Category: Climate Act Feasibility

DPS Definitions for Establishment of a Renewable Energy Program

I believe that the biggest shortcoming of the Hochul Administration’s implementation of the Climate Leadership & Community Protection Act (Climate Act) is the lack of a plan.  For example, in order to implement a transition to meet the mandate that all electricity must be generated by “zero-emissions” resources by 2040 it is necessary to define “zero emissions”.  On November 4, 2024, the Department of Public Service (DPS) staff finally proposed definitions for two key components of the 2040 target.   This post describes my impressions of the definitions.

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.  The DPS Proceeding on “Motion of the Commission to Implement a Large-Scale Renewable Program and a Clean Energy Standard” case number 15-E-0302 is the primary implementation proceeding.

Background

On November 4, 2024, the DPS staff proposal concerning definitions for key terms (Staff Proposal) in Public Service Law §66-p.  The Introduction of the Staff Proposal explains:

In this proposal, the Department of Public Service Staff (Staff) suggests interpretations of key terms in the provisions of the Climate Leadership and Community Protection Act (Climate Act), codified in Section 66-p of the Public Service Law (PSL), which directs the Public Service Commission (Commission) to establish a renewable energy program and design it to achieve particular targets. At issue in this proposal is the language of PSL §66-p(2)(b), which directs the Commission to establish a program pursuant to which, by the year 2040, the “statewide electrical demand system will be zero emissions.” Of particular note, neither of the terms “statewide electrical demand system” nor “zero emissions” are expressly defined in the Climate Act or in the PSL. This lack of statutory definition requires the Commission’s interpretation of these terms to ensure proper regulatory implementation.

The last sentence understates the obvious – it is impossible to implement a plan if we don’t define these terms.  I have highlighted the two terms in the law that are the focus of the definitions, § 66-p, 2:

No later than June thirtieth, two thousand twenty-one, the commission shall establish a program to require that: (a) a minimum of seventy percent of the state wide electric generation secured by jurisdictional load serving entities to meet the electrical energy requirements of all end-use customers in New York state in two thousand thirty shall be generated by renewable energy systems; and (b) that by the year two thousand forty (collectively, the “targets”) the statewide electrical demand system will be zero emissions. In establishing such program, the commission shall consider and where applicable formulate the program to address impacts of the program on safe and adequate electric service in the state under reasonably foreseeable conditions.  The commission may, in designing the program, modify the obligations of jurisdictional load serving entities and/or the targets upon consideration of the factors described in this subdivision.

Note that the program to implement these mandates has already been established so these definitions have not been addressed thus far.  Also note that there is specific language mandating consideration of the implementation program impacts on “safe and adequate electric service”.  On one hand, they have been working on the implementing programs without defining these key terms and on the other hand, they have a mandate to make sure it works.  I do not think they can protect reliability without a plan that addresses definitions of these terms.

Statewide Electrical Demand System

One of the key definitions describes the statewide electrical demand system.  This is an esoteric concern that is less relevant in my opinion because it is basically just concerns emissions accounting.  The definition problem is that the electricity used in the state comes from sources within the state and imported from other states.  DPS has a good handle on the characteristics of power generated within New York but there is much less information for imported power.  The document does a good job explaining the limitations for New York to impose restrictions on imported electricity based on source type.  DPS Staff basically recommended tracking the emissions and accounting for the different source types. 

There are related concerns with facilities and process emissions.  This boils down to accounting for emissions in specific situations such as those related to co-generation facilities that provide both process energy and generate electricity for on-site use. The Staff Proposal concludes “In sum, Staff reads the legislature’s use of “system” as reflective of an intent to not encompass every power-generating resource in the state, but only those that participate in the operation of the statewide electric grid and do so in a routinized or systematic way.”

In my career I spent a lot of time preparing emission compliance reports.  The accounting issues related to the these definitions make me very glad I will not have to address these problems now that I am retired.

Zero Emissions

The more important definition is for “zero emissions”.  The Staff Proposal states:

The Commission’s interpretation of this term will lay the foundation for decisions about planning, investments, and more in the run-up to 2040. That interpretation must address several issues: whether non-greenhouse gas emissions count; which aspects of a resource’s emissions profile to count; whether and how to count emissions from fuel production processes that arguably occur outside the power sector; whether the emissions attributed to a resource should be counted on a gross basis or on a net basis that recognizes the potential for use of particular feedstocks to reduce or wholly avoid emissions that would occur otherwise; how “zero” should be applied as a threshold; and the significance of the Climate Act’s categorization of a fuel cell that does not consume fossil fuels as a “renewable” resource.

Some of these issues are more important than others.  One of the topics during CAC meetings related to whether non-greenhouse gas emissions count.  Members of the Council who were appointed by Democrats ideologically favored the strict interpretation that zero emissions meant no pollutant emissions whatsoever.  Practically speaking the issue was related to the use of hydrogen which is the recommended zero-emissions fuel technology for hard to convert sectors and the place holder for the new Dispatchable Emissions-Free Resource (DEFR) that the Integration Analysis argues is necessary.  Everyone agrees that compliant hydrogen cannot be produced with fossil fuels, but the question was whether the hydrogen had to be used in fuel cells so that the only emission was water or whether it could be burned to produce energy.

I am sure that the ideologues are having fits over the proposed definition:

Staff recommends that the Commission interpret “zero emissions” to refer to greenhouse gases only and not to emissions of other air pollutants. Several points argue in favor of this interpretation. In New York, “unless a contrary intent is clear, lawmakers employ words as they are commonly or ordinarily employed.” Some commenters argue that no ordinary usage of “zero emissions” can be read to exclude particular pollutants, because ordinary usage would specify which are at issue if the intent was to include only some. But, in this instance, at least three aspects of the Climate Act reflect a contrary intent on the part of the legislature. Those are: (1) the Climate Act’s legislative findings; (2) several of its definitions; and (3) its references to “co-pollutants.” As other commenters note, these point to the same conclusion, namely that the legislature’s primary focus in the Climate Act is on the regulation of greenhouse gas emissions, and that it refers to co-pollutants for specific and discrete purposes that complement the regulation of greenhouse gases.

In my opinion this is a pragmatic decision so I support it.  It will be hard enough and expensive enough to produce hydrogen for the uses proposed without adding to the challenge by insisting that it be used in fuel cells.  While fuel cells are a proven technology for limited applications, trying to deploy them on the scale necessary in this instance would be a problem.

I am not particularly concerned with the other zero emissions issues. 

Conclusion

There are two Climate Act electric sector targets: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040. The DPS has finally defined two terms relevant to those targets in Public Service Law §66-p: statewide electrical demand system and zero emissions. The law mandated that a program be established by 6/30/2021 to meet the targets.  The fact that the terms crucial to the development of an implementation plan were defined 28 months after the program was supposed to be established epitomizes the lack of planning throughout the Hochul Administration’s implementation of the Climate Act.

The definitions themselves are not of particular interest to the public.  The “statewide electrical demand system” definition is an esoteric concern related to emissions accounting.  The practical consequence of the “zero emissions” definition is the pragmatic decision to accept some emissions rather than demanding no emissions for “zero emissions” technologies.  The best example is that this enables the use of technologies that burn hydrogen and emit nitrogen oxides instead of fuel cells that only emit water.

The DPS staff proposal also included a section titled “Reviewing Progress Towards Achieving the 2040 Target” that will be the subject of a future post.  The bottom line for this DPS report is that making progress is a moot point when there is no overall plan.  New York could be headed towards a policy dead-end that could be prevented if a study assessing whether the Scoping Plan outline of strategies is feasible was conducted first.  Given that no jurisdiction anywhere has developed an electric system reliant on wind, solar, and energy storage, a demonstration project would be best.

Navigating the physical realities of the energy transition

This post was also published at Watts Up With That

A recent McKinsey Global Institute report The hard stuff: Navigating the physical realities of the energy transition (McKinsey Report) describes the challenges of the energy transition transformation for those who want a decarbonized society.  This post describes my review of the description of the power sector with respect to my primary concerns for the New York Climate Leadership & Community Leadership Act transition of the electric grid to zero-emissions by 2040.  Those concerns are the need for a dispatchable emissions-free resource (DEFR) and the enormous risk associated with determining how much DEFR must be deployed to prevent blackouts in electric grids that depend on variable renewable energy resources, .i.e., wind and solar.

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 450 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 McKinsey Report describes the realities of the global clean energy transition that proponents claim is necessary to address the existential threat of climate change.  I think the authors did a good job explaining many of the complicated issues associated with the energy transition.  The scope of the report is enormous because they are trying to cover the entire global energy system:

The energy system consists of the production, conversion, delivery, and consumption of energy resources across sectors as both fuels and feedstocks (that is, inputs for the production of different materials).  The system is a massive, interlocking physical entity that has been optimized over centuries. It has served billions of people—if not yet all of humanity—well. But in an era in which countries and companies around the world are aspiring to address climate change, the high emissions resulting from the current energy system are now firmly in focus. The world has duly embarked on a huge transformation, centered on switching from the high-emissions assets and processes on which the system is largely based to new low-emissions solutions.

The summary describes the key points in the report:

  • The energy transition is in its early stages, with about 10 percent of required deployment of low-emissions technologies by 2050 achieved in most areas. Optimized over centuries, today’s energy system has many advantages, but the production and consumption of energy account for more than 85 percent of global carbon dioxide (CO2) emissions. Creating a low-emissions system, even while expanding energy access globally, would require deploying millions of new assets. Progress has occurred in some areas, but thus far has largely been in less difficult use cases.
  • Twenty-five interlinked physical challenges would need to be tackled to advance the transition. They involve developing and deploying new low-emissions technologies, and entirely new supply chains and infrastructure to support them.
  • About half of energy-related CO2 emissions reduction depends on addressing the most demanding physical challenges. Examples are managing power systems with a large share of variable renewables, addressing range and payload challenges in electric trucks, finding alternative heat sources and feedstocks for producing industrial materials, and deploying hydrogen and carbon capture in these and other use cases.
  • The most demanding challenges share three features. First, some use cases lack established low-emissions technologies that can deliver the same performance as high-emissions ones.  Second, the most demanding challenges depend on addressing other difficult ones, calling for a systemic approach. Finally, the sheer scale of the deployment required is tough given constraints and the lack of a track record.
  • Understanding these physical challenges can enable CEOs and policy makers to navigate a successful transition. They can determine where to play offense to capture viable opportunities today, where to anticipate and address bottlenecks, and how best to tackle the most demanding challenges through a blend of innovation and system reconfiguration.

I am only going to consider the power sector and not the other six end-use sectors discussed.  Twenty-five physical challenges are described for these sectors.  Each of the challenges is described relative to the difficulty of the challenge.  This review focuses on the power sector energy transition physical challenges that are shown in the following figure.

Exhibit E1: McKinsey Global Institute The hard stuff: Navigating the physical realities of the energy transition

The description of the power sector physical challenges explains:

Addressing physical challenges in power is fundamental to the entire transition because abating emissions in the huge energy-consuming sectors—mobility, industry, and buildings—requires sweeping electrification under typical decarbonization scenarios. Two difficult challenges arise: managing the variability of renewables such as solar and wind, as they grow their share of total generation; and doing so specifically for emerging power systems that need to grow, often more rapidly and by more than advanced power systems. These two are classified as Level 3 because addressing variability challenges would require the use of novel technologies that have not yet been deployed commercially and face other substantial barriers. Four other challenges, classified as Level 2, relate to constraints on scaling more established technologies, inputs, and infrastructure, where accelerated progress would be needed for the transition.

