Climate Act – Page 25 – Pragmatic Environmentalist of New York

NYISO Resource Outlook Dispatchable Emissions-Free Resource

A recent article of mine summarized analyses describing a new category of generating resources called Dispatchable Emissions-Free Resources (DEFR) necessary for a future grid that depends upon wind, solar, and energy storage resources. Most analysts 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 Appendix F – Dispatchable Emission-Free Resources in the New York Independent System Operator 2023-2042 System & Resource Outlook (“Outlook”).

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 450 articles about New York’s net-zero transition. The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview

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

Dispatchable Emissions-Free Resources

In my Compendium of DEFR Analyses I summarized published posts describing DEFR that is highlighted as a concern in the NYISO Outlook. I described six analyses describing the need for DEFR: the Integration Analysis, New York Department of Public Service (DPS) Proceeding 15-E-0302 Technical Conference, NYISO Resource Outlook, Richard Ellenbogen, Cornell Biology and Environmental Engineering, and Nuclear New York.

The Overview in Appendix F – Dispatchable Emission-Free Resources describes the reason DEFR is needed:

Numerous studies have shown that a system comprised of intermittent renewable energy resources and short-duration storage (i.e. 4 and 8-hour capacity duration) that cycle daily can economically meet demand in most hours across a year.

Importantly NYISO is responsible for meeting demand at all times. Most of the time it is easy but there are times when it is not:

However, due to the seasonal mismatch in electricity demand and weather dependent production from wind and solar resources, there remains a significant amount of energy that must be shifted from the low net load intervals of the spring and fall seasons to the peak load times during the summer and winter months, as discussed in Appendix E: Renewable Profiles and Variability.

I described Appendix E previously. The data presented in Appendix E show that there are frequent periods when all the wind and solar resources are expected to provide much lower output than their rated capacity. It appears that planners must, at a minimum, account for a 36-hour period when all the land-based wind, offshore wind, and solar combined provide less than 10% of their rated capacity. The Overview goes on:

Advances in technological, economic, and modeling approaches are needed to better quantify and characterize the seasonal energy gap that remains to be served after the coordinated economic dispatch of renewables and storage resources. The NYISO seeks to improve the representation of this fleet segment in each of its successive study, while understanding that characterization of emerging technology implementation pathways can introduce its own uncertainty into the model. The NYISO continues to recognize that there is a need for supply beyond renewables and storage resources that can provide dependability supply during the summer and winter peak periods and when the output of renewable resources is low.

In the remainder of this article I will summarize the different sections of Appendix F – Dispatchable Emission-Free Resources.

Technologies

Appendix F in the Outlook evaluates three DEFR options that they believe represent the most likely viable approach but concede that there still are concerns even with these:

While DEFRs represent a broad range of potential options for future supply resources, two technology pathways being discussed as potential options for commercialization are: 1) utilization of low- or zero-carbon intensity hydrogen (typically generated by electrolysis derived from renewable generation) in new or retrofit combustion turbine or fuel cell applications or 2) advanced small modular nuclear reactors, which are currently seeking approval from the relevant regulatory bodies to design and operate these resources. Currently, both technologies have shown limited commercial viability on the proof of concept. Even assuming that they are commercially viable, there remains significant work in the implementation and logistics that must be overcome to economically justify transitioning the dispatchable fleet to some combination of new technologies in the next 15 years. Long-duration energy storage could potentially serve in the role of the modeled DEFRs in the Outlook. In many respects, long-duration energy storage closely mimics various hydrogen production and conversion pathways. Long-duration energy storage adds to load in many hours, similar to electrolysis production of hydrogen. However, a notable difference is that electrolysis production of hydrogen has a lower round-trip efficiency when injecting energy into the system compared to other long duration energy storage technologies under development.

I have a concern about these pathways. Hydrogen and advanced nuclear both “have shown limited commercial viability on the proof of concept”. Commercial viability is particularly important in New York’s deregulated environment because the State must entice some developers to risk an enormous amount of money to provide the necessary resources. Consider that “there remains significant work in the implementation and logistics that must be overcome to economically justify transitioning the dispatchable fleet to some combination of new technologies in the next 15 years”. As a result, I think the State is going to find it very difficult to convince anyone to take on the risk of either technology.

In its description of DEFR option Appendix F also notes “Understanding that many aspects of these technologies are currently unknown, and their capabilities and characteristics could change as more experience is gained, there is no standout leader among the options”. It goes on to conclude that “that a combination of resources and approaches will be needed to serve the role of the DEFR fleet”.

The Resource Outlook provides projections for future generating resources, so it needs to include some technology options. To fulfil this need and consider the uncertainties, the Outlook “modeled several generic DEFRs to represent the range of potential capital and operating costs. In particular, the Low Capital/High Operating cost (LcHo) and High Capital/Low Operating cost (HcLo) DEFRs modeled in this Outlook are informed primarily by hydrogen and nuclear technologies, respectively.”

Capital and Operating Costs

The models that NYISO uses to project future generating resource requirements necessarily incorporate costs. The capital and operating cost DEFR labels refer to high and low values but those are relative costs. This section of Appendix F provides some indications of costs but does not include expected costs to the consumers in the report. I think this information is very important, so I plan to return to this topic in a future post.

Because DEFR technologies are still in development the NYISO cannot use historical cost data. Instead, they used information from six different sources to estimate costs. The results are presented in the two following figures.

Figure F-1: Generator Capital Cost vs. Variable Operating & Maintenance, Fuel, and Emissions Costs

Figure F-2: Generator Capital Cost vs Fixed Operating & Maintenance Costs

I have also included a graph of Dispatchable Emission-Free Resources: 2040 Capacity and Generation from the NYISO Public Information Session presentation on 8/8/24

For what it is worth the following table provides values for the DEFR costs from these three figures. As noted, I will try to use these numbers to provide cost estimates in the future. Regrettably the NYISO report does not provide specific numbers.

DEFR Cost Considerations

This section in Appendix F presented some of the factors that must be addressed when considering costs. It explains that “since DEFRs are a developing technology, the first units built will likely be more expensive compared to similar DEFRs built thereafter”. The Outlook used capital costs representing a mature deployment and “first-of-a-kind costs are not explicitly included as assumed cost components in this study”. As the Outlook points out this means that “the costs for DEFRs in this Outlook are likely to be below the actual costs of the first DEFRs built on the system.”

The Outlook points out that nuclear small modular reactors (SMRs) are a “developing technology and therefore, have varying approaches to their design”. The theory is that “SMRs have the potential of reducing cost through the development and use of uniform designs”. Although this will lower capital costs capital costs will still be higher than other technologies. The expectation for DEFRs is that they will have low operating times and will ramp up and down. The Outlook notes:

Like large-scale nuclear power plants, SMRs can mitigate the risk of high capital costs with lower operating costs and operating with high utilization rates. In other words, it is optimal for an SMR to consistently operate at 100% power to take advantage of its low operating cost. This has the potential to conflict with the notion of DEFRs being used for their ability to dispatch up and down based on variability in the load. The disconnect between a DEFR’s purpose and an SMR can be bridged by pairing the reactor with a behind-the-meter, dispatchable load. The SMR can remain at 100% power, while the behind-the-meter load dispatches up or down to effectively fluctuate the injection onto the grid, as needed.

Unsaid is the obvious alternative that if SMT nuclear is viable then it could be used to replace renewables rather than just provide backup support. Nuclear energy generates zero-emissions electricity, provides firm power that does not require supplemental ancillary transmission support, has low land-use requirements, and requires less transmission development than wind and solar. Going all in for nuclear would not eliminate the need for a peaking power source but it may be possible to use hydro for that purpose. In a rational world keeping existing dual-fueled peaking plants available for this purpose would be an option too.

The Outlook also addresses hydrogen:

Hydrogen-burning combustion turbines or combined cycle units have effective cost mitigation strategies as well. To minimize hydrogen transport costs, the electrolyzer can be sited at the same facility as the resource. This eliminates the need for using an expensive hydrogen pipeline to import the hydrogen from elsewhere in state or even out of state. Additionally, as fossil fuel burning combustion turbines and combined cycle units retire, their assets can be repurposed and retrofit to burn hydrogen as a fuel instead. This has the potential to be less expensive than building a brand-new resource since many elements of the combustion turbine or combined cycle power plants can be reused with limited modification.

One of the more difficult electric system reliability problems is specifical considerations for New York City (NYC). Specifically, there is a reliability requirement for in-city generation. The 1977 NYC blackout was caused by transmission shutdowns and the inability of generating stations within the city to supply necessary load. The reliability load specifies how much in-city generation must be available to replace the loss of transmission power. I bring this up because this issue has not been discussed regarding DEFR. There will have to be DEFR resources in NYC and if hydrogen is the chosen technology, then hydrogen will have to be stored within the city. Hydrogen is a colorless, odorless, explosive gas that is hard to store. What could go wrong.

Operating Parameters

This section describes how some technical parameters are defined and used. The heat rate parameter is a measure of production efficiency, the lower the heat rate the less energy used to produce electricity. Lower heat rate units operate more often. The text lists the values used in the analysis.

There also is a discussion on the need for DEFRs to meet specific requirements such as the ability to be dispatched to follow load. Existing nuclear power technologies in the US have not been used to provide this service. The discussion describes how this service could be provided in future nuclear power designs. It also notes that there is a possibility that future reactors could be re-fueled while online which is much different than today’s reactors that require significant outages to re-fuel.

Conclusion

The NYISO Resource Outlook chapter on DEFR provides further proof that new technology is in fact necessary for the future zero-emissions New York electric system mandated by the Climate Act. The Hochul Administration has not provided cost estimates for the overall transition. I believe that DEFR costs will be a particular problem because this resource is used as rare backup. This report provides some cost information but not enough to estimate expected costs.

Personal Comments on Clean Energy Standard Biennial Review

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.” In July Clean Energy Standard Biennial Review Report (Biennial Review) was released in response to this requirement and this post describes my comments to the PSC.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 450 articles about New York’s net-zero transition. The opinions expressed in this article do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Overview and Background

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. Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The 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, proceedings, and legislation.

Biennial Review Summary

The Introduction to the Biennial Review is a good summary of the report.

The Climate Leadership and Community Protection Act of 2019 requires that the Public Service Commission (Commission) 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.

My Comments

A comprehensive review of the Biennial Report would have been an enormous effort, so I confined my review to a limited number of issues. The Biennial Review concedes that the 2030 goal to achieve 70% of New York’s electricity from renewable sources is unlikely to be achieved. However, it does not acknowledge that the issues that are causing delays may not be resolved anytime soon. Public Service Law §66-p(4) provides an exemption that enables a delay of the Climate Act targets but no one has defined the safety valve criteria.

There are a couple of broad concerns. An overarching issue with Climate Act implementation is the lack of a comprehensive a feasibility study. The recent announcement of the long-delayed State Energy Plan offers hope that there will be feasibility analyses from that effort, but that will not be available until late next year. In the meantime, the Biennial Review should address whether building as much wind and solar as possible as fast as possible is appropriate. There is another enormous risk that should be addressed. I maintain that the differences between resource planning for the existing system and the proposed weather-dependent electric energy system introduce reliability risks that need to be addressed now.

