Category: Climate Act Implementation Components

Status Update on New York Wind and Solar Generation Capacity Factors

Note – Table 2 was corrected on May 25, 2025 at 21:30 EDT

Last year I published an article describing the New York Independent System Operator (NYISO) Load & Capacity Data Report (also known as the “Gold Book”) and how I used it.  This post uses the latest edition to determine the wind and solar capacity factors last year.

I am convinced that implementation of the Climate Act net-zero mandates will do more harm than good because the energy density of wind and solar energy is too low and the resource intermittency too variable to ever support a reliable electric system relying on those resources. I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 500 articles about New York’s net-zero transition.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes an interim reduction target of a 40% GHG reduction by 2030 and a mandate for zero-emissions electricity by 2040.  The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.”  After a year-long review, the Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation. 

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Capacity Factor

The capacity factor is a useful metric to understand electric generation resources.  The annual capacity factor for a generator equals the actual observed generation (MWh) divided by maximum possible generation (capacity in MW times the hours in a year).  Projections for the amount of future wind and solar generation capacity needed for the Climate Act depend on capacity factor assumptions.

Not surprisingly, the aspirational schedule of the Climate Act has proven to be more difficult to implement than planned and many aspects of the transition are falling behind.  Worse, there has not been any indication that the Scoping Plan is being refined to incorporate the lessons learned in the years since it was drafted or address any of the issues raised in the comments.  The capacity factor assumptions are a prime example of an issue that needs to be addressed.

Wind and Solar Capacity Factor Projections

I have previously summarized future resource projections. The New York Independent System Operator (NYISO) 2021-2040 System & Resource Outlook is part of the NYISO Comprehensive System Planning Process.  That analysis included several scenarios for the future grid that includes capacity factor projections.  The Integration Analysis also included several scenarios and capacity factor projections.  In both instances the capacity factor projections determine how much wind and solar capacity will be needed in the future.

I am not the only one who submitted comments about the Scoping Plan capacity factors.  I pointed out that the Integration Analysis land-based wind capacity factors were unrealistically high.  The model projected the 2020 generation with a capacity factor of 29% but the 2021 observed capacity factor was only 22%.  The Integration Analysis model could not even get the starting year correct.  As a result, the Integration Analysis projections for the land-based wind capacity needed to meet the load are too low.  It is particularly disturbing that the State has never attempted to reconcile the NYISO projections and assumptions with the Integration Analysis.  For all renewable resources the Integration Analysis capacity factors are higher than the NYISO projections as shown in Table 1.

Table 1: Capacity Factors (%) NYISO Outlook Study S-1 and Integration Analysis Mitigation S-2

2024 Wind and Solar Observed Capacity Factors

The New York Independent System Operator (NYISO) 2024 Load & Capacity Data Report (also known as the “Gold Book”) is now available and has been posted on the NYISO website: 2025 Load & Capacity Data Report (Gold Book).  Many of the most useful tables are also provided as spreadsheets.  The following supplemental materials have also been posted:

The Existing Generating Facilities spreadsheet was used to calculate New York capacity factors.  Table 2 sums the capacities and net energy for all the combinations of primary fuel type and secondary fuel type for all the generators tracked by the NYISO.  This includes units that are in the market system as well as others that are not.  The nameplate capacity of generating units that use natural gas and can also burn number 2 fuel oil is the largest category in the state.

Table 2: 2025 NYISO Gold Book Tables III – 2a NYISO Market Generators and Table III – 2b Non-Market Generators 2023 Capacity, Energy, and Capacity Factors

Table 3 lists the capacity data and net energy produced for the wind generating units in New York.  Note that the Western NY Wind Power site was deactivated and that the offshore Southfork Wind Farm came on line on July 16, 2024.  Using the data, it is possible to calculate the capacity factors for each facility.  The NYISO Resource Outlook and the Integration Analysis both assume a land-based 34% capacity factor in 2030.  Only one wind farm exceeded 34% and there were seven more that were over 30% capacity of the 30 wind farms in New York.  In 2023 two exceeded 34% and three exceeded 30%.  The overall capacity factor was up from 21.8% to 23.4%.  To achieve the assumed capacity factor for 2030 most of the existing onshore wind farms will have to be replaced.  The Integration Analysis does not retire any of the existing wind farms which I suspect is so that the cost estimate does not have to include those costs.

One of the oft-touted benefits of offshore wind is that it will have higher capacity factors.  The NYISO Resource Outlook and the Integration Analysis both assume offshore wind capacity factors of at least 45% in 2030.  The annual observed capacity factor was only 34.8%.  I assumed that the full capacity was available on the in-service date.  That might explain why the offshore wind capacity is so low.

Table 3: NY 2024 Wind Facilities in the 2025 Gold Book

I have been tracking the wind farm capacity factors since 2006 as shown in Table 4.  There is nothing to suggest that 2024 was an abnormal year.  To meet the 2030 projections these wind farms are going to have to be replaced or a large number of wind farms with much higher capacity factors that will bring the average up will have to be built.  The data shown are also interesting as they show large interannual variation by site and the state overall.  Finally note that the NYISO wind capacity factor for 2019 was modeled as 25% but the observed capacity factor was  22.3%.  The Integration Analysis did not get their first year correct either.  It modeled the 2020 capacity factor as 29% but the observed capacity factor was only 23.9%.

Table 4: New York State Onshore Wind Facility Capacity Factors Based on NYISO “Gold Book” Load & Capacity Data Reports Table III-1

In 2024 the capacity factor of the solar facilities in New York was 17.7%, the highest capacity factor was 22.6% and the lowest capacity factor was 12.8%. The NYISO assumed a capacity factor of 15% from 2019 to 2040.  On the other hand, the Integration Analysis assumed a capacity factor of 17% in 2020, increasing to 20% by 2030 so they expected a capacity factor of 18.2% in 2024.  The observed capacity is less than the Integration Analysis.

Table 5: NY 2024 Utility-Scale Solar Facilities in the 2025 Gold Book

I have been tracking the industrial solar facility capacity factors since 2018 as shown in Table 6 but until 2022 there was only one reporting facility.  There is nothing to suggest that 2024 was an abnormal year. 

Table 6: New York State Utility-Scale Solar Facility Capacity Factors Based on NYISO “Gold Book” Load & Capacity Data Reports Table III-1

Discussion

The NYISO has interesting generation resource information available in its Gold Book.  As shown here, that information can be used to calculate the capacity factors for wind and solar resources in New York.  The annual wind capacity factors observed are consistently lower than the values used in the Integration Analysis which is being used to implement the state plan to meet the Climate Act mandates.  Solar is better but the statewide capacity factor is less than the Integration Analysis projection in 2024  As a result, The Scoping Plan is underpredicting the wind and solar resources necessary to generate the energy they project will be needed. That means that their cost projections are too low.

It is troubling that the differences shown here between the NYISO capacity factors and the Integration Analysis capacity factors have not been reconciled.  Worse, none of the differences between the two sets of projected resource projections have been addressed.  This matters not only because the differences affect the projected outcomes and the costs, but also because Integration Analysis projections are being used for the New York Cap-and-Invest (NYCI) Program proposal.A key component of the NYCI plan is the trajectory for allowance allocations.  NYCI’s reduction trajectory is based on the Integration Analysis and the overly optimistic capacity factors used means that they are projecting lower emissions than is likely to occur.  That imbalance could have significant consequences to the allowance market.

One other point is that these are annual metrics.  In order to assure that the electric grid will be able to provide energy when it is needed the most the NYISO must deal with resource availability over shorter periods.  Think of it as the capacity factor over the coldest week of the year.  That is a much more difficult issue and one that the Scoping Plan did not address and has not been addressed by the Public Service Commission.

Conclusion

This post documents the most recent wind and solar capacity factors observed in New York.  It is notable that the wind data show a lot of interannual variation that should be considered when projecting future resource availability.  Historical data have not been incorporated into an updated analysis of the generating resources needed to achieve the Climate Act goals. 

I have long argued that the State’s plans for implementing the Climate Act mandates must include a feasibility study that could address the observed variability and lower capacity factors.  Given the tremendous uncertainties like these shown here, I have recently decided that a feasibility study is not enough.  No jurisdiction anywhere has successfully demonstrated an electric grid that depends on wind and solar to the extent that the Scoping Plan does.  Before New York goes any further it should prove it can be done with a demonstration project.  Anything less risks catastrophic blackouts and enormous costs.

Champlain Hudson Power Express Payment in Lieu of Taxes Grift

One of the reasons that I decided to submit a statement in opposition to the Niagara Mohawk Power Corporation dba National Grid (NMPC) rate case proceeding was the lack of transparency on costs of the Climate Leadership & Community Protection Act (Climate Act) net zero transition.   This article describes a Climate Act cost to New Yorkers that uncaring Albany policy makers pass down to localities.

I am convinced that implementation of the Climate Act net-zero mandates will do more harm than good because of reliability and affordability risks.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 500 articles about New York’s net-zero transition.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes an interim target of a 100% zero emission grid by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.”  After a year-long review, the Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation. 

Another Renewables Subsidy

One missing piece in the implementation of the Climate Act is an honest admission of costs.  Not only has the State failed to provide required cost information, but there is no accounting of all the costs like the property tax exemption for renewable projects.   Peter Carney explains the basis of the property tax subsidy:

New York State laws encourage projects that are aligned with specific public policies such as the development of renewable energy or infrastructure that supports the economy, in a variety of ways including Real Property Tax exemptions.

The laws provide the local county, town, and schools with the option of negotiating Payment In Lieu of Tax (PILOT) agreements to compensate the local jurisdictions for some of the lost tax revenue.

There are three outcomes for these potentially tax-exempt projects:

  1. The projects can be accepted as fully exempt (no tax revenues are collected) (TCSD has not done this).
  2. The local entities can negotiate Payment In Lieu of Taxes (PILOT) agreements that compensate the local jurisdictions for some of the lost tax revenue. (TCSD has done this with the recent energy projects.)
  3. The law also provides the affected governments with the several or joint ability to opt out of the tax exemptions provided by the state law, in which case the energy projects would be fully taxable. (The TCSD has not enacted such an opt-out provision and thus none of the energy projects will be taxed at their full value.)

New York State’s Real Property Tax Law (RPTL) Section 487 provides a 15-year tax exemption for properties with renewable energy systems, including solar, wind, and other clean energy technologies.  The costs of this tax forgiveness from PILOTs are not “hidden” rather the policy makers in Albany just don’t care about the costs imposed on local taxpayers.  It is setup as an “opt-out” rule that requires local jurisdictions to jump through hoops if they decide not to participate.  It automatically applies otherwise. 

PILOT agreements provide a structured payment system to developers that reduce their initial property tax burden to help support the new projects. Their benefits include “multifaceted effects on local economies, ranging from stimulating redevelopment to reshaping municipal revenue streams”. PILOT agreements in New York cover the following types of projects:

  • Manufacturing and industrial developments
  • Not-for-profit organizations
  • Renewable energy installations, particularly solar projects
  • Commercial and residential real estate developments
  • Economic revitalization initiatives

In my opinion, four of these five types of projects will provide value to the jurisdictions once the development is complete.  On the other hand, renewable energy installations do not.  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 so emission reduction projects in New York will be supplanted by increases elsewhere in a year..  Furthermore, New York’s statewide impact on global temperature is unmeasurable so no new project is going to impact global warming.

