Category: Climate Act

Peer Review and Costs of Building Electrification for Commercial Users 

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

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

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

Heat Pump Hype

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

Ellenbogen Heat Pump Experience

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

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

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

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

Commercial Facility Projection

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

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

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

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

Environmental Impacts

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

Discussion

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

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

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

Ellenbogen summarized his peer review concerns in this regard.

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

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

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

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

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

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

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

Conclusion

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

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

New York State 2024 GHG Emissions Inventory

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

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

Overview

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

NYS GHG Emissions

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

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

The 2024 GHG Report includes the following documents:

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

Electric Generating Unit Emission Trends

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

Table 1: EPA and NYS Electric Sector Emissions

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

2022 GHG Emissions

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

NYS GHG Emissions Data

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

Trends in Sectors

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

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

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

Discussion

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

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

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

Conclusion

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

Unraveling the Narrative Supporting a Green Energy Transition

I recently wrote an article about wind intermittency that created quite a few comments for the version that was published at Watts Up With That.  The commenters were more loud than correct and I found myself wishing that I could reference a document that addressed Green Energy advocacy talking points.  Russ Schussler, aka Planning Engineer, has provided just such a document. 

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 post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Scoping Plan was finalized at the end of 2022.  The Climate Act green energy transition outlined in the Scoping Plan is starting to unravel as the politician’s aspirational fantasies meet reality.

Before he retired Russ Schussler was a long-time electric utility planning engineer.  Starting in 2014 he wrote 45 articles at the Climate Etc. blog on a wide variety of topics related to the net-zero transition that is the basis of the Climate Act. He recently published a prequel to this article that discussed the narrative around the green energy transition.  He concluded that “Expectations from the green energy narrative and real-world results are not consistent and this gulf will continue to widen as long as policy makers continue to reflexively buy into the green energy narrative.”

Schussler describes his article:

The purpose of this article is to summarize and debunk many of the issues in the narrative surrounding the proposed green energy transition.   The issues are so numerous that this piece is both too long and too short. A full unraveling deserves a book or series of books. This posting however challenges the narrative through summary comments with links to previous posts and articles which can be read for a more detailed explanation or greater depth. 

Unraveling the Narrative Supporting a Green Energy Transition

In my opinion, the typical green energy transition plan is to primarily deploy wind, solar, and energy storage to replace fossil-fired sources of electric energy. Other sources are included as “green” and clean but mostly as an afterthought.  The green energy transition narrative can be summarized as GHG emissions can be reduced to some aggressive net-zero goal simply by deploying existing technology, will be cheaper because there are no fuel costs, and will not affect the reliability of the electric grid.  Schussler notes that the components of this narrative are appealing and dangerous:

This narrative is compelling to many consumers and major policy makers. Unqualified acceptance of this powerful narrative makes it clear we should all be behind the movement to increase wind and solar generation along with other efforts to expand renewable resources.  Most all of the above statements making up the narrative are “somewhat” true. Unfortunately, the collective narrative as frequently adopted is at odds with the economics and physical realities of providing electric power and supporting civilization. 

How did a “false” narrative become so widely accepted despite dismal real-world results?  A previous posting discussed, “How the Green Energy Narrative Confuses Things” through misleading language (#44). Additionally,  tribal loyalties enable distortions and suppress more realistic assessments (#18, #10,#22, #42, & #39). While others should chime in on the social psychology supporting this movement, astute observers can’t miss the power of fear-based narratives, groupthink, demonization of dissenters and misplaced altruism (#39, #18,& #10).  Incentives and their impact on key actors play a major role (#38 & #29). The media overblowing trivialities and focusing on continually emerging “good news” helps cement undeserved optimism.   Finally, it should be noted that the electric grid has been very robust. In the short run you can make a lot of “bad decisions” before negative consequences emerge to challenge the narrative.

Narrative Statements

Schussler lists 19 component statements of the green energy narrative that are “widely believed, embraced and supported by various experts, a large part of the public and far too many policy makers”.  The article provides a response to each statement that is supported by references to 45 articles he has written since 2014.   This is an excellent resource that can be used to refute the usual suspects when they make narrative claims.  The following topics are included:

  1. Renewable Energy can meet the electric demand of the United States and World
  2. Renewable Energy is economic
  3. Renewable Energy sources can provide reliable electric service to consumers and support the grid
  4. Renewable energy sources are inexhaustible and widely available
  5. Clean Energy resources don’t produce carbon and are environmentally neutral
  6. Renewable Energy Costs are decreasing over time 
  7. It will become easier to add renewables as we become more familiar with the technologies
  8. The intermittency problems associated with wind and solar can be addressed through batteries.
  9. Inverter based generation from wind, solar and batteries can be made to perform like conventional rotating generator technology  
  10. Battery improvements will enable the green transition
  11. We are at a tipping point for renewables
  12. Wind, Solar, and Battery technologies collectively contribute to a cleaner environment, economic growth, energy security, and a sustainable future
  13. The world is facing severe consequences from increased CO2 emissions.
  14. There will be an inevitable and necessary transition to clean economic renewables
  15. Green Energy will allow independence from world energy markets
  16. The clean grid will facilitate clean buses, trucks, tanks, planes
  17. The third world will bypass fossil fuels and promote global equity
  18. Replacing fossil fuels with green energy will have huge health benefits
  19. It’s all about Urgency and Action

He acknowledges that it may be argued that the responses are short and lack detailed substantial evidence. He responds:

While there is quite a bit out there that can be referenced, it should be pointed out that the arguments supporting a green transition are asserted without with much serious reasoning and far flimsier support than provided here.  That which is easily asserted without foundation should not require overly demanding refutations. Clearly when and if more detailed claims supporting a green energy transition are made, they can be answered with more detailed rebuttals.

I particularly endorse his description of the academics whose work plays an out-sized role in the Climate Act:

Academics are a key part of the problem of a sustained false narrative. Much of the “evidence” out there comes from small studies of single variables with academic models which are stretched far behind what was analyzed.  Additionally, expert opinions come from many “experts” who “preach” far outside their fields of expertise and training. There are rewards in academia for furthering optimism on the green transition.  There are not so many incentives for nay-sayers.  Academics who understand the problems and would offer caution, generally do not have the reach of those who promote optimism by clouding the facts.  The many half-truths presented from different sources cannot be summed up to imply a credible narrative, even though many have the impression this makes a strong case.  #44

Necessary Energy Transition Narrative Truths

Another section of the article lists and references truths that need to be part of energy transition narrative.  These truths include:

  1. Adequately addressing the energy future requires we understand the true costs and benefits of ALL available and potentially available technologies. #1 & #3
  2. Large grids are dependent upon and run on rotating machines. #3, #7, #11, #26 & #12
  3. No grids run on asynchronous generation only (or majority asynchronous) without significant backup.  Asynchronous wind, solar and batteries without rotating backup resources are not feasible power supply elements for large power systems.
  4. Hydro, biomass and geothermal are fine for grid support, but are problematic and/or not available in many areas.
  5. Wind and solar face major challenges in achieving significant penetration levels and have many underdiscussed issues. 
  6. Costs of Wind and solar resources are often hidden and assigned to others. #5, #6, & #31
  7. If Nuclear is the right direction, current efforts at wind and solar are misguided. Nuclear plants run best full out with low incremental cost.   Displacing nuclear power with intermittent wind and solar makes little to no sense.
  8. It’s possible to subsidize a few things that have small costs to support development of green resources, but small costs multiplied by orders of magnitude are crushing. #6
  9. Utility costs are regressive, dis-proportionally hitting those less well-off and least able to afford rising costs. These costs are more regressive than taxation schemes. #5 #6, & #31
  10. If we must cut carbon emissions without nuclear and hydro, drastically changing civilization is an option that needs to be on the table, openly and frequently discussed and given full considered.
  11. Energy markets are not working well.  Perhaps I am wrong, but experience tells us markets uncharacteristically are not working well for energy and energy services. #45
  12. Credible plans for any electric energy future, let alone a major transition, will need to integrate studies of both supply and deliverability while balancing economics, costs and public responsibility. No conclusions about what may be worthwhile is possible without such considerations. #16 & #39

Other Topics

Schussler describes other topics that need to be considered:

  1. Givern that India and China emissions are greater than US emissions what role should we play in the proposed transition?
  2. What about developing countries in the Third World?
  3. Can effective regulation, as opposed to current regulatory practices revive nuclear construction significantly?
  4. Energy density problem (EROEI) – Can solar and wind provide enough energy to be self-perpetuating considering full lifetime needs?
  5. Grid and energy prices are globally critical to healthy economies and a reasonable quality of life.
  6. How do we incentivize policy makers to prioritize long term goals versus what’s expedient the next few years. #38 & #1

The last section of text addresses the question – when will reality force a re-assessment of the myths of the green energy narrative.  I will address that section in another post.

Discussion

My experiences writing this blog parallel Schussler’s.  As a result, he provides insights that I empathize with.  For example:

Clearly there are many discontinuities between theory and what is observed in the real world with regards to the potential for wind, solar and batteries.  Milton Friedman said, “One of the great mistakes is to judge policies and programs by their intentions rather than their results.” I’d add, “What happens in the field should be more convincing what you calculated on paper”

I have long advocated for a demonstration project and was encouraged that Schussler agrees:

The case for an energy transition based on wind, solar and batteries is grossly incomplete and stands against evidence and reason.  The green narratives sub-propositions in isolation contain some truths, but they are extended in misleading ways.   A collection of 200, 800, or ten million studies showing that isolated challenges around renewable resources can be addressed cannot make a case for reliable, affordable deliverable energy.  When the resources are ready, proponents can make a case by operating a small system without connection to conventional generation that experiences  varied load conditions and real-world challenges.  When a case for large scale penetration of wind, solar, and batteries has been made with adequate considerations of costs, reliability and deliverability, it can then be reviewed and challenged with detail.

I want to emphasize an important point about Schussler’s work.  It is from an expert whose career was dedicated to electric resource planning.  The following paragraph is advice that New York politicians that think they know best for energy policy should take to heart:

Planning must balance economics, reliability and environmental responsibility using  real workable technology which conforms with the physics of the grid and meets the needs of society (#15,#16, #25, #23 & #32).  Electric supply and the grid are too important to base policies upon poor narratives and incomplete understandings. Hope for future improvements must be based on realistic expectations.  Going a short way down the “green” path is easy.  Adding a bit more “renewables: isn’t that expensive and the gird is plenty robust for incremental hits.  For most involved, it’s easier to go with that flow than to stand up for long-term concerns.  But we are getting closer to the cliff as costs continue to increase and reliability problems become more prevalent. 

Conclusion

I think it is frightening that someone whose expertise I admire is worried about the scope of the problem and the possible ramifications.  Schussler concludes:

Policy makers need to consider a fuller and more complete array of truths around renewables and the grid. Rigorous considerations of many complex and interlinking issues between generation and transmission are needed to build and support modern grids. No-one, even those with a lifetime in the business, fully understands everything involved. Experience and incremental changes have served the development and operation of the grid well.  Many outside “experts”,  have next to no real knowledge of the complexities involved and propose dramatic changes. Without serious and time-consuming efforts from policy makers, real grid experts can’t compete with proposals that are basically founded upon tee-shirt slogans.  Spending money, altering systems, and hoping for the best based on the green narrative alone is a recipe for disaster. 

Net Zero Cure is Worse Than the Disease

David Turver supports my belief that New York’s Climate Leadership & Community Protection Act (Climate Act) is not in the best interests of New Yorkers.  The basis of his arguments is the unfolding disaster in Great Britain.  His post includes a video of a talk on the topic, copy of the slides, and the argument summary described below.

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

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  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.” 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. 

Net Zero Cure is Worse Than the Disease

Turver introduces his arguments by noting that climate change impacts are exaggerated:

Although people like Antonio Guterres have made the foolish claim we have entered the era of global boiling, we have to acknowledge that the world has warmed a bit since pre-industrial times. The alarmist response to this is Net Zero which is an example of a so-called mitigation strategy that calls for everyone to reduce their emissions of carbon dioxide to save the planet.

Earlier this year I quoted Richard Lindzen’s description of the made-up rationale: “In this complex multifactor system, what is the likelihood of the climate (which, itself, consists in many variables and not just globally averaged temperature anomaly) is controlled by this 2% perturbation in a single variable? Believing this is pretty close to believing in magic.” 

The following paragraph eviscerates the entire rationale of the Climate Act.  Turver explains that the mitigation can never work:

The trouble with this approach is that it can only work if two conditions are met. First, mitigation can only work if CO2 is the only climate control knob. But we know this to be wrong, because the IPCC’s first report showed marked temperature fluctuations over thousand-, ten thousand- and million-year timescales when CO2 levels in the atmosphere were pretty constant. Second, mitigation can only work if everyone else follows the same strategy. But we know that global emissions of greenhouse gases are rising sharply even though ours have fallen into insignificance. Global consumption of coal, oil and gas are at record levels. Neither condition is met, so the UK’s Net Zero mitigation strategy can never work.

Turver is as frustrated as I am about the impact of net zero policies like the Climate Act:

Nevertheless, this has not stopped politicians and policymakers rushing headlong into Net Zero policies that have resulted in the UK having the most expensive industrial electricity costs in the IEA, some 4X those of the US and 2.6X Korean prices. This is leading to energy austerity with UK primary energy consumption down 23% since 1990 while global energy consumption is up 72% over the same period. Our National Energy System Operator, NESO wants to double down on energy austerity and halve our energy consumption per capita from 2023 levels by 2050.

