Accelerated Energy Growth and Community Benefit Act: Electric System Concerns

In the summer of 2019 Governor Cuomo and the New York State Legislature passed the Climate Leadership and Community Protection Act (CLCPA) which was described as the most ambitious and comprehensive climate and clean energy legislation in the country when Cuomo signed the legislation.  In early April 2020, NYS passed the Accelerated Renewable Energy Growth and Community Benefit Act (AREGCBA) as part of the 2020-21 state budget.  This legislation is intended to ensure that renewable generation is sited in a timely and cost-effective manner.   It is best described by a knowledgeable friend as “Once again the idiots in Albany have proven they are willing to dive from the high board without looking to see if there is any water in the pool.”  When this was proposed I posted an essay describing the hypocrisy and over-reach aspects.  This post show why there are significant risks to the electric system.  I will follow up with a post addressing the environmental problems associated with these laws.


The AREGCBA legislation states that the CLCPA targets “shall mean the public policies established in the climate leadership and community protection act enacted in chapter one hundred six of the laws of 2019, including the requirement that a minimum of seventy percent of the statewide electric generation be produced by renewable energy systems by 2030, that by the year 2040 the statewide electrical demand system will generate zero emissions and the procurement of at least nine gigawatts of offshore wind electricity generation by 2035, six gigawatts of photovoltaic solar generation by 2025 and to support three gigawatts of statewide energy storage capacity by 2030”.

Unfortunately, the politicians that passed this law never bothered to figure out how it could be done.  Prudence would have been to do a study to determine what was feasible and then set the targets. Instead, the legislation sets up a Climate Action Council with the charge to prepare and approve a draft scoping plan “outlining the recommendations for attaining the statewide greenhouse gas emissions limits” within two years of the effective date of the legislation.  One year later, the council shall submit the final scoping plan to the governor, the speaker of the assembly and the temporary president of the senate and post such plan on its website.  I have written a series of posts on the feasibility risks, implications and some of the costs of the CLCPA that provides more details on the law.

The Accelerated Renewable Energy Growth and Community Benefit Act is Cuomo’s legislation and the unintended consequences will be his fault.  On February 21, 2020 he announced “he is advancing a 30-day budget amendment to dramatically speed up the permitting and construction of renewable energy projects, combat climate change and grow the state’s green economy. If adopted, the Accelerated Renewable Energy Growth and Community Benefit Act will create a new Office of Renewable Energy Permitting to improve and streamline the process for environmentally responsible and cost-effective siting of large-scale renewable energy projects across New York while delivering significant benefits to local communities.”  New York State’s budget process has never been a template for good governance and this March would have been an appropriate time to concentrate on the financial implications of the coronavirus pandemic.   Instead, Cuomo jammed this legislation into the budget package making it difficult for the assembly or senate to discuss, much less object.

2. Legislative findings and statement of purpose

I have copied section 4 of this chapter of the legislation and inserted my comments in italics.  My over-riding problem with the CLCPA is that there is no plan.  The AREGCBA legislation compounds the problem by removing the evaluation of community impacts constraints.

    1. A public policy purpose would be served and the interests of the people of the state would be advanced by:

(a) expediting the regulatory review for the siting of major renewable energy facilities and transmission infrastructure necessary to meet the CLCPA targets, in recognition of the importance of these facilities and their ability to lower carbon emissions;

Article 10 Law currently requires “environmental and public health impact analyses, studies regarding environmental justice and public safety, and consideration of local laws” but those requirements take time to evaluate and it appears this regulation over-rides the time needed for those analyses.

(b) making available to developers of clean generation resources build-ready sites for the construction and operation of such renewable energy facilities;

In my opinion if the CLCPA and AREGCBA laws had been written such that the plans were developed first it would have been more protective for New Yorkers.  In that approach the State would fulfill all the Article 10 requirements as part of the “build-ready sites” approach.  It is possible that is the intent of this part of the rule but there will be more sites needed then those which are incentivized by section (e) below. 

(c) developing uniform permit standards and conditions that are applicable to classes and categories of renewable energy facilities, that reflect the environmental benefits of such facilities and address common conditions necessary to minimize impacts to the surrounding community and environment;

I have reviewed all the Article 10 solar applications and there is no question that uniform permit standards and common conditions could be addressed by a comprehensive planning approach. 

(d) providing for workforce training, especially in disadvantaged communities;

This is a transparent effort to develop support from a specific voting bloc.

(e) implementing one or more programs to provide benefits to owners of land and communities where renewable energy facilities and transmission infrastructure would be sited;

This is political payola.  It is a bribe given in exchange for accepting any negative consequences of the renewable energy facilities.

(f) incentivizing the re-use or adaptation of sites with existing or abandoned commercial or industrial uses, such as brownfields, landfills, dormant electric generating sites and former commercial or industrial sites, for the development of major renewable energy facilities and to restore and protect the value of taxable land and leverage existing resources; and

This is a noble gesture.  Without question it is a nice idea to re-use or adapt unused sites but the fact is that those sites are small relative to the areal needs of diffuse wind and solar power production required by the CLCPA.

(g) implementing the state’s policy to protect, conserve and recover endangered and threatened species while establishing additional mechanisms to facilitate the achievement of a net conservation benefit to endangered or threatened species which may be impacted by the construction or operation of major renewable energy facilities.

In the long list of Cuomo’s hypocritical environmental policies this may be the topper.  There is no question that there is value for net conservation benefits.  For example, if an acre of a wetland is impacted, then the applicant could restore, create or enhance more wetland acreage nearby for a net environmental benefit.  The Cuomo administration has a consistent record of ignoring the possibility of this approach where it is inconvenient for their rationale to reject an application (e.g., any of the pipeline applications rejected in his tenure).  While this may be appropriate for affected wetlands at renewable facilities the real concern with blanketing the state with wind turbines is the effect on endangered or threatened avian species.  What in the world could be proposed as a net benefit for incidental slaughter of birds and bats at y wind turbine? 

Electric System Concerns

The politicians that enacted CLCPA made a major mistake putting the cart (the aggressive targets) before the horse (figuring out what was feasible).  The draft scoping plan outlining attainment recommendations will not be approved until June 2021 and the final version will not be presented to the Governor, Assembly and Senate for another year.   The crony capitalists, environmental activists, and all the others who stand to gain from this ambitious plan have conned the legislators and Governor into believing that meeting the targets is simply a matter of political will but as I show below that is not the case.

I worry about the costs of the CLCPA because jurisdictions that are attempting similar GHG reductions have seen higher costs. Renewable energy supporters claim solar and wind are cheaper than conventional power plants but that is only the cost of the facility.  The problem is the cost of the generator does not include the cost to get the power to where it is needed when it is needed.  I evaluated one example of Cuomo’s renewable energy promises: freeing the state fairgrounds of fossil fuels.  One advocate claimed “solar is doable” and that “the 9 million kilowatt hours the fair used in 2018-2019 could be supplied by a 45-acre solar array and that would cost about $12 million to build”.  In my post I calculated what would be needed to provide all the electric power needed during the ten days the fair is open.  In my cheapest scenario I estimate that the solar array has to be at least twice as large, a wind farm with ten 2.5 MW wind turbines has to be added to reduce energy storage requirements and that you would still need an energy storage array totaling 43 MWh.  I have not evaluated the costs of solar and wind but have looked into the costs of Li-Ion batteries for energy storage.  Using National Renewable Energy Laboratory information, I estimate that the cost of just battery backup would be $17 million.  Assuming that a wind farm is a comparable cost to the 45-acre solar array and doubling the size of the array, the crude cost is $53 million.  Of course, with no detailed plan we have no idea of the cost of the CLCPA.

But it not just a question of cost but also of feasibility.  The State needs to show how many wind turbines, solar panels and energy storage systems will be needed when we most need power.  The only way to do that is to determine the availability of wind and solar based on historical meteorological data.  Done properly the study should look at hourly solar insolation, snow cover, and wind speed meteorological records across the state.  The other component is expected load.  In order to meet all the CLCPA targets the heating and transportation sectors will have to be electrified and that means that the future load peak will be in the winter.  The over-riding feasibility problem is what resources will be needed to cover a winter peak when solar resources are low.  I estimated the resources needed for a load estimate from the Citizen’s Budget Commission with wind and solar output estimates based on meteorological data from January 3-4 2018 and found that New York would have to build 11,395 MW of residential solar, 16,117 MW of utility-scale solar, 18,457 MW of on-shore wind and 16,363 MW of off-shore wind to meet the increased load needed for the CLCPA targets.  For the example winter peak period I showed that the light winds at night would require 150,000 MWh of energy storage and using National Renewable Energy Lab information showed that energy storage alone could cost $176 billion by 2050.

There is another feasibility problem.  Wind and solar are diffuse and chaotically intermittent.  Because they are diffuse the transmission system is needed but because they are so intermittent the transmission system has to be modified.  Conventional fossil-fuel fired, nuclear, and hydro units generate relatively stable power.  Wind and solar units provide variable power generation so resources also have to be developed to handle grid balancing services.  No major electric system has even come close to the targets in the CLCPA but transmission problems have shown up where renewable energy input is about half of the total such as South Australia.  Battery storage such as LI-ion batteries can provide these services in theory but no where has any system near the size of New York demonstrated the practicality of such a system.  Again, because there is no plan, we have no idea of the added costs of this necessary component of the future CLCPA electric energy system.