The response to my Perplexity AI query “How do New York Payment in lieu of tax agreements benefit jurisdictions for transmission or renewable energy projects?” claimed other benefits PILOT proponents thought these agreements would provide.  The query claimed seven benefits to the jurisdictions granting the PILOT:

  1. Predictable revenue streams – The basis of this is that traditional property tax arrangements can fluctuate with changes in assessment values, so the PILOT payments provide predictability.  I think that one thing that is predictable is that the tax revenues will be less than the traditional property tax proceeds.
  2. Growth-oriented payment structures – If the jurisdiction negotiates an escalation clause, then payments can increase.
  3. Revenue preservation mechanisms – “While PILOT agreements offer tax exemptions, they are designed to preserve a significant portion of the potential tax revenue that would have been generated without compromising project viability. Under New York law, PILOT amounts cannot exceed what the tax amount would have been without the exemption, creating a natural ceiling that balances developer needs with jurisdictional interests.”
  4. Economic development benefits – Proponents of PILOTs argue that the agreements support broad economic development but that only benefits New York if the installed infrastructure is manufactured in New York.
  5. Job creation and industry growth – The AI response claimed that there was remarkable growth in the renewable energy sector, but this is a weak argument in my opinion.  For an individual jurisdiction PILOT agreements for manufacturing or industrial projects will provide local jobs but the construction of a transmission line will only impact a local jurisdiction during construction and those jobs will not be local.  I do not think this is a benefit for a renewable project.
  6. Supporting the transition to clean energy – As noted previously, the Climate Act transition will have no tangible effect on global emissions or temperature, so it is only a virtue-signaling exercise.
  7. Jurisdictional control and flexibility – The Perplexity AI explanation states: “PILOT agreements provide local governments with significant control over how renewable energy projects are incentivized and taxed.”  It is not clear to me why local jurisdictions would care about incentives and taxation for renewable energy.

The Perplexity AI response claiming benefits for renewable energy projects from PILOT agreements gave an example of a successful agreement.  Note that the only reference cited for the following quotation was a Bethlehem Central School description of the PILOT:

The Champlain Hudson Power Express Project (CHPE) demonstrates how PILOT agreements work for large-scale transmission projects. This underground transmission line, delivering renewable energy from Canada to New York City, spans multiple jurisdictions including four towns, two villages, and four school districts

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The Albany County Industrial Development Agency (IDA) structured a 30-year PILOT agreement for this project, significantly longer than typical 10-11 year terms. Payments are apportioned based on geographical coverage, with the Bethlehem Central School District receiving benefits proportional to the 2.14 miles of pipeline within its boundaries.

After reviewing the proposed PILOT terms, the school district found them reasonable, highlighting how these agreements can satisfy the needs of both developers and local jurisdictions.

After the acceptance of a PILOT agreement there is no way a school district is going to acknowledge any issues.  Before describing an example, here are more details on CHPE.

Champlain Hudson Power Express (CHPE)

This transmission project is intended to bring zero-carbon electricity from Quebec to New York City: “Two five-inch-diameter cables will be placed underwater or underground and run 339 miles from the U.S.-Canadian border, south through Lake Champlain, along and under the Hudson River, and eventually ending at a converter station that will be built in Astoria, Queens.”  This project has been underway for a long time.  The first regulatory filing was posted on March 30, 2010.  Construction finally started in September 2023 and the developers claim that as of April 2025 it is on schedule for an in-service date of May 2026. The New York Independent System Operator (NYISO) 2023-2032 Comprehensive Reliability Plan notes that the reliability of the grid is “heavily reliant on the timely completion of planned transmission projects, chiefly the Champlain Hudson Power Express (CHPE) project.”    

Note that it was designed with no substations or interconnections to the local or regional transmission system between Quebec and New York City along the CHPE route. The transmission line was designed as a point-to-point HVDC link, running continuously from the Hydro-Québec system at Hertel to the Astoria converter station.  This is not to say that an interconnection could be added later but for now it means that there are no local benefits once the line is in place.

CHPE Ticonderoga Central School PILOT

Peter Carney authored “A review of the Ticonderoga Central School District’s energy project PILOT agreements and impacts on taxpayers” (White Paper) that breaks down the effect of the PILOT agreements on local taxpayers that the Bethlehem Central School district description did not. Carney prepared the white paper to “document missed opportunities for the TCSD Board of Education (BoE) to increase non-tax school revenues, estimated at more than $1 million annually, from seven new energy projects. Consequently, rather than the energy projects paying their fair share of taxes, the taxpayers of Hague and Ticonderoga will need to make up the difference.” 

The White Paper analyzed six solar projects and CHPE.  It explains the impacts related to CHPE as follows:

This project is for the installation of a 1,250 MW DC transmission system from Hydro Quebec to New York City. Without the successful completion of this project, load shedding and blackouts are projected for NYC as soon as 2026vii. Clearly, this project will go forward to completion with or without a PILOT tax exemption.

Despite this, TCSD agreed to several disadvantageous terms:

  • The PILOT is a small fraction of the full tax: The PILOT Agreement forecasts that in the first year, TCSD will receive $122,770 or approximately one quarter of the fair share of taxes due from CHPE if taxed at full value.
  • The PILOT is calculated based on estimated construction costs, almost certain to be lower than the actual costs incurred several years later. Any costs above the preconstruction estimate will be fully tax exempt.
  • There are no PILOT payments until CHPE decides that the PILOT agreement should begin.
  • The payment schedule is back-end loaded with most of the payments due to be delivered in the last several years of the 30-year PILOT agreement.

The route for this system passes through TCSD jurisdiction for 9.26 miles. The first year PILOT payment for Essex County is fixed at $1,532,592 which will be divided among Essex County, seven host towns and six school districts based on a formulation that considers route distance, and full value tax rates for each jurisdiction for the first year the PILOT is effective.

TCSD copied the Town of Ticonderoga’s agreement, which copied the Essex County agreement, without considering that TCSD includes Hague and what impact that would have.

To the extent that Hague’s total Full Market Value assessment (FMV) increases compared to Ticonderoga’s, the Ticonderoga school tax rate decreases and therefore the TCSD will receive a reduced portion of the Essex County PILOT payments.

Discussion

The White Paper included the following table that reports the level of PILOT tax exemptions reported in NY.  Unfortunately, TCSD clearly passed up opportunities to be more protective of its taxpayers in its negotiations with CHPE. The only jurisdiction that gets value for providing tax breaks is New York City and they are taxing CHPE at the full value.  The opt-out provisions of New York’s Real Property Tax Law contributed to the sad state of affairs where a rural upstate school district unwittingly subsidizes a renewable energy project that provides no direct benefits to its taxpayers while the only entity that benefits charges the project as much as it can.

There are other costs associated with CHPE that are not obvious.  Carney wrote me that “Not only will CHPE receive New York State Energy Research & Development Authority subsidies that are many multiples of the New York City Locational Based Marginal Pricing (LBMP) they are also going to significantly increase the Locational Capacity Requirements for New York State thus increasing the capacity cost to New York City.  Through the magic of Perplexity AI, I have an explanation of his comment if you are interested.  Finally, if Niagara Mohawk/National Grid, Transco, and Con Ed built the CHPE it would be fully taxable, so the developers are unquestionably getting millions of dollars of tax breaks each year for 30 yrs on top of being paid many multiples of the LBMP in New York City.

Conclusion

CHPE offers a perfect example of the many subsidies and programs set up to facilitate renewable energy development. The Department of Public Service is required to report annually on the status of the implementation of the Climate Act and include cost impacts.  Not only is the 2024 report overdue, but it will not account for hidden costs like those described here.  Anyone who thinks that special interests are not taking advantage of these complexities at the expense of New Yorkers is naïve.

Personal Comments on National Grid Long-Term Gas System Plan Report

The New York Climate Leadership & Community Protection Act (Climate Act) net zero transition has unleashed an avalanche of Public Service Commission (PSC) proceedings.  I submitted comments on Case 24-G-0248 Review of the Long-Term Gas System Plan for National Grid because they provide the natural gas I use for heating, cooking hot water, and my backup generator.  There are so many issues coming up with the schedule and ambition of the Climate Act that it is obvious that we need to pause implementation and figure out how best to proceed.  The National Grid Long-Term Plan (“LT Plan”) is a perfect example of a component that should be paused.

I am convinced that implementation of the Climate Act net-zero mandates will do more harm than good because the proposed green energy programs are crimes against physics.  The energy density of wind and solar energy is too low and the resource intermittency too variable to ever support a reliable electric system relying on those resources. If this reality is not acknowledged soon and these policies paused, then the enormous costs of this futile gesture to control the climate will bankrupt the state. 

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 500 articles about New York’s net-zero transition.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes an interim reduction target of a 40% GHG reduction by 2030. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.”  After a year-long review, the Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation. 

I submitted comments on the LT Plan as a National Grid customer who relies on natural gas to provide affordable, reliable and resilient energy to my home.  My comments showed that there is insufficient consideration of the enormous challenge of the Climate Act transition to a zero-emissions energy system in the LT Plan.  I also included a technical comment on the incorrect calculation of the societal cost calculation of avoided GHG emissions.

Safety Valve Criteria

I believe it is premature to implement the transition plan outlined in the LT Plan until metrics for affordability and reliability are established.  The LT Plan does not acknowledge the safety valve requirements in New York Public Service Law  § 66-p (4). “Establishment of a renewable energy program”.   Section 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 believe that as part of the Scoping Plan process the Climate Action Council should have developed criteria for the Public Service Law affordability and reliability mandates in Public Service Law Section 66-p (4).  That did not happen, so it is incumbent upon the Commission to define “safe and adequate electric service” and “significant increase in arrears or service disconnections” before the LT Plan is implemented.  It is irresponsible to begin replacing the existing resilient, reliable and affordable natural gas system without assurances that New York has a viable zero emissions electric system transition plan.

Reliability

I am particularly concerned about reliability.  I moved to Liverpool, NY in June 1981 and lived through two extended electricity outages: the Labor Day storm of 1998 and an ice storm in April 2003.  I have never had a natural gas outage since 1981.  As I write this there are still electric over 3,000 customers in Michigan in the dark after an ice storm 17 days ago.  Keeping the heat on in cold weather is a life and death requirement and natural gas is a resilient resource.  During our ice storm I relied on the natural gas-fired furnace, stove, and hot water using a portable generator to provide power.  Because of this concern, I have installed a whole-house generator so that I can survive when another ice storm inevitably occurs.

The LT Plan does not mention that the replacement of natural gas with electric systems will be viable only if the electric system is reliable.  As noted above, there are electricity deliverability issues associated with extreme weather events that are not present with natural gas delivery.  The biggest unacknowledged reliability risk associated with glacial pace of agency progress is addressed in Case 15-E-0302 – Proceeding on Motion of the Commission to Implement a Large-Scale Renewable Program and Clean Energy Standard.  New York agencies all agree that new Dispatchable Emissions-Free Resource (DEFR) technologies are needed to make a solar and wind-reliant electric energy system viable during extended periods of low wind and solar resource availability.  Case 15-E-0302 is supposed to address this technology because no such technology is currently available.  I believe the only likely viable DEFR backup technology is nuclear generation despite its shortcomings because it is the only candidate resource that is technologically ready, can be expanded as needed, and does not suffer from limitations of the Second Law of Thermodynamics.

My comments  described inherent weather variability planning risks associated with non-nuclear DEFR technology that is problematic as long as New York continues to champion an electric system dependent upon wind and solar resources.  It is necessary to determine how much DEFR capacity is needed for wind and solar resource lulls using as long record of weather data as possible.  That has not been done and there is nothing in place for it yet, but analyses done to date suggest that resource capacity equivalent to existing fossil resources will be needed.  I used information from my recent post on the assessment of extreme renewable resource lulls to comment on other issues that need to be resolved before the LT Plan is implemented.

