Climate Act Scoping Plan Toolkit

The Climate Leadership & Community Protection Act (Climate Act) website was extensively revised at the start of 2023.  It includes a link for the Scoping Plan Toolkit which is described as “resource to help community and partner organizations” with specific “resources to facilitate conversations about New York’s climate work.”  As I was working on an article about the cap and invest program I noticed that there were two fact sheet pdf files for cap and invest: Cap-and-Invest One Pager [PDF] and Cap-and-Invest vs. Cap-and-Trade vs. Carbon Tax [PDF].  This is a short post about the new format of the website and the cap and invest “toolkits”.

The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Climate Act Website

The Climate Act website was revised at the start of 2023.  Now it is a public relations site to sell the Climate Act.  It has been revised so that it is more accessible to smart phones with large text fonts and splashy graphics.  The main internal links cover “Our Impact”, “Get Involved”, News & Events”, “Resources” and “Partner Toolkit”.  I list the links within each of these categories below:

“Our Impacts”

“Get Involved”

“News & Events”


“Partner Toolkit” Fact Sheets

There is blog post fodder in every one of these links. For example, the lead for the Addressing Energy Affordability Concerns link says “As energy prices rise, we must power our future focused on clean and renewable resources.”  Not included in the platitudes and talking points within the link is a reference to the experience of any jurisdiction that has pushed the use of wind and solar resources over fossil fuel that has actually lowered consumer bills.  It is all flash and style for pushing the narrative without substance. 

Cap and Invest Toolkit Fact Sheets

This post is going to introduce issues associated with the cap and invest toolkits.  There are two fact sheets for the cap and invest program:  Cap-and-Invest One Pager [PDF] and Cap-and-Invest vs. Cap-and-Trade vs. Carbon Tax [PDF].  When I first started looking at these resources. I found that they both linked to the cap and invest program one pager.  I alerted a contact I have known for years because there is no contact on the web pages.  The next morning the link to the Cap-and-Invest vs. Cap-and-Trade vs. Carbon Tax  was changed so someone else caught the problem.  I also question the label of the one pager document. The author’s interpretation is that a one pager means two sides of one page.  I think the generally accepted implication is to condense the summary to a single page.

I am going to do a more detailed post on the cap and invest plan toolkits but for now I just want to make one point.  Both fact sheets extoll the virtues and success of the Regional Greenhouse Gas Initiative (RGGI) cap and invest program.  New York utilities have been covered by that program since 2009 and New York agencies never lose the opportunity to claim that it has been a success.  I have been involved in the RGGI program process since its inception and have written many articles about the details of the RGGI program.

In early December I evaluated the 2020 RGGI Investment Proceeds report that describes the results of RGGI investments over the entire region.  I found that since the beginning of the RGGI program CO2 emissions have been reduced more than 50% but that RGGI funded control programs have been responsible for only 5.6% of the observed reductions.  The main reason for the reductions has been fuel switching to natural gas.  When the sum of the RGGI investments is divided by the sum of the annual emission reductions the CO2 emission reduction efficiency is $818 per ton of CO2 reduced. 

In late December I did a similar analysis of just the New York investment proceed results.  I found that in New York since the beginning of the RGGI program CO2 emissions have been reduced 39% in 2021 but the reduction was 47% until the State shutdown the Indian Point nuclear station.  The RGGI funded control programs have been responsible for only 16% of the observed reductions.  The main reason for the reductions has been fuel switching to natural gas.  When the sum of the RGGI investments is divided by the sum of the annual emission reductions the CO2 emission reduction efficiency is $565 per ton of CO2 reduced. 

I conclude that RGGI is not an effective CO2 emission reduction program and that because the emission reduction efficiency of the RGGI investments is far greater than any social cost of carbon metric yet proposed that the investments are not cost-effective.  RGGI success is the eye of the beholder.

Climate Act Scoping Plan Costs Shell Game

In the past twelve months I have spent an inordinate amount of time evaluating the Climate Leadership and Community Protection Act (Climate Act) and the Scoping Plan implementation plan framework to meet the ambitious net-zero goal by 2050.  Climate Action Council Co-Chair Harris recently made the claim that delaying climate action will cost New Yorkers more than acting now.  However, that statement is misleading and inaccurate.  This post shows that the claim is no more than a shell game gimmick.

Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies.  I submitted comments on the Climate Act implementation plan and have written over 250 articles about New York’s net-zero transition because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Climate Act Background

The Climate Act establishes a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will outline how to “achieve the State’s bold clean energy and climate agenda.”  The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the strategies.  That material was used to write a Draft Scoping Plan that was released for public comment at the end of 2021. The final Scoping Plan was approved by the Climate Action Council on December 19, 2022 and the Integration Analysis documentation was recently updated.

Documentation Shell Games

The Scoping Plan has been described as “a true masterpiece in how to hide what is important under an avalanche of words designed to make people never want to read it”. The Implementation Analysis quantitative assessment goes further.  It does not even pretend to clearly include what is important to evaluate the numbers that are used in the Scoping Plan.  There is no concise documentation that includes the costs, expected emission reductions and assumptions used for the control strategies included in the Integration Analysis documentation.  Instead, these is a massive spreadsheet with key drivers and input assumptions for all aspects of the transition.  The public is left to try to decipher what is included in each control strategy, figure out how the information was used, and then calculate what the results are for all control strategies.

The first shell game gimmick picks and chooses what control strategies are included in the costs of de-carbonization.  In order to evaluate the effects of different policy options, The Integration Analysis model projects future conditions for a baseline case.  The evaluation analysis makes projections for different policy options, and then the results are compared relative to the baseline.  Standard operating procedure for this kind of modeling is to use a business-as-usual or status quo case for the baseline.  Appendix G Section 3.4: Benefits and Costs argues that the costs of the control strategies should be considered relative to status quo or business as usual costs:

When viewed from a systems expenditure perspective (Figure 48), the NPV of net direct costs for Scenarios 2, 3, and 4 are moderate, roughly 11% as a share of the NPV of reference case system expenditures ($2.7 trillion). Because significant infrastructure investment will be needed to maintain business as usual infrastructure within the state irrespective of further climate policy, redirecting investment away from status quo energy expenditures and toward decarbonization is key to realizing the aims of the Climate Act.

