Category: Climate Act Feasibility

Time for Resets in California and New York

The Breakthrough Journal published an article by Jennifer Hernandez and Lauren Teixeira entitled Time to reset California’s climate leadership that I think is relevant to New York.  I have recently argued that because there are so many unanswered questions and unresolved issues that the logical next step for New York is to pause in Climate Leadership & Community Protection Act (Climate Act) implementation until we understand how to decarbonize our electric system without adversely affecting affordability and current reliability standards.   Hernandez and Teixeira come to the same conclusion but with arguments that I have not made but are applicable to New York too.

I am convinced that implementation of the New York Climate Act net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 490 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 2030 reduction target of a 40% GHG reduction by 2030. Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040.

Responsible New York agencies all agree that new Dispatchable Emissions-Free Resource (DEFR) technologies are needed to make a solar and wind-reliant electric energy system work reliably during periods of extended periods of low wind and solar resource availability.  Because DEFR is needed and because we don’t know what technology can be used, I think that the Climate Act schedule needs to be paused.  In that light I was interested in this article calling for California to “go back to the drawing board”.

Jennifer Hernandez and Lauren Teixeira are both well versed in California energy policies.  Hernandez has practiced land use and environmental law for more than 30 years and has received numerous civil rights awards for her work on overcoming environmentalist opposition to housing and other projects needed and supported by minority communities.  Teixeira is a Climate and Energy Analyst with the Breakthrough Institute. 

California Climate Leadership

California was the first in the nation legislate a “solution” to climate change with its AB32 Global Warming Solutions Act of 2006.  After fourteen years the inevitable effects of reality are getting the attention of the politicians that supported the law.  The introductory paragraph explains:

Faced with the election of Donald Trump to a second term, soaring inequality, and a decline in support from the state’s non-white majority, California’s Democratic leaders have begun asking hard questions about the state’s vaunted climate policies. California’s Democratic Assembly leader Richard Rivas opened the new Legislative session signalling a strong focus on meeting voter concerns about housing and the state’s extraordinarily high cost of living, specifically calling out the state’s climate policies: “California has always led the way on climate. And we will continue to lead on climate,” he told his Assembly colleagues. “But not on the backs of poor and working people, not with taxes or fees for programs that don’t work, and not by blocking housing and critical infrastructure projects. It’s why we must be outcome driven. We can’t blindly defend the institutions contributing to these issues.”

Hernandez and Teixeira compared several metrics for California, Florida, Texas, and the United States to determine how successful California’s claim that they lead the way on climate has been. They explained that:

California’s claims to eco-superiority long predate the passage of AB32, the 2006 law that committed the state to ambitious climate targets and established a cap-and-trade system by which to achieve them. Even before this landmark bill, the state’s per capita carbon emissions were far lower than the national average.

Table 1 compares the data from CA, FL, TX, and the US along with New York and the original ten Regional Greenhouse Gas Initiative (RGGI} states.  I included the RGGI states because they also claim to be climate mitigation leaders.  The authors chose to compare current emissions to 2006 when California’s landmark climate law AB32 was passed.  I analyzed Energy Information Administration  data and added two other years. I included 1990 because that is the base year for most net-zero transition programs and 2000 because that has been used by New York State in recent analyses.  The results show that New York is close to California for most years. Note that compared to the other jurisdictions New York is the worst performer almost every year.

Table 1: Per capita energy-related carbon dioxide emissions

Hernandez and Teixeira explained the reason for the decreases was the same as what I have found in New York:

The reason why states like Texas and Florida were able to reduce greenhouse gas emissions with practically no climate policy to speak of is quite simple: natural gas. Emissions reductions in Texas and Florida were driven by the electricity sector, which had transitioned from coal to natural gas for largely economic reasons. Indeed, by 2017, 41 out of 50 U.S. states had decoupled economic growth from emissions, a phenomenon widely attributed to this transition.

New York politicians were undoubtedly influenced by California’s AB32 because we have similar restrictions on the what technologies were acceptable for reducing GHG emissions:

Along with its climate commitments, California’s political leaders also decreed that further carbon emission reductions in the electricity sector would need to be achieved with a limited suite of renewable energy technologies: solar, wind and battery storage. (Both legacy technologies like hydropower and nuclear, and technologies considered renewable in other states and countries such as biomass, did not meet the state’s narrow definition of “renewable” energy.)

This decision had consequences. Costly renewable energy power purchase agreements, combined with the expense of integrating intermittent resources into the grid, helped to make California’s retail electricity prices the highest in the country (second only to Hawaii). Meanwhile, the state’s remarkable rate of rooftop solar adoption—due to the combination of costly retail electricity, generous state subsidies to often-wealthy homeowners, and rooftop solar mandates—ended up raising electricity prices still further, pushing costs disproportionately onto renters and low-income households who do not have their own rooftop solar.

Given California’s fourteen-year head start I am not surprised that New York’s rates have not shown comparable increases, but double-digit rate case settlements and all the other costs required for the transition will inevitably show similar impacts at some point.  The important point made here is that California’s policies have disproportionately increased costs for those least able to afford it.  I have always thought that was a likely outcome but here is proof.

Decarbonization at the expense of growth and civil rights?

In the introduction, Hernandez and Teixeira quoted Speaker of the Assembly Richard Rivas who said “California has always led the way on climate. And we will continue to lead on climate, but not on the backs of poor and working people, not with taxes or fees for programs that don’t work, and not by blocking housing and critical infrastructure projects.”  The authors also addressed his concerns about effects of AB32 on the economy.

At first glance, California’s impressive economy—the world’s fifth largest, as state officials are fond of reminding the press and populace—would seem to vindicate its climate policy, demonstrating by virtue of its enormity that economic prosperity and deep decarbonization can coexist.

But the state’s wealth masks some troubling trends. While growth in California has significantly outstripped the rest of the country, it has been highly concentrated in just a few high-income places. Since 2001, California’s real GDP has grown by 82%–23 percentage points higher than the U.S. average of 55%. This difference disappears, however, when you take out the three Bay area counties that house Silicon Valley. Bolstered by four of the world’s seven companies with trillion dollar valuations, real GDP in these counties rose at four times the rate of the U.S. average. This remarkable and hyperlocal rise accounted almost entirely for California’s above-average growth:

New York proponents of the Climate Act also trot out New York’s economy relative to the world but don’t mention recent growth.  New York does not have the benefit of four massively successful companies so growth is much worse than California.  Hernandez and Teixeira note that even with those companies, recent growth is problematic:

But even with massively outsized contributions from Silicon Valley, California’s growth in recent years is not very impressive. Between 2017 and 2023, real GDP in California grew by only 18.5%, slightly above the national average (15.6%), and well behind real GDP in red state competitors Texas (25.7%) and Florida (27.3%).

I dug up some comparable gross state product numbers for New York.  Between 2017 and 2023 the gross state product only grew by 10%, well behind all three states and the nation.  Hernandez and Teixeira broke down growth by county and showed that the growth was unevenly distributed.  They also showed there was a racial disparity to growth.  I could not find similar data for New York, but I don’t think it is a stretch to imagine similar patterns are present in New York.

Hernandez and Teixeira also noted that growth is affected by environmental regulations:

California’s strict environmental regulatory regime has not helped to improve this unbalanced state of affairs; in fact, it has likely exacerbated it. Despite abundant natural reserves, the state’s once-mighty oil production industry—a source of well-paying jobs for non-college educated workers—is threatened with terminal decline due to a hostile regulatory environment. After 145 years in California, Chevron is moving its headquarters to Texas.

New York’s ban on hydraulic fracking has certainly limited growth in the same way.  The authors addressed other issues raised by Speaker of the Assembly Richard Rivas.  In both examples, the situation in New York is identical:

Conclusion

Hernandez and Teixeira summed up by making several points:

  • Considering California’s environmental and economic record since 2006, one can reasonably conclude one of two things: either it is not possible to achieve deep emissions reductions without slowing growth and making economic inequality worse, or California is doing something wrong.
  • California’s climate policies have contributed to slow economic growth for most of the state and have disproportionately punished the poor and non-college educated workers.
  • Until the state demonstrates that it can cut its emissions equitably, such that working people once more see the Golden State as a land of opportunity rather than fleeing it, California should not be held up as a model of climate governance.
  • Expensive policies, supported by high end keyboard economy tax revenue, are simply not exportable to the rest of the country, much less the rest of the world.

Buried somewhere in the Climate Act language is a mandate for New York to consider what is happening at other jurisdictions who are developing their own net-zero transition plans.  Typically, California is considered an example of what we should be doing.  In this instance I agree with the conclusion of Hernandez and Teixeira that: “While some state leaders may still be tempted to double down on current climate policies, the state, its political leaders, its economy, and the climate will be far better served by going back to the drawing board—as Speaker Rivas has urged.”  I also think that New York would be well served by their recommendation: “California’s claims to climate leadership now depend not upon proving that the state is willing to cut its emissions at any cost but rather demonstrating that it can cut its emissions while assuring that home ownership, an affordable cost of living, and good jobs are available to all.”

Climate Science New Year Rant

As I age, I am becoming less willing to play along with the Climate Leadership & Community Protection Act (Climate Act) narrative that there is an existential threat to mankind from man-made climate change and that an energy system that relies on wind, solar, and energy storage can solve that threat.  One aspect of playing along is to appease supporters by accepting that there is a reason to reduce GHG emissions and agreeing that solar and wind resources should be part of the future electric energy system.  Ron Clutz’s recent article “Lacking data, climate models rely on guesses” included information that spurred this article.

I am convinced that implementation of the New York Climate Act net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 480 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.

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  The authors of the Climate Act believed 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 that it could be done completely with technologies available at that time (a decade ago)”.  In my opinion we need a feasibility analysis to determine if this presumption is correct.  This article addresses the questions: should we be trying to reduce GHG emissions in hopes of affecting the climate and even if we accept that decarbonization is a worthy goal should we try to rely on wind and solar.

Is There an Existential Threat?

Keep in mind that climate models provide all the evidence that there is an existential threat.  Despite the constant claims in the main stream media, attributing extreme weather events to man-made climate change is a claim no one without a vested interest in that answer is willing to make.  Ron Clutz’s recent article “Lacking data, climate models rely on guesses” described the response to a question about climate model accuracy by Dr. Keith Minor.  The following is parts of the summary from Ron’s post.

A recent question was posed on  Quora: Say there are merely 15 variables involved in predicting global climate change. Assume climatologists have mastered each variable to a near perfect accuracy of 95%. How accurate would a climate model built on this simplified system be?  Keith Minor has a PhD in organic chemistry, PhD in Geology, and PhD in Geology & Paleontology from The University of Texas at Austin. 

Minor responded with bolds by Clutz:

I like the answers to this question, and Matthew stole my thunder on the climate models not being statistical models. If we take the question and it’s assumptions at face value, one unsolvable overriding problem, and a limit to developing an accurate climate model that is rarely ever addressed, is the sampling issue. Knowing 15 parameters to 99+% accuracy won’t solve this problem.

The modeling of the atmosphere is a boundary condition problem. No, I’m not talking about frontal boundaries. Thermodynamic systems are boundary condition problems, meaning that the evolution of a thermodynamic system is dependent not only on the conditions at t > 0 (is the system under adiabatic conditions, isothermal conditions, do these conditions change during the process, etc.?), but also on the initial conditions at t = 0 (sec, whatever). Knowing almost nothing about what even a fraction of a fraction of the molecules in the atmosphere are doing at t = 0 or at t > 0 is a huge problem to accurately predicting what the atmosphere will do in the near or far future.

These problems boil down to the challenge of measuring the meteorological parameters necessary to initiate weather and climate models.   The reference to t = 0 relates to the start time of the model. Minor explains that there are many sources of variability within the models themselves too including:

  • The inability of the models to handle water (the most important greenhouse gas in the atmosphere, not CO2) and processes related to it;  e.g., models still can’t handle the formation and non-formation of clouds;
  • The non-linearity of thermodynamic properties of matter (which seem to be an afterthought, especially in popular discussions regarding the roles that CO2 plays in the atmosphere and biosphere), and
  • The always-present sampling problem.

Minor goes on to describe how these issues affect weather forecasting and how more sampling could improve certain forecasts.  He concludes:

So back to the Quora question, with regard to a cost-effective (cost-effect is the operational term) climate model or models (say an ensemble model) that would “verify” say 50 years from now, the sampling issue is ever present, and likely cost-prohibitive at the level needed to make the sampling statistically significant. And will the climatologist be around in 50 years to be “hoisted with their own petard” when the climate model is proven to be wrong? The absence of accountability is the other problem with these long-range models into which many put so much faith.