Affordability

One advantage of developing comments is that I can use my articles as source material.  In this instance my comments raised affordability issues that were included in a recently submitted a letter in relation to Public Service Commission (PSC) Proceeding 22-M-0149 “Assessing Implementation of and Compliance with the Requirements and Targets of the Climate Leadership and Community Protection Act” regarding an affordability standard.  I described those comments in this post. 

I did some original work for my comments about costs.  It was a holy crap moment when I found the projected costs in the LT Plan for three scenarios.  The scenarios include a reference case, CEV or “clean energy vision”, and AE or “accelerated electrification”.  The 2030 average monthly increase for National Grid customers in the former Niagara Mohawk service territory ranges from a 50% increase to a 96% increase.  The 2030 average monthly increase for National Grid customers in the former Brooklyn Union Gas service territory ranges from a 65% increase to a 148% increase.  The 2030 average monthly increase for National Grid customers in the former Key Span service territory on Long Island ranges from a 41% increase to a 90% increase.

Table 12-11: Niagara Mohawk Bill Impacts by Scenario

Table 12-12: Brooklyn Union Gas Company Bill Impacts by Scenario

Table 12-13: KeySpan Gas (LILCO) Bill Impacts by Scenario

It is inconceivable that those costs when combined with similar increases in electric costs will not result in a significant increase in arrears or service disconnections that exceeds the Public Service Law Section 66-p (4) safety valve.  It is long overdue for National Grid and the PSC to acknowledge these costs to ratepayers and for the PSC recognize that its mission to ensure “affordable, safe, secure, and reliable access” to electric and gas services is incompatible with the Climate Act mandates.

The DEFR requirement and weather variability risk described in the previous section also have affordability implications.   Until a DEFR strategy is proposed we have no idea how much this will all cost so any claims that the Climate Act will be “affordable” are incomplete.  Because any DEFR backup resource will be used so little and will be so expensive there will be inevitable tradeoff considerations for the rarely used backup resource.  The result will be pressure to minimize the costs associated with DEFR backup capacity which will increase the probability of a catastrophic blackout.  If natural gas has been shut off the blackout effects will be exacerbated.

Societal Cost Test (“SCT”)

I also included a technical comment on the incorrect calculation of the societal cost calculation of avoided GHG emissions.

I believe the SCT methodology over-estimates the benefits of the societal impacts of greenhouse gas emissions.  As far as I can tell, the National Grid Long-Term Gas System Plan report calculates the societal benefits based on avoided emissions. I believe the reference to “avoided” emissions means that the emission reductions for the different scenarios are accumulated out to a specific date.  I also evaluated the latest NYS GJG emissions inventory and found that the New York State total GHG emissions from the buildings and industry sectors were 84.5 million metric tons in 2021.  In that year the NYSERDA Patterns and Trends report showed that National Grid sold roughly half the natural gas in New York.  Based on that I assume that National Grid emitted 42.2 million metric tons in 2021.  Table 8-8: GHG Emissions Reductions by Scenario and Operating Company in the LT Report lists emissions ranging from 223.8 to 1,239 million metric tons which far exceeds the observed 2021 emissions.

Calculations of avoided emissions benefits consider reductions over some time frame.  It is inappropriate to claim the benefits of an annual reduction of a ton of greenhouse gas over any lifetime or to compare it with lifetime avoided emissions.  The value of a GHG emission reduction is based on all the damage predicted to occur from the year that the ton of carbon is reduced out to 2300.  The correct societal benefit can be no more than the current GHG emissions times the social cost of carbon.  Clearly, using cumulative values for this parameter is incorrect because it counts those values over and over. That is equivalent to me saying I lost 25 pounds because I lost 5 pounds five years ago and kept it off.  I contacted social cost of carbon expert Dr. Richard Tol about my interpretation of the use of lifetime savings and he confirmed that “The SCC should not be compared to life-time savings or life-time costs (unless the project life is one year)”. 

Conclusion

National Grid has developed a long-term plan to replace natural gas with electricity. The projected costs are enormous and the benefits overstated.    The plan does not acknowledge that this is a safe and viable approach only if the future electric system is reliable.  In my opinion, the feasibility of a reliable electric system that relies on wind and solar has not been proven.  The Scoping Plan zero emissions electric system needs a new resource, we don’t know how much of that resource is needed, what it will be, or how much it will cost.

I concluded that it is imprudent for the Commission and National Grid to continue this long-term plan to eliminate natural gas until the affordability and reliability mandates in Public Service Law Section 66-p (4) are defined and evaluated.  I have no doubts that the mandated evaluation will find that the Climate Act impedes the provision of safe and adequate electric service and will cause a significant increase in arrears or service disconnections that result in suspension or modification of the Climate Act mandates including the long-term shutdown of the natural gas system.  It is therefore irresponsible to begin the replacement of the existing resilient, reliable and affordable natural gas system until New York has a viable zero-emissions electric system available.  The LT Plan should acknowledge this prerequisite to implementation.

Conclusion

National Grid has developed a long-term plan to replace natural gas with electricity.  Their plan does not acknowledge that this is a safe and viable approach only if the future electric system is reliable.  In my opinion, the feasibility of a wind and solar dependent electric system has not been proven.  The Scoping Plan zero emissions electric system needs a new resource, we don’t know how much of that resource is needed, what it will be, or how much it will cost, and that whatever we do eventually it won’t be enough so people will die in a catastrophic blackout. 

It is imprudent for the Commission and National Grid to continue this long-term plan to eliminate natural gas until the affordability and reliability mandates in Public Service Law Section 66-p (4) are defined and evaluated.  I have no doubts that the mandated evaluation will find that the Climate Act impedes the provision of safe and adequate electric service and will cause a significant increase in arrears or service disconnections that result in suspension or modification of the Climate Act mandates including the long-term shutdown of the natural gas system.  It is therefore irresponsible to begin the replacement of the existing resilient, reliable and affordable natural gas system until New York has a viable zero-emissions electric system available.  The LT Plan should acknowledge this prerequisite to implementation.

Implication of Assessment of Extreme Renewable Resource Lulls

Note: A version of this article was posted at Watts Up With That

I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act) could have devastating impacts on New York residents as long if proponents ignore lessons that could be learned elsewhere and continue down the current path.  This post describes work done in Great Britain that has direct bearing on New York’s implementation plans and shows we need to re-think the tradeoffs of Climate Act implementation.

I believe that implementation of the Climate Act net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 500 articles about New York’s net-zero transition.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes an interim reduction target of a 40% GHG reduction by 2030. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.”  After a year-long review, the Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation.  Recently, the State initiated the State Energy Plan process to update it to be consistent with the Climate Act.  It is not clear whether this proceeding will consider stakeholder comments that were ignored during the Scoping Plan process.

Renewable Resource Lulls

The Scoping Plan, Integration Analysis, New York Independent System Operator (NYISO), New York Department of Public Service, the New York State Reliability Council, and others all have noted that a new category of generating resources called Dispatchable Emissions-Free Resources (DEFR) is necessary to keep the lights on during periods of extended low wind and solar resource availability.  The frequency, duration, and intensity of wind and solar availability gaps must be known to properly plan to provide the generation, storage, and DEFR resources necessary to maintain reliable service.  Analyses done by the New York State Reliability Council Extreme Weather Working Group have shown that extended periods of low wind and solar resource availability will be challenging for the future New York electric system. 

On December 24, 2024 I submitted testimony for the December 18, 2024, Assembly Standing Committee on Energy Public Hearing regarding NYSERDA Spending and Program Review. I noted that the biggest feasibility challenge is the identified “gap” when wind and solar resources are low for long periods.  As one example of appropriate feasibility funding, I recommend analyzing the variability in low wind and solar resource availability.  The characteristics of the resource gaps must be quantified not only for New York but also for adjoining regional systems presuming that they also transition to an electric system with a similar reliance on wind and solar.

The Independent System Operator of New England (ISO-NE) Operational Impact of Extreme Weather Events  completed an analysis that addresses this need for New England.  The study evaluated 1-, 5-, and 21-day extreme cold and hot events using a database covering 1950 to 2021. The results found that the system risk or “the aggregated unavailable supply plus the exceptional demand” during an event increased as the lookback period increased.  If the resource adequacy planning for New England only looked at the last ten years, then the system risk would be 8,714 MW, but over the whole period of record, the worst system risk was 9,160 MW which represents a resource increase of 5.1%.  This means that the low renewable resource analysis should cover as long a period as possible to determine the longest period of exceptional demand and low renewable resources.

Great Britain Renewable Assessment

David Turver blogs about energy issues in Great Britain. In an October 2023 post  he describes a report from the Climate Change Committee (CCC),  their equivalent to New York’s Climate Action Council. He explains that the Royal Society (RS) Large Scale Electricity Storage report authored by Professor Chris Llewellyn-Smith claims that Great Britain can meet its demand for electricity with wind and solar, supported by large-scale hydrogen storage.  Large-scale hydrogen storage is the placeholder DEFR technology in the Scoping Plan, so this analysis is directly applicable to New York’s DEFR resource issue.

Turver argues that the report is deeply flawed. Among his concerns are the following:

They begin by assuming that electricity demand will be 570TWh in 2050 which represents roughly halving the energy demand across residential, transport and industrial and commercial categories. The evidence from Our World in Data shows that rich economies require high energy consumption to thrive. There are no rich countries with low energy consumption and those countries that have reduced energy consumption have grown more slowly, or even shrunk. The first extraordinary claim of low energy consumption fails because the evidence shows that if we allow that to happen, we will be much poorer.

The report then goes on to assume that the profile of electricity demand will be the same as today. However, as we move from gas to electricity to heat our homes and offices, the winter surge in electricity demand will be further exaggerated. Moreover, demand will change from year to year such as during the cold winter in 2010 that also coincided with a calm period when we would have generated much less renewable electricity. These variations in demand profile will lead to more generation capacity and an even bigger energy store than RS assumes, pushing up costs.

He goes on to argue that there are other flaws.  the report assumes unrealistic load factors for both onshore and offshore wind. It underestimates the amount of offshore wind needed and goes on to assume efficiencies and costs for hydrogen electrolysers, storage, and generation that do not stand up to scrutiny.  He also points out that the economic assumptions are flawed. 

He describes the “main positive aspect of the report”:

The thing that stands out most is the painstaking analysis that has been conducted to understand the very significant changes in the weather that occur on yearly and decadal timescales. They analysed wind and solar records over 37 years to estimate the level of variation we might expect from wind power.

In a recent article Turver includes a graphic that shows this issue using the 37 year database.

The analysis of 37 years is longer than anything done to date for New York.  He also points out an aspect of DEFR that relies on hydrogen storage that I had not considered previously.  It is not just the annual worst-case episode but there can be multi-year issues:

They found that we can sometimes have several consecutive years where the wind speed is lower than average. This means that if we are to have a grid powered solely by wind, solar and storage, then we need to build up massive stores of energy in the windy years to be used in the calmer years. They conclude that to consistently deliver their 570TWh of electricity each year, we would need 123TWh of hydrogen storage. Some of that hydrogen may have to be stored for a decade or more before it is used.

He also points out that the requirement for decadal storage is another flaw for any DEFR backup resource:

This has important implications for the economics of storage and effectively rules out batteries as the storage medium. Who would want to spend millions on building a battery or hydrogen storage cavern, even more to fill it and maintain it, yet not see any revenue from it for years after it was completed?

DEFR Backup Reliability Risk

Turver’s article raises the ultimate reliability risk for a weather-dependent electric system.  Today’s electric system resource planners for a conventional system base the amount of capacity that they think will be needed based on decades of observations of the fallibility of power plants.  The result is that they know the probability there will be a shortage of available capacity to meet load when the installed reserve system capacity margin is a fixed percentage of the expected load very well.  In New York State the installed reserve margin to meet the accepted probability of a loss of load expectation of an outage no more than once in ten years reliability metric is around 20%.

