Climate Act – Page 12 – Pragmatic Environmentalist of New York

Spain and Portugal Blackout – Another Reason to Pause the Climate Act

I am very frustrated with the New York Climate Leadership & Community Protection Act (Climate Act) net zero transition because the reality is that 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. This article explains that the ramifications of the recent blackout in Spain and Portugal need to be considered to ensure that the cause of the blackout is not a feature of all renewable-energy dependent electric systems.

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. 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-emissions electric system 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.

In 2023 the New York Independent System Operator (NYISO) reports that solar capacity was 254 MW for utility scale facilities and 5,172 MW for behind-the-meter solar capacity. NYISO data shows that the utility-scale capacity factor was only 16.6%. The Scoping Plan Strategic Use of Low-Carbon Fuels scenario projects that 40,860 MW of total solar capacity will be needed to meet the 2040 zero-emissions target. The report projects that solar will be 30% of the total capacity of New York.

Spain and Portugal Blackout – April 29,2025

Earlier this week there was a massive blackout that started in Spain. According to Reuters:

At around 12:30 p.m. (1030 GMT), electricity generation in Spain dropped rapidly from around 27 gigawatts to just over 12 GW. The 15 GW loss was equivalent to 10% of Spain’s total installed capacity.

The sudden drop in grid load destabilized electricity flows, which require an extremely stable frequency of 50 Hertz to maintain supply. This, in turn caused a break in the Spanish and French electricity interconnection that goes through the Pyrenees mountains, resulting in the total collapse of the Spanish power system.

Spain exports electricity to Portugal, so the collapse of power in Spain quickly spread throughout the Iberian Peninsula. Some areas in France also suffered brief outages on Monday.

The blackout in Spain is projected to cost 2-4 billion euros. It is imperative to figure out what caused it. Currently there hasn’t been any definitive explanation. Nonetheless, there are reasons tp believe that it could have been caused by Spain’s reliance on wind and solar.

Potential Causes Related to Wind and Solar

Net Zero Watch described a potential problem:.

Grid analysts have suggested a high likelihood that the extent of yesterday’s blackout in Iberia was a result of the Spanish grid operating almost entirely on renewables at the time. The stability of power grids depends on so-called ‘inertia’, a resistance to rapid change that is an inherent feature of large spinning turbines, such as gas-fired power stations, but not of wind and solar farms. Too much renewables capacity on a grid can therefore mean inadequate inertia. As a result, in grids dominated by wind and solar, faults can propagate almost instantaneously across grids, leading to blackouts.

In a recent Net Zero Watch paper, entitled Blackout Risk in the Great Britan Grid, energy system analyst Kathyn Porter pointed out that the Great Britain electricity system is becoming increasingly unstable. “Large fluctuations in grid frequency – the first sign of problems – are becoming much more common”. This has not been observed in New York, yet.

Richard Ellenbogen sent an email with more information. He explained:

While the exact cause of the blackout is uncertain, both Spain and Portugal have become heavily reliant on renewables. The power loss was caused by the sudden disappearance of 15 GW of generation for five seconds. To understand the scale of the problem, the five nuclear power plants in Spain have a combined installed capacity of 7.4 GW.

There is a reliability criterion in New York that boils down to keeping enough generation capacity online and available to that if the largest source of power trips offline that the spare capacity can replace it easily. If we have to worry about all the solar going offline this quickly there is a huge challenge to resolve. Ellenbogen explained that a few minutes before the blackout, 60% of Spain’s energy was coming from solar. He also quoted an article by Robert Bryce:

The best explanation of grid inertia and its importance was published in 2016 by University of Queensland professor Simon Bartlett. In a paper written for the Energy Policy Institute of Australia, “The ‘Pressure Cooker’ Effect of Intermittent Renewable Generation on Power Systems,” Bartlett declared that the “practical upper limit for renewables is around 40% of total electricity generated.” He continued, “The scale-up of intermittent renewables not only diminishes the robustness of a particular power system but can also magnify the short and long-term risk of investing in non-renewable generation assets and the power grid itself.”

Ellenbogen also provided a link that provides an explanation about utility frequency issues for anyone that wants to read further.

Discussion

Ellenbogen closed his email with the thought that “with all of the investment that has been made in their renewable infrastructure, will we see a realistic report from the Spanish utility? An article in Reuters by Ron Bousso titled “Don’t blame renewables for Spain’s power outage” supports Ellenbogen’s concern that advocates for renewables are too invested in them to admit their proposed use may be irretrievably flawed. The article opens:

While it may be tempting to blame the unprecedented power outage that hit the Iberian peninsula this week on the rapid growth of wind and solar power in Spain, reliance on renewables is not to blame. Rather, the issue appears to be the management of renewables in the modern grid.

I love this. We don’t know what happened, but he claims it could not have been the renewables. This was followed by the description of what occurred that I quoted earlier. The next section noted that the “cause of the initial drop that led to the catastrophic cascade of events is unclear, though a collapse in Spain’s solar power system was certainly involved.” At least he admits that the solar power system was “certainly involved”. Bousso notes:

One possible contributor is the lack of so-called ‘grid inertia’ as a result of the relatively small share of nuclear and fossil fuel generation in Spain’s power mix.

Inverter-based wind and solar power, which generated just under 70% of Spain’s total electricity at the critical moment on Monday, does not involve physical rotation and therefore inertia could not compensate for the sudden loss of power.

What grid management of renewables in the modern grid is possible? His short-term solution? “An obvious short-term solution to avoid a repeat of the blackout would be to maintain a higher baseload of rotating power generation.” The current generation payment system that gives solar and wind power preferential treatment means that wholesale changes to the payment system would have to be implemented. Furthermore, if we must keep enough rotating power generation on-line to cover the sudden loss of all wind and solar due, then it begs the question why we just don’t use those resources and skip the charade of green energy.

His long-term solution is batteries:

Over the long term, however, power systems will need to invest heavily in battery capacity to store electricity as well as technologies for synchronising the grid that are critical to maintaining the 50 Hz frequency. In theory, this should be doable, as battery costs have declined sharply in recent years and are being deployed at scale around the world.

There is a critical caveat that is glossed over when he says “this should be doable”. One of the poorly understood aspects of inverter-based resources like wind and solar is the energy management systems in the inverters. It is beyond my experience to explain but the experts that I have talked to about this note that distinguishing between a problem with the equipment that requires a shutdown to protect the equipment and a grid problem that requires the system to stay on and support the system is no easy task. It gets worse when you consider that there are behind-the-meter resources like residential solar that cannot be expected to have sophisticated energy management systems. The other aspect is the cost:

But all this would still require heavy investment. While spending on new solar capacity reached around $500 billion last year, investment in grids was only at around $400 billion, becoming bottlenecks for the energy transition, according to the International Energy Agency.

Professor Simon Bartlett declared that the “practical upper limit for renewables is around 40% of total electricity generated. The New York Scoping Plan projects that in 2040 solar capacity will be 40,860 MW, onshore wind 13,096 MW, and offshore wind 13,484 MW so the renewable total is 67,440 MW. The question is whether the Scoping Plan analysis capped the amount of wind and solar output at any one time at 40%. I doubt it but this is a nuance that cannot be answered by looking at the impenetrable Scoping Plan documentation. Clearly this is another reason to pause implementation because now we know that this can be a billion-dollar risk and we don’t know how the Scoping Plan or for that matter the NYISO analyses addressed it.

Conclusion

In the coming months the green energy apologists will be saying that it is unfair to blame renewables for Spain’s power outage. My first observation is that it would be incredibly insulting to the public to say that renewables were not the original cause of the problem. The question is whether an electric system can be designed and operated to address this problem. I have the utmost respect for electric system planners and their ability to design the system to address known problems. However, given the complexity of the electric generating and transmission system I do not think that they can anticipate every potential problem that could cause a blackout. Another important consideration is whether the proposed New York electric system has incorporated features that would preclude the observed problem from happening here when we become as dependent upon inverter-based resources.

This is another reason to pause the Climate Act implementation. We simply don’t know if the proposed zero-emissions system that relies so much on wind and solar will work. If New York decides that the future electric system must be zero-emissions and it turns out that no more than 40% of the power at any time can come from wind and solar, then the only viable approach is nuclear power. Nuclear replace can replace renewables, eliminate the need for a massive backup resource to address this problem, and provide an electric system that we know can maintain current standards of reliability. Therefore, it would be prudent to pause renewable development until this issue is resolved because nuclear generation may be the only viable path to zero emissions.

