Category: Climate Act Feasibility

Update 8/26/24: Riverhead local published my response to the original op-ed

In a recent article describing a new category of generating resources called Dispatchable Emissions-Free Resources (DEFR) I noted there still are people who maintain that existing technologies—led by solar and wind—can solve the climate crisis.  A recent op-ed titled “With New York’s climate action goals in question, governor’s comments on future role of nuclear power worry environmental advocates” at Riverhead Local provides an example.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 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 company or 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 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.

Three recent reports all have suggested that implementation of the Climate Act is not going as planned and that reassessment is necessary.  The Public Service Commission (PSC) Clean Energy Standard Biennial Review Report found that the 70% renewable energy goal will likely not be achieved until 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.

Dispatchable Emissions-Free Resources

One of the most important reliability issues is the need for a new category of generating resources called Dispatchable Emissions-Free Resources (DEFR) necessary for a future grid that depends upon wind, solar, and energy storage resources. Reputable analyses of the future New York electric system agree that new technologies are necessary to keep the lights on during periods of extended low wind and solar resource availability.  Despite the overwhelming consensus of the organizations responsible for keeping the lights on that DEFR is needed there are people who believe otherwise.

One such person is Karl Grossman.  According to his bio published with the op-ed:

Karl is a veteran investigative reporter and columnist, the winner of numerous awards for his work and a member of the L.I. Journalism Hall of Fame. He is a professor of journalism at SUNY at Old Westbury and the author of eight books.

The basis of Grossman’s belief is Dr. Mark Z. Jacobson’s 2023 book “No Miracles Needed: How Today’s Technology Can Save Our Climate and Clean Our Air.”   Grossman interviewed Jacobson and quoted him as saying: “Whether New York can reach the 70% goal by 2030 is a matter of social and political willpower. It is not a question of technology or economics.” 

Grossman describes Jacobson’s claims, but I am not going to respond to those claims in detail.  In my recent article about DEFR I explained why I know that Jacobson is wrong.  In brief, I found six analyses describing the need for new technology: the Integration Analysis, New York Department of Public Service (DPS) Proceeding 15-E-0302 Technical Conference, NYISO Resource Outlook, Richard Ellenbogen, Cornell Biology and Environmental Engineering, and Nuclear New York.  Jacobson and his protégé Dr. Robert Howarth frequently refer to their “peer-reviewed” work as validation but neglect the rebuttal peer-reviewed responses to their work and the many other peer-reviewed analyses that show DEFR is needed.  Finally, I also found three books that refute the Jacobson book and his claims that the energy transition can be accomplished with no new technologies at low cost with large benefits.

Environmentalist Responses

I recently noted that Governor Hochul seems to be floating the idea that reassessment is necessary.  Grossman noted that Newsday headlined a two-page spread two weeks ago: “Hochul Says New York Won’t Meet 2030 Climate Goal.” In the article, Newsday cited Gov. Kathy Hochul’s comments in an Albany Times Union newspaper podcast.

“We’re gonna get to our goals, but if we miss it by a couple of years—which is probably what’ll happen—the goals are still worthwhile,” Hochul said. But we have to think about the collateral damage of all of our major decisions… either mitigate them or you have to rethink them.” In the podcast, she also termed herself as “a staunch environmentalist.”

The Grossman op-ed described how environmentalists are reacting.  Not surprisingly they still claim that the state has not done enough on renewable energy.

Judith Enck, for seven years regional administrator of the U.S. Environmental Protection Agency for an area that includes New York State and before that deputy secretary for the environment for two New York governors, said delaying the 70% goal “is a terrible decision by the governor. I hope she revisits it. We’re in a climate crisis. She says things have changed—and they have: the climate crisis has gotten worse. The governor should look at ways to accelerate meeting the goals, not delaying them.” Renewable energy, she said, is not a priority for state government.

Liz Moran, New York political advocate for the group Earthjustice, said: “The administration has been appearing to slow walk it from the jump. It’s a fear-based approach rather than a brave and bold approach that we need in the face of this crisis.” 

“We’re certainly not ready to wave the white flag,” said Julie Tighe, president of the New York League of Conservation Voters.

Environmental advocates such as these ignore or disparage analyses such as the NYISO 2023-2042 System & Resource Outlook that describes issues that threaten reliability and resilience of the electric system.  I recently described how the proposed transition that relies on wind and solar exacerbates their concerns. Unfortunately, the document is full of technical jargon and politically correct terminology, so the full implications of this analysis are not readily apparent.  NYISO cannot bluntly say this cannot work as proposed on the schedule mandated but that is the underlying message.

Environmental advocates also ignore New York’s role in this global problem.  Using GHG emissions data from Our World In Data I looked at recent NY emissions with global data.  In 2021, NYS GHG emissions (GWP-100) were 247 million metric tonnes (MMT).  GHG emissions from China were 13,774 MMT and from India were 3,879 MMT.  The increase in emission from 2020 to 2021 were 498 MMT in China and 265 MMT in India.  New York emissions will be supplanted by emissions from China or India in less than one year.  Overall, New York’s emissions are less than a half a percent of global emissions.  This does not necessarily mean that we should not do something, but it does mean that meeting the arbitrary goals of the Climate Act will not have a meaningful impact on global warming impacts.

Grossman’s op-ed goes on:

Meanwhile, Politico published a report in May headlined “New York policymakers thaw on nuclear energy.” The piece by Marie J. French began: “Gov. Kathy Hochul has cracked the door open to the potential for new, small nuclear power plants as a way for the state to try to meet its ambitious climate coals.”

