Climate Act – Page 22 – Pragmatic Environmentalist of New York

Risks of Climate Act Net Zero

I believe the Climate Leadership & Community Protection Act (Climate Act) transition will negatively affect affordability, reliability, and the environment. I have been meaning to summarize my concerns for quite a while and two recent articles prompted me to write this. David Turver explains how the transition to Net Zero has negatively affected affordability in the United Kingdom. Robert Bryce provides an example of how the Climate Act mandates for offshore wind development will negatively affect the endangered North American Right Whale. Finally, I describe why I worry that the reliance on wind and solar generating resources markedly increases reliability risks.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 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 company I have been associated with, these comments are mine alone.

Introduction

David Turver’s Risks of Net Zero article prompted me to write this post. He is the author of the Eigen Values Substack. He is a retired consultant, CIO and project management professional. His description says that he is a first principles thinker who is tired of superficial media simply republishing press releases without critical analysis. His Substack incudes articles about contentious issues such as climate, energy, and net zero.

The Introduction to Risks of Net Zero provides an overview of the general concern about the risk. He states:

We hear a lot about how we are supposedly in a climate crisis and how The Science™ tells us we are about to succumb to global boiling. Most climate activists claim that we must cut emissions by spending more money on windmills and solar panels or we will all burn to a crisp.

I would describe myself as a lukewarmer, by which I mean that I acknowledge the earth is warming and that human emissions of CO₂ have made some contribution to that warming. However, it is also true that the climate has changed dramatically without human intervention; clearly, there are other causes of climate change too.

The strategy of reducing emissions of greenhouse gases to Net Zero is classified as a “mitigation strategy” in the parlance of the IPCC. The alternative strategy is adaptation which means taking measures to adjust to climate change such as building flood defences, irrigation systems or developing new strains of crops to cope better with changing weather patterns. Most spending effort in the West is geared towards mitigation. But, what if the Net Zero cure is worse than the disease? What if mitigation is less effective than adaptation?

Before he addresses affordability Turver compares mitigation against adapatation. He and I agree that adaptation is likely to be more effective than mitigation. He explains why in the following.

Mitigation Drawbacks

Turver points out issues related to mitigating climate change by reducing emissions. Mitigation only works if CO₂ is the only climate control knob but that cannot be the case because we have observed temperature changes over the last thousand years. Mitigation can only work if everyone else slashes emissions too and we can see from Figure 2 (from Our World in Data) that this is not happening.

Adaptation Successes

Turver explains that adaptation since 1900 has dramatically decreased death rates. He includes a figure sourced from Our World in Data.

Not mentioned but certainly a factor is that the death rate went down in no small part because fossil fuels increased the ability of society to address the causes listed. Based on past success the obvious alternative is to emphasize adaptation. Turver explains:

Adaptation measures have many benefits. First, they require no international treaty, and they can be applied locally where they produce results quickly. They also work to protect against changes in the climate that are not driven by CO₂. Adaptation measures might also have additional benefits such as more efficient water use or more robust crop varieties. There is no reason why we cannot continue to adapt.

New York Effect on Climate Change

There is another aspect of mitigation that is routinely ignored by proponents of the Climate Act. New York emissions are tiny relative to global emissions. In 2021, NYS GHG emissions (GWP-100) were 247 million metric tonnes (MMT). GHG emissions from China were 13,774 MMT and from India were 3,879 MMT. The increase in emission from 2020 to 2021 were 498 MMT in China and 265 MMT in India. New York emissions will be supplanted by emissions from China or India in less than one year. New York’s net-zero transition plan emission reductions will have no effect on emissions and thus no effect on the purported effects of climate change. Adaptation investments in New York infrastructure to reduce the costs of extreme weather impacts will focus on New York so the benefits will be to New Yorkers.

Climate Act advocates frequently argue that New York must take action because our economy is large. I analyzed that claim and summarized the data here. New York’s 2020 Gross State Product (GSP) ranks ninth if compared to the Gross Domestic Product (GDP) of countries in the world. However, when New York’s GHG 2016 emissions are compared to emissions from other countries, New York ranks 35^th. More importantly, a country’s emissions divided by its GDP is a measure of GHG emission efficiency. New York ranks third in this category trailing only Switzerland and Sweden. We are already doing our share.

Net Zero Affordability Risks

I think the biggest issue with the Climate Act is affordability. Everyone wants a clean and safe environment but just how clean, how safe and at what price are all value judgements. Turver points out that implementation of net-zero policies like the Climate Act have poorly acknowledged risks:

First and most obvious, they cannot work against climatic changes that are driven by forces other than CO₂. Second is the outright cost.

He goes on to describe observed cost increases in the United Kingdom. He makes the point that additional costs also make manufacturing and other production less competitive, which leads to job losses. Ultimately the inability to produce basic needs reduces security. He also points out that renewable energy development requires more materials than alternatives. That has environmental and cost implications.

Turver explains that the increased penetration of renewables in the United Kingdom has led to a massive increase in electricity bills. This increase comes from “renewables subsidies as well as grid balancing costs and the massive costs of expanding the grid out to remote offshore wind farms”. The article compares recent United Kingdom industrial gas prices and industrial electricity prices:

As can be seen in Figure 5, from 2008 to 2020, industrial electricity prices rose 53.8% while industrial gas prices actually fell slightly over the same time period. Both gas prices and electricity rose in 2021 as gas prices started to spike as demand increased after Covid lockdowns ended and supply could not keep up with demand. However, even though there was a spike in gas prices in 2021, the increase from 2008 is still only 33%, whereas electricity prices have surged 71.4% over the same period. The figures for 2022 are not yet available, but we might expect to see a big surge in both gas and electricity prices due to supply shortages resulting from the war in Ukraine.

There is no doubt that all these impacts will inevitably occur in New York as the Climate Act mandates are implemented. A recurring theme of many of my posts is that the Hochul Administration has never provided clear and comprehensive cost estimates for all the control strategies in the Scoping Plan

American Offshore Wind Energy Scandal

I believe that the environmental impacts of wind and solar development are greater than the impacts of fossil-fueled or nuclear resource development. In my Draft Scoping Plan comments I noted that on September 17, 2020 the Final Supplemental Generic Environmental Impact Statement (SGEIS) for the Climate Leadership and Community Protection Act was released. It covered the “environmental impacts of the offshore wind and distributed solar procurement goals, and the estimate of utility-scale solar capacity required to meet the meet the 70 by 30 goal” based on the resources estimated necessary at that time. Since then, considerably more resources have been projected but the cumulative assessment has not been updated.

Robert Bryce published an article entitled The Offshore Wind Scandal is Even Worse Than You Think that addresses one of the cumulative environmental impacts that the Scoping Plan ignored. Bryce is an author, filmmaker, and public speaker who has been reporting on the energy sector for more than 30 years. His background enables him to provide graphical evidence to support his arguments that I think are well done. In this article he includes 11 charts that “show how America’s biggest NGOs are colluding with foreign corporations that want to industrialize our oceans with thousands of turbines that will hurt whales and ratepayers”.

He writes:

The hard reality is that America’s offshore wind sector is a subsidy-dependent industry that is dominated by foreign companies who are in bed with some of America’s biggest climate NGOs, including the NRDC (gross receipts: $555 million) and Sierra Club (Gross receipts: $184 million). Those NGOs and others, including the National Wildlife Federation (gross receipts: $142 million) and Conservation Law Foundation (gross receipts: $17.5 million), are leading the most shameful environmental betrayal in modern American history. Rather than seek to protect marine mammals and stop the industrialization of our oceans, they are eagerly promoting the installation of hundreds of offshore wind platforms smack in the middle of the known habitat of the critically endangered North Atlantic Right Whale.

I recommend the article for its details. In this summation I am not going to address all the charts in detail. The first four charts support the quotation above. The fifth chart addresses environmental impacts. The offshore wind shills claim that there aren’t impacts on whales, but Federal scientists disagree.

Bryce describes Chart 6:

I’m old enough to remember when environmental groups cared about whales. Alas, that was a long time ago. On Sunday, the Daily Mail published an article about Apostolos Gerasoulis, a Rutgers professor emeritus of computer science who built a software system to analyze the dozens of whale deaths that have occurred on the Eastern Seaboard over the past few years. Gerasoulis set out to determine if the whale deaths were related to the loud blasts of sonar used by offshore wind survey vessels. His conclusion: “Offshore wind kills whales…The numbers never lie. There is a cause. We have shown that the cause for death of the whales is offshore wind. Period.” (H/t fellow Substack writer David Blackmon.)

In Chart 7 Bryce notes that the Massachusetts Sierra Club notes that “Because the North Atlantic Right Whale has such a small population and a low annual reproductive rate, a single whale death can have a significant negative impact on the species’ ability to recover.” In Chart 8 he provides a plain English translation of a statement in the Bureau of Ocean Energy Management environmental impact statement of Vineyard Wind: “These projects won’t make any difference on climate change. But they are good because they allow state-level bureaucrats to say they met their policy goals.”

The remaining charts compare offshore wind capacity and costs relative to other resources. He concludes that these developments will markedly increase costs for states that already have some of the highest electricity rates in the country.

I maintain that the New York State has shirked its commitment to the environment because it has not addressed cumulative environmental impacts of the Scoping Plan buildout of wind and solar. No where is this more impactful than the effects on whales in general and the remaining North American Right Whales in particular. Bryce quotes an opponent of offshore wind: “What is Big Wind going to say when they kill the last whale? ‘Sorry’?”

Reliability Risks

I described my concern about the enormous risk of an electric grid relying on wind and solar resources in this post. Since then, I have refined my description of the problem. It boils down to “correlated intermittency”. Let me explain.

Wind and solar are inherently intermittent – the sun does not shine at night and the wind does not always blow. That intermittency is correlated. All the solar in New York is unavailable at night. It turns out that wind resources across New York also are usually high or low at the same time. There are exceptions but there is a high incidence of similar behavior.

That matters for electric resource planning. Today electric resource planning relies on decades of performance experience with hydro, nuclear, and fossil plants that do not correlate, that is to say there is no reason to expect that all the nuclear plants will be offline at the same time. As shown in the following New York Independent System Operator (NYISO) slide, this characteristic enables the resource planners to determine how much generating capacity is necessary to meet the loss of load expectation (LOLE) criterion. The probability of losing load not more than once in ten years is based on observations of the existing uncorrelated generating resources. 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.

Source: NYISO Amount of Capacity Required, Intermediate ICAP Course, June 2023

The variation in weather that affects 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 waterway planning. This is the one in a hundred probability that the water level in a river or lake will exceed a certain level. Similar estimates of low wind and solar resource availability must be developed and incorporated into electric resource planning.

The unresolved problem is what return period probability is acceptable. If the resource planning process does not provide sufficient backup resources to provide capacity for a peak load period, then blackouts are inevitable. Two factors exacerbate the challenge of this problem:

Periods of highest load are associated with the hottest and coldest times of the year and frequently correspond to the periods of lowest wind resource availability.
The decarbonization strategy is to electrify everything possible so the impacts of a peak load blackout during the coldest and hottest periods will be greater.

In an earlier post I described an analysis by the Independent System Operator of New England (ISO-NE) Operational Impact of Extreme Weather Events. The study evaluated 1, 5, and 21-day extreme cold and hot events using a database covering 1950 to 2021. Not surprisingly the system risk or “the aggregated unavailable supply plus the exceptional demand” during an event increased as the lookback period increased. If the resource adequacy planning for New England only looked at the last ten years, then the system risk would be 8,714 MW, but over the whole period the worst system risk was 9,160 and that represents a resource increase of 5.1%. There is no question that a similar analysis for New York would find a similar result.

The correlated intermittency of wind and solar resources means that we will depend on energy-limited resources that are a function of the weather causing low resource availability at the same time. The unresolved issue is how to design an affordable and practical system to meet the worst-case weather induced lull. Consider the ISO-NE analysis where it was found that the most recent 10-year planning lookback period consistent with current LOLE evaluations would plan for a system risk of 8,714 MW. If the planning horizon covered the period back to 1961, the worst-case to 1950, an additional 446 MW would be required to meet system risk. I cannot imagine a business case for the deployment of electric system resources that will only be needed once in 63 years. For one thing, the life expectancy of these technologies is much less than 63 years. Even over a shorter horizon such as the last ten years, how will a required facility be able to stay solvent when it runs so rarely? The only solution is subsidies to build and very high payments when they do run.

Reliability risks have also been identified by the North American Electric Reliability Corporation. They have expressed concerns that extreme weather events, rapid demand growth, and systemic vulnerabilities pose risks for supply shortfalls and grid reliability. These are serious risks to the Climate Act net-zero transition plan that must be resolved sooner rather than later.

