Category: Climate Act Feasibility

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? 

On July 2, 2023 the Syracuse Post Standard published my letter to the editor Expert’s view of solar energy’s potential in NY is far too sunny that responded to an earlier commentary  Five Reasons New Yorkers Should Embrace a Solar Energy Future by Richard Perez, Ph.D.  On July 16, 2023, a couple of rebuttal letters responded to my commentary: In defense of solar energy development in New York. 

Given that there are limitations on how often I can get letters published I must settle for responses here. 

New York’s response to climate change is the Climate Leadership & Community Protection Act (Climate Act).  I have been following the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 300 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, an interim 2030 target of a 40% reduction by 2030, and 100% “zero emissions” electricity generation by 2030. 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 by 2040.  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. 

According to the New York Independent System Operator (NYISO) “Gold Book” load and capacity report, in 2022 there were a total of 4,444 MW of solar nameplate capacity (154 MW of utility-scale solar and 4,290 MW of behind-the-meter) on-line in the state.   However, implementation of the Climate Act transition to net-zero will significantly increase that amount by 2030.  By 2030 the New York State Energy Research & Development Authority (NYSERDA) and consultant Energy + Environmental Economics (E3) Integration Analysis that provides quantitative estimates of resources for the Scoping Plan projects a total of 18,852 MW and the NYISO 2021-2040 System & Resource Outlook projects 14,731 MW.

Rebuttal to Letters to My Commentary

There were two letters published in response to my commentary.  The first by Shelley Conture from

Syracuse and the second by Gary McDermott from Chittenango.  I have attached all the commentaries below for your information.  Conture basically repeated everything Perez said and insinuated that because he has “notable credentials” he must be right.  McDermott addressed the points I made and raised a couple of points that deserve clarification.

Perez claimed the Earth receives more solar energy than the total annual energy consumption of all economies, combined, in a week.  I argued that ignores that availability when and where needed is a critical requirement. In New York, the winter solar resource is poor because the days are short, the irradiance is low because the sun is low in the sky, and clouds and snow-covered panels contribute to low solar resource availability. 

McDermott responded: “No one is claiming solar power will be the only source, but rather a major source of power in the future. We will always use hydropower in New York.”  Both statements are true but both are naïve.  The Integration Analysis projects that by 2035 there will be more installed solar capacity than today’s fossil capacity so the issue is the magnitude of the reliance on solar.  My concern with hydro is that we cannot add significantly more capacity so its advantages are tapped out.

McDermott goes on to address specifics associated with solar abundance.  He states that “The suggestion that winter days are too short for solar fails to recognize that we also have 15-hour long days in the summer, three hours longer than Florida” but ignores the implication that reliability requires electric planners to consider the worst case.  When everything is electrified, the peak load will be in the winter so we must address 9-hour long days.  He says “As far as snow on panels is concerned: It’s simple to brush snow off a 35-degree slope panel, especially since we don’t get as much annual snow.”   Not considering the worst case is problematic here too.  It may not be so simple to brush snow off panels if it is not possible to get to the panels because there is too much snow or ice.  Better would be a requirement that the utility-scale solar installations use tilting-axis panels so that they can be adjusted to minimize snow accumulation, albeit that only works if there is no power outage.  More of a problem is that roof-top distributed systems may not accessible to clear off.  He again ignores the worst case when he states “Also, wind power occurs at night.” Wind lulls can occur at night and then what?

I firmly believe that most people do not understand the ramifications of the Climate Act.  McDermott appears to be knowledgeable but does not understand the Climate Act targets when he says “During low sunshine conditions, natural gas energy can temporarily fill in, but with greater volumes of solar power, our net gas usage would grow much smaller.”  The goal of the Climate Act is no natural gas by 2040.  The practicality of that mandate is the issue.  

