Pragmatic Environmentalist of New York

New York’s Energy Transition Club

Ron Clutz wrote an article describing an article by Irina Slav that lists the rules strictly followed by leaders of the Great Energy Transition at her substack Irina Slav on Energy. I want to illustrate how proponents of the Climate Leadership & Community Protection Act (Climate Act) follow these rules. In the end, however, reality will win out and the energy transition will flounder.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 350 articles about New York’s net-zero transition. I have devoted a lot of time to the Climate Act 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 by increasing costs unacceptably, threatening electric system reliability, and causing significant unintended environmental impacts. The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Background

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

Irina Slav describes net-sero transition leadership as “climate crusaders, climateers, a cult, and other, less polite words.” She points out this crowd is a club that follows six rules:

Rule #1: We do not talk about the problems. (Unless we absolutely have to.)

Rule #2: Facts are obsolete. Only the transition matters. (Until facts punch you in the face.)

Rule #3: Tell a lie big enough and keep repeating it

Rule #4: If it’s failing, double down

Rule #5: Words and numbers are weapons

Rule #6: Questions are denial

Rule #1: Do Not Talk About Problems

Irina Slav gave an example for this rule citing an International Energy Agency report that said the world needed to replace and build 50 million miles of transmission lines to make the transition work. She explained:

This would only take $600 billion annually by 2030, which is double the current investment rate for transmission lines. For context, the global transmission line network is half the length the IEA says we need right now.

The expansion needs to take place by 2040 because Climate Targets. In other words, the world needs to double its transmission line network in a matter of less than 20 years… after it took a century to build all the lines we currently have. Realistic, right?

In fairness, the IEA does hint that there might be a slight problem with securing all of the raw materials necessary for this enormous undertaking. It absolutely had to admit it, what with miners crying shortage all the time, annoying people. But that cannot stop the transition. Else we get global broiling.

The New York Independent System Operator’s 2021-2040 System & Resource Outlook notes that “A minimum of 5 TWh of renewable energy in 2030 and 10 TWh in 2035 is projected to be curtailed due to transmission limitations in renewable pockets.” The report notes that “Without investment in transmission, these areas of the New York grid will experience persistent and significant limitations to deliver the renewable power from these pockets to consumers in the upcoming years.” New York’s Energy Transition Club has not addressed supply chain materials issues, skilled labor shortages, or funding for the transmission projects necessary for the schedule needed to meet Climate Act mandates.

Rule #2: Facts are obsolete

Slav’s second rule states “Facts are obsolete. Only the transition matters. (Until facts punch you in the face.)” She explains that the UK government had a plan to replace gas heating systems in homes with hydrogen but “following massive opposition from the target community, the government ditched the trial plan and started mumbling that maybe hydrogen for heating is not such a marvelous idea.” She explains:

The facts: hydrogen — green hydrogen, that is — is expensive. All hydrogen is also dangerous, which makes the green variety even more expensive. At the time the plans were made, these facts were shunned. The opposition of the locals in the village of Whitby, however, prompted their return to the scene, ultimately leading to this piece of news: Hydrogen for UK home heating should be ruled out, says infrastructure adviser

Summed up, the match between facts and fantasy in hydrogen sounds like this, per the FT: ““We do not see any role for hydrogen in the future of home heating,” said Nick Winser, NIC commissioner, arguing it was “simply not ready at scale” and risked being an inefficient use of green electricity.”

The leaders of the New York’s Energy Transition Club are in the New York State Energy Research & Development Authority. This organization is responsible for the Integration Analysis that supports the Scoping Plan and they chose to use “green” hydrogen as the place holder for the dispatchable emissions-free resource (DEFR) included in future generating resource projections. All the issues raised by Slav are relevant for this plan. An article by Steve Goreham expands on “green” hydrogen problems and the facts that have been ignored by NYSERDA.

Rule #3: Tell a lie big enough and keep repeating it

Slav explains the derivation of this rule. Here’s the whole quote:

“If you tell a lie big enough and keep repeating it, people will eventually come to believe it. The lie can be maintained only for such time as the State can shield the people from the political, economic and/or military consequences of the lie. It thus becomes vitally important for the State to use all of its powers to repress dissent, for the truth is the mortal enemy of the lie, and thus by extension, the truth is the greatest enemy of the State.”

She notes:

It kind of feels I can add nothing constructive to this description of the climate change narrative, especially if you consider the source, which appears to be (though not verbatim, I understand) a little book called Mein Kampf. I mean, if a tactic was tried in one context and it worked splendidly, you can totally make it work in another, and I’m not being ironic. The tactic does work.

Despite the Climate Act requirement in section 16 of § 75-0103 to consider efforts at other jurisdictions and observed increases in energy costs in Europe, NYSERDA continues the “big lie” that the transition will be affordable. After the Public Service Commission decision to deny an increase in contract prices for renewable projects, NYSERDA announced the award of 6.5 GW of two award groups renewable energy. Doreen Harris, president and CEO of NYSERDA said “In this case, the two award groups combined will have an impact of about $3 a month on your average New York residential consumer” and “Affordable, but we certainly keep that central to our work.” Unfortunately, she has never admitted how much they expect the total costs for the transition, instead deceptively claiming that “the costs of inaction are greater than the costs of action”.

Rule #4: If it’s failing, double down

Slav describes this rule:

The countries with the greatest wind and solar power generation capacity in the EU also have some of the highest electricity prices. This is a mystery to absolutely no one with rudimentary mental acuity. And yet the billions continue flowing into wind and solar. And then, once a gas crunch hits, they start flowing into households.

Wind and solar clearly cannot work at the scale their fans want them to work. It is physically and financially impossible for them to make sense at that scale at this point in time. The evidence is there on a daily basis, courtesy of Electricity Maps and, I’m sure, other real-time tracking websites.

Transition Club has no truck with evidence, however, unless it’s the right kind of evidence, such as record-setting wind/solar output for some day or another. The rest is dismissed as irrelevant, disinformation, or simply ignored. And the billions keep flowing because there are targets to be hit in wind and solar installations. Whatever it takes.

New York’s transition has not reached the point where we have performance data. However, doubling down examples abound. In mid-October the Public Service Commission denied requests by European energy firms Orsted, Equinor, BP and other renewable developers to charge customers billions of dollars more under future power sale contracts for four offshore wind and 86 land-based renewable projects. “These projects must be financially sustainable to proceed,” Molly Morris, president of Equinor Renewables Americas, told Reuters, noting Equinor and BP will “assess the impact of the state’s decision on these projects.” On the same day Governor Hochul announced a “10-Point Action Plan to Expand the Renewable Energy Industry and Support High-Quality Clean Jobs in New York State”. A couple of weeks later NYSERDA announced the largest-ever investment in renewable energy described previously. The Hochul Administration has never related the new cost projections to the never revealed estimates in the Integration Analysis. The Integration Analysis assumed that renewable development costs would decrease over time and that is not happening. Nonetheless we race ahead doubling down that someday the costs will fall.

Rule #5: Words and numbers are weapons

Irina Slav’s fifth rule:

Old but gold and put to good use by the Club. All the talk about global boiling, the highway to hell, the accelerating extreme weather, the climate catastrophe and all the rest of it are water to the Transition Club agitprop mill. It keeps the lie going.

Numbers are even better: from the 99% of climate scientists who are in agreement about the climate and related catastrophies to all the CO2 emission updates and the horrific temperature readings from this summer we get actual numbers that stoke up fears that the planet is dying and we’re on our way out with it unless we kill the oil and gas industry and go full-wind/solar.

Or unless we check how the authors of the 99% consensus study came to their conclusion and what their sample size was, what the significance of those emission updates is for the total content of CO2 in the atmosphere, and how those temperatures were measured during the summer.

This rule is commonly involked by Club members. For example, an opinion piece by Francesca Rheannon, co-chair of the Climate Reality Project-Long Island Chapter and a member of the East Hampton Energy and Sustainability Advisory Committee, exemplifies the Club call to action:

I have long been anxiously observing our world as it moves ever closer to the boiling point, noting the growing impacts of climate chaos on our daily lives. This past summer’s orange skies were terrifyingly otherworldly. Atlantic hurricanes are not just stronger, but getting stronger faster and less predictably. This year, we have (so far) dodged the bullet. But what will happen next year or the year after that? My house insurance premium has soared and my broker said the cause was anticipated increased risk from hurricanes. And the policy only covers up to Category 2 hurricane damage; any damages above that fall entirely on me.

Roger Pielke, Jr. addresses global hurricane facts. For the North Atlantic offshore of Long Island he explains that the National Oceanic and Atmospheric Administration has recently concluded:

In summary, it is premature to conclude with high confidence that human-caused increases in greenhouse gases have caused a change in past Atlantic basin hurricane activity that is outside the range of natural variability, although greenhouse gases are strongly linked to global warming.

Rule #6: Questions are denial

Slav describes the sixth rule:

This rule evolved organically from following all the others and sprouted actual disinformation laws, at least in the EU, for now, and not-so-official reporting rules for the media that require the climate narrative to be reported as fact despite evidence to the contrary, said evidence being dismissed as science denial and denialist propaganda, even when — and perhaps especially when — it comes from actual scientists.

Apparently, these days there are two kinds the scientists, the right and the wrong kind. The wrong kind are those asking questions, even though science is by definition a process that involves a lot of question-asking.

Per the Oxford Dictionary science means “the systematic study of the structure and behaviour of the physical and natural world through observation, experimentation, and the testing of theories against the evidence obtained.”

Not in the transition era, it doesn’t. In the transition era, there is a right kind of observation and computer modelling to replace experimentation and testing of theories against evidence. Then there is the wrong kind, which is any systematic study of the physical and natural world that questions the right kind, using evidence.

During the development of the Climate Act Scoping Plan there was no discussion of the scientific rationale for the net-zero transition. Any thought that there could be questions about the need to move as quickly as possible was not considered. However, the “Questions are denial rule” was still a prominent talking point by members of the Climate Action Council.

The May 26, 2022 Climate Action Council meeting (recording) included an agenda item for Council members to describe their impressions of comments made at the public hearings Many commenters expressed concern about reliability. Paul Shepson invoked this rule when he said:

Mis-representation I see as on-going. One of you mentioned the word reliability. I think the word reliability is very intentionally presented as a way of expressing the improper idea that renewable energy will not be reliable. I don’t accept that will be the case. In fact, it cannot be the case for the CLCPA that installation of renewable energy, the conversion to renewable energy, will be unreliable. It cannot be.

Robert Howarth also invoked this rule when he said that fear and confusion is based on mis-information but we have information to counter that and help ease the fears. He stated that he thought reliability is one of those issues: “Clearly one can run a 100% renewable grid with reliability”. A quote from a recent New York Independent System Operator presentation question both claims that dismiss reliability issues associated with renewable energy: “Significant uncertainty is related to cost / availability of Dispatchable Emissions Free Resource IDEFR) technologies, as well as regulatory definition of ‘zero-emissions’ compliant technologies”.

Conclusion

I believe that these rules are followed by New York’s Energy Transition Club. Slav’s description of these rules is amusing but illustrates some of the techniques used to further the net-zero transition. She points out that people cannot be shielded from the consequences of these rules for very long because reality always wins.

Articles of Note 29 October 2023

Sometimes I just don’t have time to put together an article about specific posts about the net-zero transition and climate change that I have read that I think are relevant. This is a summary of posts that I think would be of interest to my readers.

I have been following the Climate Leadership & Community Protection Act (Climate Act) Climate Act since it was first proposed and most of the articles described are related to it. I have devoted a lot of time to the Climate Act 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 article 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.

Massachusetts Plan to Meet Its Climate Goals

This article describing an implementation plan for Massachusetts caught my eye becauseit argues that the first order of business is to analyze what it will cost to achieve its climate goals. The report argues that the cost of inaction are less than the cost of action but the report “suggests that state agencies submit preliminary recommendations for how Massachusetts can come up with the money to meet its goals by the end of 2024.”

When it comes to climate and clean energy goals, Massachusetts has some of the most ambitious in the country. But what the state doesn’t have is a detailed plan to achieve them.

To help bridge this gap, the state’s Climate Chief, Melissa Hoffer, published a new report this week with 39 recommendations for how the state can do three big things: Zero-out carbon emissions by mid-century, build more clean energy and prepare for more severe weather.

