Citizens Budget Commission Getting Greener – Findings

Update: I have prepared three technical posts on this report: Once I completed these three posts, I realized that they were too wonky for a general audience.  The first post discussed their findings, the second post addressed their renewable energy forecast to meet the CLCPA, and the third post calculates the energy storage requirement for a winter peak period.  Because the CBC study is so important, I have prepared a less-technical summary that hits the highlights of all three posts.

On December 9, 2019 the Citizens Budget Commission (CBC) released a report entitled Getting Greener: Cost-Effective Options for Achieving New York’s Greenhouse Gas Goals  that addresses the impacts of the Climate Leadership and Community Protection Act (CLCPA).   There is much to like about the report but I disagree with a few of their recommendations and have concerns about some of the methodology.  In order to do this report justice, I have prepared three posts.  If you have an interest in New York energy policy I recommend that you read the entire document.  It is well written, comprehensively covers many of the issues associated with the CLCPA, and makes estimates of the resources needed to implement the CLCPA.  This post concentrates on their findings.  The second post addresses their energy forecast to meet the CLCPA and the final post calculates the energy storage needed.


The CBC is a nonpartisan, nonprofit civic organization whose mission is “to achieve constructive change in the finances and services of New York City and New York State government”.  They claim to serve the public rather than narrow special interests try to preserve public resources, whether financial or human; and focus on the well-being of future New Yorkers which they say are “the most underrepresented group in city and state government”.

The CBC Energy Policy Committee managed the development of the report.  It was prepared for CBC by Seth Hulkower, President of Strategic Energy Advisory Services.  Apparently, this project has been in the works for a long time because the “initial findings of this report were presented at a CBC research conference held in New York City in December 2018”. The report was not completed until December 2019 because of New York’s changing policies over the past year.  In particular, the Climate Leadership and Community Protection Act (CLCPA) was promulgated in July 2019. They made revisions based on feedback from external reviewers and staff at the Public Service Commission and the New York League of Conservation Voters but noted that their willingness to assist in the research does not “imply any endorsement of the report’s findings and recommendations”.

Annotated CBC Findings

The report notes that New York is already green: “compared to other states it produced the fewest per-capita GHG emissions in 2016 and experienced the greatest percentage decrease in emissions– 13 percent– between 1990 and 2016”. Most of New York’s decrease occurred in the electric power sector as NY power plants shifted almost entirely away from coal and oil to increased use of natural gas and nuclear power.  They also say that during this time GHG emissions also decreased significantly in the industrial sector and declined slightly in the residential and commercial sectors. In contrast, emissions grew 25 percent in the transportation sector and that represents more than one-third of all GHG state emissions and over 40 percent of end-use energy.

The report explains that New York’s ability to continue to make such gains and to meet CLCPA goals is uncertain and gives the following reasons.  My comments are italicized.

    1. “Immense scaling up of renewable generation capacity is necessary and is likely infeasible by 2030. Much of New York’s GHG strategy rests upon continued reductions in the electric sector; specifically, state plans are to more than double renewable generation capacity, mostly from offshore wind turbines. However, it will be challenging to install the required resources by 2030: too few projects are underway and project timelines are lengthy and are likely to be delayed by extensive permitting procedures and often community opposition. New York is poised to direct the expenditure of billions of dollars and still fall short of the stated goals.”
      • I agree with these concerns. It is not clear to me what the amount of offshore wind turbines relative to other renewables will be because there is no state comprehensive plan.
    2. “The focus on building renewable resources, particularly offshore wind, and entering into long-term power contracts limits flexibility and diminishes consideration of other cost-effective approaches. Efforts to scale up renewables are necessary, but projects planned require the State to offer supplemental payments to make them work. Furthermore, the massive infrastructure investment required to procure offshore wind capacity will require long-term contracts that will lock in increased costs for electric customers for years to come. Based on analysis of a recent offshore wind project contract, meeting the renewable target entirely with offshore wind will increase electricity costs by $2.3 billion annually, an increase of between 8 and 12 percent to New Yorkers’ electric bills, which could be a significant increase in monthly living expenses for some low-income and working class New Yorkers. Other options may be more cost-effective, particularly as technology evolves in the long term.”
      • The importance of concern about locking in long-term contracts cannot be over-estimated. If the State does this wrong then we will be locked into significant cost increases for a long time.  Moreover, I think that their cost estimates are low because they only consider the cost of the turbines themselves and do not include the extra costs necessary to make off-shore wind power dispatchable.
    3. “State policies on nuclear, natural gas, and hydropower are counterproductive. First, the state’s six nuclear power plants are scheduled to shut down between 2020 and 2046. Elimination of the nuclear fleet will erase nearly all previous emissions gains as that power supply by necessity will likely be replaced in the near-term by natural gas, which produces greater emissions than nuclear power. Second, attempts to expand natural gas pipelines have been blocked, which resulted in moratoria on new gas installations downstate. Natural gas provides an economical alternative to dirtier fossil fuels and is a dependable source when renewable sources like solar and wind are not available. Third, while hydro is a key renewable resource, state policies have not supported use of hydro when construction of a new dam is involved, limiting the ability to access additional affordable and clean power from Canada.”
      • I admire the restraint of this section. Calling the policies counterproductive is kind.  The massive hypocrisy of on one hand calling for a response to an existential threat while at the same time shutting down operating nuclear plants begs out to be called stupid at least.  Energy facts undermine the current administration’s irrational war on fracked natural gas which is based purely on emotions.  Throw in the lack of support for hydro and the State’s energy future is not going to go through tough times.
    4. “The focus on other sectors—particularly transportation—is insufficient. The State’s strategy to tackle growing transportation emissions is focused on facilitating expanded use of electric vehicles, which is expensive and challenging for some parts of the state. Furthermore, achieving the long-term goals to cut GHGs by 85 percent will require electrifying almost all heating and transportation, affecting every home and business and nearly every vehicle in the state. This conversion from direct fossil fuel consumption to electric power will necessitate a dramatic further increase in renewable energy supply and energy efficiency: New York State will need to add an additional 94,000 Gigawatt hours of renewables, more than double existing renewable resources. It will also require an expansion of the state’s transmission capacity, which is already constrained from upstate to the downstate area, where most energy is used. The construction of offshore wind facilities will bring more renewable energy directly to the downstate market, but a larger mix of resources, some operating intermittently, will require an expanded transmission grid to deliver power throughout the state.”
      • This paragraph summarizes a fundamental issue with the CLCPA very well. On one hand the State proposes to completely re-make the energy production system while simultaneously increasing our dependency upon reliable power.  The only thing I would add to this discussion is a concern about resiliency.  What happens when everyone depends on electric heat and an ice storm takes out the power lines?

The report introduces the recommendation summary with the following:

While GHG emissions have risen in other large states like Texas and Florida, New York has been a leader in reducing GHG emissions; the focus on further emissions reductions is necessary and important. The challenge now is to find the most efficient approaches to secure the greatest amount of incremental carbon reduction per each dollar spent. Doing so will require tackling emissions across all sectors; maintaining optionality in the approaches used; and partnering with other states and Canada.

        • I take exception to the comment “the focus on further emissions reductions is necessary and important” because the State has never provided its estimates of the effects these policies on global warming potential. By my calculations, the ultimate impact of a 100% reduction of New York’s 1990 218.1 million metric ton of emissions on projected global temperature rise would be a reduction, or a “savings,” of approximately 0.0032°C by the year 2050 and 0.0067°C by the year 2100.  This small a temperature difference cannot be measured.  I don’t accept those changes as necessary and important.

The report offers the following six recommendations:

  1. Establish an economy-wide carbon pricing system to deliver effective price signals to energy consumers. Two options for such a system are: (1) a carbon fee and (2) a cap-and-trade system. To be most effective, these policies should be implemented on at least a regional, if not national, scale, so that dollars are directed most effectively toward the dirtiest energy sources and states. CLCPA tasks the New York State Department of Environmental Conservation with estimating a “social cost of carbon,” that is, a monetary figure capturing the costs of an incremental increase in carbon emissions, an important step for implementing a pricing scheme. New York is already a member of the Regional Greenhouse Gas Initiative (RGGI), an effective 9-state cap-and-trade system covering the electrical generation power sector. To be most effective RGGI should be expanded to other sectors of the economy, including transportation.
    • Carbon pricing has theoretical appeal but in practice I am very pessimistic that the results will work out as planned based on the results of the Regional Greenhouse Gas Initiative. CBC correctly recognizes that carbon pricing should be economy-wide and regional, if not national, to be successful but appears to favor a tax where “dollars are directed most effectively”.  The problem with that is that it is regressive and hurts those least able to afford it the hardest.  Trying to address a regressive tax makes this approach less effective.
    • CLCPA notes that determining a social cost of carbon is part of the CLCPA. Aside from the very real issues associated with that value it is not clear that the social cost of carbon is an adequate price signal for renewable energy development.
    • CBC states that RGGI is an “effective 9-state cap and trade system”. In the first place it is not a cap and trade program it is simply a tax masquerading as a cap and auction   More importantly, it is not particularly effective because I have shown that RGGI itself was responsible for only 5% of the observed reductions since the inception of the program.  Finally, the Accumulated Annual Regional Greenhouse Gas Initiative Benefits table shows that the cost per ton reduced from RGGI investments ($897) are far in excess of the $50 global social cost of carbon at a 3% discount rate.  Because the social cost of carbon is an estimate of the economic damages that would result from emitting one additional ton of greenhouse gas this means that RGGI investments are much more costly than the economic damages.
  2. Look beyond New York’s borders for low-cost, low-emission energy supplies and to cut GHG emissions. New York should explore the possibility of a multi-state buyers’ consortium to purchase large-scale low- and zero-GHG energy resources. New York, New Jersey, Connecticut, Rhode Island, and Massachusetts are all in the process of developing offshore wind energy projects. The states are seeking low-cost electricity, but also vying for jobs from the burgeoning offshore wind industry. Rather than compete, these states should work together to bring the most cost-effective resources to the market. Another opportunity is to import Canadian hydropower, which is competitively priced and clean.
    • No comment – this seems reasonable.
  3. Retain nuclear energy to retain the benefits of carbon avoidance. The state’s nuclear facilities operate with the help of subsidies, known as Zero Emissions Credits, that expire in 2029. If these subsidies are not extended, the nuclear plants may shut down while still holding valid operating licenses. The state should explore further extensions of these operating licenses with the U.S. Nuclear Regulatory Commission. The implementation of a properly priced carbon fee would be a benefit to the nuclear plants, which generate no greenhouse gases.
    • CBC recognizes that if there is a climate emergency then reducing power from the largest source of carbon free electric generation in the state is counter-productive.
  4. Avoid self-imposed constraints such as limiting gas pipeline capacity. A strong preference for renewable energy has resulted in constraints on expansion of natural gas. Denying permits to several natural gas pipelines is constraining energy markets to the point that New York will not be able to reap the GHG reduction benefits of converting home heating from oil to natural gas. Likewise, a lack of stable natural gas supply for new businesses may harm the state’s economic competitiveness. Regulatory and legal actions should not hamper use of resources that can continue to reduce GHG emission and provide reliable energy solutions. New York should create a competitive market of options to reduce greenhouse gases.
    • CBC recognizes that renewable energy implementation for the entire energy sector is a long-term process and that natural gas should be an interim part of the transition or a rational energy plan when the State realizes it cannot afford the CLCPA boondoggle.
  5. Promote broad transportation solutions that build on existing infrastructure. New York has made a large commitment to electric vehicles that will subsidize both car buyers and the construction of charging stations. This is an expensive GHG emissions reduction strategy. Greater emphasis should be placed on one of the areas that has made New York a low GHG-emitting state: energy-efficient public transportation. While a hybrid or electric vehicle produces fewer GHGs than a gasoline powered vehicle, public transportation produces even less per passenger mile traveled.
    • CBC recognizes that the commitment to electric vehicles is expensive and suggest greater emphasis on energy-efficient public transportation. I agree with the sentiment but the problem is what do you do in rural and suburban areas where cost-effective public transportation is out of the question.
  6. Establish a prioritization system to pursue renewables that provide the greatest GHG reductions at lowest cost. Renewables are and must be an increasing part of the state’s energy portfolio; however, policymakers should allow price signals to determine how much wind capacity, distributed solar, utility-scale solar, and hydropower is built rather than mandating specific technologies. All these projects should be put on a common basis of cost to consumer for tons of GHG avoided and those with the lowest net cost should be prioritized for development and contracts. A balanced portfolio of resources and contract term lengths will provide New York with the greatest security and stability to reach its long-term GHG reductions goals. This also will allow for competition from new resources so that if newer projects can be completed at lower cost, New York will reap the benefit. It also allows for the possibility that leaps in technology will be able to fill the mix rather than being locked into old technology for 20 years. New York is now leading the way on greenhouse gas reductions, but it should also lead the way in using competition to provide the greatest emissions reductions at the lowest cost.
    • I agree that spending priorities should be established based on emission reduction cost effectiveness but I think if CBC spent some time looking at the numbers, they would be surprised how expensive these technologies are. I fully support their suggestions to minimize future financial exposure.


