Updates to Pragmatic Environmentalist Pages  

This is another summary of updates I made to the pages I maintain at  Pragmatic Environmentalist of New York and Reforming the Energy Vision Inconvenient Truths.  I have an extensive list of reference materials on my original blog that I occasionally update when I run across an article that is particularly interesting and relevant and this blog also has reference material.  This article describes some recent page updates and I also have highlighted a few recent articles that don’t fit my needs on those pages.

I started blogging in late 2017 on New York’s energy policies because I was convinced that they are going to end as an expensive boondoggle driving electricity prices in particular and energy prices in general significantly higher. Reforming the Energy Vision (REV) was the previous comprehensive energy strategy for New York. I wrote about the inconvenient unpublicized or missing pieces of New York State’s REV policy: implementation plan, costs and impacts. At some point I should probably combine that blog with this one but in the meantime, I maintain them both.  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.

I ran across an intriguing video that sums up the future of New York’s energy future under the Climate Leadership and Community Protection Act and linked to it in my page for lessons to be learned from othersAndrew Bolt describes the effects of green energy policies on Australia.  He makes that point that “willful ignorance” on climate change is making people “poorer and weaker”.  New York is not as far along as Australia on our transition but the same thing is going to happen here.   

I updated theClimate Claims page that addresses the alleged threat of a climate driven existential threat with links to a two part series by Kip Hansen “Reprise — Why I Don’t Deny: Confessions of a Climate Skeptic”.  Hansen updated his original five-year old articles after a conversation with a colleague who’s only understanding of the issue came from main stream media.  The articles update the originals with newer information.  In the first part, he describes the temperature and explains that the temperatures have been increasing since 1650 – 1700.  That is important because that is 150 to 200 years before the start of increased GHG emissions associated with the industrial revolution.  He explains that he agrees that global warming is happening and  human activity causes [some of] it.] but he does not agree with the assertion that CO2 and other anthropogenic emissions  are “the dominant cause of the observed warming since the mid-20th century.”  He says that he disagrees with the attribution and the effect size.

In the second article Hansen provides his reasoning for this position.  He shows that sea-level rise that is also attributed to anthropogenic warming follows the temperature record.  It has been rising since 1700 when it bottomed out at the end of the Little Ice Age.  He also presents data on snow and ice cover that behave similarly.  He concludes that:

The IPCC and the Climate Science community have, so far, failed to rule out the CO2 driven global warming hypothesis —  nothing more.    They have, however, shown in their historical reconstructions that the main bodies of evidence their hypothesis relies on — surface air temperature, sea level rise, snow and ice cover —  all started changing long before COconcentrations could possibly had any appreciable effect.

I also added a link to Judith Curry’s latest presentation on climate uncertainty and risk.  She gave a 20-minute presentation at the ICCC Conference and the blog post summarizes the main points.  She does a great job explaining “what we know, versus what we don’t and cannot know” and how that should but does not affect climate policy.  It all comes back to how climate risk is characterized and she argues that is not being done will today. 

I updated my renewable energy feasibility page with this zoning requirements link.  Kevon Martis has prepared wind and solar zoning talks that have the pro-renewable groups spun up because they effectively provide information to keep local control of wind and solar siting.  Robert Bradley writes about a hit piece describing him of sowing fear and misinformation about renewable energy.  When asked by people wanting help, Martis gives a 40-60 minute wind or solar zoning talk, answers questions and then goes home. The links to the two talks are here and here

The Climate Act and all its components repeatedly claim that that weather events are getting worse as the justification for the net-zero transition.  I provide examples of problems with those claims at the Climate Change Impacts page.  The Climate Fact Sheet: January 2023 Edition addresses media claims in January 2023 that all run counter to the popular narrative.  

I added a link on my Electric Vehicle Issues page “Are electric vehicle charging stations really worth taxpayer money?”.  Steve Goreham looks into the costs of electric vehicle charging stations and concludes that it’s unlikely that charging fees can cover the capital and operating costs of public chargers or make money for investors.  Ultimately, he predicts that public charging stations will eventually owned by the electric utilities paid for by higher electricity prices and hidden subsidy costs to consumers.

Finally, I have added a page with links to relevant videos.  The following videos are included:

Climate Science

  • Unsettled Climate Science:  Link is to a post that includes videos of a discussion between Jordan Peterson and Steven Koonin, on-line material, and a couple of debates.
  • Climate Change: What do scientists say? Prager University presentation by Richard Lindzen

New York Net-Zero Transition

Implementation Issues

  • Mark Mills: The energy transition delusion: inescapable mineral realities shows that the amount of mining necessary to provide the raw materials needed for the net-zero transition is so large that the transition is impossible.
  • Li-Ion battery fires: Paul Christensen, Professor of Pure and Applied Electrochemistry at Newcastle University in the United Kingdom gave a presentation at PV magazine’s Insight Australia event in 2021 that describes the risks  of thermal runaway fires in li-ion batteries. His videos of thermal runaway tests are terrifying.   
  • Problems with hydrogen: Link to a post with a video and description of contents

Climate Change Issues

Net Zero or Good Enough?

Originally published at Climate Etc.

Russel Schussler and Roger Caiazza

Electric generation plans need to be well crafted and carefully considered. Because of concerns around  climate change many politicians have become galvanized to hastily enact legislation to target  net-zero anthropogenic greenhouse gas emissions by 2050.  The authors argue that the more seriously you take climate change, the more important it becomes that you have a good plan for electric generation in the near and midterm planning arena.  Taking foolish actions in the near to mid-range time periods will not help with CO2 reductions or climate change and may be far worse than doing nothing.  Maybe we all could compromise and find a less grand something that has more likely benefits with far fewer threats to reliability, affordability, and overall environmental impacts.

The authors have both been writing about the proposed net-zero transition by 2050 for years.  Schussler (aka the Planning Engineer) has been writing about the challenges of “green energy” since 2014 at the Judith Curry’s Climate Etc. blog.  Caiazza has focused on New York energy and environmental issues at Pragmatic Environmentalist of New York blog since 2017.  Since the original proposal for New York’s Climate Leadership and Community Protection Act (Climate Act) in 2019, he has written over 280 articles about that plan to transition to net zero by 2050.

Traditional Generation Planning

Utilities used to look at 30-year time periods in developing their generation expansion plans.  This was not because they believed anyone could forecast what might happen 30 years into the future, but rather because of the recognition of the futility of such efforts. Decisions were made about the next ten years or so, but the later years tested the flexibility of the plans.  Because power plants have a long life, many different scenarios were studied in the additional 20 years or so after the plant addition.  Commercial technologies were supported by more dependable cost and performance estimates than what could be obtained for newer technologies, but it was recognized that all parameters could change across any technologies.  Scenarios would vary fuel prices and availability, potential environmental requirements, as well as other varying system requirements. Back then, no one had the hubris to say this is what the system would, or should look like 20 or 30 years from now.  Planners sought to make decisions that would be flexible enough to work well across a variety of future potential scenarios. The hope was for this plan to work with and adapt to the emerging future. 

Some jurisdictions have made commitments to completely transform their electric generating systems in less than 30 years.  Rather than intending to be flexible in the mid to long term, these plans are often overly prescriptive. This post addresses the potential consequences and suggests a less risky approach.

New York Climate Act

New York’s Climate Act is a good example of prescriptive net-zero legislation.  Implementation to meet the following inflexible targets has begun:

  • Reduce GHG emissions to 60 percent of 1990 emissions levels by 2030;
  • Zero GHG emissions from electricity production by 2040; and
  • Reduce GHG emissions to less than 15 percent of 1990 emissions levels by 2050, with offsets to reduce net emissions to zero.

New York passed the Climate Act in 2019 effective 1/1/2020.  The legislation established a Climate Action Council to prepare the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.”  In brief, that plan is to electrify everything possible and power the electric grid with zero-emissions generating resources by 2040.  The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantified the impact of the electrification strategies.  The Final Scoping Plan was completed at the end of 2022.  In 2023 the New York State Department of Environmental Conservation and the Legislature are supposed to promulgate the necessary regulations and legislation to fulfill the recommendations in the Scoping Plan. 

There are deep flaws in the New York implementation process.  The Scoping Plan is just an outline list of control strategies that NYSERDA claims will reduce emissions as needed and provide reliable electricity.  NYSERDA, New York State Independent System Operator (NYISO), and New York State Reliability Council (NYSRC) have not done a consolidated feasibility analysis that addresses the fundamental question: will it work?  There are significant differences between the Final Scoping Plan and NYISO 2021-2040 System & Resource Outlook.  The following figure from the Resource Outlook summarizes the key findings that are applicable to any net-zero by 2050 initiative.  Our biggest concern is that both resource projections rely on untested technology.  The Resource Outlook notes:

By 2040, all existing fossil generators are assumed to be retired to achieve the Climate Act target for a zero-emission grid and are replaced by Dispatchable Emission-Free Resources (DEFRs). These resources represent a proxy technology that will meet the flexibility and emissions-free energy needs of the future system but are not yet mature technologies that are commercially available (some examples include hydrogen, renewable natural gas, and small modular nuclear reactors).

What are the characteristics of Good Plans versus Bad plans

In this section we consider the characteristic and provide commentary in italics relative to the New York Scoping Plan.

Bad plans assume that critical elements of the future are all known.  Bad plans are narrowly constructed to a specified future. They risk not allowing the flexibility to adapt when things turn out differently than was planned.  Good plans look at their impacts or current decisions across a wide variety of potential futures.  Good plans provide flexibility and nimbleness for when future conditions change. 

The NY Climate Act electrifies as much as possible to decarbonize and presumes all the elements necessary to accomplish the transition are known.  The critical element of future expected load must be well known to determine generation resource requirements.  Future net-zero load is a function of increased electricity for heating, cooking, water, and electric vehicles at the same time there is increased emphasis on energy efficiency and conservation.  Projections in this instance are anything but well known.

Good plans understand that the power supply system and power grid are very complicated systems requiring careful design, construction, and operation.  Great consideration is given to the architecture of the system and how it will work.  A poor plan leaves the power system and grid as an unplanned afterthought.  It specifies some goals and ingredients but ignores the greater system.

The basis of the Climate Act electric grid transition plan is the wind, water, and solar (WWS) approach championed by Stanford University Professor Mark Jacobson.  The approach had outsized influence on the members of the Climate Action Council but there are issues with this work.  Advocates of this particular transition approach have overstated its findings, it does not put appropriate emphasis on the high load and low renewable resource problem, and understates the challenges of a quick transition to a zero-emissions electrical grid.

Bad plans are one-size fits all.  They employ a presumption of what is best and fail to take in the particular specific considerations that can vary across time and place.  Good plans recognize that what works in one area, may be less appropriate in another. Good plans seek to capitalize on differing advantages wherever and whenever they may occur.

The New York electrical grid is pretty much two different grids.  There is a traditional grid Upstate but there are unique problems in New York City.  Experience has shown that sufficient in-city generation must be available to account for the loss of a transmission line into the New York City load pocket or blackouts can occur.  The Scoping Plan does not adequately address these differences in their on-size fits all plan.

Good generation plans recognize how people prefer to use electricity.  If behavior needs to be changed, they are sensitive to the capabilities and limits of incentives.  Depending on the generation mix the value of electricity will likely vary considerably across hours, days, months, and seasons.  Good plans will seek to provide value.  Bad plans tend not to differentiate between when and how energy might be supplied.  Plans crafted based on just average use and average costs will likely not have good results.  Traditionally generation planning recognized baseload, intermediate and peaking needs. While many seem to forget these distinctions when comparing alternatives, their importance has not diminished. 

The New York plan presumes that net-zero transition to net-zero required changes to personal energy choice preferences will be universally accepted.  The behavioral changes required by the Scoping Plan are massive (e.g., type of vehicles, heating your home, and cooking your food). Furthermore, there may be limits on the timing of electric usage.  Modeling assumptions on the effects of these changes to personal habits are important for planning but also very uncertain if people do not make the changes expected.   It is highly unlikely that load shifting and energy conservation will prevent a markedly higher electric load peak in winter mornings.  The Scoping Plan compounds these issues because it does not adequately address the baseload, intermediate and peaking requirements naively arguing that “smart” planning will mitigate issues associated with them.

Good plans look at major environmental impacts across the production and lifetime of a resource.  Bad plans tend to look only at marginal impacts when the facilities are operating.  Tremendous resources and costs are incurred just getting a generating resource in place. Generally, the longer that resource can operate, the better its average environmental impact might be.  Good plans should consider the realistic lifetime of potential resource.  Many “green” resources projected to last 30 years fall far shy of 20 years.  Conventional resources typically are capable of lasting many years beyond the thirty-year study life. 

The Climate Act takes this concern to a higher level.  Many life-cycle environmental impacts of fossil generating resources are considered.  None of the life-cycle environmental impacts of wind, solar, and  energy storage are considered.  The Integration Analysis assumes that all wind, solar, and energy storage resources keep operating from the present until 2050.  Furthermore, the Climate Action Council has tried to appease climate justice advocates who fervently believe that the risks of fossil-fired generating resources are so great that existing resources must be shut down as soon as possible.  Their concern is at odds with consideration of environmental impacts across the production and lifetime of all resources.

Good plans rely on proven technology that can fulfill the specific requirements.  For example, providing power for periods of peak load is required for reliable power when it is needed most.  Peak loads are typically associated with the hottest and coldest periods of the year when electricity is used for cooling and heating.  Typically, those periods occur less than 5% of the time so a technology should be as low cost as possible to keep the price of electricity down during peak loads.  A good plan would make the sensible decision to keep an old fossil fired plant around to help the system meet peak loads.  Fossil-fired steam boiler electric generating units are a proven technology that can be used to meet this need.