There has never been a clear and transparent accounting of costs. It is long past time for the impacts on rates to be provided. I recommended that this report should address consumer costs

Finally, I commented on a couple of potentially disingenuous approaches used in the Biennial Review. The emphasis on the Clean Energy Standard underestimates the challenge of meeting all the Climate Act mandates. In the Scoping Plan the unique use of the Reference Case gave misleading cost impact results.

Implications of Progress Issues

The Biennial Review concedes that the 2030 goal to achieve 70% of New York’s electricity from renewable sources is unlikely to be achieved. However, it does not acknowledge that the issues that are causing delays may not be resolved anytime soon. Section 5 provides a speculative path to the 2030 70% goal. Table 8 summarizes the outlook. There is a projected gap of 42,145 GWh or 37% of the 70% goal.

The remainder of Section 5 proposes new development estimates and CES reform options that can accelerate progress. However, while there is an assessment of major factors that have affected and will likely continue to affect progress towards the goals, there is no acknowledgment that those factors are likely to continue to be issues. It concludes that there is a potential path so the 70% goal could be met by 2033 but does not address how building as much wind and solar as possible as fast as possible will ensure a reliable system. It is time to consider a reassessment of the schedule and goals to develop a realistic revised schedule.

The introduction to the Biennial Review mentions New York Public Service Law § 66-p (4) “Establishment of a renewable energy program” that includes safety valve conditions for affordability and reliability that are directly related to the zero emissions resource. § 66-p (4) states: “The commission may temporarily suspend or modify the obligations under such program provided that the commission, after conducting a hearing as provided in section twenty of this chapter, makes a finding that the program impedes the provision of safe and adequate electric service; the program is likely to impair existing obligations and agreements; and/or that there is a significant increase in arrears or service disconnections that the commission determines is related to the program”.

The criteria used to define “safe and adequate electric service” and “significant increase in arrears or service disconnections” should be defined in the Biennial Review. This is necessary so that there is a clearly defined standard for determining the need to conduct the hearing included in § 66-p (4) that would form the basis for a schedule revision.

Feasibility

The Biennial Review is supposed to assess what remains to be done to achieve transition goals and present policy options and proposals, However, the Review does not confront the biggest problem – feasibility. At this time, the State has not 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, from the expected addition of new large sources of load like chip fabrication plants and data centers, and from the load added as part of electrification decarbonization strategies. 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 difference 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. Clearly this should be addressed in the Biennial Review.

I am particularly concerned about the unacknowledged inherent risks of relying on weather dependent resources to provide a substantial portion of future electric power in New York. Wind and solar are inherently intermittent – the sun does not shine at night and the wind does not always blow. Renewable resource 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. All the solutions proposed to deal with solar and wind intermittency have failed to acknowledge that weather dependency makes the reliance on correlated resources very risky. The draft Biennial Review unacknowledged risk is that whatever criteria are used to determine how many resources are necessary to provide an affordable and practical system to meet the worst-case weather induced wind and solar resource lull there will be a high probability that eventually there will be a more extreme case that exceeds the criteria. When that happens, rolling blackouts are inevitable and there is risk of a larger and more severe blackout.

Consumer Costs

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.

The Biennial Review should directly respond to this recommendation. In an interview with Susan Arbetter NYSERDA’s Doreen Harris said the “The proceeding that is before the PSC is intended to ‘specifically they look at all this in the context of consumer cost”. If the Biennial Review is part of the Proceeding, then costs should be included. However, consumer costs are not included in the report.

Disingenuous Approaches

The Introduction to the Biennial Review includes the following description in the contents of each section: “Policy options and proposals under consideration in this Report are limited to the Clean Energy Standard (CES) itself.” The problem is that the CES includes a 9-gigawatt (GW) goal for offshore wind by 2035, a 6 GW by 2025 goal for distributed solar, and a 3 GW energy storage resources goal by 2030. Those only cover a portion of the resources needed to achieve Climate Act goals. I think I represent most New Yorkers when I state that the Biennial Review should include all aspects of the transition not a subset of programs. Choosing subsets of related programs is inappropriate because we want to know the total costs to achieve all mandates and all challenges that must be addressed to meet the targets.

There is a related CES issue. In Section 5.1 on page 53 of the Biennial Review the document states: “In all other respects, this Report’s base case reflects the Reference Case presented in NYSERDA’s Integration Analysis”. There is a cost related problem relative to the Scoping Plan “Reference Case” that I have described in a blog post and in my comments on the Draft Scoping Plan. I noted that the Integration Analysis modeling scenarios used an unusual approach. In this type of analysis policy scenarios are typically compared to a “business-as-usual” future without any policy components. However, the Integration Analysis uses a Reference Case that is different than a typical business-as-usual future scenario because it includes already implemented policies. In the Scoping Plan this unique approach was used to suggest the costs of inaction are more than the costs of action, but that claim did not include all the costs to achieve the Climate Act mandates because it excluded the CES components. Everyone outside the Hochul Administration wants to know the costs to achieve the Climate Act, not some subset of component programs.

Discussion

The draft Biennial Review does not address fundamental issues. It does acknowledge that the schedule is in danger but does not concede there are fundamental problems that may not be resolvable. The presumption that a law written by ideologues with a schedule determined for political ends must be met no matter what needs to be laid to rest. A feasibility analysis that addresses the fundamental technology and implementation schedule issues is the only rational way forward.

As it stands the draft Biennial Review is another political document that fulfills a tortured interpretation of the Climate Act requirements. It apparently parses out different components of the implementation efforts. All the transition components must be considered, and the citizens of New York deserve to know the costs for the entire implementation effort.

It is time to confront overarching issues. There are technological issues related to the Integration Analysis strategies for a zero emissions electric grid by 2040. Until the challenges associated with dispatchable emissions-free resources are resolved then it is inappropriate to shut down any existing fossil-fired generators. Relying on weather-dependent resources introduces significant reliability risks that have not been acknowledged. Until this risk is understood better, it is inappropriate to continue to just build as much wind and solar as possible and hope it works out.

The recently announced draft Advanced Nuclear Technologies Blueprint is important for two reasons. It is an appropriate outline for a feasibility study for one of the transition components that should be expanded to all technologies. Secondly, it is recognition that nuclear is the only existing technology that has a proven record of significant carbon reductions. The implications of this blueprint should be incorporated into the Biennial Review.

Conclusion

Only time will tell if the Biennial Review is only a check the box response. While there are some hints that the ramifications of an unreasonable and unachievable energy transition are become so evident that they cannot be ignored, the draft Biennial Review does not confront the problems sufficiently. Public Service Law §66-p (4) provides for a potential delay of the Climate Act schedule and it was mentioned in the draft. In my opinion, if the Hochul Administration is truly committed to addressing the problems identified in the draft, then this requirement must get more attention in the final Biennial Review.

The Math Does Not Support New York’s Climate Plan

I frequently collaborate with Richard Ellenbogen regarding issues related to the Climate Leadership & Community Protection Act (Climate Act). This post describes his recent blog article The Math Does Not Support New York’s Climate Plan published at the Empire Center for Public Policy. He explains why the numbers show that the Climate Act implementation plan is doomed to failure based on his experience adopting renewable and lower-emission combustion technologies in his home and business. This post condenses his findings and publicizes his work.

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 including a description of his keynote address to the Business Council of New York 2023 Renewable Energy Conference Energy titled: “Energy on Demand as the Life Blood of Business and Entrepreneurship in the State -video here: Why NY State Must Rethink Its Energy Plan and Ten Suggestions to Help Fix the Problems” and another video presentation he developed describing problems with Climate Act implementation. He comes to the table as an engineer who truly cares about the environment and as an early adopter of renewable technologies going back to the 1990’s at both his home and business two decades ago.

Overview and Background

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. Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The 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, proceedings, and legislation.

Introduction

Ellenbogen introduces the problem:

I have been analyzing the numbers coming out of Albany regarding the Climate Leadership and Community Protection Act (CLCPA), New York’s plan to drastically reduce the use of fossil fuels, for over five years now.

I am not anti-renewable and I am not a climate denier. What I am is an engineer that lives by numbers. The numbers underpinning the CLCPA—namely the belief that New York can replace most of its natural gas-fired electricity generation with renewables in the next six or even nine years—are a fantasy.

New York is letting the perfect be the enemy of the good, prohibiting or frustrating viable solutions that could reduce emissions.

Instead, New York is relying on older, less efficient power plants, in hopes that wind and solar—built in more rural areas or offshore—can someday replace them.

Even if New York were to build the wind, solar and battery backup necessary to keep the lights on without fossil fuels, the storage requirements, either onsite or grid-based, would be cost-prohibitive.

State Comptroller Tom DiNapoli in July described “inadequate planning, monitoring and assessment of risks and challenges” by state energy officials. That’s just the tip of the iceberg.

Greener Than The Grid

In the next section of the article, Ellenbogen describes his manufacturing business and the steps he has taken to reduce energy use at his facility. His company, Allied Converters, manufactures food packaging for large bakeries and supermarket chains. The machinery is thermally intensive and uses large amounts of electricity.

In 2002 he “installed the first microturbine-based Combined Heat and Power (CHP) system in the Con Ed service area.” This approach generates electricity by burning natural gas. Waste heat is recovered “to heat the building in the winter, or to be sent to absorption chillers to cool the building in the summer.” This approach allows him to recover 70 to 75 percent of the energy content of the fuel.

He compares the factory efficiency to the grid:

Most of downstate’s electricity comes from burning natural gas. New York’s single-cycle gas generating plants are in the neighborhood of 30 to 35 percent efficient. Newer combined-cycle plants are in the range of 55 to 60 percent efficient. For both, about 7 percent of energy produced is lost as heat in the transmission lines, a loss we avoid by generating electricity onsite.

Contrast that with New York’s plan to replace gas and oil furnaces at homes and businesses with electric heat pumps, which will—at least for the foreseeable future—require more electricity generation from fossil fuels, farther away from where the electricity is needed (and therefore more line losses).

In 2007 he installed the first commercial-scale solar array in New Rochelle. His article describes the tribulations related to being an early adopter with the planning agency and the utility. Later that year he added a “Reactive Power Mitigation System and in conjunction with the onsite generation, reduced load on the utility by 80 percent. To top it off he collects data on all the electric parameters in the building.

This massive amount of data, along with my training as an electrical engineer, has formed my frame of reference regarding the CLCPA. Renewable generation has a place in the energy mix but it cannot be used as the backbone of the utility system. Renewables are a tool and when you misuse a tool, bad things will happen. When you need a hammer, you don’t use a screwdriver, but that is essentially what the state is trying to do with renewables.

Energy System Model

His facility is a template for a pragmatic energy system:

The factory is a microcosm of NY’s energy system. It has a fossil fuel-based high efficiency generator to provide baseline load which it supplements with a solar array. The balance of the energy is dispatched by the utility when we need more.

All told, the factory’s carbon footprint is 30 to 40 percent smaller than it would be otherwise. Additionally, our utility bill, including the cost of natural gas, is less than half of what it would have been if we hadn’t added the energy systems. We have not only reduced our carbon emissions but we have also saved money through reduced energy usage and the associated expenses, about $1 million over the past 17 years. Our savings have been relatively higher during recent years as the business has grown and we have used more energy. Contrast that with current bills for other utility customers that are rising at an increasing rate.

