Category: Climate Act Feasibility

I have been writing about the Climate Leadership & Community Protection Act (Climate Act) for over four years and a constant theme in my work has been concerns about affordability and reliability.  For all the analyses and pontification by the State of New York about the net-zero transition, there still is no documentation describing the costs of the control strategies proposed by the Scoping Plan and estimates of how New Yorkers will pay for the transition.  The focus of this post is on reliability.  I believe that the only way we can be sure that the plans proposed to operate an electric grid that relies primarily on wind and solar is to prove it with a demonstration project.  The project should include all the key elements: wind and solar generation, energy storage, a dispatchable emissions-free resource and any other resources needed to provide necessary ancillary services.   This post highlights work by Francis Menton that advocates just such a demonstration project.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 350 articles about New York’s net-zero transition.  I have devoted a lot of time to the Climate Act because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good by increasing costs unacceptably, threatening electric system reliability, and causing significant unintended environmental impacts.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Climate Act Background

The Climate Act established a New York “Net Zero” target (85% reduction 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” by 2040. The Climate Action Council is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.”  In brief, that plan is to electrify everything possible using zero-emissions electricity. 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.  After a year-long review, the Scoping Plan recommendations were finalized at the end of 2022.  In 2023 the Scoping Plan recommendations are supposed to be implemented through regulation and legislation.  Over nine months into 2023 and reality is starting to set in and cast aspersions on the aspirational plans.

Demonstration Project Proposal

Last February I did a post on Climate Smart Communities and I proposed a challenge to the local governments that pledged to be climate smart.  Go for it, but not just this virtue-signaling public relations gesture to get some money.  I described Francis Menton’s article explaining that a demonstration project of a mainly renewables-based electrical grid is a common sense prerequisite before there are any more plans or pledges.  I said that Climate Smart Communities of New York should prove their bona fides and develop a demonstration project for their community to address the issues he raised:

Could anybody possibly be stupid enough to believe the line that wind and solar generators can provide reliable electricity to consumers that is cheaper than electricity generated by fossil fuels? It takes hardly any thought about the matter to realize that wind and solar don’t work when it is calm and dark, as it often is, and particularly so in the winter, when it is also generally cold. Thus a wind/solar electricity system needs full backup, or alternatively storage — things that add to and multiply costs. Surely, our political leaders and top energy gurus are fully aware of these things, and would not try to mislead the public about the cost of electricity from a predominantly wind/solar system.

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Nobody would be happier than me to see a demonstration project built that showed that wind and solar could provide reliable electricity at low cost. Unfortunately, I know too much about the subject to think that that is likely, or even remotely possible. But at least the rest of us need to demand a demonstration project from the promoters of these fantasies.

A few days ago Menton followed up on his February post with What Passes For A “Demonstration Project” Among Our Government Geniuses.  I recommend readers check out both articles.  I will summarize the key points from the more recent article here.

Menton describes people who don’t support the need for an encompassing fossil-fuel-free renewable grid demonstration project.  Government officials and green energy advocates won’t support this because:

(1) they are not bright enough to understand the subject, or (2) their understanding is impaired because they are too blinded by religious fervor to “save the planet,” or (3) they are intentionally deceiving the public to make money or fame or career advancement for themselves. Or it could be all three!

Instead of a single comprehensive demonstration, net-zero proponents promote projects that only “attempt to demonstrate various portions of the full system that would be needed to provide reliable 24/7/365 electricity from predominantly wind and solar generation.”  I believe a common problem of all the “green” energy solutions is that they do not work all the time and renewable resource availability is correlated over large distances which makes demonstrations of individual components worthless.

Menton agrees and describes the example of the latest news on energy storage. He explain that on October 13, the Department of Energy announced big new grants and subsidies for a series of what they call “hydrogen hubs.” Here is a report from E&E News Energy Wire. Excerpt:

The Department of Energy on Friday announced seven projects that will receive $7 billion to build landmark hydrogen hubs, delivering a major boost to a nascent U.S. industry. The long-awaited move is a key piece of the Biden administration’s climate agenda. On Friday, the White House said it expects the DOE funding to help cut 25 million metric tons of carbon dioxide annually, roughly equivalent to removing 5.5 million gasoline-powered vehicles from the road each year. “With this historic investment, the Biden-Harris administration is laying the foundation for a new, American-led industry that will propel the global clean energy transition,” said Secretary of Energy Jennifer Granholm.

The New York placeholder for dispatchable emissions-free resources is “green” hydrogen.  Menton explains that according to this further piece from Energy Wire on August 21, the Biden Administration has set a goal of having the U.S. produce 10 million metric tons of “green” hydrogen (by electrolysis from water) by 2030. The E&E piece states that the massive funding for “hydrogen hubs” is for “demonstrations.”  He points out that this is not the demonstration project needed to prove viability of the net-zero transition because the demonstrations focus on production, storage, transport and consumption but not the integrated resource necessary.  He notes:

They are clearly leaving out the critical piece of the puzzle, which is the demonstration of how much of this hydrogen, and capacity to make more of it, will be needed, and at what cost, to get the country — or even some small town — through a full year (or two or five) without need for fossil fuel backup. That completely obvious elephant is not part of this multi-billion dollar “demonstration.”

Another dispatchable emissions-free resource for New York’s net-zero transition could be long duration energy storage. Menton notes that the Department of Energy has a “separate big bucks effort called the “Long Duration Storage Shot” that is throwing bucketsful of cash at various research efforts into batteries.”  Unfortunately, he notes:

The battery efforts are even farther removed from any relevant demonstration project. From DOE’s opening webpage describing that initiative (with a date of September 2021):

The U.S. Department of Energy’s (DOE) Energy Earthshots Initiative aims to accelerate breakthroughs of more abundant, affordable, and reliable clean energy solutions within the decade. Achieving the Energy Earthshots will help America tackle the toughest remaining barriers to addressing the climate crisis, and more quickly reach the Biden-Harris Administration’s goal of net-zero carbon emissions by 2050 while creating good-paying union jobs and growing the clean energy economy. . . . The Long Duration Storage Shot establishes a target to reduce the cost of grid-scale energy storage by 90% for systems that deliver 10+ hours of duration within the decade.