Massachusetts has detailed climate goals for 2050, but it has no idea what it will cost to achieve them. So, the first order of business, according to Hoffer’s report, is a comprehensive economy-wide analysis of what the state will need to spend to decarbonize — or dramatically slash planet-warming emissions. This work entails connecting a whole lot more renewable energy to the electric grid, protecting natural lands that suck carbon out of the air, protecting coastal communities and preparing for a future with more extreme weather.

GHG Emissions and Climate Change

Francis Menton writes:

It’s by far the most important scientific question of our age: Do human emissions of CO2 and other such “greenhouse gases” cause significant global warming, aka “climate change”? Based on the belief that an affirmative answer to that question is a universally accepted truth, our government has embarked on a multi-trillion dollar campaign to transform our economy.

The authors of the two new papers beg to differ. First, we have a paper by John Dagsvik and Sigmund Moen of Statistics Norway, dated September 2023, titled “To what extent are temperature levels changing due to greenhouse gas emissions?”

The second important new paper is from Antonis Christofides and co-authors dated September 26, 2023. They introduce their paper with a long post of that date at Climate, Etc. titled “Causality and Climate.”

Both papers evaluate historical data and the results “appear to refute, and certainly does not prove, the endlessly repeated claims of impending climate doom from human CO2 emissions”.

Siemens Energy Stock

There are so many signs that the aggressive renewable deployment schedule mandated for the Climate Act that I find it very troubling that there hasn’t been any sign of concern by the Hochul Administration. For example, the green energy sector shows signs of distress, as illustrated by the plummeting shares of Siemens Energy. An article on ZeroHedge meticulously unfolds the tale of challenges and uncertainties clouding the renewable energy sector, with Siemens Energy at its epicenter.

Wind Industry Cost Increases in Great Britain

Here is another example. RWE Renewables has just told the Government that it needs its subsidy “strike price” to rise by 70% if any more wind farms are to be built.

Net Zero Watch director Andrew Montford said:

Rishi Sunak has said that there has been a long-term deception of the British public. RWE’s demand for more subsidy confirms it. The Green Blob has been lying about renewables costs for years. The truth is that wind power is expensive, and becoming more so. The energy “transition” is a transition to poverty, but few in Westminster seem to have the guts to say so.

Heat-pump nightmare

Heat pumps are a key component in the Climate Act plan to electrify home heating, but there are issues. “It’s now clear from the evidence that heat pumps are an impractical form of heating for millions of UK homes. This is due not only to high upfront costs but also the lack of insulation in older buildings and the inability of systems driven by heat pumps to respond quickly to weather variations”

Electric Vehicles

Another key component of the Climate Act transition is to electrify transportation. This article suggests that the plan to shove electric vehicles into every driver’s life may be in trouble. Axios reports that a new analysis findsa”strong and enduring correlation” between political ideology and U.S. electric vehicle adoption.

Driving the news: The working paper, from UC Berkeley’s Energy Institute at Haas, explores county-level new car registrations from 2012-2022 and compares them to voting records in presidential races.

“During our time period about half of all EVs went to the 10% most Democratic counties, and about one-third went to the top 5%,” the study found.

“There is relatively little evidence that this correlation has decreased over time, and even some specifications that point to increasing correlation.”

Why it matters:If EV uptake remains a big thing only in very blue places, it may be “harder than previously believed” to reach high market penetration, they write.

In my opinion, the idea that battery electric heavy-duty trucks will ever be a viable transportation are simply absurd. There are too many trucks that are going so far to expect that any battery system is going to be able to effectively replace the existing system. This article describes a National Grid study that will begin modeling Northeast electric truck charging needs.

National Grid’s study will focus on highways with heavy trucking traffic and areas with commercial activity like ports. Modeled sites will be in New York, New Jersey, Pennsylvania and the New England states.

“This roadmap will inform efforts by states, utilities, communities, and industry leaders to create a seamless truck charging network across the region,” Franey said.

“This study will help deepen the understanding of electrification needs and help New York State and the region strategically put more medium and heavy-duty electric trucks on the road,” said David Sandbank, vice president of distributed energy resources at the New York State Energy Research and Development Authority.

An off-hand remark supports my concern:

The work will build on National Grid’s “Electric Highways Study,” which was published in 2022 and concluded a large highway fast-charging site could have power demands similar to a small town by 2045.

If every truck stop is supposed to be replaced by a fast-charging site and they require the power demands of a small town, then the infrastructure needs will be enormous across the country. Do these people ever go on a long trip and see how many trucks and how many truck stops there are?

New York City Zero Emission Vehicle Fleet Legislation

This was also published at Watts Up with That

A recent post, New York City Goes Pedal to the Metal on Electric Vehicles, at Watts Up with That described new legislation that will require vehicles procured by the City to be zero emissions. The author of the article, Charles Rotter, included a note at the top: “I can’t wait for Francis Menton or Roger Caiazza to weigh in on this.” It is a rainy Saturday and I don’t have anything else to do so I will take a shot at it.

I have followed New York State’s Climate Leadership & Community Protection Act (Climate Act) since it was first proposed but have not followed the efforts in New York City closely. I have devoted a lot of time to the Climate Act 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 by increasing costs unacceptably, threatening electric system reliability, and causing significant unintended environmental impacts. The same goes for anything New York City is doing. The opinions expressed in this post do not reflect the position of any of my previous employers or any other organization I have been associated with, these comments are mine alone

Benefits

I try to look at environmental policy pragmatically balancing benefits and costs. The benefits used to rationalize the law are weak. Rotter quoted the Statements made by two of the politicians responsible for the legislation that make benefits claims:

“New York City continues to set the standard for sustainability by becoming the largest city in the nation to require its fleet to be entirely made up of zero emission vehicles,” said Speaker Adrienne Adams. “The Council is proud to champion legislative efforts to address the environmental and health impacts of vehicle pollution, reduce our carbon footprint, and prepare our workforce for the repair and maintenance of electric vehicles. I thank Majority Leader Keith Powers for his leadership on this critical legislation, my Council colleagues for supporting policies that transition us to a more sustainable future, and Mayor Adams for signing the bill into law.”

“New York City continues to lead the country in creating a greener, more sustainable world,” said Majority Leader Keith Powers. “Today’s signing of Intro. 279 enacts a historic piece of legislation that will drive down our city’s carbon footprint and advance environmental justice. Starting in just two years, our city’s fleet of over 30,000 vehicles will lead the way towards a zero-emissions future. I am proud to have worked with numerous partners to have made today a reality.”

The majority of New York City and State politicians cater to the climate advocate constituency and these statements reflect that. Adams ticks all the boxes in the narrative that reducing GHG emissions also reduces pollutants that will have environmental and health benefits, the existential threat of climate change will be reduced, and the transition will create jobs. Even a cursory review shows how shallow those claims are. The shift to “zero-emissions” ignores the reality that all energy production creates emissions somewhere. In this case there may not be emissions in New York City, but the mining, processing, and manufacturing of the needed batteries necessary certainly creates emissions. Jobs created by the “green” technologies are always mentioned but the jobs lost are rarely mentioned.

Another characteristic of these politicians is innumeracy. The city fleet has 30,000 vehicles. I calculate that those vehicles are responsible for about 400,000 tons of CO2 emissions per year. Driving down the “city’s carbon footprint” needs to be considered in the context of global emissions. The Global Energy Monitor mission is “to develop and share information in support of the worldwide movement for clean energy”. As part of their mission, they have prepared a spreadsheet with data on all coal-fired power plants in the world. Table 1 is based on that data. It lists capacity and projected annual CO2 emissions for three categories of power plants: operating, permitted but not yet under construction, and under construction. Every hour the operating coal-fired power plants emit 1,245,158 tons of CO2. That means that the CO2 reductions due converting the New York City owned fleet of vehicles will be subsumed by coal fired emissions elsewhere on the globe in 0.3 hours or 19 minutes. This law will not have any discernable effect on global warming.

Costs

My concerns with New York State and New York City (NYC) “zero-emission” transition costs are related to reliability and affordability. Noodling around on the NYC fleet management site I found this description:

New York City operates over 30,000 owned and leased vehicles, the largest municipal fleet in the United States. NYC maintains fleet units at 37 main repair locations and has over 400 in-house fueling and 400 separate electric charging locations. More than 2,000 staff work full-time in fleet repair and garage operations across over 50 fleet operating agencies and offices. In total, nearly $1 billion is spent annually on fleet repair, fueling, and procurement.

I found a page that includes a table that describes the fleet daily service report which lists the number of vehicles for each agency and what they are used for to give an idea of the importance of reliability. The NYC fleet includes the police department and fire department vehicles which must provide reliable service. I suspect that relying on electric-only fire equipment will be very risky because of the high energy demands needed to operate those trucks. The last thing in the world you want to have happen is for a pumper truck to lose power when fighting a fire. The vehicle fleet includes sanitation trucks which are also used to plow snow. However, there is an issue: “city officials have declared they have yet to find an electric garbage truck powerful enough to plow snow. The sanitation department already tested electric trucks, and they couldn’t plow snow for more than four hours, as they ran out of battery. “

Digging deeper into the fleet management site, there is a sustainability page that claims that “New York City’s fleet is the greenest in the nation”. They already have some electric vehicles:

The City of New York operates over 2,260 on-road electric vehicles (EVs) and plug-in hybrids. Full EVs include over 250 Nissan Leafs and over 300 Chevy Bolts, among others. The City has over 600 additional off-road EV and solar units. Please see our presentation Let’s Talk about EVs to learn how to charge an EV and the differences between an EV and the conventional fuel vehicles you may be used to driving.

The sustainability page also notes:

DCAS is rapidly expanding its base of electric chargers to support its electric and plug-in hybrid vehicles. We have installed over 1,600 charging ports across over 1,025 charging stations, including over 180 fast-charging stations, at City garages and parking locations around the city. We have deployed over 80 solar carports that allow EVs to be completely independent from the electrical grid and fossil fuel energy. We have partnered with City schools to provide both solar chargers and EVs to support education programs and adopted other solar powered city equipment.

It appears to me that the vehicle fleet service department has been given the charge to look at a transition to lower emission vehicles and are proceeding on that path.

I have been following the transition to electric vehicles and have been struck by the higher cost of electric vehicles so I wondered about the costs of this law. I checked the law itself and supporting documents to see if costs had been addressed. The law is titled A Local Law to amend the administrative code of the city of New York, in relation to the purchase of zero emission vehicles by the city. The description states:

This bill would require that all light- and medium-duty vehicles procured by the City after July 1, 2025 be zero emission vehicles such that all light- and medium-duty vehicles in the City’s fleet are zero emission vehicles by July 1, 2035. This bill would also require that all heavy-duty vehicles procured by the City after July 1, 2028 be zero emission vehicles, such that all heavy-duty vehicles in the City’s fleet are zero emission vehicles by July 1, 2038. Further, this bill would require that all motorcycles in the City’s fleet are zero emission vehicles by July 1, 2035. The requirements to procure zero emission vehicles are subject to certain exceptions, such as cost, availability, and lack of charging infrastructure.

The last sentence is a welcome reality slap – the procurement requirements are conditional upon costs among other things. I thought the Fiscal Impact Statement would provide information about costs relative to this condition. The following excerpt from that statement is a head scratcher:

I guess the current fiscal impact statement is a placeholder. Presumably sometime before Fiscal Year 2029 the expenditures and source of funds will be determined. Then the cost exception requirements to procure zero emission vehicles will be considered.

Conclusion

The New York City Department of Citywide Administrative Services fleet management department has a sustainability program in place that tests options for lower emissions and zero emissions vehicles. Some of their tests are working and others are not. The key point is that these are the folks responsible for keeping the vehicles necessary to protect the city and provide services and they are working on it. Mind you I think trying to convert the NYC vehicle fleet to zero-emissions is a waste of time and effort that will likely do more harm than good.

Enter the politicians. The legislation does include conditions upon deployment but it appears that the issue is already being addressed. I would bet a lot of money that the fleet staff reacted to the bragging by the politicians who supported this legislation with exasperated sighs and eye-rolling. As far as I can tell this legislation only provides street cred for politician target constituencies and does nothing but get in the way of the people who are trying to get things done.