The New York grid relies on nuclear, fossil, and hydro resources for most of its load, wind and solar to supplement the other resources, and imports the rest. The grid load varies more than the factory. As a result, resources are called for varying loads depending on their operating characteristics and costs. Ellenbogen describes current reliability issues.

The New York Independent System Operator (NYISO), the independent nonprofit organization that operates the electric grid and oversees the state’s wholesale electricity market, has been warning about potential blackouts due to closing existing fossil-fuel generators before new generators come online.

A 2019 plan by the state Department of Environmental Conservation to close smaller “peaker” power plants risked causing rolling blackouts on hot days as soon as 2025, before NYISO officials pushed back and kept some of the plants open.

As NYISO officials warned earlier this summer, reliability margins—the cushions in each region that ensure there’s enough electricity to meet demand at all times—“are also observed to be narrowing across the grid in New York, which poses significant challenges for the electric system over the next ten years.”

The reality is that the issue is going to extend well past 2033 and the energy shortages will get worse as gas plants aren’t replaced.

Future Model

Ellenbogen describes what would be needed at his factory if he were to rely only on solar and not use natural gas. Note that wind is not a practical source at his location.

To generate the same amount of electric energy that we currently use, we would need a solar array six times the size of what we currently have. Below is a photo of the 25,000+ square foot roof of the factory with the 50,000 watt (50 KW) solar array on it. (The factory is 55,000 square feet across two floors).

Ellenbogen,s factory, with its 50 KW rooftop solar array, in New Rochelle, NY

We could fit an additional 50 KW array on our roof for a total of 100 KW. However, we would need a roof three times the size of what we currently have to house a large enough solar array to generate the amount of electrical energy that we currently use. That doesn’t include the heat generated by the CHP system.

If we switched to heat pumps, we would need at least an additional 300 KW of solar arrays to support the building’s thermal load. So in total we would need 12 times the panels—on a roof six times the size.

Beyond the enormous additional costs needed to build a system of that magnitude, we don’t have the physical space or the roof area to remotely come close to supporting a system of that size.

The Model Storage Problem

The Climate Act insists on a zero-emissions mandate so that fossil-fired generators cannot be used to support intermittent wind and solar. This leads to the enormous challenge of storage.

Because of the looming plight of New York utility system, my team and I have been looking for ways to supply the building during a power failure. We first looked at a backup generator but Con Ed wanted $140,000 to run a larger gas line to our building. That being cost-prohibitive, we have been looking at a new type of energy storage that does not have the deficiencies of lithium-ion batteries.

The newer storage, using supercapacitors, has a comparable cost to lithium-ion, will last 25 to 40 years instead of the eight to 10 years of lithium-ion, and it will not go into a state of thermal runaway and burn at 2600 degrees Fahrenheit as occasionally happens with lithium-ion batteries. It will fit in a space the size of a sea container and it can be charged at night from our CHP system and on weekends from our solar array. With an energy storage system of 720 to 900 KWh in conjunction with the CHP system and the solar array, we could operate 100 percent free of the utility with a carbon footprint 10 percent lower than what we have now.

However, the Climate Act prohibits the use of the natural gas fired micro turbine currently in use. That means more storage would be required.

We would have to install nearly sixty times the amount of energy storage as what we currently need for backup purposes—at sixty times the price–to ensure that the panel’s energy was available at night or for extended periods during the winter months. That storage would occupy a volume approximately equivalent to that of fifty large sea containers—for my factory alone.

When the example for his factory is considered relative to the State the lunacy of the Scoping Plan becomes clear.

NYSERDA, the state’s energy agency, in late 2022 said “complete replacement” of fossil fuel plants with solar and wind generation would require 2,400 gigawatt-hours of storage to get the state through lulls when wind isn’t blowing and output from solar panels is low. At $567 per kilowatt-hour, the recent average cost of new non-residential energy storage, that works out to more than $1.3 trillion in new costs, or about $68,000 per New Yorker.

Summing Up

Ellenbogen describes his misgivings about the Climate Act.

Unlike New York’s plan that is relying on resources that either don’t exist, don’t exist at scale, are prohibitively expensive to install, are opposed by the residents near the sites, double utility costs, and as a result cannot be installed in any reasonable time frame so that they are not reducing GHG emissions, the technologies that we have used to achieve our carbon reductions are just the opposite. My neighbors are unaware of what we have onsite. The only thing that is visible is the solar array on the roof that can be seen with aerial photos or from a distance from the new high rises that have been built.

The technologies we used existed 20 years ago, reduce GHG emissions, are cost-effective, reduce line losses, reduce transmission and distribution costs, save money for the end user and the utility simultaneously, and can be implemented now in densely populated areas eliminating the need for multi-billion dollar transmission lines.

This conclusion wasn’t derived from what I like or don’t like, or about what I want or don’t want, and unlike the Climate Act, it is not based upon emotion. It is based upon tens of millions of data points that definitively say that if NY State keeps proceeding on this path, it will be a calamity for the state. If the Comptroller or others in state government wonder why the Climate Action Council never did a financial analysis of the Climate Act that they forced upon the state, with the assistance of unknowing legislators, it is because the costs are so ridiculously high that if the number was actually publicized, it would be political suicide.

Climate Act Nuclear Reality and Clueless Anti-Nuclear Activists

Two recent Syracuse Post Standard letters, “Nuclear power emits no carbon dioxide but is anything but clean” and “Coverage of Hochul energy summit did not convey dangers of nuclear waste” oppose the idea of using nuclear power as part of the zero-emissions generating resources needed to achieve the Climate Leadership & Community Protection Act (Climate Act) goals. In this post I explain why their knee jerk rejection of nuclear is not in the best interests of New York.

Overview and Background

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. Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The 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, proceedings, and legislation.

Evidence is mounting that the implementation is not going to as planned. The Public Service Commission (PSC) Clean Energy Standard Biennial Review Report found that the 70% renewable energy goal will likely not be achieved until at least 2033. The New York State Comptroller Office Climate Act Goals – Planning, Procurements, and Progress Tracking audit found that the PSC and NYSERDA implementation plans did not comprise all essential components, including “assessing risks to meeting goals and projecting costs.” The New York Independent System Operator (NYISO) 2023-2042 System & Resource Outlook described issues that threaten reliability and resilience of the current and future electric system. The Department of Public Service Proceeding 15-E-0302 has initiated a process to “identify technologies that can close the gap between the capabilities of existing renewable energy technologies and future system reliability needs, and more broadly to identify the actions needed to pursue attainment of the Zero Emission by 2040 Target”. The Business Council of New York cited those reports and gave other reasons in a letter asking for a reassessment of the Climate Act goals.

A technical conference held under the PSC’s auspices on December 11 and 12, 2023 entitled “Zero Emissions by 2040” included a session titled “Gap Characterization.” Panelists at the session recognized the need for some new resource that would need to be developed to provide electricity to meet demand when wind and solar production are low. They referred to this new, not-yet-existing, hypothetical technology as the Dispatchable Emissions-Free Resource, or “DEFR.” The panel also described a few potential DEFR technologies. Nuclear is the only proven technology that can be expanded sufficiently to fulfill the DEFR energy requirements projected for the future electric grid.

Future Energy Summit

In an apparent response to these issues, on September 4-5, 2024, the Hochul Administration hosted a Future Energy Summit that announced the draft Advanced Nuclear Technologies Blueprint. The blueprint notes that a “growing and innovative group of advanced nuclear energy technologies has recently emerged as a potential source of dispatchable carbon-free power”. The blueprint introduces the goals:

The term advanced nuclear represents a suite of technologies, a description of which is provided in subsequent sections of this document. Advanced nuclear technologies could offer attractive possibilities for New York, with its scalability, economic development, low land use, and potential applications of process heat. It may represent an opportunity for additional grid capacity to support an electrifying economy, that can complement New York’s buildout of renewables. Yet advanced nuclear technologies raise a host of questions that would have to be addressed before planning on it, regarding technological readiness, costs and cost risks, environmental justice, among other factors.

Accordingly, this discussion paper examines a number of advanced nuclear technology options from the standpoint of technological readiness and systemic challenges and issues. The objective is to surface the most important opportunities, issues, and questions associated with these options to create a platform for additional analysis and stakeholder input on these options that moves New York forward towards its energy, economic, climate, and equity goals.

Tim Knauss described the Summit and the initial public response. He noted that the Summit attracted two street demonstrations – one for nuclear energy and the other against. He described the two protests:

Several speakers at the energy summit noted that both Democrats and Republicans in Washington support expanding nuclear power. And polling shows that a majority of Americans — some 56% — support building new nuclear plants, according to Pew Research Center.

But at the local level, the subject can still be divisive.

That was evident Thursday outside the energy summit at the Marriott Downtown Syracuse, where about 60 protestors gathered to denounce the discussions of nuclear power.

“Governor Hochul’s climate leadership is in freefall,’’ said Laura Shindell, New York director of Food & Water Watch, an environmental group. “Now, at the very moment that we need Gov. Hochul to be our climate’s strongest defender, she is instead wining and dining the slow, expensive, dirty and dangerous nuclear industry.”

Shindell and other activists called nuclear power a “fairytale distraction’’ that will weaken the state’s efforts to meet climate goals mandated by the 2019 Climate Leadership and Community Protection Act.

They were joined by Cornell University professor Robert Howarth, who served with Harris on the Climate Action Council that drew up the state’s plan to comply with the law’s mandates.

Aside from its environmental hazards – including uranium mining, much of which mars lands occupied by Indigenous peoples – nuclear power is too expensive and too slow to construct to help meet New York’s emission reduction goals, Howarth said.

Spending on nuclear will detract from the development of more beneficial power sources, he said. “It’s nonsense in terms of our energy future in New York, even if it had an acceptable environmental and health footprint, which it does not,’’ Howarth said. “We can meet all of the energy needs of New York with solar, with hydro and wind and appropriate (energy) storage.’’

But the energy summit also drew a pro-nuclear protest. U.S. Rep. Brandon Williams, R-Sennett, and members of Nuclear New York held their own sidewalk event to protest the anti-nuclear protest.

Williams, a former nuclear submarine officer, said he strongly supports new nuclear power for New York. But he does not support New York’s mandate of zero-emission electricity, which he said is costly and ineffective. “This goal of net-zero emissions is based on ideology, not on economics and not on engineering and not on science,’’ Williams said.

Anti-Nuclear Letters

The Syracuse Post Standard published two anti-nuclear letters after the Summit. “Nuclear power emits no carbon dioxide but is anything but clean” was written by Donald Hughes, Ph.D., a longtime resident of Syracuse and environmental activist with Sierra Club and Sustain CNY. “Coverage of Hochul energy summit did not convey dangers of nuclear waste” was written by Carole Resnick from Syracuse. I have submitted rebuttals to those letters but there are space constraints and there is no assurance that my letter will be published. This section describes my concerns with these letters.

Hughes argues that nuclear is anything but “clean.” He claimed that the construction of reactors has a huge carbon footprint but ignored the mineral intensity of wind, solar, and energy storage technologies. He said the nuclear fuel cycle is highly toxic and cited problems with uranium mining in the American Southwest. I have compiled references for similar issues with the resources he claims are “clean”. As part of the Nuclear New York demonstration mentioned previously ,Chris Denton assembled a booklet with numbers and pictures that show that ignoring the impacts of wind and solar when complaining about nuclear is poor form.

