Guest Posts – Pragmatic Environmentalist of New York

Fort Edward Solar Filings

On October 27, 2025, Fort Edward Solar responded to the Issues Statement, Party Status Request, and Public Comments on a Draft Permit. Simultaneously, the Office of Renewable Energy Siting (ORES) staff filed a responsive brief to the Petition for Full Party Status submitted by the Grassland Bird Trust for this project. I previously described this project and published Gary Abraham’s explanation why ORES ignores local stakeholders. In conjunction with Gary Abraham, this post describes the ORES responses and confirms my worst-case fears.

Gary Abraham is a lawyer who has been more deeply involved in the renewable energy siting process than I have. He represented a citizen group under State Environmental Quality Review Act (SEQRA) before Article 10 in the Everpower case (Town of Allegany). He represented municipalities or citizen groups in Article 10 proceedings in the cases of Cassadaga (the first Article 10 proceeding), Lighthouse Wind, and Alle-Catt and the Horseshoe Solar matter (Town of Rush) until it transferred to Office of Renewable Energy Siting under Exec. L. 94-c.

Overview

The Climate Leadership & Community Protection Act (Climate Act) established a New York “Net Zero” target (85% reduction in GHG emissions and 15% offset of emissions) by 2050. The Climate Action Council (CAC) was responsible for preparing the Scoping Plan that outlined how to “achieve the State’s bold clean energy and climate agenda.” After a year-long review, the Scoping Plan was finalized at the end of 2022. Since then, the State has been trying to implement the Scoping Plan recommendations through regulations, proceedings, and legislation. However, this does not mean that there is a feasible plan that includes milestones, acceptability criteria for targets or boundary conditions that must be met to continue.

I think the crux of the problem is that the State never bothered to develop siting acceptability criteria to guide permitting decisions. Combined with the ORES monomaniacal focus on permitting renewable projects without consideration of local concerns, environmental protections developed over years are routinely ignored.

Fort Edward Solar Filings

In my previous posts on this topic I have argued that the Fort Edward, Washington Co., PSC No. 23-03023 project is a travesty of ORES environmental siting considerations. On October 27, 2025, Fort Edward Solar responded to the Issues Statement, Party Status Request, and Public Comments on Draft Permit. Filings included the Fort Edward Solar cover letter with a memorandum prepared by WSP USA, an engineering and professional services consultant responding to avian issues; a facility location map, their response to public comments, response to issue statements, and a couple of conservation easement documents. On the same day, ORES staff filed their Responsive Brief and Filing Letter.

Bird Habitats

The main issue with Fort Edward Solar is its location relative to grassland bird habitats. In my opinion, responsible solar siting would focus first on land that has the least ecological or agricultural value. As Abraham explains this is not the case:

The grassland bird habitat map (Figure 1) was submitted by my colleague Ben Wisniewski, representing the Grassland Bird Trust, Inc., showing that “the Project is proposed to inhabit a unique area of extreme importance to birds. The 1,828-acre project site (the ‘Project Site’) lies within the New York State Department of Environmental Conservation (‘NYSDEC’) Washington County Grassland Bird Conservation Center (‘GBCC’). In addition, within the Washington County GBCC, the Washington County Grassland Wildlife Management Area (‘WMA’) serves as an anchor field for grassland birds.”

Figure 1: Attachment B Grassland Wildlife Conservation Areas near Fort Edward Solar Project

“The proposed Project Site surrounds the WMA and is situated within a recognized ecological area of critical importance for grassland birds . . .” Specifically, the WMA anchors the adjacent Audubon-designated Fort Edward Grasslands Important Bird Area (IBA), the NYNHP Raptor Winter Concentration Area, Grassland Bird Trust (GBT) properties, NYSDEC Grassland Wildlife Management Area, all areas known to be occupied by threatened and endangered bird species.

That’s why these areas are protected locally. The map, submitted with the party application, shows that the proposed solar project surrounds these areas, sharing their property lines. That is, as Ben showed, the project location is “inconsistent with the numerous special conservation designations and initiatives already applicable to the Facility Site.” ORES Staff now says none of that matters.

Avian Memorandum

WSP USA prepared an analysis that addressed the issues raised by Grassland Bird Trust (GBT). The analysis addresses the following issues presented in the Fort Edward Solar Avian Impact and Mitigation Assessment prepared by GBT:

Value of Proposed Project Site for Grassland Birds
Impacts of Proposed Project on Grassland Birds
No Proof that Proposed Mitigation Provides a Net Conservation Benefit
Default Permit Conditions are Insufficient to Mitigate Impacts to Grassland birds in theWildlife Management Area (WMA)

I am not a biologist so I cannot opine upon the quality of the analysis. However, I am familiar with the process. Site surveys to determine which birds are in the area to be disturbed must be conducted. As far as I can tell there is agreement about the species in the area. Site surveys to determine current and future land use are also necessary and this is the controversial bit. There isn’t agreement about the value of agricultural fields used as pasture lands or hay production relative to the quality of native forests, shrubland, and wetlands when “analyzed on a terrestrial habitat quality level.”

Another aspect of the process is that developers can mitigate impacts within the areas disturbed by their project by obtaining protecting land nearby that has the habitat characteristics desired. GBT argued that Fort Edward Solar would need to conserve substantially more land in order to provide a net conservation benefit. The WAP USA analysis cited ORES regulation § 1100-6.4(o)(3)(ix) that reads as follows:

If the permittee proposes a NCBP [net conservation benefit plan] involving permittee-implemented grassland bird habitat conservation in lieu of payment of a mitigation fee pursuant to subparagraph (viii) of this paragraph, the required mitigation ratio shall be 0.4 acres of mitigation for every acre of occupied grassland bird breeding habitat determined to be taken and 0.2 acres of mitigation for every acre of occupied grassland bird wintering habitat determined to be taken.

The wetlands offset ratios specified by New York Department of Environmental Conservation (DEC) guidelines are typically 2:1 or 3:1 or much greater than the ORES regulation. At the risk of stepping outside my expertise, it seems to me that the ecological values of wetlands are greater than grasslands so the mitigation offset ratio should be higher not lower.

Gary Abraham has extensive experience with environmental permitting. He points out that in DEC permitting processes these tradeoffs would be addressed in the permitting process. ORES simply ignores the tradeoffs and does not give parties a chance to present their side of the issue. Abraham explains the differences.

The potential for adverse impacts on protected birds (a “significant” issue) is clearly proven by this map (making it a “substantive” issue, i.e., “a reasonable person would require further inquiry”, 16 NYCRR § 1100-8.3(c)(2)).

In its response to Ben’s petition for party status on behalf of GBT, ORES Staff issued a brief concluding that there is no reasonable basis to inquire further, and recommending that ORES reject GBT’s issue (which it will undoubtedly do).

I want to reiterate my belief that ORES has shortchanged DEC and other agency recommendations because ORES does not address tradeoffs. The politicians who wrote the law implementing ORES (the RAPID Act) did not write the regulations that are being applied here. The RAPID Act purpose is plainly to “ensur[e] the protection of the environment”. PSL Art. VIII, § 136. ORES simply failed to do that here. Abraham explains how this works.

Among other things, Staff says that the “NYSDEC Strategy for Grassland Bird Habitat Management and Conservation 2022-2027”, while in conflict with siting the project here, is not a required regulation, but rather a voluntary program. The Strategy (undoubtedly part of the state’s environmental policies) is thus magically not inconsistent with siting the project here (Staff says nothing in the Strategy “speaks to siting of the Facility in the proposed location”). The brief goes on to dismiss factual assertions that the project will adversely impact the other protected bird areas, including an Audubon’s Important Bird Area, despite the fact (acknowledged by Staff) that the project covers “15 percent of the IBA”. There is, according to Staff, no “authority that prohibits or limits siting of the Facility in this designated area.” But that’s because ORES does not site renewable energy facilities. Developers do that and are not required to consider alternative sites. ORES simply permits sites that developers select. It is a misnomer to say ORES sites projects. It does not. –Staff adds that the intervenor party has not “demonstrated that impacts have not been sufficiently identified” in the application. But that’s not the standard. The standard focuses on the potential for adverse impacts on the environment and whether, based on that potential, a reasonable person would want to know more about the impacts, not on legal prohibitions to renewable energy siting (which do not exist) which (as Staff argues) ought to preclude any further inquiry.

ORES Staff says it will be sufficient if the applicant makes a payment to the Endangered and Threatened Species Mitigation Bank Fund. See 19 NYCRR § 900-10.2(f)(1). But the ORES regulations require Staff to consider impacts on “Audubon Important Bird Areas”. NYCRR § 900-10.2(g)(3).

ORES says, for example, that a designated raptor wintering area, protecting endangered Short-Eared Owl and the threatened Northern Harrier, also located within the project area, is identified in the application which already acknowledges that the “wintering occupied habitat will be impacted”, but “the Office’s [ORES’s] Take Determination quantifies the impacts and therefore requires an NCBP [net conservation benefit plan]”, which in turn allows the applicant obtain a taking permit by doing no more than making a payment to the state’s E&T Species Mitigation Bank Fund.

Thus, because impacts on protected bird species are addressed in the application, there can be no significant issue. Therefore, there is no point to considering substantive proof on adverse impacts to the environment.

This is how ORES circumvents the “substantive” and “significant” standard for adjudicating issues that it inherited from NYSDEC (where it was an opportunity for public participation).

Public Comment Response

One of the filings on October 27 was a response to public comments. I want to note just one example of the hypocrisy of the Fort Edward Solar developers. The first comment from Janice Teft stated:

I am writing with respect to the plan by Fort Edward Solar to build a more than 1,828 acre solar Facility in Ft. Edward NY.

This project will cause great harm to grassland birds and endangered threatened raptors. It is the worst possible place for a solar facility. It’s time to stop taking land away from Wildlife in general.

I enjoy going there, especially in the Winter, to see the Snowy Owls. It’s an Audubon designated Important bird area.

The thought that this is even a possibly is so disturbing in so many ways.

All conserved land should be located in the important bird area, not some random place in NY.

And, the developer should work with the Grassland Bird Trust which has worked for over 15 years to protect this area.

Thank you for consideration of my comments

Janice Tefft

Here is the response of the developer:

The Applicant shares your commitment to environmental stewardship and has actively engaged with the appropriate regulatory agencies throughout the development of the project. Specifically, the Applicant has conducted consultations with the New York State Office of Renewable Energy Siting (ORES), the New York State Department of Environmental Conservation (DEC), the U.S. Fish and Wildlife Service (USFWS), and the U.S. Army Corps of Engineers (USACE). All documentation related to these consultations has been submitted and is publicly available within the official ORES docket for the Fort Edward Solar Project (Matter No. 23-03023).

The Applicant has been diligent in following the permitting process outlined by the State of New York, including comprehensive environmental assessments, coordination with regulatory agencies, and the development of mitigation strategies to address potential impacts to protected species and habitats. In support of this effort, the Applicant continues to work closely with qualified consultants to ensure thorough evaluation of all project components and the application of best practices.

The Applicant recognizes the ecological significance of the Fort Edward grasslands and understand the concerns regarding habitat loss and its potential effects on declining grassland bird populations. As such, the Applicant is committed to continue working with regulatory agencies, ORES, and stakeholders to develop mitigation measures that reflect the importance of this habitat.

This response has no substance; it simply reiterates that the developer followed the regulations and shows the environmental poverty of regulations. If Fort Edward Solar shared her commitment to environmental stewardship, then they would not have applied to build a solar facility on recognized ecological areas of critical importance. Presuming that there was no other place in the state for their development then they would have proposed to mitigate their impacts by protecting more critical habitat than the ORES minimum.

Discussion

I believe that the Climate Act net-zero transition plan will do more harm than good because of impacts on affordability, reliability and environment impacts. In my opinion, the Andrew Cuomo and Kathy Hochul Administrations have politicized all the New York agencies. Speed in approving developers’ sites has eclipsed the purpose of siting, to balance the need for renewable energy sites with the serious environmental degradation they often cause. Ultimately the problem is that the Hochul Administration has never defined acceptability criteria for such sites. The Climate Act and its progeny, the RAPID Act, have probably caused greater environmental degradation than it avoided. As shown here, because ORES is the final arbiter the DEC charged with protecting the environment has little leverage in the siting decisions.

In my opinion, responsible solar siting would focus development in areas that do not affect ecological areas of critical importance period. The WSP USA analysis incorporates every trick to minimize mitigation ratios. Because grasslands are an interim successional stage, they argue that were it not for their commitment to maintain the grasslands, then the land would be dominated by woody vegetation. So why doesn’t the developer build on land that is dominated by woody vegetation?

Conclusion

The ORES process ensures that renewable energy development causes more harm than good. It is long past time to reconsider a process that prioritizes building as much renewable energy capacity as possible as fast as possible without any siting criteria.

Ellenbogen Tries to Talk Sense to an Irate Ratepayer

The ongoing Consolidated Edison Company (Con Ed) rate case is going to raise rates. Unsurprisingly, ratepayers are upset. This post describes an email that was sent to the distribution list for the parties in the case by an individual who I think lives in New York City. She argues that the cost increases are unacceptable because “Hard working New Yorkers shouldn’t have to decide between a doctor’s visit or keeping the lights on.” She goes on to say this problem is made worse by climate change and claims “Con Ed continues to perpetuate our state’s dependence on fossil fuels by advocating for infrastructure like gas pipelines that would increase the cost burden on New York consumers and fail to adequately address the peak energy demands of our state and city.”