The findings support my position that the State needs to do a feasibility study to determine how the CLCPA could be implemented. I will address their renewables analysis in a future post but the spoiler alert is that it requires massive renewable development.  This will require enormous investments and the findings point out the financial and flexibility risks if those investments are funded incorrectly.  They also raise the concern that existing sources of nuclear and hydro zero emitting generating power are not currently encouraged to remain in operation and suggest that discouraging natural gas infrastructure is counter-productive.  The final finding is the observation that there is much work to be done to implement the CLCPA targets for other sectors.  I agree with all these concerns.

The report makes a number of recommendations.   I agree that the State should prioritize investments based on performance, look beyond New York for additional sources of reduction support, eliminate self-imposed constraints on natural gas use, and retain our existing nuclear energy capacity as long as possible.  I do not think that a carbon pricing system will work if it only applies to New York or a limited region so I disagree with their recommendation for one even if it is across all sectors. Their transportation recommendation to think beyond electric vehicles for reductions makes sense where public transit investments could be cost-effective but that precludes rural areas.

Although I am not on board with the CBC’s desire to do something because it is “necessary”, I am encouraged that an organization that feels that is necessary realizes the magnitude of the effort and the very real possibility of massive future financial exposure.  The CBC report underscores the potential that doing something wrong would not be in the best interests of the State no matter how noble the intention.

NYISO Wind Generation Record Publicity

The New York Independent System Operator (NYISO) issued a press release on December 17, 2019 announcing a new wind generation record for the state.  I disagree with the tenor of the press release and this post explains why I think it is inappropriate.  It was a lost opportunity to educate the public about the magnitude of the effort needed to meet the State’s ambitious clean energy goals.

Press Release

The press release stated:

Strong winds across New York State over the weekend pushed electricity generated by wind power to a new record.

The new record output of 1,675 megawatts (MW) was set during the 11:00 p.m. hour on Saturday, December 14, eclipsing the previous record of 1,651 MW which was set during the 8:00 p.m. hour on April 26, 2019.

When overall wind production peaked at 1,675 MW on Saturday night, it provided 11% of all energy generation in New York. The record output represents 84% of the 1,985 MW of installed wind capacity in New York State.

One megawatt is approximately the amount of electricity required to supply 800 to 1,000 homes. Interested parties can track the NYISO’s real-time fuel mix on our website,

In my opinion the press release is thinly veiled propaganda support for the Climate Leadership and Community Protection Act (CLCPA) which includes a requirement to eliminate the use of fossil-fueled electric generation by 2040.  Announcing this record without qualifying the wind resources of New York gives the impression that the State is on track to meet that target.

Right off the bat note that the “record output represents 84% of the 1,985 MW of installed wind capacity in New York State.  Think about that.  The State has invested in wind energy and the best they have done is 84% of the total installed.  Unfortunately, when you look at the big picture serious problems show up.


I used two sources of data from NYISO to evaluate the existing New York wind energy resource.  For an overview I used the annual report that presents load and capacity data including historical and forecast seasonal peak demand, energy usage, and existing and proposed generation and transmission facilities.  The Load and Capacity Date Report or Gold Book is a featured report in the NYISO document library.  This post and a summary I posted in April 2019 use data in Table III-2 Existing Generating Facilities from those reports to describe the annual wind energy resources available.  Note that in 2018 all wind energy came from on-shore facilities.

The NYISO Real-Time Dashboard includes a window for the real-time fuel mix that includes the amount of wind generation being generated in the state.  The window also includes a link to historical data.  I downloaded data for all of 2018, sorted out the wind production numbers, and then calculated hourly averages to compare with the annual numbers from the Gold Book.  I use Statgraphics Centurion software from StatPoint Technologies, Inc. to do my statistical analyses and in this case I loaded the hourly data and calculated frequency distribution statistics.


The NY 2018 Wind Facilities in the NYISO 2019 Gold Book table lists all the New York wind energy facilities.  The NYISO table provides the name plate ratings and 2018 net energy produced.  I used that information to calculate the annual capacity factor for each facility.  Note that there is a wide variation of capacity factors, that the highest is only 35.7%, and the state-wide capacity factor is only 24.5%.  In other words, New York wind facilities only provide a quarter of their name plate capacity.  So in the best hour wind energy has reached 84% of the nameplate capacity and over the year wind energy only produces only 24.5% of the possible power that could be produced.  But wait, there’s more.

Another wind-resource issue is the distribution of the hourly output.  The 2018 Hourly Wind Generation (MW) Frequency Distribution document lists frequency distribution data for all of 2018.  The histogram of wind output categories shows a skewed distribution such that low output is more frequent than high output.  The frequency tabulation for wind table shows that there were 10 hours when none of the 24 wind facilities in the state produced any power and that 32% of the time less than 200 MW per hour was produced.  The percentiles indicate that half the time hourly wind output is less than 346 MW and that for 876 hours (the tenth percentile) wind energy provides less than 49 MW of energy.

If New York has to rely on renewable energy in the future it is important to know the frequency distribution of wind at night when solar output is unavailable.  I used the New York City sunrise and sunset times and calculated when it was dark.  The 2018 Hourly Wind Generation (MW) Frequency Distribution at Night document lists the same statistics as before but only for night time hours.  While there was only one hour with no wind output and the frequency of hours with output less than 200 MW was down to 28% there still is a significant number of hours when there is no appreciable renewable energy being generated. The percentiles indicate that half the time at night hourly wind output is less than 367 MW and that for 876 hours (the tenth percentile) wind energy provides less than 65 MW of energy.  That means that energy storage is going to be absolutely necessary.


I think that the independent system operator has an obligation to the consumers of the state to tell it like it is.  This politically expedient press release did not mention any of the issues associated with wind energy relative to the CLCPA target.  Based on my results I am sure they could have easily found a day when the wind resources were weak.

I have no doubt that NYISO knows about these issues.  They know that the annual capacity factors are low.  I have never seen them publish the distribution of hourly wind output but I have to assume that they have looked at the resource in a similar manner.  I did not think it would be as bad as it is, and these results have important implications with respect to energy storage.  In an earlier post I estimated how much energy storage would be needed for one example period and the costs are startling.

Advocates for renewable power maintain that it is possible to address the problem of calm winds at one location by simply adding facilities in other locations where the wind is blowing.  If that were the case using New York resources the hourly distribution would not show that 5% of the time the total wind energy production for the entire state was less than 24 MW.  Furthermore, I suspect that even expanding the location of wind facilities to off-shore New York and adjoining jurisdictions is not going to significantly reduce the number of hours when wind resources are going to have to be supported by energy storage.  The fact that night time wind generation also shows significant hours with low levels exacerbates the need for energy storage because we cannot use solar to shave the amount needed.

I am very disappointed that NYISO ignored the opportunity to educate the public about the limitations of New York’s wind energy resource.  These results reinforce my position that New York State has to do a comprehensive analysis of the availability of renewable resources to determine a strategy for meeting demand with an all-renewable system.  Until that is complete, we are only guessing whether this can be done, much less how much this is all going to cost.  The NYISO should be pressing for this analysis and this was an opportunity to explain why it is necessary.

Generic Carbon Pricing Issues

The New York Independent System Operator (NYISO) is currently campaigning for its Carbon Pricing Initiative as the preferred approach to meet the requirements of New York’s Climate Leadership and Community Protection Act (CLCPA).  For example, they sponsored a blurb in the Politico New York Energy daily newsletter.  I have written extensively on my issues with the NYISO initiative and this post explains my concerns with carbon pricing schemes in general.

 The NYISO sponsored the following message in Politico New York Energy:

An increasing number of organizations recognize this unique, market-based solution as a viable, scalable option for helping to reduce carbon emissions. The World Economic Forum recently published an article by New York ISO, CEO Rich Dewey, Putting a Price on Carbon Will Help New York State Achieve a Clean Energy Future.

The World Economic Forum, an organization for public-private cooperation, engages the foremost political, business, cultural and other leaders of society to shape global, regional and industry agendas. New York, the 11th largest economy in the world, recently enacted the United States’ most aggressive climate change legislation. The New York ISO’s proposal for carbon pricing would embed a cost per ton of CO2 emissions in the sale of wholesale electricity, creating a price signal for investment in new clean energy resources. Read article.

Carbon pricing theory says that when the price of energy is raised by adding a cost for carbon, the increased costs at the higher CO2 emitting sources of energy will provide incentives to transition to lower or zero CO2 energy sources.  This is supposed to lead to the most cost-effective reductions.  I think that there are a number of practical reasons that carbon pricing will generally not work as theorized: leakage, revenues over time, theory vs. reality, market signal inefficiency, and implementation logistics.  Based on those concerns the NYISO plan is not going to solve anything in NYS.


Leakage refers to the situation when a pollution reduction policy simply moves the pollution around rather than actually reducing it.  Ideally you want the carbon price to apply to all sectors across the globe so that cannot happen.  I don’t think a global carbon pricing scheme is ever going to happen because of the tradeoff between the benefits which are all long term versus the costs which are mostly short term.  I don’t see how anyone could ever come up with a pricing scheme that equitably addresses the gulf between the energy abundant “haves” and those who don’t have access to reliable energy such that “have nots” will be willing to pay more to catch up with those who have abundant energy.

Ultimately, I think that leakage will be a problem for any limited area carbon pricing policy.  Trying to force fit this global theory into the New York electricity market is an even more difficult problem.  As proposed, it will likely result in locational leakage where energy and emissions are not reduced but simply shift emission location within the inter-connected electric grid.   Additionally note that a carbon price on just the electric sector may result in leakage if more consumers generate their own power using unpriced fossil fuel.

Revenues Over Time

A fundamental problem with all carbon pricing schemes is that funds decrease over time as carbon emissions decrease unless the carbon price is adjusted significantly upwards over time.  This problem is exacerbated because over time reducing CO2 emissions becomes more difficult.  It has been observed that roughly 80% of the effects come from 20% of the causes and everyone knows the meaning of low hanging fruit.  This has been observed with regard to New York’s observed CO2 emission reductions to date.  New York electric sector emissions dropped 56% between 1990 and 2016 mostly by retiring old units and fuel switching to lower emitting fuels.  It can be argued that those reductions would have happened anyway because retirements and fuel switching were lower cost options without even considering CO2 emissions.   Furthermore, I believe that air pollution control costs increase exponentially as efficiency increases which makes this issue even more problematic.