High energy prices coupled with energy austerity have led to economic stagnation. There is a strong correlation between reduced energy use and slow growth, with the EU27 and US growing faster than the UK because they have had smaller cuts to energy use. Korea, India China and the rest of the world are using much more energy and their economies are powering ahead.

I do not see any scenario where these impacts will not occur in New York.

The rationale for the Climate Act is that we have a problem, that it can be solved by reducing greenhouse gas emissions, and that there is an easy way to reduce emissions.  Turver describes the myths created to promote renewables:

Despite the obvious economic and social costs of Net Zero, a series of myths have been created to support the renewables agenda. They claim renewables are cheap, but we pay £11bn/yr in renewables subsidies, £2.5bn for grid balancing and a further £1bn for the capacity market. National Grid have announced £112bn in spending on grid expansion by 2035 which will also find its way on to our bills. Moreover, the cost of renewables is rising and projects like Norfolk Boreas and Hornsea Project Four have been cancelled because the developers cannot make money at the prices they agreed. Ed Miliband wants to spend £260-290bn by 2030 on his Clean Power plan to save only around £7bn/yr of the money we spend on gas-fired generation.

Turver explains that the ideologues pursuing these policies think that it will improve the economy:

The second myth is that Net Zero will create jobs and growth. But the truth is expensive energy costs are destroying high-productivity industries like chemicals, petrochemicals, ceramics and steel that are growing more slowly than the rest of the economy or outright shrinking. Instead we are growing less energy intensive low-productivity sectors that are damaging productivity and growth for the whole economy. Green energy jobs are destroying real jobs and cost around £250K/yr per job.

Turver describes another myth that has been used in New York:

The third myth is that renewables increase energy security. But intermittent sources like wind and solar can never deliver security because we cannot control the weather. As a result we came close to blackouts last month as NESO suffered a margin call. We cannot rely upon interconnectors either, because the Norwegian Government fell because of the impact interconnectors are having on their electricity prices.

The Climate Act mandates that all environmental impacts of fossil fuels be considered but pointedly ignores any consideration of wind and solar development impacts.  Turver notes that this is a common flaw:

Finally, it is claimed that wind and solar renewables are green and kind to the environment. But both have very high mineral intensity, meaning massive mines will be scarring the landscape to produce the copper, silver, cobalt and rare earth metals required. They also take up a lot of land, land that would be better utilised to grow food.

The Climate Act does include a requirement to consider adaptation.  Turver explains that adaptation is a superior strategy:

By contrast, adaptation is a far superior strategy. Deaths from natural disasters and weather events have fallen more than 10-fold over the past century as we have used cheap, abundant energy to tame nature. Global life expectancy has doubled since 1850 and cereal yields are up three times since 1961. These remarkable achievements have come despite, some might argue because of, the rise in temperatures and global CO2 levels.

In my opinion, New York short changes this strategy because at its root the Climate Act is a political tool.  Politicians passed the law to cater to specific constituencies but the opportunities to make money via adaptation are small. Given that there are no organized rallies organized by politically connected constituencies at the Capitol lobbying for adaptation policies this strategy is not a priority.

Turver concludes that nuclear power is the answer:

Turning now to the answer. For humanity to thrive, we need cheap, abundant and reliable energy. This will give us the surplus energy that we need to continue to adapt by building flood defences, improving irrigation developing new crop varieties and so on. Adaptation has the big advantage is that it works regardless of the cause of global warming or climate change. The only technology that is proven to work at scale is nuclear power. This will take time, so we need gas as a transition technology. Nuclear power has the added advantage of being energy dense, reliable and requires very little mining so has the smallest overall environmental footprint. We need nuclear power everywhere all at once.

I agree that developing nuclear power is a better choice.  His pragmatic approach to use natural gas as a bridge fuel used to be the accepted path forward.  The vilification of natural gas is based almost entirely upon emotion and precludes a strategy that has proven success.

Conclusion

Philosopher George Santayana, originally stated, “Those who cannot remember the past are condemned to repeat it”.  In this instance New York is ignoring what is currently happening with respect to the net-zero transition in Great Britain.  The consequences will be the same.  Turver concludes:

Net Zero is ineffective in achieving its primary goal and can never stop the weather changing. The impact of Net Zero policies is devastating for the economy and high productivity, energy intensive industries in particular. Renewables are not kind to the environment and the lies being told to promote them are untenable. The Net Zero cure is worse than the climate change disease.

Governor Hochul and Climate Act Affordability Part 2

I have argued that Climate Leadership & Community Protection Act (Climate Act) affordability would become a political issue.  I also argued that when Governor Hochul assigns Climate Act responsibilities to the New York Power Authority (NYPA)and then says “Too many New Yorkers are already falling behind on their energy bills and I will do everything in my power to reign in these astronomical costs” when NYPA proposed raising rates to cover those costs it is hypocritical.  This post looks at utility rate impacts.  Those costs are already increasing dramatically.

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

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes two 2030 targets: an interim emissions reduction target of a 40% GHG reduction by 2030 and a mandate that 70% of the electricity must come from renewable energy 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. 

Personal Experience

This post was prompted by an email from a friend who sent along screen shots of his most recent and last year’s electric supply bills from New York State Electric & Gas (NYSE&G).

NYSE&G current bill screen shot:

NYSE&G electric bill from a year ago:

I looked up my electric bills.  Here are screenshots of current Niagara Mohawk Power Corporation, dba– National Grid electric rates

Here is a screenshot of the same information from a year ago:

I compared the cost increases in Table 1.  NYSE&G electric supply rates have increased sharply.  National Grid went up but not nearly as much. 

Table 1: New York Electric Supply Rate Increases Examples

New York State Electric Utility Rate Cases

The differences between the two utility rates in Table 1 is striking.  Particularly because the service territories overlap so much (Figure 1).

Figure 1: NYS Electric Utility Service Territories

I suspected that the differences at this time are due to the status of New York State electric utility rate cases.  NYSE&G has recently settled their rate case whereas National Grid is in a pending case.  National Grid rates will go up as soon as a new rate case is settled and the only question is how much.  I checked the Public Service Commission (PSC) Pending and Recent Electric Rate Cases web pages and found the following information.

Niagara Mohawk Power Corporation dba National Grid:

NMPC is requesting an increase in annual electric revenues of approximately $525 million (20 percent increase in delivery revenues or 11 percent in total revenues) for the rate year ending March 31, 2026. NMPC estimates that the requested increase in delivery revenues will result in a monthly bill increase of $18.92 (23.4 percent increase in delivery bill or 15.3 percent increase in total bill) for a typical residential customer using 625 kilowatt-hours (kWh).