Conclusion

I believe that the Climate Act will do more harm than good. Affordability is the first problem. The Hochul Administration has not provided transparent and comprehensive cost estimates for the control strategies proposed for the net-zero transition. The New York State Comptroller Office audit of costs in Climate Act Goals – Planning, Procurements, and Progress Tracking agrees with my concern and recommends a detailed analysis of cost estimates to transition to renewable energy sources and meet Climate Act goals. I believe such an analysis will agree with observed results elsewhere that show the costs will be extraordinary and will certainly affect affordability.

The Hochul Administration has not provided a cumulative environmental impact assessment for the generating resources projected in the Scoping Plan. Nowhere is the potential impact more critical than with respect to whales and the massive deployment of offshore wind proposed. It is incumbent upon the State to prove that there will not be adverse impacts to the critically endangered North American Right Whales.

Finally, there ae reliability risks inherent in a weather-dependent electric grid when all the wind and solar output is reduced at the same time. This raises overarching questions that have not been addressed. Furthermore, even if these weather risks can be addressed in theory, the solution will involve technologies that are not commercially available today. I have no doubts that the only safe way to decarbonize the electric grid is to rely on nuclear power. The Hochul Administration needs to confront these issues before it is too late.

The risks of the Climate Act are all associated with mitigation efforts to reduce GHG emissions. I agree with Turver that mitigation should be emphasized. He concludes:

The risks of climate change can be averted by continuing to adapt, just as we have for millennia. It is certain that unilateral action by the UK, or indeed multilateral action by much of the West, will do nothing to change the weather while the developing world continues to increase their consumption of hydrocarbons to make themselves richer. Indeed, even if mitigation measures were adopted globally, it is naïve to believe that bad weather will cease and we will suddenly get the “stable climate” demanded by more than 170 lawyers.

Ellenbogen on the Comptroller Audit of the Climate Act

On July 16, 2024 the New York State Comptroller Office released an audit of the New York State Energy Research and Development Authority (NYSERDA) and Public Service Commission (PSC) of their implementation efforts for the Climate Leadership and Community Protection Act (Climate Act) titled Climate Act Goals – Planning, Procurements, and Progress Tracking. The key finding summary states: “While PSC and NYSERDA have taken considerable steps to plan for the transition to renewable energy in accordance with the Climate Act and CES, their plans did not comprise all essential components, including assessing risks to meeting goals and projecting costs.” As much as I would like to do a post on this, I am stretched too thin. Fortunately, Richard Ellenbogen sent along his thoughts that I have incorporated into my overview of the background and context of this report.

Ellenbogen is the President [BIO] Allied Converters and frequently copies me on emails that address various issues associated with the Climate Act I have published other articles by Ellenbogen and collaborated on a position paper on New York City’s Local Law 97 with him. There are only a few people in New York that are trying to educate people about the risks of the Climate Act with as much passion as I am, but Richard certainly fits that description. He comes at the problem as an engineer who truly cares about the environment and how best to improve the environment without unintended consequences. He has spent an enormous amount of time honing his presentation summarizing the problems he sees but most of all the environmental performance record of his business shows that he is walking the walk.

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 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies. That material was used to develop the Draft Scoping Plan outline of strategies. After a year-long review, the Scoping Plan was finalized at the end of 2022. Since then, State agencies and the legislature have been attempting to implement the plans through regulations, PSC orders, and legislation.

The New York State Comptroller Office audit of NYSERDA and PSC is available in Climate Act Goals – Planning, Procurements, and Progress Tracking as a pdf format file. The Audit Highlights section of the report lists the key findings and key recommendations:

Key Findings

While PSC and NYSERDA have taken considerable steps to plan for the transition to renewable energy in accordance with the Climate Act and CES, their plans did not comprise all essential components, including assessing risks to meeting goals and projecting costs. Specifically:

PSC is using outdated data, and, at times, incorrect calculations, for planning purposes and has not started to address all current and emerging issues that could significantly increase electricity demand and lower projected generation, such as increased push to transition to electric vehicles by 2035 and the cancellation or delay in renewable energy projects. Between 2005 and April 2023, 12% of contracted large-scale renewable projects were canceled.

The costs of transitioning to renewable energy are not known, nor have they been reasonably estimated. Moreover, funding sources to cover those costs have not been identified, leaving the ratepayers as the primary source of funding. The lack of alternative funding sources adds additional risk to whether the State can meet its goals timely. Data shows utility costs have already risen sharply over the last two decades and more New Yorkers are having difficulty paying their utility bills.

PSC has taken steps to address some risks and issues; however, it has not yet begun to formally review progress toward Climate Act goals with updated generation and electricity demand forecasts. While PSC noted it has until July 2024 to begin this assessment, waiting until that point to fully review all efforts and costs of the transition to renewable energy increases the risk that Climate Act goals will not be met within the established time frame.

Finally, a formal backup plan has not been established in the event Climate Act goals are found to be unachievable within the prescribed time frames, other than PSC suspending or modifying the obligations under the Climate Act and relying on the continued use of fossil fuels to generate electricity until sufficient renewable electric generation is developed. However, continuing to use fossil fuels as a backup plan would delay emission reductions and increase the burden on ratepayers by forcing them to continue to support fossil-fuel generation that otherwise could be retired—including the additional cost of the infrastructure to safely transport the fossil fuels to where they will be used to generate energy.

Key Recommendations

•            Begin the required comprehensive review of the Climate Act, including assessment of progress toward the goals, distribution of systems by load and size, and annual funding commitments and expenditures.

•            Continuously analyze the existing and emerging risks and known issues to ensure they are evaluated and addressed to minimize impact on the State’s ability to meet Climate Act goals.

•            Conduct a detailed analysis of cost estimates to transition to renewable energy sources and meet Climate Act goals. Periodically update and report the results of the analysis to the public.

•            Assess the extent to which ratepayers can reasonably assume the responsibility for covering Climate Act implementation costs. Identify potential alternative funding sources.

Note that the key finding that states that the PSC “has not yet begun to formally review progress toward Climate Act goals with updated generation and electricity demand forecasts.” It goes on to say that “While PSC noted it has until July 2024 to begin this assessment, waiting until that point to fully review all efforts and costs of the transition to renewable energy increases the risk that Climate Act goals will not be met within the established time frame.” A couple of weeks ago the PSC released the Clean Energy Standard Biennial Review Report. I do not think that report uses “updated generation and electricity demand forecasts” but it does conclude that the 2030 goal requiring 70% of the electricity supplied to the grid come from renewable sources will not be met without extraordinary efforts.

In addition, the biennial report does not address costs. It states that:

Appendix A also provides CES funding and expenditures for recent years through 2023. Forward-looking cost estimates for the CES and other costs associated with pursuit of the CLCPA goals are provided separately in the Department of Public Service (DPS) Annual CLCPA Report. The most recent such report was filed on July 20, 2024. Case 22-M-0149, Proceeding on Motion of the Commission Assessing Implementation of and Compliance with the Requirements and Targets of the Climate Leadership and Community Protection Act, New York State Department of Public Service First Annual Informational Report on Overall Implementation of the Climate Leadership and Community Protection Act (filed July 20, 2024). The next report is expected to be filed later in 2024.

In other words the biennial reports are not going to provide the cost data that the Comptroller audit recommends.

Ellenbogen Commentary

The following was included in an email from Ellenbogen on 17 July 2024. I have made a few edits for consistency with this article and have added a couple of annotations.

Regarding DiNapoli’s request for more transparent information mentioned in the audit report, he is correct but he is directing his arrows at the wrong targets. While I have major issues with some of the things that NYSERDA has done over the past couple of years, primarily their silence on the CLCPA, the PSC and NYSERDA are not the ultimate culprits here. At the BCNYS Renewable Energy Conference, I asked the NYISO speaker why they were screaming between the lines and not just coming out and saying that the entire process is devoid of reality because the people that need to hear it can’t, or are unwilling to, read between the lines. The NYISO says that, “Because we shut down gas generation too quickly, the system is compromised and has inadequate excess generation during times of extremely high load” which translates to, “If we have too many hot days in a row, there is going to be a blackout and people are going to die.”

In their 2022 6 GW storage report, NYSERDA stated that to get the system to work would require 1000+ hours of storage and the cost at the time was $560 per KWh. Doing the math, that was $3.36 Trillion dollars for storage that would last only ten years. That doesn’t include the renewables and transmission that would be required or the hundreds of billions of dollars to electrify the buildings. The actual cost will be at least ten times NY State’s annual budget, if not more. It will impose a tax burden on every New Yorker that none of them will be able to afford. NYSERDA put the number out there, but everyone ignored it and just plowed along as though they could somehow overcome that little detail. The cost also ignores logistical issues that I have mentioned on numerous occasions.

The problem with agency cost estimates is that they are buried in different reports. The Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda” is the logical place to provide comprehensive cost estimates for all the strategies proposed to achieve the Climate Act mandates. However, the cost documentation is incomplete, sparsely referenced, and misleading, in short it does not provide the necessary information for estimating ratepayer costs to New Yorkers.

This is a problem because New York Public Service Law § 66-p (4), “Establishment of a renewable energy program”, states: “The commission may temporarily suspend or modify the obligations under such program provided that the commission, after conducting a hearing as provided in section twenty of this chapter, makes a finding that the program impedes the provision of safe and adequate electric service; the program is likely to impair existing obligations and agreements; and/or that there is a significant increase in arrears or service disconnections that the commission determines is related to the program”. It is only possible to determine the impact on ratepayers in arrears or service disconnections if full cost estimates are available. The Comptroller audit appropriately addresses this shortcoming with the recommendation to “Conduct a detailed analysis of cost estimates to transition to renewable energy sources and meet Climate Act goals” and “Periodically update and report the results of the analysis to the public.”

I agree with Ellenbogen’s following explanation why this information is not available:

No one wants to put the actual number into the public domain because it is so astronomical that the minute it was announced, the project would implode, and the political fallout will be staggering. Further, I’m sure that the lesson of what happened to Justin Driscoll of NYPA when he told the truth about the process is fresh in everyone’s mind. The acolytes of this process wanted to hang him upside down from a light pole, as was done to Mussolini. He was just telling them the truth but that evidently doesn’t mean anything in NY State. No sane person wants to put that number down on paper and get pilloried for it and called a liar. Everyone at the state level that knows better is required by law to implement this ridiculous plan that can’t be implemented. So, they can tell the truth and get fired or they can duck and cover and hope that the law gets changed when it becomes brutally obvious how flawed it really is. In the interim, everyone is finger pointing, including the state comptroller.

The real targets for DiNapoli should be the Climate Action Council and the legislature that proposed this insanity based upon fantasies with no grounding in reality. No realistic cost analysis was ever done prior to voting to pass the Climate Act. The cost analysis for the Draft Scoping Plan was inadequate but the Climate Act Scoping Plan was still approved and that is the fault of the Climate Action Council (CAC). The few numbers that I have seen in the Climate Act Scoping Plan are so devoid from reality that they would be funny if the situation wasn’t so serious. You can make stuff up as the Climate Action Council did, but with math and physics, reality will eventually rear its ugly head and that is what is happening now.

In a second email Ellenbogen continued:

The issue isn’t that the PSC and NYSERDA aren’t planning properly. If you look at the three key findings quoted from the Audit highlights above, they are unachievable under any circumstances. It wouldn’t matter what NYSERDA and the PSC did. They can’t pull rabbits out of hats last I checked.

There is a Climate Action Council mandate (section 16 of § 75-0103) to consider efforts at other jurisdictions: “The council shall identify existing climate change mitigation and adaptation efforts at the federal, state, and local levels and may make recommendations regarding how such policies may improve the state’s efforts”. Ellenbogen points out the there are lessons to be learned at other jurisdictions that have attempted to decarbonize using wind and solar that have been ignored. Why?

The math behind the solar and wind utility system doesn’t work. It hasn’t worked anywhere it has been tried and the time frames have been measured in decades to get to a fraction of a renewable system, not 10 years or 20 years like the CLCPA requires. Germany is 34 years in, controls the banking system in their jurisdiction which NY State does not, and they’ve only gotten to 34% renewables after about 34 years with energy costs twice those of France next door. Their politicians are paying for that. The costs are rising because they are being required to install transmission that only operates 15% of the time for solar or 30% for wind where it would operate 93% of the time for fossil or nuclear. That increases the transmission cost per megawatt-hour. Offshore wind bids are coming in at three times the price of current generation. Projects are being canceled because of high transmission costs and material costs. Building electrification is prohibitively expensive. How can you plan for that?

Why didn’t the legislature request a cost analysis prior to passing the bill? Why didn’t the Climate Action Council do a cost analysis of what they were proposing? It’s because it was driven by a couple of college professors that have absolutely no understanding of procurement, energy, economics, or basically anything else in the real world. In their minds, no cost was too high to eliminate fossil fuels from the state. The question for politicians today is whether spiraling energy costs brought on by this bill are going to make re-election more difficult.