This difficulty should be even more of a concern with CO2 emission reductions because at some point replacing existing fossil-fired generation not only has to consider the direct power output conversion costs but must also address dispatchability and grid support costs.  When those costs are included there will be a sharp increase in total costs per CO2 reduced.  Like many others, the NYISO Carbon Pricing Initiative proposes to use the social cost of carbon (SCC) as the carbon price.  The SCC cost increases over time but the costs over time do not increase enough in my opinion to keep pace with the necessarily more expensive total costs to maintain reliable electricity to consumers.

Theory vs. Reality

Another problem with carbon pricing theory is that in practice affected sources may not act rationally or as theory expects.  The Regional Greenhouse Gas Initiative (RGGI) is a market-based carbon pricing program and I have written extensively on it.  The academic theory for RGGI market behavior is that affected sources will treat allowances as a storable commodity and act in their own best interest on that basis.  If that were true affected sources would be purchasing allowances for long-term needs and “playing” the market to maximize earnings.  In practice RGGI affected sources plan and operate on much shorter time frames and have shown no signs of making compliance obligations a profit center.

Carbon pricing theory claims that when the cost of using higher emitting energy increases that will provide incentives to develop alternatives and discourage continued use of existing resources.  However, these incentives are indirect and again assume rational behavior in the market.  While theory says that a company that currently operates a fossil-fired plant will change its business plan and develop a renewable energy facility to stay in business, there are a whole host of reasons why the company may not go that route and instead treat the carbon price as a tax and continue to operate with that constraint.  In my opinion RGGI did not induce any NYS companies to change their business plans.

Market Signal Inefficiency

I am also concerned because the carbon price signal is an indirect inducement for emission reductions. CO2 emission reduction efficiency is an issue based on New York’s experience in RGGI.  The New York State Energy Research and Development Authority (NYSERDA) report New York’s RGGI-Funded Programs Status Report – Semiannual Report through December 31, 2018 (“Status Report”) describes how New York invested the proceeds from the RGGI auctions.  That report lists the many programs that are funded using RGGI proceeds as shown in Table 2 Summary of Expected Cumulative Annualized Program Benefits through December 31, 2018. There are six program categories: Green Jobs – Green New York, Energy Efficiency, Renewable Energy, Community Clean Energy, Innovative GHG Abatement Strategies, and Clean Energy Fund.

I combined the data for the six program categories in the Consolidated Summary of Expected Cumulative Annualized Program Benefits through 31 December 2018 table.  It summarizes the emission reduction benefits and costs for those categories.  The cost per ton reduced ratio ranges from $167 to $3,437.  At the high end the GHG Abatement Strategies category emphasizes long-term research and development.  Because this research could lead to a cost breakthrough this funding can be justified.  Looking at the other categories it appears that the more investments are focused on direct reductions rather than indirect investments the better the cost benefit ratio.  For example, the best ratio ($167 per ton removed) is in Community Clean Energy and that category includes direct support for renewable energy projects.   The Energy Efficiency category is an example of indirect support because investments in this category do not directly reduce emissions.  Instead the investments reduce energy use which reduces the need for energy production and indirectly reduces emissions.  However, the cost per ton removed, $425, is markedly higher than the best category.

Theory says that the carbon price alone can incentivize lower emitting energy production and that the market choices will be more efficient than government mandated choices. However, as a result of these observations, I do not think that carbon pricing schemes, like the NYISO initiative, that raise the cost of energy and do not include specific funding aspects will work as efficiently in the short term and in limited markets like New York as theory suggests.  There are risks involved so who is going to make the investments and when will they make investments?

Implementation Logistics

Finally, I believe that there are significant logistical issues associated with carbon pricing that the NYISO process has simply ignored.  In order to set a carbon price, you have to know what the carbon emissions are for every source providing energy to the market.  For a global all-sector pricing scheme, you could set the price as the fuel is produced so that everyone pays the cost all the way through its end use.  On the other hand, the NYISO has to set the price as electric energy is sold on a real-time basis.  That is a non-trivial problem.  In New York, NYISO knows which generator is running and has a pretty good idea of their emission rate.  However, the final emission numbers are not available real-time because the emission values reported to prove compliance are not finalized until quality assurance post processing is complete and that can be months after the fact. The more significant problem is that NYISO has no way to calculate imported electricity carbon emissions on a real-time basis so cannot assign a carbon price value that accurately reflects how imported electricity is being generated.  These issues have been glossed over to date.


The NYISO claims that “An increasing number of organizations recognize this unique, market-based solution as a viable, scalable option for helping to reduce carbon emissions market-based solution”.  I frankly don’t think those organizations have had actual experience with a carbon pricing initiative logistics and have not evaluated whether the carbon prices proposed will provide the market signals necessary to spur the necessary renewable development needed to meet any CO2 emission reduction goals as a viable, scalable option for helping to reduce carbon emissions for the CLCPA.

The success of any carbon pricing scheme boils down to the question whether the carbon price set will provide enough of an incentive for projects that produce emission reductions that displace today’s generators and eventually covers the costs to provide the dispatchability and grid support functions provided by today’s generation mix. There are no estimates that this will be the case for the NYISO initiative.

In my opinion, NYISO carbon price initiative support is based on parochial interests.  In the case of NYISO they appear to believe it will simplify the cost accounting for New York’s renewable implementation efforts.  I think they have under-estimated the difficulty implementing the infrastructure necessary to accurately track the price of carbon and have ignored the potential that the complex scheme needed to reduce leakage will lead to unintended consequences.  Other support appears to be based on the potential to make money and it is not clear that is in the best interest of the State’s desire to reduce CO2 emissions as cost-effectively as possible.

The more I study the practical implementation of carbon pricing schemes the more skeptical I become.  I think that there are a number of practical reasons that carbon pricing will not work as theorized.  Because a global program is impractical, leakage is always going to be a problem.  The carbon price has to be set such that revenues over time increase significantly.  The economists who support this theory seem to be blissfully unaware of the reality of the energy market. Based on observed results I think that indirect market signals are going to lead to less cost-effective reductions in the time frame necessary for the aggressive reduction rules.  Finally, no supporters seem to understand the very real problems of implementation logistics.

Update December 30, 2019:  Please check out the companion post describing additional problems with carbon pricing raised by Paul Homewood at Not a Lot of People Know That blog.

NYISO Winter Peak Analysis Implications to CLCPA

A new report prepared at the request of the New York Independent System Operator (NYISO) addresses issues associated with an electric system reliant on renewable energy sources during the winter.  This post compares these results with my previous work related to New York’s Climate Leadership and Community Protection Act (CLCPA) and discusses the implications on that law.

The Citizens Budget Commission developed an overview of the CLCPA targets in Green in Perspective: 6 Facts to Help New Yorkers Understand the Climate Leadership and Community Protection Act.  The goals of the law are truly aspirational:

Reduce greenhouse gas (GHG) emissions:

      • Reduce GHG emissions to 60 percent of 1990 emissions levels in 2030;
      • Generate zero GHG emissions from electricity production by 2040; and
      • Ensure GHG emissions are less than 15 percent of 1990 emissions levels in 2050, with offsets to reduce net emissions to zero.
      • GHG offsets means that for every ton emitted into the air one ton is removed via GHG capture of some sort. For example, a company or individual can pay a landowner to leave trees standing that would otherwise be removed or plant additional trees to offset GHG emissions.

Increase renewable electricity:

      • Increase renewable sources to 70 percent by 2030; and

Develop or support:

      • 9 gigawatts (GW) of offshore wind electric generation by 2035;
      • 6 GW of distributed photovoltaic solar generation by 2025; and
      • 3 GW of energy storage capacity by 2030.
      • Conserve 185 trillion British thermal units (TBTUs) of annual end-use energy use by 2025, of which at least 20 percent should be from energy efficiency improvements in disadvantaged communities.
      • The CLCPA also requires between 35 percent and 40 percent of spending on clean energy or efficiency programs be in disadvantaged communities and mandates an air monitoring program in at least four such communities.

I have evaluated winter peak impacts in previous posts on New York Resource Adequacy Proceeding Comments, Solar Issues in Upstate New York , CLCPA Solar and Wind Capacity Requirements and CLCPA Energy Storage Requirements.  My primary concern is the requirement to generate zero GHG emissions from electricity sector production by 2040 coupled with the increased load needed to electrify the heating and transportation sectors enough to meet the 85% reduction by 2050 target.

Fuel and Energy Security In New York State Report

NYISO  had the Analysis Group do a forward-looking assessment of the fuel and energy security of the New York electric grid during winter operations.  The November 2019 final report was titled: Fuel and Energy Security In New York State: An Assessment of Winter Operational Risks for a Power System in Transition.  The objective was to assess winter fuel and energy security risks and identify key factors that would affect risks. Specifically, the study targeted potential reliability risks and impacts under severe winter conditions and adverse circumstances regarding system resources, physical disruptions, and fuel availability.  Importantly it is a snapshot of the winter of 2023-2024 before the CLCPA renewable energy and electrification of other sectors implementation really kicks in

Previously I have analyzed the effect of winter peaks and I chose 12/29/17 to 1/12/2018, a period that is included in their analysis.  The Analysis Group defined extreme weather events including the largest increase above average daily load over a long period as 14 days from 12/25/2017 to 1/8/2018 and more extreme shorter periods where they found in the last 25 years the fourth lowest 3-day cold snap was 1/4/2018 to 1/7/2018.  Then they evaluated different scenarios that included different combinations of “(a) timeframe for the development of new renewable resources; (b) capacity imports from neighboring regions; (c) potential retirement of units affected by the peaker rule; and (d) availability of natural gas for power generation”. The evaluation determined where these scenarios might cause problems.

The analysis included the following relevant conclusions (two key points underlined by my emphasis):

    • With the continued operation and availability of most of the assets currently expected to be in place in the winter of 2023/2024, the NY grid contains sufficient diversity and depth of fuel supply to support reliable winter operations. This result is consistent with the historical operating experience in recent past winters, including during severe weather conditions.
    • Meeting the state’s renewable and clean energy goals can provide valuable reliability support, and may be particularly true with respect to offshore wind. Delayed realization of renewable resource additions (as compared to the 2017 CARIS Phase 1, System Resource Shift case levels that are assumed under initial conditions) can lead to potential LOL events that would not otherwise occur when combined with other adverse system conditions. The potential magnitude and pace of change to the resource fleet stemming from requirements under the CLCPA may be of far greater importance for evaluation than the considerations, scenarios and physical disruptions evaluated in this fuel and energy security study with respect to winter operational risks.
    • The availability and contributions of adequate levels of natural gas-fired and oil-fired (or dual fuel) generating resources is necessary to maintain power system reliability in cold winter conditions in the near-term. This is particularly true for Long Island and New York City. Simply put, avoidance of potential loss of load events in these load centers, under plausible adverse winter conditions, requires operation of natural gas and oil-fired units. Reduction in the generation available from such resources – whether through capacity retirements, low initial oil inventories, reduction in natural gas availability for power generation, or interruptions in the ability to refuel oil tanks throughout the winter represents the most challenging circumstances for reliable winter system operations in New York over the coming years.

Implications for CLCPA

The analysis notes that the “potential magnitude and pace of change to the resource fleet stemming from requirements under the CLCPA may be of far greater importance for evaluation than the considerations, scenarios and physical disruptions evaluated in this fuel and energy security study with respect to winter operational risks”.  I agree because I believe that it is absolutely necessary for the State to prove that when the energy load increases when other sectors are electrified that fuel and energy security can be maintained without using fossil fuels.

