Climate Leadership & Community Protection Act Presentation to the New York Propane Gas Association October 2021

I gave a presentation titled “Climate Act – All Pain and No Gain” describing the New York Climate Leadership and Community Protection Act (Climate Act) to the New York Propane Gas Association Fall Conference on October 25, 2021.  This post summarizes the presentation because it gives a good overview of issues related to the Climate Act.

I have written extensively on implementation of the CLCPA because I believe the ambitions for a zero-emissions economy outstrip available technology such that it will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   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.

Background

According to their website the New York Propane Gas Association (NYPGA) is “a member-focused trade organization providing services that communicate, educate and promote the propane industry in New York”.  I led off the discussion of the Climate act with my overview presentation on the Climate Act. The second speaker, Richard Goldberg from Warm Thoughts Communications, described their plans to fight the Climate Act.   Finally, Assemblyman Phil Palmesano updated the group on the climate initiatives political situation in Albany.  I am only going to discuss my presentation in this post.

Presentation

Because the slides and annotated slides with references are available I will not go through every slide in the presentation.  Instead, I will highlight the points that I was trying to make and only include a few slides.  There were four main topics: an overview of the science, a summary of the Climate Act, a description why I think there is no gain from the Climate Act and an explanation why it is all pain.

For the science overview I used slides prepared by Dr. Judith Curry that she graciously allowed me to use.  One problem I had is that there is so much material that I could have presented it was difficult to pare down the content to fit the 30-minute time slot.  I only used the first three slides from Dr Curry’s presentation.  The first slide described the common perception of the climate crisis.  The second explained problems with the climate crisis narrative:

  • We’ve vastly oversimplified both the problem and its solutions
  • The complexity and uncertainty surrounding climate change is being kept away from the public and policy debates.
  • Rapid reductions in emissions are technologically and politically infeasible on a global scale

I also included her summary of the 97% climate science consensus and the disagreements about the current state of climate science:

  • How much of the recent warming has been caused by humans?
  • How much the planet will warm in the 21st century?
  • Whether warming is ‘dangerous’
  • And how we should respond to the warming to improve human well-being

My summary of the Climate Act used graphics from the New York agency publications.  I noted that the rationale for the Climate Act is that we need to do something to address the “the greatest threat facing life as we know it” but explained that I did not have time to demonstrate that this claim is an exaggeration, see this example of the material I would have used if I had time.  When I showed a list of the Climate Act targets, I explained that they were developed by motivated special interest authors and that the limits were set entirely to fit a political agenda with no thought of feasibility.

While I tried to avoid getting into the details of the greenhouse effect, I had to address a couple of points. I included a slide describing the greenhouse effect as background for the discussion of global warming potential (GWP) after a slide listing the six greenhouse gases covered by the Climate Act.  The GWP is used to intercompare the effects of different greenhouse gases.  It is a function of the gases’ ability to absorb radiation and their residence time in the atmosphere.  The Climate Act vilifies methane by using a 20-year GWP time scale whereas, everybody else uses a 100-year GWP time scale.  This triples the importance of methane in the accounting for all the gases.  However, if the Climate Act is really intended to address the potential for New York emissions to cause global warming this is inappropriate.  The actual effect of a greenhouse gas on global warming is a function not only of GWP but also observed atmospheric concentrations.  Because the concentration of methane is so low in the atmosphere, doubling the concentration will “change the outgoing forcing by less than one percent”.  In other words even if we control methane it will have not effect on global warming.

I included the following table that showed where the state currently stands relative to the 2030 goal of a 40% reduction of greenhouse gas emissions.  The data in the table were extracted from the advisory panel presentations and are a sum of all six greenhouse gases expressed in million metric tons of carbon dioxide equivalent – adjusted for the 20-year global warming potential.  In the most recent year of data (2018), emissions were only 8% less than 1990.  Getting an additional 32% by 2030 is an ambitious goal.  I also pointed out that Climate Act methane obsession increases residential, commercial, and waste sector emissions to nearly half the total in 2018.

My no gain for the Climate Act argument is that it will not have an effect on global warming. If the point is that we want to reduce global warming to reduce the effects we constantly hear about in the media, then perhaps it is time to re-think this approach.  I showed that if New York manages to eliminate all the 1990 emissions that we can only expect a reduction, or a “savings,” to global warming of approximately 0.0097°C by the year 2100.  Given that atmospheric temperature measurements only have a precision of 0.1°C that means we will never measure the change due to the Climate Act.  In addition, we will never perceive that reduction using the general rule of thumb for temperature change with elevation or latitude because the predicted temperature savings is equivalent to a vertical distance change of 39 inches or latitudinal distance change of 0.9 miles.  Most importantly emission increases elsewhere overwhelm any reductions New York can make.  For example, emissions from coal plants under construction and completed in China in 2019 will subsume the reductions of all of New York in less than two years. 

I also argued that there is a moral case for using fossil fuels that makes it very likely that fossil fuel will be the appropriate choice to provide reliable, affordable, and abundant electricity to the over 1.2 billion people in the world who don’t currently have it.  The following slides shows that even as CO2 emissions have gone up poverty has decreased, life expectancy has increased and population has increased.  Similar results for other parameters representing human well being show the same thing.

Why the Left Cancels Any Climate Questioning

My presentation went on to describe how the Climate Act implementation was set up and the current status.  I explained that the law established the Climate Action Council to develop a scoping plan to meet the targets.  It has 22 members and 14 members were appointed indirectly or directly by former Governor Cuomo.  Those members were chosen for political purposes rather than technical expertise.  Technical expertise was supposed to come from the advisory panels composed of people with expertise or direct involvement.  Unfortunately, direct involvement meant politically correct so technical expertise was short-changed.  The result was that the proposed strategies from the panels are more aspirational than practical.

I went on to explain that the strategy recommendations developed since last year have been turned into specific policies by the New York State Energy Research & Development Authority (NYSERDA) and its consultant by using an economy-wide energy model that quantifies emissions and costs. The results from the integration analysis are being incorporated into the draft scoping plan in October so that the scoping plan can be finalized by the Climate Action Council by the end of the year.  Next year the public and other stakeholders will get to comment on the scoping plan

In recent Climate Action Council meetings (October 1, 2021 and October 14, 2021), the initial results of the integration analysis were presented.  The analysis compares the model output for a reference case that estimates emissions and costs assuming no Climate Act policies with different scenarios that incorporate emission reduction strategies.  All of the analyses have common themes as shown in the following slide.  They will have major impacts to reliability, cost, and personal choice.  For the presentation I concentrated on the theme for “more rapid and widespread end-use electrification & efficiency” that translates into mandates for electrification of heating, cooking, and hot-water. 

Four scenarios are included in the integration analysis.  Scenario 1 incorporates recommendations by the Advisory Panels for potential reduction strategies that included ambitious actions but the emission reductions were only 34% by 2030 instead of the 40% target.  The remaining scenarios were designed to meet the 40% target at a minimum and include even more ambitious actions.  Scenario 2:  uses low carbon fuels (bioenergy and hydrogen) for combustion for difficult to electrify applications and for times of low renewable availability.  In order to placate the members of the Climate Action Council who believe that all forms of combustion are bad Scenario 3 reduces combustion as much as possible and accelerates electrification of buildings and transportation actions.  Scenario 4 was developed to respond to those on the Climate Action Council who think that more reductions faster are possible which pushes all the actions further.

At the October 1, 2021 Climate Action Council meeting new findings from the integration strategies were described.  The one I find most unsettling notes that meeting the targets will require: “unprecedented rate of adoption of novel and potentially disruptive technologies and measures”.  I explained that I did not know what a disruptive technology was so I had to look it up.  I found a reference that explained that disruptive technologies “significantly alter the way consumers, industries, or businesses operate” and a “disruptive technology is one that enters the mainstream and changes the way most people think or behave.”  However, that same reference notes that there are disadvantages: “New technology is typically untested and unrefined during its early stages and development can continue for years” and “innovations go through a period of problem-solving”.  The problem is that the Climate Act schedule precludes most testing and problem-solving for these technologies  For example, one of the low-carbon fuels proposed is green hydrogen produced by hydrolysis of water powered by wind and solar but the economic viability of this new technology is unclear.  Beyond the mere unproven mechanics of the process as a way to store intermittent wind and solar for later use, the logistics of deploying the technology as well as the environmental impacts have not been addressed.  The bottom line is that depending on disruptive technologies to meet the Climate Act goals is incredibly risky.

For this presentation I concentrated on the theme for “more rapid and widespread end-use electrification & efficiency” and specifically discussed the potential mandates for electrification of heating.  The silver bullet technology for home heating is the heat pump.  I explained that they are more efficient than combustion and they have the advantage that they can provide both cooling and heating.  I noted that they basically are refrigerators operated in reverse.  Instead of taking heat out of the refrigerator to cool it they take heat out of the environment to warm the house.  There are two types of heat pumps.  Ground-source heat pumps use energy in ground that does not vary as much but are more costly and more difficult to retrofit.  Air-source heat pumps are cheaper and can be retrofit more easily.  However, they use atmospheric energy so they require backup heating capability in New York because there is insufficient energy available outside when the temperatures go below zero deg. F.  I went back to the refrigerator analogy to make the point that refrigerators work well because they are insulated and well-sealed.  In order to work as well in a building, comparable insulation and building shell efficiencies are needed. Clearly that is unlikely in most homes.

I explained that the mitigation scenarios all have mandates for heat pump installations.  I extracted the heat pump strategies in the October 1, 2021 building sector descriptions for the following table.  The scenarios assume that all furnaces sold in 2035 will be heat pumps and include a transition of heat pump sales (77% to 80%) by 2029.  Note that this modeling does not propose how people will be coerced into those sales before the 2035 mandate.  The modeling also makes assumptions about the number of heat pumps in the system by 2035 and 2050.  Scenario 2 assumes 80% of the heat pumps installed are air source and Scenario 3 is a “lower share”.  Backup is mostly electric in Scenario 2 and is all electric in scenario 3.  It is interesting to note that only Scenario 3 admits that retirement before the end of useful life of fossil-fired furnaces is needed.  It is not clear how they would design a regulation to enforce that mandate.

I explained that there are three painful aspects of the Climate Act

  1. Strategies don’t work everywhere
  2. Strategies don’t work all the time
    1. In some cases that is just a nuisance
    2. In other cases, it could be dangerous
    3. Without significant revisions I think it could lead to catastrophe
  3. Real costs will be substantial and their purported benefits are unrealistic
    1. It is not possible to offset consumer costs with the benefits claimed

I gave three examples of Climate Act strategies that do not work everywhere.  One of the prominent buzz phrases in the advisory planning recommendations is “smart planning” which basically boils down to strategies that reduce energy use such that less generation is needed.  One prominent example is to combine residential, commercial, and retail in one location to reduce energy use.  For example, a smartly planned development could enable residents to walk to a grocery store rather than having to drive.  However, in order to work the population density has to be high enough to support the grocery store.  I don’t see how that strategy could work outside of New York City and its immediate suburbs.  A major strategy to reduce transportation emissions is to enhance public transit to enable people to reduce vehicle use but this also needs a minimum population density and is unlikely to ever be a viable alternative in rural areas.  Note that the Climate Action Council members who want to eliminate combustion sources would eliminate the use of wood burning for home heating.  I believe that would be a non-starter for many rural residents who use their wood lots to provide the energy for heating their homes.