Update on Washington State Cap-and-Invest Program Impacts

Paul Fundingsland has been sending me his thoughts on the implementation of Washington State’s experiences with their cap-and-invest “putting a price on carbon” scheme. This dispatch from the front lines of the cap-and-invest war on citizens covers three items: the letter he got from Puget Sound Energy about his natural gas bill, an opinion piece describing ways to reduce the cost burden on citizens, and an article explaining how the program is affecting trucking companies. I believe this is what is headed to New York and appreciate the time he has taken sending the information.

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

Background

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

The New York State Department of Environmental Conservation (DEC) has developed an official website for cap and invest. It states:

An economywide Cap-and-Invest Program will establish a declining cap on greenhouse gas emissions, limit potential costs to New Yorkers, invest proceeds in programs that drive emission reductions in an equitable manner, and maintain the competitiveness of New York businesses and industries. Cap-and-Invest will ensure the state meets the greenhouse gas emission reduction requirements set forth in the Climate Leadership and Community Protection Act (Climate Act).

I started writing about the effects of the Washington Cap-and-Invest Program last summer. Washington State Gasoline Prices Are a Precursor to New York’s Future and the article published at Watts Up With That – Do Washington State Residents Know Why Their Gasoline Prices Are So High Now? addressed the observation that gas prices in Washing spiked soon after the first auction of the program. I also published Washington State Gasoline Prices and Public Perceptions that consolidated responses from Washington residents in the comments from the Watts Up With That article.

Paul contacted me soon after those articles came out with his thoughts that I turned into posts here. The first article on Washington State gas prices described his opinion of how the program came to be and concluded that it is a “state tax shell game preying on the less affluent”. He later sent a long email that I turned into a post that described how the program has been evolving.

My initial impression of Washington GHG emissions is that there are no “easy” emission reductions because the target sectors are transportation, residential-industrial-commercial heating, and “other”. Fundingsland agrees pointing out that:

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

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

Washington Climate Commitment Act

Washington’s Climate Commitment Act appears to be even more aspirational than California or New York. The Washington Department of Ecology (“Ecology”) web page explains:

The Climate Commitment Act (CCA) caps and reduces greenhouse gas (GHG) emissions from Washington’s largest emitting sources and industries, allowing businesses to find the most efficient path to lower carbon emissions. This powerful program works alongside other critical climate policies to help Washington achieve its commitment to reducing GHG emissions by 95% by 2050.

The state plans in Washington, California, and New York all aim for net-zero emissions where greenhouse gas (GHG) emissions are equal to the amount of GHG that are removed. Washington’s emission reduction target is 95% by 2050. California is shooting for 85% by 2045 while New York’s target is 85% by 2050 but covers the whole economy. In addition to the target levels and dates there are differences in what GHG emissions are included, how the mass quantities are calculated, and which sectors of the economy must comply.

According to the Washington State Department of Ecology description of their cap-and-invest program:

In 2021, the Washington Legislature passed the Climate Commitment Act (or CCA) which establishes a comprehensive, market-based program to reduce carbon pollution and achieve the greenhouse gas limits set in state law. The program started on Jan. 1, 2023, and the first emissions allowance auction was held on Feb. 28.

Businesses covered by the program must obtain allowances equal to their emissions and submit them to Ecology according to a staggered four-year compliance schedule. The first compliance deadline is Nov. 1, 2024, at which time businesses need to have allowances to cover just 30% of their 2023 emissions.

Puget Sound Energy Response

Paul sent information that was used for another article based on a local news update noting that natural gas company Puget Sound Energy (PSE) had announced a 3% rate price hike due to their mandated “Cap & Invest” auction allowance costs. He noted that:

The companies required to participate in the auction allowances are simply passing these costs to their bottom line along to their customers. In essence, the State taxes the company and the company taxes its customers.

What makes this particular example more disgusting than usual is the fact that PSE wanted to simply include a line item on the customer’s bill identifying this cost but the Washington Utilities and Transportation Commission (UTC) actually made it illegal to do so claiming that would make for a “lengthy confusing” bill.

Even though PSE was not allowed to include the costs of the program in their utility bill they are not keeping silent on the reason for the associated cost increase. Paul’s latest correspondence noted that: PSE is being very transparent about why this price increase is happening. It is a direct result of the State’s mandated “Cap & Invest” program.

As far as I can tell according to this web site pse.com/cca my November bill will increase somewhere in the neighborhood of 3%. This is the second documented result of the Washington State required “emissions allowances auctions” (forced permit purchases required to emit greenhouse gases) held quarterly affecting businesses like PSE and ultimately it’s customers. The first example being this past summer’s overnight increase of $.43 a gallon for gas attributed to this scheme.

Since the state mandates that PSE and other companies in the state identified as emitting notable amounts of CO2 must participate in quarterly scheduled “emission allowances auctions”, it is easy to anticipate these kinds of price increases will continue to rise, perhaps at an alarming rate in both transparent and un-transparent ways for the foreseeable future.

The following letter from PSE indicates I can also expect a price increase for the same reasons on my electrical bill from them once they work out those cost details. When that happens, that will be the third documented price increase as a direct result of the recently initiated Washington State “emission allowances auctions” under its “Cap (Tax) & Invest” scheme.

Paul explains:

These are just the obvious examples of Washington State forced increased bottom line public business costs being passed on to their customers. Most of the affected companies in the Washington State scheme do not have the high profile of a utility or refinery with their traceable and identifiable costs and results. The price increases for the other companies will also be passed along to their customers but are much more difficult to identify and document. But they are there none the less, un-transparently adversely affecting the finances of every state citizen especially the lower-, middle-, and fixed-income brackets.

Affordability

The New York Cap-and-Invest Program is supposed to address affordability with a political solution. According to the official website for cap and invest: “Governor Hochul’s Consumer Climate Action Account will deliver at least 30 percent in future Cap-and-Invest proceeds to New Yorkers every year to mitigate consumer costs.”

Paul sent along an opinion piece describing political solutions for Washington. It states:

Today, there are four proposals on the table. Most legislators in the majority have remained silent, and presumably want to use these funds to pay for new or existing programs. Sen. Mark Mullet, D-Issaquah, would like to use these funds to reduce car-tab fees for two years, but this would shortchange the transportation budget resulting in a shell-game in which Carbon Commitment Act (CCA) dollars are used to backfill transportation funds. His proposal also calls for lowering compliance obligations in the short-term, which means increasing carbon emissions.

Finally, Senate Republican Leader John Braun wants to use these funds for property-tax exemptions and credits to renters.

Rep. Mary Dye, R-Pomeroy, and I have a simpler plan. We would send all extra funds back to Washington drivers as CAR check. Unlike Sen. Mullet’s proposal, our bill would not change car-tab fee amounts or emission reductions. Drivers get a rebate, and we adhere to our emission reduction goals.

Fundingsland notes that these represent signs of pushback as the “climate taxes” imposed by the State’s scheme are being realistically viewed as exorbitant and start to adversely affect the citizens. He explains:

Various groups appear to be trying to come up with ways to get funds back out of the state government and returned to the citizens. Let’s see: Washington State taxes the companies. The companies pass those costs along to their consumers. Some of those monies are somehow then given from the State back to the citizens. And, of course there will bureaucratic “processing” costs at every level of the monies going in and coming back out.

Can it be any more convoluted? It Probably will if given a chance.

Sector Fuel Exemptions

Finally, Paul sent another article describing another political solution to the cost problem. Certain industry sectors are supposed to be exempt from any fuel surcharges fuel companies pass along to customers due to the cap-and-trade program. The article explains:

Last week, Joel Creswell – the Washington State Department of Ecology’s climate pollution reduction program manager – touted progress regarding exempting certain industries from paying a fuel tax based on the state’s carbon emission auctions.

“So, we’ve really made significant progress on the exempt fuels issue,” he told the Senate Environment, Energy & Technology Committee on Oct. 9.

According to the Department of Agriculture, certain types of fuel or categories of fuel usage in the agriculture, maritime and aviation sectors are exempt from the fuel surcharge.

The Center Square reached out to various organizations to get their take on Creswell’s assessment.

Washington Trucking Association President and CEO Sheri Call was less sanguine about implementation of the fuel tax exemption.

“It’s definitely more rosy than in reality, and it still doesn’t take into consideration the complex nature of the trucking industry and multiple things that our members do, so I’m still disappointed, honestly,” Call said of Creswell’s assessment. “The work group didn’t really produce much of anything.”

…….

Call said small carriers – mentioning a two-truck operation in eastern Washington – are being hit especially hard, noting that not all of them have “a direct line of sight to covered entities.” She went on to say, “So, they’re not going to make a 50-mile round trip out of their way to buy fuel from a supplier who has offered this exemption.”

Small carriers are struggling, she explained. “For those small carriers who have no choice, they’re trying to fuel as efficiently and cheaply as they can,” she said.

Call mentioned some dollar figures to bring home the impact of the fuel surcharge. “This two truck operation – to them, it’s a $20,000 to $25,000 additional cost to fuel a year, and that’s just one story,” Call said. “I have people who are spending $20,000 to $25,000 a month on fuel because of the surcharge. So, it’s still significant. People are still hurting. and it’s, honestly, it’s a really bad time.”

The current state of the economy isn’t helping, she lamented. “So for us to be suffering with the highest or second-highest fuel prices in the nation right now when the economy is doing so poorly, especially for freight, it’s just a bad combination,” Call said. “It’s a terrible thing to be doing business in Washington. But I’m hearing from carriers who, because of the economic situation, they’re basically instructing their drivers to top off in Washington but do not fuel.”

Honestly, I distrust any political “fix” to a problem created by a political policy. Paul agrees:

Let’s see: Washington State taxes the companies. The companies pass those costs along to their consumers. Some of those monies are somehow then given from the State back to the citizens. And of course there will bureaucratic “processing” costs at every level of the monies going in and coming back out. Can it be any more convoluted? It Probably will if given a chance.

Conclusion

These developments are fascinating. I am impressed that Puget Sound Energy went to its customers directly to explain why the costs spiked in October. Frankly, I don’t see that happening with New York utilities. It is telling that politicians are starting to figure out that being associated with higher energy costs is not necessarily a good political position. However, tacking on another political “fix” is unlikely to work. This is made clear by the trucking industry problems. There is a program to help certain sectors but it is not working in practice and the little guys are getting hurt the most.

The reason I appreciate hearing from Paul and publishing his thoughts is that everything that is happening in Washington will likely happen in New York. I believe that proponents of cap-and-dividend programs have unrealistic expectations for these programs. Setting caps that can only be met indirectly by substitution of an alternate “zero-emissions” resource is dangerous because if the alternatives do not become available to meet the arbitrary emission reduction targets, then the only option for affected sources to comply is to shut down. Even if that “works” I completely agree with Paul’s cost observation:

Washington State thinks it is encouraging greenhouse gas emitting companies to change their ways with its “Cap (Tax) & Invest” scheme when in fact it is just punishing its own citizens through these companies with an unreasonable heftier financial burden now, for an unverifiable, seriously dubious, theoretical computer modeled climate benefit 80 years in the future.

I sympathize with him when he told me that he is not looking forward to the effects of the next quarterly emissions allocations auction circus because of the associated financial consequences. It is coming to New York and will also cause energy prices to spike. He concludes:

This money “circus” will be interesting to watch unfold. But not so much fun watching my money help pay for this absurd spectacle.

The Wind is Always Blowing Somewhere Fallacy

I am fed up with rent-seeking capitalists and naïve academics who claim that wind, water, and solar resources are the only ones needed to provide reliable electric power. This narrative was used as rationale for the Climate Leadership & Community Protection Act (Climate Act). This post shows by way of example that this is an unrealistic argument.

Climate Act Background

My primary focus over the last several years has been New York’s the Climate Leadership and Community Protection Act (Climate Act). Robert W. Howarth authored sections of the Climate Act and was a member of the Climate Action Council that is responsible for preparing the Scoping Plan that outlines how to “achieve the State’s bold clean energy and climate agenda.” . He submitted a statement supporting the Scoping Plan that exemplifies the narrative that no new technology is needed:

I further wish to acknowledge the incredible role that Prof. Mark Jacobson of Stanford has played in moving the entire world towards a carbon-free future, including New York State. A decade ago, Jacobson, I and others laid out a specific plan for New York (Jacobson et al. 2013). In that peer-reviewed analysis, we demonstrated that our State could rapidly move away from fossil fuels and instead be fueled completely by the power of the wind, the sun, and hydro. We further demonstrated that it could be done completely with technologies available at that time (a decade ago), that it could be cost effective, that it would be hugely beneficial for public health and energy security, and that it would stimulate a large increase in well-paying jobs. I have seen nothing in the past decade that would dissuade me from pushing for the same path forward. The economic arguments have only grown stronger, the climate crisis more severe. The fundamental arguments remain the same.