A fundamental observation is that there is no expectation that the failure of conventional power plants will be correlated.  We do not expect that many will fail at the same time.  That in turn means that even if we decided to set the reliability metric based on a one in thirty-year probability that there would not be much of an increase in the installed reserve margin.

That all changes when the electric system transitions to one dependent upon wind and solar weather-dependent resources.  We know that solar energy is zero and night and much lower in the winter.  Similarly, we know that wind energy is much lower in a high-pressure system, and that those systems are huge and cover all Great Britain and much of western Europe or eastern North America at the same time.  Exacerbating the problem is the fact that those conditions are associated with the hottest and coldest episodes with the greatest expected electric loads.

Turver’s post shows that looking at one year is absurd.  Not looking at the worst year on record is nearly as bad: “They used 1987 as a 1-in-20 year stress test, when they admit that 2010 was a 1-in-50 year event”.  The insurmountable problem is that we know that if an even longer period of record was used there would very likely be an even worse event.  Instead of the confidence in the current planning process that increasing the lookback period will not markedly change the resources needed for the worst case, relying on weather-dependent resources means that inevitably there will be a period of extreme weather that exceeds the planning criteria chosen and the expected resources based on those criteria.  The costs to provide DEFR backup support will be extraordinary and building excess capacity for a very rare event will significantly add to those costs.  This trade-off means that eventually there will be a catastrophic blackout when the load exceeds the storage capacity.

Conclusion

Turver’s articles are further evidence of the DEFR “gap” problems for any electric system that relies upon weather-dependent renewable resources.  The first problem is that you have to determine how much DEFR capacity is needed using as long record as possible.  The second problem is that there is no commercially available DEFR technology that is available to deploy for the aspirational Climate Act targets.  Thirdly, until a DEFR strategy is proposed we have no idea how much this will all cost so any claims that the Climate Act will be “affordable” are incomplete.  Finally, there is the insurmountable weather-related probability that eventually there will be a unusual set of weather conditions and load requirements that exceed the DEFR resources deployed. 

To sum up: we know that a new resource will be needed, we don’t know how much, what it will be, how much it will cost, and that whatever we do eventually it won’t be enough so people will die in a catastrophic blackout.  This is insanity.

Energy Plan Board Meeting Misleading Information – Climate Change Impacts are Here

I recently wrote an article about the claim that renewable energy can reduce costs in the presentation by Jeff Freedman from the Atmospheric Sciences Research Center, University at Albany at the Energy Planning Board on March 3, 2025.  I concluded that the claim is based on hope not evidence.  Dr. Freedman’s presentation also included slides that support the Hochul Administration narrative that Greenhouse Gases (GHG) are the cause of the observed increases in global temperature and that the impacts of that warming are evident today.  This article explains why I disagree with those claims in Freedman’s presentation.

I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act) net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 500 articles about New York’s net-zero transition.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Energy Plan Overview

According to the New York State Energy Plan website (Accessed 3/16/25):

The State Energy Plan is a comprehensive roadmap to build a clean, resilient, and affordable energy system for all New Yorkers. The Plan provides broad program and policy development direction to guide energy-related decision-making in the public and private sectors within New York State.

The current Plan was initially published in 2015, and updated in 2020, when it was amended to align with the objectives of the 2019 Climate Leadership and Community Protection Act (Climate Act). Since the last update, the Climate Action Council produced its Scoping Plan, examining many of the energy issues that contribute to climate change and offering recommendations that are currently being implemented by the State.

On September 9, 2024, the Hochul Administration initiated the State Energy Plan process to update the Plan consistent with the Climate Act.  The goal of the planning process is to “map the state’s energy future by showing how the state can ensure adequate supplies of power, reduce demand through new technologies and energy efficiency, preserve the environment, reduce dependence on imported gas and oil, stimulate economic growth, and preserve the individual welfare of New York citizens and energy users.” The major question that must be addressed is whether the Hochul Administration will use the energy planning process as an opportunity to consider the advice of stakeholders in its stakeholder process or just an obligation with no attempt to meaningfully engage with any comments inconsistent with the narrative.

If the March 3 meeting is any indication, then the Energy Plan will be another political show extolling the virtues of the Climate Act and ignoring anything inconsistent with the political narrative.  In other words, it looks just like the Scoping Plan process.  Many of the appointees to the Climate Action Council chosen to approve the Scoping Plan were chosen because of their position within the Hochul Administration or political connections and not their technical expertise.  One feature of the Scoping Plan process was the New York State Energy Research & Development Authority (NYSERDA) strict adherence to the political narrative rather than full disclosure of inconsistent issues.  This article addresses several arguments made in the NYSERDA presentation by Freedman that misled the Energy Planning Board members.

Narrative Support

Climate Leadership & Community Protection Act Section 1. Legislative findings and declaration, subsection 3 defines the narrative:

Action undertaken by New York to reduce greenhouse emissions will have an impact on global greenhouse gas emissions and the rate of climate change. In addition, such action will encourage other jurisdictions to implement complementary greenhouse gas reduction strategies and provide an example of how such strategies can be implemented. It will also advance the development of green technologies and sustainable practices within the private sector, which can have far-reaching impacts such as a reduction in the cost of renewable energy components, and the creation of jobs and tax revenues in New York.

The  presentation slides for the March 3 meeting included Freedman’s Key Findings slide that support this narrative.   The first finding says that “Climate change is already constraining some sources of energy supply and stressing transmission and distribution infrastructure through extreme heat, changes in precipitation, and increasing storm intensity”.  The implication is that reducing GHG emissions in New York will affect the rate of climate change which they claim has already become evident.  The second finding that “Patterns of energy demand are shifting due to climate change and are expected to continue evolving over the coming decades” explicitly states that impacts are observable.

These findings were presented to the Energy Planning Boad as unequivocal statements of fact.  In reality, there is significant uncertainty that should be considered in the draft Energy Plan.

Comparison of CO2 and Global Temperature

The common basis of the threat of climate change caused by human emissions of GHG is the graph comparing the concentration of CO2 and global temperatures that was included in Freedman’s presentation.  There is no question that increasing the concentration of GHG in the atmosphere will reduce the out-going long wave radiation which will warm the atmosphere, and the graph shows a correlation.  However, the conclusion that reducing New York’s GHG will affect global temperatures and the alleged weather impacts given the small contribution to the global concentration is unwarranted.

Esteemed climate scientist Richard Lindzen describes the energy budget in context:

The energy budget of this system involves the absorption and re-emission of about 200 watts per square meter. Doubling CO2 involves a 2% perturbation to this budget. So do minor changes in clouds and other features, and such changes are common. In this complex multifactor system, what is the likelihood of the climate (which, itself, consists in many variables and not just globally averaged temperature anomaly) is controlled by this 2% perturbation in a single variable?

Lindzen points out that believing this is “pretty close to believing in magic”.  Nonetheless, Freedman presents the graph of CO2 concentration and global temperature without any mention of the shortcomings and complexities of the climate system.

My point is that this is not as obvious a relationship as claimed.  Sabine Hossenfelder produces You Tube videos on science and technology.  Her climate change-related videos generally adhere to the narrative, but she has shown signs of waking up to reality. Peter Ridd commented on her awakening noting that she does not quite get there.  I call your attention to Ridd’s commentary where he talks about uncertainties about how the earth’s weather system works. Especially relevant to Freedman’s graphic is Ridd’s explanation of temperature and CO2 concentrations going further back in time than Freedman’s graph.  Ridd points out in the following graph that temperatures were higher many times in the last 10,000 years at the same time that CO2 concentrations were lower.  That directly contradicts the notion that global temperature is primarily driven by anthropogenic CO2 concentrations.

Climate vs. Weather

Freedman perpetuates the Climate Act myth that climate change is increasing extreme heat, changes in precipitation, and increasing storm intensity with a graph that shows increasing storm events in New York from 2001 to 2024.  In general, climate is what you expect, and weather is what you get.  To determine what you expect from climate, meteorologists use a 30-year climatological average.  Therefore, to have a climate trend you need to look at the difference between two 30-year averages at a minimum.  Freedman’s graph is a weather average trend unsuitable for making any climate trends claims.

After I drafted this article Anthony Watts summed up my problems with claims that climate change is an existential threat in a post entitled “Is Climate Change Real? Short Answer: Yes — But It’s Complicated.”  I published an article that quoted the article with my annotated comments relating the points he made to the Climate Act.  I highly recommend reading that aartilce.

Basis for Narrative Claims

Expert presentations designed to promote the Climate Act narrative to an audience such as the Energy Planning Board often cite the results of modeling.  In this instance there is a slide that describes the “effects of climate change on renewable energy distribution in New York State” based on “results from high-resolution dynamic downscaling”.  Sounds very scientific and above reproach.

The grid size for CMIP5 (Coupled Model Intercomparison Project Phase 5) climate models typically ranges between 125 km to 300 km.  This is too coarse for predicting the impacts of climate change on New York so higher-resolution regional models have been used in projects sponsored by NYSERDA to project impacts.  This process is called dynamical downscaling.  Unmentioned are the errors and inherited biases in the process from the Global Climate Models (GCM) for the following:

  • Temperature trends: Persistent warm/cold biases in coastal and inland regions, exacerbated by future GCM projections exceeding historical maxima.
  • Precipitation patterns: Systematic underestimation of seasonal rainfall in regions like the Caribbean and Southern Africa.
  • Extreme events: Misrepresentation of high-frequency, low-intensity rainfall (“drizzle problem”) due to GCM limitations.

I think that those issues underestimate the problems because the fact is the GCM projections do not include the physics of clouds.  The problem is that coarse grid size cannot incorporate precipitation or extreme events.  This is not to say that the models don’t predict storms, just keep in mind that they are little more than guesses strongly influenced by the biases of the modelers. 

There are structural RCM limitations that introduce their own errors despite higher grid size resolution:

  • Simplified physics: Inadequate representation of convective processes and local interactions (e.g., lake effects).
  • Scale mismatches: Difficulty resolving sub-grid features even at 10–50 km resolutions.
  • Computational constraints: Limited ability to run multiple GCM-RCM combinations, reducing uncertainty sampling.

Those limitations are relevant to the purported New York results.  For five months of the year much of Upstate weather is strongly influenced by the Great Lakes.  Convective processes and local interactions like lake effect are erroneous in the RCM because the scale of the lake effects is smaller than the resolution of the models.  I have been working with weather models and Upstate mesoscale weather regimes for decades and I am positive that the model projections are poor at best.   Combined with the fact that the projections use a totally unrealistic estimate of future emissions (the RCP 8.5 scenario), I do not believe the results presented have any value. 

Discussion

NYSERDA scripted the presentation to the Energy Board so that it was completely consistent with the narrative that climate change impacts are occurring today.  I recently showed that the uncertainty of the historical temperature measurements is similar to the alleged temperature increase due to GHG emissions.  This post explains that the claimed trend in storm events is not a climatic trend because the time range is too short, and that the model projections of weather have limited value. As a result, the Energy Planning Board came away from the meeting erroneously believing that the effects of climate change are occurring now and that reducing New York GHG emissions will reduce those impacts.

This is not in the best interests of New York.  The New York energy plan is supposed to be a roadmap for a “clean, resilient, and affordable energy system for all New Yorkers.”   There are conflicting priorities and challenges for those three goals.  The State Energy Planning Board should be given all the information so that they can “focus on strategies to meet future energy needs and advance economy-wide decarbonization, while balancing reliability, affordability, environmental and public health impacts and economic growth.”  The presentation did not give any of the qualifying information about uncertainties, so it gave the Board a false basis for evaluating the Climate Act approach and schedule.