Unfortunately, she hasn’t made the connection that the Climate Leadership & Community Protection Act is part of the reason for the higher rates. Richard Ellenbogen and I share the same frustration that people like this fail to connect the dots. This post publishes his response to her email.

Ellenbogen Background

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

STOP STOP HIKING RATES

On 10/28/2025 12:10 PM, Annie Pahlow sent an email about the Consolidated Edison rate case.

To whom it may concern New York electric and gas bills are already some of the highest in the country. It is absolutely inexcusable to approve a rate hike that would increase the cost burden on New Yorkers across the state when the company already makes billions in revenue. The monopoly Con Ed has on New York City delivery upcharges consumers while hundreds of thousands of New Yorkers struggle to pay their bills or even have their utilities shut off as a result. Energy is a human right and an absolute necessity. Hard working New Yorkers shouldn’t have to decide between a doctor’s visit or keeping the lights on.

With the worsening effects of climate change, summer heatwaves are becoming worse and more frequent, making summertime cooling essential for vulnerable populations. Due to the high cost of energy nearly 20% of New Yorkers who own air conditioners can’t afford to run them because of the financial burden to do so.

In the face of the climate crisis, Con Ed continues to perpetuate our state’s dependence on fossil fuels by advocating for infrastructure like gas pipelines that would increase the cost burden on New York consumers and fail to adequately address the peak energy demands of our state and city. They might claim this hike would fund clean energy investments but these are in bad faith as they continue to advocate for additional pipeline infrastructure that is unwarranted and unnecessary. It is abhorrent that Con Ed would dare to request a rate hike when failing to commit to transitioning away from fossil fuels completely, in accordance with our own state’s goals of being net zero by 2030.

30% of New Yorkers struggle to pay their energy bill and these rate hikes would only increase the cost for folks to stay cool in the summer, and warm in the winter. The proposed rate hikes for electric and gas would cost New Yorkers $30-$50 more per month and has drawn widespread criticism from elected officials across the board. That is why the New York Public Service Commission should outright reject the proposed rate hikes for electric and gas from Con Ed.

Ellenbogen Response

On October 28, 2025 2:34 PM Ellenbogen sent the following response:

You should get out of your ideological bubble and look at the math. The rates in the downstate region are too high but your proposals will raise them faster. I suggest that you read the New York Independent System Operator (NYISO) 2025-2034 Comprehensive Reliability Plan. It would be great to transition away from fossil fuels except the electricity doesn’t exist to do so and won’t exist for decades. Figure 16 from that report is included below. Everything below the black lines at “0” is a power failure and the margins will soon be supported by generation that is well past its usable life. Good luck running a heat pump with no electricity.

Source NYISO 2025-2034 Comprehensive Reliability Plan.

Further, the downstate region is only 5% renewable. That can be seen in the following pie chart from page 8 of the same document. Con Ed’s reliability analysis stopped at their borders but what happens when the electricity isn’t there for Con Ed to supply? The NYISO isn’t lying or exaggerating. I was called anti-electrification by someone on this email distribution list but the reality is that you can’t electrify without having enough electricity. This is quickly becoming a crisis that will result in loss of life. What I am against is killing people to support a policy that won’t have any environmental benefits.

The next graph is one I did for engineers at NYSERDA in 2019 and updated in 2023. Their engineers confirmed the numbers and the underlying math. I haven’t recalculated the rates for 2025, but electricity costs have been rising faster than gas making the disparity even higher, so if you really want to bankrupt ratepayers have them install electric heat. That’s why certain parties have been trying to get a special utility rate for heat pumps as part of this tariff hearing but those rates have to be subsidized by other ratepayers. Once everyone is on the special rate, who will subsidize it? And what about the rising costs for other ratepayers that have to pay the subsidies for a heating technology that doubles costs? If you want to replace oil combustion with heat pumps, that will lower people’s bills and you wouldn’t even need subsidies, but replacing locations with gas will not lower bills or emissions.

Another aspect of the New York transition is ignoring results elsewhere. Ellenbogen explains the problem:

If your answer is to install more solar and wind to increase electrical output, Germany has been trying that for 35 years since 1990 and has reached 34% renewable generation with electric rates 2 – 3 times higher than France next door despite spending hundreds of billions of dollars attempting it. They claim 42% but the last 8% is wood combustion with a higher carbon footprint than coal and far higher particulate emissions that cause respiratory diseases. The same time frame of 35 years would take New York State to 2061 with still no viable solution installed. If Germany is an example, the rates would be much higher than they are now. I could explain why that is the case, but it would take another full email.

The renewable technologies can help to lower CO2 emissions, but they don’t have the energy density or the reliability to fully support a modern society. Germany has added gas generation recently because the renewables can’t generate enough electricity. Further, the areas of NY State where there is room to install renewables are cloudy for a significant portion of the year and there is no existing storage technology that will carry energy for 6 months to heating season. Even if it could be built, the cost would be trillions of dollars (Yes, Trillions). The cost to install that storage technology would raise rates beyond anything we have seen to date. The money must come from somewhere so the people of New York State will either pay it through their utility rates or their taxes. Either way, it will make New York State less affordable.

There is another unacknowledged challenge for New York. Our renewable energy resources are less than other jurisdictions.

Extreme cold kills a lot more people every year than extreme heat but ideology promoting solutions that won’t work is going to waste time and resources that could be applied to fixing things. It will also raise utility rates with no climate benefit. You can’t compare New York State to California, Australia, Texas, or the Iberian Peninsula. Those are all warmer climates with a far superior renewable profile when compared to New York State so they have more efficient renewables and they don’t have nearly as large of a heating issue and in some cases, they have no heating issue which greatly reduces energy requirements.

Ellenbogen explains the basis for his claims.

And before someone tells me that I am inflammatory and unprofessional, keep in mind that I own two solar arrays, both installed in 2007, a home with the most efficient geo-thermal heat pump system in New York State, and my factory recycles 99% of its waste byproducts and generates 80% of its electrical energy onsite with a carbon footprint 30% – 40% lower than the Con Ed system. I have also driven a Tesla since 2017. I have 47 years of experience with energy systems, and I have written papers for the Public Service Commission, one of which was used to initiate a utility conference on line loss. As a result of that experience and training, I understand what works and what doesn’t because I understand the math and physics underlying the systems. My factory’s utility bills in the Con Ed Service Area have gone down by 4% over the past two years while everyone else has had theirs increase by about 14% because I have applied that knowledge to implement solutions that will work. Between October 2022 and October 2023, the factory’s utility bills were $69,999 and over the past twelve months through October 2025, they were $67,265. That amounts to $1.20 per square foot for the 55,000 square foot facility or about one-third the energy costs of the average commercial/industrial facility in NY State. Those are total energy costs for the facility and include both electricity and gas.

Ellenbogen concludes:

Ideology cannot supersede math, physics, or thermodynamics. In the end, reality will always rear its ugly head because it doesn’t care what anyone has to say about the issue. A failure to recognize that fact will reduce reliability and raise costs which is already happening across the state.

Final Comment

As shown in his response, Ellenbogen has the background and experience to build a low carbon system that works and knows what will not work. He has shown that the current New York plan will not work. I seriously doubt that people like Annie Pahlow will listen to his expertise until the blackouts he expects occur. I give him an E for effort.

Ellenbogen on Recent NYISO Reliability Concerns

On October 13, 2025 the New York Independent System Operator (NYISO) released its quarterly assessment of reliability of the bulk electric system. The analysis found a deficit in reliability margins for the New York City area beginning in summer 2026. NYISO also released the draft 2025-2034 Comprehensive Reliability Plan (CRP), that provides a plan to maintain a reliable electric grid over a ten-year planning period. This post presents Richard Ellenbogen’s take on the issues raised.

Ellenbogen Background

This post is based on an Ellenbogen email. In his introduction he note that he has been warning about this situation since the gas moratorium commenced in 2019. When he started looking at the issue it took him about 8 hours total across two evenings to realize that the state’s plan didn’t have “A snowballs chance in Hell” of working. He joined the PSC Case 15-E-0302 in July, 2023 because he was so concerned about this situation. His August 2023 filing lists all of the problems with the current plan that he had been addressing with state legislators, NYSERDA, and the PSC since 2019. Keep in mind that many of the solutions that have been proposed are from parties that have a monetary stake in the various outcomes, or from climate activists or biologists that have absolutely no idea how the system works. Ellenbogen hasn’t taken a penny from anyone for any of the thousands of hours of work that he has put into this. He just wants to see the lights stay on and to not have anyone die in a power failure. He states: “This is entirely about protecting the state’s energy system in general and the downstate system in particular because that is at a far higher risk of failure.”

Alternative Approach

In my opinion, the biggest reason to pay attention to his work is that he walks the walk. He has reduced GHG emissions at his home and factory. In addition, his home was powered though the entirety of a week-long power outage after Sandy and his factory can operate at 50% capacity during a power failure. He is working on bringing that up to 100% within a year. As a result, his recommendations are based on experience and not theory. The following quotes are from his email but include clarifying references.

Despite the mess that we are currently in, there is a viable solution to the problems described by the NYISO. The equipment could be here by 2028-2029 and installed by 2030-2032. However, it will require a sea change in the group think about natural gas. This will need to be done quickly as the rapid increase in data center construction is going to increase the lead times for this equipment. The lead time for new gas turbines from GE Vernova is now out to 2028 when I checked recently.

Retooling the three Long Island Power Plants, Port Jefferson, E F Barret, and Northport could increase their energy output and reduce their carbon emissions by about 50%. LILCO/LIPA wanted to do this in 2015 but was rebuffed by state planners that insisted on offshore wind, however that was never going to work, even before Trump. The wind bids in 2023 came in at $155/MWh, over twice that of other energy costs in the state. That is because of the Jones Act driving up installation costs or making them almost impossible to install entirely. As a comparison, offshore wind costs in the UK bid at that time, came in at $75 – $80/MWh showing the effect of the Jones Act on costs. Wind costs in Texas are at $25/MWh which is why they are having such a rapid expansion of the technology there. Additionally, wind speeds during the summer off the coast of Long Island are slower and would not support the summer peak electric demand even had the wind farms been installed.

The reason that such large CO2 reductions are possible with the new plants is that they are combined cycle. The three plants that I mentioned are steam plants, date to the 1960’s and 1970’s, and are 30% to 33% efficient in turning fuel into electricity. 67% -70% of the energy goes up the chimney. A combined cycle plant uses a gas turbine on the front end to make electricity at about a 33% efficiency but then captures the heat exhaust and uses that to make steam which is then fed to a steam turbine. The combined efficiency of the entire plant is about 60% – 65% plus the newer plants have better technology for reducing NOx, SOx and particulate emissions (PM2.5, PM5, and PM 10). NOx has a carbon footprint 100 times that of CO2. The emissions profiles of the three plants mentioned plus the Caithness plant are shown on the graph from the report. Caithness is combined cycle and they wanted to build Caitness 2 but that was rebuffed because the plant was so efficient that it would have rendered the other plants worthless and there was a legal agreement signed when National Grid took them over from LILCO. You can see the radical difference in emissions in Figure 1.

Figure 1: Emissions from Long Island Power Plants (Survey of National Grid Generation Formerly Owned By LILCO)

The higher efficiency reduces the energy costs and will cut the gas use nearly in half for each plant, freeing up capacity for Caithness 2 or to install larger generators at each location so that the peaker plants in NY City could be shut down if local transmission issues are resolved. Further, because there are already generating plants at the locations, the transmission infrastructure and fuel infrastructure already exists so there will be a minimal cost to bring it up to modern standards or if the capacities are increased making it a much less expensive option than the current plans.

I wrote a paper for the PSC in February that showed how NY State could combine the newer plants with carbon capture technology and achieve a 90% carbon reduction. The equipment exists but the generating plants would have to be increased in size by about 25% to net the same power output because that much energy would be needed to liquefy the CO2 and pump it two miles underneath the ocean floor. They would still use 25% less fuel for the same amount of usable energy but would be 90% carbon free. Babcock and Wilcox has that technology available now as do some other companies. Even without the carbon capture, the combined cycle plants are extremely worthwhile and could be retrofitted with the Carbon Capture technology later as long as they were oversized now to generate sufficient energy to supply the utility loads and liquefy the CO2.

Natural Gas

Ellenbogen and I agree that the state’s position on natural gas is a problem.

Regarding the natural gas issue that has proved to be such an albatross around the state’s neck, the idea originated at Stanford with Professor Jacobsen in about 2012 and was adopted by Professor Howarth at Cornell. I offered to debate Howarth at Cornell but he declined. I told him in 2019 that his ideas were misguided, and recent studies have proven him wrong. Howarth sat on the Climate Action Council and infected it with his thinking. They stated that the rapid rise of methane in the atmosphere was due to fracking and leaking pipes in the streets. However, a study from 2022 that scooped methane out of the atmosphere found that atmospheric methane has the wrong carbon isotope to be from fossil fuels. Instead, it is primarily from organic decay so NY State reducing gas usage will have almost no effect on methane emissions but it will leave us with no electricity. The Gas Stove study from the Rocky Mountain Institute that claimed that gas stoves caused childhood asthma was equally misguided.