Wind Energy Reasons to Pause

I am very frustrated with the New York Climate Leadership & Community Protection Act (Climate Act) net zero transition because the reality is that 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. This article describes reasons to pause implementation associated with wind energy deployment.

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.

The Scoping Plan Strategic Use of Low-Carbon Fuels scenario projects that 13,096 MW of onshore wind and 13,484 MW of offshore wind will be needed for the electric system to be “zero emissions” in 2040. If the onshore wind turbines are like the Alle-Catt 340 MW project that has 117 turbines, then each turbine will be 2.9 MW and 4,516 turbines will be needed. If the offshore wind turbines are similar to the Empire Wind project that proposes 15 MW turbines then 899 offshore turbines will be needed.

This post describes problems with wind energy in recent articles.

Wind Curtailment

Parker Gallant keeps track of wind energy production in Ontario and the problem of what to do with excess wind energy when the production from Ontario exceeds the load. The current strategy is to dump the excess power into Quebec, New York, and Michigan at a low price which has short-term consumer benefits to those jurisdictions. However, Gallant has documented that through 4/20/25 dumping the excess wind and solar energy has cost Ontario taxpayers and ratepayers $64 million. On April 21 the total bill was another $12,3 million. On April 26, the total for the month had reached $101 million which is about $20 per Ontario household.

He explains what happened on April 21:

Even though our Peak Hour was a little bit higher reaching 16,250 MW at Hour 20 we still didn’t need what the IWT and solar were generating so IESO were selling it for deep discounts to our neighbours as the average HOEP (hourly Ontario energy price) was a piddly $17.80/MWh (1.8 cents/kwh). IESO had forecast those IWT would generate 88,811 MW (75.5% of capacity) but only accepted 81,846 MW meaning they curtailed 7,000 MW which we paid for. Solar generation was small (not much sun) and generated only 1,326 MW! IESO’s intertie data indicates they sold 89,574 MW to our neighbours which means we Ontario ratepayers and taxpayers ate $12.3 million of their respective costs along with a few dollars for the other exported power which probably was baseload nuclear and hydro!

This is another reason to pause the implementation because in 2040 when there are over 5400 wind turbines running, we will have the same problem. I must believe that the problem will get worse for Ontario because they at least got paid something but, in the future, when our turbines are producing too much we will not be a market so they will just have to eat the curtailment costs. When our neighbors install their turbines, then we will have to eat our costs too. How is this supposed to work for New York ratepayers?

European Experience

Tallbloke’s Talkshop poses the renewables question whether “endless subsidies for a so-called ‘energy transition’ are affordable for those forced to cover the costs, especially when the things being subsidised are creating daily problems for electricity supply and grid stability due to the erratic nature of the technology? He describes an article in the Europe section of an OilPrice.com opinion piece that addresses the question.

Certainly, there are plenty of industries that rely on state subsidies, but how many of these, it’s worth asking, rely on these subsidies for their very survival?

The answer is inconvenient for the transition lobby. These are the only industries that literally cannot survive without massive and consistent state financial support. And that essentially makes them unviable in a natural market environment.

For recent proof, look no further than Europe. There is no anti-transition government in Europe. There is no Trump or anything like him at the helm of any European country. And yet it was in Europe that the chief executive of Danish Ørsted insisted that the government step up their financial support for the offshore wind industry to ensure its survival.

As reported by the Financial Times, which spoke to Rasmus Erbroe, “European capitals to commit to consistent annual support for the industry in order to meet offshore wind targets and help reverse rising costs.”

“If you want to deliver on energy security, energy independence, affordability for Europe for the coming decades and meet the targets, then we need to make this change,” the executive said, quite likely believing every word that came out of his mouth was the holy truth. In fact, there is nothing affordable about an energy that cannot absorb its own costs and turn in a profit without government guarantees of that profit.

Surely the question whether wind energy can ever turn a profit without government guarantees of that profit is a valid question that needs to be addressed before New York squanders more money on this technology.

Wake Physics

I described the Scoping Plan projections for wind energy earlier in this article. Those are underestimates because the projections for the expected annual output are too optimistic. In other words, if reasonable estimates were used then even more wind turbines would be needed. Pierre Gosselin describes another nuance that could affect the number of turbines needed. Klimanachrichten explains that wakes from upwind turbines reduces the output of downwind turbines. He notes:

The expansion of offshore wind energy in the North Sea is a central component of the European energy transition. However, two of the biggest players in the industry are now warning of negative effects: Ørsted and Equinor have jointly calculated that the planned 1.5 gigawatt wind farm ‘Outer Dowsing’ could cause significant so-called wake losses. These are yield losses that occur when the wind is weakened by upstream wind farms, causing downstream turbines to produce less electricity.

This might be included in the Scoping Plan, but the documentation is so poor that it is impossible to know. If I had to bet then I would bet the ranch that this nuance is not included.

Ultimate Problem

Regular readers of this blog are undoubtedly tired of me constantly whining about the insurmountable challenges associated with extended periods of extended periods of light winds. Chris Morrison describes notes that in the first quarter of 2025 “low levels of renewable generation and high demand drove gas-fired power production to its highest level since 2021”. He continues:

But this gas rescue act came at a large cost since Britain’s increasingly unstable electricity supply, which provides some of the highest prices in the world, showed wild cost swings in windless days in January. On at least two freezing winter days, wind production was more-or-less zero. Not untypical winter weather conditions also saw the sun fail to shine for a number of consecutive days. Some periods saw the wholesale peak-time electricity price top £160 per megawatt hour ((MWh). On January 8th, when winter high pressure stopped the wind blowing across the UK, the wholesale price soared to £300 MWh, while the sophisticated clearing price needed to balance the non-storable supply with instant demand soared to £2,900 MWh.

Rafe Champion agrees with my concern. He recently wrote:

The wind and solar system is vulnerable to wind droughts. It is not entirely fanciful to plan a book titled How Wind Droughts Almost Destroyed Civilisation based on these articles: The late discovery of wind droughts, We have to talk about wind droughts, and The “wind drought trap.”

The Scoping Plan analyses were not sophisticated enough to incorporate these costs into their projections. So this massive problem was downplayed by the Climate Action Council.

Killing Eagles

I recently received an email about a seminar addressing bird kills associated with wind turbines. Proponents argue that wind turbines kill only “a fraction as many as are killed by house cats, buildings, or even the fossil fuel operations that wind farms replace.” Of course, when asked about raptor kills there is no response. David Wojick continues his great coverage of the impacts of wind turbines on eagles with a post about eagle kill offset rules. He explains the problem:

Every operating wind power facility has a US Fish and Wildlife Service (FWS) permit to kill eagles on an ongoing basis and many do kill eagles. Each permit depends on eagle-kill offset rules which appear to be false. If so then the killing is illegal, a violation of the Bald and Golden Eagle Protection Act.

The eagle kill offset rules are not protecting eagles. This is another unacknowledged issue in the Scoping Plan.

Accountability for Wind Farms in France

There was an encouraging article. A court in France took action when an eagle was killed:

The recent shutdown of the Bernagues wind farm in Hérault, France, marks a long-overdue reckoning with the lethal impacts of wind energy on wildlife—particularly raptors like the golden eagle. On April 9, 2025, a French court ordered the entire site to cease operations for one year following the confirmed death of a golden eagle, a protected species, that collided with one of the farm’s turbine blades in January 2023. The decision also slapped Energie Renouvelable du Languedoc (ERL), the farm’s operator, with a €200,000 fine, half of which was suspended, and imposed an additional €40,000 fine on the company’s director.

I don’t think that it is very likely that a New York judge would take such an action. Nor do I expect that the Department of Environmental Conservation to step up until it has become obvious that 5,000 wind turbines could destroy the comeback of the Bald Eagle in New York State and by then it would probably be too late.

Breaking the Law in the US

Unfortunately in the United States the Federal government has been charging ahead with offshore wind development and it is not clear that they are following the law.

The Save the Right Whales Coalition has joined legal challenges to the Bureau of Ocean Energy Management’s (BOEM) approval of the Vineyard Wind 1 project and ten other offshore wind facilities. In a newly filed amicus brief, SRWC argues that BOEM broke federal law by rewriting statutory language, bypassing public rulemaking, and using compensation to justify harm — all to advance offshore wind at any cost.

Despite the offshore wind advocates arguments that the massive development of offshore wind will not affect the endangered Right Whale, I believe that it will. There are just too many potential impacts that will accumulate and overwhelm the few whales left.