I addressed Howarth’s claim and others in his statement in a post here late last year. I include this because it exemplifies the idea that wind, sun, and hydro can power New York’s electric grid completely. In this post I consider the challenge of using wind, solar, and hydro to replace one component of the NY grid – New York City’s existing fossil fired units

According to the New York Independent System Operator (NYISO) Gold Book the New York City (Zone J) fossil generation summer capability in 2022 was 9,026 MW. This represents the capacity needed to replace New York City’s fossil generation capacity at any hour. For the purposes of this thought experiment, I am going to ignore reliability rules related to transmission constraints and in-city generation. I assume only that New York City needs dedicated availability of 9,026 MW. There is no chance that an additional 9,026 MW of hydro can be developed in New York and there is no guarantee that the amount of capacity will only be needed during the day which means we cannot use solar. This example estimates how much wind capacity from somewhere will be needed to provide this dedicated capacity requirement.

New York Wind Variability

In May 2022 I published Climate Act and New York State 2021 Wind Resources that evaluated New York State onshore wind availability. I used a New York Independent System Operator (NYISO) resource that provides 2021 wind production and 2021 wind curtailment. The data sets list the hourly total wind production and curtailments for the entire New York Control Area (NYCA). I have summarized the data in the following table. Curtailments are those hours when the system load is small enough that wind production is greater than what is needed so the wind power is curtailed, i.e., not used.

Table 1: NYISO 2021 Hourly Wind Production at the Aggregated NYCA-Wide Level

These data are representative of every wind energy resource data set I have ever seen. See, for example, analyses for Belgium by Michel at the Trust Yet Verify website or for Australia by Anton Lang. The crux of the problem is that low-energy density wind resources are highly correlated across wide areas. Across New York, and other regions, the wind speeds drop across the entire area frequently. Frequently, as in every time a high-pressure system crosses over the area. As a result, the mean annual average availability for all the NYCA onshore wind turbines is only 22% and the median is 16%.

Moreover, I believe it is unlikely that additional sources in a region will change the availability much. I do not expect any significant change to the low-end onshore wind numbers when all the land-based wind resources proposed to meet the Climate Act net-zero transition are developed. The overall distribution of expected offshore wind will be similar although the numbers will show slightly higher availability.

Implications

Wind variability has implications on the use of wind energy to replace firm dispatchable generation. I use these data as a starting point for this analysis to explain why the fact that the wind is always blowing somewhere does not mean it can be used cost-effectively to replace dispatchable fossil-fired generating in an electric grid that relies on wind and solar as claimed by Dr. Howarth and others.

To estimate the wind resources needed to replace New York City’s 9,026 MW of existing fossil-fired generation I will use the distribution of New York land-based wind with the following assumptions. In the absence of offshore observed wind energy historical data, I assumed that the wind production would be increased by a five-percentile category from the onshore wind distributions. In other words, when the onshore wind is at the 75% percentile capacity availability level, I assumed that offshore wind resources are at the 80% capacity level.

Table 2 estimates the amount of land-based or offshore wind capacity from the New York Control Area necessary to replace New York City’s 9,026 MW fossil capacity. Because the observed wind production capability at the 99^th percentile is 78%, 11,563 MW of wind turbine capacity are needed (9,026 divided by 78%) to assure replacement of the existing fossil-fired units in New York City. For reliability support the wind resources must be able to cover all the levels of wind resource availability. Half of the time (50^th percentile) 55,068 MW of capacity would be needed. In order to ensure reliability, wind capacity must be available at all hours but the wind capacities at the lower end of the distribution are unrealistic so a system dependent upon only wind energy is going to have to go wherever the wind is blowing. The proponents of the wind is always blowing somewhere respond that all New York must do is to import electricity from outside the NYCA to address this but have not used this kind of distribution to determine how much, from how far, would be necessary

Table 2: NYCA Wind Capacity Support Requirements to Replace NYC Fossil – 9,026 MW

To determine how much wind capacity is needed outside of New York, I first determined the

potential wind energy availability within the New York Control Area (NYCA). For capacity potential I used the larger capacity projections for land-base and offshore wind from two different modeling analyses. The offshore wind capacity (MW) in the Integration Analysis Scenario 2: Strategic Use of Low-Carbon Fuels was 12,675 MW. The onshore wind capacity in the NYISO 2021-2040 System & Resource Outlookwas 19,087 MW. Table 3 uses those resource projections to provide estimates of the available energy in the NYCA at each resource potential level. For each percentile I calculated the available capacity at each percentile for on-shore and offshore wind, summed them, and listed the deficit if the sum was less than 9,026 MW. For this thought experiment, the projected wind resources can replace the fossil resources up to the 70^th percentile if all the wind power can be dedicated just to New York City at the hour when 9,026 MW of wind capacity is needed in the City. This means that somewhere between 65% and 70% of the time, wind resources outside the NYCA must provide additional power to replace New York City’s existing fossil resources.

Table 3: NYCA Wind Energy Available from Climate Act Wind Resource Projections

Table 4 provides an estimate of the wind generated capacity available to cover the deficit margin in Table 3 outside the control area in an area similar in size and characteristics to the NYCA 500 miles away from New York City. For this thought experiment I assumed that the wind capacity at any hour in this region would be at a production percentile 25% higher than the corresponding NYCA percentile. I believe that there is higher level of spatial correlation than those who believe that the wind is always blowing somewhere acknowledge. In this example, when NYCA wind levels are at the 65^th percentile I presume that 500 miles away the wind resource will be at the 90^th percentile. Because I believe that wind in all regions of a similar size to New York will exhibit the same wind distribution pattern, a key takeaway is that wind resources 500 miles away are insufficient to always provide support when power outside the NYCA is needed. The 500-mile resources only cover the NYCA deficit down to 55^th NYCA percentile corresponding to the 500-mile 80^th percentile. We must go out at least another 500 miles for reliable power.

Table 4: Wind Resource Availability from 10,000 MW of Turbines 500 Miles from NYC

Table 5 provides an estimate of the additional wind generated capacity needed outside the control area in an area 1000 miles away from New York City. I assumed that the wind capacity at any hour would be at a production percentile 50% higher than the corresponding NYCA percentile. In this example, when NYCA wind levels are at the 50^th percentile I presume that 1000 miles away the wind resource will be at the maximum level of 86%. Importantly, this assumption is the same as assuming there is no correlation between NYCA wind and 1000- mile wind. I do assume that the correlation has the same directionality. In other words, winds in both regions go down at the same time. Of course, it is more complicated because “somewhere else” winds could go up when NYCA winds go down. In order to address that issue an analysis for the entire onshore and offshore wind resource availability is needed.

The 1000-mile resource availabilities cover the NYCA deficit down to 25^th NYCA percentile and the 1000-mile 75^th percentile so we must go out another 500 miles to assure replacement of the existing fossil generation.

Table 5: Wind Resource Availability from 10,000 MW of Turbines 1000 Miles from NYC

Table 6 provides an estimate of the additional wind generated capacity needed within NYCA and the 500- and 1000-mile resource areas in an area 1500 miles away from New York City. I assumed that the wind capacity at any hour would be at a production percentile 75% higher than the corresponding NYCA percentile. In this example, when NYCA wind levels are at the 5^th percentile I presume that 1000 miles away the wind resource will be at the 80^th percentile. Even the addition of these resources is insufficient to cover all the power needed by New York City existing fossil resources. However, it is so close that adding another 1,049 MW of capacity in any of the regions would assure that New York City’s existing fossil generation could be replaced by resources where” the wind is always blowing”.

Table 6: Wind Resource Availability 1500 Miles from NYC

Discussion

The forgoing analysis confirms that the wind is indeed always blowing somewhere and that wind energy resources could replace the existing fossil generation in New York City as suggested by Howarth and others However, just because it is possible does not mean it is feasible. The fatal flaw is that New York City requires dedicated resources to replace existing generation when it is needed to keep the lights on. This is particularly important because the high pressure systems that characterize low wind availability over large areas also are associated with hottest and coldest periods of the year when the electric load peaks and the need for reliable power is the greatest.

Existing fossil generation capacity in New York City totals 9,026 MW. New York’s Climate Act projected onshore and offshore wind planned capacity is 31,762 MW. Relying on wind only requires another 30,000 MW located “somewhere else”. The fatal flaw to the wind blowing “somewhere else” argument for New York City is that those resources must be dedicated to New York City. The idea that anyone could afford to build 10,000 MW and 500 mile transmission lines for use as backup that will only be used 65% of the time, another 10,000 MW and 1,000 mile transmission lines for backup 50% of the time, and another 10,000 MW with 1,00 mile transmission lines for backup 25% of the time is disconnected from reality.

Of course, there are suggestions that the surplus power could be stored in batteries or used to make “green hydrogen” to address the low wind availability problem. However, Howarth claimed that New York “could rapidly move away from fossil fuels and instead be fueled completely by the power of the wind, the sun, and hydro” and that “it could be done completely with technologies available at that time (a decade ago) and that that it could be cost effective”. This simple analysis suggests otherwise.

Conclusion

I agree with Francis Menton who has argued that we need a demonstration project to prove all the wind, solar, and energy storage components necessary for a zero-emissions electric grid that does not rely on nuclear power can work. In addition, I believe that a comprehensive analysis of wind and solar resource availability across the continent that addresses the correlation and energy density deficiencies of wind and solar is also needed. Based on my work, I think that this sort of analysis would show the need for far more resources than anyone is contemplating at this time. If New York does not address these concerns correctly people will literally freeze to death in the dark.

The Climate Act Needs a Feasibility Demonstration

I have been writing about the Climate Leadership & Community Protection Act (Climate Act) for over four years and a constant theme in my work has been concerns about affordability and reliability. For all the analyses and pontification by the State of New York about the net-zero transition, there still is no documentation describing the costs of the control strategies proposed by the Scoping Plan and estimates of how New Yorkers will pay for the transition. The focus of this post is on reliability. I believe that the only way we can be sure that the plans proposed to operate an electric grid that relies primarily on wind and solar is to prove it with a demonstration project. The project should include all the key elements: wind and solar generation, energy storage, a dispatchable emissions-free resource and any other resources needed to provide necessary ancillary services. This post highlights work by Francis Menton that advocates just such a demonstration project.

Climate Act Background

Demonstration Project Proposal

Last February I did a post on Climate Smart Communities and I proposed a challenge to the local governments that pledged to be climate smart. Go for it, but not just this virtue-signaling public relations gesture to get some money. I described Francis Menton’s article explaining that a demonstration project of a mainly renewables-based electrical grid is a common sense prerequisite before there are any more plans or pledges. I said that Climate Smart Communities of New York should prove their bona fides and develop a demonstration project for their community to address the issues he raised:

Could anybody possibly be stupid enough to believe the line that wind and solar generators can provide reliable electricity to consumers that is cheaper than electricity generated by fossil fuels? It takes hardly any thought about the matter to realize that wind and solar don’t work when it is calm and dark, as it often is, and particularly so in the winter, when it is also generally cold. Thus a wind/solar electricity system needs full backup, or alternatively storage — things that add to and multiply costs. Surely, our political leaders and top energy gurus are fully aware of these things, and would not try to mislead the public about the cost of electricity from a predominantly wind/solar system.

……………..

Nobody would be happier than me to see a demonstration project built that showed that wind and solar could provide reliable electricity at low cost. Unfortunately, I know too much about the subject to think that that is likely, or even remotely possible. But at least the rest of us need to demand a demonstration project from the promoters of these fantasies.

A few days ago Menton followed up on his February post with What Passes For A “Demonstration Project” Among Our Government Geniuses. I recommend readers check out both articles. I will summarize the key points from the more recent article here.