The article told of this happening “at a private dinner with environmentalists April 29, according to two attendees who spoke on the condition of anonymity because of the private conversations. It’s not the first time that her administration has raised the idea. One of her top aides suggested as much earlier this year.”

Enck said last week: “I think the governor even speculating on nuclear power in New York is trouble.” Enck spoke of how decades were spent in “shutting down the Indian Point nuclear plants” 25 miles north of New York City. We “shouldn’t promote the same thing again.”

Nuclear is the only proven DEFR technology that can be expanded sufficiently to fulfill the energy requirements of the Climate Act goals.  Nuclear energy generates zero-emissions electricity, provides firm power that does not require supplemental ancillary transmission support, has low land-use requirements, and requires less transmission development than wind and solar.  The dangers of nuclear are consistently over-hyped.   Bill Gates has pointed out that “nuclear energy, in terms of an overall safety record, is better than other energy.”  It is a mystery to me why any environmental advocate continues to harbor this irrational fear of nuclear power and consider its use troubling,

Discussion

Grossman concludes:

The central message of Jacobson’s “No Miracles Needed” book is how existing technologies—led by solar and wind—can solve the climate crisis, and he emphasizes how nuclear power is not needed and also investing in it would obstruct a transition to green renewable energy.

I conclude Grossman has naively backed the wrong source for this op-ed.  Even the Climate Act Scoping Plan acknowledges the need for the new DEFR technology directly contradicting Jacobson’s primary claim.  The Scoping Plan also contradicts all the other cost, schedule, and technology requirement claims made by Jacobson.  The NYISO 2023-2042 System & Resource Outlook findings are consistent with the Scoping Plan.  In my opinion, the arguments of anyone who does not face any repercussions if proven wrong should be given much less weight than arguments from those who have responsibilities.

With regards to the nuclear power recommendations Grossman is also wrong.  The article does not provide any rationale for not developing nuclear other it would obstruct the transition to green renewable energy.  The fact is that France successful cut its GHG emissions using nuclear power, but no jurisdiction has managed similar electric sector reductions relying on wind and solar.  As a utility meteorologist with over 40 years’ experience I think the variability of wind and solar is an insurmountable challenge for a reliable electric grid.  In my opinion, one of the advantages of nuclear is that it would preclude the need for “green renewable energy”.

Conclusion

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”.  Grossman’s op-ed is the first article I have seen to suggest that nuclear power should not be one of the next generation clean energy technologies.  In my article describing the announcement of the summit I noted that it will be interesting to see how legislators, the Big Green NGOs, climate activists, and the renewable energy shills react to nuclear power. Based on this article it appears Big Green NGOs and climate activists will not acknowledge that nuclear and other pragmatic considerations are necessary for the Climate Act implementation.

The New York Independent System Operator recently released the 2023-2042 System & Resource Outlook (“Outlook”).  It examines “a wide range of potential future system conditions and compares possible pathways to an increasingly greener resource mix.”  This post summarizes the key findings of Appendix E: New York Renewable Profiles and Variability.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 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 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, a 70% electric system renewable energy  mandate 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 used to reduce greenhouse gas emissions.  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, Public Service Commission orders, and legislation.

Overview of the Outlook Report

I provided an overview of the NYISO 2023-2042 System & Resource Outlook earlier.  The document and 11 appendices are available at the NYISO website:

• 2023-2042 Outlook Report
• Appendix A – Production Cost Model Benchmark
• Appendix B – Production Cost Assumptions Matrix
• Appendix C – Capacity Expansion Assumptions Matrix
• Appendix D – Modeling & Methodologies
• Appendix E – Renewable Profiles & Variability
• Appendix F – Dispatchable Emission-Free Resources
• Appendix G – Production Cost Model Results
• Appendix H – Capacity Expansion Model Results
• Appendix I – Transmission Congestion Analysis
• Appendix J – Renewable Generation Pockets
• Appendix K – Capacity Expansion Model Sensitivities

The Executive Summary explains that:

• The Outlook examines a wide range of potential future system conditions and compares possible pathways to an increasingly greener resource mix. By simulating several possible future system configurations and forecasting the transmission constraints for each, the NYISO:
• Postulates possible resource mixes that achieve New York’s public policy mandates, while maintaining reserve margins, and capacity requirements;
• Identifies regions of New York where renewable or other resources may be unable to generate at their full capability due to transmission constraints;
• Quantifies the extent to which these transmission constraints limit delivery of renewable energy to consumers; and
• Highlights potential opportunities for transmission investment that may provide economic, policy, and/or operational benefits.

Renewable Resource Characterization

The information presented in Appendix E was developed by DNV.  They modeled “long-term hourly simulated weather and generation profiles for representative offshore wind (OSW), land-based wind (LBW), and utility- scale solar (UPV) generators” in two phases.  Initially DNV assessed the OSW production for seven locations.   In the second phase, the analyzed LBW and UPV generation for nearly 80 LBW and UPV locations each throughout the state.  The projections were used to “determine the zonal or county aggregate net capacity factor (NCF) profiles that the NYISO used as inputs for this Outlook.