Clutz also references a quote by esteemed climate scientist Richard Lindzen that I think sums up whether we should rely on climate models to make the policy decision to transition away from fossil fuels.   In a presentation (here) Lindzen states:

I haven’t spent much time on the details of the science, but there is one thing that should spark skepticism in any intelligent reader. The system we are looking at consists of two turbulent fluids interacting with each other. They are on a rotating planet that is differentially heated by the sun. A vital constituent of the atmospheric component is water in the liquid, solid and vapor phases, and the changes in phase have vast energetic ramifications. The energy budget of this system involves the absorption and re-emission of about 200 watts per square meter. Doubling CO2 involves a 2% perturbation to this budget. So do minor changes in clouds and other features, and such changes are common. 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. Instead, you are told that it is believing in ‘science.’ Such a claim should be a tip-off that something is amiss. After all, science is a mode of inquiry rather than a belief structure.

Can We Transition Away from Fossil Fuels

A recurrent theme at this blog is that the electric energy system absolutely needs new technology to achieve decarbonization.  Responsible New York agencies all agree that new Dispatchable Emissions-Free Resource (DEFR) technologies are needed to make a solar and wind-reliant electric energy system work reliably.  Because DEFR is needed and because we don’t know what should be used, I think that the Climate Act schedule needs to be reconsidered or at least paused.

I believe the only likely viable 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. I do concede that there are financial issues that need to be addressed.  The bigger issue is that DEFR is needed as a backup during extended periods of low wind and solar resource availability, but nuclear power is best used for baseload energy.  I estimate that 24 GW of nuclear could replace 178 GW of wind, water, battery storage.  Developing nuclear eliminates the need for a huge DEFR backup resource and massive buildout of wind turbines and solar panels sprawling over the state’s lands and water.  Until the New York Energy Plan settles on a DEFR solution the only rational thing to do is to pause the implementation process.

Lest you think that I am the only skeptical voice about the viability of an electrical energy transition relying on wind and solar resources I list some recent articles below.

Thomas Shepstone describes a fact sheet from the Empowerment Alliance that outlines why the electric grid is headed to a crisis:

America’s Electrical Grid Crisis is on the brink of a crisis that no one is talking about. Government mandates and pledges from utilities to achieve “net zero” emissions by 2050 or sooner have led to the closure of traditional power plants fueled by coal, natural gas and nuclear energy.

However, the wind and solar energy that is supposed to replace these sources is intermittent, unreliable and artificially supported by government subsidies. “Net zero” policies may sound nice on paper but they are not ready for practice in the real world.

In fact, the crisis may have already begun. A recent capacity auction by the largest U.S. electrical grid operator resulted in an over 800% price increase for these very reasons. And, everyday Americans are going to pay the price through higher bills for less reliable electricity.

  • One study of electricity plans in the Midwest found that, “Of the 38 major investor-owned utilities spanning the Great Lakes region, 32 are pledged to net zero by 2050 or sooner. Of the seven states analyzed in this report, three have net zero mandates by law, one has net zero mandates through regulation and the other three have no net zero mandates at the state level.”
  • “The Midcontinent Independent Systems Operator, the grid operator for much of the Midwest, projects that by 2032, none of the five Great Lakes states in its territory will have enough electricity capacity to meet even the most conservative projection of demand load.”
  • “Wind and solar cannot be relied on as a one-for-one replacement of existing generation sources, like coal, natural gas and nuclear. If the grid relies on forms of generation that are uncontrollable and unreliable, it must also maintain backup sources that are controllable and reliable. Because wind and solar production can fall to near zero at times, utilities may need to maintain up to another grid’s worth of generation capacity.”

Source:

Joshua Antonini and Jason Hayes, “Shorting The Shorting The Great Lakes Grid: Great Lakes Grid: How Net Zero Plans Risk Energy Reliability,” Mackinac Center for Public Policy, 2024

Thomas Shepstone describes a report by the Fraser Institute regarding the real costs of electricity produced from solar and wind facilities, compared to other energy sources.  Tom highlights the money paragraphs with his emphasis added:

Often, when proponents claim that wind and solar sources are cheaper than fossil fuels, they ignore [backup energy] costs. A recent study published in Energy, a peer-reviewed energy and engineering journal, found that—after accounting for backup, energy storage and associated indirect costs—solar power costs skyrocket from US$36 per megawatt hour (MWh) to as high as US$1,548 and wind generation costs increase from US$40 to up to US$504 per MWh.

Which is why when governments phase out fossil fuels to expand the role of renewable sources in the electricity grid, electricity become more expensive. In fact, a study by University of Chicago economists showed that between 1990 and 2015, U.S. states that mandated minimum renewable power sources experienced significant electricity price increases after accounting for backup infrastructure and other costs. Specifically, in those states electricity prices increased by an average of 11 per cent, costing consumers an additional $30 billion annually. The study also found that electricity prices grew more expensive over time, and by the twelfth year, electricity prices were 17 per cent higher (on average).

Finally, Chris Martz compares the impacts of wind and solar vs. nuclear power. I should note that he is not including DEFR support in his estimates. He concludes:

In order to power the same number of homes that a 1,000 MW nuclear power plant can, it would require either:

• For 𝐬𝐨𝐥𝐚𝐫 𝐏𝐕: Approximately 4,000 MW of installed power (equivalent to four nuclear facilities) and 24,000 acres of land (some 37.5 × as much land area than a nuclear plant).

• For 𝐨𝐧𝐬𝐡𝐨𝐫𝐞 𝐰𝐢𝐧𝐝: Approximately 2,800 MW of installed power (equivalent to 2.8 nuclear facilities) and 89,600 acres of land (some 140 × as much land area than a nuclear power generation station).

But, I should caution you that these estimates are in fact conservative. Why? Because they do 𝒏𝒐𝒕 take into consideration land area required for battery storage due to their intermittency in overcast sky conditions, low wind speed and/or overnight.

Conclusion

It is terrifying that the rationale and proposed solution to a New York policy that could cost hundreds of billions is based on fantasy.  Richard Lindzen describes 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.”  Keith Minor explains that even if this perturbation was the climate change driver that we can never provide enough data to to ensure that a model could accurately project the impacts.  The myth that wind and solar can replace fossil fuels on the schedule mandated by the Climate Act is dependent upon the fantastical notion that a resource that does not exist can be developed, tested, permitted, and deployed by 2040.

I can only conclude that allowing politicians to set energy policy will turn out to be an unmitigated disaster.

Why New York Renewables?

On December 18, 2024, the New York Assembly Committee on Energy held a public hearing to gather information about New York State Research & Development Authority (NYSERDA) revenues, expenditures, and the effectiveness of NYSERDA’s programs.  During questioning, members of the committee asked NYSERDA and New York Department of Public Service staff questions about implementation of the Climate Leadership & Community Protection Act (Climate Act).  This article discusses the response to the question can New York rely solely on wind and solar.

This is the 800th post at this blog.  I am convinced that implementation of the New York Climate Act net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 480 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 2030 reduction target of a 40% GHG reduction by 2030. Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantified the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation. 

The New York Assembly Committee on Energy hearing was intended to gather information about NYSERDA’s revenues and expenditures in order to gain a broader perspective on effectiveness of NYSERDA’s programs.  I submitted written testimony describing NYSERDA’s RGGI program effectiveness that included two documents: my public statement and an attachment that documented the analysis of the trends and cost-effectiveness.  I also included a link to the spreadsheet that generated all the trends and graphs.

At the end of this article is a complete transcript of the questions and responses.  The body of the article is not going to provide specific references.  Assembly Member Philip Palmesano asked the question about renewables that is the subject of this article.  Jessica Waldorf, Chief of Staff & Director of Policy Implementation, New York State Department of Public Service and John Williams, Executive Vice President, Policy and Regulatory Affairs, New York State Energy Research and Development Authority responded.

Why Renewables

I frequently make the point that 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 if New York were to successfully eliminate its GHG emissions the increases elsewhere we supplant our efforts in less than a year. 

Palmesano made the same point that New York emissions are not going to affect global warming and asked what impact the emission reduction programs are going to have.  I think that is an obvious question and it appeared that Waldorf and Williams had prepared to respond to it.

Waldorf said that there are other reasons “to build renewable energy resources in New York that are not just related to emissions.  She gave two reasons: energy security and price volatility.  Palmesano followed up early in her response questioning whether the emphasis on wind and solar was putting all our eggs in one basket provided energy security. 

Waldorf’s explanation of energy security mentioned “localizing energy production here”.  She went on to state:

The other thing I would say about energy security is price volatility.  Customers are beholden to the winds of the fossil fuel industry and the up and down markets that we see from fossil fuels.  Localizing our energy production and renewables allows us for price stability.  That is definitely a benefit of building resources here. 

With regards to energy security, my interpretation is that the Agency position believes that if we develop the wind and solar resources called for in the Scoping Plan that we will not be dependent upon other jurisdictions for our electricity.  That ignores the fact that the supply chain for the rare earth elements necessary for wind, solar, and energy storage has significant risks:

Despite their global importance, the production of rare earth elements has become increasingly concentrated in China over recent years. Not only does this present a geopolitical and economic risk to most of the developed world, but it is also indicative of possible future supply constraints which could interrupt progress toward a decarbonized future.

There is another flaw in this vision for New York electricity system independence using wind and solar – weather variability.  In my comments on the Draft Scope of the Energy Plan I argued that this is an unresolved issue that must be addressed sooner rather than later.  All solar goes away at night and wind lulls can affect all of New York and adjoining regional transmission organization (RTO) areas at the same time. Therefore, when a future electric grid relies on wind and solar those resources will correlate in time and space.  This issue is exacerbated by the fact that the wind lulls occur at the same time the highest load is expected.  I do not believe we can ever trust a wind, solar, and energy storage grid because if we depend on energy-limited resources that are a function of the weather, then a system designed to meet the worst-case is likely impractical.  For example. I believe that in the last 70 years the worst-case weather lull occurred in 1961.  I cannot imagine a business case for the deployment of enough of any Dispatchable Emissions Free Resources (DEFR) technology that will only be needed once in 63 years.  For one thing, the life expectancy of the candidate technologies is much less than 63 years

At first glance, the price volatility argument is persuasive because we have all experienced the impact of increased fuel costs in recent memory.  However, in the last two months the European electric market has shown what happens when an electric system becomes overly dependent upon wind and solar:

From November 2 to November 8 and from December 10 to December 13, Germany’s electricity supply from renewable energies collapsed as a typical winter weather situation with a lull in the wind and minimal solar irradiation led to supply shortages, high electricity imports and skyrocketing electricity prices.

The electric transmission connections to other countries raised prices elsewhere.  Prof. Fritz Vahrenholt says they went up so much in Norway that the energy minister “wants to cut the power cable to Denmark and renegotiate the electricity contracts with Germany”.  Swedish Energy Minister Ebba Busch stated: “It is difficult for an industrial economy to rely on the benevolence of the weather gods for its prosperity.” He went on to respond directly to Habeck’s green policy: “No political will is strong enough to override the laws of physics – not even Mr. Habeck’s.”

Finally, note that the DEFR technologies are proposed as backup with expected operations of under ten percent per year.  Those resources will have to be paid very high rates during those hours when needed to be economically viable.  That makes price volatility of a wind and solar electric system inevitable.

Waldorf also responded to Palmesano’s question about over-reliance on wind and solar:

The other thing I would say is we’re not putting all our eggs in one basket when it comes to generation resources.   The points that were discussed earlier and in the zero by forty proceeding, we are looking at other zero emission resources and the value that they can bring into the grid.  So, it’s not the case that we’re just looking at solar and wind.  We are looking at energy storage, at nuclear, and at other resources and how they fit into the picture.

At other times during their response to questions Waldorf and Williams touched on the need for DEFR to back up wind and solar resources during extended periods of calm winds and low solar availability.  In that context, they said the state was looking at these other resources.  They are trying to make the need for DEFR resources a feature not a flaw. 

Responsible New York agencies all agree that new DEFR technologies are needed to make a solar and wind-reliant electric energy system work reliably.  No one knows what those technologies are.  I believe the only likely viable 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. I do concede that there are financial issues that need to be resolved for nuclear, but this is an issue for any of the DEFR options. 