Even if a study shows it is feasible what about resiliency?  Coal is no longer burned to generate electricity in New York and residual oil is discouraged but both fuels could be stored on-site making them more resilient sources of power.  I recently showed that a 9” snowstorm blocked all the power output from a solar facility for four days.  When the CLCPA target of 6 GW of solar PV is implemented and we have a similar snowstorm to the March 12-14 superstorm that covered the state with 10” of snow, how can the electrical needs be met with no solar generation.  Even worse, what happens when an ice storm takes the power out to a city when residents completely depend on electric heat?  The ultimate resiliency question is how can New York City possibly meet its requirements for in-city generation using diffuse renewables.  Failure to meet those specifications raises the possibility of a New York City blackout.

There also are worrying issues with the environmental aspects.  In order to do justice to those topics I am going to follow up with another post.


The New York electric system is part of one of the largest and most effective machines in the world.  It produces affordable reliable electricity when and where it is needed.  However, the popular conception of the grid is that for all of its complexity and acknowledged past success it is outdated.  Enter the “Smart Grid” to solve all the problems.  According to, “the Smart Grid will consist of controls, computers, automation, and new technologies and equipment working together, but in this case, these technologies will work with the electrical grid to respond digitally to our quickly changing electric demand.“  They also say that “The Smart Grid represents an unprecedented opportunity to move the energy industry into a new era of reliability, availability, and efficiency that will contribute to our economic and environmental health.”  I believe that the underlying impetus is “environmental health”.  The only way to integrate renewable technology is the smart grid and everyone knows that we need renewables to save the planet.

New York State energy policy is on board with the Smart Grid and it has been sold to the gullible and innumerate as a simple, cheaper solution.  Cynics like me say if it is so good then the market should choose it as the preferred alternative.  Instead we get laws like CLCPA with its ambitious targets and the AREGCBA with its rushed incentives to build renewable technology.  As I have shown there is no New York plan to implement this technology and serious technological issues to address.  All we are left with are hollow promises and vague reassurances from the politicians.  Until we have a plan that includes costs and environmental impacts these laws should be put on hold if not repealed altogether.  The problem with the idiots in Albany diving from the high board without looking to see if there is any water in the pool is that they will take the reliable and affordable electric system crashing down with them.

Another Solar Power Issue in Upstate New York

I have calculated how much solar and wind power might be available based on meteorological data for several scenarios.  I discovered another complication that I had not previously included in my analyses that is the subject of this post.  In particular, the effect of snow cover on solar output.


I have analyzed the potential solar generation output that can be expected from facilities in New York based on incoming solar radiation.  In comments that I submitted on the New York Department of Public Services resource adequacy proceeding I prepared a white paper that provides an initial estimate of the likely energy storage component requirement based on historical meteorological data and developed an example of potential problems with air source heat pumps.  Based on that work, my primary concern is that New York State has not done a feasibility study to determine whether the solar and wind resources in the winter are sufficient to provide enough power when the heating sector is electrified.

Obviously if solar panels are covered with snow the generation output will be reduced but I had never quantified the impact.  The New York State Energy and Research Development Authority (NYSERDA) has an integrated data system that provides operational data on Distributed Energy Resources installed in New York.  During the research for a  previous post on this system I downloaded solar output data for the Howland Solar project in Sandy Creek, NY for the winter of 2020 and found data that could be used to estimate the effect of snow cover.

The following graph shows solar output data for the Howland Solar project in Sandy Creek, NY for the winter of 2020.  This site is located east of Lake Ontario in the heart of its lake-effect snow belt.

The thing that caught my eye were four periods when the daily average electricity generated was zero. In this analysis I will focus on the period near December 23. As shown in the next graph data from 16 December through 22 December indicate there was zero solar generation on five consecutive days.

The NYS mesonet has a monitoring station located close to this solar facility at Belleville. The following 7-day meteogram for this site shows that there was a snowstorm during this period. Note that the time scale in these graphs is for UTC time so they differ from the local time by five hours.

Although it is hard to see, the gold trace in the upper left graph is solar insolation. That graph also lists temperature which was below freezing throughout the period. The dark green line in the lower left graph is cumulative precipitation. On the graph it starts between 16/23 and 17/23 but because of the UTC times the onset was much closer to the start of December 17. Note that at the time when the total precipitation increased the most that the sonic wind speed and gusts (black and blue) in the upper right graph also peaked and that the wind direction was WNW as shown in the lower right graph. Those conditions are the classic signature of a lake-effect snow event.

The Buffalo National Weather Service office archives lake-effect snowfall maps for all big events. The map for this period confirms that this was a lake-effect event. The solar facility and the mesonet station are located just north of Pulaski at the eastern end of Lake Ontario squarely in the area that got at least 7″ of snowfall.

The Problem

The following temperature and solar radiation meteogram graph for 20 December shows the solar radiation more clearly than in the seven day. I have not found a better daily solar insolation curve to date. There is no indication (squiggles on the curve) of any variation of intensity other than diurnal sun angle. There could not have been a single cloud that day. The key point is that the temperature struggled to get up to 10 degrees F that day so there would have been high energy demand for heating at the same time .

So how much electric generation did the Howland solar installation provide to the grid that day? There were two hours of 1 kW, two hours of 4kW and two hours of 6 kW for a daily total output of 22 kWh. I checked my usage for that period and I used a total of 766 kWh for a daily average just under the total output of this facility. Importantly I do not use electricity for heating, cooking or hot water.


Clearly, it is not enough to just look at meteorological conditions to determine the potential worst case for solar power generation output.  Intuitively it is obvious that snow will cover solar panels and the output will be reduced.  This post demonstrates that for a 7” snowfall one solar facility output went to zero for four consecutive days.  I expect that any solar facility with a similar panel configuration located inside the seven-inch contour of the lake effect snow summary map would be similarly affected.

Weather maps for December 17-19 2019 show one typical winter storm scenario for New York.  On 17 December the first snow falls when a storm system goes up the coast.  When this happens snowfall is widespread but higher closer to the coast. 

On 18 December the storm system heads off to the north and east and as it does it draws colder air down from the north.  Oftentimes like in this period, lake effect snow bands develop with smaller areal extent but more snowfall. 

Finally, the cold air settles in behind the storm and lake-effect event, albeit not shown well in the 19 December map.

The future energy system ramification of this is important.  As shown here snow cover can eliminate solar generation output.  It is important to consider what will happen when there is a really big snowstorm that blankets New York with 7” of snow, followed by a lake-effect event that covers the usual lake effect areas with even more, and ends with a really cold day caused by a high pressure system.  Now you are talking about no solar output and reduced wind output at the same time electric loads will be high due to heating electrification.  The data shown here suggest that the no solar output situation can last for days. 

Until such time that New York State shows that they have a plan to address this worst-case situation I believe we could end up with people freezing to death in the dark.

New York Distributed Energy Resources Information

Distributed energy resources (DER) are technologies that generate or manage the demand of electricity at different points of the grid, such as at homes and businesses, instead of exclusively at power plants.  The New York State Energy and Research Development Authority (NYSERDA) has an integrated data system that provides operational data on DERs installed in New York. According to NYSERDA “DERs can play a critical role in supporting Governor Andrew M. Cuomo’s Climate Leadership and Community Protection Act (CLCPA). The CLCPA codifies Governor Cuomo’s nation-leading goals.”   This post looks at the data available from NYSERDA.


NYSERDA has developed dashboards like their DER integrated data system on various energy and environmental topics.  The main purpose, I think, is to publicize the results of their programs.  While the idea to have a location where anyone can track information is understandable my experience with these systems is that these overview systems can also lead to misunderstandings and unintended uses for the data.  As we shall see this is the case for this dashboard.

The NYSERDA website provides an overview of the DER resource.  NYSERDA alleges that they “allow owners to reduce their facilities’ carbon footprints, rein in energy costs, and improve utility grid power-outage resiliency”.  My intention was to use their data to check on these claimed benefits but it is not clear how useful the information presented is for this purpose.  First here is what is available.

The Solar data provided includes performance data for 508 larger commercial and industrial solar installations. According to NYSERDA:

“DER Solar panels, which are made up of photovoltaic (PV) cells, convert sunlight into electricity without creating noise, air, or water pollution. Solar can be connected directly to the grid or connected behind the customer’s meter within the building. Either way, utilities offer compensation for electricity generated by solar but not used on-site.”

The website lists 418 Energy Storage projects but provides no summary performance data information.. According to NYSERDA:

“On-site energy storage, including batteries, allows facility owners to lower their costs by storing cheaper energy for use when electricity costs are high. This includes storing electricity purchased during periods of low demand to use during peak hours, or similarly storing energy generated by solar panels during the day for use later. They can also be used to shift the building’s demand, thereby allowing for savings on utility demand charges. Depending on how they are interconnected, energy storage systems can be used during grid outages to provide some resiliency to the building.”

The summary of resources describes Hybrid Systems but offers no information on such systems in New York.  According to NYSERDA:

“Hybrid DER projects have two or more energy technologies installed at a site, working in synergy to provide more benefits than two separate projects. For example, solar projects combined with energy storage technologies can save excess energy generated from the solar panels during the middle of the day, which can be used in the late afternoon and evening.”