For many years New York City peak load requirements were met with simple-cycle gas turbines installed in the early 1970’s.  However, those units were old, inefficient, and had unacceptably high emission rates so, after a multi-year process of reliability planning the State has instituted a regulation to phase them out.  After the regulation was promulgated the Environmental Justice (EJ) community glommed on to the issue of peaking power plants: “Fossil peaker plants in New York City are perhaps the most egregious energy-related example of what environmental injustice means today”.  Even though the poorly controlled peaking turbines are being phased out, the issue remains a point of contention.  Now the EJ organizations are demanding that all fossil-fired power plants in New York City be shut down including the remaining steam boilers even though they meet all emission limits and do not contribute to the alleged health benefits in disadvantaged communities near the facilities.  The proposed solution to use renewable energy and energy storage replaces proven technology with one that has not been proven on the scale necessary to keep the lights on in New York City.

Bad plans presume that a new technology can fulfill specific needs.  A necessary component of any future system is dependable emergency capacity.  For example, a system might need emergency capacity once every five years due to extreme weather either causing very high loads, an unexpected long-term outage of existing resources, or because of an extended drought of wind and solar resources.  A bad plan proposes a new technology for this emergency requirement. In order to provide capacity in a zero-emissions electric system a new category of generating resources called Dispatchable Emissions-Free Resources (DEFR) has been suggested to keep the lights on during periods of extended low wind and solar resource availability.   In Wyoming, PacifiCorp’s 2021 integrated resource plan (IRP) includes a resource labelled as “non-emitting peaker plants” that is unexplained but appears to be the same as DEFR. The New York Independent System Operator (NYISO)  2021-2040 System Resource Outlook states:

DEFRs that provide sustained on-demand power and system stability will be essential to meeting policy objectives while maintaining a reliable electric grid. While essential to the grid of the future, such DEFR technologies are not commercially viable today. DEFRs will require committed public and private investment in research and development efforts to identify the most efficient and cost-effective technologies with a view towards the development and eventual adoption of commercially viable resources. The development and construction lead times necessary for these technologies may extend beyond policy target dates.

 In both instances no specific technology has been specified.  The New York Scoping Plan DEFR placeholder is producing and storing “green” hydrogen for use when needed.   

This is the fatal flaw of the New York Scoping Plan.  The NYISO 2021-2040 System & Resource Outlook states that “To achieve an emission-free grid, Dispatchable Emission-Free Resources (DEFRs) must be developed and deployed”.  This magical resource does not exist!  The Scoping Plan uses “Green” hydrogen as a placeholder for the technology and predicts that it will be used on average around 3% of the time.   The fantasy of the Scoping Plan is that developing the infrastructure to produce hydrogen, store it, and then produce electricity in hydrogen fuel cells can provide affordable and reliable energy to keep the lights on.  The costs will be astronomical for a resource used so little presuming that the technological issues can be overcome.

What are the ingredients of a compromise plan?

As mentioned above good plansrecognize how people prefer to use electricity.  Electricity usage across a region rarely drops to zero, but at times demand peaks for limited periods of time.  It may make sense to build high fixed cost, low variable cost resources (Nuclear, Coal and Combined Cycle) to meet the baseload needs of system.  If the plant can run all the time with low variable cost the higher investment cost can be justified.  It does not make sense to put in such facilities to serve load levels that only occur rarely. For this component of the load it makes more sense to put in low cost infrastructure that might have higher marginal costs.  Between these two conditions there are loads levels that may be present for a few hours a day.  To meet these loads, it is usually better to put in plants with moderate costs and moderate marginal costs.  This is the thinking behind traditional utility planning which looked at peaking, intermediate and baseload needs in terms of generation fitted for those specific characteristics. There is one other type of generation, intermittent.  Intermittent typically was low-cost generation that although it could not be counted on, it could be used to back off generation using higher priced fuels.  In looking at the ingredients below it will helpful to consider where they may be most appropriate. 

Wind, Solar and Batteries can work to displace fossil fuel generation.  With backup from batteries the energy provided can be made to have more value.  Unexpected and innovative changes in the capabilities of batteries could be a game changer, but it is too soon to count on timing in this arena.  The narrative that these “zero-emissions” resources have zero downsides is false.  The construction of wind and solar takes a lot of resources; their construction has a lot of environmental consequences; and fabrication uses a lot of energy that will be difficult to displace away from fossil fuels (making steel for example). 

Nuclear power works well to meet baseload needs.  It also works supports the transmission system providing needed electrical characteristics commonly called Essential Reliability Services.   Nuclear plants can be planned and operated to provide some ramping and load following capabilities.  Nuclear offers the best opportunity to reduce dependence upon fossil fuels for electric generation because it is the only proven technology with no emissions that can be scaled up in the immediate future.

Hydro expansion is very unlikely.  Environmental considerations make it unlikely that additional locations for hydro generation could be developed.  Similarly, there are limited opportunities for additional pumped storage, but there may be some areas where such might be pursued.  Finally, geothermal plants when feasible are a good resource, but opportunities for exploiting this resource are limited.

Natural Gas combustion turbines and combined cycle are best suited to fill in the gaps when reliable and functional generation additions are needed. As more environmentally desirable units become capable of doing the job, eventually new construction should be halted and  existing units phased out as they age.  Keep in mind the US through fracking reduced CO2 more effectively than Germany did with their massive expenditures on “clean” resources.

Existing Resources such as coal- and oil-fired boilers should not be ignored for future plans.  It is extremely unlikely that new plants burning those fuels will be built in the US in the foreseeable future.  Clean coal was on the table a few years back, but highly visible failures coupled with environmental concerns have closed this door for a while.  The cost differential between oil and natural gas as well as the efficiency relative to a combined cycle combustion turbine precludes construction of oil-fired boilers.  However, the existing fleet of these plants could be kept around for limited peaking power needs, emergency power, and long-term temporary system needs.

Other potential ingredients to a future plan include technologies currently on the drawing board.  Examples include tidal energy, biofuels, fusion, big HVDC ties and so on.  These new technologies will have to prove themselves before they are employed as anchoring technologies in good plans.  Most new technologies will not prove themselves in the next 10 to 20 years if history is a guide.  But some might.  While we can’t dependably plan on unproven technology, we must be ready to jump on anything valuable that works.  Such technology will likely be available and workable in niche applications many years before they can be deployed more broadly in long term plans.

Smart Grids have also been touted as a component of future electric systems.  This is a favorite approach of visionary academics, to concerns about observed and emerging grid problems.  In the New York net-zero transition planning process many issues were dismissed with a call for “Smart Grids” as if that would magically solve everything.  Modern grids are “smart” but as  with any “smart” technology there are all kinds of applications that could be adopted, so of course it is not a panacea for future grid plans.

Energy Efficiency is another favorite future grid resource for the naïve.  When concerns about peak loads and the necessary infrastructure are raised, the response is to double down on energy efficiency and energy conservation programs to flatten the peak loads.  Of course, if the goal is to decarbonize by electrifying everything, then the load will have to increase to cover building heating, cooking, and hot water.  Add in battery electric vehicles and this approach can only hope to reduce the peak but it will never eliminate the need for a peaking power generation resource.

A Good Enough Plan

Assuming the plan is a compromise between net zero and a working power system, the biggest step would be to commit to getting as much nuclear power as possible into the mix as soon as possible.  This best supports the grid and reduces CO2.  We need to figure out how to get plants built more efficiently and quickly. Adding nuclear must be the centerpiece and driver for meeting emerging generation needs.  Under reasonable regulations, it is the only zero-emissions technology that can be scaled up and provide reliable and dispatchable power.

 The continued massive ramp up of wind and solar does not make sense currently.  There are major reliability concerns which would emerge with the introduction of high level of intermittent asynchronous wind and solar power.  Such programs distract from the needed focus upon nuclear programs.  As technology improves and better resource choice emerges, large scale existing wind and solar that requires some sort of dispatchable emissions-free resource are likely to become dinosaurs.

At this time, it appears that plans for the addition of fossil-fired plants would center around the gaps where new nuclear power can not be made available or meeting peak demand levels not met by current resource plans.  Natural gas plants will be a good compromise.  Lower cost combustion turbines will have long term value to aid with ramping, meeting peaking needs and providing emergency power.  Higher cost more efficient combined cycle plant will make sense the longer the delay for nuclear development.  They can serve variable load levels that occur regularly but vary considerably day to day.

The potential for additional hydro is low, but any ability to effectively exploit remaining opportunities should be considered.  Additionally, some areas may offer the potential for the addition of  pumped storage hydro or geothermal power  Hopefully battery technology will improve and its ability to support energy needs and the grid can be expanded and amplified.

The authors have recognized for years that the economics, even without all the environmental and regulatory considerations, will not support building a new steam boiler plant in the US.  Gas is just too cheap in the US compared to coal or oil.  New coal is a non-starter given the need for elaborate and expensive pollution controls.  However, this does not mean it makes sense to retire functioning coal, gas, and oil plants. In many cases they will be the best emergency back resource available across the board considering economics, environmental impact, and reliability. 

There is another economics aspect of our good enough plan that needs to be stressed.  The plan does not require the development and deployment of the magical dispatchable emissions-free resource that is a necessary component in a electric system that relies on wind, solar, and energy storage.  Eliminating the cost of a brand-new resource to fulfill a very limited role will make this approach cheaper than any net-zero alternative.

There is a segment of society that is invested in the need to do “something” about climate change by mitigating emissions.  A good enough plan would support R&D on clean technologies for future generation, energy storage, and transmission system support.  Currently, these clean technologies are simply not ready to provide reliable and affordable energy.  The developing world will not use zero-emission technologies until they can provide electricity cheaper than existing resources so this R&D is necessary for a global solution.   In addition, if the full life-cycle impacts of those technologies are considered, then they are not nearly as “clean” as commonly portrayed.


The proposed good enough plan provides direction but is not overly constraining. It’s hard to know the future, but it’s a safe bet that any plan will not anticipate some critical twists that will emerge down the road. This plan would lay a strong foundation.   A major shift to the nuclear plants that are the obvious best choice for baseload power, supplemented with natural gas units, and retention of on the ground facilities should be the framework of a good enough plan.  Good enough plans are also flexible so integration of newer technologies when and as warranted is a reasonable attainable path without major downsides. This good enough plan may get you to net zero before the more ambitious ones.  It is likely to have less carbon emissions than the more aggressive plans over time.  It certainly will be more reliable and affordable.

500 Posts

I wanted to mark the occasion of this, my 500th post, with a bit of retrospective since I started posting on this blog on January 11, 2017.  I did something similar on July 29, 2021 when I reached 300 posts.

The goal in my blog is to describe environmental issues from a pragmatic viewpoint.  Pragmatic environmentalism is all about balancing the risks and benefits of both sides of issues.  Unfortunately, public perception is too often driven by scary one-sided sound bites that must be rebutted by getting into details.  I have tried to show the complicated “other” side of environmental issues that gets overlooked during policy discussions. My background as a scientist and my earlier responsibilities to provide technical comments on new or revised regulations means that I tend to get bogged down in technical details that are, too be kind, wonky.  I have tried to tone down the technical aspects but have not been entirely successful.

Although my posts cover a wide range of topics that interest me there are two primary topics covered.  At the time of my 300th post, the Climate Act implementation process accounted for 109 articles.  Since then, 169 of the 200 latest published articles have addressed it for a total of 278 out of the 500 articles. I truly believe that the Climate Act “solution” will be far worse than the impacts of the problem they are trying to address and that does not consider the enormous costs.  I also have also written numerous articles on the Regional Greenhouse Gas Initiative (RGGI).  This greenhouse gas control program is frequently described as a success but I have not been able to resist pointing out the flaws in that belief.

The final question I have asked myself is whether my obsession with this blog has been a success and to me success is having people read the blog.  According to the WordPress statistics, the views of the blog have been steadily increasing and there have been over 28,775 visitors.  There is an option for people to like a post and those have been going up.  Comments have been a bit of a disappointment especially because many of the comments are simply approvals of references to previous posts. 

So where are the people coming from to find the blog.  Very early on Judith Curry included this blog on her blogroll and a large percentage of the visitors visited since then.  Tom Shepstone started reposting my articles at his Natural Gas Now blog starting 12/28/18 and he has spread my message in many reposts.  My thanks to both of them for bringing visitors.

I have also done blog posts for Judith’s site and Watts Up With That and there usually is a flurry of visitors after those posts.  Francis Menton has posted blog articles on my articles about the CLCPA implementation process which get re-printed on Watts Up With That.  The comments on my work in those posts dwarf the responses on the blog itself and I am sure the total views were larger too.  Recently the editor of the GreenCarJournal contacted me and asked if I would like to share my perspective but that did not result in a spike of visitors.

Most gratifying is the occasional contact from people whose work I respect offering advice, encouragement, and praise.  I have also heard that there are industry people who follow the blog. 

Another measure of personal satisfaction are the contact emails.  I get pleasure whenever I get something like this:

We are soul brothers. My background is in the green industry – Horticulture, arboriculture, landscaping, etc. I got into the world of pesticides because I really was convinced all pesticides were bad. Guess what… they’re not. If you read the label and do as you’re supposed to…

I feel obligated to do our part to reduce pollution, and waste but there are many who don’t know or care to know what the trade-offs are. There are way too many pushing change without considering all the ramifications.

Keep preaching brother and if I can be of help at any point, give me a shout.

The blog statistics describe what visitors are reading.  It is not a good sign that nearly half the viewers look at the home page, about page or menu. It appears that many viewers see what the page is about and have no interest to continue on. The most popular article by far is one on the proposed rebuilding of Interstate 81 through Syracuse.  I presume that the title matched some trending internet search term and they ended up at the site. Early on I did a post on the Paris climate agreement costs that also got a lot of views. I suspect it is a source of frustration to the state that when searching for specific Climate Act items my posts generally turn up.

Finally, it is a source of amusement to me that people from all over the world have visited the site.  Someone has visited the site from every country that is highlighted in the following map.  I also have listed the number of visitors from the more popular countries below that.

In conclusion this has been a rewarding experience for me.  I devoutly believe that it is important to keep busy during retirement and this blog keeps me busy.  Just when I get discouraged and think about quitting, some insane proposal or article comes up that provides more than enough incentive to keep writing.  My thanks to everyone who has read my work.