Quality Review Concerns

The two review concerns for a power sector depend upon weather-dependent resources that I think must be addressed in any assessment of the quality of the report are the need for a new resource to address long-term wind and solar deficits and the challenge of specifying how much of those resources is needed.

In my opinion, all credible analyses of future electric energy systems depending upon wind and solar must acknowledge the need for a new resource to backup up weather dependent resources that New York has named DEFR.  Francis Menton explains that this creates a likely impossible challenge: 

The reason is that the intermittency of wind and solar generators means that they require full back-up from some other source. But the back-up source will by hypothesis be woefully underused and idle most of the time so long as most of the electricity comes from wind and sun. No back-up source can possibly be economical under these conditions, and therefore nobody will develop and deploy such a source.

There is another aspect of DEFRs that needs to be considered.  Menton also did a post on September 28, 2023 that covered a Report then just out from Britain’s Royal Society dealing with issues of long-term energy storage to back up wind and solar generators that concisely describes my other quality concern.  He explains that the Royal Society had collected weather data for Britain for some 37 years and documented that “there are worst-case wind and sun “droughts,” comparable to rain droughts, that may occur only once every 20 years or more.” 

The Royal Society: Large-scale electricity storage, Issued: September 2023 DES6851_1, ISBN: 978-1-78252-666-7

To be a credible analysis of future power sector projected needs, ten both of these concerns need to be considered.  If they are not included, then the complexity will be underestimated and the magnitude of resources required overlooked.

McKinsey Report Analysis of Concerns

For the power sector the McKinsey report addressed six challenges.  I will describe the relevant challenges and mention the challenges that affect the global system but not the New York power sector.

Challenge 1: Managing renewables variability (Level 3):

With the energy transition, Variable Renewable Energy (VRE) sources, such as solar and wind, would be required to grow and reach a relatively high share of total generation. As this happens, the output of power systems would become progressively more variable, exceeding demand on some days but falling substantially short on others. Consider Germany. VRE could potentially account for 90 percent of all power generation by 2050, in the McKinsey 2023 Achieved Commitments scenario. Nonetheless, there could still be about 75 days a year when VRE generation would be insufficient to meet a large share of demand (meaning that at least one-quarter of demand would have to be met by other sources) (Exhibit 6). VRE-heavy power systems would therefore require much more supply-side flexibility. This could come from storage (both power and heat), backup generation capacity (including thermal generation like gas power and beyond), and interconnections. Such flexibility solutions may need to scale by as much as two to seven times faster than overall power demand globally in the next three decades.  However, these forms of flexibility in turn face significant barriers relating, for example, to critical inputs (for some forms of energy storage) and other factors such as market design mechanisms (for backup generation). Most critically, some of the technologies that would be crucial for providing flexibility to the power system over the course of seasons, including novel long-duration energy storage (LDES) and hydrogen-based generation, would need to scale hundreds of times by 2050 from a negligible base today.

The Challenge 1 description emphasizes the need for supply-side flexibility.  Exhibit 6 notes that at least one quarter of the days will require backup resources to resolve VRE intermittency explaining that “novel long-duration energy storage (LDES) and hydrogen-based generation” is needed “over the course of seasons”.  The example resources can be used for DEFR but it does not address my second concern, the worst-case wind and sun drought.  This study appears to only consider average conditions, which is a common flaw in academic assessments.  For electric system resource planners, the emphasis on reliability for all periods mandates that the analysis addresses extreme conditions.    As a result, the magnitude of DEFR support necessary to keep the lights on at all times is underestimated in this analysis.

The second challenge, “scaling emerging power systems”, is also rated as Level 3. The description notes that “Many countries, especially those that are lower-income, need faster and more significant growth in their power systems to increase access to electricity.”  This is not an issue for New York. 

The description of Challenge 3: Flexing power demand (Level 2) notes that “Alongside supply-side flexibility, there may be more opportunity for demand-side flexibility in power as the world electrifies” and does not address either concern. The McKinsey Report claims that this kind of flexibility could provide as much as 25 percent of the total amount needed to accommodate VRE in 2050, in the IEA’s Net Zero scenario.  However, it exposes a weakness in studies that use averages.  Industry planners do not rely on demand-side flexibility because in the worst-case scenarios the capability of those resources is much lower and can be essentially worthless.  This means that studies that only look at averages miss the point that to keep the lights on demand-side resources may not displace as many supply-side resources during the worst-case scenario as they project.  In my opinion, the value of any resource that does not provide firm energy during the worst-case scenario should be downrated.

Challenge 4, “securing land for renewables” is rated as Level 2.  This is a problem for any jurisdiction that tries to rely on VRE because wind and solar resources are diffuse.  This challenge does not address either of my concerns.

Challenge 5: Connecting through grid expansion (Level 2):

With the growth of the power system and the addition of more geographically dispersed energy sources such as VRE, grids would need to become larger and more distributed, interconnected, and resilient. They may need to more than double in size by 2050, growing 40 to 50 percent faster than they are currently. However, lead times for the permitting and construction of transmission lines are long, especially in mature markets such as the EU and the United States, where they have tended to be between five and 15 years. Among other initiatives, accelerating permitting with new streamlined processes could facilitate the expansion of grids.

This challenge does not address either of my concerns.

Challenge 6: Navigating nuclear and other clean firm energy (Level 2):

Increased deployment of clean firm power, such as nuclear, geothermal, and low-emissions thermal plants (for example, hydrogen, biogas, and natural gas with CCUS), could reduce the challenges of variability, land use, and grid expansion. Nuclear is an example of a clean firm technology that is mature and gaining momentum. At COP28, for example, a group of economies announced commitments to triple nuclear capacity by 2050.  Nonetheless, increasing the deployment of nuclear requires managing complex engineering, supply chain, skills, and siting issues as well as safety considerations. In combination, these issues could result in long lead times, frequent delays, and cost overruns. Addressing these would require, for instance, standardizing the design of nuclear plants and building multiple plants using the same designs to leverage shared learning, training workforces in the skills they need, and developing necessary supply chains.

These issues affect the deployment of DEFR but do not address my concerns directly.

Discussion

Although there is useful information in this report, it fails to address my concerns about the need for a new resource to address the specific problem of worst-case wind and solar “droughts” and the related problem of defining just how much of the new resources will be needed to prevent blackouts for the worst of the worst-case periods.

I think the main problem can be traced to the use of averages rather than worst-case conditions for evaluation of resource requirements.  I searched the document for the terms “worst” and “extreme”.  The term “worst” did not appear.  The term “extreme” did show up relative to battery electric vehicle use and heat pumps.  The McKinsey Report noted that special considerations were needed for the worst-case extremes for those applications.  Unfortunately, the authors did not extend that consideration to the power sector.

There is one other consideration unmentioned in the power sector challenges.  Wind and solar resources do not provide the ancillary services necessary to support the transmission system.  The McKinsey Report did note that transmission requirements would be a challenge but overlooked this aspect.

Conclusion

The report concludes that:

The path of the energy transition will not be straightforward, and stark trade-offs and consequences lie ahead. Taking time for the transition to play out, as in many physical transformations of the past, could allow for the physical realities of the transformation to be confronted more gradually with time to innovate and scale new low-emissions technologies, address bottlenecks, and reconfigure the system. While this may make navigating the physical challenges easier, such a path would almost certainly involve compromising on the climate goals that countries and companies across the world have agreed to, with consequences for rising physical risks. However, driving the transition forward without confronting physical realities would most likely compromise the performance of the energy system—and as a result challenge energy access, growth, prosperity, and support for the transition itself.

Alternatively, stakeholders could confront difficult physical challenges head-on—in fact, they could use an understanding of physical realities to guide the way forward to an affordable, reliable, competitive path to net zero. While many open questions remain on what precise path would enable the physical challenges to be addressed, this analysis sheds light on some crucial ingredients that would have to be present in a successful energy transition.

The power sector analysis appears to use averages to project future needs.  As a result, it fails to address my concerns about the need for DEFR and the related risk that improper assessment of the amount of DEFR needed threatens the reliability of the electric system.  The ultimate concern is that the conditions associated with extreme wind and solar droughts are also associated with extreme hot and cold weather when the electrified society will be most vulnerable if there is a blackout.  The report sheds some light on crucial ingredients but overlooks a potential fatal flaw.

Clearly there is no question in the minds of the authors that the transformation to net-zero is necessary. The conclusion talks about trade-offs and consequences but does not acknowledge that there may not be an “affordable, reliable, competitive path to net zero” using VRE.   Given the vulnerability risk, I remain convinced that the VRE transition will do more harm than good in New York and elsewhere.  I think the nuclear option is the only path forward for those who want to decarbonize.

Draft NYISO Reliability Needs Assessment Regulatory Policies Affecting Reliability

It has been a while since I have written about New York Independent System Operator (NYISO) reliability planning process documents.  This post summarizes the section describing regulatory policies affecting reliability in the draft October 2024 draft Reliability Needs Assessment (RNA). 

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 450 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 rationale for the Climate Act is the existential threat of climate change and the Hochul Administration never misses an opportunity to describe every weather extreme as a more proof.  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% reduction. 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.

NYISO Reliability Planning

The NYISO reliability planning process consists of two analyses: the Reliability Needs Assessment (RNA) and Comprehensive Reliability Plan (CRP). The RNA evaluates the adequacy and security of the bulk power transmission facilities over a ten-year planning period, the resources in megawatts (MW), and the locations where required to meet projected needs.  If necessary, the NYISO will request solutions for identified needs.  The CRP determines if the proposed solutions are viable and sufficient then documents the solutions meet the identified reliability needs. 

As part of this continuous process the NYISO has released a “draft for discussion purposes only” of the 2024 RNA on October 4, 2024.  The Regulatory Policies Affecting Reliability section caught my attention, so I wrote this article.

Regulatory Policies Affecting Reliability

A common theme in this blog is the risks to reliable electricity posed by political machinations.  Although the NYISO is technically an independent organization there is tremendous political pressure for the organization to comport with the politically driven narrative of the Hochul Administration.  The section discussing regulatory policies is carefully written so as not to offend the politicians:

Increasingly ambitious environmental and energy policies, evolving market rules, technological advancements, and economic factors impact the decisions by market participants and are accelerating the transition in the state’s resource supply mix. During this transition, the pace of both the addition of new resource additions and the retirement of older, higher-emitting resources are projected to exceed historical levels. Changes to demand patterns and the generation fleet driven by federal, state, and local government regulatory programs may impact the operation and reliability of New York’s bulk power system.

“May impact” operation and reliability is a massive understatement.  Consider the following:

Compliance with federal and state regulatory initiatives and environmental and permitting requirements may require investment by the owners of New York’s existing thermal power plants in order to continue operation. If the owners of those plants must make significant investments to comply, the increased cost to continue operating could lead to the retirement of these resources needed to maintain the reliability of New York’s bulk power system and, therefore, could necessitate replacement.

The document lists eight public policy initiatives that could require investment.  One of the initiatives is the “Peaker Rule:” that targets Nitrogen Oxide (NOx) emission limits for simple cycle and regenerative combustion turbines that provides an example of the challenges.  This initiative should be a model for New York energy policy.  The rule was needed for the state to comply with EPA requirements to reduce NOx to help reduce ozone concentrations.  On the other hand, the simple cycle “peaker” turbines fulfill a critical reliability function.  Recognizing this tradeoff the NY Department of Environmental Conservation (DEC), the generating companies, and NYISO worked out a plan to ensure that the facilities would eventually retire or install control equipment to reduce emissions on a proscribed schedule.  The non-regulated owners of the facilities all determined that the market would not support control equipment investment and submitted plans to retire.  The NYISO determined that temporarily retaining the peaker generators on the Gowanus 2 & 3 and Narrows 1 & 2 barges is necessary to address a reliability requirement, but the others have retired.