Figure 51 from Appendix G is the documentation for the claim that the cost of inaction exceeds the cost of action by more than $115 billion.  In my Draft Scoping Plan comments I argued that the figure is mis-leading because it presents the numbers relative to a Reference Case rather than a business-as-usual or status quo case that represents a future without decarbonization programs.  I maintain that the true cost of New York’s net-zero transition by 2050 should include all costs associated with all programs designed to reduce GHG emissions.  The authors of the Integration Analysis and Scoping Plan excluded decarbonization costs that I believe should be included and provided insufficient documentation to enable anyone to determine what is in or out of the Reference Case. 

In the Scoping Plan shell game, the first thing to watch is the claim that “significant infrastructure investment will be needed to maintain business as usual infrastructure within the state irrespective of further climate policy, redirecting investment away from status quo energy expenditures and toward decarbonization is key to realizing the aims of the Climate Act” but at the same time including decarbonization costs for “already implemented” programs in the Reference Case.  If a reader loses track of this shell, it is easy to assume that the costs presented are relative to a business-as-usual or status quo modeling scenario per standard procedures.  Instead, the State compares mitigation scenario costs to a Reference Case that includes “already implemented” decarbonization costs.

There is another shell to watch.  In my review of the Draft Integration Analysis supplement, I ended up searching the document for the phrase “reference case” to try to determine what “already implemented” decarbonization programs were included in the Reference Case.  The following figure reproduces the page with the documentation on page 12 in Appendix G Integration Analysis Technical Supplement Section I. The documentation is buried in the footnote for the circled reference for the blank caption to Figure 4. 

Given its importance to the cost/benefit claim, my Draft Scoping Plan comment noted that this reference case caveat should be clearly described in the text rather than in a footnote.  What I missed in the draft was a reference to explanatory text in section 5.3 of the document.  However, that text was not included in the draft document! The appropriate text is in the recently released Appendix G section 5.3: Scenario Assumptions chapter and lists the “already implemented” programs.  It states:

The integration analysis evaluated a business-as-usual future (Reference Case) a representation of recommendations from CAC Advisory Panels (Scenario 1), and three scenarios designed to meet or exceed GHG limits and carbon neutrality (Scenarios 2 through 4). Scenarios 2, 3, and 4 all carry forward foundational themes based on findings from Advisory Panels and supporting analysis but represent distinct worldviews. A detailed compilation of scenario assumptions can be found in Annex 2.

For the record Annex 2 refers to a  massive spreadsheet that is certainly detailed but most certainly does not provide an easily accessible compilation of scenario assumptions.  In particular, the documentation does not provide explicit information to determine what costs are specifically included in the Reference Case relative to the other scenarios.

The Reference Case described as “Business as usual plus implemented policies” includes the following:

  • Growth in housing units, population, commercial square footage, and GDP
  • Federal appliance standards
  • Economic fuel switching
  • New York State bioheat mandate
  • Estimate of New Efficiency, New York Energy Efficiency achieved by funded programs: HCR+NYPA, DPS (IOUs), LIPA, NYSERDA CEF (assumes market transformation maintains level of efficiency and electrification post-2025)
  • Funded building electrification (4% HP stock share by 2030)
  • Corporate Average Fuel Economy (CAFE) standards
  • Zero-emission vehicle mandate (8% LDV ZEV stock share by 2030)
  • Clean Energy Standard (70×30), including technology carveouts: (6 GW of behind-the-meter solar by 2025, 3 GW of battery storage by 2030, 9 GW of offshore wind by 2035, 1.25 GW of Tier 4 renewables by 2030)

Figure 47 shows the total net present value (NPV) of direct costs relative to the Reference Case over the period 2020-2050.  However, these bar charts provide little information.

It is more useful to look at a table of the values to try to understand how the Reference Case costs differ from the mitigation scenarios.  That information is available in the IA-Tech-Supplement-Annex-2-Key-Drivers-Outputs-2022 spreadsheet.   One thing that jumps out is the $3.45 billion difference for the Transportation Investment between the Reference Cased and the Low-Carbon Fuels Scenario.  There are only two decarbonization programs included in the Reference Case: Corporate Average Fuel Economy (CAFE) standards and Zero-emission vehicle mandate (8% LDV ZEV stock share by 2030).   In my opinion that $3.45 billion difference either indicates that most of the EV electrification costs are improperly included in the Reference Case or that the cost estimates are suspect.

I found that both issues contribute to the small difference between the Reference Case and the Low-Carbon Fuels scenario.  According to the Scoping Plan the costs to replace light-duty vehicles, trucks, and buses with electric alternatives, provide the charging infrastructure to support those vehicles, and upgrade public transit services is only $3.45 billion over 30 years.  For the most part the only reason for those expenses is decarbonization and whether it is explicitly part of the Climate Act or not, those costs should be included in the costs of the Climate Act.  They have to be hundreds of billions of dollars. I have no doubts that proper accounting would reduce or reverse the alleged favorable benefit-cost ratio if just this is correctly attributed.

I believe that the cost estimates are also suspect.  My Draft Scoping Plan Comment on Electric Vehiclesanalyzed the Integration Analysis spreadsheet documentation.  The Integration Analysis presumes that the device costs for zero-emissions charging technology and the vehicles themselves decrease significantly over time.  Home EV chargers and battery electric vehicles both are claimed to go down 18% between 2020 and 2030 alone.  The following graph of electric vehicle costs shows that the costs for battery electric and hydrogen fuel cell vehicles that are the proposed solution go down over time.   The costs for gas, diesel, and Plug-in Hybrid Electric vehicles are all identical and stay pretty constant.  Given that PHEV also use batteries, why wouldn’t that technology cost decrease similar to the full battery EV.  The overall cost decreases in the preferred technologies are so large that the total costs for the zero-emissions vehicles adoption is cheaper than using existing technology.  My comments noted that I cannot accept this optimistic assessment of future cost reductions without documentation that addresses at least the potential for battery supply chain issues.  The Climate Action Council “acknowledged” my comment by providing a link but never addressed the issues that I raised.


A shell game is defined as “A fraud or deception perpetrated by shifting conspicuous things to hide something else.”  In the Scoping Plan shell game, the authors argue that energy costs in New York are needed to maintain business as usual infrastructure even without decarbonization policies but then include decarbonization costs for “already implemented” programs in the Reference Case baseline contrary to standard operating procedure to use a status quo baseline for this kind of modeling.  The documentation for Reference Case assumptions was missing in the draft documents. Shifting legitimate decarbonization costs to the Reference Case because they are already implemented and hiding the documentation fits the shifting condition of the shell game deception definition perfectly. 