The website lists 208 Combined Heat and Power projects.  According to NYSERDA:

“Combined heat and power (CHP), or cogeneration, simultaneously generates thermal and electrical energy from a single fuel source. By recycling valuable heat from the combustion process, CHP can result in greater overall efficiencies than centralized power generation, transmission and distribution. The recovered thermal energy from on-site CHP systems may be used for industrial processes, space heating, domestic hot water, or cooling through an absorption chiller. CHP is considered a viable and economical use of distributed generation (DG) when installed at or near the point of use.  At the start of 2017, 4,395 commercial, industrial, healthcare, multi-family residential, and other energy use-intensive facilities in the United States had operational CHP systems, representing a combined electric generation capacity of 82,600 MW. 631 of these systems, totaling 5,500 MW, were in New York State.”

“Combined heat and power” is the current label for “co-generation”.  Cogeneration has a bad reputation.  The Public Utility Regulatory Policies Act of 1978 (PURPA) was intended to encourage:

      • The conservation of electric energy,
      • Increased efficiency in the use of facilities and resources by electric utilities,
      • Equitable retail rates for electric consumers,
      • Expeditious development of hydroelectric potential at existing small dams, and
      • Conservation of natural gas while ensuring that rates to natural gas consumers are equitable

One of the ways PURPA tried to accomplish its goals was through the establishment of a new class of generating facilities which would receive special rate and regulatory treatment. Generating facilities in this group are known as qualifying facilities (QFs), and fall into two categories: qualifying small power production facilities and qualifying cogeneration facilities.

In 1981 New York regulators tried to enact energy policy that went beyond PURPA in the well-intended, but disastrous, legislation known as the “six-cent law,” that required utilities to purchase power from unregulated co-generators for a minimum of six cents when more often than not, the utility-owned generation made power at less than half that cost.  The legislation estimated that the avoided cost of generation would be worth six cents but when the actual costs were much lower the feeding frenzy in the market overwhelmed the regulatory process and caused massive losses for the regulated utilities that were passed on to the consumers.  The high mandated price prices coupled with “the ingenuity of new entrepreneurs who stormed into the market were enough to create a massive problem of excess capacity”.  In 1992, New York amended its Public Service Law to eliminate the mandatory six-cent rate.  There is no wonder that the co-generation label is avoided at all costs by New York regulatory agencies.

The website lists 38 Anaerobic Digester projects.  According to NYSERDA:

“When organic materials such as manure, agricultural waste, food waste, and other wastes breakdown in the absence of oxygen—a process called anaerobic digestion—they produce an energy-rich gas called anaerobic digester gas (ADG) or biogas. Anaerobic digestion processes can reduce methane emissions from organic wastes in addition to producing renewable energy from ADG. Facilities with ADG systems can reduce their energy costs and emissions by generating and using electricity onsite or produce vehicle fuel from what would otherwise be waste.”

The website lists 41 Fuel Cells projects.  According to NYSERDA:

“Fuel cells use an electrochemical process to convert a fuel’s energy to electricity without combustion. Fuel cell uses include portable power generation, stationary power generation, and power for transportation.”

Performance Data

NYSERDA tracks real-world performance data for over 1200 projects so I thought that I could use their information to project how these resources have operated to date.  When I accessed the website on March 8, 2020 the total performance to date claim was 6,260 GWh of electricity have been produced.  The data can be accessed for individual facilities or combined in a portfolio.  I downloaded the performance data for portfolios composed of all the anerobic digesters, combined heat and power, fuel cell, and solar resources to get capacity factors, electric efficiency, and thermal efficiency.  The NYSERDA Distributed Energy Resources Performance Data table lists the performance data by these resources.  I found the first inconsistency in the data at this point.  The GWh sum of the individual resources is 5,258 GWh.

I contacted NYSERDA about this issue and did get a response.  According to staff, the DER data website ignores “unreliable” data which doesn’t meet quality control algorithms.   In this instance I would expect that the total performance data would exclude unreliable data so that the dashboard total would be less than the total of the individual sources.  So either NYSERDA or I misunderstood the other party.

 Characteristics Data

The NYSERDA Distributed Energy Resources Characteristics Data Summary table lists data for the different types of resources.  It lists the number of facilities for different sizes, the largest rated electric capacity within each type, the total capacity, and the number of facilities in the performance data and the characteristics data.  As was the case with the performance data there was another inconsistency because the summary totals and the sum of the individual projects do not match.

In response to my question about this discrepancy NYSERDA responded that “The differences in counts (number of “facilities” not exactly matching number of “reporting entities”) could occur if a given site has two different systems on different electric services and thus different data collection/data reporting meters (one site, two data streams)”.   This is an example of an unintended application for the dashboard.  As an overview it is fine but if someone else has specific questions about a certain type or resource they will get as confused as I did.

There are 38 anerobic digesters in both the performance and characteristics data.  The majority (29) of these digesters are located on dairy farms.  Eight are at waste water treatment plants and one is located at the Saranac brewery.  Note that the “system” rated electric generation is inconsistent with the “project” rated electric generation.  I used the system values.  Only three of these are greater than 3 MW and the majority are rated between 100 and 500 kW. As a result, they should be viewed as replacing the power they need from the grid rather than a potential source of significant supplemental dispatchable power.

Combined heat and power distributed energy resources include the highest electric capacity unit at 37.5 MW.  The NYSERDA performance data says that there are 208 facilities but when I totaled the characteristic data, I only came up with 206.  There are 158 facilities under 0.5 MW, 19 between 0.5 and 1 MW and 29 greater than 1 MW.  These facilities have advantages for the system in that they are dispatchable, they are generally bigger than most other resources, and they provide over 200 MW of capacity.  I think there is another huge advantage in that they are truly resilient.  If they are using natural gas then their supply is underground and cannot be blown away by high winds.  The problem is that they are fossil-fired so it is not clear how much of a contribution they can make in the CLCPA 2040 electric generation world when no electricity is supposed to be fossil-fired.

Energy storage systems resources did not include any performance data.  Energy storage is a critical component for the CLCPA 2040 goal because there are times when the wind does not blow at night so there will be no renewable energy generation.  I estimated that the amount of energy storage needed for a light-wind fifteen-hour period from January 3, 2018 at 1600 until January 4, 2018 at 0600 would total 134,545 MWh.  The storage projects listed in here total 63.3 MW and have a storage capacity of 123.6 MWh.  In addition, note that there were two projects where the storage capacity in kWh was less than the storage in kW, i.e., the data are wrong.  According to NYSERDA there are 418 energy storage projects but 75 projects don’t have any discharge capacity levels listed so my table only lists 343 projects.  Again, that means the data are incomplete or wrong.  Most of the projects are small.  In fact, there were 306 projects that were smaller than 25 kW.  Another 30 are smaller than 1 MW which means that there were only seven projects greater than 1 MW.  I doubt that energy storage below 1 MW will have value for the grid energy storage deficit reduction I predict will be needed.

Fuel cells are toys in my opinion.  The data characteristic data has a total of 36 facilities and the performance data summary claims 41.  Thirty-two facilities are less than 0.5 MW.  Distributed energy resource purports to make the grid smarter by spreading the generation out but these facilities are so small that they will likely only provide power for the facility served.  Very little generation could be provided to support the grid itself.

Solar PV is the largest distributed energy resource.  The data characteristic data has a total of 485 facilities and the performance data summary claims 508.  There is a total rated electrical capacity of 732 MW and the largest facility is 14.9 MW.  Also note that there are 226 facilities that are rated for over one MW.  Unfortunately, the solar PV resource is intermittent and diffuse.  In order to support the grid you need energy storage and transmission to get the power from where it is produced to where it is needed.


I conclude that the NYSERDA integrated data system is an interesting source of distributed energy resource data and it can be used to determine how well the State’s programs are doing.  At this time there is just over one GW of DER rated capacity in this system provided by over 1200 facilities.  It is not clear to me whether the results presented are a cause for optimism or pessimism.  On one hand there are quite a few projects but on the other the output is not all that impressive.

NYSERDA could use this information to do an analysis to determine just how effective these resources would be relative to the Climate Leadership and Community Protection Act targets.  For example, one question could b:  if anerobic digesters were installed at all the municipal waste water plants how much power could be generated?  Of course, it is more complicated because there are likely space constraints the preclude installation.  The follow up question then becomes were the eight waste water treatment plant systems installed all that could be installed?  I have argued that a study to determine the availability of wind and solar based on meteorological data is necessary and believe this shows that a study of other resource availability would also be appropriate.

Hornsdale Power Reserve Considerations

At the Trust, yet verify blog, Michel has written a couple of posts about the Hornsdale Power Reserve.  I had intended to do a post on this energy storage facility for a while and commented that I was planning to do a post but hadn’t gotten around to it.  When I said would not have to produce a post Michel said his was only one way to look at it and there are other possible views.  After reading the second post I decided to make a point about this system as it relates to New York State energy policy.


According to the Hornsdale Power Reserve website “At 100MW/129MWh, the Hornsdale Power Reserve is the largest lithium-ion battery in the world, and provides network security services to South Australian electricity consumers in concert with the South Australian Government and the Australian Energy Market Operator (AEMO).  The Hornsdale Power Reserve is a facility comprising of a 100MW/129MWh Tesla Powerpack system located approximately 15km north of Jamestown in South Australia.”