The net-zero transition plan requires “Distributed Emission Free Resources” or DEFR’s that don’t exist in the present day aside from nuclear and that is a dirty word in NY State. Even if the State made the rational decision to decarbonize the electric sector with nuclear instead of wind and solar, it would also take about 30 – 40 years to build enough nuclear capacity to meet the state’s needs if they started today. Waiting for an alternative new technology to fulfill the DEFR requirement will take even longer. None of these time frames fits within the CLCPA mandate.

The only mistake that the PSC and NYSERDA made was not speaking up in 2019 before this mess was passed but Cuomo was ruling with an iron hand at the time. What makes this all so senseless is that nothing NY State does is going to impact Climate Change. I’m not saying that we should do nothing, but we should be intelligent in our planning. Saying that NY State is an energy leader is a joke. We’re only a leader in chasing our businesses to other states where they are assured of an adequate energy supply. In 20 years NY State is going to be an example of what not to do.

The backup plan for the near term to ensure sufficient generation would require the construction of fossil fuel plants which will draw the ire of the lunatic fringe that has no understanding of energy or math. I gave them a backup plan in comments I submitted to the record for Department of Public Service Proceeding 15-E-0302 but numerous groups will fight against that. When the level of desperation gets high enough, they will be implemented. Unfortunately, there may have to be a major blackout to bring people to their senses.

Conclusion

The Comptroller Climate Act Goals – Planning, Procurements, and Progress Tracking and the PSC Clean Energy Standard Biennial Review Report both acknowledge that Climate Act implementation is not going as planned. I believe Ellenbogen agrees with me that all the recommendations in the audit report should be implemented as soon as possible:

• Begin the required comprehensive review of the Climate Act, including assessment of progress toward the goals, distribution of systems by load and size, and annual funding commitments and expenditures.

• Continuously analyze the existing and emerging risks and known issues to ensure they are evaluated and addressed to minimize impact on the State’s ability to meet Climate Act goals.

• Conduct a detailed analysis of cost estimates to transition to renewable energy sources and meet Climate Act goals. Periodically update and report the results of the analysis to the public.

• Assess the extent to which ratepayers can reasonably assume the responsibility for covering Climate Act implementation costs. Identify potential alternative funding sources.

Richard Ellenbogen and I have long argued that a clear and transparent accounting of all the costs to meet the Climate Act goals is not available. It is heartening to see that the Comptroller audit agrees with our position that this information is necessary. The biennial review report concludes that the 2030 electric grid goal for 70% renewable energy is not likely. It is time for New York State to acknowledge these problems should be resolved before continuing. I recommend a pause in implementation until all the recommendations in the audit report are implemented and a feasibility study reconciles the electric system projections in the Scoping Plan and the New York Independent System Operator resource adequacy analyses.

Ellenbogen sums up the situation:

There is nothing happening now that I didn’t tell them would happen five years ago. I’m not Nostradamus. I just know how to count.

Climate Act Presumption That DEFR is Unnecessary

The New York Department of Public Service (DPS) Proceeding 15-E-0302 addresses among other things a new category of generating resources called Dispatchable Emissions-Free Resources (DEFR). All credible analyses of the future New York electric system agree that new technologies are necessary to keep the lights on during periods of extended low wind and solar resource availability. This article describes the presumption of the authors of the Climate Leadership & Community Protection Act (Climate Act) that no new technologies would be required.

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 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “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 Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies. That material was used to develop the Draft Scoping Plan outline of strategies. 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 and legislation.

I have written about the out-sized and misleading impact that Robert W. Howarth, Ph.D., the David R. Atkinson Professor of Ecology & Environmental Biology at Cornell University had on many of the members of the Climate Action Council. His statement supporting the approval of the Draft Scoping plan claimed that he played a key role in the drafting of the Climate Act and explained why he believes that no new technologies are needed to meet the Climate Act goals:

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

The presumption that “it could be done completely with technologies available at that time (a decade ago)” was a primary driver of the Climate Act schedule and confidence of success by the legislature and the Climate Action Council. The feeling was that all it takes is a matter of political will because the professor said it will work. Howarth appealed to the authority of peer-reviewed science to provide credibility for the Jacobson analysis that is the basis of his claims. However, science is a continuous process where hypotheses are constantly challenged and confirmed. In this instance Howarth neglected to mention the analyses that discredit the Jacobson work.

Jacobson Wind, Water, and Solar

The Jacobson analysis cited was a continuation of previous work broadly labeled as Wind, Water, and Solar. For example, in a widely publicized November 2009 Scientific American article, Mark Jacobson and Mark Delucchi suggested all electrical generation and ground transportation internationally could be supplied by wind, water and solar resources as early as 2030. However, other contemporary projections were less optimistic, for example two examples: the 2015 MIT Energy and Climate Outlook has low carbon sources worldwide as only 25% of primary energy by 2050, and renewables only 16% and the International Energy Agency’s two-degree scenario has renewables, including biomass, as less than 50%.

Howarth’s statement cites a specific plan for New York (Jacobson et al. 2013) that he and Jacobson laid out a decade ago. He says that “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.” Table 2 from that report follows. This analysis includes power from exotic resources such as waves, geothermal, tidal turbines, and concentrated solar power but no energy storage. It is significantly different than the projections in the Integration Analysis and the New York Independent System Operator (NYISO) 2021-2040 System & Resource Outlook that exclude all the exotic renewable generating capacity, contain significant amounts of energy storage, and include a new dispatchable, emissions-free resource for a set of resources that they think can provide sufficient electrical power for the future. Furthermore, Jacobson and Howarth claim that end-use power demand can be decreased by 37%. In my opinion, there are many flaws in his claims. For example, any analysis that suggests that concentrated solar power is a viable source of energy in New York is simply not credible because that resource would never work in New York. It is too cloudy to operate enough to cover costs and the environmental impacts would be too great.

There was a formal rebuttal paper to this analysis by Nathaniel Gilbraith, Paulina Jaramillo, Fan Tong, and Felipe Faria. The rebuttal paper argued that:

The feasibility analysis performed by Jacobson et al. (2013) is incomplete and scientifically questionable from both the technical and economic perspectives, and it implicitly assumes, without sufficient justification, that social criterion would not produce even larger feasibility barriers.

Jacobson et al. responded to that rebuttal claiming that “The main limitations are social and political, not technical or economic.” Given the significant differences between that analysis and the most recent projections by the organization responsible for keeping the lights on, I agree with the Gilbraith et al. conclusion cited above. I do not believe that the 2013 WWS analysis includes a defensible feasibility analysis.

Using Jacobson as the basis for the idea that the Climate Act transition needs no new technology gets worse. Unmentioned by Dr. Howarth is that in a 2015 article for a different iteration of the wind, water, and solar roadmap Clack et al, 2017 discredited the Jacobson approach:

In this paper, we evaluate that study and find significant shortcomings in the analysis. In particular, we point out that this work used invalid modeling tools, contained modeling errors, and made implausible and inadequately supported assumptions. Policy makers should treat with caution any visions of a rapid, reliable, and low-cost transition to entire energy systems that relies almost exclusively on wind, solar, and hydroelectric power.

In the scientific process, when issues with your work are noted, the proper response is to provide more evidence supporting your modeling tools, explain why the claimed errors are not errors, and defend your assumptions. Instead, Jacobson filed a lawsuit, demanding $10 million in damages, against the peer-reviewed scientific journal Proceedings of the National Academy of Sciences and the authors for their study showing that Jacobson made improper assumptions in order to make his claims that he had demonstrated U.S. energy could be provided exclusively by renewable energy, primarily wind, water, and solar. In my opinion this is an appalling attack on free speech and scientific inquiry but want to emphasize that the bad actions by Jacobson in no way should be attributed to Howarth.

In February 2018, following a hearing at which PNAS argued for the case to be dismissed, Jacobson dropped the suit. The defendants then filed, based on the anti-SLAPP — for “Strategic Lawsuit Against Public Participation” — statute in Washington, DC, for Jacobson to pay their legal fees. In September 2022, he was ordered to pay the defendants’ legal fees based on a statute “designed to provide for early dismissal of meritless lawsuits filed against people for the exercise of First Amendment rights.” Jacobson appealed that award but lost that appeal in February 2024 thus closing this sad tale of academic controversy.

In Meredith Angwin’s 2020 book Shorting the Grid: The Hidden Fragility of Our Electric Grid (Carnot Communications, Wilder, VT, 422 pp.) she also addressed the Jacobson analysis. Her description in a section entitled Hard-Core Renewables at page 195 is consistent with my portrayal above:

Wind and solar are the technologies that most people think about when they think of “renewables.” Indeed, many hard-core renewables advocates accept only solar, wind, and (sometimes) hydro as renewables. Biomass rarely makes the cut as a true renewable. Professor Mark Z. Jacobson of Stanford plans WWS (Wind Water Solar) as the energy sources for the world. In 2015, Jacobson and others published an article in the Proceedings of the National Academy of Sciences on using WWS for all purposes.¹²⁵

In 2017, a group of professors headed by Christopher Clack responded with an evaluation article also in the Proceedings.¹²⁶ The first paragraph of the Clack article stated that “We find that their (Jacobson analysis) involves errors, inappropriate methods, and implausible assumptions.” For example, their rebuttal paper pointed out that the Jacobson paper describes hydro power as providing 700 to 1300 GW. However, existing installed hydro capacity is 87 or 145 GW, depending on whether pumped hydro is included, and the most useful sites have already been exploited.¹²⁷

When the Clack paper appeared, Jacobson published a letter in the same issue of the Proceedings, claiming “The premise and all error claims (of the Clack paper)… are demonstrably false.”¹²⁸ Jacobson said that his assertion on the availability of hydro power was an “assumption,” not an error. As Jacobson wrote in the published letter: “The value of 1,300 GW is correct, because turbines were assumed added to existing reservoirs to increase their peak instantaneous discharge rate without increasing their average annual energy consumption.” Shortly after the Clack paper and the Jacobson rebuttal were published in the Proceedings, Jacobson sued Clack and the Proceedings for defamation.

Jacobson later dropped his lawsuit. On the Greentech Media website, Julian Spector wrote an article about the controversy and the lawsuit.¹²⁹ In his article, Spector notes that “this ‘assumption’ (about hydro) was unwritten” in the original Jacobson article. In other words, in his original paper, Jacobson did not describe his assumption that multiple turbines would be added to existing dams. Frankly, adding about ten times as many turbines to existing powerhouses seems very unlikely to me. Dam construction is a massive undertaking. Putting many more turbines in an existing powerhouse … well, I can’t see how that could even work.¹³⁰

Jacobson did drop his lawsuit, which should be a happy ending, I suppose. However, many people, including myself, feel that the fact that Jacobson even brought a lawsuit has had a chilling effect on the whole renewable-energy debate. If scientists can’t debate each other in peer-reviewed journals without fear of lawsuits, science will not be able to move forward very well.

There are two books directly refuting the Jacobson plan. Roadmap to Nowhere: The Myth of Powering the Nation With Renewable Energy by Mike Conley and Tim Maloney is available as a free PDF download on the web.¹³¹ Mathijs Beckers, of the Netherlands, wrote The Non-Solutions Project, available as an ebook or paperback.¹³²The work of these authors is clear and easy to follow.

Footnotes

Mark Z. Jacobson, Mark A. Delucchi, Mary A. Cameron, and Bethany A. Frew, “Low-cost solution to the grid reliability problem with 100% penetration of intermittent wind, water, and solar for all purposes,” Proceedings of the National Academy of Sciences, 112, no. 49 (December 8, 2015): 15060-15065, https://wwu .pnas.org/’content/112149115060.

Christopher T. M. Clack et al., “Evaluation of a proposal for reliable low- cost grid power with 100% wind, water, and solar,” Proceedings of the National Academy of Sciences 114, no. 26 (June 27, 2017): 6722-2627, https://www.pnas . o rg/con tent/114/2 6/6722.

Supporting information for the above article by Clack et al., https://www.pnas .org/content/pnas/suppl/2017/06/16/16103 81114. DCSupplemental/pnas. 1610381114 .sapp.pdf

Mark Z. Jacobson, Mark A. Delucchi, Mary A. Cameron, and Bethany A. Frew, “The United States can keep the grid stable at low cost with 100% clean, renewable energy in all sectors despite inaccurate claims” (letter), Proceedings of the National Academy of Sciences 114, no. 26 (June 27, 2017), https://www.pnas .org/content 1114126/P5021.

Julian Spector, “Mark Jacobson Drops Lawsuit Against Critics of His 100% Renewables Plan,” gtm: (website of Greentech Media), February 26, 2018. https://www.greentechmedia.com/articles/read/mark-jacobson-drops-lawsnit- against-critics-of-his-100-renewables.

Besides my general knowledge of the grid and several visits to working dams, I also headed a project on predicting and preventing corrosion in the penstocks of several medium-size dams in mountainous country. This project was not published: it was only a report to the client, so I cannot provide a link. While I would not claim hydro power as an area of deep expertise for me, I have enough knowledge to be seriously skeptical about the idea of adding ten times as many turbines to existing hydro plants.