I noted that there are three examples of Climate Act strategies that do not work all the time.  The second major strategy to reduce transportation emissions is to electrify vehicles.  I will admit that electric vehicles work well for limited applications but they have limitations relative to gas powered cars.  For example, I could use an electric vehicle for most of my local trips around Syracuse but I also use the car to visit family in Brooklyn.  I don’t think that is a viable option with an electric vehicle because I would have to stop en route to charge up the car and then compete with around a million other car owners to find a place to charge when in the city.  However, it is just a nuisance because I have the alternative of taking a train or flying down.

The Climate Act strategy to electrify home heating is more problematic.  While heat pumps have advantages, the inescapable fact is that air source heat pumps don’t work well in really cold weather when you need heat the most.  In my case, in order to ensure that I have sufficient heat when the temperature is below zero, I am going to have to have a backup radiant electric heat that is inconvenient and expensive.  When everyone in my neighborhood has been forced to install similar systems, we will have to hope that the local distribution system will be able to handle the extra load because trying to heat our houses with toasters is not energy efficient.  I also have to hope that my house service can handle the extra load at the time of critical need.  If I get this wrong, it is not only inconvenient but also dangerous.  I don’t think the odds of everyone getting this right are very high.

There is an even worse possibility.  The future electric system is going to depend on intermittent wind and solar energy to provide electricity.  If electric system planning gets this wrong the results could be catastrophic.  I have previously described this situation as the Ultimate Problem with the Climate Act.  In early 2020 a couple of analyses highlighted this issue as shown in the following slide.  In order to keep the lights on grid operators have to balance load and generation which is relatively easy when the majority of the generators can be dispatched to do the matching.  However, wind and solar are not dispatchable so it gets more complicated.  In their presentation to the Power Generation Advisory Panel on September 16, 2020,  E3 included a slide titled Electricity Supply – Firm Capacity that stated that: “The need for dispatchable resources is most pronounced during winter periods of high demand for electrified heating and transportation and lower wind and solar output”.  They noted that they had found multi-day periods with low wind and solar output as shown in the slide when the renewable resource energy was far less than the load needed.

In order to provide sufficient electrical energy to power the future grid when home heating and transportation loads are added to the electrical loads, we have to know the frequency, duration and intensity of the periods when there is low wind and solar output.  In February 2021, there was a disaster in Texas caused in part because the electrical system failed when it was needed most.  Energy problems were related to the fact that the Texas electricity market only pays for the power produced, nuclear and fossil generators were not sufficiently resilient to cold weather, and the cold weather was accompanied by light winds so wind resources were mostly useless.  In order to keep the grid operating they had rolling blackouts. 

Superstorm Sandy , often mentioned as a reason why we need to implement the Climate Act, killed 147 people and caused $70 billion in property damages.  The Texas energy debacle in February 2021 caused at least 151 deaths, property damage of $18 billion, and $50 billion for electricity over normal prices during the storm.  Note that because one aspect of smart planning is to increase the cost of electricity when load is highest, that prices will be highest when backup resistance heating is required so there will be similar increases in cost over normal prices.  If New York similarly mis-judges the availability of renewable resources similar impacts can be expected.   

There is an even more concerning issue.  If New York does its planning correctly the frequency, duration and intensity of low solar and wind output periods will be known and, assuming the disruptive technologies necessary do work as hoped, the electrical grid may be able to avoid a renewable resource reliability crisis.  However, those are predictable conditions.  What happens for a black swan event?  The projected amount of offshore wind resources in 2050 is 10% of the capacity and 20% of the energy.  What happens when a Category 4 hurricane hits the offshore wind farms?  That would have the potential to destroy a significant portion of New York’s electrical generating resources for years.  Maybe not at the same scale but an ice storm would also be problematic when everything is electrified.  Clearly anyone who claims that a wind and solar energy system is “resilient” is pushing the envelope for credibility.

The final painful aspect of the Climate Act is the cost.  The first summary of costs and benefits was presented at the October 14, 2021 Climate Action Council Meeting and I provided my first impression here.  Costs in Scenario 2 are estimated to be $340 billion and if we start spending that in 2025 that is over $13 billion per year.  They claim that the cost of inaction exceeds the cost of action by more than $80 billion.  The basis for that claim is that improvements in air quality, increased active transportation, and energy efficiency interventions provide health benefits ranging from $160 – 170 billion and that reduced GHG emissions avoid economic impacts of damages caused by climate change equaling approximately $260 billion.

Conclusion

I concluded with five takeaways:

      • We’ve vastly oversimplified both the problem and its solutions
      • Over-reliance on technological innovation is incredibly risky
      • Strategies proposed don’t work all the time and you need them the most when they don’t work
      • Texas energy debacle was caused in part by over-reliance on renewables and costs were equivalent to the costs of superstorm Sandy
      • The bottom line is that the solutions don’t add up

I think the presentation was well received.  It was encouraging to talk to like-minded individuals because this is a hot button topic that I have found best to avoid because the true believers cannot be persuaded that there are issues and uncertainties associated with the science.  It is troubling that I see the same slavish devotion to the premise that renewable energy solutions can replace the existing system if we only have the political will.  On the other hand, now that we have specific policy recommendations, I am convinced that a list of what will be required will awaken the majority of New Yorkers to what is coming at them.  Then we can explain the fact that the ambitions for a zero-emissions economy are not affordable and increase energy reliability risks too much with available technology.  It is appropriate to call time out and determine a better course of action than the Climate Act.

Climate Leadership & Community Protection Act: Yet Another Industrial Solar Issue

I am starting to see more New Yorkers becoming aware of the impacts of New York’s Climate Leadership and Community Protection Act (CLCPA).  In order to meet the target of a 100% carbon-free electricity system by 2040, an enormous amount of solar power will have to be built.  I recently heard from Dan Steward, an agronomist and environmental planner in western New York who raised the issue of another unintended consequence after finding this blog.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   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.

Steward’s Concern

In brief, Dan notes that most farmers rent a significant portion of land for their operations, especially dairy farmers who use it to grow forage for their herds.   Farmers have always competed for the use of land:  there is a saying that the farmer who can farm the land most profitably is the one who will end up with it.  This is economics 101.  Farmers are now competing with solar developers with vast direct and indirect subsidies, offering land owners up to ten times the current agricultural annual lease rates.   This raises the concern that farmers will not have enough available farmland to support the investment they have made in facilities, livestock, or equipment.   At a minimum, it will raise the cost of land for New York farmers, making it harder to compete on the increasingly global food markets.

Dan explained that in the last year they have reviewed and commented on Notices of Intent for at least a half dozen industrial solar developments that convert farmland in agricultural districts in New York’s Chautauqua County.  He notes that although there are “guidelines” for developers to site solar on poorer, under-utilized soils, many of the project plans they have reviewed are planned for prime soils. 

He doesn’t think most farmers understand what is heading their way. He said: “New York State Ag and Markets, who does know, is doing very little to speak out against this travesty. This is just another unintended consequence of this ill-advised policy put forward by our “leaders.”

In the past large utility-scale solar projects would have gone through an extensive permitting process that includes a requirement to inform everyone who could be impacted by the project about the plan.  However in order to “ensure that renewable generation is sited in a timely and cost-effective manner” the state passed the Accelerated Renewable Energy Growth and Community Benefit Act (AREGCBA).  The AREGCBA has guidelines to site solar away from prime farmlands but, given the volume of applications, I doubt that permitting staff at the agencies has time to review applications to ensure that this guideline is applied.  Moreover, because the permitting requirements for notifications are so much less stringent so it is very possible that a developer could get an application approved before impacted farmers could object to the loss of the prime farmland they need to operate.

It gets worse.  Another guideline concerns decommissioning.  Developers are supposed to set-aside enough money so that when the solar development is decommissioned the land can be returned to its previous condition.  That challenge is markedly easier if the land is poorer quality or under-utilized but if the land used was prime farmland, it is much more difficult. 

There are a couple of concerns.  Given the state’s aggressive implementation policy and lack of stakeholder input in the permitting process, there is a good chance that insufficient funds will be set-aside for reclamation.  Dan is concerned about a situation where the developer declares bankruptcy without having a legitimate bond and then the landowner will let the property go back on taxes to the county without ever having decommissioned or restored the land.  He explained that:

When the question about who is responsible for decommissioning is posed at meetings or addressed in informational literature, it is stated that a land-owner should consult an attorney to protect themselves. However, in the situation I just described, it is the local taxpayers, neighbors and the county that will ultimately be left in possession of what is now basically a brownfield.

We the public have the risk, not the landowner. The landowner will have collected, according to reports, around $1,000 per acre annually. He has more than recouped the value of the land and has no incentive to engage in a costly clean up. I understand that bonding is supposed to play a role in these projects. I admit that I am not familiar with different forms of bonding and how they work. However…

This must be a common concern with these projects, but I have never heard it addressed definitively. Why does everyone need to get a lawyer to get an answer?

If you are interested in more information, Dan also passed on a video of the September 15, 2021 meeting of the Planning and Economic Development Committee of the Chautauqua County Legislature where these topics were discussed.

Cornell Analysis

In a similar vein, Max Zhang, professor in the Sibley School of Mechanical and Aerospace Engineering at Cornell recently published “Strategic Land Use Analysis for Solar Energy Development in New York State“. Unfortunately it is paywalled, but there is a summary of the article in Science Daily, Roadmap to expand NY solar energy, meet green goals. The study notes that:

So far, 40% of current solar energy capacity has been developed on agricultural land, the researchers found, while 84% of land identified as suitable for future solar development — about 140 gigawatts — is agricultural.

“Solar farms are already taking up agricultural land and it will likely take even more to achieve New York’s energy goals,” Zhang said. “For the solar-energy community, this is not a surprise. But for the agricultural community, this is a surprise.”

All this is consistent with Steward’s concerns.  Zhang’s analysis estimated the amount of solar needed for the CLCPA targets.

Under New York state’s 2019 Climate Leadership and Community Protection Act, the state must reach 70% renewable energy generation by 2030 — and 100% by 2040. Assuming no further offshore wind energy development beyond the current 9-gigawatt goal, the state will need 21.6 gigawatts of utility-scale solar energy capacity to reach that target.

However, Zhang did not have the results of the latest estimates of solar deployment.  On October 14, 2021 integration analyses were presented to the Climate Action Council that include the resources necessary to meet the CLCPA targets.  Scenario 2, “strategic use of fossil fuels”, projects that 64.6 GW of solar will need to be deployed.  That total includes both utility-scale facility and roof-top solar.  Assuming half is utility-scale solar that means we can expect 32.3 GW of industrial solar installations.  I have reviewed Article Ten solar facility applications and 11 included both the proposed capacity (MW) and area expected to be covered with equipment.  The average was 9.3 acres per MW so that means in order to meet the CLCPA targets 300,300 acres or 469 square miles of land will need to be covered with 32.3 GW of solar panels by 2050.

Zhang has a couple of suggestions to reduce negative impacts.  He suggests that “Keeping solar farms from becoming too concentrated in regions will likely help mitigate negative economic activity”. Overly concentrated development leads to agricultural land conversion which initiates “a negative, economic chain reaction for businesses that depend on farming”.  In an interview on his paper Zhang notes that  one strategy would be to use low quality land or consider dual-use (agrivoltaics) options.  He does note that there is an economic reason to use the higher quality land because it is flat and has already been cleared.

For the most part I agree with his analysis and statements.  However, I have to disagree with his interview statement that “solar PV is generally a benign technology.  In order to get the solar power to your home energy storage is required.  Processing to obtain the rare earth metals needed for solar and energy storage is anything but a benign impact.  In addition, the installation of the massive number of panels creates massive areas of impermeable surface which will increase stormwater runoff.  If not handled correctly serious problems will occur.