The goal of this work is to estimate the energy production of LBW, OSW, and solar—both UPV and behind the meter (BTM) PV.  The report explains:

The production amounts of each type of generation are considered when determining the representative days selected for the capacity expansion model and are used as hourly generation shapes in the production cost model for this Outlook.  The NYISO acknowledges that advances in renewable energy technology are continuously occurring and can lead to improved performance among generators built in the later years of the study period. Offsetting this effect, however, is that better sites may be utilized before less favorable resource sites leading to older technology on more favorable sites. Moreover, once installed, equipment performance can degrade over time. While these impacts are known, the exact magnitude of the impacts is difficult to quantify. Accordingly, this Outlook does not make any assumptions about improved performance of renewable generators built in the later years of the study period or performance degradation of resources once in operation.

The NCF data can be combined with hypothetical wind and solar projects sited throughout the state and in the New York Bight on the Outer Continental Shelf to estimate the generation production that represents actual historical weather conditions.  As the report notes: “The increasing weather dependent supply resources and electrified load will necessitate more attention be paid to the modeling of spatiotemporally correlated renewable generation and loads in long-term planning studies.”

These data can be used in multiple ways: “Resource production profiles can be characterized in various ways to describe interannual variability in, for example, resource output, hourly ramps, variability, and duration of low output.”

Metrics for Characterizing Renewable Production

There is a lot of information in this report that can be used to describe how renewable energy production will be affected by weather.  For example, Figure 1 shows the interannual variation for the net capacity factor of land-based wind (LBW), utility-scale solar photovoltaic (UPV), and offshore wind (OSW).  Net capacity factor (NCF) is the annual amount of electrical energy produced divided by the maximum potential energy that could be produced.  This parameter is used to determine how many resources need to be built to provide sufficient generation production to supply the necessary load.  The Integration Analysis assumed a single capacity factor value for the three generating resources and these figures show that a proper analysis of resource requirements needs to address the variability shown.

Figure E-1: Annual Capacity Factor of UPV, LBW, and OSW: 2030 Contract Case

I derived the latest Integration Analysis capacity factors from the total capacity (MW) and annual energy production (MWh).  I calculated that the 2040 projected LBW capacity factor was 37%, OSW capacity factor was 47%, and the solar capacity factor was 21%.  I eyeballed the capacity factors in Figure E-1 for Table 1 that lists annual capacity factors.  The projected mean annual capacity factors were less than the Integration Analysis for LBW and OSW while the solar projection was more than the Integration Analysis value.  This means that the wind generation capacity resources projected by the Integration Analysis are insufficient to meet the average resource availability.  It would be much easier for electric resource projections if planners only had to worry about average resource availability, but to provide electricity all the time planners need to consider the worst-case scenario.  The minimum average annual capacity factor over this 22-year period was less than the Integration Analysis projections for all three resource categories.  This means that the Integration Analysis underestimates the average generating resources needed and thus the costs of implementation.

Table 1: Annual Capacity Factors

The figures in Appendix E include results for the entire 22-year period of record and 2018.  The NYISO report supports their resource adequacy planning efforts that focus on an individual year, in this case 2018.  Appendix E notes that “understanding the variation in production over the years by comparing the annual capacity factors by technology type provides an initial indication of the energy impact of the choice of 2018 relative to other years in the DNV database.” For this article, I only present the combined 2000-2001 results and have modified the following quoted text to exclude any references to 2018. The Appendix describes the characterization approach:  

Renewable production profiles can be characterized on a more granular level by examining statistics within individual month and hour bins. Commonly referred to as “twelve by twenty-fours” (12×24), this calculation allows the diurnal and seasonal contributions of different renewable generation types to be accessed from the hourly timeseries. Further comparison of the net load provides insight on when and how much other supply resources are needed across the year and when there is a potential for renewable oversupply (i.e., negative net loads).

The graphics below present the hourly and monthly average NCF by technology type and present the NCF of the capacity weighted aggregation of UPV, LBW, and OSW. The figures show the averages over the 22-year period (2000-2021)

A number of salient features of the input data can be observed using this methodology. The concentration of UPV generation in the summer and mid-day hours is clearly observed, as well as comparably lower UPV generation in the winter months due to shorter daytime periods. In the shoulder months, UPV production is slightly higher in the spring relative to the fall. On the other hand, production of both LBW and OSW is concentrated on average to the winter evening hours, with this impact more pronounced for OSW than LBW. Across the board, OSW produces at higher NCF levels than LBW. The combined impact of the wind and UPV display clear features of each of the technologies with the highest overall renewable production during the summer mid-day. The lowest production persists during the evening hours in the summer and early fall with fleet capacity factors under 20% on average.

Electric resource planners need to consider these observations in their capacity resource projections.  As noted previously, the planners cannot rely on projections based on annual averages because generation must always match load.  The proposed dependence wind and solar means the resource availability considerations described above must be considered for future resource projections.  These results are the most comprehensive estimates for New York to date.  In short, they make all the Integration Analysis projections obsolete.

Figure E-2: “12×24” Average Net Capacity Factors for UPV, LBW, OSW, and Combined: 2030 Contract Case

The Appendix explains why this information is important:

By comparing renewable energy supply to the timing of the expected load, the remaining supply resources needed to serve demand (e.g., hydro, nuclear, imports, fossil-fuel and other generation, storage, and DEFRs) can be better understood. Using a similar framework to simplify the comparison, the figure below displays the variability in net load by displaying 12×24 charts for average, minimum, and maximum net load in GW. The figure displays net load over the 22-year period (assuming the same load in each year but varying the renewable energy shapes).