Mike Conley and Tim Maloney, “Road Map to Nowhere: The Myth of Powering the Nation with Renewable Energy,” Road Map to Nowhere (website), December 2017, https://www.roadmaptonowhere.com.

Mathijs Beckers, “The non-solutions project,” CreateSpace Independent Publishing Platform January 18, 2017), https://www.amazon.com/gp/product/ B01N6SN5El/re/=dbs_a_def_rwt_hsch_vapi_tkin_pl_il.

Conclusion

Much of this material was published 18 months ago. I wrote this article for two reasons. I wanted to update some information and add the reference by Angwin. The other reason is that I am compiling articles about DEFR to be used in a reference page.

Howarth’s argument that no new technology is needed has been refuted in the peer reviewed literature but also in other work. When I publish the reference page it will include multiple examples of other analyses that conclude that the new DEFR technology is required for New York’s electric grid zero-emissions transition. Successful implementation is not just a matter of political will.

It is unsettling that Howarth continues to claim that no new technology is needed in that light and relative to the lawsuits associated with Jacobson’s work. Angwin and I agree that Jacobson’s attempted lawsuit was because his work could not stand on its own. It is time for the Climate Action Council to disavow itself from any suggestions that DEFR will not be needed.

New York City Local Law 97 – Don’t Do It

I have the pleasure to announce the availability of a new report prepared for New York Co-op and Condo Boards and Trade Associations regarding New York City Local Law 97 mandated conversion to electric heat. Local Law 97 mandates that “most buildings over 25,000 square feet are required to meet new energy efficiency and greenhouse gas emissions limits as of 2024, with stricter limits coming into effect in 2030.” Our report (“LL97 Impacts Report”) argues that in the absence of a credible and feasible plan demonstrating where the electricity will come from, backed up by a functioning Demonstration Project showing how the transformed grid will work and how much the electricity will cost, Co-op and Condo Boards cannot responsibly undergo the enormously costly process of conversion to electric heat.

I have followed the Climate Leadership & Community Protection Act (CLCPA) since it was first proposed, submitted comments on the CLCPA implementation plan, and have written over 400 articles about New York’s net-zero transition. I am convinced that the CLCPA will adversely affect affordability, reliability, and that the environmental impacts of the proposed transition are greater than the possible impacts of climate change. 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.

Background

Co-authors Francis Menton, Richard Ellenbogen, and I prepared this report without compensation and on a pro bono basis because we felt duty-bound to warn people of the significant impending threat to their health and safety. We received no funding of any kind from the real estate industry, the energy industry, or anyone else for this report.

I believe that the three of us represent different but complementary backgrounds that provide a unique take on the implementation of this law. Francis Menton retired from the law firm Willkie Farr & Gallagher LLP after 31 years as a partner and brings a legal background to our team. He has written about climate and energy issues for publications including the City Journal, Gatestone Institute, Real Clear Energy, and others, and is the main author at ManhattanContrarian.com with many of his articles reposted here. Richard Ellenbogenhas a Bachelor’s degree and a Master’s Degree in Electrical Engineering from Cornell University. He worked at Bell Telephone Laboratories in their Power Systems Laboratory, before joining Allied Converters, a plastic food packaging manufacturer in New Rochelle, N.Y. As president of Allied Converters, Ellenbogen has overseen the company’s transformation into a green manufacturer with 100% waste recycling/repurposing, a 65 KW CHP System, and a 50-kilowatt solar array. Very few if any people in New York bring as much practical experience related to reducing energy use and lowering GHG emission. For nearly the past two decades, Allied Converters has generated approximately 80% of its electric energy onsite and has operated with a Carbon Footprint 40% lower than the utility system. I am a retired air pollution meteorologist who started working at the interface between the electric utility industry and New York regulatory agencies starting in 1981. I still closely follow New York regulatory initiatives and provide personal comments on energy and environment topics for regulatory proceedings and policy proposals. I author the Pragmatic Environmentalist of New York blog and occasionally post articles here.

Francis Menton’s daughter Jane lived in a Queens co-op and was on their Board when Local Law 97 (LL97) was passed. She and the members of her Board had an analysis done of the costs to meet the LL97 mandates. In short, it was unaffordable. Not only that, but Jane also knew, based on her understanding of energy constraints in NYC, that it was unworkable and would result in an energy catastrophe. She recruited her father to write a report explaining the limitations of the electric grid. Menton contacted me, I contacted Ellenbogen and the three of us agreed that, based on our backgrounds and experiences, we had a moral obligation to document the problems we expect will occur. This report is intended to provide information for a grass roots organization, directed by Jane, that we hope will coordinate a response by co-ops and condo boards throughout New York City (NYC).

Local Law 97

The goal of LL97 is to reduce the emissions produced by the city’s largest buildings 40 percent by 2030 and net zero by 2050. Similar to New York’s Climate Leadership and Community Protection Act (Climate Act) this is political theater without regard to practicality. The law also established the Local Law 97 Advisory Board and Climate Working Groups which are supposed to advise the city on how best to meet the LL97 mandates.

In December 2022, the NYC Buildings Department released a report (“NYC LL97”) from the LL97 Advisory Board. The NYC LL97 report “represents the culmination of hundreds of hours of work of the Advisory Board, Working Groups, and staff members who dedicated their time and expertise to help the City advance building energy efficiency and emissions reduction efforts”. This is a political document. LL97 mandated the appointment of sixteen people – eight appointed by the mayor and eight of appointed by the speaker of the City Council. In theory the membership was supposed to represent “key stakeholder interests from the building sector” but I can guarantee that the primary qualification for membership was alignment with the political goals – just like the advisory panels for the Climate Act’s planning process.

There were seven Climate Working Groups. These Working Groups “leveraged subject-matter experts in a variety of fields to present proposals to the Board on specific issue areas. I do not want to disparage the work of these folks but the basic working premise of all these efforts is that we must do this because it is the law. There are plenty of organizations that are happy to provide experts that can develop implementation plans that purport to show that it will work. Pursuant to LL97, the NYC LL97 report included “recommendations regarding several issues related to implementation of the law, including improving performance requirements to achieve at least a 40% reduction in aggregate GHG emissions by 2030”. The report provides these recommendations.

The NYC LL97 report includes chapters on calculating and reporting GHG emissions; recommendations for “tailored emission reduction approaches based on different building types; mechanisms for maximizing emission reductions; assistance to “assist properties, especially those in high need areas, with compliance, rather than to fine them for noncompliance” approaches to maximize “compliance with LL97 through clear communications to the public and robust, direct outreach to covered property owners and stakeholders”; achieving consistency across existing regulations; and recommendations for further analysis. The bottom line is that to meet the mandated emission limits buildings will eventually have to electrify their heating, cooking, and hot water systems.

The NYC LL97 report is incomplete. Like the Climate Act Scoping Plan, the report does not address feasibility. This is a particularly critical point because at the same time as this law is mandating increased use of electricity, the Climate Act mandates 70% renewable electrical generation by 2030 and 100% zero emissions generation by 2040. Our report (“LL97 Impacts Report”) argues that credible and feasible plan must be prepared that demonstrates where the electricity will come from. In order to guarantee health and safety a functioning Demonstration Project showing how the transformed grid will work and how much the electricity will cost is needed before Co-op and Condo Boards can responsibly undergo the enormously costly process of conversion to electric heat.

Report to Co-op and Condo Boards and Trade Associations regarding New York City Local Law 97

The LL97 Impacts Report points out that LL97 mandates that most large residential buildings in the City must convert to electric heat by 2030, and all of them by 2035. Such conversions, should they occur, will add substantially to the demand on the City’s electrical grid. Simultaneously, New York State has enacted the Climate Act, an even more comprehensive climate statute, that mandates that power plants that run on natural gas — the generators of most of the City’s reliable electricity — must be closed during the 2020s and 30s, and all of them closed by 2040. The State has also mandated that a portion of new vehicle sales be zero-emissions vehicles starting in 2026, ramping up to 100% of all such sales by 2035, further dramatically increasing the demand on the City’s grid. These several mandates are in irreconcilable conflict. They cannot all be met simultaneously; and, in combination, they will inevitably undermine the reliability of the City’s electric grid.

The LL97 Impacts Report points out that neither the State nor the City of New York has presented any credible plan demonstrating that in the early to mid-2030s there will be sufficient reliable electricity generation to meet the demands anticipated from both current uses, and from the large additions that have been mandated. Indeed, the State has admitted that, in lieu of a definitive plan, it relies instead on a speculative hope for new technologies not yet invented or deployed at scale to bridge the large gap in electricity supply that will inevitably arise from the conflicting mandates. The State can point to no Demonstration Project showing how its hope for a de-carbonized electrical grid can succeed, nor to any detailed projection of the anticipated costs.

Even the New York Independent System Operator (NYISO) – the entity responsible for maintaining the reliability of the grid it oversees – has recently issued warnings as to the looming dangers ahead from insufficient and unreliable electricity supply. In its recent 10-year Power Trends study, NYISO sees the danger of unreliability of the grid as arising no later than the phasing out by December 31, 2030 of the New York Power Authority’s small natural gas plants located in New York City. The NYISO report states:

“If demand on the grid grows at a rate greater than the buildout of new generation and transmission, reliability deficiencies could arise…”.

In addition, the Public Service Commission recently released its Clean Energy Standard Biennial Review Report that admits that the Climate Act 70% renewable electrical generation by 2030 goal will not be met until 2033 at the earliest. The report cites global interest rates, inflation, and supply chain pressures as factors affecting the progress needed to meet the 2030 mandate. Those factors also impact LL97 implementation.

The LL97 Impacts Report provides detailed descriptions of the issues raised in the NYISO and PSC report. It explains that the ongoing pursuit of New York’s irreconcilable energy mandates creates especially severe potential consequences for the City’s large co-ops and condominiums. The boards of most of these buildings currently face a mandatory 2030 deadline for conversion to electric heat. Complying with this mandate can only be done at very large cost, indeed a cost so large that it would stretch the finances of nearly all buildings to the breaking point. Boards also have under New York law a fiduciary duty to their shareholders and members, which encompasses protecting the health and safety of all residents, and not squandering their constituents’ money.

The LL97 Impacts Report notes that in the absence of a credible and feasible plan demonstrating where the electricity will come from, backed up by a functioning Demonstration Project showing how the transformed grid will work and how much the electricity will cost, Boards cannot responsibly undergo the enormously costly process of conversion to electric heat. Because of their fiduciary duties, Board members can face severe personal liability if, for example, they put their residents in the position of losing heat when the electrical grid fails on the coldest days of winter; or if they commit their building to borrowing large sums that must be repaid to install a heating system that then does not work when needed.

Conclusion

The NYC LL97 report falls far short of what is needed to provide Co-op and Condo Boards and the residents of those buildings with any assurance that the LL97 mandates can be met at the same time the Climate Act is transforming the electric energy system with massive deployments of wind, solar, and energy storage as well as not yet commercially available resources. This means extraordinary risks for keeping the heat on in the winter in NYC.

The fines that are slated to be imposed on buildings failing to convert by 2030, although substantial, are small compared to the combined exposures of conversion costs plus potential liabilities. Moreover, when it becomes apparent that the grid cannot handle the mandated demands, the laws imposing impossible and irreconcilable mandates must inevitably be modified. The LL97 Impacts Report concludes that no responsible Board can go down the road of converting a large building to electric heat until NYC proves that the mandates are demonstrably feasible without threatening the safety and welfare of affected residents.

Filling the Gap in New York’s Decarbonization Plan: A New View of the Electric Grid

Nuclear New York, Inc. submitted the report “Filling the Gap in the State’s Decarbonization Plan” to the New York Department of Public Service (DPS) Proceeding 15-E-0302 related to a new category of generating resources called Dispatchable Emissions-Free Resources (DEFR). All credible analyses of the future New York electric system agree that new technologies are necessary to keep the lights on during periods of extended low wind and solar resource availability. This article documents this analysis.

I have followed the Climate Leadership & Community Protection Act (Climate Act)since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 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 company I have been associated with, these comments are mine alone.

Overview

When the Climate Action Council voted to accept the Scoping Plan draft members made statements. I have previously described the outsized influence of Dr. Robert Howarth the David R. Atkinson Professor of Ecology & Environmental Biology at Cornell University on the findings of the Council. His statement, in support of approving the Scoping Plan draft included the following:

A decade ago, Jacobson, I and others laid out a specific plan for New York (Jacobson et al. 2013). In that peer-reviewed analysis, we demonstrated that our State could rapidly move away from fossil fuels and instead be fueled completely by the power of the wind, the sun, and hydro. We further demonstrated that it could be done completely with technologies available at that time (a decade ago), that it could be cost effective, that it would be hugely beneficial for public health and energy security, and that it would stimulate a large increase in well-paying jobs. I have seen nothing in the past decade that would dissuade me from pushing for the same path forward.