On September 22, 2023 the Administration announced some $325 million for “15 projects across 17 states and one tribal nation” to “accelerate the development” of these “long duration” battery technologies. He writes:

So are these battery technologies, or any one of them, even a potential solution to the problem of making a mostly wind/solar electricity grid work without fossil fuel backup? Again, you will not find any mention at those links, or at other government or advocate sites discussing the issue of how many of these batteries would be necessary and at what cost to actually fully back up a predominantly wind/solar grid and make it into a functional 24/7/365 electricity system.

I cannot over-emphasize how challenging these two technologies are.  I fear that some aspects of some of these demonstrations will be deemed a success which will be used to argue that the concerns of  organizations responsible for keeping the lights on and skeptical technical experts who have no vested interests in the green energy scam are unwarranted.  Theory, small prototype tests, and these demonstration projects all will not prove the feasibility of a fully-functioning wind/solar/hydrogen storage 24/7/365 electricity grid.

Another aspect of this is that until we have a proof-of-concept demonstration that incorporates all the components needed to get to a reliable system, we cannot know how much it will cost.  Menton argues that a rough cost estimate  “would come to a multiple (not necessarily a huge one, but nonetheless a multiple) of what our current electricity system costs.”  He does not bother to make an estimate writing:

The reason I’m not going to do it is that there as an obvious fact that tells you all you need to know, which is that no one in the country is spending their own private money to build out this system. They are all waiting for the government handouts. If this system could be built profitably at a cost competitive with what we have, there would be investors falling all over themselves to build it. When Thomas Edison built his first electricity plant, he did not go to the government for handouts to build it.  Because this is all a fantasy kept alive by government handouts, as soon as the handouts go away or even slow down, the whole thing will dry up and fade away.

Conclusion

We do not know if the net-zero transition is technically possible.  All we have is assurances from vested interests and slick marketing claims from the state.  Richard Feynman said “For a successful technology, reality must take precedence over public relations, for Nature cannot be fooled.”  Before New York goes any further, a comprehensive demonstration project for a smaller jurisdiction is the pragmatic approach.

A recent article by Ed Reid prompted me to put together this post.  Reid compared different Offshore Wind (OSW) developer estimates of the capacity factor of a couple of projects and found inconsistencies.  This article compares his results with Climate Leadership & Community Protection Act (Climate Act) OSW projections.  I also address energy storage implications associated with OSW.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 350 articles about New York’s net-zero transition.  I have devoted a lot of time to the Climate Act because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good by increasing costs unacceptably, threatening electric system reliability, and causing significant unintended environmental impacts.  The opinions expressed in this post do not reflect the position of the New York State Reliability Council, the Extreme Weather Working Group, any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Climate Act Background

The Climate Act established a New York “Net Zero” target (85% reduction 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” by 2040. The Climate Action Council is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.”  In brief, that plan is to electrify everything possible using zero-emissions electricity. 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.  After a year-long review, the Scoping Plan recommendations were finalized at the end of 2022.  In 2023 the Scoping Plan recommendations are supposed to be implemented through regulation and legislation. 

Off Shore Wind (OSW) is supposed to be a major renewable resource in the “zero-emissions” electric energy system.  The Climate Act mandates 9,000 MW of Off Shore Wind (OSW) generating capacity by 2035.  The Integration Analysis modeling used to develop the Scoping Plan projects OSW capacity at 6,200 MW by 2030, 9,096 MW by 2035 and reaches 14,364 MW in 2040.  On the other hand, the New York Independent System Operator 2021-2040 System & Resource Outlook expects 5,036 MW in 2030 and 9,000 MW in 2035 with no additional development after that.  By 2030 the Integration Analysis predicts that 14% of the electric energy (GWh) produced will come from OSW and the Resource Outlook predicts nearly as much (12%).  This is an extraordinary build-out for a resource that is currently non-existent. 

Capacity Factors

The capacity factor is a useful metric to understand and compare electric generation resources.  The annual capacity factor equals the actual observed generation (MWh) divided by maximum possible generation (capacity (MW) times 8,760 hours.  At sea the wind resource higher capacity factors are higher than onshore wind resources, primarily because there are no hills and vegetation to slow down wind.  Supporters of OSW tout the higher capacity factors of this resource as a big benefit. 

Ed Reid writing at The Right Insight describes issues with Offshore Wind (OSW) data used for claiming benefits.  Reid described developer claims for two projects:

Orsted’s recently approved Ocean Wind 1 development, to be located off the New Jersey coast near Atlantic City and Ocean City, would consist of one hundred 11MW wind turbine generators, for a total capacity of 1,100 MW. This would suggest annual generation, at a 100% capacity factor, of 9,600 GWh. The International Energy Agency uses a capacity factor of 50% for offshore wind. We will use that figure here, since there is no offshore wind capacity factor data for the US East Coast. This suggests annual production of approximately 4,800 GWh for Ocean Wind 1.

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Dominion Energy’s proposed Coastal Virginia Offshore Wind (CVOW) development, to be located off the Virginia coast near Norfolk, would consist of one hundred seventy-six 15 MW wind turbine generators, for a total capacity of 2,600 MW. This would suggest annual generation, at a 100% capacity factor, of approximately 22,800 GWh, or approximately 11,400 GWh at a 50% capacity factor.

The US Energy Information Administration reports average US residential electricity consumption as 10,600 kWh per year.  The developers describe the output of their projects in terms of the number of homes served. Reid estimates capacity factors for both projects using that information. Orsted projects that Ocean Wind 1 would serve 500,000 homes. Based on these numbers, Ocean wind would have to generate 5300 GWh per year, or a capacity factor of approximately 55%. Dominion projects that CVOW would serve 660,000 homes. Using the same approach, the annual capacity factor of the Dominium CVOW would be 30%.  Thar is far lower than the IEA figure.