The analysis also states that “Simply put, avoidance of potential loss of load events in these load centers, under plausible adverse winter conditions, requires operation of natural gas and oil-fired units”.  The CLCPA requirement that all electric energy must come from non-fossil fired sources in 2040 is an extraordinarily difficult goal to meet.  The political calculus to include this in legislation was not backed up by any analysis.  The state has to show how this can be done as soon as possible lest New York resources be squandered on an impossible quest.  As I show below, the actual renewable resource may not support this target because of logistical issues and even if it does there may be immense costs.

Need for Renewable Energy Resource Analysis

In my back of the envelope analysis of the summer peak energy storage requirements I used actual wind speed data to estimate the New York off-shore wind resource.  New York State awarded the first two contracts for off-shore wind projects in July 2019.  The Equinor 816 MW winning project press release said “The project is expected to be developed with 60-80 wind turbines, with an installed capacity of more than 10 MW each”.  Among the many details redacted in the public version of their proposal was specific information on the proposed wind turbines.  The public version included a diagram of the proposed wind turbine size as compared to the Chrysler building and showed that top tip of the blade at 250 m.  I estimated the hub height to be 173 m by scaling the drawing.  In this analysis I characterized wind energy output as a function of observed wind as follows.   I found a wind turbine power output variation curve that had a cut-in speed of 3.5 m/s and a cut-out wind speed of 25 m/s. Using that wind variation curve, I estimated that output of each 10.2 MW wind turbine will equal 0.971 times the wind speed minus 3.4.

For the input meteorological data, I found a National Oceanic and Atmospheric Administration buoy located 30 nautical miles south of Islip, NY (40°15’3″ N 73°9’52” W) that I used to represent NY offshore wind resource availability. The observed wind speed at the hub height is proportional to the logarithm of the height above ground.  For that calculation I assumed a hub height of 173 m and a surface roughness of 0.0003 using the buoy anemometer height of 4.9 m. I downloaded hourly NDBC data for 2018 and 2017 and calculated the wind energy output for every hour in the period 12/25/2017 to 1/8/2018 using that relationship and the wind turbine output variation equation I derived.

The key finding is that there were two no wind energy output periods on 3-4 January 2018 during an intense cold snap when electric load is high as shown in the New York Off-Shore Wind Generation Estimate for 9000 MW CLCPA Off-Shore Target table.  I was surprised to see that the wind resource went to zero during a high load period not only when the winds were light on January 3 but also when a deep low pressure developed and the wind speeds exceeded 25 m/s on the very next day.  The wind generation estimate table lists the output from a single 10.2 MW wind turbine, 80 turbines in the Equinor proposed wind facility and for all 9,000 MW of Cuomo’s CLCPA target of 9,000 MW of off-shore wind.  It is important to note that adding even more wind turbines still does not preclude the need for substantial energy storage.  While all the New York off-shore wind resource may not go to zero simultaneously that resource is going to be highly correlated across the available area so they all will track closely.


Every time I look at the meteorological data relative to the winter peak I get a surprise.  I expected that the winter observed peak load would occur during very cold weather associated with a slowly moving high pressure system that originated in the cold northern plains large enough to cover the entire northeastern US.  The resulting multi-day period of clear skies, light winds, and inherent cold temperatures would result in very high energy demand for heating.  The early January 2018 high load period was very different.  Weather maps for this period show (January 2018 Weather Maps) a relatively small high pressure system in the central US on January 2 that moved east ahead of a storm system on January 3.  The high pressure was strong enough over the New York offshore wind region that winds were less than 3.5 m/s for five hours on January 3.  However, the storm system moved eastward and re-developed into a strong storm just off the coast on January 4 with an eleven-hour period of greater than 25 m/s wind speed 13 hours after the light wind period ended.  By January 5 the storm had raced northeast to the Canadian Maritimes but was pumping cold air back across New York State.

This period must be analyzed in more detail by New York State to determine whether the CLCPA requirements endanger fuel and energy security.  If the assumptions I used for no wind power due to light winds and strong winds are correct then there will be 16 hours of no wind power in a 29-hour period during the coldest extended duration cold weather event that the Analysis Group identified after analyzing 25 years of data.  Furthermore, it also overlaps fourth worst 3-day cold snap.  The State needs to estimate what the future load will be when the home heating and transportation sectors are electrified to meet the CLCPA emission reduction goal and then assess whether renewable resources will be adequate during the entire extended duration period using the proprietary energy output information in the renewable energy proposals submitted to the State not only in the NYSERDA off-shore wind program but also the Article Ten applications.  This analysis has to be done for the entire state and obviously will lead to an estimate of the amount of energy storage necessary in 2040 when no electric energy from fossil-fired facilities is allowed.  It is not clear to me if there is enough space available where it is needed to site all the renewable and energy storage necessary.  Even if there is enough space, this analysis will provide the information needed to estimate how much all this will cost.

Frankly, it is laughable that the New York State legislature and Governor Cuomo enacted a law mandating specific energy and emission reduction goals without doing such an analysis first.  I believe it is time for the energy professionals in the State to step up and demand such an analysis before the State squanders money on a system design that can only be implemented with massive wind, solar and energy storage development.  Even if this system could be developed it will surely be expensive.  Just how much is anyone’s guess until such a study is completed.

CLCPA Renewables Needed for Doubled Electric Load

The Brattle Group recently released a report entitled “Achieving New England’s Ambitious 2050 Greenhouse Gas Reduction Goals Will Require Keeping the Foot on the Clean Energy Deployment Accelerator”.  The primary emphasis of this blog is on New York environmental and energy policy issues so this post applies their renewables needed estimate to the New York’s Climate Leadership and Community Protection Act (CLCPA) requirements.

In particular, the Brattle report notes that in order to reduce greenhouse gas emissions from the whole economy it will be necessary to electrify transportation and heating which will increase electric load.  They estimate that in order to meet New England’s goal of an 80% reduction by 2050 that electricity demand could be “twice the current level by 2050”.   I have yet to see any New York agency estimate of future load for the CLCPA so I decided to try to estimate how much renewable energy would be needed if New York electric load doubles by 2040 at the same time that New York electric load is supposed to eliminate fossil-fired generation.  I used that estimate to estimate how much renewable energy capacity (MW) in the form of on-shore wind, off-shore wind and solar could be needed in New York in 2040.  I determined how much power (MWh) was used in 2018, doubled that, and then guessed how the necessary capacity could be distributed between on-shore wind, off-shore wind and utility solar.

Brattle Key Findings

The Brattle Group prepared their report on behalf of the Coalition for Community Solar Access.  According to the news release there were several key findings:

      • Electricity will play a critical role in decarbonizing the New England economy. As a result, electricity demand will grow substantially and could well be twice the current level by 2050.
      • In supplying this growing demand for power, both solar photovoltaic (PV) and offshore wind will likely play a critical role.
      • Merely maintaining the current rate of clean energy resource deployment will cause the region to fall short of its targets. Currently planned clean energy resource generation for 2019–2030 in New England amounts to approximately 830 MW per year. This represents a significant increase from the historical generation of 280 MW per year from 2010–2018.
      • However, to achieve the 2050 targets, New England will need to accelerate clean energy resource additions to between 4 and 7 GW per year on average between 2021 and 2050.
      • To reach these levels, annual clean energy resource additions will need to continue to grow by approximately 9% per year through 2050.


The first step is to determine how much generation was used in 2018.  I used the 2019 NYISO  Load & Capacity Report “Gold Book” Summary of Table III-3c 2018 Annual Net Energy Generation by Zone and Type to estimate 2018 energy generation by generator type and I have included a consolidated summary of data by fuel type.  Note that fossil fuel accounted for 41.9% of the generation in 2018.  Total load was 135,585 GWh so a 2040 doubled load will equal 271,170 GWh.

Estimating the feasibility for future development scenarios is difficult.  The Projected Net Energy Generation in 2040 table lists the assumptions I made to determine how New York generation could meet the doubled load.  There are three main components of the response: expand output from pumped storage and conventional hydro, maintain nuclear, and expand renewable combustion (landfill gas and municipal waste incineration); reduce load through energy efficiency, tighter codes & standards, behind-the meter (BTM) distributed solar and BTM non-solar distributed generation; and utility scale on-shore wind, off-shore wind and solar.

In the first component I estimated future generation as a function of fuel type.  The CLCPA law requires that all fossil-fired electric generation be replaced by 2040 so I zeroed out potential generation in those categories.  Although I have seen claims that additional hydro generation can be developed, I doubt that those resources could ever exceed a 10% increase over current levels.  In 2040 I estimated that only Nine Mile 2 nuclear would be operating because all the other nuclear generating stations would be over 60 years old.  The renewable combustion category includes internal combustion from landfill gas as well as wood and refuse fired steam generators.  I assumed that those resources could only increase 10% over current levels.  The result is that Component 1 can only cover 18.4% of the estimated load.

Reducing energy use through energy efficiency, improvements in codes and standards for energy use, behind the meter solar, and behind the meter non-solar distributed generation will reduce the amount of energy needed in Component 2.  Table I-b: Summary of NYCA Annual Energy Forecasts in the Gold Book lists GWh projections for these categories in 2040. The Gold book also includes tables that provide the net energy and the estimated capacity for each of these categories.  Since the publication of the 2019 Gold Book, the distributed solar deployment target was increased to 6,000 megawatts by 2025, up from 3,000 megawatts by 2023.  I adjusted my projection for that by assuming 6,000 MW in 2025, that observed energy per capacity would remain the same and that the annual increase after 2025 would be the same as the Gold Book projection.  Instead of 5,928 GWh from 4,525 MW of distributed BTM solar I estimate 9,847 GWh from 7,517 MW in 2040. The result is that Component 2 can only cover 13.6% of the estimated load.

The last component of the expected load is utility-scale wind and solar. On the basis of the assumptions for components 1 and 2, these resources will have to provide 68% of the load or 184,285 GWh.  In my opinion, this requirement will lead to a large increase in imported generation but if we assume that is not the case, this will require a massive buildout of large renewables.  In round numbers this buildout will require development of 9,214 GWh of generation output per year as shown in the Projected Renewable Energy Resources Needed to Meet Doubled Annual Electric Load in 2040 table.

In order to determine how much capacity will have to be developed to generate that much energy capacity factors have to be used.  In 2018, 1,739 MW of on-shore wind produced 3,985 GWh of net energy and 32 MW of utility solar produced 49 GWh of net energy.  Those observed values can be used to determine an on-shore wind capacity factor of 26% and a utility solar capacity factor of 17%.  I assumed those capacity factors for 2040.  Off-shore wind capacity will be developed by 2040 and I assumed a capacity factor of 50% based on the NYSERDA assumption for its recent awards. Using those capacity factors, I arbitrarily picked an annual development rate to meet the 9,214 GWh annual rate target.  I calculated that 1,050 MW of on-shore wind, 1,500 MW of utility solar and 1,050 MW of off-shore wind which will generate 9,293 GWh additional energy per year which exceeds the target development rate.

Sanity Check

One question is whether my arbitrary future renewable energy choices are reasonable.  I compare those numbers to an earlier wind analysis and NYS announced projects below.

The National Renewable Energy Laboratory sponsored the Eastern Wind Integration and Transmission Study (EWITS) and that report includes an estimate of future NY wind requirements.  The study was designed to examine the operational impact of up to 20% to 30% wind energy penetration on the bulk power system in the Eastern Interconnection of the United States. It included development of a database of wind resource and plant output data for the eastern United States.  One of the scenarios modeled 30% penetration of wind energy into the total energy consumed.  The scenario was labeled “Aggressive On- and Offshore” and required “a substantial amount of the higher quality wind resource in the NREL database” and noted that a “large amount of offshore generation is needed to reach the target energy level”.  The total wind capacity projected for the New York State Independent System Operator to meet a 30% penetration level was 23,167 MW of on-shore wind and 9,280 MW of off-shore wind.  The total on-shore wind capacity projected for the arbitrary choice is 20,000 MW and that compares well with the EWITS value, but the arbitrary choice for total off-shore wind is 23,000 MW more than double the EWITS value.