I made the point that there is no mandate that solar developments meet the Department of Agriculture and Markets prime farmland protection goal and that projects approved to date have converted 21% of the prime farmland within project areas to unusable land.  I do not disagree with McDermott’s response except that I stand by the prime farmland protections.  Responsible solar siting that includes agrivoltaics is appropriate but not enough.  He states:

In Boulder, Colorado, farmers grow tomatoes, turnips, carrots, squash, beets, lettuce, kale, chard and peppers under 8-foot-high solar panels. I recommend that state laws require solar farm panels to be built this high, to maintain farming. With this reality in mind, the greatest threat to farm land is not solar, but rural housing developments.

McDermott’s other comments do not stand up to scrutiny.  He said that “It’s pointless to complain about new transmission requirements when any new source of electricity will require additional power lines.”  The point is that diffuse renewables require much more transmission and getting offshore wind into the existing grid system is extraordinarily expensive.  I disagree with his statement that “Solar panels last 30 years, whereas combined-cycle gas turbines last only between 25 and 30 years, and produce more pollution.”  The life expectancy of a gas plant is on the order of 40 years and I have never heard a solar developer claim 30 years.  In addition, solar panels degrade 0.8% per year but fossil plants do not degrade.  There are also significant environmental impacts associated with mining the rare earth metals necessary for solar panels.

Both Conture and McDermott claim solar is cheaper.  McDermott says “On average, it costs about $200,000 more per megawatt to build a gas plant than it does a solar farm.”  Conture just repeats what Perez said.  In the limited space I had, I said:

Perez claims that “utility-scale solar electricity has become the least expensive form of electricity generation” but that only refers power capacity (MW). When you consider the relative amount of energy that can be produced annually, the storage needed to provide energy when the sun isn’t shining, the shorter life expectancy of PV panels, transmission support service requirements and the need for a new dispatchable, emissions-free resource, then the cost of solar energy provided when and where needed is much higher than conventional sources of electricity.

In my post providing background material for the commentary, I expanded on this description.  The claim that “utility-scale solar electricity has become the least expensive form of electricity generation” refers only to power capacity (MW).  Even if solar capacity is half the cost of fossil capacity the cost for delivered energy is much more.  We pay for the kWh electric energy we use each month and we expect it to be available 24-7 throughout the year.  In order to provide usable energy, other things must be considered that destroy the myth that utility-scale solar is cheaper than other types of power plants.  On average a well-designed solar facility can provide (round numbers) 20% of its potential energy possible in New York.  A natural gas fired power plant can operate to produce at least 80% of its potential energy over a year.  In order to produce the same amount of energy, that means that you need four times as much solar capacity.  Even if the solar capacity cost is half the cost for the capacity the energy cost is double simply due to this capacity factor difference. 

But wait, there is more.  In order to make the energy available when needed storage must be added to the cost of the solar capacity.  Also consider that the life expectancy of solar panels is less than the observed life expectancy of fossil-fired power plants.  There are unintended financial consequences that affect the viability of other generators that are needed for reliability that add to ratepayer costs. Because the solar resource is diffuse, it is necessary to support the transmission system to get the solar power to New York City.  There are inherent characteristics of conventional generation that contribute to the stability of the transmission system that are not provided by solar or wind generation.  Someone, somewhere must deploy a replacement resource to provide those ancillary transmission services and that cost should be included the cost comparison. 

Finally, the Integration Analysis, New York Independent System Operator (NYISO, New York State Reliability Council), and the Public Service Commission all agree that another resource that can be dispatched and is emissions-free (DEFR) is needed when the electric grid becomes dependent upon solar and wind resources.  The state’s irrational fear of nuclear generation precludes the only proven resource that meets the necessary criteria so an entirely new resource must be developed, tested, and deployed. 

The Integration Analysis and NYISO 2021-2040 System & Resource Outlook both project that the DEFR resource will be comparable in size to existing fossil resources but will operate no more than 9% of the time.  I have yet to see an expected cost for this resource but have no doubts that it will be extraordinarily expensive.  Summing all the costs necessary to make solar power usable for electric energy reliable delivery and there is no doubt that solar is much more expensive.

Conture brings up an issue that McDermott does not address. She says:

With regard to reliability, he discusses the emerging solutions to the concern about solar energy’s intermittency. In his words these solutions, (which he enumerates) “will ensure a continuous power supply which will be available day and night year round without fail.”