The deceptions of the Scoping Plan are furthered by ignoring stakeholder input that ran contrary to their narrative.  Climate Action Council Co-Chair Harris recently claimed that the stakeholder “comments, letters, and engagement have absolutely impacted this process and the plan it has produced for the better.”  I see no evidence that the Climate Action Council addressed my Integration Analysis comments on the benefits and costs evaluation or any other stakeholder comments associated with quantitative Integration Analysis issues.   

New York Climate Act Scoping Plan Approved

First published at Watts Up With That

The New York Climate Leadership and Community Protection Act (Climate Act) Scoping Plan framework for the net-zero by 2050 transition plan was approved by the Climate Action Council on December 19, 2022.  This is follow to my earlier description of the process explains some of the rationale for that decision.


The Climate Act establishes a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will outline how to “achieve the State’s bold clean energy and climate agenda.”  In brief, that plan is to electrify everything possible and power the electric grid with zero-emissions generating resources by 2040.  The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies.  That material was used by staff from various State agencies to write a Draft Scoping Plan that was released for public comment at the end of 2021. The Climate Action Council is finalized the Scoping Plan on schedule.

The December 19, 2022 meeting materials are available at the New York Climate meetings page including the meeting presentation and the meeting recording.  In my previous article I noted that the it was unlikely that the Climate Action Council would not vote to approve the Scoping Plan because all but two of the 22 members were picked by the Democrats who passed the legislation   I wondered if anyone would cast a symbolic “no” vote and was surprised that three members voted against approval.  After the formal vote each member of the Council gave a statement supporting their decision.  This post summarizes those statements in three categories: the Hochul Administration’s position, the at-large members who supported it and the three members who voted against approval.  I am not going to provide any commentary on these summaries.

New York State Leadership Statement

Co-chair of the Climate Action Council and President & CEO of the New York State Energy Research & Development Authority Doreen M. Harris summed up the position of the Hochul Administration.  Her statement said the plan “upholds three main principles of the work that we have advanced throughout this almost three-year process”:

Principle 1: Climate Action

This plan demonstrates that climate action is not only necessary, but that delay is to be avoided. Delaying climate action has been shown to cost New Yorkers more. Therefore, I am in favor of undertaking this action now so that we may begin delivering additional benefits to the New Yorkers we are acting on behalf of.

As we implement our climate actions, certainly we will consider the on-the-ground issues and immediate costs and concerns of citizens and businesses. This is how we implement policy in New York every day and will continue to do so.

But our eye is on the prize and we in New York are wise to take climate action and have it serve as a model to the rest of the country.

Principle 2: Climate Justice

We have a plan that demonstrates how success can only be claimed when we have been able to advance and implement our climate action in a manner that addresses the issues of past decisions.

Historically, underserved communities have not been included in the dialogue and that must change. Underserved communities have also not had sufficient access to clean energy in housing, education and career opportunities and that must also change.

This plan is demonstrating how all disciplines around this table – Energy, Environment, Education, Transportation, Labor, Health, Housing, Industry, Agriculture – have responsibilities to make sure that justice is an equal outcome to the changes in our day-in, day-out business operations.

To put it simply, business as usual is no longer an option.

Principle 3: Climate Economy

I do agree with comments made at previous meetings that the economic opportunities we are looking to create through our climate planning have often been an unspoken undercurrent in this process.

We simply do not succeed if our state economy is not better off for our activities in advancing this plan. I am beyond enthusiastic about the new industries and career opportunities that we are creating in New York. And, as a product of Upstate New York myself I have never seen the level of opportunity that is at our doorstep in all parts of the state.

But that is not to discount the attention that must be paid to New Yorkers – particularly my energy colleagues and workers – that will need to find their new opportunities in our decarbonizing economy. I pledge that I will do what I can to make sure we create all those opportunities and more so that you too can become part of the more than 200,000 jobs that we stand to gain.

At Large Member Supporters of the Scoping Plan

Four Council Members chosen for their ideology and not their energy system expertise all voted to approve the Scoping Plan.  Their comments beg for responses but that will have to wait until another time. 

The statement of Robert W. Howarth, Ph.D., the David R. Atkinson Professor of Ecology & Environmental Biology at Cornell University was very illuminating relative to the motives of the supporters.  It is also very difficult to quote this without responding.  For starters, Dr. Howarth basically takes credit for the law:

Assembly Person Steven Englebright was hugely instrumental in the passage of the Climate Leadership & Community Protection Act that established the Climate Action Council. I thank him for his leadership on this, and particularly for his support of the progressive approach on greenhouse gas emissions that is a central part of the CLCPA. I originally proposed this to Assembly Person Englebright in 2016, and he enthusiastically endorsed and supported it through multiple versions of the bill that finally led to passage of the CLCPA in 2019. In this accounting for greenhouse gases, a major government for the first time ever fully endorsed the science demonstrating that methane emissions are a major contributor to global climate change and disruption. Further, in passing the CLCPA New York recognized that consumption of fossil fuels (and not simply geographic boundaries) is what matters in addressing the climate crisis. New York wisely banned the use of high-volume hydraulic fracturing (“fracking”) to develop shale gas in our State. But since the time of that ban, the use of fossil natural gas has risen faster in our State than any other in the Union. Methane emissions from this use of shale gas are high, but much of that occurs outside of our boundaries in the nearby states of Pennsylvania, West Virginia, and Ohio. Through the CLCPA, the citizens of New York are taking responsibility for these out-of-state emission caused by our use of fossil fuels, particularly for fossil natural gas. The way to reduce these emissions is to rapidly reduce our use of fracked shale gas.

He went to claim that the Scoping Plan development process ” brought in a large number of experts and key stakeholders who worked diligently to advise the Council on our Scoping Plan”.  After extolling the success of the stakeholder process and the staff members who contributed he explained why everything will work out:

I further wish to acknowledge the incredible role that Prof. Mark Jacobson of Stanford has played in moving the entire world towards a carbon-free future, including New York State. A decade ago, Jacobson, I and others laid out a specific plan for New York (Jacobson et al. 2013). In that peer-reviewed analysis, we demonstrated that our State could rapidly move away from fossil fuels and instead be fueled completely by the power of the wind, the sun, and hydro. We further demonstrated that it could be done completely with technologies available at that time (a decade ago), that it could be cost effective, that it would be hugely beneficial for public health and energy security, and that it would stimulate a large increase in well-paying jobs. I have seen nothing in the past decade that would dissuade me from pushing for the same path forward. The economic arguments have only grown stronger, the climate crisis more severe. The fundamental arguments remain the same.