Another solution that could be implemented even more quickly is to replace all of the older train cars on the MTA system. I joined three other independent intervenors in the Con Ed rate case tried to have that included, to no avail. Presently, only about 25% of the MTA subway cars have regeneration. By replacing the other 75% of the older cars with newer ones that have regeneration, we could reduce the peak load on the downstate system by about 500 Megawatts and save hundreds of Gigawatt-hours of energy annually. Now, when the cars slow down their brakes get hot requiring more maintenance. By adding regeneration, cars that slow down would put electric energy back into the system where other trains could use it to operate without needing additional generation. As rush hour coincides with peak utility usage between 4 PM and 10 PM, the maximum energy savings would be occurring exactly when it was needed. The energy savings and the reduced brake maintenance would decrease the costs of operating the system. The 500 Megawatts is also more than the capacity of the oil fired peaker plants around the city. As more lower- and middle-class people use mass transit, that is actual climate justice. We have spoken to people at the MTA and they agree that this would work.

All of the above expenditures will yield monetary savings and provide the region with sufficient energy while also greatly reducing carbon emissions. Additionally, load increases from building electrification should be curtailed until we have enough generation to support it. If they want to engage in energy efficiency and carbon reduction, they can do the following which will reduce energy and electric use while also saving the ratepayers money:

Have people eliminate oil combustion which has 50% higher emissions than gas and also has higher particulate emissions. Switch them to either gas or electric heat pumps. Oil is also much more expensive than either alternative.

Subsidize homeowners that have electric radiant heat and get them to switch to heat pumps. It will cut their bills and their energy usage by about 60%. That technology is more prevalent upstate.

Wrap all heating pipes with insulation to reduce heating loss and improve building envelopes (windows and insulation)

Encourage large energy users to install CHP Systems. It’s the technology that I use in my factory and I have saved about $1 million in utility bills over the past 14-16 years while also reducing our carbon emissions by about 30% – 40%. Large apartment buildings in close proximity could also Siamese their heating systems and cooling systems and install CHP systems to run them with a great benefit.

Add rooftop solar. As it doesn’t need transmission infrastructure it is relatively inexpensive to install and it not only reduces energy use but it also reduces transmission line losses which average to 7% over the course of the year and up to 11% during the summer when the solar arrays make most of their power.

Get rid of NY Steam and use the steam from that plant to generate electricity. Convert NY Steam users to alternative electric heating and cooling. That will provide additional electric energy and NY Steam is a technology that has outlived its usefulness in the modern era. All of those steam puffs rising out of the streets are lost energy, the system needs a huge amount of maintenance, and because a large portion of it is “open loop”, huge amounts of hot condensate are dumped into the sewers every year putting more strain on that system and greatly increasing fresh water usage. Disposing of all of that hot water is also energy loss. They could still use the steam system for the closed loop portion of the system that is located near the steam plant. This will anger Con Ed because NY Steam is a Cash Cow for them but is being operated to the detriment of NY State residents and to the environment.

Conclusion

I am in complete agreement with Ellenbogen’s concluding remarks:

One of the reasons that Roger Caiazza and I filed the article 78 against the PSC and the state energy policy is not because I am against carbon reductions or energy efficiency but instead because the present plan is unworkable and based upon an unattainable fantasy. If the legislature doesn’t fix the mess that it has created by revising these policies, for lack of a better term, we are all screwed. The PSC is stuck trying to adhere to a state policy that isn’t going to work. I said as much when I addressed the NY Senate Energy and Telecommunications committee this past March.

That fantasy is now running headlong into reality and maybe now, people will finally understand what I have been warning about for six years.

If someone wants to install solar or wind and it is cost effective, then fine but we need sources of firm generation now.

Guest Post: Climate Change and Electric Utilities

One of the nice things about writing this blog has been the opportunity to meet people online. For example, one such contact recently reached out and we discussed opportunities to collaborate. He sent me an article that is the basis of this post.

Background

A friend of this contact is a registered PE with several decades of design work for electric utility power plants. He is still working and wants to remain anonymous because his views are not aligned with the his employer. His situation is similar to Russel Schussler aka “Planning Engineer” who published articles at Judith Curry’s Climate Etc. for years before his retirement. I too have been affected by the concerns of utility management regarding my work here. For the record, the opinions expressed in this article do not reflect the position of any of our employers or any other organization with which we have been associated.

In the following I chose to lightly edit the article I received from “Design Engineer”, added some introductory/clarifying paragraphs, and have included some personal comments in the discussion section. I apologize if I have misconstrued anything.

The Problem

Electric utilities must deal with the competing dynamics of political pressure, responsibility to shareholders and societal accountability. This has led to policies that are likely not in the best long-term interests of most people.

Today, regulated utility CEOs are glad to get rid of coal plants that operate 85% of the time to install windmills that operate 30% of the time and solar that operates 15% of the time. They also must install battery storage of some kind to store the wind and solar energy because wind and solar only operate when nature allows it to operate but electric customers want power all the time. However, to have the same reliability of utilities power production, the rate base attributable to power production will have to increase by 5-10 times if coal plants are shut down.

So why is this occurring? Regulated utilities get earnings from the rate base. The rate base increases when you build new plants. The complete cost of the new plant goes into the rate base. The new equipment then is depreciated. The rate base decreases each year if no additional capital expenditures are made. Most coal and nuclear plants have low values in the rate base. So, getting rid of coal plants and installing wind, solar and battery storage increase utility earnings, and the CEOs pay. It doesn’t matter if a regulated electric utility builds a plant that never runs. As long as it is in the rate base it makes the company money because of rate base accounting.

There are other financial incentives as well. Banks and Wall Street want utilities to shut down coal plants so they can lend them money for new wind, solar and battery plants. Bank CEOs have a vested interest in pushing climate change hysteria so they can increase earnings. Wall Street sees the potential for lower risk investments if the renewable energy spending is guaranteed a fixed rate of return by Federal and State policies.

Lost in the greed are the customers. All the subsidized windmills, solar installations, energy storage and other electrification installations are adding to our national debt. This cost is hidden from consumers. Ultimately these costs go to the taxpayers and the citizens of this country.

It gets worse. Increasing electric costs make our industries uncompetitive on the world stage when compared to countries like China and India who do not worry about so called climate change. In 2024 the world shut down 17,000 MW of coal plants and China built 17,000 MW of coal plants. World CO2 levels are not decreasing. All we are doing is sending jobs to China and decreasing our national security by not manufacturing equipment in the United States. China is now producing four times the CO2 of the United States. If you are worrying about dying from climate change, why would you buy anything from China.

This is why I think climate change is all about making money. The greedy CEOs in this country have brought the communist country China to power by transferring all of these manufacturing jobs to China and letting them grow out of the dark ages. This has made the world much more dangerous.

Here is a short sidebar lesson on tariffs. The economic textbooks say free trade is good. Every country produces the products that they are most efficient at producing and trades with other countries. An example would be aluminum smelting which occurs where electricity is very cheap because the process of creating aluminum is very energy intensive. This benefits all countries. What is never mentioned is this free trade principle is based on all exogenous variables being the same. That means regulations, environmental laws, lawyers suing people or companies, countries such as China providing cheap capital to companies. These all have to be the same between countries for there to be real free trade. If you think China has the same environmental laws as the US you are kidding yourself. They also don’t have to deal with the multitude of lawsuits US companies have to deal with. US companies don’t normally receive subsidies from the government until President Biden came along. So, there may be some free trade in the world. None of it is occurring in China.

When I started working for an electric utility in the 1980s, the mantra was 1/3 customers, 1/3 employees and 1/3 shareholders. Each of those groups was to be considered when making decisions. This has migrated to 100% shareholders over the years. If this old mantra was in place now electric utility executives would have fought the environmentalists because they know electric prices would rise dramatically. My salary would also be more than double what it is now if I kept the same relationship of salary to the CEO. And this compares a new engineer to a 40-year veteran engineer. The point I am making is it is all about shareholders now. And customers don’t have an alternative. At least employees can leave.

The Coverup

Design engineers and plant engineers in electric utilities realize renewables are a big scam. Rates will increase dramatically, and we may have blackouts too. Unfortunately, it is not a good career move to speak out and unscrupulous engineers go so far as to lie to stay in the graces of management.

The only way to make a windmill markedly more efficient is to make it bigger. In my experience, the newer windmills that are larger only have a 10-year life on land. The older, smaller windmills have a 15-year life on land. Windmills installed in the ocean only have a 5-year life. Solar plants have a 15–20-year life. Currently there is no recycling options for windmill blades. They are also still working on recycling options for solar installations. Where is all of this waste going to go?

There is another wind siting concern. As more and more sites get developed, the remaining choices may have less wind resource availability and other problems. Some good sites left are impacted by endangered bat species. There is now a windmill location in NE Missouri that is not operating for about 6 months a year because of endangered bat species.

The availability difference between renewables and coal plants is stark. Most coal plants have a 60-days coal storage pile on site. The plants can pump electricity out for 60 days even if their coal supply is shutoff. Midwest utilities know how to handle frozen coal problems in winter due to extreme temperatures. Windmills have restrictions on cold weather operations to protect the blades and gearboxes. These values have been decreasing. Five years ago, they could not operate under 9 degrees F. These cold spells often are characterized by light winds so just when you need the power the most, the windmill can’t provide it. And if you get a snowstorm, ice storm or cloudy days solar isn’t much help. Ice storms can also shut down windmills. None of these things shut down a coal plant. Coal plants can run at 25 below zero in the Midwest. I have witnessed this three times in the past 35 years.

Every windmill and solar installation that is built requires backup. If you build a 100 MW wind installation, you need to build a 2400 MWhr battery farm to store one day’s worth of energy. This is 100 MW x 24 hours = 2400 MWhrs. A Tesla 100 MW power wall can store 400 MWhrs of electric energy. So you would need six 100 MW Tesla power walls to store one day’s worth of wind energy. The cost of the power wall far exceeds the cost of the windmill or the solar installation. Utility executives have finally realized this. That is why they are now building natural gas power plants with abandon. They know windmills and solar cannot provide a reliable electric grid. They are happy to build any kind of plant because they all go into the rate base. Shareholders are happy. Customers are hurt badly.

All these natural gas plants being built are interruptible in winter. That means the pipeline companies will shut off the gas flow to natural gas power plants when the weather gets cold because they must supply the natural gas to natural gas heating customers. Electric utilities are not willing to reserve the pipeline capacity because the demand charges are so high. You would need dedicated new pipelines to feed all these natural gas power plants. That would increase the cost of the plants exponentially. Instead, utilities are building 3-day oil storage on site. They hope a 3-day cold snap could be met with oil storage. Historically that is not a good bet. In 1982 there was a 24-inch snowstorm with a cold snap that lasted longer than 3 days. Also, they will be depending on the combustion turbine to be operating successfully on possibly subzero temperatures when the oil-fired part has not been used the rest of the year.

The extra use of natural gas year-round for electric power will increase natural gas prices for gas heating customers. So, consumers will face a double whammy: Rising electric rates and rising gas rates.

Consumers are also impacted by the drive to electrify home heating. Environmentalists are pushing heat pumps. This may be an acceptable alternative to gas heating in the south. In the Midwest and North, it is a risky proposition. It is notable that many utility engineers are installing backup generators to power their gas furnaces. A small generator can power the furnace blower and controls in winter. Whether you lose electricity due to insufficient power production or an ice storm, you can stop your house from freezing. With the preponderance of two-story houses, you can no longer drain your water piping like in the old days with ranch houses with unfinished basements. Activists do not acknowledge that installation of heat pumps may cause many people to lose heat and suffer damage to their homes which will be expensive to repair.

There is another ignored problem with the transition away from coal. There are not enough pipefitters, electricians, millwrights, carpenters, iron workers, boilermakers, laborers and engineers to build all of these plants. There are not enough line workers to build all the transmission lines to transmit the electricity from good wind locations to the population centers. We are shutting down perfectly good coal plants with many useful years of life left. We are basically destroying our capital base of coal plants.

Now all the computer companies such as Google and Microsoft want to build data centers to increase their earnings. This occurs after their efforts to eliminate coal plants for the last 20 years. They don’t care about electric rates for the consumer. They are just worried about increasing their profits.

In conclusion, we should be bringing back coal plants if they haven’t already been torn down. I believe that current policies are causing an energy crisis.

Caiazza Discussion

I agree with “Design Engineer’s” conclusions. I also want to make the point that every time I have talked to a different power plant expert, there always has been a new concern or two raise that I did not know anything about. In this case, the expected lifetimes of the large windmills in the Midwest are shorter than I expected. Some may quibble with these numbers but there simply isn’t a lot of experience with the gigantic windmills.

The biggest takeaway is that we are in the midst of a great experiment where short-sighted policies are shutting down coal plants that have a proven record as a reliable source of electricity in extreme weather. At the same time, there is a drive to electrify home heating which puts a greater emphasis on the need for reliable electricity during extremely cold spells. These policies will also raise consumer prices.