Waldorf and Williams ignore the following point.  If the only viable DEFR solution is nuclear, then the wind, solar, and energy storage approach they are advocating cannot be implemented without nuclear.  I estimate that 24 GW of nuclear can replace 178 GW of wind, water, battery storage.  Developing nuclear eliminates the need for a huge DEFR backup resource and massive buildout of wind turbines and solar panels sprawling over the state’s lands and water.  If I had the opportunity to ask them a question I would have asked if it would be prudent to pause renewable development until a DEFR technology is proven feasible because the choice and even the viability of any DEFR technology will affect the entire design of the future electric structure necessary to meet the Climate Act net-zero energy system.  Throwing money at renewable energy without knowing that there is a viable backup resource is the last thing we should do because New York cannot afford to invest in “false solutions”.

One last point, Waldorf and Williams did not mention the effect of global warming conceding the fact that New York emission reductions are not going to make any difference.

Conclusion

I have always wondered how state agencies would respond to the point that New York GHG emissions are smaller than the observed increase in global emissions thus making our efforts inconsequential.  The energy security and price volatility response given at this hearing was rehearsed and flawed. 

The “localized” energy security advantage for the wind, solar, and energy storage approach is easily rebutted.  Deployment of the resources is dependent upon supply chains that are anything but secure.  Because all New York wind and solar resource availability is correlated, that means we will be reliant upon resources outside of New York for support.  Finally it is hardly secure that we must develop and deploy new DEFR technologies that are not currently commercially available on an ambitious schedule.

The intermittency of wind and solar has two impacts on price volatility.  During peak demands and likely low renewable resource availability we need DEFR technologies that will likely be expensive.  Even in the absence of DEFR, European experience shows that extreme price volatility occurs during these periods.

There are so many unanswered questions and unresolved issues that the only logical next step is a pause in Climate Act implementation until we truly understand how to decarbonize our electric system without adversely affecting affordability and current reliability standards.    

Transcript of the Why Renewables Question

There is a video of the entire presentation available at the NYS Assembly website.  The question and response is in the video available in the sub-listing of questions in Assemblyman Palmesano’s second link.  The following is a transcript of the entire exchange that I captured using the Dictate application in Microsoft Word and then edited for clarity.

Palmesano Question during second round of questions at 2:05:32

New York contributes 0.4% of total global missions.  China contributes 30%, has 1000 coal plants and is building more every week.  In fact they expanded their coal generating capacity actually by 70 gigawatts, double our total generating capacity including wind, solar, hydro, nuclear, and natural gas.  What true impact are we really making with this process?  Are we just driving out more families, farmers, small businesses, and manufacturers because this only affects New York.  It doesn’t affect China, India, or Russia which is 42% of total emissions.  It doesn’t affect Pennsylvania.  What impact are we truly going to make?

Waldorf response at 2:06:11

I’ll respond to that first and say that there are other reasons to build renewable energy resources in New York that are not just related to emissions.  Some of them relate to things like energy security so localizing energy production here.  Some of them also relate to a point that one of my colleagues made earlier which is a lot of the different fuel sources that provide our energy today are …. 

Palmesano interrupted her here.

Palmesano follow up question at 2:06:32

You mentioned energy security.  I’m supportive of wind and solar and support wind and solar as part of the energy portfolio but you’re putting all your eggs in one basket of full electrification. We don’t have the technology out there for 2040.  Natural gas is used by 60% percent of New York homes for heating.  Natural gas should be a part of the portfolio just like the diversified 401K.  That’s what we should be doing with her energy portfolio if you want to stabilize prices and have energy security in New York You’re going away from that.  It’s not gonna work.  It’s not very successful.  It’s gonna be very costly.

Waldorf response at 2:07:10

The other thing I would say about energy security is price volatility.  Customers are beholden to the winds of the fossil fuel industry and the up and down markets that we see from fossil fuels.  Localizing our energy production and renewables allows us for price stability.  That is definitely a benefit of building resources here.  The other thing I would say is we’re not putting all our eggs in one basket when it comes to generation resources.   The points that were discussed earlier and in the zero by forty proceeding we are looking at other zero emission resources and the value that they can bring into the grid.  So, it’s not the case that we’re just looking at solar and wind we looking at energy storage, at nuclear, and at other resources and how they fit into the picture.

On electrification we’re certainly mindful of the breakdown of how customers get their heating and electricity services today.  In things like gas transitioning and our gas policy planning proceeding we are looking at the best way to make an equitable transition and what that looks like for the current customers that rely on those fuels today.  It is not the case that we’re asking everybody to make the switch tomorrow.  We see this as a transition that’s going to span several years, several decades in terms of meaningful returns transitioning away those customers that currently rely on natural gas to a cleaner source.  It’s not the case that it is an overnight switch.  We are really looking at the long term and trying to achieve those objectives.  

Williams response at 2:08:35

If I could just add on the long-term objectives, focusing particularly on the generation aspects.  We are in the midst of an energy plan process.   We recently launched that and we had a meeting of the planning committee last week where we brought in a representative of the North American electric reliability council and representatives from the New York independent system operator.  What we were asking them to really inform us about was how we should be approaching planning, over the next 15 years that’s our energy plan horizon.  We asked what the nature of the resources that we should be bringing in.  They responded that we must look at all the attributes that various resources can bring into the system.   The emissions aspect is one thing, but we have to understand the varying different contributions to all of the engineering that’s necessary to run a secure and reliable electricity system.  It’s not just a question of just the energy but we need to look at all of those other aspects of electricity whether it’s frequency or voltage. What are the nature of the resources that are necessary to do that.   We are going to be taking a look at that through our energy plans.

DEFR Implications on Solar Power Viability

I recently published an article summarizing a Syracuse Post Standard description of the transition problem by Tim Knauss who described the work done by Cornell’s Anderson Lab headed by Dr. Lindsay Anderson. I submitted a letter to the editor describing the implications of Anderson’s work arguing that pausing renewable energy development would be appropriate.  This post responds to the rebuttal of my letter by Peter Wirth, Vice President, Climate Change Awareness and Action who claims that pausing renewable energy is the last thing we should do.

I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act) net-zero mandates will do more harm than good if the electric system transition relies on wind, solar, and energy storage because of reliability and affordability issues.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 480 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 2030 reduction target of a 40% GHG reduction by 2030. Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantified the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation.  New York Department of Public Service (DPS) Proceeding 15-E-0302 addresses DEFR but there is no schedule for resolving the future plans for DEFR in New York.

My primary reliability concern is the challenge of providing electric energy during periods of extended low wind and solar resource availability.  Experts, including those that are responsible for electric system reliability, agree that a new category of generating resources called Dispatchable Emissions-Free Resources (DEFR) is necessary during those periods.  I have dedicated a page to DEFR which I described in an article that summarized six analyses describing the need for DEFR: the Integration Analysis, New York Department of Public Service (DPS) Proceeding 15-E-0302 Technical Conference, NYISO Resource Outlook, Richard Ellenbogen, Cornell Biology and Environmental Engineering Anderson Lab, and Nuclear New York. 

My Letter to the Editor

On the same day that the Syracuse Post Standard published the Knauss article they published the following letter to the Editor:

The Tim Knauss article on Cornell Professor Anderson’s evaluation of the future New York electric grid is a readable summary of the issues associated with the need for a new dispatchable emissions-free resource (DEFR). 

However, it does not address the implications on current NY energy policy.

The Hochul Administration has finally started its update of the NY Energy Plan.  The draft scope of the plan describes an electric system that relies on wind and solar generation.  No jurisdiction anywhere has successfully developed such a system.  The State agencies responsible for a reliable electric system agree with Professor Anderson that a wind, solar, and energy storage system requires DEFR.  It is prudent to fund a demonstration project to prove that such an electric system will work or, at the very least, complete a comprehensive renewable feasibility analysis to determine whether such a system will maintain affordability and reliability standards.

The most likely DEFR backup technology is nuclear generation because it is the only candidate resource that is technologically ready.  Nuclear power has a proven record for resilient electric production, development would not require changes to the rest of the electric system, it is not limited by weather extremes, it has lower environmental impacts, and when life cycle costs are considered is likely cheaper.   Its use as backbone energy would eliminate the need for wind, solar, energy storage, and new DEFR deployment to meet Climate Act mandates.  Renewable development should be paused until proven feasible because it is likely a dead-end approach.

Rebuttal to My Letter

Two weeks later the Syracuse Post Standard published a rebuttal to my letter by Peter Wirth entitled “Pausing cheap, renewable energy is the last thing NY should do”

Roger Caiazza’s letter, “NY must not rely on wind, solar to meet its energy needs” (Nov. 20, 2024), might make sense if it were written in 1954, when Bell Labs announced the invention of the first silicon solar cell.

Today, solar power is the least expensive form of energy, growing in leaps and bounds and the technology improving year by year.

In 1954, the cell developed by Bell Labs was about 6% efficient at converting sunlight into electricity. Today’s solar cells convert 20% to 22% of sunlight into electricity. Advanced research panels have reached as high as 30% efficiency. Every year the rate of efficiency improves.

Solar energy per kilowatt is cheaper than coal, which is less expensive than gas. Nuclear energy is, by far, the most expensive. In 2019, it was reported that New York utility customers subsidized nuclear reactors in Upstate NY to the tune of $540 million.

Given that solar energy is the least expensive, we should not be surprised that solar power has seen massive growth in the U.S. Between 2000 and 2022, solar capacity increased by an average of 37% per year, doubling every 2.2 years. As of the end of 2023, the United States had nearly 210 gigawatts (GW) of solar capacity installed, enough to power 36 million homes.

Solar energy is the energy of the future!

The study by Cornell Professor Lindsay Anderson does raise valid, serious questions. The grid needs to be upgraded. Storage capacity needs to be increased. Can we bring enough renewable energy on line quick enough? What is the role of nuclear energy in the short run? This is a complex problem with many moving parts.

However, to pause renewable energy — which has a track record of being the least expensive, becoming more efficient every year and emitting no greenhouse gases, the cause of climate change — is the last thing we want to do.

My Response

There are two problems with Wirth’s response.  If the consumer cost for delivered energy is considered, then solar is not the “least expensive”.  Secondly, Wirth did not acknowledge that until the feasibility of DEFR technology is resolved solar and wind resources may not be viable.

First, I will address the Wirth claim that the “solar energy per kilowatt is cheaper” than coal or natural gas which are both cheaper than nuclear.  I agree that is true.  For example, in this Energy Information Agency analysis the total overnight cost (2022$/kW) states that nuclear is 5.8 times more expensive than solar.  However, I think most consumers care about the cost of getting electric energy delivered to their homes on a kilowatt-hour basis which is what we pay for.  When that metric is used solar is not cheaper than nuclear

For starters in 2023 the New York Independent System Operator reported in the  2024 Load & Capacity Data Report that the energy produced by all the New York utility-scale solar facilities relative to the maximum they could have produced was only 16.6% whereas the nuclear facilities generated 92.5% (Table 1).  Using the two years of data available it is reasonable to say that the ratio between nuclear capacity and solar capacity is around five.  That means to get the same kilowatt-hour production you need five times as much capacity. 

Table 1: Comparison of New York Nuclear and Solar Capacity Factors

Wind and solar resources are intermittent, and energy storage must be included to address that.  Nuclear units operate at full load for months at a time.  Solar only works during daylight.  The cost of energy storage for diurnal variations and seasonal variations must be included in the costs to deliver energy to our homes.  The implication of the study by Cornell Professor Lindsay Anderson is that DEFR is also needed beyond the short-term energy storage capacity. 

Consider the Scoping Plan projected capacity of different resources shown in Table 2.  In 2040 the Climate Act mandates that all electricity generated be 100% “zero emissions”.  The Scoping Plan projects that 40,860 MW of solar capacity and 26,580 MW of wind from various sources will be required.  To back that up an additional 15,388 MW of battery storage and 17,868 MW of zero-carbon firm resource, aka DEFR, are needed.  The cost of the solar share of the backup sources need to be considered for a “apples to apples” comparison of the cost of solar relative to nuclear.

Table 2: Scoping Plan Mitigation Scenario Summary Fuel Mix (Capacity)

But wait there is more.  The life expectancy of solar panels is on the order of 25 years whereas nuclear is at least 50 years.  Solar facilities are spread out and require transmission development. There are additional ancillary support services provided by nuclear that are not provided by solar so there are additional costs there as well.