I compared the New York Independent System Operator (NYISO) 2021-2040 System & Resource Outlook  modeling analysis with the Integration Analysis modeling and determined the capacity factors used.  The following table lists the capacity factors for different generating resources including offshore wind.  There is no question that OSW resources have higher capacity factors than onshore wind or solar. The NYISO annual projections are around 45% while the Integration Analysis projects slightly higher estimates no greater than 48%  These estimates are closer to the International Energy Agency capacity factor of 50% than either Ocean 1 or CVOW.  Note that the renewable resources capacity factors represent the best they can do but that the fossil capacity factor is low because, in part, they are displaced by wind and solar.  

Estimates and Averages

Reid describes average estimates used for the OSW developer claims:

The estimates above are based on a number of averages: average wind resource; average capacity factor; average maintenance and repair allowances; and, average residential electricity consumption. The available wind resource varies on time scales from minutes to hours to days to seasons, as does residential energy consumption and demand. The use of averages loses a lot of the detail of the match between customer load and generator output.

He explains that intermittent generation from wind turbines shifts the resources used in the grid:

Since each of these industrial wind installations would be connected to a grid with a far larger customer base than the claimed number of residential customers served, above average output would be absorbed by other loads on the grids, displacing a portion of the output from some form(s) of conventional generation. Below average generator output would require support from some form(s) of conventional generation.

In my opinion, the intermittency of wind and solar projects should be addressed by the developer.  As it stands now somebody else must provide supporting conventional generation or energy storage so wind and solar get a free ride.  Reid explains the problem:

Arguably, fluctuations in generator output and customer load could also be compensated for by additions to and withdrawals from some type of energy storage capacity. However, there is no energy storage capacity included in either of the wind projects discussed above. The issue of storage can be deferred as long as there is sufficient excess conventional generating capacity available to compensate for the fluctuation of the output of the wind facilities and maintain a capacity reserve margin. However, as conventional generating capacity is retired due to age or regulation, and additional intermittent renewable generating capacity is added, addressing the issue of storage cannot be avoided.

Extremes

All issues related to the net-zero transition are more complicated than expected at first glance.  In order to address this complexity, more explanation and analysis are required.  For example, in this instance Reid wrote a short article addressing average fluctuating wind resources.  He did not call out the extreme case when the wind resource is essentially zero for extended periods probably because it would have made the story too long.  However, I think this is a critical consideration.  Since the beginning of the Climate Act implementation process, lulls of renewable energy production, what I call the ultimate problem, has been a concern.

In their presentation to the Power Generation Advisory Panel on September 16, 2020 Energy + Environmental Economics (E3) noted that: “The need for dispatchable resources is most pronounced during winter periods of high demand for electrified heating and transportation and lower wind and solar output”.  They also noted that: “As the share of intermittent resources like wind and solar grows substantially, some studies suggest that complementing with firm, zero emission resources, such as bioenergy, synthesized fuels such as hydrogen, hydropower, carbon capture and sequestration, and nuclear generation could provide a number of benefits.”  Of particular interest is the graph of electric load and renewable generation because it shows that this problem may extend over multiple days.

Since the time of this presentation, the New York State Independent System Operator (NYISO), New York State Reliability Council, and Public Service Commission in the Order Initiating Process Regarding Zero Emissions Target in Case 15-E-0302 all have been considering the ramifications of this problem.  The New York State Reliability Council Extreme Weather Working Group (EWWG) was established to “identify actions to preserve New York Control Area reliability for extreme weather events and other extreme

system conditions” and create a corresponding action plan to “evaluate the potential need for

new resource adequacy and transmission planning design rules for planning the system to meet

extreme weather and other extreme conditions.”  Wind lulls are one of the extreme weather events being considered by the EWWG.

The EWWG looked at the observed correlation of the frequency and duration of low-wind episodes across the entire state, including the offshore wind development areas.  This summer they finalized a report titled Off Shore Wind Data Review – NYSRC Preliminary Findings (“OSW Report”) that is relevant to this discussion.  The OSW Report analysis was based on an NYISO analysis that made available 21 years of hourly wind data at seven wind development sites (Figure 1), extending from New Jersey to Rhode Island, prepared by its consultant DNV. DNV performed analysis of wind data translating meteorological data into detailed power profiles for each site including loss considerations.  The report describes frequency analysis and interregional impacts.

Figure 1: Seven Wind Development Sites Analyzed

The OSW Report wind lull analysis is relevant to this discussion.  The analysis defined wind lulls as periods of each hour of wind output of less than 5%-20%.  For extended periods of 24 hours or longer, lulls occur about 30 times per year on average. Wind lulls of 48 hours or longer occur on average about seven times per year, and wind lulls of 72 hours or longer occur on average two times per year.  About 70% of these wind lulls over the 21-year period occurred during the current peak load four-month summer period from June to September.

Of note, is the following finding:

Lastly an analysis was performed to identify the most persistent wind lull experienced in the 20-year wind data with net capacity factor less than 10% for the entire period across all seven wind sites. Analysis indicates wind lulls of up to 86 hours with an average energy output of approximately 5% net capacity factor occurring across all seven sites were observed in the DNV dataset (this compares to an average annual net capacity factor of approximately 45%). While data associated with longer periods than 21 years were not readily available it may be appropriate to characterize this as a 1 in 20 year extreme weather event.