Menton describes people who don’t support the need for an encompassing fossil-fuel-free renewable grid demonstration project. Government officials and green energy advocates won’t support this because:

(1) they are not bright enough to understand the subject, or (2) their understanding is impaired because they are too blinded by religious fervor to “save the planet,” or (3) they are intentionally deceiving the public to make money or fame or career advancement for themselves. Or it could be all three!

Instead of a single comprehensive demonstration, net-zero proponents promote projects that only “attempt to demonstrate various portions of the full system that would be needed to provide reliable 24/7/365 electricity from predominantly wind and solar generation.” I believe a common problem of all the “green” energy solutions is that they do not work all the time and renewable resource availability is correlated over large distances which makes demonstrations of individual components worthless.

Menton agrees and describes the example of the latest news on energy storage. He explain that on October 13, the Department of Energy announced big new grants and subsidies for a series of what they call “hydrogen hubs.” Here is a report from E&E News Energy Wire. Excerpt:

The Department of Energy on Friday announced seven projects that will receive $7 billion to build landmark hydrogen hubs, delivering a major boost to a nascent U.S. industry. The long-awaited move is a key piece of the Biden administration’s climate agenda. On Friday, the White House said it expects the DOE funding to help cut 25 million metric tons of carbon dioxide annually, roughly equivalent to removing 5.5 million gasoline-powered vehicles from the road each year. “With this historic investment, the Biden-Harris administration is laying the foundation for a new, American-led industry that will propel the global clean energy transition,” said Secretary of Energy Jennifer Granholm.

The New York placeholder for dispatchable emissions-free resources is “green” hydrogen. Menton explains that according to this further piece from Energy Wire on August 21, the Biden Administration has set a goal of having the U.S. produce 10 million metric tons of “green” hydrogen (by electrolysis from water) by 2030. The E&E piece states that the massive funding for “hydrogen hubs” is for “demonstrations.” He points out that this is not the demonstration project needed to prove viability of the net-zero transition because the demonstrations focus on production, storage, transport and consumption but not the integrated resource necessary. He notes:

They are clearly leaving out the critical piece of the puzzle, which is the demonstration of how much of this hydrogen, and capacity to make more of it, will be needed, and at what cost, to get the country — or even some small town — through a full year (or two or five) without need for fossil fuel backup. That completely obvious elephant is not part of this multi-billion dollar “demonstration.”

Another dispatchable emissions-free resource for New York’s net-zero transition could be long duration energy storage. Menton notes that the Department of Energy has a “separate big bucks effort called the “Long Duration Storage Shot” that is throwing bucketsful of cash at various research efforts into batteries.” Unfortunately, he notes:

The battery efforts are even farther removed from any relevant demonstration project. From DOE’s opening webpage describing that initiative (with a date of September 2021):

The U.S. Department of Energy’s (DOE) Energy Earthshots Initiative aims to accelerate breakthroughs of more abundant, affordable, and reliable clean energy solutions within the decade. Achieving the Energy Earthshots will help America tackle the toughest remaining barriers to addressing the climate crisis, and more quickly reach the Biden-Harris Administration’s goal of net-zero carbon emissions by 2050 while creating good-paying union jobs and growing the clean energy economy. . . . The Long Duration Storage Shot establishes a target to reduce the cost of grid-scale energy storage by 90% for systems that deliver 10+ hours of duration within the decade.

On September 22, 2023 the Administration announced some $325 million for “15 projects across 17 states and one tribal nation” to “accelerate the development” of these “long duration” battery technologies. He writes:

So are these battery technologies, or any one of them, even a potential solution to the problem of making a mostly wind/solar electricity grid work without fossil fuel backup? Again, you will not find any mention at those links, or at other government or advocate sites discussing the issue of how many of these batteries would be necessary and at what cost to actually fully back up a predominantly wind/solar grid and make it into a functional 24/7/365 electricity system.

I cannot over-emphasize how challenging these two technologies are. I fear that some aspects of some of these demonstrations will be deemed a success which will be used to argue that the concerns of organizations responsible for keeping the lights on and skeptical technical experts who have no vested interests in the green energy scam are unwarranted. Theory, small prototype tests, and these demonstration projects all will not prove the feasibility of a fully-functioning wind/solar/hydrogen storage 24/7/365 electricity grid.

Another aspect of this is that until we have a proof-of-concept demonstration that incorporates all the components needed to get to a reliable system, we cannot know how much it will cost. Menton argues that a rough cost estimate “would come to a multiple (not necessarily a huge one, but nonetheless a multiple) of what our current electricity system costs.” He does not bother to make an estimate writing:

The reason I’m not going to do it is that there as an obvious fact that tells you all you need to know, which is that no one in the country is spending their own private money to build out this system. They are all waiting for the government handouts. If this system could be built profitably at a cost competitive with what we have, there would be investors falling all over themselves to build it. When Thomas Edison built his first electricity plant, he did not go to the government for handouts to build it. Because this is all a fantasy kept alive by government handouts, as soon as the handouts go away or even slow down, the whole thing will dry up and fade away.

Conclusion

We do not know if the net-zero transition is technically possible. All we have is assurances from vested interests and slick marketing claims from the state. Richard Feynman said “For a successful technology, reality must take precedence over public relations, for Nature cannot be fooled.” Before New York goes any further, a comprehensive demonstration project for a smaller jurisdiction is the pragmatic approach.

Regional Greenhouse Gas Initiative Third Program Review

The Regional Greenhouse Gas Initiative (RGGI) is a carbon dioxide control program in the Northeastern United States. One aspect of the program is a program review that is a “comprehensive, periodic review of their CO2 budget trading programs, to consider successes, impacts, and design elements”. On September 26, 2023 the RGGI States hosted two webinars describing technical modeling & analyses that examined the electricity market, emissions, and economic impacts of potential changes to RGGI. This post describes the disconnect between the results of RGGI to date relative to the expectations in the RGGI Third Program Review modeling that I addressed in my comments to RGGI.

I have been involved in the RGGI program process since its inception. I blog about the details of the RGGI program because very few seem to want to provide any criticisms of the program. The opinions expressed in this post do not reflect the position of any of my previous employers or any other company I have been associated with, these comments are mine alone.

Background

RGGI is a market-based program to reduce greenhouse gas emissions. According to RGGI:

The Regional Greenhouse Gas Initiative (RGGI) is a cooperative effort among the states of Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Vermont, and Virginia to cap and reduce power sector CO₂ emissions.

RGGI is composed of individual CO₂ Budget Trading Programs in each participating state. Through independent regulations, based on the RGGI Model Rule, each state’s CO₂ Budget Trading Program limits emissions of CO₂ from electric power plants, issues CO₂ allowances and establishes participation in regional CO₂ allowance auctions.

More background information on cap-and-trade pollution control programs and RGGI is available from the Environmental Protection Agency and my RGGI posts page. Proponents of these programs consider them silver bullet solutions. However, I agree with Danny Cullenward and David Victor’s book Making Climate Policy Work that the politics of creating and maintaining market-based policies for Greenhouse Gas (GHG) emissions “render them ineffective nearly everywhere they have been applied”.

Third Program Review

The RGGI participating states hosted two public meetings on September 26, 2023, to discuss updates on the Third Program Review and electricity sector analysis. Meeting materials included the following: Meeting Agenda PDF; Presentation Slides PDF; Topics for Consideration PDF; Draft RGGI Emissions Dashboard ArcGIS Dashboard; RGGI Emissions Dashboard Draft User Guide PDF; Meeting Recording – Session 1, Meeting Recording – Session 2 and Draft IPM Matrix Case Results XLSX.

The RGGI States contracted ICF to analyze the different scenarios to inform the options for future RGGI. ICF has a proprietary model, the Integrated Planning Model (IPM^©), that has been used by the RGGI States since the inception of the program and which EPA uses to evaluate many of its control policies. According to ICF:

ICF’s Integrated Planning Model provides true integration of wholesale power, system reliability, environmental constraints, fuel choice, transmission, capacity expansion, and all key operational elements of generators on the power grid in a linear optimization framework. The model captures a detailed representation of every electric boiler and generator in the power market being modeled.

In March the RGGI States explained that they planned to use IPM to evaluate several issues. One problem is “fluidity of state participation”. Nine states have been members of RGGI since its inception. New Jersey was a charter member, got out, and now is back in; Virginia was in but is now getting out; and Pennsylvania is trying to get in but participation has been stalled by litigation. RGGI planning must address climate and complementary energy policies that will dramatically impact electricity load such as electric vehicles and EV infrastructure, electrification in the building sector, and aggressive energy efficiency efforts. A major concern of the program review was allowance availability so the decarbonization timeline for the electricity sector was considered. This is complicated because participating State timelines vary, implementation of offshore wind deployment affects decarbonization rates and grid-scale battery storage deployment, duration, and supply certainties affect the outcomes.

The September 26 webinar described three key observations from the modeling results:

Modeling shows how current state decarbonization and renewable requirements can significantly reduce emissions;
Federal incentives for clean energy have the potential to rapidly transform the RGGI region generation mix; and
Scenarios modeled to date show relatively low allowance prices compared to the ECR/CCR price triggers in the Model Rule

The RGGI States have not proposed their plans for the Third Program Review. The modeling observations support the idea that the RGGI allowance availability can be made more stringent. So much so that the modeling plans changed from the spring to add a more stringent trajectory to reach zero emissions by 2035 rather than just looking at a zero emissions by 2040 trajetory. My comments addressed these key observations .

I will summarize my concerns below but first it is necessary to review RGGI results to date.

RGGI Results to Date

There is an unfortunate disconnect between the results of RGGI to date relative to the expectations in the Third Program Review. During the September 26 meeting the explanation of cap-and-trade systems stated that “States reinvestthe proceeds in decarbonization and other programs to deliver benefits to their communities.” What was missing was any mention of the efficacy of those investments relative to the emission reductions observed.

The primary cause of the observed RGGI emission reductions has been the fuel switch from coal and residual oil to natural gas. Table 1 lists the emissions by fuel types for the nine RGGI states that have been members since the start. I believe that RGGI had very little to do with these fuel switches because fuel costs are the biggest driver for operational costs and natural gas was cheaper. The cost adder of the RGGI carbon price to date has been too small to drive the conversions from coal and oil to natural gas.

Table 1: RGGI Program Unit CO2 Emissions (tons) by State and Year

RGGI sources within the nine-state region have already implemented most of the coal and residual oil fuel switching opportunities available so this control strategy will be less impactful in the future. For example, in New York coal-fired electric generation has been banned and the remaining units that burn residual oil primarily run to only provide critical reliability support so their emissions are not expected to change much from current levels. In the future, RGGI affected source emission reductions will rely on the displacement of natural gas fired units with wind and solar zero emitting sources.

The 2021 investment proceeds report released on June 27, 2023 provides insight into the success of RGGI investments as an emission reduction tool. The report breaks down the investments into five major categories:

Energy efficiency makes up 51% of 2021 RGGI investments and 55% of cumulative investments. Programs funded by these investments in 2021 are expected to return about $418 million in lifetime energy bill savings to more than 34,000 participating households and over 570 businesses in the region and avoid the release of 2.3 million short tons of CO2.

Clean and renewable energy makes up 4% of 2021 RGGI investments and 13% of cumulative investments. RGGI investments in these technologies in 2021 are expected to return over $600 million in lifetime energy bill savings and avoid the release of more than 1.7 million short tons of CO2.

Beneficial electrification makes up 13% of 2021 RGGI investments and 3% of cumulative investments. RGGI investments in beneficial electrification in 2021 are expected to avoid the release of 370,000 short tons of CO2 and return nearly $164 million in lifetime savings.

Greenhouse gas abatement and climate change adaptation makes up 11% of 2021 RGGI investments and 8% of cumulative investments. RGGI investments in greenhouse gas (GHG) abatement and climate change adaptation (CCA) in 2021 are expected to avoid the release of more than 10,000 short tons of CO2 and to return over $20 million in lifetime savings.

Direct bill assistance makes up 14% of 2021 RGGI investments and 13% of cumulative investments. Direct bill assistance programs funded through RGGI in 2021 have returned over $29 million in credits or assistance to consumers.