Another of the initiatives, “New York Power Authority (NYPA) Small Gas Power Plant Phase Out” is an example of an inappropriate energy planning initiative.  The document describes it as impacting 517 MW nameplate capacity in New York City and Long Island. It requires a plan to phase out production of electricity from fossil fuels, considering clean replacement resources and impacts on emissions and system reliability.  In particular,

NYPA is required to publish a plan by May 2025 to phase out the production of electricity from its seven small natural gas plants (simple-cycle combustion turbines) in New York City and Long Island by December 31, 2030, unless those plants are determined to be necessary for electric system reliability or emergency power service or energy from other sources that may replace energy from NYPA’s small plants would result in more than a de minimis net increase in emissions within a disadvantaged community.

The peaking power plant issue has become a major point of focus of the environmental justice community and proponents managed to convince politicians to include this legislation in the 2023-2024 enacted state budget.  I described many issues with this bogus problem last February.  In short, while there is no question that power plants do affect adjacent neighborhoods, their impacts are all less than the National Ambient Air Quality Standards and the contributions from buildings and transportation sectors are more impactful.  In my opinion, that means that they are not as evil as portrayed,  Furthermore, a DEC Cap and Invest program presentation noted that the power plants had negligible emissions relative to total state-wide emissions.  On the other hand, they fulfill a critical reliability need. 

The draft RNA explains that there are challenges for the replacing these resources:

Balancing the grid throughout this transition not only requires maintaining sufficient capacity to meet demand but also requires that new resources entering service comparably replace the capabilities and attributes of the resources leaving the system (e.g., fast starting/ramping and dispatchable both up and down, available when and for as long as needed, providing essential reliability services such as voltage and frequency control, support system’s stability during disturbances). Continued dialogue and engagement among Market Participants, policymakers, and the NYISO will be essential to support the planning processes in order to identify the needs and services required to maintain a reliable system during and after this transition period.

The NYPA Small Gas Power Plant Phase Out regulation affects modern units that have emission rates far lower than the old units affected by the Peaker Rule.  The environmental justice advocates have the mistaken impression that they can be replaced by battery energy storage powered by wind and solar resources.  This description lays down a marker. The bottom line is that the only resource that can provide the necessary attributes at this time is a fossil-fired generating unit.  Wind, solar, and battery energy storage cannot replace the capabilities and attributes described.

However, given that there have been multiple attempts to permit new replacement fossil-fired generating units to replace the existing peaker units do not underestimate political attempts to deny reality..  The DEC has, under considerable political pressure in my opinion, refused to permit any of these proposed resources citing nothing more than the project being inconsistent with the Climate Act.  Consequently, nothing to replace the old resources has been built.

Conclusion

The “Peaker Rule” promulgation and implementation predated the Climate Act.  It was a common sense approach that provided environmental benefits and protected electric system reliability, Since then reliability concerns have been given short shrift and practical reliability solutions have not been permitted.  The NYPA Small Gas Power Plant Phase Out regulation codifies the irrational New York energy policy approach whereby politicians claim to know better than the electric planner professionals responsible for maintaining a reliable electric system.  Now the NYISO must deal with this legislation that is supposed to shut down existing power plants in favor of a magical resource that does everything needed without any environmental impacts in response to a mostly non-existent problem.  At some point the Hochul Administration is going to have to step up and support the resources necessary to keep the lights on.

The Math Does Not Support New York’s Climate Plan

I frequently collaborate with Richard Ellenbogen regarding issues related to the Climate Leadership & Community Protection Act (Climate Act).  This post describes his recent blog article The Math Does Not Support New York’s Climate Plan published at the Empire Center for Public Policy.  He explains why the numbers show that the Climate Act implementation plan is doomed to failure based on his experience adopting renewable and lower-emission combustion technologies in his home and business.  This post condenses his findings and publicizes his work.

Ellenbogen is the President [BIO] Allied Converters and frequently copies me on emails that address various issues associated with the Climate Act. I have published other articles by Ellenbogen including a description of his keynote address to the Business Council of New York 2023 Renewable Energy Conference Energy titled: “Energy on Demand as the Life Blood of Business and Entrepreneurship in the State -video here:  Why NY State Must Rethink Its Energy Plan and Ten Suggestions to Help Fix the Problems” and another video presentation he developed describing problems with Climate Act implementation.   He comes to the table as an engineer who truly cares about the environment and as an early adopter of renewable technologies going back to the 1990’s at both his home and business two decades ago.

Overview and Background

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% 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 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.

Introduction

Ellenbogen introduces the problem:

I have been analyzing the numbers coming out of Albany regarding the Climate Leadership and Community Protection Act (CLCPA), New York’s plan to drastically reduce the use of fossil fuels, for over five years now.  

I am not anti-renewable and I am not a climate denier. What I am is an engineer that lives by numbers. The numbers underpinning the CLCPA—namely the belief that New York can replace most of its natural gas-fired electricity generation with renewables in the next six or even nine years—are a fantasy.

  • New York is letting the perfect be the enemy of the good, prohibiting or frustrating viable solutions that could reduce emissions. 
  • Instead, New York is relying on older, less efficient power plants, in hopes that wind and solar—built in more rural areas or offshore—can someday replace them. 
  • Even if New York were to build the wind, solar and battery backup necessary to keep the lights on without fossil fuels, the storage requirements, either onsite or grid-based, would be cost-prohibitive. 

State Comptroller Tom DiNapoli in July described “inadequate planning, monitoring and assessment of risks and challenges” by state energy officials. That’s just the tip of the iceberg. 

Greener Than The Grid

In the next section of the article, Ellenbogen describes his manufacturing business and the steps he has taken to reduce energy use at his facility.  His company, Allied Converters, manufactures food packaging for large bakeries and supermarket chains. The machinery is thermally intensive and uses large amounts of electricity.  

In 2002 he “installed the first microturbine-based Combined Heat and Power (CHP) system in the Con Ed service area.”  This approach generates electricity by burning natural gas.  Waste heat is recovered “to heat the building in the winter, or to be sent to absorption chillers to cool the building in the summer.”  This approach allows him to recover 70 to 75 percent of the energy content of the fuel. 

He compares the factory efficiency to the grid:

Most of downstate’s electricity comes from burning natural gas. New York’s single-cycle gas generating plants are in the neighborhood of 30 to 35 percent efficient. Newer combined-cycle plants are in the range of 55 to 60 percent efficient. For both, about 7 percent of energy produced is lost as heat in the transmission lines, a loss we avoid by generating electricity onsite. 

Contrast that with New York’s plan to replace gas and oil furnaces at homes and businesses with electric heat pumps, which will—at least for the foreseeable future—require more electricity generation from fossil fuels, farther away from where the electricity is needed (and therefore more line losses). 

In 2007 he installed the first commercial-scale solar array in New Rochelle.  His article describes the tribulations related to being an early adopter with the planning agency and the utility.  Later that year he added a “Reactive Power Mitigation System and in conjunction with the onsite generation, reduced load on the utility by 80 percent.  To top it off he collects data on all the electric parameters in the building. 

This massive amount of data, along with my training as an electrical engineer, has formed my frame of reference regarding the CLCPA. Renewable generation has a place in the energy mix but it cannot be used as the backbone of the utility system. Renewables are a tool and when you misuse a tool, bad things will happen. When you need a hammer, you don’t use a screwdriver, but that is essentially what the state is trying to do with renewables.

Energy System Model

His facility is a template for a pragmatic energy system:

The factory is a microcosm of NY’s energy system. It has a fossil fuel-based high efficiency generator to provide baseline load which it supplements with a solar array. The balance of the energy is dispatched by the utility when we need more.

All told, the factory’s carbon footprint is 30 to 40 percent smaller than it would be otherwise.  Additionally, our utility bill, including the cost of natural gas, is less than half of what it would have been if we hadn’t added the energy systems. We have not only reduced our carbon emissions but we have also saved money through reduced energy usage and the associated expenses, about $1 million over the past 17 years. Our savings have been relatively higher during recent years as the business has grown and we have used more energy. Contrast that with current bills for other utility customers that are rising at an increasing rate. 

The New York grid relies on nuclear, fossil, and hydro resources for most of its load, wind and solar to supplement the other resources, and imports the rest.  The grid load varies more than the factory.  As a result, resources are called for varying loads depending on their operating characteristics and costs.  Ellenbogen describes current reliability issues.

The New York Independent System Operator (NYISO), the independent nonprofit organization that operates the electric grid and oversees the state’s wholesale electricity market, has been warning about potential blackouts due to closing existing fossil-fuel generators before new generators come online. 

A 2019 plan by the state Department of Environmental Conservation to close smaller “peaker” power plants risked causing rolling blackouts on hot days as soon as 2025, before NYISO officials pushed back and kept some of the plants open. 

As NYISO officials warned earlier this summer, reliability margins—the cushions in each region that ensure there’s enough electricity to meet demand at all times—“are also observed to be narrowing across the grid in New York, which poses significant challenges for the electric system over the next ten years.” 

The reality is that the issue is going to extend well past 2033 and the energy shortages will get worse as gas plants aren’t replaced. 

Future Model

Ellenbogen describes what would be needed at his factory if he were to rely only on solar and not use natural gas.  Note that wind is not a practical source at his location.

To generate the same amount of electric energy that we currently use, we would need a solar array six times the size of what we currently have. Below is a photo of the 25,000+ square foot roof of the factory with the 50,000 watt (50 KW) solar array on it. (The factory is 55,000 square feet across two floors).    

Ellenbogen,s factory, with its 50 KW rooftop solar array, in New Rochelle, NY

We could fit an additional 50 KW array on our roof for a total of 100 KW. However, we would need a roof three times the size of what we currently have to house a large enough solar array to generate the amount of electrical energy that we currently use. That doesn’t include the heat generated by the CHP system. 

If we switched to heat pumps, we would need at least an additional 300 KW of solar arrays to support the building’s thermal load. So in total we would need 12 times the panels—on a roof six times the size. 

Beyond the enormous additional costs needed to build a system of that magnitude, we don’t have the physical space or the roof area to remotely come close to supporting a system of that size. 

The Model Storage Problem

The Climate Act insists on a zero-emissions mandate so that fossil-fired generators cannot be used to support intermittent wind and solar.  This leads to the enormous challenge of storage.

Because of the looming plight of New York utility system, my team and I have been looking for ways to supply the building during a power failure. We first looked at a backup generator but Con Ed wanted $140,000 to run a larger gas line to our building. That being cost-prohibitive, we have been looking at a new type of energy storage that does not have the deficiencies of lithium-ion batteries. 

The newer storage, using supercapacitors, has a comparable cost to lithium-ion, will last 25 to 40 years instead of the eight to 10 years of lithium-ion, and it will not go into a state of thermal runaway and burn at 2600 degrees Fahrenheit as occasionally happens with lithium-ion batteries. It will fit in a space the size of a sea container and it can be charged at night from our CHP system and on weekends from our solar array. With an energy storage system of 720 to 900 KWh in conjunction with the CHP system and the solar array, we could operate 100 percent free of the utility with a carbon footprint 10 percent lower than what we have now. 

However, the Climate Act prohibits the use of the natural gas fired micro turbine currently in use.  That means more storage would be required.