The Scoping Plan directly contradicts his statement that technologies available when the paper was written and today are sufficient for the transition away from fossil fuels. The Scoping Plan itself explains why DEFR is necessary. I provide more details about DEFR at a dedicated webpage and I am compiling a list of analyses that contend that it is necessary. This post describes the Nuclear New York report “Filling the Gap in the State’s Decarbonization Plan” that also argues that New York’s plans have underestimated the need for dispatchable resources in the future.

A New View of the Electric Grid

The Filling the Gap in New York’s Decarbonization Plan: A New View of the Electric Grid report was authored by Leonard Rodberg, PhD, Research Director, Nuclear New York, Inc.; Consultant, Energy Policy; Reiner Kuhr, Founder, Center for Academic Collaborative Initiatives (CAIC); and Ahmad Nofal, Co-founder, CAIC. The rest of this section quotes the Executive Summary and includes my annotations.

The report clearly describes the issue. At the same time load is expected to increase significantly, New York is proposing to rely on wind and solar that needs a firm dispatchable resource aka DEFR:

New York State has seriously underestimated the need for a large firm dispatchable source (A firm dispatchable source is always available and able to supply whatever additional electric output is needed) in its future decarbonized grid. The growth in demand from the expected electrification of automobiles and the heating of buildings requires that such a resource operate for more than a third of the year to provide a grid that is reliable and avoids rolling blackouts.

I believe that an hourly analysis is necessary. The authors used a model that “performs an hour-by-hour analysis of the projected electricity demand in 2040 to show how the in-state sources assumed in NYSERDA’s scenario actually behave when serving this varying demand.” The Center for Academic Collaborative Initiatives model “uses spreadsheet software to calculate, for each hour throughout the year, how the available energy sources, including battery storage and the DEFR, will be used to meet projected electric load.”

We have analyzed a Renewable-Focused Plan (RFPlan) with characteristics similar to scenarios describing the state’s future electric grid prepared by the NYS Energy Research and Development Authority (NYSERDA) for the Climate Action Council. (CAC). Using a new modeling tool that allows an hour-by-hour analysis of electric system behavior, we can see details of the hourly operation of each energy source, features not disclosed by existing models, including that used by NYSERDA. We can also estimate the cost to the purchasers of electricity and taxpayers of these scenarios.

The authors used the installed capacities included in the Integration Analysis Scenario 3 but the model dictates how the units operate.

The State’s Climate Leadership and Community Protection Act (CLCPA) requires that the electric grid be free of greenhouse gas emissions by 2040. NYSERDA’s scenarios create a plan which depends almost entirely on generating electricity with renewable sources. They retain existing nuclear plants, but no new ones are added.

The Executive Summary outlines the approach used in the Scoping Plan:

The Scoping Plan adopted by the CAC declares that “wind, water, and sunlight will power most of New York’s economy.” While its focus is on renewable sources, the CAC does recognize the need for an additional clean source: “plan analysis and current studies show that the 2040 zero-emission goal requires between 15 and 45 gigawatts (GW) of electric power from dispatchable zero-emission resources”. However, NYSERDA finds that little more than 2% of the potential output of such a dispatchable emission-free resource (DEFR) will actually be used.

The authors explain that the Scoping Plan approach is based on a lot of wishful thinking:

Simple arithmetic makes this seem highly questionable. By 2040, NYSERDA and NYISO, the grid operator, estimate that building and transportation electrification will have expanded so that the grid will have a peak load in winter of 46-50 GW. Yet, even with land-based and offshore wind blowing at full capacity, no more than 35 GW will be available during winter evenings. Little or no excess capacity exists to charge the batteries, and, of course, solar won’t be available. Much more than 2% of the dispatchable source’s potential output has to be available to get through the winter without blackouts.

The CAIC model projects a dramatic difference in the use of DEFR:

Our hour-by-hour analysis shows that the firm dispatchable source has to run two-thirds of the year. The total load has increased from today. The summer peak has been replaced by a much higher winter peak. That greater demand is met by the extended operation of the DEFR which runs during most evenings in the cooler portion of the year. In fact, we find a capacity factor — the fraction of potential output actually used –of 14.4%. Our detailed results are shown below.

In my opinion, the CAIC analysis treats DEFR differently than the Integration Analysis does. I believe that when the Integration Analysis determines which resources should be applied to meet load, they use DEFR as a last resort. On the other hand, CAIC uses DEFR much more frequently. That could be due to a difference in the hourly projections of wind, solar, energy storage, and load for the two models or presumptions in the models.

The final aspect of the modeling is a proposal for an alternative approach:

In this paper we suggest alternatives to NYSERDA’s plan that use baseload nuclear power along with a nuclear-powered firm dispatchable resource (DEFR) to ensure a reliable grid. Our plan costs one-third less than the RFPlan.

DEFR Implications

The CAIC model was also used to evaluate the placeholder Integration Analysis DEFR technology:

NYSERDA suggests, in its Integration Analysis, the use of hydrogen produced with renewable generated electricity to fuel the DEFR. We have examined this case and find that supplying sufficient energy to produce the required hydrogen would necessitate a 40% increase in the number of solar and wind installations, beyond those envisioned in the RFPlan. We are unable to estimate that system’s cost, since it would require creating a new infrastructure to produce, transport, and store a large supply of hydrogen during the summer for use in the winter. Analyzing such a construction project is beyond the scope of this study.

It is not clear how the Integration Analysis deals with hydrogen. I think that they believe that they have included sufficient wind and solar resources to support hydrogen production using electrolysis. However, I also think that the Integration Analysis has arbitrarily decided that half of the needed hydrogen will come from out of state. I think that is a wildly optimistic presumption and very unlikely to occur. In any event, no one can estimate how much this will cost using the documentation provided.

Nuclear Option

Not surprisingly Nuclear New York proposes nuclear energy as a DEFR candidate. The Scoping Plan makes a token suggestion that nuclear should be considered but there is no serious attempt to compare nuclear relative to their other technology recommendations. The report describes the Nuclear New York proposal:

The following scenarios, which we term “Brighter Future,” build upon a 2022 policy proposal

prepared by Nuclear New York, Clean Energy Jobs Coalition NY, and A Campaign for a Green Nuclear Deal. Recognizing that much of New York’s electricity demand is constant throughout the year, Brighter Future utilizes nuclear power as a principal source of clean power throughout the year, not simply as a DEFR when solar and wind are incapable of meeting the load. Nuclear becomes the backbone of the system, not simply a backup to intermittent, weather-dependent renewables.

These scenarios include 7 GW of new baseload nuclear power – adding more than twice what is

already operating in upstate New York – along with 26 to 30 GW of DEFR. Far fewer solar and wind installations are needed; we assume 80% fewer installations than in RFPlan. Our grid model presently does not allow for the DEFR to charge batteries. Since adding batteries that are seldom charged adds unnecessary costs, we exclude them from the Brighter Future scenarios. We will evaluate their inclusion in future research.

The first, Brighter Future 1, has 9 GW of offshore wind, the minimum called for in the CLCPA.

Brighter Future 2 has no offshore wind and costs significantly less. Not only does offshore wind add to the system cost, but it will be shut down, and possibly seriously damaged whenever frequent and increasingly intense storms arrive from the Caribbean and South Atlantic.

The following table from the report summarizes their findings and provides total per-unit generation costs for in-state resources under two DEFR capital cost scenarios: current-cost at ~$6,000/kW and low-cost at ~$3,000/kW.

I agree that nuclear must be used if New York wants to decarbonize safely and suspect that the all-in costs of nuclear will be less than wind, solar, energy storage, and DEFR.

DEFR Options

The report also includes a section describing alternative DEFR technologies. The report evaluates a number of suggested options:

Fuel cells or gas turbines powered by “green hydrogen”: Hydrogen fuel cells or combustion power plants similar to those now burning fossil fuels could run on “green hydrogen” produced in electrolyzers powered by renewable energy, as NYSERDA has suggested. However, such a plan requires the creation of an expensive infrastructure to transport and store the hydrogen, as well as a buildout of additional costly, land-hungry solar and wind facilities to power the hydrolysis plants that produce the hydrogen. Using hydrogen for energy storage is challenged, also, by the fact that the round-trip power-to-gas-to-power (P2G2P) efficiency is just 40%.34 This means more than twice as much additional energy is needed as will be generated by the DEFR, with a commensurate drain on material resources, land, and societal wealth.

Long-duration storage: This might help, but currently no realistic scalable form of such storage exists. If it did, it, too, would require a vast expansion of generating capacity if solar and wind power charges whatever storage medium is used.

Carbon capture and storage (CCS) attached to gas-fired power plants: This only exists on an experimental basis. It would add substantial cost to the power it was attached to, and there would be upstream leakage of greenhouse gases and other pollutants to the environment. The captured CO2 would have to be disposed of, presumably underground, adding additional cost as well as potential environmental damage.

Nuclear power: This is the DEFR energy source used in each of our scenarios, as well as for additional baseload generation in the Brighter Future scenarios. Only nuclear power has been demonstrated to have the necessary capabilities, not only in the gigawatt-scale reactors now operating in New York State and elsewhere, but in the smaller reactors now under commercial development and operating on submarines and ships for over fifty years (many designed in New York State at the Knolls Atomic Power Laboratory).

Alternate nuclear options: Alternate ways of using nuclear energy will deserve consideration. Nuclear reactors, like most energy sources, are most cost-efficient when they run more of the time to meet demand. We found that the DEFR would be operating at partial capacity for most of the year. A more cost-effective plan might use a smaller number of reactors running continuously to produce hydrogen which could be used in fuel cells. Another option would be to use nuclear facilities to produce carbon-neutral synthetic fuels.35,36 Full analysis of the cost and suitability of these options is beyond the scope of this paper, but they deserve serious study.

I agree with their findings. I will only believe that the State seriously wants to reduce carbon emission if and only if they abandon the wind and solar approach and go nuclear. As this report explains it is the only viable approach.

Discussion

The report lists some limitations of the modeling and their research. Those include: a simplified view of the in-state transmission system, absence of reserves mandated by reliability requirements, fixed cost assumptions, a couple of potential refinements for the nuclear proposals, and optional DEFR designs.

I caution readers that this analysis is not as sophisticated as the work that NYISO does. Transmission constraints will definitely affect the outcome of projections. NYISO projections handle all the complications associated with those constraints. I do not think that the Integration Analysis includes sophisticated transmission constraints either.

Despite its limitations I do not believe that these limitations affect the general outcomes: DEFR is needed and nuclear is the best option available because it markedly reduces the amount needed.

Dunkelflaute

Dunkelflaute is a “German term that is used in the energy industry to describe a period of multiple consecutive days in which low or minimal energy can be generated by renewable energy sources, such as solar or wind”. Of course this describes the conditions that drive the need for DEFR.

In response to comments I submitted on this topic to the Proceeding on Motion of the Commission to Implement a Large-Scale Renewable Program and a Clean Energy Standard – Zero Emissions Target Case No. 15-E-0302author Leonard Rodberg sent me the following information:

Your analysis of the frequency of overcast and wind lull (“Dunkelflaute”) conditions is impressive and important. However, there are much larger problems with the State’s renewable-focused plan which they and everyone else seem to be ignoring.

On many winter nights in a fossil-free 2040, there will only be wind and the remaining nuclear and hydro to power the grid. No sun, of course, and batteries uncharged since there’s no excess power during the day to charge them. The result will be many nights when the grid shuts down unless a gap-filling clean firm source is available.

In fact, it’s even worse than that. Both NYSERDA and NYISO project winter peaks of 46-50 GW, but even with their projected wind power at its peak output, there’s just 35 GW available (see the graph below). No one seems to have bothered to add these up, and the model they’re using hides it .

The gap is large and is present much of the year. I’ve used an hourly dispatch model to show what’s really likely to happen in that situation. It’s shown and explained here. (This is a reference to the report described in this article.)

I included this because I think it reinforces the position I wanted to publicize. DEFR is necessary and the State’s analyses are not treating it well.

Conclusion

I concur with the report conclusion:

We have shown, with a modeling tool capable of performing an hour-by-hour analysis, that

dispatchable emission-free resources are essential to meeting the goal of a reliable, zero-emission grid. Further, this clean dispatchable source must be able to run a large portion of the year. The only such source likely to be available within the next several decades is nuclear power. The state will further benefit from the deployment of additional baseload nuclear power. This combination of nuclear resources will be more cost-efficient and environmentally-protective than an alternative focused on intermittent weather dependent sources.

Finally note that is another analysis that destroys the Climate Action Council argument that New York can rapidly move away from fossil fuels and instead be fueled completely by the power of the wind, the sun, and hydro using technologies available at this time. That is simply not true.

