather affecting wind and solar resource availability will require changes to electric resource planning.  Everyone has heard of a hundred-year flood which is the parameter used for watershed planning.  This is the one in a hundred probability that the water level in a river or lake will exceed a certain level in a given year.  Similar estimates of low wind and solar resource availability must be developed and incorporated into electric resource planning. Based on New York data I think a hundred-year planning horizon is appropriate.  The problem is that the costs for such a threshold are huge and the resources will be used less than their expected operating lifetimes.  The resulting reliability risk is that affordable backup resources will be insufficient to support the load during the hundred-year low wind and solar availability event and a catastrophic blackout will result.

Russ and I discussed my interpretation of this reliability risk, and we agreed that we are making the same point in different ways.  If money is not an issue, then it is possible that the intermittency issue can be overcome by overbuilding wind and solar resources, short-term energy storage, long-term energy storage to deal with extended low wind and solar resource periods, and transmission.  However, affordability is a fatal flaw because the costs necessary would be astronomical for a resource that would only be used less than the expected lifetime of the resources.  On the other hand, the grid support requirements cannot be resolved by throwing any amont of money at the problem so that is unsolvable.

Narrative Control – Shameless Hucksterism and the Media

The last green energy narrative trick is controlling the narrative.  Schussler explains:

The green energy narrative is propelled by stories of success. Often these “successes” are very different from what seemed to be represented. We see great stories of planned projects that should do wonderful things, but they go down the memory hole as they prove not to work out. We see incomplete stories where they talk of power generated but not of associated costs or how much better other alternatives might have been.

He goes on to describe an example headline that claims that seven countries get 99.7% of their electricity from geothermal, hydro, solar, and wind power. However, he points out:

Without the spin, collectively those countries get close to 99% of their energy from rotating synchronous geothermal and hydro resources and less that 2% of their combined electric energy from wind and solar. The fact that some countries have high amounts of hydro, does not provide evidence that we are approaching a tipping point involving wind and solar. In fact, one could observe that high levels of renewable penetration are associated with low levels of wind and solar.

Conclusion

Schussler and I agree that it is becoming increasingly apparent that wind, solar and batteries when pursued at high penetration levels result in high costs, lower reliability and poorer operational outcomes. He points out that “Expectations from the green energy narrative and real-world results are not consistent and this gulf will continue to widen as long as policy makers continue to reflexively buy into the green energy narrative.”

The high expectations in the green energy narrative shaped the promulgation of the Climate Act and is driving its implementation.  Schussler describes the inherent misinformation and other various deceptions to hide the real-world challenges for New York’s net-zero transition. As reality sets in, proponents must push this narrative harder and louder to hide the obvious flaws.  I look forward to Schussler’s follow up article that “will more systemically examine the components of the green energy narrative and raise many items of critical importance considerations that the green energy narrative ignores.”