The basic strategy for decarbonizing the economy is electrification of all sectors.  Authors of the Climate Act believed that no new technology was needed for the transition of the electric sector to “zero emissions” using wind, solar, and hydro.  All the organizations responsible for electric system reliability agree that a new dispatchable, emissions-free resource is necessary for extended periods of low wind and solar resource availability so that presumption is wrong.  That means that the schedule must be adjusted to account for the necessity to develop, test, and deploy this new technology. 

 A primary driver for the Climate Act schedule was the perceived necessity to do something immediately because the effects of climate change are evident now.  As shown here, that argument is not supported when temperature trend uncertainty is considered, long-term trends of weather events are evaluated, and the weaknesses of global climate models are acknowledged.  Those results do not necessarily mean that it is inappropriate to do something, but the results do mean that the claims we must act immediately are unwarranted.  We have time to do this right.  I think that is a primary concept that should be incorporated into the Energy Plan.

Conclusion

I am disappointed that NYSERDA has become so politicized.  The NYSERDA presentation by Dr. Freedman gave the Energy Planning Board misleading information about the threat of climate change and the need to act immediately.  It is becoming increasingly evident that there are so many unanticipated issues associated with the Climate Act implementation that a pause to re-evaluate the schedule and goals is in order.  If NYSERDA documentation had not been politicized the Scoping Plan could have included caveats and achievement milestones to provide an off-ramp to a Plan B that is clearly necessary.  As it stands now, admitting delays and unavailable technologies will be a political embarrassment.  However, it is necessary to ensure that reliability, affordability, environmental and public health impacts, and economic growth goals can be achieved.

Upstate New York Air Source Heat Pump Experience

 “Green energy” advocates continue to lobby for the NY HEAT Act that would end “New York’s gas mandate and forced ratepayer subsidies for gas expansion”.  This is part of their irrational war on natural gas which will only be successful if they prevent the use of natural gas in the future which means a switch to heat pumps for heating.   Constantine Kontogiannis  has calculated the costs of heat pumps Upstate that complements an earlier analysis by Richard Ellenbogen for Downstate.

I am convinced that implementation of the New York Climate Leadership & Community Protection Act (Climate Act) net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 500 articles about New York’s net-zero transition.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Background

The “NY HEAT Act that would end the gas mandate that proponents claim means that “a single home that wants to stay on the gas system can prevent an entire neighborhood from having the opportunity to receive cheaper, cleaner heating alternatives from their utility.”

I recently posted an article in collaboration with Rich Ellenbogen that detailed the excessive winter operating cost of a geothermal-source heat pump (GSHP) system at his Westchester County residence, using his secondary heating source (a high-efficiency natural gas boiler) for comparison). After it was posted I was contacted by Constantine Kontogiannis who offered to describe his experience with a heat pump.  Mr. Kontogiannis is a mechanical engineer by training with over 25 years of energy related experience.   I jumped at the opportunity for him to describe his heat pump experience.  The following is his lightly edited submittal.

Another Heat Pump Experience – Constantine Kontogiannis

If your readers are wondering how relevant Rich’s experience is to a typical participant of the NYS Clean Heat Program, I have some additional information that might be of interest.  In 2023, I installed a cold climate air-source heat pump (ccASHP) system at my residence in Albany.  According to the NYS Clean Heat 2022 Annual Report, ccASHP systems are much more common than GSHP systems in residential applications, with approximately 18,730 ccASHPs installed in New York State in 2022 (not including Long Island), compared to approximately 670 GSHPs.  That’s a ratio of about 28 to 1 in favor of ccASHP systems.

The stated goal of the NYS Clean Heat Program (which commenced in 2020) is to convert 100,000 homes to heat pumps statewide, and based on the 2022 Annual Report I would estimate that the program is nearly 75% of the way towards that objective.  The data collected so far implies that the vast majority of these heat pumps will be ccASHP systems just like the one that I recently installed.

When I was researching my various heat pump options, I was concerned about their cost effectiveness in heating mode.  So I decided to retain my existing natural gas heating system, which consists of a condensing boiler and radiant underfloor piping.  In hindsight, this proved to be a wise decision, as my 2023/24 heating costs were nearly double what they had been previously.  

For the 2024/25 heating season, I decided to switch back to using my natural gas heating system instead.  Sure enough, my heating costs dropped substantially – even though this winter seemed to be much colder.  To confirm this, I found the following comparison of Heating Degree Days (HDDs) over the past two winters:

From this table, it’s pretty clear that the winter of 2024/25 was much colder than last year.  Here in Albany, our cumulative HDD for this winter was within 3% of a “Normal” heating season, which makes it an ideal time window to calculate the respective heat pump and natural gas system heating costs over a typical winter.  That’s what I decided to do, and to get started, I compiled a summary of my most recent energy and cost data:

(If you’re wondering why my electric consumption is so high from Thanksgiving to Valentines Day, it’s our exterior Christmas lights – they’re all LED, but maybe we go a bit overboard.)

From the table above, I used 988 Therms this winter at a total cost of roughly $817.  I have low temperature (110 degF) radiant underfloor piping, so my boiler is always set to operate in fully condensing mode at the rated 96% AFUE.  If I had chosen to use my heat pumps this winter, I would have needed approximately 948.5 equivalent Therms (988 x 0.96).  This translates to 27,791 kWh at a COP of 1, which is how much energy would be needed if I was using electric resistance heat (948.5 x 100,000 / 3,413).  

The appeal of heat pumps is their vastly improved COP compared to electric resistance heat.  To determine the seasonal COP of my ccASHP system in heating mode, it’s available in the manufacturer’s product data:

My heat pump system uses ducted 3-ton units – this is a common application, particularly when heat pumps are replacing an existing natural gas furnace and air conditioner combination.  Since ducted units retain the existing heating and cooling distribution ductwork, they are significantly less costly to install and more effective in heating dominant climates when compared to the alternative of using multiple split-system terminals throughout the house (in a ducted system, there’s generally at least one supply air register in each room).  

From the table above, my heat pumps have an HSPF2 rating of 10.0 (the left “Ducted” column).  This is a typical HSPF2 value for ccASHPs installed through the NYS Clean Heat Program, which requires a higher efficiency for program participation than generally stipulated by building code.  

To calculate the seasonal COP, we take the HSPF2, divide it by 0.85 and multiply it by 0.293, which is approximately 3.4 for my system.  Here’s the calculator .   

I discovered something interesting about the HSPF2 rating – it’s based on heating performance in a warmer region – Climate Zone 4, which only includes eight downstate counties in New York from Westchester to NYC through Long Island.  See the definitions at the bottom of this webpage  and the map.  

A higher resolution climate zone map with a table of the individual NY counties in each zone was used in this analysis.  From the earlier HDD table, the upstate cities in Climate Zone 5 (Albany, Syracuse, Rochester, and Buffalo) have roughly 40% more heating degree days than NYC, which is in Climate Zone 4.  So it’s likely that since I live in Climate Zone 5, the true seasonal COP of my heat pump system is lower than the value calculated from an HSPF2 rating in Climate Zone 4.  

But let’s put that aside for now – we’ll just be conservative and utilize the seasonal COP of 3.4 derived from the HSPF2 rating.  In an earlier paragraph, I calculated the equivalent energy at a COP of 1 required to heat my home this winter at 27,791 kWh.  Dividing this by the seasonal COP of 3.4 for our ccASHP system, our estimated heating energy consumption this winter would be 8,174 kWh.  

At my current winter electric rate of $0.214/kWh, this translates to a seasonal heating bill of $1,749.  That’s more than double my $817 natural gas bill this winter, 114% more to be exact.    

To offset a portion of the installation cost, the NYS Clean Heat Program provides an average rebate of $4,600 to replace a gas furnace with a ccASHP, and a $2,000 tax credit is also applicable.  But if the system costs between $8,000 and $12,000 to install, and then adds $900 to the utility bill every year, the rebate and tax credit aren’t very helpful.  Over a 15-year equipment lifespan, the detrimental cost impact could add up to $16,000 or more.  

Caiazza Comment

Proponents of NY HEAT suggest that one advantage of the legislation is to save money.  The New York State Energy Research & Development Authority (NYSERDA) produces featured stories  that “provide insights into New York’s clean energy transition and offer practical information for New Yorkers to incorporate clean energy into their homes and businesses.”  The Experience the Comfort of Clean Heat story does not explicitly address costs.  Kontogiannis and I agree that at one time NYSERDA claimed universal savings. To their credit NYSERDA’s Heat Pump Program description does explicitly state that replacing oil, propane, or electric baseboards with air source heat pumps as your primary heating source is a more efficient way to keep your home comfortable. I recently heard an advertisement by approved contractor who did not explain that savings were unlikely for a home that burns natural gas, apparently without any pushback from the program administrator.

The five-year estimate (2017-2021) of space heating totals of occupied housing units in New York shows that there are 7,530,150 housing units and 59.6% or 4,489,695 of them use utility gas for space heating.  The two analyses that compared heat pump costs and NYSERDA agree that natural gas heating is cheaper.  Kontogiannis estimates that at least 30,000 heat pumps installed through this NYSERDA program have replaced natural gas.  He notes that according to the 2022 summary report, “very few of the installations include the decommissioning of the previous heating system”.  As a result we are skeptical of any carbon savings claims. The bottom line is that the Climate Act will make home heat more costly for more than half of the state but I have not seen any advocate admitting that fact.

My thanks to Rich Ellenbogen and onstantine Kontogiannis for their insights.

Peer Review and Costs of Building Electrification for Commercial Users 

This is an article primarily by Richard Ellenbogen that estimates projected annual operating costs and emission reductions for New York commercial facilities when the new building codes are implemented.  It is also an example of how peer review should be done.

I am convinced that implementation of the New York Climate Act net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 500 articles about New York’s net-zero transition.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

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

Heat Pump Hype

I am a long-time critic of the New York State Energy Research & Development Authority’s (NYDSERDA) biased promotion of all green energy technologies.  Their description of cold climate heat pumps is a good example: “Today’s cold-climate heat pumps are a smarter, more efficient option to keep your home comfortable all year long. These all-in-one heating and air conditioning systems are environmentally friendly, extremely efficient, and affordable to operate.”  In another example, they breathlessly exclaim that heat pumps outsell gas furnaces for the second straight year.  This claim uses national figures and could be solely the result of new building sales that are much stronger in southern states where heat pumps are a cost-effective choice.  Ellenbogen addresses the affordability claims below.

Ellenbogen Heat Pump Experience

Ellenbogen installed geothermal heat pumps when his house was completed in 2004.  He has 21 years of experience with them and has maintained a database of the performance and costs.  His monitoring system includes temperature sensors on the inputs and the outputs of the wells and water flow.  Because he uses a geothermal system, he can rely on it even during the coldest periods when air source heat pumps cannot extract enough energy from the air to keep the house warm.  Furthermore, his system uses deeper wells than are currently allowed by law that were legal when the system was developed.  They are also open loop which greatly increases their efficiency but that is also no longer allowed. In his configuration, his heat pumps can pull 7 tons of heat transfer per well where current geothermal wells are limited to about 2.5 tons per well.  As a result, his system can achieve a Coefficient of Performance (COP) of about 5.5 whereas current Geo-thermal systems can achieve a COP of about 3.5 with the restrictions on well depth and having to be closed loop.  During long periods of cold temperatures that force the heat pumps to run for extended periods, the well temperatures can drop and the efficiency of the system decreases so it will use more energy.