Conclusion

Evidence continues to mount that issues associated with every component of the Climate Act transition plan are so great that a pause to re-assess the plan is necessary. New York Public Service Law § 66-p (4). “Establishment of a renewable energy program” includes safety valve conditions for affordability and reliability that are directly related to wind energy deployment. The failure of the Hochul Administration to establish criteria for those safety vales and provide public tracking of the status must be corrected before implementation proceeds.

NY State Senate Energy and Telecommunications Committee Air Quality Considerations

In March 2025 Senator Mattera invited Richard Ellenbogen to Albany to address the NY State Senate Energy & Telecommunications Committee regarding NY State’s energy situation relative to the Climate Leadership & Community Protection Act (Climate Act). I was impressed that the meeting showed that the Committee agreed with Ellenbogen that there are implementation issues and course corrections are necessary. I previously described the emissions analysis I did for the Committee. This post describes the air quality aspects of New York power plant emissions.

Overview

Senate Energy and Telecommunications Committee Meeting

On March 18, 2025 Senator Mattera invited Richard Ellenbogen to Albany to address the NY State Senate Energy & Telecommunications Committee regarding NY State’s energy situation. Senator Parker, the committee chair, gave Ellenbogen time to describe his thoughts on the Climate Act transition, describe his proposal to use of existing technology that will not get to zero but will maintain system reliability, and answer questions. There is a video of the hearing available and a previous post includes links to specific discussions within the video.

Ellenbogen’s presentation argued that there is a better way that “adheres to reality”. He believes that repowering existing power plants with combined cycle gas turbines gives significant carbon reductions. Replacing the old units reduces emissions, decreases reliability risks because the old units are so old that they are more likely to fail, and because the combined cycle plants are more efficient, they would burn less fuel to produce the same amount of electricity.

During the discussions at the meeting, Chairman Parker said a couple of times that he wanted to get specific numbers for potential emission reductions. I described the detailed description of the emissions analysis I provided to the Committee in another post. The last thing I want to address is air quality associated with New York electric generating units.

Context

The detailed analysis that I submitted to the Committee included this section on context. I joined Niagara Mohawk Power Corporation (NMPC) in 1981 and one of my responsibilities until I retired in 2010 was accounting and reporting air pollution emissions. I think it is important to understand that there have been massive reductions in electric generating unit emissions in New York since the time I joined the utility industry. The earliest records I have date back to 1984. At the time NMPC owned and operated oil-fired facilities in Albany and Oswego and coal-fired plants in Dunkirk and Tonawanda. In 1984 those facilities emitted 136,684 tons of sulfur dioxide (SO2), 37,221 tons of nitrogen oxides (NOx), and 12,530,220 tons of carbon dioxide. In 1995, according to the Environmental Protection Agency all the fossil fueled power plants in New York emitted 239,183 tons of sulfur dioxide, 120,138 tons of nitrogen oxides, and 54,000,913 tons of carbon dioxide. In 2024 all the fossil fueled power plants in New York emitted 698 tons of sulfur dioxide, 7,757 tons of nitrogen oxides, and 31,201,251 tons of carbon dioxide. The following table (NY Emissions Analysis.xls “NYS” tab) lists the annual values from 1980 until 2024.

New York Electric Generating Unit Annual Emissions from EPA Clean Air Markets Division

Air Quality Trends

There have been recent reports that noted that the American Lung Association (ALA) reported that dangerous air pollution is affecting more Americans than last year. Behind the headlines is the fact that the data they used included “exceptional (e.g., wildfires) and natural events (e.g., stratospheric intrusions)” that are the reason air quality worsened. Not mentioning the fact that the deteriorating air quality has very little to do with humans would not help their agenda and fund raising so that information isn’t included in the news stories. In this context, however, it leads the general public to believe that this indicates a trend towards worse air quality.

The National Ambient Air Quality Standards (NAAQS) establish air quality levels that are protective of public health and welfare with an adequate margin for safety, including protecting the health of ‘sensitive’ populations such as asthmatics, children, and the elderly”. From a regulatory standpoint, there is nothing that local jurisdictions can do to reduce exceptional and natural events. Consequently, the high air quality associated with those events is not counted against the attainment designation relative to the NAAQS. The air quality was worse last year in many places but in the absence of exceptional and natural events the air quality is getting better. I also believe that while there are extreme weather events that cause things like wildfires, that climate change is not exacerbating extreme weather to any observable degree.

Without those events the observed emission reductions have been accompanied by improvements in air quality. SO2 levels have decreased dramatically, with a 98% reduction in annual average levels from 2009 to 2017. I found that nitrogen dioxide one-hour ambient levels decreased 63%. There also have been decreases in particulate matter.

For the most part New York air quality reflects national and regional trends. According to the EPA nonattainment/maintenance status summary, there are multiple counties In New York that do not attain the current NAAQS for ozone and New York County does not meet the coarse particulate matter standard. Note that all of New York State meets the inhalable particulate (PM_2.5) NAAQS. All the other pollutants are in attainment. Finally, note that over the years the NAAQS limits have become more stringent.

Despite the fact that there have been significant improvements and New York is mostly in attainment with the NAAQS there is another approach to air quality health impacts that regulators and activists have used to claim more reductions are necessary. They claim that levels of pollution lower than the NAAQS have health impacts based on simplistic epidemiological extrapolations that assume there are no health impact thresholds.

For example, even though New York City is in attainment for inhalable particulates, this pollutant is used as a rationale for shutting down peaking power plants because of claims that reducing inhalable air quality impacts is beneficial. The New York City Department of Health and Mental Hygiene’s (DOHMH) 2011 Air Pollution and the Health of New Yorkers report is often referenced in this regard. The DOHMOH report concludes: “Each year, PM_2.5pollution in [New York City] causes more than 3,000 deaths, 2,000 hospital admissions for lung and heart conditions, and approximately 6,000 emergency department visits for asthma in children and adults.” These conclusions are for average air inhalable particulate pollution levels in New York City over the period 2005-2007 of 13.9 µg/m³.

I submitted comments on the Draft Scoping Plan where I showed that the New York City 2018-2020 average PM_2.5concentration was 7.4 µg/m³ which is substantially lower than the DOHMOH goal of 10.9 µg/m³. If the epidemiological linear no-threshold model is correct, then because inhalable particulate levels have come down In New York City there should be significant observed health benefits since the 2011. However, DOHMH has not verified their projections against observations. Until such time that the projected health impacts using this approach are validated with observed data, I will be skeptical of this metric. The fact that asthma and other health impacts have not improved at the same rate as the air quality improvements suggests that other factors are driving those outcomes. In my opinion, there should be a commitment to determining the more likely causes rather than wasting money on reducing already low power plant emissions.

Current Air Quality Conditions

During the Energy & Telecommunications Committee hearing on March 18, 2025 Chairman Parker questioned air quality levels around power plants. He said that there are “people sitting in the shadow of both industrial plants and nuclear power plants who are developing health outcomes that are negative because of these plants”. I need to address this misconception as it applies to fossil-fired power plants. First, I want to point out that there is no credible health outcome threat of air quality related to nuclear power plants.

I think that Chairman Parker has been misled by a “righteous risk”. In a post on this risk I noted that these risks arise from a “value-based policy approach that filters out facts and data within an ethical perspective.” The importance of these risks are “influenced by what is perceived as ethical rather than what is rational or scientific.” The Climate Act includes specific mandates to address righteous risks.

The Climate Act includes a commitment to address equity for “communities within New York that have been historically overburdened by environmental pollution”. One of the most repeated claims is related to air quality levels around power plants and reductions in co-pollutants is a prime benefit of the Climate Act.. The PEAK coalition has stated that “Fossil peaker plants in New York City are perhaps the most egregious energy-related example of what environmental injustice means today.” I believe this argument influenced Senator Parker. However, the presumption of egregious harm is based on selective choice of metrics, poor understanding of air quality health impacts, and ignorance of air quality trends. I have documented my concerns based on my extensive experience with air pollution control theory, implementation, and evaluation over my 45+ year career.

One of the legislative attempts to facilitate the Climate Act is the Build Public Renewables Act that gives the New York Power Authority (NYPA) renewable development responsibilities. This law is supposed to speed up the energy transition but it also includes a requirement for NYPA to shut down its existing fossil-fired power plants including a number of peaking power plants in New York City. I think this is as poor a policy choice as the decision to shutdown of the Indian Point nuclear power plant.