The Appendix goes on to describe an alternate way to present the data that focuses on supply requirements:

Average net loads are highest in the summer and winter evening hours after sunset. This indicates the need for additional supply beyond the assumed wind and solar resources to meet expected demand. Net loads are lowest during the mid-day spring and fall months when loads are lower and renewable energy production is generally high. The minimum net loads, which may be negative, provide an indication of the minimum generation levels needed from the remaining fleet when loads are lowest and renewable output is high. Negative net loads indicate intervals where the renewable energy supplied by wind and solar resources exceeds the demand on the New York Contral Area and coincides with times of low average net load during the shoulder mid-day periods, primarily due to the concentration of solar output.

Figure E-3: “12×24” Average, Minimum, and Maximum Net Loads (GW): 2030 Contract Case

The Appendix briefly describes how these observations could be addressed:

Storage resources would potentially be able to shift a significant amount of this excess mid-day renewable output during the day or across a few days. However, storage resources may not be fully capable of economically addressing the seasonal mismatch between times of low and negative net loads in the shoulder seasons and high positive net loads during peak season after the sun goes down. This impact is only exacerbated as weather-dependent electrified load (e.g., building heating) increases the potential peak load sensitivity of the system during temperature or weather extremes. This results in the requirement for even further supply resources to meet the larger net load peak without significant efforts to mitigate the potential peak load growth impacts.

After a discussion of ramping rate implications, the Appendix goes on to address low renewable resource availability ramifications and the analysis performed:

Characterization of the magnitude and frequency of low output intervals of renewable output is an important consideration when analyzing the impact of serving demand during longer duration events of low renewable production. Different output levels and durations must be considered, and one threshold must be selected to perform this analysis on an input renewable generation profile. For this analysis, low output events, or lulls, are defined as continuous durations where the production is below the identified threshold. Events are then binned by the duration of the number of hours for each event for each year. This analysis was performed for LBW, OSW, and a combination of LBW, OSW, and UPV to examine the impact of the combined assumed renewable fleet on the number of lulls of a given set of duration bins.

This issue has always been my biggest concern, so I was glad to see it addressed.  Note, however, that the threshold selected makes all the difference in the results.  The analysis presented uses a 10% NCF threshold which means that 90% of the resource capacity is unavailable.  The question is what threshold should be used.  This is a new planning criterion that should be watched carefully.  The results show:

Figure E-6 presents the results of reviewing the LBW profiles over the 2000-2021 period on an annual basis assuming a 10% hourly NCF threshold (i.e., lull hours are defined as those with a NCF less than 0.1). The x-axis displays the event duration bins (e.g., “[1,4]” collect all one-to-four-hour events while “97+” collects all events that are 97 hours or longer) except for the last bin that displays the longest duration event in hours during the year. Each bar within a bin going from left to right represents the number of events in each duration bin for one year from 2000-2021, with 2018 labeled with black bars and the corresponding number of events. The dashed line across each bin shows the average value of the number of lulls (and maximum duration) across the 22-year period. The analysis shows that, in 2018, the longest event where LBW output stayed below 10% of capacity across New York was 83 hours long and there were 12 events between 25 and 48 hours long. The chart also shows that there were less short duration LBW lull events in 2018 relative to the 22-year average but that there were in general more lulls longer than one day in duration than in a typical year.

The Appendix also presents results for OSW:

Comparison of the DNV renewable production shapes shows that LBW has more and longer wind lulls than the OSW shapes. This is expected, in part, as OSW has higher average capacity factors as shown in the monthly-hourly analysis earlier in this section.

The combination of resource lulls is most useful for planning:

Combining the LBW, OSW, and UPV shapes on a capacity weighted basis and performing the same analysis results in less lulls of all durations because the diversity in timing of production from the different generation types has the effect removing or splitting longer lulls into more shorter events.

I modified Figure E-8 to highlight the worst-case duration of a combined lull as shown by the red line.  It appears that there was a 36 period when 90% of the OSW, LBW and UPV resources were unavailable.  Keep in mind that light winds are associated with high-pressure system weather that also correlates highly with extreme cold and hot temperatures that mean high electric loads.  This has resource planning ramifications that must also be addressed.

The Appendix concludes:

Analysis of the input renewable and load shapes over the course of a single year can provide significant information about when additional resources will most likely be needed to provide additional supply to the system. Using the 22-years of simulated renewable NCF profiles applied to the zonal capacity mix in the 2030 Contract Case provides significant insight into general system characteristics and potential needs for additional supply resources. Comparative review of these metrics for the 2035 Lower and Higher Demand scenarios in the Policy Case shows largely similar features across all of the discussed metrics but with larger impacts due to the higher loads and slightly larger renewable builds present in the 2035 Policy Case relative to the 2030 Contract Case.

Discussion

The NYISO has started to incorporate weather variability in future planning for an electric system that depends on wind and solar resources.  I want to make two points.

The current NYISO resource adequacy planning process is based on decades of experience with the existing system that relies on fossil, nuclear, and hydro resources.  Over the years, the resource planners have developed a good idea how much surplus capacity is needed on the system to ensure that when the load peaks that there will be adequate generation in place to service the load.  Those projections are based on the fact that outages across the system are not correlated for the most part.  These data show that there are frequent periods when all of the wind and solar resources are expected to provide much lower output than their rated capacity.  It appears that planners must account for a 36 hour period when all the LBW, OSW, and solar combined provide less than 10% of their rated capacity.  This is a huge challenge.