Perez discounts the need for and difficulties associated with DEFR technologies that the organizations responsible for electric system reliability all agree are necessary.  The NYISO’s recent reports all emphasize the point that DEFR is not “commercially available” and the PSC Proceeding is devoted to this issue.  I believe that a ensuring a continuous power supply is much more difficult than Perez thinks.

Conclusion

Sadly, readers of the Post Standard will likely remember the last opinions and not mine despite the fallacies of the writers.  Conture appeals to authority and simply repeats what Perez said.  McDermott at least tries to address my points.  Part of his reasoning is that my arguments are invalid because he underestimates the magnitude of the solar resources projected in the Scoping Plan and the Climate Act target that mandates zero emissions by 2040.  My concerns are directly related to the impacts of those considerations. 

Perez subscribes to the academic belief that exiting renewable technologies are sufficient and deployment will result in lower costs.  The fatal flaw in the arguments supporting those points is that they don’t address the worst-case renewable energy droughts that will coincide with future larger peaks in the winter.  The organizations responsible for reliability in New York State all agree that unless nuclear power is deployed that a resource that is not yet commercially available must be developed, tested, and deployed.  I think that is an incredible risk unacknowledged by Perez and the authors of these letters.

I stand by the concluding remark in my commentary. This is a recipe for disaster because if the resource adequacy planning does not correctly estimate the worst-case period of abnormally low wind and solar energy availability then the energy needed to keep the lights on and homes heated will not be available when needed most. People will freeze to death in the dark.

Caiazza Commentary

The June 12, 2023, commentary “Five reasons New Yorkers should embrace a solar energy future” by Richard Perez, Ph.D., claims to “clarify common misunderstandings about solar energy and demonstrate its potential to provide an abundant, reliable, affordable and environmentally friendly energy future for New York.” I disagree with his reasons.

Perez claim the Earth receives more solar energy than the total annual energy consumption of all economies, combined, in a week but ignores that availability when and where needed is a critical requirement. In New York, the winter solar resource is poor because the days are short, the irradiance is low because the sun is low in the sky, and clouds and snow-covered panels contribute to low solar resource availability.

“Solar technology is improving” is another claimed reason but solar energy in New York is limited because of the latitude and weather so there are limits to the value of technological improvements. If it is so good, then why does deployment rely on direct subsidies?

While solar energy may not have environmental impacts in New York, that does not mean that there are no impacts. Instead. they are moved elsewhere, likely where environmental constraints and social justice concerns are not as strict. The rare earth metals necessary for solar, wind and battery technology require massive amount of mining and the disposal of all the solar panels are significant unconsidered environmental issues.

Perez dismisses land use issues because “a 100% renewable PV/wind future for New York would require less than 1% of the state’s total area.” There is no mandate that solar developments meet the Department of Agriculture and Markets prime farmland protection goal. Projects approved to date have converted 21% of the prime farmland within project areas to unusable land. There is no requirement for utility-scale solar projects to use tracking solar panels, so more panels are required than originally estimated.

Perez claims that “utility-scale solar electricity has become the least expensive form of electricity generation” but that only refers power capacity (MW). When you consider the relative amount of energy that can be produced annually, the storage needed to provide energy when the sun isn’t shining, the shorter life expectancy of PV panels, transmission support service requirements and the need for a new dispatchable, emissions-free resource, then the cost of solar energy provided when and where needed is much higher than conventional sources of electricity.

The suggestion that a system depending on solar energy will be more dependable than the existing system would be laughable if it were not so dangerous. The reliability of the existing electric system has evolved over decades using dispatchable resources with inherent qualities that support the transmission of electric energy. The net-zero electric system will depend upon wind and solar resources hoping they will be available when needed, additional resources to support transmission requirements, and a new resource that is not commercially available. This is a recipe for disaster because if the resource adequacy planning does not correctly estimate the worst-case period of abnormally low wind and solar energy availability then the energy needed to keep the lights on and homes heated will not be available when needed most. People will freeze to death in the dark.