For the record here is information on other rate cases listed at the PSC website.

Central Hudson:

Central Hudson Gas and Electric Corporation is requesting an increase in annual electric delivery revenues of approximately $47.2 million (8.8 percent increase in base delivery revenues, or 4.6 percent increase in total system revenues), compared to the revenues approved by the Commission for the Company’s current Rate Year. The requested increase in electric delivery revenues results in a monthly bill increase of $9.19 (8.6 percent increase on the delivery bill, or 5.3 percent increase on the total bill) for an average residential customer using 630 kilowatt-hour per month.

Consolidated Edison:

Con Edison is requesting an increase in annual electric delivery revenues of approximately $1,612 million (an 18.0 percent increase in base delivery revenues, or an 11.4 percent increase in total revenues). The requested increase in delivery revenues results in an average residential monthly delivery bill increase of $26.60 (a 19.1 percent increase on the delivery bill, or a 13.4 percent increase on the total bill) for a 600 kilowatt-hour/month customer. 

The primary drivers of the requested electric increase are local property taxes (which account for an overall electric bill increase of 3.1 percent), new infrastructure investment (2.6 percent) and operating expenses (2.6 percent). Con Edison purports that its filing will help accommodate demand growth, especially with clean energy options and substation investments, while maintaining reliability with investments in feeder replacements. The Company is also enhancing its system resiliency for more frequent and severe storms, as well as warmer temperatures.

In addition, the Company’s filing purportedly includes a focus on improving customer outreach and accessibility, enhancing customer support and the customer experience, and promoting energy efficient programs. The Company plans to expand outreach efforts to enroll eligible customers in the Energy Affordability Program.

I also did a Perplexity AI search asking the question: What is the status of New York State electric utility rate cases.  The results noted that “as of February 17, 2025, there are no pending or recent electric rate cases for New York State Electric & Gas (NYSEG). However, there are some notable developments in the New York electric utility landscape”.  The response stated:

Con Edison’s proposed rate hike: Governor Hochul has directed the state agency to reject Con Edison’s proposed rate increase, which would have raised electricity rates by 11.4% in 2026.

Orange & Rockland Utilities: There is a pending case (Case 24-E-0060) for Orange and Rockland Utilities, Inc. The company is requesting a 7.3% increase in electric delivery revenues for the rate year ending December 31, 2025.

National Grid: The company filed a request in May 2024 for new electric and gas rates in upstate New York, proposing to reset prices beginning in Spring 2025.

Previous rate increases: Con Edison has already implemented rate increases of 9% in 2023, 4% in 2024, and 1.4% in January 2025.

Discussion

The Perplexity AI response also noted that “It’s worth noting that Governor Hochul has also directed the Department of Public Service to conduct a statewide audit of utility company salaries and compensation, which may impact future rate cases.”   The referenced article notes that Governor Hochul “pushed back against proposed rate hikes from Con Edison, directing the state’s Department of Public Service to reject the company’s request for approval.”  I believe that there should be a line on bills that documents the Climate Act costs.  That transparency could be politically damaging so that will never happen.

I am also concerned about the Public Service Commission.  Given that all the Commissioners are partisan political appointees when she directs them to reject the rate case, that is what will happen.  Furthermore, most of the board has ties to green energy.  This will certainly lead to biased outcomes that I think will not be in the best interests of New York.

I asked Perplexity AI another question – Are the commissioners of the New York Public Service Commission partisan appointees of the governor. It responded that was true.  The response was based primarily upon New York Public Service Law Section 4 and stated that:

The governor appoints the commissioners with the advice and consent of the New York State Senate.

However, there are restrictions on partisan composition:

  • The commission consists of up to seven members.
  • No more than three commissioners may be members of the same political party if there are five commissioners.
  • If the number of commissioners is increased to seven, no more than four may be from the same political party.

These rules ensure some level of bipartisan representation on the commission, despite the commissioners being appointed by the governor. The commissioners serve six-year terms on a full-time basis.

However, the current composition is anything but bipartisan.  Technically there are only three Democrats and one Republican but four members have direct experience with green energy non-governmental organizations.  The Public Service Commission website for the Commissioners lists the backgrounds of the seven members. 

  • Rory M. Christian, Chair of the Commission – Chairs of New York agencies are chosen for political allegiance to the party of the Governor so I count him as a Democrat.  He also was the Director of New York Clean Energy at Environmental Defense Fund.
  • James S. Alesi – Held an office as a Republican.
  • David J. Valesky – Held an office as a Democrat.
  • John B. Maggiore – Worked in Democrat administrations.             
  • Uchenna S. Bright – Has not held political office but worked with environmental non-governmental organizations include the Natural Resources Defense Council (NRDC).
  • Denise M. Sheehan has not held political office but has “30 years of experience in government and non-profit sectors” and currently serves as Senior Advisor to the New York Battery and Energy Storage Technology Consortium (NY-BEST).
  • Radina R. Valova has not held political office.  Served as Vice President of the Regulatory Program at the Interstate Renewable Energy Council (IREC), a national non-profit organization that builds the foundation for clean energy and energy efficiency.  Prior to joining IREC, Ms. Valova served as Senior Staff Attorney and Regulatory Affairs Manager for the Pace Energy and Climate Center in White Plains.

I make that one Republican, three Democrats, and three that could conceivably be called non-partisan but certainly could also be called environmentalists.  As a result, I think the makeup of these Commissioners will acquiesce to anything the Governor wants.  At the top of that list is the Climate Act green energy narrative that transitioning away from fossil fuels to “free” solar and wind will lower prices.  If that does not happen it must be because of the greedy utility companies.

There is only one problem with that approach – reality.  In the real world, providing reliable wind and solar energy is expensive.  The utility companies will be on the hook to provide the distribution and transmission system upgrades necessary to get the diffuse solar and wind power from where it is generated to where it is needed.  The utility companies have also been told to develop infrastructure for electric vehicle charging. If Hochul’s grandstanding disapproval of rate cases continues, then how are those necessary components of the net-zero transition going to get built?

Conclusion

Hochul was quoted as saying “Too many New Yorkers are already falling behind on their energy bills and I will do everything in my power to reign in these astronomical costs.”  I can’t believe that the Hochul Administration does not understand that the transition will cost enormous amounts of money and is a major reason for those “astronomical” costs.    In my opinion, the political solution is to stop the transition and blame someone else.  I expect that the Trump Administration’s slow down of offshore wind, cancellation of electric vehicle mandates, and the cut back on components of the Inflation Reduction Act will provide the political cover for Hochul to say we tried but evil Trump makes it impossible.   Stay tuned to the political theater as this unfolds.