We would have to install nearly sixty times the amount of energy storage as what we currently need for backup purposes—at sixty times the price–to ensure that the panel’s energy was available at night or for extended periods during the winter months. That storage would occupy a volume approximately equivalent to that of fifty large sea containers—for my factory alone.  

When the example for his factory is considered relative to the State the lunacy of the Scoping Plan becomes clear.

NYSERDA, the state’s energy agency, in late 2022 said “complete replacement” of fossil fuel plants with solar and wind generation would require 2,400 gigawatt-hours of storage to get the state through lulls when wind isn’t blowing and output from solar panels is low. At $567 per kilowatt-hour, the recent average cost of new non-residential energy storage, that works out to more than $1.3 trillion in new costs, or about $68,000 per New Yorker.

Summing Up

Ellenbogen describes his misgivings about the Climate Act.

Unlike New York’s plan that is relying on resources that either don’t exist, don’t exist at scale, are prohibitively expensive to install, are opposed by the residents near the sites, double utility costs, and as a result cannot be installed in any reasonable time frame so that they are not reducing GHG emissions, the technologies that we have used to achieve our carbon reductions are just the opposite. My neighbors are unaware of what we have onsite. The only thing that is visible is the solar array on the roof that can be seen with aerial photos or from a distance from the new high rises that have been built. 

The technologies we used existed 20 years ago, reduce GHG emissions, are cost-effective, reduce line losses, reduce transmission and distribution costs, save money for the end user and the utility simultaneously, and can be implemented now in densely populated areas eliminating the need for multi-billion dollar transmission lines. 

This conclusion wasn’t derived from what I like or don’t like, or about what I want or don’t want, and unlike the Climate Act, it is not based upon emotion. It is based upon tens of millions of data points that definitively say that if NY State keeps proceeding on this path, it will be a calamity for the state. If the Comptroller or others in state government wonder why the Climate Action Council never did a financial analysis of the Climate Act that they forced upon the state, with the assistance of unknowing legislators, it is because the costs are so ridiculously high that if the number was actually publicized, it would be political suicide. 

Climate Act Nuclear Reality and Clueless Anti-Nuclear Activists

Two recent Syracuse Post Standard letters, “Nuclear power emits no carbon dioxide but is anything but clean” and “Coverage of Hochul energy summit did not convey dangers of nuclear waste” oppose the idea of using nuclear power as part of the zero-emissions generating resources needed to achieve the Climate Leadership & Community Protection  Act (Climate Act) goals.  In this post I explain why their knee jerk rejection of nuclear is not in the best interests of New York.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 450 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 and Background

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% 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 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.

Evidence is mounting that the implementation is not going to as planned.  The Public Service Commission (PSC) Clean Energy Standard Biennial Review Report found that the 70% renewable energy goal will likely not be achieved until at least 2033.  The New York State Comptroller Office Climate Act Goals – Planning, Procurements, and Progress Tracking audit found that the PSC and NYSERDA implementation plans did not comprise all essential components, including “assessing risks to meeting goals and projecting costs.”  The New York Independent System Operator (NYISO) 2023-2042 System & Resource Outlook described issues that threaten reliability and resilience of the current and future electric system. The Department of Public Service Proceeding 15-E-0302 has initiated a process to “identify technologies that can close the gap between the capabilities of existing renewable energy technologies and future system reliability needs, and more broadly to identify the actions needed to pursue attainment of the Zero Emission by 2040 Target”. The Business Council of New York cited those reports and gave other reasons in a letter asking for a reassessment of the Climate Act goals. 

A technical conference held under the PSC’s auspices on December 11 and 12, 2023 entitled “Zero Emissions by 2040” included a session titled “Gap Characterization.”  Panelists at the session recognized the need for some new resource that would need to be developed to provide electricity to meet demand when wind and solar production are low.  They referred to this new, not-yet-existing, hypothetical technology as the Dispatchable Emissions-Free Resource, or “DEFR.”  The panel also described a few potential DEFR technologies.  Nuclear is the only proven technology that can be expanded sufficiently to fulfill the DEFR energy requirements projected for the future electric grid.

Future Energy Summit

In an apparent response to these issues, on September 4-5, 2024, the Hochul Administration hosted a Future Energy Summit that announced the draft Advanced Nuclear Technologies Blueprint.  The blueprint notes that a “growing and innovative group of advanced nuclear energy technologies has recently emerged as a potential source of dispatchable carbon-free power”. The blueprint introduces the goals:

The term advanced nuclear represents a suite of technologies, a description of which is provided in subsequent sections of this document. Advanced nuclear technologies could offer attractive possibilities for New York, with its scalability, economic development, low land use, and potential applications of process heat. It may represent an opportunity for additional grid capacity to support an electrifying economy, that can complement New York’s buildout of renewables. Yet advanced nuclear technologies raise a host of questions that would have to be addressed before planning on it, regarding technological readiness, costs and cost risks, environmental justice, among other factors.

Accordingly, this discussion paper examines a number of advanced nuclear technology options from the standpoint of technological readiness and systemic challenges and issues. The objective is to surface the most important opportunities, issues, and questions associated with these options to create a platform for additional analysis and stakeholder input on these options that moves New York forward towards its energy, economic, climate, and equity goals.

Tim Knauss described the Summit and the initial public response.  He noted that the Summit attracted two street demonstrations – one for nuclear energy and the other against.  He described the two protests:

Several speakers at the energy summit noted that both Democrats and Republicans in Washington support expanding nuclear power. And polling shows that a majority of Americans — some 56% — support building new nuclear plants, according to Pew Research Center.

But at the local level, the subject can still be divisive.

That was evident Thursday outside the energy summit at the Marriott Downtown Syracuse, where about 60 protestors gathered to denounce the discussions of nuclear power.

“Governor Hochul’s climate leadership is in freefall,’’ said Laura Shindell, New York director of Food & Water Watch, an environmental group. “Now, at the very moment that we need Gov. Hochul to be our climate’s strongest defender, she is instead wining and dining the slow, expensive, dirty and dangerous nuclear industry.”

Shindell and other activists called nuclear power a “fairytale distraction’’ that will weaken the state’s efforts to meet climate goals mandated by the 2019 Climate Leadership and Community Protection Act.

They were joined by Cornell University professor Robert Howarth, who served with Harris on the Climate Action Council that drew up the state’s plan to comply with the law’s mandates.

Aside from its environmental hazards – including uranium mining, much of which mars lands occupied by Indigenous peoples – nuclear power is too expensive and too slow to construct to help meet New York’s emission reduction goals, Howarth said.

Spending on nuclear will detract from the development of more beneficial power sources, he said.  “It’s nonsense in terms of our energy future in New York, even if it had an acceptable environmental and health footprint, which it does not,’’ Howarth said. “We can meet all of the energy needs of New York with solar, with hydro and wind and appropriate (energy) storage.’’

But the energy summit also drew a pro-nuclear protest. U.S. Rep. Brandon Williams, R-Sennett, and members of Nuclear New York held their own sidewalk event to protest the anti-nuclear protest. 

Williams, a former nuclear submarine officer, said he strongly supports new nuclear power for New York. But he does not support New York’s mandate of zero-emission electricity, which he said is costly and ineffective.  “This goal of net-zero emissions is based on ideology, not on economics and not on engineering and not on science,’’ Williams said.

Anti-Nuclear Letters

The Syracuse Post Standard published two anti-nuclear letters after the Summit.  “Nuclear power emits no carbon dioxide but is anything but clean” was written by Donald Hughes, Ph.D., a longtime resident of Syracuse and environmental activist with Sierra Club and Sustain CNY.  “Coverage of Hochul energy summit did not convey dangers of nuclear waste” was written by Carole Resnick from Syracuse.  I have submitted rebuttals to those letters but there are space constraints and there is no assurance that my letter will be published.  This section describes my concerns with these letters.

Hughes argues that nuclear is anything but “clean.”  He claimed that the construction of reactors has a huge carbon footprint but ignored the mineral intensity of wind, solar, and energy storage technologies.   He said the nuclear fuel cycle is highly toxic and cited problems with uranium mining in the American Southwest.   I have compiled references for similar issues with the resources he claims are “clean”.  As part of the Nuclear New York demonstration mentioned previously ,Chris Denton assembled a booklet with numbers and pictures that show that ignoring the impacts of wind and solar when complaining about nuclear is poor form.

Hughes dismisses the advanced nuclear technology under consideration in the Advanced Nuclear Technologies Blueprint because of concerns with safety, nuclear waste, and costs. However, nuclear advocates see an opportunity to develop different types of reactors that could address these issues.  Ronald Stein explains:

The nuclear power production industry has the best industrial safety record among all industries for electricity production. So, the fear that most needs attention is the one surrounding spent nuclear fuel, which is commonly referred to as “nuclear waste.” The solution, then, lies in educating heads of state, mainstream media, and policymakers by extending the concept of recycling to include the unspent energy in used nuclear fuels, a method that can convince people that the “nuclear waste” issue is being dealt with, the cost of power is competitive, and that the production of nuclear power is safe.

Recycling Slightly Used Nuclear Fuel (SUNF) in a Fast Breeder Reactor (FBR) provides all these remedies in a way that is competitive and publicly acceptable.  The advantages to recycling used nuclear fuel in Fast Breeder Reactors are many:

  1. It provides a solution to the disposition of the stockpile of Slightly Used Nuclear Fuel (SUNF).
  2. Current inventories of SUNF provide an essentially unlimited supply of domestic fuel.
  3. The fuel material is already mined, so the energy produced is much closer to 100% clean, and further environmental degradation from mining operations is not required.
  4. The public would be more receptive to nuclear power because “waste” is being used as “fuel,” reducing the retention of unspent fuels and diminishing perceived risks.
  5. The design is “intrinsically safe”. This means that the reactor is designed to cool sufficiently in the case of an accident without human intervention.
  6. The current stockpile of SUNF has a value of $10 Trillion when the electric power that it produces is sold at 1 cent per kWh.
  7. Process heat can be used for industrial purposes such as hydrogen, freshwater production, and synthetic fuel production.

Hughes complains that the costs make nuclear a poor choice.  His main argument is that the relative costs of nuclear compared to wind, solar, and energy storage are high.  For example he cites a study by Lazard, that estimated that the unsubsidized levelized cost of electricity from new nuclear plants in the U.S. will be between $141 and $221 per megawatt hour. In comparison, a newly constructed utility-scale solar facility, with battery storage to provide power after the sun sets, will produce power at an unsubsidized levelized cost of between $46 and $102 per megawatt hour.

Willis Eschenbach evaluated that Lazard April 2023 annual report and summarized the problem with the Lazard Levelized Cost of Energy (LCOE) methodology:

The LCOE estimates the total capital, operations, and maintenance costs for new electric power plants coming into service. People use the Lazard LCOE all the time to claim that renewable electricity sources are now cheaper than fossil fuel electricity. However, the Lazard data has a problem—it doesn’t include the cost of backup and other costs for renewable energy. These costs fall into four groups:

  1. Backup costs – All power sources require backup power for the times when they are not generating any or enough power. However, the amount of backup required is much larger for intermittent sources.
  2. Balancing costs – Extra equipment is required when you have intermittent sources, to keep their highly variable input to the grid from destabilizing it.
  3. Grid connection costs – Renewable wind and solar power is variable voltage direct current. Before it can be fed into the grid, it must be run through costly synchronous inverters to convert it to stable voltage, stable frequency alternating current.
  4. Grid reinforcement/extension costs – Unlike fossil or nuclear plants, which can generally be sited as required, renewable sources of energy are often located far from where the power is needed. As a result, the grid will generally need to be extended, strengthened, or both for such source

Eschenbach’s analysis includes the following figure that compares the original Lazard costs relative to the addition of potential costs for the cost groups described above.