Hughes dismisses the advanced nuclear technology under consideration in the Advanced Nuclear Technologies Blueprint because of concerns with safety, nuclear waste, and costs. However, nuclear advocates see an opportunity to develop different types of reactors that could address these issues. Ronald Stein explains:

The nuclear power production industry has the best industrial safety record among all industries for electricity production. So, the fear that most needs attention is the one surrounding spent nuclear fuel, which is commonly referred to as “nuclear waste.” The solution, then, lies in educating heads of state, mainstream media, and policymakers by extending the concept of recycling to include the unspent energy in used nuclear fuels, a method that can convince people that the “nuclear waste” issue is being dealt with, the cost of power is competitive, and that the production of nuclear power is safe.

Recycling Slightly Used Nuclear Fuel (SUNF) in a Fast Breeder Reactor (FBR) provides all these remedies in a way that is competitive and publicly acceptable. The advantages to recycling used nuclear fuel in Fast Breeder Reactors are many:

It provides a solution to the disposition of the stockpile of Slightly Used Nuclear Fuel (SUNF).

Current inventories of SUNF provide an essentially unlimited supply of domestic fuel.

The fuel material is already mined, so the energy produced is much closer to 100% clean, and further environmental degradation from mining operations is not required.

The public would be more receptive to nuclear power because “waste” is being used as “fuel,” reducing the retention of unspent fuels and diminishing perceived risks.

The design is “intrinsically safe”. This means that the reactor is designed to cool sufficiently in the case of an accident without human intervention.

The current stockpile of SUNF has a value of $10 Trillion when the electric power that it produces is sold at 1 cent per kWh.

Process heat can be used for industrial purposes such as hydrogen, freshwater production, and synthetic fuel production.

Hughes complains that the costs make nuclear a poor choice. His main argument is that the relative costs of nuclear compared to wind, solar, and energy storage are high. For example he cites a study by Lazard, that estimated that the unsubsidized levelized cost of electricity from new nuclear plants in the U.S. will be between $141 and $221 per megawatt hour. In comparison, a newly constructed utility-scale solar facility, with battery storage to provide power after the sun sets, will produce power at an unsubsidized levelized cost of between $46 and $102 per megawatt hour.

Willis Eschenbach evaluated that Lazard April 2023 annual report and summarized the problem with the Lazard Levelized Cost of Energy (LCOE) methodology:

The LCOE estimates the total capital, operations, and maintenance costs for new electric power plants coming into service. People use the Lazard LCOE all the time to claim that renewable electricity sources are now cheaper than fossil fuel electricity. However, the Lazard data has a problem—it doesn’t include the cost of backup and other costs for renewable energy. These costs fall into four groups:

Backup costs – All power sources require backup power for the times when they are not generating any or enough power. However, the amount of backup required is much larger for intermittent sources.

Balancing costs – Extra equipment is required when you have intermittent sources, to keep their highly variable input to the grid from destabilizing it.

Grid connection costs – Renewable wind and solar power is variable voltage direct current. Before it can be fed into the grid, it must be run through costly synchronous inverters to convert it to stable voltage, stable frequency alternating current.

Grid reinforcement/extension costs – Unlike fossil or nuclear plants, which can generally be sited as required, renewable sources of energy are often located far from where the power is needed. As a result, the grid will generally need to be extended, strengthened, or both for such source

Eschenbach’s analysis includes the following figure that compares the original Lazard costs relative to the addition of potential costs for the cost groups described above.

Note that nuclear costs are still higher than solar and wind. However, these projections are based on a 50% penetration of generating sources. New York’s Climate Act requires 100% penetration of wind and solar. As a result, it does not include the necessity for a DEFR resource to backup solar and wind. When DEFR cost support is included I believe that nuclear will be the cheaper option.

The only proven DEFR technology is nuclear so it is possible that there won’t be any choice but to develop it. However, note that DEFR is not needed very often so it does not make much sense to use it solely for DEFR. Instead, the obvious solution is to go all in for nuclear and stop trying to develop wind and solar. Ron Stein sums it up: “Rather than pursue renewables of wind and solar that require huge land footprints, huge taxpayer subsidies, and even then, only generate electricity occasionally, it’s time to focus our technology resources on the nuclear power production industry that has the best industrial safety record among all companies and a track record of producing the cheapest non-subsidized electricity.”

The letter from Carole Resnick was long on emotion and short on numbers. She believes professor of ecology and evolutionary biology professor Robert W. Howarth’s claim that “We can meet all of the energy needs of New York with solar, with hydro and wind and appropriate (energy) storage.” Her belief is misplaced because Howarth is wrong. I have analyzed his arguments that no new technology is needed and found them wanting. More importantly, the Scoping Plan Integration Analysis, all analyses done by the New York Independent System Operator, and the Public Service Commission ‘Zero Emissions by 2040’ proceeding described previously all agree on the need for a new dispatchable emissions-free resource to support the electric system. Her arguments against nuclear power itself echo the same points argued by Hughes

Conclusion

Hughes anti-nuclear claim is that “The reality is that it’s an unaffordable, slow to build and highly toxic process that has no place in a clean energy future.” Resnick claims that nuclear is a false solution and insinuates that is being considerable because it is profitable. Neither of their arguments stands up to inspection.

I believe when the total costs of a wind, solar, and energy storage system are compared to the cost of a system that relies on nuclear for electricity generation that the nuclear system will be cheaper. In addition, it will be more reliable because there is no reliance on weather-dependent generating resources.

The letter authors suggest that wind, solar, and energy storage have no downsides. However, when the emissions from the full life cycle of those technologies, the impacts of renewable energy sprawl across the countryside, and the cumulative environmental impact of thousands of wind turbines and thousands of acres of solar panels necessary to provide the electricity projected are compared to the nuclear option, those technologies are anything but green.

It is time for a nuclear renaissance.

Climate Act Costs and the Election Cycle

The Climate Leadership & Community Protection Act (Climate Act) was passed five years ago and the Scoping Plan that outlines how the to implement the required transition was completed 20 months ago. However, the Hochul Administration still has not admitted how much it will cost the consumers of New York. In my opinion, the reason this information is not available is because the costs are politically toxic. This post describes the requirements to provide costs that have been ignored by Governor Hochul.

Overview

The Climate Act established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. It includes an interim reduction target of a 40% GHG reduction by 2030, and two targets that address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The 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, proceedings, and legislation.

Scoping Plan Costs

The Scoping Plan outline for achieving the “State’s bold clean energy and climate agenda” should have provided substantive cost information. Although costs to ratepayers and citizens were requested frequently by several Climate Action Council members the Scoping Plan went to great lengths to obfuscate the expected costs for the net-zero transition. The Scoping Plan supporting documentation does not provide a transparent description of the information needed to estimate consumer costs. At a minimum it should have provided clear descriptions of all proposed control measures, the assumptions made for those control measures, the expected costs for each measure, and the expected emission reductions projected for them. The Scoping Plan does not even summarize sectoral expected costs for the different projection scenarios. The numbers that are provided are buried in an enormous spreadsheet with inadequate documentation so it is impossible to determine what was used.

Instead of providing substantiated numbers the Scoping Plan cost benefit projections provided nothing more than support for the oft-repeated sound bite: the costs of inaction are more than the costs of action. I summarized the machinations used to support this statement in a blog post and argued that the statement was misleading and inaccurate in my Draft Scoping Plan verbal comments and written benefit, and cost/benefit comments. There never has been a response to my comments.

There are substantive problems with the claim that the costs of inaction are more than the costs of action. It is misleading because the Scoping Plan did not include all the costs to meet the Climate Act mandates. Instead, it only included costs directly related to the Climate Act itself and not already implemented programs such as the Clean Energy Standard including 6 GW of behind-the-meter solar, 3 GW of battery storage, and 9 GW of offshore wind. As a result, the acknowledged costs are much less than the total costs of implementation. Also note that this accounting trick was very poorly referenced to hide this chicanery.

The overarching thing to keep in mind is that the costs are real, but the benefits are based on value judgements with a wide range of possible values. Worse, the calculation of the societal benefits expected from carbon dioxide emission reductions was incorrectly applied. The societal benefit was incorrectly applied multiple times rather than just once. Their approach is equivalent to claiming that a wight loss of five pounds five years ago should be counted as a loss of 25 pounds if it was kept off.

All this results in unrealistically low-cost estimates and value-laden high benefit estimates to “prove” the costs of inaction are more than the costs of action.

New York Cap and Invest

The Climate Action Council’s Scoping Plan recommended a market-based economywide cap-and-invest program. The New York State Department of Environmental Conservation (DEC) and NYSERDA are developing the New York Cap-and-Invest (NYCI) Program. In March they took comments on the pre-proposal outline of the regulations but have only had one stakeholder meeting since. On August 15, 2024 a webinar presented “a draft proposed framework for guiding the allocation of these funds and identification of potential areas that could receive investments.” During the webinar they claimed that draft rules would be out later this year and that appropriations and spending of NYCI proceeds would begin in the next fiscal year beginning April 2025. In the stakeholder engagement process at the beginning of the year DEC and NYSERDA claimed they would propose regulations by summer and the final rules would be in place by the end of the year. Clearly this is not happening according to plan.

Implementing a program like this is a major undertaking and I believe that the DEC is unable to respond as quickly as they would like simply because of staffing issues. On the other hand, this program is a carbon tax. There is no way that it will not affect prices significantly so I doubt very much there is any desire to get the program details out quickly. 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. In my opinion, these costs are one reason that the Hochul Administration is not in a hurry to release the regulations and proceed with the implementation process.

Comptroller Report

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 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 Clean Energy Standard, their plans did not comprise all essential components, including assessing risks to meeting goals and projecting costs.”

The Audit Highlights section of the Comptroller Report listed cost-related key findings and key recommendations. The summary of the key findings included a cost-related specific finding:

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.

There were three key recommendations related to costs:

• 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.

• 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.

There has been no formal response directly to these findings. Susan Arbetter’s Capital Tonight show featured an interview with NYSERDA President and CEO Doreen Harris and Rory Christian, Chair and CEO of the PSC where the cost findings came up. I wrote an article that focused on Arbetter’s attempts to get either one of them to open up about the costs. Arbetter asked: “I just want make sure that while there are factors that have contributed to the delay in implementation of our energy goals, is there anything leading the Administration to delay this because of cost.” (Note that this is not an exact quote but it is pretty close – check out the video at 1:40/9:00). Harris responded (2:00/9:00 of the video): “The proceeding that is before the PSC is intended to look at just that”. Harris explained: “How much progress have we made, do we need to make, and specifically they look at all this in the context of consumer cost”.

Biennial Report

The Climate Act requires the Public Service Commission (PSC) issue a biennial review for notice and comment that considers “(a) progress in meeting the overall targets for deployment of renewable energy systems and zero emission sources, including factors that will or are likely to frustrate progress toward the targets; (b) distribution of systems by size and load zone; and (c) annual funding commitments and expenditures.” I believe this is the PSC proceeding referenced by Harris. The draft Clean Energy Standard Biennial Review Report released on July 1, 2024 fulfills this requirement.