In the first post Michel addressed the claim made by renewable energy advocates that batteries can replace natural gas for peaking and gap filling.  The advocates point to Hornsdale profits as proof of this claim.  However, he showed that the facility was making most of its money providing Frequency Control Ancillary Services.  There is great value to the electric grid having a way to quickly address variations in grid frequency and this system does that well.  However, peaking requirements are different and there is no sign that this small a system can provide much value for that need.

In the second post he responded to a heated discussion on a reblog of the first post on the blog “Utopia, you are standing in it!“  An advocate for renewable energy claimed that battery systems like Hornsdale can compensate for intermittency problems.  In this particular case, the intermittency from break downs at fossil-fired power plants was the cited example.  Michel concluded that “A power plant with a capacity of 1,480 to 2,200 MW breaking down is by no means a “minor” event and if a battery system with a capacity of 55 MW / 80 MWh (or even a 100 MW / 129 MWh in case of the Hornsdale Power Reserve) is able to compensate for such an event, then it most probably wasn’t a “break down””.

In this post I want to look at the use of energy storage batteries for short-term fluctuations of renewable energy resources at an example solar facility.  On March 17, 2020 North Park Energy submitted their Public Involvement Program Plan as the first step of the New York State electric generation permitting process.  Their proposed Declaration Energy Center Project in Seneca County is proposed to have a generating capacity of 450 MW covering a project area of ~4,400 acres of land of which ~ 2,500 to 3,000 acres will be used for the solar energy center.


In this post I want to show that there is another aspect of the intermittency problem. To date I have focused on intermittency energy storage when wind and solar resources are low and must be replaced.  In particular, those times when the wind does not blow at night.  The problem I want to address here is short-term intermittency when solar is affected by variable clouds.

In order to determine how solar electric generation could vary over short periods I used short-term meteorological data from the NYS Mesonet meteorological system. The NYS mesonet is a network of 126 weather observing sites across New York State.  The official website of the Mesonet includes a tab for live data that brings up station information for the 126 operating individual sites that shows that available data include wind direction and speed, temperature at two levels, relative humidity, precipitation, pressure, solar radiation, snow depth, and camera images. For this analysis I obtained 5-minute archived meteorological data for the Rush and York Mesonet stations near Caledonia, NY.  I previously used these data to evaluate the output from a proposed 180 MW solar facility nearby but will assume that these data also represent conditions that could be expected at the Declaration Solar 450 MW project.

I analyzed the five-minute solar insolation (watts per meter squared) to determine how the electric generation output from photovoltaic solar panels would vary.  I only looked at five-minute periods when the solar insolation was greater than zero for a fifteen-day period (12 July through July 26 2017). The Summary Solar Insolation Statistics for Rush and York page lists statistics for different parameters in three tables.  I list the standard descriptive statistics for both stations in the first table.  There are over 2,700 five-minute periods when there was solar insolation greater than zero in this period.  The average insolation was around 300 watts per meter squared and the maximum insolation was just over 1,000.

In order to assess solar variability effects, I calculated the absolute difference between successive observations.  In the second table I list the summary statistics.  While the average difference is around 50 watts per meter squared the standard deviations are 1.7 times greater suggesting that there is a lot of variability.  Importantly, the maximum difference between successive periods is 702 watts per meter squared at Rush and 675 at York.  The maximum solar output difference divided by the maximum solar radiation represents the maximum variability.  Any solar facility near Rush could generate up to a change of 68.9% of the maximum output in successive five-minute periods and at York the maximum change would be 62.4%.  The last table shows the frequency distribution of the five-minute absolute difference percentage change.  Note that 1% of the time solar generation output varies 40% or more.


The solar variability analysis provides an overview of the data for one example period.  The archive for the Mesonet includes daily meteograms or graphs of different weather parameter which provides an overall description of the day.  The reports for the July 18, 2017 solar radiation example are available at these links: Rush and York but I have also provided  the Rush and York 18 July 2017 meteograms  which combines the two. (Note that the hours listed are UTC times so you need to subtract five hours to get to Eastern Daylight Time.)  During the proceeding night temperatures dropped enough that in the morning there was very high humidity and possibly fog with light winds so I don’t think there were clouds.  Once the sun came out the temperature rose quickly but note the variability throughout the day.

The Solar Variation in Five-Minute Meteorological Data at the Rush and York NYS Mesonet Stations table lists all the meteorological data available from the Mesonet five-minute data archive and the calculated absolute solar insolation difference between five-minute periods.  This table highlights cells where the difference between successive 5-minute periods is greater than half the maximum observed solar radiation in the Insolation % of Max Delta column.  Note that during this 8-hour period that value was exceeded seven times at Rush and six times at York.

The Solar Electric Output Variation in Five-Minute Meteorological Data at the Rush and York NYS Mesonet Stations table lists estimated power output based on two testing conditions used to rate the output of solar photovoltaic modules for a more limited period than the previous table.  Although there is a temperature factor that should be included to increase accuracy, I am only going to consider the effect of insolation.  In this instance ambient temperatures were close to the testing temperature of 20 deg C so it probably is not much or a factor.  The first test condition is Photovoltaics for Utility Scale Applications (PV-USA) and that determines maximum output when the insolation equals 1,000 watts per square meter.  The second condition is normal operating cell temperature (NOCT) which rates maximum output when the insolation equals 800 watts per square meter.  The Declaration Energy Center Project is proposed to have a generating capacity of 450 MW.  My naïve formula for solar output was simply the observed input solar insolation times solar PV capacity (450 MW) divided by the test condition insolation.

Using Rush meteorological conditions, the largest 5-minute change occurs from 1245 to 1250 EDT when the output changes 66% or 301 MW using PV-USA or 376 MW using NOCT.  It might be more of problem for the York data at 1325 EDT when the output went down 59% but then back in the next five-minute period 52%.  That is a PV-USA load swing of 287 MW and 256 MW or a NOCT load swing of 359 MW and 320 MW.

That is concerning enough but the fact is that the partly cloudy weather on July 18, 2017 commonly covers a large area and it would not surprise me in the least that most of New York was in these conditions.  As of March 17, 2020 there are 36 solar facilities totaling 5,759 MW and another four solar plus storage facilities totaling 740 MW currently in the New York State active permitting queue.  Let’s say that half of the solar-only facilities were in the same weather pattern.  In that case I expect that the solar output would be jumping around by hundreds of MW every five minutes and in the worst case by a couple of thousand MW.  This would be large short-term variability for the grid to handle and remember that I showed earlier that 1% of the time solar generation output varies 40% or more between five-minute periods.

The obvious solution is to require solar facilities to have an energy storage battery that could buffer the output from the solar panels to the grid.  Instead of tying the solar facility directly to the grid the output would go to a battery that should be able to provide power with less fluctuations.


This post adds another caveat to the claims of renewable energy advocates. The all-renewable electric grid has to rely on energy storage.  At first glance energy storage only appears necessary to provide power when renewable resources are not available for hours or days.  However, the requirements are more complicated and nuanced than that.

In previous posts at the Trust, yet verify blog, it was shown that energy storage systems such as the Hornsdale Power Reserve cannot provide peaking support or compensate for intermittency problems at larger power plants unless they are much larger.  On the other hand, Hornsdale is making money providing Frequency Control Ancillary Services.

In my previous energy storage work I considered energy storage with respect to renewable energy resources to determine costs.  In order to rely on renewable energy, stored energy has to be provided at night when the wind is not blowing.  This article shows that in addition to the longer-term storage problem, there is a short-term renewable output fluctuation problem that we may have to rely on battery energy storage to resolve.

There is no question that energy storage systems like the Hornsdale Power Reserve can provide value to the electric grid.  However, we have shown that increased renewable resources will cause multiple problems that have to be resolved.  On one hand, it is clear that much larger battery systems will be needed for the more obvious requirements but it is not clear to me that those systems could also be used to simultaneously resolve the other problems described.   I suspect that batteries operated to provide Frequency Control Ancillary Services or to address the five-minute fluctuations issue have to be operated differently because in both instances they have to react to increases and decreases in power.  Therefore, the batteries would not be charged to the maximum level.  On the other hand, if the primary purpose is energy storage then you need to keep them charged as much as possible.

Renewable advocates are fond of saying that wind and solar development costs are cheaper than fossil-fired alternatives.  However, when you start adding the costs to make those intermittent sources available as needed that argument fails because of the energy storage issues described here.


Cuomo’s Promise to Free the New York State Fairgrounds of Fossil Fuels

On March 11, 2020 Glenn Coin at the Syracuse Post Standard posted a paywalled article at entitled Governor Cuomo’s big promise to free the state fairgrounds of fossil fuels: What’s the status?  This post addresses the prospects for a fossil-free State Fair.


I am a retired electric utility meteorologist with nearly 40 years-experience analyzing the effects of meteorology on electric operations.  I have also spent a lot of time evaluating electric load and generation variability.  That background served me well preparing this post.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Mr. Coin did a good job describing the problems involved, but he did not critically evaluate what he was told by the energy experts he interviewed.  On the basis of his interviews he concluded “While building enough solar panels to provide the fair’s electricity would be straightforward and effective, heating the fairgrounds’ vast buildings all year would be much harder and could involve wholesale renovations to heating and hot water systems”.  This post will concentrate on the claim that providing electricity from renewable resources would be “straightforward and effective”.