Note that nuclear costs are still higher than solar and wind.  However, these projections are based on a 50% penetration of generating sources.  New York’s Climate Act requires 100% penetration of wind and solar.  As a result, it does not include the necessity for a DEFR resource to backup solar and wind.  When DEFR cost support is included I believe that nuclear will be the cheaper option.

The only proven DEFR technology is nuclear so it is possible that there won’t be any choice but to develop it.  However, note that DEFR is not needed very often so it does not make much sense to use it solely for DEFR.  Instead, the obvious solution is to go all in for nuclear and stop trying to develop wind and solar.  Ron Stein sums it up: “Rather than pursue renewables of wind and solar that require huge land footprints, huge taxpayer subsidies, and even then, only generate electricity occasionally, it’s time to focus our technology resources on the nuclear power production industry that has the best industrial safety record among all companies and a track record of producing the cheapest non-subsidized electricity.”

The letter from Carole Resnick was long on emotion and short on numbers.  She believes professor of ecology and evolutionary biology professor Robert W. Howarth’s claim that “We can meet all of the energy needs of New York with solar, with hydro and wind and appropriate (energy) storage.”  Her belief is misplaced because Howarth is wrong.  I have analyzed his arguments that no new technology is needed and found them wanting.  More importantly, the Scoping Plan Integration Analysis, all analyses done by the New York Independent System Operator, and the Public Service Commission ‘Zero Emissions by 2040’ proceeding described previously all agree on the need for a new dispatchable emissions-free resource to support the electric system.  Her arguments against nuclear power itself echo the same points argued by Hughes

Conclusion

Hughes anti-nuclear claim is that “The reality is that it’s an unaffordable, slow to build and highly toxic process that has no place in a clean energy future.” Resnick claims that nuclear is a false solution and insinuates that is being considerable because it is profitable.  Neither of their arguments stands up to inspection.

I believe when the total costs of a wind, solar, and energy storage system are compared to the cost of a system that relies on nuclear for electricity generation that the nuclear system will be cheaper.  In addition, it will be more reliable because there is no reliance on weather-dependent generating resources.

The letter authors suggest that wind, solar, and energy storage have no downsides.  However, when the emissions from the full life cycle of those technologies, the impacts of renewable energy sprawl across the countryside, and the cumulative environmental impact of thousands of wind turbines and thousands of acres of solar panels necessary to provide the electricity projected are compared to the nuclear option, those technologies are anything but green. 

It is time for a nuclear renaissance.

Has the Electricity Reality Check Arrived?

An article by Todd Snitchler originally published by RealClearEnergy  and republished at Watts Up With That provides an excellent overview of the issues confronting the electric system today.  It is also a response to clean energy advocates that demand that New York double down on its efforts to meet the Climate Leadership & Community Protection Act (Climate Act) mandates using wind and solar resources.  This post annotates the Snitchler article with comments framing the New York context.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 450 articles about New York’s net-zero transition.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes an interim reduction target of a 40% GHG reduction by 2030, and two targets that 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 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.

On September 4-5 the Hochul Administration hosted a Future Energy Summit.  I have written several preliminary impression articles about it and plan to do a final summary after the video is posted.  My impression is that Hochul suggested the idea for the Summit, but the primary rationale is not obvious.  Initially I thought it was in response to three recent independent reports that found that there were schedule issues, inadequate cost support and potential reliability risks.  Those findings coupled with a Business Council of New York letter that cited those reports in a plea for a reassessment I thought were compelling reasons for a meeting.

However, the Summit did not address the problems identified.  There were a couple of passing mentions of some of the problems but none of the panelists made any statements contrary to the Administration’s narrative.  However, two sessions were devoted to incorporating nuclear energy in the implementation plan and a draft blueprint for consideration of advanced nuclear technologies was released for comment.  I now think that the purpose was to gauge the political blowback for that option.

In this context, Spectrum News with Susan Arbetter has recently hosted guests (here and here) to discuss the “benefits of nuclear energy, specifically as a dispatchable resource that can fill in the gaps that arise with solar and wind.”  The most recent interview was with Blair Horner from the New York Public Interest Research Group (NYPIRG).  I address his comments in my annotations of the article below.

Has the Electricity Reality Check Arrived?

The author of the article is Todd Snitchler.  He is President and CEO of the Electric Power Supply Association (EPSA).  He introduces the article by noting that dispatchable generation is needed.  For background keep in mind that electric system operators must balance the load with available generation constantly.  That challenge is much easier if they have resources available that can be dispatched, that is to say controlled, as needed. Wind and solar are not dispatchable.

At meetings of energy regulators, policymakers, consumer advocates, and industry this summer, the content and tone of the conversations around electric system reliability have changed dramatically. Executives from across the industry all agree that dispatchable generation is needed now and will be needed for many years to come.

Electric system owners have economic goals that are inordinately affected by politicians.  As a result, they are reticent to say anything that is inconsistent with the current political narrative.  In this case the political narrative is the constant refrain about the need to do something about the “existential” threat of climate change.  Consequently, everyone who knows better that works for the utilities or the state has not been speaking out about the risks of relying on generating resources that cannot be dispatched. However, reality is forcing their hands and suggestions that laws like the Climate Act might not work as touted are coming out.

Most prominently, the realization and willingness to say publicly that dispatchable resources like natural gas-fired generation will be needed as the energy expansion continues and load growth accelerates for the first time in decades is a welcome admission.

For several years the discussion around the future of the electrical grid was about how inexpensive it will be and how “out of political favor” resources would be moved off the grid in favor of politically favored ones without creating any disruptions or reliability challenges. And just like that, the story has changed – dramatically. Why?

Privately all the experts who really understand the electric system admit that the proposed Climate Act transition plan is very unlikely to work and certainly cannot work on the arbitrary schedule mandated by the Climate Act.  On the other hand, advocates like NYPIRG’s Horner cling to the incorrect notion that no new technologies are needed.  That belief underpinned the Climate Act law’s schedule and presumption that meeting the schedule was just a matter of political will.  Snitchler describes three reasons why plans like the Climate Act cannot work as advertised in the real world.

First, load growth – and a substantial amount of it is expected in the short term. The second is the pace of dispatchable generation retirements, without replacement generation with similar performance characteristics. The third is consistent and increasing warnings coming from reliability organizations and grid operators that a crisis is coming and coming quickly if system planning does not improve.

The authors of the Climate Act did not understand how the electric grid operates and the impacts of wind and solar intermittency on the proposed changes to the system.   In the interview with Arbetter at about the 2:00 mark Horner makes the point that the law established a schedule that must be met.  Ignoring all the issues related to the massive shift in resources proposed and all the difficulties associated pandemic impacts to supply chains, he whines that the Hochul Administration is not doing what they are supposed to be doing.  Snitchler’s description of grid operation realities is inconsistent with the Climate Act mandates so the State is in an impossible situation relative to the schedule.

What does this mean? In short, it is a long-awaited recognition of the reality of grid operations combined with the acknowledgment (albeit grudgingly in some circles) that dispatchable resources, like natural gas, will need to be retained and operated for a longer time horizon than many were willing to admit. This recognition matches the significant number of credible studies, including work done by McKinsey and EFI, that all said dispatchable natural gas generation would be needed even in a high renewable resource penetration scenario.

The problem of dispatchability is compounded in New York because natural gas generation is prohibited by the Climate Act.  Instead, the credible plans for the future electric system plan to use a not yet commercially available “Dispatchable Emissions-Free Resource (DEFR)”.  It is long past time that anyone who denies this need should be ignored in the conversation but unfortunately the Hochul Administration has not done anything to confront this problem.

That is not all.  Snitchler describes other issues that have impacted the Climate Act schedule that Horner ignores when he whines that the State is not meeting the schedule:

As the reality of load growth, supply chain issues, permitting, siting, and construction challenges impacting all types of resources settled in and the sharp warnings of imminent reliability issues combined, it became clear that the rhetoric was far ahead of reality. Recognizing the problem is the first step in solving it.

Unfortunately, there is a crisis brewing as the reliability margins shrink.  This summer there were operator alerts for generation emergencies.  Snitchler explains that this is largely due to retirements of fossil-fired generating resources before adequate replacements were available.  He goes on to recommend a solution.

Because all resources are now accountable for reliability, including dispatchable, intermittent, and storage resources, the requirement to acknowledge and adapt to grid realities is no longer optional – it’s mission critical. The retirement of significant amounts of dispatchable resources without adequate replacements has pushed us ever closer to a system with zero margin of error.

To correct this situation, policymakers and regulators should take steps to minimize the risk to customers. First, the timing gap between retirements and additions to the system must be addressed; we can’t let existing resources off the grid before the replacements are ready. The process for connecting new generation to the grid must be reformed to ensure projects match system needs, not just policy pronouncements. Permitting and siting reforms are needed so we can deliver development of all types of energy projects.

I agree with Snitchler that one thing that must be done is to readjust the aspirational targets of energy transition laws like the Climate Act.  I endorse the idea that offramps for reliability is necessary. 

Second, policymakers must temper enthusiasm and set goals that align with the reality of system needs and operational constraints. This could mean pausing policies that hinder the deployment of needed resources or including offramps in legislation to ensure grid reliability.

I do have a concern with his plea for siting reforms and pausing policies that hinder deployment of needed resources.  I do not agree if that approach is used to justify deploying wind and solar faster because I think there is a fundamental issue that has not been addressed.  Analyses of renewable resource availability have identified periods where DEFRs are required.  What has not yet been addressed is the risk that designing an electric system to meet a weather-dependent requirement will inevitably mean that practicality and affordability constraints will lead to a situation where an extreme event exceeds the planning criteria.  That would lead to blackouts.  I do not believe this has received adequate evaluation and discussion.  As a result, I think it is more appropriate to consider reliability constraints before proceeding to build as much solar and wind as possible as fast as possible.

Snitchler raises another practicality issue that is not on the radar of advocates like Horner.  New York policies must be consistent with other states or bad outcomes will result.  In addition, there must be a plan for developing a market signal for DEFRs.  This will be an expensive resource that is not used much raising market viability concerns.

Third, grid operators must move more quickly to adjust markets to send the appropriate signals that will drive investment of the required resources. States must recognize the broader benefits of market participation and positive outcomes for their constituents and stop merely demanding grid operators do what one state wants to the detriment of another. States must again appreciate that the benefits of their utilities joining markets far outweigh their ability to dictate resources and timelines and then disclaim responsibility for the issues those decisions create.

Advocates like Horner are first to accuse market participants of biased motives when there are inconsistencies with their goals.  Everyone wants a better environment and would like to reduce the risks of extreme weather impacts due to climate change.  Snitchler correctly points out that unrealistic goals raise the risk of reliability problems that, in my opinion, are a much worse outcome than effects of climate change that these policies could possibly alter.

To close, lest anyone accuse market participants of not wanting to reduce emissions or only wanting to profit from their current resources, this reality check in no way means walking away from striving to meet policy goals. Bottom line – we can set goals, but they must be tethered to operational reality to ensure success and reliability are both achieved.

Discussion

I think this is a good summary of issues confronting all the electric grid operators in the United States.  The risks in New York are even greater because of the unrealistic Climate Act mandates and the attitude of many that because it is a law the mandates must be met with no acknowledgement that there has never been a feasibility analysis to confirm whether it can be done and how fast it could be done.  It is unfortunate that the Future Energy Summit did not address these concerns.  I believe that a reassessment is overdue.