I have been an air quality meteorologist for 45+ years. A foundational presumption in my career is that if the ambient air quality effect of any polluting source is lower than the NAAQS then public safety and welfare is protected. There are two additional levels of air quality security. When the NYPA peaking power plants were permitted NYPA had to demonstrate that the increase in pollution due to the facilities was less than the Prevention of Significant Deterioration increment put in place to assure that new sources of pollution do not meaningfully worsen the air quality. In addition, the facilities had to install Lowest Achievable Emission Rate air pollution control equipment which is as good as it gets. My point is that the facilities that New York politicians are forcing to close may not have zero impacts, but they are close enough to no impacts, that they cannot possibly adversely affect health outcomes.

Discussion

After much thought I think I have an analogy that puts this in perspective. Think of power plant controls like cleaning the kitchen floor. Power plants have different levels of control equipment just like we all have different options to clean the floor. Keeping the kitchen floor clean is necessary for food safety given the likelihood of spills. In my opinion, sweeping the floor daily and mopping it regularly is “good enough”. Many don’t think that mopping the floor is good enough now because there are more sophisticated options like the Swiffer PowerMop or even steam mops. For some once-a-week mopping is not good enough and they may want to do that daily. The point is that there is a tradeoff between time and money for cleaning the floor “good enough”. In my opinion, the NYPA peaking power plants in New York City with Lowest Achievable Emission Rate controls are equivalent to using a steam mop several times a day. Demands to shut down the NYPA power plants is equivalent to deciding not use the kitchen because it is not clean enough even when using a steam mop several times a day.

Conclusion

A state-of-the-art combined cycle natural gas-fired turbine provides great grid support and is so efficient that it has significantly lower CO2 emissions than existing fossil-fired units in New York. To correctly consider the value of this technology for New York’s electric system it is necessary to use appropriate comparison metrics, have a comprehensive understanding of air quality health impacts, and consider air quality trends.Three things described in my emissions status article should also be considered. I found that a future electric system that uses nuclear power as the backbone and natural gas-fired combined cycle combustion turbines for backup support resolves the reliability risks and overall costs of a wind, solar, and energy storage system. At the same time it could reduce emissions from about 30 million tons per year today to less than 2 million tons per year in the future. I also noted 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. Even Senator Parker acknowledges that this means “at the end of the day New York is not going to solve the climate crisis”. Finally, I pointed out that New York’s impact on global warming is unmeasurable. These three points lead to the inescapable pragmatic conclusion that nuclear power as the backbone combined with combined cycle combustion turbines is good enough for environmental risks even if there are some GHG emissions and co-pollutant emissions are not zero.

NY State Senate Energy and Telecommunications Committee Meeting – Emission Status

On March 18, 2025 Senator Mattera invited Richard Ellenbogen to Albany to address the NY State Senate Energy & Telecommunications Committee regarding NY State’s energy situation relative to the Climate Leadership & Community Protection Act (Climate Act). I was impressed that the meeting showed that the Committee agreed with Ellenbogen that there are implementation issues and course corrections are necessary. This post describes the emission estimates that I provided and puts electric generating unit emissions in context.

Overview

Senate Energy and Telecommunications Committee Meeting

On March 18, 2025 Senator Mattera invited Richard Ellenbogen to Albany to address the NY State Senate Energy & Telecommunications Committee regarding NY State’s energy situation. Senator Parker, the committee chair, gave Ellenbogen time to describe his thoughts on the Climate Act transition, describe his proposal to use existing technology that will not get to zero but will maintain system reliability, and answer questions. There is a video of the hearing available and my previous post includes links to specific discussions within the video.

Ellenbogen’s presentation argued that there is a better way that “adheres to reality”. He believes that repowering existing power plants with combined cycle gas turbines gives a carbon reduction of “30 to 40%.” Replacing the old units reduces emissions, decreases reliability risks because the old units are so old that they are more likely to fail, and because the combined cycle plants are more efficient, they would burn less fuel to produce the same amount of electricity.

During the discussions at the meeting, Chairman Parker said a couple of times that he wanted to get specific numbers for potential emission reductions. In my description of the meeting, I promised to publish a post describing my supplemental emissions analysis that provided those numbers. This article fulfills that promise.

Observed and Projected Electric Generating Unit Emissions Analysis

Following the meeting I sent Ellenbogen material to send on to Senator Parker. The evaluation of observed electric generating unit carbon dioxide (CO2) emissions for selected New York power plants that represent the current state-of-the-art compared with other existing units included the information requested. My submittal included a detailed description of the analysis as well as the spreadsheet that generated the data in each table in the report. The description includes references to each tab within the spreadsheet that provides the data for every table. I am only going to summarize the evaluation because the documentation provides the details.

The analysis was complicated because it was necessary to combine two different data sets for the comparison. I used the EPA Clean Air Markets Division data that includes CO2, SO2, and NOx emissions along with several operating parameters. Unfortunately, the EPA load data represents gross load and net loads are needed to project CO2 emissions for the different scenarios. The New York Independent System Operator (NYISO) annual load and capacity data report, universally known as the “Gold Book, provides net loads. I chose 2020 because I wanted to include the Somerset coal-fired power plant information to represent the highest CO2 emissions. Because of naming convention and facility component differences, it was not possible to include all the steam turbine, combined cycle or cogeneration units in the state. However, the 43 units (Note that the report refers to 45 units but there are only 43 units in the tables) included provide a representative sample of the state, representative data for state-of-the-art generating units and includes specific units that were requested by the Committee.

I manually combined 2020 data from the two data sets for 43 electric generating units as shown in Table 3 from the report (NY Emissions Analysis.xls “Compare 2020” tab). It combines the NYISO net energy (GWh) and the EPA CO2 emissions (tons) to determine the state-of-the-art CO2 emission rate (tons/GWh). Note that the CO2 emission rate ranges from just over 400 for the combined cycle gas turbines to 1200 tons per GWh for a coal plant. I assumed that the new Cricket Valley, CPV-Valley, and Caithness combined cycle gas turbines represent a state-of-the art combined cycle power plant. Table 3 shows that those three facilities do represent the lowest emission rates and that the Bethlehem Energy Center is within their ranges so also state-of-the-art. I assumed that the average of the blue highlighted cells represents a representative state-of-the-art combined cycle power plant CO2 emission rate (410.8 tons CO2 per GWh).

Table 3 : Combine the NYISO Net Energy (GWh) and the EPA CO2 Emissions (tons) to Determine State of the Art CO2 Emission Rate

Table 4 (NY Emissions Analysis.xls “2020 Projections” tab) compares existing emissions to estimated emissions if the facility were replaced with a state-of-the art combined cycle combined cycle gas turbine power plant with and without a carbon capture and sequestration (CCS) control equipment. The observed CO2 Mass column lists 2020 annual emissions. The state-of-the-art projected CO2 emissions column equals the state-of-the-art combined cycle power plant CO2 emission rate (410.8 tons CO2 per GWh times the observed 2020 net energy rate. The column that adds the CCS control at 90% efficiency lists the emissions if the control equipment were in place. There are also columns that list the difference between observed emissions and these projections.

Table 4: Projected CO2 Emissions – Replace with Combined-Cycle GT or Combined-Cycle GT with Carbon Capture

In 2020 the electric sector emitted 26,920,636 tons of CO2. The 45 units included in this analysis emitted 21,305,661 tons representing 79% of the total. If all 45 units were state-of-the-art combined cycle natural gas fired combustion turbines, the emissions would be reduced to 17,955,036 tons which is a 16% reduction. If all 45 units added carbon capture and sequestration control equipment, the emissions would be reduced to 1,795,504 tons, a 76% reduction. My results are less than the Ellenbogen presentation because I did not account for the improved efficiency and resulting lower fuel use that would reduce emissions more.

Future Electric System

I also projected 2040 CO2 emissions for a pragmatic future electric system that relies on nuclear power but uses state-of-the-art combined cycle natural gas fired combustion turbines (CCGT) for peaking support. Making projections for future electric energy sector resource allocations is best left to the professional electric system planners who can use complex and sophisticated models that can incorporate the nuances of the capabilities and performance of different types of generation. The biggest problem is that an electric system that relies on wind and solar resources needs to overbuild wind and solar capacity. That introduces a significant error in my projection approach. Nonetheless, this analysis gives a rough idea of potential emissions for two scenarios – building CCGT instead of renewables and building nuclear for everything except peaking generation.

The detailed description of the analysis provides specifics. In brief, I first chose a New York Independent System Operator (NYISO) annual energy forecast for the emissions projection. The second step was to allocate the generation needed to provide the NYISO future energy projection. I made many assumptions to establish the arbitrary generation resource categories I used in my projections.