Initial Impression of Clean Energy Standard Biennial Status Report

The Climate Leadership & Community Protection Act (Climate Act) requires that the Public Service Commission (PSC) issue a 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 recently released Clean Energy Standard Biennial Review Report contains a lot of information that will be addressed in future posts. This post provides my first impression of the document. Spoiler – there is no chance that the 2030 mandate for the 70% renewable electric energy will be met.

I have followed the Climate act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 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 company 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 2030 reduction target of a 40% reduction by 2030, a requirement for 70% renewable energy for electric production by 2030, and a requirement that all electricity generated be “zero-emissions” 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 Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies. That material was used to develop the Draft Scoping Plan outline of strategies. After a year-long review, the Scoping Plan was finalized at the end of 2022.

Biennial Report

The Introduction to the report states:

The Climate Leadership and Community Protection Act (CLCPA) of 2019 requires that the Public Service Commission (PSC) issue a 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.” This Report serves to inform the Commission’s review. It summarizes the progress made toward the renewable energy and zero emission goals set by the CLCPA since the establishment of New York State’s Clean Energy Standard (CES), assesses what remains to be done to achieve those goals, presents policy options and proposals, and invites comments from stakeholders and the public on these or any other matters raised in this Report. The Report focuses in particular on New York’s goal to obtain 70% of New York’s electricity from renewable sources by 2030 (the 70% goal) and the related goal of 9 gigawatts (GW) of offshore wind by 2035.

The footnote for the first sentence states: PSL §66-p(3). PSL §66-p(4) provides the Commission with authority to “temporarily suspend or modify” the obligations created by the Program if, after conducting a hearing, it finds that the Program “impedes the provision of safe and adequate electric service,” “is likely to impair existing obligations and agreements,” and/or is related to “a significant increase in arrears or service disconnections.” The Introduction goes on:

Section 1 identifies the key regulatory actions taken to date to support renewable energy deployment in New York, including the establishment of the CES. Section 2 summarizes progress to date in achieving the CLCPA and CES goals in terms of current contributions of operational renewable energy systems and zero-emission sources to the State’s energy portfolio. Section 3 offers a detailed assessment of major factors that have affected and will likely continue to affect progress towards the goals. Section 4 reports on the pipeline of contracted renewables from previous Tier 1 and offshore wind solicitations. Section 5 accesses the amount of renewables that would need to be procured, under the CES or a modified version of the program, to achieve the 70% goal and recommends adjustments to NYSERDA’s procurement authorization that may be necessary to do so. Section 6 considers other programmatic options for accelerating development and construction of renewable energy resources. Policy options and proposals under consideration in this Report are limited to the CES itself.

I could do a post on each section and may end up doing that. It is encouraging that the PSC acknowledges the safety valve mechanism in Public Service Law §66 that I have mentioned on many occasions. Optimistically could this signal recognition that if the aspirational scheduled mandates of the Climate Act are not feasible that the schedule must be modified?

Progress to Date

Section 5 summarizes the “Path to the 70% goal”. The description of the Table 8 “Summary of progress” states:

Under the base case load forecast assumption of 164,910 GWh by 2030 as described above, the 70% goal equates to 115,437 GWh. Table 8 below summarizes the contributions towards the goal from currently operational and contracted renewables, as set out above in Section 2 and Section 4 of this Report. In addition, it projects 10 GW of distributed generation by 2030 secured outside the CES framework.

I will follow up with a post addressing the assumptions used to calculate the numbers in Table 8. Sections 2 and 4 described how operational and contracted/awarded renewable estimates were projected and that discussion is also worthy of its own post. At this time it is notable that one of the key points in the report is the admission that contracted projects don’t always get built.

The report describes Table 8:

With these conservative assumptions, the expected amount of renewable generation from operational and awarded/contracted sources in 2030 totals 73,292 GWh. Under the base case forecast for the 2030 statewide electric load, there is a renewable energy supply deficit of 42,145 GWh that would have to be addressed through future procurements in order to reach the 70% goal amount of 115,437 GWh.

Consider these numbers in context. There is an admitted gap of 42,145 GWh which is greater than the total operational renewable generation in 2022, 2022 imports and operational after 2022 (37.692 GWh). Trying to cover that gap is an ambitious challenge.

2030 Projected Renewables

The Biennial report proposes to double down on building renewables to cover the gap and meet the target.

To fill the expected gap, three Tier 1 annual solicitations – those for 2024, 2025, and 2026 – are currently scheduled and will seek projects capable of deploying by 2030. However, the amounts procured in these solicitations would need to be adjusted to secure the needed quantity of 42,145 GWh. The analysis suggests NYSERDA would have to procure approximately 14,048 GWh per solicitation, assuming no project attrition, or, assuming a 30% attrition rate, an amount of 20,068 GWh per solicitation. This volume is significantly higher than the annual procurement quantity of 4,500 GWh per Tier 1 solicitation (before attrition) estimated in the 2020 CES White Paper and 2020 CES Order.

The best efforts of the State to date for renewable solicitations are far lower than what is needed. The report admits that “the maximum annual new project development rate would likely be in the range of 6,000-7,000 GWh per year at least in the near term” and that is contingent on meeting a number of conditions. Table 9 below describes what the report argues is feasible.

Even under the revised assumptions the PSC projects that the 70% renewable energy goal will not be achieved until 2033 when the historic renewable resource deployments are considered.

Conclusion

The State has never done a feasibility analysis to prove that their plan to rely on wind and solar will work. The Climate Act deadlines were set arbitrarily by politicians so achieving that is another level of wishful thinking.

Get out the popcorn. Reality is catching up to the Climate Act net-zero transition. This report is the first indication that things are not going as planned. How will the Hochul Administration handle the obvious need to relax the deadlines?

Stay tuned for future articles on this important report.

Pew Research: How Americans View National, Local and Personal Energy Choices

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

According to Pew Research, Americans still want renewable energy, but support is waning. This comes as the impacts of the Climate Leadership & Community Protection Act (Climate Act) are becoming clear. It would be interesting to see a similar poll for New York residents.

Overview

How Americans View National, Local and Personal Energy Choices

The Pew Research Center released the results of its survey on June 27, 2024

How Americans View National, Local and Personal Energy Choices

Most Americans want more renewable energy, but support has dipped. Interest in electric vehicles has also declined

By Alec Tyson and Brian Kennedy

The planet’s continued streak of record heat has spurred calls for action by scientists and global leaders. Meanwhile, in the United States, energy development policy is being hotly debated on the national and local levels this election year. How do Americans feel about U.S. energy policy options, and what steps are they willing to take in their own lives to reduce carbon emissions? A new Pew Research Center survey takes a look.

Among the major findings:

There’s been a decline in the breadth of support for wind and solar power. The shares who favor expanding solar and wind power farms are down 12 percentage points and 11 points, respectively, since 2020, driven by sharp drops in support among Republicans.

Interest in buying an electric vehicle (EV) is lower than a year ago. Today, 29% of Americans say they would consider an EV for their next purchase, down from 38% in 2023.

Still, a majority of Americans (63%) support the goal of the U.S. taking steps to become carbon neutral by 2050. When asked which is the greater priority, far more Americans continue to say the country should focus on developing renewable energy than fossil fuel sources (65% vs. 34%).

The survey, conducted May 13-19 among 8,638 U.S. adults, finds a fairly modest share of U.S. adults (25%) say it’s extremely or very important to them personally to limit their own “carbon footprint.” Far more give this middling or low priority.

These findings illustrate how large shares of Americans back more renewable energy that would decrease overall carbon emissions. Still, this general orientation does not necessarily translate into strong commitment to reducing personal carbon emissions or interest in buying an EV.

Maybe it is just me but the lead sentence claim that record heat is spurring action smacks of bias. I checked the description of how they did the survey to see if my concerns were warranted:

Pew Research Center conducted this study to understand Americans’ views of energy issues. For this analysis, we surveyed 8,638 U.S. adults from May 13 to 19, 2024.

Everyone who took part in the survey is a member of the Center’s American Trends Panel (ATP), an online survey panel that is recruited through national, random sampling of residential addresses. This way, nearly all U.S. adults have a chance of selection. The survey is weighted to be representative of the U.S. adult population by gender, race, ethnicity, partisan affiliation, education and other categories. Read more about the ATP’s methodology.

Here are the questions used for this report, along with responses, and its Methodology.

The questions used for the survey were not overtly biased. Nothing like “In order to save the planet from imminent doom are you in favor of solar farms?” My only reservation is that these questions were part of a bigger survey, so it is not clear if previous questions primed the pump towards climate impact alarm. One other point is that the methodology was different from most surveys. Instead of a phone survey the Pew Research Center has established the American Trends Panel “a nationally representative panel of randomly selected U.S. adults who participate via self-administered web surveys.” I have no opinion if this affects survey results.

Rather than just provide the results of the survey the Pew website description addresses the question of what’s behind the declines in support for wind and solar.

Declines in public support for renewable energy have been driven by Republicans and Republican-leaning independents, whose support started to fall sharply after President Joe Biden took office in early 2020.

64% of Republicans say they favor more solar panel farms, down from 84% in 2020.

56% of Republicans say they favor more wind turbine farms, a 19-point drop from 2020.

Over this same time period, views among Democrats and Democratic leaners on these measures are little changed, with large majorities continuing to support more wind and solar development.

In some cases, gaps between Republicans and Democrats over energy policy now approach the very wide partisan divides seen over the importance of climate change.

In May 2020, Democrats were 26 points more likely than Republicans to say the country’s priority should be developing renewable energy (91% vs. 65%). Four years later, that gap has ballooned to 49 points, due almost entirely to changing views among Republicans – 61% of whom now say developing fossil fuels like oil, coal and natural gas should be the more important priority.

However, the authors do admit that it is not just political affiliation:

But changes in attitudes about policies that would reduce carbon emissions are not solely the result of more negative views among Republicans. For instance, the share of Democrats who say they are very or somewhat likely to consider an EV for their next car purchase has declined from 56% to 45% in the last year. And the share of Democrats who call climate change a very big problem for the U.S. has declined from 71% in 2021 to 58% today.

New York’s Climate Leadership & Community Protection Act (Climate Act) mandates massive changes to the energy choices of New Yorkers that require action today. I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition. One over-riding conclusion based on my work and discussions with others who share my concerns is that the majority of New Yorkers have no clue what is coming at them.

Nationally the mandates and potential impacts are much less imminent, I believe that a big part of the decline in support of wind and solar is increased knowledge. The survey includes more detailed questions regarding solar developments – Would solar development make the landscape unattractive, take up too much space, bring in more tax revenue, and lower the price you pay for electricity. I believe that answering those questions requires personal knowledge and in my personal experience it has only been in the last several years that I have seen solar developments. Having seen them I doubt many would think they are attractive and do not take up too much space. The more knowledge people have the lower the favorability in my opinion.

The survey also addresses electric vehicles.

Amid a major policy push at the federal level for electric vehicles, Americans are unenthusiastic about steps that would phase out gas-powered vehicles.

In March of this year, the Biden administration announced a rule aimed at dramatically expanding EV sales. Overall, 58% of Americans say they oppose these rules that would make EVs at least half of all new cars and trucks sold in the U.S. by 2032. Republicans overwhelmingly oppose this policy (83%). Among Democrats, 64% support these rules to expand EV sales, while 35% say they oppose them

Source: https://www.pewresearch.org/science/2024/06/27/how-americans-view-national-local-and-personal-energy-choices/

In support of my belief that knowledge spurs skeptical concerns note the following results for a question about EV reliability:

As more people hear about electric vehicle experiences the reality of problems with the technology become evident.

The survey also included questions about personal carbon footprints.

Discussions about reducing carbon emissions often include the everyday actions people can take to reduce the amount of energy they use. One-in-four Americans say it is extremely or very important to them personally to limit their own “carbon footprint.” Larger shares say this is either somewhat (42%) or not too or not at all (32%) important to them.

There is one important aspect of energy choice that was not included in the survey. What about the costs? The follow up questions for wind and solar development included a question asking whether respondents thought that those developments would reduce electricity prices. There were also questions about electric vehicle cost to purchase and refuel them. Nothing about overall costs was included. I have yet to see a poll that indicates that people are willing to pay much for the energy transition being forced down our throats.

The description of the survey claims that “large shares of Americans back more renewable energy that would decrease overall carbon emissions.” It also admits that “this general orientation does not necessarily translate into strong commitment to reducing personal carbon emissions or interest in buying an EV”. If the willingness to pay aspect had been incorporated into the poll, I have no doubts that support for wind and solar would drop significantly. I am confident that as more people become aware of the hidden costs of renewable energy the inevitable result will be much less support.

New York Power Trends Report

Recently the New York Independent System Operator (NYISO) released the latest edition of Power Trends 2024. This is the NYISO’s annual analysis of factors influencing New York State’s power grid and wholesale electricity markets. This post highlights some of the key points made.