I believe the transition away from coal-fired power plants will cause an energy crisis that will do more harm than good. Consumers will pay more for less reliable power risking the potential for catastrophic blackouts.

My thanks to Design Engineer for his submittal.

Washington State Goes One for Three on the Pragmatic Climate Scale…Maybe

One of the things that makes my blogging obsession worthwhile is meeting people across the world in connection with my posts. It varies from people who comment on my work in the comments section of posts to people who have corresponded directly. The direct contacts have provided insights into their own experiences that are helpful to me. There also are a few who write with material that I use for guest posts. Paul Fundingsland is one of the latter who has provided information for posts about his experiences in Washington State with their net-zero plan. This post annotates the article (Washington State Goes One for Three on the Pragmatic Climate Scale…Maybe) that I edited for him to post at Watts Up With That.

Paul describes himself as a “Free Lance writer with a two decade long obsession with all things climate change.” Although he is a retired professor, he has no scientific or other degrees specific to these kinds of issues that can be cited as offering personal official expertise or credibility. What he does have is a two-decade-old avid, enthusiastic, obsession with all things Climate Change related.

In this article he described three climate related initiatives that were decided in Washington recently. Initiative 2066 was a referendum to repeal laws and regulations that discourage natural gas use and would require current natural gas customers to switch to electric heating. Initiative 2117 was another referendum to repeal the state’s commitment to reduce greenhouse gas emissions by 95% by 2050 in the Climate Commitment Act. Finally, the Horse Haven Wind, Solar and Battery Complex permit was approved.

Initiative 2066

I am envious that Washington State has a way for citizens to demand a referendum to put a law up for a vote of the people. This was one of two recall referendums.

The bright spot was the successful passage of Initiative 2066 which ensures access to natural gas in homes and other buildings and repeals a state law requiring plans to transition from the use of natural gas to electricity. The final tally was 52% yes, 48% no.

Washington is basically a one-party blue state – Kamala Harris won by a lopsided 58% of the presidential vote. Even though only a third of the residents rely on natural gas with the bulk of the populace (58%) using electricity, the “yes” vote prevailed in a surprising outcome given the political demographics.

I think there were several reasons for the outcome. The main issue that resonated with all the gas users was the extreme cost of a switch over from gas appliances to all electric they would be expected to finance almost entirely by themselves. Since Washingtonians have been using gas with no significant identifiable adverse effects for decades, it was hard to convince them that demonizing the use of gas was now all of a sudden, a threat to their health and wellbeing. There also may have been a fair number of the electric heat users who preferred using gas for cooking and in their fireplaces.

The “vote no” people took the main tack that using gas was a pollutant, a health hazard and would prevent the State from achieving its Climate Commitment Act goals.

It is only a matter of time until a similar law is passed in New York that forbids natural gas use because the Climate Leadership & Community Protection Act (Climate Act) mandates building emission limits that can only be met if natural gas is prohibited. The New York Home Energy Affordable Transition Act (NY HEAT) puts some limits on natural gas use but stops short of the Washington law I think. Fundingsland goes on to point out that litigation of the referendum result is still possible.

Despite the result there still is a maybe part of the passage of this initiative. The “no vote campaign” intends to take this issue to the State Supreme Court. They are claiming it should be voided because it violates the State rule that an initiative should not embrace more than one subject. They have deep pockets to fight this vote of the people. The sore losers include the Sierra Club, Statewide Poverty Action Network, Front and Centered, plus “unnamed” renewable energy groups (no surprise there).

The “yes” campaign claims the initiative was written very carefully expecting successful passage to be challenged in court. The “no” campaign started putting their challenge together months before the final vote just in case it passed.

It will be interesting to see if passage of I-2066 by the voters is brought before the State Supreme Court. Voiding the obvious majority of the people on some sort of technicality could prove problematic in coming elections by raising rational voter ire. That might give the “no” campaign second thoughts as to how this may play out in the long run if they pursue this avenue of opposition.

Initiative 2117

The referendum on the funding approach for the Washington version of the Climate Act is timely vis-à-vis New York. The Hochul Administration is supposed to propose rules for the New York Cap-and-Invest program that will put a cost on carbon emissions. That regulation is late, undoubtedly because of political fears that the costs are too high. I was disappointed that a state that has seen a sharp increase in gasoline costs voted down repealing the Washington version.

On the losing side of the “one for three” pragmatic climate issues was voting down Initiative 2117 which would have essentially ended funding for the State’s Climate Commitment Act (CCA) resulting in lower gas prices at the pump. It really did not have a chance of passage once the big money came rolling in advertising against it.

The five biggest donors against passage were all essentially billionaires. They included Steve and Connie Ballmer, Bill Gates, Microsoft (the company) and the 4-billion-dollar Nature Conservancy. Their media ads were very slick, very professional and appeared all over the TV channels at all times of the day and night but especially during the evening news, sports (football, soccer etc.). They were even on the Fox Business News channel.

It really didn’t matter what time of day or what channel you were watching, there would be an ad to defeat this measure that would show up. The amount of money spent to defeat this measure must have been eye-popping.

The main selling point was that voting for I-2117 would cause unclean air, unclean water, worse wildfires, a dirtier environment with worse roads and transportation. Voting it down would mean cleaner air, cleaner water, better wildfire management, a cleaner environment, and even better roads and transportation. There was, of course, no mention of just how much less global warming would result from a no vote.

One of the ads featured individuals wearing their respective professional garbs advocating voting no (doctor, fireman, construction worker, forest ranger, Tribal member, etc.) An observation was that these are the very same special interest groups who have recently been getting money from the CCA fund so of course they don’t want to see those funds go away.

One of the ads accused the promoter of this measure (and three of the other measures) of being just a greedy millionaire out for himself. Never mind the billionaires who funded the campaign against it and how or whether they might benefit somehow from it being defeated.

It was obvious the campaign for passage of I-2117 did not have the requisite funding to successfully get their message across with the necessary effective media advertising. The ads were spread too thinly between several issues. The ads were somewhat rudimentary, lacking a professional look, and they appeared sparsely. They just didn’t have the money and the focus to get their message across.

My personal opinion is that had the “yes” ads concentrated on the fact that no matter how much you were paying for a gallon of gas (whether a high price or low one) $10 would be going to the state for every 20 gallons of gas they bought. I think that would have made a much bigger impact on the voters by helping them understand just how much they were sending to the State every time they filled up.

Sadly the billionaires won this one.

There still is hope because the costs, due to the law will only increase over time.

There is a chance this issue could be brought up for a statewide vote again at a later date, perhaps when Washington surpasses California for the cost of gas at the pump which may not be all that far off. If it is brought up again, the people behind it now know what they are up against and will have to adjust accordingly, being a lot more clever with their focus and their financing.

Horse Haven Wind, Solar, and Battery Complex

The other initiative was the approval of a massive renewable energy complex. Nobody has proposed a single project this big in New York yet.

The other one of the three climate-related issues is our Governor’s final approval of the “Horse Haven Wind, Solar and Battery Complex” in Eastern Washington. It’s a huge complex stretching 24 scenic miles long and 8 miles wide covering 72,000 acres with 5,000 of those farmland acres surfaced with solar panels. The final proposal is to have either 172 five-hundred-foot towers or 113 six hundred seventy foot tall towers. The battery complex is yet to be determined as to size and placement.

A valiant opposition movement (here) of Benton County residences, tribal members and wildlife advocates has been so far unsuccessful in stopping this monstrosity from happening. The Energy Facility Site Evaluation Council confirmed the Governor’s approval in a 4-3 vote. There is now only one more avenue to pause or stop the building of this grotesque complex…the court system.

And that is exactly what has just happened. Benton county has filed suit against the state over this project.

One other long shot outside possibility that might stop this atrocious wind project from being built could be when the new national administration takes office in January. Indications are that the new administration intends to terminate subsidies for wind and solar projects. If that does happen, it is likely the Horse Haven Wind Farm may become unprofitable to build.

Washington prides itself on being an enlightened, leading energy progressive state. This wind/solar/battery complex is anything but progressive. It is an exorbitantly expensive energy system at $1.7 billion (2021 estimate and counting) for the amount of intermittent power it can produce. It regressively degrades and seriously threatens the reliability of the existing electric grid by providing only non-dispatchable erratic weather dependent electricity.

Nuclear Power

I am convinced that the wind, solar, and energy storage approach epitomized by the kind of project will do more harm than good. I also believe that the only rational way to decarbonize the New York electric system is to deploy nuclear resources. Fundingsland agrees as shown in the following.

A leading enlightened progressive State would be planning on installing a small modular nuclear system such as NuScale’s Voygr-12 module complex of SMRs. The NuScale SMR system was developed in Oregon and is the only one so far to receive design approval by the Nuclear Regulatory Commission. Or the State could support the expansion or duplication of Amazon and Energy Northwest’s planned Central Washington installation of X-energy’s 12 module system.

Ironically, Energy Northwest is headquartered in Richland Washington. Their potential SMR site is a mere 50 miles from the planned wind farm next to the Columbia Nuclear Generating station (Washington’s only functioning nuclear plant). This gives their planned site close, easy access to the electrical grid.

Both SMR systems can deliver dispatchable electricity under all weather conditions 24/7365. They are CO2 free and can generate approximately 924 actual nameplate MWe where as the wind system will be lucky to generate 40% of its nameplate. And that energy will be erratic and intermittent grid destabilizing energy that requires storage. Their respective footprints use only a miserly 0.06 square miles of land in contrast to the wind farm’s approximately 100 square miles. Their environmental footprint is small, scenically unobtrusive, and non-threatening to birds of prey.

Both SMR products have a passive safety system so they cannot melt down or blow up. Each one of the 12 SMRs composing either company’s modular complex are built in a factory and can be delivered by truck, rail or barge in three sections.

There is a serious disconnect between the “Energy Magical Thinking” flowing from the Capitol in Olympia versus pragmatic, modern, non-invasive solutions available. This is especially disconcerting considering Portland Oregon (the headquarters of NuScale) is only 114 miles away from the capitol building in Olympia.

On the Washington boarder to the east, the state of Idaho is embracing and promoting nuclear with it’s Idaho National Laboratory Frontiers Initiative.

In their words:

“Eight states are developing economic development plans focused on advanced nuclear energy deployment with the help from Idaho National Laboratory’s (INL) Frontiers Initiative.

Frontiers was established in 2021 to help stakeholders identify and capitalize on key economic opportunities afforded by early adoption of advanced nuclear energy. The initiative also helps stakeholders leverage advanced nuclear to capture emerging global market opportunities in low-emission industries.

The 2024 Frontiers Initiative Impacts Report, released today, (Oct. 24) highlights the initiative’s impacts on first-mover states identified as actively pursuing advanced nuclear energy to encourage economic development.

We have strengthened our partnerships with stakeholders in first-mover states – Idaho, Utah, Wyoming and Alaska – while adding engagements where increasing interest in advanced

Nuclear energy intersects industry needs, including in Louisiana, Montana, North Dakota and South Carolina,” said Steven Aumeier, senior advisor at INL.”

One of the advantages of publishing at Watts Up With That is that there is much wider exposure than at this blog. As a result of the wider exposure there are more comments. Sometimes that is not so good but more often there are valuable insights. For example, in the comments to his article Beta Blocker provided links to several presentations and reports published in recent months concerning energy reliability in the US Northwest and described a hypothetical wind and solar expansion. There is an enormous amount of useful information in those two comments.

Fundingsland also recommended a movie is called “Nuclear Now”.

It is by Oliver Stone and was released just last year (2023). It is an extremely thorough movie about the development of nuclear power from the very beginnings to the present day. It basically covers all the various aspects of nuclear. This includes the past massive demonstrations against its use in the 60s-70s as well as the three scary nuclear power plant accidents and why those issues mislead and continue to color the modern deployment of nuclear power. It ends with a fairly thorough review of the modern nuclear systems, which countries are developing them (Russia, China, US) and how far along they are. And then it mostly concludes focusing a lot on SMRs.

Discussion

Fundingsland’s article argued that Washington is more talk than action. Given that I think nuclear is the rational approach I would argue that New York should be trying to emulate Tennessee rather than California.

transition, shamefully Washington State is not among these “first-mover states”.

If Washington was serious about being a modern enlightened energy progressive state, they also might want to look at what is happening in Tennessee. Their General Assembly created a $60 million fund (The Tennessee Nuclear Energy Fund) that has attracted four projects in the last six months headed by Orono USA, a company specializing in: “Uranium. Mining/conversion/enrichment, used nuclear fuel management and recycling, decommissioning shutdown nuclear energy facilities, federal site cleanup and closure and developing nuclear medicines to fight cancer”

Oak Ridge is determined to become “the place the nation is looking for to lead the next nuclear race”. Oak Ridge and Knoxville are now home to some 154 nuclear companies.

Oregon, Idaho and Tennessee have blown past Washington in the enlightened pragmatic electric energy transition. It leaves our state in the dustbin of yesterday’s expensive, environmentally invasive, dysfunctional grid threatening Wind/Solar/Battery energy systems.

Fundingsland concluded

The jury is still out on whether Washington residents can hold on to their current right to use the energy of their choice for heating/cooking. And whether an out-of-date, environmentally destructive dysfunctional grid threatening Wind/Solar/Battery system gets installed against the wishes of the impacted citizens.