Coin quoted Chris Carrick, energy program manager for the Central New York Regional Planning and Development Board as saying that “solar is doable”. Carrick, who has overseen solar installations in Central New York, said “the 9 million kilowatt hours the fair used in 2018-2019 could be supplied by a 45-acre solar array and that would cost about $12 million to build”.  Coin pointed out that there would be a problem if the fair installed its own solar power because the electrical use isn’t constant throughout the year. Using monthly data provided by the Fair Data he found that it uses about a third of its annual electricity during the months of August and September.

Coin also interviewed a professor and renewable energy expert at SUNY College of Environmental Science and Forestry, Dr. Neal Abrams. “The fair uses a lot of power, but only for a small amount of time,” Abrams, “Installing solar and/or wind exclusively for the fair doesn’t make sense, but if it is part of a larger state- or utility-owned project, it could.”  Abrams said it might make more sense for the fair to tap into community based solar projects. If the state wanted wind power at the fair, he said, there’s no reason to build new turbines when wind farms are already in place in in Madison county and Tug Hill.

For the purposes of this post I am going to calculate what renewable resources would be required to meet the Governor’s proposal.  In my opinion the claim should stand on its own with new renewable resources.  What the fair does not need can be used elsewhere but it should not rely on existing sources or projects in development designated for other purposes.  Otherwise Governor Cuomo could already have said the State Fair gets all its electric power from renewables instead of a promise for the future.

In order to properly calculate the requirements to make New York State Fair electricity fossil-free detailed historical load information is needed.  I don’t have that information so I am going to have to explain what I am assuming about load and why I am assuming it.  Ultimately, I hope to show readers the difficulties glossed over by the renewable energy proponents that Mr. Coin interviewed.  If you don’t want to wade through the numbers then skip the analysis section and cut to the chase.


I am going to focus on Chris Carrick’s claim that “solar is doable”. He said “the 9 million kilowatt hours the fair used in 2018-2019 could be supplied by a 45-acre solar array and that would cost about $12 million to build”.  I will show solar is not so doable or cheap unless you use his simplistic approach.

One of the difficulties explaining technical information is the need for background information.  Another problem is there is little room for the details and, frankly, no public appetite for the boring minutiae needed to check numbers so it is understandable why that information was not included in the article.  I don’t have any space restrictions and will try to keep readers awake long enough in this explanation section so that you understand my calculations and conclusions.

A primary problem with solar energy is that it is intermittent.  Obviously at night there can be no solar energy generated and when it is cloudy the amount produced is lower than on a clear day.  The capacity factor (the actual amount of energy produced divided by the maximum possible amount of energy produced) is a measure of the availability of any electric generation source.  I will use that parameter in this analysis to calculate how much energy can be produced for a solar farm of a given size over a given time.

I chose to use performance information from a local solar installation to evaluate the claim that solar is doable and would cost about $12 million.  I used the Onondaga County Oak Orchard Waste Water Treatment Plant (OOWWTP) which has data in the New York State Energy & Research Development Authority Distributed Energy Resources system.  The first data reported from this installation is dated 31 August 2018.  The facility was developed by Tesla Energy Operations, Inc. with a rated electric generation capacity of 2,523 kW.  Even though this is about ten miles away from the Fair I chose the site because it is relatively new, is at the same elevation as the state fair so there should be no problem with orographic cloud so cloudiness should be relatively similar, and because there wasn’t anything with data available really close to the fair grounds.

According to Coin’s article the fair used 9 million kilowatt hours in 2018-2019.  I will assume that is an annual number.   In 2019 OOWWTP generated 2,363,640 kW of electricity for a capacity factor of 10.7%.  In other words, it produced 937 kWh for each kW of capacity.  In order to produce 9 million kWh the facility would have to have a capacity of 9,607 kW.  The article did not give a capacity but did state that a 45-acre solar farm could provide the electrical energy needed. Assuming 66 square feet generates 1kW of solar energy 9,607 kW would require 14.6 acres of solar panels.  Another way to calculate the space needed from OOWWTP is by estimating the area of the solar array from a satellite view.  I estimate that the OOWWTP array itself covers 7.54 acres and scaling that by the kW capacity produces an area of 28.7 acres.  My annual estimate appears to be significantly different that the Carrick’s quoted 45 acres of panels so I assume he did not use the annual number to estimate the size of the needed solar farm.

Even though I cannot reasonably say that my estimates of the annual solar electric generation reasonably match the article’s estimate it does not matter much because using annual numbers is wrong.  I will show below that the time period used to estimate the necessary resources matters a lot.

The article notes that “The fair uses about a third of its annual electricity during the months of August and September”.  The annual number is 9 million kWh so for those two months 3 million kWh is needed.  The good news is that 2019 monthly capacity factors ranged between 2.14% and 19.44% and the higher numbers are in the summer.  The Monthly Solar Output Onondaga County Oak Orchard WWTP table lists all the monthly values.  I calculated that the capacity factor for the two months would be 14.13%.  In August and September 2019 OOWWTP generated 521,976 kWh of electricity.  Therefore, it produced 207 kWh for each kW of capacity.  In order to produce 3 million kWh the facility would have to have a capacity of 14,500 kW.  Based on the data for these two months the solar facility would have 1.5 times larger capacity than one sized based on annual data.  Assuming 66 square feet generates 1kW of solar energy 14,500 kW would require 22.0 acres of solar panels and scaling the size of the OOWWTP array would be 43.3 acres.  That is pretty close to Carrick’s 45 acres so let’s assume he used the monthly numbers to estimate the necessary resources.

Of course, most of the power is used during the 13-day run of the fair itself.  In order to estimate the daily requirements, I arbitrarily assume that the power used during the State Fair days is ten times the power used on the other 49 days in August and September.  I calculate that the average power used on a State Fair day is 167,598 kWh.  The Daily 2019 State Fair Electric Energy (kWh) Needed and Production Equivalent to Oak Orchard WWTP Solar System table lists the data used to calculate the average State Fair day electric energy need and the daily output and daily capacity factor from the OOWWTP.  Using the same methodology to determine how much electric energy could be generated for each 1 kW of capacity the table lists the capacity needed for each day of the 2019 Fair season.  There probably are daily difference sin energy use as a function of the attendance but I did not try to estimate that effect.  Nonetheless, we can see that even on the day with largest capacity factor (8/25/2019) the capacity needed for one state fair day doubles the monthly estimate and that a facility with a capacity of 30,415 kW would be needed. Importantly note that the day to day variation of the capacity factor.  On the worst day you would need to over 171,000 kW of capacity using these assumptions about daily load at the State Fair and that would require a solar facility nearly 12 times larger than one based on the monthly numbers.  I assume that would be an overestimate because on the day with the lowest solar capacity problem also was the lowest attendance day so probably was not only cloudy but raining.

Renewable proponents rarely acknowledge the time period problem shown here because it makes their cost estimate of the renewable resource worse.  There is an even bigger problem that is rarely mentioned.  The all renewable resource plan should also account for energy storage needed when winds are calm at night.  The Hourly State Fair Electric Energy (kW) Requirements and Estimated Deficit table lists estimated hourly loads and potential solar and wind hourly output.  In order to estimate the hourly load, I made assumptions about the hourly load in the State Fair Hours Weight column.  I assumed that hours 19 through 22 would be maximum load and that hour 02 through 06 would be 15% of the maximum.  The column lists the hourly assumed load as a percentage of the maximum load for all the hours.  I used that information and the assumed 167,598 kWh of a State Fair day value to calculate the hourly loads shown.

The table also lists the hourly renewable energy outputs which can be combined with the hourly load estimate to determine the margin between the two.  Remember that the Governor wants to make State Fair electricity all renewable so at the end of the day the cumulative margin should be positive.  In this analysis I estimated how much wind and solar would be available on the best solar capacity factor day.  I estimated that a solar facility (capacity of 30,415 kW) based on the previous daily requirement analysis combined would be needed and combined that with the OOWWTP output data for August 25, 2019 to predict solar generation.  I utilized the same approach to calculate the capacity that would be needed for a wind farm to power the same average daily load.  II used the capacity factor from all the onshore wind farms during the State Fair and calculated that 23,423 kW of wind capacity would be needed to provide 1,675,978 kWh.  Hourly wind data downloaded from the NYISO real-time dashboard were used to calculate the hourly capacity factors needed to estimate hourly availability of wind on August 25, 2019.

The analysis shows that there are five hours when the combined solar and wind energy resources are insufficient to power the State Fair.  The Governor’s promise to use only renewable resources should include energy storage costs for those five hours when winds are light at night. A recently released report from the National Renewable Energy Lab (NREL): “2018 U.S. Utility-Scale Photovoltaics-Plus-Energy Storage System Cost Benchmark” provides information that can be used to estimate the costs of the energy storage option.  I explained how information from that report could be modified to estimate costs for any configuration in another posted essay.  In the Calculated Cost Breakdown $ per kWh Parameters for a U.S. Li-ion Standalone Storage System table I show how to estimate the costs for a solar-only system ($30.5 million) and a combined solar and wind system ($9 million) to meet the shortfalls for this example State Fair day.