Reid explained that compensating load can be provided by adjoining transmission operators.  This report addresses this concern relative to the OSW resource:

NY relies on emergency assistance from neighboring regions to achieve reliable system design, thus continued availability of surplus power from these areas is an important consideration. Similar to NY, policy makers from PJM and New England are also moving forward with policies to install large scale wind power to address decarbonization and planned shutdown of thermal units, with proposals in each region also totaling tens of thousands of MW. As noted in Section 3.0, OSW off the coast of the state of New Jersey is targeted at 7.5 GW by 2035 increasing to 11.0 GW by 2040, and similarly OSW off the coast of Rhode Island/ Massachusetts is targeted at 8.0 GW by 2035. In total PJM member States have announced off shore wind targets totaling 24 GW by 2035, and 32.7 GW by 2040.

The OSW Report compares the output from all seven wind sites during an interregional wind lull event which occurred August 8, 2017 – August 13, 2017.  Over that time period the following graph shows that the fraction of wind output from all the sites clearly correlates.  The implication is that compensating load will not be available from adjoining transmission operator’s OSW resources in periods like this.

The OSW Report concludes:

It is noted reliability of the traditional interconnected power system design relies on diversity of forced outage rates and independence of outage events. Correlation of interregional wind lulls eliminates diversity of loss of power output events associated with OSW and alters this aspect of system design.

Interregional wind lulls simultaneously impacting tens of thousands of MWs of interregional OSW located in PJM, NY and NE could reduce reserve sharing and emergency assistance available for support from neighboring control areas significantly impacting operational reliability and resource adequacy.

The most important point of this article is that the OSW Report documents correlation of interregional wind lulls.  I believe this problem extends to onshore and wind and solar resources.  I have looked at enough New York onshore wind data to be certain that this correlation extends to all the onshore wind resources in New York and adjoining regions.  When it comes to solar, cloudiness affecting New York State solar may not be as highly correlated with wind but at night every single solar facility will not be producing any power. 

One of the challenges faced by the EWWG is trying to determine the worst-case renewable resource lull.  NYISO has had DNV do a similar analysis for onshore wind and solar resources in New York using the same 21-year data set.  Metrological experts on the EWWG have suggested using as long an input meteorological dataset as possible for an analysis to obtain a fuller understanding of range and return period of events. 

Finally, there is one more complication.  The meteorological conditions that lead to the lowest wind resource availability are associated with the coldest and hottest periods of the year.  Those periods cause the peak annual loads.  Wind and solar may provide power most of the time but when electricity is needed the most, they are expected to provide their lowest output.  I think this is an enormous challenge to the proposed “zero-emissions” electric grid that can only be addressed by using nuclear power.

Energy Storage Implications

To always provide reliable electricity, energy storage is needed to cover periods when solar and wind are not available.  Obviously, energy storage is needed to cover the daily variation of solar.  Energy storage duration is not a large issue for this requirement.  On the other hand, there is a seasonal variation of solar irradiance and resulting power output that needs a long-duration storage solution.   There are no commercially available long-duration storage systems that can be expanded to meet New York’s requirements.  There are also seasonal variations in wind resource availability that require a long duration system.  The biggest problem is the worst-case renewable resource lull.  The EWWG analysis found a one in twenty-year resource deficiency which is something that no long-duration storage system could ever effectively address. 

There are serious energy storage technological hurdles that have not been resolved.  Francis Menton writing at the Manhattan Contrarian summarizes energy storage problems in a recent post on a new British Royal Society report “Large-scale energy storage.”  Menton explains (my emphasis added):

Having now put some time into studying this Report, I would characterize it as semi-competent. That is an enormous improvement over every other effort on this subject that I have seen from green energy advocates. But despite their promising start, the authors come nowhere near a sufficient showing that wind plus solar plus storage can make a viable and cost-effective electricity system. In the end, their quasi-religious commitment to a fossil-fuel-free future leads them to minimize and divert attention away from critical cost and feasibility issues. As a result, the Report, despite containing much valuable information, is actually useless for any public policy purpose.

As noted previously wind and solar resources will be at their lowest expected availability during periods when the electric load peaks.  When heating and transportation is electrified this problem is exacerbated, peak loads will occur in the winter when solar resources are inherently low.  The Scoping Plan glossed over this challenge and nothing since directly addresses the challenge.  The rational thing to do would be to develop demonstration projects to prove feasibility and cost of the new technology needed before dismantling the current system.  Francis Menton explains why this is necessary and how it could work. 

Conclusion

Ed Reid explains how OSW developers describe the output of their projects in terms of the number of homes served.  He found issues with their calculations.  The developers ignore the support needed to provide electricity to the homes served when the wind isn’t blowing.

Supporters of OSW tout the higher capacity factors of this resource as a big benefit.  Ed Reid describes deficiencies in their arguments using average data.  This article explains that the problem becomes more acute when shorter-term extended renewable resource lulls are considered.  OSW will perform better than other renewable resources during periods when the energy is not critically needed. The conundrum is that when it is needed most,  OSW will fail at the same time New York’s onshore wind resources fail so an as yet commercially unavailable energy storage technology is needed.  All indications are that this problem extends into the adjoining control areas so they cannot be counted on.  Addressing this issue is a critical reliability consideration.  If not addressed correctly then the grid will fail when needed most and people will freeze to death in the dark.

One notable feature of New York’s Climate Leadership & Community Protection Act (Climate Act) implementation process has been the emphasis on environmental justice (EJ) for disadvantaged communities.  A dogmatic concern of New York City EJ advocacy organizations is peaking powerplants which are alleged to be a primary air quality problem in disadvantaged communities.  Unfortunately, those generating facilities fulfill a critical reliability service so the New York Independent System Operator (NYISO) has been warning that premature shutdown of the facilities will cause reliability problems.  This post highlights a relevant NYISO filing that concisely summarizes their concerns and recent comments by EJ advocates.  Get your popcorn, it will be interesting to see how this gets resolved.

I have been following the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 350 articles about New York’s net-zero transition.  I have devoted a lot of time to the Climate Act because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good.  The opinions expressed in this post 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.