Past Experience

In no small part the reason for Dan’s cynicism is his past experience with other state renewable energy programs.  He cites the problematic wind turbines installed on the Thruway. Several years after installation they weren’t working and the State ended up suing the developer.  I could not find any reference to a resolution of the problem. 

Another example is the NYSERDA Solar Thermal Incentive Program.  Dan explains that:

Contractors were paid to install solar thermal panels on barn roofs. Most farmers paid nothing for them. However, there was no incentive to make them work. All of the farms I have talked to, including my brothers, that had them installed through this program have told me they never worked! The contractors took their money and got out of Dodge. Eventually they will need to be taken down at the farmer’s expense. Some may now have some equipment that has some value for other uses, but in most cases, little to no renewable energy hot water was produced. Stop in and ask a farm or two.

Western New York barn with thermal solar courtesy Dan Steward

Dan also mentions another renewable energy project that I remember from my days at Niagara Mohawk.  The idea was to plant stands of willows as a pilot project for renewable energy on agricultural land.  The plan was to burn the willow at the Dunkirk coal-fired power plant but when somebody did the math it turns out that the plant could have burned all the willow planted in such a short time that they could not justify getting the system setup to use the wood.  As a result, it was never harvested and it is not hard to find hundreds of acres of willow in Chautauqua and Cattaraugus County if you know where to look.  Of course, even if it had worked the plant is closed now so failure to use the resource was only a matter of time.

Conclusion When the people affected by the massive amounts of renewable energy development get a chance to make their concerns known, it turns out that there are legitimate concerns that should be addressed.  Unfortunately, the New York renewable energy siting process no longer mandates that their concerns should be heard even from peer-reviewed work such as Zhang’s.  As a result, I expect many unintended consequences to arise unless changes are made. Given that the history of previous renewable energy projects in New York does not have a particularly good record of success it is easy to presume that this will be the case this time too.

CLCPA Environmental Hypocrisy – Offshore Wind Cable Water Quality Impacts

This post discusses an example of New York’s Climate Leadership and Community Protection Act (CLCPA) environmental hypocrisy.  I describe an instance where infrastructure support projects will have a far greater environmental impact than similar but smaller impacts that were grounds for permit denials for fossil fuel infrastructure applications.  This example discusses underwater cables and pipelines.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   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.

New York Regulatory Decision for a Pipeline

On May 15, 2020 the New York Department of Environmental Conservation (DEC) announced the denial of the Water Quality Certification (WQC) the proposed North Easy Supply Enhancement (NESE) Project.

This project included a 26-inch diameter pipeline proposed by Transcontinental Gas Pipe Line Company LLC (Transco) that would transport natural gas from Pennsylvania through New Jersey, traveling underwater in the Raritan Bay and Lower New York Bay to approximately three miles offshore of the Rockaway Peninsula in Queens Borough. Approximately 23.5 miles of underwater pipeline will be installed, of which approximately 17.4 miles would be in New York State waters.

The DEC denial letter states that the application was denied, in part, because of:

Transco’s inability to demonstrate the Project’s compliance with all applicable water quality standards. To obtain a WQC from the Department, an applicant must, among other requirements, demonstrate compliance with State water quality standards. See 6 NYCRR § 608.9. Transco has not demonstrated that construction and operation of the Project would comply with applicable water quality standards. Because the Department lacks reasonable assurances that the Project would comply with applicable water quality standards, particularly without the use of a default 500-foot mixing zone for mercury and copper, the Department hereby denies the 2019 WQC Application.

The letter goes on to say:

Transco’s projections in the 2019 WQC Application are based on the presumed use of a default 500-foot mixing zone. But as the Department noted in its 2019 Denial, the Department maintains discretion to assign a smaller mixing zone or no mixing zone, based on its assessment of relevant factors including the nature of sediment contamination, the proximity of sensitive habitats, and other qualitative assessments. The Department has considered the Project in light of these criteria and has determined that the default 500-foot mixing zone is not appropriate at all locations proposed to be crossed by the Project. Without the use of a default mixing zone at all locations, the Project would not comply with all applicable water quality standards, and therefore, the Department is denying the 2019 WQC Application.

The DEC description of the permit denial states that:

Based on NYSDEC’s review of the May 17, 2019 WQC application for the NESE Project, including all supplemental materials, review of the over 16,000 public comments received, and review of the FEIS and other record materials associated with the NESE Project, NYSDEC has determined that the construction of the Project would likely have significant water quality impacts in New York State. This includes significant water quality impacts from the resuspension of sediments and other contaminants, including mercury and copper, particularly without the use of the discretionary default mixing zone in certain areas. The Project would cause impacts to habitats due to the disturbance of shellfish beds and other benthic resources. The water quality impacts would be especially problematic within the productive hard clam area located between milepost (MP) 14.2 to MP 19.7.

CLCPA Offshore Wind

At the October 14, 2021 CLCPA Climate Action Council  meeting Carl Mas from the New York State Energy Research & Development Authority (NYSERDA) presented results from the integration analysis.  At this time, he explained that an estimated 16,000 to 19,000 MW of offshore wind development will be required to meet the CLCPA targets.  One of the first offshore wind projects recently announced that they are pushing back the completion date for their 816 MW project to the end of 2026.  According to the article, “While Empire Wind does not plan to have its project generate power for the grid by the on meeting the 2025 deadline, the developer said it is prepared to make ‘substantial investments’ by that date in order to ease potential concerns on part of New York Independent System Operator. Among the investments, Empire Wind will build a substation at Gowanus, lay 40 nautical miles of submarine and underground interconnection cable circuits, and install an offshore collector substation in the New York Bight project site.”

Project Comparison

The NESE project proposed a 26-inch diameter pipeline traveling underwater in the Raritan Bay and Lower New York Bay to approximately three miles offshore of the Rockaway Peninsula in Queens Borough. Approximately 23.5 miles of underwater pipeline was planned and it was all outside of the inner New York Harbor.  The Empire wind project includes a 40 nautical mile underground cable from somewhere out in the New York Bight that will cross the location of the proposed NESE pipeline as it runs through the inner New York Harbor to Gowanus in Brooklyn.  Assuming that all the offshore wind projects will be about the same size indicates that at least 20 offshore wind projects with comparable underground cables will be required.

The New York Power Grid study identifies the transmission upgrades necessary to support the CLCPA targets.  It concludes that interconnecting 5,000 to 6,000 MW of offshore wind into New York City electric Zone J “should be feasible with sufficient planning and coordination to efficiently use scarce cable routing corridors through the New York Harbor and limited space at the points of interconnection substations. In addition to the planned cables, it would require siting four 1,300 MW cables and securing landing points in Zone J.”  Note, however, that this study analyzed the resources needed for 9,000 MW of offshore wind, far less than 16,000 to 19,000 MW the integration analysis indicates is necessary.

Based on this project comparison it appears to me that four transmission cables each 40 nautical miles long are needed just for 6,000 MW of offshore wind power into the New York City points of interconnection substations.  That is over seven times as much seafloor disturbance as the NESE pipeline that was rejected because of water quality concerns.  All four cables will have to cross the proposed location of the pipeline but rather than staying outside of New York Harbor they will all be located within the harbor.  The remainder of the offshore wind energy will land on Long Island but they will all have similar impacts.

Conclusion

Any rational comparison of the scope and impact of the underwater cables needed for the proposed offshore wind developments necessary to meet the CLCPA targets and the NESE pipeline must conclude that the offshore wind cable water quality impacts will far exceed those of the pipeline.  Obviously, the pipeline denial was a blatant politically motivated action to cater to the environmental activist community who demand the end of fossil fuel infrastructure without having any appreciation of importance of reliable energy.  The Cuomo administration made the calculated decision to appease this voting bloc rather than make an unpopular decision to guarantee reliable energy.  Of course, the politicians in charge now will deny any responsibility if the gas pipeline supply issues do cause energy reliability problems.

I don’t think New York politicians have figured out that it is impossible to always appease environmental activists.  For example, the NESE pipeline explicitly noted that “The water quality impacts would be especially problematic within the productive hard clam area located between milepost (MP) 14.2 to MP 19.7.”  I cannot imagine that everyone who raised that issue would give the offshore wind cables a pass to site the underground cables in the same locations.  However, given the expedited review process of renewable energy projects under the Accelerated Renewable Energy Growth and Community Benefit Act those folks may not be aware of the permitting application in time to comment.  Furthermore, the organizations that motivated their members to comment on the pipeline have such a focus against fossil fuels that I believe that they would willingly not notify their members of the underground cable water quality impacts because it is for a “good” cause.

Climate Leadership & Community Protection Act Integration Analysis: New Findings

At the October 1, 2021 meeting of New York’s Climate Leadership and Community Protection Act (CLCPA) Climate Action Council  Carl Mas from the New York State Energy Research & Development Authority (NYSERDA) described findings from the integration analysis.  These findings underscore the difficulties faced to meet the CLCPA targets.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   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.

Background

The Climate Action Council is responsible for submitting the Scoping Plan that will outline a plan to implement strategies to meet the ambitious targets of the CLCPA.  Of particular interest are the targets to reduce greenhouse gas emissions by 40% relative to the 1990 baseline and supply 70% or the electrical energy come from renewable resources by 2030 and by 2040 provide all electricity from zero-emissions sources.  Meeting these targets will require a transition of the entire New York energy system.

Last spring advisory panels submitted their recommendations to the Climate Action Council for strategies in seven sectors to meet the targets.  The Council and the advisory panels are composed of political appointees chosen more for their advocacy and politics than their expertise in the energy sector.  In order to address the lack of expertise and assemble a comprehensive strategy New York State Energy Research and Development Authority (NYSERDA) and their consultants are providing technical support by developing an integration analysis.

The integration analysis has developed a reference case and four scenarios that include specific strategies, emission estimates, and costs for Climate Action Council comment and discussion:

      • Reference Case
        • Currently implemented policies
      • Scenario 1: Advisory Panel Recommendations
        • Aggregate impacts of recommendations from Advisory Panels
        • Scenarios that meet or exceed GHG emission limits, achieve carbon neutrality by midcentury
      • Scenario 2: Strategic Use of Low-Carbon Fuels
        • Includes the use of bioenergy derived from biogenic waste, agriculture & forest residues, and limited purpose grown biomass, as well as green hydrogen, for difficult to electrify applications
      • Scenario 3: Accelerated Transition Away from Combustion
        • Low-to-no bioenergy and hydrogen combustion; Accelerated electrification of buildings and transportation
      • Scenario 4: Beyond 85% Reduction
        • Accelerated electrification limited low-carbon fuels; Additional VMT reductions; Additional innovation in methane abatement; Avoids direct air capture of CO2

According to the presentation in order to meet the targets, there are foundational themes across the scenarios based on findings from Advisory Panels and supporting analysis:

      • Zero emission power sector by 2040
      • Enhancement and expansion of transit & vehicle miles traveled reduction
      • More rapid and widespread end-use electrification & efficiency
      • Higher methane mitigation in agriculture and waste
      • End-use electric load flexibility reflective of high customer engagement and advanced techs

The schedule for the remainder of the year is ambitious.  The integration analysis will be incorporated into the draft scoping plan by the end of October and in November the Climate Action Council will discuss the strategies and provide feedback on the draft scoping plan.  The plan is to finalize scoping plan by the end of the year and next year put it out for public comment.