The state seems most focused on keeping money from it’s CCA (Climate Commitment Act) flowing from the hike in gas prices at the pump this act has caused. The state needs the money given that it was just announced it is currently around $10 billion in debt. My cynical side wonders just how much of that CCA money is going to end up being diverted towards reducing that debt rather than “fighting “Climate Change” as it was advertised to be used for.

Washington state has many enlightened social programs to be proud of. There is a rational, pragmatic program supporting parents (both wife and husband) of newborns with a generous paid leave time so they can tend to their new child. A State sponsored long term care program has just been enacted designed for those elderly who do not have such means helping them towards the end off their days.

But when it comes to the State’s energy policy, it’s a whole different story. “Magical Thinking” prevails forcing rationality and pragmatism to go right out through the ozone hole.

So much for Washington leading the nation with a modern, clean, reliable, environmentally friendly electrical energy transition path. It’s much more enlightening to watch what states like Idaho and Tennessee are doing to find out where the future of rational, pragmatic energy systems are going.

I expect that New York’s experience with Climate Act implementation will be the same as Washington State’s experience. Thanks to Paul Fundingsland for sharing his experiences. Now we just need to wake up the citizenry to stop the nonsense.

Ronald Stein – Net-Zero Transition Lesson from Germany

Ronald Stein’s Energy Literacy Newsletter is an excellent resource. This post reproduces his latest article. He says:

As the United States follows Germany’s green deal, YOU should anticipate uncontrollable electricity prices. If you think your electricity prices are high now, brace yourself for what’s coming!

I have followed the Climate Leadership & Community Protection Act (Climate Act) since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 400 articles about New York’s net-zero transition. Proponents of the Climate Act refer to Germany’s transition as an example to emulate but show no sign of understanding all the issues. The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Ron Stein Overview

Stein’s newsletter provides an overview of his primary concerns:

My books have a common theme as they address the elephant in the room that the ruling class and the media refuse to talk about, i.e., the lack of products in the future, and the lack of fuels for planes, ships, militaries, and space programs, manufactured from the fossil fuels that built the world from 1 to 8 billion people in less than 200 years.

Without a planned replacement for crude oil to make those same products, limiting the supply of the products and fuels manufactured from crude oil will inflict shortages and inflation in perpetuity on current lifestyles.

Energy literacy starts with the knowledge that Crude oil is the basis of our materialistic society… All the components and equipment for the generation of electricity by wind, solar, coal, natural gas, nuclear, and hydro are all made from the oil derivatives manufactured from crude oil !

For the 8 billion on this planet that are quite dependent on food and medications, those wind turbines and solar panels cannot manufacture any of the fuels for 50,000 ships, 50,000 planes, militaries, and space programs, nor can they make the 6,000 products in our daily lives. Enhancing ones energy literacy will empower individuals to have conversations on energy at the dinner table with friends and co-workers.

Net-Zero Transition Lesson from Germany Uncontrollable Electricity Prices

The remainer of this post reproduces his latest newsletter article:

Germany was the first country to go “green”. Today, Germany now has some of the highest prices for electricity in the world and the number of Germany’s corporate insolvencies in March 2024 reached the highest level on record as the Great Green Electricity economic debacle continues.

The push to “green” electricity from wind and solar, and away from conventional sources, began in earnest under the government led by Germany’s Angela Merkel and her CDU center right party. The latest Socialist-Green coalition government, led by Olaf Scholz and Robert Habeck, have since pushed further draconian policies that have only exacerbated Germany’s economic and electricity woes.

In addition, high electricity prices in Germany and inflation are sapping consumers’ purchasing power, which further aggravates the economic situation. Currently, Germany is resorting to restarting several mothballed coal plants to keep the lights on as their wind industry continued its long record of failure to live up to promised performance and cost levels.

Shockingly, most of America and the Western Countries are following the German green movement, and are forging ahead with shuttering their generators of reliable, continuous, and uninterruptible electricity generation, that may be dispatched at short order as required by the network load, and adding more weather-dependent variable renewable electricity with almost no regard to electricity reliability or affordability to support hospitals, airports, offices, manufacturing, military sites, data centers, the general consumer public and telemetry, that all need continuous uninterruptable supplies of electricity.

Of the six electrical generation methods, occasional generated electricity from wind and solar cannot compete with reliable, continuous, and uninterruptable electricity from hydro, nuclear, coal, or natural gas:

Wind and solar generate occasional electricity, due to the time of day and the inherent vagaries of weather.

Hydro, nuclear, coal, and natural gas generate continuous uninterruptible electricity.

Solar and wind generators, as currently widely employed by the dreamers in Germany, America, Australia, and the UK, are inherently unreliable and cannot ever provide the continuous, uninterruptable, and reliable electric power as is generated by coal, oil, nuclear and hydro systems. Their use, under mandatory policies of governments, is forcing the consumer to subsidize net-negative dreams of intermittent electric power from breezes and sunshine. Such speculative ventures should not be funded by the taxpayer, they should be required to obtain funding from commercial entities and independent investors.

It is incomprehensible that twenty-three states in America have adopted goals to move to 100 percent “clean” ELECTRICTY by 2050. The elephant in the room that no policymaker understands nor wants to discuss is that:

The nameplate generation capacity of both solar and wind equipment is a total farce. Time of day solarization and the vagaries of weather determine the power output of both systems, this has no relationship whatsoever with the nameplate capacity value. As these systems also exhibit frequent mechanical failures due to wear and damage from weather conditions, they should be subject to penalties for periods of inactivity. Further, they should be subject to additional penalties for failure to provide adequate back-up generation during periods when there is no sun illumination, or the wind speed level is inadequate.

Occasional electricity generated from wind and solar CANNOT ever support hospitals, airports, offices, manufacturing, military sites, data centers, computers, and telemetry, that all need continuous uninterruptable supplies of electric power.

Wind and solar CANNOT manufacture anything as neither the occasional electricity from wind turbines nor solar panels, can replace the supply chain of products from crude oil that are the foundation of our materialistic society demanded by the 8 billion on this planet.

Practically every wind turbine or solar panel requires a backup from coal, natural gas, or nuclear, thus understanding electricity generation’s true cost is paramount to choosing and prioritizing our future electricity generating systems.

When we look outside the few wealthy countries, we see that at least 80 percent of humanity, or more than six billion in this world are living on less than $10 a day, and billions living with little to no access to electricity.

Politicians and policymakers in the few wealthy countries are pursuing the most expensive ways to generate intermittent electricity. Electricity poverty is among the most crippling but least talked-about crises of the 21^st century. We should not take electricity for granted. Wealthy countries may be able to bear the cost of expensive electricity and fuels, but those that live under conditions of “electricity poverty” cannot do so.

Germany was the first country to go “green”. Most Germans used to be enthusiastic supporters of the country’s Energiewende (transition to renewable electricity from wind and solar), especially in the early days when they were brazenly misled about the endeavor’s humungous costs and technical limitations. Those days are gone. Finland, France, China, Japan, and others are not following the lead of Germany that now has the highest cost for their electricity, and that electricity generation is occasional as it depends on breezes and sunshine.

Finland already gets about a third of its electricity from nuclear generation and has joined France, UK, China, Japan, and others as they pursue dependable, reliable, affordable, and zero emission electricity by ramping up their nuclear power generations capabilities. The Finnish government has announced that the first order of business is expanding Finland’s nuclear power generation capacity as soon as humanly possible.

Solar and wind power are specified by the state government to be critical to meeting California’s ambitious requirement to switch to 90% carbon-free electricity generation by 2035 and to 100% by 2045. This policy has resulted in the state continuously shutting down coal, natural gas, and nuclear generating stations that provide continuous uninterruptible electricity in favor of occasionally generated electricity from renewables However, in spite of the policy and renewable stations built, California now imports more electric power than any other US state, more than twice the amount in Virginia, the USA’s second largest importer of electric power. California typically receives between one-fifth and one-third of its electricity supply from outside of the state.

Most experts argue that the government hasn’t been fixing problems, rather it has been making them far worse. It simply refuses to acknowledge the reality and participate in conversations regarding the real verifiable science of the world’s climate changes.

A situation is developing in the US where personal debt and homelessness numbers are increasing at an alarming rate. The average debt in this country is greater than $100,000 per person (across credit cards, mortgages, auto loans and student loans), and with more than half of Americans living paycheck-to-paycheck, society is facing an unsustainable problem where those “financially challenged” will never pay off their continuously increasing debt.

Further, the loss of employment resulting from failed businesses, the failure of which is mostly caused by impossible increases in power costs, has forced many more people into a homeless situation. It is not possible to forecast the rate of rise of homelessness, but it will increase substantially as power prices continue to escalate under a failed renewable electricity policy.

The question that must be answered is how the electric power process can be brought back to sustainable levels to halt the failure of businesses and the resultant increases in poverty and homelessness.

Wind turbines and solar panels are recipients of free breezes and free sunshine, plus humongous government subsidies, so the question needs to be asked of those in charge of electricity policy in the governments of the USA why are ELECTRICITY PRICES ESCALATING AT AN ALARMING RATES?

Conclusion

Everything in Stein’s article is applicable to New York’s Climate Act. It cannot end well.

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Ellenbogen Comments on DEFR Proceeding

Richard Ellenbogen recently submitted comments as part of the record for the Department of Public Service Proceeding 15-E-0302 related to the net -zero mandate of the Climate Leadership and Community Protection Act (CLCPA), Last spring the New York State Public Service Commission (PSC) recently initiated an “Order initiating a process regarding the zero-emissions target” that will “identify innovative technologies to ensure reliability of a zero-emissions electric grid”. His comments discuss “a viable, affordable, and rapidly executable Plan B to assist NY State in reducing its carbon footprint using technologies that actually exist at scale, unlike the technologies proposed by the CLCPA which only exist at scale in the fantasies of its proponents.” I think it is important that his message gets out to all New Yorkers to try to avert the inevitable collision between aspiration and reality..

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

CLCPA Overview

The CLCPA established a New York “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. It includes an interim 2030 reduction target of a 40% reduction by 2030 and a requirement that all electricity generated be “zero-emissions” by 2040. The Climate Action Council (CAC) is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.” In brief, that plan is to electrify everything possible using zero-emissions electricity. The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the electrification strategies. That material was used to develop the Draft Scoping Plan. After a year-long review, the Scoping Plan recommendations were finalized at the end of 2022. In 2023 the Scoping Plan recommendations are supposed to be implemented through regulation and legislation.

Although vocal members of the Climate Action Council refused to acknowledge that not all the technology necessary for net-zero transition is available today the PSC zero-emissions target order recognizes that is not true. The Council ideologues ignored the fact that the Integration Analysis recognized that “as renewable resources and storage facilities are added to the State’s energy supply, additional clean-energy resources capable of responding to fluctuating conditions might be needed to maintain the reliability of the electric grid”. I published a post last summer summarizing the proceeding, including an overview of the questions raised by the PSC, and describing t comments I submitted.

I described the first set of comments for this Order submitted by Ellenbogen last summer. In order to make it easier for readers I have copied his submittal here. I converted his footnotes into inline references because footnotes do not lend themselves to blog posts.

About the Author

The first section of his comments describes his background and its relevance to the Proceeding.

Richard Ellenbogen an active party in the case , a resident of the State of New York, the CEO of Allied Converters, and welcomes the opportunity to provide comments as requested by the Commission in the above referenced proceeding, issued in the May 18, 2023 “Order Initiating Process Regarding Zero Target”.

I am a Former Bell Labs Engineer that has done work on the Utility System with NYSERDA and Con Ed. I also decarbonized my factory starting in 1999 and those measurements resulted in the Public Service Commissions Case 08-E-0751 to reduce power line losses. I was an invited speaker to a PSC Utility Conference in 2008 for that case on Line Loss Reduction that was initiated by Steven Keller based upon my work at the factory and a paper written at the request of Con Ed after a factory visit. I was the Keynote Speaker at the 2023 Business Council of NY Renewable Energy Conference and an invited speaker at the Dutchess County Chamber of Commerce meeting on Energy. I was an early adopter of renewable technologies going back to the 1990’s and decarbonized both my home and my business two decades ago. Between 2006 and mid-2023, the business recycled or repurposed 100% of its waste and sent nothing to a landfill. Over the past 20 years, the factory has generated between 60% and 85% of its electrical energy onsite with a carbon footprint approximately 30% lower than the Con Ed System, even prior to the closing of Indian Point.

I have lived live in an “electric” house since 2004 with a solar array and a geo-thermal heating system with 100% radiant heat using 95–100-degree water with a COP between 5.5 – 6.0, far more efficient than what most places will build under NY State guidelines, and I have driven an EV for six years. As all of the parameters in both the house and factory are measured three times per minute, I see firsthand what implementing the CLCPA will do to the load every day. The house was written up in the NY Times in November, 2008 under “Going Green: Still Challenging Turf” and the factory was written up in the Wall Street Journal under, “Westchester Plastics Maker Embraced Renewable Energy Decades Before The Gas Moratorium”.4 Additionally, I defeated Con Ed in a tariff hearing (NY State Public Service Commission Case 08-E-1426 Allied Converters, Inc. – Petition For a Declaratory Ruling on the Administration of Solar Net Metering Provisions at Locations Where Multiple (Hybrid) Energy Efficient Generation Technologies Are Installed) in 2008-2009 to allow additional interconnection of renewables and the factory became the first building in NY State with multiple sources of high efficiency grid connected generation.