Governor Hochul and Climate Act Affordability

I have argued that Climate Leadership & Community Protection Act (Climate Act) affordability would become a political issue soon.  My previous article concluded that there is no way to simultaneously achieve the Climate Act emission reduction goals and maintain affordability such that it will not be a campaign issue for Governor Hochul 2026 re-election campaign.  This article follows that up with the ramifications of this news “The New York Power Authority (NYPA) backed down from a significant rate increase proposed for hydropower after facing bipartisan backlash, but it was an order from Gov. Kathy Hochul herself that ultimately doomed the plan.”

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

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes two 2030 targets: an interim emissions reduction target of a 40% GHG reduction by 2030 and a mandate that 70% of the electricity must come from renewable energy 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. 

NYPA Rate Hike 

According to the Governor’s press release:

Governor Kathy Hochul today announced that she is demanding the New York Power Authority suspend its proposed electric rate hike, protecting consumers from sky-high utility costs that are making New York State less affordable.

“Today, I’m calling for an end to the Power Authority’s unacceptable proposal to raise electric rates on its customers statewide,” Governor Hochul said. “Too many New Yorkers are already falling behind on their energy bills and I will do everything in my power to reign in these astronomical costs. While I recognize the Power Authority’s critical importance in providing invaluable, clean, baseload power from its large hydroelectric power plants Upstate, I expect NYPA to go back to the drawing board, shelve this existing proposal, and figure out a better way forward.”

Spectrum News provided background on the news:

The New York Power Authority backed down from a significant rate increase proposed for hydropower after facing bipartisan backlash, but it was an order from Gov. Kathy Hochul herself that ultimately doomed the plan.

The increase, which was in the midst of a lengthy implementation process, would have sent hydropower rates from $12.88/MWh to $33.05 over the next four years before settling back to a rate of $24.26 by 2029.

Republican lawmakers in Western New York pushed back on the proposal.

Sen. George Borrello told Spectrum News 1 he is thankful that NYPA called the rate hike off.

“As a business owner in New York state, this is one of he few things that is actually a positive when doing business in New York, the ability to get low cost power,” Borrello said.

Spectrum News noted that:

“At Governor Hochul’s request, NYPA will move to withdraw the 2025 proposed rate increase. We understand that New Yorkers are struggling right now, and we intend to make every effort to collaborate with our customers and stakeholders to find a way forward,” NYPA told Spectrum News 1 in a statement

NYPA had said the increases were necessary to keep pace with maintenance and operational costs.

I question the claim that the costs were primarily related to maintenance and operational costs.  I am not alone.  Spectrum News said that:

Borrello and others have blamed both instances on the state’s drive toward clean energy to meet its climate goals.

“It’s all directly related to the [Climate Leadership and Community Protection Act] then you add to it the reliability, the fact that we’ve shut down reliable forms of energy like Indian Point which supplies 20% of New York City’s power,” Borrello said.

Not surprisingly Hochul has pushed back on that premise.  When discussing the large proposed Con Ed hike, she said: “It is a factor, but to increase rates to this percentage is not supported by that.”

New NYPA Climate Act Responsibilities

In the magical world of political cost accounting, adding responsibilities to state agencies is free. In the last year Governor Hochul has placed significant mandates on NYPA related to the Climate Act.   According to the NYPA Strategic Renewables Plan dated January 28, 2025:

The 2023-24 State Budget authorized the most significant expansion of NYPA’s authority under the Power Authority Act in a generation. This expanded authority builds on the day-to-day work of NYPA staff to supply the state with reliable electricity, expand New York’s transmission system, and provide clean, affordable power and innovative energy services to our customers.

The enactment included four new areas of responsibility for NYPA, one of which expanded our authority to develop, own, and operate renewable energy generation projects to help meet the state’s clean energy goals. The expanded authority directed NYPA– beginning in 2025 and biennially thereafter– to develop and publish a renewable energy generation strategic plan that identifies our renewable energy generating priorities for the next two years. In addition, NYPA is directed to update the plan annually and may update the plan more often than annually if needed.

Beyond directing NYPA to build renewables, the budget enactment contained several other mandates:

  • NYPA will work with the New York State Public Service Commission (PSC) to establish the REACH program to provide renewable energy bill credits to low- or moderate-income New Yorkers in disadvantaged communities;
  • NYPA will invest up to $25 million annually in workforce training in collaboration with the New York State Department of Labor (DOL);
  • NYPA will cease fossil fuel generation at its small natural gas power plants by the end of 2030, so long as electric system reliability and environmental conditions allow.

In addition, NYPA will lead the Decarbonization Leadership Program, which calls for the development of energy and emissions profiles for state government’s largest carbon-emitting facilities and decarbonization action plans that will guide state agencies on facility improvements that will reduce carbon emissions.

If I was a betting man, I would wager that the costs of these efforts are a significant chunk of the revenues raised by increasing hydropower rates from $12.88/MWh to $33.05 over the next four years before settling back to a rate of $24.26 by 2029. 

Time for a Cost Reckoning

It is time for the Hochul Administration to acknowledge the total costs of all the programs associated with Climate Act implementation.  The Climate Act requires that the Public Service Commission (PSC) issue a biennial review for notice and comment that considers “(a) progress in meeting the overall targets for deployment of renewable energy systems and zero emission sources, including factors that will or are likely to frustrate progress toward the targets; (b) distribution of systems by size and load zone; and (c) annual funding commitments and expenditures.”  The draft Clean Energy Standard Biennial Review Report released on July 1, 2024 will fulfill this requirement.  The final report was due at the end of 2024 but was delayed on December 17, 2024.

On December 18, 2024, the New York Assembly Committee on Energy held a public hearing where the status of the Biennial Report was discussed.  At 28:01 of the video, Jessica Waldorf, Chief of Staff & Director of Policy Implementation, New York State Department of Public Service (DPS) explained the decision to delay:

The decision to pull the report yesterday was really based on the fact that we did a major review of the main program that would have otherwise been included in that report – the Clean Energy Standard that governs all the renewable energy programs.  That report is currently under consideration by the Commission.  Rather than do things piece meal we’re going to release the next version of the CLCPA annual report once the commission has acted on that CES biennial review.  We will include one comprehensive review report that will look back two years and also respond to other stakeholder feedback that we’ve received in response to the issuance of the first report.

My interpretation of this statement is that there is no commitment when the costs report is coming out.  If they could get away with delaying the report, they would wait until after the 2026 election.  More troubling was her comment about NYSERDA spending increases:

It also can’t be attributed to just the Climate Act.  Many of the initiatives go back several years all the way to 1996 when we started authorizing funds for things like energy efficiency investments and so a lot of programs and initiatives preceded the Climate Act. 