New Findings

I extracted the bullet points describing the new findings of the integration analysis from the October 1, 2021 Climate Action Council meeting presentation.  My reaction to these findings is shown in italics below.

  • Achievement of emissions reductions to meet state law requires action in all sectors, especially considering New York State’s novel emissions accounting

Novel emissions reporting refers to the emphasis on greenhouse gases other than CO2, particularly, methane and nitrous oxides.  Novel is another way of saying no other jurisdiction in the world has prepared an inventory of emissions with such an overt and flawed emphasis on natural gas.

      • Every sector will see high levels of transformation over the next decade and beyond, requiring critical investments in New York’s economy
  • Energy efficiency and end-use electrification will be essential parts of any Pathway that hits NYS Emissions Limits
      • In all scenarios modeled, zero emission vehicles and heat pumps become the majority of new purchases by the late 2020s, and fossil-emitting cars and appliances are no longer sold after 2035
      • 1 -2 million efficient homes electrified with heat pumps by 2030
          • In 2017 there were 7,302,710 occupied housing units in NYS
          • 2% or 820,554 used electricity for space heating
          • The fraction of heat pumps used is unknown but has to be small
          • To reach 1.5 million heat pump homes requires about 200,000 conversions per year
      • Approximately 3 million zero-emission vehicles (predominantly battery electric) by 2030
          • 1 million vehicle registrations on file in 2018 so 2030 is 27% EV
          • On 9/2/2021 there were 81,858 ZEVs on the road in NY, 0.9%
          • Over the last 12 months 2.15% of the new vehicles registered were electric vehicles and the greatest month was 4.36%
  • Unprecedented rate of adoption of novel and potentially disruptive technologies and measures

Disruptive technologies “significantly alter the way consumers, industries, or businesses operate”.  “To be considered disruptive, technology must be easily accessed by a majority of the population. Revolutionary inventions are often not disruptive because they’re too expensive for the common consumer. In many cases, it’s not until the technology is refined enough to become affordable that it’s considered disruptive to the market. A disruptive technology is one that enters the mainstream and changes the way most people think or behave.

Disadvantages of disruptive technologies:

          • “New technology is typically untested and unrefined during its early stages and development can continue for years.”
          • “Nearly all innovations go through a period of problem-solving.”
          • “It can take time for a disruptive technology to find its place in the marketplace.”

It is incredibly risky to be counting on novel and disruptive technologies to meet the CLCPA targets.

  • Consumer decision-making plays a large role, especially important for the purchase of new passenger vehicles and heating systems for homes and businesses through the next decade

The climate act implementation echo chamber has not addressed what will happen when there is an extended outage following an ice storm.  Many folks have a contingency plan for that kind of an event but see no reasonable alternatives when everything is electrified.

  • Substantially reduce vehicle miles traveled while increasing transportation access
    • Expansion of transit service structured around community needs
    • Smart growth inclusive of equitable transit-oriented development
    • Transportation demand management

I do not believe that the majority of New Yorkers are aware that the CLCPA will mandate these limitations on personal mobility.  The climate act implementation echo chamber has not explained how this will not have massive impacts to rural areas and the rural poor.

  • Wind, water, and sunlight power the majority of New York’s economy in 2050 in all Pathways
    • Even with aggressively managed load, electric consumption doubles and peak nearly doubles by 2050, and NYS becomes a winter peaking system by 2035.

Although the presentation mentions that the reliability standards are included in the scenarios it is not clear to me that is the case because there is so little documentation available.  Furthermore, I think it is likely that there will be new reliability rules that certainly have not been included.

  • Offshore wind on the order of 20 GW, solar on the order of 60 GW, and 4-and 8-hour battery storage on the order of 20 GW by 2050

These are extraordinary numbers.  The largest integrated solar-powered battery will be at the Florida Power & Light Manatee Solar Energy Center rated at 409 MW, 900 MWh.  Note that the energy storage facility only provides two hours of storage so over 100 equivalent facilities will have to be built.

  • Firm, zero-emission resources, such as green hydrogen or long-duration storage, will play an important role to ensure a reliable electricity system beyond 2040

Long-duration storage does not exist today and green hydrogen has not been deployed at utility scale.  Moreover, as the hydrogen is produced it will have to be stored and transported to where it will be used which is no easy feat.

  • Low-carbon fuels such as bioenergy or hydrogen may play a critical role in helping to decarbonize sectors that are challenging to electrify
    • By 2030, initial market adoption of green hydrogen in the following applications: medium and heavy-duty vehicles, high-temperature industrial (sic).

For a technology not yet commercially available expecting any significant market adoption in this time frame is a stretch.

  • Additional promising end-use applications include district heating and non-road transportation such as aviation and rail.

In theory these fuels might work for these applications but the technology has not been proven.

  • Required transition to low-GWP refrigerants and enhanced refrigerant management by 2050

If these refrigerants and enhanced management were cost-effective,then they would be used now.

  • Large-scale carbon sequestration opportunities include lands and forests and negative emissions technologies
    • Protecting and growing New York’s forests is required for carbon neutrality

I get the impression but have not confirmed that one of the control strategies is to convert home heating with wood to electric.  The concept that people do that because they cannot afford alternatives and the probable increase in costs associated with this law suggests that more rather than less people will want to heat with wood.  It is not clear to me how the State would regulate a land owner’s use of wood for home heating.

  • Negative emissions technologies (e.g., direct air capture of CO2) may be required if the State cannot exceed 85% direct emissions reductions

This is an absurd statement because it presumes that the New York contribution to the total greenhouse gas levels in the atmosphere can be measured to the point where direct air capture could have an effect.  

  • Strategic land-use planning will be essential to balance needs
  • Necessary methane emissions mitigation in waste and agriculture will require transformative solutions
    • Diversion of organic waste, capture of fugitive methane emissions are key in waste sector

Easy to say but extremely difficult to implement in practice.

  • Alternative manure management and animal feeding practices are key in agriculture

If these practices were cost-effective farmers would be doing them today.  Apparently they are not using them so who pays for farmers to use them?

 Additional innovation will be required in areas such as carbon sequestration solutions, long-duration storage, flexible electric loads, low-GWP refrigerants, and animal feeding, in concert with Federal action (e.g. Earthshots)

Requiring “additional innovation” to ensure that the lights are on, homes are kept warm and people will be able to charge their mandated electric vehicles is extraordinarily risky.  If the risks associated with the effects of climate change that could be changed by New York emissions were compared to the risks of this policy causing a blackout, then I have no doubts that the integration analysis strategies would be rejected out of hand.

 For what it is worth, the Earthshot example refers to the Department of Energy’s “Energy Earthshots” that will “accelerate breakthroughs of more abundant, affordable, and reliable clean energy solutions within the decade”.  Even if they accomplish a breakthrough the CLCPA schedule is too aggressive to take advantage of it.

  • Largest three remaining sources of emissions in 2050: Landfills, aviation, and animal feeding

No comment.

Conclusion

Of particular concern is that the integration analysis acknowledges that disruptive technologies will be required to meet the CLCPA targets.  I explain that these technologies are typically untested and unrefined during early stages and development can continue for years.  These innovations go through a period of problem-solving.  Given that the electric system has a long history of revisions following blackouts to address reliability problems as they arose it is unrealistic to expect that similar problems will not arise in the future. 

In order to meet the CLCPA legal schedule there has been insufficient time to prepare the documentation necessary for stakeholders to evaluate the proposed strategies.  However, given the absolute need to try to avoid catastrophic problems the integration analysis scenarios have to be fully documented.  Climate Action Council meetings have included multiple member statements arguing that the law requires some of the more unrealistic proposals incorporated into the strategies.  The ultimate question for the Climate Act is what happens when stakeholders expose the reliability risks of those strategies.  Will the Hochul administration cave to the special interests or listen to those responsible for keeping the lights on.

CLCPA “Winging It” is a Catastrophe Waiting to Happen

At the September 13, 2021 meeting of New York’s Climate Leadership and Community Protection Act (CLCPA) Climate Action Council a requirement to consider carbon reduction measures in other jurisdictions was discussed.  I agree that this is an important consideration and recently wrote that the European experience reflects not only high energy costs but there are troubling signs that reliability issues can occur even during periods when the electric system is not stressed due to high demand.  This post calls reader’s attention to Minister of Parliament Steve Baker’s recent article on the United Kingdom’s similar plans to reach net zero emissions.   

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   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.

Background

Steve Baker is a Conservative MP and former Brexit Minister. He is a trustee of the Global Warming Policy Foundation (GWPF).  I wanted to include a description of the GWPF in this section but recent changes have made that difficult.  If you do an internet search for the GWPF, you will get a string of results all branding them as the “United Kingdom’s most high profile climate denier group” but won’t be able to find their own link without searching.   If you get to gwpf.com then you are redirected to Net Zero Watch.  GWPF has set up Net Zero Watch to “provide serious analysis of naïve and un-costed decarbonisation policies.”  They plan to “highlight the serious economic, societal and geopolitical impacts of poorly-considered policies, both domestically and internationally”.

Net Zero Watch has been setup to “highlight and discuss the serious implications of expensive and poorly considered climate change policies”.  A recent energy crisis in Europe foreshadows New York’s future under the CLCPA:

With our domestic shale gas resources sitting untapped under an absurd government ban, gas prices are going through the roof. Net Zero Watch will challenge the wild claims of green activists and policy advisers about this venerable and benign technology, which has brought US gas prices down to a small fraction of those here.  As this year’s weather has shown, our decision to phase out fossil fuels and nuclear power and to rely more and more on wind farms for our electricity supply has had dangerous consequences. We will campaign to put affordability and security of supply back at the centre of the energy debate, and we will expose the risky wishful thinking behind many claims about energy storage.

Baker’s description of the United Kingdom net-zero plan is entirely consistent with my impression of the CLCPA.  The following section quotes Steve Baker’s commentary in italics with my indented and unitalicized comments.  I don’t have many comments because one only has to substitute New York for UK and Albany for Westminster for the most part.

“Winging It” is a Catastrophe Waiting to Happen

The UK’s plans to decarbonise the economy are a classic example of the ancient political strategy of “winging it”. Hard though it is to credit that idea, it’s true; the “experts” in Westminster have been basing your future and mine on a plan that relies, to a very great extent, on a collective crossing of the fingers.

 The CLCPA experts in Albany rely on bureaucrats at the state agencies that have to tailor their results to meet the political agendas of their appointed directors to sustain their careers.

Governments of one shade or another, Whitehall bureaucrats, and their advisers in the Climate Change Committee have been working on such plans for well over a decade now, and it’s fair to say that they still have little or no idea how Net Zero can be achieved, beyond a vague idea that we should electrify everything and have lots of energy from windfarms.

 The description of the scenarios to meet the CLCPA targets at the October 1, 2021 meeting of the Climate Action Council is entirely consistent with this description.

 That’s no more than a starting point, of course. There are enormous practical difficulties (and eye-watering costs) to be dealt with, but such nitty-gritty issues seem of little interest to the experts in Westminster. “Things will become cheaper…” they say “….we’ll invent something”.

 Expert handwaving of this kind has been enough to convince the media and most politicians, but as the legendary physicist Richard Feynman once pointed out, Nature cannot be fooled, and it looks very much as Nature is going to lay her cards on the table this winter.

 One of the key problems is that we don’t have any way to store electricity on a large scale for when the wind isn’t blowing. That can be a few weeks in a normal year, or months in a bad one. The problem has always been there, and we have had no firm answer from the “experts”. We don’t have enough suitable sites for pumped hydro; batteries and hydrogen are far too expensive. As was pointed out in a letter to one of the national newspapers last week, enough batteries to see us through a wind lull lasting just ten days would cost £150,000 per household at current prices.