One of the most important topics for a reassessment is that the need for dispatchable resources destroys the myth that wind, solar, and energy storage are the only technologies needed.  Energy storage can provide some of the necessary dispatchability, but the overwhelming consensus is that new DEFR technology is necessary.  It is time to stop giving Robert Howarth, the self-avowed author the Climate Act, any platform to say “We can meet all of the energy needs of New York with solar, with hydro and wind and appropriate (energy) storage.’’  That statement is wrong and incorrectly influences advocacy groups like NYPIRG.

Conclusion

Snitchler summarizes the reality check issues that need to be confronted nationally and in New York.  If these issues continue to be ignored and unresolved, then the only outcome will be grid reliability problems.  I fear that there are many who will only admit that these problems are real only after there has been a catastrophic blackout.

New York Future Energy Economy Summit Post Meeting Preliminary Update

On August 5 Governor Hochul announced a Future Energy Economy Summit that will “gather feedback on strategies to accelerate renewable energy deployment and explore the potential role of next generation clean energy technologies”.  I described my initial thoughts on the summit and followed up with a second pre-meeting post.  This post describes my initial reaction to the meeting.  I will follow up with another post when the meeting recording is posted.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 450 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% 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 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.

Setting the Stage for the Meeting

As I have noted previously there are many reasons why an assessment of the future energy economy is needed.  Three recent reports top the list.  The Public Service Commission (PSC) Clean Energy Standard Biennial Review Report found that the 70% renewable energy goal will likely not be achieved until at least 2033.  The New York State Comptroller Office Climate Act Goals – Planning, Procurements, and Progress Tracking audit found that the PSC and NYSERDA implementation plans did not comprise all essential components, including “assessing risks to meeting goals and projecting costs.”  The New York Independent System Operator (NYISO) 2023-2042 System & Resource Outlook described issues that threaten reliability and resilience of the current and future electric system. The Department of Public Service Proceeding 15-E-0302 may also be influencing the Governor and precipitating the need for the summit.   The Business Council of New York has cited those reports and gave other reasons why it is needed.  As a result, the governor said the state’s climate goals are something she “would love to meet, but also the cost has gone up so much. I now have to step back and say, ‘What is the cost on the typical New York family?’ Just like I did with congestion pricing.” 

Annotated Agenda

Welcome

  • Doreen Harris, President and CEO, New York State Energy Research and Development Authority
    • Reason to meet in Syracuse was because of Micron chip fabrication plant
    • Administration is committed to Climate Act goals but refinements may be necessary

Morning Keynote

  • Kathy Hochul, Governor Press Release
    • Reiterated commitment to Climate Act goals because of all the climate events
    • She managed to appeal to a wide range of her constituents with specific statements

Fireside Chat: State of Technology

  • David Crane, Under Secretary for Infrastructure, U.S. Department of Energy
  • Richard Kauffman, Chair, New York State Energy Research and Development Authority
    • I was not impressed with this session
    • Neither speaker has a technical background and it showed
    • Upton Sinclair’s quote is apropos: “It is difficult to get a man to understand something when his salary depends upon his not understanding it.

Accelerating Renewable Energy Deployment in New York State

  • Moderator, Georges Sassine, Vice President, Large Scale Renewables, New York State Energy Research and Development Authority
  • Laura Beane, President North America, Vestas
  • Lori Bird, Director of U.S. Energy Program and Polsky Chair for Renewable Energy, World Resources Institute
  • Eric Cohen, Head of Green Economy Banking, JP Morgan Chase
  • Frank Macchiarola, Chief Policy Officer, American Clean Power Association
  • Jonah Wagner, Senior Advisor to the Director, U.S. Department of Energy Loan Programs Office
    • All of these speakers have a vested interest in the clean energy transition so my notes are sparse
    • I posted a question asking if it was a good idea to build as much renewable energy as possible before the necessary dispatchable emissions-free resource technology is specified.  There was no response to the question.

Status of Next Generation Energy Technologies

  • Moderator, Brandon Owens, Vice President, Innovation, New York State Energy Research and Development Authority
  • Dr. William Acker, Executive Director, New York Battery and Energy Storage Technology Consortium
  • Dr. Monterey Gardiner, Chief Engineer, National Renewable Energy Lab
  • Dr. Benjamin Houlton, The Ronald P. Lynch Dean, Cornell College of Agriculture and Life Sciences
  • Dr. Jack Lewnard, Program Director, Advanced Research Projects Agency – Energy, U.S. Department of Energy
  • Jeffery Preece, Director of Research and Development, Electric Power Research Institute
  • Julie Tighe, President, New York League of Conservation Voters
    • One of the significant points made during the Summit is that certain industries are willing to pay more for reliable high-quality electric power. 
    • This broaches the idea that those companies would be willing to make investments in reliable power
    • It also acknowledges that certain industries recognize that a future grid that relies on wind, solar, and energy storage will not be reliable enough

Lunchtime Keynote Speaker Clean Energy Supply for Large Loads

  • Rich Powell, Chief Executive Officer, Clean Energy Buyers Association
    • He explained how large companies signal their climate virtue by claiming credits for zero-carbon generation virtually

Insights from Large Consumers of Electricity

  • Moderator, Hope Knight, President, CEO, and Commissioner, Empire State Development
  • Miranda Ballentine, Senior Advisor, Green Strategies
  • Amber Bieg, Lead Senior Program Manager for Global Sustainability, Micron 
  • Moshe (Mo) Bonder, Director, Business Development Low Carbon Solutions, National Grid Ventures
  • Jennifer Lupo, Vice President, Energy Solutions, Supply Chain & Leasing, The Raymond Corporation
  • Dr. Varun Sivaram, Senior Fellow for Energy and Climate, Council on Foreign Relations
    • This session gets into the real reason for the Summit
    • In order to do justice to the commentary I need to review the meeting recording
    • All these companies subscribe to the belief that it is important that the electricity they use be “clean”
    • There was even a suggestion that to be competitive, companies demand clean energy.  My impression was that affordability and reliability were weighed equally with cleanliness.  That does not seem appropriate, so I need to get exact quotes

Global Perspective: Advanced Nuclear Development in Other States and Nations

  • Moderator, Rory Christian, Chair, New York State Public Service Commission
  • Nicolle Butcher, Chief Operations Officer, Ontario Power Generation
  • Steve Chengelis, Senior Director of Future Nuclear, Electric Power Research Institute
  • Dr. John Parsons, Deputy Director for Research, MIT Center for Energy and Environmental Policy Research
  • Dr. Andrew Whittaker, SUNY Distinguished Professor, University of Buffalo
    • This session addressed the status of nuclear elsewhere
    • Questions were posed and answers debunking common anti-nuclear talking points were included

Blueprint for Consideration of Advanced Nuclear Technologies

  • Moderator, John Williams, Executive Vice President of Policy and Regulatory Affairs, New York State Energy Research and Development Authority
  • Armond Cohen, Chair, Clean Air Task Force
  • Judi Greenwald, Executive Director, Nuclear Innovation Alliance
  • Christine King, Director, U.S. Department of Energy’s Gateway for Accelerated Innovation in Nuclear Program
  • Greg Lancette, Business Manager, United Association of Plumbers and Steamfitters Local 81
  • J. Ryan McMahon II, Onondaga County Executive
  • Marc Nichol, Executive Director of New Nuclear, Nuclear Energy Institute
    • In the interest of full disclosure I bailed on this session

Wrap up and Next Steps

  • Doreen Harris, President and CEO, New York State Energy Research and Development Authority
  • I got into the meeting webinar when I got home in time for this
    • Harris read accolades to her boss’s vision to fight the crisis
    • She said there were three takeaways
    • She doubled down on the need for building renewables and making them the primary energy source
    • She acknowledged that dispatchable emission-free resources were needed
    • She argued that we must not miss the opportunity to leverage federal initiatives to fund New York’s transition.
    • She believes that the clean energy transition will grow a prosperous economy
  • Discussion

In an earlier post I noted that the State must confront the possibility that the safety valve criteria in New York Public Service Law  § 66-p (4) for unsafe and inadequate electric service, impairment of existing obligations and agreements, and unacceptable increase in arrear or service disconnections will be exceeded.  There was no suggestion whatsoever that the Hochul Administration has any doubts that a zero-carbon electric grid that relies on wind and solar will work.

It seems obvious that there are large consumers of electricity that want to at least be able to say that they use 100% renewable energy. I think this summit was in no small part designed to cater to those companies.  However, there were some hints that high quality electric power was enough of a concern that nuclear might be an acceptable option.

The other reason for this meeting was to broach the nuclear power option to the State.  The draft blueprint is potentially a referendum on its use.  I have no doubts that the anti-nuclear activists are frantically developing their plan to inundate the comment process with negative comments.  The political calculus of weighing the squeaky wheel crowd relative to the reliability of the wagon realists will be interesting.  Will the Administration admit that reliability and resiliency are not just slogans.

Conclusion

I remain convinced that the current Scoping Plan implementation will do more harm than good.  The Energy Summit could have been the start of a correction process that might reduce the inevitable increased risks to reliability, extraordinary price increases, and significant environmental impacts but that does not appear to be the case.  As I said before the Summit is another Macbeth story: “A tale told by an idiot, full of sound and fury, signifying nothing”.

New York Future Energy Economy Summit Pre-Meeting Update

On August 5 Governor Hochul announced a Future Energy Economy Summit that will “gather feedback on strategies to accelerate renewable energy deployment and explore the potential role of next generation clean energy technologies”.  I described my initial thoughts on the summit and possible outcomes earlier.  This post provides a pre-meeting update.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 450 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% 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 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.

Purpose

As I have noted previously there are many reasons why an assessment of the future energy economy is needed.  Three recent reports top the list.  The Public Service Commission (PSC) Clean Energy Standard Biennial Review Report found that the 70% renewable energy goal will likely not be achieved until at least 2033.  The New York State Comptroller Office Climate Act Goals – Planning, Procurements, and Progress Tracking audit found that the PSC and NYSERDA implementation plans did not comprise all essential components, including “assessing risks to meeting goals and projecting costs.”  The New York Independent System Operator (NYISO) 2023-2042 System & Resource Outlook described issues that threaten reliability and resilience of the current and future electric system. The Department of Public Service Proceeding 15-E-0302 may also be influencing the Governor and precipitating the need for the summit.   The Business Council of New York has cited those reports and gave other reasons why it is needed.  As a result, the governor said the state’s climate goals are something she “would love to meet, but also the cost has gone up so much. I now have to step back and say, ‘What is the cost on the typical New York family?’ Just like I did with congestion pricing.” 

Never forget that the Climate Act has always been mostly about politics and much less about rational energy policy.  I do not think that there is any question that this Summit is intended in part to gauge the reaction of favored political constituencies.  I have seen several notices from activist organizations calling for people to rally at the event against “false solutions” which I believe boils down to anything other than wind, solar, and energy storage.  With nuclear being at the top of the worst example of a false solution. 

In my opinion, the State must confront the possibility that the safety valve criteria in New York Public Service Law  § 66-p (4) for unsafe and inadequate electric service, impairment of existing obligations and agreements, and unacceptable increase in arrear or service disconnections will be exceeded.  I recently recommended that those criteria be specified so that there are quantifiable targets.  I hope that there are discussions that can further that requirement during the summit.