Climate Act Background

The Climate Act established a New York “Net Zero” target (85% reduction 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” by 2040. The Climate Action Council is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.”  In brief, that plan is to electrify everything possible and power the electric grid with zero-emissions generating resources.  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 write a Draft Scoping Plan.  After a year-long review the Scoping Plan recommendations were finalized at the end of 2022.  In 2023 the Scoping Plan recommendations are supposed to be implemented through regulation and legislation. 

One of the implementation issues to be resolved is the subject of a New York State Public Service Commission (PSC) “Order initiating a process regarding the zero-emissions target” that will “identify innovative technologies to ensure reliability of a zero-emissions electric grid”.  The ultimate problem with wind, solar, and energy storage technologies proposed to replace fossil-fired electric generation is that they do not work all the time.  The Integration Analysis, NYISO, New York State Reliability Council, and the PSC order all recognize that a new technology is needed to support the grid during those periods.  The problem is exacerbated because the periods when wind and solar resources provide the least power are frequently the periods of highest load when peaking power plants are needed to prevent blackouts.  

Peaking Power Plants

I set up a page dedicated to this issue.  The following is a top-level summary.

In order to provide electricity to everyone who needs it when they need it the NYISO must balance power availability with the load on the system.  NYISO is responsible not only for the real-time delivery of power but also for reliability planning.  If the load did not vary, then this would be much less difficult but the reality is that load varies diurnally and seasonally.  Most important is meeting demand when loads are highest in the summer and winter because it is necessary to provide electricity to maintain the health and well-being of customers. Ultimately the problem boils down to the fact that there are short periods when so much load is needed that there are generating units dedicated by intent or circumstances to provide power during peak load demand. 

About fifty years ago, when Consolidated Edison was responsible for generating power and providing it to their customers, they developed a fleet of around 100 simple cycle combustion turbines at locations within New York City to provide this peaking power.  Those units were cheap but relatively inefficient and had high emission rates.  In a considered process the Department of Environmental Conservation, NYISO, and the owners of the facilities are in a regulation that ensures that the units either meet more stringent NOx emission limits or shutdown if the NYISO and Consolidated Edison do not identify specific reliability issues.  My point is that there is already a process in place to address the units that have always been considered peaking units.

The 2020 PEAK Coalition report entitled: “Dirty Energy, Big Money” is a primary reason that environmental justice organizations vilify all New York City peaking power plants.  I described this work in three posts.  I published a post that provided information on the primary air quality problem associated with these facilities, the organizations behind the report, the State’s response to date, the underlying issue of environmental justice and addressed the motivation for the analysis.  The second post addressed the rationale and feasibility of the proposed plan to replace these peaking facilities with “renewable and clean energy alternatives” relative to environmental effects, affordability, and reliability.  Finally, I discussed the  Physicians, Scientists, and Engineers (PSE) for Healthy Energy report Opportunities for Replacing Peaker Plants with Energy Storage in New York State that provided technical information used by the PEAK Coalition.  

There are two relevant aspects of the PEAK Coalition report.  That report did not make a distinction between the traditional peaking simple cycle combustion turbines and other power plants that were originally designed for frequent operations.  The fuel costs to burn oil at New York power plants is so expensive that they do not generally operate except in peak load periods.  “Dirty Energy, Big Money” only defined a peaking unit as one that operates infrequently so the EJ advocates consider these relatively large steam boiler units peakers.  The second point is that I found that the presumption of egregious harm from all the peaking facilities is based on selective choice of metrics, poor understanding of air quality health impacts,  and ignorance of air quality trends.  This is not as dire a problem as it is portrayed.

Peaking Power Plant Shutdowns

Environmental justice advocates believe that it is a problem.  Marie French recently wrote a Politico article that noted that “Shutting the units down is a top priority for environmental justice groups in the city”.  The article quoted Daniel Chu, the energy planner for the NYC Environmental Justice Alliance: “We think it’s unacceptable that for the sake of reliability, we would have to sacrifice communities for two more years or potentially even longer just to ensure that we don’t have blackouts or brownouts”.  He went on to say: “We don’t want blackouts or brownouts, but we also don’t want continued pollution.”

Raya Salter who is the founder of Energy Justice Law & Policy Center and is a member of the Climate Action Council never misses an opportunity to emphasize her belief that these facilities are a root cause of air quality health impacts in New York City disadvantaged communities.  In a recent Equity and Climate Justice Roundtable session, she argued that the New York Cap-and-Invest program should make shutting down the peaking units a priority.  She believes that equity is only achieved when fossil plant emissions are zero saying that “Anything less than shutting down power plants is a distraction from the goals of the Climate Act”.  However, she also says getting to zero mush be done “in a way that prioritizes emissions and co-pollutant reductions in front line communities and does not disproportionately burden disadvantaged communities”. 

The disconnect between those goals will have to addressed in another post.  You cannot have your cake and eat it too.  In this post I will consider the unconditional demand for shutdowns relative to the concerns of NYISO.

NYISO Reliability Concerns

Last month NYISO released its quarterly assessment of reliability of the bulk electric system which found  a deficit in reliability margins for the New York City area beginning in summer 2025.  I explained that report found that without changes to existing load pattern the summer peak load demand in New York City would be “deficient by 306 MW in 2025 for a duration of 7 hours”.  It is possible, due to uncertain load demand forecasts, that the deficiency could be “446 MW over 9 hours.”  They found that: “The deficient margin is primarily due to the increased demand forecasts within New York City combined with the planned unavailability of simple-cycle combustion turbines to comply with the DEC’s Peaker Rule in 2025”.   

On August 25, 2023 NYISO submitted comments on a petition filed by Alliance for Clean Energy New York, Inc. seeking modification to Clean Energy Standard Tier 1 Renewable Energy Certificate purchase and sale agreements as part of Case 15-E-0302 – Proceeding on Motion of the Commission to Implement a Large-Scale Renewable Program and a Clean Energy Standard.  The submittal includes a succinct description of the replacement power problem. 