One of the things I admire as a techno-weenie is Ellenbogen’s quantitative nature.  He built his house “as a science project to satisfy his intellectual curiosity” and it has yielded an enormous amount of data. When the Indian Point nuclear station was operating, he ran a calculation and found his geo-thermal system was about 7% more carbon free than his 95% efficient modulating gas boilers that were originally installed as a backup in case of a power failure.  After New York politicians shut down Indian Point the carbon emissions of local electricity increased and the GHG emissions advantage vanished.  Given his concerns about GHG emissions he decided to figure out a cost and energy comparison.  He turned the heat pumps off this winter and used the duplicate gas system to compare with multiple years of data with the heat pumps operating.

The results are notable.  His gas bill went up less than the electric bill went down and this is for an electric system with an efficiency 57% higher than what can be built now during a colder winter.  The electric bill was about $8600 lower than it would have been with the heat pumps operating.  The gas bill only went up by $6057 for a net savings of $2543 using the natural gas heating and the current winter has been 120 degree days colder than last year.  That figure has been adjusted for the higher electricity prices this year.   Note that the heating system is well designed with 14,500 square feet of high mass radiant floors that use 100-degree water in the system and 18 separate zones which makes it even more efficient.  The large scale of the system removes measurement aberrations that might occur with a smaller system.

To compare the costs of heating with electricity and natural gas it is appropriate to compare the cost to generate the same amount of heat.  Table 1 lists the cost for the delivery of one therm (heat energy equal to 100,000 British thermal units) between a 95% efficient boiler and electric heat at relationship different Coefficient of Performance efficiency values.  A COP of 1 is inefficient.  A highly efficient ground source heat pump has a COP of 3.5.  Even an efficient ground source heat pump is 16% more expensive ($2.85 for one therm compared to $2.45 for a 95% efficient gas system in the Downstate New York area which covers 60% of the state’s population.  Also note that air source heat pumps on a very cold day can reach COP’s of 1 – 1.5 and easily go below 2.  As a result, they can be two to three times as expensive to operate.

Commercial Facility Projection

New York State legislators passed a prohibition on the installation of fossil fuel equipment and building systems starting in 2026 for small buildings and 2029 for larger ones. The prohibition starts in 2026 for new buildings up to 7 stories tall, except for commercial and industrial buildings larger than 100,000 square feet. There are exemptions for certain types of buildings including emergency backup power systems, manufacturing facilities, commercial food establishments, laboratories, hospitals and medical facilities, critical infrastructure (e.g., water treatment plants), agricultural buildings, crematoriums.

Ellenbogen applied the numbers derived from his house experiment to his business and extrapolated them to the 55,000 square foot factory which would fall under the less than 100,000 square foot rule for new construction after 2026.  Admittedly, there is no law currently in place that would require a developer who wanted to replicate Ellenbogen’s manufacturing facility because of the exemptions.  Eventually, however, the net-zero mandates will require all electric construction of all new facilities and for the replacement of existing equipment before the end of useful life.  Therefore, it is a relevant example of Climate Leadership and Community Protection Act (Climate Act). costs.

Ellenbogen’s home has a backup gas boiler heating system and his manufacturing plant has a combined heat and power system.  In 2002 he installed the first microturbine-based Combined Heat and Power (CHP) system in the Con Ed service area.  This approach generates electricity by burning natural gas.  Waste heat is recovered “to heat the building in the winter, or to be sent to absorption chillers to cool the building in the summer.”  This approach allows him to recover 70 to 75 percent of the energy content of the fuel and augments a solar array on the roof.

By doing a thermal analysis of his home’s gas usage he was able to determine what would be needed to heat the factory.  The end result is that removing gas from his manufacturing facility would raise energy bills to about $147,000, more than doubling them,  and raise his carbon footprint by about 15%.  The key takeaway is that even using the most efficient electric heating/cooling system available, it still means that this gas ban policy will cost businesses in NY state enormously while raising carbon emissions.  When and if the Downstate New York electric system reaches zero GHG emissions the carbon emissions will be reduced.

Environmental Impacts

Ellenbogen calculated that because the Downstate electric system is CO2 rate is 950 pounds per MWh according to 2022 EPA data, that the CO2 emissions from using the CHP system are actually less than if heat pumps were used.  He also pointed out he has replaced three compressors in his home’s ground source system over the past 21 years and each time the failure resulted in a full loss of refrigerant.  He said that it is not preventable and that you only find out when the unit gives a fault code with no early warning.

Discussion

This post is based on three emails from Ellenbogen.  I did not include all the calculation details he provided in the originals but will provide them if requested.  The reason for the three versions is that the details provided enabled a reader to point out an issue that he corrected.  Ellenbogen noted that:

Those damned Laws of Thermodynamics are getting in the way again, but this may be a teaching moment to show what a real peer review looks like and that we have to acknowledge errors to make sure that the best information is in the public space.  It also is a clear example of how we can’t escape those Laws in our calculations.  Miscalculations introduce errors and a failure to account for the Laws of Thermodynamics entirely when setting energy policy introduces huge errors.

This raises an issue with the implementation of the Climate Act.  The agencies responsible for the implementation plans have not provided adequate documentation to enable detailed review of the plan.  Even if it is possible to make a detailed comment on an obvious issue, there hasn’t been any acknowledgement of any problem, much less evidence of a revision to the plans.  The appropriate peer review process exemplified by Ellenbogen’s analysis is not a feature of the Climate Act stakeholder process.  As a result, Ellenbogen notes “errors are apparent across the entire spectrum of NY State’s Energy plan.”

Ellenbogen summarized his peer review concerns in this regard.

While I hate to beat on academia, it has a great deal of responsibility for NY State’s energy mess.  A certain University Professor that sat on the Climate Action Council still refuses to acknowledge that all of the technologies for this transition do not exist despite a Public Service Commission conference determining that fact in 2023.   Unfortunately, people in the legislature and certain environmental groups have adopted those ideas despite there being known large deficiencies in those theories as it applies to putting them into practice.  Untested theories that can’t be put into practice in the “Real World” are dangerous for society.  State residents shouldn’t be turned into a science project and that is what is happening. 

I received the following response to my email from a retired professor that now works in industry.  I have redacted portions to keep them anonymous.  While on average, the refrigerant replacement is every 20 years as there are three heat pumps, their observations are profound and are critical to understanding a huge issue now facing the NY State.  It follows in italics.

This is the most sobering analysis of a heating system I have ever read. I constantly hear about the miracles of heat pumps, but the carbon footprint is never honestly presented. Plus the replacement of freon every 7 years is never included. Thanks for providing a clear analysis of a day in the life of a NY business and resident.

I’m still enjoying life in XXXXXXXX, and in no longer being a professor. Academia lives in a bubble, and you can’t see that until you leave. Professors need to do a real sabbatical leave in industry and be forced to solve real problems, not problems they dream up. It’s tough out here! I thought I knew something about XXXXXX  after XX  years as an academic doing research, but XX years at XXXXXXX  has shown me I have much to learn. It is stimulating, I’m glad to be here. They need to have a similar experience.

Regarding the statement above, one of the reasons that the carbon footprints of heat pumps is never honestly mentioned is that the loudest voices in the space are the people selling them and other people don’t have enough experience to question the results.  I’ve been using them for 21 years.  My house was built as a science project to satisfy my intellectual curiosity.  It has yielded an enormous amount of data, some of which has been used by the state.

One of the major issues that I have with NY State policy is that many of the people that are hired to do the energy analyses for the government actually work for the manufacturers or other interested parties.  The reports read more like advertisements paid for by the NY State taxpayers than a sound scientific document.  I dealt with that in a 2020 paper on the Lansing Gas moratorium.  The company hired to do the Tompkins County energy analysis sold heat pumps and the resulting report reflected that and had a huge error in its results.  The paper is very relevant to the building electrification discussion.

Regarding the professor’s comments, when someone is forced to deal with the consequences of their decisions as occurs in industry, it greatly changes their perspective.  There are no negative consequences for someone theorizing about policy on a University Campus and that is okay because it can move society forward.  However, if they don’t really test those ideas before pushing them into society as a gospel, there will be huge problems and that is what we are now seeing in NY State.

Conclusion

The ramifications of New York’s Climate Act on business development are becoming evident.  In 2026, certain new buildings in New York will no longer be able to install fossil fuel equipment and building systems.  Richard Ellenbogen has performed a “science project” that proves that New York’s net-zero transition electrification plans for heating will be more expensive than using natural gas.  It is also notable that the experiment was best on a geothermal heat pump system that is more efficient than legally possible today.  Adding to the already large energy costs in New York is not a good way to attract and maintain manufacturing in the state. 

This exercise also shows the importance of robust peer review.  Ellenbogen’s first draft contained an error that was identified because he showed his work.  He acknowledged the problem and corrected his analysis.  New York’s Climate Act stakeholder process does not document analyses well enough for considered review and the Hochul Administration does not acknowledge any comments that do not comport with their narrative.  As a result, the broken stakeholder process in New York will likely ignore Ellenbogen’s real-world results. 

New York State 2024 GHG Emissions Inventory

This post describes the latest New York State (NYS) GHG emission inventory report that provides data through 2022.   The Climate Leadership & Community Protection Act (Climate Act) includes a target for a 40% reduction of greenhouse gas (GHG) emissions from 1990 levels by 2030 and the inventory has some implications relative to that target. 

I am convinced that implementation of the New York Climate Act net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 500 articles about New York’s net-zero transition.  The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  In addition to the 2030 GHG emission target, the electric sector is required to be 70% renewable. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation. 

NYS GHG Emissions

At the end of 2024 the New York State Department of Environmental Conservation (DEC) released the 2024 statewide GHG emissions report (2024 GHG Report).  DEC is required by the Climate Act to follow unique inventory requirements.  I published an overview post of this greenhouse gas (GHG) inventory that described things that maximize emissions in an apparent attempt to make GHG emissions as large as possible.

Climate Act emissions accounting includes upstream emissions and is biased against methane.  Obviously if upstream emissions are included then the total increases but at the same time it makes the inventory incompatible with everybody else’s inventory.  There are two methane effects.  Global warming potential (GWP) weighs the radiative forcing of a gas against that of carbon dioxide over a specified time frame so that it is possible to compare the effects of different gases.  The values used by New York compare the effect on a molecular basis not on the basis of the gases in the atmosphere, so the numbers are biased.  Almost all jurisdictions use a 100-year GWP time horizon, but the Climate Act mandates the use of the 20-year GWP which increases carbon dioxide equivalent values. 

The 2024 GHG Report includes the following documents:

To calculate all the emissions in New York and estimate the upstream emissions it takes DEC, the New York State Energy Research & Development Authority (NYSERDA) and consultants two years to produce the reports.  This article compares NYS GHG inventory electric sector emissions with EPA emissions and GHG emissions through 2022 relative to the 2030 40% reduction target.

Electric Generating Unit Emission Trends

Last month I summarized New York electric sector emissions trends.  Electric generating units report emissions to the Environmental Protection Agency Clean Air Markets Division as part of the compliance requirements for the Acid Rain Program and other market-based programs that require accurate and complete emissions data.  Table 1 lists the EPA CO2 emissions by fuel type for the available years and the total electricity sector GHG emissions from the NYS GHG Inventory.

Table 1: EPA and NYS Electric Sector Emissions

The EPA electric sector emissions are significantly less than the NYS GHG inventory.  There are three primary reasons: the inclusion of upstream emissions, imported electricity emissions, and including three other greenhouse gases: methane (CH4), nitrous oxide N2O, and sulfur hexafluoride (SF6).  Note that the choice of the GWP-20 rather than GWP-100 increases the final numbers further.

2022 GHG Emissions

Table ES.2 in the Summary Report presents emissions for different sectors.  Electric generation emissions are listed as electric power fuel combustion, imported electricity, and as part of imported fossil fuels.  In 2022, GHG gas emissions from electric power fuel combustion totaled 27.79 million metric tons of carbon dioxide equivalent (mmt CO2e) using a 20-year global warming potential.  Imported electricity totaled 8.71 mmt CO2e.  Fuel combustion and imported electricity emissions were primarily CO2.  The Table ES.2 imported fossil fuel value shown covers all fossil fuel used in other sectors. 