I considered two future scenarios for 2040. In Scenario 1 the existing nuclear and hydro capacity and generation stay the same but new combined cycle gas turbines provide all the capacity and generation necessary to meet the NYISO forecast. In Scenario 2 the existing hydro capacity and generation stayed the same, new combined cycle gas turbines provide the peaking power and all the remaining capacity and generation necessary is provided by nuclear power.

My results showed that significant reductions are possible with these scenarios. If nuclear and hydro stay the same and new CCGT is used to make up the capacity and energy necessary to match the NYISO forecast, then the emission projection is 70,301,856 tons of CO2 or 7,030,186 tons with 90% CCS controls. This is an overestimate because the NYISO projection incorporates over-building wind and solar capacity that would not be necessary if conventional generating resources are used. The second scenario in which nuclear is used for everything except peaking generation and CCGT is only used for peaking purposes is probably closer to a realistic estimate. That scenario predicts that using fossil fuels solely for that purpose would produce 1,226,718 tons of CO2 and only 122,672 tons if 90% CCS was employed. This also is an over-estimate because of the renewable over-building but the significantly lower emissions shows how effective nuclear power is for reducing emissions.

Relative Impacts

The nuclear/CCGT approach does not eliminate 100% of CO2 emissions. However, 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. Even Senator Parker acknowledges that this means “at the end of the day New York is not going to solve the climate crisis”.

There is one other argument in favor of this pragmatic approach. In short, New York’s impact on global warming is unmeasurable. Table 9 (NY Emissions Analysis.xls “Warming Averted” tab) projects the amount of global warming “savings” for the projection scenarios and historical emissions. The calculations are based on a Perplexity AI query “What is the expected change in global warming per ton of CO2 reduced”. None of the emission scenarios for the projected warming predict measurable changes in global warming.

Table 9: Potential Warming Savings for Emission Scenarios and Historical Emissions

Conclusion

The purpose of this analysis is to show that a state-of-the-art combined cycle natural gas-fired turbine is so efficient that it has significantly lower CO2 emissions than existing fossil-fired units in New York. If a cost-effective carbon capture and sequestration system could be added to those facilities the emissions are reduced much more. When combined with nuclear power for baseload electric power, there are advantages to using a system with combined cycle gas turbines when compared to using a system based on using wind, solar, and energy storage. The energy density of wind and solar energy is so low and the resource intermittency so variable hat no electric system relying on those resources for most of its energy can ever hope to provide reliable electricity. The low energy density requires a massive buildout of transmission, and an intermittent weather-dependent system requires an unproven dispatchable emissions-free resource. The nuclear/CCGT approach resolves those challenges. When the potential effects of New York emissions on global warming are considered, it is apparent that zero emissions mandates do not provide any measurable benefits.

The negligible relative impacts of New York emissions does not mean that we should do nothing, but it does suggest that strategies that do not go to zero should not be rejected. That is especially true if those strategies can be implemented for a fraction of the cost of the current plan. In addition, the emissions from combined cycle gas turbines used to replace existing generation would not meaningfully contribute to global warming but their continued use not only reduces emissions over historical levels but also resolves reliability challenges that must be addressed if zero emissions are mandated. The concept of natural gas as a bridge fuel for even lower emission alternatives is a pragmatic approach.

NY State Senate Energy and Telecommunications Committee Meeting 18 March 2025

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 is an engineer who truly cares about the environment and is an early adopter of renewable technologies at both his home and business.

Overview

Senate Energy and Telecommunications Committee Meeting

On March 18, 2025 Senator Mattera invited Richard Ellenbogen to Albany to address the NY State Senate Energy & Telecommunications Committee regarding NY State’s energy situation. Senator Parker, the committee chair, was extremely gracious and essentially gave him an unlimited amount of time to describe his thoughts on utility decarbonization using existing technologies. There is a video of the hearing available. Ellenbogen’s presentation starts at 12:40.

Senator Parker has shown signs of pragmatism regarding the implementation of the Climate Act. During the 2023 budget process he co-sponsored a bill to modify the Climate Act to use the 100-year global warming potential (GWP) that the Environmental Protection Agency and the Intergovernmental Panel on Climate Change use instead of the 20-year GWP mandated by the Climate Act. The only reason to use the 20-year GWP is the irrational belief that methane is a significant threat to global climate. New York’s environmental community went ballistic calling the proposed revision an attempt to gut the Climate Act. The proposal was quietly withdrawn in response to the pressure. Frankly, I thought that experience would mean that Ellenbogen’s presentation on the heretical idea that using natural-gas fired combined cycle combustion turbines with carbon capture (that can get a 90% CO2 reduction but not reach zero emissions) would be given short shrift but it wasn’t.

Ellenbogen Presentation

Ellenbogen referred to a handout during his presentation and the full version of the document is available. He also referenced recent comments on utility system decarbonization 15-e-0302 that provide more background information. The remainder of this section describes highlights of the hearing with links to the video for each highlight.

Ellenbogen’s presentation started with a description of his background. As noted in the introduction he has a proven record of reducing GHG emissions, waste reductions, and energy efficiency deployment at both his home and manufacturing facility. He emphasized that his strategies reduced emissions significantly but did not eliminate them entirely so his efforts would not be enough to meet Climate Act mandates.

Ellenbogen made the point that the Climate Act authors placed too much reliance on Academic “Science”. He gave an example describing how the emphasis on methane is misplaced. I agree that the methane obsession in the Climate Act is irrational.

Ellenbogen offered to discuss his concerns about the results of Ignoring science during his summary of the problem. His personal decarbonization experience made him aware of logistical issues so the labor and supply chain that are delaying the Climate Act strategies were no surprise to him. He argues that physics makes the reliance on wind and solar an impossible proposition. He has explained to me that 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

Ellenbogen says that one of the huge issues is New York’s existing fossil load. He described the following chart explaining that the first column is the load in 2019. If we were to electrify everything you would get the second column because many of the electric technologies are more efficient. The problem is that without energy storage the system breaks down. The third column shows the energy storage in the NYSERDA report New York’s 6 GW Energy Storage Roadmap: Policy Options for Continued Growth in Energy Storage. Column D lists the state plan for renewables in 2035. The point of the graph is that the projected renewables do not come anywhere near what is needed.

Ellenbogen’s presentation argued that there is a better way that “adheres to reality”. He believes that repowering existing power plants with combined cycle gas turbines gives a carbon reduction of “30 to 40%.” Replacing the old units reduces emissions, decreases reliability risks because the old units are so old that they are more likely to fail, and because the combined cycle plants are more efficient, they would burn less fuel to produce the same amount of electricity.

Note: I will eventually publish a post describing my supplemental emissions analysis of this proposal. For this article note that when I evaluated 2020 emissions and I found that if 45 existing New York fossil-fired units were replaced by state-of-the-art combined cycle natural gas fired combustion turbines, annual emissions would be reduced 16%. My results are lower than the Ellenbogen presentation because I did not account for the improved efficiency and resulting lower fuel use that would reduce emissions more. Ellenbogen’s email description of the analysis provides background information until I do a detailed post on emissions.

Questions

I am not going to address all the questions and issues that were raised during the presentation. The following are some highlights.

Senator Parker had questions about methane. Ellenbogen responded that the emphasis on methane reductions is misleading because recent analysis shows that anthropogenic activities are not the primary source of methane in the atmosphere. Consequently, reducing natural gas in New York is not going to significantly affect potential global warming.

There was a cost discussion. Ellenbogen did not respond to the issues raised during the presentation because he needed to review recent information. He did respond to the questions in a follow-up letter that referenced a Central Hudson response to a rate case question about the costs of the Climate Act. It has been my experience that every issue I have looked at is more complicated than it appears at first glance. Such is the case with the Central Hudson $4.269 trillion cost estimate based on the Scoping Plan. Suffice to say here that there is a lot of uncertainty associated with that figure. I have addressed some of the affordability problems recently but will explain the issues associated with the Scoping Plan cost estimates some other time.

I want to discuss is the comment by Parker that the state will not be repealing the Climate Act. He asked Ellenbogen what we can do to make it successful. Ellenbogen responded that we need to broaden the terms to overcome physics reality. He explained that the energy density of wind and solar is insufficient for what is needed. Intermittency is another issue because it needs over-building and storage. Ellenbogen’s recommendation is for a non-zero alternative because it is energy-dense and dispatchable. There still are significant reductions but reliability risks are eliminated.