In the introduction to the comments, the letter states:

The NYISO is committed to operating an electric system that provides reliable service 24 hours a day, 365 days a year, and to planning a reliable system for the future grid. The Climate Action Council’s Scoping Plan accurately notes, “[w]hile transitioning away from fossil fuel use, maintaining reliable access to power, whether through centralized or distributed energy sources, is crucial for maintaining good public health in our energy-dependent society.”  The NYISO takes no position on the issue of whether, and if so how, REC Agreements should be modified as requested in the Petition and related dockets. The NYISO offers these comments to highlight the importance of developing and deploying generation resources that comply with the CLCPA requirements in a manner that is rationally coordinated with the retirement of existing fossil resources so that system reliability is not jeopardized.

The following is the letter’s comments section (without footnote references):

New Yorkers have long enjoyed reliable electric service and will expect the same level of service to continue. Reliable electric generation supports every aspect of New Yorkers’ daily lives and is vital to the state’s economy. Economic development within the state is driving the interconnection of large loads to the grid and increasing the demand for electricity. As transportation and building heat turn to the electric grid to drive the required economy-wide greenhouse gas emission reductions, people will become even more dependent on reliable electric service for their health, welfare, and safety. Reliable electric service is critical today and will become more critical to everyone’s daily life and general well-being as other sectors of the economy electrify.

Reliable, dispatchable electric generation is in jeopardy as generation retires faster than new resources become operational. Electric system margins have decreased to unprecedentedly low levels. In fact, the NYISO’s Short-Term Assessment of Reliability for 2023 Quarter 2 concluded that the New York City locality is deficient by as much as 446 MW for a duration of nine hours on the peak summer day under expected weather conditions, after accounting for forecasted economic growth and policy-driven increases in demand for electricity. The deficiency would be significantly greater if New York City experiences a heatwave or an extreme heatwave. The narrowing margins and the identified deficiency in New York City demonstrate that the addition of new resources is timely and critical.

NYISO’s ability to facilitate a reliable electric system, including delivery to consumers, requires that the introduction of new resources be coordinated with and occur prior to the orderly retirement of any existing generators. This order of operations is critical for maintaining reliability after such retirements. Electric system reliability margins are already close to minimum reliability requirements in certain areas across New York and continue to tighten, as discussed above. If these margins are totally depleted, the reliability of the grid would be at risk and power outages could disrupt normal life or negatively impact public health, welfare, and safety.

The figures below demonstrate the trend of shrinking reliability margins. Figure 1 shows how resource retirements are beginning to outpace resource additions, notably over the last three years. Figure 2 depicts how this trend is leading to tighter reliability margins in the coming years. While the state’s bulk electric system meets current reliability requirements, risks to reliability and system resilience remain. One key factor driving this risk continues to be resource retirements outpacing additions.

A sufficient fleet of new generation resources that satisfy the CLCPA must be available before more of the existing, traditional generators retire voluntarily or are forced out of service. New generation resources are required now to serve consumers’ needs and to maintain electric system reliability as load increases and existing generators retire. Large-scale renewable energy

generation, offshore wind generation, storage, and distributed energy resources are needed to satisfy CLCPA mandates and to support electric system reliability. Renewable energy generation must still increase substantially to achieve the CLCPA’s 70 percent by 2030 renewable energy requirement and then increase further between 2030 and 2040. This transition will facilitate new renewable resources entering service in the near term, fossil generation will operate less and less prior to retiring, but remain available for when it is needed to serve load and maintain system reliability.

Conclusion

Two opposing viewpoints must be reconciled to resolve the direction of Climate Act implementation.  On one hand, there are ideologues who have so far been setting Climate Act policy.  Despite their lack of energy system qualifications, they argue that the Climate Act mandates require zero emissions.  On the other side NYISO says that introduction of new resources to get to zero emissions must be coordinated with and occur prior to the orderly retirement of any existing generators. Failure to acknowledge this requirement will risk and power outages that could disrupt normal life or negatively impact public health, welfare, and safety.

I believe that those who believe that the Climate Act law has no implementation restrictions are wrong.  There are reliability and affordability safety valve provisions in New York Public Service Law  § 66-p (4). “Establishment of a renewable energy program”.   §66-p (4) states: “The commission may temporarily suspend or modify the obligations under such program provided that the commission, after conducting a hearing as provided in section twenty of this chapter, makes a finding that the program impedes the provision of safe and adequate electric service; the program is likely to impair existing obligations and agreements; and/or that there is a significant increase in arrears or service disconnections that the commission determines is related to the program”. 

I have never seen anyone else suggesting that this is a possibility so it is likely that I am wrong.  In any event, is the Hochul Administration so invested in appeasing the EJ constituency that they are willing to risk causing a blackout or out of control energy costs?  In my opinion if the pragmatic approach to put the implementation on hold until the costs are known and reliability risks are minimized, the ideologues will have a meltdown and call for Hochul’s head.  There is no sign whatsoever that they will accept any compromises or delays to their demands.  As noted in the introduction, get out the popcorn watching this unfold is going to be fascinating.

On August 1, 2023 the New York State Comptroller’s Office released Renewable Electricity in New York State Review and Prospects (“Comptroller Report”) that addressed progress and prospects for attaining New York’s Climate Leadership & Community Protection Act (Climate Act) 2040 mandate for a zero-emissions electric grid.  This post discusses the findings of that report.

I have been following the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 350 articles about New York’s net-zero transition.  I have devoted a lot of time to the Climate Act because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good.  The opinions expressed in this post 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.

Climate Act Background

The Climate Act established a New York “Net Zero” target (85% reduction 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” by 2040. The Climate Action Council is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.”  In brief, that plan is to electrify everything possible and power the electric grid with zero-emissions generating resources.  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 write a Draft Scoping Plan.  After a year-long review the Scoping Plan recommendations were finalized at the end of 2022.  In 2023 the Scoping Plan recommendations are supposed to be implemented through regulation and legislation. 