Climate Action Council Affordability Lost Opportunity

The Climate Action Council is responsible for the framework of the New York Climate Leadership and Community Protection Act (Climate Act) transition plan to meet the ambitious net-zero goal by 2050.  I recently published an article explaining why I think that they have failed to address key overarching issues. This post illustrates my specific concerns related to affordability based on a more thorough review of the Climate Action Council’s discussions.

Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies.  I submitted comments on the Climate Act implementation plan and have written over 250 articles about New York’s net-zero transition because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that the net-zero transition will do more harm than good.  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.

Climate Act Background

The Climate Act establishes a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will outline how to “achieve the State’s bold clean energy and climate agenda.”  The Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants quantifies the impact of the strategies.  That material was used to write a Draft Scoping Plan that was released for public comment at the end of 2021. In my recent article I provided a detailed explanation of the plan for the rest of the year and described the lost opportunities for the Council to provide meaningful guidance for the rest of the transition plan implementation.  I will only provide highlights here.

The meeting presentation for the 5 December 2022 Climate Action Council meeting described the remaining steps for 2022.  That meeting was the last chance for any desired revisions to the Scoping Plan draft. The last draft will be circulated the week of December 12 and the Council will vote on it on December 19, 2022.  Next year the Department of Environmental Conservation (DEC) will promulgate enforceable regulations to ensure achievement of the Statewide GHG emission limits. This is a very ambitious schedule and it will be hampered by the fact that the Scoping Plan is only a framework.  It does not include a feasibility analysis so it is not clear how regulations can be promulgated when the implementation risks to reliability, affordability, and the environment are unknown. 

In my previous article I noted that I was very disappointed by the Climate Action Council response to comments.  There is no sign that the Hochul Administration considered the comment period as anything but a bothersome obligation that had to be fulfilled.  It was certainly not considered an opportunity to improve, correct, or clarify the Scoping Plan.  Because there were over 10,000 unique comments submitted, the Administration used Agency staff to review the comments.  Staff organized the comments into themes for presentation to the Council.  Summaries of public comments by theme were presented to the Council at five meetings this fall.  That is a tremendous amount of information that I have just started looking at in detail.

Affordability Discussion

In my previous article I argued that the Hochul Administration’s leadership on the Climate Action Council inappropriately catered to the ideological biases of the members and, as a result, focused on relatively minor details at the expense of significant overarching issues.  I described example issues associated with the lack of response to my personal comments and the lost opportunity to provide meaningful guidance for issues associated with reliability, affordability, and cumulative environmental impacts.  My over-riding concern is that conditional guidance is necessary for safe regulatory implementation.  This post addresses more detailed issues associated with affordability and provides some insight into the Hochul Administration’s response to public comments.

The discussion of the public stakeholder comments had four components.  The meeting presentations had slides that described the public comment themes.  An Agency staff person gave an overview of those slides and then explained the Agency staff recommendations to modify the Scoping Plan draft to address those themes.  The final component of this review of public comments was a discussion with the Climate Action Council members.

I am going to limit this affordability discussion to the electric system chapter of the Draft Scoping Plan although I know that the reliability issue was discussed elsewhere.  The Electricity feedback discussion came up at the 10/25/22 Climate Action Council Meeting.  The following slide is the primary instance where affordability is mentioned. 

In her presentation on the themes, Jessica Waldorf described the summary electricity themes developed by Agency staff using this slide as part of the presentation.  My general impression of the summaries to the Council is that there was clear bias in the theme presentations – anything inconsistent with narrative was disparaged, downplayed, or ignored.  In this example, even though affordability was the lead issue in the summary theme slide it was not mentioned in her overview.  She summarized phasing out fossil fuel power generation infrastructure without mentioning affordability.  The consistent narrative of the Hochul Administration is that the Climate Act transition does not have any affordability issues and it was ignored here.  Administration priorities such as the bitcoin mining ban and the reuse of fossil plant sites were highlighted. According to the minutes:

Phasing out fossil fuel power generation infrastructure, including a ban on bitcoin mining and reusing existing fossil fuel power plant sites for battery storage or low-carbon fuel networks, support and opposition to nuclear generation, and continuing the Tier 2 program to support existing hydropower and renewables to ensure baseline renewable generation.

To her credit the description of the Staff recommendations for changes to the draft Final Scoping Plan did address affordability as the Minutes note:

The responsible and equitable phase out of fossil fuel generation facilities by adding and clarifying text regarding the potential repurpose of fossil fuel generation facilities, coordinating with the New York State Reliability Council and the New York State Independent System Operator in the reliability planning process, prioritizing the retirement or repurposing of fossil fuel generating facilities in Disadvantaged Communities, and maintaining energy affordability and reliability during decarbonization.

On the other hand, the slide used for the presentation put affordability as the last topic.

The final component of the Climate Action Council public comment discussion is Agency Staff response to comments from Climate Action Council Members.  Affordability was the first topic raised.  According to the minutes:

In response to an inquiry from Dr. Shepson as to the definition of “energy affordability”, Ms. Waldorf responded that the Gas System Transition Subgroup defined it to be consistent with NYS Public Service Commission policy which ensure that consumers don’t suffer from more than 6% of their income on their energy burden.

In response to a comment and inquiry from Raya Salter regarding energy affordability, believing that using the word “maintaining” is a misnomer given her belief that New York is among the most expensive energy cost states, and whether the Inflation Reduction Act opportunities have been considered to reduce energy affordability burdens, Ms. Waldorf responded that the recommendations do address the possibility of price volatility, including the potential for federal funding to mitigate price volatility. Mr. Mas noted that the final Integration Analysis will include references to the potential opportunities from the Inflation Reduction Act within each of the sectors. Ms. Salter noted the importance of keeping equity and justice at the center of the price volatility considerations.

Affordability Lost Opportunity

In my previous post about the Climate Action Council’s lost opportunities to responsibly lead the process, I noted that every jurisdiction that has tried to implement a similar transition plan has seen significant price increases of electricity (see the following figure)  The missing piece in the affordability presentation and the apparent direction of the final Scoping Plan is completely ignoring the possibility that the costs of the transition could be so high that the implementation on the Climate Act mandated schedule may not be feasible.  My comments raised the concept that implementation should be conditional.  If the transition exceeds the affordability, reliability, and environmental impact thresholds determined by the Council that re-assessment at least is appropriate.  In my opinion this decision could extend to a full stop on the transition until the technology catches up with the ambition.

In my previous article I said that the Climate Act Council should have discussed affordability but reviewing the documentation that came out after I had drafted the article, they did discuss it.  However, the discussion was inadequate because it missed the main point.

Dr. Shepson asked the appropriate question: what does “energy affordability” means in quantitative terms.  Waldorf responded that the Gas System Transition Subgroup defined maintaining energy affordability to be consistent with New York State Public Service Commission (PSC) policy which ensures that consumers don’t suffer from more than 6% of their income on their energy burden. Raya Salter said “maintaining” is a misnomer because she believes that New York is among the most expensive energy cost states, so “It is not affordable now.”

As has been the case with every aspect of the Climate Act transition I have looked at in detail, this is more complicated and has implications beyond the pronouncements from the authors of the Scoping Plan.  The PSC Energy Affordability Policy (EAP) states: “an energy burden at or below 6% of household income shall be the target level for all 2.3 million low-income households in New York” per Case 14-M-0565, Order Adopting Low Income Program Modifications and Directing Utility Filings, p. 3 issued May 20, 2016.  Department of Public Service Proceeding, Case 14-M-0565 – Proceeding on Motion of the Commission to Examine Programs to Address Energy Affordability for Low Income Utility Customers, sets up a Percentage of Income Payment Plan.  In the New York plan funding is provided to low-income households such that their energy burden is kept at or below 6%.  The relevant problem is that there is an upper limit on program funding.  If electricity costs increase too much than that limit will be exceeded and more people will have energy burdens exceeding the 6% of household income policy goal.

Shepson and Salter almost got to the main point but fell short.  It is not sufficient to just reference the PSC Energy Affordability Policy.  The Climate Action Council should have discussed the implications of the metric and whether it is appropriate for this application.  The discussion should have addressed the following.  It is not clear whether all low-income households comply with that metric now.  What is the status of the funding relative to the upper limit on program funding?   If in the future that metric is exceeded then what?  There also is a presumption that energy poverty is only a problem with lower income households but the numbers affected are tied to the definition of an acceptable energy burden.  The Council should have discussed these over-arching issues and current state policies explained to the Council.  I also believe that the State should track the status of energy poverty burden current status numbers.  It is not available as far as I can tell on the Open NY website that is the supposed repository of all New York quantitative data. 

I submitted the following comment on the Draft Scoping Plan that addressed these issues.  Apparently, it did not rise to the level where it was a theme that should have been addressed.

Because there are limitations to existing technology the Final Scoping Plan must incorporate conditions based on reliability and affordability.  The Climate Action Council should define the criteria for reliability and affordability and then establish conditions incorporating those criteria.  For example, a recent legislative proposal included a requirement for state agencies to identify policies to ensure affordable housing and affordable electricity (defined as electricity costs no more than 6% of a residential customer’s income) for all-electric buildings.  Alternatively, Addressing Energy Poverty in the US offers other possible criteria:

“According to the U.S. Department of Energy, the average energy burden for low-income households is 8.6%. That is three times higher than for non-low income households, which is about 3%.  And according to the Kleinman Center for Energy Policy at University of Pennsylvania, more than one-third of US households are experiencing “energy poverty,” having difficulty affording the energy they need to keep the lights on and heat and cool their home.” 

Once the Council has established the appropriate affordability metric and the current status of that metric has been determined, then a condition using the metric can be established.  For example, if the criterion is that the average energy burden cannot increase above the average and the Integration Analysis projects that a certain mitigation strategy could lead to an increase above the average then that strategy should not be implemented until the costs come down or a subsidy can be set up to prevent exceeding the criterion.

Ultimately, I believe the Council should have spent more time discussing what the quantitative measure of affordability should be.  It is not clear when, at the end of 2021, there were 1.267 million utility accounts in arrears totaling $1.7 billion whether the PSC Energy Affordability Policy is working and how well it represents the current state of utility costs.  Raya Salter is correct saying there is a problem now and even maintaining current levels is unacceptable.

I believe that the Council should establish an affordability metric and provide status information.  If the costs exceed some acceptability threshold that they define, then I believe there should be a response.  I believe that the tremendous costs of the Climate Act transition will exceed any reasonable threshold for acceptability.

I am also disappointed that the Council did not work with the Climate Justice Working Group on the topic of affordability for those least able to afford energy price increases.  For all the social justice concerns addressed why wasn’t prevention of regressive energy price increases on disadvantaged communities a priority.  The poor will be hit hardest by any energy price increase and there was nary a peep of concern.  There should have been a push to provide the energy poverty metric determined by census tract so that any disproportionate impacts on disadvantaged communities could be tracked and addressed.


The affordability issue is a prime example of the Hochul Administration’s failure to address any issues raised that are inconsistent with their narrative.  In this case the narrative is that the costs of inaction are greater than the costs of action and that cost impacts to will be small and manageable.  This flies in the face of the results at all other jurisdictions that have tried to implement something similar. 

I am disappointed that my comments on affordability did not rise to the level of a theme whereby they warranted a mention in the Agency Staff presentation on public comments received.  More concerning is that the concerns of the Climate Action Council members were given short shrift.  Shepson and Salter almost got to the core issue that there are “what if” questions related to the 6% PSC policy but in the rush to meet the deadline they got an answer that was not responsive.  The Stafff answer does not address how to quantify reliability vis-à-vis the PSC policy and does not necessarily address the on-going problem of energy affordability.

Replacing Peaking Power Plants with Battery Energy Storage Systems

In the last couple of years environmental advocates have vilified peaking power plants in their endless quest for zero risk to Environmental Justice (EJ) communities.  There is no benign way to generate and distribute electricity so every option has drawbacks.  I do not believe that the advocates understand that replacing a fossil-fired peaking power plant with their preference for “clean” energy and battery energy storage has risks that are potentially worse.

Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies.  This requires a pragmatic approach.  The purpose of this blog is to describe the environmental tradeoffs associated with energy production and use in New York.  I am motivated to write this article because I have been intimately involved with New York’s peaking power plants for a couple of decades.  I believe the State’s policy appeasement of the environmental advocacy organizations is ill-founded and dangerous.  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.

Peaking Power Plants

Peaking power plants are used to balance generation and load.  I recently described a paper that explains that electric load varies substantially: “Variations in demand profiles and the existence of demand peaks are caused by variation in weather, end-use technology stock, and, ultimately, consumer preferences and behavior”.  Developing an electric system that reliably provides power for these demand peaks has always been part of the planning process for electric power systems.  While on the face of it, for example as described in Wikipedia, the use of peaking power plants seems to be simple the reality is much different. 

In 2020 the PEAK Coalition released a report entitled: “Dirty Energy, Big Money” that vilified peaking power plants in New York City.  The PEAK coalition’s goal is to “come together to end the long-standing pollution burden from power plants on the city’s most climate-vulnerable people”.  They claim their efforts are the first comprehensive effort in the US to reduce the negative and racially disproportionate health impacts of a city’s peaker plants by replacing them with renewable energy and storage solutions.

At the time I evaluated the technical analysis for the PEAK Coalition report by Physicians, Scientists, and Engineers (PSE) for Healthy Energy. I described my evaluation in three detailed technical posts.  The first post provided information on the primary air quality problem associated with these facilities, the organizations behind the report, the State’s response to date, the underlying issue of environmental justice and addressed the motivation for the analysis.  The second post addressed the rationale and feasibility of the Coalition’s proposed plan relative to environmental effects, affordability, and reliability.  Finally, I discussed the  Physicians, Scientists, and Engineers (PSE) for Healthy Energy report Opportunities for Replacing Peaker Plants with Energy Storage in New York State that provided technical information used by the PEAK Coalition.  Because those were technically oriented and long, I also prepared a simpler summary post that addressed all my concerns.