My concern is that this suggests that the DPS is going to hide the total costs of all the programs needed to achieve Climate Act mandates when the biennial report cost estimates are released.  The emphasis on the Clean Energy Standard when describing the review suggests that they will try to list only the costs of that component of New York’s energy plan net-zero transition. If the costs of programs and initiatives like the Clean Energy Standard, that preceded the Climate Act are not included, then Hochul can claim lower costs but New Yorkers are still on the hook for all the costs.   I recently described this as mal-information because while the costs listed are based on reality it is misleading and harms New Yorkers because it improperly excludes necessary costs to achieve all the goals of the energy transition.  New Yorkers deserve to know all the costs associated with Climate Act implementation.

Discussion

The costs of green energy policies has become an issue elsewhere as well.  Gordon Tomb of the Commonwealth Foundation recently explained that

Last October, electric grid operator PJM Interconnection received a joint letter from five Democrat governors—Pennsylvania’s Josh Shapiro, Illinois’ JB Pritzker, New Jersey’s Phil Murphy, Maryland’s Wes Moore, and Delaware’s John Carney. According to them, PJM, which supplies electricity to 13 states and the District of Columbia, has gouged customers with its annual capacity auctions

Just like Hochul rather than take accountability for destructive policies that produced the higher costs these Democrat governors are playing the blame game.  Tomb concludes:

It is time for policymakers to face the economic and physical realities of energy production. Their misguided efforts to reduce carbon emissions—from cap-and-trade schemes to government mandates favoring solar and wind—have proved costly to consumers and damaging to the reliability of power systems.

This perfectly exemplifies Progressive New York Democrats led by the Governor Hochul.  Their Climate Act fantasies are going to cost enormous amounts of money and risks to reliability have been largely ignored by them.  So far, the Hochul Administration has not fulfilled the mandate to document the “annual funding commitments and expenditures” and I suspect that they when they finally provide numbers they will continue the mal-information coverup used to minimize Scoping Plan costs y excluding costs not associated with the Climate Act itself.

There is another missing piece in the cost assessments.  The cost projections in the Scoping Plan are approaching several years old now.  It is time that those numbers were updated.  To do it right, clear documentation for all the energy use and emission reduction strategies proposed that includes assumptions, expected costs, and projected emission reductions is necessary.

Conclusion

Hochul was quoted as saying “Too many New Yorkers are already falling behind on their energy bills and I will do everything in my power to reign in these astronomical costs.”  It is inconceivable that her Administration does not understand that these new NYPA responsibilities will cost a lot of money.  That makes her actions hypocritical.  She was indignant that the companies and NYPA would hike rates when people are struggling but conveniently overlooks all the costs for renewables and other Climate Act mandates that are buried in the rate cases. It is time for transparency.  There should be a line on consumer bills that documents Climate Act costs.

New York Cap and Invest Status

New York’s Climate Leadership & Community Protection Act (Climate Act) is stalled.  This article updates the current status of NYCI implementation based on a analysis of a comprehensive overview by Samanth Maldonado titled “Green Lawmakers Pressure Hochul to Speed up Action on Climate Act”.

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

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050.  It includes two 2030 targets: an interim emissions reduction target of a 40% GHG reduction by 2030 and a mandate that 70% of the electricity must come from renewable energy 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 New York Cap-and-Invest Program (NYCI) is a key component of Climate Act implementation.  Before the 2025 State of the State was released, I believed that Governor Hochul would announce the next steps associated with the implementation of NYCI. However, the only mention of NYCI in the speech and in the FY2026 NYS Executive Budget Book noted that in the coming months the Department of Environmental Conservation (DEC) and the New York State Energy Research and Development Authority (NYSERDA) will take steps forward on developing the cap-and-invest program by proposing new reporting regulations to gather information on emissions sources.  Not surprisingly, Climate Act proponents were outraged. 

Samanth Maldonado’s article Green Lawmakers Pressure Hochul to Speed up Action on Climate Act is a useful summary of the status of NYCI.  I also realized while reading it that some arguments by people she interviewed deserved a response.

Status

Clearly Governor Hochul is having second thoughts about the Climate Act relative to her re-election ambitions in 2026.  Maldonado summarized the political considerations:

But Hochul has had other priorities and expressed a willingness to “rethink” where climate fits into her agenda. Her current main theme is “Making New York State More Affordable,” and the governor has been sensitive to anything that might hit New Yorkers’ wallets. That includes measures that would advance aspects of the climate law — but could also raise household costs.

“It was a different time,” Hochul said in July, noting that the climate law passed under her predecessor, Andrew Cuomo, adding “I can’t be caught in the past of 2019 into 2024 and 2025 and make decisions based on that, because a lot has changed.” 

She called the climate goals “something I would love to meet but also the costs have gone up so much, I now have to step back and say, “What is the cost on the typical New York family?’ just like I did with congestion pricing.”

Maldonado is clearly a believer in the rationale for the Climate, but she acknowledges that things have changed since it was passed:

That law, enacted in 2019, requires the state to drive down planet-warming emissions and shift away from fossil fuels, touching on nearly every sector of the economy and costing a projected $300 billion.  Nearly six years later, the goals at the heart of the CLCPA remain aligned with what climate scientists agree is urgent and necessary to mitigate and adapt to the impacts of a warming globe, but the political and economic environment have changed. Notably, federal funds supporting New York’s progress may disappear thanks to Trump’s federal funding freeze. 

For the record, the $300 billion dollar figure is Hochul mal-information because that figure only includes an unspecified fraction of the total costs and the projection cost methodologies consistently biased the expected costs low.  As to her deference given to Climate Scientists™ Dr. Matthew Wielicki explains that many ignore long-standing scientific norms to push alarmist narratives.

The implementation problems highlighted by Maldonado can be traced back to the fact that there is no plan that includes a feasibility assessment.  She notes that “an advisory group led by state officials came up with a blueprint to achieve the CLCPA, it did not create a spending plan, nor did it prescribe which actions to take first”.  This is because the CAC Advisory Group was made up of individuals chosen by ideology not technical expertise and limited discussion on issues outside of the narrative.  The Hochul Administration has yet to acknowledge that there is a reliability crisis brewing.  The lack of a plan is evident to others too.    

Andrew Rein, president of the Citizens Budget Commission, said that lack of planning and prioritization means it’s hard to know what the most cost-effective emissions reduction strategies or resiliency investments might be.

“We’ve got to pick and choose what we’re going to spend,” Rein said, referring to the state. “People are advocating for positions and keep debating, which makes it hard to be flexible with circumstances and facts as they change. That’s where I think New Yorkers have to come together and say, ‘We have to balance affordability, the economy and environmental needs. What can we do together?’”

I believe that it is time to pause the implementation process be paused until the issues raised bb Rein are addressed, certain technical issues considered, and proposed emission reduction strategies are defined.