The other missing piece to date is the implementation plan for the transition.  The Scoping Plan is no more than a outline list of different strategies that someone has calculated will produce the emission reductions necessary and the energy required for New York State to meet the Climate Act mandates.  There is insufficient documentation to meaningfully critique the outline, and the Hochul Administration failed to respond to technical comments on the draft before it approved the Final draft.  A feasibility analysis has not been produced and must be included for a credible transition plan.  Better still would be a small-scale net-zero demonstration for an isolated jurisdiction that proves that an electric system can rely on intermittent wind and solar resources as the primary source of generation.  I hope that there will be discussion of this concept at the Summit.

Attendance

There is still no indication who will be on the panels.  In my original post I mentioned that I was worried that this would just be another dog and pony show. I cannot comment on this until I know who is on the panels.

Public participation has been restrictred  The meeting announcement mentioned that there was limited seating capacity for the event but at the same time it listed statements from eight different agencies.  I fail to see a connection between the Department of Health and Department of Labor with respect to energy policy.  If they send representatives, then fewer affected stakeholders or members of the public can attend.  I heard from several people who were waitlisted and asked a politician for help but did not get invited.  Contrary to my expectations, I managed to get invited.

Summit Agenda

On August 7 when I wrote the first summary of the Summit, I included the following list of sessions that had been posted:

  • Welcome Remarks and Morning Keynote
  • State of Technology
  • Status of Next Generation Energy Technologies
  • Luncheon Keynote
  • Insights from Large Consumers of Electricity
  • Global Perspectives: Representatives from other states and nations who are pursuing advanced nuclear installations.
  • New Nuclear Blueprint: Vet Draft Blueprint as framework for New Nuclear Master Plan
  • Wrap up and Next Steps

The agenda for the meeting on September 2 has changed.  The original first session “State of Technology” has been changed to “Accelerating Renewable Energy Deployment in New York State”.  The original first session “State of Technology” did not seem to be all that much different from the second session “Status of Next Generation Energy Technologies” so this makes sense.  However, the title “accelerating renewable energy deployment” suggests that no one is willing to conceded that building as much renewable energy as possible as fast as possible without a plan or feasibility analysis might not be a good idea.

At the PSC Zero Emissions by 2040 Technical Conference last December there were sessions devoted to pandering to real “false solutions” for a future economy.  Technology shills and activists subscribe to a dream that with enough energy conservation and “smart planning” the myriad problems identified by the organizations responsible for grid reliability can be ignored.  I fear that the Status of Next Generation Energy Technologies panel will include the same proposals without anyone on the panel providing contrary feedback.  It is long past time for the Hochul Administration to support the concerns expressed by the  PSC, NYISO and other organizations with reliability responsibilities and stop pretending that some of the cockamamie schemes suggested by irresponsible entities can provide meaningful future support.

The opening and luncheon keynote speakers will likely set the tone for the meeting.  One hour is set aside for the welcome and keynote presentations.  If that is nothing more than bragging about the “success” so far and excuses for the findings of the negative assessments, then I will have little hope for any meaningful results.  The same holds for the luncheon speaker.

One of the issues raised by the analyses to date is that loads will increase due to electrification of everything and new “Large Consumers of Electricity”.  The huge, proposed Micron chip fabrication plant is the prime example.  What are the odds that representatives from those facilities will tell the truth that unless there is demonstrated path to success or an alternative backup plan that it would be madness to invest billions of dollars because there is no assurance of reliable, affordable electricity.

The last two sessions address nuclear energy projects.  In my opinion, this is the primary driver of this Summit.  The only jurisdictions that have significantly reduced their GHG emissions from the electric sector without relying on hydro or geo-thermal resources used nuclear.  However, nuclear is unacceptable to many of the activists who are the strongest supporters of the Climate Act.  I have seen several pleas for people to come to rally against the false solutions.  The meeting was held in Syracuse and that just happens to be the closest city to three operating nuclear reactors.  I will be shocked if there aren’t visible signs of support from staff at those facilities.   

Conclusion

There are some encouraging signs that people are catching on that no matter how you feel about doing something about climate change the reality is that New York’s plan is deeply flawed.  I am convinced that the plan will do more harm than good.  The Energy Summit could be the start of a correction process that might reduce the inevitable increased risks to reliability, extraordinary price increases, and significant environmental impacts if there is no course correction.  On the other hand, it could be another story from Macbeth “A tale told by an idiot, full of sound and fury, signifying nothing”.

Stay tuned for an update later this week.

Offshore Wind Meets Reality

Last month I described a flurry of offshore wind related news and there have been enough stories since then for another update.  In my opinion these latest revelations suggest that a reassessment of the viability of offshore wind projects is in order.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 450 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% reduction by 2030. Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity has to be 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.

Offshore wind developments are a key Climate Act decarbonization strategy.  There is a mandated target of 9,000 MW of offshore wind by 2035.  The Integration Analysis projects that offshore wind capacity will exceed 13 GW by 2040.  However, there are overlooked risks to this strategy that are now becoming obvious.  The fact is that the huge, proposed wind turbines have not been field tested.

Turbine Blade Failures

Bud’s Offshore Energy reports that:

  • The “highly unusual and rare” talking point for turbine blade failures seems to have finally been discarded.
  • 3 new GE Haliade-X blades failed shortly after installation at Dogger Bank and Vineyard Wind. A total of only 48 turbines had been installed.

Bud’s Offshore Energy continues with some other thoughts:

  • The offshore safety regulator (BSEE) has a very capable technical staff and should produce an informed report on the Vineyard Wind blade failure. The concern is with the internal review process that has seriously delayed the publication of accident investigation reports and safety alerts.
  • Presumably, DNV, the Vineyard Wind CVA, will provide input into the BSEE investigation. Perhaps the effectiveness of the CVA process and quality control procedures should be separately considered.
  • Will Equinor, a major oil and gas producer, Dogger Bank partner, and offshore wind advocate, be investigating the Dogger Bank failures?
  • A comprehensive International data base on turbine incidents and performance is needed.
  • As previously noted, offshore substations are large structures. A closeup of the Vineyard Wind 1 substation is pasted below.

Consequences of Turbine Blade Failures

Paul Driessen points out that one broken wind turbine blade shut down Massachusetts beaches and asks what would happen if a hurricane struck.  He describes the impact of the Vineyard Wind failure:

Shards, chunks and finally the rest of a turbine blade fell into the ocean. One blade … from a 62-turbine project that’s only three-fourths completed … broken by its own weight, not by a storm.

And yet beaches had to be closed amid peak tourist season, while crews picked up pieces of fiberglass-resin-plastic-foam blades, and boats dodged big pieces floating in the water. Worse, Vineyard Wind didn’t tell Nantucket officials about the problems until two days after the blade began disintegrating.

Each blade is 350 feet long and 140,000 pounds. That’s more than a fully occupied Boeing 737 jetliner. Vineyard Wind involves 186 blades: 65,000 feet (12 miles) in total combined length, weighing in at a combined 26,000,000 pounds!

Vineyard Wind will have 62 wind turbines and a total capacity of 800 MW.  Driessen notes that:

The Biden-Harris offshore wind plan calls for 30,000 megawatts of generating capacity by 2030. That’s 2,500 gigantic 12-MW offshore turbines. That won’t even meet New York State’s current peak summer electricity needs, before all these extra demands kick in. Offshore wind’s contribution toward meeting future demands for all Atlantic Coast states could easily require 5,000 such turbines: 15,000 blades, weighing a combined 2 billion pounds and spanning a combined 5,250,000 feet (995 miles)!

Source posted by Brian J @Mainsail23

He points out the obvious problem that the planned offshore wind facilities on the East Coast can all be affected by hurricanes:

Even more disturbing, the entire Atlantic coastline is hurricane country. Every year, almost without fail. The only questions are how many hurricanes, how powerful, and where each one will hit.

NOAA records for landfalling hurricanes – those that actually hit US beaches and cities – reveal that 105 Category 1-5 hurricanes struck the Atlantic seaboard, from Florida to Maine, from 1851 through 2023. Add in those that remained at sea, where the turbines will be, and that number could double.

Of that total, 23 were Category 3-5 (111-157 or higher mph winds). Most struck Florida, Georgia and South Carolina. But 39 made landfall between North Carolina and Delaware – and 19 hit Northeastern States, including nine Category 2-3 monsters (96-129 mph winds).

Mind you – these turbines will be weakened by constant corrosive salt spray and frequently by sub-hurricane storms. When the inevitable big hurricane roars up the coast, devastation will follow.

The 1935 Labor Day Hurricane clobbered Florida with 200+ mph devastation, Georgia with Category 1 winds. The Great New England Hurricane of 1938 smashed into New York, Connecticut, Rhode Island and Massachusetts with 115-120 mph force. 1944’s Great Atlantic Hurricane – punished the coast from North Carolina to New Jersey and Massachusetts with Category 2 winds.

Edna hit the Northeast with Category 2 winds in 1954, Donna did it again in 1960, and Gloria clobbered the region with 96-115 mph blasts in 1985, even reaching New Hampshire and Maine! Isabel hit North Carolina and Virginia in 2003. The “minor” Category 1 hurricane of 2012, better known as Superstorm Sandy, was also devastating.

This summary includes just some that hit North and Mid-Atlantic States, and a few that slammed Florida, Georgia and South Carolina – all prime territory for forests of offshore turbines, fixed to the seafloor or insanely sitting atop enormous floating platforms off Maine and other states. They’d all flounder.

I have found one reference to offshore wind turbine expectations relative to hurricanes.  Our EnergyPolicy (OEP) hosted a panel discussion on New York State’s emerging offshore wind market and the policy and business challenges facing this evolving sector, in its Energy Leaders Luncheon Series December 2019 event in New York City.  The question was asked “Will wind turbines in New York be able to withstand a Category 5 storm?”

Clint Plummer who was the head of market strategies and new projects for Ørsted, the world’s largest owner, developer, and operator of offshore wind responded that “wind turbines are designed to withstand a Category 3 hurricane, and they have built into their permit applications an insurance fund that can pay for repairs in cases of catastrophic loss from a storm more severe”. He said “a Category 5 hurricane has a return period in excess of 100 years, while the design life of a wind farm is 30-35 years, so wind turbines are not designed to withstand a Category 5 storm because they are not expected to experience one”. “Anything less than that up to a certain speed is just a really good day for producing a lot of wind power,” he said

At the time of this response the offshore wind turbines proposed were smaller.  Since then, the quest for higher capacity availability has led to bigger turbines that recent events suggest may not be as robust as the smaller designs.  It is conceivable that when a hurricane with intensities like those observed inevitably reoccurs after the massive buildouts proposed are in place that many (most?) wind turbine blades will fail.  Driessen argues that it will take months or years to replace widespread broken wind turbine blades and that it may require the construction of alternative generating sources:

Hopefully, politicians and bureaucrats could expedite new gas turbine and modular nuclear power plants. That would mean only a few years of deprivation and blackouts, instead of many years, perhaps decades.

Otherwise, floating slabs of broken turbine blades would endanger boats for months or years, until they are retrieved, hauled ashore and landfilled. Cleaning up billions of sharp shards of fiberglass – each an inch to a couple feet in length, and nearly invisible – would likely take decades, during which time they would impale and imperil beach walkers, swimmers, fish, whales, dolphins and other marine life.

I’m not a microbiologist, but I’m not aware of any microbes that devour fiberglass, resin or plastic foam.

With no bonds or requirements that Big Wind cover cleanup and turbine removal costs, electricity-bereft taxpayers and ratepayers would be left holding the bag.

Before we rush any further into this “renewable energy transformation,” can we first have some realistic, commonsense analysis? Can we at least think before casting our ballots this fall?