Another sanity check is to compare the annual generation development predicted with the queue of New York Projects.  In New York all utility scale projects over 25 MW are required to go through an Article 10 review process.  As part of that process all the projects in the review queue are tracked.  The New York State Department of Public Service Article Ten Project Queue table lists the MW capacity for projects summed by technology proposed categories and the year the permitting process began.  In the best year 1,478 MW if wind projects started permitting and in 2019 to date there have been 3,193 MW of solar and solar plus storage projects have started permitting.  Therefore, it appears that my guess that 1,050 MW of on-shore wind and 1,500 MW of utility solar development per year is possible.


The Brattle estimate for the additional energy needed to power all the electrification necessary to reduce CO2 emissions in New England by 80% is double the current load.  Thus, when New York State gets around to proposing how much energy might be necessary for the CLCPA, it is not unreasonable to expect that it will be at least two times the current amount.

At some point the intermittent and diffuse nature of renewables will have to be addressed.  Because renewables are intermittent, storage to cover light winds and low solar irradiance will be required.  Because they are diffuse transmission links to move the power as needed are also required.  As a result, the renewable generating facilities will not only have to replace existing fossil-fired dispatchable load but also provide support to the transmission system that is currently provided by those facilities.  I believe that will add to the amount of renewables needed.

When New York State gets around to proposing how much energy might be necessary for the CLCPA, it is not unreasonable to expect that it will be at least two times the current amount.  The wild guess estimate of the renewable capacity does not appear to exceed any feasibility threshold but there are some caveats.  For all components of the proposed response the problem of diminished returns on investment cannot be dismissed.  For example, it is not unreasonable to expect that the best on-shore wind development sites will be developed first and may in fact be already developed.  Consequently, later developments are going to have to go to sites with a lower potential wind resource so the capacity factor for future developments will be reduced.  The same problem should be expected for distributed solar, utility solar, and energy efficiency investments.

There are other issues of course.  First, and foremost, is cost.  There are also logistical issues developing this much renewable energy over this time frame.  Finally, note that given that the expected lifetime of these renewable projects is on the order of 20 to 25 years, there will be an eventual de-commissioning and re-development steady-state of constant investments required forever in the future.

October 28 2019 Buffalo NYS Public Participation Workshop on Regional Approaches to Climate and Transportation

On October 28, 2019 I attended the Buffalo NYS Public Participation Workshop on Regional Approaches to Climate and Transportation.  As I promised previously this post describes the meeting.

My over-whelming impression of this meeting is that the NYS Department of Environmental Conservation (DEC) and Department of Transportation (DOT) staff supporting the effort to develop a low-carbon transportation future believe that their public stakeholder process represents the will of the people.  I disagree with this characterization because my definition of “public” refers to society as a whole.  This stakeholder process has been confined to a limited and biased subset of the people based on my attendance at three meetings.  Please consider submitting a comment asking for costs which I think is the primary concern of the “public”.


According to the Transportation and Climate Initiative webpage:

“The Transportation and Climate Initiative (TCI) is a regional collaboration of 12 Northeast and Mid-Atlantic states and the District of Columbia that seeks to improve transportation, develop the clean energy economy and reduce carbon emissions from the transportation sector. The participating states are: Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Vermont, and Virginia.”

This meeting was part of New York’s response to the TCI and a component of the response to the state’s Climate Leadership and Community Protection Act (CLCPA).  In order to meet the “most aggressive” climate law transportation controls are needed on the sector because as shown in the New York State GHG Emissions 1990–2016 table it is has the most emissions of any sector.  Moreover, because the CLCPA is now the law DEC and DOT have to come up with a plan to make reductions from the sector.

The invitation to the meeting described the purpose and provided links to background information:

“The State Departments of Environmental Conservation (DEC) and Transportation (DOT) and the New York State Energy Research and Development Authority (NYSERDA) are conducting public outreach to inform New York’s participation in a multi-state initiative to reduce greenhouse gas emissions from the transportation sector with the Transportation and Climate Initiative (TCI). DEC, DOT, and NYSERDA are seeking input from the public regarding New York’s potential participation in a regional program designed to reduce emissions, boost the economy, improve public health, and achieve fair and equitable outcomes for underserved communities and transportation-related businesses.”

“The states participating in the Transportation and Climate Initiative have released a framework for a draft regional policy proposal to reduce greenhouse gas emissions from transportation and are seeking public feedback. The framework can be reviewed at We invite the public to submit input to the TCI portal at Background materials are available at”

“In addition, DEC, DOT and NYSERDA are conducting public meetings to better understand various perspectives on New York’s potential participation in a regional policy. The agencies will also seek input on alternative or complementary strategies to reduce emissions from transportation.”

“Additional information is available on the DEC website  Questions can be directed to”


The agenda for the workshop that I attended had two main components.  After opening remarks that introduced speakers and introduced the topics, the first main component was “Key Elements of a Potential Regional Approach to Transportation and Climate”.  After a break the second component was a “Discussion on Investment Opportunities”.  The meeting ended with “suggestions, reflection and next steps”.

The description of the cap-and-invest program described their current thinking.  At this time, they plan to regulate state fuel suppliers of gasoline and on-road diesel.  That means the tank farms where distributors provide gasoline and diesel fuel that is sent to retail outlets will have to participate in the trading program.  They are doing analyses to determine the cap level and, as I understand it, the costs necessary to fund control programs to determine the rate of reductions that will be proposed.  Frankly, the lack of specificity for this aspect of the proposed framework is troubling and this meeting provided no details.

My primary interest in the meeting was the discussion of the multi-state process to develop a potential cap-and-invest program.  I have been involved with emissions marketing pollution control programs since 1990 and the Regional Greenhouse Gas Initiative (RGGI) since its inception over ten years ago so I wanted to see what they are thinking in the first half of the meeting.  In my opinion the proponents of a transportation cap-and-invest program overlook many of the lessons of RGGI.  Because they have to do something I took the opportunity to make the following suggestion for doing what I think will be least destructive and costly:

I think you should just go with a carbon tax rather than trying a cap and dividend program for the following reasons:

      • In the TCI framework the affected sources are state fuel suppliers.  They have no real stake in compliance with the cap and minor options to directly meet the cap. All they will do is sell fuel up to the cap limit and tack the price they paid for allowances onto the price they sell to fuel retailers.
      • RGGI was a cap and dividend program and it did not work out as well as many believe. Per the 2017 proceeds investment report that came out earlier this month, of the observed RGGI emission reductions less than 5% were directly attributed to dividend investments
      • The observed cost per ton of CO2 reduced was $897 – far higher than the social cost of carbon.
      • Logistically there is a cost issue. As reductions are made the amount of fuel sold will go down so the dividend proceeds will also go down.  How can you maintain the funding to keep up the rate of reductions needed?
      • I also worry that there will be cost increases related to the cap and dividend program that will increase cost to customers that will not be passed on as dividends to the public.

The second half of the meeting focused on the question “How could the proceeds from a cap-and-invest program promote cleaner transportation, improve public health, create economic opportunities, and enhance mobility?  While it is nice to come up with a list of possible investment projects such a list does not consider practicality and cost so I see little value in the exercise.  Faced with a two and a half hour ride home I left the meeting at the break.


As noted in the introduction my overall impression with this process is that the organizers and administrators truly believe that their public stakeholder process is representative of the “public”.  I disagree with this characterization because my definition of “public” refers to society as a whole and I have seen no indication that this topic has not been confined to a limited and biased subset of the public who have vested interests in transportation planning.  I base this impression on the three meetings I attended.

I went to the Georgetown Climate Center listening session in Albany, NY on April 9, 2018.  I don’t believe that there was public notice of the meeting because I got a call from NYS Department of Environmental Conservation Deputy Commissioner Jared Snyder asking why I wanted to attend.  He was clearly surprised that I knew about the meeting.  After assuring him that I would behave, I was allowed to attend.  When I showed up at the meeting, where I expected to be the only member of the public, I was surprised how many members of environmental organizations were present in addition to the regulatory agency people.   Whatever the motivation to check my rationale to participate, this was not an event that the general public knew about.

New York had its own listening sessions  to help advance a cleaner, safer, and more reliable low-carbon transportation future in the summer of 2018.  I attended the Central New York session on August 21, 2018.  The meeting was “designed to engage stakeholders with diverse interests and concerns in discussion of the economic and social considerations for deploying clean transportation options, opportunities to enhance environmental and public health benefits through a modernized transportation system, how innovative, low-carbon transportation can enhance quality of life and boost economic competitiveness, and what policies and programs may help advance a clean transportation future”.  Notice for this meeting was provided in the NYS DEC e-mail distribution system and there was a press release, so the general public as a whole might have had the opportunity to hear about the meeting.  However, attendance at the meeting was limited to members of environmental organizations, staff from transit agencies in the region, other people with a vested interest in a clean transportation future, and me.

Because the Buffalo meeting did not include an opportunity to formally meet people and the attendance list was not published, I don’t know the background of the attendees.  However, the people I did know were mostly agency staff so at least a third were there as part of their job.  The meeting was hosted by PUSH Buffalo whose mission is “to mobilize residents to create strong neighborhoods with quality, affordable housing; to expand local hiring opportunities; and to advance economic and environmental justice in Buffalo”.  As a result, I think that the majority of the rest of the audience were in that demographic or environmental organizations.  I do believe that there were some industry people in attendance but did not hear from any of them while I was at the meeting.

Therefore, I think it is presumptuous to say that these meetings provide engagement from the public, which I define as including anyone outside the wonky world of future transportation policy especially as it pertains to environmental justice.  Moreover, the format of these meetings was more about “what are the things we can do for clean transportation options” than “how can we implement these options and at what cost?”.  None of the meetings I attended addressed implementation issues, feasibility concerns, or potential costs.

Public Involvement

Roger Pielke Jr.’s Iron Law of Climate Policy states that “while people are often willing to pay some price for achieving environmental objectives, that willingness has its limits”.  I find it difficult to believe that the modeling mentioned at this meeting and described on the TCI webpage has not generated an estimated cost per gallon of fuel.  I believe that is an over-riding concern of the public so I suggest that asking for that information is entirely appropriate.

I think it is very important that residents of Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Vermont, and Virginia submit input to the TCI portal at   All you have to do is go to that link, fill out a few questions and then you can share your input with the Transportation and Climate Initiative.  I think a comment as simple as “I am concerned about the cost of this initiative and would like to know the expected cost increase to a gallon of gasoline.” from members of the public and not just the folks who go to these meetings would be effective.  By all means please consider making more extensive comments but the more people who ask for the costs the better.  New Yorkers could also send an email to asking for the expected cost.  I am not saying that they won’t ignore the request but at least they will be on notice that the public worries about the cost.

Final Note

By the way I did wear my yellow vest so I may go down as the first such protester at a NY meeting.  I did not go out of my way to get a reaction from the meeting attendees but I did make my point.  Over the years I have made the acquaintance of many people at DEC including Deputy Director Jared Snyder and now retired DEC climate advocate Lois New.  I got to the meeting early and had a chance to make sure they understood I was wearing the vest because I think yellow vest protests are inevitable.  Their reaction was a mixture of amusement (curmudgeon Roger is joking around again) and amazement (I don’t think that either Jared or Lois have contact with very many people who don’t agree with their views on climate change so this kind of confrontation surprised them.)