Political Climate

In my opinion, the Climate Act has always been more about catering to political constituencies than reducing greenhouse gas emissions.  The failure to launch NYCI is undoubtedly due to political policy discussions. Maldonado points out:

Hochul’s recent announcement indicated the first cap-and-invest rules, related to emissions reporting, would come out by the end of this year. That means the cap-and-invest program wouldn’t likely take effect until late 2026 or sometime in 2027 — after the next election for governor. 

She also notes that:

New York is falling behind on two key requirements of the Climate Act: sourcing 70% of its electricity from renewables like solar and wind by 2030, and reducing planet-warming greenhouse gas emissions 40% below 1990 levels by 2030 (and 85% by 2050). New York is about three years behind the first target and has so far reduced emissions about 9% below 1990 levels, according to the latest data available.

The clean energy advocates also believe that NYCI’s delay is driven by politics:

Hochul’s slow-walking the cap-and-invest program is “110%” tied to her concerns around her reelection prospects, said John Raskin, president of the Spring Street Climate Fund and a political strategist.  “It’s reasonable she wants to take care of people’s immediate needs, but she’s not doing herself any political favors by rejecting or stepping away from climate action,” Raskin said. “If she wants to improve her poll numbers and for people to see her as a leader, she should move forward on climate action while communicating how it helps to meet people’s needs.”

Of course, there are very few people in the state that have a bigger stake in the Climate Act proceeding quickly than Raskin.  The Spring Street Climate Fund “supports high-impact policy campaigns that can make New York a model state for climate progress. We identify opportunities to win scalable climate solutions and invest in the grassroots climate campaigns that can succeed.”  There is nothing in their business model that addresses affordability, reliability, or environmental impacts that affect New Yorkers.

Raskin is not the only one with a vested interest.  Michael Gerrard is the founder and director of the Sabin Center for Climate Change Law at Columbia University.  The Sabin Center would not exist if there were not a problem.  Maldonado quotes a thinly veiled threat from him:

“I think Gov. Hochul was exceeding her authority much as she did when pausing congestion pricing, and DEC has a legal obligation to issue the regulations,” Gerrard said. “Cap and invest would generate revenues that could be used to build more renewable energy and more energy efficiency — things that the federal government is pulling back on.”

Gerrard spearheaded a lawsuit against Hochul’s congestion pricing pause, and now suggests legal action to challenge the cap-and-invest program delay could be on the horizon.

Advocates for NYCI presume that it would be an effective policy that would provide funding and ensure compliance because existing programs worked.  However, I have shown that results from the Regional Greenhouse Gas Initiative show that cap-and-invest programs can raise money but have not shown success in reducing emissions.  My biggest concern is that the draft NYCI documents have not acknowledged these results.  Past results are no guarantee of future success, especially when past results did not produce the results that advocates claim.

The disconnect between reality and New York Progressive politician’s understanding of the energy system and the effects of climate change is even worse.  Moldonado quotes Sen. Pete Harckham (D-Hudson Valley), chair of the Senate Committee on Environmental Conservation:

Harckham countered criticism of the Climate Act by pointing out that climate change impacts have only worsened since the law was enacted. Some investments could save money down the road, he added, a point NYSERDA staff made during public hearings about the CLCPA in years past.

“We need to be redoubling our efforts,” he told THE CITY. “Clean energy is cheaper than fossil fuel energy. I reject the equivalency that this is more expensive. In the long run, this is going to be much less expensive.”

The price on carbon through a cap-and-invest program could increase fuel costs for New Yorkers, including low- and middle-income households, in the short term, but rebates kicking in could result in net savings, according to a state analysis. Two reports issued by environmental groups in January showed how a cap-and-invest program could benefit low-income New Yorkers, depending on its design.

“We are literally showing you research and making a case that we are helping the exact New Yorkers that you say you want to from an affordability angle,” said New York City Environmental Justice Alliance Deputy Director Eunice Ko, who worked on one of the reports. “This is just one tool. We’re not saying it should be the only tool, but we need things like this, absent federal support and federal funding.”

I already explained that the State’s cost numbers are bogus.  The idea that green energy is cheaper than fossil fuel energy is wrong.  The idea that rebates could result in net savings is a favorite talking point but ignores implementation concerns.  People who are having trouble paying for energy now do not have extra money available and will have difficulty waiting for the rebates to get to them.  The claims that NYCI could benefit low-income New Yorkers are a stretch and ignore the fact that some of the money generated by NYCI must be spent to reduce emissions. 

Conclusion

I agree with those who argue that NYCI deployment has been stalled due to political reasons.  I do not agree that is necessarily a bad thing.  While I have no hope that there will be an epiphany within the Hochul Administration that expectations for NYCI must be tempered by reality.  It cannot support funding commitments to dis-advantaged communities, provide enough rebates to make low-income citizens whole, and fund emission reduction programs.  Funding should be guided by the experience gained with the similar RGGI program and the necessity to support emission reductions must be acknowledged.

The reality is that there is no way to simultaneously achieve the Climate Act emission reduction goals and maintain affordability such that it will not be a campaign issue for Hochul.  How she tries to resolve the irreconcilable will be fascinating to watch in the coming months.  Going forward or stalling for time she cannot win.

Wind Blowing Somewhere Does Not Solve the Intermittency Problem

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

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

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

Overview

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

Wind Lulls

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

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

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

EIA data

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

Figure 2: US Energy Information Administration Hourly Electric Grid Monitor

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

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

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

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

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

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

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

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

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

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

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

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

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

Discussion

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

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

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

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

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

Conclusion

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

How the Green Energy Narrative Confuses the Climate Act

Russ Schussler, aka Planning Engineer, has published a prequel to an upcoming article discussing the narrative around the green energy transition that is a prominent component of the Climate Leadership & Community Protection Act (Climate Act).

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

Overview

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

Green Energy Narrative

Schussler describes the narrative of the wind and solar proponents aka green energy:

The green energy narrative works somewhat like a magician’s patter, overemphasizing many things of irrelevance and distracting the audience from the important things going on. Misdirection ensures small truths are misinterpreted and magnified, leading to completely unrealistic hopes and expectations.

For example, there have been many simple studies examining how much energy might be produced by a green resource, or set of green resources, such as wind and solar power. These studies ignore important issues such as deliverability, timing, reliability and costs. Based on simple studies the media, activists and policy makers frequently conclude that such resources can be used near universally on a large scale to provide electric service to consumers effectively, efficiently and economically.

This is precisely what happened in New York when the Climate Act authors developed the targets and mandates of the law.  These ideologues misinformed the Legislature and Governor Hochul with claims that “our State could rapidly move away from fossil fuels and instead be fueled completely by the power of the wind, the sun, and hydro” and “that it could be done completely with technologies available at that time (a decade ago), that it could be cost effective, that it would be hugely beneficial for public health and energy security, and that it would stimulate a large increase in well-paying jobs.”