The second point is that the developing adequate resource to backup the wind and solar resources during these extended low resource periods must now account for weather variability.  These results are based on a 22-year data set and is analogous to the 100-year flood metric.  For flood management planning, analysts use the 100-year flood probability of a certain flood height to develop a resilient plan for the flood plain.  Future electric resource planning is going to have to develop something similar.  I am concerned that while the ramifications of a flood that exceeds the planning criteria are bad, the effects of inadequate electric power when New York has electrified homes, businesses, and transportation will be catastrophic.

I have long advocated a similar analysis that expands on this one.  Because New York depends on imports from adjoining regional transmission operators the geographical scope should be expanded to cover those regions.  The period of record should be as long as possible.  There are data available that could be used to extend the analysis to 1950.  Even if the resource planning is based on such a study, the over dependence upon weather related resources means that eventually there will be an even worse resource lull that causes a catastrophic blackout.  There is a limit to how much society can invest to avoid such an outcome, and I think that dynamic will inevitably lead to disaster. 

In addition, note that these results show that the Integration Analysis projections for future wind and solar capacity are underestimated.  The net capacity factors used are greater than the observed capacity factors.  This is another aspect of the state plan that needs to be reconciled with the most current NYISO work.

Conclusion

These results highlight the complications that weather-dependent electric grid planning must address.  Given the magnitude of the planning challenges I am not optimistic that planners will be able to anticipate all the effects to prevent reliability crises.  The results also destroy the myth that the wind and solar future grid will be more resilient than the existing grid.  That is just an empty slogan with no basis.

This is an intriguing development.  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”.  In this post I offer some thoughts on the reason for the summit and possible outcomes.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 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 that 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, a 70% electric system renewable energy mandate 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 used to reduce greenhouse gas emissions.  That material was used to develop the Draft Scoping Plan outline of strategies.  After a year-long review, the Scoping Plan was finalized and approved by the CAC at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, Public Service Commission orders, and legislation.   However, recent reports have raised problems with the implementation process and Hochul has threatened to pause the process due to costs.

Announcement for Clean Energy Technology Summit

The press release for the Clean Energy Technology Summit stated:

Governor Kathy Hochul today announced New York State will convene global experts to discuss the role of next generation clean energy technologies and strategies to accelerate renewable energy deployment while collectively supporting economic development in New York. The “Future Energy Economy Summit,” to be held on September 4-5, will convene relevant state agencies and authorities, global and federal leaders, power producers, technical experts, labor groups, environmental groups, business groups and other interested stakeholders. The summit will explore how next generation clean energy technologies can support the establishment and expansion of commercial and industrial enterprises, as well as how the state can accelerate the deployment of dispatchable emissions-free resources that will be needed to bolster its notable and ongoing efforts to scale renewable energy.

Note that the summit is only one day.  Registration is the only activity available the evening before the meeting.  After the obligatory political bragging that I am not going to include, the press release went on to say:

The Governor has appointed New York State Energy Research and Development Authority (NYSERDA) Board Chair, Richard Kauffman, to serve as chair of the summit with contributions from leadership and staff from NYSERDA, the Department of Public Service (DPS), Empire State Development (ESD), New York Power Authority (NYPA), Department of Environmental Conservation (DEC), Department of Health (DOH), Division of Homeland Security and Emergency Services (DHSES) and Department of Labor (DOL).

I find it troubling that there will be so many agencies involved in the summit.  The heavy involvement of different agencies suggests that his may end up being no more than a dog and pony show to highlight the Administration’s commitment to fighting climate change.  Among the real issues that have to be addressed are those raised at last December’s technical conference entitled Zero Emissions by 2040 held as part of the Department of Public Service Proceeding 15-E-0302.  The conference confirmed the need for a new category of generating resources called Dispatchable Emissions-Free Resources (DEFR) but there hasn’t been any public progress addressing this resource.  The problem is DEFR technologies simply do not exist yet on a commercial scale, and it is very unlikely that the they will be available when needed to meet the arbitrary Climate Act schedule.  There are hints in the next paragraph that the summit might be intended to address this problem.

New York State anticipates major growth in electric demand in coming years driven by historic economic development projects and the increased adoption of electrification technologies in the building and transportation sectors. Building upon New York State’s unprecedented and continued commitment to scaling up and accelerating renewable energy such as offshore wind, hydropower, solar and onshore wind statewide, a key component of the summit will be gathering further input on technologies including next generation geothermal, advanced nuclear, clean hydrogen, long duration energy storage, as well as other emerging technologies. The input received will inform State strategies in the use of these technologies to support economic development across the state and provide context for the Public Service Commission (Commission) proceeding that is investigating technologies that can help meet the 2040 zero-emissions electricity system target established through New York’s Climate Act.

The technologies mentioned, next generation geothermal, advanced nuclear, clean hydrogen, and long duration energy storage are all potential DEFR solutions.  The following paragraph reinforces the idea that the summit is intended to address the need to implement currently unavailable DEFR technologies.

NYSERDA and DPS staff are currently developing technology and economic studies of diverse generation technologies that could complement the state’s wide scale deployment of renewable energy and play an expanded role in a decarbonizing economy. These studies will gather information and examine technologies ranging from small modular nuclear reactors to long-duration energy storage technologies to grid-forming inverters. The studies will complement the outputs from this summit and inform the State’s options for future generation including through the Commission’s proceeding.