It is through this lens that I have developed an understanding of the shortcomings of renewables after over 20 years of living with them. They are a great way to reduce the reliance on fossil fuels but attempting to run the entire system on them is going to be an unmitigated disaster which will be documented in the following pages. The requirement in the CLCPA for 25 – 37 Gigawatts of Dispatchable Emission Free Generation (DEFR) by 2040 is problematic at best and is impossible to execute in the stated sixteen year time frame, especially when considering that a single 1.2 GW Power Cable will have taken nearly that long to plan, construct, and get operational (2011 – 2026). I recommend that this DEFR proceeding determine whether there is a dispatchable emissions-free resource that can provide sufficient baseload and, if not, recommend a Plan B.

Introduction

The introduction lays out reasons that things have changed since last summer that could affect the schedule and viability of the Scoping Plan list of control strategies.

Since the original filing was made in August, a lot has changed in the NY State energy landscape. Renewables projects requested $12 billion in infaltionary increases that were declined by the Public Service Commission and that led to the cancellation of numerous projects, including solar, offshore wind, and battery storage. Those resources are now being rebid, likely at a significantly higher price.

The NYISO has indicated that the peaker plants will be operating far longer than planned because of a lack of renewables needed to replace them. Champlain Hudson Power Express (CHPE) is running into issues with landholders in upstate NY and may have to make eminent domain filings for certain parcels. It will not cripple the project but may delay it.

As mentioned in the earlier filing, the NYSERDA 6 GW Energy Storage Report, on page 94 of the 104 pages documents a need for 1000+ hours of storage or 6000 GWh of storage. Text from page 94 follows in italics.

Solar output is highest in the summer and lowest in the winter, and wind output is complementary to solar, as shown in Figure 40. With seasonal storage (1000+ hours), the availability of a specific resource during critical weeks – or in between multiple critical weeks in a season matters less; instead, the cheapest form of energy, such as solar in the spring and summer, can be stored and discharged over multiple winter weeks.

Column C in Figure 1, below, shows the 6,000 GWh of storage on the same scale of generation and demand. It is almost non-existent relative to the loads and will be totally inadequate to support the system. Far more storage than that will be needed to support a renewable system, however the NYSERDA report also documents a cost of $560 per KWh. At that price, the 6,000 GWh will cost $3.4 trillion, or about 16 times NY State’s annual budget. Some have been proposing using EV batteries to support the system. Having driven an EV for six years, I am almost never near a charger except when I am charging so there would be no way to feed energy back into the system. Further, how many people will willingly use their car to support the utility when they find out they will rescive 20% less revenue for discharging than they paid for charging and that the more frequent cycling will shorten the battery life. There are also capacitive batteries now being manufactured that will have a longer life span and a greatly reduced fire risk, however that are not ready for mass distribution. They also have a much lower energy density which makes them larger. That will work for utility scale storage but not EV’s. However, the price is roughly comparable to Lithium-Ion batteries so they will still be prohibitively expensive if used to support the utility system..

The Renewable Generation shown in column D was based upon 2019 projections that are no longer applicable as several Offshore Wind contracts have been canceled and several land based solar and wind projects have been canceled and others are meeting local resistance.

Additional Issues

Ellenbogen explains that these are not the only issues.

We are reaching a crossroads in New York State whereby the cost of the renewable generation and other mandates included in the CLCPA may make it impossible to live or work here.

The New Jersey nuclear plants announced this past week that they no longer need state subsidies because of the Inflation Reduction Act (IRA) subsidies that are now available to them. This raises the question, what does nuclear generation cost relative to the renewables that NY State is having enormous difficulty getting installed? Is there a viable carbon free Plan B?

This link is from a paper from September, 2022, published by the Cato Institute, regarding the costs of different generating options and the effect of the IRA on the cost of nuclear generation.

If you look at Table 2 below, from the paper, in the lower left hand column (Baseline), you will see that the UNSUBSIDIZED HIGH CONSTRUCTION cost for nuclear generation is 14.4 cents per KWh. The expected bids for Offshore wind are expected to come in substantially higher than that and the earlier bids were nearly that large. The recently canceled wind bids in NY State varied from $107 per MWh to $118 per MWh, despite Wind generation in the United States being heavily subsidized.

The next table shows the recently canceled wind bids and their costs. The requested increase had an average cost of $167/MWh. These are going to be rebid at a higher price and many will not be available for over 6 years, at a minimum, if they are ever built. Also note that the total capacity listed is 5 GW short of NY State’s ultimate goals. I referred to the High-Cost nuclear construction scenario because that is approximately what the recently built Vogtle reactors costs correlate with. This is a worst-case comparison of nuclear generation compared to the renewable generation.

Bids For Offshore Wind In NY State

According to information developed by David Stevenson (described here) ) the new projects were approved by NYSERDA with an average nominal cost MWh of $145.07 which compares to $167.07 in the table above. The table prices were requested in December 2023 while the new projects bids were likely made in early 2023 and may not reflect the tine cost needed to obtain financing today. The projects in the table most likely would have started construction in 2025 while the new projects are slated to start in 2030. It is highly likely that by 2030 the projects could not be built at these prices and the developers will come back for higher prices.

A recent blog post presented by Parker Gallant Energy Perspectives and highlighted in a recent post by Roger Caiazza of The Pragmatic Environmentalist, analyzed the costs of various generation types in Ontario, Canada. The results are shown in the table below. In Ontario, Nuclear Generation is approximately 30% less expensive than wind and 40% less than solar despite the claims that wind and solar are less expensive. Combined cycle gas generation is slightly less than nuclear in Canada.

That shows that unsubsidized nuclear is less expensive than OSW and doesn’t kill any birds or people, despite the claims of the fear mongers. OSW and solar could cost NY State ratepayers 30% more than nuclear generation, not including the costs of the required batteries and the more extensive transmission lines needed for those technologies due to their low capacity factor. If batteries are added in to support the intermittent renewables, the costs will be higher still. As shown in the earlier analysis of battery costs based upon the NYSERDA Energy Storage Report, the required batteries will cost more than the nuclear generation, independent of the costs of the renewable generation.

Again, I have developed an understanding of the shortcomings of renewables after over 20 years of living with them. In my experience, I believe that they are a great way to reduce the reliance on fossil fuels but expectations that they can completely replace fossil fuels are misplaced. A primary concern is cost and maintaining public support for the process. Public support will evaporate quickly with the current projected costs of the wind, solar, and batteries.

Regarding “Cap and Invest”, Table 3 below is also from the Cato Paper. It shows the carbon taxes required to achieve parity between nuclear and fossil fuel generation. With the High Cost nuclear, the carbon tax required to bring nuclear into parity with combined cycle gas generation is $196 per Metric Ton of CO2. According to the EIA, combined cycle gas generation will yield 2.25 MWh per metric ton of CO2 (976 pounds per MWh). With wind being more expensive than nuclear by between 20% and 30%, it will cost between $235 – $275 per metric ton to bring wind and Combined cycle gas generation into parity. Doing the math, $235 / 2.25 to make wind cost effective when compared to natural gas, even with the current subsidies, the taxes would be over $100/MWh. It would double the cost of the energy in the entire downstate region. If electric heat is forced upon the downstate residents, a current doubling of operating costs will morph to a tripling or quadrupling of heating bills for downstate residents.

Keep in mind that natural gas prices have dropped since 2022 so the actual tax would have to be higher in 2024.

These are the kinds of taxes that Cap and Invest will have to assess to make the plan work and they are ludicrous. Even without Cap and Invest, these are the additional costs that are going to be incurred by NY State ratepayers if the CLCPA keeps progressing. What makes this situation even worse is that the state can’t effectively install generation that won’t be taxed, building owners don’t have space or can’t afford upgrades to avoid penalties from the mandates, and the proponents of this plan can’t define who is going to pay the tax, acting as if the ratepayers and the taxpayers are mutually exclusive. A Venn Diagram of NY State ratepayers and NY State taxpayers will have an enormous amount of overlap.

A Viable Low Carbon / Carbon Free Solution That Will Not Bankrupt NY State Residents and Businesses

Ellenbogen offers a pragmatic alternative.

As nuclear generation takes years to get approved and sited, new combined cycle natural gas generation that feeds the CO2 emissions into greenhouses will provide low carbon energy at a low cost for NY State ratepayers in the near term. It is the least expensive generation to build and at present, it is also the least expensive generation to operate. It can provide baseload generation so it will eliminate the cost of battery storage. As it operates with a capacity factor two to seven times higher than renewables, the cost per MWh of transmission will be that much less expensive. As an initial step, siting a large combined cycle generating plant in Central New York, near the Western end of CleanPath, would provide easy access to natural gas from Pennsylvania while also allowing CleanPath to be fully utilized, reducing its costs to taxpayers. Additionally, there is available land in Central NY that is already used for farming that would be ideal to support large greenhouses. Routes 81, 86, and 88 provide easy access for shipping the agricultural products to population centers in NY State within four hours.

As can be seen in the following graph (Figure 2) a comparison of the emissions of Long Island Generating plants, the newer Caithness plant, shown on the right, operates far more cleanly than the E F Barret Plant shown on the left. E F Barret, which is a conventional steam generating plant that is operating well past its useful lifetime because of flawed NY State policy, was supposed to be replaced by a combined cycle plant six years ago. However, the expectation that Offshore Wind would replace it has fallen flat and Long Island residents are suffering with higher emissions and twice the energy cost of what could have been built six years ago. The Offshore Wind, if it is ever built, will reduce the emissions but based upon the current cost structure, it will not improve upon the operating costs of the old plant. This issue was addressed at length in the earlier filing.

By feeding the CO2 output of the combined cycle plants into large greenhouses, it can be used to increase crop yield by providing a twelve month growing season for NY State farms and increase food security in the state while using less land and water than existing farms. It will also use far less land than renewable generation. Additionally, it will harden farming in NY State to the effects of climate change.

Unlike the 25–37 Gigawatts of as yet unknown and non-existent Dispatchable Carbon Free Generation fantasized about in the CLCPA, this technology exists now and the greenhouses will cost far less than the batteries while also generating revenue and extremely high crop yields. The greenhouses will also last well beyond the 10 year lifespan of the batteries so they are a far more cost effective capital investment to make.

Additionally, operating EV’s from combined cycle gas generation is far more energy efficient than using internal combustion engines and will greatly reduce harmful pollutant emissions in the population centers.

Conclusion

Ellenbogen concludes that an alternative that does not go to zero provides a better solution.

Interim Combined Cycle Natural Gas Generation phasing to nuclear over time is a far more cost effective and secure way to power the state than what the CLCPA is mandating. Recovering the Combined Cycle emissions in greenhouses will mitigate the negative effect of the carbon emissions. That will also provide energy security that renewables can’t, while simultaneously providing food security as climate change makes food production more challenging.

Pragmatic Environmentalist Conclusion

The Hochul Administration has supported the ideological insistence that the schedule is necessary, and that zero-emissions in the electric sector by 2040 is mandatory. This is a political construct that does not stand up to any realistic evaluation. I have shown that New York’s GHG emissions are less than one half of one percent of global emissions and that global emissions are increasing by more than one half of one percent per year. That fact destroys any urgency arguments. We have time to do this right. This also implies that not reaching zero will not influence the alleged impacts to global warming. Ellenbogen’s alternative does not meet the ideological mandates but would be affordable, reliable, and have fewer environmental impacts. I endorse his comments.

Long Island Power Plans

Mark Sertoff, a science/technology educator, occasionally sends me information. This post describes his comments on the Long Island Power Authority’s (LIPA) Integrated Resource Plan “where they want to replace fossil generation with mythical wind, battery and solar power.”

Integrated Resource Plan Comments

I have lightly edited Mark’s comments and added some references.

LIPA’s plunge into wind and solar power replacing reliable, cost-effective, clean fossil generation is the path to energy disaster. Through decades of solid engineering and execution, Long Island has developed the most reliable and economical above ground power distribution system in New York State. The defective initiative to wind and solar generation will leave Long Island with seriously unreliable and costly power.

Wind and solar work about 20% of the nameplate capacity. They need battery backup, which is very expensive, requires rare earths mined in unfriendly countries with child labor that creates environmental pollution in refining. Existing storage technology only lasts a few hours when a week may be required. To top it off the batteries have safety issues because they can explode and burn in unquenchable fires emitting toxic fumes. Europe tried wind and solar with massive problems in reliability and cost so is reopening fossil generation plants. Germany, the former industrial powerhouse of Europe, is losing its industrial base due to high energy costs.

There are significant environmental impacts. Wind turbines in the marine environment have drastically shorter lives and kill land and sea birds. Solar panels are negligibly recyclable and require rare earths sourced from unfriendly foreign countries via child labor and create copious pollution in fabrication while being barely recyclable. There are mountains of scrap wind turbine blades now that can’t be recycled. Marine wind turbines in construction and operation have caused the deaths of many whales along the East Coast. Machine gun sonar, pile driving, and sub sonic rotor vibrations injure and disorient sea mammals leading to beaching and ship collisions. Solar panels have such low energy density that habitats are destroyed to install solar when conventional generation would make many times more reliable power in a fraction of the land area at lower per-watt cost.