Our final Scoping Plan from the Climate Action implicitly endorses the vision of the Jacobson et al. paper and is quite clear: we can meet the goals of the CLCPA and we can and will do so in way that is affordable and that will benefit all New Yorkers. Our State will be stronger as this plan is implemented, the health and well being of our citizens improved. Economic uncertainties and vulnerabilities will be reduced. Energy security will be enhanced. Our plan is also clear that the #1 priorities are to continue to move towards wind, solar, and hydro as our source of electricity; to move rapidly towards beneficial electrification as a source of heating and cooling in our homes and commercial buildings; and to move rapidly towards beneficial electrification in our personal and commercial vehicles.

Peter Iwanowicz is Executive Director, Environmental Advocates of New York.  His statement included the following comments:

When it was passed by the Legislature, The New York Times called the Climate Leadership and Community Protection Act (CLCPA) “One of the world’s most ambitious climate plans.”  While a bold pronouncement and attention-grabbing headline, it was by any measure an accurate depiction of the legislation. For the CLCPA is legislation written by those on the frontlines of the climate crisis for the benefit of those on frontlines of the climate crisis. At the time a novel approach and a testament to how policy should work.

The CLCPA provided us the promise and—through multiple provisions in the law—the guidance to make the right decisions on the pace and scale of the change needed.  At its core, the CLCPA is about establishing standards into law so that New York does its share to create a planet that is healthy enough for humans to inhabit.  What we learned through our process is that zeroing out all greenhouse gas emissions through a massive transformation of our economy is the only viable and certain path.

What truly makes the CLCPA the most ambitious of plans is the legal assurance that those disproportionately impacted by climate change and poor air quality will have their needs, health, and communities prioritized. That, and we will not leave any worker behind as the transition unfolds. 

What we have developed is a solid blueprint to guide the public and lawmakers on how to secure the promises of our climate law.

The plan shows the pathway forward to provide big benefits, including:

Reducing energy bills

Improving our health and lowering health care costs

Reversing decades of environmental injustice that has caused such harm to those who live, work, and play in our state’s disadvantaged communities.

The costs of acting are not trivial, but the analysis that the council has agreed to revealed that the cost of inaction is greater than the cost of acting.  Our plan shows that the quicker the public, the Governor and Legislature move to electrify all sectors, the faster we’ll realize the benefits.

Raya Salter Esq., Principal, Imagine Power LLC is “an attorney, consultant, educator and clean energy law and policy expert with a focus on energy and climate justice.”  Highlights from her statement reflected her background:

The true credit for this Plan belongs to the thousands of activists across New York who have rallied, marched, wrote letters and demanded that this be the people’s plan. In 2019 I stood with activists not far from where we sit now, who shut down then-Governor Cuomo’s office in an action to demand the passage of what ultimately became the Climate Leadership and Community Protection Act. It is that law that required this process and plan.

The release of this final Scoping Plan is a landmark moment for climate action in New York State. The Plan, if implemented, will guide New York towards a just energy transition and away from fossil fuels.

I was a member of the Council’s Gas Transition Subgroup and worked on the Scoping Plan’s vision to retire fossil fuel plants and decarbonize the buildings sector. It includes a blueprint for the retirement of New York City’s most-polluting fossil fuel plants and their sites by 2030 that will inform broader planning to retire fossil fuel plants throughout the State. This is a win for environmental justice.

The Plan is not perfect. Ideas for market-based “cap and invest,” and biofuels schemes should be rejected if they can’t overcome design flaws and stakeholder concerns. While the state’s climate law should ultimately prohibit the use of most “alternative fuels,” like “renewable natural gas” and hydrogen for use in pipelines on an emissions basis, the Plan is wrong to contemplate these false solutions. Likewise, looks into so-called “advanced-nuclear” are a dangerous distraction.

The Scoping Plan, however, provides a comprehensive approach to reaching the state’s nation-leading climate goals with a focus on justice and equity. The next step is to see it fully implemented.

Dr. Paul Shepson, Dean, School of Marine and Atmospheric Sciences at Stony Brook University only offered a short statement:

I will start by noting and asking us to remember that people around the world have not been paying the actual costs of burning fossil fuels to meet our energy needs; and so it is exciting and just and honorable that we are now embarking on a better way, with far fewer collateral costs to the environment, in support of ALL living things on the planet. And so, I enthusiastically endorse the December 19, 2022 final version of the New York State Climate Action Council Scoping Plan. While the Scoping Plan incorporates multiple compromises in wording and orientation, given the diverse and sometimes divergent interests of components of the CAC membership, it is nonetheless a great statement of New York State’s commitment to national and global leadership in the effort to achieve climate stabilization. The Scoping Plan, which supports the implementation of the CLCPA, is a document of which I am proud, and feel fortunate to have been able to contribute to its completion. I am impressed by and grateful for the hard work and dedication of the agency staff members who worked to bring this effort to completion, and the fantastic leadership of our co-chairs and of Sarah Osgood, and want to thank my fellow CAC members for helping to make this process enjoyable, and successful.

Council Members who Voted Against the Scoping Plan

I don’t think it is a coincidence that three members of the Climate Action Council with the most energy system practical experience voted against approval of the Scoping Plan.

Donna L. DeCarolis, President, National Fuel Gas Distribution Corporation explained that she supported many aspects of the Scoping Plan.  However her statement described why she voted against it:

Throughout my tenure on the Council, and from my perspective as the President of a utility in western New York serving communities with more than 1.6 million people, I have continued to express concerns about the Scoping Plan’s consumer impacts – for residential homeowners, small businesses and industrial interests in the state – and to offer perspectives and alternatives that will allow us to meet the requirements of the Climate Leadership and Community Protection Act (Climate Act) while preserving reliability (at both the wholesale power generation level and for homes and businesses), energy system resiliency and an affordable transition for consumers. I find the final Scoping Plan falls short in this regard, and there remain significant concerns that could jeopardize the reliable, resilient and affordable provision of energy for the state’s residents and businesses. Specifically, the Scoping Plan:

•             Fails to adequately ensure grid reliability for consumers;

•             Relies too heavily on a single energy source that is prone to weather-related disruption; and,

•             Does not include a full assessment of impacts on consumer energy affordability.

Gavin Donohue, President and CEO, Independent Power Producers of New York also voted against approving the Scoping Plan.  His statement overview is a good summary of his position:

Two years ago, I was appointed to the State’s Climate Action Council. The Climate Leadership and Community Protection Act (“CLCPA”) requires an economy-wide approach to addressing climate change and decarbonization, coupled with mandates to deliver 70% of New York’s energy from renewable resources by 2030 and 100% emissions-free electricity supply by 2040 (“100 by 40 target”). The Scoping Plan (“Plan”) was intended to inform New York residents and businesses about measures necessary to meet the requirements of the CLCPA. While the Council is required to update the Plan at least once every five years, it is essential that the inaugural Plan is practical, comprehensive, and contains provisions that send investment signals necessary to achieve the CLCPA’s requirements in a reliable and cost-effective manner. There is no backup plan to this one, and the manner in which the document is structured does not achieve the expectations set two years ago.