Overview

Power Trends includes a letter from the NYISO CEO Rich Dewey. He highlights concerns about the Climate Act and grid:

New York’s public policies are increasingly prioritizing clean energy production and a rapid transition away from fossil fuels. It is imperative that during this time of rapid change we maintain adequate supply necessary to meet growing consumer demand for electricity. Power Trends shows that achieving this balance will be the central industry challenge over the next decade.

The NYISO power assessment information includes: Power Trends Resources is the landing page for documentation, Power Trends 2024 is the report itself, and there is a Power Trends Fact Sheet. The report notes:

The shift from fossil fuel-based generation to clean energy resources is advancing with a quickening pace. At the same time, consumer demand for electricity is increasing as state policies decarbonize the building and transportation sectors and attract large economic development projects to New York. The successful transition of the electric grid depends on the careful balance of reliable energy supply with the forecasted increase in demand.

NYISO planning must address public policies intended to drive rapid change in the electric system in the state, impacting how electricity is produced, transmitted, and consumed. There are two Climate Act direct drivers for the electric system. In addition to the requirement that all electricity generated be “zero-emissions” by 2040 there is a mandate that the electric grid be 70% renewable energy by 2030.

This article highlights the following challenges raised in the report: status of the system, electrification challenges, Climate Act schedule, the interconnection process, the technology required, and the electric market.

Status

Power Trends included a discussion of the present status of the electric systems. It concludes that “electricity supplies are adequate to meet expected summer demand under normal conditions, but extreme weather and other factors pose reliability risks.” In a recent post about the June heatwave I quoted the following from the Summer 2024 reliability outlook:

For summer 2024, the NYISO expects 34,913 MW of resources available to meet 31,541 MW of forecasted demand under normal conditions. Under extreme summer weather conditions, however, forecasted reliability margins could potentially be deficient without reliance on emergency operating procedures. For example, if the state experiences a heatwave with an average daily temperature of 95 degrees lasting three or more days, demand is forecasted to rise to 33,301 MW, while predicted supply levels are reduced to 34,502 MW. When accounting for the required 2,620 MW of operating reserves that must be maintained, this scenario results in a forecasted reliability margin of -1,419 MW. That reliability margin declines further to -3,093 MW under an extreme heatwave with an average daily temperature of 98 degrees. Under these more extreme summer weather conditions, the NYISO forecasts an available supply of 34,317 MW to meet the required 2,620 MW of operating reserve requirements, plus a forecasted demand of 34,790 MW.

The Climate Act strategy to reduce building emissions through electrification will eventually shift the peak loads to winter. In the meantime, there are potential issues. The report notes that “On the coldest days, the availability of natural gas for power generation may be limited and significant interruptions to natural gas supply can disrupt reliable operations.” In addition, electric planners across the country as well as New York are dealing with “evolving challenges and considerations for ensuring power system reliability under extreme winter conditions.” The increased reliance on natural gas is a problem when there is intense cold weather because it stresses gas networks and electricity grids across the nation. An unintended consequence of the shift from coal to natural gas is the loss of electricity generated by facilities with on-site storage. Now there is reliance on the gas network and something else that can go wrong. New York addresses this with dual-fueled units that can burn oil stored on-site.

The last Power Trends status issue is declining reliability margins as illustrated in the following figure. As noted, this is mostly because fossil units are retiring faster than the zero emissions replacements are coming on-line. In addition, the New York Department of Environmental Conservation (DEC) is pressuring existing power plants to reduce emissions or shut down and they have rejected several applications to replace existing old generators with modern new facilities because of the Climate Act. Unfortunately, there is no direct link between the proposed facilities and a particular reliability issue. As a result, the permit decisions were considered in isolation and the permits were rejected exacerbating the declining reliability margin.

Electrification Control Strategy

The Power Trends report addresses the trend for higher electric loads. The primary Climate Act emissions reduction strategy is to electrify everything possible using zero-emissions electricity. In addition, economic development initiatives are driving projected demand higher. The following graphic describes the proposed energy-intensive projects. Not included is the potential for new data centers needed to power the artificial intelligence applications coming out.

As shown below, the New York statewide grid is projected to become a winter-peaking system in the 2030s, primarily driven by electrification of space heating and transportation. This means that the focus on future generating sources will have to change. In particular, the value of solar resources is lower during the shorter days of winter and reduced solar intensity due to lower sun angles. Moreover, there is the potential for even more reductions if solar panels are covered in snow.

Schedule

The Climate Act was promulgated without consideration of feasibility. Nowhere is this more impactful than with respect to the schedule. A rational New York energy plan would implement the zero-emission resources before retiring existing generating resources. New York is not rational. Despite the obvious delays in construction of new supply and transmission due to a whole host is issues the Hochul Administration has not broached the possibility of postponing any Climate Act targets.

The Power Trends report includes a description of their reliability planning process. Four reports are included:

Short-Term Assessment of Reliability (STAR): Conducted every quarter to assess reliability needs within a five-year horizon to determine whether the grid will be able to supply enough power to meet demand.
Reliability Needs Assessment (RNA): Evaluates the reliability of the New York bulk electric system considering forecasts of peak power demand, planned upgrades to the transmission system, and changes to the generation mix over the next ten years.
Comprehensive Reliability Plan (CRP): integrates STAR reports and the most recent RNA, resolves any identified reliability needs and develops a ten-year reliability plan.
System and Resource Outlook (Outlook): The Outlook will provide a comprehensive overview of system resources and transmission constraints throughout New York, highlighting opportunities for transmission investment driven by economics and public policy over a 20 year period.

Implementing the resources necessary to meet the Climate Act is not just a matter of building as many zero-emissions resources as possible as soon as possible. These reliability planning reports indirectly affect the implementation schedule. The process identifies specific issues which triggers a procedure to address them. All that takes time. The bigger issue is NYISO’s interconnection process. Before any generator can be added to the electric grid NYISO has to evaluate its impact. This process is so important that it was highlighted.

Improving the interconnection process

The Power Trends report notes that “NYISO’s interconnection processes continue to evolve to balance developer flexibility with the need to manage the process to more stringent timeframes.” NYISO is trying to speed up the turnaround time and make the process more efficient while protecting grid reliability. The report notes:

Driven by state and federal policies, an unprecedented number of renewable and clean energy projects are entering our interconnection queue. In 2019, there were 275 projects in the queue. Today, more than 500 projects are under consideration. Recent enhancements to our processes, interconnection team, and technology have led to measurable improvements.

There is another complication. Wind and solar project electric out has different characteristics than fossil-fired units. The Federal Energy Regulatory Commission’s Order 2023 addresses those differences and NYISO is incorporating that order into their processes. They hope that “Those reforms will further shorten the total study period while maintaining a focus on system reliability.”

Despite these improvements it takes years from the time a company starts to develop a wind or solar project until it gets online.

DEFR

The Power Trends report describes a major technological issue:

Renewable energy generation, subject to sudden changes in weather, also provides new challenges to grid operators that must balance supply and demand in real time. These variables highlight the need for new generation technologies that can fill in when weather-dependent resources are unavailable. Such new technologies, collectively referred to as Dispatchable Emission Free Resources (DEFRs), must be dispatchable, emissions free, and able to respond quickly to changing grid conditions. Such technologies do not exist yet on a commercial scale.

The NYISO described this resource in the last System and Resource Outlook:

DEFRs are a classification of emission- free resources that provide the reliability attributes of synchronous generation and can be dispatched to provide both energy and capacity over long durations. DEFRs must be developed and added to the system at scale to reliably serve demand when intermittent generation is unavailable. The lead time necessary for research, development, permitting, and construction of DEFR supply will require action well in advance of 2040 if state policy mandates under the CLCPA are to be achieved.

Both descriptions closed with the caveat that these resources do not exist. I described other DEFR issues raised at a Department of Public Service technical conference last December. The report statement that research and development are required before permitting and construction can begin underscores the scheduling challenge that this resource entails.

Markets

When the New York electric system was de-regulated the NYISO was formed to operate the electric system. To transition the electric markets to meet the Climate Act mandates the NYISO must attract necessary investments. The report explains:

Managing wholesale electric markets is a core responsibility for the NYISO. We are committed to administering and overseeing the competitive electricity markets as the most cost-effective way to attract and retain new resources to meet our reliability needs as we transition to a decarbonized grid.

For 25 years, competitive electricity markets have provided New Yorkers with reliable, least- cost power. Since 2000, the carbon dioxide emissions rate in the power sector decreased by 45%. Competitive markets produce real-time price signals that allow power suppliers to respond to the grid’s changing needs. With ever-increasing intermittency, extreme weather, and demand from electrification and economic development, the balancing force of markets is essential.

Our market design team is hard at work developing new tools and programs to encourage investment in resources that are fast-ramping, flexible, dispatchable, and emissions-free ― resource characteristics that are becoming increasingly important for grid reliability.

It is not surprising that NYISO places great faith in markets given that they are the reason for its existence. However, even market advocates must admit that developing the market for DEFR and all the other components of the grid needed for the transition adds another layer of complexity. It is not only that a new resource has to be developed but now the NYISO has to develop some sort of market mechanism to ensure that it is available when it is needed. Given the likely high costs for this new technology and the expected low utilization rate that is a serious challenge.

Discussion

The Power Trends report explains that Climate Act mandates on the electric system will drive electric system planning and development efforts through 2040. It notes that “The successful transition of the electric grid depends on the careful balance of reliable energy supply with the forecasted increase in demand.” The NYISO reliability planning analyses are based on decades of experience with dispatchable resources. Balancing demand with weather-dependent resources is an extraordinary test for the Climate Act schedule.

In its review of the status of the system NYISO notes important reliability caveats. An extended heatwave or limits on natural gas in winter could cause problems today and New York energy policies are reducing options to address those concerns. New York energy policy eliminated coal-fired generation and environmental requirements have reduced the number of facilities that provide peaking power. State policy has also restricted the development of more natural gas pipelines that directly contributes to increasing risk for the problems noted.

The report also describes potential scheduling issues but does not explicitly compare the real scheduling issues with the aspirational schedule. Other NYISO reports have projected that the number of new resources needed to meet the Climate Act mandates is unprecedented. Despite obvious delays in deployments today for reasons (e.g., supply chain issues, lack of trade personnel, and inflation) that show no sign of abating, the NYISO has not broached the idea that delays should be considered. This report describes interconnection issues and the requirement for a new resource that must be developed from scratch that exacerbate the problem.

Finally, market mechanisms must be developed to encourage the investments necessary to deploy all these resources. Despite the optimism of NYISO I suspect that investors are going to be reluctant to jump into the New York market without guarantees. All that uncertainty adds to potential costs and time to deploy resources.

There is an overarching issue unrecognized by the State and not addressed in this report. The NYISO resource adequacy planning process is based on decades of experience with independently operating generators. Probabilistic estimates of their performance are used to evaluate reliability standards. There is no expectation that many of the facilities will not be available at the same time. The proposed Climate Act transition to wind and solar resources changes that paradigm. Weather-dependent resources are highly correlated in space and time, and this is the reason DEFR is needed. The unresolved issue is that the worst-case wind and solar resource lull is very rare. Deploying sufficient DEFR to provide adequate resources based on the historical worst-case is likely impractical. However, if society does not develop those resources, then when those weather conditions inevitably reoccur in the future, there will be a catastrophic blackout.

Conclusion

The Power Trends 2024 report provides an excellent overview of New York State’s power grid and wholesale electricity markets. Unfortunately, NYISO does not consolidate all the warning signs about Climate Act implementation, nor does it call out state policies that are exacerbating problems.

Ultimately the problem is that New York has no comprehensive energy plan. The Scoping Plan is just a list of technologies that describe an electric system that is zero-emissions. However, there is no feasibility study that shows how it will work nor has the Hochul Administration reconciled the differences between the Integration Analysis and NYISO resource outlooks. As it stands now the apparent Administration plan is to build as many wind and solar facilities as possible and hope someone works out how they are supposed to be integrated into the electric system. When that does not work, I predict the NYISO will be fall guy.

The only way to ensure the safety of New Yorkers is to do a demonstration project that proves that an electric system that relies on wind and solar will work. A poor second choice would be a comprehensive feasibility analysis that reconciles the Integration Analysis and NYISO analyses. Failing to do either is planning to fail.

June 2024 Update on the New York Cap-and-Invest Plan

In the first two months of 2024 the New York State Department of Environmental Conservation (DEC) and the New York Energy Research & Development Authority (NYSERDA) worked on the New York Cap-and-Invest (NYCI) Program stakeholder engagement process requesting comments on the pre-proposal outline of the regulations. Since then, there have not been any signs of progress. This post describes my recent letter to the editor published at Syracuse.com.

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 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” In brief, that plan is to electrify everything possible using zero-emissions electricity. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies. That material was used to develop the Draft Scoping Plan outline of strategies. After a year-long review, the Scoping Plan was finalized at the end of 2022. Since then, State agencies and the legislature have been attempting to implement the plans.