I concluded that the claims that peaking power plants are dangers to neighboring environmental justice communities are based on emotion.  In the evaluation I did of the PSE analysis and the PEAK Coalition report, I found that the alleged impacts of the existing peaking power plants over-estimates impact on local communities relative to other sources.   The primary air quality health impacts claimed are associated with ozone and inhalable particulates that are secondary pollutants.  While some inhalable particulates are emitted directly, most of the particulates and all of the ozone form after they are emitted and transported away from the disadvantaged communities peaking power plant closure is supposed to protect. 

In my previous work I discussed feasibility challenges associated with the solar plus energy storage “solution” advocated by PSE and the PEAK Coalition.  I believe that it will markedly increase costs significantly and it may not even work because solar and energy storage is not a proven technology on the scale necessary to provide New York City’s peaking power requirements.  Until such time that the state’s organizations responsible for reliability confirm that those technologies are adequate it simply is not safe to rely on them.  This post is going to address another pragmatic tradeoff – the relative potential environmental and health impacts of the so-called “zero-emissions” solar plus energy storage alternative.

New York Peaking Power Plant Environmental Policy

In order to address the peak load power requirements, New York utilities have relied on two types of generating resources: purpose-built units and existing but aging and inefficient units.  The primary peaking power plant issue is in New York City where generating units are necessarily close to residential neighborhoods.  Around 1970 Consolidated Edison of New York installed about 100 simple cycle combustion turbines to provide peaking power and also maintain reliability in specific regions of New York City and Long Island – known as load pockets. Load pockets represent transmission-constrained geographic areas where energy needs in that area can only be served by local generators, due to the inability to import energy over the transmission system during certain high-demand conditions.  These units were cheap but not particularly efficient or clean.  After de-regulation they were sold to several generating companies who considered replacement with efficient modern and clean units but despite the fact that permits to build replacements were approved no one ever built one.  I believe this occurred because the developers did not think that they could recover the costs of building the replacements.  I think that reflects the difficulty financing a facility that only operates infrequently.

However, the continued operation of the purpose built inefficient and dirty peaking turbines is coming  to an end due to the New York Department of Environmental Conservation’s (DEC) “Peaker Rule”.  The rule sets new limits on nitrogen oxides emissions from simple-cycle combustion turbines in a phased implementation from 2023 to 2025 that effectively forces them to install controls or be retired.  Importantly, the rule included an electric system reliability subpart that ensured that the units would not retire until replacement power was available as determined by the “New York Independent System Operator (NYISO), the local transmission/distribution owner, or the New York State Public Service Commission”.  This rule sets a good precedent for how electric generating units should be retired due to environmental policy.

The other source of peaking generation is older units that are no longer efficient enough to compete for normal operations.  New York State has quite a few large steam boilers that were designed to burn residual oil.  Over time the cost differential between oil and gas has shifted such that residual oil is rarely a cost-effective fuel to burn.  Consequently, those steam boilers run very little and survive primarily to provide peaking power support. In addition, New York City has specific reliability requirements for in-city generation that mean that despite their low operating times those large steam boilers are paid for their ability to provide that service.  The reliability requirements also mean that any replacement options for these facilities also have to be located in New York City.

At this time DEC is proposing guidance changes to the permitting process that will address the eventual retirement of these units to meet Climate Act mandates.  It is worrisome that the lessons learned from the successful Peaker Rule don’t appear to be incorporated.  Moreover, DEC is modifying its regulations for public participation in the Uniform Procedures Act apparently to appease the environmental advocates.  I am convinced that the common theme in any public comments will be shut down the boilers and replace them with clean energy and battery energy storage without acknowledging the issues described in the next section.

Advocacy Replacement Proposal Issues

The crux of the problem is that  environmental advocacy organizations and the PSE Opportunities for Replacing Peaker Plants with Energy Storage in New York State propose similar solutions for the purpose built turbines as the steam boilers.  In 2019 the Department of Public Service released a report that studied the potential replacement of peaking units with energy storage that was adopted as proof that energy storage technology could be used for all the peaking power plants even though that report was concerned primarily with the peaking turbines.  The PSE report did not differentiate between small peaking turbines and much larger steam boilers.  In addition to the local air quality impact concerns, the Climate Leadership and Community Protection Act includes a mandate to make the electric grid zero-emissions by 2040.  As a result, environmental advocacy groups are lobbying hard to shut down any remaining units, including the steam boilers, that operate infrequently enough to be classified as peaking units.  Their plan is to phase out fossil fuel peaker power plants and replace them with clean renewables and battery energy storage system (BESS) technologies. 

I believe PSE has misled the advocacy groups that their control alternative is a viable option for large boilers.  There are two problems with large boiler replacement.  The first is the size of the boilers.  The following table lists the remaining New York City steam electric boiler units.  They are all old and some run under 5% of the time.  Next year the majority of the operating (Title V) permits for the boilers will expire. In New York City, the smallest boiler is 146 MW, there is a total of 2,095 MW of boilers that operated less than 5% of the time in 2021 a total of 3,555 MW of boilers whose operating permits expire next year, and total of 3,887 MW of steam boiler capacity in New York City.  The cost of replacing that amount of capability will be very high at a time of increasing energy costs.

New York City Steam-Electric Boilers

The second boiler replacement problem is the space necessary for a battery array that can provide the energy equivalent to any of the electric-steam boilers still operating in New York City.  I was unable to find spatial requirements on the web so I base my estimates on the Elkhorn Battery facility at Moss Landing in California.  Elkhorn Battery consists of a total of 256 Tesla Megapacks, the total energy capacity is 730 MWh, and power output is up to 182.5 MW, As shown in the following view there are 132 cubical structures that apparently hold two Megapacks each.  I estimate that one third (in the 4 by 11 configuration) of the Megapacks are rated at 60.8 MW and produce 243 MWh cover an area of 240 by 280 feet which works out to around 1.5 acres.

Google Maps view of the Elkhorn Battery array at Moss Landing, California

Using that estimate of spatial requirements I estimated the New York City acreage necessary to replace steam electric boilers with the clean energy and battery storage option.  Replacing the smallest boiler would require 3.6 acres. Replacing the 2,095 MW of boilers that operated less than 5% of the time in 2021 would require 52 acres.  Replacing the total of 3,555 MW of boilers whose operating permits expire next year would require 88 acres.  Finally, replacing all the steam boiler capacity in New York City would require 95.9 acres.  Space in New York City is at a premium so the area needed may not be available.

One other point is that these spatial estimates are based on power (MW) capabilities.  At this time battery energy storage systems only provide energy for four hours.  Because peak load requirements can be greater than four hours and these steam boilers can run throughout a load peak, the number of batteries necessary to provide that energy is significantly greater than shown here.  I believe that when the full energy requirements necessary to replace the steam boilers is calculated it will be determined that there is insufficient room available in New York City to provide equivalent capabilities.

Energy Storage System Environmental Risks

In addition to logistical implementation issues, there are environmental tradeoffs and safety risks.  The Tesla Megapack lithium-ion batteries are similar to the ones in electric vehicles.  Michael Mills explains that there is no such thing as a “zero-emissions” vehicle.  He points out that you don’t eliminate emissions you export them.  This also applies to BESS components but I am not going to discuss this hypocrisy anymore in this post.

Instead, I am going to focus on the potential risks of BESS thermal runaway fires and explosions.  Paul Christensen, Professor of Pure and Applied Electrochemistry at Newcastle University in the United Kingdom gave a presentation at PV magazine’s Insight Australia event in 2021 that describes the risks.  He is one of the world’s leading experts on battery fires and safety and said global uptake of lithium-ion battery technology has “outstripped” our knowledge of the risks.  I recommend the entire presentation as a good overview of this issue.

His primary concern about battery fires is described in the presentation.  Once a battery is abused the chemistry can become unstable.  If it does that generates gases and heat, the heat creates more gases and the potential exists for a thermal runaway reaction.  The following slide illustrates the relationship. 

Christensen explains that:

In thermal runaway and prior to ignition, lithium- ion batteries produce a white vapour which consists of: hydrogen (ca. 30-50%), carbon monoxide, carbon dioxide, hydrogen fluoride, hydrogen chloride, hydrogen cyanide, small droplets of the organic solvents, ethane, methane and other hydrocarbons, sulphur dioxide and nitrogen oxides, i.e. a vapour cloud.

He explains that thermal runaway runaways should be prevented by safety systems, but he points out that fires and explosions are still occurring on land, sea, and in the air.  His presentation included the following slide that lists Lithium Ion Battery Energy Storage System (LiBESS) events.  The acronym VCE stands for vapor cloud explosion on the list.  Also note that since the presentation, the Moss Landing facility had another fire incident on September 20, 2022 that shut down traffic and resulted in a shelter in place advisory.

Christensen explained that the Korean government is leading the world in LiBESS developments and the presentation included a description of a translation of the official South Korean government report on LiBESS fires:

It is likely that these safety flaws are not unique to battery systems and BESS made in Korea. It is more likely that the large amount of BESS installed in Korea has made the flaws evident earlier. These flaws are also likely to exist in BESS and battery systems that were not made by Korean manufacturers.

BESS safety can only be fully assessed on the system level. A safe battery cell is the foundation for a safe BESS, but not a guarantee. The historical strong focus on cell safety only has led to avoidable slips in the technical risk management of BESS projects as a whole. Therefore, the safety assessment of the BESS should cover all hazards, not just the electrochemical related hazards.

The LG Chem report on SK incidents blames:

  1. Inadequate design of the electrical protection system
  2. Inadequate control of the operating environment within system enclosures
  3. Careless installation practices that degraded system integrity
  4. Inadequate ESS system control and protection

Failures could only be reproduced with multiple stresses, e.g.: High humidity + Common Mode Voltage (CMV) aka Common Mode Noise.

Christensen describes the characteristics of the thermal runaway plume and then he shows frightening examples of tests of vapor cloud fires and explosions.  The intensity of the fires and the toxic gases mean that fire fighters cannot put the fires out safely.  They just have to let them burn themselves out and hope that the fires don’t destroy anything other than the batteries and their enclosures. 


The peaking power plant issue is a poster child example of the dangers of environmental advocacy organizations misplaced focus on one issue.  Disparaging ugly peaking power plants in neighborhoods makes for a great sound bite rallying call to stir up action.  However, the argument that those facilities are the root cause of significant health issues rings hollow because the primary air quality effects are from secondary pollutants that form after the emitted pollution has been transported away from the neighborhood.  Moreover, my bet if an air quality monitoring attribution analysis was done in the so-called “asthma alley” that advocates mention in their press releases, is that fossil-fired power plants would not be the dominant component.

Nonetheless, the Hochul Administration is pushing for closure of power plants in New York City.  According to the LS Power website:

On October 17, 2019, the PSC granted a Certificate of Public Convenience and Necessity (CPCN) for LS Power’s proposed 316-megawatt battery energy storage project at the Ravenswood Generating Station in Long Island City. Additionally, the Ravenswood storage project was accepted in the New York Independent System Operator (NYISO) 2019 interconnection facility study process, and is therefore well positioned to be able to meet a 2022 in-service requirement.

A trade press article about the Ravenswood renewable redevelopment plans states:

Energy asset developer Rise Light & Power will redevelop its 2,480MW Ravenswood Generating Station – New York City’s biggest power plant – as a new renewable energy hub including on-site energy storage.

The 27-acre site in Queens will be turned into a hub integrating various clean energy sources, although the press release is not clear on when the fossil fuel units will be retired nor exactly what renewable capacity will be built on-site.

It does make clear that large-scale battery energy storage will be deployed directly on the facility site, which currently powers 20% of New York City’s needs.

The redevelopment will repurpose existing infrastructure to connect thousands of megawatts of offshore wind and onshore wind, solar, and other clean energy resources from Upstate New York to the City’s grid, a press release said. Ravenswood’s river water intake system will also be repurposed to provide zero-emission thermal energy to nearby communities.

LS Power is proposing a 316 MW BESS on a 27-acre site in New York City.  According to my estimates that requires 7.8 acres for equivalent battery energy storage.  I could not find any details of the proposed plan but they necessarily must pack the batteries closer together than the battery array at the Elkhorn Battery in Moss Landing, CA.  Given that facility has had two fires since it began operating a little over a year ago and the Christensen presentation shows how dangerous those fires can be, my impression that is not such a good idea.  Dr. Christensen’s remark that he is “astounded and appalled that if there is no appreciation of the safety issues involved” certainly should prompt an extensive safety review before this facility is permitted and constructed.


I conclude that until you have a viable alternative, and I submit that the renewable energy battery storage option is not viable, then it is premature to shut down the existing fossil fired peaking generation in New York City and the state.  Not only will the closures have minimal effect on health impacts but closure could affect reliability.  Given the impacts of New York City blackouts I don’t believe any threats to current reliability standards should be accepted.

Furthermore, the proposed alternative of renewable energy and energy storage systems has to overcome space constraint issues and is not proven technology.  When a leading expert on batteries says “Everybody has to be educated how to use these batteries safely”, I think the best course of action is to follow his advice.  It is not appropriate to make the residents of the disadvantage communities near a BESS become unwilling lab rats to test whether a technology that can generate toxic gases, fires, and explosions is appropriate in an urban setting. 

Another unrecognized constraint by the environmental advocacy organizations is the financing model for a necessary resource that only operates a few times a year.  Purpose-built peaking generation resources to this point have relied on the cheapest resource available such as simple-cycle combustion turbines.  While an argument may be made that some renewable generation resources are competitive with simple cycle turbines the requirement in New York City is for a dedicated resource capable of providing peaking power on demand.  That means that the renewable resources, the transmission to get that power to New York City, and the BESS to provide that power have to be dedicated to this requirement.  I believe those costs will be several multiples greater than any fossil-fired alternative so financing and operation costs will be a problem. 

Of course, the environmental advocate argument is that it is necessary to address climate change.  Paraphrasing Tom Shepstone, my ultimate concern is “It is profound climate misinformation to suppose global warming is such a threat that any action, no matter how risky, is somehow preferable to a fossil fuel alternative without those risks”.