I am voting against the final Plan since it remains significantly lacking in these core areas, with additional concerns as discussed below:

Reliability is inadequately addressed, putting New York at risk for economy crushing blackouts and potential public safety risks.

High energy costs for energy consumers and the impact on their cost of living and on the competitiveness of New York businesses.

Insufficient programs to keep benefits of existing renewable facilities in this state.

Leaping to moratoriums and bans instead of developing innovative technologies.

Undefined wording and the lack of a glossary of terms creates ambiguity in some of the Plan’s language.

To help raise awareness for these concerns and ensure that New York’s clean energy transition is done in a more responsible manner, IPPNY, along with the New York State AFL-CIO, the New York State Building & Construction Trades Council, and Business Council of New York State, formed a unique coalition to develop a set of seven principles1 to advance New York’s clean energy goals and establish the criteria to be met by the Plan. This coalition put productive and positive ideas on the table to make the Plan better. Unfortunately, these principles were insufficiently addressed by the Council and the Plan.

Dennis Elsenbeck, Head of Energy and Sustainability, Phillips Lytle was the final Council member to vote against the Scoping Plan.  He explained that he voted against the Plan because “we have fundamentally missed the mark on balancing environmental and economic sustainability, choosing one over the other, thereby limiting the potential to achieve either goal.”  His statement included five key concerns that led to that decision.  The first two concerns are:

Limiting our solutions by losing sight of our climate challenges

We must not lose sight of the challenges we are working to solve. The CLCPA set ambitious climate and clean energy goals to safeguard our state’s resources for future generations while reinvesting in disadvantaged communities. Much of our discussions appeared to be more about shutting down the natural gas transmission and distribution network than on achieving the 85% Greenhouse Gas (GHG) reduction by 2050. Although they may appear similar, shutting down the natural gas network and achieving the CLCPA’s GHG goals are separate objectives requiring different technical paths. Our focus should be meeting our GHG reduction goals. Any discussions surrounding the natural gas transition should explore, with equal weight, what we are transitioning from and what we may be transitioning to. In my experience, limiting options also decreases the probability of meeting aggressive goals, such as our GHG objective.

Readiness of our Electric System

Much of the CLCPA outlines a transition from a fossil fuel to an all-electric economy. In my opinion, New York’s current electric distribution infrastructure cannot handle the projected 50% increase in demand. I have been adamant throughout Council discussions that without action, such as a PSC Order requiring utilities to respond, the electric distribution system is not equipped to accommodate such a transition without major investment-the cost, timing and implementability of which is yet to be determined. The Scoping Document begins to frame this challenge but falls short on how to resolve the matter_ As with most states and countries, climate initiatives begin on the supply side of the electric system. Large scale renewable energy projects appear to be focused on land (and water) availability and not as much on proximity to load centers resulting ina need for additional transmission investment; we must anticipate the impact of electrification on the distribution system to fully explore non-traditional utility investment by engaging market participants. Subject matter experts such as regulatory agencies, the NYISO, NERC and the electric utilities must be given the opportunity to respond to the Scoping Document before it reaches the Governor’s desk. We should have a more balanced and mandated planning strategy that aligns supply, demand and delivery and advances the CLCPA’s goals and our state’s economic development aspirations for business expansion, attraction and site readiness. We need to resolve the issue of dispatchable supply through continued exploration of the role of long duration storage, nuclear, hydrogen, renewable natural gas and other non-fossil-based approaches to ensure that we have a stable electric system in concert with how we progress with any gas transition strategy.


These statements give a good overview of the positions and motivations of Council membership.  Needless to say, I strongly endorse the statements of the three members who voted against the Scoping Plan.  When I find time I intend to address some of the more egregious claims of the proponents.

The Plan is just a framework that does not include a feasibility analysis to ensure the strategies proposed will maintain current standards of electric system reliability or the reliability of any other energy system components for that matter.  Readers of this blog are well aware of the affordability crises that similar programs at other jurisdictions that are further along are experiencing this winter.  The statements presented include a couple of references to a claim that the costs of inaction are greater than the cost of action.  Earlier this year I posted an article describing the machinations used to make that misleading and inaccurate claim.  I made those arguments to the Council in my verbal comments and followed up with detailed written comments but there was no acknowledgement of them by the Council.  This whole process has been rigged from the start to get the pre-ordained answer.

The proponents of the Climate Act Scoping Plan are bound and determined to dive into this net-zero transition plan.  Unfortunately, they don’t want to check to see if there is any water in the pool.


Roger Caiazza blogs on New York energy and environmental issues at Pragmatic Environmentalist of New York.  More details on the Climate Leadership & Community Protection Act are available here and an inventory of over 250 articles about the Climate Act is also available.   This represents his opinion and not the opinion of any of his previous employers or any other company with which he has been associated.

Comparison of NYISO Resource Outlook and Draft Scoping Plan Generating Resource Projections

The final version of the important New York Independent System Operator (NYISO) 2021-2040 System & Resource Outlook that addresses New York’s Climate Leadership and Community Protection Act (Climate Act) was released on September 22, 2022.  This post compares the projections for resources needed to meet the Climate Act targets in this report and the Draft Scoping Plan. 

Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies.  I submitted comments on the Climate Act implementation plan and have written extensively on New York’s net-zero transition because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that this supposed cure will do more harm than good.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.


The implementation for the New York’s Climate Act “Net Zero” target (85% reduction and 15% offset of emissions) by 2050 is underway.  The Climate Action Council has been working to develop plans to implement the Climate Act.  Over the summer of 2021 the New York State Energy Research & Development Authority (NYSERDA) and its consultant Energy + Environmental Economics (E3) prepared an Integration Analysis to “estimate the economy-wide benefits, costs, and GHG emissions reductions associated with pathways that achieve the Climate Act GHG emission limits and carbon neutrality goal”.  Integration Analysis implementation strategies were incorporated into the Draft Scoping Plan when it was released at the end of 2021.  Since the end of the public comment period in early July 2022 the Climate Action Council has been addressing the comments received as part of the development of the Final Scoping Plan that is supposed to provide a guide for the net-zero transition.