Maine’s Floating Turbines

As if the construction of wind turbines on fixed platforms is not enough of a challenge there are proposals for floating wind turbines. Bud’s Offshore Energy noted that recent bids on lease areas were much lower than previous sales.  

David Wojick describes the curious first lease for floating offshore wind turbines in the Gulf of Maine.  The State of Maine was awarded the lease which is described as a research lease rather than a commercial development lease. 

To begin with, the lease is for a 144 MW “research array” of turbines, as it is called. Well, 144 MW is huge for research. The South Fork Wind site (fixed, not floating) that is already running is a 12-turbine, 132 MW commercial facility, so this array will be bigger than commercial.

It could cost $3 billion-plus the cost of the factory to make the dozen or so floaters. Different websites suggest different turbine sizes from 10 to 12 MW. Of course, if this is really research, they might use a variety of sizes, but the total is still huge.

Why so big is the first mystery, and the official explanations are far too vague to justify it. They mostly talk about research into things like efficiency, supply chain, and even jobs.

Wojick makes a couple of other points.  This “research” lease development is occurring at the same time there are commercial developments underway so the results will not benefit project developments.  The payment structure of this project is mirky: “if a Purchase Power Agreement (PPA) is supposed to pay for the array, plus profit, then it is very much a commercial development meanwhile research is expensive and unpredictable so how can there be an advance PPA to pay for it?”. 

He suggests that there is another possibility: “This project is not about research it is about building the floater factory and demonstrating the University of Maine technology.” 

There is a monster wild card in the floating wind game, and that is the factory. Fixed bottom wind is very simple onshore. All you need is a good dock, a big crane, and a place to sit the components until they are taken to the site and installed. There are just a few simple components — monopile, tower, turbine, and blades. It is all made elsewhere.

Floating wind is made from scratch onshore then towed as a whole to the offshore site. The Uni-patented technology uses concrete floaters which might weigh 15,000 tons or more and are complex structures. Factory construction of floaters will be a huge job.

This fact about floating wind is seldom mentioned, and when it is, the language is usually deceptive. The industry talks about “ports,” not factories, and the Maine floater factory is called a port. See my. note that the factory will be operated by Diamond.

So here is what might happen. As part of the “research” Maine builds the floater factory and enough floaters to demonstrate that the patented Uni- technology works. Developers of the 15,000 MW of commercial Gulf wind have to choose technologies for their various sites. If they choose any other technology, out of over a hundred candidates, they will have to build the factory to make it.

Once the floater factory is built then a powerful incentive to use it exists.  Given that they are talking about $100 billion in floaters the developers, the State of Maine and the University of Maine will make a huge amount of money.  Of course, the money has to come from somewhere so expect the ratepayers in Maine to be on the hook for that.  Wojick concludes:

Mind you I am not claiming this is what is going on, but it certainly makes sense out of this supposed research array. The primary obstacle is that the Uni-technology has never been built at 10-12 MW scale and it might not be feasible. Also, the factory design that I have seen does not work, but that is a separate issue.

Hot Air Renewable Notes

Beege Welborn has a nice overview article: Blade Failures Continue and Don’t Go Missing in an Offshore Wind Farm on the Hot Air website.  The article describes blade failures in Missouri, covers the problems at Vineyard Wind, notes that the plans for huge offshore wind farms require mind-boggling amounts of material, and notes that there are radar interference issues with planes and offshore wind farms.  Finally the article includes a reference to an incident where “wind industry henchmen are showing their true colors during citizen meetings”. The thug” walked up and grabbed” a bag belonging to a woman showing fiberglass shards that washed ashore from the damaged turbine while she attempted to explain her concerns about offshore wind development at a Newport, RI wind farm forum.  The guy had been featured at Senator Sheldon Whitehouse’s website until the incident.  Thankfully, the goon’s facing assault charges.

Conclusion

The Hochul Administration’s Integration Analysis projects that offshore wind capacity will exceed 13 GW by 2040.  These latest revelations suggest that a reassessment of the viability of offshore wind projects is in order. The technology has not been tested on the scale proposed and it sure appears that there are survivability issues even without storms.  What could possibly go wrong?

Cassadaga Wind Concerns

Rich Ellenbogen sent an email today after receiving a link to a video describing the construction of the Cassadaga Wind Farm in Chautauqua County, New York.  Rich describes the video, provides some background information, and expresses concern about end-of-use disposal.  The email triggered a recollection of an article about a post by Robert Bryce that found that the output from the facility was contracted to New England.  I have combined Rich’s email with relevant parts of my earlier article in this post.

Ellenbogen is the President [BIO] Allied Converters and frequently copies me on emails that address various issues associated with the Climate Leadership and Community Protection Act (Climate Act). I have published other articles by Ellenbogen including a description of his keynote address to the Business Council of New York 2023 Renewable Energy Conference Energy titled: “Energy on Demand as the Life Blood of Business and Entrepreneurship in the State -video here:  Why NY State Must Rethink Its Energy Plan and Ten Suggestions to Help Fix the Problems” and another video presentation he developed describing problems with Climate Act implementation.   He comes to the table as an engineer who truly cares about the environment and as an early adopter of renewable technologies going back to the 1990’s at both his home and business two decades ago.

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 450 articles about New York’s net-zero transition. I have over 40 yers experience with New York energy and environmental issues.  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% reduction by 2030. Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity has to be 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.

Current projections for land-based wind in New York State in 2040 when all electricity must be generated by “zero-emissions” resources range from 15,549 MW in the New York Independent System Operator 2023-2042 System & Resource Outlook (State Scenario Capacity Expansion Model Results – No Headroom case) to the 13,096 MW in the latest Integration Analysis.  In 2021 there were 2,277 MW of land-based wind so in the next 19 years between 13,322 and 10,869 MW more wind capacity is projected.

 Ellenbogen Summary

In this section I have edited and reformatted the material in Ellenbogen’s email.

The video Green Madness – The Waste and Destruction Caused by One Industrial Wind Project  was made by people in western New York whose beautiful countryside has been damaged by industrial wind. The compelling video shows the massive destruction involved.  For scale here is a satellite view from Bing maps.

Source: Bing Maps Several miles SW of Cherry Creek, NY

Ellenbogen continues noting that what is happening now in New York State is very similar to what occurred in Ontario in 2018 – 2019 that led to a change in the government.  Now they are tearing down completed wind farms.  It started with a “rebellion” in the rural areas because of the exact same thing that is shown in the video and then progressed to the urban areas when the energy prices spiked. 

Someone else that received the video sent the chart below that shows the materials needed to generate one megawatt hour of electricity with the different technologies.  The 20% capacity factor for solar is high for NY State so the Material per MWh will be higher.

Ellenbogen notes that upstate residents are not only angry with the amount of material used and the clear cutting of large amounts of forest but also the net holistic impact on the environment, especially when considering the end of life disposal.  This link documents the issue that a town in Minnesota is having with that.

Seriously, this sucks’: How a small Minnesota town was left with a giant pile of wind turbine blades Grand Meadow wants someone to get rid of the mess after a failed effort to recycle the massive, worn-out parts.

The article

By Walker Orenstein

In the Minnesota Star Tribune states:

GRAND MEADOW, MINN. – Darcy Richardson had big plans for a garden patio enveloped by flowers in her backyard in this little community south of Rochester.

She gave up once the blades arrived.

Trucks dropped off more than 100 fiberglass turbine blades on the empty lot next door in 2020, haphazardly stacked to the edge of Richardson’s property. Almost four years later, the mountain of old wind parts — which is visible on Google Earth — is still there.

Some blades are cracked and stained. Locals say they draw feral cats and foxes and are a safety risk because kids climb on the junk.

They’re also ugly, ruining Richardson’s view, hurting property values and attracting the curiosity of seemingly everyone who drives the highway into town.

Cassadaga Wind Farm Energy Contract

I found that the story for this wind farm is even worse.   Robert Bryce, writing on the Real Clear Energy blog described an aspect of New York wind development that I wrote an article  about in June 2020.

Bryce explained how New York is becoming “a wind-energy plantation for New England” with massive projects proposed in the state’s poorest counties.  In particular, he describes one project:

“The 126-megawatt Cassadaga Wind Project is now being built in Chautauqua County, New York’s westernmost county. The project includes 37 turbines, each standing about 500 feet high, spread over 40,000 acres (62 square miles). The project is owned by Innogy, a subsidiary of the Essen, German-based utility E.On.”

On January 18, 2018, the New York Department of Public Service published the Order Granting Certificate of Environmental Compatibility and Public Need, With Conditions which approves the application to build the facility.  Buried in this document is the following: “the output of the Facility is contracted for out-of-state purchase”.  Mr. Bryce explains that generation will be credited toward renewable goals in Massachusetts, Connecticut and Rhode Island.  He notes that in an email:

“a spokesperson for Innogy confirmed that the buyer of the power to be produced by Cassadaga is a group of seven New England utilities procured through the New England Clean Energy request for proposals’ in 2016. How will the juice from New York get to New England? It won’t. Instead, the Innogy spokesperson told me that the energy produced by the turbines at Cassadaga ‘will be used to serve local energy requirements in areas surrounding the project. Export to areas outside New York would require dedicated point-to-point transmission lines’.”

Mr. Bryce also reviewed data published by the Department of Energy and the New England Power Pool to look the overall picture.  He found that “of the nearly 4 million megawatt-hours of wind energy produced in New York in 2018, the state exported 1.2 million megawatt-hours, or 30 percent, to New England. When the Cassadaga wind project begins operating, it will likely add another 364,000 megawatt-hours per year in renewable-energy credits to that export total”.

As a result, the Cassadaga Wind Farm cannot be considered as part of the renewable energy that should not be included in the Climate Act renewable energy credit claims because that would be double counting.  I have no idea how many other NY facilities have renewable energy credit agreements with New England, but I bet it is not zero.

The Cassadaga permit application approval Order Granting Certificate of Environmental Compatibility and Public Need, With Conditions noted that the output of the facility will be credited out-of-state:

“As the Examiners demonstrated, the goals of the State Energy Plan are not restricted to renewable electricity consumed within the state, but are also oriented toward national and international goals of reducing carbon and transforming the energy industry. For that reason, the Examiners’ finding was not changed by the fact that the output of the Facility is contracted for out-of-state purchase. This conclusion is bolstered by the decision of the Appellate Decision in a previous Article X proceeding that production of electricity within the state is beneficial irrespective of the contract path of the output. No party took exception to the RD’s proposed findings and determinations on this issue, and we adopt them.”

Conclusion

There are 37 wind turbines in the Cassadaga project.  There are 27 Nordex N117 turbines rated at 3.675 MW and 10 Siemens Gamesa Renewable Energy G114-2.625 MW turbines rated at 2.625 MW.  Recall that the NYISO Resource Outlook and the Integration Analysis have projected that between 13,322 and 10,869 MW more wind capacity will be needed.  That means that there will be at least 2,958 new turbines and could be as many as 5,075 turbines.  That means impacts on the order of 100 times those shown in the video will be coming soon to New York State.

I have yet to see any acknowledgement of this kind of contract’s impact on Climate Act renewable energy accounting. This is another complication ignored by the Scoping Plan implementation program. Acknowledgement of the issue would make compliance harder so it is not surprising that it has been ignored.

It never ceases to amaze me how every single aspect of the Climate Act transition is more complicated and uncertain than acknowledged by the Hochul Adminstration. Those factors certainly will add to the ultimate costs and make it less likely that the political aspirations can overcome reality. This is madness.