There is an important caveat to the emission reductions reported in the report. The RGGI compliance metric is annual emissions and the above quote lists the lifetime emission reductions. The sum of the lifetime emission reductions from the 2021 investments is 4.38 million tons but the annual emission reductions due to RGGI investments were only 235,299 tons (Figure 1). The 9-state allowance allocation annual reduction in 2021 was 2,275,000 allowances so RGGI was only responsible for around 10% of the emission reductions required.

Figure 1: Table 1 from the 2021 investment proceeds report

The results in 2021 are consistent with historical observations. To make a comparison to the CO2 reduction goals I had to sum the annual values in the previous reports because RGGI does not report the annual RGGI investment CO2 reduction values accumulated since the beginning of the program. Table 2 lists the annual avoided CO2 emissions generated by the RGGI investments from previous reports. The accumulated total of the annual reductions from RGGI investments is 3,893,925 tons while the difference between the three-year baseline of 2006-2008 and 2021 emissions is 58,334,373 tons. The RGGI investments are only directly responsible for 6.7% of the total observed annual reductions over the baseline to 2021 timeframe!

Table 2: Accumulated Annual RGGI Benefits Through 2021

Dividing the total RGGI investments by the total tons reduced provides the cost per ton reduced. The cumulative RGGI investment cost effectiveness is $927 per ton reduced. That is far more than the Resources for the Future Social Cost of Carbon estimate of $185 per ton and indicates that costs exceed societal benefits.

Concerns with Results – Recommendations are highlighted in bold

There is a unique aspect of the Third Program Review modeling process that has not been available previously. There are two independent modeling projections of the New York electricity system resources necessary to meet a zero-emission target by 2040. The New York Independent System Operator (NYISO) has evaluated scenarios that project the resources necessary to achieve the New York Climate Leadership and Community Protection Act goal of a zero-emissions electricity generating system by 2040. New York’s Scoping Plan was guided by an Integration Analysis that modeled the transition. Comparison of those projections with the Integrated Planning Model (IPM) projections enables a check on how these requirements can reduce emissions using different methodologies.

The most glaring difference between the RGGI IPM modeling of New York and the New York analyses is the generation fossil-fuels sector (Table 3). The table subtracts the NYISO Resource Outlook Scenario 1 projected generation from the RGGI IPM modeling allowance supply scenarios for Assumption Set B and Integration Analysis Scenario 2. The percentage difference shows that the IPM projects substantially more generation than NYISO and the Integration Analysis.

Table 3: Fossil Resource Sector Difference in Generation (GWH) Between the NYISO Resource Outlook and the RGGI IPM and Scoping Plan Integration Analysis Strategic Use of Low-Carbon Fuels Scenario

Because RGGI affected source emissions are so strongly correlated with operations these higher operating rates mean that the RGGI IPM modeling projects lower fossil-fired emissions than either model. In Table 4 I estimated New York CO2 emissions by multiplying these projected generation differences times the 2022 calculated CO2 emission rate per MWh. In the NYISO Resource Outlook column the emissions are relative to those scenario differences. Similarly, the emission differences in the Integration Analysis are relative to the Scoping Plan projections. IPM underestimates the fossil sectors emissions significantly.

Table 4: Fossil Resource Sector Difference in Projected CO2 Emissions (tons) Between the RGGI IPM and NYISO Resource Outlook and Scoping Plan

The RGGI States chose not to include any allowance supply numbers so I was forced to make my own estimates to determine the significance of these emissions. I projected allowance availability using a linear interpolation between 2023 allowance allocations and zero by 2035 and 2040. For the zero by 2040 allowance supply scenario, the 2030 emissions difference represents 27% of my estimated allowance allocation. For the zero by 2035 allowance supply scenario, the 2030 emissions difference represents 42% of my estimated allowance allocation. This suggests that this modeling difference needs to be reconciled to determine its impact on the RGGI State allowance allocation trajectory proposal.

There is another issue associated with the modeling results. The ICF description of these modeling results notes that “due to the stringency of the program after 2040, the model shows an over-compliance of emissions in the early years (2025-2030) and banking of those allowances for when the cap is reduced in 2035 and beyond. “ This is an artifact of the perfect foresight methodology of IPM and, I believe, is unlikely to occur.

I think this is wrong because the modeling approach claims affected sources “over-comply”. RGGI sources do not “over-comply” but rather acquire allowances to meet their compliance obligations with a slight surplus to ensure compliance My primary concern is New York and in New York sources that could fuel switch to natural gas have already done so. They cannot directly affect their compliance except by limiting operations. Thus, RGGI sources in NY are at the point where they must rely on renewable energy to displace their need to operate. This means that they only purchase the allowances they expect to use for their compliance obligations plus a small compliance cushion.

Based on the modeling description, IPM “perfect foresight” projects results over longer planning horizons than used in practice. I believe that affected-sources across RGGI treat the allowance requirements as a short-term, no more than a couple of compliance periods, compliance obligation. It is highly unlikely that most affected sources are making plans beyond short-term compliance periods so the idea that affected source would over-comply in early years for more stringent limits ten years ahead is incorrect. The open question is how does this affect the allowance trajectories. It might also account for differences between the NYISO and Integration Analysis projections. The best way to reconcile this is in an open public forum with the modeling groups.

Renewable developments are struggling due to soaring interest rates and rising equipment and labor costs. Reuters describes two “procured” projects in the RGGI region that have been cancelled:

(AGR.N), a U.S. subsidiary of Spanish energy firm Iberdrola (IBE.MC), said it filed agreements with power companies in Connecticut to cancel power purchase agreements for Avangrid’s proposed Park City offshore wind project.

               “One year ago, Avangrid was the first offshore wind developer in the United States to make public the unprecedented economic headwinds facing the industry,” Avangrid said in a release.

               Those headwinds include “record inflation, supply chain disruptions, and sharp interest rate hikes, the aggregate impact of which rendered the Park City Wind project unfinanceable under its existing contracts,” Avangrid said.

                              Avangrid has said it planned to rebid the Park City project in future offshore wind solicitations.

               Also over the past week, utility regulators in Massachusetts approved a proposal by SouthCoast Wind, another offshore wind developer, to pay local power companies a total of around $60 million to terminate contracts to provide about 1,200 MW of power.

In New York, on October 12, 2023 the Public Service Commission turned down a request to address the same cost issues. Times Union writer Rick Karlin summarizes:

               At issue was a request in June by ACE NY, as well as Empire Offshore Wind LLC, Beacon Wind LLC, and Sunrise Wind LLC, which are putting up the offshore wind tower farms.

               All told, the request, which was in the form of a filing before the PSC, represented four offshore wind projects totaling 4.2 gigawatts of power, five land-based wind farms worth 7.5 gigawatts and 81 large solar arrays.

               All of these projects are underway but not completed. They have already been selected and are under contract with the New York State Energy Research and Development Authority, or NYSERDA, to help New York transition to a clean power grid, as called for in the Climate Leadership and Community Protection Act, approved by the state Legislature and signed into law in 2019.

Developer response to the PSC decision suggests that “a number of planned projects will now be canceled, and their developers will try to rebid for a higher price at a later date — which will lead to delays in ushering in an era of green energy in New York”. Karlin also quotes Fred Zalcman, director of the New York Offshore Wind Alliance: “Today’s PSC decision denying relief to the portfolio of contracted offshore wind projects puts these projects in serious jeopardy,”

These issues impact the proposed RGGI allowance trajectories based on the “potential to rapidly transform the RGGI region generation mix”. The IPM modeling projects significant emission reductions presuming that procured renewable energy projects will come on line consistent with the contracts at the time of the modeling. The two cancelled projects in New England total 2,000 MW and the threatened New York wind projects total 11,700 MW. Any projects delayed mean RGGI-affected source emissions will not be displaced as originally expected. If the allowance trajectory proposed does not account for this new information, then compliance will be threatened because affected sources have so few options available to reduce emissions. I recommended that a RGGI IPM modeling scenario be run to consider the effect of a delayed implementation schedule before finalizing Third Program Review recommendations. In fact, given the importance of renewable development on the emission trajectories it might even be appropriate to delay the timing of completion of this program review.

There is another consideration regarding feasibility. As noted above, the accumulated annual emission reductions due to RGGI investments is 3,893,925 tons and RGGI investments over the same time frame total $3,608,950,013 so the cost per ton avoided is $927. If the only source of future emission reductions were the result of RGGI investments, then RGGI allowance prices would have to equal $927 to get the necessary reductions. Of course, other investments will also reduce emissions but the RGGI States should consider cost considerations for the viability of renewable energy resources needed to get RGGI affected source emissions to zero. None of these models address this uncertainty.

The final observation noted at the September 26 webinar was that “Scenarios modeled to date show relatively low allowance prices compared to the ECR/CCR price triggers in the Model Rule”. Low allowance prices indicate that emissions are lower than the allowances auctioned so there is a surplus of allowances. My description of RGGI results to date noted that RGGI-affected sources have limited options to switch from coal and residual oil to natural gas. I expect that as the opportunities to switch fuels diminish that the allowance market will get tighter and allowance prices will go up. This could trigger the RGGI cost containment reserve. If allowance prices exceed predefined price levels, this RGGI feature will release additional allowances to the market. If the allowance trajectory is too aggressive and emissions do not decrease as expected because wind and solar do not come on line as planned or there is an abnormal weather year increasing load and decreasing wind and solar availability, then there could be a situation where there simply are not enough allowances available for compliance. The Cost Containment Reserve could prevent this from occurring. However, no scenarios with this feature have been modeled yet. I recommended that the RGGI States should model a scenario where the renewable implementation is delayed and the Cost Containment Reserve is employed.

Conclusion

I am afraid that the RGGI States are placing so much reliance on the IPM analysis results that they could propose unrealistic allowance reduction trajectories. It is naïve to treat any model projections of the future energy system without a good deal of skepticism because the electric grid is so complex and currently dependent upon dispatchable resources. Replacement of RGGI-affected sources with intermittent and diffuse wind and solar resources that cannot be dispatched is an enormous challenge with likely unintended consequences. Therefore, the results should be considered relative to historical observations.

I don’t see much indication that the RGGI States are considering the results of RGGI to date. I am leery of any model projections of this future system but I have much greater faith in projections by the NYISO because they are responsible for electric system reliability. I think there are significant differences between the NYISO projections and IPM. Until those differences are reconciled, I will be skeptical. Kevin Kilty summed up a rational approach to the use of model results that I fear the RGGI States will ignore: “Beware. Expect Surprises. Expensive Ones”.

Articles of Note October 15 2023

I have been following the Climate Leadership & Community Protection Act (Climate Act)

Climate Act since it was first proposed and most of the articles described are related to it. I have devoted a lot of time to the Climate Act 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 article 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.

lawsuit is filed in New York.

Climate Act Background

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

Videos of Note

For those of you who would rather watch a video than read about a topic I list a few interesting videos. This video describes historic global temperatures and how ancient temperatures are estimated. I think it does a good job describing a complicated subject.

This interview of Judith Curry by John Stossel is a good overview of the climate science hype.

Offshore Wind Costs

Renewable developments are struggling due to soaring interest rates and rising equipment and labor costs. Reuters describes two “procured” projects that have been cancelled:

On Monday, Avangrid (AGR.N), a U.S. subsidiary of Spanish energy firm Iberdrola (IBE.MC), said it filed agreements with power companies in Connecticut to cancel power purchase agreements for Avangrid’s proposed Park City offshore wind project.

“One year ago, Avangrid was the first offshore wind developer in the United States to make public the unprecedented economic headwinds facing the industry,” Avangrid said in a release.

Those headwinds include “record inflation, supply chain disruptions, and sharp interest rate hikes, the aggregate impact of which rendered the Park City Wind project unfinanceable under its existing contracts,” Avangrid said.

Avangrid has said it planned to rebid the Park City project in future offshore wind solicitations.

Also over the past week, utility regulators in Massachusetts approved a proposal by SouthCoast Wind, another offshore wind developer, to pay local power companies a total of around $60 million to terminate contracts to provide about 1,200 MW of power.