I have previously written that the Climate Action Council has not confronted reliability issues raised by New York agencies responsible for keeping the lights on.  The first post (New York Climate Act: Is Anyone Listening to the Experts?) described the NYISO 2021-2030 Comprehensive Reliability Plan (CRP) report (appendices) released late last year and the difficulties raised in the report are large. The second post (New York Climate Act: What the Experts are Saying Now) highlighted results shown in a draft presentation for the 2021-2040 System & Resource Outlook that all but admitted meeting the net-zero goals of the Climate Act are impossible on the mandated schedule.  Recently I wrote about the “For discussion purposes only” draft of the 2021-2040 System & Resource Outlook report described in the previous article and the concerns raised.  It is amazing to me that these issues continue to be ignored.

Description of Resource Outlook and Draft Scoping Plan Mitigation Scenarios

This section compares two alternate approaches to meeting the Climate Act net-zero transition requirements. 

The NYISO Resource Outlook report includes two scenarios that “reflect full achievement of the Climate Act targets”. 

Outlook Scenario 1 – Utilizes industry data and NYISO load forecasts, representing a future with high demand (57,144 MW winter peak and 208,679 GWh energy demand in 2040) and assumes less restrictions in renewable generation buildout options.

Outlook Scenario 2 – Utilizes various assumptions consistent with the Climate Action Council Integration Analysis and represents a future with a moderate peak but a higher overall energy demand (42,301 MW winter peak and 235,731 GWh energy demand in 2040).

The Resource Outlook describes the scenarios:

In both Policy Case scenarios, a significant amount of land-based wind capacity was built by 2040. The model selected land-based wind due to its assumed capital cost, energy output, and capacity ratings. In both scenarios, land-based wind capacity builds to the assumed capacity build limits imposed (~16 GW).

In both scenarios, a significant amount of capacity from renewable generation and dispatchable emission free resources (DEFRs) is projected by 2040, with the most installation forecasted in the last five years, to help offset the projected fossil-fueled generation retirements. Dispatchable emission free resources are a proxy generator type assumed for generation expansion in the Policy Case to represent a yet unavailable future technology that would be dispatchable and produces emissions-free energy (e.g., hydrogen, RNG, nuclear, other long-term season storage, etc.). As noted above, all existing fossil-fueled generation (~26 GW) was modeled as retired by 2040 due to the CLCPA requirement of a zero emissions grid by 2040. In addition, in Scenario 2 the age-based retirement assumption captured the retirement of 12 GW, nearly half the fossil fleet. The models expanded to approximately 111 GW of total capacity for Scenario 1 and 124 GW of total capacity for Scenario 2, inclusive of NYCA generators, BTM-PV, and qualifying imports from Hydro Québec. This level of total installed capacity would be needed in 2040 to satisfy the state policy, energy, and resource adequacy constraints for Scenario 1 and Scenario 2, respectively. Of this total, approximately 85 GW to 100 GW represent generation expansion for Scenario 1 and Scenario 2, respectively, beyond the 9.5 GW planned through state contracts.25 For comparison, the Contract Case has approximately 51 GW of total installed capacity by 2040.

In general, resources take years from development to deployment. By year 2030, roughly seven years from the publication of this report, an estimated 20 GW of additional renewable generation needs to be in-service to support the energy policy target of 100% zero-emission generation by 2040. For reference, 12.9 GW of new generation has been developed since wholesale electricity markets began more than 20 years ago in 1999. Over the past five years, 2.6 GW of renewable and fossil-fueled generators came on-line while 4.8 GW of generation deactivated26. This Outlook demonstrates the need for an unprecedented pace of project deployment, which will require significant labor and materials available for New York over a long period of time.

Offshore wind capacity buildout remains near the 9 GW policy objective through 2040 for both scenarios. This outcome results primarily from the assumed high capital cost of offshore wind technology in the model, which was the highest cost renewable technology available. Additionally, considering the declining marginal capacity reliability value curves assumed, offshore wind at the levels modeled is an inefficient resource to meet peak capacity needs and Locational Capacity Requirements because the capacity contribution of intermittent renewable resources declines as more are added to the system.

Overall, results for Scenario 2 showed a higher level of renewable buildout than Scenario 1, most notably in utility-scale solar capacity, and had a different projection of the capacity expansion throughout the study period as compared to Scenario 1 for all generator types. The main factors for these differences are the assumptions for load forecasts and differences in generator types eligible for capacity expansion as well as the maximum allowable capacity builds by technology type modeled between the two scenarios. One major difference in Scenario 2 is that a reduced land-based wind capacity limit was used, which changed the projection of capacity builds for all types. Notably, the projections for offshore wind were higher earlier in the model horizon (e.g., 2030) in Scenario 2 as compared to Scenario 1 to help achieve the 70 x 30 target.

Two primary drivers are attributable to increased renewable resources in capacity expansion: (1) high operating cost of dispatchable generators, and (2) low capital costs for renewable generators. High fuel (e.g., natural gas prices, clean DEFR fuel prices) and/or high CO2 emissions prices result in significant decrease in fossil generation and subsequent increase in renewable generation earlier than otherwise projected. Low capital costs for renewable generators result in capacity builds much earlier than otherwise projected, and often an increase in the total amount of capacity built.

In terms of the zonal location for capacity buildouts determined by the capacity expansion model, limitations were imposed on the zonal level as to which generator type(s) could build in each zone. For instance, land-based wind was eligible for expansion in upstate regions (Zones A-G), utility-scale solar was eligible for expansion in upstate regions and Long Island (Zones A-G and Zone K), and offshore wind was eligible for expansion in New York City and Long Island (Zones J and K). Dispatchable emission free resource (DEFR) technologies and battery storage were included as generation resource options in all NYCA zones.

The Draft Scoping Plan includes a reference case and four mitigation scenarios.  The first mitigation scenario only includes the initial recommendations of the Climate Act Advisory Panels but it did not meet the targets.  The three remaining mitigation scenarios meet or exceed GHG emission limits and achieve carbon neutrality by 2050.  They all include:

  • Zero emission power sector by 2040
  • Enhancement and expansion of transit & vehicle miles traveled (VMT) reduction
  • More rapid and widespread end-use electrification & efficiency
  • Higher methane mitigation in agriculture and waste
  • End-use electric load flexibility reflective of high customer engagement and advanced technologies

The three mitigation scenarios that meet the Climate Act targets address concerns raised by the Climate Action Council membership:

Draft Scoping Plan Scenario 2: Strategic Use of Low-Carbon Fuels: Includes the use of bioenergy derived from biogenic waste, agriculture & forest residues, and limited purpose grown biomass, as well as green hydrogen, for difficult to electrify applications

Draft Scoping Plan Scenario 3: Accelerated Transition Away from Combustion: Includes Low-to-no bioenergy and hydrogen combustion and accelerated electrification of buildings and transportation

Draft Scoping Plan Scenario 4: Beyond 85% Reduction:  Accelerated electrification + limited low-carbon fuels: This scenario adds additional VMT reductions; additional innovation in methane abatement; and avoids direct air capture of CO2

I prepared Draft Scoping Plan comments on these mitigation scenarios that includes descriptions and a comparison of the differences between them based on Appendix G of the Draft Scoping Plan.  Unfortunately, the documentation is so poor that it does not explain the rationale for the generation sector differences described in the next section.