There is another consideration with Li-Ion battery storage systems.  The National Renewable Energy Lab (NREL) report Life Prediction Model for Grid-Connected Li-ion Battery Energy Storage System  notes that in order to maximize battery life the batteries have to be operated such that a limited operating range is used.  In particular the report says that they must use “active thermal management and cycle the battery within a restricted 54% operating range”.  When the operating range limitation is included the battery storage costs increase to $55.7 million for the solar-only system and $16.8 million for the solar and wind system.  Don’t forget that is only for ten years!

 Conclusion aka The Chase

As noted before Chris Carrick claimed “solar is doable”. He said “the 9 million kilowatt hours the fair used in 2018-2019 could be supplied by a 45-acre solar array and that would cost about $12 million to build”.  Using the information available in the article I was not able to reproduce those values exactly so I am not sure what assumptions were used.

I used historical data from a nearby 2,523 kW solar array to compare with Carrick’s numbers.  Using 2019 annual operating capacity in order to produce 9 million kWh the capacity of a solar array would have to be 9,607 kW.  However, the proportion of the size of the local solar array to the size of the array needed is 29 acres which is not particularly close to the size Carrick claimed would be needed.  I assume that even though he mentioned needing 9 million kWh that he did not use that value to calculate the size.

The fair uses about a third of its annual electricity during August and September.  Using the observed operating characteristics of the local array I determined that the size of the array necessary to provide the State Fair with that amount of power would have to be 14,500 kW.  The proportion of that amount of power to the local array indicates that new array would have to be 43 acres so I assume that Carrick sized his array based on the August and September data.

However, in order for renewable resources to provide all the electricity for the State Fair we need to look at the renewable resources and energy use on the ten days when the State Fair is open.  Using the best local data availability and my estimated daily energy usage the solar array necessary to meet the Fair’s needs would have to have a capacity of 30,415 kW, over twice as large as using a monthly estimate to determine needs.  The Daily 2019 State Fair Electric Energy (kWh) Needed and Production Equivalent to Oak Orchard WWTP Solar Systemtable shows that daily variation is high.  On the worst-case day, you would need a solar array of 171,000 kW capacity nearly 12 times larger than one based on a monthly value.

Proponents of renewable energy typically ignore the short-term renewable requirements but there is an even bigger problem.  Any plan to become 100% fossil free needs to account for the fact that energy storage is required at night when the winds are light.  On August 25, 2019 I determined that there were five hours when solar and wind energy resource output would be insufficient to power the fair and that energy storage would be required.  I estimated that 23 MWh of energy storage would be required to balance the deficits observed.  In order to maximize battery life the operating range of Li-Ion batteries is only 54% so that means that batteries capable of providing 43 MWh are needed.


I was not able to verify Carrick’s cost estimate of $12 million dollars.  However, using daily data instead of monthly data increases the solar power needed between two and twelve times his estimate so it will be more expensive than he claimed.  In order to minimize energy storage cost, I included output from a 24,423 kW wind farm which I would expect to be on the order of the same cost of the solar array.  Even with the wind farm, the energy storage cost to backup the solar array adds another $16.8 million dollars.  If we assume that the wind and solar resources can last 30 years then that means that the battery cost will be tripled.


In conclusion, I expect that the cost of the solar array will be at least doubled if the daily needs of the State Fair are considered, in order to minimize energy storage a wind farm costing about the same as the original solar array has to be included, and energy storage at about the cost of the original solar array will be needed three times over the lifetime of the solar array.  Add them all up and I estimate that the true cost of renewables is at least six times higher than Carrick’s estimate of $12 million.

Mr. Coin concluded “While building enough solar panels to provide the fair’s electricity would be straightforward and effective”.  If costs are no object then it is “doable”, but I challenge the “straightforward and effective” conclusion.  The claim that all that is needed is a 45 acre solar facility is wrong if we are to provide the State Fair with all the electric power needed during the ten days the fair is open.  In the cheapest scenario I estimate that the solar array has to be at least twice as large, a wind farm with ten 2.5 MW wind turbines and an energy storage array totaling 43 MWh would be needed.

I don’t have the time to comment on Mr Coin’s conclusion that “heating the fairgrounds’ vast buildings all year would be much harder and could involve wholesale renovations to heating and hot water systems”.  However, all the problems that I found for the summertime use of electricity at the fairgrounds are compounded in the winter because the solar resource is so much lower.

Finally, there is one last aspect of Cuomo’s, dare I say it, grandstanding.  What about transportation at the State Fair?  With the exception of some of the buses that provide shuttle service, all the transportation servicing the Fair are powered by fossil fuels.  That includes trucks bringing food and material, moving the midway with all the carnival rides and attractions, and all the farmers bringing livestock to exhibit.  Finally even the on-site the trams used to get around are pulled by fossil-fired tractors.

Do not hold your breath waiting for a truly fossil free New York State Fair.

EPRI Electrification Scenarios for New York’s Energy Future

In the summer of 2019 Governor Cuomo and the New York State Legislature passed the Climate Leadership and Community Protection Act (CLCPA) which was described as the most ambitious and comprehensive climate and clean energy legislation in the country when Cuomo signed the legislation. The Electric Power Research Institute (EPRI) recently released an “assessment of the potential role of electric technologies to meet energy needs and resulting impacts on end-use energy efficiency, electricity supply, and economy-wide emissions through 2050” for New York.  This post looks at the results of this analysis relative to the CLCPA and is another in a series of posts on this legislation.

I am following the implementation of the CLCPA closely because its implementation affects my future as a New Yorker, specifically can I afford to continue to live here in retirement.  Given the results for other jurisdictions that have implemented renewable energy resources at far lower levels, I am convinced that the costs will be enormous and my analyses have supported that concern.  The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.


The politicians who passed the CLCPA mandated a reduction of New York’s GHG emissions to 60 percent of 1990 emissions levels in 2030 and that emissions from electricity production would be zero by 2040.  However, they just assumed that their targets could be met and only mandated that two years of the effective date of the legislation the climate action council would prepare and approve a scoping plan outlining the recommendations for attaining the statewide greenhouse gas emissions limits in accordance with the schedule.  In other words, this is a classic cart before the horse legislation example.

In the absence of a state plan I welcome any analysis of New York’s future energy system so I was happy to see this document.  The Executive Summary describes the report and notes the important caveat that it does not address the CLCPA requirements:

The analysis finds that electrification outcomes in New York, including the extent and timing of adoption, infrastructure and investment needs, and associated economy-wide emission reductions, will vary depending on a range of policy, economic, and technology factors. This study was conducted before the enactment of the state’s Climate Leadership and Community Protection Act and does not make policy recommendations or identify specific pathways to achieving the state’s greenhouse gas (GHG) targets. Instead, it illustrates that a portfolio of electric technologies could play a significant role in reaching the state’s energy goals. Furthermore, this initial assessment helps identify the areas in which legislators, regulators, utilities, grid operators, customers, and other stakeholders can work together on the next chapter of New York’s clean energy future.

Study Summary

The report describes the study methodology, assumptions, and limitations first.  Then it describes how NYS consumers use energy today. The study examines the evolution of electric technology adoption and the impact on the NYS energy system for four scenarios using EPRI’s NY-REGEN energy-economy

model.  The fourth section provides “an in-depth look at a variety of electric technologies, analyzes consumer costs and use cases, and identifies areas in which customer outreach and education may be needed in the future” .This approach is straight-forward and consistent with what anyone who is trying to project what may happen in the future would do.  There is one caveat I will mention though.  The NY-REGEN energy-economy model is simply a fancy packaging of what the model developers think will happen so it is only as good as the input assumptions.

For this type of analysis, the results have to be considered relatively.  Four scenarios were analyzed.

      1. The Baseline scenario reflects moderate improvement in technology costs and performance based on anticipated trends and EPRI research, and the attainment of pre-2019 NYS clean energy targets. Assumptions of economic growth, fuel prices, and service demand are drawn from the U.S. Energy Information Administration.
      2. The Carbon Price scenario maintains Baseline assumptions on technology improvements and cost decline. Under these conditions it explores the impact of hypothetical economy-wide carbon policy in which carbon dioxide (CO2) is illustratively valued at $50/ton CO2 starting in 20202 and escalating to $216/ ton CO2 in 2050.
      3. The Mandates scenario explores the impact of possible regulatory interventions for electric end uses and additional energy efficiency. The policies this scenario examines would require electric technologies for all installations of building heating equipment and new vehicle purchases in 2030 onwards. In addition to the Baseline assumptions, heating equipment performance improvements are accelerated by 15 years, but cold-weather breakthroughs are not assumed.
      4. The Transformation scenario combines the above Mandates with a hypothetical economy-wide carbon price of CO2 illustratively valued at $100/ton CO2 beginning in 2020 (escalating to $432/ton CO2 in 2050) with elements of the expanded clean energy targets in the state’s Climate Leadership and Community Protection Act.

Findings Summary

The report lists the following key findings with my italicized clarification comments

The results of this study are based on a suite of detailed assumptions and should be interpreted as directional in nature, helping to frame priorities for further study as New York State advances its energy goals. As noted previously the study developed a scenario for a baseline and then did three possible scenarios for the future.  Results should be considered by comparing the baseline results to the results of each of the scenarios.