Schussler explains the problem with this argument:

In the green energy narrative costs have been demonstrated, environmental impacts have been demonstrated, reliability has been demonstrated, deliverability has been demonstrated and all shown to possibly work, BUT NOT AT THE SAME TIME. In the eyes of many, such demonstrations cumulatively strengthen the green energy narrative. However, the gullible audience will be shocked when wind, solar and batteries are not at all well suited to support electric generation on their own.

Schussler highlights three tricks of the green energy narrative: misleading language, false problem and narrative control.

Misleading Language

Schussler addresses the term “renewable” calling it “one of the most misleading bits of language advancing the green agenda.”  He notes:

Different “renewable” resources have vastly differing capabilities. There is vast potential to develop some ‘renewables”. Some “renewables do a great job supporting the grid. Some “renewables” have low energy costs in some areas. Some “renewables” are environmentally sound in some areas. No matter how well individual “renewable” resources might be combined to tick off all the boxes of importance, that doesn’t mean that any combination of “renewable” resources can be found that will work well for any given area. It means little that hydro and geothermal provide excellent support for the grid in an area where you can only add wind and solar. Similarly, just because solar and wind have potential environmental benefits that doesn’t cancel out environmental concerns around hydro in delicate ecosystems.

The problem is that in most areas including New York, “there are no compatible combinations of renewables that at any significantly high penetration level that can provide  affordable, environmentally responsible energy in a reliable manner. Referring broadly to what “renewables” can and might do, serves to hide this inconvenient truth.”

The False Problem – Intermittency is not THE problem for Wind and Solar

Schussler argues that:

It is a fallacy to assume that because part or some of the difficulties associated with a technology can be overcome, that therefore all of the problems associated with a technology can be overcome. Worst case for a “partial solutions fallacy” is when a major problem is hidden by presenting a minor problem as the major stumbling block. Primarily focusing on the minor problem incorrectly implies that there will be smooth sailing once this solvable problem is overcome by hiding the large problem.

To implement a green transition bolstered by heavy wind and solar, all associated problems must be addressed. The major problem associated with wide-scale use of these resources  cannot be ignored.

Schussler goes on to argue:

The real problem is that wind, solar and batteries do not readily provide essential reliability services and support the grid. Most of the talk is around addressing intermittency through batteries and other storage approaches. Misdirection here focuses on intermittency, the smaller problem, while ignoring the major problem.

Schussler believes that it may be possible to address intermittency:

The long-term problems associated with wind and solar due to their intermittency could and may likely be made manageable with improved technology and decreasing costs. But such changes will not make wind, solar and batteries comparable to more conventional generating resources, such that they can play a large role in a green energy transition, because the large problem is not intermittency.

The point of his discussion is that there is another, more serious problem that is a fatal flaw:

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

I think that in an electric system that is reliant on weather dependent wind and solar resource, intermittency creates an unacceptable reliability risk.  Current resource assessments are based on observations of the existing uncorrelated generating resources over many years that show that unplanned outages do not happen at the same time.  There is no reason to expect, for example, that all the nuclear plants will be forced offline at the same time.  This characteristic enables the resource planners to determine how much generating capacity is necessary to meet the probability of losing load not more than once in ten years loss of load expectation (LOLE) reliability criterion.  Importantly, I believe that the lack of correlation also means that the capacity needed above firm system load would not change substantially if the LOLE planning horizon was shifted to 1 day in 20 years or more.

The problem with weather intermittency is that it is correlated over large areas at the same time. As a result, variations in weather affecting wind and solar resource availability will require changes to electric resource planning.  Everyone has heard of a hundred-year flood which is the parameter used for watershed planning.  This is the one in a hundred probability that the water level in a river or lake will exceed a certain level in a given year.  Similar estimates of low wind and solar resource availability must be developed and incorporated into electric resource planning. Based on New York data I think a hundred-year planning horizon is appropriate.  The problem is that the costs for such a threshold are huge and the resources will be used less than their expected operating lifetimes.  The resulting reliability risk is that affordable backup resources will be insufficient to support the load during the hundred-year low wind and solar availability event and a catastrophic blackout will result.

Russ and I discussed my interpretation of this reliability risk, and we agreed that we are making the same point in different ways.  If money is not an issue, then it is possible that the intermittency issue can be overcome by overbuilding wind and solar resources, short-term energy storage, long-term energy storage to deal with extended low wind and solar resource periods, and transmission.  However, affordability is a fatal flaw because the costs necessary would be astronomical for a resource that would only be used less than the expected lifetime of the resources.  On the other hand, the grid support requirements cannot be resolved by throwing any amont of money at the problem so that is unsolvable.

Narrative Control – Shameless Hucksterism and the Media

The last green energy narrative trick is controlling the narrative.  Schussler explains:

The green energy narrative is propelled by stories of success. Often these “successes” are very different from what seemed to be represented. We see great stories of planned projects that should do wonderful things, but they go down the memory hole as they prove not to work out. We see incomplete stories where they talk of power generated but not of associated costs or how much better other alternatives might have been.

He goes on to describe an example headline that claims that seven countries get 99.7% of their electricity from geothermal, hydro, solar, and wind power. However, he points out:

Without the spin, collectively those countries get close to 99% of their energy from rotating synchronous geothermal and hydro resources and less that 2% of their combined electric energy from wind and solar. The fact that some countries have high amounts of hydro, does not provide evidence that we are approaching a tipping point involving wind and solar. In fact, one could observe that high levels of renewable penetration are associated with low levels of wind and solar.

Conclusion

Schussler and I agree that it is becoming increasingly apparent that wind, solar and batteries when pursued at high penetration levels result in high costs, lower reliability and poorer operational outcomes. He points out that “Expectations from the green energy narrative and real-world results are not consistent and this gulf will continue to widen as long as policy makers continue to reflexively buy into the green energy narrative.”

The high expectations in the green energy narrative shaped the promulgation of the Climate Act and is driving its implementation.  Schussler describes the inherent misinformation and other various deceptions to hide the real-world challenges for New York’s net-zero transition. As reality sets in, proponents must push this narrative harder and louder to hide the obvious flaws.  I look forward to Schussler’s follow up article that “will more systemically examine the components of the green energy narrative and raise many items of critical importance considerations that the green energy narrative ignores.”

Ellenbogen and Caiazza Comments on DPS Definitions for Renewable Energy Program

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

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

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

Overview

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

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

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

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

Electric Industry Filings

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

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

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

Criteria for Pausing

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

Dispatchable Emissions-Free Resources (DEFR)

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

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

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

Lithium-Ion Storage Safety Concerns

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

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

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

BESS Timing

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

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

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

Conclusion

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