There are questions about the renewable energy business model. No wind or solar generation would be viable without government taxpayer subsidies. That says it all. It’s a defective business and energy plan. If it were a real upgrade, the market would support it without subsidies.

Finally, there is no climate crisis. This “crisis” is based on defective UN climate computer models. Thousands of scientists around the world concur. The greenhouse gas effect is real, but it is only one of many different drivers of climate. We experience cyclical weather in decadal, century, and millennial cycles and we do not understand those natural cycles well. It is likely that those cycles are the primary drivers of the observed changes in global temperatures observed and that the greenhouse effect has a minor impact, Certainly nothing that warrants the proposed changes to our energy system.

Conclusion

I published this because it is a concise summary of the myriad issues associated with New York’s net-zero obsession. It cannot end well and won’t make a difference.

Two Views of the Climate Act Energy Plan

Dennis Higgins passes on his commentaries associated with New York’s Climate Leadership and Community Protection Act (Climate Act). I asked his permission to present his status analysis of the transmission system components of the Climate Act net-zero transition that was published in AllOtsego. I also became aware of a puff piece claiming all is well by Basil Seggos, co-chair of the Climate Act’s Climate Action Council that provides the State’s story. Comparing the two pieces I don’t see how this will end well.

Dennis taught for just a few years at St Lawrence and Scranton University, but spent most of my career at SUNY Oneonta, teaching Mathematics and Computer Science. He retired early, several years ago, in order to devote more time to home-schooling his four daughters. (Three will be in college next year and the youngest opted to go to the local public school, so his home schooling is ending this June.) Dennis and his wife run a farm with large vegetable gardens. They keep horses and raise chickens, goats, and beef. He has been involved in environmental and energy issues for a decade or more. Although he did work extensively with the ‘Big Greens’ in efforts to stop gas infrastructure, his views on what needs to happen, and his opinions of Big Green advocacy, have served to separate them.

Climate Act Narrative

Basil Seggos is the politically appointed Commissioner of the New York State Department of Environmental Conservation (DEC). The header (title?) for the article posted at the Empire Report was Climate change is here. New York’s comprehensive approach will help ensure the Empire State is prepared.

The game plan for the Climate Act public narrative is to point to a recent weather event and claim that is proof of climate change. The difference between weather and climate is never acknowledged and there has never been any estimate of how much Climate Act implementation will affect the alleged weather impacts. Seggos follows the script:

As made clear by the recent storms that ravaged many Long Island communities, time is running short to comprehensively address the flooding, erosion, and regional economic damage being wrought by increasingly common extreme weather events. We are witnessing the impacts of the climate crisis in real time, both here in New York and across the planet. It’s time for bold action at every level of society.

The next item in the usual script is to tout some new effort and its alleged benefits. That is the primary purpose of this article:

With the ongoing leadership of Governor Kathy Hochul, New York State is taking sweeping actions to reduce the many sources of greenhouse gas emissions that cause climate change. And in her recent State of the State Address and 2024-25 Executive Budget, Governor Hochul proposed a suite of actions to address climate change’s effects – including $435 million for initiatives to support long-term resiliency projects and protect communities across the state.

The funding will help create a new ‘Resilient & Ready Program’ with resources for low- and moderate-income households experiencing flood damage to assist with necessary repairs in the aftermath of storms, as well as improvements to prevent future damage.

The Governor also proposes a ‘Blue Buffers’ Voluntary Buyout Program to compensate residents in communities most vulnerable to flooding so they can relocate to another area with lesser flood risk. This not only saves taxpayer dollars when inevitable flooding occurs, it spares households the tangible and emotional losses that come with each rising tide and record rainfall.

Supported with $250 million from the $4.2 billion Clean Water, Clean Air and Green Jobs Environmental Bond Act, Blue Buffers would first educate property owners on the benefits of relocating homes and businesses regularly affected by high water, sea-level rise, and storm surges, and then partner with willing sellers on projects that could be eligible for buyouts. Purchased properties then revert to becoming permanently protected as open space, serving as a buffer against future flooding and benefiting the resiliency of the surrounding community.

Building on past investments, Governor Hochul is bolstering New York’s efforts to mitigate the effects of climate change with new proposals to repair aging flood control projects and remove hazard dams. The Governor also directed an update of Coastal Erosion Hazard Area maps essential to the protection of beaches, dunes, and bluffs that maintain and enhance flood resilience, and to overhaul building codes design to create higher standards for resistance to wind, snow, and temperature extremes.

As many Long Islanders know, since Superstorm Sandy, New York aggressively stepped-up efforts to boost targeted investments for critical infrastructure, flood-proofing, shoreline restoration, and disaster response. The response included ongoing work with federal and local partners to use every tool at our disposal.

The recent U.S. Army Corps of Engineers determination of eligibility for the process to assess, fund, and repair their damaged coastal projects on Fire Island, as requested by the Governor and Department of Environmental Conservation (DEC), is welcome news. It is one of many projects that DEC will continue to help implement to protect homes, critical infrastructure, and shorelines.

Climate change is here. With the ongoing cooperation and collaboration of Long Islanders, New York’s comprehensive approach to adaptation and resiliency will help ensure the Empire State is prepared for the gathering storm.

As far as I can tell the only way for the State to meet the Climate Act targets is magical game-changing technology. I do not see anything in these projects that makes me think that these programs are game changers. Another component of the narrative is to never discuss the status of the transition and the component programs. The question whether the existing programs are having any sort of an effect are not mentioned and no issues associated with recently proposed programs are ever addressed.

Flawed Energy Plan Moves Forward

On the other hand, Dennis Higgins’s article Flawed Energy Plan Moves Forward in AllOtsego takes a critical look at one new effort. This one is associated with transmission development.

Legislation proposed in Albany would create “RAPID,” a new department in the Office of Renewable Energy Siting to accelerate transmission buildout. Per megawatt-hour—amount of energy moved—those new lines will be very expensive. We must build full nameplate transmission for wind, which has a capacity factor under 25 percent. Solar has a capacity factor of under 14 percent: Although full capacity generation might occur mid-day in summer, much of the rest of the time solar yields little or no energy. Transmission for hundreds of solar and wind resources represents a lot of expensive wire to buy and install and maintain; wire which will need to be run across private land; wire that mostly will move nothing at all.

With each of New York’s staggering missteps in decarbonization efforts, we reflect on the mess we’re in. ORES itself has stalled out in efforts to site intermittent resources. Solar and wind builders cancelled contracts late last year when the state would not simply award them more money. They are rebidding, and the state will make new, more expensive, awards. Upstate communities are pushing back at the state’s efforts to locate solar and wind projects where local laws say “no” to industrial development.

New York gets about 20 percent of its baseload energy from hydroelectric on the St. Lawrence and Niagara rivers. Solar and wind currently account for about 7 percent of total state electricity. The fast approaching 70-by-30 goal in the Climate Leadership and Community Protection Act requires that 70 percent of the state’s electricity come from renewables. In other words, 50 percent of the state’s capacity must come from solar and wind. The state must multiply all the installed solar and wind built over the last 20 or more years by seven- or eight-fold in the next six years. Hochul has no ruby slippers and no magic wand, so press releases can safely be ignored. The 70-by-30 CLCPA goal is not going to happen.

Still, the state has decided lack of transmission must be the culprit. Let’s take a closer look at some of the problems with the state plan.

In its 20-year “Outlook” report, the grid operator NYISO detailed transmission constraints across Long Island, the Southern Tier and Finger Lakes. These will prevent energy moving from intermittent resources to downstate through this decade, and maybe the next. Can we fix the state plan by building high-voltage lines over rural New Yorkers’ objections to support energy resources that may never exist?

In its 2023 Power Trends, NYISO indicated that most—70 percent, or about 17,000 megawatts—of the state’s fossil-fuel capacity will need to be available after 2030. NYISO has already determined that peakers, which CLCPA says must be shut down, will need to be kept online. The storage projected in state planning, a hundred times the largest lithium-ion battery on earth and costing many billions of dollars, if fully charged, would not power New York City for a day. Alberta Canada, like Texas, recently issued energy alerts to its citizens as it discovered that wind power does not work well when it is very cold. Of course, solar generates almost nothing in the winter. Assuming we could get anyone in Albany to listen, is there some sort of broader lesson in all this?

California—following the same wacky blueprint New York is using—has had 20 years to build out its solar and wind assets, including transmission lines to move generated energy. California gets twice the electricity from every panel that New York could hope to get. California has deserts to site intermittent resources and transmission, while New York must sacrifice its farmland and forest. California exports solar to Nevada at a loss to avoid curtailment, yet still dumped something like three terawatt-hours of energy in 2023, enough to keep the lights on in New York City for a week. California has struggled to reduce reliance on fossil fuels: It has built new gas plants and still needs to import coal-fired electricity to ensure reliability.

The 2015 Mark Jacobson publication—which was in part the model for New York’s energy plan—was soundly debunked by about two dozen climate scientists two years before the CLCPA was enacted. The Jacobson paper is nevertheless a sort of bible to the Big Greens. As noted in MIT’s technology review, that paper “contained modeling errors and implausible assumptions that could distort public policy and spending decisions.” Consequently, the CLCPA and the resulting scoping plan, following similar flawed analysis, have already led to “wildly unrealistic expectations” and “massive misallocation of resources.”

As MIT Press noted,

“Jacobson and his coauthors dramatically miscalculated the amount of hydroelectric power available and seriously underestimated the cost of installing and integrating large-scale underground thermal energy storage systems…They treat U.S. hydropower as an entirely fungible resource. Like the amount [of power] coming from a river in Washington state is available in Georgia, instantaneously… )“

Following this flawed plan, it always looks like there is a transmission problem, since the grid is not one big copper plate.

In fact, no new energy solution or gigantic storage mechanism is needed at all. New York only needs to look around the world at those places that have successfully decarbonized their grids. New York only needs to look in the mirror: the downstate grid is over 90 percent “dirty,” powered by gas and oil. Upstate is over 90 percent emission free, and like those large economies that have cut fossil-fuel use, it is powered by hydro and nuclear.

But don’t tell Albany: New York is intent on pursuing an expensive land-hungry plan which we already know will fail.

Discussion

The Hochul Administration is not addressing the implementation issues associated with their Climate Act net-zero transition. Instead, we get a barrage of slick announcements claiming that we have to do something and here’s a whole new pile of “something” that we think might work, will appeal to the constituencies that demand action, and likely provide political payola to some politically connected constituency.

Dennis Higgins provides the other side of the story. He describes numerous issues with the transition and relates them to the fundamentally flawed Jacobsen/Howarth transition plan. The fact is that if New York State is serious about de-carbonizing the electric grid nuclear power must be part of the solution. Dennis advocates for that position but to little avail. Without a commitment to nuclear this will never work.

Conclusion

Higgins noted that his piece was incomplete: “The mess is so big you can’t say it all — fiscally irresponsible/unsound engineering and, already failed where it’s been tried.” He noted that he did not have the space to make the point that RAPID will give developers authority to use eminent domain for transmission. He thinks that this is something we all need to push back on with local and state elected reps.

I agree with Dennis that “New York is intent on pursuing an expensive land-hungry plan which we already know will fail.” He speaks to reality and in the end reality always wins.

Guest Post: Washington State Cap and Invest Update

Last month I published several articles about the experiences of Washington State as they implement their cap-and-invest program because I think it is likely that New York’s experiences will be similar. In one I elevated a comment from Washington resident Paul Fundingsland into a post. He recently did “a bit of research with some comments, thoughts and a more or less rough idea of what seems to be going on in the Washington State cap-and-invest scheme” that I have converted into a guest post.

Paul describes himself as “An Obsessive Climate Change Generalist”. Although he is a retired professor, he say he has no scientific or other degrees specific to these kinds of issues that can be cited as offering personal official expertise or credibility. What he does have is a two decades old avid, enthusiastic, obsession with all things Climate Change related.

Last month I published Washington State Gasoline Prices Are a Precursor to New York’s Future, which was a variation of an article published at Watts Up With That – Do Washington State Residents Know Why Their Gasoline Prices Are So High Now?. I also published Washington State Gasoline Prices and Public Perceptions that consolidated responses from Washington residents in the comments from the Watts Up With That article. The last article, Feedback from Washington State on Gas Prices was from Paul Fundingsland. All the articles addressed recent reports that gasoline prices in the State of Washington are now higher than California.

In this post Fundingsland provides an update after doing a bit of research. I provide his thoughts with my commentary below.

Initial Thoughts

The focus of my articles was the increase in gasoline prices. Not surprisingly that has become a hot topic in Washington. Paul explains:

Pushback on the rise in gas prices associated with the “Cap-and-Invest” scheme (hereafter referred to as “Tax-and-Reallocate” because that is essentially how it works) has caused our Governor to publicly blame the oil companies for price gouging apparently thinking they should absorb the loss of revenue and not pass their state mandated added costs for doing business on to their customers. Apparently he thought these companies should unrealistically absorb the loss of revenue and not pass their state mandated added costs for doing business on to their customers.