      • The NYS energy system has large potential for electrification, which, in conjunction with low-carbon electricity, can achieve substantial CO2 reductions. Electricity’s role in the state economy will continue to grow over the next 30 years—the pace and extent of that growth will depend on policy decisions, technology improvement, market readiness, and economic conditions. Across the study’s four scenarios, electricity’s share in final energy use ranges from roughly 25% to 70% in 2050, up from around 20% today. If they had done an evaluation of the CLCPA then electricity’s share of final energy use would be even higher.
      • Energy efficiency is a key factor in reducing energy use, limiting CO2 emissions, and managing infrastructure needs. Even before accounting for electrification, the study finds that robust energy efficiency cuts total final energy use in NYS by 35% of what it otherwise would be in 2050; additional efficiency gains from electrification range from 9% to 21%. Energy efficiency gains are realized by both electric and direct fuel alternatives, with annual improvement rates ranging from 0.5% to 4% depending on the end-use technology.
      • After energy efficiency, electrifying transportation while decarbonizing the grid with renewable energy offers the greatest potential to cost-effectively reduce CO2 emissions in NYS. Electric vehicles (EVs) and plugin hybrid electric vehicles (PHEVs) are projected to become lower cost alternatives to conventional vehicles for most drivers within the next decade, even without additional economic incentives. Almost 30% of New York passenger vehicle miles are projected to be fueled by electricity by 2030 in the Baseline scenario, increasing to roughly 75% by 2050. EV charging infrastructure is an essential component to achieving a highly electrified transportation fleet in NYS. (According to Figure 2-6, there were 12,116,00 light-duty vehicles and 41,000 were electric in 2015 for 0.34%.)
      • New York’s winter climate and building stock call for advanced technologies and targeted approaches to heating electrification when compared to other areas of the United States (EPRI, 2018). While air-source heat pumps (ASHPs) are more efficient and cost-effective than oil-based heating, which continues to warm about one in four homes in New York, natural gas furnaces are currently more economic in NYS on an annualized capital and operating cost metric. Nevertheless, potential breakthroughs in cold-climate heat pumps—including ground-source heat pumps—have the potential to alter these cost and performance projections. Further study could assess the benefits, costs, and feasibility of these advanced technologies in conjunction with building envelope efficiency improvements. (Retrofitting ground source heat pumps is problematic so the more likely retrofit option is air source heat pumps.)
      • The adoption of electric end-use technologies will depend on individual customer decisions—market readiness, technology maturity, vendor-to-customer education, and appropriate incentives will be crucial to advancing electrification. While technology progress and carbon policy help to shift the market from fossil fuels toward electrified end uses, accelerating this transition may well require collaborative market interventions by policymakers, regulators, and utilities, with consideration of the needs of a diverse range of consumer situations—including low-income housing, older or landmarked buildings, and rural settings. (Collaborative market interventions could be construed as ramming what they want down the consumer’s throats.)
      • In all scenarios, New York’s statewide peak demand shifts from summer to winter and, if unmanaged, could increase substantially. Peak demands are expected to shift toward the early mornings of the coldest winter days, primarily due to increased EV charging needs in low temperatures plus electric heat pump adoption, while summer electricity usage drops as air conditioning efficiency improvements outpace growth in service demand. In the Mandates and Transformation scenarios, where customers electrify nearly all space heating and transportation but do not manage the timing of demand on the grid, peak winter demand in 2050 could be more than twice as high as today’s system peak. This highlights a key opportunity for New York’s electricity system stakeholders to develop and implement solution approaches such as cost-reflective time-of-use pricing, active load management of smart vehicle charging and other flexible loads such as space conditioning, behind-the-meter storage, and advanced cold-weather heating systems.
      • Flexible resources arising from a portfolio of advanced technologies and additional transmission will be critical to decarbonizing electricity generation. As more renewables are added to the generation mix to meet New York’s clean energy goals, dispatchable technologies will be needed to maintain reliability and balance variable generation, especially after 2030. Broadening the state’s portfolio of low-carbon, flexible generation assets can help reduce reliance on the gas generation fleet. EPRI’s new Low-Carbon Resources Initiative may provide important insights in this area. (The CLCPA likely remove the low-carbon resources initiative option from consideration.)
      • Customer adoption trends and electricity grid impacts are projected to vary across the state. Limited residential EV curbside charging, split tenant/landlord incentives, and variety across household characteristics and building types influence implementation in downstate urban areas, while affordability of converting to electric technologies may be a factor to consider in other parts of the state.
      • Electrification of specialized applications such as off-road vehicles (for example, forklifts), ground equipment at ports and airports, and industrial end uses may offer substantial benefits. Potential benefits include energy efficiency and reductions in emissions, noise, maintenance, and costs compared to the direct fuel alternative.

Motivated reasoning

There is a prevailing bias in this study that I believe motivates the reasoning and ultimately the results.  According to the document EPRI “brings together its scientists and engineers as well as experts from academia and industry to help address challenges in electricity, including reliability, efficiency, affordability, health, safety and the environment”.  There is no charge to EPRI from its funding organizations to consider all energy sources and determine the most affordable solutions for the future.  Consequently, they are all in for electrification.

This study was funded by the New York Power Authority (NYPA) and Consolidated Edison (Con Ed).  Both organizations have a vested interest in electrification and publicly supporting the CLCPA.  Increased electrification enhances their empires for lack of a better word so the more the better.  The Power Authority is an agency controlled by Governor Cuomo.  I can assure you that they cannot publicly question any action by any agency and certainly cannot raise questions about the viability of the Governor’s signature climate legislation.  Consolidated Edison is a corporation whose profits are dependent upon revenues determined by the Department of Public Services again controlled by Governor Cuomo.  Consequently, they too are reluctant to question the viability of the CLCPA.

According to the report “The study did not explicitly model recently adopted laws in New York City and New York State, such as New York City’s Local Law 97 or the State’s CLCPA. The study is not intended to identify explicit pathways to achieving the state’s GHG reduction targets. The scenarios presented here have been designed to illustrate the role of advanced technology alongside policy and regulatory drivers in reaching NYS’s clean energy requirements.”  I am confident that this language was vetted at the highest levels of NYPA and Con Ed to provide as much distance as possible from anything that could be construed as derogatory to CLCPA implementation.

One would think that a primary result from this analysis would be a comparison of the total costs for the four scenarios.  I did not read every word in the entire document but I did search for the word “cost” and the symbol “$”.  There are costs for options discussed in the electrification technology case studies but the total costs are not listed.  For example, the cost of air source heat pumps relative to natural and oil-fired furnaces are listed and it is shown that air source heat pumps are more cost-effective than oil-fired furnaces.  However, the study did not combine the number of fossil-fired furnaces that have to be converted and the cost of air source heat pumps to come up with a statewide cost. The absence of that obvious information certainly could be construed as a hiding a result inconvenient to the CLCPA.

Magical solutions

In my opinion, the findings include some results that are only possible if there are magical solutions.  In this category are technologies that are not currently available but are assumed to appear as needed in the future.  Also included are policies that have not succeeded as hoped so far but are also assumed to work as needed to meet the electrification scenario requirements.

In the electrifying transportation findings summary above I noted that in New York only 0.34% of the vehicles registered in 2015 were electric vehicles but the Baseline scenario assumes that almost 30% of New York passenger vehicle miles are projected to be fueled by electricity by 2030.  The latest NYSERDA electric vehicle registrations show that by October 2019 the number of electric vehicles was up to 64,588.  If we assume that the number of electric vehicles is proportional to the electric of vehicle miles traveled, then by 2030 there need to be 12,116,00*30% or 3,634,800 light duty vehicles so 3,570,212 electric vehicles have to be purchased in the next ten years.  The magical solution: “Even in the Baseline scenario, declining battery costs combined with lower fuel and maintenance costs make light-duty electric vehicles the economic choice for many households. The upfront cost premium relative to conventional vehicles is more than offset by lower total ownership costs of fueling and maintenance, driving economic adoption for many households and businesses.”  All this does is ignore the very real concerns of people who depend on their vehicles to provide transportation whenever they need it whatever the temperature to go wherever they need to go.  It also assumes that batteries will necessarily get cheaper.

In order to meet the CLCPA emission reduction goals electrification of home heating has to be increased.  EPRI points out that air-source heat pumps are more efficient and cost-effective than oil-based heating.  The problem is that below 20°F the “baseline ASHP system modeled for installation in 2020 provides full heating needs above 20°F only; at lower temperatures, supplemental heating by electric resistance, gas furnace, or oil-based heating equipment is required”.  Of course, all of New York has to have supplemental heating equipment because temperatures below 20°F are to be expected and that makes air-source heat pumps less attractive.  The magical solution: “potential breakthroughs in cold-climate heat pumps—including ground-source heat pumps—have the potential to alter cost and performance projections” that makes more widespread adoption the preferred approach.  This ignores the fact that heat pumps work by transferring energy from one place to another and that there just isn’t that much energy when the temperature is below 20°F.  The potential to alter cost and performance by much is not very likely absent repeals of the laws of physics.