To sum up, the solar capacity needed to produce the same capacity as nuclear is five times larger.  It is reasonable to assume that the short-term energy storage costs needed for solar and the DEFR requirement will another doubling of capacity costs.  Solar lasts half as long as nuclear so over the long-term, so there is another doubling of capacity costs.  I have no idea what the costs to provide ancillary support services would be or how much the additional transmission development would cost so I won’t include them in the total.  Overall, the long-term cost of solar power is roughly 15 times as much as nuclear power.  Even if solar energy per kilowatt is six times less than nuclear power, the delivered cost over the long term is 2.5 times higher than nuclear.

It is more disappointing that Wirth missed the point I tried to make about the implications of DEFR feasibility on the viability of solar.  Assuming that the reason was my poor description, let me try another way to explain that DEFR is a necessary requirement for renewables deployment as envisioned by the Climate Act.

Anderson and responsible agencies all agree that new DEFR technologies are needed to make a solar and wind-reliant electric energy system work reliably.  No one knows what those technologies are.  I believe the only likely viable 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. I do concede that there are commercial issues that need to be resolved. 

Here is the key point, if the only viable DEFR solution is nuclear, then the wind, solar, and energy storage approach favored by Wirth cannot be implemented without nuclear.  I estimate that 24 GW of nuclear can replace 178 GW of wind, water, battery storage, and DEFR which eliminates the need for a huge DEFR backup resource and even more massive buildout of wind turbines and solar panels sprawling over the state’s lands and water.  I suggested that it be prudent to pause renewable development until a DEFR technology is proven feasible because the choice and even the viability of any DEFR technology will affect the entire design of the future electric structure necessary to meet the Climate Act net-zero energy system.  Throwing money at renewable energy is the last thing we should do because New York cannot afford to invest in “false solutions”.

Conclusion

Over the years I have had many conversations with people who understand the electric system.  Universally they all agree that the wind, solar, battery storage, and DEFR electric system will never work.  Most also agree that the momentum of the political mandates for this approach will only be checked when there is a catastrophic blackout caused by over-reliance on renewable resources.  I have no doubt that advocates like Wirth will argue that such a blackout was caused by industry not transitioning to renewables correctly despite evidence to the contrary. 

In a recent meeting, someone from the New York State Energy Research & Development Authority suggested that there would be a five-year plan to address DEFR technologies.  In a rational world, the fact that New York is proceeding to implement a “zero emissions” electric system by 2040 that requires a new technology to be developed, tested, and deployed in that time frame would concern the Hochul Administration enough to pause implementation until a DEFR technology is proven feasible in the suggested five year plan.  The fact is that without such technology the renewables approach cannot work, and  if nuclear power is determined to be the only viable DEFR technology, then renewable investments are not needed.

Keith Schue: New York Needs Nuclear

Keith Schue alerted me to his piece for the Empire Report titled New York Needs Nuclear, a Balanced Approach to Clean Energy.  I am always happy to publish pragmatic discussions of New York energy policy so I am re-publishing his article in this post.

Keith Schue is an electrical engineer and technical adviser on energy policy. Schue has been engaged in New York energy policy since 2010 and currently volunteers as a technical advisor for several organizations, including New York Energy & Climate Advocates. Before moving to New York, he was employed with the Florida chapter of The Nature Conservancy.  He recently co-authored a commentary in the Albany Times Union with climate scientist James Hansen, making a persuasive case for using nuclear in the future. 

Overview

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

I recently published Schue’s summary of draft documents that covered three of these implementation initiatives.  In this article he references the New York Power Authority (NYPA) Draft Renewables Plan.  He noted that the Build Public Renewables Act adopted last year now forces NYPA to try installing solar, wind, and batteries even faster than the private sector is already doing with subsidies.  He suggested that comments on the NYPA renewables plan should say:

Achieving carbon-free electricity requires firm reliable power. Therefore, throwing more public money and resources at intermittent generation not only jeopardizes reliability and affordability, but also ensures that NY will remain dependent on fossil fuels. Instead of focusing on solar panels and wind turbines that the private sector can install on its own, NYPA should do what it has historically done best by working on reliable public projects for the common good, like nuclear energy, hydropower, and utility infrastructure.

In the following section I present Schue’s article that first appeared in Empire Report in its entirety.

New York Needs Nuclear, a Balanced Approach to Clean Energy

Global warming is real, as is the urgency for action to address it. However, New York will only make good on its promise of tackling the climate crisis if it pursues solutions that work in the real world.

Unfortunately, the strategic plan recently drafted by the New York Power Authority (NYPA) falls short of what’s needed—not because it fails to install enough solar panels, wind turbines and batteries, but because that is all it proposes to do.

For decades, NYPA has spearheaded vital energy projects that serve the public good. From the construction of large hydroelectric plants to positioning New York as a leader in nuclear power, the authority has consistently delivered electricity that is reliable, clean, and affordable to communities and business upstate. Indeed, NYPA is the reason why New Yorks’ upstate grid is already 90% carbon-free.

Yet, instead of building upon that impressive legacy, the plan currently proposed threatens grid stability by marginalizing firm resources and focusing on those that are fragile, intermittent, and incredibly land-intensive. It is an approach that jeopardizes greenhouse gas reduction, perpetuating dependence on fossil fuels while making electricity less reliable and more expensive.

It is also an approach that reflects outdated politics of the past.

Today, there is overwhelming consensus among engineers, industry leaders, the business community, and labor unions that a diverse mix of resources—including advanced nuclear power—will be essential to decarbonize while providing ample energy for a growing economy and workforce. Even Governor Hochul emphasized this reality at her recent Future Energy Economy Summit in Syracuse. Micron’s semiconductor manufacturing operations alone are expected to surpass the electricity demand of Vermont and New Hampshire combined. However, in addition to accommodating unprecedented growth, a zero-emission grid must be robust. Dispatchable Emission-Free Resources (DEFRs) capable of serving demand when renewables cannot are essential.  Moreover, DEFRs that operate a lot more than 2% of the time will be needed in the real world to avoid retaining large amounts of fossil fuel capacity. Batteries and hydrogen simply won’t suffice.

Rather than focusing on sprawling intermittent sources that cannot go the distance, the state should pursue compact solutions that will. NYPA should leverage its technical and financial expertise to support the Governor’s vision of integrating flexible advanced nuclear into New York’s grid. There are communities eager to embrace it. Where possible, responsible hydropower expansion can also be explored, like collaborating with the Green Island Power Authority to increase generation capacity on the Hudson River. Infrastructure improvements should be pursued as well, but in a manner that respects communities.

One thing is certain: New York’s energy strategy must change. Communities are under attack from the Office of Renewable Energy Siting, businesses are questioning whether they can survive in the state, industry is asking whether there will be energy to expand, and skilled labor is wondering if the only jobs left for them will be unpacking solar panels from China.

A successful strategy will require compromise. With a balanced expansion of solar, wind, and firm nuclear power, the state can meet its energy goals. However, NYPA’s leadership in needed more than ever to forge pragmatic solutions that work. The future of New York hinges on its ability to adapt and champion a diverse, reliable, and sustainable energy portfolio. NYPA should be a guiding force in that critical transition.

Commentary

I was happy to re-publish Keith’s article because I agree with him that nuclear power is necessary and that NYPA should be considering it along with solar and wind in the Draft Renewables Plan.  I have one minor point of emphasis difference because I think balanced expansion with wind and solar development is a dead end.  I have come to the conclusion that reliance on those resources will do more harm than good because of reliability and affordability risks.  Importantly, consider that the State agencies responsible for a reliable energy system agree that a wind, solar, and energy storage system needs a new dispatchable emissions free resource (DEFR) to account for low resource availability during periods of extended light wind and cloudiness.  At some point, New York must do a feasibility analysis to determine which DEFR technologies should be used in New York.  I believe that analysis will find that the only viable candidate for DEFR is nuclear power.  That means that a wind and solar energy system must include nuclear power as the DEFR backup technology.  However, economics suggest nuclear resources should be used as much as possible instead of as a backup. Using nuclear as the backbone of the electric system eliminates the need for the massive wind, solar and energy development proposed and addresses my concerns about reliability and affordability.

September New York Dunkelflaute or Wind Lull

I have been meaning to write this article for several months.  In September Parker Gallant noted that industrial wind turbines (IWT) in Ontario “show up at the party, almost always, after everyone has left” in a post that described poor performance of the province’s wind turbines over a five day period in September.  I looked at New York data, found that wind data was also poor in the state at the same time, and planned to do a post.  Other issues came up but a recent Dunkelflaute wind lull in Germany has spurred me to complete the post.  Better late than never, here it is. 

I have followed the Climate Leadership & Community Protection Act (Climate Act) since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 470 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 2030 reduction target of a 40% GHG reduction by 2030. Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantified the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation.  Unfortunately implementation efforts to date have short-changed addressing issues that have been identified.

Dunkelflaute

The German description of a wind and solar resource lull is Dunkelflaute.  Iowa Climate Science Education explains that the term refers to “dark doldrums”.  A large high pressure system has recently affected wind and solar resources in Europe.  Daniel Wetzel notes that:

At 5 p.m. on Wednesday, solar power was only supplying a single megawatt hour. The 1602 offshore wind turbines in the North and Baltic Seas – each one the size of the Eiffel Tower – were at a complete standstill. Zero electricity production.

Earlier in the week the British electric system faced a similar situation.

Ontario Dunkelflaute

Parker Gallant’s article provided a great example:

Looking at the following IESO Power data chart from September 13th to late in the day on September 18th it is evident Ontario Demand (solid green line) clearly demonstrates the daily swings in Ontario demand during those “summery” days. It is evident, demand fluctuates by almost 6,000 MW from the middle of the night to later in the day!  Those swings in demand are even higher when you examine the data in respect to “market demand” (blue line) which reflects our imports and exports via our intertie connections with our neighbours.

From the top of the chart:  the tiny “red” represents biofuel generation and “yellow” represents generation supplied by solar panels. The “green” tells us what those industrial wind turbines are generating hourly! The “dark blue” is generation from our natural gas plants and the “light blue” is power being supplied by our hydro generation stations some of which are classified as “baseload”! The solid unwavering “orange” represents what our baseload nuclear plants provide us with!

He describes the charts:

Looking at the six days illustrated, the highest peak demand occurred September 16th reaching 21,547 MW at Hour 17 (hour ending at 5 PM) and the lowest peak demand was September 14th reaching 19,288 MW at Hour 17! Interestingly Hour 17 was the peak hour on all six days.

As the Supply chart clearly demonstrates those natural gas plants (dark blue) fluctuated widely as needed to ensure we were able to avoid blackouts each and every day by either ramping up or ramping down as required! Hydro generation also played a role by also modestly, ramping up or down in addition to supplying some of the baseload.

Gallant went on to describe how the IWT performed:

Well, the high for generation by those IWT occurred at Hour 24 (ending at midnight) September 14th when they generated 2,199 MWh or 44.8% of their capacity and the low generation occurred at Hour 11 on September 13th when they only managed to generate 22 MWh or 0.5% of their capacity. Interestingly at Hour 24 on September 14th IESO reported our net-exports were 2,956 MWh at the low price of $24.07/MWh so we apparently didn’t need that power and were forced to sell it off for a cheap price! Also IWT over the six days hit their peak generation at Hours 23, 24 or Hour 1 when peak demand is always near its lowest for each and every day! Coincidently their low generation over the same  6 days occurred at either Hours 10 or 11 when demand is accelerating!

New York Wind Data

I attempted to access the Ontario IESO generation data for the period but could not find it.  On the other hand, the New York Independent System Operator (NYISO) provides access to their data.  New York fuel-mix load available at the NYISO Real-Time Dashboard where there is a link to historical data.

The Real-Time Fuel Mix panel includes links to current and historical five-minute generation (MW) for energy generated in New York State.  I processed that data to calculate hourly averages.  The generator types include “Hydro” that includes pumped storage hydro; “Wind”, mostly land-based wind but does include 136 MW of offshore wind; “Other Renewables” that covers solar energy (394 MW of “front-of-the-meter solar”), energy storage resources (63 MW), methane, refuse, or wood; “Other Fossil Fuels” is oil; “Nuclear”; “Natural Gas”; and “Dual Fuel” which are units that burn both natural gas and oil. As an aside, oil capability is maintained as a reliability measure.

The following graph shows the hourly fuel type generation throughout the period.  Note that there are similarities with the Ontario data.  New York does not have as much nuclear, but both control areas use it as solid, unwavering baseload power. New York hydro has more diurnal variation because there are pumped storage hydro facilities used for load following.  In both control areas natural gas is relied on to provide power when needed.  New York has dual-fuel units that probably burned natural gas during this period.