Updates to Pragmatic Environmentalist Pages

This is a second summary of updates I made to the pages I maintain at  Pragmatic Environmentalist of New York and Reforming the Energy Vision Inconvenient Truths.  I have an extensive list of reference materials on my original blog that I occasionally update when I run across an article that is particularly interesting and relevant and this blog also has reference material.  This article describes some recent page updates and I also have highlighted a few recent articles that don’t fit my needs on those pages.

I started blogging in late 2017 on New York’s energy policies because I was convinced that they are going to end as an expensive boondoggle driving electricity prices in particular and energy prices in general significantly higher. Reforming the Energy Vision (REV) was the previous comprehensive energy strategy for New York. I wrote about the inconvenient unpublicized or missing pieces of New York State’s REV policy: implementation plan, costs and impacts. At some point I should probably combine that blog with this one but in the meantime, I will maintain them both.  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.


I added links to three articles on the Renewable Energy Feasibility page including two videos. Michael Mills Prager University video “How much energy will the world need?” explains that oil, natural gas, and coal provide 84% of the world’s energy today despite great expenditures to wean the world off fossil fuels over several decades.  He points out that the materials needed to develop wind and solar require massive amounts of mining to produce which in turn requires major increases in energy use.  Dr. John Robson Climate Discussion Nexus video “American Energy for Grownups” describes how the Biden Administration’s goal of phasing out fossil fuels has increased the difference between supply and demand such that costs have increased dramatically.  In addition, Robson explains that due to environmental regulations and climate regulatory expectations has led to a lack of infrastructure investments.  He points out that the existential threat of climate change claims are overblown and that the actual effects of greenhouse gas emissions on climate change are vastly out-weighed by the benefits of plentiful and affordable energy provided by fossil fuel use.  Most recently, Francis Menton sums it all up showing that society cannot develop “green” energy using only green energy. 

I added a link to the Electric Heating page that describes a proposed Department of Energy rulemaking on energy conservation standards for residential furnaces.  Robert Bradley describes this proposal seeks to “regulate/prohibit gas furnaces on a pure physical efficiency standard, demoting up-front cost considerations, as well as back-end reliability issues (such as when the power goes out).”  He describes comments submitted by free market advocacy groups that argues that “A fair-field, no-favor competitive market for home and business heating—a let the market decide policy—is the obvious choice in place of one-size government policy from Washington, DC.”  I added the link because the article eviscerates the climate impact rationale for the revised standards and provides links to other articles about the decarbonization efforts to eliminate the use of natural gas in homes.

As soon as Hurricane Ian hit the Florida coast the usual suspects came out and claimed links to global warming.  Chris Martz did a great job reviewing the claims made and examined the claims to see if they held up to close examination.  He found common themes and rated them for accuracy.

Hurricane Ian tied with several others as the 5th most intense to strike the Contiguous United States since records began in 1851.  This was rated true but debatable because the measurement methodology has changed over time and that could affect the ratings.

Storms like Hurricane Ian are becoming more likely because of human-caused climate change. Martz provided detailed information and many examples that shows that this is a false claim.

Globally, we are observing stronger tropical cyclones; a greater proportion of hurricanes are reaching major hurricane status.  Martz provided detailed information and many examples that shows that this is a false claim.

Rapid intensification (RI) events (30-knot increase in 24-hours) are becoming increasingly common because warmth from rising sea surface temperatures (SSTs) is diffusing into deeper layers, increasing the fuel, or ocean heat content (OHC) for hurricanes.  Martz explained that the information necessary to calculate these events is only available for a limited time and showed that it proves this is a false claim.

The size of storm surge has increased due to both sea level rise (SLR) and increasing tropical cyclone size.  Martz argued that there is missing context from this claim.  “Sea-level rise could certainly prove to be a major issue for coastal communities during the next couple of centuries assuming rates either remain constant or accelerate. However, that’s an entirely separate issue from the size of a hurricane’s storm surge, and with current scientific understanding, discernable trends in magnitude remain to be seen.”

Climate change upped rainfall amounts in Hurricane Ian by at least 10%. For every 1°C rise in ocean surface temperatures, the amount of water evaporating into the atmosphere increases by 7% which exacerbates flooding from extreme rainfall.  Martz explains that “Oversimplifying a complex issue leads to erroneous results and flawed reasoning” and shows that the claim is false.

Paul Homewood did an article that reminds us just how destructive mining for lithium needed for electric vehicles is to the environment.  He references an article that describes how water quality, wildlife populations, and crops are all adversely affected by lithium mining.  He concludes with a question that bothers me too: “It is one of the great mysteries why the green movement in general is not actively campaigning against this”.

Other Posts of Note

Jo Nova described French President Macron response to the Yellow Vest protests a couple of years ago. His government chose 150 people who spent nine months learning climate science to figure out what the other 65 million French citizens would have chosen had they been there. Naturally, they were marinated and baked in approved ClimateThink, and no dissenting scientists or citizens were invited.  The result was predictable:

After this intense love in, they came up with a list of policies as big as a phone book, the government picked the ones they were probably going to do anyway, and flicked the ones they weren’t and then proclaimed the citizens had spoken! In theory there was supposed to be a Referendum option at the end, but this, well, nevermind, became just another round of votes in Parliament.

I mention this because it is similar to New York’s Climate Action Plan response to comments.  In New York the 22-member Climate Action Council (plus one added to appease the labor constituency of Hochul’s demographics) and the 13-member Climate Justice Working Group decide which stakeholder comments get addressed out of the 35,000 comments submitted.  As far as I can tell there never has been any intention to address any issues raised that are inconsistent with the narrative.

Two articles make me pessimistic about the future.  Don Ritter led the National Environmental Policy Institute after leaving Congress. His commentary The Real “Existential Threat” To People and Planet argued persuasively that green policies that promote green energy and suppress fossil fuels are doing more harm than good.  I believed that once there was an unmistakable link between the green policies and a bad outcome that there would be an acknowledgement and similar policies would be off the table elsewhere.  Michael Schellenberger’s interview with Will Cain discuss the war on fertilizer (at 7:55 of the video) and the response to the Sri Lanka agriculture disaster.  They agree that agencies advocating the ban on fertilizer just blew off the problems and have moved on to advocate implementation elsewhere.  I believe that when the inevitable blackout occurs in New York all the Climate Act advocates will blame someone else and double down on their policies that caused it.

Climate Act Misinformation: Renewable Energy Reliability Risks

If you read this blog regularly you know that one of my persistent topics addresses the myth that the transition to the net-zero Climate Leadership and Community Protection Act (Climate Act) mandated targets relying on intermittent wind and solar resources has no potential reliability issues.  I have a long list of other potential topics to discuss but given its importance and the recent publication of a relevant blog post, I am going to try again to explain the reliability challenges embedded in the Climate Act implementation plans.   In particular I am going to call your attention to two recent blog posts The Penetration Problem Part I: Wind and Solar – The More You Do the Harder it Gets and The Penetration Problem Part II: Will the Inflation Reduction Act Cause a Blackout?.  This post excerpts some of the key points and explains the context relative to New York’s implementation plans.

Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies.  I submitted comments on the Climate Act implementation plan and have written extensively on New York’s net-zero transition because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that this supposed cure will be worse than the disease.  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.

Climate Act Implementation Background

The Climate Act establishes a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council.  Those strategies were used to develop the integration analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that tried to quantify the impact of the strategies.  That material was used to write a Draft Scoping Plan that was released for public comment at the end of 2021. The Climate Action Council states that it will revise the Draft Scoping Plan based on comments and other expert input in 2022 with the goal to finalize the Scoping Plan by the end of the year.

My concern about misinformation arises from the response to stakeholder comments.  The leadership of the Climate Action Council has overly emphasized responses to comments by the Climate Justice Working Group and certain members of the Council itself.  Because the favored few members were appointed to their positions because of their ideological opinions and not their technological expertise the over-arching legal mandate to provide input to the Scoping Plan that “shall inform the state energy planning board’s adoption of a state energy plan” has suffered.  The Climate Act has always been more about the politics than reality and the politicians who are driving this process naïvely believe that the technology needed is only a matter of political will.  Many of the appointed ideologues also ascribe to that view, and some of the more vocal members of the Council have downplayed reliability as a concern going so far to claim that those concerns are misinformation.  I believe there is no greater example of actual misinformation than the claim that there are no risks to reliability inherent in the net-zero transition plan described in the Draft Scoping Plan.

Reliability Concerns

I have previously written that the Climate Action Council has not confronted reliability issues raised by New York agencies responsible for keeping the lights on.  The first post (New York Climate Act: Is Anyone Listening to the Experts?) described the New York Independent System Operator (NYISO) 2021-2030 Comprehensive Reliability Plan (CRP) report (appendices) released late last year. The second post (New York Climate Act: What the Experts are Saying Now) highlighted results shown in a draft presentation for the 2021-2040 System & Resource Outlook that all but admitted meeting the net-zero goals of the Climate Act are impossible on the mandated schedule.  Recently I wrote about the draft of the 2021-2040 System & Resource Outlook report described in the previous article and the concerns raised.  Another post detailed the differences between the Resource Outlook and the Draft Scoping Plan Integration Analysis and recommended that those differences be reconciled in a public forum.  Most recently, I explained why the response to the reliability concerns to date has been even worse than I imagined possible.

There was never any response to my suggestion early in the process that everyone associated with the Climate Act transition get a briefing to explain how the electric grid works and highlight potential issues associated with the net-zero transition. As an example of potential topics I referred to the renewable energy systems page that I maintain.  The page provides links to posts that I recommend that anyone who is interested in researching the story behind the complexities of the energy system and relying on renewable wind and solar energy read.  All of the relevant articles by the author of the recommended articles are referenced there.

Retired registered Professional Engineer Russell Schussler writes under the pen name Planning Engineer at Judith Curry’s blog Climate Etc He initially wrote under a pseudonym so that his comments would not be taken as representing his employer.  He continues to use it there because he is well known at the website and he believes his ideas should stand on their own merits, not on claims of expertise.  He hasa BSEE is from The Ohio State University and a Masters of Electrical Engineering from University of Southern California. He worked in generation and transmission for over 30 years for different sized utilities, participated and held leadership roles in various research groups and reliability organizations before his retirement.

In the articles listed above I repeatedly tried to explain the risks inherent in the Draft Scoping Plan reliance on intermittent wind and solar.  I believe the Planning Engineer’s expertise and more accessible writing style makes a better case than I have to date so this post describes his concerns.

Wind and Solar – The More You Do the Harder it Gets 

In the first post Schussler explains:

There seems to be a belief that increasing the level of wind and solar projects will make subsequent progress with these resources easier. Nothing could be further from the truth.  Increasing penetration levels of wind and solar is like a Sisyphean task, except that it is worse. The challenge may be better understood as akin to pushing a huge rock which is getting heavier and heavier, up a hill of a steeper and steeper slope while the ground below gets slicker and more unstable. The problems associated with increased penetration swamp any potential benefits that might be achieved through economies of scale. 

He provides eight reasons why “increasing the penetration levels of renewables will lead to rapidly increasing costs as well as rapidly decreasing reliability”.   I have annotated my New York centric concerns relative to the Draft Scoping Plan to the list of his challenges below.  For further information I refer you to the original article.

Wind and solar do not readily supply essential reliability services. 

The Draft Scoping Plan does not consider these ancillary services in any meaningful way.

Wind and solar are intermittent resources and their availability/output often does not match or support system needs.

The New York Independent System Operator (NYISO) 2021-2040 System & Resource Outlook projected resources necessary to match system needs are significantly different than the resources in the Draft Scoping Plan.  There is no indication of any urgency to resolve those differences.

The success of wind and solar installations is highly location specific.

This is a particular concern for New York solar resources.  New York is not only a high latitude state with weaker winter insolation and shorter days but large portions of the state have high wintertime snowfall and cloudiness due to the Great Lakes.

Wind and solar depend on materials which must be mined and their ability may be limited.

The Draft Scoping Plan calculates life-cycle impacts for anything related to fossil fuels but ignores all life-cycle impacts for “zero” emission wind and solar components.

As wind and solar generation increase penetration it will become more and more challenging for other resources to subsidize their expansion.

The Draft Scoping Plan ignores this issue.

It takes a lot of energy to build wind and solar facilities.

The Draft Scoping Plan ignores this issue.

Wind and solar make the study, control and operation of the power system more complicated and uncertain.

The Draft Scoping Plan ignores this issue.

Widespread deployment of wind and solar would require that power be transmitted across great distances (or you would need an unrealistic and incredible amount of battery storage.) 

Th NYISO resource outlook raises transmission concerns but the Draft Scoping Plan ignores the issue.

Schussler talks about how the challenges might be overcome.  He argues that “it’s hard to imagine that any economies of scale would allow these resources to leap the formidable challenges” and that “it does not appear that significant improvements in economies of scale are to be expected”. He points out that nuclear energy could be a piece of the net-zero transition because none of the challenges apply.  Unfortunately, even though hydro is zero-emissions and works well with the power system, there are “negligible to no potential locations to expand hydro generation”.

He concludes:

It is way too soon to be envisioning a 100% renewable future with significant contributions from current wind and solar capabilities. It is not a good strategy to support current “green” technologies and retire and prohibit conventional generation hoping that a miracle will occur when we need it. Perhaps with the extensive deployment of nuclear power, carbon capture and other technologies we might be able to approach a zero-carbon grid. At best, current wind and solar technologies will play at most a small part in such a plan.

Will the Inflation Reduction Act Cause a Blackout?

The second post could have been renamed “Will the Climate Act cause a blackout” because the issues raised are directly applicable to the New York net-zero transition.  Schussler sums up the challenge:

Replacing conventional synchronous generating resources, which have been the foundation of the power system, with asynchronous intermittent resources will degrade the reliability of the grid and contribute to blackout risk. The power system is the largest, most complicated wonderful machine ever made. At any given time, it must deal with multiple problems and remain stable. No resources are perfect; in a large system you will regularly find numerous problems occurring across the system. Generally, a power system can handle multiple problems and continue to provide reliable service. However, when a system lacks supportive generation sources, it becomes much more likely it will not be able function reliably when problems occur.