So far the NYSERDA and DPS studies like the Scoping Plan are long on ambition and short on facts.  Worse, there hasn’t been any meaningful attempt to engage stakeholders by responding to comments submitted.  I worry that this summit is part of the packaging for whatever the Administration has already decided to do.  We can only wait and see what happens at this meeting.

Unfortunately, resolving the technological challenge for DEFR development and implementation is not the only implementation problem.  The green new deal aspect of the Climate Act mandates investments in disadvantaged communities which complicates implementation.  While I agree that all the factors described in the following paragraph are important, I am worried that there is no mention of a feasibility analysis.  The presumption of the state is that once they set a goal, it will happen despite the lack of any evidence that it is possible.

This summit will address advancing key factors to develop these technologies’ supply chain investments in New York, workforce opportunities, and how these investments can be leveraged to support large load growth and low-carbon economic development across New York while benefiting disadvantaged communities. The summit will also inform the development of a blueprint to advance issues and considerations for the deployment of advanced nuclear power generation and potentially leverage federal funding programs, including but not limited to, nuclear planning grants.

Summit Agenda

The only information on the summit itself is the following list of sessions:

• 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 Nest Steps

Tim Knauss described the meeting for Syracuse.com. 

Two of the five panel discussions at the daylong conference will be focused on “new nuclear” technology such as small advanced nuclear reactors, according to a draft agenda.

The meeting also will include discussions about accelerating the deployment of renewable power sources like wind and solar. And there will be a focus on developing new power sources that can be dispatched when renewable power falls short.

Knauss interviewed Doreen Harris, president and CEO of the New York State Energy Research and Development Authority.  She said the summit “will explore a wide variety of technologies for achieving a clean system” and went on to say:

At this point, nuclear power is a more mature technology than many alternatives, she said.

“It is actually a more, I’d say, advanced area of commercial viability, as opposed to some of the other resources that we see on the technical horizon at this point,’’ Harris said in an interview Monday.

NYSERDA plans to develop a roadmap for the potential deployment of new nuclear power, similar to the Offshore Wind Master Plan the authority crafted to guide development of that resource, Harris said. NYSERDA plans to gain expert feedback at the Syracuse summit to help prepare a policy for new nuclear power, she said.

“New nuclear is a resource that we see strong federal support for,’’ Harris said. And frankly, we see deployment of these technologies — such that it is, I would say, ripe for consideration. Is this a resource that New York would consider? But it’s not to say we have the answer to that.”

Discussion

Three recent reports all have suggested that reassessment is necessary.  The Public Service Commission (PSC) Clean Energy Standard Biennial Review Report found that the 70% renewable energy goal will likely not be achieved until 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.

As a result of these findings and perhaps pressure by the business community, 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.”  The Department of Public Service Proceeding 15-E-0302 may also be influencing the Governor and precipitating the need for the summit. 

The fact is that reality is an energy policy that was promulgated by motivated politicians without a vetted analysis of the scope and schedule was never going to be successful.  This summit might be an attempt to provide political cover to broach the need for schedule adjustments and to consider alternatives that have thus far not been considered seriously in the implementation process.  At the top of the list is the nuclear power that is the only technology that has a proven record of deep decarbonization success but most certainly cannot be deployed on the Climate Act schedule.  It will be interesting to see how legislators, the Big Green NGOs, and the renewable energy shills react to this development.  Will they acknowledge that nuclear is necessary for the Climate Act goals?  Stay tuned.

This article summarizes published posts describing a new category of generating resources called Dispatchable Emissions-Free Resources (DEFR) that many reputable electric energy analysts believe is necessary for a future grid that depends upon wind, solar, and energy storage resources. The reputable analyses of the future New York electric system agree that new technologies are necessary to keep the lights on during periods of extended low wind and solar resource availability.  However there still is an influential group of people who maintain otherwise.  Hence the need to document the reputable analyses.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 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 company 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 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 and legislation.

Compendium of DEFR Analyses

The following descriptions have been integrated into a Pragmatic Environmental of New York page that I can update as necessary and use as a reference.  This article summarizes six analyses describing the need for DEFR: the Integration Analysis, New York Department of Public Service (DPS) Proceeding 15-E-0302 Technical Conference, NYISO Resource Outlook, Richard Ellenbogen, Cornell Biology and Environmental Engineering, and Nuclear New York.  I also include the Jacobson and Howarth work that forms the basis for those who believe that no new technology is needed.

DEFR is not Required

When the Climate Action Council voted to accept the Scoping Plan draft, council members made statements justifying their positions. The statement of Robert W. Howarth, Ph.D., the David R. Atkinson Professor of Ecology & Environmental Biology at Cornell University argued that no new technologies are needed and was uncritically accepted by some members of the Council. Importantly, the leadership of the Council did not object to the following:

A decade ago, Jacobson, I and others laid out a specific plan for New York (Jacobson et al. 2013). In that peer-reviewed analysis, we demonstrated that our State could rapidly move away from fossil fuels and instead be fueled completely by the power of the wind, the sun, and hydro. We further demonstrated that it could be done completely with technologies available at that time (a decade ago), that it could be cost effective, that it would be hugely beneficial for public health and energy security, and that it would stimulate a large increase in well-paying jobs. I have seen nothing in the past decade that would dissuade me from pushing for the same path forward.