Parker said he would need to see the difference between the various options described. We know existing emissions levels but he also wants to see the improvements due to more efficient combined cycle units and the improvements if carbon capture is added to that. The analysis of mine described earlier was prepared to directly respond to these questions.

When Ellenbogen was asked for recommendations going forward, he said “We have to be realistic” because the reality is that physics and math limit what can be done for the transition. That leads to his recommendation to pursue combined cycle combustion turbines with carbon capture until other proven zero-emissions technologies like nuclear can be deployed.

Parker re-iterated his request for emission numbers and noted that the timeline may have to shift to accommodate numbers and physics. He admitted that we are not on track for a variety of reasons. More importantly he also said that at the end of the day NY is not going to solve the climate crisis but we can still provide leadership.

Discussion

Ellenbogen’s recommendation is a pragmatic solution that I support. Unfortunately, there was no one at this hearing who was aware of the recent history of re-powering proposals for combined cycle natural gas plants and relevant nuances of the Climate Act that make this approach a tough sell.

For example, at one point Senator Parker stated that if there are companies out there that want to submit proposals for combined cycle plants, they should submit proposals. The problem is that three repowering project applications have all been rejected or withdrawn since the Climate Act passed. The Danskhammer Energy Center proposed a replacement gas-fired combined-cycle combustion turbine but DEC denied the permit stating that “The proposed project would be inconsistent with or would interfere with the statewide greenhouse gas emissions limits established in the Climate Act.” Although not a combined cycle proposal, NRG Energy proposed replacing their old units with modern units but the DEC decision letter claimed that “the Project would be inconsistent with or would interfere with the attainment of the Statewide greenhouse gas (GHG) emission limits established in Article 75 of the Environmental Conservation Law (ECL)”. A subsidiary of Eastern Generation LLC proposed to repower their old turbines at Gowanus and Narrows with modern simple cycle turbines. As far as I could tell everyone at this hearing understood the benefits of replacing old with new and trying to avoid stranding the investments. This development was for barge mounted turbines. Once it was clear that they could be replaced with something consistent with the Climate Act they could have been moved elsewhere but the company withdrew their application because of DEC’s position on consistency with the Climate Act.

There also is a problem with the recommendation to capture the carbon. My reading of the Climate Law is that it prohibits the use of carbon capture and sequestration for an electric generating unit. The references to sequestration in the law are associated with the definition of “Greenhouse gas emission offset projects” that includes the following project: carbon capture and sequestration. Section 75-0109 “Promulgation of regulations to achieve statewide greenhouse gas emissions reductions (4. a.)” states that “The department may establish an alternative compliance mechanism to be used by sources subject to greenhouse gas emissions limits to achieve net zero emissions.” However, carbon capture and sequestration at electric units is expressly prohibited in § 75-0109, (4,f) “Sources in the electric generation sector shall not be eligible to participate in such mechanism.”

Conclusion

I was very encouraged by the meeting. Senator Parker’s admission that there are implementation issues and course corrections are necessary is refreshing because most of his colleagues have not shown any departure from the orthodoxy. At one point during the meeting Senator Mattera and Senator Parker agreed on the need to be more flexible which Richard Ellenbogen notes is the equivalent of seeing a Unicorn. All this suggests that there might be support for a course correction of the Climate Act.

Nonetheless, I want to point out that at the end of the meeting Ellenbogen left a gift for Albany – a wand in a glass case with a note saying in case of a blackout break glass. A magical solution still may be the last hope.

Are New Yorkers Willing to Pay for the Climate Act?

Last December the Empire Center did a poll that asked questions about the Climate Leadership & Community Protection Act (Climate Act). I missed it at the time, but the results are striking. This post describes the results and takes a deeper look at the willingness to pay question.

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

Poll Overview

The Empire Center, based in Albany, is an independent, not-for-profit, non-partisan think tank dedicated to promoting policies that can make New York a better place to live, work and raise a family.  In the interests of full disclosure, I am an adjunct fellow of the Empire Center.

They sponsored a survey late last year. The Empire Center announcement of the survey says it canvassed 1,021 New York registered voters (margin of error: 3 percent) and was conducted by Morning Consult in mid-December 2024. The toplines and crosstabs can be viewed here. For survey neophytes like me the topline lists the questions and the overall results. Crosstabs breakdown the responses by the characteristics of the people polled. There were 38 questions in the survey and 16 questions about the demographics of the respondents. The crosstabs provides the breakdown of questions by the demographic categories.

Questions about the Climate Act were in the minority. Most of the questions were related to the value of taxes paid – “New Yorkers by a margin of more than two-to-one said they aren’t getting their money’s worth from taxes they pay in the state”. Other questions addressed the education system

There were six questions about the Climate Act. I will address the first two questions in this article but will only list the others below.

Climate Act Awareness

Knowing what I understand about this law it is frustrating that there is so little pushback associated with it. The only reason I could think of is that the majority of New Yorkers are unaware of it. The question “How familiar are you, if at all, with the provisions of the Climate Leadership and Community Protection Act (also known as CLCPA or the Climate Act) that was signed into law in New York in 2019?” confirms my suspicion.

The survey found that 45% of the people polled had never heard of it and another 24% had heard of it, but didn’t know what it is. In my opinion, if they only have a general sense what it is (another 19%) then they are probably unaware of how much it will cost. That means 88% of the people polled do not know what is coming in enough detail to understand its impacts on affordability, personal choice, reliability, and environmental impacts.

I believe that the biggest trigger for demands to pause this will be the costs so let’s talk about those results.

Willingness to Pay

I have never seen any poll regarding a willingness to pay that did not find most people are unwilling to pay very much. This is proof of Roger Pielke’s Iron Law of Climate “While people are often willing to pay some price for achieving climate objectives, that willingness has its limits.”

This poll is no different. One third of the respondents are not willing to anything on their monthly energy bill for cleaner energy. Another 28% are only willing to pay up to $20 a month for cleaner energy while another 20% would pay up to $40 a month. Nineteen percent are willing to pay up to $200 a month but only 3% are willing to pay more than $200 per month. Another 7% did not know or had no opinion.

I recently submitted comments about affordability in Proceeding 22-M-0149 “Assessing Implementation of and Compliance with the Requirements and Targets of the Climate Leadership and Community Protection Act”. On March 26, 2025, Jessica Waldorf, Chief of Staff and Director of Policy Implementation for the Department of Public Service (DPS) posted a letter responding to a letter from Michael B. Mager Counsel to Multiple Intervenors that had been submitted earlier in March to Chair of the Public Service Commission Rory Christian regarding the affordability standard. The Mager letter from the Multiple Intervenors pointed out that the DPS and New York State Energy Research & Development Authority (NYSEDA) were supposed to provide an annual report describing Climate Act implementation costs. No report was produced in 2024 and the letter asked when the next report would be provided. Waldorf’s response made no commitment. Given the politicization of all New York agencies and the willingness to pay results I don’t think that it is surprising that the Hochul Administration is stonewalling those estimates because I am sure that they will probably exceed $200 a month.

National Grid Long-Term Gas Plan

In a recent post I described the comments I submitted on Case 24-G-0248 Review of the Long-Term Gas System Plan for National Grid. That plan describes how the three National Grid operating companies intend to transition away from natural gas out to 2050.

I was frankly surprised with the costs for just this component of Climate At transition plan. The scenarios include a reference case, CEV or “clean energy vision”, and AE or “accelerated electrification”. The difference between the reference case and the CEV scenario represents the minimum cost of the Climate Act. The following tables are from the Long-Term Gas System Plan document.

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 Climate Act cost by 2030 is $57 additional per month.

Table 12-11: Niagara Mohawk Bill Impacts by Scenario

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 Climate Act cost by 2030 is $43 additional per month.

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

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. The Climate Act cost by 2030 is $44 additional per month.

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

Willingness to Pay for National Grid Long-Term Gas Plan

In the National Grid Long-Term Gas Plan, the expected increase in price to implement the “clean energy vision” exceeds $40 per month for all three service companies. Table 1 lists the willingness to pay $40 per month for selected demographics of the survey participants. Note that 71% of respondents when polled said that they were unwilling to pay more than $40 per month. I am not going to discuss the demographic breakdowns but present them for your edification.

Table 1: Empire Center Willingness to Pay for Increased Energy Costs Relative to National Grid Expected Gas System Transition Costs of at least $40 per Month Additional by 2030

Discussion

The electric and gas utilities must invest in programs that will implement the Climate Act mandates and those costs are starting to show up in their rate case proceedings. The National Grid long-term plan to transition the gas system out of existence which is necessary to comply with the Climate Act is but one example. The expected cost increase by 2030 to fulfill the clean energy vision is more than $40 per month. Only 22% of the people polled were willing to pay that much.