I like his description of the cumulative effects of adding renewable resources:

Just as a pile of dry wood and flammable material can be sparked from many potential sources, or a very unhealthy person could succumb to many different threats, a weakened power system is more vulnerable to many conditions than a robust one. In this post I discussed responsibility for the Texas winter blackout. Many things went wrong that day in Texas. But often many things do go wrong – the real problem was that the Texas market did not provide incentives for standby resources.  In Texas there were not enough committed resources to provide for the system load levels and potential contingencies. Texas relied on an energy market designed to favor wind and solar resources and it failed them. However, many analyses of the Texas blackout focused on the proximate conditions (problems of the sort that are common) ignoring or denying the major underlying problem.

Heat Pumps

One of the key Draft Scoping Plan emissions reduction components for buildings is electrification of the heating system using heat pumps.  Schussler describes electric system issues with heat pumps as the number of heat pumps increased.  The argument in favor of heat pumps is that they are more efficient producing heat because they move energy rather than create it.  In his description of the technology, he states that:

Because of their behavior at colder temperatures, heat pumps are not appropriate for all parts of the country. In the north the many hours they would have to run with resistance heat makes them both environmentally irresponsible and too expensive. Natural gas is a better option. 

I think this is a fundamental problem in the Climate Act.  In their zealous pursuit of zero risk, they are foisting technology upon the citizens of the state that is not appropriate.  Of course, they have an answer: “In all scenarios electric heat pump space heating technologies are predominantly cold climate air source heat pumps (ASHPs) with electric backup and a significant role for ground source heat pumps (GSHPs)”.  I submitted 23 pages of comments on residential heating electrification and I argued that at many locations in the state all air source heat pumps will have insufficient energy to transfer and will require resistance heat backup.  The New York narrative is that they work in the Nordic countries where it is even colder so they should work in New York too.  Proponents neglect to point out that the reason they work there is that the housing units are smaller and much more energy efficient. 

The particular heat pump problem described by Schussler was that as more heat pumps were introduced the peak annual load shifted to the winter because during cold snaps inefficient electric resistance heating kicked in.  As a result, the electric system design requirements have to change and despite warning signs that this could be a problem, the resulting change in peak load requirements affected average energy costs.  He concludes this section noting that “While almost no one wanted to see it coming, once the effects hit, most everyone in the power supply chain wished they had. This was a terrible blow to rural electric cooperatives who had invested big to improve their load factor, only to find they had subsidized a worse winter load factor”.  Importantly, the same thing is coming to New York and someday down the road there will be unintended consequences.

Renewable Resources

Schussler goes on to discuss how the Inflation Reduction Act will enable blackouts by its encouragement of renewable resources. I believe New Yorkers can substitute Climate Act for Inflation Reduction Act to estimate impacts in the state:

The Inflation Reduction Act seeks to decarbonize the grid. In looking at the grid, you should not make one goal a priority but should instead seek to balance competing objectives. See Balance and the Grid for a discussion of how efforts to maximize one objective without due attention to other major goals can result in a worsening condition for all goals. It seems apparent that all the “green” measures in the Inflation Reduction Act were included because independently they all seem capable of reducing carbon. I have not seen any evidence that any consideration was given to system reliability or how these measures might interact to create problems.

Schussler then goes on to explain how the measures encouraged by the inflation Reduction Act, and Climate Act I believe, will lead to generic blackouts in many situations  He provides a specific prediction for the winter peak demand period: that I believe is applicable to New York:

Winter peaks can be extreme, much more so than summer peaks. As temperatures climb in the summer, air conditioners reach a saturation point. The climb in summer peak demand with each additional increase in temperature typically flattens out. In the winter each additional degree drop can increase demand more than the one before. There are a lot of potential sources of resistive heat that increase demand. In severe cold more and more heating elements come into play and the increase in demand rather than flattening can go up exponentially. Peak winter loads tend to hit just before sunrise. The system sees a rapidly rising peak, often described as needle shaped, which drops as the sun comes up and temperatures warm.  Such peaks can easily be 5 to 20% above normal winter peaks in many areas.   Thus, these conditions have the potential to cause more severe concerns than California sees during extreme summer conditions.

The Climate Act encourages and is projecting significant solar development.  Because the peak load is just before sunrise all this solar provides no support for the peak.  All the virtue-signaling homeowners with solar panels that have insufficient or no battery backup will not only be not providing any power but will be putting maximum demand on the grid.  He points out that “The infrastructure needs to supply a home which only puts a demand on the system a few hours a year concurrent with other uses maximum demand is basically the same as the infrastructure need to support a full requirements home.”  It is difficult for an electric rate structure to cover those system costs so either the needed infrastructure improvements are delayed or everyone else ends up subsidizing residential solar panel households.

Schussler also explains that wind resources are a problem too:

The Act encourages wind development. Like solar, wind will push other better suited resources out of the supply pool. Wind is generally slower just before sunrise and winter is not generally peak wind season. In any case wind is intermittent and some of the times during cold weather wind is not available. Some say that wind tends to rise up as temperatures get colder and there are ways to keep turbines from freezing,. Nonetheless, we do see freezing problems and a tendency for wind to be there is not a guarantee. Green resources perform much better in theory than practice. At least at sometimes wind power will not likely be a great asset during winter morning peaks demand conditions.

Another way to address this requirement is to encourage energy efficiency.  There is no question that this helps reduce load and, if the energy efficiency upgrades are consistent with the Nordic country requirements, then the amount of resistance heating necessary can be reduced.  Schussler points out some unintended consequences:

The Act encourages efficiency. This could help to reduce load and thereby make severe outages less likely. But the real problem with peak demand is the difference in demand during the extreme peak period and other more normal high load periods. If efficiency reduces load, you will likely see a reduction in generating resources to serve the load at all high load levels. The risk from peak conditions is more attributable to the delta between the winter peak demand and more common high load levels.  This is because regular loads drive generation additions more than extreme conditions. I don’t know that efficiency measures work better during the most extreme winter temperatures than it does at normal winter cold temperatures (probably less so), therefore its mitigating impact may be small to none. Also, there are those who might argue that consistent with Jevon’s Paradox efficiency efforts lead to increased energy consumption. The basic mechanism, behind this counterintuitive theorem, is illustrated by mechanisms observed such as   individual consumers with more efficient homes choosing to heat more rooms or increase comfort because you get more for your money in an efficient home.

On my long list of analyses that I would like to do is to compare the New York State Energy Research & Development Authority energy efficiency targets and goals with the actual observed improvements.  I have no reason to believe that they have ever come close to meeting their targets, in part, because of some the aforementioned issues.  As a result, I have no reason to believe that New York will achieve the levels of energy efficiency necessary to meaningfully, much less eliminate, the effect of resistance heaters affecting the peak load.

Schussler summarizes this section:

The chart below shows the US typical resource generation by major energy source. Imagine how this chart will look as fossil fuel is phased out. Hydro only makes up about 6% of the mix and expansion there is limited. Nuclear could replace these resources but it is not great for ramping up and down to follow needle peaks. If wind and solar step up to replace fossil fuels this leave us vulnerable to energy shortages during winter peaks just before daybreak. Battery capability would need to be huge, expansive and probably would not be procured in advance of demonstrated needs.

Recall that New York’s residential heating electrification magical solution is cold climate air source heat pumps that allegedly extract energy for home heating on the coldest days.  New York’s answer to the resource requirements quandary is another magical solution: dispatchable emissions-free resources.  This is a resource that has all the electric grid capabilities of a fossil-fired power plant without the emissions.  The NYISO Power Trends 2022 report sums up the challenge: “Long-duration, dispatchable, and emission-free resources will be necessary to maintain reliability and meet the objectives of the CLCPA. Resources with this combination of attributes are not commercially available at this time but will be critical to future grid reliability.” The Draft Scoping Plan uses “green hydrogen” as its placeholder for this resource and I addressed issues with that pipe dream in my comments on the Draft Scoping Plan.

Specific Blackout Prediction

Schussler lists the following set of conditions that he believes are inevitable in many areas including New York:

  • Very cold pre-dawn extreme temperatures
  • Backup quick start fossil fuel combustion turbines have been largely driven out of the resource mix,
  • Nuclear, hydro and battery resources are tapped out
  • Solar is absent from the distribution side and not available on the generation side
  • Wind may or may not be blowing
  • Heat pumps are operating maxed out in resistance mode, along with other resistive heating to drive system load to extreme heights
  • As with every power system there will be a few problems on the system
  • System will be forced to deliberately shed a lot of load or may go unstable and suffer crippling blackouts

Schussler emphasized this diurnal set of conditions.  I maintain that the ultimate problem with a net-zero energy system is that increased electrification will markedly raise loads during weather conditions that cause peak loads but also can have low wind and solar resource availability over extended periods.  I recently described a paper, Getting to 100%: Six strategies for the challenging last 10%, describes approaches for providing power during peak conditions that are not included in his analysis.  I believe that an extended period of low wind resources in the winter will exacerbate these conditions and tap out all the energy stored in batteries. 

Although New York is surrounded by other sources of electricity and most of the jurisdictions have not committed to either the renewable development targets or aggressive schedule of the Climate Act, there is a particular New York problem.  New York City is a load pocket and has specific reliability mandates that I believe will be violated in the scenario outlined.  That constraint exacerbates all the conditions.  The result will be another catastrophic New York City blackout.


Schussler offers some suggestions to avoid this worst-case outcome.  Unfortunately, New York’s Climate Act mandates and policy actions are working against every one of his suggestions.  I believe that the Climate Action Council naïvely believes that there isn’t a potential reliability issue and has resisted requests to confront the rationales for the differences between the Integration Analysis and the NYISO resource outlook.  An open and comprehensive resolution of those differences should be done before the Scoping Plan is finalized but I have seen no indications that will be done.

To paraphrase Schussler: “The Climate Act is promoting a system with less stability, robustness and reliability”.  I cling to the hope that somebody will step up and be responsible enough to address the reliability concerns described so well by Mr. Schussler.  Unfortunately, I am not optimistic because the Hochul Administration has to this point refused to even address the claims of Climate Action Council members that argue that anyone suggesting there are reliability threats in an electric system that relies on renewable energy is misinformation.  That claim is just wrong and is the real misinformation.

Climate Action Council Question: Thruway EV Infrastructure

The Climate Leadership and Community Protection Act (Climate Act) has a legal mandate for New York State greenhouse gas emissions to meet the ambitious net-zero goal by 2050 and the process to develop the implementation plan is well underway.  Unfortunately, Governor Kathy Hochul’s administration does not appear to be focused on reliability and affordability issues and is instead placating the ideologues on the Climate Justice Working Group (CJWG) and particular members of the Climate Action Council.  This post illustrates the problem by looking at one particular question about the electric vehicle (EV) charging infrastructure at the redeveloped New York State Thruway service centers that was brought up at the September 29, 2022 Council meeting (presentation and recording).

Everyone wants to do right by the environment to the extent that they can afford to and not be unduly burdened by the effects of environmental policies.  I submitted comments on the Climate Act implementation plan and have written extensively on New York’s net-zero transition because I believe the ambitions for a zero-emissions economy embodied in the Climate Act outstrip available renewable technology such that this supposed cure will be worse than the disease.  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.

Climate Act Background

The Climate Act establishes a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050. The Climate Action Council is responsible for preparing the Scoping Plan that will “achieve the State’s bold clean energy and climate agenda”.  They were assisted by Advisory Panels who developed and presented strategies to the meet the goals to the Council.  Those strategies were used to develop the Integration Analysis prepared by the New York State Energy Research and Development Authority (NYSERDA) and its consultants that tried to quantify the impact of the strategies.  That material was used to write a Draft Scoping Plan that was released for public comment at the end of 2021. The Climate Action Council states that it will revise the Draft Scoping Plan based on comments and other expert input in 2022 with the goal to finalize the Scoping Plan by the end of the year.

I recently described my concerns about the Climate Action Council response to stakeholder comments.  In brief, there is no indication that any comment that raised issues inconsistent with the narrative will be addressed.  Most concerning to me is that there is no apparent realization that it is inappropriate to not reconcile the differences between the Integration Analysis generating resource projections with the estimates made by the New York Independent System Operator (NYISO) in their 2021-2040 System & Resource Outlook report.  Another concern is that the leadership of the Council has paid so much attention to questions and issues raised by some of the more vocal but energy illiterate members of the Council that substantive issues will not be addressed.  Throughout the Council’s Scoping Plan development process, the leadership has allowed those members to go off on tangents to address their particular personal agendas rather than keeping the meetings focused on the overall objective to “inform the state energy planning board’s adoption of a state energy plan”. 

Thruway Electric Vehicle Charging

In my article on the September 29, 2022 Climate Action Council meeting I gave an example of one of the frivolous questions from the Council.  At 22:28 of the meeting recording Peter Iwanowicz asked about the New York State Thruway Service Area Redesign and Redevelopment Project that is presently underway.  He asked if anyone in the administration could give the Council an idea what’s going on with respect to fast charging at the Thruway rest stops stating: “I was personally blown away at driving into one of the newly reopened ones to see no electric vehicle charging there”.  He went on to say that “it’s pretty shocking to me, one as a member of the Council but two as an EV driver not to see chargers in the newly reopened station charging”.  In this case the response was “Let us get back to you”.  I noted that I would address this in more detail in a future post.

The New York State Thruway is a toll road that runs just under 500 miles from New York City north to Albany, west to Syracuse and Buffalo then on to the Pennsylvania line near Erie, PA.   The New York State Thruway Service Area Redesign and Redevelopment Project explains that there is an effort underway to redevelop 27 service areas along the toll road.  It took very little effort to find an answer to the Iwanowicz question.  The website’s Frequently Asked Questions explains that they are working on it:

Additionally, under direct guidance and consultation with the New York Power Authority (NYPA), Empire plans to implement a passenger vehicle electric charging program at all Service Areas to further New York’s goals of reducing emissions and expanding electric vehicle infrastructure across the State.