Cap-and-Invest

The Climate Action Council’s Scoping Plan recommended a market-based economywide cap-and-invest program. The program works by setting an annual cap on the amount of greenhouse gas pollution that is permitted to be emitted in New York: “The declining cap ensures annual emissions are reduced, setting the state on a trajectory to meet our greenhouse gas emission reduction requirements of 40% by 2030, and at least 85% from 1990 levels by 2050, as mandated by the Climate Leadership & Community Protection Act (Climate Act).” In addition to the declining cap, it is supposed to limit potential costs to New Yorkers, invest proceeds in programs that drive emission reductions in an equitable manner, and maintain the competitiveness of New York businesses and industries. The stakeholder engagement process was supposed to refine the proposal, DEC will and NYSERDA will propose regulations by summer, and the final rules are supposed to be in place by the end of the year.

Late last year DEC and NYSERDA released the pre-proposal outline of issues that included a long list of topics. The Agencies said that they were “seeking and appreciate any feedback provided on these pre-proposal program leanings to inform final decisions in the State’s stakeholder-driven process to develop these programs.” In a post describing my comments I provided additional background information.

Letter to the Editor

Because I knew that NYCI would eventually get released I contacted the editorial staff at the Syracuse Post Standard weeks ago with a proposed commentary (800-word limit). After no response to that I submitted a letter (250-word limit) and that was published. In the following I will annotate the letter with background and reference information.

The published letter points out that Governor Hochul’s recent decision to pause implementation of the New York City congestion pricing was based on costs. I believe that the costs of the Climate Act should be considered in the same light.

On June 7, 2024, Gov. Kathy Hochul explained why she reversed the decision to proceed with the New York City congestion pricing plan, stating: “Now my job is not to make it harder or more expensive for New Yorkers to live in our state — working hard, make ends meet, raise their families.” The ultimate question is whether this concern also should be raised relative to the Climate Leadership & Community Protection Act (Climate Act).

With the word limit it was impossible to provide much detail on the NYCI plan.

This summer, her administration will be rolling out an economy-wide cap-and-invest plan to fund Climate Act decarbonization projects. The New York Cap-and-Invest (NYCI) Program is simply a tax on carbon. It will require large-scale distributors of heating and transportation fuels to purchase permits to pay for carbon emissions in the fuels they sell. Those costs will be passed on to consumers.

At the Energy Access and Equity Research webinar sponsored by the NYU Institute for Policy Integrity on May 13, 2024 Jonathan Binder stated that the New York Cap and Invest Program would generate proceeds of “between $6 and $12 billion per year” by 2030.

Administration officials estimate that NYCI auctions will generate “between $6 [billion] and $12 billion per year” by 2030. The New York City congestion pricing program was projected to raise $1 billion per year.

I used the example of gasoline costs for consumer impacts.

Consider gasoline costs. The current NYCI proposal outline analyzed allowance prices starting at $23 per ton of CO2 in 2025 with 5% escalation for 2026, and an increase to a higher ceiling in 2027, escalating by 6% annually thereafter. According to the U.S. Energy Information Administration, 17.86 pounds of CO2 are emitted per gallon of finished motor gasoline; 112 gallons burned equals 1 ton of CO2. A price of $23 per ton of CO2 translates to an increase in gasoline prices of 21 cents per gallon in 2025, 48 cents per gallon in 2027 and 57 cents per gallon in 2030.

Faced with the word limit, I concluded that New Yorkers want to know how much this will cost.

Raising the cost of fuel makes it harder to make ends meet. It is time to demand a transparent accounting of all Climate Act costs.

Commentary Version

In the longer version that was rejected I made some other points.

I pointed out that there are significant unaddressed issues and insufficient documentation to verify that it will not adversely affect energy affordability. Everyone wants a cleaner, greener, safer planet, but not at the cost of a decent standard of living and quality of life. There are unacknowledged tradeoffs associated with the Climate Act requirements that its supporters are covering up. Everyone has a different tolerance for these tradeoffs but resolving them requires much more information than is presently available. The state needs to provide the public with a clear New York Cap-and-Invest (NYCI) roadmap to achieve the 2030 targets, including additional emission reduction mandates, their costs, and how they will be paid for.

I also included information based on the comments I submitted. NYCI proponents argue that similar programs are a “well-tested mechanism for addressing climate change.” Past performance does not guarantee future success especially as the NYCI proposal contains significant revisions to earlier programs. Differences include proposals for limitations to trading and banking of allowances included in previous programs, emission reduction schedules in NYCI that did not include any evaluation of practicality, and a mandate to reach zero emissions.

I am convinced that affordability is the main concern of New Yorkers, so I addressed that in more detail. No price adder can drive emission reductions at existing sources because control technology to go to zero emissions does not exist. The only control strategy available is to displace fossil fuel usage with a different technology. The entities responsible for NYCI compliance do not control the deployment of the replacement technology and determining the market price necessary to incentivize their development is uncertain. If the 2030 allowance price is $64.31 the total auction proceeds will be $10.9 billion. There is a state law that mandates that 30% or $3.3 billion will be allocated to the Consumer Climate Action Account. The NYCI outline proposes that 63% or $6.8 billion be dedicated to clean energy investments. The State has not provided an analysis that specifies affordability targets or the requirements for the zero-emissions technology necessary to displace existing fossil fuel use.

There is another underappreciated NYCI risk that I included in the commentary. The allowances available for auctions will be determined by the Climate Act targets. If insufficient investments are made for the deployment of replacement zero-emissions technologies or there are issues that delay implementation, then the emissions will not decrease at a rate consistent with allowance availability. Without a safety-valve provision, the only compliance option available is to stop burning fossil fuels. If gasoline distributors, for example, think they have insufficient allowances near the end of the year they would stop selling gasoline. Fortunately, the NYCI outline proposal includes a safety valve provision that will prevent an artificial energy shortage.

Even though there is a safety valve mechanism included, climate activists have argued that is inappropriate. Their ideological position is inconsistent with reality. In 2021 CO2 emissions in the Chinese energy sector increased by 400 million tons. Total New York GHG emissions for all greenhouse gases and all sectors in 2021 were 268 million tons. If the safety valve provision is needed it will only cover a small fraction of the total NY emissions. Insistence on meeting an arbitrary cap when annual emission increases elsewhere are greater than total NY emissions is not in the best interest of New Yorkers.

Conclusion

To meet the promise that NYCI implementing regulations would be in place by the end of the year, the proposed regulations have to be released soon. I think that the process has been delayed in large part because DEC has staffing issues. From what I understand the California environmental agency had ten times more staff working on the project and took longer than the time available to meet the end of the year target. This is a very big ask for DEC.

I have no idea whether the pre-proposal outline will have significant changes. The climate activists have made their position known and the Hochul Administration has given them pretty much whatever they have demanded in the past. The pragmatic inclusion of a safety valve will ensure that there are consumer safeguards in place but I am not confident it will make the final draft.

Madison County Wind Farm – Theory vs. Results

I recently stumbled upon an old New York State Energy Research and Development Authority report describing the first New York industrial wind facility. This post compares the projections for the facility with the observed performance.

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 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” In brief, that plan is to electrify everything possible using zero-emissions electricity. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies. That material was used to develop the Draft Scoping Plan outline of strategies. After a year-long review, the Scoping Plan was finalized at the end of 2022. Since then State agencies and the legislature have been attempting to implement the plans.

Madison Wind Farm

According to its Wikipedia page:

The Madison Wind Farm is a power generation plant located in the town of Madison, New York. Constructed in 1999-2000, it was the first wind farm completed in New York state and the first merchant wind farm in the country. The power plant consists of seven Vestas V66-1.65 MW wind turbines,^[1] generating enough energy to power up to 10,000 homes. The Vestas V66-1.65 MW wind turbines have a hub height of 67m and a 66m rotor diameter totally 100m to the top of the rotor

It is now owned by EDP renewables. There have been maintenance issues and talk of decommissioning but could not find anything to confirm that.

The Madison Windpower Project Final Report was prepared for NYSERDA by AWS Scientific, Inc. December 2003. The Abstract for the report stated that:

This report covers the development and operation of the Madison Windpower Project in Madison County, New York developed by PG&E Generating. The project began commercial operation in October 2000 and consists of seven Vestas V66-1.65 MW OptiSlip® wind turbines for a total capacity of 11.55 MW. Long term wind resource estimates predicted an annual hub-height average wind speed of 7.3 m/s. The net annual plant energy production was predicted to be 23,621 MWh, which would produce a capacity factor of 23.3%. The wind turbines were dispatched and controlled from the PG&E Pittsfield operations center, which was also responsible for substation maintenance. Vestas took charge of inspection, adjustment, and repair of the turbines (both scheduled and unscheduled) and established an operations and maintenance facility in the Madison area. The wind plant produced a total of 61,379 MWh of electricity for three years for an annual average of 20,460 MWh and an overall capacity factor of 21%. The capacity factor is lower than the expected value of 23.3% primarily due to lower than predicted wind speeds and turbine and grid outages.

Observed Operations

The New York Independent System Operator (NYISO) prepares a report describing load and capacity data for all New York generating units that participate in the electric market. Universally known s the “Gold Book” it is the best reference for New York electric generation data. The 2024 Load & Capacity Data Report presents load and capacity data for 2024 and future years. To prepare this summary of Madison Wind Farm operations I relied on a compilation of observed data from Gold Book reports dating back to 2006.

The following table lists the observed net energy (GWh) and capacity factors from 2006 to 2023 and the projections made in 2003 by AWS. In that analysis the observed capacity factor was 21% in the first three years. Since then, only one year achieved that level and the last three years the capacity factor was less than 14%. AWS projected that 425 GWh would be produced since 2006 but the energy produced by this facility was only 332 GWh, 22% less.

Table 1: Madison Wind Farm Performance Based on NYISO “Gold Book” Load & Capacity Data Report Table III-1 Including AWS 2003 Projections

The Conclusion of the AWS report summarizes the key findings:

The experience at Madison shows that the energy production from a wind facility is primarily dependent on the actual wind experienced and the performance and reliability of the turbines. The Vestas V66 turbines performed well when they were online because they produced the expected amount of energy for a given windspeed. However, the actual wind speeds experienced during the period and the reliability of the turbines were both lower than expected.

The wind speeds were lower than expected due to the incomplete meteorological record used to predict the wind resource, the lower-than-average wind speeds in this region of the state during plant operation, and the difference in elevation of the project met towers. This experience demonstrates the need to have sufficient long-term meteorological data in order to predict a wind plant’s energy production accurately. Continued evaluation of the projected wind speeds during plant operation can clarify trends and enhance understanding of the site’s wind resource. As such, it is expected that the overall wind resource at Madison will be more favorable during the lifetime of the plant.

The reliability of the machines was lower than expected due to the gearbox failures and other component difficulties discussed earlier in the report. These failures highlight the need for robust turbine reliability warrantees to protect turbine owners against loss of revenue in the case of such unexpected turbine component failures. On the positive side, excellent lightning protection in the V66 resulted in fewer outages due to static discharge than have been observed at other sites.

Discussion

As the first industrial wind facility Madison Wind Farm performance was evaluated in the AWS project. The report claims that it was a successful demonstration of large-scale wind development. I agree that it provides power and the information learned from it has been used to integrate other projects. However, I have concerns about the poor availability and decreasing capacity factors.

It was obvious at the time of the analysis that the projected capacity factor was lower than projected. The report argues that this was due to inadequate meteorological monitoring but optimistically notes the wind resource will be “more favorable during the lifetime of the plant”. That did not happen. The actual production since 2006 is 22% lower than they anticipated.

I think over-optimism is a characteristic of NYSERDA. The NYSERDA Integration Analysis projected a state-wide wind capacity factor of 29% in 2020 increasing to 34% in 2030. The Gold Book statewide capacity factor in 2020 was 23.9%. The Integration Analysis projected New York land-based wind in 2030 would generate 5,043 GWh but the actual production was only 4,162 GWh, 18% lower than they projected. In addition, the Integration Analysis did not acknowledge that as wind systems age their performance drops.

NYSERDA’s Integration Analysis quantified the generating resources that will be needed to meet the Climate Act mandates. However, comparison of observed and projected energy production shows that they have overestimated energy production which means that more wind capacity will have to be developed and that the costs will necessarily be higher than they projected. Unfortunately, there has not been any reconciliation between Integration Analysis projections and observations to refine their projections. This is in keeping with their complete lack of response to technical issues raised in comments on the Scoping Plan.

Conclusion

The performance of the first wind farm in New York is considerably less than projected. This is consistent with the observed and projected Integration Analysis 2020 statewide wind generation. These results should be used to refine the Scoping Plan but there is no indication that NYSERDA is considering such an effort. This is just one more example of the flaws hidden behind a veneer of political slogans that claim all is well with the Climate Act. Eventually it will become obvious that the Hochul Administration electric system “plan” is incompatible with reality. Unfortunately failing to address these issues promptly will increase costs and reliability risks