Annotated Press Release

The press release DiNapoli: State Needs to Supercharge Efforts to Meet Renewable Electricity Goals is as good a place as any to discuss the report.  In this section I will comment on the points made.

My overarching concern with the Comptroller Report is that it underestimates the technological challenges of the net-zero transition.  That is entirely consistent with the Scoping Plan and the beliefs that the politicians who dreamed up the Climate Act and the ideologues who controlled the Climate Action Council can develop rational energy policy.  The introduction basically says all we must do is try harder:

New York state will have to take multiple steps to increase renewable electricity generation to achieve the objectives of the Climate Leadership and Community Protection Act (Climate Act). Success will also require state agencies to consistently and proactively identify and address problems, continue streamlining permit and interconnection study procedures, and develop the necessary infrastructure to connect renewable projects to the grid and New Yorkers’ homes, according to a report issued today by State Comptroller Thomas P. DiNapoli.

“New York State has rightly pursued an aggressive campaign to reduce greenhouse gas emissions to limit the most dangerous impacts of climate change,” DiNapoli said. “New York’s energy goals are attainable, but require careful attention and management to address challenges, meet ambitious deadlines and avoid future pitfalls.”

My first thought when I heard that the Comptroller had issued this report was why in the world did he get involved.  The definition of comptroller, a public official who audits government accounts and sometimes certifies expenditures, wasn’t much help.  The responsibilities listed on State Comptroller website includes “Providing independent fiscal oversight on State, New York City and local finances” which I suppose could provide justification. 

Fiscal oversight means numbers and the report quotes New York Independent System Operator numbers:

DiNapoli’s report found that renewable generators in New York would need to produce an additional 78,073-gigawatt hours above 2022 levels, an increase of over 200%, to reach the Climate Act’s 2030 goal of 70% renewable electricity consumption. The analysis is based on projections from the New York Independent System Operator (NYISO).

NYISO has also projected that the state would need to add 20 gigawatts of installed renewable capacity by 2030, which is triple the 2022 capacity of approximately 6.5 gigawatts. In the last 20 years, New York added 12.9 gigawatts of total electric generation, including both fossil fuel and renewable sources.

The press release discusses the actions taken to try to meet the targets:

The state has taken steps to address these challenges:

• Increased and consistent funding under the state’s Clean Energy Standard facilitated increases in the development of renewable electricity generation. Between 2017 and 2021, at least 1,100 megawatts of projects came under contract annually, compared to between 0 and 726 megawatts annually in the preceding years.
• The Department of State’s Office of Renewable Energy Siting (ORES) was formed to streamline the permitting process, and the NYISO has also been improving the interconnection process to bring renewable electricity generation projects online more quickly. Continuing to improve the renewable electric project permitting and interconnection processes to allow for timely approvals, while ensuring community responsiveness and project impacts are mitigated, is critical to achieving the Climate Act goals.

The solutions proposed here are supposed to be a good thing.  I am not impressed.  Increased and consistent funding translates to throw more and more money at it without a plan that defines what the affordability tolerance level is.  ORES is a gift to the renewable energy developers that circumvents environmental protections, home rule, and anything else that could slow down much less stop renewable development.  Here is a new flash to the Albany bureaucrats – not all projects deserve to be built.  ORES has no responsible solar siting requirements in place so solar developers routinely exceed the Department of Agriculture and Markets guidelines for protection of prime farmlands.  My solar development scorecard found that prime farmland comprises 21% of the project area of 18 utility-scale solar project permitted applications which is double the Ag and Markets guideline.

The following paragraph talks about the transmission requirements.  All the points raised are legitimate and there are few technological barriers to development.  It is just a matter of cost and no one has owned up to the expected costs.  The subsequent paragraph acknowledges the problem and implies the problem can be resolved can be resolved if the state wishes hard enough to hold down the costs.

The state will also face challenges given the volume and scale of new projects. The transmission capacity for connecting upstate regions to New York City is limited and renewable facilities in some upstate regions are already being forced to curtail generation due to transmission constraints. Significant new electric transmission infrastructure is needed to allow for the transmission of renewable electricity to customers throughout the state, including interconnect offshore wind projects and additional export capacity from Long Island, and bulk transmission connecting New York City and Long Island to upstate.

The costs of incentives to encourage renewable siting and the costs of transmission projects approved by the Public Service Commission are borne almost exclusively by New York’s utility customers. The state should make every effort to clearly identify how these costs will affect consumer electric bills and must hold down these costs to the state’s electric customers.

The final section of the press release explains “where New York ranks”.  It is not clear how relevant the numbers are vis-à-vis Climate Act implementation or why the 2022 data presented in the report were not used.  Also conspicuous by its absence is where New York ranks relative to global emissions.  Clearly, acknowledging that New York GHG emissions are less than one half of one percent of global emissions and global emissions have been increasing on average by more than one half of one percent per year since 1990 is not a fact that the Comptroller wants to acknowledge lest someone ask what is the point?

In 2020, New York produced 124,912 gigawatt hours of renewable energy, ranking 6th in the nation. This figure includes both renewable fuels, such as biodiesel, and renewable electricity sources, including hydropower, solar, and wind. New York was 3rd in the nation after Washington and Oregon in the generation of hydroelectric power, 10th in generation of solar electricity, and 18th in generation of electricity with wind.

As of 2022, approximately 29% of the electricity generated in the state came from renewable sources. Of this renewable generation, roughly 75% came from hydroelectric generation, with the remaining 25% primarily split between wind and solar.

Report Topics Not Included in Press Release

The press release was not an exhaustive summation of the contents of the Comptroller Report.  The report also addressed the renewable energy goals,

The Comptroller Report notes that:

The State’s renewable electric generation averaged 20 percent of total electric generation between 2005 and 2016. Since then, the share grew to approximately 29 percent of State generation in 2022. To reach the CLCPA goal of 70 percent in 2030, renewable generators in New York would need to produce an additional 78,073 gigawatt hours above 2022 production levels, an increase of over 200 percent.