While they are “working on it” is the simple answer, the real concern of the Climate Action Council should be on the expectations for electric vehicle charging.  As has been the case for every component of the transition plan that I have researched the answers are more complicated and uncertain than implied in the Draft Scoping Plan.  When the electric car mandate came out, I posted an article that was republished at Watts Up With That.  One of the comments on the republished article caught my eye.  Steven Pfeiffer stated:

I’m sure that the New York State officials have carefully taken into account the impact of EV’s on the electrical grid in NY. /SARC

Where it could get interesting is the peak demand with fast chargers, because a lot of them will be needed even with many people charging at low levels overnight or at work.

Let’s say a typical “Quick Mart” has 16 gas pumps. Each gas pump now has a fractional HP pump, maybe a load of 500 Watts per pump. So maybe 8 kW total peak demand.

Replace those (or add) today’s “fast” chargers, say 16 of those at a nominal 250 kW (that may be on the low end, Tesla’s may be 350 kW).

16 x 250 = 4,000 kW or 4 MW of connected load. So suddenly every suburban or rural Quick Mart has an electric load (design peak demand) equal to a paper mill, auto assembly plant, or a medium size college campus.

And if I’m doing my math correctly, a 250 kW charger (with 15% loss) adds a net of about 3.5 kWh per minute to the EV battery, so it will be adding about 12-14 miles range per minute of actual charge time.

Compare that to my sedan, where I can add over 300 miles of range in about two minutes of actual full time, or 150 miles per minute.

Either electric or gas cars will have similar time requirements to pull in, park, initiate the process with a payment method, etc. So the actual “fill time” is what is important.

Most EV proponents assume the in the future, new batteries and chargers will be developed that will make EV charging “as convenient” as filling the tank of an IC engine vehicle.

If that ever becomes reality then the impact on the grid will be monumental – based on simple calculations, the supercharger load will be about 4 megawatts per charger – that is 4 MW for ONE charger supplying ONE car, to be able to match the miles added per unit of time attainable with a conventional IC engine car.

In the following section I am going to adapt his analysis (spreadsheet) for an example service center. Note, I did not double check his assumptions.  I used the New York program to develop electric vehicle infrastructure, Evolve NY electric chargers for more information.  I presume this NYPA program will be combined for the service center implementation of passenger vehicle charging stations.  The description of these charging stations states that charging speeds range between 150-350kW. 

Warners Service Center Electric Vehicle Charging

Google Maps satellite view of NYS Thruway Warners Service Center

I arbitrarily chose to look at the closest service center to my home primarily because the re-development has not started there yet.  There are ten automotive fuel pumps and one truck pump.  I counted the parking spots in the automotive lot and found that there were 154 parking spaces: 6 handicapped, 97 spaces in the interior and 51 spaces on the edge where I presume it would be possible to install an electric charger.

Steven Pfeiffer’s example considered 16 gas pumps but Warners only has 10. Each gas pump has a fractional HP pump, with “maybe a load of 500 Watts per pump”. Warners has a peak load 5 kW.  The common comparison metric for load is a typical household which is 1 kWh/day with a peak load of 100kW.  In this case the peak load at the service center is equivalent to 5% of a typical household.

Pfeiffer’s example compared those gas pumps to a “fast” charger with a charging rate of 250 kW.  That works out to a peak load of 2,500 kW which is equivalent to the peak load of 25 households.  Note, however, that the Evolve NY chargers include 350 kW chargers.  That works out to a peak load of 3,500 kW and that is equivalent to the peak load of 35 households.

Travelers don’t really care about the electricity requirements.  Their main concern is how long it takes to fuel up.  For this analysis assume that an internal combustion engine (ICE) automobile gets 25 miles to the gallon, has a 12-gallon tank (so it has a 300-mile range), and that a motorist would fill up when the tank is 1/6 full so that 10 gallons would be pumped.  If the gas pump fills at 5 gallons per minute, then pumping takes 2 minutes and 250 miles are added to the range.

Pfeiffer notes that if he is doing his math correctly: “a 250-kW charger (with 15% loss) adds a net of about 3.5 kWh per minute to the EV battery, so it will be adding about 12-14 miles range per minute of actual charge time.”  Assuming that the charger adds 13 miles of range per minute of charging time it will take 19.2 minutes to get the same mileage with the 250-kW charger.  I assumed that all the values were proportional for the 350-kW charger and found that it will take 13.7 minutes to get 250 miles of additional range.

Cars will have similar time requirements to pull in, park, initiate the process with a payment method and do everything else necessary to fuel.  I assume that those requirements add three minutes to the car fill up.  Using these assumptions an ICE automobile can get filled up in five minutes, an EV can get charged in 22 minutes with a 250-kW charger and 17 minutes with a 350-kW charger.

I maintain that the question about the availability of charging systems at the Thruway service center was inappropriate because it is so limited.  I believe it would be more appropriate for the Climate Action Council to be discussing bigger picture expectations.  In this instance it would be more appropriate to discuss whether the EV plan for the Thruway service center redevelopments should be to provide equivalent re-fueling capabilities such that the same level of service is available in the future.  The existing Warners service center has ten pumps and can fuel 600 vehicles per hour.  In order to match that hourly rate, the service center would need 44 250-kW chargers or 33 350-kW chargers.

In order to provide that level of service the peak load will increase.  For the 250-kW chargers the peak load is 11,115 kW which is equivalent to 111 households.  For the 350-kW chargers the peak load is 11,550 kW which is equivalent to 116 households.  At this point complicating questions about the electric distribution service availability come up.  At a minimum, additional transformers will be needed.  Many of these service centers are in rural areas and additional upgrades may be required for the power supply.  The Council should know whether those complications are considered in the Draft Scoping Plan.

Pfeiffer points out that “Most EV proponents assume the in the future, new batteries and chargers will be developed that will make EV charging “as convenient” as filling the tank of an IC engine vehicle.”  He explains that “If that ever becomes reality then the impact on the grid will be monumental – based on simple calculations, the supercharger load will be about 4 megawatts per charger – that is 4 MW for one charger supplying one car, to be able to match the miles added per unit of time attainable with a conventional IC engine car”.  In this example that would increase the peak load at the service center to 40,000 kW which is equivalent to 400 households.  At that level I would expect that a new substation might be required.

In addition to the power constraints, installation of EV charging stations needs to consider site constraints.  Recall that there are 154 parking spaces: 6 handicapped, 97 spaces in the interior and 51 spaces on the edges.  Here is another appropriate overview discussion for the Council.  There is a tradeoff between parking available for people who need to attend to personal needs (restaurants and bathrooms) and for chargers.  At some point in the future placing EV chargers in the current fueling area will be possible but that transition has to be planned.  The ultimate question is how long and whether New York intends to provide fossil fuels to out-of-state visitors and grandfathered vehicles owned by residents.

Google Maps Satellite View of NYS Thruway Warners Service Center Parking Area

On a practical level I assume that that the preferred location for chargers would be on the edges.  Depending on the fast charger type between 33 and 44 chargers provide equivalent service and there are 51 spaces on the exterior.  The first practical question is whether additional parking spots are needed to respond to the loss of spots to chargers.  I imagine there will also be installation issues for the electric power and infrastructure needed for the charging points.  Another issue is whether there should be provision for charging services for vehicles towing trailers.

The bigger challenge is New York winters.  One issue is that the charging efficiency and the vehicle range are both reduced in cold weather.  The current re-fueling capabilities are not seasonally dependent.  Should there be additional chargers added because more people will need to stop to charge and it will take charging longer in the winter?  The bigger issue in my opinion is snow.  While it is more practical to put the charging stations on the edges of the parking lot that is also the only place that snow removed from the lot can initially go.  Parking lot designs that do not take into account snow removal can cause safety issues and certainly affect the time necessary to clean up after snow storms.


On the list of issues confronting the state’s energy transition this particular question is pretty low on the priority list.  We have already seen the leadership of the Council claim that there is too little time to reconcile the electric grid projections made by the NYISO with the Integration Analysis.  Nevertheless, a Council member thinks that it is appropriate to cut into the precious little time available for the Council to consider the entirety of the energy transition with his personally biased question.  More importantly this is just an example of a recurring theme throughout the Scoping Plan process.  Any question from the CJWG and certain members of the Council gets a response no matter how removed from the issue at hand. 

I highlighted this particular question because it illustrates my bigger concern.  The Climate Action Council should be focused on big picture items that affect not only the net-zero transition but also the public’s use of energy.  Instead, the leadership has allowed the membership to go off on tangents like this.  In this example, the relatively trivial issue is what can be expected at the Thruway service areas and over-arching questions arose.  What does the Council recommend for future planning: minimizing resources required which increases public inconvenience or the opposite?  How does the Draft Scoping Plan address these tradeoffs?  What is the expectation for resources like this during the transition?  Unfortunately, those big picture items are not getting addressed while Staff tries to track down answers to questions like this.

There are many over-arching net-zero transition issues that the membership of the Council seems OK ignoring as the Scoping Plan development process unfolds.  I am particularly concerned that the Draft Scoping Plan only provides aggregated costs relative to societal benefits and there are significant unresolved differences between the generation resource projections for the net-zero transition between the Integration Analysis and the NYISO Resource Outlook.  It is not clear that the aspirational technology deployments proposed in the Draft Scoping Plan are feasible with respect to affordability and reliability.  I believe the Council should define their expectations for those two aspects.  What does affordable mean; how should it be tracked as the transition unfolds to protect the low- and middle-income citizens who are least able to afford regressive energy cost increases; and what does the Scoping Plan project will happen in this regard?  Reliability is a bigger concern because it directly affects public safety.  Does the Council believe that current reliability standards must be maintained in the future?  How will that be enforced?  In particular, if the organizations responsible for reliability believe the current reliability standards are threatened what is the plan?


I have shown that even a trivial question about New York State Thruway service centers raises more important general issues that should be the focus of the Climate Action Council.  Not so long ago, affordability and reliability were the paramount concerns for the New York energy system.  At that time the idea that the existing system would be dismantled without proven technology in place would be dismissed out of hand.  It was generally accepted that, for example, natural gas could be used a bridge fuel until the aspirational dispatchable emission-free resources could be tested at the scale needed, perform like a natural gas fired generating unit, and provide power at a similar cost, was generally accepted as a rational approach. The analogy for the current approach is that proponents including some members of the Climate Action Council want to jump out of a perfectly good airplane without a parachute because they assume that the concept of a parachute will be developed, proven technically and economically feasible, and then delivered in time to provide a soft landing.  The risks of the current approach are not even being discussed by the Council as they fritter away time dealing with politically expedient Integration Analysis updates and personal agenda items of the membership.  I am not optimistic about the future.

Updates to Pragmatic Environmentalist Pages

I am going to start summarizing updates I make to the pages I maintain at  Pragmatic Environmentalist of New York and Reforming the Energy Vision Inconvenient Truths.  I have an extensive list of reference materials on my original blog that I occasionally update when I run across an article that is particularly interesting and relevant and this blog also has reference material.  This article describes some recent page updates.

I started blogging in late 2017 on New York’s energy policies because I was convinced that they are going to end as an expensive boondoggle driving electricity prices in particular and energy prices in general significantly higher. Reforming the Energy Vision (REV) was the previous comprehensive energy strategy for New York. I wrote about the inconvenient unpublicized or missing pieces of New York State’s REV policy: implementation plan, costs and impacts. At some point I should probably combine that blog with this one but in the meantime, I will maintain them both.  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.


I linked two articles to the renewable energy feasibility page.  This very good overview of all the problems associated with green energy was described at the Australian Stop These Things website.  Author Andrew Roman points out six issues ignored by New York State energy policy:

All energy sources have some adverse effects on the environment, including wind and solar:

  • extensive use of scarce minerals supply, largely controlled by China;
  • massive concrete bases and steel towers of wind generators require extensive use of coal in manufacturing;
  • low energy density requires huge amounts of land (some 25 per cent of the US land area if all electricity was to be generated by solar panels);
  • wind turbines kill birds and bats;
  • both solar panels and wind turbines create huge amounts of un-recyclable waste
  • China dominates solar panel and wind turbine manufacturing by burning a lot of coal.

The article goes on to document these issues.

The second renewable feasibility article by Francis Menton made the point that the easiest Net-Zero goal is to eliminate emissions in the electric generation sector.  However, he points out that not only has no jurisdiction successfully made the transition but also argues that it will be never be achieved.  He notes that wind and solar development is entirely dependent upon government subsidies.  All other energy transitions have been based on organic consumer demand not on government mandates.  His article describes the current situation in Europe where net=zero energy transition policies have created a situation where they don’t have dispatchable, emissions-free generating resources available for extended periods of low wind and solar resource availability causing affordability and reliability issues.  He concludes:

So, if you have a chance to make a bet, you’ll be extremely safe betting against Net Zero generation of electricity any time during your life. Nuclear is the only way it could potentially be done, and that’s blocked by regulatory obstruction more or less everywhere.

Chris Denton from New York’s Southern Tier wrote a great article describing a reasonable development policy for industrial solar that I linked to my solar issues page.  He points out that it is reasonable to have a policy framework in place before we “advance the production of electric energy by means of industrial free-standing solar collectors”.  He argues that developing industrial solar facilities diverts land from an existing use (e.g., habitat or agriculture) it follows that “how much and where we divert the sun’s rays ought be very carefully measured and studied before allowing any further industrial development of solar electric generation.”  He points out that there are plenty of locations that do not impact agriculture and sequestration so those should a priority.  He concludes:

The damage caused by our refusal to recognize these impacts can destroy our environment as effectively as any other unexamined industrial or commercial project. It is that very blindness to incremental, unplanned action that has led to the very global warming which we are now trying to unwind.  We should not make the same mistake in the cure as we did in acquiring the disease. We need to take care that in our zeal to protect our environment from unrestricted global warming, we don’t destroy the very plants, animals, land, water, and scenic values which we are trying to protect.

I added a link to this article on offshore wind turbine spacing to the wind issues page.  As turbines become bigger their wakes become bigger and that leads to a reduction of output at any existing turbine that is too close.  “An important new working paper from renewables consultants ArcVera is reporting that the wake effects behind the huge turbinesthat are now coming onstream are going to be much worse than previously thought.”