This is the reason I am compiling DEFR analyses because it simply is not consistent with any of the organizations accountable for New York energy policy.  The basis of the no new technology claim is the “Wind, Water, and Solar” work of Professor Mark Jacobson of Stanford.  In my summary of this belief, I showed that Howarth’s argument that no new technology is needed has been refuted in the peer reviewed literature.  In the remainder of this article I describe six other analyses that conclude that DEFR is required.

The Jacobson approach wass described in a widely publicized November 2009 Scientific American article by Mark Jacobson and Mark Delucchi that suggested all electrical generation and ground transportation internationally could be supplied by wind, water and solar resources as early as 2030. However, other contemporary projections were less optimistic, for example two examples disagreed: the 2015 MIT Energy and Climate Outlook has low carbon sources worldwide as only 25% of primary energy by 2050, and renewables only 16% and the International Energy Agency’s two-degree scenario has renewables, including biomass, as less than 50%.

Howarth’s statement cites a specific plan for New York (Jacobson et al. 2013) that he and Jacobson laid out a decade ago.  He says that “In that peer- reviewed analysis, we demonstrated that our State could rapidly move away from fossil fuels and instead be fueled completely by the power of the wind, the sun, and hydro.”   There was a formal rebuttal paper to this analysis by Nathaniel Gilbraith, Paulina Jaramillo, Fan Tong, and Felipe Faria. The rebuttal paper argued that: 

The feasibility analysis performed by Jacobson et al. (2013) is incomplete and scientifically questionable from both the technical and economic perspectives, and it implicitly assumes, without sufficient justification, that social criterion would not produce even larger feasibility barriers.

Jacobson et al. responded to that rebuttal claiming  that “The main limitations are social and political, not technical or economic.”  Given the significant differences between that analysis and the most recent projections by the organizations responsible for keeping the lights on, I agree with the Gilbraith et al. conclusion cited above.  I do not believe that the 2013 WWS analysis includes a defensible feasibility analysis proving that a dispatchable, emissions free resource is not needed during extended periods of low wind and solar resource availability.

Three books include analyses that also refute the Jacobson work.  Meredith Angwin’s 2020 book Shorting the Grid: The Hidden Fragility of Our Electric Grid cites academic work rebutting the Jacobson premise.  Angwin also describes two other books that directly refute it.  Roadmap to Nowhere: The Myth of Powering the Nation With Renewable Energy by Mike Conley and Tim Maloney is available as a free PDF download on the web. Mathijs Beckers, of the Netherlands, wrote The Non-Solutions Project, available as an ebook or paperback.

I conclude that the basis for the influential position that no new technology is needed is not supported by the Jacobson work.  More importantly, the following analyses all conclude new technology is needed.

Integration Analysis

The Final Scoping Plan is the “official” Hochul Administration strategy description of the Climate Act transition.  The Scoping Plan directly contradicts the statement that technologies available when the Howarth paper was written and today are sufficient for the transition away from fossil fuels.  In particular, the Final Scoping Plan Appendix G, Section I page 49 states:

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

The analysis also recommends technologies for this resource:

Hydrogen effectively provides a form of storage to the system on the order of hundreds of hours. Large quantities of fuel can be produced during the spring and summer and then utilized over the course of the winter provided that there is sufficient fuel storage. In addition to hydrogen-based resources, the analysis also examined the potential to meet reliability needs with a long-duration battery storage solution. In this assessment, the firm zero-carbon capacity, as well as renewable resources needed to produce hydrogen, were removed from the system, and the analysis identified a need for 25 GW of 100-hour battery storage to replace the contributions of 21 GW of a fully dispatchable hydrogen-based resource, along with 14 GW of incremental renewable resources to provide storage charging.40 A 100-hour battery resource can provide firm capacity to meet system needs over several days. However, in contrast to a hydrogen-based resource, if sufficient excess energy is not available to fully recharge the batteries following a challenging stretch, their ability to meet a similar system need in subsequent weeks of the winter is diminished. As a result, a higher amount of 100-hour battery capacity is needed to meet the same level of reliability as hydrogen-based resources.

At the Zero Emissions by 2040 Technical Conference session Gap Characterization  Kevin Steinberger, Director, Energy and Environmental Economics (E3) stated that their modeling consistently showed the need for a new resource that is firm, dispatchable, and has no emissions that can power the system for days without significant recharge from wind and solar resources. 

NYISO Resource Outlook In all the resource analyses prepared by the New York Independent System Operator (NYISO) since Climate Act implementation began, the necessity of DEFR has been mentioned.  In the spring of 2024 the Power Trends 2024 report notes:

Renewable energy generation, subject to sudden changes in weather, also provides new challenges to grid operators that must balance supply and demand in real time. These variables highlight the need for new generation technologies that can fill in when weather-dependent resources are unavailable. Such new technologies, collectively referred to as Dispatchable Emission Free Resources (DEFRs), must be dispatchable, emissions free, and able to respond quickly to changing grid conditions. Such technologies do not exist yet on a commercial scale.

The NYISO described this resource in the 2021-2040 System & Resource Outlook:

DEFRs are a classification of emission- free resources that provide the reliability attributes of synchronous generation and can be dispatched to provide both energy and capacity over long durations. DEFRs must be developed and added to the system at scale to reliably serve demand when intermittent generation is unavailable. The lead time necessary for research, development, permitting, and construction of DEFR supply will require action well in advance of 2040 if state policy mandates under the CLCPA are to be achieved.