NYS GHG Emissions Data

There is one notable feature of the GHG inventory.  DEC and NYSERDA previously conducted an analysis of statewide emissions in 1990 to establish a baseline for the “Statewide GHG Emission Limits” established by ECL 75-0107 and reflected in 6 NYCRR Part 496. It is important to understand that GHG emission inventories are not based completely on measured emissions.  The EPA CAMD data are based on direct measurements but all the other estimates are derived using emission factors and estimates of activities such as fuel use or vehicle miles traveled.  The last four emission inventories all have estimated a different 1990 value than the regulatory limit in Part 496.  The report notes “The 6 NYCRR Part 496 regulation may be revised at a later date using updated information. For your information, I have compiled all four tables explaining the differences between the estimate of gross statewide emissions in 1990 from the 6 NYCRR Part 496 rulemaking and in this report.

Trends in Sectors

The 2022 GHG Inventory includes four  sectoral reports for energy, industrial processes and product use, agriculture, forestry and land use, and waste.  The Summary Report describes the observed trends:

 In Figure ES.2, emissions are organized into the sectors described in the IPCC approach (IPCC 2006). The Energy sector encompasses emissions associated with the energy system, including electricity, transportation, and building/industrial heating. The Industrial Process and Product Use (or IPPU) sector covers emissions associated with manufacturing and manufactured products. The Waste sector encompasses any activities to manage human-generated wastes. Finally, the Agriculture, Forest, and Other Land Use (or AFOLU) sector encompasses emissions from the management of lands and livestock as well as net emission removals from land management and the long-term storage of carbon in durable goods.

The Energy sector represents the majority of emissions (76%, 2018-2022), but energy emissions in 2022 were 17.7% lower than in 1990 (Figure ES.2). The overall reduction in energy emissions was offset by increases in all other sectors and by a 1.7% decline in net emission removals. The largest increases occurred in IPPU due to the increasing use of hydrofluorocarbons (4.66mmt CO2e) and in AFOLU resulting from changes in agricultural practices (2.37mmt CO2e). Waste sector emissions declined by 4.36mmt COze over the period, primarily due to implementation of landfill gas capture systems.

Discussion

The implications of the GHG inventory are important.  The Climate Act includes a target for a 40% reduction of greenhouse gas (GHG) emissions from 1990 levels by 2030.  The NYS Part 496 1990 baseline emissions were 404.26 million metric ton (mmt) CO2e.  The total 2022 NYS emissions were 371.38 mmt CO2e which is only a 9% or 37.9 mmt CO2e reduction from the baseline.  The 2030 limit is 245.9 mmt CO2e which will require a further 34% or 163.4 mmt CO2e reduction. 

It is beyond the scope of the GHG inventory to provide any commentary regarding the achievability of meeting the 2030 target, but it is clear that, absent a miracle, the targets will not be met.  It is time for the Hochul Administration to acknowledge that the 2030 targets cannot be achieved.  The Climate Act requires that the Public Service Commission (PSC) issue a biennial review for notice and comment that considers “(a) progress in meeting the overall targets for deployment of renewable energy systems and zero emission sources, including factors that will or are likely to frustrate progress toward the targets; (b) distribution of systems by size and load zone; and (c) annual funding commitments and expenditures.”  The draft Clean Energy Standard Biennial Review Report released on July 1, 2024 will fulfill this requirement.  The final report was due at the end of 2024 but was delayed on December 17, 2024.  The draft document compared the renewable energy deployment progress relative to the Climate Act goal to obtain 70% of New York’s electricity from renewable sources by 2030.  It projects that the 70% by 2030 goal will not be achieved until 2033 when historic renewable resource deployments are considered.  The report did not address the 40% reduction of GHG emissions by 2030 target.

The Climate Act has always been a political ploy to gain favor with certain constituencies and has had little basis with reality.  Nowhere is the missing link to reality starker than regarding the implementation of emission reduction programs.  The green narrative is that the transition away from fossil fuels will be economic, simple, and only a matter of political will.  The reality is completely the opposite.  The fact is that to reduce GHG emissions to zero as mandated means that existing energy use of fossil fuels requires replacement of existing infrastructure, development of additional supporting infrastructure, and development of new implementation resources (supply chains and trained trades people).  To compound the challenge the Climate Act schedule was not developed on the basis of a rational plan.  Instead, the politicians arbitrarily chose the deadlines.  We are now seeing the results of this boondoggle and the ramifications are unclear.

Conclusion

The 2024 GHG emission inventory reports should be a wake-up call regarding Climate Act implementation.  It is clear that the 2030 GHG emission reduction target cannot be met.  In addition, the transition of the electric generating system requires a new technology to ensure reliability and the Hochul Administration has not yet responded to last summer’s Comptroller report that found that: “While PSC and NYSERDA have taken considerable steps to plan for the transition to renewable energy in accordance with the Climate Act and Clean Energy Standard, their plans did not comprise all essential components, including assessing risks to meeting goals and projecting costs.”  It is obvious that that New York State should pause implementation of the Climate Act and address the myriad issues uncovered to date.

Wind Blowing Somewhere Does Not Solve the Intermittency Problem

A version of this article was published at Watts Up With That

In October 2023 an article of mine was published that addressed the wind is always blowing somewhere fallacy used by green energy proponents to argue that large amounts of storage and any new dispatchable emissions-free resources are not necessary in a future electric system that relies on wind and solar generating resources.  I recently discovered the US Energy Information Administration Hourly Electric Grid Monitor that provides hourly net generation by energy source for the Lower 48 states.  This article describes 2024 energy source data with an emphasis on wind energy relative to the “wind is always blowing somewhere” claim.

I am convinced that implementation of the Climate Act net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 500 articles about New York’s net-zero transition.  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.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Scoping Plan was finalized at the end of 2022.  Schussler’s article is relevant because the Scoping Plan proposes to meet the zero-emissions mandate using wind, solar, and energy storage.  In 2040, the Scoping Plan projected that39% of the electric energy would be provided by wind generation and 30% by solar.

Wind Lulls

CAC member Dr. Robert Howarth claims that he played a key role in the drafting of the Climate Act and his statement  at the meeting where the Scoping Plan was approved claims that: ”A decade ago, Jacobson, I and others laid out a specific plan for New York (Jacobson et al. 2013). In that peer-reviewed analysis, we demonstrated that our State could rapidly move away from fossil fuels and instead be fueled completely by the power of the wind, the sun, and hydro. We further demonstrated that it could be done completely with technologies available at that time (a decade ago)”.  More recently, Mark Jacobsen of Stanford acknowledges that wind intermittency is a challenge but claims that it can be simply addressed by developing interconnections, a mix of renewable energy sources, including wind, water, and solar, and implementing energy storage solutions.  The question addressed here is the extent of the interconnections needed to get to the wind blowing somewhere from New York

In the real world most analysts are not claiming that there is a simple solution to extended periods of low wind and solar resources.  In September Parker Gallant noted that industrial wind turbines (IWT) in Ontario “show up at the party, almost always, after everyone has left” in a post that described poor performance of the province’s wind turbines over a five day period in September 2024.  I evaluated the performance of New York’s 2,454 wind turbine fleet and found that there was an hour when the total generation was 0.2 MW during this September event.  David Theilen directly addressed the wind is always blowing somewhere argument with this graph using data from the US Energy Information Administration Hourly Electric Grid Monitor.

Figure 1: US Energy Information Administration Hourly Electric Grid Monitor December 2024

EIA data

I used the data dashboard at the US Energy Information Administration Hourly Electric Grid Monitor as the source of the hourly 2024 generation by energy source data used in this analysis.  EIA notes that this is “Hourly total net generation and net generation by energy source for the Lower 48 states.”   The settings widget enables a user to change the time and period albeit hourly data are only available for up to 31 days, so I had to import data by month.  There is another issue.  January generation categories included Wind, Solar, Hydro, Unknown, Other, Petroleum, Natural Gas, Coal, and Nuclear.  December generation categories changed to Battery storage, Solar with integrated battery storage, Pumped storage, Unknown energy storage, Wind, Solar, Hydro, Unknown, Other, Petroleum, Natural Gas, Coal, and Nuclear.  I made no attempt to account for the different categories when I downloaded the data.

Figure 2: US Energy Information Administration Hourly Electric Grid Monitor

I wanted to show the installed capacity for the different energy sources but I was only able to find EIA values for solar – 107,400 MW.  Figure 3 shows the Maximum Hourly Generation (MW) in 2024 for the primary energy source categories that gives an idea how much capacity is installed for each energy source.  Note the maximum solar is 75% of the EIA installed capacity.  I expect the percentage of installed wind relative to the observed maximum hourly MW would be even less.

Figure 3: US Energy Information Administration Hourly Electric Grid Monitor 2024 Maximum Hourly Generation (MW)

Figure 4 lists the US Energy Information Administration Hourly Electric Grid Monitor 2024 Total Energy (GWh).  I was frankly surprised how much wind capacity was generated on an annual basis.  However, totals and averages are not the primary planning issue – determining how much energy is needed in the worst case is a prerequisite for reliability planning.

Figure 4: US Energy Information Administration Hourly Electric Grid Monitor 2024 Total Energy (GWh)

Table 1 summarizes nationwide energy source hourly data for 2024.  Solar has the most hourly variability because it is unavailable at night.  Wind has 95% variability and petroleum that is used for peaking purposes has 99% variability.  Only nuclear has less variability than the total energy.  The distribution of wind energy hourly output is notable. 

Table 1: US Energy Information Administration Electric Grid Monitor 2024 Hourly Data Distribution

For a general idea of the variability of the wind resource across the Lower 48 consider Figure 5 a graph of annual hourly data.

Figure 5: US Energy Information Administration Hourly Electric Grid Monitor 2024 Hourly Wind Energy Production (MW)

I could not find a map of wind energy facilities at the EIA website.  Synapse Energy has developed an interactive map of U.S. power plants, including wind facilities which is shown as Figure 6.

Figure 6: Synapse Energy Map of U.S. Wind Power Plants

Assuming that the EIA wind energy facilities are similar to those used by Synapse Energy, it is clear that there is a wide spatial distribution across the Lower 48.  Consider that if a wind lull in New York City was caused by a high-pressure system that covers everything east of the Mississippi that dedicated transmission to dedicated wind turbines 1,000 miles away would be required to ensure that New York State wind energy could be supplanted by wind elsewhere.  In the next step I analyzed temporal variation. 

Table 2 provides an estimate of wind lulls at different thresholds.  I evaluated the hourly data to determine the total available wind energy (GWh) available when the total available wind capacity was less than six percentile thresholds.  At the first percentile only 14,440 MW or less was generated.  This level is 15% of the maximum observed hourly wind capacity.  There were 14 episodes that met this threshold and total energy generated during those periods was 988 GWh.  From a planning standpoint the maximum duration is important.  There was a 14-hour period when all the Lower 48 wind facilities produced less than 15% of the maximum observed capacity and the total energy generated was only 29 GWh which is only 2% of the capability over that period.  At the 25th percentile, all the wind facilities produced 40% of the maximum observed capacity.  There were 180 episodes that met this threshold and total energy generated during those periods was 63,430 GWh.  For the maximum duration there was a 115-hour period when all the Lower 48 wind facilities produced less than 40% of the maximum observed capacity and the total energy generated was 2,319 GWh which is 21% of the capability over that period.