Other Articles of Interest

There were a couple of other articles that were interesting but inappropriate for my pages. 

Science and religion belong to separate domains. Science is empirical, falsifiable and logical, where later scientists “stand on the shoulders” of the earlier. It constitutes the finest achievement of Western civilization. The Tenth Climate Commandment’s prohibition against debate leads to the death of science, when science is replaced by an ideology that justifies its authority by its order not to question.  This is the same claim which religions have made through the ages. As the Roman poet Horace warns: “vestigia terrent”- the footprints are frightening

    Ithaca Public Housing Climate Act Investment

    The Climate Leadership and Community Protection Act (Climate Act) includes a commitment for environmental justice goals.  As part of that effort the Climate Act created the Climate Justice Working Group (CJWG) who has been tasked to help decide what that commitment entails.  This article describes one project that I believe will be considered part of the environmental justice financial investments.

    The Climate Act establishes a “Net Zero” target (85% reduction and 15% offset of emissions) by 2050.  I have written extensively on implementation of the Climate Act.  Everyone wants to do right by the environment to the extent that efforts will make a positive impact at an affordable level.  Based on my analysis of the Climate Act I don’t think that will be the case.  I believe that the ambitions for a zero-emissions economy outstrip available renewable technology such that the transition to an electric system relying on wind and solar will do more harm than good.  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.

    Climate Act Background

    The Climate Act is “Working to ensure all New Yorkers are represented in the State’s transition to a cleaner energy future and benefit from investments and opportunities provided by this historic transition”.  In other words, they are addressing environmental justice.  According to EPA: “Environmental justice is the fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income, with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies.”

    One key part of that commitment is investment in disadvantaged communities.  According to the Climate Justice Working Group (CJWG) webpage:

    The Climate Act requires the state to invest or direct resources in a manner designed to ensure that disadvantaged communities to receive at least 35 percent, with the goal of 40 percent, of overall benefits of spending on: clean energy and energy efficiency programs and projects or investments in the areas of housing, workforce development, pollution reduction, low-income energy assistance, energy, transportation, and economic development

    As I noted in a recent post on my CJWG disadvantaged community criteria comments, the distribution of those investments is sure to be contentious.  I believe that the State is going to invest money in public housing for low- and middle-income housing as part of those investments.  There are two concerns: is this what the CJWG thinks is appropriate and is this a good investment for society as a whole?

    Ithaca Public Housing Rehabilitation

    In what I believe is a prototype for public housing investments, on August 5, 2022 Governor Kathy Hochul announced a $75 million project to upgrade and preserve two outdated Ithaca Housing Authority properties with a total of 36 apartments and to replace another obsolete Authority property with 82 new affordable apartments. The 118-unit Ithaca Housing Authority Redevelopment is designed to be all-electric and was awarded funding through the Clean Energy Initiative program for multifamily buildings. A rendering of the project is shown below.

    According to the press release:

    Governor Hochul: “My administration is steadfast in our commitment to preserving and creating affordable housing that is sustainable, high-quality, and comfortable,” Governor Hochul said. “Today’s $75 million investment will help strengthen communities and provide new opportunities for Ithaca residents. We will continue to upgrade and modernize New York’s supply of public housing in the Southern Tier to provide a more stable and equitable future for the next generation.”

    The Ithaca Housing Authority Redevelopment complements Governor Hochul’s sweeping plans to make housing more affordable, equitable, and stable. In the 2022-23 State Budget, the Governor introduced and successfully secured a new $25 billion, five-year, comprehensive housing plan that will increase housing supply by creating or preserving 100,000 affordable homes across New York including 10,000 with support services for vulnerable populations, plus the electrification of an additional 50,000 homes.

    The first component of the Ithaca Housing project will be redevelopment at Overlook Terrace and Southview Gardens.  The plan will renovate two buildings with 46 apartments, a community building, and a building for laundry and mechanical equipment. Major capital improvements will include the replacement of water heaters and furnaces to an all-electric option; upgraded laundry facilities; the replacement of entry doors, vinyl and aluminum siding, soffits and trim, windows, and roofs.; and site landscaping. 

    The other component is a complete rebuild of 70 apartments at The Northside Developments.  The new affordable development will have 17 residential buildings with a total of 82 apartments – 12 more than the original thanks to a reconfiguration that adds much-needed one-bedroom apartments. The new development will include a one-story community building with a kitchen, office spaces, and a laundry room.

    The press release notes that:

    In total, there will be 20 one-bedroom units, 34 two-bedroom units, 40 three-bedroom units, 22 four-bedroom units, and two five-bedroom units. All of the apartments will be for households earning at or below 80 percent of the Area Median Income.

    The press release also describes the funding sources:

    State funding for the $75 million Ithaca Housing Authority Redevelopment includes $10.6 million in permanent tax-exempt bonds, Federal Low Income Housing Tax Credits that will generate $29.7 million in equity, and $18.8 million in subsidy from New York State Homes and Community Renewal. The development was awarded $1.4 million from the Clean Energy Initiative. Other funding sources include $9.3 million from the Ithaca Housing Authority, $300,000 from Tompkins County Community Housing Fund, and nearly $91,000 from Ithaca Urban Renewal.

    Finally, the press release says:

    The Clean Energy Initiative developed by New York State Homes and Community Renewal and the New York State Energy Research and Development Authority to create more than 1,500 energy-efficient, all-electric or electric-ready, climate-friendly affordable homes in existing multifamily buildings across the state.

    What about the Numbers?

    I have added an addendum with quotes included in the press release.  To hear those people this is the greatest thing ever.  For example, New York State Energy Research and Development Authority President and CEO Doreen M. Harris said, “NYSERDA is pleased to see construction commence on the Ithaca Housing Authority redevelopment project, which demonstrates that clean, resilient and affordable housing can be accessible to all New Yorkers”.  The pragmatic approach is to look into the numbers to see if this is likely.

    According to the press release this is a $75 million project to upgrade and preserve outdated Ithaca Housing Authority properties that will renovate or rebuild a total of 118 housing units.  That works out to $635,593 per unit. The two components of the project both include a community building that also has mechanical equipment but however you calculate the cost per housing unit it is extremely high.  According to the Ithaca Journal the typical cost of a home in Ithaca’s county in June 2022 was $357,450 and the cost of these units is well above that value.

     The Press Release notes that:

    All three properties will be highly energy-efficient and have an all-electric building design pursuant to the New York’s nation-leading Climate Leadership and Community Protection Act to curb building emissions. Additional energy efficiency measures will include heat-reflective roofing systems with tapered insulation, ENERGY STAR rated appliances, energy-efficient lighting and low-flow plumbing fixtures for a projected 15 percent in total energy savings.

    The Draft Scoping Plan for the Climate Act does not provide detailed enough data to determine an estimate of the typical residential greenhouse gas emissions per year.  The New York State Energy Research and Development Authority Patterns and Trends document gives estimates of total household energy for different fuels.  I used Energy Information Administration carbon dioxide emission coefficients by fuel and found that the highest estimated emissions for the New York are for homes using fuel oil.  As a conservative surrogate for the largest potential impact that these projects could possibly have, I used that estimate of 10 tons per year.  If we assume that the existing housing units are responsible for ten tons of GHG emissions per year and that the project will eliminate all the emissions that means that the annual reduction of GHG emissions is 1,180 tons.  The resulting cost per ton of CO2 removed is $63,559.


    This article addressed two concerns: is this what the CJWG thinks is appropriate and is this a good investment for society as a whole?  I believe that this project is an appropriate environmental justice investment because “All of the apartments will be for households earning at or below 80 percent of the Area Median Income”.   As far as I can tell however, only Southview Gardens is in a draft Disadvantaged Community so it remains to be seen of all or only part of this investment is of the “least 35 percent, with the goal of 40 percent” investment target.

    I have two relevant concerns about the Climate Act transition to net-zero.  The first is affordability and the second is feasibility.  The press release quotes Doreen M. Harris as saying “NYSERDA is pleased to see construction commence on the Ithaca Housing Authority redevelopment project, which demonstrates that clean, resilient and affordable housing can be accessible to all New Yorkers”.  The numbers are worrisome relative to the claim that this project will demonstrate that affordable housing that meets the standards for the Climate Act is viable.  Seriously, given that there are probably at least one million housing units similar to these, can New York afford to upgrade public housing to those standards at a cost over $600,000 per unit or over $600 billion in total? 

    As noted above the typical cost of a home in Ithaca’s county in June 2022 was $357,450.  It is notable that there is such a big difference in cost relative to the redevelopment costs.  Without a lot of work, it is not possible to break down the cost estimates to see how much of the projected costs are due to the energy transition enhancements. If those costs are a significant driver in the difference, then it is appropriate to ask whether this is an appropriate environmental justice investment.  In my opinion, it is more appropriate to address environmental justice concerns for impacted communities today than it is to make investments that are futile unless all jurisdictions in the world also make similar commitments.  Given that there is a limited amount of money available, then providing more upgraded housing is a better investment than limiting the housing upgrades because of the increased costs of the net-zero transition.


    It will be interesting to see how this plays out.  The Ithaca Housing Authority projects meet all the criteria for appropriate environmental justice investments except that most of the housing affected is outside of a Draft Disadvantaged Community.  Will the CJWG recommend that all or only part of the funding be included in the 35% target and what will the State say?

    The numbers are not encouraging from an affordability standpoint.  If this is any indication of the potential costs for environmental justice investments then there will be problems.  In addition to the magnitude of the per housing unit cost, the cost reduction efficiency is an issue.  According to the Integration Analysis in 2020 the building sector emitted 105 million metric tons of carbon dioxide equivalent.  Until such time that the cost per ton reduced for the building sector is brought down three orders of magnitude ($63 instead of $63,000 per ton reduced), I cannot imagine that the emissions reductions are affordable.

    Addendum for Press Release Quotes:

    Homes and Community Renewal Commissioner RuthAnne Visnauskas said, “This $75 million investment in the Ithaca Housing Authority speaks to our commitment to upgrading and protecting our existing affordable housing assets. The redesign of these apartments will yield modern and highly energy-efficient homes for 118 households and will preserve affordability and extend the useful life of these buildings for decades to come. Governor Hochul’s bold and forward-looking housing agenda is ensuring a brighter and more secure future for public housing residents in Ithaca and across the entire state.”

    New York State Energy Research and Development Authority President and CEO Doreen M. Harris said, “NYSERDA is pleased to see construction commence on the Ithaca Housing Authority redevelopment project, which demonstrates that clean, resilient and affordable housing can be accessible to all New Yorkers. Through the Clean Energy Initiative, we are working with our sister agency, New York State Homes and Community Renewal, to make strategic investments in multifamily buildings like those being developed through this project, that reduce greenhouse-gas emissions and provide healthier, comfortable and resilient living spaces.”

    Senator Chuck Schumer said, “Every New Yorker deserves access to safe affordable housing, but historic underinvestment has created a housing crisis in places like Ithaca. I am proud that the federal Low-Income Housing Tax Credit that I have fought hard to protect and expand has supplied the millions needed to make these new affordable homes a reality. Housing is a human right and I will keep fighting to get every dollar of federal support needed to help lay the foundation in Ithaca for a brighter, ‘gorges’, and more equitable future for all residents.”

    State Senator Tom O’Mara said, “State investments in safe and affordable housing continue to strengthen the fabric of neighborhoods and the quality of life for tenants and residents in the city of Ithaca and communities across this region and state.  It’s an important commitment that will deliver critical short- and long-term benefits.”

    Assemblymember Anna Kelles said, “I am encouraged to see this project move forward at a moment when rising rents, increased home prices, and lack of supply have exacerbated the housing and affordability crisis. We must continue to create affordable and safe housing for low- and middle-income families. This project addresses this need by rehabilitating 36 units, and fully replacing 70 units that were outdated and potentially unsafe with 82 new, safe, and sustainable units. This 118 unit project will add 12 new units, including one and two bedroom units which are currently in acute deficit in Ithaca and all units will be rented at 80% area median income (AMI). Hopefully this is just one more step in a long needed road of adding to our affordable housing stock. I also applaud the project’s sustainability goals with all of the units in this housing project constructed all-electric with air source heat pumps providing heating and cooling, in line with the city of Ithaca and Tompkins County aggressive climate goals.” 

    Acting Ithaca Mayor Laura Lewis said, “The city of Ithaca is pleased to have the support of so many partner agencies in the redevelopment of critically needed low-income housing. Substantial renovations of Overlook Terrace and Southview Garden and, at Northside Apartments the complete replacement of outdated buildings that were first constructed decades ago, will provide families with high quality and environmentally efficient homes. This investment in our community will benefit generations of Ithacans.”

    Tompkins County Legislature Chairwoman Shawna M. Black said, “This project is an excellent example of re-invigorating our affordable housing options in Tompkins County. We’re proud of what Ithaca Housing Authority offers to our community and that these projects will be energy efficient and align with New York State’s Climate Leadership and Community Protection Act. Thank you to New York State, Ithaca Housing Authority, and our Tompkins County Community Housing Fund for contributing to these developments. I can’t wait to see construction begin and to get people back into their homes.”

    3d Development Group President Bruce Levine said, “Our focus was on the needs of the existing tenants, future tenants, the community at large, and the global need for improved energy sustainability and reducing fossil fuel emissions. This project was made possible by the support received from the state, federal and local government agencies. Because everyone got on board and believed in the goals and initiative, the final result will transform the Ithaca Northside neighborhood for decades to come.”

    Ithaca Housing Authority Executive Director Brenda Westfall said, “Our vision and end goal is to provide quality affordable housing for our current and future tenants while ensuring that the properties are energy efficient and meet energy sustainability goals for decades to come. As a lifelong resident of the city of Ithaca, it is extremely rewarding to witness the commitment and support that many different agencies brought forth in bringing our vision to life. This project will both improve and preserve the quantity and quality of affordable housing we are able to provide while complimenting the landscape of the neighborhoods in which the properties are located.”