NYS Public Participation Workshop on Regional Approaches to Climate and Transportation

On October 28, 2019 I attended the Buffalo NYS Public Participation Workshop on Regional Approaches to Climate and Transportation.  I wore a yellow vest to the meeting because I believe that the policy suggested at the workshop will inevitably lead to prices that will be unacceptably high.  I also made up a handout if anyone asked about the yellow vest and that included a link to my posts on the Climate Leadership and Community Protection Act (CLCPA) page where I have posted this expanded version of the Handout DEC Workshop on Regional Approaches to Climate and Transportation.  I will post on the meeting itself later.

There have been multiple instances where expensive climate policies were the initial spark to protests that expanded in scope to cover more issues.  The French “Yellow Vest” movement was triggered in November 2018 when fuel prices were raised.  In October 2019 protests started in Chile when subway fares were increased.  The evidence in this post and my handout suggests that a similar protest could occur in New York as the 2030 requirement to reduce greenhouse gas (GHG) emissions to 60 percent of 1990 emissions levels in 2030 included in the CLCPA legislation is implemented.

The New York State GHG Emissions 1990–2016 table lists historical GHG emissions in New York.  The State has yet to provide a plan to meet the requirements of the CLCPA.  One way to meet the 2030 emission target in ten years would be to require all these sectors to reduce their 2016 emissions 30%.  While the ultimate plan probably will require different amounts from each sector the final strategy’s reduction requirements probably will not vary too much from 30% each.

I only considered the transportation sector in my handout.  The ultimate strategy to meet the CLCPA goals will have to specify options for each component of the transportation sector.   In order to meet a 30% reduction goal from this sector the plan could call for 30% electric vehicle conversions of each of these registration categories in the New York State Dept of Motor Vehicles Registrations in 2016 table.  For the standard registration category that means that we would need 2,844,099 electric vehicles on the road by 2030.  According to the NYS Energy Research & Development Authority (NYSERDA) there are 58,278 electric vehicle registrations in the state as of June 2019 and 35,296 were registered since January 2017.  As a result, we need to have 2,808,803 more electric vehicles to meet the 30% reduction goal and sales would have to average 244,244 electric vehicles per year.  That is over four times per year the total number of electric vehicles in the state in June 2019.

The transportation cap-and-invest program proposed would “cap emissions of carbon dioxide from the combustion of the fossil component of finished motor gasoline and on-road diesel fuel in the region”.  Owners of fuel at terminals would buy permits to sell the equivalent amount of fuel corresponding to the emissions cap and then New York will invest the money received in programs to reduce fuel use.  One investment could be to fund the current $2,000 NYSERDA incentive for the purchase of electric vehicles.  In the previous example that is $488 million per year and would roughly add 9 cents per gallon.  However, the $2,000 per car incentive is not working well enough to get many people to purchase them.  If the incentive is kicked up to $10,000 per vehicle then the cap cost would go up to 43 cents per gallon.  The cost per electric vehicle is just the start of the costs necessary to implement over two million electric vehicles.  What is the plan for charging infrastructure particularly in cities where residents have to park in lots or on the street and how much will that cost?

A recent poll asked the public how much they were willing to pay to combat climate change.  The poll found that “To combat climate change, 57 percent of Americans are willing to pay a $1 monthly fee and 23 percent are willing to pay a monthly fee of $40.”  Dividing the NYS annual gasoline sales of 5.73 million gallons in 2016 by the 9,480,329 standard registrations averages 50 gallons per month so the nine cents per gallon equates to $4.29 per month but would rise to $21 a month for 43 cents per gallon to fund a $10,000 per vehicle incentive.

Advocates for the cap-and-invest program point to the Regional Greenhouse Gas Initiative (RGGI) as model of a program that works.  I believe that RGGI has significant differences that make the approach unlikely to work well if at all.  In RGGI, affected sources did not have viable options to install control equipment but could switch to a lower emitting fuel.  I have calculated that fuel switching was the cause of most of the reductions and that reductions linked directly to investments from the auction dividends provided only 5% of the total reductions.  Another big difference is that affected sources have different stakes.  The TCI proposed cap and dividend approach proposes to regulate state fuel suppliers.  In RGGI affected sources were penalized if they did not comply but the TCI affected sources have no stake in compliance with the cap.  They will only sell whatever amount of fuel is specified by the cap and will not worry about how society meets the cap.  As a result, the TCI price signal has to be high enough to force the public to reduce fuel use and TCI dividend investments have to give citizens viable options that use less fuel.

There is another problem.  The RGGI dividend investment results did not reduce emissions enough to meet the cap.  If the TCI investments don’t reduce emissions sufficiently to meet the cap necessary to meet New York’s CLCPA targets, then the inevitable outcome is that there will be more demand for fuel than the cap allows and the amount of fuel available will be limited.  It is inconceivable to me that government-caused fuel outages would be acceptable to the citizens of New York.

Ultimately a cap-and-dividend program equates to a tax.  Just as taxes are invested by government for services this approach takes in money that supposedly will be invested to promote cleaner transportation, improve public health, create economic opportunities, and enhance mobility.  Before anyone can reasonably be expected to decide to support this program the State needs to provide their plan for specific programs and resulting costs.  What is the expected increase to fuel prices for this new tax and how will it be structured so that the those least able to afford a price increase not be adversely affected in general and particularly the rural poor located beyond the availability of public transit?

Most importantly, this analysis looks only at one sector.  The electric generation, residential, commercial, industrial and other sectors all have to make similar reductions.  Given that the costs of just this sector fall between the amount 57% and 23% of the public are willing to pay I believe it is clear that there will be pushback similar to the French “yellow vest” movement in New York when the costs of the CLCPA become apparent.  Roger Pielke Jr.’s Iron Law of Climate Policy states that “while people are often willing to pay some price for achieving environmental objectives, that willingness has its limits”.  New York will test that law.

NYSERDA RGGI Investments – Status Through 2018

I have written previously on the Regional Greenhouse Gas Initiative (RGGI) investment report such as The Investment of RGGI Proceeds in 2016  in this post.  This post covers the analogous New York State Energy Research and Development Authority (NYSERDA) report New York’s RGGI-Funded Programs Status Report – Semiannual Report through December 31, 2018 (“Status Report”).  I believe that the reported benefits for these investments fall far short of what is necessary to meet the RGGI reduction goals and are a warning sign that the Climate Leadership and Climate Protection Act goals are going to be even tougher to meet.

I have been involved in the RGGI program process since its inception.  I blog about these details of the program because very few seem to want to provide any criticisms of the program. 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.


RGGI is a market-based program to reduce greenhouse gas emissions. It is a cooperative effort among the states of Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New York, Rhode Island, and Vermont to cap and reduce CO2 emissions from the power sector.  The program sets a limit on CO2 emissions and auctions allowances for each ton in the cap.  As the cap is ratcheted down over time emissions necessarily have to go down.  The auction proceeds are used for investments in CO2 emissions reductions.

According to the NYSERDA Status Report:

The State invests RGGI proceeds to support comprehensive strategies that best achieve the RGGI CO2 emission reduction goals. These strategies aim to reduce global climate change and pollution through energy efficiency, renewable energy, and carbon abatement technology. Deploying commercially available renewable energy and energy efficiency technologies help to reduce greenhouse gas (GHG) emissions from both electricity and other energy sources in the short term. To move the State toward a more sustainable future, RGGI funds are used to empower communities to make decisions that prompt the use of cleaner and more energy-efficient technologies that lead to lower carbon emissions as well as economic and societal co-benefits. RGGI helps to build capacity for long-term carbon reduction by training workers and partnering with industry. Using innovative financing, RGGI supports the pursuit of cleaner, more efficient energy systems and encourages investment to stimulate entrepreneurial growth of clean energy companies. All of these activities use funds in ways that accelerate the uptake of low-to-zero emitting technologies.

That is the theory. In practice the results have been mixed and even environmental advocacy organizations have voiced their displeasure.  For example, Environmental Advocates of New York (EANY) recently released a report, “RGGI at a Crossroads”, that details the allocation of funds raised by the Regional Greenhouse Gas Initiative (RGGI) in New York State.  I published a post that agreed with their findings.  The overview for RGGI at a Crossroads states:

“For the past seven years, the Cuomo Administration has used funding made available to New York through the Regional Greenhouse Gas Initiative (RGGI) for some authentic climate mitigation purposes as well as some highly questionable ones. While programs like Green Jobs – Green New York, 76West, and the Drive Clean Rebate owe their success to RGGI funding; the Governor has also diverted RGGI funds to subsidize power rates for Long Islanders and plug budget holes. These diversions are bad policy precedents that squander the opportunity to better the environment. An upcoming revision to state regulations offers the Governor an opportunity to take his hand out of the cookie jar and invest RGGI proceeds in a way that will propel New York to the forefront of climate justice.”

However, while I agree that if RGGI is supposed to be a CO2 reduction program that the auction proceeds should only be used for CO2 emissions reductions, I am less impressed with the value of their investments than EANY as I will show in the following.

Social Cost of Carbon

In order to put the value of RGGI investments in context of potential benefits some background on the social cost of carbon (SCC) is necessary.  Regulators necessarily have to balance costs and benefits.  This parameter was developed to estimate the cost of the long-term (that is to say hundreds of years) damage done by a ton of carbon dioxide (CO2) emitted today.  This dollar figure also represents the benefit of a CO2 reduction. I have posted on some of the issues with this parameter but for the purposes of this post you need to know that the values range widely depending on assumptions.  For example, if you use a discount rate of 3% and consider global benefits like the Obama-era Environmental Protection Agency (EPA) did then the current SCC value is $50.  On the other hand, the current Administration EPA SCC value for SCC is $7 for a 3% discount rate and $2 for a 5% discount rate that represents only benefits to the United States.  Needless to say, New York’s preference is to use the $50 value.

December 2018 Semi-Annual Report Status Report

According to the Status Report, New York State has accumulated $1,184,631,180 either from direct auction proceeds from the sale of more than 366 million CO2 allowances or interest earnings as of December 31, 2018.  Note that while the allowance prices are increasing over time the total number of allowances sold is decreasing.  For the three-year control period ending in 2011 144,305,904 allowances were sold but in the control period ending in 2017 only 72,401,365 were sold.  The increase in allowance costs does not offset the drop in allowances sold so annual proceeds are decreasing over time.

The Status Report  2018 Investment Summary Table 1 deserves special comment.  The lifetime net energy savings 62,466,470 mmBtu, renewable generation 8,243,824 MWh, net efficiency electricity savings 17,446,899 MWh, and net CO2 emissions reductions of 20,762,489 tons are all big numbers.  When you consider that total investments are $558 million you could be led to believe that the cost benefit ratio dollars invested per ton of CO2 reduced is $26.88.  That is well below the NY SCC target of $50.  However, using expected lifetime savings is bogus.

The CLCPA has a target to reduce annual CO2 emissions to zero compared to the 1990 emissions.  The key is that we need to know what the program investments do to annual emissions.  The New York State Energy Research and Development Authority Patterns and Trends document provides CO2 emissions data and that shows that in 1990 the NY total was 235.8 million metric tons.  In order to assess progress against that goal annualized reductions are the only ones that matter so the only cost benefit values that matter are for annual reductions.

The Status Report  2018 Investment Summary Table 2 and Table 2 notes provides the information necessary to determine progress relative to the goals.  There are six program categories: Green Jobs – Green New York, Energy Efficiency, Renewable Energy, Community Clean Energy, Innovative GHG Abatement Strategies, and Clean Energy Fund. The Consolidated Summary of Expected Cumulative Annualized Program Benefits through 31 December 2018 table summarizes the benefits and costs for those categories.  Note that the cost benefit ratio is $463.54, nearly ten times the NY SCC value.