Conture Response

I am writing to express my disagreement with a letter in the paper on Sunday, July 2, 2023, “View of NY solar energy potential is far too sunny.” The letter writer refers to the essay, “5 reasons New Yorkers should embrace a solar energy future,” by Richard Perez, Ph.D., published June 12, 2023.

This writer even refers to Perez’s stated goal which is to “clarify common misunderstandings about solar energy and demonstrate its potential to provide an abundant, reliable, affordable environmentally friendly energy future for New York” in a way that suggests that there is something questionable about this goal. I have read Perez’s essay and strongly disagree with these negative implications.

Perez is far more than a concerned citizen expressing his strong opinion. Along with other notable credentials, he heads solar energy research at SUNY Albany’s Atmospheric Sciences Research Center and has served multiple terms on the board of the American Solar Energy Society.

As intended, he covers the topics of the growth of solar technology as well as solar energy’s abundance, affordability, reliability and significantly lower environmental footprint — and he does so very well. He also addresses the concerns about its affordability and reliability in ways that should reassure people who are concerned about these issues.

With regard to reliability, he discusses the emerging solutions to the concern about solar energy’s intermittency. In his words these solutions, (which he enumerates) “will ensure a continuous power supply which will be available day and night year round without fail.”

And with regard to affordability, as with his other responses to common misunderstandings, Perez is careful to back up his statement that, “solar power is now considerably cheaper than new coal, natural gas or nuclear energy.”

What I especially objected to in the July 2 letter is the writer’s calling what Perez suggests “dangerous” and implying that we would do much better by continuing to stay with our conventional sources of electricity. This would, of course, involve the burning of fossil fuels, which is known to be the primary cause of the greenhouse gases that cause climate change.

I totally understand why people might prefer to do this. It would be more convenient and more familiar. But what I, along with many others, believe is that this is no longer a real choice. Our choice is actually between staying addicted to fossil fuels and believing the misinformation promoting them, or making difficult but ultimately better choices which could halt the continuing destruction of the planet.

Shelley Conture

Syracuse

McDermott Response

In response to Roger Caiazza’s letter on solar power, “View of NY solar energy potential is far too sunny.”

No one is claiming solar power will be the only source, but rather a major source of power in the future. We will always use hydropower in New York. The suggestion that are winter days are too short for solar fails to recognize that we also have 15-hour long days in the summer, three hours longer than Florida. As far as snow on panels is concerned: It’s simple to brush snow off a 35-degree slope panel, especially since we don’t get as much annual snow. During low sunshine conditions, natural gas energy can temporarily fill in, but with greater volumes of solar power, our net gas usage would grow much smaller. Also, wind power occurs at night.

In Boulder, Colorado, farmers grow tomatoes, turnips, carrots, squash, beets, lettuce, kale, chard and peppers under 8-foot-high solar panels. I recommend that state laws require solar farm panels to be built this high, to maintain farming. With this reality in mind, the greatest threat to farm land is not solar, but rural housing developments.

It’s pointless to complain about new transmission requirements when any new source of electricity will require additional power lines. On average, it costs about $200,000 more per megawatt to build a gas plant than it does a solar farm. Solar panels last 30 years, whereas combined-cycle gas turbines last only between 25 and 30 years, and produce more pollution. People pay less for solar electricity.

Gary McDermott

Chittenango

At the Business Council of New York 2023 Renewable Energy Conference Energy Richard Ellenbogen, President [BIO] Allied Converters, gave the keynote address.  This post summarizes the power point presentation for his address: “Energy on Demand as the Life Blood of Business and Entrepreneurship in the State –  Why NY State Must Rethink Its Energy Plan and Ten Suggestions to Help Fix the Problems.” 

Ellenbogen frequently copies me on emails that address various issues associated with New York’s Climate Leadership and Community Protection Act (CLCPA).  I have published other articles by Ellenbogen because he truly cares about the environment and the environmental performance record of his business shows that he is walking the walk.   When he sent a copy of the presentation I asked if I could it post after the conference.