The focus of this article is the Dunkelflaute, so the wind data are of most interest.  The following figure lists the wind data only.  Because I could not combine data sets, we can only consider a qualitative comparison between New York and Ontario.  The wind output is the similar – low when needed most and picking up when demand drops.

Because I have access to the actual data, I can summarize just how bad the wind was over this 192-hour period.  New York has 2,454 MW of wind capacity.  The maximum wind capacity occurred on 19 September at hour 21 when 502 MW of wind power was generated, an unimpressive 20.5% of the total capacity.  The minimum wind capacity occurred on 13 September at hour 12 when 0.2 MW of wind power was generated.  I summarized the hourly totals by category in Table 1.  There were 96 hours representing half the period when the capacity of all the wind generation in New York was less than 5%.  All but one of the hours had a capacity factor of less than 20%.

Table 1: Categorial Hourly Totals for New York State Wind Power from 12 September 2024 hour 0000 to 19 September 2024 hour 2300

The NYISO Operations Report for September 2024 Wind Performance Figure shows daily wind production over the entire month.  Those data show that the daily capacity factor was less than 10% from 9/10/24 to 9/20/24. 

Discussion

In my opinion, climate scientists tend to over-emphasize potential global warming drivers when explaining weather observations.  For example, I saw a news segment where a climate scientist claimed that warmer temperatures associated with global warming increased the rainfall associated with Hurricane Helene in western North Carolina by 15 to 20% exacerbating the flooding.  Baloney, I say.  The supposed rationale is that warmer weather increases the amount of moisture that the atmosphere can hold and climate change models are used provide numbers for these attribution statements.  I addressed the Helene hype claims earlier.  Given that there was a storm in 1916 that produced higher flood levels I don’t think that moisture content was the primary driver for the flood.  Instead, I believe that an unusual weather pattern caused the storm to stall over the region.  Even if there was some greater water capacity effect, it was small relative to the weather pattern impact.

My whole diatribe was a lead-in to make a point about weather patterns and the observed data in September 2024.  Light winds over 11 days are only possible if there is a large, slow-moving high-pressure system.  I have never seen any observational analyses claiming that they are trends in this kind of weather pattern.

More importantly, there are implications of these observations relative to the Climate Act transition to an electric system that relies on wind, solar, and energy storage capacity.  The fact that all of the New York wind generation only produced 0.2 MW during one hour must mean that the stagnant high pressure system was at least as big as New York including the offshore wind facility south of Long Island. It is hard to conclusively pick out the Ontario wind generation during the worst hour but it appears that there is very little wind generation at that time.  I maintain that to fully understand the geographical implications that a detailed analysis of meteorological data and expected wind and solar generation for New York and all the adjoining electric system control areas is necessary.  Lastly, I believe that the weather pattern that caused this wind lull could occur at any time of the year.  It may be more likely during certain times of the year but there is no reason that similar conditions could occur anytime.  This exacerbates the problem because the high-pressure systems that cause light winds often are accompanied by the most extreme temperatures which are when the observed peak loads occur.

My primary reliability concern is the challenge of providing electric energy during these periods of extended low wind and solar resource availability.  This period perfectly exemplifies this kind of extended wind lull period.  To address this problem the organizations responsible for New York State electric system reliability agree that a new Dispatchable Emissions-Free Resource (DEFR) is need as described here.  In addition to the geographical considerations noted above, planning for must evaluate as long a period as possible.  That work must consider when wind and solar can charge energy storage capacity and when short-term energy storage must be discharged to meet system requirements.  The challenge of that analysis is obvious when looking at these wind output graphs.

Conclusion

The Dunkelflaute wind lull phenomenon occurs worldwide.  The comparison of Ontario and New York data shows that these conditions can cover both jurisdictions.  The New York data show the severity of the wind lull.  It is essential that electric system planners consider the impacts of the Dunkelflaute.  I believe that New York is addressing this issue.  However, I will only feel comfortable that they have considered the worst-case situation when they assess a longer period of data covering adjacent electric system control areas.

Unfortunately, clean energy advocates continue to dismiss the extent of the problem.  Even worse, some do not acknowledge that wind, solar, and energy storage cannot be relied on during those periods and that when the power is needed the most it is most likely to be in a resource lull.  These advocates are simply wrong and should be ignored.

NYCP – Get Charged Up for the New York State Energy Plan

On September 9, 2024 the Hochul Administration initiated the development of the State Energy Plan announcing the release of a draft scope of the plan.  On November 15 New Yorkers for Clean Power (NYCP) sponsored a related webinar titled “Get Charged Up for the New York Energy Plan”.  My first post on this webinar described the response to my question does New York need a Climate Act feasibility analysis. This post addresses the presentation of one of the speakers.

I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act) net-zero mandates will do more harm than good if the electric system transition 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 470 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.

Takeaway Message – If you don’t have ~15 minutes to read the whole thing

This article describes the presentation by Janet Joseph who was deeply involved in the development of the Scoping Plan.  She noted that issues associated with reliability and affordability are real problems that the advocacy community must address. The insurmountable problem with that is reality bats last. 

Her presentation and the others in the webinar did not provide solid support for the listeners to address the reliability and affordability problems. In my previous post about this webinar I documented that the claim by Dr. Robert Howarth that no new technology is necessary is contradicted by the agencies and organization responsible for electric system reliability.  Janet Joseph’s presentation disparaged those professionals so I expect that will be the essence of advocate comments.   Her presentation also argued that the energy plan should align with the Scoping Plan ignoring the fact that there hasn’t been a response to critical comments on that document.  Worse, the Hochul Administration has never proven that the list of strategies in the Scoping Plan are feasible. 

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

Although related, the Energy Plan should not be confused with the Scoping Plan.  Every several years the New York Energy Planning Board is required to update its overall energy plan for the state. The process begins with an initial document that identifies a “scope” of work–meaning the set of things to be evaluated in the plan with a defined planning horizon of 2040. This makes the Climate Act’s 2040 goal of carbon-free electricity particularly relevant. That plan is to rely on wind, solar, and energy storage.  In my opinion, the Energy Plan must prove this will work.

Key Takeaways from the Event

The description of the New Yorkers for Clean Power sponsored a webinar titled “Get Charged Up for the New York Energy Plan” stated:

on November 15th. We are electrified by the demonstrated interest and information shared to support New York’s climate goals through the development of an ambitious and equitable State Energy Plan. To recap, our featured speakers were:

  • Janet Joseph, Principal, JLJ Sustainability Solutions (Former VP of Strategy and Market Development, NYSERDA
  • Dr. Robert Howarth, Member, New York’s Climate Action Council, and David R. Atkinson Professor of Ecology and Environmental Biology at Cornell University
  • Christopher Casey, Utility Regulatory Director for New York Climate and Energy, Natural Resources Defense Council (NRDC)

We’re excited to share the recording and slideshow from the event: Here is the recording of the event and check out the Presenters’ slides here.

Key Takeaways from the Event

  • Energy Plan is foundational to achieving New York’s climate and energy goals, aligning policies with the CLCPA.
  • Engagement from advocates, community members and developers is critical for ensuring equitable and actionable outcomes.
  • Challenges like building decarbonization and system reliability require innovative solutions and statutory changes.

This post addresses the presentations of Janet Joseph with respect to my concern that transitioning the New York electric grid to one that relies primarily on wind, solar, and energy storage will adversely affect reliability and affordability. 

Janet Joseph Presentation

The introduction for Janet Joseph notes that before her present gig with her own consulting firm she worked at the New York State Energy Research & Development Authority (NYSERDA).  In that role she was involved in the development of the Scoping Plan and earlier iterations of the Energy Plan.  Her

presentation noted that now that she is on her own, she can say what she “really thinks” about the transition dictated by the Climate Act.

One of my issues with New York’s unilateral net-zero transition is that we are such a small player in this global problem that whatever we do really cannot make a difference.  Joseph argued the opposing view that New York’s climate agenda is important.  She believes that New York needs to lead the way showing other jurisdictions how decarbonization can be accomplished.  “Mother nature’s accounting system is the only one that matters means we have to push for things that can be replicated in other regions”.  She did note that political accounting means we must push for policies that provide real co-benefits.  There were many things stated during the webinar that I take exception to, and this is one of them.  The calculation of co-benefits is largely a values judgement exercise that the Scoping Plan has biased by over-estimating benefits and ignoring disbenefits.  I could go on, but this is a minor issue relative to the Energy Plan.

Joseph explained the differences between the Energy Plan and Scoping Plan.  Her description of the Energy Plan concerns me.  She stated that the energy plan is the original place where NY’s “progressive energy policies and practices originated” due to the energy crisis of the 1970’s.  In my opinion one of the major tenets of progressivism is the preference for equity over equality which I believe adds unnecessary risks to electric system planning.  Note that the NYCP takeaways include the desire for “equitable and actionable outcomes”.  Joseph also said that the Energy Plan is “the vehicle used to push many progressive policies in New York”.    Equity “recognizes that each person has different circumstances and allocates the exact resources and opportunities needed to reach an equal outcome”.  On the other hand, “equality means each individual or group of people is given the same resources or opportunities”.   Translating that difference into electric system planning is a distraction for safe and adequate power for everyone.

Jospeh’s presentation notes that policies like renewable portfolio standards, energy efficiency, solar and storage issues all came from the energy plan.  I am disappointed by her remarks related to renewable energy.  She stated that “In the 1990’s, get this, we were debating 300 MW of renewable energy” because the opposition at the time said, “it would bring the system down”.  She concluded “Same arguments and same barriers in different decades” insinuating the proposed transition is simple.  In the first place, the scale of the renewable development is different – in 2030 wind and solar is expected to be over 100 times greater than 300 MW.  I think it is irresponsible to demonize the people who are responsible for keeping the lights on by anyone who will suffer no consequences by being wrong.  The biggest issue is that we are now debating whether the existing electric system of New York can be converted to one that relies on renewables even though no jurisdiction anywhere has successfully done so.  Disparaging New York’s electric experts gives the advocates who listened to the presentation false security and hope.

Joseph noted that while we have a comprehensive climate plan, we still must do the energy plan.  This is another point of disagreement.  In my opinion, the Scoping Plan is not comprehensive, it is just an outline of strategies that the Integration Analysis claims will comply with the Climate Act mandates. There has never been any responses to critiques raised during the Scoping Plan comment process but, more egregious from my perspective, there has never been a feasibility analysis. 

In the presentation she said that there were five things advocates should be looking  to be included in the Energy Plan but in her presentation she only described four things.

She said that the first aspect that needs to be included in the Energy Plan is alignment between the scoping plan and the energy plan.  Joseph argued that confusion and conflict between the two documents would cause delays, and we do not have time for that.  She wants “at a minimum, high level alignment, and ideally all the way down to perfect synergy of these documents”. In my opinion, the presumption made by the presenters that the Scoping Plan is feasible is simply crossing our fingers and hoping.  I raised many issues in my Draft Scoping Plan comments that were not addressed by the Climate Action Council and remain unresolved to this day.  Therefore, the Energy Plan offers the opportunity to correct the oversights and errors in the Scoping Plan.  It is inappropriate to assume alignment of the documents is appropriate.  We need to determine feasibility.

The second aspect raised was that the Energy Plan is a medium range plan from 2025 to 2040.  Her presentation urged the advocates to not debate how we will achieve the last 20%.  Joseph said that her experience has led her to believe we should focus on what we need to do to achieve the next 20% of reductions.  I disagree with this concept because it is likely that when the technologies for dispatchable emissions-free resources are selected nuclear power will be the best choice.  If that is the case, then renewables are not needed, making the current approach a costly dead end.

The third item she mentioned was that the Energy Plan has its roots in system reliability.  She said opponents to the renewables approach will be harping on reliability and affordability.  She admitted that those issues are real and that they will resonate politically.  Then she said that “the advocacy community must be armed to fight that battle and address the impact on reliability and affordability as best you can.”  She went on “System reliability issues will be the primary lenses through which recommendations will be filtered.”  Then she gave an example where the Urban Green Council partnered with a utility and a “credible analytical entity” to determine where reliability issues would not be an issue for New York City residential building electrification.  This is a common advocacy approach where “results for hire” consultants develop an analysis that supports the pre-conceived conclusions of funding organizations.  In my previous post on this webinar I documented that a similar targeted analysis that runs contrary to the findings of all the agencies of responsible for New York electric system reliability is being used to support renewable development.  In my opinion, the only way to refute concerns about reliability issues associated with renewables is to cherry pick analyses and ignore reality.