Green Jobs – Green New York

As shown in my Consolidated Summary table total program costs were $172.5 million through the end of 2018 for programs that reduced CO2 264,048 tons for a cost benefit ratio of $653.29 per ton reduced.  Green Jobs – Green New York provides “funding for energy assessments, low-cost financing for energy upgrades, and technical and financial support to develop a clean energy workforce”. It is administered by NYSERDA and made available by the Green Jobs – Green New York Act of 2009.  As I recall the administrative costs associated with this program are notable.

Energy Efficiency

As shown in my Consolidated Summary table total program costs were $260.2 million through the end of 2018 for programs that reduced CO2 611,898 tons for a cost benefit ratio of $425.23 per ton reduced.  These programs provide “comprehensive energy efficiency services for single and multifamily existing buildings and new construction, including low-income households”. RGGI funds are provided to the Long Island Power Authority support energy efficiency programs administered by PSEG Long Island.  RGGI funds were also used to “fill gaps in residential energy efficiency services, offering incentives to implement energy efficiency measures related to petroleum fuel opportunities, or opportunities on Long Island and municipal electric districts”.

Renewable Energy

As shown in my Consolidated Summary table total program costs were $79.9 million through the end of 2018 for programs that reduced CO2 144,408 tons for a cost benefit ratio of $553.29 per ton reduced.  One program in this category tries to increase the use of biomass for renewable heating. NY-Sun provides “declining incentives for the installation of systems and works to reduce solar electric balance-of-system costs through technology advancements, streamlined processes, and customer aggregation models” with a goal to “achieve a sustainable solar industry that does not depend on incentives”.  There is another solar incentive program that funded “221 solar electric system installations outside of Long Island”.  The Advanced Renewable Energy Program supports “projects that foster the market introduction of a broad range of promising new and advanced renewable energy technologies, including advanced biomass, tidal, and offshore wind technologies”.

Finally, in a vivid example of Cuomo Administration creative accounting, RGGI funds the New York Generation Attribute Tracking System that records “electricity generation attribute information within NYS, and processes generation attribute information from energy imported and consumed within the State as a basis for creating tradable generation attribute certificates”.  Although there is a tortuous path linked to emission reductions linked to this program it really is an example of the type of program that really should be funded by the State and not RGGI that the EANY RGGI at a Crossroads report described.

Community Clean Energy

As shown in my Consolidated Summary table total program costs were $21.8 million through the end of 2018 for programs that reduced CO2 130,662 tons for a cost benefit ratio of $166.84 per ton reduced.  There are seven component programs in this general category.  It is notable that this category’s emphasis on funding specific GHG reduction projects makes this most cost-effective program area.  Mind you the Reforming the Energy Vision Campus Competition Program component award for Bard College’s Micro Hydro for Macro Impact project that will use local dams to develop micro hydropower is probably not going to help much meet the CLCPA target.  The Status Report breathlessly notes that “the  project is expected to avoid 335 metric tons of GHG emissions annually, equivalent to taking 70 cars off the road”.

Innovative GHG Abatement Strategies

As shown in my Consolidated Summary table total program costs were $6.2 million through the end of 2018 for programs that reduced CO2 1,804 tons for a cost benefit ratio of $3,436.81 per ton reduced.  This includes a longer-term Industrial innovations program that “supports development and demonstration of technologies with substantial GHG reduction potential and technologies relevant to NYS manufacturing industries and building systems”.   Another creative accounting effort includes the Climate Research and Analysis Program that “supports research studies, demonstrations, policy research and analyses, and outreach and education efforts”. According to the report these activities address “critical climate change related problems facing the State and the region, including the needs of environmental justice communities”.  All well and good but this is a mission of NYSERDA and should be funded out of the Administration’s budget and not detract from the RGGI mission to reduce CO2 emissions.  Also included in this program is the Clean Energy Business Development program that “seeks to support emerging business opportunities in clean energy and environmental technologies while maintaining the goal of carbon mitigation”.  Perhaps I have been reading to much of this but I am getting a wift of crony capitalism for the well-connected in Albany.  There are several programs similar to those listed here.

Clean Energy Fund

As shown in my Consolidated Summary table total program costs were $17.4 million through the end of 2018 for programs that reduced CO2 50,961 tons for a cost benefit ratio of $341.44 per ton reduced.  This program area is not described in the document.

Cost Recovery Fee

For your information, this is another example of New York State bureaucracy at its best.  The New York State Cost Recovery Fee is imposed on the New York State Energy Research and Development Authority (NYSERDA) by law to reimburse the State for the cost attributable to the provision of central government services to NYSERDA.  The available RGGI funding budget at the end of 2018 is $1.245 billion and $11.9 million is reimbursed to the state for the privilege of adding money for reducing emissions.


There is a wide range of cost benefit ratios for the six program areas. At the high end Innovative GHG Abatement Strategies have a cost benefit ratio of $3,347 per ton reduced and the at the low end Community Clean Energy has a cost benefit ratio of $167 per ton reduced. Overall the cost benefit ratio was $464.  The cost benefit ratios can be used to estimate the total costs to meet the CLCPA target to eliminate CO2 emissions from the NY electric sector.  The  Status Report cost to reduce NYS fossil fuel 2018 CO2 emissions to zero table multiplies the 2018 CO2 emissions from the electric sector (27,786,614 tons) by the cost benefit ratios.  If NY eliminates CO2 emissions using the approaches in use for the RGGI investments, the total costs range from $4.6 billion to $95 billion with an overall cost of $12.9 billion.

Another important point is that there is likely a reason for the range of cost benefit ratios.  At the high end, the GHG Abatement Strategies category emphasizes long-term research and development.  Because this research could make a cost breakthrough the investments make sense.  Looking at the other categories it appears that the more investments are focused on direct reductions rather than indirect investments the better the cost benefit ratio.  For example, the best ratio is in Community Clean Energy and that category includes direct support for renewable energy projects.  Although the Renewable Energy category would seemingly meet the criteria for direct support, remember that the Cuomo Administration has diverted funds for other program areas that do not directly support climate mitigation efforts.  The Energy Efficiency category is a better example of indirect support.  Investments in this category do not directly reduce emissions.  Instead reducing energy use reduces the need for energy production and indirectly reduces emissions.


The most important conclusion is that none of the NYSERDA investments of RGGI auction proceeds meet the social cost of carbon criterion of a cost-effective benefit.  New York proposes to use the Obama era SCC value which is $50 in 2019 and the best investment category cost benefit ratio is three times greater than that value.  The cost benefit ratio for all the investments is over nine times greater than the $50 SCC value.

I also believe that there are important ramifications to the apparent reason for the range of cost-benefit ratios.  I think that the more focus on direct investments in emission reductions the better the ratio.  On one hand it could be seen as intuitively obvious but the point is that carbon pricing proposals rely on a completely indirect impetus for emission reductions.  As such those proposals, as theoretically appealing as they may be, may be much less cost effective than suggested.

The Status Report includes a table that lists the expected lifetime benefits of the projects.  Because our primary concern is meeting annual limits those numbers are at best a distraction and at worst a coverup attempt of the poor return on investments.

Finally, the total costs are staggering.  I estimate that the projected costs will be over $25 billion for just the electric sector to meet the CLCPA targets.  If NY relies on the approaches used by NYSERDA for the RGGI investments to eliminate fossil fuel CO2 emissions, the overall cost is $12.9 billion.  I earlier made an estimate of the costs for energy storage if fossil fuels generation is eliminated and that came out to $12.5 billion.

New York Resource Adequacy Proceeding Comments

Update March 25, 2020: Submittal documents: Caiazza comments Resource Adequacy, Initial Estimate of Energy Storage Required White Paper,Energy Storage White Paper Appendix 1 Solar Irradiance Maps, and Appendix 1 Air Source Heat Pumps

The New York State Public Service Commission (PSC) issued an order commencing a proceeding to examine how to reconcile resource adequacy programs and the State’s renewable energy and environmental emission reduction goals. This post describes the comments I submitted in this proceeding.

Materials and information are available in the Department of Public Services (DPS) resource adequacy matters docket Case 19-E-0530.  .  According to the Order Instituting Proceeding and Soliciting Comments, the inquiry is “necessitated by the Commission’s statutory obligations to ensure the provision of safe and adequate service at just and reasonable rates. Costs to consumers are a primary and ultimate consideration, recognizing that the necessary investments in resources must have sound economics.”

The PSC order solicited comments on the following questions.  Does the New York Independent System Operator (NYISO) have sufficient resource adequacy evaluation mechanisms in place to deal with the State’s ambitious renewable energy and environmental emission reduction goals?  Do the policies and market structure mechanisms insure just and reasonable consumer rates? There were several specific questions about existing products and their value with respect to costs.  Finally, there was a general question about the State’s role with respect to resource adequacy and request for recommendations for what to do next.

I submitted comments because I am not sure that the Climate Leadership and Community Protection Act (CLCPA) can be implemented so that it does not jeopardize safe and adequate energy service at just and reasonable rates. I based the comments on evaluations I did for previous posts on Solar Issues in Upstate New York , CLCPA Solar and Wind Capacity Requirements and CLCPA Energy Storage Requirements.

My filed documents (dated 9/16/2019 as a filing on behalf of an individual) illustrate my concerns with two examples.  I prepared a white paper that provides an initial estimate of the likely energy storage component requirement based on real world data.  It shows that at night when winds are light the energy produced from these sources will have to be supplanted with stored energy if New York shuts down all its fossil generation.  Given the extraordinary cost of battery energy storage I estimate that the batteries alone will cost over $12 billion to replace existing fossil generation and Indian Point after it retires.  The second example describes a potential problem with winter peak loads once the CLCPA is implemented.  Because of the stringency of the law, home heating is going to have to be electrified.  The preferred retrofit option is an air source heat pump.  However, they don’t produce heat when the temperature gets below zero so homeowners will need a backup system and the cheapest alternative is radiant heat which is much more inefficient.  As a result there will be a spike in electrical load that cannot be avoided.

Both examples used data from the NYS Mesonet.  I believe the best way to determine resource adequacy is to base the analysis on historical meteorological information as shown in the examples.  In order to determine the amount of energy storage you have to calculate how much wind and solar power is available and when.  In order to determine the effect of air source heat pumps meteorological data from the winter 2017-2018 peak load period was used.  I recommended that historical meteorological data be used to characterize potential solar and wind energy production to determine the feasibility of the CLCPA emission reduction target that eliminates emissions from electricity production by 2040.

In addition, I believe that the State needs to do a cumulative environmental impact assessment of this regulation.  The problem is that while an individual industrial wind facility or solar facility may not have a significant environmental impact the cumulative impact of all the facilities necessary to provide enough power to meet the reliability needs of the state could have significant environmental impacts.  For example, if one raptor gets killed by every ten wind turbines that might be acceptable but if we need a thousand wind turbines is one hundred raptors per year acceptable?

My final recommendation is for an independent review of the findings of the feasibility studies.  The CLCPA is the result of political pandering and the likelihood that a feasibility study would be subject to political influence is high.  The only way I can think of to prevent that is to establish an independent group to review the findings.  Membership should deliberately be chosen to represent both “sides” of vested interests in the outcomes.  They may not be able to come agree but their evaluation report can list where they have agreed to disagree and that will be useful for the public.

I think it is obvious that the resource adequacy proceeding must determine if the CLCPA can be implemented such that it does not jeopardize safe and adequate energy service at just and reasonable rates.  If renewable resources and energy storage are inadequate during the winter peak, then safe and adequate energy service could easily be jeopardized.  No jurisdiction has ever successfully reduced greenhouse gas emissions by developing renewable energy resources and managed to keep prices down and I see no reason that New York will be able to reverse that result.  Most importantly, the increase in energy prices will affect those who can least afford the increased costs.