 There is no reason to believe that New York’s costs to maintain current reliability standards will differ much from the £150,000 per household or $204,000 per household.

 The Climate Change Committee says that we can get electricity through interconnectors from other countries when the wind doesn’t blow here. This is something of a “magic solution” for them, because they can simply claim that we’ll build as much interconnector capacity as we need. However, it again ignores the practical difficulties, such as the fact that if the wind isn’t blowing here, it probably isn’t blowing in most of western Europe either, so assuming (as the “experts” in Westminster do) that everyone follows us down the decarbonisation path, we are all going to get in a bidding war for the few megawatts of power that are left. There is also a national security problem with interconnectors, as was recently brought sharply into focus by French threats to cut the UK off if we didn’t play ball over fishing rights.

 To this point, the CLCPA scenarios avoid the use of imported power and, for the most part, we don’t have to worry about international security issues.  Note, however, that a key component for New York City is a transmission interconnection for hydropower  from Quebec.

 The CCC also says we can get a bit of power from gas-fired power stations equipped with carbon capture and storage (CCS). However, the practical problems are again fairly stark; nobody has yet made a success of CCS – a series of pilot projects have tested the waters on the easier ground of coal-fired power stations, and each has been closed as an economic failure; the power they produce is simply too expensive. And nobody has yet got the technology to work at all for gas-fired power stations.

 New York’s plans include CCS for concrete manufacturing but so far have downplayed its use for power generation.  All of the concerns listed are relevant and don’t note that a suitable location for sequestration is needed.  Incredibly there are members of the Climate Action Council that want to prohibit all forms of combustion which would preclude the use of CCS altogether.

 The other problem with planning for gas and CCS to deliver us from the perils of intermittency is that it appears unlikely we are going to have any cheap gas to feed them with – successive governments, egged on by the CCC, the renewables industry, and the green movement have told us we must “keep fossil fuels in the ground”.

 This was seen in part as a way to encourage the second part of the decarbonisation strategy, namely for people to “invent something”. In other words, if we have no gas and no way to balance the grid, well, someone will come up with some way to fix the problem. So we first made the electricity grid unwelcoming for gas-fired power stations, then we neutered the nascent shale gas industry with absurd regulations, and then we banned it completely.

 This is entirely consistent with New York’s CLCPA implementation.

 Which brings us to where we are today, with the whole country crossing its fingers and praying that someone will “invent something”, or at least find us a way to make it through the winter without the lights going out.

 For twenty years, the vested interests have had their say, and public relations have taken precedence over engineering and economics. But, to return to Professor Feynman, Mother Nature really cannot be fooled, and when she reveals her hand, the results are likely to be horrible.

 Is catastrophe coming? I fear so, unless ministers get a grip and liberate the private sector to go for gas, right now.

 New York’s problems are not so imminent largely because Pennsylvania went ahead with the natural gas fracking and now has an abundance of natural gas to sell to New York.  Nonetheless, National Grid has warned its customers in Central New York that natural gas bills could go up 31% because of increased demand and a global spike in prices.  I cannot help but wonder if New York had developed its natural gas resources if we would be seeing a similar price increase.

 Conclusion

The slow motion train wreck that is the future of New York energy under the CLCPA will only continue to a similar crisis unless it is repealed for all of the reasons shown in MP Steve Baker’s commentary.  To date “vested interests have had their say, and public relations have taken precedence over engineering and economics” but at some point, reality has to be addressed.  The fact is that today’s wind, solar and energy storage technology is not up to the role conceived by the authors of the CLCPA.

Reliability Goal of a Renewable-Dependent Electricity System

In early September 2021 I wrote an article, “Reliability Challenges in Meeting New York’s Climate Act Requirements”, that described a presentation made by the New York State Reliability Council (NYSRC) to the New York Climate Action Council.  In this post I describe a recent paper that analyzes synoptic-scale extreme reductions in wind and solar power energy resources that I think raises an important reliability question: when New York relies on fragile intermittent wind and solar energy resources is the current New York reliability goal to prevent a loss of load event due to resource adequacy of no more than once per ten years still appropriate.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   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.

Background

In my reliability challenge article, I explained that there is consensus that the future worst-case situation in New York will be a multi-day winter time wind lull when both wind and solar availabilities are low.  Coupled with increased electricity load in order to reduce emissions from transportation and heating, any analysis of future renewable energy resources that adequately addresses the worst-case renewable energy resource availability shows the required amounts of wind, solar and energy storage will have to be enormous.  Importantly, the NYSRC analysis indicates that in order to ensure reliability the installed reserve margin will have to be increase substantially above current levels to satisfy anticipated load and the intermittent nature of wind and solar resources.  The NYSRC presentation concludes that the state of New York appears to be headed down a transition path which will require reliance on technologies that do not currently exist in less than ten years.

Wind and Solar Droughts

Dr. Patrick Brown’s blog post describes his recent paper co-authored with David J. Farnham and Ken Caldeira entitled “Meteorology and climatology of historical weekly wind and solar power resource droughts over western North America in ERA5” (Brown et al., 2021).  His post explains that as wind and solar become more indispensable for providing electricity it is important that we understand the intensity, frequency, and duration of droughts of their availability.  In Brown et al., 2021 they use a meteorological database that covers 71 years from 1950 to 2020.  They compared estimated weekly solar and wind availability against cooling and heating degree days as a proxy for electrical load over that entire period. 

The following plot of the weekly values is of special interest.  The plot explanation states:

All weekly values from 1950 to 2020 (average over the western North America domain, Fig. 1) for power supplied by wind and solar resources (x and y axes respectively) and a proxy for power demanded via cooling degree days (color of dots). The mean seasonal cycle in wind and solar power is shown by the black loop (52 black dots for each week of the year). Drought weeks are indicated with black edge colors with wind droughts represented as circles, solar droughts represented as squares and compound wind and solar droughts represented as diamonds.

Of particular concern is the lower left quadrant which represents weeks where both wind and solar resources are lower than the annual mean of long-term availability.  Note that this quadrant is “mostly astronomical autumn. The mean wind & solar power given a wind + solar drought label shows that during a drought you can only expect around 40% of the solar resource and 65% of the wind resource.

There is an animation showing the degree to which there is persistence in time.  In the video each week is sequentially plotted since 1979 over a plot of the seasonal cycle.  As you watch the video keep in mind that you are watching the seasonal progression of plots.  While the majority of weeks with both wind and solar droughts are in autumn there are periods at the start of each year that appear to me to be among the most intense.  That is consistent with New York analyses that define the ultimate problem

that must be resolved to ensure reliability: firm capacity is needed to meet a multi-day period of low solar and wind resource availability during the winter. 

In their presentation to the Power Generation Advisory Panel on September 16, 2020 E3 included a slide titled Electricity Supply – Firm Capacity that states: “The need for dispatchable resources is most pronounced during winter periods of high demand for electrified heating and transportation and lower wind and solar output”.  The slide goes on to say: “As the share of intermittent resources like wind and solar grows substantially, some studies suggest that complementing with firm, zero emission resources, such as bioenergy, synthesized fuels such as hydrogen, hydropower, carbon capture and sequestration, and nuclear generation could provide a number of benefits.  Of particular interest is the graph of electric load and renewable generation because it shows that this problem may extend over multiple days.

Brown et al., 2021 is a promising approach for evaluating the long-term frequency of wind and solar droughts.  However, there are some limitations.  Obviously, the work has to be done for a New York centric domain.  In addition, because previous New York analyses by Energy + Environmental Economics  and The Analysis Group both identified problems on a multi-day basis it would be more appropriate to evaluate New York’s droughts on a daily basis. I strongly recommend that New York sponsor this analysis to determine the frequency and duration of renewable resource droughts. 

Because wind and solar are naturally intermittent the amount of energy storage needed to balance output must be determined.  The Brown et al., 2021 technique can also be used to identify periods that should be evaluated in more detail to determine the intensity of the droughts so that energy storage requirements can be determined.  This is important not only for grid planning but also for distributed energy resources (DER).  In theory DER can “generate smaller amounts of clean electricity closer to end-users, to increase energy efficiency, reduce carbon pollution, improve grid resiliency, and potentially curtail the need for costly transmission investments”.  However, unless they incorporate sufficient energy storage these resources won’t work when the system is stressed the most, so they may not be the panacea that advocates claim.

Reliability Planning

New York’s electric system is de-regulated so reliability planning is provided by the New York Independent System Operator, various state agencies and the NYSRC.  The NYSRC presentation describes the NYSRC and the Installed Reserve Margin (IRM) parameter.  The IRM is defined as the “minimum installed capacity margin above the estimated peak load to meet the Northeast Power Coordinating Council (NPCC) requirement that the probability of shedding load is not greater than one day in ten years”.   Load shedding occurs when the demand for electricity exceeds supply and grid operators have to turn power off for groups of customers in order to prevent the whole system from collapsing. 

To this point, reliability planning has been primarily focused on an electric system powered by conventional dispatchable generating resources. In that context resource obtainability is not particularly concerned with long-term availability of the resource because the resources are not intermittent.  That changes when the system becomes dependent upon wind and solar because there are short-term and long-term availability concerns.  It is in this context that the results from Brown et al., 2021 climatology becomes important and raises the question whether planning based on a ten-year metric is still appropriate in the future.  Using this approach, we can determine the frequency and duration of the expected worst case over ten years consistent with current IRM planning.  However, because we can consider a longer period, we can also consider the frequency and duration of droughts over the whole 70 years and get expected worst cases over other time periods.  If there is a marked difference over say the 30-year time period, it may be appropriate to expand the IRM planning period in order to prevent the probability of shedding load due to more severe drought.

Black Swan Events

To this point in this article, I have only addressed normal weather variability effects. During the preparation of this post, I came to believe that there is another reliability concern related to renewable resource adequacy that has to be addressed.  What happens to the electric system when unprecedented extreme weather cripples the relatively fragile renewable generating and transmission system?  These statistical outliers are described as a “black swan event”.

A Black Swan event is an event in human history that was unprecedented and unexpected at the point in time it occurred. However, after evaluating the surrounding context, domain experts (and in some cases even laymen) can usually conclude: “it was bound to happen”. Even though some parameters may differ (such as the event’s time, location, or specific type), it is likely that similar incidences have had similar effects in the past.

In this context the conclusion that “it was bound to happen” has to be discussed.  At an Our Energy Policy (OEP) panel discussion on New York State’s emerging offshore wind market, someone asked an off-shore wind industry expert whether wind turbines in New York would be able to withstand a Category 5 storm.  Clint Plummer the head of market strategies and new projects for Ørsted, the world’s largest owner, developer, and operator of offshore wind responded: “wind turbines are designed to withstand a Category 3 hurricane, and they have built into their permit applications an insurance fund that can pay for repairs in cases of catastrophic loss from a storm more severe”. He said “a Category 5 hurricane has a return period in excess of 100 years, while the design life of a wind farm is 30-35 years, so wind turbines are not designed to withstand a Category 5 storm because they are not expected to experience one”. “Anything less than that up to a certain speed is just a really good day for producing a lot of wind power,” he said.

In the October 1, 2021 Climate Action Council meeting presentation Carl Mas described the initial results of the integration analysis that will be used to develop the plan to implement changes to New York’s energy system to meet the CLCPA targets.  Four scenarios have been developed with different renewable resource, load reduction and sequestration strategies.  The new findings indicate that 20 GW of offshore wind resources will be necessary.  Assuming that New York builds the latest generation offshore wind turbine, e.g. the GE Haliade-X 12 MW turbine, that equates to over 1,600 turbines with 220 m or 722 foot rotors. 