Rich Ellenbogen described how the Offshore Wind Market is broken all over the world in an email. First he mentioned this Avangrid project buyout of their contractual obligations. He also pointed out that at a recent UK wind auction, there were no bidders because the maximum selling price for the electricity was not high enough to justify the investment. Their installation costs have risen by about 40% and the UK government did not factor that in to the allowable costs. He explains:

The article states that the wholesale price of electricity in the UK is £80 /Megawatt hour (MWh). With an exchange rate of $1.23 per pound-sterling, that equates to $98.40 per MWh. The article also states that they would need £60 per MWh to make the wind farms profitable, or $73.80 per MWh. However, according to this link, “the wholesale price for electricity in NY State in calendar year 2023 has increased from $24.57/MWh to $42.97/MWh over the last year.”, 47% lower than the wholesale cost in the UK and 72% lower than what the wind installers say that they need to be profitable.

If the Wind installers can get $73.80/MWh installing wind farms in the UK but they can only get $42.97/MWh installing Wind farms here, 42% less, while also having no ships to do the installation because of the Jones Act, where do you think that they will install the wind farms? This is a global market.

The other way to look at this is that the energy from Offshore Wind will cost 72% more than what the ratepayers of NY State are currently paying. This is not a good economic model for the NY State rate payers. 72% increases are well outside of what surveys have said the public will tolerate. Coupled with 15% increase in delivery costs from the utilities, the number of ratepayers, currently 1.2 million ratepayers that are $1.8 billion in arrears, will greatly increase making NY State even less affordable than it already is.

In New York, on October 12, 2023 the Public Service Commission turned down a request to address the same cost issues. Times Union writer Rick Karlin summarizes:

At issue was a request in June by ACE NY, as well as Empire Offshore Wind LLC, Beacon Wind LLC, and Sunrise Wind LLC, which are putting up the offshore wind tower farms.

All told, the request, which was in the form of a filing before the PSC, represented four offshore wind projects totaling 4.2 gigawatts of power, five land-based wind farms worth 7.5 gigawatts and 81 large solar arrays.

All of these projects are underway but not completed. They have already been selected and are under contract with the New York State Energy Research and Development Authority, or NYSERDA, to help New York transition to a clean power grid, as called for in the Climate Leadership and Community Protection Act, approved by the state Legislature and signed into law in 2019.

Developer response suggests that “a number of planned projects will now be canceled, and their developers will try to rebid for a higher price at a later date — which will lead to delays in ushering in an era of green energy in New York”. Karlin also quotes Fred Zalcman, director of the New York Offshore Wind Alliance: “Today’s PSC decision denying relief to the portfolio of contracted offshore wind projects puts these projects in serious jeopardy,”

Francis Menton did an overview of the status of offshore wind projects that summarizes all the issues confronting offshore wind development.

Renewable Costs

Francis Menton also did an overview of renewable costs.

Another article in the Telegraph also addresses green energy costs.

Weather and Climate

The September edition of Climate Fact Check debunks ten bogus climate claims from last month. There is a description of the analysis here.

Electric Vehicles

Electric van maker on verge of bankruptcy

EV owners facing soaring insurance costs

The Solution to Extreme Weather Issues is not to Reduce GHG Emissions

As a meteorologist I find it frustrating that every extreme weather event is considered a reflection of “a “new normal” due to the effects of climate change”. As a pragmatic environmentalist, it is even more frustrating when a report comes out criticizing New York’s infrastructure resiliency to minimize the effects of extreme weather but fails to pick up the tradeoffs between resiliency infrastructure investments versus reducing greenhouse gas emissions that will supposedly prevent extreme weather. This article describes an example of this dynamic: the New York City Metropolitan Transit Authority (MTA) extreme weather resiliency plan.

I have followed the Climate Leadership & Community Protection Act (Climate Act) since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 350 articles about New York’s net-zero transition. I have devoted a lot of time to the Climate Act 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 by increasing costs unacceptably, threatening electric system reliability, and causing significant unintended environmental impacts. The opinions expressed in this post do not reflect the position of the New York State Reliability Council, the Extreme Weather Working Group, any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Climate Act Background

New York City Flooding

On September 29, 2023, CNN reported that “Record rain in New York City generates ‘life-threatening’ flooding, overwhelms streets and subways”. Fox News said New York received record rain:

“Friday’s deluge dropped 8.05 inches of rain at JFK Airport, making it the wettest day on record, beating Hurricane Irene’s daily record set back on Aug. 14, 2011, the National Weather Service said. Widespread rain totals of 4 to 6 inches were New York City, Long Island and Hudson Valley, with locally higher amounts in excess of 7 inches of rain.

Tony Heller does a great job documenting historical accounts of extreme weather events. He found that on October 8, 1903 New York received 10.04 inches of rain.

Ryan Maue checked out the Central Park precipitation data and found that on September 23, 1882 the site measured the highest daily value of 8.28” and that this recent event was the 9^th wettest day at that site.

Nonetheless, it did not prevent the usual suspects, including Governor Hochul from blaming climate change: “This is unfortunately what we have to expect as the new normal”. She also described the storm as “Mother Nature at her most powerful.” “This was the kind of rain that was once unimaginable — we called them once-in-a- century storms,” Hochul said Saturday. “But this is the third time since I was sworn in two years ago, I’ve had a once-in-a-century storm.”

Of course, this storm will also be used as more justification by the same crowd to implement the Climate Act. Because it is generally accepted that climate change caused by GHG emissions did not kick in until after 1950, the higher historical precipitation in 1882 and 1903 conclusively falsify the Governor’s “new normal” and the idea that GHG emission reductions can prevent further similar storms.

MTA Climate Resilience Upgrades

Flooding caused major disruptions to New York’s subway system, according to the Metropolitan Transportation Agency. The flash flood caused “full or partial suspension of service on half the lines in the system, with MTA officials saying full service was restored by 8:30 p.m after 20 million gallons of water were pumped out of the subway”. On a personal note, the subway closures forced my grand-daughter to stay with a classmate in Manhattan rather than going home to Brooklyn that day.

A couple of days earlier, the MTA published a 20-year needs assessment report that said “Some 400 miles of subway tracks, half of Metro-North’s Hudson Line and several Long Island Rail Road stations are in dire need of upgrades to stave off flooding and other extreme weather exacerbated by climate change.” The Resilience Improvement weblink states:

Climate change is here—and we must prepare. Over the next two decades, climate change projections indicate that the New York region will experience more frequent and intense coastal storms, more than twice the current number of torrential rainfall events, and triple the current number of extreme heat days over 90 degrees. Meanwhile, sea levels will rise approximately 2.5 feet by the 2050s and almost 5 feet by the 2080s.

Our infrastructure was not built to withstand future climate conditions. We’ve made significant progress retrofitting, renovating, and rebuilding infrastructure in anticipation of future climate conditions, but climate change won’t wait for us to finish. For our systems to keep running as lifelines through the coming climate-induced crises, we must move faster.

On the same day of the storm, the State Comptroller’s office released “Risk Assessment and Implementation of Measures to Address Extreme Weather Conditions”. The objective of this audit was:

To determine whether the Metropolitan Transportation Authority (MTA) – New York City Transit (Transit) identified potential damage to its system and developed plans to mitigate the effect of extreme weather conditions and flooding. We also determined whether the MTA tested/updated the plans and inspected and maintained the equipment to ensure they can be deployed when needed. Our audit covered the period from April 2009 to August 2022.

The key findings of the report include the following:

To date, the MTA has not implemented one of the most important recommendations of the 2009 Report – the development of the climate change adaptation master plan. Since Superstorm Sandy, Transit has assessed and identified areas of its system that are at risk of flooding from extreme weather events and developed and carried out capital projects to both correct damage caused by Superstorm Sandy and mitigate potential flooding conditions in the Transit system. Further:

Our review of a sample of 23 of 221 capital projects intended to correct or prevent damage found that projects were often incomplete in scope of work, not finished on time or within budget, or insufficiently documented. Just two of six critical stations that Transit indicated should have been made more watertight and resistant to potential flooding were completed in one project we reviewed. Another project was initiated to prevent flood water from entering 14 fan plants; however, only 11 fan plants were mitigated. Transit officials stated the three remaining fan plants were completed but did not provide documentation to support their statements. (Fan plants are facilities with large vent gratings and fans located atop shafts connected to the Transit tunnels.)

Transit did not sufficiently document inspections of individual pieces of equipment. Instead, it reported more broadly by subway stations or by rooms in off-site facilities that were inspected. In one instance, because not all rooms were inspected at a facility, we were able to determine that 51 of 72 pieces of equipment in our sample were not inspected between January 2021 and August 2022.

While Transit has developed winter, hurricane, rain, and extreme heat plans, we found that these plans were inconsistently activated, with no documentation explaining the rationale for decision making. In our sample of 18 weather events, plans were not activated for six events that included tropical storms, hurricanes, or coastal flooding.

I support the concept to identify and address potential flooding conditions. My problem with this report is that it does not recognize the differences between weather and climate, namely weather is going to cause flooding conditions whether or not climate change exacerbates the impacts. It seems that climate change must be included as part of the marketing to get support for the audit.

Discussion

Response to the 20-year plan included the concern by advocates that no costs were attached to the plans for the improvements that MTA says is necessary. For example:

“While the MTA’s needs assessment is thorough and shows that our transit system is in dire need of investment, it lacks dollar figures showing exactly how much money will be needed to fix the subways, buses, and commuter railroads,” wrote Rachael Fauss with the good government group Reinvent Albany in an email. “The needs of everyday riders must come first. In an environment of limited resources, it is essential that we prioritize capital projects based on objective measures of need, not politics, to repair the subways, buses and commuter railroads and ensure that they continue to best serve New Yorkers in this era of climate change.”

I think it is important to consider whether the net-zero transition GHG emission reduction measures in New York State will have any material effect on the extreme weather events that caused the problems observed during the latest flash flood. The answer to that question is no. As noted previously, the fact that there were days with greater rainfall before GHG emissions allegedly became the driver of observed global warming suggests that GHG emissions reductions would have to go to pre-industrial levels to just keep rainfall rates at the same level as 1882. That is clearly an ambitious target even if you believe that GHG concentrations are a driver of extreme weather and I don’t believe that. It gets worse. New York GHG emissions are less than one half of one percent of global emissions and global emissions have been increasing on average by more than one half of one percent per year since 1990. Even if GHG emissions in New York were to get to zero, that reduction will be supplanted by increases elsewhere in less than a year.

Conclusion

One of my pragmatic principles is Russel Schussler’s observation that “We can do almost anything we want, but we can’t do everything”. In this instance the costs of the Climate Act’s net-zero transition should be considered relative to the MTA plan. The upgrades necessary to prevent extreme rainfall events and storm surge from flooding New York’s subway system will be enormous but at the end of the day those investments would have a measurable effect. In order to get to net-zero, the costs will be an order of magnitude greater than “enormous” with no hope for a measurable effect on severe weather. I agree with Rachel Fauss: “it is essential that we prioritize capital projects based on objective measures of need, not politics”.

The disconnect between MTA, the media, and even Fauss in this example is frustrating. For example, Rachael Fauss noted that the investments are necessary “in this era of climate change” misses the point that climate is what you expect and weather is what you get. Climate change had very little effect on this event and certainly not enough to cause the storm or materially change its impacts. Ultimately, throwing away money on a pointless virtue-signaling net-zero transition will likely forestall the investments needed to maintain and strengthen the resiliency of the subway system. Reducing New York GHG emissions in a quest to minimize extreme weather issues in New York is not going to work and will be counter-productive for real solutions.

Offshore Wind Lulls and Energy Storage Conundrum

A recent article by Ed Reid prompted me to put together this post. Reid compared different Offshore Wind (OSW) developer estimates of the capacity factor of a couple of projects and found inconsistencies. This article compares his results with Climate Leadership & Community Protection Act (Climate Act) OSW projections. I also address energy storage implications associated with OSW.

I have followed the Climate Act since it was first proposed, submitted comments on the Climate Act implementation plan, and have written over 350 articles about New York’s net-zero transition. I have devoted a lot of time to the Climate Act 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 by increasing costs unacceptably, threatening electric system reliability, and causing significant unintended environmental impacts. The opinions expressed in this post do not reflect the position of the New York State Reliability Council, the Extreme Weather Working Group, any of my previous employers or any other organization I have been associated with, these comments are mine alone.