The fourth aspect energy plan she made is particularly concerning.  She said that (my transcript):

We have to evolve and expand from a narrow technocratic focus on the engineering requirements that keep the fuel flowing and the lights on to one that considers how our system, our infrastructure, and our practices need to change to increase the resiliency of human beings to survive within the new energy system dynamics and new climate extremes.

This aspirational baloney is difficult to interpret.  The interpretation and weighting of the proposed energy plan effects on “new energy system dynamics” and “new climate extremes” makes all the difference in the interpretation of her comments.  When advocates ignore the difference between weather and climate to ascribe every extreme weather event to climate change then the concept that everything needs to change to deal with the supposed existential threat is necessary.  She could be arguing that the Energy Plan must address this effect.  On the other hand, the reference to “new energy system dynamics” could be a tacit acknowledgement that relying on weather-dependent resources is an inherently less reliable approach.  I believe that relying on weather-dependent resources will inevitably mean that someday electricity will not be available when needed most.  She goes but does not clarify this distinction in my opinion:

“In short we need more focus not on just system reliability in this energy plan but resiliency.  We cannot be afraid to talk about what happens when the lights go out and how people remain safe in that event.  We will have storms, we will have downed power lines, and the lights will go out.  We need to think through this.  It is not just a New York issue.  This is a certainly a global issue.  We will have extreme weather that will affect the totality of our infrastructure. 

This is bigger than an emergency preparedness plan.  Our future energy and related infrastructure policies and practices need to be shaped with these considerations in mind.  Here too, I sat in too many conversations over the years where people are debating – That shouldn’t be in an energy plan – it should be in an adaptation plan.  “That’s not a climate plan – it should be in a resiliency plan”.  It doesn’t matter where it is folks.  We have to start thinking through the weather extremes that we will be faced with, this rapidly changing energy system and how it affects people.  We need more focus on resiliency. 

She then threw out some ideas to “make it real”.  She suggested both heating and cooling capabilities should be mandated for landlords in our future climate.  She recommended more “community resiliency facilities with backup power”.  She also suggested that home designs should include “climate-safe zones” and maybe “requirements for solar and storage on every new home and subsidies for those who can’t afford it”.  She recommended weatherization to increase passive survivability in the event of a power outage.    She admitted that we have “GW of solar that is “not going to help us from a resiliency standpoint” and concluded that we need to determine what to do to improve upon this.

She concluded that:

I think that we have made tremendous progress in New York State in the Climate Scoping Plan developing really comprehensive GHG mitigation strategies.  I am proud to have participated in that activity.  But I don’t think we really have moved the needle on policies and practices that would develop a more resilient system at the central community and local level.  Just to be clear

I am not in the camp of those people who think every change we are making to reduce GHG emissions and increase renewables is going to take the system down.  I am in the camp that we have to think through this and make sure we are building in resiliency all the way down to the local level.  So I am hopeful that this energy plan will pick up on those hard resiliency discussions in a very meaningful and substantive way.  These are hard conversations but we have to start having them. 

The interpretation of which factors affecting resiliency she is concerned about is important.  She has enough experience and background to know that the new energy system dynamics have real risks.  I have no doubt that she sincerely believes that “new climate extremes” is a real thing.  If she believe that the primary resiliency driver is more extreme weather, her suggestions boil down to whether the emphasis should be on mitigation or adaptation.  On the other hand, she could be admitting that the new energy system dynamics are a real concern that could be addressed by accepting less reliability and just dealing with blackouts better.  That is not outside the realm of possibility because I have read climate advocates who have argued that it is appropriate.  However, that response is antithetical to New York electric resource planning doctrine and I think most electric users in the state would not accept more frequent and longer blackouts as an acceptable risk for reducing GHG emissions.

Conclusion

It was interesting that Janet Joseph recognized that reliability and affordability are real.  Then she said that “the advocacy community must be armed to fight that battle and address the impact on reliability and affordability as best you can.”  The insurmountable problem with that is reality bats last.  I have three related concerns about presentations at this webinar.

The presentations gives Climate Act proponents false confidence that the proposed transition to an electric system that relies on wind, solar, and energy storage has few risks.  In my previous post about this webinar I documented that the claim by Dr. Robert Howarth that no new technology is necessary is contradicted by the agencies and organization responsible for electric system reliability.  Janet Joseph’s presentation disparaged those professionals inappropriately in my opinion.

Joseph’s remarks also argued that the upcoming Energy Plan must align with the Climate Act’s Scoping Plan.  I do not think that the Scoping Plan proved that its proposed strategies would maintain system reliability standards or that it would be affordable.  In her leadership role on the Energy Efficiency and Housing Advisory Panel she never responded to related comments and questions on the Draft Scoping Plan.  That lack of acknowledgement of criticism was true of all the critical comments made.  As a result, I think the Scoping Plan is flawed and must not be used as the template for the Energy Plan.

Finally, I disagree with the Joseph’s support for progressive equity concepts relative to the electric system.  That approach would require treating the availability and affordability of electricity differently to certain constituencies.  That is anathema to me because I think there will be serious unintended consequences.

My Comments on the NYPA Draft Strategic Renewables Plan

The 2023-24 Enacted State Budget authorized and directed the New York Power Authority (NYPA) to advance renewable energy and support other state priorities.  Last month NYPA published its Draft Renewables Strategic Plan (Dreft Plan) which describes how NYPA will “operationalize our renewables work, along with our continued and critical obligations to our existing generation, transmission, customer, and community commitments.”  This article describes my comments on the Draft Plan.  I encourage New Yorkers to also submit comments.

I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act) net-zero mandates will do more harm than good if the electric system transition relies on wind, solar, and energy storage.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 480 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 2030 reduction target of a 40% GHG reduction by 2030. Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantified the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation.  The Build Public Renewables Act (BPRA) is an legislation example.

Draft Renewables Strategic Plan

The Executive Summary states:

The Power Authority of the State of New York (“NYPA” or the “Power Authority”) is pleased to publish for public comment and hearings its inaugural draft Strategic Plan for developing new renewable energy generation projects to supply New Yorkers with affordable, reliable, and emissions-free electricity.

The main point in my comments is that there is no evidence that renewable energy generation projects can provide affordable and reliable electricity so that presumption must be addressed first.

The 2023-24 Enacted State Budget authorized and directed the Power Authority to engage in the largest expansion of our responsibilities in decades to advance renewable energy and support other state priorities. This expanded authority will enable NYPA to accelerate the development of renewable energy, support workforce training for jobs in the renewable energy sector, and to establish the Renewable Energy Access and Community Help (REACH) program to provide bill credits for low- and moderate-income ratepayers in disadvantaged communities served by New York’s investor-owned utilities.

The Climate Act is a Progressive “Green New Deal”.   Addressing climate change is just a front to achieve other social aims like job creation, economic growth, and environmental justice.

In the time since Governor Kathy Hochul signed the State Budget into law on May 3, 2023, NYPA has made major progress toward the development of new renewables. This progress includes establishing the business structures, filling key personnel roles, and garnering other necessary resources to carry out our new missions, all while advancing the first tranche of projects.

Like any bureaucracy, NYPA’s primary business goal is to get bigger, and this is a golden opportunity for growth.  However, when the costs to comply with the Climate Act goals are totaled, I guarantee that the bureaucratic expenses for these resources will never be included. 

With the opportunity to become a leader in responsible development of new renewables, NYPA aims to expeditiously build affordable projects, staying grounded in our commitment to the communities in which we operate now and, in the future, all while ensuring fair and family-sustaining worker wages.

One of the worst outcomes of the Climate Act implementation has been the destruction of “home rule” whereby local governments have “the ability to craft ordinances and make decisions based on local needs, rather than having to follow a one-size-fits-all state code that’s decided by state legislators.”  State generation permitting rules and transmission siting rules have been modified specifically to enable a faster buildout of renewable energy facilities short circuiting the ability of affected towns to object.  This law adds to that problem because now projects that are not privately feasible will be pushed ahead by NYPA.

We are proud to present this inaugural NYPA Renewables Strategic Plan, which describes how the Power Authority will operationalize our new renewables work, along with our continued and critical obligations to our existing generation, transmission, customer, and community commitments.

My Comments on the plan also raise three points all related to the inanity of politicians thinking they should dictate energy policy.  The overarching problem is the feasibility of a renewables-based electric system was the first concern addressed.  I responded to one of the specific political components in the BPRA the mandate to shut down NYPA’s peaking power plants in New York City.  Finally, state officials have a way of overlooking inconvenient aspects of their programs which I addressed with respect to solar siting.

Feasibility

This has been a recurrent theme at this blog since the beginning but the last few months the necessity of a pause in implementation to determine whether New York should be planning to rely on wind, solar, and energy storage has become clear.  As a result, I have been saying the same thing repeatedly which must bore regular readers.  Bear with me in this section.

The authors of the Climate Act believed that no new technologies are needed to implement their aspirational electric system mandates.  That is wrong.  The experts responsible for electric reliability planning in New York and independent experts capable of refined analyses of the electric grid agree that during periods of extended low wind and solar resource availability a new category of generating resources called Dispatchable Emissions-Free Resources (DEFR) is required.  The problem is that there is no commercially available DEFR technology that can be expanded as needed to support projected wind and solar resources necessary to comply with the 2040 “zero-emissions” mandate.  I maintain a feasibility study to address this requirement is necessary.

In my 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 can replace renewables, eliminating the need for a huge DEFR backup resource and even more massive buildout of wind turbines and solar panels sprawling over the state’s lands and water.  Therefore, it would be prudent to pause renewable development until a proven DEFR technology is proven feasible because nuclear generation may be the only viable path to zero emissions.  That would make any further renewable investments a bad choice.

Peaking Power Plants

The authors of the enabling legislation for the NYPA renewables responsibilities also included a specific mandate for New York City peaking power plants owned by NYPA.  Environmental justice advocates like the Peak Coalition, have convinced state officials that New York City peaking power plants are “perhaps the most egregious energy-related example of what environmental injustice means today.”  The enacting law for the Draft Plan specifically directed NYPA to publish a plan by May 3, 2025, to end generating electricity with fossil fuel at its 11 small natural gas power plant (SNGPP) units located at seven sites in New York City and on Long Island by the end of 2030 if reliability and environmental requirements are met.  I have documented that 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. In brief, the continued operation of these facilities will have no discernable impact on local neighborhood air quality and shutting them down is solely political virtue-signaling.  On the other hand, these facilities serve specific reliability needs that are not easily replaced. 

Someday, someone in the Hochul Administration is going to have to confront the advocacy organizations and explain that tradeoffs are often required to balance different societal needs.  In this instance it is the tradeoff between the desire for zero pollutant impacts against the need to keep the lights on.  At least in this instance the law does mandate that a feasibility analysis is necessary before the plants get shut down because the law states they can only be shut down “if reliability and environmental requirements are met.”

Solar Development

It is very frustrating to me that New York utility-scale solar development has no requirement to protect prime farmland.  In my draft Scoping Plan  comments I called for a moratorium on solar development because the Hochul Administration has not required solar developers to adhere to all the NYS Department of Agriculture and Markets (NYSDAM) guidelines protecting prime farmland.  As of November 25, 2024, my Solar Project Scorecard shows that  3,414 MW of solar projects have been permitted on project areas of 46,981 acres. These projects will take 7,588 acres of prime farmland out of production.  Of the 21 solar projects permitted only 8 meet the NYSDAM guidelines.  NYPA solar projects should meet the NYSDAM guidelines.

There are two other solar deployment issues that the Draft Plan should address.  The Integration Analysis projections for solar capacity presume that the facilities use tilting axis solar panels to maximize production.  However, the Hochul Administration has not made that a requirement so there are facilities being subsidized that will produce less energy than expected.  This means that the Scoping Plan projections for capacity and costs are underestimated.  NYPA solar projects should use tilting-axis panels.  Finally, a simple constraint to maximize availability when needed the most should be included.  Specifically, subsidizing solar panels that lay flat on rooftops should not be supported by NYPA because they could be covered by snow when temperatures are lowest and loads highest.

Discussion

New York State residents who read this can comment on the Draft Plan until December 8. 

The New York Power Authority welcomes your views on how we can most effectively and equitably build new renewable resources to support the State’s efforts to advance its ambitious renewable energy goals. If you have feedback or comments, please contact us using the form here. 