Climate Leadership and Community Protection Act Background

The CLCPA established a New York “Net Zero” target (85% reduction and 15% offset of emissions) by 2050 and an interim 2030 target of a 40% reduction by 2030. 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 by 2040.  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. 

Richard Ellenbogen

I have published other articles by Ellenbogen because he truly cares about the environment and the environmental performance record of his business shows that he is walking the walk.   His bio is available at the Business Council website.

Ellenbogen’s presentation covers four major points before making recommendations.  I summarize each of these points in the following.

Energy System

Ellenbogen  describes the energy system as an introduction to the problem and what he thinks we should do.  He explains that we want an energy system that provides reliable, affordable, and clean power but that based on what has been happening in Germany the current plan will negatively impact all those features.  He argues that climate change is a real issue and that methane also needs to be addressed.  He makes a good argument that the plans to eliminate natural gas before zero emission sources of electrical generation will decrease the rate of decarbonization.  He projects that the costs of CLCPA implementation will exceed $4 trillion because the entire electric transmission, distribution, and electric service system will have to be replaced.  These costs are far in excess of anything that the Hochul Administration has  claimed.  His introduction concludes that we need to adjust the plan.

Implementation

Ellenbogen describes obstacles to implementation in the next section.  He lists ten specific obstacles and then goes on to highlight a few issues.  He addresses heat pumps and gas stoves.  His presentation points out that converting to heat pumps “will not reduce GHG emissions or energy prices on a generation system supported by fossil fuels”.  Germany has tried to do this and it has not worked out as planned.  In particular, he explains in Germany that “it just moved the CO2 emissions to a different location with an as large or larger CO2 footprint and with much higher operating costs!”.  He points out that Germany’s past 30-year history is New York’s future.  There are similar concerns about gas stove and explains why the conclusions of recent gas stove studies are “extremely questionable” that are being used to justify banning those appliances.

In order to describe the difficulties associated with implementation he delves into the physics of power and energy.  They are not the same thing as shown in the following slide.  CLCPA  proponents often do not properly recognize the distinction and that misleads the public on the capabilities of wind and solar generation.  He also describes the capabilities of different types of generation.

CLCPA Fantasy

The physics lessons are necessary to show why the CLCPA Scoping Plan is a fantasy.  He compares the power and energy projections in the Integration Analysis and then explains why the documentation is using unrealistic energy estimates.  As a result, he points out that “the solar energy output is being over-estimated in the CLCPA by 72%”.  There is a slide that describes the CLCPA generation plan that concludes that the assumptions are unrealistic.  Keep in mind that the Integration Analysis model back calculated the resources required to meet the CLCPA targets but did not incorporate a feasibility analysis to determine if those assumptions were realistic.  He points out that the benefits claimed do not consider state emissions relative to the rest of the world:  “NY state could eliminate 100% of its GHG emissions and not affect damages caused by climate change”.  He also notes that “in the last two years the rest of the world GHG emissions increased seven times as much” as New York total emissions.

Reality

Ellenbogen summarizes New York State energy in a chart with four columns that list energy use in  gigawatt-hours:

1. Total existing energy use
2. Energy use if it was fully converted to electric systems
3. The amount of storage expected to be installed by 2040 according to the recently released NYSERDA NY state energy roadmap
4. The amount of new renewable generation that will be installed by 2035.

He makes two points with the graph.  The renewable energy installation schedule is falling behind as he predicted in March 2019.  The other point is that converting buildings to all electric energy has a hidden problem.   Natural gas deliveries to homes are “used with an efficiency over 80% to 95% during onsite combustion so replacing it will require staggering amounts of electrical generation.”  In order to replace it power plants will have to generate the needed electricity because the renewables won’t be reading in time.   Power plant efficiencies are in the range of 33% – 50% and there is another 7% energy loss on transmission lines delivering it to the end user.