That is only one cost component for New Yorkers. Electric bills will need to increase by at least the same amount to pay for the infrastructure necessary to electrifying everything. The New York Cap-and-Invest program is nothing more than a tax on carbon that will necessarily increase the cost of gasoline and heating fuels. To electrify homes and transportation individual investments will be necessary. I believe that when people finally figure out that there is law in place that will markedly increase their energy costs that there will be a reckoning. I also believe that the Hochul Administration is fully aware of the ramifications of Climate Act costs on the next election. Consequently, they are slow walking the mandates to provide cost information.

In the meantime, the politicians will be more than willing to let the utilities take the heat for the inevitable major cost increases. No doubt they will simultaneously forbid the utilities to explicitly break out the Climate Act costs in their bills and demand that they lower their rate case proposals.

Conclusion

Any way you look at the willingness to pay question response, the Empire Center survey confirms Roger Pielke Jr’s Iron Law of Climate. People polled are not willing to pay much for the net-zero aspirations of the Climate Act if 50% are unwilling to pay more than $10 per month for cleaner energy. It is troubling that 88% of the New Yorkers polled had no more than a general sense of the Climate Act and many had never heard of it. This is setting up a reckoning for all the politicians that foisted the Climate Act on New Yorkers. It is inevitable that the politicians will reconsider and give up on it or be voted out for utter stupidity. The only question is whether political reality will occur before the electric and gas system is destroyed and costs bankrupts the state.

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.

Overview

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.

More Reasons to Pause Climate Act Implementation April 16 2025 Edition

I am very frustrated with the New York Climate Leadership & Community Protection Act (Climate Act) net zero transition because the reality is that 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. This article describes additional reasons to pause implementation.

Overview

Protecting American Energy from State Overreach

On April 8 President Trump issued an Executive Order protecting American energy from state overreach. The purpose of the order: “My Administration is committed to unleashing American energy, especially through the removal of all illegitimate impediments to the identification, development, siting, production, investment in, or use of domestic energy resources — particularly oil, natural gas, coal, hydropower, geothermal, biofuel, critical mineral, and nuclear energy resources.”

New York earned a specific callout:

Many States have enacted, or are in the process of enacting, burdensome and ideologically motivated “climate change” or energy policies that threaten American energy dominance and our economic and national security. New York, for example, enacted a “climate change” extortion law that seeks to retroactively impose billions in fines (erroneously labelled “compensatory payments”) on traditional energy producers for their purported past contributions to greenhouse gas emissions not only in New York but also anywhere in the United States and the world.

But wait there’s more. Trump implicitly addresses New York’s carbon taxation cap and invest plan:

Other States have taken different approaches in an effort to dictate national energy policy. California, for example, punishes carbon use by adopting impossible caps on the amount of carbon businesses may use, all but forcing businesses to pay large sums to “trade” carbon credits to meet California’s radical requirements. Some States delay review of permit applications to produce energy, creating de facto barriers to entry in the energy market.

The first section ends with this: “These State laws and policies are fundamentally irreconcilable with my Administration’s objective to unleash American energy. They should not stand.”

Section 2 starts with this:

State Laws and Causes of Action.

The Attorney General, in consultation with the heads of appropriate executive departments and agencies, shall identify all State and local laws, regulations, causes of action, policies, and practices (collectively, State laws) burdening the identification, development, siting, production, or use of domestic energy resources that are or may be unconstitutional, preempted by Federal law, or otherwise unenforceable. The Attorney General shall prioritize the identification of any such State laws purporting to address “climate change” or involving “environmental, social, and governance” initiatives, “environmental justice,” carbon or “greenhouse gas” emissions, and funds to collect carbon penalties or carbon taxes.

The Attorney General shall expeditiously take all appropriate action to stop the enforcement of State laws and continuation of civil actions identified in subsection (a) of this section that the Attorney General determines to be illegal.

That section also notes that the report from the Attorney General is due in 60 days. I imagine that the report will prominently feature New York’ Climate Act as impeding American energy. I think even the fanatics in the Hochul Administration are realizing that Climate Act implementation is going to be ruinously expensive even if it works and there are signs that it won’t. However, admitting this will open the Administration to attacks that they are not trying hard enough. What better excuse to pause than to blame this Trump Executive Order?

Electric Vehicle Mandates are Failing

Paul Homewood at Not a Lot of People Know That published three recent articles describing the progress of electric vehicle mandates in Great Britain. There are no encouraging signs that it is working.

In the first article he documents that the electric vehicle (EV) sales figures are lower than the mandates.

The second article notes that the EV costs are not coming down as projected which no doubt contributes to the poor sales. He concludes with a note describing the government’s long awaited announcement of the new plans to rollout EVs. He notes: “But strip away the waffle, greenwash and gaslighting, and we are left with rearranging to deckchairs on the Titanic to a higher deck, so that they don’t sink below the waves quite as soon!”

There is no way that the EV projections and rollout will be any different in New York.

Green Energy Jobs

Proponents of the Climate Act claim that the investments in green energy are creating new economic activity in New York. The 2024 Clean Energy Industry Report claims in a factsheet that “New York’s clean energy industry gained 7,700 jobs between 2022 and 2023”. I recently ran across a well-documented post by JoNova that suggests that this claim is a biased assessment:

It’s not rocket science. If energy costs more, that means we have to make do with less of it, or make do with less of something else. Thus if the government forces everyone to pay more for electricity, companies have less spare cash to employ people. Their margins are tighter, they can’t make and sell as many products. So when we are told the clean energy revolution is creating jobs, is it virtually self-evident that’s a mythical fairy claim.

Her article quotes analyses that show that each green job in Britain costs £100,000 (and 3.7 other jobs); in Spain for every green job created 2.2 jobs were lost; in Italy, each green job cost 5 jobs from the rest of the economy; in Germany, the subsidies far exceed the wages of the jobs created; and in Denmark wind power reduces the GDP. If there is a full accounting of the costs of the Climate Act provided we will be able to calculate the cost per job created. I doubt that New York will perform any better than the European countries when a final job accounting is completed.

Pausing to assess whether the job benefits are real is not the only jobs-related issue. The bigger problem is that the work needed relies on skilled tradespeople and there simply are not enough available to do what needs to be done.

Necessity for Nuclear Challenge

I have frequently written about the dispatchable emissions free resource (DEFR) necessary to keep the lights on during extended periods of low wind and solar resource availability in the Scoping Plan proposed electric system. One major problem is that there are no commercially available DEFR resources. I think the most promising 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. However, it is not really ready to fulfill New York’s needs.

Ted Nordhaus describes the issues that the nuclear industry has to overcome before we can deploy it in New York effectively: “Rebooting the US nuclear sector for the 21st century is a hard problem in the face of an ossified industry, an overbearing and underprepared regulator, liberalized electricity markets that are ill-suited to investing in large public works projects, and competition from both cheap gas and a mature, subsidized renewables industry.”

Clearly it would be prudent to pause renewable development until DEFR feasibility is proven because nuclear generation may be the only viable path to zero emissions and that will not be ready to deploy as needed to meet the aspirational Climate Act schedule..

My Comments on the New York Affordability Standard

On March 26, 2025, Jessica Waldorf, Chief of Staff and Director of Policy Implementation for the Department of Public Service (DPS) posted a letter responding to a letter from Michael B. Mager Counsel to Multiple Intervenors that had been submitted earlier in March to Chair of the Public Service Commission Rory Christian regarding the affordability standard. I agreed with the comments submitted by Multiple Intevenors and was disappointed with the DPS response so I submitted a letter to Christian today. This article summarizes my letter and why I was disappointed by the DPS letter and the overall DPS response to the Climate Leadership & Community Protection Act (CLCPA) implementation to date.

I am convinced that implementation of the 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.

Overview

PSC Proceeding 22-M-0149

This proceeding is an example of the implementation programs currently underway. 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” order for the Proceeding describes all the actions underway as of May 2022. To their credit, the PSC commissioners realized that a proceeding that formally required tracking of progress was needed:

The Commission has quickly taken action related to items within its jurisdiction to help put the State on a path to meet the aggressive CLCPA targets. However, in consideration of the scope of the CLCPA and the extensive work necessary to achieve its mandates, continuous monitoring of the progress made will be crucial to ensure the State remains on track to achieve these objectives. In addition, there are existing policies that will need to be reviewed, and new policies that will need to be developed, to further the enablement of the CLCPA. This proceeding will be the forum for such policy development. By this Order, the Commission institutes this new proceeding to both track and assess the advancements made towards meeting the CLCPA mandates and provide policy guidance, as necessary, for the additional actions needed to help achieve the objectives of the CLCPA.