Comparison of Scenarios

The following table provides an overview of the capacity (MW) and energy generated (GWhr) generating resources in the five scenarios described above.  Because it is difficult to read the table I have also provided a spreadsheet with the table and the input data extracted from the NYISO and Integration Analysis spreadsheets.  I will compare each of the resource categories in the following from 2019 up to 2040 when the state’s electric grid is supposed to be zero-emissions.

The first resource category is nuclear.  There is no significant difference in the capacity and power generated between the scenarios.  They all reflect the irrational shutdown of over 2,000 MW at the Indian Point Nuclear Station and continued operation of the remaining nuclear facilities to 2040.  Despite the fact that nuclear is the only dispatchable emissions-free generating resource that can be scaled up neither analysis believes that additional nuclear power generation could be part of New York’s future.

There are interesting differences between the scenarios in the fossil generation resource category.  Resource Outlook Scenario 1 reduces fossil capacity 19% from 2019 to 2030, keeps it the same in 2035, and then goes to zero in 2040.  Resource Outlook Scenario 2 reduces fossil capacity 33% from 2019 to 2030, reduces it another 9% by 2035, and then goes to zero in 2040.  Note that the energy produced is the same for both scenarios in 2030 but in 2025 Scenario 1 is reduced 8% more. So even though there is more fossil capacity in 2035 in Scenario 1 it is used less.  This is problematic for me because it means that the production resource model is treating the fossil resources differently between the scenarios.  It is not clear what would cause this difference.

The Integration Analysis scenario fossil projections raise similar concerns.  Scenario 2, Accelerated Transition from Combustion, capacity and generation is higher in 2030 compared to the other two scenarios but then does show a marked decrease in 2035.  If it is accelerated, why is it higher in 2030?  Integration Analysis Scenarios 2 and 4 are comparable to Resource Outlook Scenario 1 and Integration Analysis Scenario 3 is comparable to Resource Outlook Scenario 2.  I assume that this reflects similar assumptions by the analysts at NYISO and NYSERDA.

All the Hydro category scenarios show an increase in capacity between 2019 and 2030.  I assume that a large part of that is due to the Clean Path New York (CPNY) and Champlain Hudson Power Express projects. 

The remaining categories are the key parts of the transition.

The land-based wind (LBW) resource category is the first where there are significant differences between the Resource Outlook and the Integration Analysis scenarios.  Resource Outlook Scenario 1 increases LBW capacity 3.1 times whereas Scenario 2 only doubles the amount in 2030.  Integration Analysis Scenario 2 also doubles capacity by 2030, Scenario 3 goes up 2.7 times, and Scenario 4 goes up 2.4 times.  The differences between scenarios disappear by 2035 but the Resource Outlook projects land-based wind capacity will be 53% higher than the mitigation scenarios in the Integration analysis with 42% more generation.

The NYISO production resource model apparently does not think that offshore wind is a cost-effective option because both scenarios do not increase the projected capacity significantly beyond the Climate Act mandate of 9,000 MW.  On the other hand, the Integration Analysis scenarios nearly double the amount of offshore wind resources projected.   Overall, the Resource Outlook offshore wind capacity is 40% lower than the average of the Integration Analysis scenarios and generation is 43% lower. 

For the solar resource there is a significant difference between Resource Outlook Scenario 1 and all the other scenarios.  The capacity is 63% lower and the generation is 71% lower than the averages of the other scenarios.  In 2040 the capacity factor for the projected resource capacity and expected generation is a reasonable 15% for Resource Outlook Scenario 1 whereas Resource Outlook Scenario 2 is 17% but 21% for the Integration Analysis scenarios.  In my opinion I question why there is a difference for the Resource outlook scenarios. I don’t think that the Integration Analysis expectation that the solar capacity factor can bas high as 21% in 2040 is reasonable for New York’s latitude and snowfalls.

The energy storage resource category capacity values are pretty much the same all the scenarios.  However, the generation projections are presented differently so that it is not possible to compare them.

As noted in the Resource Outlook, the Dispatchable Emissions-Free Resource (DEFR) category is a proxy generator type that represents a yet unavailable future technology that would be dispatchable and produces emissions-free energy (e.g., hydrogen, RNG, nuclear, other long-term season storage, etc.).  The DEFR capacity and generation is substantially higher in Resource Outlook Scenario 1 and all the other scenarios.  Even Resource Outlook Scenario 2 is higher than the Integration Analysis scenarios.  In addition, Resource Outlook Scenario 1 capacity factor is 9% whereas the others are all around 2%.

Getting to 100%: Six strategies for the challenging last 10%

My most recent post described a recent paper, Getting to 100%: Six strategies for the challenging last 10%, that provides a concise evaluation of six zero-emissions technologies.  It is instructive to consider these strategies in the context of these projections.  The authors from the National Renewable Energy Laboratory provided the following summary of the challenge:

Meeting the last increment of demand always poses challenges, irrespective of whether the resources used to meet it are carbon free.  The challenges primarily stem from the infrequent utilization of assets deployed to meet high demand periods, which require very high revenue during those periods to recover capital costs.  Achieving 100% carbon-free electricity obviates the use of traditional fossil-fuel-based generation technologies, by themselves, to serve the last increment of demand—which we refer to as the ‘‘last 10%.’’

The Getting to 100% paper describes six strategies that are summarized in the following table.  Note that the strategies are compared to an ideal solution.  Ideally, the solution for peak loads would have low capital expenses and low operating expense, low resource constraints, be technologically mature, have low environmental impacts, and work well with other resources.  Needless to say, no technology comes close to meeting those ideal conditions.  The authors note that: “Although existing studies generally highlight the same fundamental causes associated with the last 10% problem, there is a lack of consensus on the preferred strategies for meeting this challenge. This is not surprising, given the diversity of possible solutions and the speculative nature of their costs, given their early stage of development.”