I suggest that you make the following points:

  • No jurisdiction has successfully built an electric system that relies primarily on wind, solar, and energy storage without fossil fuel backup.
  • The agencies that are responsible for electric system reliability agree that a new resource is required for periods of prolonged poor wind and solar availability.
  • Therefore, an analysis to identify technologies that can maintain current standards of affordability and reliability must be completed before NYPA provides funding to support renewable projects.

Conclusion

In my opinion, experts who understand the electric system agree that the wind, solar, and energy storage system envisioned by the authors of the Climate Act needs a new technology.  I believe experts agree with me that the only feasible DEFR technology is nuclear power and that cannot be deployed fast enough to meet the aspirational schedule of the Climate Act.  There is tremendous pressure for agency experts and responsible organizations to not speak out against the politically correct façade that renewables are the solution for decarbonizing New York’s electric system.  I understand why they do not speak out but it is frustrating.  I only hope that in private conversations with responsible public officials the experts are recommending a feasibility study. 

The more people who say “Please provide evidence that the enormous changes to the existing system proposed in the Climate Act can work” the better.  Climate Act proponents have never provided well-documented cost estimates to reach net-zero from a base case where decarbonization is not considered.  The requirement to develop, test, and deploy sufficient wind, solar, energy storage, and DEFR by 2040 is a tremendous challenge to reliability.  It is also fair to ask for an environmental assessment of the cumulative impacts of all the resources needed for the wind, solar and energy storage system proposed.  All those concerns should be considered against the backdrop that the climate change issue is a global problem and our contributions are negligible.

Does New York Need a Climate Act Feasibility Analysis

On September 9, 2024 the Hochul Administration initiated the development of the State Energy Plan announcing the release of a draft scope of the plan.  On November 15 New Yorkers for Clean Power (NYCP) sponsored a webinar titled “Get Charged Up for the New York Energy Plan” that was intended to brief their supporters about the Energy Plan.  This article will be the first of two posts addressing this webinar. I have a tendency to write comprehensive posts that are too long for my readers so I am going to break this story up.

I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act) net-zero mandates will do more harm than good if the electric system transition relies on wind, solar, and energy storage.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 470 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 2030 reduction target of a 40% GHG reduction by 2030. Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantified the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation. 

Although related, the Energy Plan should not be confused with the Scoping Plan.  Every several years the New York Energy Planning Board is required to update its overall energy plan for the state. The process begins with an initial document that identifies a “scope” of work–meaning the set of things to be evaluated in the plan with a defined planning horizon of 2040. This makes the Climate Act’s 2040 goal of carbon-free electricity particularly relevant. Unlike the 70% renewable goal which only applies in 2030, the 2040 goal does not mandate an arbitrary quota of “renewables”. Instead, it simply mandates carbon-free electricity, which can include nuclear power. 

Key Action Items from the Webinar

The description of the New Yorkers for Clean Power webinar titled “Get Charged Up for the New York Energy Plan” stated:

Thank you for joining us for the “Get Charged Up for the New York State Energy Plan” Teach-In on November 15th. We are electrified by the demonstrated interest and information shared to support New York’s climate goals through the development of an ambitious and equitable State Energy Plan. To recap, our featured speakers were:

  • Janet Joseph, Principal, JLJ Sustainability Solutions (Former VP of Strategy and Market Development, NYSERDA
  • Dr. Robert Howarth, Member, New York’s Climate Action Council, and David R. Atkinson Professor of Ecology and Environmental Biology at Cornell University
  • Christopher Casey, Utility Regulatory Director for New York Climate and Energy, Natural Resources Defense Council (NRDC)

We’re excited to share the recording and slideshow from the event: Here is the recording of the event and check out the Presenters’ slides here.

Key Takeaways from the Event

  • Energy Plan is foundational to achieving New York’s climate and energy goals, aligning policies with the CLCPA.
  • Engagement from advocates, community members and developers is critical for ensuring equitable and actionable outcomes
  • Challenges like building decarbonization and system reliability require innovative solutions and statutory changes.

I am going to address the presentations of Janet Joseph and Robert Howarth in a later post.  I disagree with their comments that downplay my concern that transitioning the New York electric grid to one that relies primarily on wind, solar, and energy storage will adversely affect reliability and affordability.  This post is going to describe Dr. Howarth’s response to my specific question about the need for a feasibility analysis.   

Feasibility Analysis Background

Dr. Howarth is venerated by New York environmental advocates but I think their faith is misplaced.  His Introduction at the webinar extolled his role in vilifying methane’s alleged importance as a greenhouse gas.  I think that obsession is irrational.  The hostess also lauded his work supporting a Biden Administration pause on applications for LNG export terminals.  However his analysis was “riddled with errors” and he eventually retracted some of the more extreme claims that received media attention.

Howarth claims that he played a key role in the drafting of the Climate Act and his statement  at the meeting where the Scopng Plan was approved claims that no new technology is needed:

I further wish to acknowledge the incredible role that Prof. Mark Jacobson of Stanford has played in moving the entire world towards a carbon-free future, including New York State. A decade ago, Jacobson, I and others laid out a specific plan for New York (Jacobson et al. 2013). In that peer-reviewed analysis, we demonstrated that our State could rapidly move away from fossil fuels and instead be fueled completely by the power of the wind, the sun, and hydro. We further demonstrated that it could be done completely with technologies available at that time (a decade ago), that it could be cost effective, that it would be hugely beneficial for public health and energy security, and that it would stimulate a large increase in well-paying jobs. I have seen nothing in the past decade that would dissuade me from pushing for the same path forward. The economic arguments have only grown stronger, the climate crisis more severe. The fundamental arguments remain the same.

As I will show in this article, I think his claim that the transition can be implemented using wind, sun, and hydro using existing technologies is wrong.        

Do We Need a Feasibility Analysis?

I thought it would be appropriate to give Howarth the opportunity to recant his feasibility claim so I submitted the following question:

On November 4, 2024, the New York Department of Public Service (DPS) staff proposal concerning definitions for key terms notes that “Pursuing the 2040 target will require the deployment of novel technologies and their integration into a changing grid”.  Should there be a feasibility analysis in the energy plan to address their concern about the new technologies?

In his response, Howarth admitted that he was not familiar with the particular reference to the DPS proceeding that is implanting the Climate Act mandates.  Then he answered (my lightly edited transcription of his responses):

I can give you the perspective of three years of discussion on the CAC.  That it is we firmly stated that the goals can be met with existing technologies. We don’t need novel technologies.

One of my unresolved questions relative to Howarth’s position and the Scoping Plan is that he voted to support the Scoping Plan.  However, the Scoping Plan explicitly contradicts his statement that technologies available in 2013 were sufficient for the transition away from fossil fuels.  In particular, the Final Scoping Plan Appendix G, Section I page 49 states (my highlight included):

During a week with persistently low solar and wind generation, additional firm zero-carbon resources, beyond the contributions of existing nuclear, imports, and hydro, are needed to avoid a significant shortfall; Figure 34 demonstrates the system needs during this type of week. During the first day of this week, most of the short-duration battery storage is quickly depleted, and there are still several days in which wind and solar are not sufficient to meet demand. A zero-carbon firm resource becomes essential to maintaining system reliability during such instances. In the modeled pathways, the need for a firm zero-carbon resource is met with hydrogen-based resources; ultimately, this system need could be met by a number of different emerging technologies.

In addition to the Scoping Plan statement that a zero-carbon firm resource is needed, the organizations responsible for New York State electric system reliability agree.  The New York Independent System Operator (NYISO) 2023-2042 System & Resource Outlook, and Power Trends 2024 analyses and the New York Department of Public Service (DPS) Proceeding 15-E-0302 Technical Conference determined that DEFR was needed.  Independent analyses by the Cornell Biology and Environmental Engineering, Richard Ellenbogen, and Nuclear New York also found that it was needed.  For example, a very readable description of the DEFR problem by Tim Knauss describing the work done by Cornell’s Biology and Environmental Engineering Anderson Lab found that “Just 15 years from now, the electric grid will need about 40 gigawatts of new generating capacity that can be activated regardless of wind speeds, cloud cover or other weather conditions”.

While this is not directly applicable to the DEFR requirement I want to highlight the following Howarth quote:

Now having said that.  There are a lot of details to work out, energy storage is going to be critical.  Lisa made the point that ground source heat pumps and thermal networks are better than air source heat pumps.  They are hugely more effective in the peak time in January.  If we go that route we don’t need as much electrical capacity overall. I would add that thermal storage is cheaper than electrical storage for energy.  Particularly if you have a thermal network because you can store heat that can provide a community with heat for weeks to months to even on an annual basis.  There is a community in Saskatchewan I believe where they store heat six months at a time which is very cheap compared to other things

I believe Howarth’s thermal network reference is to Calgary’s Drake Landing solar heating community.   There is only one problem. The system established in 2006 is failing and will be decommissioned less than 20 years after it was built.  In my opinion, the New York Energy Plan must include a critique of the Drake Landing experiment and the implications for New York thermal networks. This is another feasibility analysis that I think is necessary.

Howarth went on to double down on his position that no new technologies are needed:

We don’t need new technologies to meet the goals of our climate law.  Mark Jacobson from Stanford, who I think is the most brilliant engineer I know.  He and I and others wrote a plan back in 2013, more than ten years ago, laying out specifically how to make the state of New York fossil fuel free on a realistic time frame.  We made the case then, more than ten years ago, that we did not need new technologies, and it was cost-effective then.  It is even more so now. The whole idea of waiting for the next new technology is an excuse for inaction.  We don’t need to wait.

I have assembled a page that describes the analyses that contradict the Jacobson and Howarth work and includes a critique of their results.  To adequately characterize the New York electric system, it is necessary to simulate the details of the New York electric transmission system.  Not surprisingly, of the 11 New York Control Areas the New York City area requires the most energy.  That fact coupled with geographical constraints because New York City is basically a load pocket means that transmission details are important.  To characterize wind and solar it is necessary to evaluate meteorological conditions to generate estimates of wind and solar resource production.  When that is coupled with projections of future load, the sophisticated analyses all conclude that the new dispatchable emissions-free resource is needed because simply adding much more short-term storage will not work.  In my opinion, academic studies like Jacobson and Howarth short-change transmission constraints and/or weather variability leading to false solutions and conclusions.

Advocates for the Scoping Plan energy approach demand action now because the law mandates renewables.  Invariably they overlook New York Public Service Law  § 66-p (4). “Establishment of a renewable energy program” that includes safety valve conditions for affordability and reliability that are directly related to the zero emissions resource.   § 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”. 

Conclusion

The Climate Action Council should have established criteria for the three § 66-p (4) requirements so that there is a clear test to suspend or modify obligations.  New York State law has restrictions that protect citizens from irrational adherence to a dangerous energy future and I believe that a feasibility analysis for the new DEFR technology should be part of the evaluation for this mandate.

In my 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 can replace renewables, eliminating the need for a massive DEFR backup resource.  Therefore, it would be prudent to pause renewable development until DEFR feasibility is proven because nuclear generation may be the only viable path to zero emissions.

Jonah Messinger summarizes my worry that New York has placed undeserved reliance on the work of Robert Howarth:

That an activist scholar with a history of contested and critiqued claims could influence the Biden administration with such an obviously erroneous study is more than concerning. It demonstrates how faulty science in the name of climate can derail important policy debates, and make the global energy transition far harder.

I am sure that none of the advocates who venerate his work will ever be convinced that his work is fatally flawed.  However, it is time that the energy experts in the state step up and confront public officials with the reality that the Climate Act schedule and mandates are only possible with a new technology.  Evaluating the potential technologies and determining if they can be feasibly implemented affordably and without risking reliability standards is an obvious approach.

DEFR Concerns Update

I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act) net-zero mandates will do more harm than good if the electric system transition relies on wind, solar, and energy storage.  My primary reliability concern is the challenge of providing electric energy during periods of extended low wind and solar resource availability.  Experts, including those that are responsible for electric system reliability, agree that a new category of generating resources called Dispatchable Emissions-Free Resources (DEFR) is necessary during those periods.  This article summarizes a very readable description of the DEFR problem by Tim Knauss who describes the work done by Cornell’s Anderson Lab headed by Dr. Lindsay Anderson.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 470 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.