If you are a resident of New York I ask that you submit comments to the DPS resource adequacy matters docket Case 19-E-0530 supporting the request for comprehensive, independent feasibility and cumulative environmental impact assessments.

CLCPA Energy Storage Requirements

Updated 31 August, 2019 in response to comments – changes in italics

On July 18, 2019 New York Governor Andrew Cuomo signed the Climate Leadership and Community Protection Act (CLCPA), which establishes targets for decreasing greenhouse gas emissions, increasing renewable electricity production, and improving energy efficiency. This is one of a series of posts on the ramifications of the “most aggressive climate law in the United States”. This post lays out an initial guess for the energy storage needed for CLCPA wind and solar resources at levels greater than announced to date.

CLCPA Target Overview

The Citizens Budget Commission developed an overview of the CLCPA targets in Green in Perspective: 6 Facts to Help New Yorkers Understand the Climate Leadership and Community Protection Act. The goals of the law are truly aspirational:

Reduce greenhouse gas (GHG) emissions:

    • Reduce GHG emissions to 60 percent of 1990 emissions levels in 2030;
    • Generate zero GHG emissions from electricity production by 2040; and
    • Ensure GHG emissions are less than 15 percent of 1990 emissions levels in 2050, with offsets to reduce net emissions to zero.
      • GHG offsets means that for every ton emitted into the air one ton is removed via GHG capture of some sort. For example, a company or individual can pay a landowner to leave trees standing that would otherwise be removed or plant additional trees to offset GHG emissions.

Increase renewable electricity:

    • Increase renewable sources to 70 percent by 2030; and

Develop or support:

    • 9 gigawatts (GW) of offshore wind electric generation by 2035;
    • 6 GW of distributed photovoltaic solar generation by 2025; and
    • 3 GW of energy storage capacity by 2030.
    • Conserve 185 trillion British thermal units (TBTUs) of annual end-use energy use by 2025, of which at least 20 percent should be from energy efficiency improvements in disadvantaged communities.
    • The CLCPA also requires between 35 percent and 40 percent of spending on clean energy or efficiency programs be in disadvantaged communities and mandates an air monitoring program in at least four such communities.

Simple Wind and Solar Capacity Model

I believe that CLCPA advocates have not figured out that an electric system that is completely dependent upon renewables will require much more energy storage than commonly assumed. I follow Michel at the Trust, yet Verify blog because he evaluates Belgian “green” technology quantitatively and has given me many insights into potential issues that might also arise in New York. Moreover, like me he prefers using real-world data. In a recent post Michel evaluated the potential effect of increased electricity production from intermittent energy sources in Belgium with a simple solar and wind capacity increase data analysis “model”. He downloaded solar generation, wind generation, and total load data for an entire year. The solar and wind data were summed together for every time period, in his case 15 minutes. Then he projected solar and wind by multiplying the observed sum by different values. The results graphically showed that adding a lot more intermittent wind and solar capacity increases production peaks but does not increase production nearly as much during production valleys. In addition, the results show that as renewable capacity increases more balancing mechanisms will be required.

In a previous post I adapted his methodology to New York State for 2018 with his help and analyzed data from August 2018 which represents the month with the most deficit periods. I believe that the CLCPA claims that renewable energy can completely replace the current fossil fuel load are extraordinary. As such, its proponents have to provide extraordinary evidence that it can work. In this post I look at the required balancing mechanisms for solar and wind to replace existing fossil generation in New York.

In the previous post I estimated how much energy storage may be required by incorporating reasonable assumptions about the future using assumptions about the availability of nuclear, solar, and wind using the Trust, yet Verify simple approach. The biggest future change is the forced shutdown of the Indian Pont nuclear facility in the next several years. In my previous analysis I used “best case” estimates that assumed that solar and wind are available at their rated capacities every hour in my test period. Because those sources are intermittent the amount of time when they are available at full load is not constant. For example, solar availability varies during the day and over the month of August there will be periods when the wind is blowing less than optimal. On the other hand assuming that Indian Point capacity is not available at its rated capability is a reasonable assumption because it usually runs at full load except for maintenance.

The ultimate result in that post estimated the wind and solar capacity from an aggressive CLCPA implementation plan.  In that post and this one I want to estimate the least amount of energy storage needed in the future so I increased renewable additions more than have been announced to date.  I don’t think there will be any significant increase in hydro or the other renewable category sources of methane, refuse, or wood firing and they are not intermittent so I made no changes to those categories. Because New York is shutting down 2,067 MW of nuclear at Indian Point in the next several years I subtracted that amount from every hour. I multiplied the existing onshore wind resource twenty times to estimate future availability. The CLCPA plan currently calls for 9,000 MW of off-shore wind power but I doubled that amount. The CLCPA plan also calls for 6,000 MW of solar PV power but I doubled that amount too. In order to account for daylight I added 6,000 MW to every time period from 0700 to 1955. In order to account for wind intermittency I made some assumptions about availability and scaled the offshore wind resource down when the on shore resource was below half of the observed maximum.

As shown in August 2018 Simple Model Aggressive CLCPA Renewables vs. Fossil Load, there are many periods of surpluses (all the renewables minus the existing fossil resource shown in blue) but there are still periods with deficits even with the best case assumptions about renewable availability. The remainder of this post examines one of the deficit periods in more detail.

Refined Renewable Resource Estimates.

In order to more realistically estimate the potential renewable resources available during one of these periods real world observations need to be included. For this analysis it is assumed that the onshore wind assumption that additional wind would be proportional to existing wind is adequate. However, I did try to modify the offshore wind and the solar components. In order to do that I chose a shorter period and collected meteorological data to get a better estimate of potential solar and off-shore wind capacity. I arbitrarily chose a deficit period on the early morning of August 8, 2018 when winds were light and the sun was either not up or not at full strength to look at the potential magnitude of energy storage required to balance the deficit.

In order to characterize the off-shore wind potential I found a National Oceanic and Atmospheric Administration buoy located 30 NM south of Islip, NY (40°15’3″ N 73°9’52” W) that I used to represent NY offshore wind resource availability. I downloaded hourly NDBC data for 2018 and scanned the data. As noted August 8 had light winds. The weather map for 8 August 2019 shows that there was a large high pressure system dominating the east coast. As a result, I am confident that this buoy characterizes NY offshore wind speeds and thus the resource of NY offshore wind.

This analysis characterizes wind energy as a function of observed wind as follows. I found a wind turbine power output variation curve, developed a straight line equation for the curve and estimated that the output of 18,000 MW of New York offshore wind equals 1714 times the wind speed minus 6000. I assumed that the observed wind speed at the hub height is proportional to the logarithm of the height above ground. For the calculations I assumed a hub height of 85 m and a surface roughness of 0.0003 while the buoy anemometer height is 4 m. The NY offshore wind output capacity in MW was calculated for every hour using this approach.

The solar output is a function of the observed solar irradiation in watts per meter squared. I assumed that 12,000 MW of solar capacity could be added in response to the CLCPA but that will be installed state wide. I downloaded solar insolation maps from the NYS Mesonet archive. I accessed the solar irradiation map in the spatial analysis directory to get solar irradiation maps and as an added bonus the maps also include gridded winds. NYS Mesonet Solar Irradiance Map 8 August 2018 at 1525 UTC is an example of these maps and can be reproduced at this link. In this case there is a lot of variation across the state which makes a state-wide single number estimate of solar irradiation weak but sufficient for this first cut analysis. I estimate that the highest irradiance was 900 W/m2 and the lowest was around 100 W/m2. To do this right one would have to determine where the solar panels might be located to weight the observations. For this hour I guessed 600 W/m2 for the state. I assumed that the 12,000 MW of solar cells produced 12,000 MW when the solar irradiation equals 800 watts per square meter (the PVUSA test condition) and I did not account for any other factors such as the cell temperature or any losses. So my naïve formula for solar output was simply the observed input solar irradiation times 12,000 divided by 800.

The Deficit Example of Simple Model of Intermittent Wind and Solar Generation vs. Fossil Generation and Indian Point Shutdown table lists 5-minute from 0300 to 0955 EDT on August 18, 2018 when the assumed aggressive CLCPA renewable capacity could not replace the existing fossil capacity and loss of the Indian Point nuclear facility.   The first three data columns list the total NYISO state-wide generation load, the NYISO total load, and the fossil generation load. The next four columns list the onshore wind load, CLCPA solar load, and the CLCPE off-shore wind load calculated as described above with the total shown in another column. The next three columns present the meteorological data used. Finally the sum of the onshore wind load, CLCPA solar load, and the CLCPE off-shore wind load minus the existing fossil and the Indian Point capacity of 2,067 MW is listed. In this period all the five-minute periods were negative. The first conclusion is that the post-CLCPA constraint may not be the peak load but instead a night-time low wind period.

Energy Storage Requirements and Costs

I have never seen an analysis that attempted to determine how much storage capacity would be required to meet a real-world generation capacity deficit. Clearly the total capacity has to exceed the observed deficit. In this case I estimate that the total deficit equals the sum of the average of the 12 5-minute deficits each hour or 33,548 MWh. I think that the maximum output of the energy storage has to equal the largest 5-minute deficit or 8,131 MW.

After that it is not clear how best to divvy up the energy storage requirements. I assumed that the least cost energy storage approach would maximize energy storage duration based on lower costs per MWh in a recently released report from the National Renewable Energy Lab (NREL): “2018 U.S. Utility-Scale Photovoltaics-Plus-Energy Storage System Cost Benchmark”. I reported on my estimates for different duration energy storage costs in a post at What’s Up With That.  In this analysis I included the costs of the battery and did not include developer costs to site, permit and connect the facility to the grid.

In the Estimated Energy Storage Required and Potential Price table I summarize the energy storage needs and my projection for the amount of different duration energy storage needed for the seven hour deficit period with my over-built renewables future scenario. In the first hour of the deficit period the hourly average was 1,140 MW but the peak was 1,390 MW so I project 1,400 MW at 7-hour duration could be used. The next hour had the peak 5-minute deficit of 8,131 MW. In order to meet that and subsequent hours I project 1,300 MW at 6-hour duration, 2,750 MW at 5-hour duration and 2,690 MW at 1-hour duration would cover that peak and most of the subsequent deficits. In order to cover subsequent peaks I added 1,200 MW at 2-hour duration and 620 MW at 1-hour duration. The total MWh stored (37,160) exceeds the observed total deficit (33,548) by 3,612 so there is a lot of room for refining this analysis but that has to be weighed against the fact that no attempt was made to find the worst case period which has to be done at some point.

The total costs are staggering. In order to cover the deficit of energy produced by solar and wind resources at an aggressive level over current on-shore wind and proposed CLCPA solar and wind, $12.5 billion dollars of energy storage will be required to replace existing fossil generation and Indian Point. Nobody in the State has suggested how much energy storage will be required and the 3,000 MW of energy storage capacity by 2030 goal has not included any duration goals. In context 11,260 MW of energy storage capacity is needed according to this analysis and there are large amounts of seven, six and five hour duration energy storage capacity required.  Needless to say, no State estimates have covered the expected costs of their storage goal much less what might ultimately be needed.


In order to determine the cost and feasibility of the CLCPA the State needs to do a similar analysis using real world data and historical load data. The analysis should attempt to site likely renewable energy resources and use the NYS Mesonet data to determine potential resource availability for as long a period as possible. The goal of the analysis would be to determine the energy storage capacity required to meet the CLCPA so that a cost estimate can be prepared.