Table 2: US EIA Electric Grid Monitor 2024 Hourly Wind Lulls

Discussion

It is a stretch to try to extrapolate these data for planning purposes to determine the resource gap for a specific area.  A sophisticated analysis that addresses the location of the wind facilities, the interconnections between the facilities, and the generation from other resources on an hour-by-hour basis is required.  Nonetheless, using the data to guess the impacts is instructive.

To take advantage of the wind blowing somewhere argument it would be necessary to upgrade the transmission system.  Assuming that transmission is available there is still a clear need for backup energy.  If the entire wind energy system would need to produce 50% of the maximum observed capacity to cover both local and distant energy needs note that this analysis found that 25% of the time only 40% of the maximum was available. The worst case was a 115-hour period when all the Lower 48 wind facilities produced only b2,319 GWh of a possible 11,150 GWh.  Assuming 50% of the maximum is needed to support the system there would be an energy gap of 3,256 GWh over this 115-hour period.  At a cost of $148/kWh to $400/kWh the storage needed for this event would be $482 to $1,302 billion.

Recently, Russ Schussler (the Planning Engineer) published an article that argued that the intermittency issue addressed here might be solvable: “The long-term problems associated with wind and solar due to their intermittency could and may likely be made manageable with improved technology and decreasing costs.”  In my opinion, practically speaking it is not possible.  It would be necessary to upgrade the electric transmission system, deploy short-term storage, and develop and deploy a dispatchable emissions-free resource all to address short and infrequent periods and to somehow finance those resources with those constraints.

Importantly, even if intermittency can be addressed Schussler argues that there is a fatal flaw:

Overcoming intermittency though complex and expensive resource additions at best gets us around a molehill which will leave a huge mountain ahead. Where will grid support come from?  Wind, solar and batteries provide energy through an electronic inverter. In practice, they lean on and are supported by conventional rotating machines. Essential Reliability Services include the ability to ramp up and down, frequency support, inertia and voltage support. For more details on the real problem see this posting. “Wind and Solar Can’t Support the Grid” describes the situation and contains links to other past postings provide greater detail on the problems.

Conclusion

Green energy advocates who minimize the challenge of transitioning the electric grid to wind and solar rely on the claim that the “wind is always blowing somewhere”.   The 2024 wind energy data suggest otherwise.  I have no doubt that a proper electric reliability resource planning analysis would verify that my intermittency concerns are real and that revolving the issues would be prohibitively expensive.  Coupled with the grid support issues, the green dream of a wind and solar electric generating system is a fantasy that will never be viable.

Ellenbogen and Caiazza Comments on DPS Definitions for Renewable Energy Program

On November 4, 2024, the Department of Public Service (DPS) staff proposed definitions for two key components of the 2040 zero emissions Climate Leadership & Community Protection Act (Climate Act)  target.   Recently I described the electric industry response comments that suggest that there will be consequences if there is no plan and recommend a re-assessment of the schedule.  This post describes comments that Richard Ellenbogen and I filed that recommends the implementation process be paused until certain issues are resolved.

I am convinced that implementation of the Climate Act net-zero mandates will do more harm than good if the future electric system relies only on wind, solar, and energy storage because of reliability and affordability risks.  I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 500 articles about New York’s net-zero transition.  The opinions expressed in this article only reflect my position and not necessarily those of Richard Ellenbogen.

Richard Ellenbogen has been speaking to NY State policy makers and regulators since 2019 regarding the deficiencies inherent in NY State Energy policy.  He has a proven record implementing carbon reduction programs at his own manufacturing business in Westchester County where has reduced its electric utility load by 80% while reducing its carbon footprint by 30% – 40% below that of the downstate system.  I have previously published other articles by Ellenbogen including a summary description of his issues with the Climate Act. 

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Scoping Plan was finalized at the end of 2022.  Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation. 

I believe that the biggest shortcoming of the Hochul Administration’s implementation of the Climate Act is the lack of a plan.  For example, to implement a transition to meet the mandate that all electricity must be generated by “zero-emissions” resources by 2040 it is first necessary to define “zero emissions”.  Amazingly, draft definitions were not proposed for over four years.  On November 4, 2024, the DPS staff proposal concerning definitions for key terms (Staff Proposal) in Public Service Law §66-p that finally defined “zero emissions”.  The Introduction of the Staff Proposal explains:

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

This post describes the comments that Ellenbogen and I filed for this proceeding.

Electric Industry Filings

We endorsed the filings made by the New York Independent System Operator and the Joint Utilities in response to the proposed definitions of “statewide electrical demand system” and “zero emissions” that I summarized earlier. We agreed that it is necessary to draft implementing regulations that rely on consistent and clear definitions to satisfy the zero emissions by the 2040 standard and to maintain electric system reliability.  It is also essential that imported energy is treated consistently and transparently. Moreover, to maintain system reliability in a zero emissions electric system that meets the aspirational Climate Act schedule, new technologies and expanded existing technologies must be deployed on an unprecedented scale.

The theme of our comments is that the implementation process should be paused until certain issues are resolved to prevent a waste of effort on false solutions.  One example reason is that a plan must be in place first and that is consistent with  this Joint Utility recommendation:

Given the potential for New York’s clean energy resources to fall short of demand, or suffer from delayed entry for various reasons, and the challenges associated with the commercial availability and maturity of new energy technologies, the Commission should require Staff to develop a plan for the development of incremental renewables, the retirement of non-compliant resources, and methodologies to address gaps between existing resources and the reliability needs of the system, while also ensuring that reliability and resource adequacy do not suffer.  Staff should also consider the development status and lead time of new and existing technologies from research and development to their commercial deployment. It is imperative to address these issues, set expectations and identify needs for the journey towards the 2040 zero emissions target.

Criteria for Pausing

The overarching reason to pause the process is that the safety valve provisions for affordability and reliability that are directly related to the zero emissions resource in New York Public Service Law  § 66-p (4). “Establishment of a renewable energy program” are not defined.  The implementation process should be paused for anything beyond Behind the Meter (BTM) generation sources and load reductions until criteria are defined and a tracking process established for “safe and adequate electric service” and “significant increase in arrears or service disconnections”.  Without established criteria it is impossible to fulfill this legal mandate.

Dispatchable Emissions-Free Resources (DEFR)

Responsible New York agencies all agree that new DEFR technologies are needed to make a solar and wind-reliant electric energy system work reliably.  No one knows what those technologies are.  We believe the only likely viable DEFR backup technology is nuclear generation because it is the only candidate resource that is technologically ready, can be expanded as needed, and does not suffer from limitations of the Second Law of Thermodynamics.

This situation is a fundamental reason why a pause is necessary.  If the only viable DEFR solution is nuclear, then the wind, solar, and energy storage approach cannot be implemented without nuclear power.  Using nuclear solely as a backup is inappropriate because it works best as a baseload resource.  Developing baseload nuclear eliminates the need for a huge DEFR backup resource and massive buildout of wind turbines and solar panels sprawling over the state’s lands and water.  Although nuclear power is expensive when compared to the resources needed for a wind, solar, energy storage, and DEFR system that all have shorter expected operational life spans it is likely that it would be cheaper.

NYSERDA and DPS have mentioned a related five-year plan presumably to determine what technology should be used going forward.   It is obviously prudent to pause renewable development until some DEFR technology is proven feasible.   The choice and even the viability of any DEFR technology will affect the entire design of the future electric structure necessary to meet the Climate Act net-zero energy system. 

Lithium-Ion Storage Safety Concerns

The Climate Act “Resilient and Distributed Grid goal is 1,500MW of energy storage, expanding to 3,000 MW by 2030”.  The Peak Coalition has recommended that battery storage replace peaking power plants and have endorsed the Rise Light & Power Renewable Ravenswood initiative that proposes to transition Ravenswood Generating Station into a clean energy hub. The plan involves the replacement of Ravenwood’s remaining peaking capacity with “a mix of offshore wind, upstate renewables, district heating, and large-scale battery storage”. 

However, there are substantive safety concerns.  These Battery Energy Storage Systems (BESS) must overcome space constraint issues and are not proven technology.  When a leading expert on batteries says: “Everybody has to be educated how to use these batteries safely”, we think the best course of action is to follow his advice.  It is not appropriate to make the residents of the disadvantaged communities near a BESS become unwilling lab rats to test whether a technology that can generate toxic gases, cause fires, and create explosions is appropriate in an urban setting. 

A recent incident reinforces this energy storage safety issue and is another reason to pause implementation. Our comments argued that it is appropriate to consider what would happen if there was a fire at Ravenswood like the fire at the Moss Landing energy storage facility in California.  Our comments were based on the analysis described in my Implications of the Moss Landing Battery Plant Fire article.  At Moss Landing, there were 7,676 acres under evacuation with only 1,214 people living there. Richard Ellenbogen described the impacts of a fire at Ravenswood if it required a similar evacuation zone.  A similar fire would require at least a shelter in place order and possibly an evacuation order for nearly a million people to say nothing about shutting down highways within the entire area circled by Routes 278 and 495 as well as the East River.   Our comments posed questions about the ramifications within this area and the Roosevelt Island community in the East River opposite Ravenswood.  Clearly, these safety concerns must be addressed before BESS facilities are built to replace peaking power plants in New York City.

BESS Timing

There are deployment timing issues that also should be addressed.  Our comments posed the question why these facilities are even needed at this time.  As Ravenswood is being redeveloped as a “Clean Energy Hub” it is not clear how much clean energy will there be to charge the batteries in the foreseeable future.  The Clean Path NY transmission line designed to bring renewables to NY City from Central NY is up in the air.  The termination of offshore wind by the Trump administration is another roadblock.  Even if it weren’t threatened by the Trump administration it is likely that significant offshore wind is likely more than 10 years away due to high costs, supply chain constraints and a lack of Jones Act compliant Jack ships needed for the installations.  We concluded that it will be years before sufficient zero-emissions energy is available for this facility.

A BESS facility built today will be storing fossil fuel-based generation with an average carbon footprint of approximately 950 pounds of CO2 per MWh as per EPA figures for the downstate NY utility system.   With 15% – 20% charge-discharge losses added that carbon footprint is increased to over 1100 pounds of CO2 per MWh for any BESS System in the downstate area.  In comparison, a highly polluting 60-year-old generating plant like EF Barrett or any of the peaking power plants that the Peak Coalition wants replaced could be replaced with a Combined Cycle gas plant with CO2 emissions of about 800 pounds per MWh, 30% lower than the battery facilities and will have a lifetime five to six times longer. 

This is another reason to pause the process.  New York State and New York City are not California where renewable development is much further along.  Solar arrays generate far less energy per acre in NY State and as a result, the state is many years away from needing these BESS facilities.  By the time that there are sufficient renewables available in NY State to create the Duck Curve and a need to charge the batteries, any Li-ion batteries installed now will have deteriorated past their 8 – 10-year operating life.  As a result, NY State ratepayers will be saddled with hundreds of millions of dollars of expenses on their utility bills that had the net effect of raising New York City and state carbon footprint more than the peaker plants that they are designed to replace

Conclusion

We concluded our comments by endorsing the Joint Utility statement recommendation that the Commission direct Staff to develop a clear roadmap that addresses, among other things, clean energy technology readiness.  This recommendation would not be necessary if there was a clear roadmap available.  In the absence of such a plan the Hochul Administration’s approach to meet the Climate Act targets has been to push ahead without consideration of technological ramifications.  The Moss Landing BESS fire underscores the risk of such an approach.  It would be inappropriate to proceed with BESS installations in New York City and the other densely populated regions of New York State until the full scope of safety risks are understood.  Additionally, the entire process should be paused until the state has a clear understanding of what resources will be needed to safely implement a sound energy plan.  This will prevent the squandering of resources on technologies that will not reduce GHG emissions and will help to ensure safety and economic vitality for New York State residents.