The idea that the costs of the program should not be passed on is also present in New York. When the prices necessarily go up it is a shock to many. Why I do not know. It is obvious that the tax-and-reallocate scheme is dealing with a lot of money and not working as planned.

One of our state legislators claims Washington State is now making more money from the sale of a gallon of gas or diesel than the oil companies. Our Department of Ecology (which is running this scheme) scrubbed the website original language indicating this scheme would have a minimal effect on gas prices. The Washington Policy Center claims the proposed climate funding budget is spending 56% of the initial $306 million on expanding government. No real surprise there.

I have concluded that the underlying motive of most of the proponents of these schemes is money. Legislator Reuven Carlyle was a sponsor of the cap-and-reallocate law and provides an example.

Carlyle who chaired the Washington State Senate Environment, Energy & Technology Committee and was a member of the Ways and Means Committee, lead the charge in the Senate for passage of the Climate Commitment Act, Clean Energy Transformation Act, Clean Fuel Standard, hydrofluorocarbon standards, building standards and much more. He left the legislature this year to cash in on his legislative work founding a startup called Earth Finance to “help businesses hit climate goals” based on his legislative accomplishments.

Program Evolution

Fundingsland’s experience with the researching the program is similar to mine:

A cursory review of how this “tax-and-reallocate” scheme is evolving in Washington and what kinds of claims and actual emissions reductions result going forward reveals a quagmire of incredibly convoluted intertwined moving parts. Trying to unravel the threads is proving to be very difficult and quite frustrating.

He notes that descriptive information is not available. That is a common trait in cap-and-invest programs in my experience:

For example under the Department of Ecology one can find a list of the companies who participated in the 2^nd auction under “Washington Cap-and-Invest Program Auction #2 May 2023 Summary Report” but no data on how many allowances each company bought or what their total costs were. Interestingly, high profile Washington businesses missing from this list include Boeing, Microsoft, Amazon and Starbucks to name a few.

As to how the monies received from the program are going to be distributed, as of the moment one can find only broad generalized categories with aspirations as to how they will be applied subject to future legislative decision making. For example: “these proceeds will be used to increase climate resiliency, fund alternative-transportation grant programs, and help Washington transition to a low-carbon economy” (my bold).

“Cap-and-Invest Auction Proceeds, consists of these generalized categories with percentages and sub accounts filled with somewhat more specific wish lists of where and how the monies are supposed to be spent. Under “Auction Public Proceeds Report” there is only broad information as to how much money was received.

Nowhere is there documentation of how much CO2 has been or is projected to be reduced by this plan in comparison with past years or how much less warming this plan has resulted in or is projected to result in.

Unfortunately, the problems he described are also present in New York’s implementation of the Climate Leadership & Community Protection Act (Climate Act). The Public Service Commission just published a summary of the implementation status of the Climate Act and the lack of specificity noted here is present in that report.

Washington Emissions

Paul notes that he is “somewhat new at sorting through government bureaucratic documents”. He caveats the following as what “might be better viewed as a rough approximation, subject to revision once more detailed and specific information is obtained.” He does think the following is approximately correct.

According to the Washington State Department of Ecology, the 2019 breakdown of Washington State greenhouse gas emissions is: Residential, Commercial, Industrial heating 25%, Transportation 39%, Electricity 21%, Other 14%.

Electrical power is 64.6% hydro supplied by eight hydro plants owned and operated by the Federal Government. Natural gas is currently at 14.4%, nuclear at 7.8%, wind 8.7%, coal at 2.9%, biomass at 1.3% and a small contribution of solar.

Washington’s natural gas utilities and electric utilities receive a determined (revisable) amount of their required emissions allowances for free. Washington’s only coal fired plant’s emissions are grandfathered in as it will be fully decommissioned in 2024.

So, unlike the lower emissions resulting from a coal to natural gas switch as fortuitously happened during the initial years of the east coast RGGI scheme, there is not a lot of low hanging CO2 emissions fruit to begin with to harvest or claim as a success from the electricity sector in Washington. And with the free emissions allowances the emissions reduction pool from this sector is even further diluted.

When I skimmed through the Washington regulations one of the things that jumped out to me was the following figure. The 2030 limit is a 45% reduction below 1990 levels. The chart indicates that 2020 emissions were equal to or slightly more than the 1990 emissions. A 45% reduction in ten years seems ambitious. Based on the information from Fundingsland, I cannot imagine this target will be achieved.

In addition, the “tax-and-reallocate scheme” contains all sorts of other emissions exemptions. One classification is termed “EITEs” consisting of over 40 facilities and businesses that qualify as Emissions-Intensive, Trade-Exposed industries even though they qualify for mandated participation in emission allowance auctions.

There are also ”tax-and-reallocate-offsets” being run thru what is designated as an Offset Project Registry that looks to be a California based company called Climate Action Reserve.

That leaves the bulk of the emissions reductions to be garnered from the other three sectors (transportation, residential-industrial-commercial heating, and “other”). At this time, it is difficult to determine how the actual 25% breakdown within the residential-industrial-commercial heating sector works. For instance, residential energy use has been reported as being 60% electric.

I have long argued that a basic flaw in the New York net-zero transition plan is that there was no feasibility analysis. Given this information about Washington I think New York is comparatively better off. Both states need to document how they plan to get where they want to go but the reduction trajectory for New York is lower than Washington.

New York is starting to come to grips with similar sector target issues. If the cap-and-reallocate scheme is supposed to provide significant funds for implementation but there are a limited number of affected sectors, then the price impacts on those sectors is going to be magnified. That is exactly what happened in Washington. It is not price gouging when that happens, it is simply supply and demand.

Assuming the industrial-commercial may be mostly gas, the amount of emissions by individual businesses will be affected by whether they are in the EITEs classification or not, whether they have “offsets” and how many tons of CO2 they emit (250,000 tons being the “trigger” amount for mandatory participation in the tax-and-reallocate emissions auctions). So the number of emissions reduction areas possible in this sector are rather “squishy” and difficult to determine. They most probably will land on the low side of 25%.

The political origins of these rules should not be overlooked. The Progressive backers of both plans cater to the labor union constituencies so both New York and Washington carve out EITE exemptions. Because the net-zero transition plans will necessarily increase the cost of energy I expect that the inevitable result is that the increase will make industries in both states uneconomic relative to other locations whatever the intent of these efforts.

The “other” classification of this sector consists of: agriculture (manure, fertilizer, livestock digestion), industrial processes (aluminum, cement), waste management (landfills, waste water treatment), and natural gas distribution. Of these, waste management and natural gas distribution are negligible.

Agriculture represents a very difficult to find pathway toward lowering emissions without adversely affecting the food supply. That leaves cement and aluminum production which are essential to modern society, are both part of the EITEs exemption legislation and have, as of yet, no known practical, workable, scaleable emission free alternatives.

So the residential-industrial-commercial-heat and “other” sectors also look not to bear much in the way of emissions reductions for various mitigating reasons.

Again, the political calculus affects the treatment of these sectors. I think the decisions are based more on what they think they can get away with than a pragmatic emission reduction plan.

At 39%, transportation is the largest emissions sector. It has been reported that in the latest emissions allowances auction held last May, energy and utilities purchased the bulk of the allowances. With utilities (probably the gas plants) garnering a certain amount of unspecified free allowances from the State, that leaves the energy companies supporting transportation to shoulder the bulk of the latest allowance purchases.

There are five refineries located in our state that serve Washington, Oregon and to a small degree California. Their products include on-road gasoline and diesel, marine fuel, jet fuel and aviation gasoline, railroad fuel, and natural gas used in transportation. However, there are some big allowance exemptions that cover fuels involving watercraft (shipping, cruise ships, navy etc.), agricultural, aviation and exported fuels.

Personal car and truck fuels in Washington have no exemptions and make up over half of the total fossil fuel emissions in this category. With the energy companies probably buying the bulk of emission auction allowances, and with all the exemptions in the other fuel use areas, it’s not a stretch to see why the costs of the allowances were passed along to the personal car and truck consumers causing the rather massive jump in gas prices at the pump.

Overall, a good guess is the Legislature will be more than satisfied for some time with the amount of monies coming in that can be used to fund the expansion of the State bureaucracy and all their manufactured future wondrous climate mitigating projects to help save the world from future computer modeled bad weather. So they will feel they are basically doing their job. It’s doubtful they will want to cause gas prices to accelerate much more in the near future for fear of garnering the wrath of the electorate.

Often the simplest answer is correct. Fundingsland makes a good argument that this is just the start of the cost impacts to transportation in Washington. The mix of sector reductions in New York is different but not enough that fuel prices won’t spike when the New York auctions begin. I agree that the revenue target is entirely a political decision.

If and when a transparent “project report” comes out, it will no doubt tout all the money received (the easy headline grabbing part), be filled with all the virtuous climate change related project accomplishments the monies were or are going to be used for (the hyped glossy political part), with the actual emissions reduction data either completely missing, obscured, massaged, tortured, or glossed over and probably relegated to some vague or indeterminant area of the document with accompanying convoluted language (the important forgotten and reason for the scheme in the first place part).

Based on current Ecology Department documents available and reports from various sources, this already seems to be the case.

New York’s participation in the Regional Greenhouse Gas Initiative (RGGI) portends what will happen in Washington and his description is apt. I have been evaluating the RGGI reports for years and can confirm that the wording and information provided is designed to claim unqualified success. Digging into the numbers shows a much different story.

Questions

Fundingsland lists the following bottom-line questions.

*How much did each “qualified” company pay for the allowances?

*What were the financial consequences to the constituents of these added costs to the companies?

*Which areas and projects did the monies actually go to and how much did each receive?

*What was the overall cost per ton of CO2 reductions (total allowance participant proceeds versus total reduction in CO2 tons).

And the four most important questions:

*How much reduction in emissions compared to recent years has resulted from this scheme?

*How much less global warming has been projected to occur by these emission reduction results?

*How much is this scheme going to cost the residents to completion or are the costs never ending?

*What metric has been identified that will be used to indicate this program is no longer needed because it has done it’s job?

I agree with his take on responses to the questions:

It will be surprising if any of these kinds of questions are going to be addressed. It is looking more and more like just another never ending, forever growing government bureaucratic convoluted way to extract more funds from their constituents for some worthwhile, some okay, and some questionable projects that may or may not have a quantifiable bearing on reducing CO2 emissions.

Summation

Fundingsland summarizes the likely results of the program:

It’s going to be extremely difficult and may not even be possible for Washington State to be able to claim any meaningful or significant emission reductions based on this tax-and-reallocate scheme given the state’s overall energy use configuration combined with all the various emission allowance exemptions.

In fact, there is a very high probability there will be next to zero emission reductions and perhaps even an increase.

The easiest and most efficient way for the 54 companies/businesses listed under the auction #2 May 2023 summery report that have been forced to participate (“qualify” in bureaucratic terminology) in the allowance auctions or face a $10,000 per day fine, is for them to just purchase the allowances, add it to their cost of doing business and pass the increase along to their customers. So in effect they won’t be reducing their emissions at all. And all will be adding their additional State forced costs for doing business on to their customers.

This the ultimate flaw in the cap-and-reallocate plan. The costs to implement emission reductions are greater than the costs of allowances. Moreover, emission reductions may only be possible by displacing fuels. The transportation fuel providers have limited means to reduce their emissions so the sector reductions will come primarily from the introduction of electric vehicles. In the meantime, the fuel providers will simply pass the costs along and if the allowance cap limits the availability of allowances too much then they will stop selling fuel or pass the $10,000 per day fine along to their customers.

Fundingsland concludes:

At the end of the day, the goal of any meaningful, measurable reduction of CO2 emissions or theoretical effective pathway to stop “climate change” looks to become a glazed over afterthought in this quagmire of a Washington State bureaucratic money-making machine.

With this scheme, Washington State Government now joins the lucrative profit side of the climate industrial complex at the expense of its constituents while giving a completely different connotation to the term “Net Zero”.

Conclusion

I think New York’s plan for an economy-wide cap-and-invest program will be a similar disaster. Earlier this year I described the book Making Climate Policy Work. I focused on their discussion about RGGI and the implications for New York’s cap-and-invest program. I noted that I agreed with the authors that these programs generate revenues. However, we also agree that the amount of money needed for decarbonization is likely more than any such market can bear. I highly recommend this book to anyone interested in potential issues with these programs.

Fundingsland picked up on the affordability issues but did not address the compliance implications. Advocates for cap-and-invest tout the claim that as the allowance cap declines, compliance with the program targets is assured. Proponents have not acknowledged or figured out that the emission reduction ambition of the reduction targets is inconsistent with technology reality. Because GHG emissions are equivalent to energy use, limiting GHG emissions before there are technological solutions that provide zero-emissions energy means that compliance will only be possible by restricting energy use. I don’t think that New York can meet its emission reduction targets but compared to Washington’s emission inventory and targets New York has a much better chance. Washington plans to rely primarily on the transportation and building sectors for its reductions and needs to make sharper cuts. I see no scenario where that will end well.

In conclusion, I believe Fundingsland did a good job describing the issues associated with cap-and-invest in Washington. New York’s program will have the same issues. It will be interesting to see how these state programs work out and which one will be the bigger flop.