Short-term Recommendations

 His presentation explains that we need to decrease energy use and increase renewable energy development to reduce the carbon footprint.  He goes on to describe problems with energy storage.  All this leads up to his recommendation to keep onsite gas combustion in place so that less energy is needed to heat homes and energy storage is not needed.  He makes a total of ten short-term recommendations that will rapidly reduce GHG emissions with much lower installation costs while also slowing or reversing utility bill increases.  The ten recommendations are:

1 – Do not electrify buildings that run on natural gas – while it will reduce GHG at the building, it will increase it as much at the generating plants While forcing residents and the utilities to incur enormous rewiring costs. There will be no reduction in column a (fossil fuel consumption).  Also, the gas stove analysis that was done recently was mathematically flawed and should not be used to set public policy. However old gas stoves should be replaced with new ones and a gas detector.

2 – Focus heat pump efforts on locations that use oil heat or that use radiant electric heat. Those locations will see a significant reduction of GHG and heat pumps will reduce grid load when compared to radiant electric heat.

3 – Focus resources on expanding grid infrastructure. This will reduce the cost of installing solar in upstate locations and reduce the number of system cancellations allowing the state to increase renewable energy development.

4 – Increasing grid infrastructure will also help with the installation of chargers for the electric vehicle wave that is about to arrive, with or without the state mandate.

5 – Do not install large amounts of battery storage until there is sufficient renewable generation to support the storage. It will increase fossil fuel usage while incurring an enormous capital outlay and starving other projects of funding. They will also decay well before sufficient renewable generation is installed.

6 – Replace older generating plants with higher efficiency combined cycle natural gas generating plants. The state will need the energy to support the EV’s and the newer plants are far more efficient. It will lower energy use, reduce gas usage and put downward pressure on the commodity price.

7 – Develop technologies other than electrolysis to generate green hydrogen (thermochemical, pyrolisis, etc.) Place an emphasis on hydrogen injection into natural gas combustion plants. It will decrease gas usage and increase combustion temperatures which reduces NOx emissions and overall energy use It will greatly lower GHG emissions at those generating Plants

8 – Focus available natural gas resources on combined heat and power systems. It will reduce the utility bills for the system owners while also reducing requirements for grid infrastructure. Allow multiple buildings to form micro-grids to utilize the thermal output and increase the generation capacity. It will greatly reduce statewide energy use and reduce the need for as much transmission infrastructure

9 – Allow Micron Technologies to build a combined cycle plant the size of Cricket Valley Energy Center on their property. The Micron facility will use more energy than the state of Vermont. With generation on-site, the thermal energy could be used at the plant and the 350 GWh of annual line loss will be eliminated. Instead of making them look “green” on paper by buying carbon credits, let them be green

in reality with high efficiency generation and have lower energy costs to make them more competitive and able to recoup the $5 billion rebate without faking it. That will eliminate the increase in statewide energy use related to the facility.

10 – Figure out how the utilities can interconnect the 9 GW of offshore wind because at the moment, no one is certain how to do it. There is limited space for underwater cables. Without that, energy curtailments will occur and impede the increase of renewable energy development, unless they use the alternative idea which is to run transmission lines across Long Island where there will be inevitable NIMBY delays.

Long-Term Recommendation

His long-term recommendations call for the development of 12 GW of nuclear generation.  That is equivalent to six facilities the size of the recently closed down Indian Point plant.  He suggests that they should use a circular fuel cycle to cut down on nuclear waste and be located near existing plants that already have necessary infrastructure.  He argues that the fatal flaw of the state’s plan is the cost of the energy storage required to backup wind and solar.  Even though nuclear is expensive the costs will be much lower than the any storage options.  In addition, the land required to provide the power would only be 3% of the land for just the solar developments.

Conclusion

Ellenbogen provides a rational and pragmatic approach to greatly reduce GHG emissions at costs that would be far less expensive than the costs of the CLCPA.  At some point the Hochul Administration is going to have to confront the reality that no amount of dodgy cost benefit analysis can avoid the reality of enormous costs.  Also ignored are the technological challenges associated with a new resource that can be dispatched without generating emissions.  Ellenbogen proposes to use the only proven resource that meets those requirements and I agree that his long-term recommendation to develop nuclear power is the only chance to succeed.   I fully support his argument that New York State is headed down a path that has not worked elsewhere as described in the following slide.