However, contrary to the Harris claim, I do not think that this report addresses the progress “in the context of consumer cost”. I searched the Biennial Report for “consumer” and only got three results: one for consumer price index and the other two in a paragraph describing the motivation for deregulating the power sector of New York. That may not disprove the claim that the report looks at all of this in the context of consumer costs, but I have not found any sections addressing consumer costs.

The timing is convenient for the election cycle. My cynical take on this is that the draft did not include consumer costs because of the potential for political fallout. By the time that costs are added to the document the current election cycle will be over.

Energy Plan

According to the New York State Energy Plan website:

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

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

In recognition of the State’s historic clean energy transition, the State Energy Planning Board will now convene, chaired by the New York State Energy Research and Development Authority (NYSERDA), to begin the process of developing a new Plan. Stakeholder engagement is an integral component in the development of the State Energy Plan, and the public will have the opportunity to provide comments on the draft scope and the draft plan throughout the process.

The Energy Plan is a political construct. The Board consists of ten Commissioners all appointed by the Governor, three appointed by the Governor, the President of the Senate, and Speaker of the Assembly, and a non-voting member from the New York Independent System Operator. Given the make up of the Board I expect that all decisions will fit the Governor’s energy narrative.

With respect to the schedule § 6-106. Conduct of the state energy planning proceeding (1) states:

Every four years, the board shall adopt a state energy plan, which addresses each item identified in subdivision two of section 6-104 of this article provided, however, the board may adopt such a plan more frequently for good cause shown. The board shall prepare biennial reports, every second year following the issuance of the final state energy plan, including a discussion and evaluation of the ability of the state and private markets to implement the policies, programs, and other recommendations as found in the state energy plan, and recommendations for new or amended policies as needed to continue successful movement towards implementation and realization of such policies and programs.

The 2015 Energy Plan was the latest edition and the last biennial report came out in 2017. In 2019 the Climate Act was promulgated and in April 2020 an amendment to the plan was adopted that incorporated the new targets. I have never heard an explanation why the plan was not updated. Clearly the Climate Act has a major impact on energy planning but it has been 20 months since the Scoping Plan was completed.

The energy plan required analyses have not been updated since 2015. § 6-104, State Energy Plan (2) (b) says the state energy plan shall include:

(b) Identification and assessment of the costs, risks, benefits, uncertainties and market potential of energy supply source alternatives, including demand-reducing measures, renewable energy resources of4 electric generation, distributed generation technologies, cogeneration technologies, biofuels and other methods and technologies reasonably available for satisfying energy supply requirements which are not reasonably certain to be met by the energy supply sources identified in paragraph (a) of this subdivision, provided that such analysis shall include the factors identified in paragraph (d) of this subdivision;

Identification and assessment of the costs, risks, benefits, uncertainties and market potential of energy supply source alternatives is only possible if there is a feasibility study. There hasn’t been a feasibility study for the Climate Act. On September 9, 2024 the State Energy Planning Board met to kick off this version of the Energy Plan. The following slide outlines the schedule. Note that the comment period on the plan itself is not anticipated until summer 2025.

Given that there is an explicit requirement for a cost assessment my money is on this process sliding until after the 2026 elections.

Conclusion

Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies. There is no question that the Climate Act costs will test the commitment of most New Yorkers to doing something about climate change once the costs are revealed.

During the Draft Scoping Plan review by the Climate Action Council, members Gavin Donohue and Donna DeCarolis repeatedly asked for consumer price cost projections. Co-chair Harris did not provide that information then and appears to be stonewalling now.

My cynical take on this is that Scoping Plan contents, the timing for the NYCI carbon tax, the response to the Comptroller’s audit report, the contents of the biennial report, and the timing for the energy plan all are being manipulated to prevent dissemination of expected consumer costs because of the potential for political fallout. As it stands the bad news will not be let out until after the 2024 election cycle. Given the enormity of the potential costs I recommend voting against any candidate who supports the Climate Act simply because we deserve to know the costs.

Has the Electricity Reality Check Arrived?

An article by Todd Snitchler originally published by RealClearEnergy and republished at Watts Up With That provides an excellent overview of the issues confronting the electric system today. It is also a response to clean energy advocates that demand that New York double down on its efforts to meet the Climate Leadership & Community Protection Act (Climate Act) mandates using wind and solar resources. This post annotates the Snitchler article with comments framing the New York context.

Overview

On September 4-5 the Hochul Administration hosted a Future Energy Summit. I have written several preliminary impression articles about it and plan to do a final summary after the video is posted. My impression is that Hochul suggested the idea for the Summit, but the primary rationale is not obvious. Initially I thought it was in response to three recent independent reports that found that there were schedule issues, inadequate cost support and potential reliability risks. Those findings coupled with a Business Council of New York letter that cited those reports in a plea for a reassessment I thought were compelling reasons for a meeting.

However, the Summit did not address the problems identified. There were a couple of passing mentions of some of the problems but none of the panelists made any statements contrary to the Administration’s narrative. However, two sessions were devoted to incorporating nuclear energy in the implementation plan and a draft blueprint for consideration of advanced nuclear technologies was released for comment. I now think that the purpose was to gauge the political blowback for that option.

In this context, Spectrum News with Susan Arbetter has recently hosted guests (here and here) to discuss the “benefits of nuclear energy, specifically as a dispatchable resource that can fill in the gaps that arise with solar and wind.” The most recent interview was with Blair Horner from the New York Public Interest Research Group (NYPIRG). I address his comments in my annotations of the article below.

Has the Electricity Reality Check Arrived?

The author of the article is Todd Snitchler. He is President and CEO of the Electric Power Supply Association (EPSA). He introduces the article by noting that dispatchable generation is needed. For background keep in mind that electric system operators must balance the load with available generation constantly. That challenge is much easier if they have resources available that can be dispatched, that is to say controlled, as needed. Wind and solar are not dispatchable.

At meetings of energy regulators, policymakers, consumer advocates, and industry this summer, the content and tone of the conversations around electric system reliability have changed dramatically. Executives from across the industry all agree that dispatchable generation is needed now and will be needed for many years to come.

Electric system owners have economic goals that are inordinately affected by politicians. As a result, they are reticent to say anything that is inconsistent with the current political narrative. In this case the political narrative is the constant refrain about the need to do something about the “existential” threat of climate change. Consequently, everyone who knows better that works for the utilities or the state has not been speaking out about the risks of relying on generating resources that cannot be dispatched. However, reality is forcing their hands and suggestions that laws like the Climate Act might not work as touted are coming out.

Most prominently, the realization and willingness to say publicly that dispatchable resources like natural gas-fired generation will be needed as the energy expansion continues and load growth accelerates for the first time in decades is a welcome admission.

For several years the discussion around the future of the electrical grid was about how inexpensive it will be and how “out of political favor” resources would be moved off the grid in favor of politically favored ones without creating any disruptions or reliability challenges. And just like that, the story has changed – dramatically. Why?

Privately all the experts who really understand the electric system admit that the proposed Climate Act transition plan is very unlikely to work and certainly cannot work on the arbitrary schedule mandated by the Climate Act. On the other hand, advocates like NYPIRG’s Horner cling to the incorrect notion that no new technologies are needed. That belief underpinned the Climate Act law’s schedule and presumption that meeting the schedule was just a matter of political will. Snitchler describes three reasons why plans like the Climate Act cannot work as advertised in the real world.

First, load growth – and a substantial amount of it is expected in the short term. The second is the pace of dispatchable generation retirements, without replacement generation with similar performance characteristics. The third is consistent and increasing warnings coming from reliability organizations and grid operators that a crisis is coming and coming quickly if system planning does not improve.

The authors of the Climate Act did not understand how the electric grid operates and the impacts of wind and solar intermittency on the proposed changes to the system. In the interview with Arbetter at about the 2:00 mark Horner makes the point that the law established a schedule that must be met. Ignoring all the issues related to the massive shift in resources proposed and all the difficulties associated pandemic impacts to supply chains, he whines that the Hochul Administration is not doing what they are supposed to be doing. Snitchler’s description of grid operation realities is inconsistent with the Climate Act mandates so the State is in an impossible situation relative to the schedule.

What does this mean? In short, it is a long-awaited recognition of the reality of grid operations combined with the acknowledgment (albeit grudgingly in some circles) that dispatchable resources, like natural gas, will need to be retained and operated for a longer time horizon than many were willing to admit. This recognition matches the significant number of credible studies, including work done by McKinsey and EFI, that all said dispatchable natural gas generation would be needed even in a high renewable resource penetration scenario.

The problem of dispatchability is compounded in New York because natural gas generation is prohibited by the Climate Act. Instead, the credible plans for the future electric system plan to use a not yet commercially available “Dispatchable Emissions-Free Resource (DEFR)”. It is long past time that anyone who denies this need should be ignored in the conversation but unfortunately the Hochul Administration has not done anything to confront this problem.

That is not all. Snitchler describes other issues that have impacted the Climate Act schedule that Horner ignores when he whines that the State is not meeting the schedule:

As the reality of load growth, supply chain issues, permitting, siting, and construction challenges impacting all types of resources settled in and the sharp warnings of imminent reliability issues combined, it became clear that the rhetoric was far ahead of reality. Recognizing the problem is the first step in solving it.

Unfortunately, there is a crisis brewing as the reliability margins shrink. This summer there were operator alerts for generation emergencies. Snitchler explains that this is largely due to retirements of fossil-fired generating resources before adequate replacements were available. He goes on to recommend a solution.

Because all resources are now accountable for reliability, including dispatchable, intermittent, and storage resources, the requirement to acknowledge and adapt to grid realities is no longer optional – it’s mission critical. The retirement of significant amounts of dispatchable resources without adequate replacements has pushed us ever closer to a system with zero margin of error.

To correct this situation, policymakers and regulators should take steps to minimize the risk to customers. First, the timing gap between retirements and additions to the system must be addressed; we can’t let existing resources off the grid before the replacements are ready. The process for connecting new generation to the grid must be reformed to ensure projects match system needs, not just policy pronouncements. Permitting and siting reforms are needed so we can deliver development of all types of energy projects.

I agree with Snitchler that one thing that must be done is to readjust the aspirational targets of energy transition laws like the Climate Act. I endorse the idea that offramps for reliability is necessary.

Second, policymakers must temper enthusiasm and set goals that align with the reality of system needs and operational constraints. This could mean pausing policies that hinder the deployment of needed resources or including offramps in legislation to ensure grid reliability.

I do have a concern with his plea for siting reforms and pausing policies that hinder deployment of needed resources. I do not agree if that approach is used to justify deploying wind and solar faster because I think there is a fundamental issue that has not been addressed. Analyses of renewable resource availability have identified periods where DEFRs are required. What has not yet been addressed is the risk that designing an electric system to meet a weather-dependent requirement will inevitably mean that practicality and affordability constraints will lead to a situation where an extreme event exceeds the planning criteria. That would lead to blackouts. I do not believe this has received adequate evaluation and discussion. As a result, I think it is more appropriate to consider reliability constraints before proceeding to build as much solar and wind as possible as fast as possible.

Snitchler raises another practicality issue that is not on the radar of advocates like Horner. New York policies must be consistent with other states or bad outcomes will result. In addition, there must be a plan for developing a market signal for DEFRs. This will be an expensive resource that is not used much raising market viability concerns.