Takeaway Message – If you don’t have time to read the whole thing

This post summarizes a readable description of DEFR in an article by Tim Knauss.  He described the work of Dr. Lindsay Anderson regarding the necessary DEFR component of the proposed transition of the electric system to zero emissions.  The article explains how Anderson’s team calculates the gap between future wind, solar, and energy storage generating resources needed and projected electric load during periods of low renewable resource availability.  I believe that the work of the Anderson Lab provides support to my contention that renewable development should be paused.  A renewable-based electric system needs DEFR, the most likely DEFR solution is nuclear, but if you have zero emissions nuclear then you don’t need renewables.  That makes renewables a dead-end approach.

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 2030 reduction target of a 40% GHG reduction by 2030. Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantified the impact of the electrification strategies.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation.  New York Department of Public Service (DPS) Proceeding 15-E-0302 addresses DEFR but there is no schedule for resolving the future plans for DEFR in New York.

Because of its importance to the feasibility of the Climate Act, the subject of DEFR rates its own Pragmatic Environmentalist of New York page.  I described the page contents last July in an article that summarized six analyses describing the need for DEFR: the Integration Analysis, New York Department of Public Service (DPS) Proceeding 15-E-0302 Technical Conference, NYISO Resource Outlook, Richard Ellenbogen, Cornell Biology and Environmental Engineering Lindsay Lab, and Nuclear New York.  I have updated the page with references to the Tim Knauss article on Cornell Professor Anderson’s work.

Syracuse Post Standard “Mind-Boggling Gap”

On November 19 the article There’s a mind-boggling gap in NY’s plan for a clean electric grid. ‘We are so far behind’ by Tim Knauss was published on the Syracuse dot com website. It is not clear to me whether the official link is accessible by non-subscribers so I have posted a version here and reproduce some of it with some annotations below.

Knauss poses the critical question: “What technology will grid operators turn to when solar and wind fall short?”.  He notes:

Maybe it will be advanced nuclear reactors. Or hydrogen-burning power plants. Nobody knows for sure. Operators will need some emission-free power source they can turn on and off at will.

At Cornell University, Professor Lindsay Anderson and fellow researchers have been studying this problem. Given the specific layout of New York’s electric grid, they asked, how much of this new power source would be needed in addition to all the solar and wind?

A staggering amount, it turns out.

Just 15 years from now, the electric grid will need about 40 gigawatts of new generating capacity that can be activated regardless of wind speeds, cloud cover or other weather conditions, according to Anderson’s research.

How much is that? It’s roughly equal to the total capacity of all of New York’s current power plants – nuclear, natural gas, hydro, wind, all of it.

You read that right. To back up the massive quantities of solar and wind power that will provide most of our future electricity, the state power grid will need some new, mystery resource equal in size to the entire generating fleet of today.

The need for new, mystery DEFR, the potential quantity required, and the technological challenges for the resource are issues well known by those who understand the electric system.  However, there is a loud and passionate segment of society who disagree that anything new is needed and reject the scale of the projected resource need.  Anderson and Knauss understand that this is a touchy subject.  Knauss writes:

Anderson knows that’s not easy to hear.

“That’s the thing, right?’’ she said. “Where people are going to start to worry is (to) say, ‘Okay, wait, so you’re telling us that we’re going to spend all this money building out all this wind and solar and batteries — AND we have to put in 40 gigawatts of this?”

But there will have to be a backup.

Knauss describes the analysis work done to generate the “mind-boggling” projections.

Anderson chairs Cornell’s department of biological and environmental engineering. She has a PhD in applied math and a master’s degree in engineering.  For the past decade, she has worked with a shifting assortment of doctoral candidates and other graduate students in her eponymous Anderson Lab, housed in a large room full of cubicles and computers. They examine issues related to the growing importance of renewable energy.

The Anderson Lab is looking at the physics of how all that will work. To do so, they built an elaborately detailed computer model – a “digital twin’’ — of New York’s electric grid.

That level of detail sets their work apart. Many of the studies that look at phasing in renewable energy pretend that the electric grid is a single pool of electrons that flow from point to point without constraint. It‘s known as the “copper plate’’ assumption.

In reality, the New York electric grid is a complex, lopsided network that has been stitched together piece by piece over a century. There are limits on how much electric current can move from one area to another.

The six analyses that are described on my DEFR page all handle the electric system in similar fashions and all unequivocally conclude DEFR is needed.  The reference to studies that use the “copper plate” assumption refers to the analysis that was used by the politicians who authored the Climate Act.  It is the basis of the Climate Act presumption that implementation was simply a matter of political will because no new technology would be required.  New York’s electric grid experts disagree.  This contradiction needs to be resolved.

The Knauss article goes on to describe DEFR:

carbon-free generating plant that can be turned on and off as needed. It’s pronounced DEE-fur.

Today, dispatchable power is provided mostly by natural gas power plants. Energy planners hope to replace them with something that does not produce greenhouse gases. Nobody knows what that will be.

“They’ve come up with a name for something that they don’t know what it is, but their modeling shows that they need something. It kind of seems like dark matter in the universe,’’ said environmentalist Tim Judson, executive director of the Nuclear Information and Referral Service.

When the state’s Climate Action Council issued their December 2022 report on how the state will eliminate greenhouse gases from the grid by 2040, they estimated a need for 18 to 23 gigawatts of DEFRs. Anderson’s study concluded that the estimate should be roughly doubled, to 37 to 40 GW.  In its most recent forecast, the NYSIO estimated a need for at least 20 GW of DEFRs, and as much as 40 GW, by the year 2040.

Knauss explains that Anderson is concerned about the need for DEFR and the quantity required as well as the ramifications of this new resource:

The need stems from two main vulnerabilities, Anderson said.

First, there will be lulls when the wind dies down for days on end and the skies cloud over, resulting in power shortages that exceed the current ability of batteries to compensate. Second, there will be periods when the state has plenty of renewable energy but not enough transmission capacity to get it where it’s needed.

There would even be times when Upstate produced too much renewable energy, which must be disconnected to keep from overloading the grid, even as blackouts rolled across Downstate due to bottled up transmission lines.

Most of those problems are likely to occur in the coldest part of winter and the hottest part of summer, when demand for electricity will surge to peak levels. And the region most vulnerable to blackouts would be Downstate, where communities with massive electricity needs sit at the end of transmission lines from Upstate that are often overloaded.

These issues raise a concern of mine.  I maintain that there are unacknowledged challenges associated with weather variability risks associated with planning for the DEFR resources needed.  The first challenge is calculating the resources needed which requires analysis of meteorological data to estimate resource availability and expected loads.  I believe no one has done a comprehensive enough analysis because they haven’t used the longest period of data available, and they have not included adjacent regional transmission operator areas.  The second challenge is more concerning to me.  The evaluation of the meteorological data develops a probabilistic estimate of the resources needed that are analogous to the one in a hundred-year flooding parameter.  The problem is that we often see a flood exceeding the one in hundred probabilities.  It is inevitable that the weather conditions that caused the worst-case resource drought planning scenario will also be exceeded.  When that happens there will not be enough electric energy available, blackouts are likely, and the consequences of blackouts on a society that decarbonized by using electricity will be catastrophic. 

There is another issue relative to the aspirational Climate Act mandate to go to “zero emissions” by 2040.  We need DEFR but the technology is not available.  Knauss describes potential DEFR technologies:

Some experts propose converting power plants to burn hydrogen rather than natural gas. Or hydrogen could be used in fuel cells, which rely on chemical reactions rather than combustion to make electricity.

Others promote the idea of sequestering the carbon emissions from gas plants underground. Or burning “renewable” methane recovered from landfills and other sources.

Recently, New York officials have expressed interest in small advanced nuclear plants, which are under development by various companies. State energy planners are developing a “roadmap’’ that should be released early next year detailing how new nuclear technology might be encouraged.

None of the possible technologies is ready for commercial application. Which will emerge?

“That’s the million-dollar question,’’ said Lanahan Kevin Lanahan, a spokesman for NYISO, the grid operator.

The article goes on to note a difference of opinion regarding DEFR deployment.  On one side is the electric industry who are obligated to provide reliable electricity.

New York is long overdue to identify DEFR technologies and to support their development, said Gavin Donohue, executive director of the Independent Power Producers of New York, a trade group representing power plant owners.  IPPNY formally asked the Public Service Commission three years ago to decide what it will accept as “zero-emission’’ generating plants. The PSC is still mulling that over in a regulatory proceeding.  “The timely development of fully dispatchable zero emitting resources is crucial to maintain reliability as the economy electrifies and reliance on intermittent renewable and duration limited resources increases,’’ the group wrote.

On the other side are the special interests who have no accountability.

But some environmentalists argue against a rush to develop DEFRs, saying it could distract from building wind and solar resources and could lead state officials to hastily subsidize unproven technology such as hydrogen combustion.

Following a technical presentation to the state Public Service Commission last year by Anderson and a NYISO planning director, representatives from Sierra Club and Earthjustice submitted rebuttal comments claiming that NYISO’s forecast of the need for DEFRs was “alarmist.” (The forecast presented by NYISO that day was about 25% lower than the Anderson Lab’s estimate.)

The critics said the state should focus on proven techniques such as importing power from out of state, improving transmission, and encouraging demand response programs under which customers cut their power consumption during peak periods.  “Rushing to deploy expensive and untested DEFRs risks committing New York to flawed technologies, as it is unclear at the present time which technologies will emerge as commercially scalable and cost effective,’’ they wrote.

I responded to some of the referenced rebuttal comments because I think their analyses are naïve.  In the first place, their analytical methodologies are not as sophisticated as the Anderson Lab.  Secondly, they don’t acknowledge the correlation of wind energy across New York so their estimates of the magnitude of the problem are flawed.  Knauss mentions the critics “solutions”.

It’s a complicated issue, in part because there are strategies other than adding power plants to help reduce demand for electricity during peak periods.  Improvements in meter technology, for example, will enable residential customers to respond during power shortages by reducing their demand, as some commercial and industrial customers do already. Likewise, grid operators could one day draw power from electric vehicle batteries during peak periods.

This line of reasoning is naïve because it ignores the fact that DEFR is needed when the electric system energy requirements are highest.  The conditions that cause light winds and low wind power output also cause extreme temperatures which lead to peak electrical loads.  Those are the conditions when residential customers are not going to want to reduce power consumption.  They will want to keep their homes warm! 

The article goes on to discuss practical alternatives to the “mind-boggling” gap and the aspirational Climate Act schedule.  Dr.  Anderson suggested looking at slightly less stringent emission limits at least as a bridge until a DEFR solution is found.

Knauss also points out that the Anderson Lab work makes the optimistic assumption that all the wind and solar projected by the Hochul Administration actually gets built on schedule.

In reality, siting battles and other issues have stalled many large wind and solar projects for years. And as inflation drives up the capital costs of renewable energy, Gov. Kathy Hochul is under mounting pressure from business and consumer groups to keep the cost of the energy transition under control.

Because of those barriers, there is a vast gap between New York’s renewable energy capacity today and what would be needed to retire all the fossil fuel plants. Developers would have to build about 10 times the wind and solar power that exists now.

“It’s a huge problem, and we are so far behind,’’ Anderson said.

Conclusion

I think that the Knauss article does a great job explaining the intricacies of the DEFR issue and the work of the Anderson Lab.  I believe they appropriately describe the challenges of DEFR.  However, the article does not address the policy implications of DEFR.

The Hochul Administration has finally started its update of the NY Energy Plan.  The draft scope of the plan considers an electric system that relies on wind and solar generation consistent with the Climate Act Scoping Plan.  No jurisdiction anywhere has successfully developed such a system.  The State agencies responsible for a reliable electric system agree with Professor Anderson that a wind, solar, and energy storage system requires DEFR.  I believe that it is prudent to fund a demonstration project to prove that such an electric system will work.  At the very least, the energy plan must provide a comprehensive renewable feasibility analysis to determine whether such a system will maintain affordability and reliability standards.

The most likely DEFR backup technology is nuclear generation because it is the only candidate resource that is technologically ready.  Nuclear power has a proven record for resilient electric production, development would not require changes to support the transmission system and buildout the system, it is not limited by weather extremes, it has lower environmental impacts, and when life cycle and backup costs are considered is likely cheaper.   Its use as backbone energy would eliminate the need for wind, solar, energy storage, and new DEFR deployment to meet Climate Act zero-emissions mandates. 

Sierra Club and Earthjustice argue that DEFR is a distraction to their preference for wind and solar development.  I believe that the work of the Anderson Lab provides support to my contention that renewable development should be paused because that development cannot work until DEFR is proven feasible.  If the DEFR solution is nuclear then renewables are a dead-end approach.