The primary focus of the Multiple Intervenor letter (“MI Letter”) was on affordability and they noted that the Commission order establishing the Proceeding said: “Since investments required to implement the CLCPA are becoming a significant driver of utility rate increases, it is critical for DPS Staff to provide the Commission and the public with specific cost-based information to understand the impact of these capital investments on ratepayers as part of our core obligation to ensure just and reasonable rates.”

MI Letter

It comes as no surprise to anyone who understands the monumental challenge of an electric system net-zero transition that New York is falling behind on the progress needed to achieve the Climate Act mandates. Given the complexities of the net-zero transition it is inevitable that Agency staff would be unable to fulfill the reporting annual report mandates.

After describing the mandate of the Proceeding order, the MI letter goes on to quote the requirement that directs DPS staff to present information on CLCPA costs annually. The MI Letter shows that DPS is behind schedule:

On July 20, 2023, DPS Staff presented its “First Annual Informational Report on Overall Implementation of the Climate Leadership and Community Protection Act” (“First Annual Report”) in compliance with the Commission’s Order in Case 22-M-0149. While Multiple Intervenors could take issue with numerous costs that were excluded from quantification in the First Annual Report, DPS Staff estimated (at page 29) that by the end of 2022, the Commission already had authorized an eye-popping $43.756 billion in CLCPA-related costs.

Unfortunately, however, there has been no second report from DPS Staff providing public information as to CLCPA implementation costs, in clear violation of the Order. Inasmuch as the First Annual Report was filed on July 20, 2023, the second such report was expected sometime in July 2024. On December 17, 2024 – approximately five months past the report’s expected due date – DPS Staff filed a letter in this proceeding informing of a delay. In the letter, Staff states that it “anticipates presenting this report in 2025.” To date, the Commission has taken no action in response to the letter, and the public is left wondering whether a report that was directed to be filed annually – and, therefore, was due in July 2024 – will be filed at any point in 2025.

I welcomed the Multiple Intervenor letter because I hoped that it would prompt a reply addressing affordability issues and the schedule for the required reports. Unfortunately, the reply letter was unresponsive to these concerns.

DPS Reply Letter

The March 26, 2025 response from Jessica Waldorf of DPS was disappointing because it is condescending, was treated as an obligation, and does not address the cost issues. It is condescending because Mr. Mager and Multiple Intervenors are aware of the history and where to find the Integration Analysis. The description of the first draft Clean Energy Standard (CES) Biennial Review opens with the clause “Earlier this year” for a document released last summer which suggests that the text was copied from another document to fulfill the obligation to provide a response. The typographical error suggests that the response was not considered an opportunity to address the affordability problems raised.

Even though the DPS response letter did not adequately respond to affordability issues, some of the statements were revealing. The letter stated that the report does not “disaggregate funding that would have incurred under programs that existed prior to the CLCPA.” I have been complaining about the implications of this important caveat since my scenarios comment on the draft Scoping Plan because it is part of a shell game in the Integration Analysis designed to hide the costs. I have shown that most of the results presented in the Integration Analysis spreadsheet were relative to a reference case. In this type of analysis, the purpose is to consider the impacts of proposed policies relative to a business-as-usual case without those policies. The Integration Analysis did not include a modeling scenario that excludes all the costs of CLCPA implementation. Instead, costs presented are relative to a Reference Case that is described as “Business as usual plus implemented policies.

This is important because the Hochul Administration mantra developed by the New York State Energy Research & Development Authority (NYSERDA) that the “costs of inaction are more than the costs of action” is deliberately misleading. It relies in part on excluding the costs of the programs that existed before the CLCPA, which is important in this context. I believe that I represent most New Yorkers when I say I want to know the costs to meet the CLCPA goals like the 100% zero emissions electricity by 2040 and 40% lower GHG emissions by 2030 mandates. The particular program that gets New York there does not matter. I want to know the total costs to meet the mandates not just the costs of the unique CLCPA components. This letter afforded me the opportunity to make this argument in a formal proceeding where it will be more difficult to ignore.

The last substantive paragraph of the DPS response letter stated:

In addition to the First Informational Report, the integration analysis performed for the CLCPA Scoping Plan contains detailed cost information related to the implementation of the CLCPA. The integration analysis can be found on the Climate Act website. Additionally, the next State Energy Plan that is currently under development, will include an update to this prior analysis from the Scoping Plan, and incorporate new information on the potential effects of the policies included in the State Energy Plan on energy costs for consumers.

Integration Analysis Annex 2 provides the “detailed cost information”. Jim Shultz referred to the Scoping Plan 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 Integration Analysis cost information is in a massive spreadsheet that is the quantitative equivalent to the Scoping Plan avalanche of words. It may be detailed but it most certainly does not provide an easily accessible compilation for all the energy use and emission reduction strategies proposed that includes assumptions, expected costs, and projected emission reductions. In particular, the documentation does not provide explicit information to determine what costs are specifically included in the Reference Case or provide sufficient information to “disaggregate funding that would have incurred under programs that existed prior to the CLCPA.” As a result, it is impossible to parse out the total expected cost to meet Climate Act goals.

Recommendations

I included three recommendations in my letter that addressed my long-standing issues.

My comments explained why I believe the DPS response letter illustrates the broken stakeholder process exemplified by the lack of responsiveness by all the agencies regarding any comments that questioned the narrative espoused by CLCPA proponents. NYSERDA and other state agencies treat the stakeholder process as an obligation and not an opportunity. NYSERDA claims that there was “robust public input” during the draft Scoping Plan process that “included 11 public hearings across the State and more than 35,000 written comments” that supposedly were read, summarized, and presented to the Climate Action Council. The problem is that Agency staff screened the comments for the Climate Action Council and there is no publicly available documentation of their work. They only presented generalities at meetings and did not address any specific comments.

My first recommendation argued that NYSERDA and DPS should prepare documentation that lists all the issues raised in submitted comments so that the Climate Action Council, the Energy Planning Board, the Commission, and stakeholders can be assured that all issues raised have been considered. The documentation should list issues, describe their relevance, explain disposition of comments, and provide the rationale if there is a difference of opinion between the agency and a commenter. If there is inadequate documentation, then there is no assurance that stakeholder concerns have been considered.

My second recommendation is a personal example of an ignored comments. I recommended that the PSC define acceptable affordability criteria, publicly track the parameters for the criteria, and be prepared to pause implementation if the criteria are exceeded for the safety valve conditions in Public Service Law in my Draft Scoping Plan comments and in other Proceedings. There has never been a response to my comments describing safety valve conditions for affordability and reliability 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 the Climate Action Council should have developed criteria for the PSC to consider affordability and reliability. That did not happen. Based on issues observed with the transition it is incumbent upon the Commission to define “safe and adequate electric service” and “significant increase in arrears or service disconnections” as part of this Proceeding. This is necessary so that there is a clearly defined standard for the temporarily suspending or modifying the provisions of Section 66-p (4).

Finally, I recommended that affordability metrics and reports on costs should include all costs necessary to meet CLCPA mandates including programs implemented before the CLCPA. This would address the shell game shenanigans used by NYSERDA in the Scoping Plan. Clear documentation that lists all the emission strategies, the expected reductions, implementation schedule and expected costs is necessary.

I also expressed my disappointment that DPS staff appear to be more interested in the political narrative than fulfilling their mission to ensure “affordable, safe, secure, and reliable access” to electric services for New York State’s residential and business consumers. For example, at the December 18, 2024 New York Assembly Committee on Energy public hearing the author of the letter, Jessica Waldorf, claimed that there are other reasons “to build renewable energy resources in New York that are not just related to emissions.” Her response claimed reduced price volatility would reduce costs. I evaluated that claim and found that it does not stand up to scrutiny. My letter made that point.

Conclusion

I submitted my letter to reiterate several of the issues that I have raised previously regarding the Climate Act implementation process. I also pointed out that the stakeholder process is broken because impactful issues like those that I described have never been acknowledged much less addressed. I make no claims that my concerns must be reconciled for the process to be acceptable. However, I did point out that the differences between the New York Independent System Operator future projections and the Scoping Plan projections have never been reconciled publicly. It is unacceptable to dismiss differences in the analyses from the organization responsible for electric system reliability.

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

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.