Third, grid operators must move more quickly to adjust markets to send the appropriate signals that will drive investment of the required resources. States must recognize the broader benefits of market participation and positive outcomes for their constituents and stop merely demanding grid operators do what one state wants to the detriment of another. States must again appreciate that the benefits of their utilities joining markets far outweigh their ability to dictate resources and timelines and then disclaim responsibility for the issues those decisions create.

Advocates like Horner are first to accuse market participants of biased motives when there are inconsistencies with their goals. Everyone wants a better environment and would like to reduce the risks of extreme weather impacts due to climate change. Snitchler correctly points out that unrealistic goals raise the risk of reliability problems that, in my opinion, are a much worse outcome than effects of climate change that these policies could possibly alter.

To close, lest anyone accuse market participants of not wanting to reduce emissions or only wanting to profit from their current resources, this reality check in no way means walking away from striving to meet policy goals. Bottom line – we can set goals, but they must be tethered to operational reality to ensure success and reliability are both achieved.

Discussion

I think this is a good summary of issues confronting all the electric grid operators in the United States. The risks in New York are even greater because of the unrealistic Climate Act mandates and the attitude of many that because it is a law the mandates must be met with no acknowledgement that there has never been a feasibility analysis to confirm whether it can be done and how fast it could be done. It is unfortunate that the Future Energy Summit did not address these concerns. I believe that a reassessment is overdue.

One of the most important topics for a reassessment is that the need for dispatchable resources destroys the myth that wind, solar, and energy storage are the only technologies needed. Energy storage can provide some of the necessary dispatchability, but the overwhelming consensus is that new DEFR technology is necessary. It is time to stop giving Robert Howarth, the self-avowed author the Climate Act, any platform to say “We can meet all of the energy needs of New York with solar, with hydro and wind and appropriate (energy) storage.’’ That statement is wrong and incorrectly influences advocacy groups like NYPIRG.

Conclusion

Snitchler summarizes the reality check issues that need to be confronted nationally and in New York. If these issues continue to be ignored and unresolved, then the only outcome will be grid reliability problems. I fear that there are many who will only admit that these problems are real only after there has been a catastrophic blackout.

New York Future Energy Economy Summit Post Meeting Preliminary Update

On August 5 Governor Hochul announced a Future Energy Economy Summit that will “gather feedback on strategies to accelerate renewable energy deployment and explore the potential role of next generation clean energy technologies”. I described my initial thoughts on the summit and followed up with a second pre-meeting post. This post describes my initial reaction to the meeting. I will follow up with another post when the meeting recording is posted.

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. Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The 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, proceedings, and legislation.

Setting the Stage for the Meeting

As I have noted previously there are many reasons why an assessment of the future energy economy is needed. Three recent reports top the list. The Public Service Commission (PSC) Clean Energy Standard Biennial Review Report found that the 70% renewable energy goal will likely not be achieved until at least 2033. The New York State Comptroller Office Climate Act Goals – Planning, Procurements, and Progress Tracking audit found that the PSC and NYSERDA implementation plans did not comprise all essential components, including “assessing risks to meeting goals and projecting costs.” The New York Independent System Operator (NYISO) 2023-2042 System & Resource Outlook described issues that threaten reliability and resilience of the current and future electric system. The Department of Public Service Proceeding 15-E-0302 may also be influencing the Governor and precipitating the need for the summit. The Business Council of New York has cited those reports and gave other reasons why it is needed. As a result, the governor said the state’s climate goals are something she “would love to meet, but also the cost has gone up so much. I now have to step back and say, ‘What is the cost on the typical New York family?’ Just like I did with congestion pricing.”

Annotated Agenda

Welcome

Doreen Harris, President and CEO, New York State Energy Research and Development Authority
- Reason to meet in Syracuse was because of Micron chip fabrication plant
- Administration is committed to Climate Act goals but refinements may be necessary

Morning Keynote

Kathy Hochul, Governor Press Release
- Reiterated commitment to Climate Act goals because of all the climate events
- Governor does not know difference between weather and climate
- She managed to appeal to a wide range of her constituents with specific statements

Fireside Chat: State of Technology

David Crane, Under Secretary for Infrastructure, U.S. Department of Energy
Richard Kauffman, Chair, New York State Energy Research and Development Authority
- I was not impressed with this session
- Neither speaker has a technical background and it showed
- Upton Sinclair’s quote is apropos: “It is difficult to get a man to understand something when his salary depends upon his not understanding it.

Accelerating Renewable Energy Deployment in New York State

Moderator, Georges Sassine, Vice President, Large Scale Renewables, New York State Energy Research and Development Authority
Laura Beane, President North America, Vestas
Lori Bird, Director of U.S. Energy Program and Polsky Chair for Renewable Energy, World Resources Institute
Eric Cohen, Head of Green Economy Banking, JP Morgan Chase
Frank Macchiarola, Chief Policy Officer, American Clean Power Association
Jonah Wagner, Senior Advisor to the Director, U.S. Department of Energy Loan Programs Office
- All of these speakers have a vested interest in the clean energy transition so my notes are sparse
- I posted a question asking if it was a good idea to build as much renewable energy as possible before the necessary dispatchable emissions-free resource technology is specified. There was no response to the question.

Status of Next Generation Energy Technologies

Moderator, Brandon Owens, Vice President, Innovation, New York State Energy Research and Development Authority
Dr. William Acker, Executive Director, New York Battery and Energy Storage Technology Consortium
Dr. Monterey Gardiner, Chief Engineer, National Renewable Energy Lab
Dr. Benjamin Houlton, The Ronald P. Lynch Dean, Cornell College of Agriculture and Life Sciences
Dr. Jack Lewnard, Program Director, Advanced Research Projects Agency – Energy, U.S. Department of Energy
Jeffery Preece, Director of Research and Development, Electric Power Research Institute
Julie Tighe, President, New York League of Conservation Voters
- One of the significant points made during the Summit is that certain industries are willing to pay more for reliable high-quality electric power.
- This broaches the idea that those companies would be willing to make investments in reliable power
- It also acknowledges that certain industries recognize that a future grid that relies on wind, solar, and energy storage will not be reliable enough

Lunchtime Keynote Speaker Clean Energy Supply for Large Loads

Rich Powell, Chief Executive Officer, Clean Energy Buyers Association
- He explained how large companies signal their climate virtue by claiming credits for zero-carbon generation virtually

Insights from Large Consumers of Electricity

Moderator, Hope Knight, President, CEO, and Commissioner, Empire State Development
Miranda Ballentine, Senior Advisor, Green Strategies
Amber Bieg, Lead Senior Program Manager for Global Sustainability, Micron
Moshe (Mo) Bonder, Director, Business Development Low Carbon Solutions, National Grid Ventures
Jennifer Lupo, Vice President, Energy Solutions, Supply Chain & Leasing, The Raymond Corporation
Dr. Varun Sivaram, Senior Fellow for Energy and Climate, Council on Foreign Relations
- This session gets into the real reason for the Summit
- In order to do justice to the commentary I need to review the meeting recording
- All these companies subscribe to the belief that it is important that the electricity they use be “clean”
- There was even a suggestion that to be competitive, companies demand clean energy. My impression was that affordability and reliability were weighed equally with cleanliness. That does not seem appropriate, so I need to get exact quotes

Global Perspective: Advanced Nuclear Development in Other States and Nations

Moderator, Rory Christian, Chair, New York State Public Service Commission
Nicolle Butcher, Chief Operations Officer, Ontario Power Generation
Steve Chengelis, Senior Director of Future Nuclear, Electric Power Research Institute
Dr. John Parsons, Deputy Director for Research, MIT Center for Energy and Environmental Policy Research
Dr. Andrew Whittaker, SUNY Distinguished Professor, University of Buffalo
- This session addressed the status of nuclear elsewhere
- Questions were posed and answers debunking common anti-nuclear talking points were included

Blueprint for Consideration of Advanced Nuclear Technologies

Moderator, John Williams, Executive Vice President of Policy and Regulatory Affairs, New York State Energy Research and Development Authority
Armond Cohen, Chair, Clean Air Task Force
Judi Greenwald, Executive Director, Nuclear Innovation Alliance
Christine King, Director, U.S. Department of Energy’s Gateway for Accelerated Innovation in Nuclear Program
Greg Lancette, Business Manager, United Association of Plumbers and Steamfitters Local 81
J. Ryan McMahon II, Onondaga County Executive
Marc Nichol, Executive Director of New Nuclear, Nuclear Energy Institute
- In the interest of full disclosure I bailed on this session

Wrap up and Next Steps

Doreen Harris, President and CEO, New York State Energy Research and Development Authority
I got into the meeting webinar when I got home in time for this
- Harris read accolades to her boss’s vision to fight the crisis
- She said there were three takeaways
- She doubled down on the need for building renewables and making them the primary energy source
- She acknowledged that dispatchable emission-free resources were needed
- She argued that we must not miss the opportunity to leverage federal initiatives to fund New York’s transition.
- She believes that the clean energy transition will grow a prosperous economy
- She encouraged everyone to review the draft blueprint for consideration of advanced nuclear technologies
Discussion

In an earlier post I noted that the State must confront the possibility that the safety valve criteria in New York Public Service Law § 66-p (4) for unsafe and inadequate electric service, impairment of existing obligations and agreements, and unacceptable increase in arrear or service disconnections will be exceeded. There was no suggestion whatsoever that the Hochul Administration has any doubts that a zero-carbon electric grid that relies on wind and solar will work.

It seems obvious that there are large consumers of electricity that want to at least be able to say that they use 100% renewable energy. I think this summit was in no small part designed to cater to those companies. However, there were some hints that high quality electric power was enough of a concern that nuclear might be an acceptable option.

The other reason for this meeting was to broach the nuclear power option to the State. The draft blueprint is potentially a referendum on its use. I have no doubts that the anti-nuclear activists are frantically developing their plan to inundate the comment process with negative comments. The political calculus of weighing the squeaky wheel crowd relative to the reliability of the wagon realists will be interesting. Will the Administration admit that reliability and resiliency are not just slogans.

Conclusion

I remain convinced that the current Scoping Plan implementation will do more harm than good. The Energy Summit could have been the start of a correction process that might reduce the inevitable increased risks to reliability, extraordinary price increases, and significant environmental impacts but that does not appear to be the case. As I said before the Summit is another Macbeth story: “A tale told by an idiot, full of sound and fury, signifying nothing”.

Offshore Wind Costs

Last month I described a flurry of offshore wind related news and last week I provided an update describing additional news. In my opinion these latest revelations suggest that a reassessment of the viability of offshore wind projects is in order. I did not address the costs but a couple of articles that have appeared since then do suggest that costs should also be considered in the reassessment.

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. Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity has to be 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, proceedings, and legislation.

Offshore wind developments are a key Climate Act decarbonization strategy. There is a mandated target of 9,000 MW of offshore wind by 2035. The Integration Analysis projects that offshore wind capacity will exceed 13 GW by 2040. However, there are overlooked risks to this strategy that are now becoming obvious. The fact is that the huge, proposed wind turbines have not been field tested.

Why Is Cheap Wind Power So Expensive?

Willis Eschenbach poses the cost question that is ignored by the green energy activists. First he describes the overarching Biden Administration goals released in Marh 2021:

Eschenbach is a numbers guy and was immediately suspicious:

Hmmm, sez I, seems a mite ambitious. Current US grid-connected offshore wind is a mere 0.17 gigawatts … so we’d need to do ~ 175 times as much as we’ve done to date and do it in a short six years.