I described the presentation by Zachary Smith that gave an overview summary presentation of the DEFR issue.  In his first slide (shown below) he gave an overview of the generating resource outlook to make the point that a large amount of new generating resources needs to be developed.  The estimates shown are from the 2021-2040 System & Resource Outlook and represent two plausible load projections.  He noted that there are “a lot of attributes that fossil fuel resources provide today that wind, solar, and energy storage simply cannot provide”.  He also made the point that the DEFR replacements do not have to be a single technology but could be several technologies that in aggregate can replace the fossil generation.

Smith listed the attributes needed by DEFR in his presentation.  In my description of his discussion I offered comments on this list of attributes.

Smith’s presentation lists the attributes of twelve sample technologies in the following slide.  This represents the NYISO opinion of the capability of different technologies to meet the attributes necessary to maintain a reliable system.  In the future grid the insistence that all fossil fired units must be shut down means that numerous technologies that meet some of the necessary attributes will be required.  The added complexity of these technologies does not increase resiliency because wind, solar, battery and demand response are all energy limited.  Ancillary support services will be a major consideration because wind, solar and battery do not provide those services.  Just from this overview, it is clear that affordability and reliability will be challenges.

Attributes of Sample DEFR Technologies

Richard Ellenbogen

I described Richard Ellenbogen’s comments as part of the record for the Department of Public Service Proceeding 15-E-0302 related to the net -zero mandate of the Climate Leadership and Community Protection Act (CLCPA). His comments discuss “a viable, affordable, and rapidly executable Plan B to assist NY State in reducing its carbon footprint using technologies that actually exist at scale, unlike the technologies proposed by the CLCPA which only exist at scale in the fantasies of its proponents.”

Ellenbogen lays out reasons that things have changed as the Climate Act is implemented that could affect the schedule and viability of the Scoping Plan list of control strategies.  He concludes that an alternative that does not go to zero provides a better solution. He argues that Interim Combined Cycle Natural Gas Generation phasing to nuclear over time is a far more cost effective and secure way to power the state than what the CLCPA is mandating. Recovering the Combined Cycle emissions in greenhouses will mitigate the negative effect of the carbon emissions. That will also provide energy security that renewables can’t, while simultaneously providing food security as climate change makes food production more challenging.

Cornell Biology and Environmental Engineering

In a post describing the Zero Emissions by 2040 Technical Conference session Gap Characterization  I summarized work by Prof. C. Lindsay Anderson, Chair of Department of Biological and Environmental Engineering Cornell.  Professor Anderson described an analysis her group did using a model they developed.  They made projections for expected loads and potential resources then used 22 years of hourly historical data to model the system.  Without considering cost constraints they assessed system vulnerabilities to evaluate periods where there was insufficient generation to meet projected loads.  Even with optimistic projections they found there will be periods during the coldest and hottest periods where there will be insufficient generation from wind, solar, and energy storage resources.  That gap must be filled with DEFR.

Nuclear New York

I described the independent analysis of the future grid found that New York State has seriously underestimated the need for DEFR. The Filling the Gap in New York’s Decarbonization Plan: A New View of the Electric Grid report was authored by Leonard Rodberg, PhD, Research Director, Nuclear New York, Inc.; Consultant, Energy Policy; Reiner Kuhr, Founder, Center for Academic Collaborative Initiatives (CAIC); and Ahmad Nofal, Co-founder, CAIC. 

The report describes the results of a new modeling tool that allows an hour-by-hour analysis of electric system behavior.  This approach enabled the authors to see details of the hourly operation of each energy source, features not disclosed by existing models.  In my opinion, the CAIC analysis treats DEFR differently than the Integration Analysis does.  I believe that when the Integration Analysis determines which resources should be applied to meet load for each hour, they use DEFR as a last resort.  On the other hand, CAIC uses DEFR much more frequently.  That could be due to a difference in the hourly projections of wind, solar, energy storage, and load for the two models or presumptions in the models.

They found that:

Our hour-by-hour analysis shows that the firm dispatchable source has to run two-thirds of the year. The total load has increased from today. The summer peak has been replaced by a much higher winter peak. That greater demand is met by the extended operation of the DEFR which runs during most evenings in the cooler portion of the year. In fact, we find a capacity factor — the fraction of potential output actually used –of 14.4%.

The report concludes:

We have shown, with a modeling tool capable of performing an hour-by-hour analysis, that dispatchable emission-free resources are essential to meeting the goal of a reliable, zero-emission grid.  Further, this clean dispatchable source must be able to run a large portion of the year. The only such source likely to be available within the next several decades is nuclear power.

Conclusion

There is overwhelming evidence that a new category of generating resources is necessary for a future grid that depends upon wind, solar, and energy storage resources. Most analysts of the future New York electric system agree that DEFR is necessary to keep the lights on during periods of extended low wind and solar resource availability.   At this point the only questions should be how much, what technologies can be used, and whether any technologies can provide the necessary services affordably.  The Hochul Administration Scoping Plan does not provide that information in sufficient detail.

Finally, the work done since the completion of the Scoping Plan should put the myth that no new technologies are necessary to death.  The Proceeding on Motion of the Commission to Implement a Large-Scale Renewable Program and a Clean Energy Standard – Zero Emissions Target Case No. 15-E-0302 addresses the need for DEFR.  However,there does not appear to be a schedule to resolve the issues raised at the PSC technical conference Zero Emissions by 2040 session titled Gap Characterization last December.  They should be resolved sooner rather than later.