However, hurricanes likely exceeding the threshold described by Ørsted expert Plummer have occurred in the area New York plans to build its offshore wind facilities.  In 1635 the “Great Colonial” Hurricane hit New York and New England and the “Great Storm of 1693” devastated Long Island. There were other hurricanes that made landfall in the Tri-State area – 1788 (left the Battery in ruins), 1821, 1893 (the second hurricane that year, different from the one that hit Halifax, Nova Scotia), 1944 (“Great Atlantic” hurricane), 1954 (Carol), and 1991 (Bob). The 1938 “Long Island Express” made landfall in Long Island as a Category 3 hurricane with sustained winds of 125 mph and wind gusts up to 150 mph bringing waves surging to 35 feet.  Given that part of the rationale for the CLCPA is that extreme weather events such as hurricanes are becoming more frequent and severe there should be no question that a contingency plan is necessary for the time that a hurricane inevitably affects, if not destroys, the New York offshore wind resource.  Moreover, should that not be a part of the reliability planning process?

Unfortunately, that is not the only extreme weather event that can have extreme consequences on a more fragile wind and solar electricity network.  I am particularly worried about ice storms.  On a local level it is not clear how the public will be able to survive a multi-day power outage caused by an ice storm when the CLCPA mandates electric heat and electric vehicles but the bigger reliability concern is that fact that ice storms can take out transmission lines.  For example, consider, the January 1998 North American ice storm:

The North American Ice Storm of 1998 (also known as Great Ice Storm of 1998) was a massive combination of five smaller successive ice storms in January 1998 that struck a relatively narrow swath of land from eastern Ontario to southern QuebecNew Brunswick and Nova Scotia in Canada, and bordering areas from northern New York to central Maine in the United States. It caused massive damage to trees and electrical infrastructure all over the area, leading to widespread long-term power outages. Millions were left in the dark for periods varying from days to several weeks, and in some instances, months. It led to 34 fatalities, a shutdown of activities in large cities like Montreal and Ottawa, and an unprecedented effort in reconstruction of the power grid. The ice storm led to the largest deployment of Canadian military personnel since the Korean War, with over 16,000 Canadian Forces personnel deployed, 12,000 in Quebec and 4,000 in Ontario at the height of the crisis.

New York Governor Kathy Hochul recently announced “two major green energy infrastructure projects to power New York City with wind, solar and hydropower projects from upstate New York and Canada”.  The press release claims that the combined project will deliver 18 million megawatt-hours of upstate and Canadian renewable energy per year.  Clean Power New York plans on over 20 wind and solar generation projects – all located in New York State – and a new 174-mile, underground transmission line. Champlain Hudson Power Express is a 338-mile underground power line from Quebec hydroelectric facilities to New York City.  The problem is that not all the associated infrastructure in these projects is underground and immune from ice storms.

Photo from 1TAC Survival Blog

Conclusion

The requirements for New York reliability planning will have to change for a future grid that relies on intermittent and diffuse wind and solar.  Current planning for the electric system is based on decades-long experience with a system powered primarily by sources that are dispatchable and includes sources that have on-site storage.  The potential for lack of source availability over days, weeks, and even months is not a serious concern today because the New York system has been diverse, redundant, and resilient to the vagaries of weather.

The CLCPA requirement for a zero-emissions electric system that relies on wind and solar energy resources changes the reliability planning requirements.  Previous analysis has highlighted the need to address multi-day wind lulls in the winter as a particular problem.  Brown et al., 2021 have developed a technique that can be used to determine the climatological frequency and duration of those periods of low wind and solar resource availability that clearly should be included in New York reliability planning.  Their analysis technique can also be used to identify the worst-case periods of wind and solar droughts so that more detailed resource availability analyses can estimate how much energy storage is needed not only for the electric grid but also the distributed energy resources proposed for the CLCPA.  This analysis is needed to prevent the kind of Texas February 2021 disaster from happening in New York.

The existing New York system has evolved over years of trial-and-error experience to the point where it is relatively resilient to extreme weather events.  While there have been exceptions, the possibility of widespread, weeks-long outages is extremely low.  However, because wind and solar resources are more fragile to wind and ice crippling damage than existing generating sources, the likelihood of the conditions that cause that level of damage should be determined.  Brown et al., 2021 can determine the occurrence of events over a 71-year period.  If, for example, their analysis suggests that the return period of a crippling event is one in thirty years, then should New York reliability planning incorporate a longer time horizon for its planning?

At this time, the off-shore wind strategy calls for 20 GW of development.  The ramifications of a Category 4 or greater hurricane destroying or significantly damaging those facilities should be at least be considered.  Repairing them will take months if not years and the ramifications if insufficient resources are available are immense. If nothing else the statements claiming that the future wind and solar dependent electric system will be more resilient should be toned down.

The Climate Leadership & Community Protection Act’s Fundamental Flaw

The authors of New York’s Climate Leadership and Community Protection Act (CLCPA) Climate Action Council biased implementation of the law to vilify methane and nitrous oxides because they have the potential to warm the atmosphere more than an equivalent amount of  carbon dioxide.  This post explains why that rationale is incorrect and makes the CLCPA fundamentally flawed.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   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.

Background

Last year I published an article, Climate Leadership and Community Protection Act Methane Obsession that described how the irrational New York obsession against natural gas has resulted in a requirement in the CLCPA to develop an emissions inventory using a 20-year time horizon because methane has a greater potential to increase global warming.  As a result of this requirement and another mandate to include upstream emissions too, the baseline 1990 greenhouse gas emissions inventory nearly doubled.  I pointed out in that article that as a result of this approach, the implementation will have to focus on immediately reducing natural gas use despite its many advantages and crucial support to energy supplies.

My previous article noted that the methane obsession in the CLCPA law and its implementation strongly relies on the research of Professor Robert Howarth of Cornell University.  According to the Cornell Chronicle Howarth played a “key role” in drafting the law and now as a member of the Climate Action Council will “identify and make recommendations on regulatory measures and other state actions that will ensure the attainment of the statewide greenhouse gas emissions limits”.  Howarth is the David R. Atkinson Professor of Ecology and Environmental Biology at Cornell and his biography notes “My training was in oceanography, and much of my research still focuses on coastal marine ecosystems”.  Cornell Alumnus David Atkinson provided funds to establish and make permanent Cornell’s Center for Sustainability because he “realized that climate change is probably the biggest issue facing humanity”.  A recent paper of Howarth’s on methane emissions inventories was funded by the Park Foundation that has a long history of anti-natural gas fracking activism.  I make these points because it is clear that his funding sources support certain outcomes so supporting research is at the very least encouraged.  Moreover, nothing in his background suggests expertise in atmospheric radiation related to a thorough understanding of nuances associated with global warming theory.  If a dentist receiving money from the tobacco industry were to publish research that said smoking has health benefits, then his motives would be questioned and his claims scrutinized in great detail.  Despite an analogous background and other research contradicting his analyses Howarth’s research is unquestioned in the implementation process.

As mentioned previously, one of the mandates specified in the CLCPA is that the global warming potential (GWP) had to be calculated over a 20-year time horizon.  The Inter-governmental Panel on Climate Change describing time horizons and the GWP notes:

“The GWP has become the default metric for transferring emissions of different gases to a common scale; often called ‘CO2 equivalent emis­sions’ (e.g., Shine, 2009). It has usually been integrated over 20, 100 or 500 years consistent with Houghton et al. (1990). Note, however that Houghton et al. presented these time horizons as ‘candidates for discussion [that] should not be considered as having any special sig­nificance’. The GWP for a time horizon of 100 years was later adopted as a metric to implement the multi-gas approach embedded in the United Nations Framework Convention on Climate Change (UNFCCC) and made operational in the 1997 Kyoto Protocol. The choice of time horizon has a strong effect on the GWP values — and thus also on the calculated contributions of CO2 equivalent emissions by component, sector or nation. There is no scientific argument for selecting 100 years compared with other choices (Fuglestvedt et al., 2003; Shine, 2009). The choice of time horizon is a value judgement because it depends on the relative weight assigned to effects at different times.”

Reference: Myhre, G., D. Shindell, F.-M. Bréon, W. Collins, J. Fuglestvedt, J. Huang, D. Koch, J.-F. Lamarque, D. Lee, B. Mendoza, T. Nakajima, A. Robock, G. Stephens, T. Takemura and H. Zhang, 2013: Anthropogenic and Natural Radiative Forc­ing. In: Climate Change 2013: The Physical Science Basis. Contribution of Working Group I to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change [Stocker, T.F., D. Qin, G.-K. Plattner, M. Tignor, S.K. Allen, J. Boschung, A. Nauels, Y. Xia, V. Bex and P.M. Midgley (eds.)]. Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA.


Howarth and others argued that it was necessary for the CLCPA to use 20-year global warming potential (GWP) values because methane is estimated to be 28 to 36 greater than carbon dioxide for a 100-year time horizon but 84-87 GWP over a 20-year period.  Because of these high potentials they assumed that meant that the effect of methane on expected warming would be significant.

Earth’s Thermal Radiation

I was prompted to write this post because of Andy May’s excellent summarization of Wijngaarden and Happer’s important paper “Dependence of Earth’s Thermal Radiation on Five Most Abundant Greenhouse Gases”.  In my previous post on New York’s methane obsession, I noted that a report entitled “Methane and Climate” by the same two authors had concluded that “Proposals to place harsh restrictions on methane emissions because of warming fears are not justified by facts.”  However, Andy May’s analysis describes the greenhouse effect and the potential impact of methane so well that it also needs to be considered in the context of the CLCPA. The greenhouse effect is the basic rationale for the alleged existential threat of climate change because additional anthropogenic greenhouse gases, in the absence of any other processes, must warm the atmosphere.  Although this is a non-controversial scientific fact, the reality is that there are so many processes, conditions, caveats, and unknowns that it is impossible to precisely estimate how much warming can be expected with added greenhouse gas emissions.  May explains the basics and some of the complexities in his recent article and references his previous article on the greenhouse effect for even more discussion of the fundamental effect.

Thermodynamics in general and atmospheric thermodynamics have always given me a headache and I agree with May’s argument that no one really understands all the component complexities of it.  Fortunately, Wijngaarden and Happer (W&H) have evaluated the likely influence of greenhouse gases (CO2, H2O, CH4, N2O, and O3. using the HITRAN line-by-line molecular transmission and absorption database maintained at Harvard University to give us a better understanding of the atmospheric processes and effects of these gases. May writes:

HITRAN stands for high-resolution transmission molecular absorption. The database compiles spectroscopic parameters that computer programmers can use to model the transmission and emission of light in the atmosphere. W&H use the database to model a hypothetical mid-latitude temperature and GHG atmospheric profile to derive a representative climate sensitivity to doubling the gases. 

In layman’s terms this analysis considers the distribution and characteristics of greenhouse gases in the atmosphere to determine how much the climate could warm due to this process in isolation.

Verbatim Andy May Summary and Conclusions  (the following section is directly quoted)

“In summary, W&H have provided us with a detailed and accurate emissions model that shows only modest warming (2.2 to 2.3°C), inclusive of likely water vapor feedback, but not counting the feedback due to cloudiness changes. Both the magnitude and sign of net cloud feedback to surface warming are unknown. Lindzen has shown it is likely negative (cooling) in the tropics, but outside the tropics no one knows.”