Climate Act Background

Off Shore Wind (OSW) is supposed to be a major renewable resource in the “zero-emissions” electric energy system. The Climate Act mandates 9,000 MW of Off Shore Wind (OSW) generating capacity by 2035. The Integration Analysis modeling used to develop the Scoping Plan projects OSW capacity at 6,200 MW by 2030, 9,096 MW by 2035 and reaches 14,364 MW in 2040. On the other hand, the New York Independent System Operator 2021-2040 System & Resource Outlook expects 5,036 MW in 2030 and 9,000 MW in 2035 with no additional development after that. By 2030 the Integration Analysis predicts that 14% of the electric energy (GWh) produced will come from OSW and the Resource Outlook predicts nearly as much (12%). This is an extraordinary build-out for a resource that is currently non-existent.

Capacity Factors

The capacity factor is a useful metric to understand and compare electric generation resources. The annual capacity factor equals the actual observed generation (MWh) divided by maximum possible generation (capacity (MW) times 8,760 hours. At sea the wind resource higher capacity factors are higher than onshore wind resources, primarily because there are no hills and vegetation to slow down wind. Supporters of OSW tout the higher capacity factors of this resource as a big benefit.

Ed Reid writing at The Right Insight describes issues with Offshore Wind (OSW) data used for claiming benefits. Reid described developer claims for two projects:

Orsted’s recently approved Ocean Wind 1 development, to be located off the New Jersey coast near Atlantic City and Ocean City, would consist of one hundred 11MW wind turbine generators, for a total capacity of 1,100 MW. This would suggest annual generation, at a 100% capacity factor, of 9,600 GWh. The International Energy Agency uses a capacity factor of 50% for offshore wind. We will use that figure here, since there is no offshore wind capacity factor data for the US East Coast. This suggests annual production of approximately 4,800 GWh for Ocean Wind 1.

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Dominion Energy’s proposed Coastal Virginia Offshore Wind (CVOW) development, to be located off the Virginia coast near Norfolk, would consist of one hundred seventy-six 15 MW wind turbine generators, for a total capacity of 2,600 MW. This would suggest annual generation, at a 100% capacity factor, of approximately 22,800 GWh, or approximately 11,400 GWh at a 50% capacity factor.

The US Energy Information Administration reports average US residential electricity consumption as 10,600 kWh per year. The developers describe the output of their projects in terms of the number of homes served. Reid estimates capacity factors for both projects using that information. Orsted projects that Ocean Wind 1 would serve 500,000 homes. Based on these numbers, Ocean wind would have to generate 5300 GWh per year, or a capacity factor of approximately 55%. Dominion projects that CVOW would serve 660,000 homes. Using the same approach, the annual capacity factor of the Dominium CVOW would be 30%. Thar is far lower than the IEA figure.

I compared the New York Independent System Operator (NYISO) 2021-2040 System & Resource Outlook modeling analysis with the Integration Analysis modeling and determined the capacity factors used. The following table lists the capacity factors for different generating resources including offshore wind. There is no question that OSW resources have higher capacity factors than onshore wind or solar. The NYISO annual projections are around 45% while the Integration Analysis projects slightly higher estimates no greater than 48% These estimates are closer to the International Energy Agency capacity factor of 50% than either Ocean 1 or CVOW. Note that the renewable resources capacity factors represent the best they can do but that the fossil capacity factor is low because, in part, they are displaced by wind and solar.

Estimates and Averages

Reid describes average estimates used for the OSW developer claims:

The estimates above are based on a number of averages: average wind resource; average capacity factor; average maintenance and repair allowances; and, average residential electricity consumption. The available wind resource varies on time scales from minutes to hours to days to seasons, as does residential energy consumption and demand. The use of averages loses a lot of the detail of the match between customer load and generator output.

He explains that intermittent generation from wind turbines shifts the resources used in the grid:

Since each of these industrial wind installations would be connected to a grid with a far larger customer base than the claimed number of residential customers served, above average output would be absorbed by other loads on the grids, displacing a portion of the output from some form(s) of conventional generation. Below average generator output would require support from some form(s) of conventional generation.

In my opinion, the intermittency of wind and solar projects should be addressed by the developer. As it stands now somebody else must provide supporting conventional generation or energy storage so wind and solar get a free ride. Reid explains the problem:

Arguably, fluctuations in generator output and customer load could also be compensated for by additions to and withdrawals from some type of energy storage capacity. However, there is no energy storage capacity included in either of the wind projects discussed above. The issue of storage can be deferred as long as there is sufficient excess conventional generating capacity available to compensate for the fluctuation of the output of the wind facilities and maintain a capacity reserve margin. However, as conventional generating capacity is retired due to age or regulation, and additional intermittent renewable generating capacity is added, addressing the issue of storage cannot be avoided.

Extremes

All issues related to the net-zero transition are more complicated than expected at first glance. In order to address this complexity, more explanation and analysis are required. For example, in this instance Reid wrote a short article addressing average fluctuating wind resources. He did not call out the extreme case when the wind resource is essentially zero for extended periods probably because it would have made the story too long. However, I think this is a critical consideration. Since the beginning of the Climate Act implementation process, lulls of renewable energy production, what I call the ultimate problem, has been a concern.

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

Since the time of this presentation, the New York State Independent System Operator (NYISO), New York State Reliability Council, and Public Service Commission in the Order Initiating Process Regarding Zero Emissions Target in Case 15-E-0302 all have been considering the ramifications of this problem. The New York State Reliability Council Extreme Weather Working Group (EWWG) was established to “identify actions to preserve New York Control Area reliability for extreme weather events and other extreme

system conditions” and create a corresponding action plan to “evaluate the potential need for

new resource adequacy and transmission planning design rules for planning the system to meet

extreme weather and other extreme conditions.” Wind lulls are one of the extreme weather events being considered by the EWWG.

The EWWG looked at the observed correlation of the frequency and duration of low-wind episodes across the entire state, including the offshore wind development areas. This summer they finalized a report titled Off Shore Wind Data Review – NYSRC Preliminary Findings (“OSW Report”) that is relevant to this discussion. The OSW Report analysis was based on an NYISO analysis that made available 21 years of hourly wind data at seven wind development sites (Figure 1), extending from New Jersey to Rhode Island, prepared by its consultant DNV. DNV performed analysis of wind data translating meteorological data into detailed power profiles for each site including loss considerations. The report describes frequency analysis and interregional impacts.

Figure 1: Seven Wind Development Sites Analyzed

The OSW Report wind lull analysis is relevant to this discussion. The analysis defined wind lulls as periods of each hour of wind output of less than 5%-20%. For extended periods of 24 hours or longer, lulls occur about 30 times per year on average. Wind lulls of 48 hours or longer occur on average about seven times per year, and wind lulls of 72 hours or longer occur on average two times per year. About 70% of these wind lulls over the 21-year period occurred during the current peak load four-month summer period from June to September.

Of note, is the following finding:

Lastly an analysis was performed to identify the most persistent wind lull experienced in the 20-year wind data with net capacity factor less than 10% for the entire period across all seven wind sites. Analysis indicates wind lulls of up to 86 hours with an average energy output of approximately 5% net capacity factor occurring across all seven sites were observed in the DNV dataset (this compares to an average annual net capacity factor of approximately 45%). While data associated with longer periods than 21 years were not readily available it may be appropriate to characterize this as a 1 in 20 year extreme weather event.

Reid explained that compensating load can be provided by adjoining transmission operators. This report addresses this concern relative to the OSW resource:

NY relies on emergency assistance from neighboring regions to achieve reliable system design, thus continued availability of surplus power from these areas is an important consideration. Similar to NY, policy makers from PJM and New England are also moving forward with policies to install large scale wind power to address decarbonization and planned shutdown of thermal units, with proposals in each region also totaling tens of thousands of MW. As noted in Section 3.0, OSW off the coast of the state of New Jersey is targeted at 7.5 GW by 2035 increasing to 11.0 GW by 2040, and similarly OSW off the coast of Rhode Island/ Massachusetts is targeted at 8.0 GW by 2035. In total PJM member States have announced off shore wind targets totaling 24 GW by 2035, and 32.7 GW by 2040.

The OSW Report compares the output from all seven wind sites during an interregional wind lull event which occurred August 8, 2017 – August 13, 2017. Over that time period the following graph shows that the fraction of wind output from all the sites clearly correlates. The implication is that compensating load will not be available from adjoining transmission operator’s OSW resources in periods like this.

The OSW Report concludes:

It is noted reliability of the traditional interconnected power system design relies on diversity of forced outage rates and independence of outage events. Correlation of interregional wind lulls eliminates diversity of loss of power output events associated with OSW and alters this aspect of system design.

Interregional wind lulls simultaneously impacting tens of thousands of MWs of interregional OSW located in PJM, NY and NE could reduce reserve sharing and emergency assistance available for support from neighboring control areas significantly impacting operational reliability and resource adequacy.

The most important point of this article is that the OSW Report documents correlation of interregional wind lulls. I believe this problem extends to onshore and wind and solar resources. I have looked at enough New York onshore wind data to be certain that this correlation extends to all the onshore wind resources in New York and adjoining regions. When it comes to solar, cloudiness affecting New York State solar may not be as highly correlated with wind but at night every single solar facility will not be producing any power.

One of the challenges faced by the EWWG is trying to determine the worst-case renewable resource lull. NYISO has had DNV do a similar analysis for onshore wind and solar resources in New York using the same 21-year data set. Metrological experts on the EWWG have suggested using as long an input meteorological dataset as possible for an analysis to obtain a fuller understanding of range and return period of events.

Finally, there is one more complication. The meteorological conditions that lead to the lowest wind resource availability are associated with the coldest and hottest periods of the year. Those periods cause the peak annual loads. Wind and solar may provide power most of the time but when electricity is needed the most, they are expected to provide their lowest output. I think this is an enormous challenge to the proposed “zero-emissions” electric grid that can only be addressed by using nuclear power.

Energy Storage Implications

To always provide reliable electricity, energy storage is needed to cover periods when solar and wind are not available. Obviously, energy storage is needed to cover the daily variation of solar. Energy storage duration is not a large issue for this requirement. On the other hand, there is a seasonal variation of solar irradiance and resulting power output that needs a long-duration storage solution. There are no commercially available long-duration storage systems that can be expanded to meet New York’s requirements. There are also seasonal variations in wind resource availability that require a long duration system. The biggest problem is the worst-case renewable resource lull. The EWWG analysis found a one in twenty-year resource deficiency which is something that no long-duration storage system could ever effectively address.

There are serious energy storage technological hurdles that have not been resolved. Francis Menton writing at the Manhattan Contrarian summarizes energy storage problems in a recent post on a new British Royal Society report “Large-scale energy storage.” Menton explains (my emphasis added):

Having now put some time into studying this Report, I would characterize it as semi-competent. That is an enormous improvement over every other effort on this subject that I have seen from green energy advocates. But despite their promising start, the authors come nowhere near a sufficient showing that wind plus solar plus storage can make a viable and cost-effective electricity system. In the end, their quasi-religious commitment to a fossil-fuel-free future leads them to minimize and divert attention away from critical cost and feasibility issues. As a result, the Report, despite containing much valuable information, is actually useless for any public policy purpose.

As noted previously wind and solar resources will be at their lowest expected availability during periods when the electric load peaks. When heating and transportation is electrified this problem is exacerbated, peak loads will occur in the winter when solar resources are inherently low. The Scoping Plan glossed over this challenge and nothing since directly addresses the challenge. The rational thing to do would be to develop demonstration projects to prove feasibility and cost of the new technology needed before dismantling the current system. Francis Menton explains why this is necessary and how it could work.

Conclusion

Ed Reid explains how OSW developers describe the output of their projects in terms of the number of homes served. He found issues with their calculations. The developers ignore the support needed to provide electricity to the homes served when the wind isn’t blowing.

Supporters of OSW tout the higher capacity factors of this resource as a big benefit. Ed Reid describes deficiencies in their arguments using average data. This article explains that the problem becomes more acute when shorter-term extended renewable resource lulls are considered. OSW will perform better than other renewable resources during periods when the energy is not critically needed. The conundrum is that when it is needed most, OSW will fail at the same time New York’s onshore wind resources fail so an as yet commercially unavailable energy storage technology is needed. All indications are that this problem extends into the adjoining control areas so they cannot be counted on. Addressing this issue is a critical reliability consideration. If not addressed correctly then the grid will fail when needed most and people will freeze to death in the dark.