The key findings note that “in all scenarios, New York’s statewide peak demand shifts from summer to winter and, if unmanaged, could increase substantially. Peak demands are expected to shift toward the early mornings of the coldest winter days, primarily due to increased EV charging needs in low temperatures plus electric heat pump adoption”. One of the promises of the future smart grid is that peak loads will be smoothed out so this is a problem.  The magical solution: EPRI claims there is a “key opportunity for New York’s electricity system stakeholders to develop and implement solution approaches such as cost-reflective time-of-use pricing, active load management of smart vehicle charging and other flexible loads such as space conditioning, behind-the-meter storage, and advanced cold-weather heating systems”.  Here is a news flash to EPRI – when residents are in the middle of a polar vortex cold snap that lasts several days, they will have to use whatever energy is needed to stay warm.  All of the solutions proposed will result in regressive costs hurting those who can afford it the least the most.


There are aspects of this report that have implications to CLCPA implementation that deserve more attention than I can include in this introductory post.  For example, the future scenarios specify values of the Social Cost of Carbon that increase over time.  I believe that is a necessary aspect for that kind of carbon pricing to work but this is the first instance where I have seen projections made for New York.  The problem I want to address is the fact that the Social Cost of Carbon is supposed to put a number on future damages from CO2 emitted today and the values they included exceed the published thresholds.  If the costs exceed the expected damages it doesn’t make sense. You wouldn’t spend more than a dollar to save a dollar.

As noted, these electrification scenarios do not “make policy recommendations or identify specific pathways to achieving the state’s greenhouse gas (GHG) targets”.  While this report has a vested interest in electrification, there also is a problem that they had to dance around or incur the wrath of the politicians that passed the CLCPA.  One of the findings noted “Flexible resources arising from a portfolio of advanced technologies and additional transmission will be critical to decarbonizing electricity generation.  As more renewables are added to the generation mix to meet New York’s clean energy goals, dispatchable technologies will be needed to maintain reliability and balance variable generation, especially after 2030”.  The most appropriate dispatchable technology (natural gas fired turbines) is a Voldemort technology which must not be named because it is evil.  Problem is when the wind is calm at night the only alternative to keep the lights on is energy storage which is horrifically expensive.  EPRI, NYPA, and Con Ed know this but could not say it, hence the obfuscatory language.

The bottom line for any of these electrification scenarios is that intermittent energy, i.e., wind and solar, cannot fuel our society on its own.  The whole concept of the CLCPA net-zero energy future is flawed.   There is currently no alternative to fossil fuels for efficient cost-effective transport and the only near-zero-carbon fuel which can meet electrical generation needs is nuclear, which New York state policy is explicitly rejecting.

NYSERDA Toward a Clean Energy Future – A Strategic Outlook 2020-2023

Alicia Barton, President & CEO of the New York State Energy Research & Development Authority (NYSERDA) recently announced the release of NYSERDA’s 2020-2023 Strategic Outlook which is their overview of their plans for the next several years.  This is important because the plan to implement the aspirational Climate Leadership and Community Protection Act (CLCPA) is supposed to be developed in this timeframe and NYSERDA staff will undoubtedly play an important role in that effort.  This post provides an overview of this report and costs.  Subsequent posts will address NYSERDA’s missions in more detail.


On February 11, 2020 the following email was sent from NYSERDA.

Last year was a landmark year for climate action in New York. Governor Cuomo’s nation-leading Green New Deal and the signing of the New York State Climate Leadership and Community Protection Act (CLCPA) have put us at the forefront in lowering carbon emissions and advance a clean energy future with a just and equitable transition that is addressing the most pressing issue of our time – climate change.

Building on the momentum of our accomplishments, New York State is on the path to achieving a carbon free electricity system by 2040, an 85 percent reduction in greenhouse gas emissions by 2050, and ultimately a carbon-neutral economy, touching on all sectors including transportation, buildings and industrial production. With climate action featured prominently in Governor Cuomo’s annual State of the State and Executive Budget addresses this year, NYSERDA’s work to combat climate change, preserve the environment, and grow the green economy is more important than ever before.

I am therefore excited to share NYSERDA’s 2020-2023 Strategic Outlook, which presents our key objectives and strategic focus areas while placing them into the broader context of New York’s long-term energy policies and market landscape. The report highlights our increasing efforts to support New York’s energy transformation through decarbonization of transportation, energy affordability and equity, electrification of buildings, and building a resilient energy system in support of NYSERDA’s five mission outcomes:

            • Greenhouse Gas Emissions Reduction
            • Renewable Energy
            • Energy Efficiency
            • A Distributed and Resilient Energy System
            • Building a Clean Energy Economy.

I hope you will take the time to review the Strategic Outlook and understand we cannot be successful in accelerating action to meet the needs of a changing energy landscape without participation from stakeholders like you. Together we will seize the opportunity to make Governor Cuomo’s vision for a clean energy future a reality.

Message from President and CEO

The strategic outlook report includes an introductory message from the President.  According to this message the rationale for action on climate change “reached new heights during the September 2019 Climate Week, with the youth movement and climate strikes in New York City and across the nation driving home the urgency and importance of addressing one of the most pressing matters of our time.”  Color me unimpressed.  According to this children and activists are responsible for setting New York policy.  What could possibly go wrong?

Funding Commitments

At the top of my list of issues for this regulation is costs which, by the way, is not usually a concern of children and activists.  According to the document: “Several funding sources help NYSERDA advance the State’s clean energy goals and achieve the Authority’s mission. NYSERDA invests these funds in a fiscally responsible manner that maximizes benefits to New Yorkers, fills critical gaps, and addresses the needs of the market.”

Per the document there are four funding mechanisms.

Clean Energy Fund

Authorized by the Public Service Commission (PSC) and derived from an assessment on retail sales of electricity by State utilities — it is comprised of four portfolios: Market Development, Innovation and Research, NY-Sun, and NY Green Bank.

Clean Energy Standard

As authorized by the PSC, these funds are realized by NYSERDA through the sale of Tier 1 Renewable Energy Credits (RECs), Offshore Wind Renewable Energy Credits (ORECs), and Zero Emission Credits (ZECs) as well as receipt of Alternative Compliance Payments from New York’s Load Serving Entities (LSEs). Through PSC orders, LSEs are obligated to meet annual compliance obligations for RECs, ORECs and ZECs. As needed, utility financial backstop collections may be called upon to meet funding shortfalls.

Regional Greenhouse Gas Initiative (RGGI)

Derived from sale of carbon emission allowances as set forth in 6 NYCRR Part 242 and 21 NYCRR Part 507.  The amount of revenues available is dependent on the variable auction prices for the allowances. Per requirements in 21 NYCRR 507, RGGI funds are used to advance energy efficiency, renewable energy, and carbon abatement projects in New York State.

Other Funds

Includes sources provided by various sponsors used for specific purposes. Public funds are leveraged considerably with private sector funding through NYSERDA programs.

For the first time that I have been able to find, the State admits how much some of this might cost.  The NYSERDA Strategic Outlook Anticipated Commitments (April 1, 2020 – March 31, 2023) table states that the total 3-year investment level cost is $14,255,988,000.  Importantly, this is not the entire cost just the cost of the State’s programs to fill critical gaps and address the needs of the market.

The Clean Energy Fund is the largest source of funding.  It is “derived from an assessment on retail sales of electricity by State utilities” which means that the ratepayers are on the hook for the $4.75 billion annual costs.  If all that funding were new charges to the utility bills and my guesses how it should be apportioned, then the average cost per residential customer is on the order of $200 per month for electricity and $200 for gas.  The state should provide that number but note the utility companies have been forbidden to show those numbers in their bills.  Make no mistake however, increases in utility rate cases undoubtedly include these added costs.

Although NYSERDA claims that they invest these funds in a fiscally responsible manner that maximizes benefits to New Yorkers their results to date do not auger well for the cost to implement the CLCPA.  The State has started to do the scoping study to determine how to meet the emission reduction targets, but that won’t be available for three years.  In the meantime, I have evaluated the cost effectiveness of New York’s CO2 investments using the New York Clean Energy Dashboard and NYSERDA’s RGGI-Funded Programs Status Report – Semiannual Report through December 31, 2018.  As shown on the table of anticipated commitments I expect that the CO2 reduction benefit will only be 44,669,559 tons based on the results of those programs to date.  More importantly, there are few indications that these investments will be fiscally responsible because most investment programs described in the investment reports do not meet the social cost of carbon[1] cost effectiveness threshold.

One last item of note is that the priority initiative for energy storage is funded at just under $160 million.  In my table I did not claim any expected reduction in CO2 emissions because energy storage does not directly displace fossil fuel emissions.  On the other hand, energy storage is absolutely needed to backup renewable wind and solar when the wind does not blow at night. When someone claims that wind and solar costs are comparable to a new gas-fired power plant they ignore the added costs necessary to get power to your home whenever you need it.  That requires energy storage and those costs will be enormous.  In particular, for the period 2040 to 2050 I found the energy storage necessary to cover the wind and solar deficit when the wind was not blowing at night for the example period of January 3-4 2018 was a staggering $176.3 billion.

[1] The Social Cost of Carbon is supposed to represent the future cost impact to society of a ton of CO2 emitted today.  Therefore, it is entirely fair to use it as a metric to determine if the investments made from carbon pricing income are cost effectively reducing CO2.  I believe New York will base their carbon pricing on a $50 global social cost of carbon at a 3% discount rate so that is the cost benefit effectiveness threshold metric I use.