“The water vapor feedback to surface warming is also very unclear, Ferenc Miskolczi (2014) has written:”

‘As long as the Earth has unlimited water supply (in the oceans) with its three phases permanently present in the atmosphere and two phases on the ground surface, the stability of the planetary climate will be controlled by the equations [see paper, page 19]. These two equations, together with the Clausius-Clapeyron equation, will regulate the transfer of the latent heat through the boundary layer in such a way that the net amount maintains the planetary radiative balance.’

“Miskolczi, and others have found that total water vapor in the atmosphere has gone down in the past 70 years, although this is questioned. The work by W&M on radiation emissions suggests that future warming due to GHGs will be modest. Speculation about the warming feedback due to clouds and changes in total water vapor is just that, speculation.”

“The results of the study are summarized in Table 2.”

Table 2. Modeled parameters for each GHG in the W&H study. The current flux at 11 km and 86 km for each GHG are shown, then the values if they are doubled, and removed from the atmosphere, and finally the percentage change in forcing (W/m2) if the current concentration is doubled. Only CO2, H2O and O3 change significantly when doubled.

“Table 2 shows that the main GHGs are CO2, H2O and O3, doubling the methane or N2O concentration changes the outgoing forcing by less than one percent. Due to the properties of water vapor, its atmospheric concentration is very unlikely to double, but if it did, it would only increase the forcing by eight percent at 11 km. Doubling CO2 only increases the forcing by four percent at 11 km.”

“The combined current 11 km and 86 km forcing values in the table are not the sum of the individual values due to overlap. It is very clear from this table that all GHGs are saturated and adding to the current concentrations will make very little difference. Doubling CO2 will cause the stratosphere to cool about 10°C, but the changes in surface temperatures from this model are all less than 2.3°C, as shown in Table 1. This is much less than the preferred IPCC AR6 value of 3°C (IPCC, 2021, pp. TS-57). Considering that the current net effect of clouds is cooling and it seems likely that total water vapor in the atmosphere is decreasing or staying flat, these results suggest we have little to worry about regarding increasing GHGs.”

CLCPA Implications

One of the bigger problems implementing the CLCPA is developing strategies to reduce methane (CH4 and nitrous oxide (N2O) especially because of the unprecedented focus on those pollutants.  While there aren’t as many sources of either one or as much emitted by either one relative to CO2, the capability to control them is difficult.  So difficult that the apparent strategy is to ban their use.  With respect to methane that means eventually banning the use of natural gas for home heating, cooking and hot water despite its inherent advantages.  Similarly, the largest source of nitrous oxides emissions is from nitrogen fertilizer so reducing those emissions has unintended consequences.

The reason that methane and nitrous oxides are included in the CLCPA and used to justify changing the emissions calculation methodology to emphasize their importance is that the global warming potential for both pollutants are much higher than the warming potential of carbon dioxide.  If it can warm more then it most be more important according to this rationale.  The CLCPA emissions inventory is calculated differently than just about every other jurisdiction for this reason.

The Wijngaarden and Happer paper destroys this rationale.  Ultimately the CLCPA rationale is to mitigate global warming by reducing the emissions that have the potential to enhance the greenhouse effect itself.  Two characteristics of greenhouse gases determine the effect: the global warming potential and the concentration of the gases in the atmosphere.  Because the atmospheric concentrations of methane and nitrous oxides are so small doubling concentrations change the “outgoing forcing by less than one percent”.  In other words, doubling emissions or cutting emissions in half of methane and nitrous oxides will have no measurable effect on global warming itself. 

The Climate Action Council claims to “follow the science” but it is evident that the CLCPA science actually selectively follows the narrative supporting the agenda to electrify everything using unreliable and expensive renewable energy.  No where is this more evident in the use of the 20-year global warming potential emissions inventory that makes natural gas untenable.  If the state actually implements these restrictions, then people will freeze to death in the dark either slowly because they cannot afford the energy costs or quickly when there is an ice storm that knocks out power for days.  All because of flawed CLCPA reasoning best shown by the following analogy.  Methane is 86 times more powerful than carbon dioxide so it is necessary to frame the emissions inventory to address methane uses the same reasoning as a claim that because an ant can lift 86 times its own weight it is more powerful than a man who cannot lift as high a percentage of its weight.

Climate Leadership & Community Protection Act Lessons from Europe

At the September 13, 2021 meeting of New York’s Climate Leadership and Community Protection Act (CLCPA) Climate Action Council a requirement to consider carbon reduction measures in other jurisdictions was discussed.  I agree that this is an important consideration but I expect that the evaluation will consider the control measures themselves in isolation and ignore the ramifications observed of those measures.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   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.

Background

Since the spring of 2020 the Climate Action Council has been developing a scoping plan outlining recommendations to implement the CLCPA.  The goal is to complete a draft scoping plan by the end of 2021, take comments next year, revise the scoping plan, have the next state energy plan incorporate the scoping plan strategies, and then have state agencies develop the many regulations necessary.  A key component of the process will be the integration analysis. At the September 13, 2021 Climate Action Council meeting , it was noted that the Integration plan provides support for the scoping plan but it is not the same as the scoping plan as a whole.  “It is designed to assess the greenhouse gas reductions, benefits and costs of portfolios of measures state-wide so the implications of various policy recommendations can be understood.”  The report will be prepared by Energy & Environmental Economics (E3) under the guidance of the New York State Energy Research & Development Authority (NYSERDA).  It “combines a detailed accounting model of energy supplies and demands across the entire economy with an optimized capacity expansion model in the electric sector” to develop a mix of energy sources that will meet the CLCPA goals.  The scoping plan will also estimate total societal costs and benefits.  For further background, I have summarized the schedule, implementation components, and provide links to the legislation itself at CLCPA Summary Implementation Requirements.

Carl Mas from NYSERDA led the discussion of the integration scenario planning process.  During his presentation he summarized feedback from the Climate Action Council.  At 1:43:40 in the video of the meeting he described the measures/policies first bullet, that notes that they will examine carbon reduction measures being pursued by “other states, regions, localities, and nations”.  He said that measures in other states and regions, “including Europe”, will be evaluated.  The purpose of this post is to point out that in addition to the measures themselves the observed outcomes should also be addressed.

Great Britain and Germany Electrical System Status

Great Britain and other European jurisdictions have similar greenhouse gas reduction policies in place.  In June 2019 Great Britain became the “first major economy to bring all greenhouse gas emissions to net zero by 2050”.  Germany has its Energiewende (energy transition) which will expand renewable energy resources and phase the electric sector out of fossil fuels to “reduce the energy sector’s emissions by 61 or 62 percent by 2030 compared to 1990”.  Implementation of both policies is further along than the New York CLCPA and the ramifications are becoming evident.

In September 2021 electricity prices reached record levels in the European and United Kingdom power markets.  The day-ahead electricity prices are triple of those a year ago.  Paul Homewood at the Not a Lot of People Know That blog writes:

The immediate trigger has been low wind speeds across much of Europe in the last few weeks, meaning reduced outputs of wind power. This has led to a shortage of power on the grid, and a consequent spiking of prices. This sort of thing occasionally happens in winter when demand is high, but is unheard of in summer months, indicating that something is going badly wrong.

European and United Kingdom Electricity Prices

https://www.catalyst-commercial.co.uk/works/september-2021-energy-market-brief/

I believe that the current problem can be traced to an increasing lack of diversity of electrical generation sources in the European and United Kingdom electrical systems.  In order to provide reliable electricity, electric operators must balance load with generation dispatching generating sources to meet load variations.  Dispatchability is a key attribute of the generators needed for reliable electricity.  Fossil-fired, nuclear, and hydro generating stations are the primary sources of dispatchable energy today.  Europe has been phasing out coal and nuclear generation so the percentage of dispatchable generation is decreasing.  In order to keep prices down the more types of dispatchable power that are available the better so that any upset in one source can be balanced by power from the other sources.  Nuclear and hydro generation has low fuel costs so those sources run as much as possible so the loss of coal capacity means that prices are strongly influenced by the availability and cost of natural gas. 

In addition, solar and wind resources have zero fuel costs so they run whenever the sun shining and the wind is blowing.  This results in less income for the dispatchable resources and is a factor in the loss of coal generation capacity shown in following graph.  This price structure also affects existing natural gas generation and makes the construction of new natural gas capacity a poor investment so new plants are not being built. The result is a long-term loss of dispatchable generation availability.  

Europe has reached the point where renewable resource availability can trigger price issues.  Recently there was a two-week wind lull at the same time there was a Europe-wide gas shortage.  As a result of the system needing sources that can only survive by charging very high prices for the short periods when their energy is needed, the electricity price spiked and  German electricity prices hit a new record high

Also note that short-term variations in solar resources caused German electric grid operators to disconnect several industrial companies from the grid to maintain the system:

The generation of electricity in Germany on this Saturday was downright chaotic. During the day, the solar systems generated a lot of electricity due to the almost optimal solar radiation. Between 1 p.m. and 2 p.m., the solar power reached a peak output of more than 30,000 megawatts. In the evening, the power generation of the solar systems collapsed drastically. Between 7 p.m. and 8 p.m., they delivered around 3,000 megawatts, just 10% of the output from the afternoon. However, the demand for electricity in the evening was almost unchanged at a good 50,000 megawatts. The network operators therefore had to call up all available reserves. But the output of the pumped storage power plants and the lignite power plants run up to their maximum load was not enough to compensate for the deficit between electricity demand and electricity generation. The still missing amount of electricity could not be compensated by importing electricity from abroad. Therefore, shortly before 8 p.m., loads were shed from larger, energy-intensive industrial plants, such as aluminum and copper smelters

Advocates for renewable energy often under-estimate the importance of reliable electricity to society.  Obviously, higher energy prices affect consumers but they also impact industrial activities and can force them to curtail operations.  As a result of the spike in prices, British fertilizer plants shut down, CO2 produced by the fertilizer plants became unavailable, and now there is the threat of food shortages because “The gas is critical to the production and transport of a range of products, from meat to bread, beer and fizzy drinks”.  The soaring energy prices have affected the viability of gas suppliers and taxpayers in Great Britain may have to bail them out.

The European crisis also underscores issues with imports.  The United Kingdom has become increasingly dependent on electricity imports from France and Ireland.  Issues with the undersea transmission line from France have reduced the amount that can be imported.  Ireland froze exports to the United Kingdom when they needed all the output from their wind farms for their own needs.  Worse, is the reliance of Europe on Russian exports of natural gas which could easily become a source of political blackmail.  The bottom line is that relying on imports introduces complications which can come back and cause problems.

Conclusion

The Climate Action Council reminded the analysts developing the CLCPA integration analysis that the law mandates review of actions being pursued by “other states, regions, localities, and nations”.  In the presentation Carl Mas summarized the planned response to feedback from the Climate Action Council.  His presentation said they would examine carbon reduction measures being pursued by other states and regions, “including Europe”.  I suspect that the response to this mandate will focus on the measures themselves and overlook the inconvenient fact that cost and reliability issues are occurring with greenhouse gas emission reduction targets similar to the CLCPA.