So I divided it out. There are 65 months until 2030. Thirty gigawatts is thirty thousand megawatts, less the 174 megawatts in place, that’s 29,826 megawatts more total generating capacity needed.

29,826 megawatts divided by 65 months means we’d have to add offshore wind generation to the tune of 465 additional megawatts of generation capacity per month. Every month. Starting now.

Get real. That’s not remotely possible. The biggest US offshore windfarm just came on line, 132 MW capacity. To reach the White House goal, every month we’d need to build three new windfarms of that size. No way that can happen. It’s just numbers picked out of the air to gain popular support.

Then he researched the expected time to get an offshore wind farm on line:

The time from the proposal of an offshore wind farm to its grid connection typically ranges from 7 to 10 years. This timeline can be broken down into several phases:

Pre-development and Planning (1-2 years): This phase involves site identification, feasibility studies, and initial environmental assessments.

Permitting and Approvals (3-5 years): Securing the necessary permits and approvals is often the most time-consuming part of the process. This includes detailed environmental impact assessments, consultations with stakeholders, and obtaining state and federal permits.

Construction (2-3 years): Once all approvals are secured, construction of the wind farm, including the installation of turbines and subsea cables, takes place. This phase also includes the grid connection process.

Commissioning and Testing (several months): After construction, the turbines are tested, and the wind farm is gradually brought online.

The bottom line is that if a project is not well along it will not be available by 2030. He found cost information for South Fork Wind which in New York’s first offshore wind farm:

South Fork Wind just came online. This gives us a chance to look at some actual cost figures. It’s the biggest wind farm to date, a 132-megawatt addition to offshore wind. It cost $637 million.

However, Federal subsidies added $191 million to that, plus another couple of hundred million or so from Bureau of Ocean Energy Management (BOEM), the National Oceanic and Atmospheric Administration (NOAA), and the New York State Energy Research and Development Authority (NYSERDA).

Stop and consider. Some private company is building a six-hundred-million-dollar white elephant in the middle of the ocean, and it’s getting paid four hundred million of taxpayer money to do so.

So … what does the New York consumer get for all of this more than generous support?

The consumer gets wind power costing FOUR TIMES AS MUCH as the current cost of power in New York.

Stop and consider. Even when the developer gets two-thirds of the cost paid by the taxpayer, offshore wind power is still four times as expensive.

Eschenbach sums it up:

What’s next?

Well, I’m sure that what’s next is the Harris/Walz campaign will declare that they are 100% behind expensive, intermittent, unreliable wind power, and will claim that if elected, they’ll do what they already said they’d do when Ms. Harris was last elected, which was to screw the consumer and the taxpayer with the huge subsidies, tax breaks, and electricity costs of offshore wind.

Oh, yeah. They claim that the 30 GW of offshore wind will “avoid 78 million metric tonnes of CO2 emissions”. Tens of millions of tonnes, sounds impressive, right?

But IF the IPCC is correct, and that’s a big if, this will reduce the temperature in the year 2050 by …

… wait for it …

… 0.0016°C. Which is almost three-thousandths of one degree F.

Can we please pass a law saying people proposing any laws or regulations in the name of “climate change” be required to tell us (and show their math) how much actual temperature difference that will make by 2050?

All the points made in this article are direct analogies to what is happening in New York State.

Offshore Trojan Horses

Gordon Hughes from the National Center for Energy Analytics compares the subsidies for offshore wind projects to “the classic warning of the Trojan Horse legend, “Beware of Greeks bearing gifts”—in other words, the hidden dangers of accepting something that seems too good to be true.” He argues that “New York State ignored that warning when it agreed to pay very high prices for the electricity to be supplied from its new offshore wind farms—Empire Wind 1 and Sunrise Wind—located off the coast of Long Island.” He continues:

In announcing the final agreements, New York Governor Kathy Hochul triumphantly claimed that the new projects would create more than 800 jobs during the construction phase and deliver more than $6 billion in economic benefits for the state over 25 years.

Rather less emphasis was given to the fact that New York will pay an average price of over $150 per MWh (megawatt hour) for the electricity generated by Empire Wind 1 and Sunrise Wind.That’s more than four times the average wholesale price of electricity in New York during 2023–24, $36 per MWh. The total annual premium over the wholesale market price for the power from these wind farms will be about $520 million per year at 2024 prices. Over 25 years, New York ratepayers will be paying about $13 billion for alleged benefits of $6 billion.

That is not all. Thanks to tax credits, U.S. taxpayers will cover at least 40% of the costs of constructing the wind farms. At a minimum cost of $5.5 million per MW (million watts) of capacity, the total federal subsidy for New York’s two wind farms will be at least $3.8 billion.

He also evaluates the jobs and economic claims made by the Hochul Administration. He concludes that “The economic benefits of the two offshore wind farms are much lower than claimed by the governor and the jobs are, in large part, temporary assignments for professional services staff”. I would add that the temporary assignments will probably be filled by experienced staff from out of state.

Conclusion

The offshore wind proposed contracts are unsustainable. Eschenbach suggests that folks in New York should be asked” “Are you willing to pay four times the going rate for electricity for the rest of your life to MAYBE cool the globe by three-thousandths of one degree Fahrenheit a quarter century from now?” I agree and think that these facts need to be publicized because most New Yorkers have no clue that Climate Act implementation inevitably will increase costs significantly.

Lastly, note that Climate Act proponents have always argued that one of the goals was to demonstrate leadership for the energy transition. This article presents two examples where New York’s transition leadership is cited. Unfortunately, both are bad examples showing what to avoid.

New York Future Energy Economy Summit Pre-Meeting Update

On August 5 Governor Hochul announced a Future Energy Economy Summit that will “gather feedback on strategies to accelerate renewable energy deployment and explore the potential role of next generation clean energy technologies”. I described my initial thoughts on the summit and possible outcomes earlier. This post provides a pre-meeting update.

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. Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity must be generated by “zero-emissions” resources by 2040. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” The 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, proceedings, and legislation.

Purpose

Never forget that the Climate Act has always been mostly about politics and much less about rational energy policy. I do not think that there is any question that this Summit is intended in part to gauge the reaction of favored political constituencies. I have seen several notices from activist organizations calling for people to rally at the event against “false solutions” which I believe boils down to anything other than wind, solar, and energy storage. With nuclear being at the top of the worst example of a false solution.

In my opinion, the State must confront the possibility that the safety valve criteria in New York Public Service Law § 66-p (4) for unsafe and inadequate electric service, impairment of existing obligations and agreements, and unacceptable increase in arrear or service disconnections will be exceeded. I recently recommended that those criteria be specified so that there are quantifiable targets. I hope that there are discussions that can further that requirement during the summit.

The other missing piece to date is the implementation plan for the transition. The Scoping Plan is no more than a outline list of different strategies that someone has calculated will produce the emission reductions necessary and the energy required for New York State to meet the Climate Act mandates. There is insufficient documentation to meaningfully critique the outline, and the Hochul Administration failed to respond to technical comments on the draft before it approved the Final draft. A feasibility analysis has not been produced and must be included for a credible transition plan. Better still would be a small-scale net-zero demonstration for an isolated jurisdiction that proves that an electric system can rely on intermittent wind and solar resources as the primary source of generation. I hope that there will be discussion of this concept at the Summit.

Attendance

There is still no indication who will be on the panels. In my original post I mentioned that I was worried that this would just be another dog and pony show. I cannot comment on this until I know who is on the panels.

Public participation has been restrictred The meeting announcement mentioned that there was limited seating capacity for the event but at the same time it listed statements from eight different agencies. I fail to see a connection between the Department of Health and Department of Labor with respect to energy policy. If they send representatives, then fewer affected stakeholders or members of the public can attend. I heard from several people who were waitlisted and asked a politician for help but did not get invited. Contrary to my expectations, I managed to get invited.

Summit Agenda

On August 7 when I wrote the first summary of the Summit, I included the following list of sessions that had been posted:

Welcome Remarks and Morning Keynote
State of Technology
Status of Next Generation Energy Technologies
Luncheon Keynote
Insights from Large Consumers of Electricity
Global Perspectives: Representatives from other states and nations who are pursuing advanced nuclear installations.
New Nuclear Blueprint: Vet Draft Blueprint as framework for New Nuclear Master Plan
Wrap up and Next Steps

The agenda for the meeting on September 2 has changed. The original first session “State of Technology” has been changed to “Accelerating Renewable Energy Deployment in New York State”. The original first session “State of Technology” did not seem to be all that much different from the second session “Status of Next Generation Energy Technologies” so this makes sense. However, the title “accelerating renewable energy deployment” suggests that no one is willing to conceded that building as much renewable energy as possible as fast as possible without a plan or feasibility analysis might not be a good idea.

At the PSC Zero Emissions by 2040 Technical Conference last December there were sessions devoted to pandering to real “false solutions” for a future economy. Technology shills and activists subscribe to a dream that with enough energy conservation and “smart planning” the myriad problems identified by the organizations responsible for grid reliability can be ignored. I fear that the Status of Next Generation Energy Technologies panel will include the same proposals without anyone on the panel providing contrary feedback. It is long past time for the Hochul Administration to support the concerns expressed by the PSC, NYISO and other organizations with reliability responsibilities and stop pretending that some of the cockamamie schemes suggested by irresponsible entities can provide meaningful future support.

The opening and luncheon keynote speakers will likely set the tone for the meeting. One hour is set aside for the welcome and keynote presentations. If that is nothing more than bragging about the “success” so far and excuses for the findings of the negative assessments, then I will have little hope for any meaningful results. The same holds for the luncheon speaker.

One of the issues raised by the analyses to date is that loads will increase due to electrification of everything and new “Large Consumers of Electricity”. The huge, proposed Micron chip fabrication plant is the prime example. What are the odds that representatives from those facilities will tell the truth that unless there is demonstrated path to success or an alternative backup plan that it would be madness to invest billions of dollars because there is no assurance of reliable, affordable electricity.

The last two sessions address nuclear energy projects. In my opinion, this is the primary driver of this Summit. The only jurisdictions that have significantly reduced their GHG emissions from the electric sector without relying on hydro or geo-thermal resources used nuclear. However, nuclear is unacceptable to many of the activists who are the strongest supporters of the Climate Act. I have seen several pleas for people to come to rally against the false solutions. The meeting was held in Syracuse and that just happens to be the closest city to three operating nuclear reactors. I will be shocked if there aren’t visible signs of support from staff at those facilities.

Conclusion

There are some encouraging signs that people are catching on that no matter how you feel about doing something about climate change the reality is that New York’s plan is deeply flawed. I am convinced that the plan will do more harm than good. The Energy Summit could be the start of a correction process that might reduce the inevitable increased risks to reliability, extraordinary price increases, and significant environmental impacts if there is no course correction. On the other hand, it could be another story from Macbeth “A tale told by an idiot, full of sound and fury, signifying nothing”.

Stay tuned for an update later this week.

Offshore Wind Meets Reality

Last month I described a flurry of offshore wind related news and there have been enough stories since then for another update. In my opinion these latest revelations suggest that a reassessment of the viability of offshore wind projects is in order.