The Getting to 100% paper described strategies for the last 10% challenge which for this resource refers to increasing the use of wind, solar, and storage to cover what I call the ultimate problem.  Both the Resource Outlook and the Integration Analysis models predict that the primary resource for this challenge will be seasonal storage using DEFR.  Although there are mentions of the other strategies the emphasis is on the dispatchable emissions-free resource.  The proxy technology in the Integration Analysis is hydrogen although the production and use options are not specified. 

There are other options for seasonal storage.  The report notes:

This group of technologies is not well defined, but it could include batteries with very low-cost electrolytes capable of longer-than-diurnal durations. Because of the requirement for very low-cost energy storage, most seasonal storage pathways focus on hydrogen, ammonia, and other hydrogen-derived fuels stored in geologic formations.

Ultimately the Getting to 100% paper evaluates hydrogen used either in a combustion turbine or a fuel cell for electricity production.  In the New York implementation plan the dispatchable emissions-free resource (DEFR) place holder is hydrogen produced using wind and solar.  There are members of the Climate Action Council that insist that the hydrogen has to be used in a fuel cell rather than a combustion turbine because combustion causes emissions.

The Draft Scoping Plan calls for the use of so-called “green hydrogen” whereby hydrogen is produced by a carbon-free process of electrolysis from water. The Draft does not include a feasibility analysis of the production and use of hydrogen in some form as the placeholder technology for DEFR.  The Resource Outlook does not specify a specific technology but emphasizes the risks of depending upon an unproven technology: “Both scenarios include significant DEFR capacity by 2035, but it is important to note that the lead time necessary for commercialization, development, permitting, and construction of DEFR power plants will require action much sooner if this timeline is to be achieved.”

I submitted a Draft Scoping Plan comment specifically addressing this presumption.  I do not believe that the Integration Analysis correctly accounted for the energy needed to produce the hydrogen needed for the DEFR requirement. I think that there will be siting issues for all the fuel cells, electrolyzers, pipelines, and hydrogen storage facilities.  .  In the exisitng system the generating sources assigned for peaking power for this reliability requirement used the cheapest technology available (simple-cycle gas turbines).  Meeting this requirement in the future using the hydrogen DEFR resource will be using the most expensive generating technology available.  The capacity factors for this resource in the Draft Scoping Plan are 2% for all mitigation scenarios so it will be difficult to cover these costs for the short periods needed.  I guarantee the usual suspects will complain about profiteering when the costs spike during these periods.

In addition, the Getting to 100%: Six strategies for the challenging last 10% report notes that “current high-cost electrolyzers need to operate almost continuously to recover their capital expense”.  The Draft Scoping Plan plans to use intermittent wind and solar that preclude any continuous processes.  That issue has been completely ignored in the Draft Scoping Plan. 

Recall that there are members of the Climate Action Council that insist that hydrogen used for electric generation has to be used in fuel cells.  The Getting to 100% paper addresses fuel cells:

Fuel cells have diverse applications, but their use for bulk power generation is currently limited. Given the range and scale of applications especially for transportation, substantial capital cost reductions for fuel cells are possible. With low capital costs for combustion turbines and future potential cost reductions for fuel cells, the economic case for hydrogen mainly hinges on lowering the cost of electrolytic hydrogen.

According to Table 1 in the Getting to 100% paper, it really is a stretch to say that there are any positive aspects for using hydrogen.  For hydrogen used in combustion turbines the report claims low capital expenses (apparently referring only to the combustion turbine but not including the generation of the hydrogen itself), medium operating expenses and resource constraints, and concerns about hydrogen storage and transport as well as competition for using hydrogen in other sectors.  For hydrogen used in fuel cells there is a potential for low capital expenses, high operating expenses, low resource constraints (apparently referring only to the fuel cell and not assuming that the hydrogen is generated with wind and solar resources), low technological maturity, and the same other considerations as hydrogen used in combustion turbines.


This analysis found significant differences between the projections for land-based wind, offshore wind, energy storage and dispatchable emissions-free resources in the Resource Outlook and the Integration Analysis.  I think that those differences should be discussed in an open forum.  Most importantly to New York citizens the costs associated with the different options have to be made available from the NYISO and Climate Action Council.  I am pretty sure costs account for the differences in the NYISO scenarios but without that information we cannot be sure.  Most importantly, the feasibility of a dispatchable emissions-free resource has to be addressed and the projected DEFR utilization difference between Resource Outlook Scenario 1 and all the other scenarios reconciled.  I also believe that both organizations have to address the economic viability challenge of DEFR stemming from the infrequent utilization of those assets deployed to meet high demand periods, which require very high revenue during those periods to recover capital costs. 

Moreover, the forum should also address implementation concerns raised by the New York State Reliability Council in their Draft Scoping Plan comments.  They made the point that the new resources required are enormous and also raised other concerns:

Practical considerations affecting the availability, schedule and operability for new interconnections include: interconnection standards; site availability; permitting; resource equipment availability; regulatory approval; large volume of projects in NYISO queue and study process; scalability of long-term battery storage and other technologies; operational control; impact of extreme weather; consideration of a must- run reliability need for legacy resources. In addition, the pace of transportation and building electrification, the timing of any natural gas phase-out and their impact on the electric T&D system must also be carefully studied from technical, economic and environmental perspectives. Together, these practical considerations require the development of reliable zero emission resources to be conscientiously sequenced and timed in the near term (through 2030) to ensure broader GHG reductions in all sectors beyond 2030.

One final point about the modeling analyses.  The programs are proprietary and the documentation is sparse so it is not possible to fully understand the results.  For example, the Integration Analysis Accelerated Transition Away from Combustion scenario has higher fossil generation projections in intermediate years than the other scenarios.  Untangling the reason for that would be a challenge.  I believe that the models can create projection differences as much by input tweaks as by the projection algorithms.  Because the models are so complicated and include so many input parameters the modelers have to be careful to limit changes between scenarios that could affect the outcomes.


I have repeatedly made the point that the differences between the NYISO projected resources and the Integration Analysis projections need to be reconciled.  This post attempted to explicitly list those differences.  Unfortunately, this concern does not seem to be shared by the Climate Action Council and the Hochul Administration.  It is only a matter of time until the ramifications of this abrogation of responsibility affects reliability and affordability of the state’s electric grid.

The other unresolved issue is the feasibility of any dispatchable emissions-free resource.  It is staggering that the State is pushing ahead without an independent analysis of the options available for this critical resource.  As it stands it will not end well.