It goes on to describe the New York Independent System Operator 2021-2040 System & Resource Outlook projections for the renewable energy needed.  It concludes that the State will have to increase the rate at which renewable electricity projects are permitted and approved for interconnection to the State electric grid.

This leads into a more detailed explanation of the challenges to meet the Climate Act goals.

There are three interrelated processes that play a role in the development of renewable electric generation resources in New York, and the State has faced challenges in each of these processes. These processes work on a parallel basis and project developers do not need to have completed any of the processes before they can enter one of the other processes.

Two of them, permitting and grid interconnection, are required for any all-new sources of generation.

• Incentives – Through various programs, particularly renewable energy certificates, incentives are provided to stimulate the market and ensure that there are enough renewable electric generation projects to meet State goals.
• Permitting and Siting – The permitting process is intended to ensure that projects are sited in areas and under conditions consistent with State and local laws and regulations.
• Interconnection – The interconnection process is intended to ensure that there is sufficient electric transmission and distribution infrastructure to move the electricity generated by the facilities to consumers and that electric service reliability standards are met.

The State faced three key challenges that hindered its progress: inconsistent provision of incentives; project cancellations; and lengthy project timelines due to delays in siting and operationalization.

In the discussion of the inconsistent provision of incentives the report stated that “New York State has used two basic approaches to incentivize the development of renewable electricity generation: contracts for the purchase of renewable energy certificates (RECs) from project developers proposing to build large scale facilities that sell electricity into the State grid; and incentives to reduce the cost of installing small facilities sited behind a customer meter that primarily generate electricity for the customer’s use, but also sell unused electricity into the distribution grid (BTM solar).”

The BTM solar incentive was cited as a success because distributed solar generation has grown steadily.  They claim that “the total combined capacity of complete projects and those in the pipeline for all years was approximately 7.1 gigawatts” as the result of increased funding commitments.  I don’t think the authors of the report understand that the electric energy planning commitment to providing reliable power at all times is hindered by this program.  There is no question that distributed solar generation reduce load requirements, but it creates operating challenges including short, steep changes in load that must be balanced, an oversupply risk when all the solar is operating at peak rates, and decreases resiliency when less resources are operating and available to automatically adjust electricity production to maintain grid reliability.  When the costs to address those problems are considered it is clear that success is limited.

The Comptroller Report argues that the RECs program has had mixed results. Each REC represents a megawatt hour of electricity sold into the State’s electric grid.  To date: “Most, but not all, of the large-scale renewable electricity generators that move through the permitting and interconnection processes are recipients of REC contracts.”   However, an analysis by the Comptroller’s Office shows a lot of variation in the projects that have had contracts:

Funding commitments under the State’s CES increased dramatically, resulting in a significant increase in the projects under contract, as shown in Figure 5. Whereas the last procurement under the RPS in 2016 carried a commitment of $360 million, the funding commitment for the 2017 procurement was approximately $1.4 billion.

The Comptroller Report seems to be surprised by the number of project cancellations:

Between 2005 and April 2023, 28 projects totaling 1.3 gigawatts were canceled—an amount equal to 11.3 percent of capacity under contract during those years—with the largest amount of capacity canceled in 2017, 2018 and 2020. In these years, canceled projects represented 20.4 percent of contracted capacity. Projects may be canceled for a variety of reasons including opposition to the project, changes in the finances of the developer, or unforeseen costs for transmission needed for grid integration.

The report notes that facilities that are operating but have lost their REC subsidies “could potentially enter into long term contracts with consumers outside of the State, which could prevent their generation from counting toward State goals.”  However, there is no mention of the operating facilities that already are under contract out-of-state.  Robert Bryce reviewed data published by the Department of Energy and the New England Power Pool and 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.  Furthermore, the Cassadaga Wind Project that was commissioned in 2021 produces power that was procured through the New England Clean Energy request for proposals’ in 2016 for a group of seven New England utilities.  Note that I have never seen an acknowledgement of this in any of the Scoping Plan documentation.

Two additional considerations are mentioned.  Getting the power from the wind and solar facilities to where it is needed is described:

New electric transmission and distribution capacity will be needed to connect the new renewable electric generation required to meet the CLCPA goals to the grid. Transmission capacity connecting upstate regions to New York City is limited and renewable facilities in some upstate regions are already being forced to curtail generation due to transmission constraints.

The other issue is affordability.  The report notes:  “The costs of incentivizing renewable electricity development and transmission upgrades are borne almost exclusively by New York’s utility customers through a charge per kilowatt hour of electricity consumed.”    The RECs described earlier are funded by the ratepayers.  In addition, the investments necessary to develop the transmission upgrades are buried in the rate cases.  The document suggests without justification that this problem will be addressed by existing programs.

Conclusion

Not surprisingly this political document proposes political solutions.  The acknowledged problems of the timeline can be resolved if “the projects currently under contract to sell RECs to the State and the projects in the NYISO’s interconnection queue are able to move through the interconnection and construction process and needed transmission and distribution infrastructure is completed in a timely way, the CLCPA’s goal of generating 70 percent of the State’s electricity with renewable technologies appears to be in reach.”  The Comptroller’s Report falls back on the it is only a matter of political will faith-based creed.  Reality is very likely to make that impossible.

In addition to political will, the report suggests that we can resolve issues by throwing more money at projects.  The State’s prior poor performance is chalked up to inconsistent funding commitments. At the same time, it acknowledges that “mechanisms to hold down the cost of meeting its goals on the State’s electric consumers” are necessary.

Against the background that New York’s contribution to global GHG emissions is less than the rate of increase in global emissions my frustration is unbounded.  Is it too much to ask Albany politicians to document the expected costs, the potential risks to reliable energy, and the environmental tradeoffs of the net zero transition called for in the Climate Act?