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. Two targets address the electric sector: 70% of the electricity must come from renewable energy by 2030 and all electricity has to be 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, proceedings, and legislation.

Turbine Blade Failures

Bud’s Offshore Energy reports that:

The “highly unusual and rare” talking point for turbine blade failures seems to have finally been discarded.

3 new GE Haliade-X blades failed shortly after installation at Dogger Bank and Vineyard Wind. A total of only 48 turbines had been installed.

Siemens Gamesa and Vestas, the other 2 leading manufacturers, have also experienced unacceptable failure rates. Also

One of the reasons for waiving the “pay as you build” financial assurance requirement for Vineyard Wind was “the use of proven wind turbine technology.”

Dr. Edgar Gunter (RIP 😢), founder of the University of Virginia’s Rotor Dynamics Lab, suggested the cause of the Vineyard Wind blade failure was not a material bonding problem, but rather “a classical torsional fatigue failure of the blade at the base.” (His message is below)

Bud’s Offshore Energy continues with some other thoughts:

The offshore safety regulator (BSEE) has a very capable technical staff and should produce an informed report on the Vineyard Wind blade failure. The concern is with the internal review process that has seriously delayed the publication of accident investigation reports and safety alerts.

Presumably, DNV, the Vineyard Wind CVA, will provide input into the BSEE investigation. Perhaps the effectiveness of the CVA process and quality control procedures should be separately considered.

Will Equinor, a major oil and gas producer, Dogger Bank partner, and offshore wind advocate, be investigating the Dogger Bank failures?

A comprehensive International data base on turbine incidents and performance is needed.

As previously noted, offshore substations are large structures. A closeup of the Vineyard Wind 1 substation is pasted below.

Consequences of Turbine Blade Failures

Paul Driessen points out that one broken wind turbine blade shut down Massachusetts beaches and asks what would happen if a hurricane struck. He describes the impact of the Vineyard Wind failure:

Shards, chunks and finally the rest of a turbine blade fell into the ocean. One blade … from a 62-turbine project that’s only three-fourths completed … broken by its own weight, not by a storm.

And yet beaches had to be closed amid peak tourist season, while crews picked up pieces of fiberglass-resin-plastic-foam blades, and boats dodged big pieces floating in the water. Worse, Vineyard Wind didn’t tell Nantucket officials about the problems until two days after the blade began disintegrating.

Each blade is 350 feet long and 140,000 pounds. That’s more than a fully occupied Boeing 737 jetliner. Vineyard Wind involves 186 blades: 65,000 feet (12 miles) in total combined length, weighing in at a combined 26,000,000 pounds!

Vineyard Wind will have 62 wind turbines and a total capacity of 800 MW. Driessen notes that:

The Biden-Harris offshore wind plan calls for 30,000 megawatts of generating capacity by 2030. That’s 2,500 gigantic 12-MW offshore turbines. That won’t even meet New York State’s current peak summer electricity needs, before all these extra demands kick in. Offshore wind’s contribution toward meeting future demands for all Atlantic Coast states could easily require 5,000 such turbines: 15,000 blades, weighing a combined 2 billion pounds and spanning a combined 5,250,000 feet (995 miles)!

Source posted by Brian J @Mainsail23

He points out the obvious problem that the planned offshore wind facilities on the East Coast can all be affected by hurricanes:

Even more disturbing, the entire Atlantic coastline is hurricane country. Every year, almost without fail. The only questions are how many hurricanes, how powerful, and where each one will hit.

NOAA records for landfalling hurricanes – those that actually hit US beaches and cities – reveal that 105 Category 1-5 hurricanes struck the Atlantic seaboard, from Florida to Maine, from 1851 through 2023. Add in those that remained at sea, where the turbines will be, and that number could double.

Of that total, 23 were Category 3-5 (111-157 or higher mph winds). Most struck Florida, Georgia and South Carolina. But 39 made landfall between North Carolina and Delaware – and 19 hit Northeastern States, including nine Category 2-3 monsters (96-129 mph winds).

Mind you – these turbines will be weakened by constant corrosive salt spray and frequently by sub-hurricane storms. When the inevitable big hurricane roars up the coast, devastation will follow.

The 1935 Labor Day Hurricane clobbered Florida with 200+ mph devastation, Georgia with Category 1 winds. The Great New England Hurricane of 1938 smashed into New York, Connecticut, Rhode Island and Massachusetts with 115-120 mph force. 1944’s Great Atlantic Hurricane – punished the coast from North Carolina to New Jersey and Massachusetts with Category 2 winds.

Edna hit the Northeast with Category 2 winds in 1954, Donna did it again in 1960, and Gloria clobbered the region with 96-115 mph blasts in 1985, even reaching New Hampshire and Maine! Isabel hit North Carolina and Virginia in 2003. The “minor” Category 1 hurricane of 2012, better known as Superstorm Sandy, was also devastating.

This summary includes just some that hit North and Mid-Atlantic States, and a few that slammed Florida, Georgia and South Carolina – all prime territory for forests of offshore turbines, fixed to the seafloor or insanely sitting atop enormous floating platforms off Maine and other states. They’d all flounder.

I have found one reference to offshore wind turbine expectations relative to hurricanes. Our EnergyPolicy (OEP) hosted a panel discussion on New York State’s emerging offshore wind market and the policy and business challenges facing this evolving sector, in its Energy Leaders Luncheon Series December 2019 event in New York City. The question was asked “Will wind turbines in New York be able to withstand a Category 5 storm?”

Clint Plummer who was the head of market strategies and new projects for Ørsted, the world’s largest owner, developer, and operator of offshore wind responded that “wind turbines are designed to withstand a Category 3 hurricane, and they have built into their permit applications an insurance fund that can pay for repairs in cases of catastrophic loss from a storm more severe”. He said “a Category 5 hurricane has a return period in excess of 100 years, while the design life of a wind farm is 30-35 years, so wind turbines are not designed to withstand a Category 5 storm because they are not expected to experience one”. “Anything less than that up to a certain speed is just a really good day for producing a lot of wind power,” he said

At the time of this response the offshore wind turbines proposed were smaller. Since then, the quest for higher capacity availability has led to bigger turbines that recent events suggest may not be as robust as the smaller designs. It is conceivable that when a hurricane with intensities like those observed inevitably reoccurs after the massive buildouts proposed are in place that many (most?) wind turbine blades will fail. Driessen argues that it will take months or years to replace widespread broken wind turbine blades and that it may require the construction of alternative generating sources:

Hopefully, politicians and bureaucrats could expedite new gas turbine and modular nuclear power plants. That would mean only a few years of deprivation and blackouts, instead of many years, perhaps decades.

Otherwise, floating slabs of broken turbine blades would endanger boats for months or years, until they are retrieved, hauled ashore and landfilled. Cleaning up billions of sharp shards of fiberglass – each an inch to a couple feet in length, and nearly invisible – would likely take decades, during which time they would impale and imperil beach walkers, swimmers, fish, whales, dolphins and other marine life.

I’m not a microbiologist, but I’m not aware of any microbes that devour fiberglass, resin or plastic foam.

With no bonds or requirements that Big Wind cover cleanup and turbine removal costs, electricity-bereft taxpayers and ratepayers would be left holding the bag.

Before we rush any further into this “renewable energy transformation,” can we first have some realistic, commonsense analysis? Can we at least think before casting our ballots this fall?

Maine’s Floating Turbines

As if the construction of wind turbines on fixed platforms is not enough of a challenge there are proposals for floating wind turbines. Bud’s Offshore Energy noted that recent bids on lease areas were much lower than previous sales.

David Wojick describes the curious first lease for floating offshore wind turbines in the Gulf of Maine. The State of Maine was awarded the lease which is described as a research lease rather than a commercial development lease.

To begin with, the lease is for a 144 MW “research array” of turbines, as it is called. Well, 144 MW is huge for research. The South Fork Wind site (fixed, not floating) that is already running is a 12-turbine, 132 MW commercial facility, so this array will be bigger than commercial.

It could cost $3 billion-plus the cost of the factory to make the dozen or so floaters. Different websites suggest different turbine sizes from 10 to 12 MW. Of course, if this is really research, they might use a variety of sizes, but the total is still huge.

Why so big is the first mystery, and the official explanations are far too vague to justify it. They mostly talk about research into things like efficiency, supply chain, and even jobs.

Wojick makes a couple of other points. This “research” lease development is occurring at the same time there are commercial developments underway so the results will not benefit project developments. The payment structure of this project is mirky: “if a Purchase Power Agreement (PPA) is supposed to pay for the array, plus profit, then it is very much a commercial development meanwhile research is expensive and unpredictable so how can there be an advance PPA to pay for it?”.

He suggests that there is another possibility: “This project is not about research it is about building the floater factory and demonstrating the University of Maine technology.”

There is a monster wild card in the floating wind game, and that is the factory. Fixed bottom wind is very simple onshore. All you need is a good dock, a big crane, and a place to sit the components until they are taken to the site and installed. There are just a few simple components — monopile, tower, turbine, and blades. It is all made elsewhere.

Floating wind is made from scratch onshore then towed as a whole to the offshore site. The Uni-patented technology uses concrete floaters which might weigh 15,000 tons or more and are complex structures. Factory construction of floaters will be a huge job.

This fact about floating wind is seldom mentioned, and when it is, the language is usually deceptive. The industry talks about “ports,” not factories, and the Maine floater factory is called a port. See my. note that the factory will be operated by Diamond.

So here is what might happen. As part of the “research” Maine builds the floater factory and enough floaters to demonstrate that the patented Uni- technology works. Developers of the 15,000 MW of commercial Gulf wind have to choose technologies for their various sites. If they choose any other technology, out of over a hundred candidates, they will have to build the factory to make it.

Once the floater factory is built then a powerful incentive to use it exists. Given that they are talking about $100 billion in floaters the developers, the State of Maine and the University of Maine will make a huge amount of money. Of course, the money has to come from somewhere so expect the ratepayers in Maine to be on the hook for that. Wojick concludes:

Mind you I am not claiming this is what is going on, but it certainly makes sense out of this supposed research array. The primary obstacle is that the Uni-technology has never been built at 10-12 MW scale and it might not be feasible. Also, the factory design that I have seen does not work, but that is a separate issue.

Hot Air Renewable Notes

Beege Welborn has a nice overview article: Blade Failures Continue and Don’t Go Missing in an Offshore Wind Farm on the Hot Air website. The article describes blade failures in Missouri, covers the problems at Vineyard Wind, notes that the plans for huge offshore wind farms require mind-boggling amounts of material, and notes that there are radar interference issues with planes and offshore wind farms. Finally the article includes a reference to an incident where “wind industry henchmen are showing their true colors during citizen meetings”. The thug” walked up and grabbed” a bag belonging to a woman showing fiberglass shards that washed ashore from the damaged turbine while she attempted to explain her concerns about offshore wind development at a Newport, RI wind farm forum. The guy had been featured at Senator Sheldon Whitehouse’s website until the incident. Thankfully, the goon’s facing assault charges.

Conclusion

The Hochul Administration’s Integration Analysis projects that offshore wind capacity will exceed 13 GW by 2040. These latest revelations suggest that a reassessment of the viability of offshore wind projects is in order. The technology has not been tested on the scale proposed and it sure appears that there are survivability issues even without storms. What could possibly go wrong?