Based on the current trajectory of the CLCPA implementation process I believe the same things happening in Europe today will happen in New York.  The majority of the Climate Action Council members have insufficient technical background to fully appreciate the magnitude of the challenge converting the existing electrical system to one dependent upon intermittent renewable energy resources.  For example, while the claim that solar generating capacity may be cheaper than natural gas fired power plants may be true the problem is that the claim only covers part of the cost of providing reliable electricity to homes and businesses.  When the total costs necessary to provide electricity when and where needed is added the cost is much higher as reflected by the long-term trend in European electricity prices.  Over dependence upon intermittent resources reliant on the vagaries of weather also affect shorter term price as shown by the September price spikes.  It also appears that increased energy use during cold weather this winter could be a problem in Europe unless it is mild due to the surging gas and electricity prices.  The European experience also shows that there are significant ramifications to high energy costs that should be addressed by the CLCPA.

The European experience reflects not only high energy costs but there are troubling signs that reliability issues can occur even during periods when the electric system is not stressed due to high demand.  Germany had to shut down power to major industrial facilities without warning in August because of solar variability.  The fact that the September wind lull during a period generally considered low load demand caused grid operators to call on rarely used coal generators suggests that continued retirements of the dispatchable resources at the same time more wind facilities are added will eventually cause insurmountable problems because when a high-pressure system causes calm winds it does so over a very large area so all the wind facilities in an area as small as Great Britain will all lose power at the same time.  Someday the over-reliance on wind energy and loss of dispatchable resources will cause a grid crisis in Great Britain and New York will fare no differently if the state goes down the same path.

The CLCPA attempt to reduce greenhouse gas emissions ignores the observed risks and impacts of a transition to an electrical system reliant on renewable energy in a quixotic quest to reduce the impacts of the imaginary existential threat of climate change.  This cannot end well unless the state accepts the lessons from Europe and radically revises the schedule and targets of the CLCPA until a feasible plan to address the problems identified is developed.

Finally, given the importance of what is happening in Europe I recommend an article on the same topic at Manhattan Contrarian.

Forecast Verification for the New York Climate Action Council Meeting

On September 4, 2021 I predicted that at the next meeting of New York’s Climate Leadership and Community Protection Act (CLCPA) Climate Action Council the recent flooding in lower New York State would be described as evidence that climate change is a reality and that the actions of the Council will fight these kinds of disasters.  This post notes that for the record the Co-Chair “remarks and reflections” included a slide on the recent flooding.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   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.

Background

Since the spring of 2020 the Climate Action Council has been developing a scoping plan outlining recommendations to implement the CLCPA.  The goal is to make the recommendations by the end of 2021 and have the next state energy plan incorporate their recommendations.  A key component of the process will be the integration analysis prepared by Energy & Environmental Economics (E3) that “combines a detailed accounting model of energy supplies and demands across the entire economy with an optimized capacity expansion model in the electric sector” to develop a mix of energy sources that will meet the CLCPA goals.  The plan will also estimate total societal costs and benefits.  For further background, I have summarized the schedule, implementation components, and provide links to the legislation itself at CLCPA Summary Implementation Requirements.

A common feature in the Climate Action Council meetings has been a “reflection” in the opening remarks by the co-chairs that brags about recent implementation actions and includes an argument that additional implementation is needed to address the latest extreme weather event.  My forecast was correct because the meeting included the following slide describing the recent New York flood events (At 8:25 in the Meeting Recording).

Discussion

The immediate response after the flooding from the usual suspects was that climate change was involved despite the fact that worse precipitation has been observed in the past.  As noted in the last post the mis-perception between climate and weather is so common that I have developed a page that explains the difference between weather and climate and includes articles debunking similar claims. 

In the previous post I concluded that flooding caused by heavy rainfall following a previous storm is much more an example of extreme weather than a climate change driven event.  The need to implement mitigation measures as part of the CLCPA is mis-guided because it diverts resources from improvements to weather forecasting, extreme weather warning communications, and resiliency adaptation measures.  Those improvements could provide tangible benefits even if the climate change alarm proves to be over rated.  On the other hand, expecting any extreme weather benefits from emission mitigation measures by New York State are doomed simply because world-wide emissions continue to increase at a greater pace than New York reductions can ever hope to slow down much less reverse.

The remarks and reflections also noted that the latest report from the Intergovernmental Panel on Climate Change had come out since the last meeting.  The director of the Department of Environmental Conservation, Basil Seggos, described the stark warnings of the report at 7:25 of the video.  Not surprisingly, there was no recognition that the high carbon pathway that gives the catastrophic predictions is based on emissions that are implausibly high because recent International Energy Agency estimates are 30% less than that IPCC scenario.  Furthermore, Dr Judith Curry writes that “The extreme tail risks from global warming, associated with very high emissions and high climate sensitivity, have shrunk and are now regarded as unlikely if not implausible.”  Nonetheless, NY policy makers continue to emphasize projections based on the high emissions and high climate sensitivity scenarios.

Conclusion

The CLCPA implementation process continues to portray any extreme weather event as “proof” of global warming driving climate change.  However, New York agencies ignore the difference between weather and climate.  A climatological average is defined as a 30-year average.  In 1954 three hurricanes and in 1955 two hurricanes hit the Atlantic coast north of South Carolina.  If that were to happen today, the alarmists would be screaming that this is definitive proof of a changing climate.  It happened over 66 years ago and has not happened again through two climatological averaging periods.  That indicates if anything, a tendency for fewer hurricanes.  I conclude that describing the flooding caused by the remnants of hurricane Ida as proof of climate change is an example of not letting a crisis go to waste and not letting the facts get in the way of a good story.

Prediction for the New York Climate Action Council’s Next Meeting

In New York’s Climate Leadership and Community Protection Act (CLCPA) the Climate Action Council is required to prepare and approve a scoping plan outlining the recommendations for attaining the statewide greenhouse gas emissions limits in accordance with the schedule of the law.  I predict that at their next meeting the recent flooding in lower New York State will be described as evidence that climate change is a reality and that the actions of the Council will fight these kinds of disasters.  This post explains why the rationale is wrong and the proposed solution hurts rather than helps the flooding problems.

I have written extensively on implementation of the CLCPA because I believe the solutions proposed will adversely affect reliability and affordability, will have worse impacts on the environment than the purported effects of climate change, and cannot measurably affect global warming when implemented.   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.

Background

Since the spring of 2020 the Climate Action Council has been developing a scoping plan outlining recommendations to implement the CLCPA.  The goal is to make the recommendations by the end of 2021 and have the next state energy plan incorporate their recommendations.  A key component of the process will be the integration analysis prepared by Energy & Environmental Economics (E3) that “combines a detailed accounting model of energy supplies and demands across the entire economy with an optimized capacity expansion model in the electric sector” to develop a mix of energy sources that will meet the CLCPA goals.  The plan will also estimate total societal costs and benefits.  For further background, I have summarized the schedule, implementation components, and provide links to the legislation itself at CLCPA Summary Implementation Requirements.

A common feature in the Climate Action Council meetings has been a “reflection” in the opening remarks by the co-chairs that brags about recent implementation actions and includes an argument that additional implementation is needed to address the latest extreme weather event.  Given that history I have no doubt that the next meeting will describe the flooding effects of hurricane Henri and the remnants of hurricane Ida and imply that the CLCPA will reduce if not eliminate those effects in the future.  That claim as well as all the other similar claims in the past is baloney.

New York Flooding

On August 22, 2021 tropical depression Henri made landfall in Rhode Island.  Although it had weakened from a hurricane and skirted New York, it dumped heavy rains from New Jersey to New England.   The region had a wet summer so the ground was already saturated.  As a result, the main impact was flooding.  Hurricane Ida struck the Louisiana coast on August 29, 2021 sixteen years to the day after Hurricane Katrina devastated New Orleans.  Although there was widespread devastation, the levees in New Orleans held and the loss of life was much less in Louisiana.

I followed the forecasts of the remnants of Ida as it slogged north and the east out to sea.  Every forecaster was warning that heavy rains were likely in the New York City area and coupled with already saturated grounds that flooding was likely.  Cliff Mass described the weather as it hit the area and noting that New York’s Central Park had a record of 3.15 inches in an hour.  He explains that hurricane remnants, known as extratropical cyclones, combine strong upward motions with large amounts of tropical moisture.  This combination causes heavy rains and flooding.  Tragically, dozens of people were killed in New York and New Jersey as a result of this flooding.

The immediate response from the usual suspects was that climate change was involved despite the fact that worse precipitation has been observed in the past.  I believe that this will also be the response by the Climate Action Council co-chairs at the next meeting.  This is such a common response that I have developed a page that explains the difference between weather and climate and includes article debunking similar claims.  In this case however, I want to respond differently.  In particular, I want to discuss what the best approach would be to prevent a reoccurrence of the deaths and devastation in New York City.

Discussion

As I mentioned before this was a very well forecasted event with some caveats.  Cliff Mass notes that there were warnings out for heavy precipitation but that there some issues with “intensity and position”. He goes on to argue that a larger number of finer resolution weather prediction ensembles could be used to develop better probabilistic/uncertainty predictions.  I think those models could also be improved by incorporating higher density observations into the models.  All those revisions could improve the forecasts if implemented.

However, the fact is that the forecasts were ignored.  In my opinion, many New York City residents are so divorced from weather impacts (they simply are not outside for long periods that much) that they don’t pay attention to weather forecasts unless it is an extreme event.  Consequently, the idea that a forecast for heavy rain means that they should monitor the weather situation, i.e., check the weather forecast frequently in that situation, is not common practice.  As a result, communication practices have to be changed to ensure that people stay off the roads and get out of low-lying basement apartments when this kind of forecast is made.

The good news vis-à-vis Ida was that the levee resilience measures installed in Louisiana since Katrina worked well enough to prevent a re-occurrence of that disaster.  If there were other levees that failed it is clear that additional strengthening is needed.  The bigger problem there is the extensive damage to the electric system.  Clearly more needs to be done to strengthen the resiliency of the electric transmission and distribution system.

After super storm Sandy In New York City extensive upgrades were made to prevent damage from storm surges.  However, given that the subways still flooded, more still needs to be done to prevent water damage to that system.  Given the extreme amount of rain it probably is not possible to engineer a system to prevent all the many water issues but it certainly is time to update what could be done.  In addition to infrastructure improvements developing an improved warning system would be useful.  For example, during such an event if people knew that the GPS driving direction systems were being updated with flooding information, they could use them to steer clear of problem areas.

All of the aforementioned resiliency measures require investments of time and money.  However, they all can provide benefits to reduce impacts of future storms.  One of the key points to understand about extreme weather and climate change is that climate change impacts are smaller than the effects of natural variability.  As a result, it is ludicrous to expect that extreme weather will stop occurring even if climate change mitigation measures reduce global warming and the alleged effects on extreme weather.  The most likely future scenario for weather is more extreme weather and that means that adapting to the effects of extreme weather is a no regrets approach.

More importantly the fact is that beyond New York and the United States fossil fuel emissions are increasing at a rate that is many times greater than New York’s emissions.  Consequently, even if New York mitigation efforts do reduce emissions there will be no impacts on the world’s weather because of increased emissions elsewhere. 

Conclusion

The next meeting of the Climate Action Council will be on Monday, September 13, 2021 at 2:00 p.m. ET.  The meeting agenda includes a welcome item that I predict will mention the flooding in New York City as a sign that climate change is a reality and we need to fight it. 

In actuality the observed heavy rainfall following a previous storm is much more an example of extreme weather than a climate change driven event.  The need to do something about it as part of the CLCPA is mis-guided because it diverts resources from improvements to weather forecasting, extreme weather warning communications, and resiliency adaptation measures.  Those improvements could provide tangible benefits in any event.  On the other hand, expecting any extreme weather benefits from emission mitigation measures by New York State are doomed simply because world-wide emissions continue to increase at a greater pace than New York reductions can ever hope to slow down much less reverse.